United States
lawn-of^
Agency
Office of
fmergeney «"«!
Remedial Response
EPA-ROD.R03-85.015
September 1985
vvEPA
Superfund
Record of Decision;
Sand, Gravel & Stone, MD
-------
1. REPORT NO.
EPA/ROD/R03-B5j015
4. T/T.L.E AND SUBTfTU
TEC+1NICAL REPORT DATA
(Please retJd Ins/ructions on the rerene before completing)
3. RECIPIENT'S ACCESSION NO.
r
Sul>Ltti' urID RECORD OF DECISION
Sand, Gravel and Stone, MD
5. REPORT DATE ..
September 30, 1985
6.4>ERFDRMING ORGANIZATION CODE
-
-
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. f>£RFORMANG ORGAAUZA TIDN NAME AND AD~£.SS
10..PROGRAM EJ..EMENT NO.
1,. CONTRACT IGRANT NO.
')
12: Sf'ONSORING AGENCY NAME AND -ADDRESS
,
U.S. Environmental protertion Agency
.40l'M Street,'S.W.
WashiDgton, '.D.C. 2046'0
13. TYPE OF REPORT AND PERIOD CDVERED
Tinal ROD Report
,.. 5f>DNSORINGAG.ENG.Y.~OE
BOO/DO
15.. SUPf'.LEM£NTARY NDT£S
~
16. ABSTRACT
.' ~:.:.The Sand, Gravel.a.nd Stone site consists of approximately .200 acres,,,and is
located .in 1::1ktOn, Cecil. County, .Maryland. The site was previqusJ,y operated as~a
. sand and gravel quarry under the name MaIyJ.andSanC!. and Graved stone Company. CU%-
rently, the site is. Dccupieii .by 1:h€. Sand, Gravel,.. and,Bmne.: Company. ~twas reported
that about 'three acres onsitewere used for the disposal of -waste processing water,
sludge, stiJ.J. bottams,.and about 90 drums. oIsolid :and.semisolid w~te..betweeJ).-196~
and~974. On July .16,' .1974, 1,300 gallons of fla1DII1able 'products':in drums were
reportedly .received and dJ,miped. On AUgllst' 5,1974,' '5, 000 gallons' ofnonfla!:1mable
materials were received at the site. Pits.. excavated onsite, . were 'used as surface
i1npoundrn€mts. where approxi:mately .700,000 gallons of wa-ste were dumped.
I\e1nedial 18easures at the site will be i1nplemented in two phases., Selected remedial
actions appro~d at this. time. include: excavation. andoffsiIe disposal of . buried
!Ilaterials (drumsuand/or tr:ucks) at an approved RCRA fac::i~ity; inStallation. of: shallow
ground water interceptOrs downgradient from the waste sources.; collection and treat-
ment of contaminated ground water; recirculatiJ)g the treated effluent to the ponds
and shallow' aquifer or..mscbarging tILMiJ.J. Creek.'. Total capital cort£or the selected
remedial alternative is- estiInated -to be~7,.o95~000 .with O&M costs approxim:ate1y
.$753,000 'peryear. The .decisioILOIl .the 7remedial';'1Ile:asures £or:the contaminated :soils,
(see separate sheet)
.DESCRIPTORS
fCEV WORDS AND DOCUMENT ANAL,v51S
b.IDENTIF IU~S/DPEN :ENDED TERMS
- --.
17.
a.
c. COSATI Field.Graur
.-
Record of Decision
SaIid,Gravei and StoJ)e.. MD
ContamiJ)ateii Media: gw, soil.. sw, sediment
Key contaminants:taluene ,methylene chlor: de
acemne..x:hlaro:form,'VOCs"xyJ..ene ,
ethy1benzene, arsenic, cadmimIi~'--chromium
. phenols, heavy-metal s
18. DISTR/BUTJONST.o.T£M.E1IIT
. .
..
--
. -
~-~_..,~ .-
19. SECURITY Cl.ASS (This R.:poni
. None
20. SE C UR I T Y CJ.ASS fT/,;s page I
None #
21. NO. OF PAGES
49
22:PRICE
--- ..
. .
. ". ~;-' .
..
£PA .-222O-J ~."."-"I
PREVIOUS EOtTION I~ OBSO.L.£.T.£
-------
INSTRUCTIONS
1.
REPORT NUMBER
Insert Ihc [FA report number as it appears on the cOYer of thc vubti&:;ation.
LEAVE 8J..ANK
2.
3.
RECIPIENTS ACCESS10N NUMBER
Reserved for use by e.u:h report lu"ipient.
~
&.
TITLE AND SUBTITLE
,Title should indicate dearly and bricfly thc subject cov.:rOl~c of th':.fI~port. OInd 110: disptJynJ plulIlIlI..nl1)'. S,'I ,uhlilk. ifu"..t.1I1 'lU~h"I
type or otherwUe subordinate it to main title. WhC1l.. report is prc~red in morC' than "111.' V.IIUUl':, f\'p:'at th,' prilll;lry till.'. .Hld \",1:1111"
Dumber and include subtitle for the specific title.
"EPORT DATE. .
Each report shaD carry a date indicatina at leaJit moruh and year. Indi.;;!tc the l'
-------
SUPERFUND RECORD OF DECISION
Sand, GraVel and Stone, Maryland
Abstract -. continued
the lower un.t::ai1solidated sand and bedrock aqui.fers, "fiDal site closure" requirements
and post closure operations and :ma.inteIlance activities has been deferred until the
Phase" II RI/F.5 is completed.
.~
-------
. RECORD OF DECISION
-- .~1AL AlTERNATIVE SELECTION
. S1~e: . !faryl.and~ Sand Gravel a1Ui SU)ne; .ElJtton.£ecll County~ Mary~aud.
Data Reviewed:
1J'he follow11Jg dQcumems descrl.bing "the analysis of t:ost-effettiveness
and feasibility of remedial alternatives for the _Sand~ Gravel and Stone Site.
I have been briefed by my staff on.their cotU:ent.s~.and :.they fODD the
-principal basis for my Jfedsion.
- .1lemPd'!al '111vestigation am1 'Feasib11i-:y Study onfFS) Report Sand,
Gravel BUd . Stone. ti%:e. .EIJtton. CerH COU!tty~&ry.1and(~uly .1985).
- Bemedial Act:ion Haster Plan and 1temedial I"mI'estip~n/FeaB1bili:ty Study
Wo-rk Plan~ Sand, Gravel aud Stone Site, Elkton, Cec..i1 CDU11ty, Haryland
(Deceube-r 1985).
- Staff Bummar:ies.and 'recommendations
. .
.~ bcommencbl%:ions ~ ~he HaTyland Department of Health -and Mentalllygiene
DescTi~tion -of Selected Remedy:
The remedial.-ueasures tdl.l be conducted..iu ""two phases 'attbis 'site.
"The Te1edial :easures approv~ at this time include excavation of
bu-ried ~aterials (drums and/or trucks) and offsite disposal of hazardous
materials at au approved RCRAfacility.. l'nstallation. of shallow ground
water il1terc~tors .dovngradient. f-romthe waste sources' to collect .the
contaminated ground wate-r and leachate for treat:ment at an onsite
treatment plant before recirculating to the ponds and shallow aquifeT or
discharging' to tUll. Creek. The a))1)roved 1Dea&uresarebssed on the Phase 1
Remedial Imn!stigat:iDn and ~1'J!lLSihility:Study . (RI/FS).
I have Jiefer-red a decision:1)11 the remedial' measures for%he
contaminated Boils~ the ~ower uucoDSolidazed sand and bedrockaquife-rs,
final sit. clDsure requiremems and pon closure .operations aDd .mailltenance
activities until comp].e~-!on of ~he Phase~ II RI/FS.
Declarations
Consirt~ w:ith "the. :Comprehensi ve!:11Vironmental lles~onse and
Compensatan and Uahi.l:1"ty.&:t of 1980 (CERCLA)..(42 'D.S.C .59601-9657) and
the' National Contingimcy Plan (40-cn t»att'..300)~ and ilO1(24) of' CERCLA,
I have determined that the'remedial action described above~ ~ogether with
proper operation' and maintenance CDnstitute a cost-effective remedy which
mitigates .aDd~11fmizeS damage. ~:. publ1cdlUlth. :welfare9 _:and the
environmeDt..~be remedial actiDn.provides for. the. removal of haza-rdous
J.
-------
-'::-,
waste and ~nimizes the threat of further contamination of the environment.
. The Maryland Department of Health and Mental Hygiene has been consulted
and agrees &ith the approved Temedy. These activities will be considered
part of the apprDved action ~ eligib.1e for Trust Fund monies.
~ nave de~1!Tmined tbat tbe action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
site. .
t/>./'?;,
ate
~~.
..
-2
-------
'1U:COBD OF m:CISION
REHED"IAL ,AL'TERNAilVE SELECTION
" , REMEDL\1. INVESTIGAiION AND' FEASTIrILTTY STUDY (PHASE I)
SAND. GRAVEL., AND: STONE SITE
_EI..KTON, -CF.CTL C011N1'Y ,MARYLAND
.D~5. ENVDtONMENTA1. .PROTECTION AGENCY
-REGION ..111 OFFICE
'~I1.AnELP.BIA., ,PENNSYLVANIA
.' " :'.SEPnKBER .1985
.' '
:'.
.
.. ,3
-------
1.0
SIIE LOCATION AND DESCRIPTION
1.1
SI1'E LOCATION
The Saud, Gravel, and Stone Site, is located in Elkton,Cecil County!
Maryland at 75°53'54" Longitude and 30°36'53" Latitude on the .USGS North
. East, Maryland, 7.5-Minute quadrangle map. Consisting of about 200 acres,
.;the site is located north of Maryland Route 40 and along a tributary to
Mill Creek about 3 miles east of Elkton (Figure 1). It 1s situated within
the western portion of a triangle formed by Marley Road to the northwest,
Nottingham Road to the northeast, and Maryland Route 40 (Pulaski Highway)
to the soutb (Figure 2).
.1.2 SITE BACKGROUND AND DESCRIP1'10N
The site was 'Previously operated as a sand and gravel quarry under
. tbe name Maryland Sand and Gravelstone Company. In DecembeT, 197-9.'-' President
Lester Summers of the Sand, Gravel and Stone Company informed the Maryland
Department of Natural Resources that the site was for sale, although no
sale bas since transpired.
...
. 'It was reported that about 3 acres onsi te were used :for the disposal
. .of waste processing water, sludge, .still bottoms, and about 90 drums of
... solid. and semisolid waste between 1969 and 1974. On July 16, 1974; 1,300
gallons of flamable products in drums were reportedly received and dumped. .
On August 5,1974; 5,000 gallons of nonflammable materials were received
at the.site. .Pits, excavated onsi'te, were used as surface impoundments,
where approximately 700,000 gallons.of waste were dumped.
~
On April 27, 1974 (1:00 P.M.), a fire occurred Ot1site during whicb
a pool of chemical was'te was burned at bigh intensity before.it was extin-
guished. The cause of the fire was not determined.
Two hundred thousand gallons of liquid waste were removed from the
site to.Kin Buc Landfill 1n Edison, New Jersey in 1974. The drums and
sludges.that remained were buried onsite in excavated pits.
Numerous seeps were observed during a s.ite reconnaissance by the
~I/FS team. Several seeps are located south of Pond POI, one seep is in
the wooded area ~ast of Pond P02, and other seeps are located downgradient
on a hillside west of Pond P03 in the Sedge Meadow. 'The Sedge Meadow is a
hillside locateddowngradieut be'tweeti Pond P03 and the western tributary
of Mill Creek. The seeps and .surface water runoff from the western and
southern .sections of: the site drain .into the western 'tributary of Mill
Creek.
A -:portion' of 'the site .loca'ted' weS'tof ~be 'Sedge Meadow. has undergone
excavation; however, 'the exact na'ture of the activities that occurred in
tbis area is unknown. Further studies and assessment of. this wes tern
.'~,.ponian are beit1g planne4.
4
-------
Within a-l-mile:radius of thevite-du!Te'are'approx:b1mtely 150 units
housing about 570 residents. Elkton, a town' of 6,468 res~dents is located
approximately 3 miles to the east of the site. ihe town of North East,
located approximately 1.8 miles west-southwest of. the s~te, bass.population
of 1,469.
Surf4U:e wa~ers fram the .site are collected by twointermittettt 1Itreams:
-the western and eastern tributaries of Mill Creek. The tributaries Derge
at the southeastern corner of the site. ~ll Creek flows south eastward
from the site, turns eastward and then becomes a tributary of Elk Creek.
Elk Creek drains into Elk River and.conseqgently into the Chesapeake Bay.
Recreational use of the surface water~( for .f~shing .ocau:s.:111 both_Elk
- Creek.and Elk ]U, ver.
. . 1.3 --EPA R~TAt.AC:uvu:j!;S
h -JuJ.y 1979, nA perlcmaed an:1n1tial site "investigation.. Prior
to this date, the State bandIed the waste mananagement activities. In
February .1982, EPA sent the field investigation team (FIT) to take more
samples. The data was used in the Hazard Ranking System and .a .f~1\al score
. of 40,81'.'was 'obtnned. In December 1982 the site was placed on the
_. .- ProposeJi Bu.ional Priority 1.18 t. The Remedial AUion Haster P.!anvas
prepared 111 March 1984 and the work plan for the nIPs was prepared in
Kay :1984.'U activities begau in.bme 1984.
