United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
-EPA/ROD/R01-88/028
September 1988
Superfund
Record of Decision
Rose Disposal Pit, MA
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30273.101
REPORT DOCUMENTATION
PAGE
I." REPORT NO.
EPA/ROD/R01-88/028
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Rose Disposal Pit, MA
irst Remedial Action - Final
S. Rtpert Oat*
09/23/88
Authorfs)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(Q
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type of Report & Period Cowered
800/000
14.
IS. Supplementary Notes
1C. Abstract (Limit 200 words) .
The Rose Disposal pit site occupies 1.5 acres in the northern section of a 14-acre
residential lot located in Lanesborough, Massachusetts, approximately 4 miles north of
Pittsfield. The property encompassing the site is bounded on the north, northeast, and
west by forests, on the east and southeast by cropland and pasture, and on the southwest
by a residential area. There is a small wetland west of the disposal area and a larger
forested wetland to the southeast of the property. A small man-made pond is located
^approximately 200 feet south of the disposal area. During the 1950s and possibly later,
Hbhe General Electric Company disposed of waste oils and solvents in a trench on the
[site, now referred to as the disposal area. Field investigations conducted between 1981
and 1986 revealed high concentrations of PCBs in surface and subsurface soils and
indicated the presence of VOCs in ground water. The volume of contaminated soil to be
remediated is approximately 15,000 yd3. The primary contaminants of concern affecting
the soil, sediments, ground water, and surface water are VOCs including PCE, TCE,
toluene, and xylenes, and other organics including PCBs.
The selected remedial action for this site includes: excavation and onsite
incineration of approximately 15,000 yd3 of contaminated soil and sediment with
(See Attached Sheet)
Rose Disposal Pit, MA
First Remedial Action - Final
Contaminated Media: gw, sw, soil, sediments
Key contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), PCBs
b. Identlfiers/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Cless (This Page)
None
21. No. of Pages
104
22. Price
(See ANSI-Z39.18)
See fnitruct/ons on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R01-88/028
Rose Disposal Pit, MX
First Remedial Action - Final
16. ABSTRACT (continued)
residue disposal onsite; ground water pump and treatment onsite using air stripping and
carbon adsorption with discharge to the aquifer; installation of a bedrock well to
prohibit ground water migration; treatment of pond sediments and surface water and
subsequent restoration of the onsite pond to its original wetlands character;
implementation of institutional controls; and ground water monitoring. The estimated
present worth cost for this remedial action is $6,450,000 with estimated present worth
OCN of $5,790,000.
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Record of Decision
Remedial Alternative Selection
Site Name and Location
Rose Disposal Pit
Lanesborough, Massachusetts
Statement of Purpose
This Decision Document presents the selected remedial action for
this site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable,
the National Contingency Plan (NCP); 40 CFR Part 300 et seq.,
47 Federal Register 31180 (July 16, 1982), as amended.
In accordance with CERCLA Section 121(f)(1)(E) and (6), EPA has
provided the Commonwealth of Massachusetts with the opportunity to
review and comment on the Remedial Investigation, the Feasibility
Study, and the Proposed Plan for Remedial Action.
Statement of Basis
This decision is based on the administrative record which was
developed in accordance with Section 113 (k) of CERCLA and which is
available for public review at the information repositories (index
attached). The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial
action is based.
Description of the Selected Remedy
The selected remedy for the Rose site is a comprehensive approach
for site remediation which includes both a source control and a
control/management of migration component.
The source control component entails the following:
* Excavation and on-site incineration of approximately
15,000 yd3 of contaminated soil and sediment. Excavation
will be to 13 ppm of PCBs to the water table and will include
limited excavation in the saturated zone to remove the
subsurface free product portion of the disposal area.
On-site incineration is a technology which has been proven to
be effective in the treatment of PCB and VOC-contaminated
soils. Extensive design work will be required, however, to
design a transportable incinerator that is suitable for the .
Rose site.
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It is estimated that it will take approximately two (2) years
to treat 15,000 cubic yards of PCB and voc-contaminated soil
and sediment. This estimate is for construction/ operation
time only, and does not include the time for design, bidding
and awarding of the construction contract.
The control/management of migration component will be implemented
as soon as possible. This component entails:
Active restoration of the shallow overburden aquifer
contaminated with volatile organic compounds (VOCs) using on-
site treatment involving air stripping and carbon adsorption.
A bedrock well will be installed in the vicinity of the free
product area to prohibit migration into fractured rock.
Groundwater will be treated to reduce contaminants to levels
which will meet drinking water standards or other appropriate
guidelines. Rose's pond sediments and surface water will also
be treated and the pond will be restored to its original
wetlands character after remediation.
EPA has determined that remediation of sediments located in
the saturated zone of the disposal area is not cost effective
and would potentially entail unacceptable impacts on the
adjacent wetlands. However, treatment of VOCs will render the
PCBs relatively immobile, thus restricting subsurface PCB
contamination to below the water table in the disposal area.
Since PCBs will be present in groundwater in excess of the
cleanup level upon completion of groundwater remediation, it
will be necessary to implement institutional controls to
prevent groundwater use and excavation into the saturated zone
within the disposal area.
The estimated present worth cost for the source control component
is $5,200,000 and the groundwater remediation component is
$1,256,000. The total estimated cost for the selected remedy for
the Rose site is $6,450,000.
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost-effective.
This remedy satisfies the statutory preference for treatment that
permanently and significantly reduces the volume, toxicity and
mobility of the hazardous substances, pollutants and contaminants
as a principal element. Zt is determined that this remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
Date Michael R. Deland
Regional Administrator, EPA Region Z
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ROD Decision Sumaary
Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
September 23, 1988
U.S. Environmental Protection Agency
Region I
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ROSE DISPOSAL PIT
TABLE OF CONTENTS
Page
I. SITE NAME, LOCATION AND DESCRIPTION ...... 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES .... 1
A. Response History ............... 1
B. Enforcement History .............. 2
III. COMMUNITY RELATIONS .............. 3
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE
ACTION .................... 3
V. SITE CHARACTERISTICS ............. 4
A. General ............ ........ 4
B. Soil ..................... 4
C. Groundwater .................. 5
VI. SUMMARY OF SITE RISKS AND CLEANUP GOALS .... 6
A. GE's Endangerment Assessment . ........ 6
B. EPA PCB Soil Cleanup Level ........... 8
C. EPA Groundwater Cleanup Goals ......... 8
VII. DOCUMENTATION OF SIGNIFICANT CHANGES ..... 9
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES . . 11
A. Statutory Requirements/Response Objectives . . 11
B. Technology and Alternative Development and
Screening ... ............... 12
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS OF ALTERNATIVES .... 14
A. Source Management Alternatives Analyzed ... 14
B. Management of Migration Alternatives Analyzed. 21.
X. THE SELECTED REMEDY ............. 23
A. Description of the Selected Remedy ...... 23
B. Rationale for Selection/Points of Compliance . 24
1. Source Management . ........... 24
2. Management of Migration ........ . 26
XI. STATUTORY DETERMINATIONS .......... . 27
A. The Selected Remedy is Protective of Human
Health and the Environment ......... . 27
B. The Selected Remedy Attains ARARs ...... 28
C. The Selected Remedial Action is Cost
Effective .................. 31
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D. The Selected Remedy Utilizes Permanent
Solutions and Alternative Treatment Technolo-
gies or Resource Recovery Technologies to the
Maxima Extent Practicable 32
E. The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element 32
XXX. STATE ROLE 33
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Rose Disposal Pit
Record of Decision Summary
LIST OF FIGURES
1. Site Location Map
2. PCB Soil Contamination Profiles in the Disposal Area
3. Hell Locations and Total VOCs in Shallow Groundwater
LIST OF TABLES
1. Summary of Field Investigations
2. Site Contaminants and Contaminants of Concern
3. Summary of Potential Exposure Routes
4. Potential Exposure Routes with Potential Human Health Risks
5. Potential Chemical-Specific ARARs, Guidelines and Cleanup
Goals for Groundwater
6. Summary of Remedial Alternatives
7. Potential Action-Specific ARARs; Federal
8. Potential Action-Specific ARARs; State
APPENDICES
Responsiveness Summary ....... . ....... Appendix A
Administrative Record Index ... .......... Appendix B
State Correspondence ............... . . Appendix C
Calculation of Soil Volumes to be Excavated ..... Appendix D
Calculation of PCB Soil Cleanup Level ........ Appendix E
Calculation of Adjusted Cost Estimates ........ Appendix F
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ROD DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
SITE NAME: Rose Disposal Pit
SITE LOCATION: Lanesborough, Massachusetts
SITE DESCRIPTION: The Rose Disposal Pit Site (Rose site) is
located on Balance Rock Road in Lanesborough, Massachusetts
approximately four (4) miles north of Pittsfield. The Rose property
was the site of waste oil and solvent disposal from the General
Electric Company (GE) during the 1950's and possibly later. The one
and one-half acre disposal area occupies the northern section of a
14-acre residential lot and was formerly a trench into which the
waste oils and solvents were dumped. The property encompassing the
site is bounded on the north and northeast by the deciduous forest of
Balance Rock State Park, on the east and southeast by cropland and
pasture, on the west by mixed forest, and on the southwest by a
residential area. A small wetland exists west of the disposal area
and a larger forested wetland exists to the southeast of the property
on the southern side of Balance Rock Road. A small man-made pond is
located approximately 200 feet south of.the disposal area. The site,
currently owned by Mr. F.T. Rose, is located on a small hill north
of the Rose's house. The areal extent of the disposal area is
approximately 200 feet by 350 feet and the depth of contaminated
soil varies between 10 and 30 feet.
A more complete description of the site can be found in the Remedial
Investigation Report entitled "1986 Supplementary Investigation at
the Rose Site; February 1987" in Chapter 2 of Volume I. See Figure 1
for a site location map.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
The General Electric Company (GE) has performed the majority of the
technical activities at the site. After the preliminary assessment
(PA), site inspection (SI), and field investigation (FI) were
performed by EPA between 1980 and 1982, all subsequent site
activities have been conducted by GE. Subsequent to EPA's studies,
Geraghty and Miller (G&M) investigated the site further and produced
a Remedial Investigation report (RI) and Blasland & Bouck (B&B)
developed the Feasibility Study (FS) as consultants to GE.
GE provided a permanent potable water supply for the Rose household
in August 1983 by connecting the residence to the Lanesborough
Municipal Water System. In May 1984, EPA issued GE
an Administrative Order under Section 106(a) of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
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(CERCXA). In compliance with this Order, GE performed the
following activities in 1984:
cured the disposal area by installing a perimeter fence and
posted signs warning unauthorized persons to keep out;.
covered the contaminated soil within the fenced-in disposal
area with a polyethylene film and stabilized this cover against
wind movement;
initiated recovery of a localized free oil layer found beneath
the surface of the disposal area through a recovery well; and
provided th« adjacent (Allard) residence west of the site
property with a permanent potable water supply by connection to
the Lanesborough Municipal Water System. The former Balance
Rock Cafe located to the east of the site property also tied in
to the permanent water main provided for the Rose property by
GE.
B* Enforcement History
Three Administrative Orders (A.O.) have been issued to GE for this
site. In May 1984 a Unilateral A.O. was issued to GE by EPA to
conduct the removal activities as outlined in the previous Response
History section. GE performed all activities in compliance with the
A.O.
In November 1984 a Unilateral A.O. was issued to GE by EPA to
conduct a FS for the site. GE subsequently submitted an Initial
Screening of Alternatives and several revisions to this document, in
compliance with the A.O.
In March 1988 an A.O. on Consent was signed by GE and EPA for GE to
conduct a detailed FS for the site. With the passage of SARA,
several modifications to the November 1984 A.O. were needed. The
current A.O. includes several new items:
a schedule for submission of interim deliverables and a
complete detailed FS by 6/30/88;
references to SARA and current OSWER guidance? and
a requirement that GE reimburse EPA for oversight costs.
Other than GE, EPA has not formally notified any parties of
potential responsibility for the Rose site.
GE, as the generator, has been very active at th« site. Other than
the preliminary investigations that were conducted by EPA, GE has
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conducted and financed all removal activities as well as the RI and
the FS for the Rose Site.
Special notice has not been issued in this case to date.
III. COMMUNITY RELATIONS
Through the Site's history, community involvement has been minimal.
EPA has recently apprised the community and other interested parties
of the Site activities through an informational meeting, fact
sheets, press releases and a public hearing.
In July 1988, EPA released a community relations plan which outlined
a program to address community concerns and keep citizens informed
during remedial activities.
The Agency published a notice and brief analysis of the Proposed
Plan in the Berkshire Eagle on July 18, 1988 and made the plan
available to the public at the Lanesborough Town Library in the Town
Hall.
On July 20, 1988, EPA held an informational meeting to discuss the
results of the Remedial Investigation, the cleanup alterna- tives
presented in the Feasibility Study, and EPA's Proposed Plan. During
this meeting, EPA answered questions from the public. From July 21
to August 19, 1988, EPA held a 30-day public comment period to accept
public comment on the alterna- tives presented in the Feasibility
Study and the Proposed Plan and on any other documents previously
released to the public. On August 3, 1988, EPA held an informal
public hearing to accept any oral comments. A transcript of this
meeting and the comments and EPA's response to comments are included
in the attached responsiveness summary as Appendix A.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining components of a
source control alternative and a control/management of migration
alternative to obtain a comprehensive approach for site remediation.
In summary, the remedy calls for excavation and on-site incineration
of approximately 15,000 yd3 of contaminated soil and sediment. (See
Appendix D for the calculation of the soil volume to be excavated.)
Excavation will extend laterally to remove all contamination down to
13 ppm PCBs, and vertically to the seasonal low water table (defined
below) and will include excavation to a deeper level into the water
table to remove the subsurface free product portion (also defined
below) of the disposal area. The remedy also includes active
restoration of the shallow overburden aquifer utilizing air stripping
followed by carbon adsorption for groundwater treatment. A bedrock
well will be installed in the vicinity of the free product area to
prohibit migration into fractured rock.
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V. SITE CHARACTERISTICS
The significant findings of the Remedial Investigation are
summarized below.
