United States
Environmental Protection
Agency
Office of
Emergency And
Remedial Response
EPA/ROD/R03-86/026
Sept 1986
&EPA
Superfund
Record of Decision
Limestone Road, MD
-------
TECHNICAL REPORT DATA
(PiHU MId In'tIIlction, on tht nllmt Mfon co,""ltt;1II)
,. "E'OAT NO. 12. 3. RECIPIE...T'S ACCESSIO'" "'0.
EPA/ROD/R03-86/026
C. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1986
Limestone Road, MD 8. PERFORMINa ORaANIZATION CODE
7. AUTHORIS) 8. PERFORMINa ORaANIZATION REPORT 1110.
8. PERFORMINa ORaANIZATION NAME AND ADDRESS 10. PRoaRAM EL.EMENT 1110.
11. CONTRACT/GRANT NO.
12. SPONSORING AaENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. SPONSORING AaENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
18. ABSTRACT
The Limestone Road site is located 2.5 miles east southeast of Cumberland, Allegheny
County, Me on the western flank of Irons Mountain. The 21O-acre site consists of "two
parcels of land, the former Diggs Sanitation Company (DSC-20 acres) and the Cumber land
Cement and Supply Company (CC & SC - 191 acres). The site is bordered on the southwest
by several residences, and immediately to the northwest lie the Cumberland City Dump and
undeveloped land. The site includes large areas of landfilled and dumped commercial,
residential and demolition refuse on both properties.. About .110 tons of a chromium
containing sludge were also disposed of on the properties. Currently, 18 residences are
within a half-mile downhill of the site, 5 within-lOO yards, and one on the Diggs
property. The water supply for these residences is ground water from private wells.
Ground water in the area of the site has the potential to be contaminated with inorganic
and organic constituents. In the mid 1970s, Mr. Charles Steiner, President of CC & SC,
began allowing various contractors to dump,-
-------
EPA/ROD/R03-86/026
Limestone Bead, MD
16.
ABSTRACT (continued)
been reportedly disposed of on the Diggs property as an extension of
previous filling and grading operations. The nearby Cumberland City Dump
functioned as a municipal landfill from 1932 to 1968. Fly ash,
miscellaneous solid metal wastes, and numerous tires are currently exposed
on the northern and southern faces of the dump. several crushed and rusted
drums were noted along the banks of the inactive landfill. The primary
contaminants of concern include: VOCs, base-neutral compounds, TCE, PCE,&
heavy metals.
The selected interim remedial action includes: site grading; capping of
contaminated soil on all properties; fencing of both properties; continued
monitoring of groundwater, surface water, and sediment; complete historical
review of pertinent geological information; collection of regional offsite
and onsite geological information; chemical analysis of the shale to
determine its composition; reevaluation and establishment of background data
control points; frequent sampling to increase the data base; increase in the
number of stream and residential sampling; evaluation of the effects of
natural and/or domestic (plumbing) conditions on the overall water quality
of the area. The estimated capital cost is $1,192,580. O&M cost will be
determined after completion of ground water studies.
-
-------
REMEDIAL ALTERNATIVE SELECTION
Site; Limestone Road Site, Cumberland Maryland
Documents Reviewed
I an basing my decision principally on the following documents describing
the analysis of cost effectiveness and feasibility of remedial alternatives for
the Limestone Road Site. Also, meetings to discuss these remedial alternatives
have been conducted with the state and the general public. I have been briefed
by my staff on the documents and the meetings and they form the principal basis
for my decision.
- Limestone Road Remedial Investigation (C^M Hill, August, 1986)
- Limestone Road Feasibility Study (C^M Hill, June, 1986)
- Staff summaries and recommendations
- Summary of Remedial Alternatives Selection
- Responsiveness Summary
Description of Selected Interim Remedy
Site grading
- Capping of contaminated soil on all properties
- Fencing of both properties
- Continued monitoring of ground water, surface water and sediment
- Complete historical review of pertinent geological information
- Collection of regional, offsite and onsite geological information
- Chemical analysis of the shale to determine its composition
- Reevaluate and establish background data control points
- Frequent sampling to increase the data base
Increase the number of stream and residential sampling
- Evaluate the effects of natural and/or domestic (plumbing) conditions
on the overall water quality of the area
- A decision will be made later regarding surface water sediment and
ground water runon interception. The above studies, including any
additional further studies will be done to characterize the site
in terms of the geology .and hydrology by- EPA and the Maryland
Waste Management Administration, and evaluated for fuLure remedial
action.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300). I have determined that the described selected alternative provides
adequate protection of public health, welfare, and the environment. The State
of Maryland has been consulted and agrees with the approved remedy.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other sites.
*•// *W
7 I
'
_ _ ---M
Date 7 I f (James" M. 4 Self
' ^Regional Administrator
-------
Site Description and Summary of Remedial
Alternative Selection for the Limestone Road Site
Site Location and Description
The Limestone Road site is located on the western flank of Irons.
Mountain near Cumberland, Maryland. The site lies entirely within Allegheny
County, Maryland, 2.5 miles east southeast of the city of Cumberland (Figure
1 and 2). The 210 acre site consists of two parcels of land, the former
Diggs Sanitation Company (20 acres) and the Cumberland Cement and Supply
Company (CC&SC - 191 acres). The site is bordered on the southwest by
several residences; immediately to the northeast lie the Cumberland City
Dump and undeveloped land.
The site includes large areas of landfilled and dumped commercial,
residential and demolition refuse on both properties. In addition, about
110 tons of a chromium ~ontaining sludge were disposed of on the properties.
Through surveillance and sampling operations by the Maryland State Department
of Health and Mental Hygiene (HDHHH) and the U.S. EPA Region III Field
Investigation Team (FIT), suspected areas of dumping totalling approximately
30 acres were defined on the: site. In 1983, the two properties were assigned
a .Hi tre Hodel hazard ranking of 30~54 ,d eich qualified them for inclusion
on the National "Priori ties List'- (NfL) 88 a. Superfund si tee The Cumberland
City Dump, though not included in the site definition used for inclusion
of the Limestone Road s1 te on the NPL, was included in some of the field
investigative work. - ,-
Currently, 18 residences are within a half mile downhill of the
Limestone Road Site, 5 within 100 yards of the site, and 1 on the Diggs
property. The water supply for residences of these nearby homes is ground
water from private wells. Ground ~ter in the area of the site h4S the
potential to be contaminated with inorganic and organic constituents from
the site. Ground water occurs under both artesian anq unconfined conditions
in the area. Tbe shales behave as a single hydrostratigraphic unit and
provide all of the private water supply in the area. Because of extensive
fracturing, some wells in the shale of the Limestone Road site yield up to
20 gallons per minute. The average is probably somewhere in the range of
5 to 7 gpm.
.
-------
-2-
Surface water drainage in the vicinity of the site 1sto unnamed
tributary streams that flow either directly to the North Branch or to Evitts
Creek, which is tributary to the North Branch. A spring discharging from
the base of CC&SC property feeds a tributary that flows south-southwesterly
to the North Branch. Another spring that discharges from the base of the
Cumberland City Dump feeds a stream that flows into an unnamed tributary
that eventually discharges into Evitts Creek just before its confluence with
the North Branch. This same tributary receives runoff from a steep eroded
slope of exposed fly ash about 1, 800 feet upstream of its confluence with
the stream and spring emanating from the base of the city dump.
Site History
On September 26, 1956, Cumberland Cement and Supply Company (CC&SC)
purchased an undivided one-half interest in a 191 acre parcel of land
located on'Limestone Road. On September 19, 1973, CC&SC purchased the
remaining half interest of the parcel. Mr. Charles Steiner, President of
CC&SC, indicated that the property was purchased with the intent of using
a preexisting limestone quarry on the property. Limestone had been quarried
in areas to the north and east of the site, however the quarry was never
worked by CC&SC.
In the mid - 1970's, Mr. Steiner began allowing various contractors to
dump clean fill (housing demolition material) on the property to provide a
larger and more level working s~rface. However, b!~cks, ~ortar, stone,
concrete, wood, domestic garbage, drums, matt~.88e8, glass, furniture,
tires, clothing, glass industry waste, wooden spools, and pallets have all
reportedly been dumped into a ravine on the property. .
The party primarily responsible for the dumping of chromium-contaminated
hazardous wastes on the CC&SC property was Diggs Sanitation; Inc. The owner
and operator of this facility was Joseph T. Diggs, a licensed hazardous waste
hauler. Allegedly, 99 tons of hazardous waste containing chromium, iead,
and cadmium from Fairchild Republic, Hagerstown, Maryland, were dumped into
a ravine on the CC&SC property in April 1981 by Diggs Santation.
Diggs Sanitation operated from the Diggs property on Limestone Road and
was also involved with commercial storage an~ salvage. Filling and grading
operations took place on the property prior to the mid-1960's. Debris and
refuse have been disposed of there since. In addition, an alleged 11 tons
of hazardous waste from Fairchild Republic, Hagerstown, Maryland, have
been reportedly disposed of on the Diggs property.
The nearby Cumberland City Dump functioned as a municipal landfill
'.. from 1932 to 1968. Fly ash from coal burning, miscellaneous solid metal
wastes, and numerous tires are currently exposed on the northern and
southeren faces of the dump. Several crushed and rusted drums were noted
along the banks of the inactive landfill. The amounts of household type.
wastes that may have been disposed of in the landfill are unknown.
-------
-3-
A complaint and order were issued to Diggs and the CC&SC in June 1981
by the MDRHH, Office of Environmental Programs, requiring them to clean up
their respective properties. In March 1982, the Region III FIT conducted a
preliminary assessment of the conditions at the site. Waste samples
collected from the CC&SC drum area contained ethyl benzene, fluorantheine,
various phthalates, benzo (a) anthracene, phenanthrene, pyrene, benzene,
1,1,2,2 - tetrachloroethane, transdichloroethene, and naphthalene. Surface
waters showed little evidence of contamination. One residential well
contained 0.01 ppm of tetrachoroethene, as well as trace amounts of 1,1,1, -
trichloroethane.
Current Site Status
EfA Region III completed a Remedial Investigation/Feasibility Study
(RI/FS) at Limestone Road in July 1986. Data collected in the R1 and in
previous studies done by EPA's Field Investigation Team (FIT) and the
Maryland Department of Health and Mental Hygiene (MDHMH) were used to
describe the nature and extent of contamination. Additional soil, sediment,
surface water, and ground water samples will be collected during design.
Pathways and receptors are described in detail along with known or
suspected risks posed by contaminants in the RI/FS RepOrts and in the EPA
Region III Technical Support Documents.
The following is a brief summary of the types and concentrations of
contaminants detected during the remedial investigation:
Inorganic contaminant concentrations found 1n the soils of the Diggs
property were highest in the. area of test pi"t S1Ol8. The inorganics of
principal interest on th~dDiggs property:When ranked from highest to lowest
concentration are as follows: zinc (4,090 mg!kg), lead, manganese, copper,
barium, nickel, chromium, selenium, arsenic, cadmium, and cyanide (6 mg/kg).
" On the CC&SC-prop~"r~YT~t~:~AGi:g~c'~~ontamraanfs wei"e cQncentrated in
test pit areas STOlOand ST03Q~ The inorganics of principal interest on the
CC&SC property when ranked fr'om highest to lowest concentration are as
follows: chromium (97,600 mg/kg), manganese, barium, cadmium, zinc, lead,
copper, cyanide, arsenic, selenium, and nickel (51 mg/kg). Based on test
pit and soil boring depth chemical analysis results, 1t 1s estimated that
chromium in this area can be found in a 5-foot layer, approximately 1.5
feet beneath the surface.
.
Organics in the soil on the Diggs property were more widely distributed
numerous, and greater in concentration than on the ceasc property. On the
CC&SC property tbey were concentrated largely in the area of test pits
STOIO and ST030. The principal organics detected onsite were base/neutral
compounds such as benzo(a)pyrene, pesticides such as chlordane, and volatiles
- '"such as trichloroethene, tetracbloroethene, and l,I,2-trichloroethane.
. Concentrations of the organic contaminants ranged widely from 57,000 ug/kg
for the base/neutral fluoranthene to 2 ug/kg for the pesticide Endosulfan II.
Results of the analytical testing program indicate that ground water
degradation has occurred as a result of landfilling operations in the area.
Degradatio~ occurs primarily in the form of inorganic constituents, some of
which are considered to be toxic.
-------
-4-
The distribution of toxic inorganic constituents in ground water is
sporadic, showing no definable trend, with perhaps the exception of nickel.
Toxic inorganic constituents detected include cadmium, chromium, cyanide,
lead, mercury, and silver. The concentration of cadmium detected in
monitoring well MWlO (10 ug/l Phase I) equaled the Primary Interim MCL (10
and exceeded the Proposed Recommended MCL.(S ug/~).
The concentrations of lead in monitoring well MW6 (66 ug/l Phase I) and
residential wells DWS-{8.1 ug/l Phase I) and DW16 (134 ug/l Phase III)
exceeded both the Primary Interim and Proposed Recommended MCL's of SO
ug/l and 20 ug/l, respectively. Readings obtained from these wells did
not always exceed values specified in the MCL lists.
ug/l)
The distribution of these constituents in residential wells is more
difficult to interpret, as many are naturally occurring constituents of
groundwater. The concentrations of iron and manganese in all residential
wells except DW9 and DWI0 exceed the secondary MCL established for the
protection of human welfare. Concentrations of zinc tn residential wells
DW7, DW9, and DW16 exceeded the Proposed Recommended MCL of 5,000 ug/l.
The distribution of organic constituents is more sporadic and less
consistent than the distribution of inorganic constituents in groundwater.
No observable trend can be identified correlating the occurrence of these
compounds with landfilled areas. Nevertheless, the. possibility does exist
given the uncertain nature of flow in fractured media.
Inorganics. of .prfmai-yinte~ in the surface waters. emanating from both
the CC&SC and Diggs property were chromium, cadmium, and zinc. Inorganics
in the surface water influenced .solely by the city dump were not substantially
different from those detected in the other surface waters.
Only the organicb1s(2:'ethylhexyi) phthalate was de"tected in low J.evels
(5 ug/l) in the surface water at locations SW005, SW006 and SW007.
Inorganic contaminants of importance detected in the stream sediment
influenced by the CC&SC property when ranked according to concentration are
as follows: manganese (2,030 mg/kg), barium, chromium, lead, nickel, and
cadmium (4.5. mg/kg-). On the Diggs property- (primarily at location So(05) ,
the inorganlcs when ranked are as follows: manganese (144,000 mg/kg),
zinc, nickel, barium, lead, copper, chromium, cadmium, and cyanide (3 mg/kg).
Organics detected in the sediment were toluene, trichloroethene, benzoic
acid, phenol, and benzene. Benzene and trichloroethene were detected only
-------
-5-
once at sites SD005 and SDO06, respectively. Toluene was detected at
sites SDOOi, SD002, SDO03, SDO04, SD005, and SDO06 at concentrations from
5 to 6 ug/kg.
Based on the quantitative findings presented in the risk characterization,
it is evident that a threat of direct contact to the public health and
environment exists from the chemicals at the Limestone Road site. The
chemicals exist in amounts above background that, if ingested from the
soil, sediment, or waters could cause harm to human ingestors and perhaps
to other animals. The following lists important findings of the quantifiable
portion of the pUblic health evaluation and environmental assessment.
o
The noncarcinogens manganese, cadmium, lead, ~nd zinc were present
in the groundwater and will exceed acceptable daily intake levels
if ingested at the published rates, in~addition to exceeding.
standards and guidelines established for safe drinking water.
Nickel appeared'in concentrations that will also exceed its
acceptable intake level. It may be that the presence of the above
in groundwater is a result of site soil contamination or some
constituents (such as lead and zinc) may have originated from
contact of the water with old or corroding piping or natural
occurrence. Further evaluation of the ground water will hopefully
delineate the problem.
o
50il at tt1~ site ,contained the carcinogens benzo(a)pyrene, beanzo(a)-
anthracene, benzo(b) fluoranthene, indeno (i,2,3-cd)pyrene, chrysene,
beta-HCCH, chlordane, heptachlor, PCB's, i,i,2-trichloroethane,
trichloroethene, and tetrachloroethane in concentrations that resulted
in site total excess lifetime cancer risks of 6x10-2, 1x10-3,
2xiO-4, and 5x10-4 for the upper and lower residential, recreational,
and occupational exposures. The polycyclic aromatic hydrocarbons
were the significant contributors t~ these risks. Total risk
based on mean contaminant concentrations were 2x10-3, 2xl0-5,
and 1x10-4 for the upper and lower residential, recreational and
occupational exposures.
o
Noncarcinogens "in the soil including arsenic, barium, cadmium,
chromium (both +3 and +6), copper, lead, cyanide, manganese, nickel,
-------
-6-
selenium, and zinc when ingested at published rates of ingescior.
will exceed cheir acceptable daily intake levels for adulcs and/or
children. ~oce chat, in the soil chromium may be expecced co be
found predominantly in che'crivalent form because of che presence
of reducing organics. This would mean Chat exceedances of the
acceptable intakes for the ~6 form or chromium may not be relevanc.
Q
Sediment at the site concained che quanCifiable carcinogens
benzo (a) anthracene, benzo (b) fluoranchene, indeno (1,2,3-cd)
pyrene, chrysene, benzene,.and trichloroethene. Total risks
associated wich these chemicals were 5xlO-4, 3ALO-S, JxlO-6, and
lxlO-5 for the upper and lower residential, recreational, and OCCUP4-
tional exposures.
'Q
The noncarcinogens arsenic, barium, cadmium, chromium, (assumed as ~6),
copper, lead, manganese, nickel, and zinc were present in the
sediment in concentrations which, if ingested (at. published rates.
of soil/sediment ingestion), Will exceed acceptable intake levels
for children. Note that in the sediment, chromium may be found
predominantly in the trivalent form, and therefore, any exceedance
of the ~6 ac~ep:!ble intake for chromium may not be applicable.