'. During the COUTse ofthe1uvest1gation it- was -realizes -tbttt tbescope .
of .-the problem -was larger than anticipated.- Tbe bedrock aquifer was
encountered, ..a well ftnstalled and a sample taken from the well showed
contamination. Also same background soil sampli1\g locations were found
to be contamdnated. In addit~on, res~dential wells about a mile from the
slt~ were ~ontaminated with organic~bemicals -and one of.the ~otentially
responsible. companies ~.ssued 'aTi!port which suggeste1L~t the contaminants
~y be from. the Sand, Gravel andStone.site. .
..-
'"The iDcrease in the scope of the investigation lead EPA to phase the
1nves~igat~on. Phase 1 activities are complete and the results are
reported in the RIfFS. -:the remedial measures for this phase will address
-theburried _teT1als~ ~he shallow ground vater aquifer and ~he .surla1:e
water seeps. Phase -n :will begin in October 1985 and will- further
investigate soils and ground water .in the western excavation .area and ~he
'.lower.unc~olidated- _and aDd bedrou- aquifers.
2.0 GEOLOGY -AND HYDROGEOLOGY
2.1 - BEGIONAL GEOLOGY
The s1"te ~s located ueaT-cbe. western .ed!e :of "the' Atlantic Coastal
. . Plain, .approximately two miles sou~he.ast of the Crysta1line~roclt outcrops
marking a .break between the 1'~edmont_. and the Atlantic Coastal.Plain .physio-
graphic' proy.1.Dces. ;;.These prn1d.ncesare..Beparated by ~ somewhat vaguely
s
-------
"
defined transitional belt averagi~g about 5 ~les 'in width, kuo~ as the
,flFal1 ZoneM or MFall Line,. which extends in a northeasterly direction
across %he State of Maryland. The bedrock deposits are extensively concealed
by soil and alluvium in the coastal plain.
ibe bedrock geology of HaTyla~ consists of a wedge of unconsolidated
, sediments, ,including gravel, sand, silt, and clay, which overlaps the
rocks of the eastern piedmont along the irregular Fall Line. Eastward,
, this wedge of sediments thickens to more than 8,000 feet at the Atlantic
coastline.
,,- The sediments of the Coastal Plain dip eastward at a low angle, generally
less than one degree, and range in Bge from Truassic to Quartenary. The
younger fOTmat10ns'crop out successively to the southeast across southern
Haryland ,and the Eaatem5hore. .A~h1ck l.4yer of Quaternary gravel and
sand covers the older formations throughout much of the region.
Mineral resources of the Coastal Plain are chiefly sand and gravel.
Which are used as aggregate materials by the construction industry. Clay
for brick and other ceramic uses is also important. Small deposits of
,':. iron ore are of histori~ interest. Plentiful supplies of ground water
are .Bvailahle.from aquifers throughout much ,of the region.
'~eep drilli~g in the area has revealed ~hat metamorphic and igneous
rocks. including schist, gneiss, and gabbro. underlie the sedimentary
rocks of %he Coastal Plain.
2.2 SITE GEOLOGY
~
The site is underlain by unconsolidated clay. sand, and gravel sediments
beli~ved to be derived from Piedmont. or Pre-Cretaceous deposits. A Potomac
geological group. ,.consisting of Patapsco (upper member) and Patuxent (basal
member) formations, has been identified.
The Patapsco formation consists of unconsolidated sand. sandy clay.
clay, silt and small amounts of gravel. The clay in this formation is
general~y tan, buff, ~te and characteristically pink, red, and mottled
pink and .White. The sand portion.is mainly fine grained. Gravel in this
~ayer is usuallyuot .in ~ontinuOUB beds but scattered through sandy ,clays.
The basal member of the Potomac group is the Patuxent formation
which.consists of disconti~uous beds and lenses of sand, clay. silt, and
gravel. Clay and sandy clay are the most abundant, sand is fairly abundant,
, .~and gravel,taleast abundant. The clays are light-coloTed white. yellow,
~ink, or red. The sand is mainly fine-grained. white, yellowish. or brownish
,,ia color.,-JDicaceous Bnd somewhat ..arkosJ,c. Coarse-grained sands are sometimes
'. -cemented with brown iron oxides.
'.The ..site is situated -em BU outcrop of the Patapsco -formatiou. At .the
J" ,'site. -:the soi.L,. .long with up to ~O feet of. 8ubsoi11118terial,vere removed
6
-------
.£iuring eScavJi~ion usocia~ed 'Wi.~h ~he qusTry .ac~ivi~ies. !oTiDg mui monitoring
we1l logs completed in this study reveal ~hat the' shallow clay layeT begins
approximat:ely 17-34 feet below the surface and'dips ~oward both the southeast
and soutbwest:. 'Tbelayer 1D8Y t:ODBist of discontinuous clay lenses.
1fbe ~1ay 1euses dip soutbwest: from"'Pond 1'03 t:owarJ! the .Sedge Meadow,
Bout:b £Tom Rand FOl towanll.Dwer 1iau1 ~d. southwest from Pond POI, and
~ben 'Sout:h '%oward the Swamp. A -,:18Y ridge line and a parallel valley to
the east of .this line occur in a llortbwest-southeast: orientation; a fact
that was confirmed by fi1U!ings from ~he geophysical s~udies and ground
water investigations. .The locatiDn of horehol~s and a geo.logical.. studies
and -ground 'Water "111Vestigatlons." The location of boreholes and a geologic
. »rofJ.le ZJf .J:ros_eaion %-%'are shown ~D F.1gures 3 and -4, TespecUvely.
. A 1II8jor U1U:ODSol1dat:e4 deep BUd a bedrock aquifer .are present 1JDSit:e.
:.''ThTougbOut: ~st of ''%be sUe,'~ shallow clay l.ayers, at tbicknesses of
24-56 feet:. . separate the un.anlsol.idated deep aquifer. from the shallow
aquifeT. "No 1:1mcl.uB1ve evid~ is. availahle ~o confirm whetheT the clay
layer is ..continuous throughout ~he site. The potential fOT iuter-aquifer
communicat:ion cannot be ruled out. The ~roposed Phase ~I RI-YS program
will address %be .deeper aquifers. in a more comprehensive.1II8nner.
1k!drodt'u OT"Ue1IT. the s1:te is' -present "at depths above 1III!an sealevel
of 32 feet to the north, -24 :feet to ~he south, and -Sfeet %o.%he.east:.
.. 1'h1s represents' a dipping of about: J-2 Jlegr-ees to the southeast with a
northeast strike. Black ~t:heredbedrDclt material overlies .:the bedrock.
2.3. lIYDROGEOl.OGY
..
A shallow '8quifer vndeT ground water table conditions is presen~
'%broughout %be. site. A shallow ground water divide and an underground
. . ~hannel exist ~u parallel. .and dissect. the site 1'11 a.. northwest-sDutheast
orientation. Three .distinctive regimes of the shallow aquifer were
delineated (Figure 5).
. .
Regi1ie~ Il.t:Overs the area around Pond POI. The ground water flows
underneath Pond POl and ..fans southwestward tOWBrd the . Swamp ..and .sOIrtbward
toward Lower BaulRoad.
Regime '2 COveTS the'.area around Pond 'P02. 'i'be ground wat:er flows
along an.undergroand 'channel in .anortbwest-southeast orientation.
Regime #3. encompasses Pond P03.The gro~d water initially flows
,,:.wesnJard towarJi the Sedge Jfeadow and then southward toward the. Sw.a1llp.
CODBequently...%hree cont:a1II1nat:ed.sha1luw 'ground water ~lumes coincide
'~"'-w1th ~be flow })aths .:1n ~be' regimes. All.three . ground vater aquifeTS out-
.. crop in the .form of surface seeps. ...Based.011 1n-sit:Js-:bydrol1c conductiv.1ties
and field measured hydraulic gradieuis, it .1s estimated that the shallow
grouUd water aquifer1lOvesat '8 rate ;'0£ :approximate1.y 10 ,feet per y~r.
The ..es-timateJ!, taeepage .flow '%anges fTDm l~ 3;, to 2.830 gallons per' . day .
..r..
~. . 7
-------
The limited number of deep monitoring wells drilled onsite were
insufficient to effectively map the ground water contours for the deep
aquifer in the unconsolidated 2one. Available information indicates
. that the flow is geneTally southward. Observations of the elevation of
the bedrock in the.Brea demonstrate. that it dips southeastward with a
northeastern~southwestern strike. Although only one bedrock well was
installed for~he study, data obtained from investigations of the nearby
residential/institutional bedrock wells show that the bedrock aquifer
generally flows southward.
2.4 -SURFACE BYDRDLOGY
SUTface water from ~he site i8 collected by tWo intermittent streams:
-the western and eastern ~ributaries of Mill Creek. The tributaries merge
at the southeastern corner of the site. Mill Creek flows southeastward
from the site~ turns eastward after crossing a railroad, and becomes a
tributary of Elk Creek. Elk Creek drains into Elk River and consequently
into Chesapeake Bay.
The major onsite surface water features include:
8
Standing water~odies: three major ponds (Ponds POI,P02;- and P03)
-. and several small low lying areas occasionally filled with water;
. ,_.8
Streams: tbe Mill Creek tri butaries, numerous seeps or
springs, and several unnamed_intermittent streams;
o
Major low lying areas: the Sedge.Meadow area, a swampy area,
and an Old Sedimentation Pond.
These onsite seeps, ~treamsand other drainage pathways. form three
distinctive hydrologic units onsite:
'. .
o
Unit 1 originates from an area near Pond POI.
o
Unit 2-originates from an area near PondP02.
o
Unit 3 originates from an area encompassing the northwestern
portion of the site, which contains Pond ;03.
- Generally tall 'onsite- streams flow sluggishly in winding courses
towaTd Hill Creek.
. 3.0 . CURRENT SITE STATUS
- An 11/1'S was conducted by .\EPCO, Inc. (a .subcontractoT to EPA through
NUS for this s1te)duTing the period June 1984. to July 1985. A brief
summary of the RI findings and appropriate remedial measures follows,
including observations on publ1c health andenvironmental.concerns.
8
-------
.3.1
GEOPHYSICAL SURVEY
Geophysical surveys weTe conducted during tbe n ~o aid in deteTmining
~he ~i-m:1ts of ~he magnetic anomalies and the possible oCJ:Urrence of :buTied
drums. An ~le~romagne~ic condu~ivity (EM) and resistivity survey coupled
with 1Dagnetome~er investigations. were J:onducted. Major geophysical .findings
-'. are SumJDaTJ..zed _low:
o
Six -magnetic anomalies of relatively high 1IIagnitude and a tH!venth
anomaly of lesser ~gn1tude were identified within the quarzied portion
of the geophysical. study. area. 'The relatively higb 1IIagnitude anomalies
range from several-hundred ~o approx1mately~~600 gammas. ~he highest
anOJl8lies occurreJ! near. the ~Dll 1»iles on the. eastern edge of 1'0nd
POI. Two 1S1D8ller 1DBpitude anomaJ.ies ocs:urred near Pond PD2 il1 the
easten -portion of. the ieopbysit:al's~udy area.' The 'lDagDetic anomalies
cDu.ld possibly be atttibuted to buried feTromagnetic masses. Ibe
estimated total weigh~ of buried ferromagne~iC:1II8teTial. at 'the site
is 45,500 pounds. Assuming that. a full 55-gallon drum weighs .44 pounds,
1,030 drums are present. .
8. Yhree con4ucti~tY.8nomalies indicated potentially cont~nate~
underground .p11n8A8 within the quarried pottion..of.tbegeophysical
study area. Two anomalies oJ:J:Ur. near Pond POI and are ,in pro.x1mi ty
,. ~o '1IIagI1etic anomalies.
. ' ne:~h1Td anomalY'1:JT couduc:tivi-ty.-zone 'occupies -8 ,larger aTea in
the.east-central "portion'approximatel}' 400 'feet-~orth 0'£ })ond POI,
but does 110t spatially correlate directly with a 1II8gnetic anomaly.
Using 8 --magnetic lo~or, .1t -was found that a rectangular metallic
object, approximately 20 feet by 30 feet, is.located appToximately
~OO f~ so~tb of, the center- afthis.conductivity anomaly area.
..In addition, seve'ral round metallic objects .coincide wi.th the
. center ,of this area.
. A: ground-.water divide oriented 110rtbwes~-southeast aud bisettiDg
. -the quarry portion of the geophysiJ:al study area is inferred
'from the teTrain conductivity .data,.and ,confirmed _by~ the .findings
:: m ~he bydrogeoIDgix:al study. '
'. .:-Based 'on 'the 1II8gne'tume'ter s~udy'of. 'ttte area -magnetic anomalies,
.:.drums and possibly..cement" mixers might be"buried in these areas.
~Contail1eri2ed wastes a~eburied in areas approximately 150 feet
l1ortbeast, 250 feet nOTth~ and 300 feet north of pond POl;.and
d1r~ctly north ,and southwest of Pond P02. Assuming an aveTage
.burial depth of.12 feet~ the study.f1ndlngssuggest that the
.:'. -huriedmeUl11c.objectB ,,Cft1IIhined ..8%'e:~Dughly.,equ1"alent in size
':%0 1,030 8teel drums.
3.2 .WASIE.D1V.ESTIGATION
Vsstes pre4om1natly in solid and sem1:-s01id .forms~ were _identified
. in Punds -POI, .P02,and POJ and in the Sedge !feadow onsite.