A. General
Field investigations conducted in 1981 and 1982 by the Region I
Field Investigation Team (FIT) contractor, Ecology and Environment
(E&E)/ revealed high concentrations of polychlorinated biphenyls
(PCBs) in surface and subsurface soils and indicated the presence of
volatile organic compounds (VOCs) in groundvater sampled from a
network of wells. Remedial Investigation studies conducted in 1983
and supplemented in 1986 by Geraghty and Miller (G&M), under
contract to General Electric, indicate that contaminated groundwater
is leaving the disposal site in two plumes. One plume is flowing
eastward toward Balance Rock State Park and one is flowing southward
toward Rose's pond. The G&M study also further delineated the extent
and magnitude of PCB contamination. It determined that the highest
concentration of PCBs is located in the primary disposal area. The
G&M study estimated that approximately 60,000 cubic yards of soil
contains greater than 50 ppm of PCBs.
This original estimate of 60,000 yd3 of soil includes soil both
above and below the water table. The water table depth fluctuates
seasonally. EPA estimates the soil volume above the seasonal low
water table to be approximately 8,000 cubic yards. This estimate
is based on the site. topography and the depth to the water table
was measured during the November 1986 sampling round. Appendix
provides the estimates that were used and includes the calculatio
approximately 3500 cubic yards of material below the water table to
address the free product portion of the site. Since the 11,500 cubic
yard estimate does not include any side slope contingencies for
actual excavation nor the bottom sediments from Rose's pond, 15,000
cubic yards is used as the total soil volume estimate. Refer to
Appendix D for a complete explanation and calculations.
Although high levels of PCB contamination are found throughout the
disposal area, the highest levels of contamination are
generally found directly below the western portion of the
disposal area. An area of "free product* in the saturated zone
exists. This material continues to be recovered from one well
located in the disposal area. This "free product" is a mixture of
oil, water, and solvents. Recent analysis of the mixture shows
350,000 ppm of total PCBs and 57,000 ppm of trichloroethane
in the oil fraction. GE sends this mixture to their stationary TSCA
incinerator located in Pittsfield for thermal destruction.
B. Soil
Drilling logs indicate that up to 90 feet of glacial sediment
overlie bedrock on the Rose Site. On the basis of field
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observations, the majority of this material is described as dense,
basal till. Driving resistances within the basal till were
extremely high (blow counts of 50 to 100 per 1 to 6 inches).
Samples of this till were very tight and dense. Till extended
upward to a depth approximately 15 to 20 feet below the ground
surface. A less compacted mixture of sand, silt, and gravel
overlies the dense till. At the Rose Site, much of this overlying
layer may have been disturbed during disposal operations. A radar
survey indicated that a significant trench up to 25 feet deep may
have once occupied the western portion of the disposal area.
Historical aerial photographs support the existence of a trench. It
is the western portion of the trench that was historically the
deepest and this is the area in which the free product is found.
E&E (1982) analyzed soil samples from the Rose Site to determine the
character of PCS and VOC contamination. Analyses indicate that VOC
contamination is moving with groundwater above or along the upper
surface of the basal till. Some infiltration into the till has
occurred, but data from wells screened at different depths indicate
that this is not a primary route of contaminant transport.
G&M (1983) sampled subsurface soils at over 100 locations to more
accurately determine the extent and severity of PCB contamination.
G&M also sampled groundwater from an expanded network of monitoring
wells for the presence of VOCs (1983 and 1986). Analyses indicate
that the highest concentrations of PCBs and VOCs are still in the
immediate disposal area. There is a localized area of free product.
in the western portion of the disposal area that GE continues to
recover through a recovery well. The VOCs, however, are migrating
from the disposal area, presumably contaminating soils below the
water table.
The PCB contamination generally has not migrated from the disposal
area. However, PCB contamination is found in the sediments in Rose
pond (and low levels of PCBs are found in the groundwater taken from
wells near the disposal area). EPA believes that the PCB
contamination in the pond spread from the disposal area by overland
transport via rain and snowmelt prior to the placement of the
synthetic cap over the disposal area in 1984. See Figure 2 for PCB
soil contamination profiles in the disposal area.
Regional mapping and limited on-site information from sample cores
indicate dolomitic marble underlies the Rose site. Bedrock was
encountered by eight borings on or near the site at depths between
34 and 100 feet below the ground surface. Much of the bedrock
recovered during drilling by E&E (1982) was significantly weathered.
C. Groundwater
E&E (1982) installed 8 wells and sampled for priority pollutants.
G&M (1984) conducted a more extensive investigation which included
the installation of 67 wells on or near the Rose property and
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conducted 3 sampling rounds for VOCs from selected locations. Zn
1986 GSM provided a supplement to the RI. This update included
sampling 34 wells for VOCs, 3 wells for full hazardous substance
list (HSL) analysis, and sediment and surface water sampling in
western and southern wetlands and in Rose's pond.
Groundwater flow in the site area is largely controlled by
topography and the vertical and horizontal hydraulic conductivities
of the soil matrix. A groundwatar mound is well defined in the area
of the source, with groundwater flowing radially from the source
disposal area. Although downward vertical gradients exist in nested
wells screened at varying depths in the area of the mound,
groundwater quality data indicate the majority of contaminant
transport is restricted to the upper 15 to 20 feet of overburden.
Dense, impermeable till, which is thought to exist at depths
approximately 20 feet below the ground surface appears to restrict
contaminant transport. Groundwatar in the shallow overburden flows
radially from the source area, with the Rose pond as a discharge
area. At deeper depths, groundwater is likely to migrate under the
pond, ultimately discharging into the wetland located to the south or
possibly west into the Daniels Brook Basin.
Two plumes of VOCs emanate from the site. One plume flows eastward
toward Balance Rock State Park. The other plume flows southward and
discharges into Rose's Pond which has low levels of VOC
contamination. Zn addition, low levels of PCBs are present in the
groundwater. See Table 1 for a summary of field investigations
Figure 3 for well locations and total VOCs in shallow groundwater.
The groundwater contamination is concentrated in shallow
overburden soils and does not pose a threat to the municipal
wells located approximately two miles east of the site.
Specific information on residential wells within one-half
mile of the site is not.available, but records for other
wells in the area and discussions with a local well driller
suggest that all private wells obtain water from the bedrock
aquifer.
A complete discussion of site characteristics can be found in the
Remedial Investigation Reports.
VI. SUMMARY OF SITE RISKS AND CLEANUP GOALS
GE performed an Endangerment Assessment (EA) to estimate the
probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with
the site. Seven (7) contaminants of concern, listed in Table 2, were
selected for evaluation in the EA. These contaminants constitute a
representative subset of the more than nineteen (19) contaminants
identified at the Site during the Remedial Investigation. The 7
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contaminants were selected to represent potential on-site hazards
based on toxicity, level of contamination, and mobility and
persistence in the environment.
Potential human health effects associated with the contaminants of
concern in soils and groundvater were estimated quantitatively
through the development of several hypothetical exposure scenarios.
Incremental lifetime cancer risks and the potential for
noncarcinogenic adverse health effects were estimated for the
various exposure scenarios. Exposure scenarios were developed to
reflect the potential for exposure to hazardous substances based on
the characteristic uses and location of the site. Factors of
special note that are reflected in GE's Endangerment Assessment are
that although the site area is residential, GE treats it as a rural
area without a large amount of pedestrian traffic on the property.
GE's EA examined potential risks to public health and the
environment posed by the presence of PCBs in soil as well as VOCs in
groundwater at the site. The study found that dermal contact with
and ingestion of PCB-contaminated soil in the disposal area poses an
unacceptable lifetime maximum cancer risk of approximately 6.9 X 10~2
and a lifetime average cancer risk of 2.6 X 10~3. GE's calculations
assumed a PCB cancer potency factor of 4.34 (mg/kg/day)"1 and a
"lifetime" exposure of 52 years. GE assumed 36 visits per year. The
cancer potency factor that is now used by EPA is 7.7 (mg/kg/day)"1
which would increase the above risk numbers.
The CPF used by GE was formerly used by EPA, but the Agency has
revised the factor based on the results of studies on the cancer-
causing potential of PCBs, reflecting the Agency's conclusion that
the cancer-causing potential is greater than previously believed.
EPA's Drinking Water Quality Criteria Document for PCBs sets forth
the data which supports this factor. Even using the CPF used by GE,
the risks posed are unacceptable.
According to GE's calculations, ingestion of contaminated
groundwater in the vicinity of the disposal area poses an
unacceptable lifetime average cancer risk of 1.4 X 10"2. This
vicinity also has a hazard index for non-carcinogenic effects of
greater than 1.0. GE's EA also found that VOCs in Rose's pond
present an unacceptable lifetime cancer risk of 7.3 X 10"4 to
animals with a hazard index of 1.8 for potential non-carcinogenic
effects.
The fencing and temporary cover on the site temporarily reduce the
risk posed to humans and to animals by contact with soils in the
disposal area. No contaminated shallow groundwater is presently
used as a drinking water supply since municipal water was extended
to the immediate area in 1984. However, there is residential use of
groundwater within one-quarter mile of the site and groundwater
contamination is migrating off-site.
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Table 3 presents a summary of potential exposure routes and Table 4
is a summary of potential human and animal health risks for the
corresponding potential exposure routes and are taken from GE's
A complete discussion of site risks can be found in the Endange
Assessment.
B. EPA PCB Soil Cleanup Level
PCBs are the most significant component of soil contamination at the
Rose site. A PCB soil clean-up level is developed using exposure
scenarios based on potential human exposures to contaminated soils by
direct contact and ingestion. The exposure scenarios reflect
hypothetical future site use. That is, they represent the level of
soil cleanup that would be acceptable without the need for long term
management of contamination at the site.
The assumptions that were used by GE have been revised by EPA to
develop the site-specific cleanup goal. At this site the zoning is
residential and the use of the area is residential. Although the
area is not densely populated at present, EPA expects that
residential and recreational use of the area will grow in the
future. See Appendix E for the assumptions used by EPA in the
calculation of the 13 ppm PCB cleanup goal.
The source management component of the selected remedial action
entails excavation and treatment of soils contaminated with PCBs at a
concentration of 13 ppm or greater located in the unsaturated tone.
This clean-up level corresponds to a 10-5 risk level for the av
case under future site use conditions. EPA is establishing the
clean-up goal for PCBs in the unsaturated zone. However, the area
containing free product in the western portion of the saturated zone
will also be excavated to facilitate groundwater cleanup. During the
excavation and treatment of soil, air quality will be monitored to
ensure that site specific ambient.action levels are not exceeded.
In applying this approach to estimate health-based soil clean-up
levels, it is important to recognize the inherent uncertainties.
Uncertainties are associated with the value of each exposure
parameter and the overall set of exposure assumptions. EPA believes
that the assumptions used to estimate the cleanup level are
reasonable, and that it is necessary to use this approach, in spite
of its uncertainties, in order to assure that the cleanup goals will
be adequately protective of public health. See Appendix E for EPA's
calculation and references for the PCB soil cleanup level.
C. EPA Groundwater Cleanup Goals
VOCs are the most significant component of groundwater contamination
at the Rose Site. Groundwater cleanup goals for certain contaminants
have been set at or below U.S. EPA Maximum Contaminant Levels (NCLs),
where available. These contaminants include: vinyl chloride; 1,1-
dichloroethylene; trichloroethylene; benzene; and p-dichlorobenzene.
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For compounds without MCLs, EPA's proposed Maximum Contaminant Level
Goals (MCLGs) have been used to define groundvater cleanup goals for
the following contaminants: t-l,2-dichloroethylene; o-
dichlorobenzene; ethylbenzene; toluene; and xylenes. For
chlorobenzene, the Lifetime Health Advisory (LHA) of 300 ppb is used
which reflects the current data being considered by the Agency. For
m-dichlorobenzene, the LHA of 620 ppb is the cleanup goal. The
proposed MCLG for PCBs and tetrachloroethylene is zero (0), which is
not considered to be technically measurable.
The cleanup goals for methylene chloride, tetrachloroethylene, and
1,1,2-trichloroethane are set at 5, 1, and 1 ppb respectively,
corresponding to a 10~6 cancer risk, assuming lifetime exposure.
Based on EPA's 1987 Drinking Water Criteria for PCBs, the health-
based cleanup level is 0.005 ppb which corresponds to a 10~6 cancer
risk.
It is likely that the groundwater treatment system for the Rose Site
will be able to reduce groundwater contaminant concentrations to
levels lower than the cleanup goals. Groundwater treatability tests
were conducted by GE for the Rose site in November 1987. Effluent
concentrations from two air stripper tests were lower than the
groundwater cleanup goals for 11 of the 16 contaminants listed in
Table 5. These results were for a single air stripper with a 10-foot
packing height. In the full-scale groundwater treatment system,
packing height will be increased to increase collection efficiency.
In addition, the air stripper will be followed by two granular
activated carbon (GAC) beds in series to remove contaminants passing
through the air stripper. As a result, the effluent concentrations
are anticipated to be lower for the full-scale air stripper-GAC
system than for the treatability test.
Refer to Table 5 for a summary listing of potential contaminant-
specific ARARs, guidelines, and cleanup goals for groundwater.
VTI. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA issued a Proposed Plan (preferred alternative) for remediation
of the site in July 1988. The source management portion of the
preferred alternative included excavation and on-site incineration
of soils in the disposal area both above and below the seasonal low
water table. The management of migration portion of the preferred
alternative included groundwater treatment by air stripping followed
by carbon absorption. All costs and soil volumes were taken directly
from GE's draft FS and were not modified.
The proposed plan did not specify the PCB cleanup goal and
approximated the extent of excavation required. The ROD defines
these. The ROD sets a PCB cleanup goal of 13 ppm for PCBs above the
seasonal low water table. Extensive soil borings which were
analyzed for PCBs (data presented in the 1984 RI report) in and
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around the disposal indicate that there is not a significant
difference between tha axtant in araas contaminated to tha 13
and 50 ppm lavals. Tharafora, tha araal axtant of contamination
assumed to ba approximately equal to the portion of the disposal area
that is fenced and covered (see Appendix D).