Q
Surface wacers contained no quantifiable carcinogens and their
ingestion does not present an excess lifetime cancer risk.
Q
~~ncarcinogens present in the site's surface water that exceeded
accep~able daily intakes were barium, cadmium, chromium, lead,
manganese, nickel, selenium, ~nd zinc. Cadmium, total chromium
(if assumed to exist as ~6), copper, selenium, and ziL1c violated
the Ambient Water Quality Criteria established for. the protection
of aquatic life. Note that for .the chromium, its pre-dominant EoC'1~ i:1
surface wac:er is proba'bly ~6 ,alC:hough. a sllk~ll amoun t may be found
as ~3. This means tnat, in c:h1s instance, the assumption or
chromium existing as +6 is relevant "and c:he exceedance applicable.
Q
The quant1fiable risk from inhalac:ion exposure to carcinogenic
chemicals.at the site was lxlO-6 ~ccounting for both. the wind
erosion plus mechanical resuspension of dust. For .wind erosion
alone, the carcinogenic risk wa~ 3x~O-7.
Q
Only the quantifiable carcinogens have been presente,~; other
carcinogenic chemicals were discovered ac: the site, but only :arely,
and did not contribuc:e subsc:an~ially to risks.
The summary of site endangerment issues is shown in Table 1.
-------
'''"
'.'", H': I I"
,..,...
. ." . ''''''''1:1 ","... ",'.n'; "., ".
,'" 1'1 ,,' "1 '," '" 0\' .~, II . I 'f' I .
II,. ....."..,........... h",,,., ....."."..... ,..,.... ".. "."...,... ,.. "..II',,~ .,,1, ,.. fI....". ,......".........,..., '"'' .."... ... "......,. ...,......,7." .:.,.. .".. ".. .....,...."".., "..""....
II", " . ""'''~''''''~ ..""..,......., ...... .,. . ...., .....;...,. .,.. """'''''' ,,' ",. ,",,,,,,,,,,,, ....,. '" ''''.,11 ,"..1,'1.., ......11. ..... ....,.... fI... ""''''.''"" ..."...' .. ,....." .10".,.
II... ,"',,,,,",,,,,, .,... ...1." "".' ......., ....... ',,01........, ...."."...",.'" ,.. .............. ,....,,,,,.......,,, ,.,....., .,.."........ '.11.. ,,,,,,.......,.,.... ,.... "......,...."., ,.. ,. ,h vII"
."'.'n' . "..".", .. ':, ~ h,'.I' .,.' .., "n',"',
"rr",,'."'" n.."
''''.'' !."n' . ~"!-"!~~:!!~~
"'I) .. fltIW'" .,!',
'"r....".,,,,,,
A"f'''r' :1"'" "nnnl..
Ih' ",.. '."""",'nr~
t. ..,..,. 'n'..,I.
1I..p:I..... r:Nlr :I.'n....t
....i t I., ,."""..... f~.'"
'It'n'..,,. "'..,,., Ar' ~
11,':'1"," 'h':"'"
~. :""'.,.,,,
~." ",.01"., M,""""
I:.,", ,......."'... L'."
r..""""".."P f!'ta'"
... '''.'ur. II.",!, art .
lit., I.',,' II...::.."
~;, .,,,.1." ,.,
5'_"" r.....",!, 'ftt
':,"I.'n~'!''''nt t,..
"...,,,,,,,. ,..."
.1","."., ,
"'.
I
~I;;: ~f~~;~:i ;'/'
--..!.!-!" -.. . 1"1"1.
III' '""Alii:'''.",
,,,.~.t''''' n' IU,,'.'" V.1'''' h',,,,,
"',,,.,,, .... r.''''nnr...n'l: r'''~''n'
,.. ...,fa".. v",,,,.
I.,i.;' Ifn,
. -c:. ,..,,..,,,,..,,:!
,~,.,' IIn,
~""","!, ,".
- -~ ----..
J_-
"'''''' '''''AIIr.1:''''''' .
I..,..t.nn ft' ...,t.".. "....t h'r.'.t,
---"." J - -1- u-
","'.. '.""AIfr.''''''',
1"1"""" "' o:.i"."," ".,..t hi"..."
"""-p',,
- ,
'I
"'1U".' ,.." ."A"'~." '" ,.,". ,,' "'" "A~If~;
. ~~I;;;j,j
. . -,_. ~:;, I '.~:!';;~"~~~I
'.o,.tlt... t,...... "".
J.lo;-'" - -. (,,/111 ro..,.,.. ~
"'III'" '''''AIII:'''. '"
A, !IIrn', flnl, "II'" ,"".."" 'It 0:","""'"
, t~.. It.... ......." f' ......... .
-.,.-- --'-
.--- -.,..- ~.
r.....".. '''$IItO,,, 15
...... ""SIJOO,. 9116
......-.~ . "'U/SI!OO' J/"
"..b, U"SDnO, rl16
I".. 1I"91~"'.n~ r/1~
110.. 'n.t th.. ..11.... """,,'"..t.et'''''
fI' t"'"~ P.It......... t.(-f.' ., ~tJnnS.
a In".' I.,. th,t II 1""",,,....... II, "...
fit, """. A" Ihte. 8.4"«:'I"".p',
..... ..",.. ~.t..""""~ ....""".... a'
......,..... !\IIIIII'.
---.----.-----., ...- .-. -. ...--
"'" .'".11:"'.'
--'-_ul
,.,~" ""4' ,,' ,"n'~ I.U"~".,
~;.II .
I :'.:.:. I ., ,.~~:;;~,,~:~;
I fl' ,. ,.... 'u'." ....,
flp_", . 1"'f"~1 . - ~''T'P'-~
''''d It,.. It, "':,,".' .",rflV'l'"'''' .
:'I"" ~........,' ,...........,
n. '.1"'""
""..,nf",
"''"..'"
I.IIr:t:l1
l1li,
,",',Ir'"
1."'1..,.......
""","'n,
n:. .
--.. -..,....-
I....
c.....-
Dr....... J
. ",...0.-..
., C..,....
b...
1Ia",'""P'"
IIhb,
Sf ,,,..,,..
PlM .
, _...~, _. . .
". "'~/~:'"'p
6. ""./~"t""
n O'\1~....,.
'.11:;."".
O."7In,",.
n. 1'.n'~'n10
'.JIIU""~
6\n/~'IIJII
'''''/S'")O
"'."5'11'"
IJ'oll/~."'"
..0; "S'"'.
'~'1I/5'"'"
'""$.'''''
n/$'''17
"fMn'~"nQI,
-.. - .. .-- ,. '-
T~"'''i
,n/"
II','
",,'
",,'
II..
""
,,~,
1I"
10/"
""
101"
""
''','
,,~,
""
HU
""
r.,;..ind,,:,i;:i
I '~,;::;, , ,.~:::.:~..::::;,
'n"." h... 1crt.,' ,..."
11.-", -'. I".,. I. . ro....,...'
.,. '''''AIII'' ".;H'
..... rll."1""....,, _'r'r, '..'I "'on,'" 1,".1
'-''''''''' 'n ,.....'n"""'.."
I
r......',.
,.~....
:::r::;--!'''
7'n,
~f1:'IIn'(I
IJ'/I'IIIII',
117" nlUII'O
J'"IIlIII1ir
'".'"1'''''''''
""
.,,,.
"'"
,,,,'
,.,.,
,
"'lIOII '''''AIlr.U..:U' "'" Ar".'OIlII: l1li. ArM.If'AIII.' "'11{111 '''''A'':'.'', "'
-- ---- ~~:.~.t.. "- "'C.:.' ~"~"= J- --1" ~""'=, ... --'. L ~~j~~ .~. ~~ ~~=i~~=;~=:~:I'"
"...... .noI."*~...,.., or ........ 10.."10 ... ."."" 'he_,.. ., .".... ..,p" ....... '''.-tp, .. t"..., "".p" ... lnol. .,......., h- ,....-.,P'
...If... ...... ... .....,,,... I".' ... ....., .H....., h .""'",P''''", "'.n 841....P' ." ''''_e'.....' ''''' ,"- ., lop. h- (~"",._, I....,
I"",."... .., ....r8C~ ""e. h- ,.." .....-..t (..~ Dr.,.." " ." ...n....t f.e. l1r.,.,p, " I". tl..., -.-.~, .'" ....bl. h......
It...., ., u..,.,- I"'" 'h~ .I~I, ..............t .'''t, "... I"".."... lnoI"",~.-... .,"n ,.'1....". h- .... -t... ........ ".""'-" ......
"''''..,. """'''fP'.''' ,.. _.11. ..r IIp''I....... ''''''''"''« r..., ..~, It., '...n",," 01 '''11, ....,.1..,.." .....,..fel (p"tt., I..... -'p "p"P' ,,,." .,"".
Ot....,!'.!' I" ........ -..""h ,,' ru'''''Ir "'. .n" 7..., f,.e..... rr.1I, r..,.."", ,."...".., ..." ...,.....
~-- "----- ::::;~:l"::L:'-- -- ---1.- - L ---- . -"=_L. J -- u -- -_umL_. _L___-
i>"" I..."'" 7... 'n, """""'nn. n' .rr""."'" ..... ''''''.:1,,' "."""".'1."""1',
'ltll"" ."'P .....,.,... a."'.IIt.. In '''p'''!'"", ~ ..It.... t..,., ......,.., ,., ".....,.,....
It,. ",.,... .." 'I" .,. ""., ".,.. "'..1":"" h' ",,,,,III1r:.
~
,
."..'" r.""A""". H'
l..o1 I "/IC.".~ J/~'
,,,,,..,,,,,",,,, "..f"'It' "",I. ""'r,-'''''' ,..
III'" ''''8''1'' n' ......,.,......1 '
""""""
,.
-------
-7-
Alternatlves Evaluation
All remedial objectives are to minimize and oicigace threats co and
provide adequate protection of human health, welfare, and the*environment
in relation to conditions caused by the CCiSC and Diggs properties. The
remedial objectives for the Limestone Road site apply only to the CC&SC and
Diggs properties, which constitute the site by definition in the NPL.
Remedial Objectives for Soil
Remedial objectives for soil apply to the CCiSC and Diggs properr-->s.
They focus on control of direct contact by receptors and contaminant
migration (interaction with other media) by soil erosion and leaching.
The remedial objectives are:
3 Minimize Direct Contact—Mitigate and minimize threat to public
health from direct contact with surface or buried soil at the
CC&SC and Olggs properties. Specific information used to assess •
hypothetical situations of threat to public health was based on
U.S. EPA'guidance for health risk assessments. The assessment
of soil volumes possibly warranting remedial -action was based on
public health threats arising from soil ingestion. Threats
associated with dust generation or* volatilization of contaminants
in the soil were not estimated but were also considered.
" Control Migration to Ground Water—Minimize and mitigate leaching of
contaminants from the soil into the ground water to adequately
protect health of receptors using local fractured shale aquifer.
This objective is general-In scope. The race of contaminant leaching
was not estimated because both properties are largely refuse fill
areas where migration rates cannot be estimated.
/
0 Control Migration to Surface Water—Manage overland migration of
contaminants fronr erosion of soil from the site properties to the
local adjacent, unnamed tributaries discharging to Evitts Creek
and the North Branch of the Potomac River.
REMEDIAL OBJECTIVES FOR 'GROUND WATER '
Remedial'objectives for ground water will be addressed.through actions
directed at the site properties and actions* directed at the receptors of
ground water. They are:
9 Minimize Direct Contaminant Consumption— Mitigate and minimize
current and possible future threat :o public health from direct
consumption of contaminated ground water. The specific information
to be used to assess the current public health threat will be Interim
Primary Drinking Water Standards and U.S. EPA guidelines for health
risk assessments, which consist of both carcinogenic and toxic
effects considerations.
8 Control Contaminant Migration to Surface Water—Manage migration
o-f contaminated ground water to the local tributaries of Evitts
Creek and 'the North Branch of the Potomac River so public health
-------
-8-
• and Che environmenc are adequately protected from surface water
and sediment contamination and ingestion of contaminated aquatic
-life.
* Control Migration of Contaminants—Minimize migration of ground
water contaminants beyond the boundaries of the site properties
to adequately protect human health, welfare, and the environment.
U.S. EPA has provided policy guidance on meeting the NCP objectives
for ground water. General ground water cleanup'objectives for each of
three aquifer classifications are described in U.S. r?A's Ground Water
Protection Strategy (1984).
The fractured shales aquifer that serves as the lc_al aquifer for
residents along Limestone Road is considered a Class II aquifer. The U.S.
EPA's general cleanup policy objectives under CERCLA and RCRA for Class II
aquifers that are presently being used for drinking water supply are to
develop remedial actions that protect human health and the environment.
REMEDIAL OBJECTIVES FOR SURFACE WATER
Objectives for surface water will be addressed in-relation to the
effects caused by the CC&SC and Oiggs properties. Surface water objectives
will be in terms of protection of aquatic organisms from toxic contaminants.
Objectives for protection of human health and welfare are secondary
considerations because ingestion of surface water is very unlikely and is
considered a minor component of overall endangerment. The remedial objec:iv-s
are:
9 Control Aquatic Toxlcity—Mitigate and minimize threats to
aquatic organisms in the North Branch of the Potomac River
from contaminants in surface water from the site properties.
Aquatic toxicity is regarded as an environmental concern in
the Potomac River and not in die small unnamed tributaries chat
carry surface water away from the site 'properties.
•
* Control Direct Contact—Mitigate and minimize threats co public
healch from direct contact with surface waters that have been
contaminated by the site.
f
REMEDIAL OBJECTIVES FOR SEDIMENT •
Objectives for sediment will be addressed in terns of effaces caused
by CC&SC and Oiggs properties. They are:
0 Direct Contacc—Ml tigate ana minimize threats to public healch and
the environment arising from direct contact with sediment contaminated
by the site in the local unnamed tributaries to the North Branch
of che Potomac River and Evitts Creek.
-------
-9-
Factors Used in Screening Remedial Technologies
Technical Criteria
o applicability to site conditions (geology,
o applicability to waste characteristics
o effectiveness and reliability
o implementability
topography, etc.)
Environmental and Public Health Criteria
o . presented in Table 1
Cost Criteria
o increased cost offering no greater reliability or effectiveness
o
increased cost offering no greater protection of public health
or environment as established by criteria
Institutional
o TSCA
o RCRA
o CWA
o NPDES
o etc.
Criteria (Compliance with other environmental laws)
For a detailed analysis of technologies screened out see Chapters 3
and 4 of the Feasibility Study.
- -
. I ~ .
. .
Technolog~es Considered in Detail Include:
soil response actions
o no action
o accessrest.rlctio,n
o containment
o removal and disposal
ground water response actions
o no action
o access restriction
o residential water supply
o mon! toring
o containment
o collection without treatment and discharge
.
surface water and sediment response actions
o no action
o access restrictions
o monitoring
o sediment removal and disposal
o runon and runoff cont.rol
o surface water collection, treatment and disposal
-------
-10-
Alternatives Considered in Detail
Five alternatives incorporating the technologies considered in detail
were evaluated for remedial action in the FS. These five alternatives
were:
1.
Soil excavation from CC& SC and Diggs property with disposal at
an offsite RCRA facility. Ground water monitoring. Surface water
and sediment monitoring.
2.
Capping of contaminated soil on CC & SC and Diggs property with
deed restrictions and fencing. In-house water treatment by ion
exchange. Surface and shallow ground water run-on interception
at CC & SC property. Surface water and sediment monitoring.
3.
Deed restrictions and fencing on CC & SC and Diggs properties
for soil. Alternative water supply by extension and connection
of Cumberland municipal water system. Surface water and shallow
ground water runon interception at CC & SC property. Surface
water and sedi~ent monitoring.
4.
Deed restrictions and fencing on CC & SC and Diggs properties for
soil. Ground water, surface water and sediment monitoring.
s.
No action. No future actions on any environmental medium.
future monitoring or access restrictions.
No
Alternative 1: S01l excavatiOt1~OfI both theCC & SC and Diggs properties
to remove soil having a calculated excess lifetime risk of 10 -6 or greater
and exceedance of the acceptable daily chronic toxic intake for children.
Excavated soil. would be transported and disposed of offsite at a RCRA land-
fill. Ground water would be monitored regularly. at both monitoring and
residential wells. Surface water and sediment would be monitored regularly
near both properties. Sediment in tributaries from both properties would
be monitored less frequently than surface water.
The advantages of this alternative inciude:
o
Excavation and disposal would be in accord with substantive RCRA
requirements. Permits Zor all activities would be routine. No
unusual land use changes or zoning issues involved.
o
Excavation and offsite disposal effectively removes selected con-
taminants from the site to a controlled facility.
o
Soil removal expected to improve quality.of surface wa~er.
-------
-11-
o Direct soil concacC potential reduced and some reduction in ground
water metals concentrations possible.
Disadvantages associated with this alternative include:
*" Implementation and construction safety concerns related to exrava-
tion in refuse.
*
o Local environmental disruption for cleaning, grubbing, and excava-
tion; micigated by surface restoration.
o Substantial noise,"~"dwt, and traffic expected.
•o Tossibility of some contamination in private wells due to the inabil-
ity of'removing all contaminants. Would have to rely on monitoring
to adequately protect public health.
Costs
*
Capital and operation and maintenance costs were obtained from the FS.
Capital costs include:
- Soil Excavation from CC & SC and Dlggs Properties - 313,279,300
»
- Surface Water and Sediment Monitoring (Yearly) - 367,800
Total Capital Costs - $14,332,300
Operation and maintenance Costs • 31 ,.053,000 based on a 30 year period.
* * » « '
Alternative 2: Limited soil capping at both properties: the western por-
tion of the fill area on the CC & SC property and a large fraction of the
refuse fill area on the Dlggs property would be capped with a relatively
imperious multilayer system. The capping system* used as the basis cor the
cost estimate was clay and soil. Ground water used for consumption in
private homes on Limestone "bad would be treated for metals removal toy ion
exchange in small in-home treatment systems. Ground water and potable
water would be monitored-'regularly to check treatment system performance.