, .9
-------
Analytical findings for samples collec~ed from 13 waste sampling
stations showed that ,the wastes contain methylene chloride, acetone,
chloroform,2-butanone, trichloroethene, benzene, 2-chloroethylvinylether,
toluene, chlorobenzene, diethyl,phthalate, di-n-butylphtbalate, and bis(2-
ethylbexyl) ~hthalate.
3.3
SURFACE SOIL INVE STlGA'U ON
Soils near Ponds POI, P02. and P03 and in the Sedge Meadow were found
to be contaminated with elevated levels of methylene chloride and acetone;
and trace amounts of chloroform, ,toluene. chlorobenzene, and 1.l,1-trichlo-
roethane.' ,
, Twen'ty-three surface soil sampling stations were' sampled doring the
R~., One of the stations de'tected elevated levels of methylene chlor1de~
acetone, and chloroform in the located western excavated area of the site.
A Phase U RIfFS has been 1>roposed to obtain a more in-depth undeTBtanding
of the status of the contamination in this area.
3.4
SURFACE WATER, SEDIMENT, AND BIOTA INVESTIGATION
Under this investigation, 34 surface water, ,29 sediment,
and 2 biota sampling stations collected samples for analysis for
chemical subst~ces and other parameters.
,Surface water qual1'ty fi-ndings i.nclude determi-nations of:
1. Concentrations exceeding national drinking water standards for
ars~nic, cadmium chromium, lead, manganese, and/or mercury in
Ponds'pOl, P02, and P03; in the Sedge Meadow; and in t~Swamp.
~e high concentrations of manganese were attributed to ,the high
natural background levels in the general area.
2. Elevated concentrations of the volatile organic compounds (VOC)
methylene chloride. trans-l,2-dichloroethene, 1 ,1, I-trichloroethane ,
trichloroethene, tetrachloroethene, toluene, chloroform, chlorobenzene,
ethylbeuzene, 2-hexanone, and xylenes in the Ponds POI, P02, and
P03 and in ~be seeps below these ponds.
'3. No detectable levels of VOC downstream from ,'the ponds and seeps at
the Sedge Meadow, Swamp, and Old Sedimentation Pond, suggesting
that surface water c~ntamination has not migrated offsite.
,4. Elevated concentrations ,of sead-volatile organic compounds 1>hthalate,
2,4-dimethylphenol,2-chloropbenol, aniline, phenol, 2-chlorophenol,
,~..and,..di-n-butY1Pbt'hA1.ate in the~:ponds and.se~s. ."
s. No detectable levels of sem1-volatile 'organic compounds at the
Swamp, indicating that surface water contamination had not migrated
beyond "the site.
10
-------
Se.di1Den% quality investigation findings yevealed "that:
1. Sediments in Ponds PDI, P02, and PO) contained e~evatedcnncentradons
of auen1c, cadmium, cl1romium, ~ead, and 1DercUTY.
_2. Sedi1Det1"ts in the Old Sedi1llentation ]tend downstream from the - ponds
did -not contain any metals above .levels found at tbe background
scnnpl1ng nation. .except 'for chromium, copper, and lead at one
stUion.
3. 'Elevated concen'tra"tlons of VOC were DOted 1:11 .sediments 111
Ponds POl. P02 and PO), and :1D the Sedge Meadow. "Ihe VOC
cD11sis'ted of ~thylene chloride, 'tri-chloroetbene, tetra-
c.h1oroetheDe, toJ.uene, .ch1Drobenzene, ethylbenzene,. an11
'~~s. .
-4. Elevat-ed levels of sem1-vo1atl1e organi-c . compounds were
identified 'in sediment samples collected from Pond POI, 'the
fleep below Pond POI, Ponds P02 and PO), 'and tbe Sedge 1jeadow.
The compounds included l,4-dichlorobenzene, 2-metbylpbenol,
",benzoic add, naph:thalene, 2-methy~ naphthalene, butylbenzyl
"phthAbte. ~thyl1Jht"},S1I1SIte.-M-n-buty~ phthalate, -and 1>h.mnl.
,.Eight fi.eh BmDples coll~ted d~am from the site -did nO"t 1Ihow
any coD1:.8m1nation (~hrougbbiomagnef:Lcation or bioac~umnlat1.on) of .'metals,
pesticides, or .PCBs. 'This~ndicatesthat ,tlffsite aquatic .biota baveno't
" ". been, affected by ..the site " comamination.
. 3.5 GROUND "WAiER QU~I'l'Y
The ons.1teshallow ground ~'ter aquifer was found to ,be.x:ontaminated
wi't h:
-. ,
1. "Ihe BS'L ,metals cadmium, chromium, and manganese at concentrations
. 'exceeding the national drinking water standards. Manganese contami-
'. nation ~s not considered to be an env.iroDmental concern, however
'because ,af ,:Lts'normal high natural JmcltgTound ~evelsiu_.the"'study
area.
'..2. Elevate1f 1evelstlf vol.a~ile' organic --compoundfJ (VOC) 'were detected
1;n the sballowmonitoring ,wells inst~ed..:.uear..and downgradient
from:Ponds'POl, ,P02, and PO) and i~diate1y'downgTadient'from the
. Swamp. Based on the yesults from all of ~he shallow monitnring
,we1ls~ 'the VOCe measured at elevated levels .were vinyl chloride,
c:hloro~hane, methylene chloride, acetone, 1,1-dichloroethane.
:::;', ~ri.chloroetha1Je. '.%ra1HJ-I~2~chletheBe.' ,1~2-di <:"h 10roethane,
. . -~'l,l,l-tr.1cl1l"Oroethane', ''tTi.chloroetbene, 1;etrachloroethene, beuze1\e,
:, .' :.2-beuDone, to l-Jeftt", dUorobeuzene. ,e'tiIy~benzeDe. . and xy~enes.
<.'. J
. ~.3.: ~1::bOODt! -- :'dete:c:~'1'D'~ '.ballGV-:1II01d.~ug :_11 :at: ~bef a r
- ,. . 'southeast corner of ,the site; but at ,concentrations that were much
. ,.,.'" :.~ower than those detected closer to the sources.' .Apparently, th'e
: quality of ~he.Bhallow ground water improves through dilution and
',:,1t1spersion bytbe .,time :it reaches, ~he,..southern and southeastern
-: .~,., - ~nndriaa.;.I:If'%he ',..a:1..te.
.' ~-~.n
-------
4. '"1'be seml-vola~ile organic 1:ompounds phenol9 aniline~ 2-chlorophenol,
1 93-dichlorabenzene9 I,2-dichlorobenzene, 1,4-dichlorobenzene,
2-methyl phenol, 4-methyl phenol, 1~2,4-'trichlorobenzene, 2-methyl
~phthalene, pentachorophenol, and naphthalene were detected in an
onaite monitoring well near the buried drum areas.
Monitoring wells downgradient from Pond POl and south of the'Swamp did
not detect tbe presence of semi-volatile organic compounds, except for
. pentachlorophenol at a low concentration. This finding demonstrates that
the water quality improves by the Lower Raul Road onslte.
Thirteen offsite residential wells were sampled for laboratoTY analysis
of contaminants. Most of the residential wells contained concentrations
of iron and manganese in excess of the applicable nUional 'drinking water
standards. This result is attributed to the bigh na~ural background
levels of these 1IH!tals in the general area.ratber tbanto any varticular
negative impacts £ram the ODBite wastes. . All of ~beO'ther metals that
'were detected were measured at concentratiDns that were below the applicable
national JiriDk1ng water sU:ndarde.
The only detection of a VOC in a residential well was a measurement
of 7.14 ug/l of 1,1,1-trichloroethane in one residentIal well. A
follow-up. test confl%med the presence of 5.0 ug/l of the same compound in
the residential well.Yhis low level of 1 ~l,l-trichloroethane is not
likely to result in any detectable acute or chronic bealth effects.
No detectable .levels of seDd-volatlle organic compounds, pesticides
or PCBs were observed in these residential wells.
~
4.0 PUBLIC H.E.ALIB AND ENVIRONMENTAL CONCERNS
A list of site "contaminants of concern" was developed, consis~ing
of fourteen hazardous substances. These substances are benzene, 1,1,1-
trichlorethane, l,l-dichloroethene, trans-l,2dichloroethene, toluene,
trichloroethene, vinyl chloride, chloroform, chlorobenzene, naphthalene,
bis(2-ethylhexyl) phthalate, .di-n-butyl phthalate, chromium, and lead.
4.1 PUBLIC HEALTH CONCERNS
The 1II8jor health concerns oftbe site contamination are:
1. Tbe'mostcritical healtb risk~elated exposure path i8 through
ingestion of contaminated shallow ground water oDslte. Such exposure
could result in chronic and carcinogenic health effects if contaminants
wer.e ingested over a prolonge1!period of time at the concentrations
. observed in onsite shallow ground water. Although the available
::.data i~cate~hat .Jd~e receptors are not presently exposed %0
.' significant levels of contaminants in dr~nking water, they may be
so exposed at some future time, particularly if the contaminants
migrate .via ground water ..to wells used for. drinking purposes.
;
12
-------
2. Airborne transport of contaminants to onsite OT offsite receptors
does not appear to be an exposure route of concern under the present
conditions at the site,_except for.onsite-remedial workers and
trespassers at or near the sources in the drum/container burial
-. areas and near Ponds POl, P02, and the Sedge MeadDw.
3. Direct ~tact 81tb onsite wastes, surface snils, se4iments,
and surface water seeps may be. a threat to site %respassers.
Although the site was fenced in 1984 during the EPA 1mmediaU
removal action, "the fence has been "torn down aud tM site
continues to be used by Mrt bikers, hunters and children ~rom
the area. -
.- 4.2 .1:NVDlOIiHENTAL mNCERNS
The ~ry env1rzmmentalamcerns are related to d1e:~reseuce and
-movement of contamination-1nleachate, whicb .eventually becomes an integral
part of ~he surface water and sediment system.in the regional~ersbed,
and the ~otentially related effects on-aquatic biota. All of."the Dffsite
biota (fish samples) showed nondetectable or backgrollnd levels of metals,
pesticides, an4 PCBs.. Analytical results. suggest %hat the aquatic communities
. have not been affected by the site contamination. .There is a low ~otent1al
for enviromaemali-mpacts on aquatic .biota.in "the - nearby. surface waters of
- .!Ull Creek, Little Elk Creek, BUd -:Elk River. .The ava1l.able chemical data
indicate that Dffsite surface ~terB and sediments have not been affected
. . by site co~mmtB. - Further 1II1gration of contaminants via ground water
-. to surface water could J.ncrease the potential for j.mpacts OD aquatic. biota.
- ..Also .site .erosion. could transport --relatively .immobile . contaminants and could
affect aquatic biota. Contaminants that pose a potentlal for bioaccumulation
and entry into the food chain Ie.g., lead, naphthalene, and bis(2-ethylhexyl)
phthalate] are of concern.
.5.0 A1.TERNATInS EVALtJATIO~
.5.1
OBJECTIVES
-.
The major objective of -remedial action at ~he Sand, Gravel and Stone
Site is to eli1llinate or at leas~ .m1tiga~e enviTOTI-"tslcontamination in
order to prouctJ)ublic .healtb..and the enuronment. .7he contamination has
.- heen Dbserved onsite.in shallow ground.water,in soils near waste 'sources,
-.-.~nd .in surface WItter and sediments immediately downgradient from . the conta-
.minant source8,:or plumes. The waste.sourcesJ.11cl.ude.Ponds.POl, P02,.and
P03',and drum/conta1ner.:lmr.ialareas (Figure 6).
In order to 1IIeet- 'tbe objective, remedial action should include 1II1nimizing
. further ground water contamination and the possibility of diTect contact
. with the wastes. . Leachate control.maybe an .integral -part of the remedial
. ..' actiona:-to e1.hriDSte -ehe:1Id.gration Df..contaDinants ~08S and off. the
, _s.ite.
"" ...' I
. 'The .1n1t1a1¥'fDT'lllU1Jrtion of1"Jtlmt.1al:a1:ternati~ .acticms:-.a1l hued both
on generic remedies and possible technologies. - l~tialscreening was based
on: 1 )... 'the .reliability' and effectiveness. -0£ a technology as a means of
protecting the population and the envirot1Dl!ntpotentially at risk from
site cDntamina-eion, 2)the_~ngineeriJ1g .feasibility of~ ~he technology ..for
.:.13
.,
,.
-------
the Sand, Gravel and Stone site, and 3) ~he cost involved in installing
or implementing the technology. Ini~ial technologies reviewed are presented
in Table 1. .
The Tesponse actioD.reviewed and the ~otential ~echnologies retained
following EPAts screening process and a detailed discussion of each of
these al~ernatives are presented in the following section.
5.2 ALTERNAiIVES
5.2.1
ALTERNATIVE A: NO ACTION ALTERNATIVE WITH MONITORING
Under a no-action alter.native~ additional remedial activities.would
no~ be peTformed. However, a long-term monitoring program would be established
to provide ~nformation on contaDdnant movement and on exposure to public
health, wellare, and the environment. Through the use of a comprehensive
wonitoriug progra~ future enviTonmental impacts could be observed and
then addressed.
Thetbree sources of water samples at the site are residential.wells,
~nitoring~lls,and surface water points. Monitoring of the residential
wells would be essential since the water is used fOT human conSumption.