Rose's pond shows PCB contamination in the sediments that exceed 13
ppm (one sample taken from the pond bottom contained 65 ppm of
PCBs). Rose's pond will be drained and the vater vill be treated by
the groundvater treatment system if this surface vater does not meet
the groundvater cleanup goals. Once the pond is drained, the bottom
sediments vill be excavated for treatment and it vill be backfilled
to restore the area to its original (vetland) condition.
Extent of PCB Removal
The depth to the vater table varies across the disposal area. EPA
estimates the volume of soil above the vater table to be excavated is
8,000 yd3. In addition to soils in the unsaturated zone, the free
product area in the western portion of the saturated zone vill also
be excavated and is estimated to be 3,500 yd3 of saturated soil. A
total soil volume of approximately 15,000 yd3 (which includes side
slopes) vill be excavated. See Appendix D for calculation of the
soil volumes to be excavated.
Actual soil volumes vill be determined during remedial design,
particularly the extent of the free product area. If this free
product area is found to extend beyond the area originally assu
additional saturated soil may need to be removed.
Another change from the proposed plan concerns the approach taken to
PCBs in the groundvater in the disposal area. Both PCBs and VOCs are
found at high concentrations in the saturated zone in the disposal
area.. Each class of chemicals has distinct characteristics. VOCs
are highly soluble in groundvater, whereas PCBs are of extremely lev
insolubility and have a tendency to adsorb onto soils. Although PCBs
may desorb from saturated zone soils and solubilize in groundvater,
PCBs have a chemical tendency to adsorb onto the next available and
less contaminated soil particle since the soil-water partitioning
coefficient for PCBs favors soils. The solubility of PCBs is
enhanced, however, in the presence of VOCs and appears to increase as
the concentration of VOCs increase. Although significant
concentrations of PCBs vill remain in the saturated zone, VOCs vill
be reduced by the groundvater treatment system. This reduction of
VOC levels vill reduce the solubility and mobility of PCBs in the
groundvater.
Nevertheless, PCBs vill still be present at lov concentrations in
the groundvater in the disposal area and are assumed to be in excess
of the 0.005 ppb health-based level for a 10~* cancer risk for PCBs.
Hovever, if the VOCs in groundvater are remediated to the cleanup
10
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goals, the PCBs remaining in the saturated zone following remediation
in effect will not migrate.
i
In order to attain a PCB level of 0.005 ppb in groundwater within
the disposal area, essentially all PCBs in the saturated zone would
need to be excavated. This would require the excavation and
treatment of approximately an additional 45,000 cubic yards (and
possibly more) of PCB contaminated soil in the saturated zone.
Excavation to achieve the groundwater PCB goal in the saturated
zone would be technically difficult, costly, and for all practical
purposes, infeasible. In addition, a large dewatering effort could
potentially have unacceptable impacts on the adjacent wetland by
significant lowering of the water table. In light of these
implementation problems, EPA has determined that it is technically
impracticable and not cost-effective to remediate the PCBs that
will remain below the water table in the disposal area. Instead,
to achieve a protective remedy in the disposal area, EPA has
concluded that dermal exposure and ingestion of PCBs in the
saturated zone can and will have to be prevented through capping
of the disposal area and institutional controls.
In addition, because PCBs will still be present in groundwater
within the disposal area in excess of the cleanup goal,
institutional controls will be required for this area to prevent
ingestion of groundwater. However, for the reasons
stated above, EPA has determined that this remedy will be
protective.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of .the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance with
CERCLA as enacted in 1980 and the revised National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part
300, dated November 20, 1985. Until the NCP is revised to reflect
SARA, the procedures and standards for responding to releases of
hazardous substances, pollutants and contaminants shall be in
accordance with Section 121 of CERCLA and to the maximum extent
practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards established under
federal and state environmental laws unless a statutory waiver is
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granted; a requirement that EPA select a remedial action that is
cost-effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and a statutory
preference for remedies that permanently and significantly Deduce
the volume, toxicity or mobility of hazardous wastes over remedies
that do not achieve such results through treatment. Response
alternatives were developed to be consistent with these
Congressional mandates.
A number of potential exposure pathways were analyzed for risk and
threats to public health and the environment in the Endangerment
Assessment and the Wetlands Assessment (Appendix A of the TS).
Guidelines in the Superfund Public Health Evaluation Manual (EPA,
1986) regarding development of design goals and risk analyses for
remedial alternatives were used to assist in the development of
response actions. As a result of these assessments, remedial
response objectives were developed to mitigate existing and future
threats to public health and the environment. These response
objectives are:
* prevent exposure to contaminated soils and groundwater
protect uncontaminated groundwater and surface water for
current and future use
restore contaminated soils and groundwater for future
use
B. Technology and Alternative Development and
Screening
CERCLA, the NCP, and.EPA guidance documents including, "Guidance
on Feasibility Studies Under CERCLA" dated June 1985, and the
Interim Guidance on Superfund Selection of Remedy" [EPA Office of
Solid Waste and Emergency Response (OSWER)], Directive No.
9355.0-19 (December 24, 1986) set forth the process by which
remedial actions are evaluated and selected. In accordance with
these requirements and guidance documents, treatment alternatives
were developed for the site. These alternatives range from an
alternative that, to the degree possible, would eliminate the need
for long-term management (including monitoring) at the site, to
alternatives involving treatment that would reduce the mobility,
toxicity, or volume of the hazardous substances as their principal
element. In addition to the range of treatment alternatives, a
containment option involving little or no treatment and a no-action
alternative were developed in accordance with Section 121 of
CERCLA.
Section 121(b)(l) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
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alternatives. In addition to these factors and the other
statutory directives of Section 121, the evaluation and selection
process was guided by the EPA document "Additional Interim
Guidance for FY '87 Records of Decision" dated July 24, 1987.
This document provides direction on the consideration of SARA
cleanup standards and sets forth nine factors that EPA should
consider in its evaluation and selection of remedial actions. The
nine factors are:
1. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2. Long term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume.
4. Short term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
9. Overall Protection of Human Health and the Environment.
The Initial Screening of Alternatives Report identified, assessed
and screened technologies based on engineering feasibility,
implementability, effectiveness, and technical reliability.
These technologies were combined into source control (SM for
"source management") and control/management of migration (GW for
"groundwater11) alternatives. Section 5 of the Feasibility Study
presented the remedial alternatives developed by combining the
technologies identified in the previous screening process in the
categories required by OSWER Directive No. 9355.0-19. The purpose
of the initial screening was to narrow the number of potential
remedial actions for further detailed analysis while preserving a
range of options. Each alternative was then evaluated and screened
in the initial screening report. In summary, of the over 100
original source management technologies and management of migration
technologies screened in the initial report, 10 source management
options and 4 groundwater options were retained for detailed
analysis. Table 6 identifies the alternatives that were retained
through the screening process. The initial screening report lists
those alternatives that were eliminated from further consideration.
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ZX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES
This Motion presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
abova. A datailad assessment of aach altarnativa can be found in
Section 6 of the Feasibility Study.
A. Source Management (SM) Alternatives Analyzed
The source management alternatives analyzed for the site include a
no action alternative (SM-0), as veil as 10 other alternatives.
For alternatives where soil volume is a cost consideration,
estimates of costs are lower than those in the draft FS. which are
based on the original soil volume estimate of 60,000 yd3. Actual
soil excavation will be limited to approximately 15,000 yd3 and
corresponding volume-sensitive cost estimates are lower. Since the
cost estimates in the draft FS were not specific enough to allow
for calculation of exact values, it was assumed that for purposes
of comparison of the alternatives, the relative cost reductions of
the different alternatives are essentially the same. Pro-rated
cost estimates are included here based on the unit costs that were
provided in the draft FS, to the extent possible. See Appendix F
for calculation of these adjusted cost estimates.
SM-0
Ho Action
This alternative for soil contamination is included in the FS to
serve as a basis for comparison with the other remedial
alternatives considered. A no action alternative is selected only
if the site poses little or no risk to public health and the
environment. For the Rose site, the no action alternative would
entail leaving contaminants untreated on site, maintaining the
existing synthetic cover and fence, continuing the ongoing program
to recover the product layer located beneath the disposal site, and
monitoring surface and groundwater for 30 years.
The no action alternative would not provide overall protection of
human health and the environment, and it would not comply with
ARARs. It is not a permanent remedy that would have long term
effectiveness since it would not reduce the toxicity or mobility
of the contaminants. This alternative would require a 5-year
review since contaminants would remain on-site.
Estimated Time for Construction and Operation: Minimum of 30 Years
Estimated Capital Cost: $0
Estimated Present.Worth of Operation and Maintenance Costs:
$210,000
Estimated Total Cost: $210,000
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SM-1
Insitu Cont^j[pnent with Impenn<*a]pt«f Cap and Barriers
"In-situ" refers to a technique the occurs "in place" without
excavating the disposal;area. This alternative would require the
construction of an upgraded cap of synthetic material to cover the
1.5-acre site. Capping helps minimize the movement of
contaminants by reducing the amount of precipitation (i.e., rain
and snow melt) that could filter through the wastes and allow
contaminants to migrate from the site. In addition, this
alternative would require construction of a groundwater cutoff
wall to limit groundwater from coming in contact with contaminated
soils. Construction of the cutoff wall would entail digging a
trench around the entire disposal area and creating a wall of
impermeable material inside the trench.
Capping is a widely-used technique that reduces the mobility of
contaminants, but it does not reduce toxicity or volume. Because
capping would contain the contamination untreated on site, future
site use would have to be restricted. Capping does not meet the
statutory preference for a permanent remedy. This alternative
would require a 5-year review since contaminants would remain on-
site.
Estimated Time for Construction: 13-18 months
Estimated Period of Operation: 30-year lifetime for cover and
cutoff wall
Estimated Capital Cost: $710,000
Estimated Present Worth of Operation and Maintenance Costs:
$200,000
Estimated Total Cost: $910,000
SM-2
In-Situ Soil Flushing with fal Incineration or fb) Biodecrradation
of Recovered Liquids
This alternative would involve pumping a solvent or surfactant
solution through the contaminated soil. As the solution
percolates through the ground, PCBs and VOCs are released from the
soil and carried with the solution to a groundwater collection
system that would be installed surrounding the site. Once the
groundwater is collected, the chemical solution and contaminants
would be extracted from the water and then either (1) incinerated
at an approved hazardous waste incinerator, or (2) treated by
biodegradation. EPA does not consider this alternative to be a
feasible project for the Rose site because of the low soil
permeabilities for in-situ application and the long time frame
required for development. GE states that a 4 to 6 year period is
required to develop the process prior to any design or
implementation activities.
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Short tarn impacts would b« minimal since no excavation would be
required, and long term environmental or health impacts were not
determined in the draft FS. This alternative has been tested on
an experimental level only; extensive additional laboratory'and
on-site testing would be required to determine the cost, cleanup
duration and overall effectiveness of this technology. EPA
concludes that this alternative does not meet the criteria for
implementability and effectiveness.
Estimated time for Construction and Operation: Undetermined
Estimated Total Cost: Undetermined
SM-3
KOHPBC Dechlorination
This alternative consists of excavating contaminated soil and
sediments and mixing them in a stainless steel chamber with a
combination of chemicals forming a reagent, KOHPEG, capable of
destroying PCBs. The mixture is heated (to approximately 150*C)
to increase the rate of.destruction of PCBs, and to drive off
VOCs in the soil. The VOC vapor is then captured with carbon
filters. Decontaminated soils would be replaced on site.
KOHPEG dechlorination would provide long term protection of public
health and the environment, compliance with ARARs, and would r«du'
the toxicity, mobility and volume of site contamination
permanently. Implementation of KOHPEG dechlorination would require
construction of a mobile treatment unit. This alternative would
require the use of engineering controls to prevent the emission of
contaminants during the excavation of contaminated soil and
sediments and during the actual treatment process. The
implementability and effectiveness of this technology at full-scale
is unproven at this time.
Estimated Time for Construction: Uncertain
Estimated Period of Operation: 2 years
Estimated Total Cost: $4,000,000 - $7,200,000
SM-4
OnSite Incineration
This alternative has been chosen as the remedy for the site.
Please see Section X for details.
Off-Site Incineration
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Under this alternative, contaminated soil and sediments would be
excavated and transported to an off-site hazardous waste
incinerator. Several incinerators currently licensed to received
PCB-contaminated wastes include: Calumet, Illinois; El Dorado,
Arkansas; and Deer Park, Texas. Similar incineration and .
pollution control processes that are used off-site would be used
at an on-site incinerator. The GE incinerator in Pittsfield is
licensed to receive PCB-contaminated liquid wastes only and cannot
be used to destroy PCB-contaminated soil from the Rose site.
While off-site incineration would remove the risk of contamina-
tion at the site, permanently destroy the contaminants, and would
meet ARARs, this alternative would present increased risk to human
health and the environment through increased traffic and off-site
shipment of contaminated wastes. These impacts will not occur with
on-site incineration. This alternative also would require
engineering solutions to prevent the emission of contaminants
during excavation and transportation of contaminated soil and
sediments over long distances.
It is possible that the limited capacity and high demand for the
existing off-site incinerators could result in a longer-term
operation than would on-site incineration. Costs associated with
this alternative would be much higher due to both transportation
and off-site charges. Therefore, EPA concludes that this
alternative is less cost effective than on-site incineration.
Estimated Period of Operation: 2 years
Estimated Total Cost: $44,000,000
SM-6
OnSite Disposal in an Approved Hazardous Waste Landfill
This alternative would require construction of a federally-
approved TSCA hazardous waste landfill on the Rose property. The
landfill would include a synthetic liner as well as a leachate
collection system to prevent potentially contaminated liquids from
migrating from the area. Contaminated soil and sediments would be
excavated and placed in the landfill. Groundwater monitoring would
be conducted to ensure the integrity of the landfill and leachate
collection system.
Landfilling is a proven technique for containing PCBs and other
hazardous wastes. Although mobility of the wastes is reduced,
landfilling does not reduce the toxicity or volume of the wastes.