At the CC & SC property, surface water and shallow ground water run-on
would be intercepted upgradient to the refuse fill area in a gravity trench
and diverted to the CC & SC tributary south'of the area of contaminated
soil. Surface water and sediment in tributaries from both sites would be
monitored regularly, though sediment less frequently.
The advantages of this alternative include:
o Implementation does not involve unusual hazards as in Alternative 1.
o Capping would isolate contaminated soil and reduce infiltration;
run-on diversion at CC & SC would further reduce migration-.
-------
-12-
o Water Treatment would reduce risks related to metals ingestion.
Long-term public health protection benefit based on water treatment
for residential wells.
o Standards for drinking water would be consistently met in all homes.
Permits for all activities would be routine.
Disadvantages associated with this alternative include:
o Local environmental disruption for cleaning and grading; mitigated
by cap revegetation, but not as substantial as in Alternative 1.
o Construction related noise, dust and traffic from import of capping
materials.
o In-house water treatment by ion exchange is somewhat unreliable,
dependent upon proper long-term operation and maintenance.
Costs
- Capping of Properties - $494,600
- Fencing both Properties - $48,700
- Residential Well Water Treatment - $22,300
Surface Water and Shallow Ground water Diversion System
Upgradient Run-on Interceptor Trench at CC & SC Property » $427,000
- Surface Water and Sediment Monitoring (Yearly) - $37,800
- Ground Water Monitoring (Yearly) - $72,900
.Total Capital £osts » $1,775,800
Operation and Maintenance Costs - $1,058,00
based on a 30 year period
*
Alternative 3: Deed restrictions on both site properties to restrict future
land use and fencing to restrict casual site access. Ground water used for
consumption in private homes on Limestone Road would be furnished by extension
of the Cumberland water system and connection of all homes. At the CC & SC
property, surface water and shallow ground water run-on would be intercepted
in a gravity trench and diverted to the CC & SC tributary south of the area
of contaminated soil. Surface water and sediment in tributaries from both
sites would be monitored regularly, though the sediment less frequently.
The advantages of this alternative include:
o Positive performance because of alternate water supply. Municipal
system considered very reliable, much more so than in-house water
treatment as in Alternative 2.
-------
-13-
o
Overall safety regarded as high because all actions are conventional
construction with minor contact with contaminated materials.
o
Minor environmental effects.
o
Standards fo~ drinking water would be consistently met in all houses.
Disadvantages associated with this alternative include:
o
Applicable laws and regulations will not be met.
o
Some cleaning and grubbing would be necessary to install the fencing,
trench, and municipal water supply lines.
o
Would not reduce infiltration and subsequent contaminant transport
from the site properties.
o
Surface water runoff and ground water discharge quality from the
Diggs property would remain unchanged.
Costs
Fencing both Properties - $48,700
Connection to Cumberland City - $91,000
Water Supply
Surface and Shallow Ground Water Diversion System, Upgrad-
ient Run-on Interceptor Trench at CC & SC Property - $427,100
Ground water Monitoring (Yearly) - $72,900
Surface Water and Sediment Monitoring (Yearly) - $37,800
Total Capital Cost - $990,600
Operation and Mainentance Costs - $1,0~6,200
(based on a 30 year period)
Alternative 4: Limited passive actions on all site media. Incorporates
deed restrictions on both the CC & SC and Diggs properties to reduce likeli-
hood of direct soil contact caused by future development. Fencing proper-
.' ties would restrict casual site access. Ground water would be monitored
"regularly at both monitoring and residential wells. Monitoring would also
be applied to the surface water and sediment on a regualr basis.
The advantages of this alternative include:
o
No construction - related effects, except for site fencing.
-------
-14-
o Continued monitoring would track the behavior of the site into the
future to provide data sufficient to trigger a remedial action.
Disadvantages associated with this alternative include:
o Applicable laws and regulations will not be met.
o Existing and potential future endangerment to public health, welfare,
and the environment would not be mitigated.
o No ground water protection for private homes.
Costs
- Fencing both Properties - $48,700
- Ground water Monitoring (Yearly) « $72,900
- Surface Water and Sediment Monitoring (Yearly) - $37,800
Total Capital Costs • $100,900
(includes engineering design costs)
Operation and Maintenance Costs - $1,048,300
(based on 30 years)
Alternative 5: No action. No future actions on any environmental medium.
No future monitoring or access restrictions. This alternative is not
appropriate because:
o Uncontrolled migration of contaminants.
* *
o Uncontrolled ingestion of contaminated ground water.
T *
o Migration of all contaminants would not be monitored.
i
o No compliance with laws and regulations.
o Existing and potential future endangerment to public health, welfare,
and the environment would not be mitigated.
No costs are associated with this alternative. Table 2 summarizes these
alternatives.
Recommended Alternative .
An interim alternative has been chosen to remediate the Limestone
Road site. This interim alternative will consist of capping of the
properties, fencing both properties, and continued surface water, sediment
-------
..-. . -'" ,-
~.;:;::~~J'."
,,,,., .....,...."
........ .."
..........., ",,,,,-'
.._~~.;;.. ;;;;;;,-;~.---
r.. 'n.....,..
..~'''.IIII,
'''''.-''''.1111,
!,=.,,., ,
"'- .. ,-_. .....--
""'-'-"U', nnu..'
""I...h.'
......." r ,,-I , .....,.",
.";,,,~,, ;....i, ,;,n:~,.;j .
!'......:"...
,.,.,..""
.,..... If".. ..." '''''''''
. . '-
I'tIIII.If: IIUI.III un"".'
!fIen," Jr'.
. '''f:'1....
.~~,_.,." ..." ."A"O' 10.. .
10.. ...,...,,"" h... tn.":.: .h"
"'I.' ,.""..." "I... ..."!,."".. .,
"""It.. Ill. t., ,"," .:,",."".
".'.'" ....."", '''P.. ~~.. ,,,... V...'fO'
.ft4t ".."......, """""n. 'n,.
. - u_.... -..- .
'".JOO.OOO
. .11..,00
"'. -."""
---_.~----- --._..
.
f:.,...UOll .". ","'.,.. ..--
PO'" ."f"ctl-.." '.".".
. .".f"t~.. «"OI't..'".".. h....
.It.. '0 '011' '01 ,." f.e"-
II,. -II..,.... -....
"".'" C""I '",...." ",' 'eet.
. "'.1.,. """"1.-. clt...,..
I.. ......., .."...., .('1 '''''a.
..,If9t:"'.tlOtt ..... '''''.
.It'"" I"" ...,.." tonr-..,,,.
,.,.,.. 'ft ..,..... I..... I"
,..,."..
~~~, flft" ,. .,,, ."~"" "". ,
..,., ..".. n I.." 1111Atlll. '"AIIIAII''' "' A'.''''''III' ~rtl""A""~o;'
.~~:,,'"" II ,., "QAI ,.. "".. ,
'~tr'h. ", .....,...."',.." .,.,'1 ""
tI:,~.: ..... "'r~" "'1":,., ",.,.
d...... ...., It. ,..~ ."" If'''' '"
,.. t.....~.. V..".., ""''''~..,., ""
,...,......"... 0:,..,...,....... "h..t..,.
.,",.."1,,,,,.. tI""," ,",.."..,."...
It' '''''.~f' """"""'. ~tt".r.
"...,.., ",,,, "r.II-... .,..1..., '''..'
S'.I~O,-
. '''.-
$'.11"'.IlOO
.--.-...-.-..----.-
..
f.., ''''.JtftC- "'''., h.
..., ..,.. .f ....,.,... ....,
,~",.."'.II" ".h, ,....,.
...., . f.p"..._11
..",... "Oftl.t...,,!, ..II
- ...... ,..,..........
f"ttftOII ".u.''''' ., ta~c
-v.I' 'wtth-, ,.-.
.''''.' ,"". ""~I h..'.....
tIIftt." 't!'''t.. ,.... ,.1.'..
I" "".1. ,,,."Utt8I.
'''''-''''''- .... ....
,,,.,,... ........1 ,",t8"I.
fir.... ...-=.. It. ,...... It.... ,,,.... 'f" "It
... \~.' ...... ,t'rr.:: r......... ,.." ".
!tltft. "'r.n...'" ,,~,.., .'''''''' frio,
........,.", .."., ''''''''''''nn ".
r........,. 1t,,11 .....fr ',...., ....,,.,
",.,.., ~'"',1''''' ".:tl.., ""of
......,.", 111""""'":1''''' ,....,... '"'..,
,.." I.... It' ... ,.~:, ..' '''f:''',.
~..It'.'" "....... ....'" ..."".....,
8nnU", h'f!.
S ,,,.-
S IIJ.-
sr."""."""
---...-..-.
.. ....-.----------. -..-
..~.:tr.", II. A'" ."A II " "'. ..
''''''' ...":"".,"'." It.... ,......,". "It
"f'A.~" ....." '''r.r,;. ",,,,,,,'11..." hIt
~..'I. ':"""u'v",,,!, ......,...,""
~"":I'" "....., .""" ...",-",
.......... 'tip.
S ''''.-
. 11..-
$I.'~",,",,,
.-..-.. '--...
ft, ,,,,....,... h.",.. .... 'h.
.".f:U..",., o' ....."",,".
ft, .'" ''''''''If, '.'v,. ..h"n....
I .., ,.n' In. ." .".
"""1'""", ,,,,,.,.,,,.4
,..II.'t- .... ...",
."",1.......,....
II'.
.-. --. -. - --. ." --.-. .
..
-.,...,... -II ..~..'U,
........ 'tlt" '"t.,~ 8r' ."". ..
","c....". 10,.. ''I.ltMl-
.....,.t .... ........" .U......
~,.. .. .,""'".
. '- ......-.. .-.
Snit ,.-.... .."'~'''' '0
'"'0''' ,..-tl" ft' ,:"".....
".t., ......""., ,,, 1""1'
h'.. l",.' ~...It~ft'.1
...""""" ,., ch.,t.,
I'''.''''. ..... "!.c...'I"",.
.t.."..P' " ..',.c.
',,'o".UOft. ~,,"t.i ."U.I
It..h" "'''', .n' U.ffh
..,...... .-. 1511 ,."",
'".''' h08 etA.,4tr. ..... ,...,
"",'10.". hf'8 "',-r..
.,,,,..,,,.
..-..-- --"--"
..
tiC."., I"" .... .. .......1
-II .. '" .«... "II"
.....,....,., '17... ,.""".-
"',,,". ,.,...,. 'n, .11
eu.... ..,. .".1. ..
'""1M". "" ...."".1 ,."..
... d.......!t '" ."n'..,
It..... 'ft-"".'. 5",
,,(" ....It',,, "t'V1l .-..1" .
,~f.,,~ ....." I It '011..,.,1...
..,...,,- ..... ".n'.r.
".'fI'."".
..
..
'--. --_..
- - .-.... ..'.'---'--, -.----
t".II'.. ""''''.8tIC'f
'.1''''. .., .,..."... ...t.,
''''''''' ""'''''.' .,.,..
t"".'It,.. ..., ,."...-.
v..,... ..f." ,..,..... ..
..'" ........ .n ~"....
.,. 'tttt..."U"".1 ~""h_-
II... "II.. .,...., C...,~,
.1,,, ,,,,,'-1,,.... ...".1.:
-.-.-.-. .-..--...-..--------- .. '-
..
r....,,_..... ,-,"-
_II ...., .-.. ., IItU.... '
..., ,.,.,. '''''''' -PI ,..
....lto','. "',..,w ....It....-
".,., .""rI.. tit.....'
.U,r'" "" ""-.11 ...-ltfllW.
...... .
..
~
.. . . .'..
.
110 ""'_M.t '.'.", .....
.'.. fI' .""1", 1l\1li,","
'".nhtlt. S. ......... ......
... ..... .. .h, ,..,. '0'
....t.... f... ..,...It... '''' 111111'..
..
". .-.-.-.---.--.-..-..-----..-.-...
.
,..,.., ."" '"""t.cl ...,.".
U., "..."... .ft' .~
,.~,,- 'It fI'''''''''''.'.'''
...,... ~"'"'''''',.tI""..
C::::t:;o,~~:1~.:':.~~c
,""". -"""""'" ,,'
'I'''''''''''''', "..,..... ".'.',
.... -....t-.r".,
..
eo",,,, .....".. ,. '''''''~
,...11., ft' ..' ,-. -.,.,
''''''''''.', .... .....,..., I.",.
.. ......-.~... l...' _.-
,_..... ""..U.. f",
. '~"'''' .... ""'''''
.'U..Ie' ., .., .,..."..
"0'" Ctttt.ttwt'", ,,,.,..
"""., "". .... ,..'u.
:::, .:t::' ... .,...,1..
-'-'- .--- - -- _.
..--.------ --.... ...
.
..
"
.
" -... ._-.... ""
""....- .... ''''''''~'. ,...".
......" -,. ... ,.........
to, ....."", '... .." ...,...-..
,... ,......... ..t """"'.'''',
....«.. ".'''', 1ft' '.'1.....,
"""'" ..-.,.. oKII....
:=~~. t.:, '~I::;:":. .:::.
.
.
-----. ..- ---.--------
. .
S"",.,.. f". "'''''...
....., .,.,.,1' .. c"".h. ,ot"
.., ,. .U "'-.. '...11.
,.. ... ..U...... _II ..
,,,,,, I.... ... ......., t....
..~ ,,-....... .. ."""'"
....... Ift-"h..'.. Stet
,..,." ,.. ~II ,""..
.. ,.... ,....,.... '''''-''''
'''''''''''
.
~,........ f". "'''''...
..,.. "W'4 ~ ,....,.,.., I,
.., .. .rr "'-.. ,~,....
f.. .U .'U.'".. -" ..
......... .... -.... ,....
=::,:~:;'J:. '::"~:.,.
"-.t~ttl .... .I:C"" "
'OtI'", h..... '...ol.e..
SIlo "","U~. -"
,....t.. ,.,.~.. '."'''''..
.
on.; i_...- ...~.~;..... .., f...,. '''II''''.'' ..."... ... "....,. -...-...~........... ... .............~ ~""." ....., .,.-. "'..11... '''11'-'''''' ....: " ,. ........., ..,..,.. .".. ...
~.".... ... .".. '''' .. ""''''~ ..lIhI.. .,,, ,....... '. -'" ,........ ~.....~.... ...., '''''''-U.... '''''- ,.. ..,~. n.'. 'To....,..""....., r..., ... ........ 'roh.....,..... .,
."....,...... II..... ~II..." ,.... ."" ro..... !II. ..... {.... .,... &"'.. ...." .....~.... ''''010 ''''1:...........- f.,..,...... ''''h. - ........ ....-,...
...... ""..... ..... h..._. ''''''''' ..... '''' .""......"11 .~"h... ..~.. "." .........."....... ''''''. .... '''''''........"
~,..... ,..,,". .....~" .. .......... "'-,... ,..,.... .. '"~ ,.".... .......... .......... .....', ,....... _,'h ..,.... ','''''.
.~ ,...... 0:'''''. ":...-. ,... .....h "1,..,1..... '."It, ,~ .-= '"'I,.....~
",.,'II'~ .11.... ..... ......" ._,,,,, ... '." ..1.. ."....,." ... .. ,,,,..",..,,. .,..,.. ..., .11.1.... ..." .... .......... ..., ... ... ....., ........ ... ........." 'I..... I...... ,.
.. 1..,.1.' ,.....1...... to' ....,.."." .."r.,: "I~'''':'"" t,"" It.. ,""!,,,,.,, 'n. ......,. .,....,,,,. "'."""'1'" .", ,..,~.,v.. """"r" 'It """"I,...~.
' ,...':""... ... -..........,,, t.."".... '.....r.,.
';1 ".11" ,
..
----.. ---'-_._-----
It...., ..... ,.....~, ""..-
II.' ........ - .-
......"... ,.. ..-..,
.... ..,'-~ -.,., "".1.
Clltle'''''''.''"", "".I'I~.
'-. -.~,. ,..... "".".
""'PC"''''' ........ft, ,....
"" ..t., h...'~.., .....
,...,......, ,.. ...."..
.----... '---".-".
.
I".., ...11 .-t..t ,..,....
..01 ........ - .-
......,,- I. ...,.,. ."'.-
11- h.... t'Cro.'t """" t..
..".,., "',,' .... I'''''''.
."" ......,,~. .......-.,..
,....... .....,... ,''''~.II..
.......11. ..,.. .... -...,..
""'" ..,..t, 'ft '.....t
'..''''''''''.
.~~"..".,. .'.11 ."."u.., ';
.... -r"1'''' IIr. t.....~ .,."..,~ "..
.n, ....h~",., .....It.., fin
'..""., ......t,,.,,",- PI, It........
,...." tt" I,.....
s 0
'.0
~ "
"". -""".'.,
II'.
If'.
II'.
II'.
......-. _. ~..
II
"1...11- ... """...,".,,.-
~fJIt"fttl.4. ...,~.tt"" fI'
'''..'''' fe'..'...I"a'.'
1'''''''Iv.,-, """~,.."nll.".,
""'.'1....., ... 1'....,....,.
"..... .......1. ..... ....
"""'n,p4.
.
[08Iptl...... ...... ".""."'..
.,,.chll, III, ,,,,.... V4''''
.. "".".. ....,"""" ."" ,.,.,
""'''0''''. 110 ,....11. 'an"
.'., '" 'tI",,,. '.e.....
,..""....".
..
..--.-- .-..
--- -'_U'-
lie "",,, .,.,.., ,....,..,.
-"""... ,. ",,,,",
'.'8'. ,,-...... lit ...,..ttttt.
..t.,. '''''.e. ",,,,.,. ".
.~....... .....11,.