Previously sampled residential wells would be monitored to detect potential
future contamination from offs~te m1.p:aUon of.contaminants.
::Since .potential for1:ross-aqulfer CDmmunication and fractures in the
bedrock can -act as pathways for migration of contaminants, it would be
necessary to monitOT both shallow and deeper aquifers. Monitoring wells
constructed during the RI phase of this study could be used for monitoring
migrating contaminants downgradient from the site. A minimum of .10 onsite
shallow, unconsolidated deep,and bedrock wells would be proposed for the
.monitoring program.
Surface waters and associated sediments. -aTe potential -receptors for
leachate that .eeps from the deposited wastes. Also, shallow ground water
may be contaminating some of -the near.by surface waters. Erosion may transport
contaminated sediments off site and consequently contaminate offsite surface
waters... To effectively detect these potential migration routes, a network
_l)f B -surface water 1n1d sediment monitoring stations would. be proposed.
Sampling .and analyses should be conducted at least once per quarter,
owing to seasonal variations. _For-costing purposes, it ~s assumed that
"this program would be continued for 30 years. There are no capital costs
for this a 1teruat ive and the annual operation and maintenance (O&M) cost
is .$128,000.
S.2.2.ALTERNATIVES "THAT MEET THE . OBJECTIVES OF CERCLA
ALTEllNAiIVE B:CAPPIRG OF SELE\;J;J:;u AREAS, SURFACE. RUNOFF AND
SHALLOW GROUND~WATER -FLOW CONTROLS AND HONITOIUNG
. This -alternative (Figure 7) meets the ~bject1ves of CERCLA.
to ~he .;8Dnitor1ng. program prev:j,.ously described, impermeable caps
. 14
.~In addition
tt1at meet
-------
standards listed in the RCU regulations (Part 264) would be be placed over
selected areas of the site where threats to 'public health exist. Before
, , installation the ponds vould be dewatered. A surface runoff and shallow
ground water flow control 'Program a150 would be i1Dplemented. i'he cap
system would reduce precipitation ;inf;ihration into ~he ground and thus
the leaching of contaminants from the sources and consequently retard
migrat;iou of contaminants .from the site. lnstall.at;iou of' the cap ayste.m
should be dune during dry weather to prevent the sy.ste.m. No leachate
collection would be })roposed for this altemative. Surface runoff would
be diverted around the si'te 'to furtbi!r reduce infiltration and ground
water influx to. the sources of. contaminants. "The shallow grouml water.
flow control system would consist of an upgradient. perimeter interceptor
and diversion trench for the collection of offsite ground wa'ter iuflux
, ~o the sUe and ~be reduction of leachate 'ProductJ.vn. "The capital cost
for this alternative ;is.$7~B19,DOO and tbe.annnelO&M1s$141~OOO.
5.2.3 .ALi'ERNAr~Vf;55mSFYING AU. APPL1:CABLE STAm>A1U>S
'. 5.2.3.1 ALTERNATIVE C-l: O~SITE l.EACHAT_~ AND SHALLOW GROUND WAi'ER
".': .nEATMENT; :.SITE CLOSURE; AND ENVI_RONMENTAL MONITORING
I .
'- . ..' This aheTDative (F:1gure 8) 'sa'tisfiesall - applicable standards.
. Under this alternative, a source reduction process. a site closure plan,
-' . and a .long-tem environmental monitoring program WDuld be .implemented.
~s source reduction,process would involve installingfoor,shallow
-ground water .;interceptor -trenches Aiowngradientframthe.waste sour.ces;
pumping of contaminated ground water; treating the ground water; recharging
the shallow ground water aquifer by recirculating treated effluent to
~onas POI, P02, and P03 and the Swamp; and discharging treated effluent
to Mill Creek. 'This 'PTOc:eSS would continue until the. organic ~ompoul1d and
heavy metal-levels in ~he sballow.,gTOund wa~er' aquifer reach background
levels 'or an acceptable risk level (10-6). or meet. standards ~etermined by
the Agency.
This alternative.: 1.s based on tbe assumptlonthat there are four 1IIajor
pools: or "reseTVo1.rs- :of ground wateT (beneath 'and'near Ponds POI, P02,
and P03, and ;in the -Swamp) containing elevate~ concentrations of heavy
metals and volatile and semi-vo.latile organic.:.compounds above the .first
.sfutllow c1ay.-1ayeT or lenses.
Because"of' ~erelatively low hydraulic -conductivity of the 'sandy
material above the;shallow cl.ay~ the interceptor trench method rather
then the Tecovery;well method is proposed~ The trenches would contain
vertical aide walls sUb1lized by sheet piling. The trenches would.
be excava~ed '~o a _pth of ~pproximately)2 to 15 :~eet just --above -.the'top
of1:be fiTS1: -'shallow ---elay layer or'.lenses.--" Excavation 1:0 depths1H!ne1:rating
the shallow clay shoulJi be avcWied so that 'the .integrity of the clay
.1ayeT- or lenses. can be maintained.
Por thi!; remedial alternative. a design' study 'wo1.i1.d, be carried out
.--:J.u1tially to ,identify optimum design-- parameters fOT the --proposed ;interceptor
.1:Yench system. Excavated mater..ial from tbe trenches will be 1:Tansported
. for offsite..disposalat an approved. landfill fadIity. ,The trenches
J.S
-------
will be covered with 'concrete blocks to minimize safety and health hazards.
All three ponds, the Swamp, and the proposed treatment. facility would be
fenced to Teduce public safety and health hazards.
For this alternative. a treatability study 'would also be necessary
~o complete the design of the ground water treatment plant. A closure
plan would be implemented at the end of the 30 year project life. The
plan would consist of (1) a RCRA cap if necessary, (2) backfilling of the
interceptor ~renches, (3) decommissioning of tbe treatment plant~ and (4)
revegetation of disturbed areas. A long-term monitoring program would be
a~so need to be implemented. The program would remain in .force .throughout
" the life of '~he project 'and:beyond until 30 years after site closure.
The capital ~ost of ~his alternative is $1l~065.000 and the annualO&M
~ost 18 $823,000.
S.1~3.2 AI:rERNATIVE"C-2: "OBSITE aACBATE AND 'SHALLOW GROUND WATER~ATMENT;
DIWH REMOVAL AND DISPOSAL; AND ENVIRONMENTAL MONITORING .
Alternative C-2 closely resembles Alternative C-l. but with the
, following major exceptions:
o ~o site closure plan has been incorporated ~nto AlteTDative C-2.
(The need for such a plan ~ll be'readdressed during ~he Phase II
li/J'S. )
... .Excavated soil would remain onsite
o
Drums would be removed and disposed at an offsite landfill meeting
RCRA requirements; and
o
The proposed ground wa~ertreatment system ~uld Temain in operation
for 3 to 5 years iustead of 30 years, as ~n Alternative C-l.
. Also under this alternative, a source reduction process aDd a long-term
environmental _onitoring program would be impleuented. Source reduction
would involve (1) excavation and removal of drums and their disposal at an
offsite landfill 1Iet!~ing RCRA requiTements; and (2) installation of four
shallow groundwater ~nterceptor trenches downgrad1ent from the waste
sources; collection and treatment of contaminated ground water; recharging
. the shallow ground. water aquifer by recirculating ~reated effluent to .
Ponds POI, P02, aDd P03 and tbe Swamp; and discharging treated effluent
to till Creek.
- . Instead of 30 years of ground water collection and treatment as proposed
in Alternative C-l, under this alterna~ive this process would continue for
either 3 or S years (Options 1 ~nd 2, respectively). Tbe objectives of -
this alternative are- 'to 'Teduce tbe vrganic compound aud beavy 1Itetal 'conce-
.ntrationsin..the shallow ground water aquifer to bacltgroundvalues or to
an acceptable risk level (10-6) or meet standards determined by the Agency.
. MateTials excavated£rom 1ttterceptor . trenches would be placed in -existing
ponds and/or.be used to backfill pits re8ult~ng from drum excava~ion.
The estimated amount vf .contaminated soil and waste to be excavated will
. be . determined in .the second phase remedial investigation.
16
-------
AccOTdi11g to ~he geophysical st:udies, 1'1: 1s esti1llat:ed that the
equ:1va1ent en 1.,030 drums were buTr~ed onsite .12 to 15 .feJ!t be.lDw t:be
- existing grade. The Mill" III .for this~ncluaion is:
. 'The '1:opDgraphic alterations res~1ug .from pau exc:avat:~on .activit:1es
..bdicatJ! ~bat ~hese ':dnms vere bur~eQ at shallow depths.
. ~erra1n 1:onduct:i vity s~udies showed ~be presence of a shallow clay
layer at a depth of 13 . to 35.feet. . This J.ayer 'probably has_~ been
pnYt~n1"ed. .
"Low ~ a)nductiv1ty rea41ugs -pTevalent at: 1iepths he10W t:he clay
. l.ayer suggest t:bat the growuf water aqai.fe% ~_"1 atel}' below ~
clay 18 not: extensivelycon%am:l.mrt:eJf. . ~hus ~he wastes Digbt not have
been buri.ed below %he clay hyer.
. . Tbe dmms have ~ot: corroud.
. The' proposed treatment. "system, for . ~bis ,
. one' for Alternative C-l~ as 'shown n Figure
adop't1on of .1uercep~or' tten1:hes :instead of
'the same as ~hat stated ~n Alternative C-l.
tenance work and 'the ~ec1m1al requ:1remen'ts
water t:rea'tmeut system would he the same as
Alternative C-l. .'.
'alternative 18 the same as the
9. The rationale for 'the
%be recovery veil 1IIetbt)d l.s
Also, the opera"tion .atUi main-
for . the trenches and ,grmmd
those, that: were identifieJi for
,The capital cost of this alterative'.1.s $7,095,000 and ~he annual OlaM
. cost .is 753,000 for each op~ion.
, .5.2.4.. ALTER!UJIVES' F.Y~'EDDG:.A1J. ,APPLICABLE~:STANDARD5
'. ,
"5.2.4.1 'AL'TERNATIVE D-t':. tlASTE EXCAVATION, DISPOSAL OF WASTES IN ,
AN APPROVED .ONSI!! I.ANDFILL, COLLECTION AND TREAnJEN'l' OF CONTAMINATED
LEACHATE .AIm. SHAn ou .mtOmm WAnIl, SIn CLOSURE, ..AND.MONITOlUNG
This al'ternative exceeds ,all applicable 's~audards. As shown
1n F1gure10; it consists of the excavation of drummed/Ct)Utainerized
wastes, as :in C-2; additional excavation of sediments, and conta.m1na~ed
soils ,iu'or near'ponds POI. 1'02 and "03;' disposal of excavat:ed wastes in
an approved ousite landfU1'faclli1:y;".co-treatmettt of pond' watert'water
collected f%'t)D. excavation activities, and contaminated leacbate and shallow
ground water at an onsite ~reatment system; a site' closure plan; and long-
term envirDDmental monit:orlng. The collection and ~reatment system for,
contam:1ua~ed1eachate and, Bhall1JWground ,water mcorporated .1n .th1.s altern-
ative is 1cleuU:a1 to-~be one~1anned for Alternative"C-1. ~ imterlal excavated
from the~ leachate' and shA110w ground water 1Dtercep~or trenches would be
disposed in the prQposed cmsite landfJ.ll facility. '''7he' site closure 1)lan
for.%his, .al%e%mttive .~sts ' of, the backfJ.1.l1ng'of '. the .trenches, .Ponds
P01~'Pb2, aDd the' Swampjdecommiss:1oning of: 'the proposed treatment plant;
and' revegetation of disturbed areas. , A '~ong-term .env:1ronment4l:'1D011i~or~ng
program would be 1mpl.emented.
.:~'- .. .Il
-------
- Given the site's past use, it is evident that all three ponds had
wastes dumped in them.- Although, some of the wastes were removed and
dipsosed offsite, it is likely that some residual wastes are still
present in these ponds. The pond water would be first pumped and stored
for co-treatment with the contaminated shallow ground water at an onsite
treatment plant. Based on the results of the RI sampling program, the
- water and sediment in and the soi1s beneath and immediately around each
pond are still contaminated by the wastes. Concentration profiles of the
surface water, sediment, 80il, and shallow ground water samples indicate
that contaminant concentrations decrease-rapidly vertically within a depth
of 5 feet and horizontally away from the waste 80urces -in these ponds.
As discussed in the RI/FS report. the onsite shallow clay acts. at
- least partially, a8 an impermeable layer against further penetration of
- . -~ontaminants to aeper soil or ground water zones.
An overid1ng factor 1'11 deslgnl11g tbewaste excavation program, which
affects the determination of a maximum safe excavation depth, is that the
shallow clay layer, regardless of its effectiveness as a barrier, must
not be punctured or compromised. This.factor effectively limits the vertical
.extent of waste excavation to 15 feet, the shallowest depth at Which the
clay layer --was found at the site during the 1.1. The 1IIOst feasible ultimate
depth of waste excavation i8 also dictated by concern for risk to public
bealth and by costs. The B.I data showed that grossly contaminated soils
did not descend beyond 3 to 4 feet below the surface.
~ased on excavation of 3 feet and assuming that the side slopes of
the excavation~its are two units horizontal to one unit vertical (2:1
slopes), the total volume of the wastes (including drummed wastes, sediments,
and contaminated soils) to be excavated would be about 51,300 cubic yards.