Also, should the disposal facility fail, this alternative would
present a risk to public health and the environment. This al-
ternative, therefore, would not provide long-term effectiveness
nor meet the statutory preference for a permanent remedy. TSCA
regulation 761.75(b)(3) requires that the bottom of a landfill be
at least 50 feet above the groundwater table. This requirement
17
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could not be met at the Rose sit*, therefore, it would not provide
compliance with ARARs. This alternative also would require
engineering solutions to prevent the emission of contaminants
during excavation of contaminated soil and sediments and during
placement of the contaminated material into the landfill.
Estimated Time for Construction: 2 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $3,450,000
Estimated Present Worth of Operation and Maintenance Costs:
$255,000
Estimated Total Cost: $3,700,000
SM-7
Offsite Disposal in an Approved Iiflndfill
This alternative would involve excavating contaminated soil and
sediments, reducing the moisture content, and disposing of the
waste at an approved off-site TSCA hazardous waste landfill.
There are currently several facilities in the United States
approved for disposal of PCB-contaminated wastes including: Model
City, NY; Niagara Falls, *Y; Cincinnati, OH; Emelle, AL; Deer
ParX, TX; and Grassy Mountain, UT. After the contaminants are
removed, clean soil would be hauled in to fill in the excavated
areas.
Off-site disposal removes the risk of contamination at the site.
However, since contaminants remain untreated, it is not a
permanent remedy. In addition, off-site disposal of untreated
wastes is the least favored alternative under CERCLA. This
alternative would present a risk to public health and the
environment due to increased traffic and off-site shipment of
contaminated wastes, or if the off-site disposal facility were to
fail. Off-site disposal would not provide long term
effectiveness. This alternative would require engineering
solutions to prevent the emission of contaminants during
excavation and transportation of contaminated soil and sediments
to the off-site facility.
Estimated Time for Removal: 2 years
Estimated Total Cost: $7,000,000
SM-8
Chemical Fixation/Stabilization of Excavated Waafreii
This alternative involves a process in which contaminated soil and
sediments would be excavated and mixed with a material such as
cement, flyash, or various polymers to bind or "fix" the
contaminants into a solid material. After stabilization of the
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soil and sediments, the material would be used to regrade the
site.
This alternative has the potential to greatly reduce the mobility
of the contaminants (with resultant increase in volume),
minimizing long term environmental effects. The toxicity,
however, would not be affected and the stabilized material would
still be a hazardous substance since the contaminants would not be
destroyed.
A number of stabilization technologies for soils with varying
levels of organic contamination are currently under development
under EPA's Superfund Innovative Technology Evaluation (SITE)
program. (Descriptions of these development programs and the EPA
SITE program are included in the Administrative Record and are
discussed in Response 24 of the responsiveness summary.) On the
basis of the information that is currently available, EPA is
unable to determine that this alternative would satisfy the
statutory preference for a permanent remedy since the
effectiveness of stabilization has not been demonstrated for the
levels and type of contamination found at the Rose site. For
these reasons, EPA finds that stabilization does not meet the
criteria of implementability and long term effectiveness for the
Rose site.
This alternative would require engineering solutions to prevent
the emission of contaminants during excavation and treatment of
contaminated soil and sediments. In addition, air emissions of
the fixed material may be of concern and would require monitoring.
This alternative would require a 5-year review since contaminants
would remain on-site.
Estimated Period of Operation: 2 years
Estimated Total Cost: $3,000,000
SM-9
Chemical Extraction with Incineration of Recovered Liquids fSoil
Washing)
This alternative is similar to alternative SM-2 in that
contaminants are extracted chemically from the soil and sediments.
In this alternative, however, excavation would be required prior to
treatment. Excavated materials are mixed in a chamber with
acetone, a solvent that releases PCBs and VOCs from the soil.
Steam is then injected into the system, separating the
acetone/contaminant mixture from the soil. At this point, the
cleaned soil is returned to the site. The acetone/contaminant
water mixture is then combined with kerosene, which draws the VOCs
and most of the PCBs out of the acetone and water. Contaminated
kerosene is removed from the site and incinerated. The
acetone/water mixture remains in the system and is distilled to
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recycle the acetone for reuse in the treatment process. All vapor
eaissions would be treated prior to release to the atmosphere.
This alternative may be used in combination with selected remedy to
enhance the efficiency of the incineration process.
This alternative has been proven effective in laboratory testing.
Field testing would be required to determine the cost,
implementability, and short and long term effectiveness at the
Rose Site. 6E*s consultants estimate that testing and development
of the full-scale treatment system would take 3 to 5 years. It
would need to be demonstrated that ARARs and long term environ-
mental and public health protection would be met by this
alternative. This alternative would require engineering solutions
to prevent the emission of contaminants during excavation and
treatment of contaminated soil and sediments. Additional
precautions for handling kerosene and acetone, both of which are
flammable, also would be required. EPA may give this alternative
further consideration as a demonstration project.
Estimated Time for Construction and Operation: Undetermined
Estimated Total Cost: Undetermined
SH-10
On-Site Biodeqradation
A biodegradation process uses naturally-occurring or laboratory-
tailored bacteria to degrade, or break down, organic compounds
such as PCBs and VOCs into harmless materials such as carbon
dioxide, water, and humus. In essence, this alternative is a
specialized form of composting. While biodegradation has been
shown to be effective treating other types of hazardous waste, the
effectiveness and implementability of this alternative for
destruction of PCBs at the Rose site has not been demonstrated.
This alternative has not been retained by EPA for further
consideration for a demonstration project because long times
frames are anticipated in GE's research and development program
that would be applicable at the Rose site.
This alternative has been tested on an experimental level;
additional laboratory and on-site testing would be required to
determine the cost, cleanup duration, and short and long term
effectiveness of this technology at the Rose site. This
alternative also would require engineering solutions to prevent
the emission of contaminants during excavation and treatment of
contaminated soil and sediments. Because the effectiveness has
not been demonstrated, EPA cannot determine that this alternative
would destroy contaminants, meet ARARs, or satisfy the other
selection criteria.
Estimated Time for Operation: Undetermined
Estimated Total Cost: Undetermined
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B. Management of Migration (GW) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
Rose site, VOC contaminants (and PCBs to a lesser extent) have
migrated from the disposal area, predominantly via groundwater.
The management of migration alternatives evaluated for the Site
include a minimal no action with monitoring alternative (see
Alternative SM-0), as veil as 4 other groundwater alternatives.
Massachusetts DEQE has stated that it will require Best Available
Control Technology (BACT) on the air stripper as a new source,
regardless of the size of the (new) groundwater treatment
equipment, based on 310 CMR 7.00. Therefore, a carbon filter will
have to be placed on the air stripper. This addition adds to both
the capital and operating and maintenance costs that the draft FS
estimated for any alternative which includes an air stripper (GW-l
and GW-1A).
The estimated time for construction and operation is stated as 10
years, the estimate used in the draft FS. The 10-year period was
an estimate only to provide a basis for cost comparison of the
various GW alternatives. It should be noted, however, that the
actual time required for groundwater treatment to meet the cleanup
goals is directly related to removal/treatment of the source area
and particularly the free product which exists in the saturated
zone. EPA estimates that if no action is taken to remediate the
source area than the groundwater treatment system would have to
operate indefinitely.
GW-l
Air Stripping/Carbon Treatment
This alternative has been chosen as the groundwater remedy for the
site; see Section X for details.
GW-1A
Air Stripping/Carbon Treatment with Hydrogen Peroxide Pretreatment
This alternative would utilize the same process as alternative GW-l
with the addition of hydrogen peroxide (H202) pretreatment. In
this process, extracted groundwater would be mixed with H202 and
then passed through a sand filter. Use of this pretreatment
process would remove approximately 75% of the VOCs in the
groundwater rather than depending predominantly on the air
stripper for VOC removal. After pretreatment, groundwater would
follow the same treatment path described in alternative GW-l in
Section X. Spent carbon would be handled in a manner similar to
that as described in alternative GW-l in Section X.
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Air stripping i» a proven technology for the removal of volatile
organic compounds of the types that hava baan found at tha Ro»a
ita. Air stripping with pretreatment has baan usad succassfully
at savaral hazardous vasta sitas. This technology would provide
overall long ten effectiveness and compliance with ARARs. It
would provide permanent reduction in the site contamination.
Short ten effects, such as air emissions, could be minimized
through engineering controls. Spent carbon would be handled in a
manner similar to that described for GW-1.
This technology, although considered to be comparable to GW-l in
cost and effectiveness, could be more difficult to implement due
to the additional step required. In addition, tha cost estimate
for. GW-1 is considered to be the most accurate; see the discussion
in Appendix F on this issue.
Estimated Time for Construction and Operation: 10 years
Estimated Capital Cost: $503,000
Estimated Present Worth of Operation and Maintenance Costs:
$615,000
Estimated Total Cost: $1,118,000
CW-2
Ultraviolet Itioht » Ozonation with Hydrogen Peroxide Pratreatment
This alternative would consist of the same pretreatment process
described in alternative GW-la. Following both H202 pretreatment
and filtering through sand beds, the groundwater would be treated
with ozone in the presence of ultraviolet (UV) light to destroy
PCBs and any remaining VOCs. Because ozone is a highly reactive
gas and toxic in high concentrations, any off-gases from the
process would be passed through an ozone decomposer to change the
ozone into oxygen prior to release.
UV-Ozonation is a relatively new technology, but has been proven
effective in treating hazardous wastes containing VOCs and PCBs.
This technology is currently a demonstration project under the EPA
SITE program. This technology would comply with ARARs, and it
would have long ten effectiveness and provide a permanent
reduction in site contamination. Short ten effects could be
minimized through engineering controls. This technology would
potentially be more difficult to implement than GW-l due to its
stage of development.
Estimated Time for Construction and Operation: 10 years
Estimated Capital Cost: $585,000
Estimated Present Worth of Operation and Maintenance Costs:
$560,000
Estimated Total Cost: $1,145,000
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GW-3
Carbon Treatment with Hydrogen Peroxide .
This alternative also would utilize the same hydrogen peroxide
pretreatment as in alternatives GW-1A and GW-2. H202 pretreatment
would be utilized to remove 80% to 90% of the VOCs. Carbon
filtering would then be utilized to remove the PCBs and the
remaining VOCs. Spent carbon would be handled in a manner similar
to that as described in alternative GW-1 in Section X.
Additional testing would be. required to prove the effectiveness of
hydrogen peroxide in removing high levels of VOCs, and its ability
to meet ARARs, prior to construction of the treatment facility.
This alternative would reduce the volume, toxicity, and mobility of
the contaminants permanently and would utilize engineering controls
to minimize short term impacts.
Estimated Time for Construction and Operation: 10 years
Estimated Capital Cost: $370,000
Estimated Present Worth of Operation and Maintenance Costs:
$880,000
Estimate Total Cost: $1,250,000
X. THE SELECTED REMEDY
The selected remedy is comprehensive since it includes both a
source management and a management of migration component.
A. Description of the Selected Remedy
After evaluating all of the feasible alternatives, EPA is
selecting a two-part.cleanup plan.to address soil and groundwater
contamination at the Rose site.
1. Air stripping and carbon treatment is selected to prevent
the spread of contamination through the groundwater and to restore
contaminated groundwater. The Rose Pond would be drained and the
water treated in the same manner if the levels continue to exceed
the groundwater cleanup goals.
2. On-site incineration is the selected alternative for
addressing soil and sediment contamination.
In an effort to encourage development of alternative technologies
for treatment of hazardous waste, however, EPA is considering
allowing GE to conduct a demonstration project for application at
the site during the design of the on-site incinerator. This
alternative is chemical extraction with incineration of extracted
liquids (SM-9). This alternative would be considered for use if it
is demonstrated to meet the criteria for evaluation for remedy
23
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selection. If the alternative is not proven to be effective by
nd of the incinerator design phase, construction and operation
the incinerator would begin immediately upon completion of desi
This demonstration project would be conducted in parallel with the
remedial design for the on-site incinerator.
To minimize further spread of contaminants from the disposal area,
EPA is requiring that groundwater treatment begin immediately and
continue until the groundvater cleanup goals are achieved.
Recovery of the subsurface free product will continue. This
oil/water/solvent mixture will continue to be shipped off-site for
thermal destruction at an approved TSCA incineration facility.
B. Rationale for Selection/Points of Compliance
The rationale for choosing the selected alternative is based on
the assessment of each criteria listed in the evaluation of
alternatives section of this document. In accordance with Section
121 of CERCLA, to be considered as a candidate for selection in the
ROD, the alternative must have been found to be protective of human
health and the environment and able to attain ARARs unless a waiver
is granted. In assessing the alternatives that met these statutory
requirements, EPA focused on the other evaluation criteria,
including short term effectiveness, long term effectiveness,
implementability, use of treatment to permanently reduce the
mobility, toxicity and volume,.and cost.
EPA has determined that incineration is the only available
technology which satisfies all of these criteria, particularly
permanence, and that on-site incineration is more cost effective
than off-site incineration for the Rose site. Additionally, the
short term impacts associated with off-site incineration of
increased truck traffic and the transportation of contaminated
materials untreated over long distances are considered to be less
acceptable than the construction impacts associated with on-site
incineration. Further, many of the potential source remedies were
not considered by EPA to be implementable because the technology
has not yet been developed. Zn addition, the groundwater treatment
is deemed necessary to comply with EPA's Groundwater Protection
Strategy and the RCRA Subpart F and 6 requirements.
EPA also considered nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance. Based upon this assessment, taking into account the
statutory preferences of CERCLA, EPA selected the remedial
approach for the Site.
1. Source Management
The source management portion of the remedial action is designed
to permanently destroy the source area soil and sediment
contamination.
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Under this alternative, contaminated soil and sediments will be
excavated and then burned in a transportable thermal destruction
facility that will be set up at the site. Three different types
of incinerators were evaluated: rotary kiln, circulating fluid-
ized bed, and infrared processing. The extremely high tempera-
tures in any of these thermal destruction facilities would destroy
virtually all of the organic contaminants. The TSCA regulations
require that the destruction and removal efficiency of PCBs by
incineration be 99.9999% and the ash (decontaminated soil) must
contain less than 2 ppm PCBs. Exhaust gases will be passed through
air pollution control devices before being released into the
atmosphere. All soil will be tested to ensure that the PCB cleanup
goals have been met and that acceptable levels of metals are
present. Decontaminated soil will be replaced on site.