-------
-15-
and ground water monitoring. Continued monitoring 0f the site will determine
if a surface water and shallow ground water diversion system and an upgradient
run-on interceptor trench at the CC & SC property is ~eeded in the future
for continued protection of aquatic life and wildlife. A complete historical
review of pertinent geological information and regional, offsite and onsite
geological information will be collected. Chemical analysis of the shale and
reevaluation of backg'round data control pOints will be conducted. Furthermore,
a more detailed evaluation will be conducted concerning the residents drinking
water. Upon completing this ev~luation, a final remedial alternative will be
selected. Based on our evaluation of the cost-effectiveness of each of the
proposed alternatives, the comments received from the public, the state, and
potentially responsible parties, information from the RIfFS and Region III
technical support documents, Region III recommends that the above interim
alternative be implemented.
Consistency With Other Environmental Laws
The recommended interim alternative was evaluated to determine consistency
with applicable or relevant and appropriate environmental laws.
Due to the elevate~ levels of hazardous substances present in the s01ls
and wastes on the Diggs and CC&SC properties, portions of the RCRA landfill
closure requirements (40 CFR 1264.310) are relevant and appropriate. A cap is
necessary and will be designed and implemented to comply with the final cover
requirements of- '264.310(a). The cap will a180 be maintained. and repaired as
necessary to comply with 5264.310(b)(1)... . During design, good engineering practice
controls will be selected to prevent run~on and run-off from eroding or damaging
the cap as per the requirements of S264.310(b)(5). Compliance with the groundwater
monitoring requirements of S264.310(b)(4) and Subpart F is being deferred at
this time and will be evaluated at the conclusion of the additional studies
discussed above. Because there are no existing leak detection or leachate collection
systems" t~fiL~equirements of S264.310(b)(2) and (3) are not applicable or relevant
and appropriate. .
. There are no surface water discharges subject to NPDES requirements; However,
if additional studies find that groundwater and surface water collection is
necessary, NPDES requirements may be applicable to offsite discharges.
.
Costs
The American Association of Cost Engineers defines an Order-of-Magni-
tude Estimate as an approximate estimate made without detailed engineering
data. It is expected that an estimate of this type is accurate within +
,- 50% to -30%. Sources of cost information include the EPA's .Compendium of
, 'Cost of Remedial Technologies at Hazardous Waste Sites,. the 1986 Means
Site Work Cost Data Guide, Cost Reference Guide for Construction Equipment
-------
-16-
1986 and vendor estimates.
native are as follows:
The projected costs for the recommended alter-
Cost Component
Construction
Cost
o & M
Cost
1.
Capping of Properties
Site preparation of CC & SC property
$6,900
Diggs
9,600
Construction of clay cap at CC & SC
101,500
Diggs
210,500
Topsoil and seed for CC & SC
$22,100
Diggs
$65,300
$43,900
Decontamination and safety for CC & SC
Diggs
$79,000
Inspection, repairs, and maintenance for
both properties
$1,000
, . - . -' . .. .' ~ ' ":" 0:-
.-. ," .
~, ..'- I,. to ,~- . . .;,
, ,
Mobilization/demobilization (5%)
, --
,','- ~ ,. 26900
":;"'k::L . ~,.. "
;','
2.
Fencing Both Properties
Digs property
$22,300
$26 ,,400
F~ncefo~~C & SC Property
- . , .1,."... - -
Annual inspection of fence
$500
Replacement of fence (10% every 10 years)
$4,300
.
4.
Ground Water Monitoring (Yearly)
Sampling
$32,700
Chemical analysis
$38,200
.'
Evaluation of results
$ 2,000
I -
-------
-17-
5.
Surface Water and Sediment Monitoring (Yearly)
Sampling
Chemical analysis
Evaluation of results
$14,000
21,800
2,000
Construction Subtotal
$614,400
Bid contingencies
Scope contingencies
10%
20%
$ 61,440
$122,880
Construction total
$798,720
Permitting and legal
10%
79,872
Services during construction 10%
79,872
Total Implementation Cost
$958,464
$116,500
. Engineering Design Cost
12%
$115,015
. ; :A.JI 15.:
Total Capi tar~"Co6t
$1,073,480.,.."
Present worth gradual fence
replacement (10 years)
. --..~.".
$2,600
Present worth of 0 & M cost
Based on 30 years)
Will b& determined 2fter
completion of ground water
studies. .
Total Present Worth
$1,192,580
If negotiations with potentially responsible parties fail, trust fund
monies will be used to pay for 90% of thes~ costs and the State of Maryland
will finance 10% of these costs. Operation and maintenance will be the
responsibility of the State of Maryland one year subsequent to completion
of construction.
Schedule
Public Meeting
Comment Period Closes
Approve ROD.
9/11/86
9/15/86
9/86
-------
Responsiveness Summary
The format of the response is a listing of responses according to the
sources of comments. Responses are referenced to specific comments within
each source as appropriate.. The sources o~ comments on the following:
o
Public meeting in Cumberland, Maryland on September 11,
1986.
o
Heron, Buchette, Ruckert & Rothwell on behalf of Fairchild
Industries, Inc.
o
Kramon and Graham, P.A. on behalf of Cumberland Cement and
Supply Company.
o
State of Maryland Office of Environmental Programs, Department
of Health and Mental Hygiene.
All responses are enclosed as Attachment A.
,;'t::. . -j ; ~ :::;
.."- .
...-- p. r.:=:.
... -.
... ". .'
: .~; , ~ -; .
. -
.. .
,.-. '
: :-" .:., --
'"
.
-------
Attachment A
RESPONSES TO COMMENTS ON
THE LIMESTONE ROAD RIfFS
.' .
",': .
-. ~- J .. !
.. .
.'(.
. ,- .
'r -"
.'
. C",,,:" .'. ,.n r
'-. . ".L.' :
", ,"I ;:" ":
.
-------
Caments and questions raised dJring the Li1nestone Road Public Meeting
held. on September 11, 1986, are sllnI'llarized below. '!he public canment
period extended fran August 22, 1986 through September 12, 1986.
REMEDIAL ALTERNATIVE PREFERENCE
1., One resident recamnended that hares on Limestone Road be connected
to public water.
EPA Response: EPA's announcement of an interUn ~emedial alternative
does not preclude the possibility of a 1100k~p to city water for
the Limestone Road residences; further evaluation of the data is
needed before a final decision is made. .
2.
When will the decision be made on a final remedial action?
EPA Response: ve cannot estimate a t:imefrarre because v.e do not know
what we will find during subsequent. evaluation of the site data.
'!here mayor may not be ItDre testing or further studies, rot we need
to condJct further examination and evaluation of the existing data
before we make a decision on arry further action.
TECHNICAL CUESTIONS
1.
A resident of Limestone Road asked for details on where and how
ground water samples were taken.
EPA Response: The contractor designed a IOOnitoring well net\o.Ork
that would provide an idea of contamination leavingv~e site. A
total of- 21 IOOnitoring wells were drilled to differ~.n~ depths --
the deepest being 27~feet, and the nr::st.- shallow being 25 feet --
the average depth :w&s 125 feet. ResidentIal wells of varying depths
were also sanpled.
2.
".. .
. .' ,"
Did EPA examine the chlorinated solvents at the PEB level?
-
EPA Response.:
Yes. 2- - '.
3.
~ .
A question was raised regarding hydrogeologic stu:Hes of the aquifer.
EPA Response: 'Ibis is not an aquifer in the traditional sense.
There is fractured shale under the ground which makes the ground water
behave like an aquifer. But because of tile nature of the fractured
shale, it is extremely difficult to characterize the flow of ground
water. 'D'1is is why further study is required, and why only part of
the solution can be presented at this tjne.
4.
How long will the testing last, and wLl residents be provided test
results?
. .
EPA Response: We do not have an est:imate on the necessity, scope,
or length of time required for additional testing. '!he s~te will
provide residents with any testing results.
-------
2
5.
Several people expressed concern that their wells had dried up since
testing began during the RIfFS.
EPA Response: Because t.~e test wells are not used constantly, we do
not believe that they are stressing the ground 'teter system. The
wells were sanpled three times during the RI.
6.
was any air sampling conducted?
7.
EPA Response:' Not during the RI; however, sane air sampling was done
as part of the initial HRS process.
One resident asked if the state could take any necessary new water
samples now while the weather is dry.
State Response: New ground water sanpling will. ccmnence the week of
Septanber 15, 1986, and will be conducted as rapidly as possible.
.
8.
fbw much chlorofoIm was detected?
EPA Response:
It 'tes detected once at a low level.
PUBLIC HEAL'1H/ENVIRJNMENTAL CONCERNS
1.
How dangerous are the chemicals found in the ground water?
EPA/COC Response: The only' c~:>ntaninant level of concern was lead;
the concentrations of other' Contaminants' are not high enqugh to
cause concern. Dr. Abrahcm (COC) recamerided,- based on data he -had
seen, that tw::> residences need alternative sources of drinking water,
which has already been acoamplished. EPA will provide all residents
a synopsis of test well results.
COSTS/FUNDING ISSUES
. ,.' n ~
~s
. '!1".i.:. ',':-,1 ..
'-.J;.: '-. t:) :
1.
.
If EPA eventually does connect the Limestone ~ad residences to city
water, who pays for it?
EPA Response: If it is a Superfund action, the state will pay 10%
and the Fund will pay 90% of the cost. If PRPs agree (or are ordered)
to finance a remedial action, then the cost share will be negotiated.
2.
'!here \1IaS concern about the amount of noney spent to date - on the
project, withoot having a final cecamended remedial action.
EPA Response: As fa!;' as we know now, the drinking water is safe
(with the two exceptions noted above).
-------
3
0'lHER ISSUES
1.
Why was the Cumberland City Dump not included in the definition of
the site? It should be.
EPA Response: We cannot offer a final solution to the problem at
Lirrestone ~ad until the status of the dl.mp is resolved. The state
is addressing the t1Jmp question: it is in the nands of the state's
attorney.
2.
Has any testing been conducted at the dump?
EPA Response: Wa have done sate 1 imi ted ~rk at the dump.
particularly concerned abcut the flyash at the dump.
We are
3.
Why has the process taken so long? The problem first surfaced in
1979.
EPA Response:
EPA's involvement dates from 1984.
4.
What about city' and county liability in the properties?
EPA Res~nse: Transfer of cwnership does not release a person fran
responslbility under CERCIA.
s.
What abcut the level of TCE at Limestone Road vis-a-vis the ~burn,
MA case?
EPA/COC Response: . '!be "safe" level of TCE is 5 P~: in the ~OOrn
case, TeE has not yet been proven to have, a casual, relationship to
the health ananalies foond in the area. TCE has nO.t been found at
Limestone ~ad above EPA I S reccmnended action leve 15: there is no
irrimediate health. risk. "
. ..'"
.
'f'."
-------
Heron; Burchette, Ruckert&RQthwell
Suite 700.
1025 Thomas Jefferson Street. N .W.
Washington. D. C. 20007
(202) 337-7700
TWX 710-822-9270
SuiIIIOO
770 L ScnIa
SII:rInrID. CA 95814
(916) 446-1428
1400 MBank Tower
221 War SWh Sner
AusIiD. TX 78701
(512)4~
September 10, 1986
--- ..-- .
! .
, - -..~
- -'...
BY FEDERAL EXPRESS
Ms. Susan E. Belski (3HW16)
Compliance Officer
u.S. EPA Regio~ ~II
841 Chestnut Building
Philadelphia, PA 19107
~~~ ~
v_~ -
. ,-"",,,,,
;,......c """
,..., -..I""'"
ft-
..--.
f~~w::"- ~j
RE:
Limestone Road Site, Cumberland, Maryland
Dear Ms. Belski:
- .
This will respond on behalf of Fairchild Industries,
Inc. to the letter of Mr. Stephen R. Wassersug, dated August
11, 1986, accompany.ing the draft Remedial Investigation and
Feasibility Study (RI/FS) and inviting. comments .ther'!on no
later than September: 12, '1986 (as per. .a~vice~from your office).
. We wish to call your attention to the fact that
Fairchild has noted numerous detailed comments concerning the
RI/FSbut has limited the following response for the purpose of
addressing tl~e major endangerment issues as presented. In so
doing, it was our purpose to restrict this commentary to ~hose
matters which directly impact on the proposed remedial action.
However, during the course of further discussions of the RI/FS
and the proposed remedial action, Fairchild may, as it deems
necessary, address further comments in order to resolve any
issue presented.
.
General Commentary
As a gener:~l commentary the RI/FS report for the
Limestone Road site ~ontains a numb~r of assumptions and
. qualifications making it difficult to reach definitive
-affirmative conclusions as to site contamination and
endangerment. What does emerge from the data as a whole is
that the detected soil contamination on the site, both organic
and inorganic, has minimal impact on surface and groundwater
and, therefore, presents little or no endangerment to human
exposure. Moreover, the possible influence or contribution by
. .
-------
"MS. Susan E. Belaki (3HW16)
September 10, 1986
Page 2
the City of Cumberland dump to overall contamination in the
area raises significant questions as to source and
responsibility which have not been addressed.
The report contains a number of statements concerning
chromium and chromium sludgel/ but in the end the data does
not support a conclusion that chromium'p~ays any significant
role in environmental endangerment at, the site. In this
connection, we believe it important to note that the Background
statement in the RI (p. 1) that 110 tons of chromium sludge was
dumped on the site is not substantiated. Indeed, a further
statemer.t that 99 tons were dumped on the .CC&SC property and 11
tons on tne Diggs property is completely groundless. In
addition, while the report makes an assumption that chromium in
the soil is in the hexavalent form it is conceded this may be
incorrect (RI, pp. 6-33 to 6~34) and that soil chromium is
expected to be found primarily in the immobile trivalent form
(RI, p. 6-37). Accordingly, it seems only fair that the report
contain a statement that there is little or no endangerment
from the Fairchild sludge at the site.1/
Based on the data in the RI, it is easily understood
why the FS makes no selection as to a specific remedial
alternative. Perhaps the unresolved issue of the City Dump is
partly responsible for this but we~~lieve ~t more likely that
under the circumstan~es where little' or no real endangerment
could be concluded it was perhaps more judicious for the EPA
. contractor to review the range. of possible alternatives within
all five of the guidelines )?,;. ~!1~; National COhtingen~y Plan
(NCP) for ultimate selecti.on by RegJon .+.~l.. and/or. the. .
responsible parties. We.. ha~t~J, therefore, "c::areful~y. reviewed
wi th the aid of~ competent, consultants all of the'aata pre.sented
in the RI to pinpoint the real problem areas and attendant
risks and will address these for pertinent remediation which is
both cost-effective and consistent with the application of the
NCP. .
.
1. Th.is is perhaps because of the reported event (by the State
of Maryland) ~f illegal dumping of chromium sludge from
Fairchild Ind~stries' ~agerstown, Maryland, plant in 1981 which
triggered the listing of the site on the National Priorities
.List.. .
2. It must be recalled that at the time, 1981 and 1982, there
were many reports in the local news media concerning Diggs'
illegal dumping of Fairchild sludge raising citizens concerns
that this was the primary and perhaps only hazard at the site.
-------
Ms. Susan E. Belski (3HW16)
September 10, 1986
Page 3
If remedial measures are to be under~aken at the site,
t~en additional efforts to identify potentially responsible
parties need to be undertaken. The FS states that the Diggs
property was part of the city dump for many years. (FS,
p. 5-14) Therefore, it appears that the City of Cumberland may
be a responsible party in connection with the Limestone Road
site. In addition, potential sources of organic contaminants
have not been identified. Materials in EPA's files on other
PRP's suggest that these parties may have generated solvents
and waste oils disposed of on the site. Other wastes possibly
sent to the site (~., glass manufacturing wastes) should be
further analyzed to determine whether they are sources of
contamination at the site. .
1.
Adequacy of Investigation
Questions exist as to the adequacy of the site
investigation. The vast majority of the soil samples analyzed
were taken from subsurface material. On the other hand, all
background soil samples were collected from the top ten inches
of soil. (!!!. RI, pp. 3.-6 to 3-8) I1\ explaining the
differences between soil and shale with regard to
concentrations of certain ions, the RI states that the ions may
have been leached from th~ soil into the groundwater and
surface waters. (RI, p. 4-11) Therefdt.;'the.b~ckground'
surface soil samples may not be comparable to the on-site
subsurface soil samples;" It should also be noted that a
che~ical analysis of on-site shale seems appropriate in order
to pr,operly interpret'the sampling' results.' "
. ,1' '. : ," I .' :
There is settcius ci6nt~triabbut~~he ~aequaci of the;
hye rogeolog ic investigation.' . "'Tfie' 'RI states that' groundwater
movement in the shales appears to be dominated by fractured
flow. (RI, .p. 4-4) The primary fractures are perpendicular to
the observed groundwater gradients based on head measurements.
(RI, pp. 4-3 to 4-4, 4-8). Although a possible secondary
fracture set may allow flow along the same direction as the
gradient, it is not clear that the generalized groundwater flow
map (RI, Figure 4-5) represents the most probable
characterization of groundwater flow. In fact, the
hydrogeologic investigation indicates localized groundwater
flow diff~rent from the regional flow. (See Attachment A,
As~~ssment of Hydrogeologic Findings by Dr. Paul Grosser~ H2M)
-------
" :ls. Susan E. Belski (3HW16)
September 10, 1986
Page 4
i
2.
Endangerment Issues
The major endangerment issues at the site relate to
on-site soil and groundwater. (FS, p. 2-5) In order for a risk
of an adverse effect from a contaminant to exist, there must
be: (1) a source of the chemical; (2) a release of the chemical
from the source; (3) a receptor for the release of the
contaminant; (4) transport of the contaminants-from the source
to a receptor; and (5) exposure of the receptor at a level
sufficient to produce an adverse effect. (RI, p. 6-3)
A.
Soil
The remedial objectives for soil contamination are to
control migration to groundwater, to control migration to
surface water, and to minimize direct contact. (FS, pp. 2-6 to
2-7) The major organic contaminants of concern in soil are
benzo(a)pyrene and polychlorinated biphenyls (PCB's). (see FS,
Table 1) polycyclic aromatic hydrocarbons such as
benzo(a)pyrene have low solubilities-and high soil-water
partition coefficients, indicating a tendency to migrate very
slowly. (RI, p. 5-6)" Biodegradation of benzo(a)pyrene is also
possible. (RI,Table 5-2). PCB's have been found at the site
at Mtrace- concentrations only. (FS, Table 6-2) PCB's readily
adsorb to soil and have very low solubilities, and thus migrate
slowly. (RI, pp. 5-7 to 5-8) In addition, the PCB Aroclor
1242 is biodegradable. In conclusion, the major organic
contaminants are unlikely to migrate from the site through
groundwater.