A onsite landfill_~~cation was proposed based on accessibility, relative
remoteness from nearby residents, proximity to all waste sources, and the
ease of post-closure maintenance and monitoring. The design of an onsite
landfill would conform with all RCRA requirements (e.g., double l~l1er/leachate
collection with approved cap). .
The proposed ~andf~ll would contain twO liners -for leachate collection
and leak detection zones. A synthetic membrane placed on a 2-foot layer
,of clay would act a8 a double layer for the base and sides. A double-layer
. cap would consist of a PVC membrane and a 2-foot-thick clay layer beneath
a seepage flow zone. Additional s011 with a vegetative cover would be
.placed on top-Qf the flow zone.
The capital cost of this alternative 1s $18,116,000 and the annual O&M
- cost .is -$884,000.
--5.2.4.2 AI;TEINATIVED-2:-WASTE "EXCAVATION, ONSITE INCINERATION OF WASTES,
- COLLECTION AND TREATMENT OF CONTAMINATED LEACHATE AND SHALLOW GROUND WATER,
-- SITE -CLOSUIE~AND MOBITOIUNG
- -Lhls alternative exceeds all applicable standards. Jt consists of
the excavation of drumued/cot1tainerized wastes, and the wastes, sediments,
and:contaalnated-soils 1'0 or near Ponds POI, P02,.And P03;_-inciner.ation of
~8
-------
An example of. such a facility would i~clude ~he construc%~on of two
~ucinerators, ~ch td%h a capaci%y of .five tons per hour.
'The capl~al ~os~ for '~b1s a1~eY'11lttJ."R is~20,145,{)OO and ~1\e annual
..O&M ~S~ is $7,944,OOD.
5.2.5 ALTERNATIVES ADOP:rING OFFnn DIgJDSAI.
.ALTERNATIVE E: WASTEEXCAVAnON, DISPOSAl. OF WASTES ;cr AN APPROVED
onSIiE LANDFILL~ COLLECTION AND-mATMENT. OF CONTAMIN.AnD,LEA~ATE
ANDGRODND WATER,.sID a.oSDRE AND.!IOl'lITORING
. ~his a1.%e-ma~~ve ~B1dentlca1 ~o Al~erna~ive 1)-1, 'excep~ ~ha~ %he
'. excavated was~e :1s dis1)osed at'aD offsite approved landfill. 'This would
, be done after the excavation process described in alternatives C-2.and
. D-l.'The Dl8'terial would be 'trans1)orted from %he si%e to ~nn1t1:ed -waste
facility. Three candida~e offsite disposal facilities were identified:
. ~ Fondessy fJacill~;, '~oJ.edo, Ob~o, about.70D mnes 'fTom ~he site.
'. .cECOS/.CEB. f81:1]:1'ty, .1l1H'hml1r:ibuTg, Ohio,.about 5501Dili!S fT01D %he
.ite.
. 'acos internatinnal..£aclll~y~.:Buff.alo, Bew.YoTk, about 500
"~JDi.les :.frOJD %be ..site.
De~eTm1uation of~the actual disposal facility depends on the offsite
" landfill capacl'ty and on ~he nego~i1!~ions. For cost es~i1ll8~ing purposes,
it is assumed. ~ha~ ~he one-way truck mileage would bea bout 600 JIliles.
Ma~erial: excavBted from t~leachate..and ground' water _%rencbes.and spent
carbon and sludges geneuted from ~he wastewater'%reatment plant wOuld also
be disposed at an approved,. offsite landfill.
IU.udi~~on to ~he removal and disposal of cDDta1Dinated material,
contaminated ground.Yater.and.leachate would be colle~ted by:1nteTceptor
trenches' and treated by ihe proposed 'ouite treatmen~. fac.1J.ity ;.discussed
for ,Alternative C-l. :The tteated effluent would be'recirculated or dis-
, chaTged tD Hill Creek. '-The Bite closure plan would i~clude backfilling
:, ~~teTceptVT trencbes,'the ~bree 1'onds and the .Swamp; decommissioning of
>,= . ,the proposed treatment plant; .and..revegeUtion of disturbed 'areas. A
, ~.~ ,.~ong~term environmental moni~oring program' wOuld be .implemented.
'-~ api-tal cost of "~his'a1~e-mative:..u $36.292~OOO and ~he-annual
O&M cost.u ~198,DOO.
,6.0 ImCOM!ol£NDED ALTERNAnVE
. ." ...Sectin '300.68(j)-'of the' Ra~iona1'=cvnttugeucy Plau '(NCP) ,[47 n. ,31180;
:,"::' 3uly 16, 1982) states that tbeappropr1ate .extent ,0£ Temedy- shall': be
", determined by ~he ,lead agency's selec~i011'1)f .the remedial al~e-rna~ive
.which ~he agency determines.~s cost-effective (i.e. the ~owes~ cost
. alternative. Uat..is .technically, feasible ..muf reliable) and .hicl1 effi!ctively
- >:..19
-------
~tigates and Ddui~es damage to and provides adequate protection of
public health, welfare, and the environment. In selecting a remedial
alternat~ve EPA considers all environmental laws that are applicable and
relevant. Based on the evaluation of the cost-effectiveness of each of
the proposed alternatives, the comments received from the public and
. information from the Maryland Department of Health and Mental Hygiene,
Waste Management Administra"tion, we recommend Alternative C-2 be implemented
at the Sand, Gravel and Stone ute, ElktOD, Maryland.
Spedfically, Alternative C-2 would involve excavation and removal
of drums and their disposal at. an offs1te landfill meeting RCRA requirements;
installation of shallo~ ground water ~nteroeptors downgradient from
the waste sources; collection and treatment of contaminated ground water;
. recharging the shallow ground water aquifer by recirculating treated
effluent to Ponds POI, 1»02 and P03 and the swamp; and discharging treated
effluent to Mill Creek.
Secondary actions associated with the alternative include the foll9wing:
-Improvement of the access road "to accommodate heavy equipment and
.. ~ruck traffic.
- Formulation of an air monitoring plan and temporary evacuation
-.. plan for protecdon of local residents.
~~~ransportation and offs~te disposal of all bazardous waste
in accordance with ~CRA and Department of ~ransportation regulations.
- Fencing around all three ponds, the swamp and the treatment facility
to reduce public safety Bnd health hazards.
Under this alternative the source .remediation and ground water treat-
ment processes would continue for 3 years (option 1). The objectives of
: this alternative are to reduce the organic compound and heavy metal concen-
trations in the shallow ground water aquifer to a design target based on
the 10-6 cancer risk. The design target will be assessed and reevaluated
_h if .necessary, upon .completion of the Phase II RI/FSstudy.
..1Ie1Dediatlon of ~he deeper aquifer and soils is being deferred at .tMs
--time-and will be addressed iu the second phase. Additional data needs to
be obtaiued to-further define contamination found in the western excavation
area, the deep unconsolidated aquifer and a deeper bedrock aquifer. The
two lower aquifers ~y have potential to carry..contaminated ground water
.offsite. .
-There .are -two-majorC011Cerns which justify the removal of the buried
.. materials and the installation of the .shallow. ground water interceptors
- for collection and treatment. ?irst, the environmental concern ~s movement
- -of leachate which eventually becomes ~art of .the surface water and sediment
~".- system. Secondly, a public health risk_exist.s for ~he. frequent -trespassers
.,who may come into contact with tbe surface seeps.
20
-------
i'be sUTface seeps in ~he. Sedge Meadow. below 'Pond POI. and Pond P02
are of aajor cancern. Tbese seeps occur in areas where tbe shallow ground
wa~er f~ow in~erse~ 'the surface and 2:hese seeps ~ontribuu to the surface
-wa~eT8 of !!ill Creek and 'the Swamp. '1n addition, access to the seeps i5
1102: iTlMbt~ iu any way. and I:hi.1dreu coulJi easily en~er the see~ aTeas.
In fact, the emergency ac2:ion Df April 1984 attempted to restrict access
%0 'the ai.U with a tnl08 .fence surroundiug dle petl.1Deter but was unsuccessful
because .tl1e dirt bike riders tore it down. Therefore, it is appropriate
. 'to imp1emeu~ 'tbese Temedial ac~iv1ties %bis ~ime. even thougb the'It1 will
... 'con~inue %0 investigate ~her areas of 'tbe site. The 'remedial. sction will
, m1tlga~ 'the threat to puhl1cheal~h. welfare and the .env.1%oD!lleIlt:. associated
- wi'th the .hallow aquifer. tbe surface ,seeps and the bnried drums 'at. the
site. The second 1>base RI/Fs 'Will addTess the dee}) sand and bedrock aquifers
and' 'the. amount of the ~tof .s:on%Am1T18't~dsoils.above the shallow ground .
wa'ter aquifer.
6...1
OPEBA1'ION Am) Mll'lu.NANCE
~he Operation and Maintenance will include ,routine mai~enance and
:1nspection of tbe ttea~t plant.
Die source reductiDn aDd 2:rea2:ment process will !te. 'couideTed part.
of "tbe appToved remedy for .a 1)eriod of 'at least tbTee years, unless contam1na-
'tion reduction targets are accompl1shd 1nless tiDe. If the' targets are
-not reacbeAi.af2:er. ~ee )'I!ars Df remedial aC2:ivity.' 'the Regional Adminis- .
1:rator will, detemine ~f. it is technically feasible :1:0 reach those targets.
.The ,long-:term. .1IIOni toringbeyond. .the .%hree-y.ear ,~er10d .ofground water
treatment and the post closure requirements are not included in this alter-
native and will .he coilsidered as part of Phase 1'1 remedy.
~.2 ~; CONSISTENCY W1'TH .uv lJWNMENU1.,I.AWS
Any drums Temoved for'offsite disposal -be tested, containerized,
transported and disposed.of in compliance with RCRA andS2:ate Waste
Hanagementlaws.
."-Tbe . .leachate collecti1:n1' am!' treatment "~em -will he t)perued' in
accordance wi~h all~lean Water .Act NPDES-requirements and Clean Air.Act
, oemiss1on standards. The collec~ionsyB2:em wi1.Lnot..be ~ocated .in or
'..affe~ ~ '"'tl"ftd~ ilood plain.
. .'~he. selected remedy 18 au 1uteri1D-measure. :-;It 1& . anticipated ~hat
" the Phase.II 1lI!FS will obtalusufficl.enti.nformation to develop a plan
to implement site closure and corrective action program which will address
. ~all app1:1cable and.:r.elevant requirements of RCRA and other statutes.
7.1) '. "D.ILDAnON OF A1."l'EDA'TIVESBOT..:sEUt.-rw
Alternative A
. ,)to Ac~1DD-.and Envj,Yuib&a;:u"tal .Mon:1.tnri-ng
This JI.l~e-rnartve vouldresult .in unacceptable 'exposure ..tD-amtamnents
:'1mIi1~e BUd will cmttinue .to allowancontrolled T~leases of ~hese contamnent&
offBi~~ %O~:%he.1II'I11t.1-rli":env1rJ)nment. .7he 8)82: .critical health risk-
',~
-------
related exposure path is through ingestion of tbe ~ontaminated shallow
ground water onsite. Such exposure could result in chronic and carcinogenic
health effects if the contaminants were ingested over a prolonged period
of ti- at the concentrations observed in the shallow ground water onsite.
Adverse impacts to the environment would cOtttinue under the '110 action
alternative.
Alternative B
. -Capping of Selected Areas; Surface Bunoff and Shallow Ground Water
Flow Controls; and Environmental Monitoring
Since ~be -exact depths and the physical state of the buried
drums/containers are currently unknown these drums could be significantly
corroded or buried at . depth different from the assumed 12 to 15 feet
below the surface. "Therefore, even-with a cap and upgradient diversion of
surface water and the shallow aquifer this alternative could allow continued
Jlligratiou. of contaminents to the shallow and/or deeper aquifers. "'This alterua-
~ive does not address remediation of existing contamination in the aquifer.
The risk for exposure to the ~ontaminated ground water would continue. -
AlteTnative C-l
Collection and Treumettt of Contaminated Lea.cl1ate and Shallow Ground
Water; Site Closure; and Environmental Monitoring
S1m1laT to AlteTnative B, this alternative does not address the
buried drums/containers. Potential for contaminant 1IIigration from the
~TUms-would cont~nue to exist. The i~terceptor trenches would collect
contaminated gTound water moving through the shallow aquifer but the
possibility for vertital migration of contaminents from the shallow
ground water aquifer to the deeper aquifers exists.
This remedial ac~~on also proposes a site closure option after 30
years of pumping and treating even though the ground water contamination
will be reduced at an unknown rate. Therefore, the length of-time to meet
the design urget levels cannot be determined.
Alternative 1)-1
Waste Excavation; Disposal of Wastes at.an Approved Onsite Landfill;
Collection and Treatment of Contaminated Leachate and Shallow Ground Water; -
-Si~e Closure;-and Environmental Monitoring. (see Alternative E)
Alternative D-2
Waste Excavation; Onsite-lncinerationof-Wastes;
Treatmettt-:of Contaminated Leachate and Shallow Ground
Environmental Monitoring. (see Alternative E)
Collection and
Water; Clsoure; and
.22
-------
:--
- Altenmtive E
Waste Excavation; Disposal of Waste a~ an Approved Offsite Landfill;
:. Collection and Treatment of Contaminated Leachate and Shallow Ground lJater;
. Site Closure and Euviroumental Monitoring. .