On-site incineration will provide long term protection of human
health and the environment. Organic contamination is destroyed;
no mobility, toxicity, or volume concerns remain, so that the
remedy will comply with ARARs. This alternative is a proven
technology and it will require engineering controls to prevent the
emission of contaminants during excavation of contaminated soil and
sediments and during actual thermal treatment, to minimize short
term impacts and to meet site specific air quality ambient action
and emissions limits. These controls will be developed during the
design process.
On-site incineration will utilize a transportable (mobile) unit.
Such systems are commercially available at the present time. It .
should be noted, however, that full scale operation of these
transportable units has been limited, and periods of downtime have
been experienced.
The extent of excavation will be to the seasonal low water table
for the majority of the disposal area. EPA has determined that
extensive dewatering would not be practicable at this site for the
reasons explained in Section VII of this ROD and is not necessary
to be protective since PCBs will be effectively immobilized by
groundwater treatment. Of equal importance, the potential impacts
on the nearby wetland from a large dewatering effort which could
lower the water table significantly are unacceptable.
Deeper excavation will be required only in the free product area
that is believed to be localized. Since the time for groundwater
treatment is directly dependent upon the volume of the source
area, this source area will be removed and treated.
The deep saturated soils which will remain on site contain PCBs up
to a maximum of approximately 5000 ppm. Leaving these soils in
place will require imposition of institutional controls for the
disposal area to prevent groundwater use and excavation in the
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saturated zone. In addition, capping the sit* will prevent any
direct contact with the remaining PCBs in the saturated rone.
Potential vast* stream* that will be generated by the incineration
process requiring disposal include material collected by the air
pollution control device(s). This material will need to be
disposed of in accordance with the land disposal ban and all other
applicable requirements.
Estimated Tint* for Construction and Operation: 2 years
Estimated Capital Cost: $208,400
Estimated Present Worth of Operation and Maintenance Cost:
$5,000,000
Estimated Total Cost: $5,200,000
2. Management of Migration
The management of migration portion of the remedial action is
designed primarily to treat contaminated groundwater that is
migrating from the sit*.
EPA will address groundwater contamination at the Rose site by
utilizing a combination of air stripping and carbon treatment.
The treatment system will entail construction of trenches or wells
to collect shallow groundwater from the 2 plumes of contamination.
In addition, a well will be installed in bedrock in the vicinity
the free product area to prohibit migration into fractured rock.
Collected groundwater will be pumped to an air stripping tower.
air is forced up through the tower, VOCs are removed from the
groundwater into the air stream. This air stream containing VOCs
is passed through an activated carbon filter to remove contaminants
before being released into the atmosphere.
Following air stripping, the groundwater will be passed through
activated carbon filter beds to remove PCBs and any residual
contaminants. Treated water will then be discharged into an area
where it will be returned to the aquifer. Water from the Rose's
pond will be treated in the same manner, if necessary, after being
pumped from the pond.
Air stripping is a proven technology for removing volatile organic
compounds of the type that have been found at the site. EPA has
used air stripping and carbon treatment successfully at numerous
hazardous waste sites. This technology will provide overall
protection of human health and the environment and compliance with
ARARs. It will provide permanent reduction in the site
contamination and will provide long term effectiveness. Short term
effects can be minimized through engineering controls, such as the
use of carbon filters. EPA believes that air stripping followed by
carbon treatment is the easiest management of migration alternative
to implement.
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The draft FS did not include the costs of a carbon filter on the
air stripper. Because Massachusetts DEQE requires Best Available
Control Technology (BACT) for all new sources, EPA has estimated
the additional costs of a carbon filter and has added them here.
See Appendix F for these cost calculations.
Spent carbon will be generated from the (used) carbon filters.
These spent filters will be disposed of either by manufacturer
regeneration, incineration, or an alternative disposal method
which will comply with the land disposal ban and the RCRA
regulations.
Estimated Time for Construction and Operation: 10 years
Estimated Capital Cost: $466,000
Estimated Present Worth of Operation and Maintenance Costs:
$790,000
Estimated Total Cost: $1,256,000
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Rose site
is consistent with CERCLA and, to the extent practicable, the NCP.
The selected remedy is protective of human health and the
environment, attains ARARs and is cost effective. The selected
remedy also satisfies the statutory preference for a permanent
solution and for treatment which reduces the mobility, toxicity or
volume as a principal element. Additionally, the selected remedy
utilizes alternate treatment technologies to the maximum extent
practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will permanently reduce the risks
presently posed to human health and the environment by:
preventing exposure to contaminated soils by excavation
and incineration of the contaminated soils above the
water table;
protecting uncontaminated groundwater and surface water
for current and future use by intercepting and treating
contaminated groundwater and by removing the free
product layer below the water table, thereby eliminating
the source for potential future contamination; and
restoring contaminated groundwater for potential future
use and elimination of this source of contamination of
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Rose's pond and surrounding w«tland areas, tharaby
removing tha thraat to wildlifa.
Tha Salactad Remedy Attains
Ibis remedy will maat or attain all applicable or ralavant and
appropriate fadaral and stats requirements that apply to the site.
Federal environmental lavs which are applicable or relevant and ap-
propriate to the selected remedial action at the Rose site are:
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Executive Order 11990 (Protection of Wetlands)
Toxic Substances Control Act (TSCA)
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
Table 8 lists potential action-specific State ARARs and presents a
brief synopsis of the requirements. Note that via the state
programs authorization process, Massachusetts' hazardous waste
regulations under Chapter 21C are essentially equivalent to the
federal counterpart found at 40 CFR Subpart F (releases from solid
waste management units, including groundwater monitoring
requirements) and Subpart 6 (closure and post-closure).
Table 5 lists the chemical-specific ARARs for groundwater. Table
7 lists potential action-specific Federal ARARs. A brief
narrative summary of the ARARs follows.
The Resource Conservation and Recovery Act (RCRA) closure
regulations require closure by removal of waste, waste residues
and contaminated subsoils which is equivalent to closure as a
surface impoundment or waste pile (40 CFR 264 Subpart K and L) j or
closure as a landfill by capping and appropriate post-closure care
(40 CFR 264 Subpart N). The selected remedy for the Rose site
attains the general RCRA closure performance standards as specified
in 40 CFR | 264.111:
The owner or operator must close the facility in a manner that:
(a) Minimizes the need for further maintenance;
(b) Controls, minimizes or eliminates, to the extent
necessary to protect human health and the environment,
post-closure escape of hazardous waste, hazardous
constituents, leachate, contaminated run-off, or
hazardous waste decomposition products to the ground or
surface waters or to the atmosphere; and
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(c) Complies with the closure requirements of Subpart 6
including, but not limited to, the requirements of §§
264.178, 264.197, 264.228, 264.258, 264.280, 264.310 and
264.351.
Excavation and treatment of PCB-contaminated soils above 13 ppm
above the water table will result in the removal of a large
portion of wastes and waste residues and it will eliminate the
direct contact threat from those contaminants, as well as their
contribution to groundwater contamination. The management of
migration groundwater treatment option will minimize and eliminate
to the extent necessary the migration of contaminants from the
site. The restriction of on-site groundwater use, in conjunction
with the RCRA closure and post-closure requirements in §§ 264.115,
264.116, 264.117, 264.119 and 264.120, will provide the necessary
long term protection for public health and the environment.
.Regarding management of migration measures, the specific relevant
Federal regulations are the RCRA Releases from Solid Waste
Management Units, including the groundwater monitoring
requirements (40 CFR 264 Subpart F), the Clean Water Act (40 CFR
Part 122) and the Safe Drinking Water Act (40 CFR 141 Subpart B).
The groundwater protection regulations require the setting of
groundwater protection standards which must be protective of
public health and the environment. The groundwater cleanup goals
were set at MCLs, proposed MCLGs, LHAs, or site-specific levels
that EPA has determined will adequately protect public health at a
lifetime cancer risk of 10~6 (see Section VI).
A groundwater monitoring system will be implemented consistent
with 40 CFR § 264.100(d) to determine the effectiveness of the
groundwater remediation system.
The remediation of groundwater is consistent with the U.S. EPA
Groundwater Protection Strategy (August 1984) which classifies the
aquifer at the Rose site as Class IIA (current usage) and requires
the restoration of these aquifers.
The Safe Drinking Water Act (SDWA) is only applicable to public
drinking water supplies (i.e. a water supply serving 25 or more
people). However, EPA considers the MCLs established under the
SDWA to be relevant and appropriate. Table 5 lists the relevant
MCLs for the Rose site. EPA finds that it is technically
infeasible to reduce PCB levels in groundwater within the 1.5-
acre disposal area to the 0.005 ppb health-based level and
institutional controls will be required for the disposal area.'
This is discussed in Section VI and VII of this ROD.
The remedy will comply with Executive Order 11990 - Protection of
Wetlands, the Clean Water Act § 404(b)(l) guidelines and the State
Wetland Protection Act (310 CMR 10.00). Rose's pond is an
artificial pond that was excavated by a previous landowner to
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drain the surrounding wetland area. The pond has been affected by
the sit* and it will b« affacted by tha remedy. Because the pond
water exceeds the groundwater cleanup goals, it will be necessary
to drain and treat this water. Because the pond bottom sediments
exhibit PCB levels in excess of the PCB cleanup goal, these-
sediments will be excavated for thermal treatment. EPA finds that
there is no practicable alternative to these actions since it is
the pond itself that is contaminated. Implementation of the remedy
will utilize measures to restore the pond to its original wetlands
character after remediation and to minimize any harm to the
surrounding wetlands. In addition, the operation of the
groundwater treatment system is intended to prevent contamination
from the shallow aquifer from impacting the wetlands, and this
system will operated to minimize any impacts on the surrounding
Under TSCA, soils contaminated with PCBs at concentrations greater
than 50 ppm that are disposed of after February 17, 1978 must be
disposed of in accordance with 40 CFR 761 Subpart D. Since
incineration is selected as the source treatment technology,
treatment and disposal of the 15,000 cubic yards of the PCB-
contaminated waste will be in accordance with the criteria of 40
CFR 761.70.
The 50 ppm TSCA regulatory threshold referred to in GE's draft
Feasibility Study is not a cleanup standard. The establishment of
this regulatory limit was based on economic and administrative
considerations as well as human health and the environment. As
such, on a site-specific basis, it does not necessarily achieve the
objective of Section 121 of CERCIA. In this case, EPA developed a
site-specific health-based cleanup standard for PCBs based upon a
risk assessment that considered future use of the Rose site.
The TSCA PCB Spill Cleanup Policy (TSCA Section 761.120 Subpart 6;
April 2, 1987) provides cleanup guidelines based on access to the
site that were considered in determining the site-specific cleanup
level. The PCB cleanup level of 13 ppm for the Rose site is
considered to be consistent with the cleanup guideline of 10 ppm
suggested in this policy.
During the excavation and treatment of PCB and VOC-contaminated
soils, and during the groundwater treatment, air emissions will be
monitored and all relevant Federal and State standards will be
attained. Specifically, the National Ambient Air Quality
Standards (NAAQS) will be met through specified techniques for
excavation activities, as well as required air monitoring for the
incinerator and during excavation, to ensure that site-specific
ambient action levels are not exceeded.
During the excavation and treatment of contaminated soils and
during groundwater treatment, OSRA regulations will be followed.
In particular, 29 CFR 1910.120 specifies standards for handling
30
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hazardous wastes and 29 CFR 1910.1000 sets allowable ambient air
concentrations for activities which involve release of VOCs in the
workplace. Techniques such as limiting the extent of excavation,
use of suppressant foams, and use of air purifying and filtering
devices will be utilized to provide compliance not only with OSHA
regulations but also any federal and state air quality standards.
C. The Selected Remedial Action is Cost Effective
Once EPA has identified alternatives that are protective and
attain ARARs, EPA analyzes those alternatives to determine a cost-
efficient means of achieving the cleanup.
The estimated cost of on-site incineration may be somewhat higher
than several of the other source management alternatives.
However, EPA believes that the remedy is cost effective due to the
fact that only incineration will permanently destroy the organic
contamination at the site. Future remedial action with associated
costs may be needed if wastes are left on site. When comparing
equivalently protective alternatives that provide permanent
remedies, KOHPEG and on-site incineration were considered to have
approximately the same cost. However, because of the lack of full-
scale implementability of the KOHPEG process, EPA considers
incineration to be preferable for the Rose site.
The actual costs for on-site incineration are difficult to
estimate precisely. However, the $380 per cubic yard estimate for
on-site incineration is well within the range provided by guidance
and vendor quotes. EPA believes that the remedial on-site
treatment market is becoming more competitive. The cost of
remedial services may decline due to factors such as increased
market competition, more efficient design and operation of
treatment equipment, improved materials handling capability, and
increased availability of equipment and treatment capacity.
The costs for GW-1 and GW-1A are considered to be approximately
the same due to the level of detail in the estimates (+50/-30%)
for feasibility studies. Further, the cost estimate for
alternative GW-1 is considered to be the most accurate. GW-1
technology has been implemented full-scale at several Superfund
sites, while the other GW alternatives have not been used as
extensively. See Appendix F for further discussion of the accuracy
of the GW cost estimates.
The addition of the GAC filter on the air stripper increased both
the capital and O&M costs for the GW-1 and GW-1A alternatives. The
design of the actual groundwater treatment system will determine if
a pretreatment phase is desirable to reduce the O&M costs. See
Appendix F for calculation of the adjusted cost estimates.
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D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the maximum Extent Practicable
«
Incineration is an alternative treatment technology that will
provide a permanent solution to the PCB problem at the site.
Excavation of the PCB-contaminated soils in the unsaturated zone
to 13 ppm and treatment by incineration will reduce the risks
posed to human health from direct contact with on-site soils by
virtual complete destruction of the organic contaminants, as well
as elimination of the potential risk of release of PCBs from this
zone into groundwater. This soil treatment process will also
provide the added benefit of treating a large quantity of VOCs in
the unsaturated zone, thus assisting in the cleanup of
groundwater. In addition, eliminating a significant source of
contamination to the groundwater by removal of the free product
below the water table will substantially reduce the time required
to meet the groundwater treatment goals.