The major inorganics of concern at the site are
barium, cadmium, chromium, copper, lead, manganese, nickel,
selenium and zinc. (FS, Table 1) The RI reviewed the
environmental behavior of the "indicator" contaminants barium,
cadmium, chromium, lead, nickel and zinc, and concluded that
sorption had a significant effect on the migration of each of
these metals. (see RI, Table 5-2) There~ore, concern regarding
migration ~f these constituents should be minimal. '
-(I]n the soil, chromium may be expected to be found
~redominantly in the trivalent form because of the presence of
ceducing organics." (RI, p. 6-33) As stated above, trivalent
chromium is immobile. The groundwater sampling results, in
. 'which chromium was not detected at concentrations considered
threatening to human health (RI, p. 4-25), support this
conclusion. -
-------
Ms. Susan E. Belski (3HW16)
September 10, 1986
Page 5
Future exposure to predominantly subsurface soils
would most likely occur if excavation or extensive erosion were
to take place. (RI, p. 6-7) The prospect of excavation can be
controlled with deed restrictions. The current "extensive"
vegetative cover should minimize the risks of erosion. (RI,
pp. 6-10 to 6-11). Fencing would also minimize direct contact
with contaminated soil and allow for further growth of
vegetation.
B. Groundwater
The remedial objectives for groundwater are to control
migration of contaminants to groundwater and surface water and
to minimize direct contaminant consumption. As stated above,
the on-site soil contaminants will tend to adsorb to soil. So
long as the risks of excavation and erosion are minimized, the
risks of migration of contaminants to groundwater and surface
water will have been adequately addressed.
The FS identifies five inorganic contaminants of
concern in groundwater: cadmium,-lead, manganese, nickel and
zinc. (FS, Table 1) Nickel exceeded EPA's acceptable daily
intake level in one sample from each of two drinking water
wells. (FS, Table 2-3; RI, Figures 4-14 to 4-17) "Of all the
toxic metals, only nickel appears to exhibit a trend even
though a specific plume cannot be identified." (RI, p. 4-23)
The report was unable to conclusively determine which filled
areas might be contributing. (RI, pp. 4-24, 6-22) The report
notes that a sample indicative of the leachate being generated
by the city dump had a significant concentration p£ nickel.
(RI, p. 4-24) Nickel could also be from local geological
materials native to the site in contact with the groundwater.
(RI, p. 6-22) The Fairchild chromium sludge did not contain
nickel.
The RI notes that the concentrations of zinc in
residential wells generally exceed the concentrations observed
in monitoring wells by one or two orders of magnitude. (RI,
p. 4-14) Zinc concentrations exceeded acceptable daily intake
levels only in residential wells. (FS, Table 2-3; RI,
Figures 4-14 to 4-17) No zinc plume was identified in the
analytical data. (RI, p. 4-14) Therefore, it is likely that
the zinc in these wells is attributable to a source other than
the landfill, area. - The RI identifies naturally occurring high
zinc concentrations and galvanized piping or tanks as among the
plausible explanations for the high zinc concentration in
residential wells. (RI, pp. 4-14 to 4-15)
-------
. Ms. Susan,E. Belski (3HW16)
September 10, 1986 .
Page 6
Lead in groundwater (as well as zinc) may have
originated from contact of the water with old or corroded
piping or solder, but the presence of galvanized piping or,
water tanks in the residential wells was not investigated.
(RI, pp. 4-14 to 4-15, 6-22, 6-32) Lead was detected in only
one monitoring well sample. (RI, Figures 4-14 to 4-16). None
of the drinking water well samples exceeded the maximum
contaminant limit for 'cadmium. (FS,'Tabl~ 2-3; RI,
Figure 4-17) The toxic inorganic constituents cadmium and lead
"appear sporadically in ,both monitoring and residential wells
'but show no consistent spatial or temporal distr ibution'." (RI,
p. 4-24) There is no consistent correlation between monitoring
wells, residential wells and groundwater flow paths to
conclusively support the contention that these constituents are
. migrating from landfilled areas. (RI, p. 4-25)
The RI states that the "analytical data do not
indicate a discernible trend relating high concentrations of
manganese in residential wells to landfilling operations." (RI,
p. 4-lS) The manganese levels are most likely from naturally
occurring geological materials at the site.
- .
Elevated levels of cadmium, lead, nickel and zinc were
found in soil samples taken from the Cumberland City Dump (RI,.
Figure 4-9); suggesting this site as a possible source of
inorganics in groundwater. Furthermore, cadmium, lead,
manganese, nickel and zinc in sediments were found in their
highest concentrations at location SD005, which rec~ives a
large portion of its contaminant input from the City Dump.
(RI, p. 6-36) The sole observations above background for
manganese, nickel and zinc were at this location.: (FS, Table l)
Despite the relatively high concentrations of cnromium
on the Diggs and the,CC&SC properties, chromium has not been
detected in groundwater at concentrations considered
threatening to human health. (RI,. p. 4-25) These results
support the conclusion that the chromium is immobile. In
conclusion, the levels of inorganics 'in drinking water rarely
exceeded the applicable standards. The mineralized groundwater
in the area of the site makes it difficult to draw any
conclusions regarding degradation attributable to landfill
areas.
:: ',~ I ,c.
Surface Water and Sediment
The FS concludes that the endangerment from surface
water contamination is minor since ingestion of surface water
would be extremely unlikely and since aquatic toxicity was not
-------
Ms. Susan E. Belski (3HW16)
September 10, 1986
Page 7
considered applicable to the surface water in either the CC&SC
or the Diggs property drainage streams (although it is
considered applicable to the North Branch of the Potomac
River). (FS, Table 1,. pp. 2-3 to 2-4)
The remedial objective for sediment is to minimize
direct contact. (FS, pp. 2-11 to 2-12) The sources of stream
sediments are precipitation from surface -water and erosion of
soils. If the surface water is not considered a contamination
problem, then the primary risk relates to erosion. Potential
erosion risks are adequately dealt with by fencing and deed
restrictions.
Proposed Remedial Action
Fairchild proposes that remedial action at the
Limestone Road site to be accomplished include:
* Deed restrictions and fencing of refuse areas of
Oiggs and CC&SC properties.
* Limited monitoring of surface water.
* Extension of city water supply to local
residences.
Based on the endangerment and risk assessments in the
RI report, we conclude that a limited remedial action above
outlined sufficiently addresses the real environmental concerns
at the Limestone Road site. As already stated in these -
comments, these areas of concern are the contaminants in the
soil and the possible effect of same on the groundwater.
Possible endangerment is limited to human exposure to both
media principally through direct contact with soil and drinking
.water consumption.
»
We agree with the FS analysis that this type of
response -- fencing and deed restrictions of the refuse-filled
area -- would reduce the likelihood of direct soil contact and
casual site access. (FS, pp. 6-10 to 6-11, 6-22 to 6-23) . It is
also significant that since the site has been closed to dumping
•.operations since 1981 most of the affected area is now covered
with vegetation. Restricted site access would allow the
vegetation to increase thereby naturally reducing possible soil
er.osion. Periodic monitoring of the surface water'from
-------
, '.MS. Susan E. Belski (3HW16)
September 10, 1986
Page 8
leachate seeps discharging from the base of the waste masses on .
both the Di99s and CC&SC properties for a. limited period of
time (annually for five ye'ars) should be sufficient to detect
any trend of contamination of these environmental media. .
While we had earlier investigated the feasibility of a
limited clay/soil cover over the soil contaminated areas, we
believe in view of the RI/FS findings and analysis that such an
alternative is inappropriate and not cost effective. The two
objectives cited for this remedial alternative are reduction of
water infiltration that may transport contaminants to
groundwater and reduction of contact with soil. Once the
affected areas are properly fenced the objective of reducing
soil contact by covering is redundant. In addition, it is
conceded in the (FS, p. 5-13) that the selective ncapn for the
CC&SC property would address less than 5% of the total volume
of water that moves over and th~ough the refuse ~ill. It is
also concluded that the effectiveness of similar capping of the
Di9gs property .cannot be estimated. (FS, p. 5-15) and that
ncorrelation of contaminant release reduction 'with capping
system is not possible for the soil and refuse matrix at
Di99S.. Finally, as stated earli~,.the fa~t that soil
contamination on both properties has minimal impact on
groundwater strongly suggests that any conc~rn regarding
transport of contaminants to groundwater through infiltration
is insufficient to warrant the expensive cover alternative.
Fairchild also believes that the groundwater quality
in the vicinity of the site, including the City Dump, may hav~
been influenced by natural background condition as well as
possible effects of landfilling operations that haye taken
place since 1962 when operations at the City Dump.commenced.
Accordingly, Fairchild recommends that modifications be made ~o
the drinking water supplies of local residences which would
constitute a response. to the natural progression of development
in the area. It is expected the City of Cumberland will
provide the resources needed for connecting the municipal water
supply to these residences. .
.
Once you have' reviewed these comments and
recommendations, we would welcome the opportunity to answer any
questions. We also believe it would be most fruitful to more
fully discuss the technical aspects of the RI/FS report and
these comments in detail toward the end of achieving agreement
"~ a proper and cost 'effective remediation.
"il/1YJ;J£L
;I~/Molleur
! .
Attachment
-------
H2M - Holzmacher, McLendon & Murrell, P.O.
a » n
ATTACHMENT "A
CONCLUSIONS
Regional groundwater flow, as traditionally based upon
hydraulic gradient, is in the northwest direction for this
area. Flow direction is further complicated by the geology of
the area (i.e., fractured shale and structural elements).
Further analysis of historical and possibly additional field
data is needed to understand these flow patterns, especially in
local areas.
Local flow patterns may render a clearer picture of actual
flow. This is evidenced by the CC&SC site where it is seen
that steep gradients demonstrate flow toward and discharging to
an unnamed tributary. At this site localized flow is towards
the southwest as opposed to regional flow to the northwest.
It is also unclear whether water percolated through the waste
mass on the CC&SC property will if -at'all reach the water
table. At this point in time, the well data directly
downgradient and beneath this location indicates that it will
not.
-------
INTRODUCTION
Comments are included herein on the hydr©geologic investi-
gation of the Remedial Investigation (RI) Report for the Lime-
stone Road Superfund Site, Cumberland, Maryland. The probable
regional groundwater flow patterns and localized groundwater flow
patterns near the Cumberland Cement & Supply Co. (CC&SC) are
discussed.
REGIONAL GROONDWATSR FLOW
The RI Report has obtained a voluminous amount of field and
historical data to support their interpretation of the regional
groundwater flow. However, these flow patterns are not clear-cut
in a fractured shale media.
_ A
Regional flow is typically based on the hydraulic gradient
which would be to the northwest at this site. At this particular
site the flow direction is complicated by the existing subsurface
(structural) geology and fracture patterns, ot the shale. The
latter items have probably more influence on groundwater flow and
need to be analyzed further. Another key (and controversial)
issue at this site is the anisotropic nature of the aquifer.
Structurally, the strike trends to the southwest-northeast
»
and the dip averages about 70° from the horizontal. This indi-
cates that the groundwater flow is perpendicular to the general
strike, which is unreasonable. Primary fracture patterns as
exhibited in Figure 4-4 of the RI Report also parallel strike,
but possible secondary fractures are perpendicular to strike.
-------
• mwnncih, P.C.
The structural elements just discussed require further
analysis to define vertical and horizontal flow patterns ir
groundwater. The State of Maryland made some pertinent comments
regarding this. Data is needed to understand the regional as
well as localized flow patterns, possible recharge points, and
artesian conditions. Presumably, Maryland has ready access to
such geologic information (historical data) and would be useful
to obtain.
Finally, a comment on treating fractured shale as porous
media. The consultant in the report is clearly aware of the
anisotropic and heterogeneous nature of the flow. The method
used was discussed in Appendix C (Snow's method employs aniso-
tropy for flow). Also, Freeze a-nd* Cherry claim it is a common
approach in field investigations to mathematically treat contami-
nant migration in fractured media as porous media of an isotropic
and homogeneous nature.
** •
PROBABLE LOCAL GROONDWATER FLOW PATTERNS AT THE CC&SC SITE
The regional flow, as stated earlier due to change in'water
level, is to the northwest. However, at the CC&SC site, local
groundwater flows from upland areas anjd discharges to the inter-
mediate stream just southwest of the site as indicated by the
groundwater contours (see Schematic Figure A>. It is assumed
that the major fracture patterns as depicted in Figure 4-4 of the
RI Report do not influence the flow in this local area.
Infiltration occurs via precipitation into the overlying,
more permeable fill at the dump site. The fill is overlying
-------
KOUMACHER. McLfiNOON * MURRELL, P.C.
fractured shale of lower permeability. The flow proceeds
vertically to the groundwater and is discharged to the stream
(see Schematic Figure B). Evidence of artesian conditions at
Well MW-12 (see RI Report p. 4-5) indicates discharge which is
probably due to topographic control.
This dump area is a ravine surrounded by steep gradients.
Natural runoff can occur from the north (City Dump) and to the
southwest as well as from the CC&SC site directly affecting the
stream. Interflow in the thin permeable soil layer is a small
contribution in addition to runoff since erosion occurs on the
steep slopes.
The fractures of Figure 4-4 of the RI Report indicate
secondary (possible) fractures near* the stream and a principal
fracture set just northeast of the CC&SC site. Remote sensing
data for this local site would aid in locating local lineaments
and surface fracture traces. It is assumed that aerial
photographs were used to locate the fractures in Figure 4-4.
*
In regard to structure, strike of the beds is north-
. - . •
northeast to south-southwest. Localized flow indicates com-
pliance with strike. It is assumed that the angle of dip is
approximately 70°.
-------
NOTf: T«t9in l.i 31.32,
-------
RESPONSES TO COMMENTS FROM HERON, BURCHETTE,
RUCKERT AND ROTHWELL -
(ON BEHALF OF FAIRCHILD INDUSTRIES, INC).
The agency agrees with the majority of the comments made on
behalf of Fairchild Industries, Inc. in reference to the
RI/FS for the Limestone Road site.
The following responses address comments made on a paragraph-
by-paragraph basis. Fairchild's comments in this set of
responses are sometimes paraphrased or" simply not repeated
to shorten the response. Actual comments are listed in a
letter dated September 10, 1986 from Richard R. Molluer of
the firm Heron, Burchette, Ruckert, and Rothwell. The
letter was addressed to Ms. Susan Belski, Compliance Officer
for ~he Region III, U.S. EPA.
GENERAL COMMENTARY, PAGE 1, PARAGRAPH 3
The agency agrees with the general comments made that the
RIfFS reports for the Limestone Road site contain assumptions
and qualifications that made it difficult to reach "definitive
"affirmative conclusions" as to site contamination and endanger-
ment. . .
The statement that the soil contamination onsite has minimal
impact on surface and groundwater and, therefore, presents
little or no endangerment to human exposure does not address
the possibility for future releases or changes in site phys-
ical conditions (such as excavation for future site develop-
ment) or changes in the amount or type of leaching water,
~hat could affect the circumstances of contamination or endan-
germent.
The agency agrees with the statement the contributions of
the Cumberland City Dump to overall contamination raises
questions as to the source of contamination and hence respon-
sibilities that have not been addressed.
PAGE 2, PARAGRAPH 1
The results of the endangerment assessment have shown that
if chromium-containing soil were to be ingested at a certain
rate, a significant endangerment to public health could result.
In this ir.stance, an endangerment to public health is considered
a form of environmental endangerment. The agency agrees
that the valence ~orm of the chromium that is present is
unknown, and recognizes that chromium may be present in the
less toxic, less mobile, trivalent form. However, this is
speculation only and cannot be confirmed with raw data. .
Therefore, it is not certain that the chromium on the CC&SC
property presents little or no endangerment.
1
-------
The source of the allegation that 99 tons of chromium containing sludge
were dumped is supported by a written report of an interview with a waste
hauler that' was conducted by the Maryland Department of Health and
Mental Hygiene during a sampling trip on April 23 and 24, 1981.
PAGE 2, PARAGRAPH 2
..
Yes, the agency agrees that the unreso~ved issue of the Cumberland City
Dump partially explains why the FS makes no specific selection of a
remedial alternative. However, the essential reason that the FS makes
no selection because the decision of the best remedial alternative
could only be made by U.S. EPA Region III after the pub~ic comments
were taken into account.
PAGE 3, PARAGRAPH 1
EPA has been conducting a potentially responsible party (PRP) search of
the site in an effort to identify PRPs and gain a PRP cleanup at the
site. EPA requests that if you have information which would assist EPA
in conducting the PRP search, that you provide that information to EPA
as soon as possible. Please also be advised that EPA is currently
reviewing its file information in an effort to identify any additional PRPs.
1.
Adequacy of Investigation
~ -" *
,':'i.
PAGE 3, PARAGRAPH 2
The RI recognizes the fact that background samples were taken from
different soil strata than thesubsur£ace~it~:sample.'~nd has presented
this as a limitation surrounding the interpre"tation' of the results. .~;.
, .
A chemical anaLysis, of the ons:Lee shale was no.e'cwns1dered as part of
the scope of work initially agreeed:upon by the EPA, St4te of .Maryland,
and CH2M HILL, because the problems currently- associated with. then'
assessment of groundwater contamination were not anticipated.
PAGE 3, PARAGRAPH 3
As far as we can tell, the only issue Dr. Grosser takes with the RI
report is the direction of groundwater ~ow being perpendicular to the
strike of regional structure. We have repeatly qualified this statement
throughout the RI report and acknowledge that flow paths other than the
assumed principal flow direction can and probably do exist. Based on
our review of Dr. Grosser's comments we are somewhat puzzled by
Fairchild's attorneys' comment on page three of their letter regarding
tbeir "serious concern about the adequacy of the hydrogeologic
'investigation." These concerns are not supported by Dr. Grosser's
comments as presented in Attachment A.