. -Basi~y, ~hese three alternatives propose a sCt)penf work wh:ich
1D8Y be beyond what is necessary. The ded.s1on on excavation of contaminated
soils and sediments i8 hIUng deferred at this tiDe. ~ z:oll~on and
treament of contaminated leachate and shallow gTound water is i.dentic:al.
to the recammended action. Although these alternatives are ~echnically
feasible and effective J.n protecting public heal~h, welfare and .the
environment, further studies are necessary to evaluate tbese alterna~ives
.J.n a cost-effectJ.ve manner.
..
'. .
~ . .~'.
....:. .' 23
t .-.-
-------
T AtiLE
1
TECHNICAL SC~EENING FON TREATMENT TECHNOLOGIES
SAHD, GRAVEL, ANO STONE SiTE, ELKTON. MARYLANU
Unit Operations and Processes
R~UinN for
.Furth~r
Eva I uat i on
Flow Equalization
Yes
Pr~cipitation. Flocculation 6
Sed imentat i on
Yes
Filtration
Yes
8iological Tr~atment Process~s:
.0 Activated Sludg~
NO
o Trickling Filter
o Rotating Biological
Contactors (A~'s)
o Other Biological
Treatment Processes
NO
NO
NO
Carbon Adsorption
Yes
Air Stripping
"0
Stear.! Stripping
NO
wet Air Oxidation
No
Uzonation witn or without
Ultraviolet Irradiation
"0
6reakpoint Cnlorination
NO
Photolysis wit" or witnout
'ata lySt( s)
NO
Evaporltion
NO
Ion Excnanye or Resin
Absorption
No
ElectrOdialysis
NO
Frlezing and Tnawing
No
Crysta 11 i zat i on
No
Polymerization
NO
Sludye Tnickening
Yes
'Sludge Uewatering
Yes
Post-A~ration
Y~s
Comments
Proven and effective
Proven and eff~ctive
Proven and effective
Susceptible to freezing in winter; ease of pro-
c~ss upset due to wastewater toxicities; ineffec-
tive when org.nic carbon and nutrients are in-
sufficient to support micrObial growtn; and
sysum ucliClltion is difficult to uniev\! ana
!:II i nu in.
(Same as above)
(Same as Illove)
(Same as clOove)
Proven Ind effective
r- .
Only removes volatile organic comtamin,nts
Only removes volatite organic compoundS; and is
energy intenSive
Level of performlnce unknown
Level of performance unknown;
does not remove metals.
Level of performance unknown; Chlorinated by~ro-
ducts may b~ nazardous.
Mot proven
Eneri1 i ntens; ve
Susceptible to fouliny; ana only removes
ionic compoundS.
SuSc~pt;ble to fouliny: ,nd only r~moves ionic
CQl!lPounds.
Energy intensive; and level of performant~ un-
known.
Not proven
Not proven for heterogenic wast~wlterS
Prov~n and effective
Proy~n and eff~ctive
Proven and ~ffectiYe
25
-------
"->
0"1
"
. .
,8 ,
" . ,
,- . -.: -~ I ,f ' .
A.."
"if..~' I:
1~~:" '~L
t . i "
I, 51U11E tlTE""
"
-j'
I
. . - " ,
..~
- , ..
,
I'
~,.
<4
PlH.
MU'"
I
I.
I,
T' -.
, .
I
.. . .' ElK HE
i\
. .
-- ~
....~ I
'It"
"'"...
I
--
.......... IIV
Source of Base Hap:
Cecil County Street Hap, MD.
Scale:
o
I
2000
I
4000 ft
I
, '
~
"
FIGURE 1. Sl!~ LOCATION MAP
-------
----,
fUll It.8eoNnIAcf 1083080J
.1 C'r~1 AEPCO P'AO.IECf NO. .,11
nlA ~ ,IHC..... -, -,
. _I '-I
r, ~ .-v',
i \.~..' oC',/.~
, .. . .
'w. ..-.... .....-.
.-
~
....-
---
.!" - .~,. -_.
::.. -
- \
\
"M'- -'-- ---~--_.
- ~--_..-
I
\
.J
,..-- \
l"-
N
!...~.
..--
....- .--..--.
FIGURE 2. SITE MAP
-------
.... ~~l
.' .
~
.-' --. .--.-
.~~. ---
.-------
CD
N
8!.."- ....---
'.
UH..
. --...
... ....,
--...
. ...,.,
,....... 1Iw-1. ... .......
..., 1Iw-le ... ...-.. I. 'lie IIIIC_....,.,.. 1_.
"'r.... 1Iw_le ... --..
hr'ec. ..,. 11...,,- .....
.- - ---
- ---- -- ..
-'_1'''''''' -. --'1."".
""-. .........
FIGURE J. LOCATION OF BOREHOLES
.. -, ... ....
-------
m
..
..
118
...
'M
...
= I-
II
t
-' 118
.
J(
C ..,
.
I
II 101
.
J .
..
I:
~ .
--
~
j;: 18
C
.
~
... ..
Ie
..
-
"
II
,
Il/fS fOl ,It( SAil). GlAY£l. AIIO StOll( sin
£lUO". cun cOUI8n. fWlYlAII)
" .' \.
-------
...--------
---------
----------...
-----------
----....-------
-----------...-
---------------
---...-----------
-----------------
------------------
--------------------
--------------------
---------------------
---------------------
---------------------
--------------------
jtlltlll~IIII~::
--
--
......
......
-
-
-
--
......
-
-
......
......
-..
-
-
-
,
-
HORIZOIIJAL DISJANCE (f..t)
'.- 1.- 1.'" 1.- I.. I..
...
III
-
.
-
-
..
FIGURE". CROSS-SECTION Z-Z.
OJ
LEGEIIO:
CM . CI.ys 0' "Igh PI.stlclt,
Cl . Gr... I I,. Sand,. and/or
Silty Cia,s with low to
Meetl.. "utl,clt,
GC . Poorl, Graded Cia,.,
Qrnels
"" . EI.stlc Silts
Ml . Silt, or Clare, S.nds
with Slight PI.stlclt,
St . Cia,., Sands
SM . Silt, Sands
Sf . Poorl, Grolded and/or
Grnell, S8nds
a
M
NOns:
I. Groundw.ter elent tons (feet .boy
MSL) were -easured on Harch II
19115
2. Mefe". to fIgure 4-2-1 for locatio
0' this cross-section
An t"109lc lIo"""ul" .... Int,rpol't'd ~t...... .
Ind ,.. MU ,,,ro"..."o,,, ht- IIo,In9'. Actu.
IOtlc ........,,10' In" ..tul,' in" ..., M "1ff,...
M""," ..,I. thon ,,,-.
AEI..~.., lilt
-------
.'.'- ~~..
tI
o-t
M
U8IIID.
- ".' "-'..t... c-t- If_.
-...- ..-........ .,.,.. _... -.1.1..' "7.'~.....,. u..
- I.r'... ...... 11......- .. -. --""'-,r_e'
.1. C......
. FIGURE 5. SHALL
OW GROUNDWATER CONTOUR MAP
-------
EM COffJRAC' "~t...... -;...
... IU8C:OHIMC' Z083Ot02 '
AEPCO,IHC :=:OI'RO.l:C' NO. .3tt
-. -.
. :=iP. ~ "".
f
.--
.~-...
- .- 0- ..--
~
t.~<-:-1
mm
." ..,.. .. c.,.,..,.. Sell. 1Ir-. c.'.'-b'.
c.,.,...,.. -11- "'''W - "'.II'e aJec'.
a.,.,..,.. SIoe"- ,.,.,.... Sw'- ..tw. .. W'-'.
FIGURE 6. CONTAMINATED AREAS
~,'-" ~~~"-~~"~~l
~
\
- . --' \
I
I
I
\
_J
N
M
-------
...-'" """"'",,\i, "-VI"""
AErC..,IHc HUll 8WCOH'IMCf ZOUOIOJ
A9'OO~CfHO, I3U
-
-. -.
. -. ...
..u~. ---':\ . -~ '1'\. 00 /'/,
I -..
.-.......---
- ,,=~ ,
...' .----
....- ..'-'-"'.--
.'
U.llm,
~~) ,.,.r...... C..
--. S.rhc. ...0" D'oor..- .ltc'
.... -.-... '.'.c-.'.'
DI--ol. Ir- 18.1.1.1
. """'.. Stott. IP. s..
FIGURE 7. ALTERNATIVE B
...........-....-........
--~
,-
I
~
- -
\
\
.---1 ." .,.
M
M
I
J
.,.. . -.,---... . ...
-------
.
I
I
. -. . .-.' .
~=
...---!...---.-
.'...- ..-. i .
-7
....-
. _0" ~ ~
lIlIl..
it p...,.. I'.".. IP.I.I
-. - r...C8 ..,. ., .-. t
- .'.'ere,,'er 'r_e. 11.'.1
8ecIre.I.".. 'ere. ..,. IR.'.-.I
FIGURE I. ALTERNATIVE C-I
.............-....-...-...
"".. ".""
~":i;
~
M
\
\
1
\
--, ... ....,.. 00
-------
~" ~......._._-
N:MEDIAllNtlnGAnoNn"IJI-.nV InDY
fOR ne IWI). GRAVEl. . 'TON: 8I'E
ElJITOtt. QCIl COUfTV.1IWtV\.NIJ
EPA CCIHTIIACT 88-01"""
...., IUM:OHTRACT 10830lIO.
AEre.,IIIC AEPCO PROJECT NO. U II
-
"
\.
..,.. .. f. .... "'''L. - II. ."1
h".. aUL CII8". "'\18
.If.... .."pctlt....,. ,......... ...... ",If...
..... ....... ..., ..,""'
...8I8I1II V8ter
8'1.1 (-W..
....,..,... ..'''''
-...-
&0
M
...,...,. ...WII
_..-
8.., ,'.... """"'" ..''''.
""111'''- ~
FIGURE 9. SCHEMATIC FLOW DIAGRAM OF THE PROPOSED TREATMENT PLANT
-------
....-
181ft. no. -".....,,- .. ... ...--.. '-'.'''-'.
c.",,"- - 'r__' .,..- ,. ... - .. ....
,. ""...tI- c.
FIGURE 10. ALTERNATIVE D-I
..............-....-.........
-------~~"
~
I
,
I
I
!
\
\
-i
\D
M
I
\
\
\
I
\
I
.... -... .... . ...
-------
TABLE 1.
SCOPE- OF REMEDIATION
\
II/FS FOR tHE SAND, GRAVEL, AND StONE SIIE
Elk'ON, CECIL COUNty, MARYLAND
" " ~ " " SCOPE 0' REMEDIAL ACtiONS
.::=..:.a==.===:==~=o=...~...a=.u==.=e....2....0...R..=...8.=...===~==========.e.c====
"'
DESCRiPtiON 0' ALTERNATIVE
"AStE AND LEACHAIE & DEEPER AWl fERS
CONtAMINATED SHALLOY AND WESIERN LONG. tERM
DRUMS SOILS GROUND"A tER EXCAVAtED AREA MONitORING POSt'CLOSURE
.. .. .. .. .. .... .... ...... ................... .................... .. .. ........ .. .. .. .. .. .. .. .. .. .. .... .. .... .. .. .. .. .... .............
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... ...... .... .. .. .. .. .. .. .. .. .. .. ..
.
A.
NO'Actlon end Envlronnentel
Monitoring
No ActIon
No Act ion
No ActIon
Defered to
Phese II
30 years
.0 Act ion
8. Cepplng of Selected Arees: Capping Capping flow Control Defered to 30 years Yes
Surface Runoff end Shellow Phase II
Groundwater flow Controls;
end Envirormental MonItoring
C-1. Collection and Treat~t of flushing of Flushing of Collect Ion & Ddered to 30+30 years Yes
Contaminated Leechate and Conemlnants Conaminants 1 reatment Phale II
Shallow GroundWater: SIte
Closure; and Environmental .....
Moni toring M
C'2. CollectIon end treatment of Exuvatlon Flushing of Collect Ion & Defered to 3 years Defered to
Contaminated Leachate and and OffsHe Conemlnants treatment Phase II (Opt ion 1) Phase II
Sh.llow Groundwater: Renoval lendf I I I 5 ye.rs
and Disposel of Oruns: and (Option 2)
Environmental MonitorIng
0.1. "aste Excavation: Disposal heavet Ion hcevat Ion Collect Ion & Defered to 30+30 years Yes
of "astes at en Approved, end Oosite end Onslte treatment Phase II
Ooslte lendflll: Collection landfill Landfill
and treatment of Cont8lllinated
Leachate and Shallow Ground,
water: Site Closure: end Envl'
rDmlentai Monitoring
0'2. "este Exc.vatlon; Dnslte buvat Ion Excavation Collection & Deferect to 30+ 30 years Yes
Incineration of "astes: and Onslte end Ons It e treatment Phase II
ColI-.ctlon end treatment of Incineration Inclneratron
Contamlnat~ Le.chete end
Shallow Groundweter: Closure:
and Environmental Monitoring
(. Vaste Excevetlon, Dlspo~el of Excavat ion Excavation Collect ion & "efered to . 30+30 years Yes
Vastes at en Approved, Offsite and Offsite and Offsite treatment Phase II
Landfill: Collection end treat. Land' it I Londflll
llent of Cont_lnated leechate
end Shallow Groundwater: Site
Closure; and (nvir~ntel
Monitor In9
-------
II/IS '011 ,., UIII>, CUVlI, A'" 110111 ""
flUON. [1[11 CWO". MUla..,
Al "...,,'"
........................................