Treatment of the groundwater will permanently and significantly
reduce the volume, toxicity and mobility of the volatile organic*
as well as reduce the mobility of the PCBs present in the
saturated zone soil matrix. Restoration of the aquifer will
permit the groundwater beyond the disposal area to be used for
drinking water purposes in the future. However, EPA will require
that institutional controls restricting groundwater use be
implemented for the disposal area.
Further, restoration of the groundwater will eliminate the threat
posed to public health and the environment from the current and
future extent of contaminant migration in groundwater and surface
water.
X. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The principal element of the selected remedy is the excavation and
on-site incineration of contaminated soil and sediments. This
element addresses the threat at the site of contamination of soil
and sediments with PCBs and VOCs. The selected remedy also
satisfies the statutory preference for treatment as a principle
element by requiring groundwater treatment.
However, some PCB contamination will remain in the saturated zone.
Only the VOC contamination in this zone will be treated to
immobilize the PCBs. The basis for this is discussed previously
in Section X.
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XII. STATE ROLE
In accordance with CERCLA Section 121(f)(1)(E) and (6), EPA has
provided the Commonwealth of Massachusetts' Department of
Environmental Quality Engineering a reasonable opportunity to
review and comment on the Remedial Investigation, the Endangerment
Assessment, and the Feasibility Study. EPA has also provided
notice to the State and an opportunity to comment on the Proposed
Plan for remedial action at the Site. A copy of the State's
correspondence is attached as Appendix C.
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Responsiveness Summary
Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
September 23, 1988
U.S. Environmental Protection Agency
Region I
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ROSE DISPOSAL PIT
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
Page
PREFACE 1
Z. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY, INCLUDING THE PREFERRED
ALTERNATIVE 2
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS. . . 4
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES
Part I - Citizen Comments 6
A. Comments Regarding the Remedial Alternatives . . 6
B. Comments Regarding Groundwater Quality 9
Part II - Potentially Responsible Party Comments. . . 9
IV. REMAINING CONCERNS 48
EXHIBIT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE ROSE
SITE
EXHIBIT B - TRANSCRIPT FROM THE INFORMAL PUBLIC HEARING
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PREFACE
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 21, 1988 to August 19, 1988 to provide an
opportunity for interested parties to comment on the draft
Feasibility Study (FS) and the July 1988 Proposed Plan prepared for
the Rose Disposal Pit Superfund site (Rose site) in Lanesborough,
Massachusetts. The draft FS examines and evaluates various
options, called remedial alternatives, for addressing
contamination of groundwater, surface water, soil and sediment at
the site. EPA identified its preferred alternative for the
cleanup of the site in the Proposed Plan before the start of the
public comment period.
The purpose of this responsiveness summary is to identify major
comments raised during the public comment period and to provide
EPA response to the comments. EPA has considered all of the
comments summarized in this document before selecting a final
remedial alternative for the contamination at the Rose site in
Lanesborough, Massachusetts.
This responsiveness summary is divided into the following
sections:
I. Overview of Remedial Alternatives Considered in the Draft
Feasibility Study. Including the Preferred Alternative -
This section briefly outlines the remedial alternatives
evaluated in the draft FS and the Proposed Plan, including
EPA's preferred alternative.
II. Background on Community Involvement and Concerns - This
section provides a brief history of community interest and
concerns regarding the Rose site.
III. Summary of Comments Received During the Public Comment Period
and EPA Responses - This section summarizes and provides EPA
responses to the oral and written comments received from the
public during the public comment period. In Part I, the
comments received from citizens are organized by subject. In
Part II, the extensive comments received from the PRP and
EPA's responses follow the order of presentation by the PRP.
A brief summary of PRP comments precedes EPA's detailed
response.
TV. Remainina Concerns - This section describes issues that may
continue to be of concern to the community during the design
and implementation of EPA's selected remedy for the Rose
site. EPA will address these concerns during the Remedial
Design and Remedial Action (RD/RA) phase of the cleanup
process.
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Exhibit A - This exhibit is a list of the community relations
activities that EPA has conducted to date at the Rose site..
Exhibit a - This exhibit is a copy of the transcript from the
informal public hearing that was held on August 3, 1988.
Z. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE DRAPT
FEASIBILITY STUDY, INCLUDING THE PREFERRED ALTERNATIVE
Using the information gathered during the Remedial Investigation
(RI) and the Endangerment Assessment (EA), EPA identified several
objectives for the cleanup of the Rose site. The response
objectives are:
1) prevent exposure to contaminated soils and groundvater;
2) protect uncontaminated groundvater and surface water for
current and future use; and
3) restore contaminated soils and groundvater for future use.
GE, with EPA oversight, screened and evaluated potential cleanup
alternatives for the Rose site. This evaluation, or feasibility
study (FS) report, specifically describes alternatives for
addressing contamination of groundvater and contaminated soil and
sediment, as veil as the criteria used to narrov the list to four
potential remedial alternatives for groundvater contamination and
eleven potential remedial alternatives for soil and sediment
contamination. Each of these alternatives is briefly described
below.
Croundvatar Alternative ilt Air Stripping/Carbon Treatment. For
this alternative, contaminated groundvater is pumped to the
surface or collected in trenches, and is then pumped to the top of
an air stripping tover. Air is forced up through the tover and
volatile organic compounds (VOCs) are removed from the groundvater
into the air stream. This air stream is passed through an
activated carbon filter to remove contaminants before being
released into the atmosphere. Following air stripping, the
groundvater is passed through a carbon filter to capture PCBs and
any residual contaminants.
In the Proposed Plan issued prior to the public comment period,
EPA recommended this alternative as the Agency's preferred
alternative for addressing groundvater contamination at Rose site.
Groundvater Alternatives ilAt Air Stripping/Carbon Treatment vith
Hydrogen Peroxide Pretreatnent. In this alternative, air
stripping/carbon treatment vould be proceeded by a hydrogen
peroxide pretreatment step. This vould involve mixing the
groundwater with hydrogen peroxide and passing the mixture through!
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a sand filter to remove approximately 75 percent of the VOCs before
the water enters the air stripping tower.
Groundvater Alternative <2; Ultraviolet Lioht-Ozonation with
Hvdroaen Peroxide Pretreatment. This alternative would consist of
the sane pretreatment process described in Alternative |1A,
followed by treatment with ozone and ultraviolet light to destroy
PCBs and any remaining contaminants.
Groundwater Alternative 13; Carbon Treatment with Hydrogen
Peroxide Pretreatment. This alternative would utilize hydrogen
peroxide pretreatment to remove 80 to 90 percent of the VOCs.
Carbon filtering then would be used to remove the PCBs and any
remaining contaminants.
Source Management! No Action Alternative. The no action
alternative would entail leaving contaminants untreated on site,
maintaining the existing synthetic cover and fence, continuing the
on-going program to recover the pocket of oil located beneath the
disposal site, and monitoring surface water and groundwater for 30
years.
Source Management Alternative lit In-Situ Containment with
Impermeable Cap and Barriers. This alternative would involve
covering the disposal site with a waterproof cap to limit the
amount of rain and snow that could filter through the wastes and
carry contaminants away from the site. A groundwater cutoff wall
also would be constructed around the disposal area to limit
groundwater contact with contaminated soils.
Source Management Alternative 12r In-Situ Soil Flushing with fai
Incineration or (b) Biodeqradation of Recovered Liquids. This
alternative would involve pumping a solvent or other solution
through the contaminated soils to release PCBs and VOCs. The
solution and contaminants then would be carried with the
groundwater and captured by a groundwater collection system.
After being separated from the groundwater, the contaminants would
be either incinerated or treated by biodegradation.
Source Management Alternative <3t KQHPEG Dechlorination. In this
alternative, contaminated soils and sediments would be excavated
and mixed in a chamber with a heated mixture of chemicals capable
of destroying PCBs. VOCs released by this process would be
captured with carbon filters prior to the treated air being
released to the atmosphere. Decontaminated soils would be replaced
on site.
Source Management Alternative 14; On-Site Incineration. Under
this alternative, contaminated sediments and soils would be
excavated and then incinerated in a mobile incinerator located at
the site. Decontaminated materials would be replaced on site.
All exhaust gases from the incinerator would be passed though air
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pollution control devices prior to release into the atmosphere.
As outlined in the Proposed Plan, EPA chose this alternative as
its preferred alternative for treatment of contaminated soil and
sediment.
Sourc« Management Alternative 15 t Off -Sit a Incineration. Undar
this alternative, contaminated soil and sediment would be excavated
and transported to an off -site hazardous waste incinerator.
Source Management Alternative tfit On-Site Disposal in an Approved
Hazardous Waste Landfill. This alternative would require
construction of a federally-approved TSCA hazardous waste landfill
on the Rose property. The landfill would include a waterproof
synthetic liner as well as a leachate collection system to prevent
potentially contaminated liquids from migrating from the area.
Groundwater monitoring also would be conducted to ensure that the
landfill and leachate collection system is functioning properly.
Contaminated soil and sediment would be excavated and placed within
the landfill.
Management Alternative §7? Off~Site TiJindfilling. This
alternative would involve excavating contaminated soil and
sediment and transporting this material to a federally-approved
off -site TSCA hazardous waste landfill.
Source Management Alternative 18 i Chemical Fixation-
Stabilization of excavated Wastes. In this alternative,
contaminated soil and sediment would be excavated and mixed with
material such as cement or flyash to bind or stabilize ("fix") the
contaminants into a solid material. Stabilized materials would be
replaced on site.
Management Alternative <9t Chemical Extraction with
Incineration of Recovered Liquids. In this alternative,
contaminated soil and sediment would be excavated and mixed with a
combination of chemicals to extract the contaminants. The
concentrated contaminants then would be transported off-site for
incineration. Decontaminated soil and sediment would be replaced
on site.
Source Management Alternative llQt On-Site Biodepradatien. In
this process, naturally-occurring or laboratory-tailored bacteria
would be utilized to degrade, or break down, site contaminants
into harmless materials such as carbon dioxide, water, and humus.
ZZ. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Rose site, which consists of a disposal area approximately 1.5
acres in size within a fourteen acre residential lot, is located in
Lanesborough, Massachusetts. Beginning in 1951 and continuing
through 1959 and possibly later, waste oils and solvents from the
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General Electric Plant in Pittsfield, Massachusetts were disposed
at the site in an open trench.
The neighborhood surrounding the site is a mix of protected
natural areas, farms, and low density residential development.
Reports on the possible presence of hazardous wastes at the -site
were first brought to the attention of town and state officials by
a neighborhood resident in 1974.
Community attention briefly focused on the site during the winter
of 1980 when the Massachusetts Department of Environmental Quality
Engineering (DEQE) conducted a site inspection. Following the
investigation, at the request of DEQE, General Electric (GE)
removed empty barrels from the site. Newspaper coverage of site
activities continued during EPA's initial site investigation and
the site's placement on the National Priorities List. Additional
coverage occurred when GE provided municipal water to residences
abutting the site and when EPA subsequently ordered GE to conduct a
Remedial Investigation/Feasibility Study of the site.
According to residents, there has been very little sustained
community interest in the site. Until EPA held a public
informational meeting in July 1988, concerns focused on the lack
of information available on the site, potential health effects
resulting from the site contamination, and confusion about the
respective roles of EPA and GE, the Potentially Responsible Party.
At the July 1988 public meeting, community concerns focused on the
extent of the site contamination, EPA's preferred alternative, and
other hazardous waste sites in Lanesborough. Specific concerns
voiced by residents are outlined below.
Roles of EPA, the State, and the PRP
Citizens expressed confusion about who is ultimately responsible
for cleaning up the Rose site. Citizens expressed their desire
that EPA make the final decisions about the cleanup. Citizens
also asked for regular information updates from EPA.
Extent of Site Contamination
Citizens expressed concern about what steps EPA was taking to
prevent the spread of contamination from the site. In addition,
citizens asked about potential contamination of private wells and
about ways to have their wells tested for contamination.
EPA's Preferred Alternative
Citizens expressed concern about the potential impact that
operation of a hazardous waste incinerator might have on the
community. Specific concerns focused on the noise associated with
excavation and incineration, possible air pollution resulting from
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excavation and incineration, and the potential for vast** from
other communities being shipped to the site for treatment.
Other Hazardous Waste Sites in Lanesb.orouah
A number of citizens stated their concern that the owner of the
Rose site at the tine wastes were deposited at the site also owned
other suspected or confined hazardous waste sites in the town.
Citizens asked EPA to investigate the potential impacts of these
sites on the community and on the municipal water supply.
Future Use of the Site and Surrounding Areas
Residents expressed concern that future development of the site
could pose a health risk to the future residents. One citizen
asked EPA about possible restrictions on development of land
adjacent to the site.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES
This responsiveness summary addresses the comments received by EPA
concerning the draft FS and Proposed Plan for the Rose Superfund
site in Lanesborough, Massachusetts. Three formal sets of written
comments were received during the public comment period (July 21 -
August 19, 1988): one from a nearby resident in Lanesborough, one
from an individual who operates a business adjacent to the site,
and one set from General Electric. One oral comment was presente
at the August 3, 1988 informal public hearing (which was reiterated
in writing during the public comment period). A copy of the
transcript is included as Exhibit B. Copies of the transcript are
also available at the Lanesborough Public Library and the EPA
Records Center at 90 Canal Street, Boston, Massachusetts, 02114 as
a part of the Administrative Record.
The comments from citizens, along with EPA responses, are
summarized and organized into the following categories:
A. Comments Regarding the Remedial Alternatives
B. Comments Regarding Water Quality
Part I - Citizen Comments
A. Comments Regarding- the Remedial Alternatives
1. One commenter stated that their business, which operates
adjacent to the Rose site, relies on telephone activities for
their mail order operations. The commenter stated that they
would like assurances from EPA that the impact of remedial
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actions upon their business will be minimal. The commenter
also asked to be notified whether personnel and equipment
associated with the cleanup would be utilizing the commenter's
property for access to the site.