-------
2. Endangerment Issues _
PAGE 4, PARAGRAPH I
The agency agrees with the assessment of the major endangerment issues
relating to onsite soil and groundwater contamination.
A. Soil
PAGE 4, PARAGRAPH 2
The agency agrees with the summary provided of the remedial objectives.
Table 1 in the FS was a draft version that should be updated with Table
6-19 from August 8, 1986 version of the RI to include other members of
the polycyclic aromatic hydrocarbon familiarity of chemicals. These
chemicals were initially not addressed because of differences of opinion
found in guidances on their quantitative assessment. Inclusion of
PAH's in the FS does not alter the curent status of the remedial
alternatives proposed.
The agency agrees with the supposition that the major organic contaminants
are unlikely to migrate from the site through the soil, although it ,
does* not presuppose that the migration of chemicals could not occur at
some future time.
PAGE 4. PARAGRAPH 3
The statement that "concerns regarding migration of the major inorganic
contaminants at, the site should be minimal: is not entirely agreeable
to the agency. Although the inorganic contaminants are probably current
being influenced by sorption, and as such have not migrated to the
groundwater, their sorption depends upon a variety of changing variables
such as the pH of the leaching water, the oxidation-reduction potential
of the soil and leaching water, the microbial activity in the soil, and
the organic content of the soil. Therefore, the agency contends that
the migration of the inorganic contaminants, although not currently
evident to a significant estent, may in the future become more than a
minimal concern.
PAGE 4, PARAGRAPH 4
Chromium was not detected in the groundwater at concentrations considered
threatening to human health. The agency has offered a possible, but
not certain, explanation that the reduced for of chromium may be
complexed with organics and hence less mobile.
-------
PAGE 5, PARAGRAPH 1
Capping would further minimize infiltration into the contaminated areas,
besides minimizing direct contact. Fencing will only provide site security.
B.
Groundwater
PAGE 5, PARAGRAPH 2
As described previously in response to the comment on Page 4, Paragraph
3, the ~gency does not consider the migration of inorganics unikely
although it does agree that minimizing the possibilities for excavation
and erosion will lessen the likelihood of contaminant migration to
groundwater and surface water.
PAGE 5, PARAGRAPH 3
The Agency does not disagree with points contained in tbis paragraph.
PAGE 5, PARAGRAPH 4
The presence of zinc in the residential well groundwater may have
attributable to naturally occurring sources, conveyance pipes, storage
tanks, or the landfill area. Data limitations have resulted in the
inability to characterize the source of the zinc further.
PAGE 6, PARAGRAPH 1
The agency agrees with this paragraph, but calls attention to the
instances where lead exceeded Interim Primary Drinking Water Standards.
PAGE 6, PARAGRAPH 2
The agency agrees with the statements in this paragraph.
PAGE 6, PARAGRAPH 3
Elevated levels of arsenic, barium,. cadmium, copper, lead and silver
. .
were found in the fly ash and soil-like material sampled from the
Cumberland City Dump. The RI suggests that the fly ash material could
be easily transported via wind and water borne routes and, therefore
cause elevated concentrations of the above elements in the soil and
sediment. Groundwater in contact with this waste mass could be a source
of the inorganics.
3
-------
Page 6, PARAGRAPH 4
The agencx agrees with the first statement of this paragraph and has
addressed the question of chromium's mobility in the response to the
comment on Page 4, Paragraph 4.
The agency is in concurrence with the option that the mimeralized
groundwater in the area of the site makes in difficult to draw conclusions
regarding groundwater degradation attributable to landfill areas.
Certain levels of cadmium, lead. manganese, iron, nickel, and zinc in
the groundwater exceed applicable standard and or acceptable daily
intake rates.
C.
Surface Water and Sediment, Page 6, Paragraph 5
The agency agrees with the statements made in this paragraph.
PAGE 7, PARAGRAPH 1
. The agency does not agree that potential erosion risks are dealt with
adequately by fencing and deed restrictions alone. This is because of
the steep nature of .the CC&SC property above the drainage stream. Deed
restrictions will allow the further growth of vegetation that will
determine erosion, but will not solve the problem in a direct fashion.
PROPOSED REMEDIAL ACTION, PAGE 7, PARAGRAPH 2
The agency agrees that the remedial action at the site should include'
the articles mentioned, but feels it should not be strictly limited to
these actions.
PAGE 7, PARAGRAPH 3
Again, the agency agrees that the remedial action at the site should
include the articles mentioned in paragraph 2 of page 7 but maintains
that other actions are also necessary. The agency agrees that
contamination in the soil and the possible effect of the contaminants
on ground water are major environmental ~oncerns at the site.
PAGE 7, PARAGRAPH 4
The agency agrees with the statements made in this paragraph, although
it has not determin~d a sufficient time period for monitoring. .
"
3
-------
PAGE 8, PARAGRAPH 1
EPA disagrees with this paragraph and has included capping as part of
the selected interim remedy. The cap will minimize the leaching of
contaminants from the soil into the ground water and will control the
erosion and migration of site contaminants from site soils into surface
waters.
PAGE 8, PARAGRAPH 2
EPA and the State are proposing additional 'hydrological studies to define
movement of ground water in the area. Once these studies have been com-
pleted, EPA and the State will. evaluate future remedial actions.
GLT611/13
.
4
-------
LAW OF'F'ICE:S
KRAMON & GRAHAM, P. A.
ANOREW JAY GRAMA"'..
JA"'ES M. KR""'ON..
LEE r-j. OGBURN
JEF'F'REY r-j. SCHERR
NANCY E. GREGOR-
JAMES P. U\.WICK.'
P..,\.,p M. ANOREWS
GERTRUOE C. BARTl!:\.
MARI\.YN HOPE F"SHER'O
SUN LIII'E BUI\.OING
C...AR\.ES CENTER
BALTIMORE:, MARy'LAND 21201
(301) 752-6030
BEL AIR OF'F'lCE'
112 SOUTH MA'N STREET
BEL AIR, MARYLANO 21014
(301) 879-5040
(30') 838-9095
TE\.ItCOP' ER
(301) 539-1269
TEI,.ECOPI ER
(301) 838-9298
. ..""SO AOWITTI:C I N NT
-410.50 AOMITTED IN QC
t .4.10.50 ...OMITTI:O IN "..I
0....50 AOMITTED I H CA
September 12, 1986
FEDERAL EXPRESS
Ms. Susan E. Be1ski (3HW16)
Compliance Officer
united states Environmental
Protection Aqency
Reqion III
841 Chestnut Buildinq
Philadelphia, Pennsylvania
~;~p
- '~..--
"". ,..- """!
. .' , ".. ..;
.....
19107
Re:
Limesto~e Road Site
CUmberland, Maryland
3HW16
CUmberland Cement
and Su~~lv Com~anv
Dear Ms. Belski:
I write' on behalf of CUmberland Cement and Supply'
Company ("CUmberlana Cement ") in response to a letter dated
Auqust 11, 1986 from Steven R. Wassersuq. Mr. Wassersuq's
letter accompanied the draft RIIFS respectinq tne
above-mentioned site and indicated that EPA was interested in
comments reqardinq the RI/FS. Your office has reqUested such
comments be forwarded no later than the date of this letter.
As a prefatory matter, Cumberland Cement adopts the
discussion contained in the "General commentary" section of
the letter dated September 10, 1986 to you from Richard R.
Molleur, Esquire, counsel for Fairchild Industries, Inc.
Cumberland Cement, of course, reserves the right to supple-
ment those comments as future discussions and analysis may
'.arrant.
As a further comment, CUmberland Cement has strong
reservations about the validity of the cost estimates for
certain major components of the assembled alternatives in the
F5. The estimates prepared by EPA's contractor are grossly
understated. At CUmberland Cement's request, a respected,
interstate enqineerinq and construction firm with operations
-------
Ms. Susan E. Belski
September 12, 1986
paqe Two
in Western Maryland prepared estimates tor projects listed in
Tables 5-3 (soil alternatives evaluation matrix) and 5-4
(qroundwater alternatives evaluation matrix) ot the FS. The
Western Maryland tirm, which has extensive experience in
undertakinq such projects in thereqion where the site is
located, determined that the actual' costs of the proposed
alternatives far exceed the estimates set torth in the FS.
. For example, the Western Maryland firm estimated
that the costot a clay cap -- not includinq topsoil -- tor
the Cumberland Cement parcel ot the site would be
$655,000.00. However, the FS estimate lists the capital.cost
tor that same portion ot the site at only $181,500.00. (FS,
Table 5-3). Further, EPA's contractor estimated that the
capital cost of providinq an alternate water supply, by means
of extendinq the City of cumberland water distribution system
to the Limestone Road residents, to be only' $176,800.00.
(FS, Table 5-4). The Western Maryland firm, however, esti-
mates that the same work will cost between $450,000.00 and
$500,000.00. Finally, the construction of a surface water
interception and diversion trench -- a remedial alternative
that EPA has made clear it does not intend to pursue -- is
estimated by the Western Maryland contractor to have a total
cost ot $700,000.00; the FS estimated the capital cost of
that diversion system, a major undertakinq, to be only
$390,000.00.
For obvious reasons, the validity of the cost
estimates prepared by EPA's contractor ,is clear~y suspect.
The astonishinqdiscrepancy'betweeri-the two' sets of estimates
compels the conclusion that further detailed and independent
analysis of the assembled alternatives must occur before
cumberland Cement can fairly be expected to participate in
any voluntary plan for remedial action.
I a1so write to advise you that cumberland Cement
concurs in' the discussion enti tlea "Proposed Remedial Action"
in Mr. Holl.ur's letter ot September 10, 1986 to you.
cumberland Cement believes that, as qenerally outlined, the
proposed action will be an adequate response to the
environmental circumstances at the site. As discussed in
my Auqust 26, 198~ letter to you, all the interested parties,
and the various qovernmental units, will need to address
allocation of costs and responsibilities for the preparation
of the RI/FS and the execution of any remedial action. Con-
sistent with the purpose and thrust of CERCLA, remedial
action must be cost effective and cumberland Cement's
-------
. --------=---- ----_.~~
Ms. Susan E. Belski
september 12, 1986
paqe Three
participation in any such plan is inexorably bound, of
course, to its financial ability to so participate.
I look forward to discussing these comments with
you in the near future, in the hope that an appropriate con-
clusion can be reached soon respecting remedial action at the
Site.
Sincerely,
(J&«. ~
Philip M. Andrews
PMA:jac
cc: Mr. Charles S. Steiner
w. Stevens Hldey, Esquire
.
- .
-------
DRAFT RESPONSES TO COMMENTS FROM KRAMON AND GRAHAM
(WRITING ON BEHALF OF CUMBERLAND CEMENT
AND SUPPLY COMPANY)
Comments by Kramon and Graham pertain to selected cost esti-
mates presented in the FS. The FS cost estimates are based
on numerous assumptions regarding size, location, physical
conditions (such as soil depth and applicable construction
methods), health and safety requirements, climate, availabil-
ity of construction materials, etc. Cost estimates prepared
in the FS are for comparative purposes'. It is probable that
the cost estimates will change as details of alternatives
are developed through the predesign and design process.
GLT611/12
.
-------
I /''": -t-'~'-"'~
. , ....... II, -~_......_~. - ~
v---' -"'or:., (; ~..~ #$,:,"'\~' ~. ' . ,
~,;:/- ,:/-... ';/ \';f:{~-UJ~;~; . /; ~/{~ ~.;'" J
J(7/{C ft" '{~,~.r!t~~~JJ,l:: \ J/lt£."~-(?l~l£b
~..~-. ; £
. ,,-";;-:~.:;./.;/. y
OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WEST PRESTON STREET. BALTIMORE. MARYLAND 21201 . AREA CODE 301 . 2255700
TTY FOR DEAF: 8alto, Area 383.7555
D.C. "'1etro 565.0451
':'cele Wllzac~. R.N.. M.S. Secretary
William M. E,cnbaum. Assistant Secretary .
July 28, 1986
Ms. Stephanie Del Re
Remedial Project Manager
U.S~ Environmental Protection
Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Dear Ms. Del Re:
This letter is in response to the draft Remedial
Investigation/Feasibility Study (RI/FS) for the Limestone R03d
Site. On July 15, 1986 you arranged a technical meeting with
your staff and the consultant to discuss the draft.Remedial
Investigation. Two of Waste Management Administration personnel
attended this meeting to ask questions about the consultant's
report. The Feasibility Study was not addressed at this meeting
and you indicated another meeting would be arranged to discuss
this document. This letter contains comments on our major
concerns with the draft Remedial Investigation. Our Comments are
listed in two categories: general comments concerning the overall
rep6rt and specific comments relating ~o certain parts of the
report.
I.) General Comments
1) The report is not direct enough in its
wording. Too often vague terminology was used
that detracted from the impact of the report.
In later drafts the use of words such as
.possibly., .probably., and .most likely. should
be avoided. If there is doubt concerning a
. specific statement or if there is no .
supportive data, then this should be stated.
-------
2) Tl)e report does not address all
possibilities or alternatives when making ~ts
conclus ions. Dur ing our mee t ing it was 'J.ear ned
that many aspects had been considered, yet only
one was presented in the report. All pertinent
aspects addressed by the consultant should be
included into the text of the report.
3) The report lacks significant support data
~hich is needed to make its conclusions. Some
of this data is merely historical (such as
references that discuss t~e.geology of the area
and the nature of the bedrock), some would be
illustrative to the reader (such as: a) .
temporal and spatial maps of investigated.
parameters, b) maps that indicate changes in,
stream quality related to specific site areas,
etc.), while some data missing are crucial to
the study. There is a lack of good background
sample data representative of the area.. Finally,
no definitive data are presented that confirm
that contamination of the sites is attributable
to the study area.
4) The Hydrogeologic Assessment of the Limestone
Road Site is over simplified. Although the report
acknowledges that the bedrock beneath the site is
well fractured, the report treats the site as if
it were a porous media aquifer. More spec.ific
comments concerningt~is are discussed later.
5) There are inac~uracies throughout the report
which needed to be corrected. First, the terms
mg/kq. and ug/kg are used incon~[stently. "In
addition, all figures should be ~~early labeled
as ppb or ppm. A number of values on the tables
are incorrect and some cited values in the report
do not match the tables.
6) It is unclear what background concentrations
are being used in many of the Tables a"d Figures.
.For example, in Figure 4-15, CC , SC Property
Monitoring Well Organics, what are the background
concentrations for eacn of the parameters being
investigated, and where were these values obtained
from? This type of information would be extrp.mely
useful to the reader.
7) One aspect not considered in the report is
that inorganic aqueous data from the monitoring
well decrease with tim~ from Phase I to Phase III.
An evaluation of this must be made in the report.
8)
As was discussed 'by your toxicologist there
- 2 -
-------
II.
..
are substantial concerns in Chapters 5 & 6 of the
Remedtal Investigation. A few of the p2inLS are
as follows: The Contaminant Transport and Fate
Chapter does not adequately address the environ-
mental issues. In the Endangerment Assessment
there is overestimate of the risk of ingestion.
EPA has a major concern of using arsenic in the
manner addressed in the report. It lacks detail
on fugitive dust and dermal considerations. A
complete pUblic health evaluation needs to be
addressed. Many of the statements are "boiler
plate", and need to be sit~ specific.
9) The changes required to improve this
Remedial Investigation (RI) will have a direct
impact on the Feasibility Study (FS). In at
least two places the FS states the "report is
based on the information and data presented in
the Remedial Investigation Report." Since th~
RI has to be rewritten, and many of the changes
made in the RI have to be incorporated into the
FS, we will reserve our comments on the FS until
the next draft of the RI is completed. We assume
that is why the FS was not discussed at the July
15th meeting and why another meeting will be
arranged to discuss the FS.
Text Comments
1)
p-3 Remedial Investigation
The text states that 16 monitoring wells were
installed on site, when in fact 21 monitoring
wells were used for the study.
2)
p-3 Hydrogeolog ic Inve s t igoa t ion.
The text recognizes that the shales are fractured,
yet the discussion of this paragraph considers the
simpler porous media groundwater flow. It is
unreasonable to make this assumption, knowing that
the shales are fractured.
.
3) p-4 through p-6 - Various inorganic and
organic constituents were noted to be above
background concentrations. However, no definitive
background levels for these constituents were
found at the site in the sediment, soil, surface
wa terO and groundwa ter ana lyses.
4)
p-9 City Dump Effects
The conclusions that groundwater is in contact.
with the Cumberland City Dump (CCD) waste is not
- 3 -
-------
substantiated later in the text. If this
conclusion is in fact true, it should be .
documented in later sections of the report.
5) p-10 Private Water Well Contamination
Although some inorganics were detected, they are
isolated in occurrence and have more than one
possible point source, which is not addressed in
the Executive Summary (i.e. natural background,
plumbing , etc.}.
6) p. 2-1 Location
Although the Cumberland City Dump (CCD) is
excluded from the Remedial Investigation (RI),
it does not interfere with making appropriate
conclusions for this RI.
7) p. 2-4 Geology
The discussion on the geology of the area is not
adequate. This section should be subdivided into
separate sections: structural geology,
stratigraphy, etc. In addition, the deformational
history and the resultant attitude of the rocks
at the site are too brief and sections pertaining
to the geologic history and geologic setting
should be added. The depositional environment of
the sedimentary rock has nothing to do with the
structural geology. (See attached references for
further information regarding the study area.)
8) p. 2-6, 2-7 Groundwater
The crest of Irons Mountain is only 'a natural
surface water divide. It cannot be assumed to
be a groundwater divide because of the fractured
nature of the shales and the structural geology in
the area.
Groundwater flowing from the Uplands to the
Potomac River is too general of a statement,
and not at all descriptive of site conditions.
Is the flow parallel to strike or normal to
strike? Does the groundwate'r discharge to
intermediate streams prior to reaching the Potonfec
River or reaching the Potomac River or does it
discharge directly to the Potomac River?