, . SWRCI [OIIUDl':
A.
lo'Actlon end InvlrGrWJ8Mt.1
Mon. '0' 1"0
I.
Capping 0' S".cted an,.;
Sur he. IU"Off eref Sh.llow
CrOt........, 'Iov Contro";
and 'nv'rorwwnt.. "onltor 1"1
t'l. Col hc, Ion end h.....,., of
Con..INtl'd l.lch... end
Shallow Crourdw.tt,; III.
[Iolur.; ..... Irwhor-.nt.t
Monltorlnv
(,1. (0111<1.01' and "."..,., 0'
Cant-lft8tftf ".,hl'8 .,.,
Ih.1 tow "",",,'t.r; ....,.1'
Ind Ollpoill 01 0._; oneI
(nvlr~I" """Uorlng
0,1. W",. ("CI"ltlon; DI.poul
0' "nu, I' In Appro..,""
On,... 'IncUIII; [Dilution
I'" h"'lnen. 0' Cont.lnetl'd
".eh... and Shallow GrOtnf.
",It,; III. CIOlurl; end (nvl.
rOf'8lon,.' Monito,lno
0'1. W.u. IlClv,"on; OnIlt.
Inr Irwr.. Ion 0' ""'''.
[olll'el Ion and Jr..,..", 0'
Cont..lnetl'd l'leha.. end
Ihillow Craundw.'n' tloewt"
end Invh--",.. ";"'''0''''''
I.
.,.~,. (u..,.tlon. O'.pote. 0'
"'Un .t en Ipprowed, O''''t.
loneIllIl: ColI..llon oneI 1"11'
IIMI 0' Conl.'Nttd l.8Chet.
end Sh.llow C,ourdfl..r: ,te.
Clo.",.; and Inwh~tel
......110.1",
II. IlAMACf"'-OI 0' '''~..IION
WO'.ceton & InvltOf'8llrnl.1 "onltort,.
........................................
TABLE 2.
HUUI ta,.
COST -EFFECTIVENESS COMPARISON OF AL TERNA TIVES
"
. \.
0.51
.IG.
............
11,086,000
I8,S49,ooo
IIS,S66,ooo
1',4H,ooo
Clip. Ion I'
11,681,000
Cllpllon l'
11 I ,Sl9,ooo
1".089,000
In,991,OOO
11,086,000
........................................
11,101,000
"""".." """"""
II,Sl1,ooo
110.461,000
114,089,000
110,611,000
CIIp"on 11
1",041.000
COI>l Ion 1,
ISl,911,ooo
U8,S16,OOO
In,749,OOO
II,Sl1,ooo
101/
-UC /If AlII COllen"
$9,'0',000
118,''',000
18.es<.000
(OptIOft ,,-
19.141,000
COpllon 1,.
116,1]9,000
1£6,'17 ,000
1£',18' ,000
11,101,000
..........................................
UnKcept.', a&pot". to cont..,."u
on ,It. end '.",tuel uncontrolled r.'
I..... o' ttw.. cont.lnenU off I".
10 Ih. ...111_11 _1'-1; .ould
pounlllllr .-. I 1.01" ._., ,Id
vi. 1......lon 01 cont.'net'" -t.r.
hposurl Ih,ouwh 1'_11" _II otll
eont ,""". StIr'acl 'a.".t. IHpI 11111
be ..~.
',CU'dwlt.r cont.'nellan will be r..
1b:11I II .. "'*-- ro... 1_lh 01
II... 01 ....clplobl. ._""'" comol
be *t.t.'nrtd.
"CMntwII.r eont_lnallon .."I be ,..
a.ctd .t .. wAMWI rlt.. OUt"lon o.
\rIlCceptlibl. ..potur. c~t t. ..".
.Inod. ."0, oddllonol "POI...., 10 .'''n
oil I,uck ..1..1 ""1", dllPOII' II ..
0110111 dhpoill lit., 'hll 111""'1'"
..III be 8ft'de>d 10 'ur ther addr... 'ouree
.onl_l...llon ""on Ch. 'hu. II ""IS II
....,1'1111.
,..... .. AIt.rnel'.1 c.,. Allo.
.ac,v,"on 0' ....... ..III '..ult 'n.
.hor..t.,.. Incr"'1 In ,Ir ""tt'ons
.." I", Ih. '_III .. lion po,lod.
I.IIIIG"'" o' ...sU. "II I ,~. I.,...
U,. h.,1 th cone.'nt Ind Ice.'.'lt.
I'OLI'OIIU, elt"""".
,..... .. Alt.,nat'., 0,1.
1- II AII.....I'... O.t. .ho. oddlll_'
.......url 10 ""n oil I"'" I'...., cb'1,.
dll......1 II .. 011111. loneIllIl.
. Opt tons 1 end I t~lr. ..,.t Ion 0' the Ptapoud I,~.t.' tr.lt.."t ..It... 'or J lnet 5 ~.t., '..pe-ct Iv.ly.
I... ., 11','ne,'w A.
'.VI......Ul COlIer..,
........................................
Continued .'I""on '0 the Ih,lIo.. .-d/
or .t'p8' ~If.r. end flW:ontroll td
,....... o. eon,..I,...,." to othlt envl.
'.--n'el -.d' ,.
Conll- 8'I,"lon 10 Ih. Ihlll... oneil
or dHptr ~lftra.
"1".,lon to ,roe.n:lwater and nl..u o'
eonl_lnant, 10 ....,.. hleh.... ..III
be '-.c11l II on ",*,-, '11'.
lIMe .. Publ' c -.,1 th Canc.rns.
I..., ., P\AJI 'e "eal th Cane,,",.
s.. .. Alternatl.. 0".
,... .. "~llc ..,t th Cone.,",
1- I. AI U,nallve A.
IIC",CAI.COIIUI.'
"""".""""""""
A"'olu.. """IIIV 01
"'''n clmot be .crur..
hlv quonlllll1l.
1-, II AIt.tNt'.' 0,1.
,..... II '.IUrnetlv, 0.1.
In addition. IICurl,. en
approv",. offtll. 'acili.
t)' c8J'8bl. o. Ice..,t I",
the "'5"" -. b. dlf".
cult.
IUlIlUII(J1IAl C01ICII.'
............................
Unecc.pt.t.
Unlec'pt .bt.
co
M
S... II hch"iclt Conr.t,,~.
Unecc"Pt.bl"
-------
MEETING SUMMARY
SAND, GRAVEL AND STONE SITE
EUCTON, CECil COUNTY, MARYLAND
SEPTEMBER 5, 1985
A public meeting was held at 7:00 p.m. on September 5, 1985, at EJlcton High
School, in Ellcton, Maryland. The purpose of the meeting was to discuss with
interested parties the results of the remedial investigation (RI) and the feasibility
study (FS) conducted by the EPA at the Sand, Gravel and Stone Site and to request
comments from the public concerning the FS and the EPA's preferred alternative.
There were approximately 30 individuals in the audience including representatives
from the local radio station and newspaper, the Cecil County Sheriff's Department,
various state agencies, contractors who have been involved in site work, the EPA,
some potentially responsible parties (PRP), and interested citizens.
Boyd Grove of th~ Maryland Department of Health and Mental Hygiene opened the
meeting by introducing himself and explaining the purpose of the meeting. He
stated that any verbal or written questions after the meeting could be com-
municated to him at his office in Baltimore. Mr. Grove then introduced_.
Ann Cardinal, who is Community Relations Coordinator for the EPA Region UI.'
office in Philadelphia, Pennsylvania. : r .
Ms. Cardinal explained the concept of the RI and FS and briefly reviewed the fact"
sheets that were made available to everyone at the meeting. She then explained
that atter the public meeting, interested parties had until September 20 to
comment on the FS before the EPA issued its Record 01 Decision (ROD), which
states the preferred alternative for cleanup of the Sand, Gravel and Stone Site.'
She went on to explain .that after the ROD is issued, the EPA begins a remedial
design phase, which studies the methods of implementing the preferred alternative.
Ms. Cardinal then turned the meeting over to Roy Schrock, who is the Region 1\1
EPA project manager for the site. Mr. SchrocK explained the roles played by the
various contractors and agencies working with the EPA on this project, includfng
NUS, AEPCO, and the Maryland Department of Health and Mental Hygiene.
Mr. Schrock's presentation was divided into two parts corresponding to the RI and
the FS reports. First he explained the history of the EPA's investigation, the RI,
and the current extent of the EPA's Knowledge about the site. This included .a
description of the contaminants found in the surface waters, the soils, and the
shallow groundwater aquifer on site. He emphasized the point that the RI thus far
had not investigated the deeper aquifers for contamination, and that this
investigation, referred to as the Phase II RI, would need to be conducted at a later
time.
He then explained that contamination was found in only one offsite well and that
the contaminant, which is not considered by the EPA to be a serious health threat,
was found at barely detectable levels (5 to 7 parts per billion). Though the
39
-------
situation does not constitute a health threat, it does indicate that the contamina-
tion has moved off site.
Prior to beginning the second part of his presentation concerning the remedial
alternatives, Mr. Schrock entertained questions from the audience. These
questions were generally requests for clarifications or addition1l1 explanations of
further proposed studies (Phase II) and the nature, quantities, and movement of
contaminants on the site. A summary of issues and responses is included at the end
of this report.
During the second part of Mr. Schrock's presentation, he briefly described each of
the 7 alternative remedial actions. He then introduced the preferred alternative,
along with a more detailed explanation and requested comments and questions from
the audience.
The comments and questions generally pertained to what had been' said at the
meeting since no one in the audience. had time to review the fact sheets prior to
that evening. Most of the questions were requests for further information or
clarification of topics discussed previously during the meeting.
Attached is a summary of issues and questions that were raised during the meeting
and the responses given by the EPA.
r .
40
-------
Issue:
. Response:
Issue:
Response:
A SUMMARY OF
CITIZEN AND INTERESTED-PARTY COMMENTS
AND CONCERNS AND U.S. ENVIRONMENTAL
PROTECTION AGENCY RESPONSES
SAND. GRAVEL AND STONE SITE
PUBUC MEETING
ElKTON. CECIL COUNTY, MARYLAND
SE~BER 5. 1985
Interested .partles were curious as to when the Phase II RI would be
completed and how the results would affect the results of the Phase I
F5.
Phase II will begin in October and will require 3 to 6 months for data
collection. After the data are analyzed, another feasibility study will
be prepared to deal with the entire site rather than just that part of
the site studied under the Phase I RI. The results of the current FS
should not be affected by further findings from the Phase II RI, except.
in terms of cost increases resulting from the potential need to treat.
greater quantities of groundwater and dispose of more materials and .
soil at offsite locations.
A number of questions pertained to the nature and movement of the
contaminants found on site. Explanations were requested for some of
the more technical terms used during the presentation. One individual
wanted to know if there were any PCBs or radioactive materials found
on site. Individuals were also concerned about what was in the buried
drums.
A description of the. difference between volatile and semivolatile
chemic~ls was given. While many of the chemicals found on the site
have been identified, the contents of the buried drums and containers
have not been sampled.. It is assumed that they contain many of the
chemicals identified on the site thus far, and possibly additional ones.
No radioactive materials or PCBs have been found on the site.
Groundwater is moving at a rate 01 about 10 feet/year, which means it
will be a long time before health threatening contamination reaches
any. .'offslte wells. Despite the fact that non health-threatening
contamination was found in one offsite well, the chances of a '"slug'" of
contamination reaching an offsite well are slight. Monitoring wells
would be able to detect any movement of this nature to offsite
locations. .
41
-------
Issue:
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
A number of individuals requested clarification or further information
on the alternatives resulting from the FS. Questions pertained
specifically to the nature of the groundwater treatment system,
schedule for cleanup, and amount of time required to flush contami-
nants from the soil.
If the preferred alternative is chosen, it will be 9 months to a year
before work begins. The buried drums would be disposed at an
approved, offsite facility. The groundwater treatment system would
consist of a number of chemical process steps designed to remove
chemical contaminants at various stages of the process, as. determined
by individual contaminant characteristics. Redundancy is b~ilt into
the system so that if one part of the system fails, that function can be
performed by a backup unit. (A technical explanation of each part of
the process was provided in response to the question.)
It was estimated that 30 to 70 years would be required to flush
contaminants from the soil.
Interested parties were concerned about the size and use of an onsite
landfill and use of the land after clos~re of the landfill.
If an alternative requiring a landfill were chosen, the landfill would be.
designed according to the needs of the site and would be'
approximately 150 feet by 150 feet. If the EPA constructed the
landfill with Superfund money, it would be used only for disposal of
onslte wastes. However, if a private consortium built it without the
use of Superfund money, and the EPA approved it, the landfill could
potentially be used for commercial disposal of offsite wastes.
Citizens were interested in knowing what could be done with the land
after the cleanup had been completed.
No final cleanup for the site has yet been proposed. The land is
privately owned, and neither the EPA nor the state would assume
ownership as a result of cleanup. If a landfill is constructed on the
site. deed restrictions would be enacted to control future land use and
the integrity of the landfill. If onsite soil treatment is required (as
opposed to offsite disposal), necessary personnel would be granted
access rights for the required amount of time. At the completion of
the cleanup, the land would still belong to the owner.
One individual wanted to know if choosing a lesser remedial alter-
native or concentrating on removal 01 one group 01 chemicals would
result in reducing the threat 01 contamination to an acceptable level.