EPA Response; EPA is aware of the desirability to minimize
impacts from the remedial activities. However, any
construction activities will inherently be disruptive to some
degree. The design and subsequent construction will attempt
to minimize the short term impacts to reach the long term goal
of overall protection of human health and the environment.
Although the implementation of a permanent remedy will have
greater short term impacts than a "no action" or minimal
action alternative, the fact that contaminants will no longer
be able to migrate from the site and that long term operation
and maintenance will be greatly reduced and ultimately
eliminated must be considered. During remedial design, local
input will be solicited to ensure that specific concerns are
addressed.
Any remedial activity will generate some degree of noise.
However, variables.such as hours of operation for
particularly noisy activities may be limited to certain times
of the day. Techniques to minimize noise and other specific
concerns will be examined during the remedial design process.
All access needs will be primarily kept to the Rose property.
In addition, EPA believes that the vast majority of the
remedial activities can be conducted on the Rose property. As
part of design, EPA will require site maps which will indicate
all land and access needs and will include an overlay map with
property boundaries. Should any land or access needs extend
beyond the Rose property, appropriate agreements with those
landowners will need to be negotiated.
2. One commenter stated that they would like assurances from EPA
that their property would be cleaned up should it become
contaminated as a result of remediation activities at the
Rose site.
EPA Response; Remediation will be conducted to minimize
impacts to surrounding areas. Should any releases occur
during construction activities, however, the construction
contractor would need to immediately address any such release.
One of the items that will be required as a part of the design
will be a "contingency plan" which will set forth the
activities to be undertaken in the event of a release or other
unplanned event. This contingency plan will be circulated for
comment to ensure that local concerns are addressed. In
addition to addressing noise and access (as noted in the
preceding comment), EPA will utilize the following
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activities, as necessary, in conjunction with the contingency
plan:
Releases to air - Air monitoring will be required to ensure
that allowable 1avals of contaminants ara not exceeded.
Potential techniques to minimize air releases include the use
of carbon filters on the air stripper, utilization of
sophisticated air pollution control devices on the
incinerator (stacX), limiting the extent of soil excavation
at any one time, and the use of suppressant foams that
control the release of contaminants during excavation.
Releases to water or surrounding soil * The groundvater
interception and treatment system vill be in place prior to
initiation of soil excavation activities. Although no
significant additional release of contaminants to the
groundvater is expected during soil excavation, the
interceptor trenches/wells vill be in place so that any
releases would be captured to prevent any offsite migration.
Soil excavation activities vill be controlled so that
releases or unplanned movement of soils vill not occur outside
of designated areas. Work areas vill be designated as either
contaminated ("hot zone"), a decontamination zone, or as clean
unrestricted areas. Site activities vill be conducted such
that these designations are maintained.
One coanenter urged EPA to utilize permanent, proven
technologies to address the site contamination. The
comnenter further urged EPA to consider the velfare of the
covaunity and the environment in making decisions related to
the cleanup before considering economic impacts upon GE.
EPA Response8 in evaluating the potential remedies for the
Rose site, the statutory preference for a permanent remedy
vas a major factor in remedy selection. Air stripping and
carbon treatment are proven techniques to permanently address
groundvater contamination. Incineration is a proven
technique to permanently destroy organic contamination in the
soil and sediment.
In addition, the nine criteria used to evaluate remedial
alternatives include such items as overall protection and
short and long term effects, as veil as community concerns.
Cost effectiveness is considered among alternatives that are
considered to be equally protective. See Section VIII of the
Record of Decision (ROD) for a discussion of these criteria.
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B. Comments Regarding Groundwater Quality
4. One commenter expressed concern that their private veil
currently could be contaminated by the wastes at the Rose
site. An additional commenter asked EPA to test their veil
for contaminants at no expense to the property owner.
EPA Response; Reviev of the groundvater monitoring results
indicate the extent of groundwater contamination based on a
network of approximately 70 wells of varying depths in and
around the site. The RI reports provide the actual data from
the various sampling rounds that have been conducted.
The most recent groundwater data (November 1986) indicates
the extent of the two contaminated shallow groundwater plumes
and is shown in the ROD on Figure 3. Because the deep wells
between the disposal area and the closest residential wells do
not show any contamination, EPA has not required GE to conduct
a residential veil sampling program. Further, the groundwater
contamination is generally restricted to the shallow
overburden aquifer (to an approximate 25 foot depth), and it
is believed that residential wells tap the deeper bedrock
aquifer.
As a part of the selected remedy, GE will be required to
install a bedrock well in the vicinity of the disposal area
(where the highest levels of contamination are found) to
prevent the migration of contamination into the fractured
bedrock. Should EPA obtain data that indicates that
groundwater contamination may extend beyond the current areas
of delineation, EPA would then conduct, or require GE to
conduct, a residential well sampling program and appropriate
monitoring.
Part II. Summary of Potentially Responsible Party Comments
EPA received and responded to extensive comments, from the PRP,
General Electric (GE). In brief, GE's main comments are: (1) GE
contends that EPA is relying on a document (the draft Feasibility
Study prepared by GE) that was never intended to, and does not,
provide the technical information necessary to determine which
source remedies meet the basic statutory criteria for treatment of
wastes at Superfund sites; (2) GE contends that mobile
incineration will not satisfy the statutory requirements of CERCLA
and that it is not appropriate for the Rose site; (3) GE contends
that mobile incineration will not be protective of human health and
the environment, nor attain Applicable or Relevant and Appropriate
Requirements (ARARs), nor be a cost-effective remedy, nor be a
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permanent solution for metals contamination; (4) GE supports EPA's
choice of a groundvater treatment alternative and recommends
implementation of the groundvatar treatment program; (5) GE.
suggests that a five-year testing period be conducted to develop
and further evaluate alternative treatment technologies for soil
contamination; and (6) GE suggests that if EPA requires immediate
implementation of a soil and sediment treatment program, that
chemical fixation/stabilization is an appropriate permanent
solution for the Rose site. EPA's responses to GE's comments are
provided in the following section.
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Part II - Potentially Responsible Party Comments
Comment 1
GE is committed to a permanent remedy for the F.T. Rose Superfund
Site that is protective of public health and the environment.
Based on the data gathered to date, the Rose Site, located in
Lanesboro, Massachusetts, may be contaminated with volatile
organic compounds (VOCs), polychlorinated biphenyls (PCBs), and
inorganic compounds. Additional site characterization work,
however, is not yet complete. In fact, soil data as to VOCs is
uncertain at best. Additional site characterization is necessary
for all substances, but particularly soil data for VOCs and
metals.
Since beginning work on the Remedial Investigation/Feasibility
Study (RI/FS), GE has worked closely with EPA to identify the
nature of contamination at the Rose Site and to devise a remedial
plan that would address the contamination in each environmental
medium. In the course of winnowing a list of over 100 remedial
alternatives originally identified, EPA and GE recognized early
that mobile (on-site) incineration was not well-suited to the
conditions of the Rose Site. Because of this, the data necessary
to evaluate thoroughly an incineration remedy was never gathered.
Up until June 1988, all indications were that EPA agreed with GE
that further development of emerging innovative technologies would
provide an effective remedy for the contaminated soil. (See
discussion of EPA correspondence summarized infra.1 Suddenly,
however, EPA reversed its course and insisted on immediately
selecting a permanent source remedy. Compounding the problems with
its sudden reversal, EPA selected mobile incineration as its
"preferred1* remedial alternative, despite the fact that mobile
incineration was not even among the top five remedies identified in
the draft FS for the Rose Site.
Response 1
EPA is committed to a timely permanent remedy for the Rose
Superfund Site that is protective of public health and the
environment. Section 116(e) of CERCLA states the statutory
mandate that substantial and continuous physical on-site remedial
action commence at NPL sites in a timely manner. This section
specifies that 175 remedial actions commence by October 16, 1989
and an additional 200 commence by October 16, 1991.
Based on the data gathered to date and available site history, the
Rose site is contaminated with volatile organic compounds (VOCs),
semi-volatile organic compounds (semi-VOCs), and polychlorinated
biphenyls (PCBs). EPA believes that the site characterization work
is adequate for remedy selection. Data necessary for remedy
selection is distinct from that required for remedial design. EPA
believes that the limited soil data on VOCs is adequate to select a
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remedy from the technologies under consideration. The soil VOC
data that is currently available is included in the October 1982
Field Investigation Report prepared by EPA (see Tables 4 through 7,
in particular). Additional site characterization is necessary for
remedial design, particularly soil data for VOCs, semi-VOCs, and
Since beginning work on the RI/FS, EPA and 6E have worked together
to identify the nature of contamination at the Rose site and to
devise a remedial plan that would address the contamination in each
environmental medium. After brief examination of over 100
technologies originally identified in the March 1985 report
entitled "Initial Screening Feasibility Study Report" prepared by
Blasland & Bouck for GE, EPA and GE recognized that mobile (on-
site) incineration was potentially suited to'the conditions of the
Rose site and it was retained as a potential alternative for
remediation. GE's reference to a different decision appears to be
based on an inaccurate perception of EPA's statements; there is no
record of any other decision. In fact, this alternative was
retained for consideration from the initial screening through the
June 1988 draft FS.
The data necessary to design an incinerator was never gathered,
nor was design data/treatability studies performed for other
proposed source management alternatives (such as dechlorination or
chemical fixation/stabilization). Treatability studies that were
conducted by GE were focused on the groundwater alternatives. Up
until June 1988, when EPA received the complete draft FS from GE,
all indications were that further development of emerging
innovative technologies could potentially provide feasible
alternatives for the remediation of contaminated soil. Three such
technologies were discussed for potential demonstration projects in
the Proposed Plan issued by EPA in July 1988. In the absence of
fully developed and implementable alternatives, EPA proposed mobile
(on-site) incineration as a timely, permanent source remedy for the
Rose site. EPA believes that incineration is the only currently
implementable technology to permanently remediate the high levels
of PCB contamination found at the Rose site.
GE's reference to the "top five remedies identified in the draft
FS* is misleading. GE's draft FS "recommended" five potential
source management alternatives for use at the Rose site, three of
which are still in the developmental phase. However, this did not
lead to a decision by EPA to exclude incineration from
consideration. EPA selects a remedial alternative on the basis of
the Administrative Record and the statutory requirements and the
response objectives. This selection process is explained in
further detail in Section VIII of the ROD.
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Comment 2
B&B, the author of the draft FS, points out that the feasibility
study has not been completed; the draft FS simply does not provide
the technical basis for selecting any source remedy. With r.egard
to mobile incineration, there are numerous, significant, unresolved
issues that make its selection, at best, uninformed, and, at worst,
arbitrary and capricious. These significant issues include, but
are not limited to, the lack of soil contamination data (which
affects a wide variety of implementability, safety, regulatory
standard compliance and cost issues), potential emissions during
excavation, the potential for
generation of-ash containing leachable metals and the limited
availability of, and experience with, mobile PCB incinerators.
Response 2
EPA believes that the RI and draft FS provides an adequate basis
for selecting a source remedy. The existing data indicates that
high levels of soil PCB contamination exist throughout the
disposal area. Figure 2 of the ROD (PCB soil contamination
profiles in the disposal area) and the soil boring data presented
in the RI show that contamination in most areas is above 50 ppm
PCBs. Under the PCB disposal requirements of TSCA, 761.60(a)(4)
states that any non-liquid PCBs at concentrations of 50 ppm or
greater in the form of contaminated soil shall be disposed of
in either an incinerator (761.70) or a chemical waste landfill
(760.75). EPA believes that incineration is an appropriate and
feasible remedy for PCB contamination of soil.
The Superfund Remedial Design and Remedial Action Guidance Manual
(OSWER Directive No. 9355.0-4A) indicates in Section 2.3.2 that
remedial actions involving on-site treatment or disposal of
contaminated wastes may .require additional studies to supplement
the technical data available from the RI/FS so that the optimum
treatment or disposal methods may be determined. Additional
studies could include field work and/or bench and pilot scale
studies. Since treatability studies during the RI/FS focused on
groundwater only, these additional studies will need to be
conducted as a part of remedial design/remedial action (RD/RA) for
the source portion of the remedy. Obtaining such design data for
all potential remedial alternatives would be extremely time-
consuming and expensive. EPA regards the existing data as
sufficient for comparison of the potential remedies.
EPA acknowledges that there is additional work needed for the
design of an incineration remedy at this site. This work
includes:
1. Soil VOC and semi-VOC data: This data is required for
evaluating emissions during excavation, for design of air
emissions control equipment for the incinerator, and for design of
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precautions for overall safety. However, any soil VOC or seai-VOCJj
contamination that exists in the PCB-contaminated soils that are toi
be excavated would be destroyed during the incineration process.
Materials handling precautions will need to be tailored during
design based upon the soil VOC levels.
The soil VOC screening and analysis that was conducted in 1981
generally indicates low levels of VOCs in the soil above the water
table.
EPA believes that there is adequate characterization of PCB soil
contamination. PCBs are the major contaminant at the site. Over
100 soils borings were taken in and around the disposal area with
over 400 analyses conducted for PCB contamination.
2. Soils metal data: This data is required to evaluate the
potential need for treatment of leachable metals which would be
concentrated in incinerator ash and for design of appropriate air
pollution control devices. EPA does not have any record of
disposal of metal-bearing wastes at the Rose site. In addition,
6E continues to recover contaminated liquids from the free product
area and send this material to their Pittsfield incinerator for
thermal destruction. Although EPA has requested data from GE on
the analysis of this material in accordance with their Toxic
Substances and Control Act (TSCA) permit, the only data received to
date is on PCB and VOC content.
Because there is no evidence that leads EPA to expect unusually
high levels of metals in the soil to be incinerated at the site,
EPA believes that the metals content of the soil will not be an
obstacle to incineration. Metals analysis conducted on water
samples represent naturally occurring levels of metals. EPA
believes the metals that may be present can be managed with
appropriate controls, including, if necessary, fixation-
solidification of the ash.