The discussion on the recharge-discharge area is
unclear. Where are the recharge-discharge areas
and how were they determined? Why is infiltration
restricted to exposed bedrock only?
- 4 -
-------
The effect of clays filling in fractures and
reducing groundwater infiltration/permeability
through the fractures is minimal. The fact that
the clays are surficial in occurrence, soil cover
is thin and steep slopes in the area allow for
significant runoff, reduce the effects of the
fractures being infilled.
The use of the term solution channels is
misleading. Solution channels are associated
with limestones and sinc~ there are no referenced
carbonate units present in these shales, this
terminology should not be used.
It cannot be assumed that upgradient and cross-
strike limestones and sandstones recharge the site
area. These units are up to one-half of a mile to
the east, are well fractured themselves, and dip
steeply 'beneath the site. Therefore, recharge of
these units may go elsewhere other than
downgradient to the site. To assume that water
flows normal to the strike (and thus normal to the
dominant fracture trends parallel to bedding) is
unrealistic. Furthermore, the Oriskany Sandstone,
which separates the shales on-site from the
'upgradient limestones, is well fractured and
extremely porous. Any recharge in the limestones
that might flow normal to strike along possible
horizontal pathways would be intercepted by the
Oriskany Sandstone.
Finally, since bedding plane frac~ures are
present, and since bedding dips steeply to the
west, there may be significant deep recharge both
upgradient and on-!ite.
The term phreatic is not useful in describing
groundwater condicions at the site. Groundwater
conditions can be better described as being an
unconfined aquifier with localized flowing to non-
flowing artesian conditions.
.
9)
p. 2-10 Land Use
The term .household - type hazardous wastes. is
mentioned in the section and some concern is
raised abQ~t this waste. Is the concern valid
and aie the landfill wastes truly hazardous?
10) p. 2-10 Events leading to the Superfund
Classification
This section mentions the Region III FIT
- 5.-
-------
conducting a preliminary assessment, when in
actuality it was a site inspection with a .minor
portion on the preliminary assessment.
11) p. 3-4 Hydrogeologic Investigations
The characterization of aquifer conditions and
groundwater flow direction is incomplete. These
points must be addressed fully, (i.e. What are all
the potential subsurface pathways and
groundwater flow direction?)
12) p. 4-2, 4-3 Geology
This section should be labeled " Geologic Aspects
that affect Groundwater*. The exact strike/dip of
the rock is not given. Some representative
measurements and their locations should be given.
Why i« the bedrock highly fractured in the upper
10'-15' zone? Is that due to weathering,
drilling, etc.?
Where were the horizontal fractures that were
mentioned observed, and what are they related
to? Are they a surface phenomena or do they
extend to depth? Why are only a small percentage
of these horizontal fractures related to
mechanical breakage?
What are representative orientations of all the
^fracture sets? (A table with this information
should be presented.) Did any of the fracture
sets have distinctive markings, such as,
weathering, cementation, mineral growth or were
they all fresh?
Regional fracture trends should be researched and
presented in the discussion of fractures. (See
attached references.)
*
Fractured rocks cannot be treated entirely as a
porous media as stated.. With regards to the
Limestone Road Site the rock is not uniformly
fractured in either direction or intensity. The
shales are dominately fractured parallel to
bedding, and different lithologies probably
develop these fractures better. Hence, there are
heterogeneties in the rock at this site which
might create an anisotropic flow, rather than the
simpler porous media flow described.
13) Figures 4-2, 4-3. 4-4
- 6 -
-------
These figures should be labeled as being normal to
strike. In addition, the strike direction.of the
rock should be shown on these figures. ~
14) Figure 4-5
The flow of groundwater is construed to be normal
to the groundwater contour lines. Groundwater
flow such as this is both normal to the strike
of the rock and the dominant fractures present.
According to Freeze & Cherry (1979) groundwater
flow in a fractured media that has a known
heterogenity can be in a' direction other than
normal to the equipotential lines.
15) p.4-4, 4-5 Groundwater Hydrology
It is assumed the water is moving normal to
strike. Yet, the best fractures present at th«
site are parallel to strike. This has to be
explained.
An important assumption is that the fractured
shales can be treated as a porous media. Although
the spacing and intensity may be treated as being
homogeneous (although it is not proven), the
orientation of the fractures is dominantly in
one•direction. Therefore, groundwater flow in the
shales can only be treated as a porous media
parallel to the fracture orientation.
The fact that monitoring wells in the valleys are
under artesian conditions suggests that some type
of control is present on the groundwater.
Assuming a porous media, the artesian conditions
would not exist.
The computed values for horizontal and vertical
groundwater gradients should be referenced.
It should be stated more clearly that borings A-l,
B-l, C-l, 0-1 are also monitoring wells MWA-1,
MWB-1, MWC-1, MWD-1.
»
The variability ?of both the vertical and
horizontal hydraulic conductivities argues
strongly against a porous media condition.
This must be explained.
16) p. 4-7 thru 4-11 Hydrogeochemistry
Throughout this section no chemical analysis
of the on-site shales was done. The lack of
knowledge of what the shales contain and the fact
- 7 -
-------
that no up-gradient wells are present hinder the
ability to assess the background contribution of
inorganic constituents. These facts should be
brought out more clearly.
the assumption that different shales will
contribute varying amounts of inorganics is
misleading. Since these are all dark shales,
deposited in similar environments, with similar
source areas and a similar geologic history, the
variance in inorganic constituents should be
minor . -
Due .to the lack of a definite point source of
contamination, the report assumes that inorganics
in DW-7, DW-10, DW-14 are due to rock
influences. However, there are other wells in the
same area without an inorganic problem. In
addition, DW-7 and DW-10 are the deepest wells
(4501 and 697', respectively). Therefore,
these two wells may be intercepting a deeper flow.
Even though the residence time ajid the travel
distance of the groundwater is important in terms
of inorganics in the groundwater, these aspects
are not that critical. First the distance
separating all the residence wells is not that
great and secondly, the residence time of the
groundwater is not that substantial, considering
your own groundwater velocities in Appendix C.
A natural occurence of zinc cannot fully explain
the zinc in the residential wells. First, if the
rock is the source, then there should be a fairly
uniform concentration. Second, there are several
nearby residential wells that don't have zinc.
Third, all the wells with zinc are greater than
200* and the wells without zinc are less than
100*. All these points need to be addressed.
17) Table 4-3
Many of the average valu.es do not agree with the
actual values. In addition, many of the values
are decreasing in- concentration chronologically
from Phase I thru Phase III. All these aspects
should be explained.
18) p. 4-15, 4-16 Soil Contamination
TP-10 and TP-30 on the CC & SC property do not
exhibit the highest values for arsenic, lead or
barium as stated in the text. TP-18 on the
Diggs property does not have the highest value
-------
for arsenic or barium as stated in the text.
Statements using values from the charts-must be
ver ifiable.
19) p. 4-17 thru 4-19 Organics
Several things in the text are implied but are not
verified by the figures.
a) Many test pits on CC & SC property have
organics and TP-10 and.TP-30 are not the
only isolated areas.
b) All the test pits on the Diggs property
show similar concentrations of organics.
This distribution of organics needs to be
explained.
c) Why does the text use four soil borings,
rather than use the thirty-four (34) test
pit results to characterize the organics on-
site?
20) p. 4-21 Inorganics
The text states the "source of lead in
residential wells is unknown." Rather than
draw on possible assumptions, this source
should be investigated (i.e. solder, piping,
etc.)
21) p. 4-26 Summary & Conclusions
Is the use of mg/kg correct or is the values
ug/kg. These also need to be stated, in ppm
or ppb.
22) p. 5-1 Migration Pathway
Migration pathways of the groundwater is
oversimplied. The use of porous media with
groundwater flow perpendicular to the
equipotential lines must? be corrected. What
flow paths do which residents lie along? Because
of earlier comments, not much credence can be put
into Figure 4-5. What is the contribution of
inorganics to the surface water and stream
sedimen.t adjacent to,and below each of the sites?
This should and can be mapped.
23) Figure 5-1 thru 5-7
These are an over simplification of site
conditions. The more likely pathways should be
-------
shown.. Shouldn't these figures be referenced?
24) Table 5-1
This table would mean a lot more if it was done
chronologically (i.e. separate Tables for Phase I,
Phase II and and Phase III) and include the
concentrations of the measured parameters. This
would enable the reader to observe long-term
and seasonal aspects.
25) p. 5-2, 5-3 Indicator Chemicals
It states that chemicals selected were found
elevated above background. What were the
background levels and locations, so comparison
can be made? All of this needs to be discussed
more thoroughly.
26) p. 5-4 thru 5-8 Indicator Chemicals Transport
& Fate
Although the potential exists for volatiles,
phenolics, base/neutrals, pesticides and PCB's to
enter into the groundwater, it should be made
clear that only inorganics have been found in the
groundwater.
The FIT Report is referenced concerning organic
contamination. This data should be included in
the report.
Why would dissolved metal ions move slowly in
groundwater that is reported to have high
velocities. Conditions that inhibit metal ion
migration should be explained. Have the effects
of sorption and precipation been observed?
27) p. 5-9 Limitations of the RI
The lack of a good set of background samples to
compare the sample analysis with severely limits
the RI. With such a large site with possible
multiple contributors this aspect should have been
a priority.
28) Table 6-1
This table would mean more if it was done
chronologically and if the concentrations were
included.
29) p. 6-28 Summary
- 10 -
-------
How often, where/ and in what concentrations was
chloroform found? • - "
30) Technical Memorandum $6, Vol. 2
Either in this memorandum, or in the main body of
the report, a complete, discussion of the sampling
techniques and rationale used should be given. It
is unclear as to how and when water levels were
measured. Were all the wells measured prior to
sampling, or were the water levels measured at
each well cluster during sampling?
31} The limitations of using filtered sample
should be discussed in the report. In addition,
to qualify the filtered sample results, the
turbidity values of each of these samples should
be given. If no measure of turbidiy is available,
then a rough estimate of clear, cloudy, etc.,
should be given.
32) To make the review of the monitoring well data
easier, all the data should be included into one
table. For example, information needed are; well
number, well depth, casing elevation, bottom
elevation, grout seal depth, screened interval,
water level measurements for Phase I, Phase II,
Phase III, and well yields. Also, a discussion of
which wells had good recharge versus those with a
limited recharge capability should be given.
The above comments have been offered to improve the draft RI
for the Limestone Road Site. These comments are meant to be
constructive and in no way are they intended to be critical of
the report or its data. If you have any questions, .please
contact me at (301)-225-5700.
Sincerely,
John W. Koontz, Administrator
Enforcement Program
JWK:jm
cc: Mr. Ronald Nelson
Mr. Frank Henderson
Mr, Robert Creter
Mr. David Healy
Mr. Ted Meyer
- 11 -
-------
OFFICE OF ENVIRONMENTAL PROGRAMS
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WEST PRESTON STPEET • BALTIMORE. MAPV_A\'D 2^201 • AP£A CODE 30^ • 225-5700
™v =.~.p ~EAF- 3d'to Area 333-7555
Aaeie Wilzacx. R.N.. M.S.. Secretary •'• : :-~ '•
September 10, 1986
Ms. Stephanie Del Re
Remedial Project Manager
'J.S Environmental Protection Agency
Region III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Dear Ms. Del Re:
We have received and reviewed the second draft of the Remedial
Investigation on the Limestone Road site. Generally, the second draft
reiterates the findings of the first draft and continues, to apply a gloss
of assumptions to groundwater flow, local geology and the extent of
contamination.
The following are the State's comments, first general and then the specific
comments:
I. General Comments;
1. This comment has been addressed. The second draft of the report has
been made more direct.
2. The report has presented and considered alternate hypotheses for the
data. However, the report is not thorough in its assessment of all the
different alternatives.
3. This comment has not been addressed.
4. The hydrogeologic assessment has been drastically improved in the
second draft of the RI. However, there are still some concerns with this
section (see the following specific comments).
-------
Page 2
S. This comment has been addressed and it appears that most of the
inaccuracies of the report have been corrected in the second draft.
6. This comment has not been addresse.d (see the spec ific comments, no. 3).
7. This comment has not been addressed (see the specific comments, no.
17).
8.
Some of the concerns of this comment have been addressed.
9.
This. comment has not been addressed.
II.
Specific Text Comments:
1.
This comment has been addressed and corrected.
2. This comment has been addressed and the second draft of the RI now
reflects WMA's concern that groundwater may be moving parallel to fractures
in the bedrock.
3. This comment has not been addressed. Various organic and inorganic
constituents are pres~nt in samples of sedi~ent, surface water, soil, and
groundwater that were presumed to be background. Secondly, a location
considered in the text as background has parameters labeled as > or Sx>
background. How can this be?
4. This comment has been addressed and now the RI states more clearly how
it concluded that groundwater was in contact with the contents of the
Cumberland City Dump.
5.
This comment has been addressed.
6. This'comme~t has not been addressed. ~1A still maintains that
appropriate conclusions can be made without the in~lusion of the Cumberland
City Dump into the RI. There is ample eviden~ present in the RI to make
some definite conclusions and responsible recommendations.
7. This comment has not been addressed. There is a large body of
background geological information pertaining to this area that has not been
consulted. At a site where the geology is as complex as Limestone Road (by
the RI's own admission), a thorough understanding of the site is needed to.
evaluate the flow of groundwater and the movement of contaminants from the
site.
-------
Page 3
8. This group of comments has been addressed; however, the entire section
on Groundwater is poorly rewritten. There are whole sections that have
been duplicated, some sentences are poorly written, and the thoughts
between paragraphs are poorly connected.
a. This comment was addressed but the revision is still inadequate.
What type of divide is Irons Mountain and what is its importance in
separating the Cumberland and Warrior Mountain Water Provinces? Isn't this
merely a surface water divide?
b-f. These comments have been addressed.
g. This comment has not been addressed. Although the report is
technically correct in using the terms "phreatic" and "vadose", these terms
are not at all descriptive of the site aquifer conditions.
9. This comment has not been addressed. The RI still raises the issue
that the Cumberland City Dump contains "house-hold hazardous waste", but no
where in the report is this verified.
10. This comment has not been addressed.
11. This comment has not been addressed. The goals of the RI from the
beginning were to "...characterize the aquifer conditions and determine
groundwater flow directions...", yet the RI states that the aquifer
conditions across the site are variable and there is no consensus of how or
where groundwater flows from underneath the site.
12. This entire group of comments has not been addressed.
a. It is imperative that basic data such as the strike and dip of' the
major geologic structures (bedding, fractures, and anticlines) be included
in the text of the RI so that future workers or readers unfamiliar with the
area can evaluate the data.
b-e. These group of comments relate specifically to the RI's
"alleged" fractures. The RI lacks any morphological, geometrical, or
dynamic description about the various observed fractures in the area. This
type of information is basic to the analysis and understanding of
fractures.
f. This comment has been addressed adequately. In fact, the RI now
contains a discussion on the fractured nature of the bedrock and
-------
Page 4
groundwater flow. However, as stated before in a letter, the
potentiometric lines (or maps) only indicate potential direction of
groundwater flow (see also comment 15).
g. Where are all the boring and monitoring well logs? The RI only
has logs for monitoring wells 3, 5, 9, Al, Bl, Cl, 01, EBl, EB2, EB3.
13. This comment has not been addressed. By labe~ing these
being normal to strike, a person unfamiliar to the area will
understand the site geology better.
figures as
be able to
14. This comment has been addressed.
(potentiometric map) has been redrawn
conditions more realistically.
The groundwater contour map
and now portrays ~he ?ossible site
15. This comment has been addressed. Now, the RI presents and considers
the possibility that groundwater flow may ae controlled by the fractured
bedrock. However, there are still some concerns with some of the RI's
statements and conclusions.
a. pp 4-4 through 4-~. The discussion on the- groundwater gradient,
both in the text and in Appendix C, is a simplistic view of groundwater
flow that is contradicted by data in Table C-l. The text states that wells
located in "upland areas" generally have slight downward gradients.
However, the data in Table C-l shows that MW 5/6 and MW 9/10 have strong
downward gradients, MW 1/2 have a slight upward gradient and only MW 3/4
have a slight downward gradient. In addition, the text. states that wells
located in valleys generally have a strong upward gradient. However, the
data in Table C-l shows that of the four well cluster~ in valleys, one has
a slight upward gradient (MW 11/12), one has a moderate upward gradien~ (l1W
7/8), one has a strong upward gradient (MW Bl/B3), and one has a strong
downward gradient (MO 01/02).
b. P 4-5. A. potentiometric map does not indicate "... the principal
direction of groundwater flow...", it only indicates the potential for
. .
groundwater flow. However, when other complicating factors such as
fractures, variable vertical and horizontal gradients (an uneven aquifer
surface) and the presence of different lithologies, potentiome_ric maps are
not useful in determining groundwater flow directions. Tbis S3me concept
must be changed in Append~x C, pp. C-3, C-4 and C-5.
c. p. 4-8. The text states that it is "... .probable that sufficient
vertical fractures exist (perpendicular to strike} to allow flow along the
same direction as the gradient." However, from the boring logs supplied in
the Appendix (Appendix TM 7-1) the fractures parallel to bedding are the
-------
Page 5
only ones described. Where are these other fractures and what are they
related to?
d. p. C-3. There is no evidence that the principal component of
groundwater flow is cross-strike (i.e., normal to the bedding and the
bedding plane fractures), nor is this fact obvious from any figure in the
RI. Again, the potentiometric map can only be used to indicate the
potential direction of groundwater flow. The. argument used to substantiate
cross-strike flow vs. parallel-strike flow is useful, but exactly wrong in
logic. Consider this: MWA1, MW3, and MW11 are all parallel to strike and
to each other, and they are all screened at approximately the same
topographic elevation. Thus, they are quite likely to be in the same, or
similar stratagraphic unit and under the same conditions. MWAl and MW3 are
both on a high plateau, and they both have similar groundwater head
elevation. MW11 is downgradient and in a valley. It also has a lower
groundwater head elevation than MWAl and MW3. Thus, there is evidence of a
gradient parallel to strike, and more importantly, there is no evidence of
similar head levels at similar topographic elevations parallel to strike.