Standards for site cleanup have not yet been put on paper, although
the EPA would like to meet drinking water standards or reduce con-
taminants so that they are below the 10-6 cancer risk level. The EPA
does not believe it is feasible to treat one set of chemicals and leave
another in the ground just .to be able to meet a standard risk level.
42
-------
Issue:
Response:
Iaau8:
Response:
tt was mentioned previously in the meeting that children have played
on the site. CitJ.zens were concerned about site security and continued
.cca.ss by these children.
One of the cPA's initial actions in Mav 1984 was to install a snow
fence with g81es. The fence tUd not prove to be a successful barrier to
children. A 6-100t chain-link fence has not been installed because it
would require building an access road. in effect Increasing access to
the area. To intruders, the trees and the wooded srea appesr to act as
. barrier around the contaminated groundwatef seep .feas. There 8re
warning signa pOSted outside the site.
CItIzen. W8I'8 fnt8T8sted In whether the r'8SJ)onslbl. parties were
known and by what m8th~ the EPA Jdentffies these parties.
To date" 1M "CPA' hiS' identlfimi "approximately 29 potentially
responsible panJes (PRP), some 01 which are Jocal firms. No le981
actJons "ave been taken against .ny of 1hese firms. The identity 01
PRPs comes from historical records and discussions with the property
owner, 15 well as other involved parties. " .
'. ,
?l
~-A
-------
RESPONSE TO WRITTEN COMMENTS
Commentator 1 - Air Products and Chemicals. Inc.
Comments submitted on August 5, 1985. September 5, 1985 and September 24. 1985
COMMENT:
This commentator's basic position is that the RIfFS is incomplete and
does not provide a rational basis for selecting any remedial alternatives
at this time. In support of this position this commentator argued that:
(1) there are no current or potential environmental risks at the site;
(2) the estimated cost of the C-2 program Is excessive primarily
because of the incomplete information now available and; (3) several
alternatives have been discarded out of hand. Additionally. this commentator
believes the EPA erred procedurely by not providing a sufficient comment
period and proceeding with the selection of a remedy prior to the
completion of the Phase II RIfFS.
RESPONSE:
The EPA believes there is sufficient information available to proceed
with selecting a remedial alternative at this site. The completed Phase I
RIfFS clearly shows that hazardous substances were disposed of at the site
and that there has been uncontrolled releases of these substances from the
disposal areas into the environment The releases have contaminated surface
waters. ground water, soils and sediments. The concentrations of hazardous
substances in the shallow ground water and surface waters near the disposal
areas are substantially above guidelines and, in some instances, regulated
limits. A toxicologic risk assessment in the RI report found that onsite
wastes, surface soils- sediments and surface waters were contaminated to
such an extent that they pose a potential direct contact threat to site
trespassers, which are known to frequent the site.
". .
The hydrogeologic and surf~ce water assessments show that the hazardous
substances are in ground water and surface water bodies which are an integral
part of the surface water and sedIment system of the regional watershed.
It is clear from the data that the substances are migrating and will
continue to migrate through the environment. The further migration of
these substances could negatively affect the environment of the watershed.
The current impacts are restricted to Sand, Gravel and Stone property,
however. EPA does not have to, nor does it believe it should, wait until
the substances have migrated off the property and cause negative off-
. property impacts before it acts to control the contamination.
At this site. the control of surface seeps and shallow ground water
is a measure which will minimize the further releases and migration of
hazardous substances before the potential for negative off-property
effects becomes a reality. The control .of the- surface seeps will also
minimize the direct contact threats the seeps pose to site trespassers.
The removal of buried drums and other containerized wastes is a reliable,
proven and effective source control measure which will further contribute
to minimizing the uncontrolled release of hazardous substances from the
site.
43
-------
In reaching a decision on the appropriate CERCLA response action
the EPA will look to other environmental laws and regulations for guidance
and will attempt to comply with these statutes. In this instance, it is
clear that there is sufficient information to assess RCRA Part 264 reg-
ulations. These regulations call for a corrective action program when
hazardous substances have migrated beyond the waste management area boundries
and closure actions in the waste disposal areas. Although, at this time
CERCLA response actions do not have to comply with other environmental
laws and regulations, it is clear that to meet the directives in EPA's
RIfFS guidance manual regarding assessment of all applicable .and relevant
standards, there is adequate information to decide that the drum removal
and water collection and treatment program are appropriate components
of a corrective action and closure program for this site.
. The estimated costs of the C-2 program is based on a reasonable initial
design of the alternative. Existing data clearly shows that the system
will have to be designed to collect and treat the shallow ground water
flows. In order to not exclude the cost effective implementation of
any additonal water treatment which may be necessary as a result of the
Phase II RIfFS, EPA will look closely at systems which have the ability
to efficeintly and effectively increase: capacity. In regard to the
drum removal, EPA will excavate and test buried drums and other containers
to determine the need for and type of offsite disposal before offsite
disposal occurs. However, until a fInal design is completed it is
premature t~ state that the;eystem has been over designed.
In selecting the C-2' option the Agency has not rejected any option
"out of hand". The feasibility study clearly considered an extensive
list of remedial options. During design EPA will continue to assess
a11 collection systems and treatment designs which meet the objectives
of the C-2 option as part of the standard value engineering reviews
conducted by the Architectural and Engineering firms which design
EPA's response actions.
r .
In regard to the comment period and Community Relations program.
EPA has conducted the community relations activities as required
by EPA guidance. The work plan was presented to the public in a meeting
held May 29, 1984 and only local officials attended. If the community had
requested more public information meetings or newsletters, the Agency would
have responded. RIfFS was released in August 1985. The comment
period was opened August 27, 1985. Copies of the RIfFS were placed in
the public library in Elkton, MD and at the YMCA near the site. A
public meeting was held on September 5, 1985 and the comment. period was
closed September 20, 1985. At the request of the commentator and others,
. the close of the comment period was extended to September 26, 1985.
The Phase I RIfFS provides adequate information to proceed with
the selection of a remedy at this time. The RI examined the site and
defined certain problems. that' can be addressed at this time while the
44
-------
remainder of the investigation for Phase II can continue. It is known
that a release to the environment has occurred by the interconnection of the
shallow ground water and the surface water seeps. It is also known -
that removal of any drummed or containerized wastes burried in the
ground water aquifer is an effective source control measure- It is
a common procedure to conduct additional RI/FS's at sites where
additonal remedial measures may be needed. The NCP does not prohibit
such actions. At this site it is apparent that a Phase II RI/FS
is needed to collect additonal information to address possible deeper
ground water contamination and soil contamiantion. The Phase I RI/FS
does, however. provide the information required in the NCP for ~ro-
ceeding with the C-2 alternative at this time.
Commentator 2 - Rene Coulet du Gard
Comment submitted on September 5. 1985
COMMENT:
The commentator lives less than 1,000 feet from the site and is very
concerned. The commentator would like to have the drums of waste removed at
once. collect and treat the contaminated ground water and replace the
soil. The commentator wants additional studies to be conducted, a thorough
cleanup of the site and a great effort to warn the people living near
the site of the danger of possible contamination.
r.
RESPONSE:
Alternative C-2 calls for the removal of containerized wastes and the
collection and treatment of contaminated shallow ground water. A decision
on the appropriate action to take in response to the contaminated soil
will be made at the completion of the Phase II RI/FS. EPA will continue
t9 hold public meetings and implement a community relations program to
inform the public of its activities at the site.
Commentator 3 - Ernest Little
Comment submitted September 15, 1985
COMMENT:
The commentator is concerned about the threats the site poses to humans
and wildlife. The commentator recommends EPA actively persue the private
parties responsible for the contamination and have the private parties
pay for the cleanup.
RESPONSE:
EPA considered public health and wildlife impacts in arriving at
its decision to select Alternative C-2. EPA has sent notice letters to a
number of private parties who may be re9ponsibl~ for the site contamination
45
-------
and will negotiate for a reasonable period of time with these parties
to have them implement the C-2 alternative and conduct the Phage II RIfFS.
EPA will not. however, enter into protacted negotiations which will
impede timely response actions. If EPA has to implement the response
actions, EPA will at a later date per sue cost recovery actions against
private parties it believes are responsible. for the site contamination.
Commentator 4 - Niles. Barton & Wilmer for Maryland Sand, Gravel and Stone Inc.
Comment submitted on September 19, 1984.
COMMENT:
The comment is essentially the same as made ~y commentator Number 1.
RESPONSE:
See response to commentator Number 1.
Commentator 5 - Dames & Moore for the PRP group
Comments submitted September 20, 1985 and September 26, 1985
r .
COMMENTS:
The September 20. 1985 comments raise the same issues as were raised
by commentator Number 1. The September 26, 1985 comments reiterate some
of the same comments and raise the following specific comments regarding
Alternative C-2:
1. The RIfFS (Phase I) does not contain the necessary site information
to determine if Alternative C-2 can be implemented in a satisfactory
manner.
2. The removal of "drums" may not be a feasible remedial measure.
3. No treatability studies were done to determine the feasibility of
the treatment system proposed in Alternative C-2.
4. The proposed system for constructing the interceptor trenches is
inconsistent with accepted practice; it is very costly and the
sheet piling could potentially do more harm than good.
5. Alternative C-2 is grossly over designed.
6. Alternative C-2 is not cost effective.
RESPONSE:
See
comment.
follows:
response to Comment Number 1 for a response to the September 20, 1985
Responses to the six comments specific to Alternative C-2 are as
46
'-
-------
1.
During design and implementation of Alternative C-2 additonal
field work will be done to determine the exact placement of
and design of the interceptor trenches to insure that a barrier
exists which will prevent the movement of contaminants through
the trench and into the deeper aquifer. Existing data indicates
that the shallow ground water is very contaminated and the
interceptor trenches will be effective in collecting this shallow
flow.
2.
As discussed in the RAMP and the RI/FS report, existing information.
aerial photos and interviews with individuals familiar with the
site indicate there is a reasonable basis for believing drums
and other containerized waste exist at the site. Existing
data clearly shows that hazardous substances are migrating
from the disposal areas, and, given the lack of any controls,
such as liners. it is reasonable to anticipate the continued
leaching of any hazardous substances remaining in the waste
disposal area. Removal of drums or other containerized wastes
will minimize the release of hazardous substances from the
waste disposal areas. Drum excavation and offsite disposal is
a common waste management method proven to be effective. The
details on how the drums will be excavated and disposed of
will be developed during design. If there are no drums containing
hazardouse substances which pose a threat, no drum removal
will occur (i.e., i£ the drums found contain only substances
which are non-toxic or would otherwise not be considered a
threat, there would be no need to remove them).
3.
Existing data clearly showed that any ground water collected would
have to be treated prior to discharge. Treatability studies will
be considered during the design and if it appears that a lower
cost treatment system can be designed which,will meet the objectives
of alternative C-2, EPA will encourage the design and implementation
of such a system.
4.
The proposed use of sheet pilings as side wall stabalizers will
be thourghly considered during design. The commentators concerns
will, of course, be considered during design of the interceptor
trenches. If it is determined that an equally effective and
less costly design can be implemented, EPA will encourage such
a trench.
5.
Alternative C-2 has not yet been designed. A conceptual program
has been developed in the FS. EPA encourages value engineering
during the design of remedial actions and the final design may
differ from the FS so long as it meets the objectives of the con-
ceptual program chosen by EPA.
47
". .
..
-------
6.
Relative to the other remedial aactions considered in the FS
Alternative C-2 is cost effective. The issues raised by.
the commentator relate to the design of Alternative C-2. EPA
will encourage the design of the least costly system which
will meet the objectives of the Alternative C-2's conceptual
program.
". .
48
-------
a/mm&j
\ :'YfVa~/zd
t
OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WEST PRESTON STREET . BALTIMORE, MARYLAND 21201 . AREA CODE 301 .
225-5647
TTY FOR DE.~;::: Saito. Area 383-7555
::).C. Metro 555-0451
Adele Wilzack, R.N., M.S., Secretary
William M. Eichbaur."\. Assistant Secretary
September 26, 1985
Mr. Stephen R. Wassersug. Director
Waste Management Division
Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania
". -
19107
Re:
Maryland Sand & Gravel
Dear Mr. Wassersug:
We have reviewed the draft Remedial Investigation/Feasibility Study
(RI/FS) dated July 1985 and attended the public meeting held September 5, 1985
and we concur with EPA's preferred alternative C-2 from the feasibility study.
Specifically, excavate the buried drums and grossly contaminated soils and
collection of shallow groundwater, downgradient from Ponds POI, P02, P03 and
the swamp, for treatment. This action should eliminate the surface seeps
arising from the sh~llow groundwater. The Department understands that this
is only a conceptual design and we will still require participation in the
development and approval of the design specifications before opened for bids.
In addition to the scope of work proposed in C-2. the Department also re-
quests expedient investigation of the western area to determine if any additionaJ
excavation will be necessary so that all excavation can be completed when a
contractor is mobilized. .
49
-------
Mr. Stephen R. Wassersug
Page 2
We concur with this partial solution and understand the final Record of
Decision will follow the Phase 2 RIfFS. We look forward to cooperatively
addressing remedial measures at the site upon completion of further studies.
RNfdlf
cc:
Virginia R. Bailey, M.D., MPH
Charles R. Taylor, Esquire
Mr. John W. Koontz-'
Mr. John K. Chlada
. r
~
Sincerely,
K~~~
Ronald Nelson, Director
Waste Management Adminis~ration
".. .
50
------- |