The same cannot be said for cross-strike flow.
A similar relationship is seen between MWC3, MW9 and MW8. These wells
are all screened at similar depths, and are parallel to each other and to
strike. The upgradient well (MW9) has the highest head elevation, while
the two downgradient wells in either direction parallel to strike, have
lower elevations that agree with one another.
e. p. C-13. Fractured media can only be assumed to behave as a
porous media in a direction that is parallel to the fractures.
f. pp. C-13 and C-14. There is a large discussion about fracture
porosity and how it does not add considerably to the groundwater flow. '
However, the amount of porosity that the fractures contribute is not of
concern, it is the degree of interconnectivity of the fractures that makes
them significant to groundwater flow. The shales already have a good
porosity. The importance of a well-developed set of fractures is that they
increase the permeability of the rock. •
g. p. C-16. Groundwater flow through a series of interconnected
joints has not been proven by this RI. It has been assumed, and there is
no indication as to which fractures are important, or how groundwater moves
in those fractures.
-------
Page 6
From all of the above, it is apparent that the groundwater flow is
very complex, and that the nature of the fracture flow and the distribution
of the lithologies beneath the site are at the core of the problem.
16. This entire group of comments has not been addressed. Statements
about what the rock can and cannot contribute to the groundwater are
hindered by this missing data. According to..WMA references, the .chemical
composition of all 9000 feet of the Devonian Shales does not vary much.
For the RI to make this point, additional supportive data needs to be used.
All the comments from our first letter still need to be addressed.
17. This comment has not been addressed. The temporal aspect with regards
to the sampling data, especially from the monitoring wells, has not been
considered. First, many of the inorganics in the monitoring wells (Tables
4-14, 15 and 16) seem to decrease in concentration over time. Second, many
of the organics appear to follow this trend too. A reason for the former
may be that the well drilling activity disturbed the rock and it has taken
some time for all the rock particles to flush out. A reason for the later
may be that the material used to construct the wells (PVC) caused some
minor contamination. Bis .(2-ethylhexyl) phthlates is a common byproduct of
PVC. Since most of the wells only have this compound, and it only occurs
at low levels, its presence may be due to the well material. (MWCl and MW9
(consistently) have elevated values for B(2-E)P which must be considered to
be from a different source.)
Finally, why wasn't sampling consistent from one p~ase to another?
For example, Figure 4-20, the locations for surface water sampling varied
during all the phases. Also, in Figure 4-18, why weren't all the
monitoring wells sampled in Phase lll~
18.
This comment has been considered and corrected.
19. This comment has not been addressed. The data shows that
contamination at both the Diggs and the CC & SC properties are
The comments that WMA made in its first lettep are still valid
be considered.
the organic
widespread.
and need to
20.
This comment has been addressed.
21.
This comment has been addressed.
22.
This comment has been addressed and. corrected.
23. Ov~rall, the migration pathways are more thorough.
discussion is not site speclfic, but general in nature.
However, the
-------
Page 7
24.
This comment has not beEn addTessed.
25. This comment has not been addressed. Again, the text refers to the
background levels of organic and inorganic constituents, but these levels
are not clearly illustrated in a table or figure. A similar comment has
been made under comment 3.
26. These comments have not been addressed.' Only.inorganics have been
detected in groundwater monitoring wells. 'No. '1,1,2-TCA, TCE, or PCE were
found in the monitoring wells. Also, why are the sample analysis from the
FIT Site Investigation mentioned here when that data is not provided in the
RI?
27. This comment has not been addressed. In fact, this entire section,
which was useful, has been deleted from the text of the report.
28.
This comment has not been addressed.
29. This comment has not been addressed. Why does the summary discuss the
risk related to chloroform in the groundwater? Chloroform was only found
in a few monitoring wells 'in Phase I, and at concentrations of less than 5
ppb. Furthermore, the discussion on page 4-29 on the RI relates the
occurrence of chloroform in the groundwater samples to possible laboratory
contamination.
30. This comment has not been addressed.
31. This comment has not been addressed.
32. This comment has not been addressed.
In summary, the Remedial Investigation is not a complete investigation of
conditions at the site. We believe that the RI, within its limitations,
provides a sound basis for a limited,response at this time and further
definition of the extent of contamination. H~wever, the Remedial
Investigation should not be presented as'a conclusive review of the site.
-------
Page 8
If you have any questio~s, please contact me at (301)-225-5700.
Sincerely,
/.
!
-- - - . ...'.
--'. _:- '..'-.
Arthur N~ Caple
Acting Admlnistrator
Enforcement Program
ANC:amj
cc:
Mr. Ronald Nelson
Mr. Frank Henderson.
Mr. Robert Creter
Mr. David Healy
Mr. Theodore Meyer
.
-------
CH2M HILL RESPONSE TO STATE OF MARYLAND COMMENTS TO THE
LIMESTONE ROAD REMEDIAL INVESTIGATION REPORT
GENERAL COMMENTS
1.
No response necessary.
2.
It is our opinion that our assessment was as thorough
as necessary for the purposes of this RI report. Reme-
dial investigations are conducted to gather sufficient
data to support a feasibility ,stuay. It is our opinion
that we have accomplished this goal. Remedial investi-
gations are not designed to be exhaustive research pro-
jects examining every detailed aspect of an NPL site.
It is our opinion that the discussion of the regional
geology is sufficient for the intended purpose bf the
RI report.
3.
A thorough discussion of the spatial and temporal distri-
bution of observed contaminants is presented in the
main body of the RI report.
Figures were prepared but not included.
able upon request.
They are avail-
The number of background samples collected for any given
site is often perceived to be insufficient. There is
constant debate on how many samples are needed to estab-
lish "background" conditions.
The remedial investigation has determined that environ-
mental degradation has occurred in the site area from
uncontrolled dumping and that this has the potential
for posing a threat to the public health and the environ-
ment. The results of the study are inconclusive as to
the source of this environmental degradation. Three
possibilities exist: the former Diggs property, the
CC&SC property and the Old City Dump.
4.
S.
No response necessary.
.
No response necessary.
6.
See No.3 under Specific Text Comments below.
7.
An analysis of trends in aqueous inorg~nic constituents
was conducted. Our conclusion is that there is no observ-
able decr.ease or increase in these constituents over
time. This is stated on page 4-20 of the RI report.
1
-------
2.
3.
4.
5.
6.
7.
9.
8.
Specific portions of Chapters 5 and 6 were changed to
reflect comments to the draft RI report. These changes
have made the report acceptable to u.S. EPA.
9.
None of the changes made to the RI report have affected
the basic conclusions of the remedial investigation.
Consequently, these changes have not had an impact on
the recommendations presented in the Feasibility Study
report.
SPECIFIC TEXT COMMENTS
1.
No response necessary.
No response necessary.
Background levels for constituents in the soil, ground-
water, surface water, and sediment have been presented
in Tables 4-6, 4-9, 4-11, and 4-12 of the RI. A separate
figure, Figure 4-10, was used to convey the constituents
present in the background soils. It was not considered
appropriate to repeat this background material on the
figures for the various media. Figures 4-15, 4-16,
4-20, and 4-22 contain typographical errors involving
the placement of asterisks under locations used as back-
ground. These asterisks should not be present.
No response necessary.
No response necessary.
We disagree.
8.
The Cumberland City Dump is a large body of waste mate-
rials immediately adjacent to the site parcels. Relative
contributions from the site parcels and tne City Dump
cannot be resolved at this time. It is our opiniQIl
that while a good understanding of the regional geology
is important, an exhaustive discussion of this subject
in the main body of the RI report is unwarranted.
It is our opinion that the section on regional groundwater
is sufficiently detailed for Lhe purposes of the RI
report. .
This statement (p. 2-11) referring to "household type
hazardous waste" states that the amounts in the randfill
are unknown..
10.
This comment was not addressed previously, as comments
from the State of Maryland were. not sent in a timely
manner and could not be addressed prior to submission
of the August 8, 1986 RI document.
2
-------
11.
12.
"13.
14.
The documents in the EPA files that describe the events
prior to classification of the site as a Superfund site
are entitled "field" or "site" investigations. The
terminology "preliminary assessment" was intended to
include the investigations that took place pursuant the
identification and assessment of the site as a hazardous
waste site.
A detailed, precise understanding of all potential migra-
tion pathways in fractured bedrock is beyond the scope
of a typical remedial investigation. It is our opinion
that the system has been describea adequately given the
time and budgetary constraints imposed on the RI. The
principal conclusion of the remedial investigation is
that the groundwater flow system is sufficiently complex
to warrant the exclusion of certain remedial actions in
favor of others~
The strike and dip of the regional and local structure
ar~ discussed on page 4-2. A regional geologic map
with references is presented in Figure 2-6. Local strike
"and dip measurements collected in the field were regret-
tably not included. These measurements generally agreed
with regional trends. these measurements will be made
available upon request through EPA.
The occurrence of fracture sets is not alleged. Their
occurrence is well documented in the boring logs contained
in the technical memoranda in Appendix A of Volume 2 of
the RI report. Horizontal fractures were observed in
several of the cores. This is well documented on the
rock core logs. It is speculated that some of these
maybe due to mechanical fracturing during coring (p. 4-3).
It is our opinion that it is sufficient to note that
the attitude" and .orientation of. the- fracture ..sets observed.
Further discussion is academic and beyond the scope of
the remedial investigation.
As noted in Technical Memorandum No.1 (RI Report, Vol-
ume 2, Appendix A), boring EB-01 was drilled and logged
at monitoring well nest location MWl1/MW12. Similarly,
borings EB-02 and EB-03 were drilled and logged at loca-
tions MW1/MW2 and MW7/MWS", respectively. The logs for
these borings are presented in Appendix TM-1-A. Their
locations are shown in Figure TM-1-2. For all the others,
the deepest boring at each location was logged.
After reading the RI section on the geology, examining
Figures 2-6 and 4-5, it should be clear that the sections
were drawn perpendicular to strike.
No response necessary.
3
-------
15.
a.
.b.
c.
d.
e.
g.
Groundwater flow is governed by a potentiometric
relationship. This is a fact. Groundwater flows
from higher to lower potential. The data presented
in Table C-1 do not contradict the discussion.
One cannot make any statement about vertical gradi-
ents at well cluster D1/D2 because well D1 was
determined to be dry. No water level was ever
collected from this well. This is documented in
Technical Memorandum No.7.
It is our opinion that we sufficiently discuss the
complicating factors which may arise to skew the
direction of groundwater flow. We agree that a
potentiometric surface map is an indication of the
possible directions of flow and acknowledge that
there may be components of flow in directions tangent
to those indicated on the potentiometric surface
maps.
Vertical fractures were noted in borings B-1 and
C-l. Examination of aerial photographs indicates
that there may be major vertical fractures perpen-
dicular to strike trending along .the ravine between
the city dump and the Diggs property. Another
fracture may exist along the ravine to the northwest
of the City Dump. There are insufficient data to
say anything further. It is beyond the scope of
the RI to characterize every aspect of the site
geology.
We acknowledge that other components of flow can
and probably do exist in the area. This is discussed
on p. C-4, Volume 2, Appendix C. This discussion
is not intended to be an exhaustive dissertation
on the subject.
We present this section for the sake of comp~eteness.
The numbers contained therein have no bearing on
the conclusions of the RI nor do they affect the
recommendations in the feasibility study. In this
regard, the reviewer's comment, while technically
correct, is academic and need not be considered
further. .
f.
The purpose of this discussion is to introduce the
concept of fracture porosity and make an estimate
of its value. We state that secondary porosity is
often greater than primary porosity. It is obvious
that the interconnectedness of the fractures will
have an effect on the hydraulic conductivity.
We repeatedly state that the flow is ~omplex.
Detailed characterization o~ the subsurface flow
4
-------
16.
17.
18.
19.
20.
21.
22.
[ 23.
I
24.
system is beyond _the .:scope ot. a .!emedial investiga-
tion. We acknowledge :that better. :understanding of
the system could be achieved. However, the time
and budgetary constraints of the remedial investi-
gation is such that we are assigned to make that
. best engineering.:deC.isions pos:sible with the limited
data. generated by~ ,the' :~L..;-,= I.t.. ifs our opinion that
the data .gener.ated by..' thi:s .R! :we're sufficient to
. conduct a feasibility nudy. ;: i
.-; ::.' '-/~"' t. :-. '. -: .,' ~ '.
::"1 :..;: :.~
. - . '"..
It is never definitLve~y. -s.ta.~d :an..ywhere in the RI report
that the seemingly anomolous concentrations of inorganic
constituents are due to naturally occurring phenomena.
It is: made clear that the dat.a. a're insufficient to make
any definitive statement aboU't..:the distribution of these
canst! tuents. The hypothesis:' is. sp'eculative and is
offered as a possible explan'a.tiJ.:m; only.
. .-'.:,.. ";' ".
... ,,".,
This comment was addressed as response No.7 of the.
General Comments section.
... ,"
No response necessary;~
~ ."::: -.. .! :;..< .
-.
a.
<. . i "~'. ..~ '';,::' . s~.' .
See-$tatement on Page:4~2!)rof':'the RI under "ORGANICS."
The statement. reads "Of' the 50il locations sampled
from th~s site, many contained HSL organic compounds."
Figures 4-.12.. and 4.-11 show..the. numerous organics
-' detected in the soil of~b~~th' properties.
..
-':
.. -',
b.
-:All the organics' det.ected' in.:'t.he: test pits on the
Diggs property do not show similar concentrations
of organics. . ~
The t~xt addresses the organics found in both the
soil borings and test pits when characterizing the
organics present (see Pages 4-20 through 4-22).
c.
- .'. . .. .-" ::.;;- \
No response necessa.ry...::::-' :::'.:.":.'~::>;;:.?:.::t.. :;;;..;
. .. -':. -.::: "; -'':J .
No response.nece5sary. .~~
, ..
.. ..-
.-
No response n~cessary.
. .
It is our opinion that the discussion of migration path-
ways is sufficient for the purposes of the RI report.
Table 5-1 was the listing used to convey the reasons
why a particular chemical was selected as an indicator
chemical for the site. It was not intended to be a
summary of the data.
5
-------
25.
26.
27.
28.
L-
Backgroun&locat~ons and 'the concentrations of their
consti tuants were'i.d:i:scussed in detail in Chapter 4.
was not. necessary: to repeat this information in
Chapter;,5.3-... :c ~..:;'."~ ,.'::-2~' ..... ':'4
It
~-:' :.'!? ." Z e r~ : -:- .':-', .::.' ':
:j.5:;: ~.:'
a.
Chapter'. 5 d!'s::.af£e:red" as-c a general description of
the ;f..at.e and:.transport:of .the indicator chemicals
at the ~ite~. ~ T~e figures and tables of Chapter 5
make it cle'~wh~h indicator chemicals were found
in the groundwater. In fact, the indicator organic
chemica:l:s bis,{'2~ed1ylhexylTphthalate and chrysene
were found in the groundw,ater.. . -:.. .
b.
. . . .
_. . .
The FIT; reportw was referenced to:' provide. an explana-
tory .example:J:ofs the possible rapid ~loss of a volatile
cheIl\ic~:l."'. Resu.lts of the. FIT investigations were
judged' net.:, to.. be-:' of verifi'ablygood' quality and,
as such, were not included in the RI (see Page 2-11).
. .
. .
c.
The scope of work of the RI did not include measure-
ment of the amount of sorbed or precipitated chemicals
occurring in the groundwater. Current Contract
Laboratory Program protocol does ~ot distinguish
the valence: state of:'metals whieh is an indication
of their like~r' environmental form.
.-
SamplesLwere..: .filtered'~in;; the field to eliminate
the 'in.1:er£e~ehce: of : suspended materials that may
have been generated during well installation. No
measurement. of,,;'particulate' metals was available.
'..- -,'~ ... .F
. .. ""'." .. .. . '.' - -,' ,,-,
The conditions inhibiting metal ion:'migration have
been addressed in Chapter 5., .
- .."
With regard to the question, "Why would dissolved
metal ions move slowly in groundwater that is
reported to have high velocities?", the conc~pt
that "dissolved meta!"\; ions move. slowly" . has been
taken out of :the context of Chapter 5, where it is
explained that metals will:)persist in the particu-
late fraction of groundwater and will, therefore,
be relatively immobile as compared to the dissolved
metal ions. " .
The "Limitations of the RI" section was moved to Page 6-37
of the RI. Subsequent to the first review draft of the
RI, additional samples for sediment and surface water
were reasoned to be inactive of background and considered
to be as close to a "good set" of background data as .
was available.
Once again, the purpose of this table was to present
the substances detected at the site. It was not intended
6
-------
29.
30.
.31'~
32.
.as a complete. summa~y.;;i9~ the RIdata.Thiswas presented
. in AppendixB. and irLthe Chapter 4 text artd .tables.
, "
.Chloroform' s' occurrenc~,:was,'described -on Page 6-21.
Chloroform was:. dis:cu$is~~..because:; it was, the only
quantifiable;qca.r~i~~geri~:obseived in the groundwater
. samples aI1dass\icn'did"not'lend,.itself to tabulation
'as fortheothet-~~dia~ ,.AI,l chemicals. that could be
quantifiably~as~es);ed' f()~, risk, were. ". 'Chloroform was
mentionedas.a,possible"laboratorycontaminant only.
This was offered: aSq a pos~ib;te' .explanation for its
singular occurrence... ,.' -' " .
, q
Sampling'tecluliqu~$a%,e. deacribed, in detail in the Quality
:Assurarice.P+oj.ect"Pl.ansand" Sampling':plans prepared for
'this site~Thes.edocuments:'are,available from U.S. EPA.
It is. o\1ropinlon thatthe.;informati6ncontained in the
Technical'Memorartda.sufficiently describe the procedures
followed." ' '
, .
We do,'notbelieve:that;:suCJ;1
------- |