3. Limited availability of, and experience with, mobile PCB
incinerators: Both pilot and full-scale mobile PCB incinerators
are available and have been used successfully at other hazardous
waste sites. Experience with this technology is more extensive
than that of the proposed demonstration technology(s). (The draft
FS states that three of the promising technologies [in-situ soil
flushing, chemical extraction, and biodegradation] all require
field study to determine their effectiveness, particularly in light
of the high levels of contamination found at the Rose site.)
EPA owns a mobile rotary kiln incinerator which consists of
specialized equipment mounted on 4 trailers. System performance
is monitored through instruments and automatic safety shutdown
controls. This mobile unit has demonstrated a greater than
99.9999% destruction and removal efficiency at a trial burn on
liquids and solids contaminated with dioxins. Xt has been
operated over the past 2 years for cleanup of dioxin-contaminated
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liquids and soils from numerous dioxin sites in Missouri. To
date, over 2 million pounds of solids and 18,000 gallons of
liquids have been processed.
Ogden Environmental Services, Inc. owns and operates a mobile
circulating bed combustor incinerator for the treatment of
hazardous wastes. Test results from the company's pilot plant
indicate that the TSCA requirement for 99.9999% destruction and
removal efficiency was achieved for soil contaminated with 10,000
ppm of PCBs.
Under EFA's Superfund Innovative Technology Evaluation (SITE)
program, a full-scale and a pilot-scale infrared system have been
demonstrated. The full-scale system demonstration was conducted
at the Peake Oil Superfund site in Florida. A total of 7,000
cubic yards of waste material contaminated with PCBs and lead was
processed. During the trial burn that was conducted, extensive
sampling was included for the solid waste feed, stack gas, ash,
scrubber liquid and water influent, scrubber effluent solids, and
ambient air. The final technical report on the demonstration will
document the entire mechanical operating history of the system and
the problems that were encountered in operating this type of full-
scale system. The pilot-scale system demonstration was conducted
at the Rose Township - Demode Road Superfund site in Michigan.
Approximately 10 cubic yards of contaminated soils were treated
utilizing a blend of the most highly PCB- and lead-contaminated
soils at the site. The final technical report will document
information similar to the full-scale demonstration.
Comment 3
As a consequence of the deficiencies in the database underlying
EPA's proposed remedy selection, and in view of the known and
potential concerns regarding the mobile incineration of the
contaminated soil at the Rose Site, EPA has clearly failed to
establish that this remedy would satisfy the four fundamental
criteria that Section 121 of the Comprehensive Environmental
Response, Compensation, Liability Act (CERCLA) requires of a
selected remedy, namely, that it:
is protective of human 'health and the environment;
attains all federal, state and local applicable or relevant
and appropriate requirements (ARARs);
is cost effective; and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable.
As detailed in the comments that follow, EPA's proposed selection
of mobile incineration cannot be demonstrated to satisfy these
statutory requirements. Indeed, presently available information
indicates that the remedy may fail all four requirements. It is
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these fundamental issues and concerns raised by EPA's remedy
selection as it relates to remediation of soil contamination which
are the focus of these comments.
Response 3
EPA believes that the existing database is adequate to support
EPA's proposed remedy selection. Identified concerns regarding
mobile incineration of contaminated soil at the Rose site are
concerns that may be addressed during the remedial design process,
and are not essential to remedy selection of mobile (on-site)
incineration. See discussion under Response 2 above.
Incineration is a proven technology which will meet ARARs and will
be protective of human health and the environment. Incineration is
considered to be the only technology currently available to meet
the remedy selection criteria and the statutory requirements.
Since on-site incineration is less expensive than off-site
incineration, it is considered the most cost-effective
alternative. Although design work is needed, there is no basis
for any expectation that new information will change EPA's
conclusion.
EPA believes that the record establishes that this remedy does
satisfy the four fundamental criteria of Section 121 of CERCLA,
namely, that it:
is protective of human health and the environment;
attains all federal, state and local applicable or relevant
and appropriate requirements (ARARs);
is cost effective; and
utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable.
See Section XI of the ROD for a discussion of each of these
issues.
6E does not reject every aspect of EPA's Proposed Plan. To the
contrary, GE supports EPA's proposed groundwater remediation plan
(air stripping and carbon treatment). Because this aspect of the
cleanup can proceed independent of soil remediation, GE proposed
that EPA divide groundwater remediation and soil remediation into
separate operable units. EPA could then issue a Record of
Decision (ROD) on the groundwater operable unit embodying the
groundwater cleanup strategy described in EPA's Proposed Plan and
implement that plan. An interim remedial measure supplemental
capping of the site ~ should also be implemented to minimize
maintenance of the existing temporary cap while GE completes
development of innovative technology to remediate the contaminated^
soils. With the completion of additional site characterization ^
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work, and following a period of time necessary to significantly
advance the promising emerging innovative technologies, EPA. could
issue a ROD on the second operable unit and a permanent solution to
the soil contamination could be implemented.
Response 4
EPA does not believe that the groundvater aspect of the cleanup
can successfully proceed independent of soil remediation. EPA has
selected a permanent source remedy in conjunction with a
groundwater remedy for this reason. EPA also does not believe
that operable units are appropriate for this site; operable units
are intended to address technically distinct portions of a site.
At the Rose site, the groundwater contamination is directly related
to the (source) disposal area. For example, the free product
portion of the disposal area contains up to 57,000 ppm
trichloroethylene (TCE) in the oil fraction, a component of the
groundwater contamination. The groundwater cleanup goal for TCE is
5 ppb. Clearly, with extremely high levels of TCE approximately 150
feet from the potential location of the interceptor trenches/wells
for the groundwater treatment system, the cleanup goals for
groundwater may never be attained if a permanent remedy for the
source area is not implemented concurrently. Although it is
possible to prevent the plume from advancing with a groundwater
treatment system in the interim, it is not possible to actually
impact groundwater contaminant levels within the existing plume and
effectively it would be a groundwater containment system. In
keeping with EPA's and GE's commitment to a permanent remedy for
the Rose site that is protective of public health and the
environment, and consistent with the response objective of
restoration of contaminated groundwater for future use and
elimination of the source of contamination to Rose's Pond, EPA has
selected a remedial approach which allows for timely remediation of
the groundwater.
Comment 5
Splitting groundwater and soil remediation into separate operable
units and delaying selection of the final source remediation is
far better than blindly selecting mobile incineration now without
the benefit of a better understanding of the Rose Site
characteristics or the innovative technologies better suited to
those characteristics. But if EPA feels compelled to select a
final source remedy now, chemical fixation/stabilization is
clearly more appropriate for the Rose Site conditions than mobile
incineration. More importantly, unlike mobile incineration,
chemical fixation/stabilization would satisfy the four fundamental
criteria under CERCLA § 121.
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Response 5
Am previously stated, EPA believes that the Rose site is
sufficiently characterized to select mobile incineration, too
innovative technologies can be judged to be better suited to the
Rose site based on the information submitted to EPA by 6E. These
referenced technologies are assumed to be those discussed in the
draft TS and the Proposed Plan for potential site demonstrations.
These technologies have not been proven in the field, nor on a
pilot scale, nor at bench scale for the contaminant concentrations
found at the Rose site. Mobile incineration is a proven technology
on all levels.
GE estimates that the timeframe necessary to sufficiently develop
the innovative technologies is four to six years, excluding
comparison of technologies and subsequent remedial design. This
timeframe is unacceptable for remediation of the Rose site in light
of the extremely high concentrations of contaminants. In addition,
this 4 to 6 year timeframe inherently conflicts with the
Congressional mandate to begin remediation at NPL sites, as stated
in Section 116(e) of CERCLA (see Response 1 above).
For discussion on this point concerning GE's proposal in
Attachment 3 to GE's comments entitled "Research and Development
Program for the Analysis and Destruction of F.T. Rose Site PCBs",
see EPA's response to Comment 7 below.
EPA does not believe that chemical fixation/stabilization is
appropriate for the Rose site. GE has not provided any proof that
existing fixation or stabilization processes are capable of
immobilizing PCBs at the levels that exist at the Rose site. See
Response 24 for detailed discussion of this issue.
Comment 6
Mobile Incineration Is Not Appropriate For The Rose Site
Incineration is a viable and appropriate treatment technology
under the right circumstances. In fact, GE operates a fixed-
based liquid PCB incinerator at its facility in Pittsfield,
Massachusetts, and a fixed-based rotary kiln hazardous waste
incinerator at its facility in Waterford, New York. GE thus
recognizes that incineration is an important treatment technology.
GE's operational experience also allows it to perceive the
limitations of incineration when not used in appropriate
circumstances.
Incineration is not appropriate at every site, or under any and
all circumstances. An enormous number of factors e.g.,
variability of waste feed composition, nature of contamination,
depth of contamination, even climate must be considered and
analyzed before one can determine if incineration can achieve the ,
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desired result at a particular site, much less how much it would
cost. It is this very type of information which EPA lacked when
it decided that mobile incineration was the preferred remedial
alternative.
Response 6
EPA agrees that incineration is not appropriate at every site. EPA
considered a variety of factors in determining that incineration
could achieve the desired clean-up goals at the Rose site. These
factors include:
1. Variability of waste feed composition: Variability in
particulate size will be addressed by design of appropriate
pretreatment and materials handling processes. Variability in
feed contaminant concentrations will be addressed by soil
blending, particularly in cases where extremely high PCB
concentrations are found. (It is possible that a successful
demonstration of the soil washing alternative could address this
factor.)
2. Nature of contamination: There is no historical evidence of
disposal of metal-bearing wastes. Contaminants identified at the
Rose site are predominantly organic and are suited to destruction
by thermal treatment. As discussed in Response 2 above, EPA does
not believe there are high levels of metals at the site.
Appropriate design of air emissions controls and ash disposal
practices can be imposed to address metals levels.
3. Depth of contamination: Soil excavation below the water table
becomes complex and expensive and generally complicates material
handling procedures. Soil moisture content affects the fuel
consumption rate of the incinerator. EPA believes that limiting
excavation to the water table for the majority of the site
addresses a number of GE's technical implementation concerns.
Because the PCB level in groundwater needed to satisfy the
drinking water risk level is so low (0.005 ppb), virtual complete
site excavation would be required. This is considered to be
technically impracticable; see the ROD for a more detailed
discussion of this issue.
4. Climate: A mobile incinerator may be more susceptible to
climate considerations than GE's stationary incinerators located
in close proximity to the site. However, appropriate
weatherproofing (e.g. temporary structures to protect the
incinerator, area of excavation, and/or materials handling and
preparation area) would mitigate climactic impacts. EPA does not
consider the weather to be an insurmountable obstacle to the
implementation of on-site incineration.
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Other factors which will need to be considered during remedial
design include, but are not limited to: non-combustible fraction
of solids, fraction of ash as particulate; combustible solids
heating value; incinerator and afterburner operating temperatures;
and residence tine. Treatability testing will be required to
determine appropriate operating parameters for the incinerator as
well as ash/decontaminated soil handling procedures.
The Draft Feasibility Study Has Not Been Finalized
GE and EPA had long contemplated that the most appropriate
approach to remediating the PCBs in the soil at the Rose Site
would most likely emerge from the innovative technologies which
are being developed under GE's Corporate Research and Development
(CRD) program. EPA Region I is quite familiar with this program,
as GE has included regular written updates which have been
submitted to EPA, which in turn have formed the basis for periodic
technical review sessions between EPA and GE. A
description of the CRD program, as it relates to the Rose Site, is
attached (Enclosure 3).
Response 7
EPA made no remedial decision as to which proposed technology
might be the most appropriate for remediating PCBs in the soil at
the Rose site prior to the Record of Decision to which this
responsiveness summary is an attachment. Technical alternatives
retained for consideration in the TS were retained based on a
screening process dictated by EPA RI/FS guidance; consideration of
GE's CRD Program was incidental.
EPA Region I is familiar with GE's CRD Program. GE has submitted
regular written updates to EPA which have formed the basis for
periodic discussions between EPA and GE. Submittals related to CRD
prior to GE's submission of these comments have not been specific
as to the Rose site. Previous submissions have focused on
bioremediation and only recently have included surfactant
extraction.
Attachment 3 is the first site-specific submission purportedly
describing research for the Rose site to EPA, particularly for the
surfactant extraction process. EPA had received the identical
{verbatim) submission which differed from Attachment 3 only in
references to site name. The report transmitted to EPA by cover
letter dated June 15, 1988 from GE entitled "Research and
Development Program for the Destruction of PCBs" otherwise
included identical text, soil sample levels, degree of extraction,
and percentage of native soil lost as fines in the precipitate for
the surfactant extraction process, but was written for GE's Oakland
site in California. Laboratory documentation subsequently
20
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submitted by GE upon request by EPA states that 6E has not
conducted any extractions on Rose site soils.
GE has represented that the timeframe for development of
innovative technologies would be an estimated 4 to 6 years.. EPA,
DEQE, and GE have now been investigating the Rose site for '
approximately 7 years. On-site incineration is a presently
available permanent remedy for organic contamination. EPA sees no
basis in CERCLA on which an available permanent remedy could be
rejected in favor of speculative, long term research, particularly
when there is no firm basis for finding that the research is likely
to yield an effective alternative within the time frame in which
the available alternative could be implemented.
Comment 8
Several of the most promising of these innovative technologies
were directly incorporated in the draft FS. As B&B states:
It is this research which has formed the basis for the
recommendations, in the draft Feasibility Study, for on-site
pilot study of several of the promising innovative
technologies at the Rose Site.
B&B Comments, p. 15. It has been GE's opinion, from the outset,
that emerging innovative technologies offered a better solution
for the Rose Site than any of the "proven" technologies,
particularly mobile incineration. This approach has been
discussed by EPA and GE in their many meetings and communications
addressing Rose Site source remediation, and it has been manifest
in the draft FS submitted by GE in the past year.
Response 8
EPA acknowledges GE's opinion as having been expressed in meetings
and in the draft FS. However, as indicated in Response 7, no
remedial decision as to which proposed technology might be the most
appropriate for the Rose site was made prior to the Record of
Decision. In addition, EPA's commitment to a timely remedy for the
site in accordance with the selection criteria conflicts with GE's
development timeframes of 4 to 6 years for "emerging innovative
technologies" that have not demonstrated the potential for
effective implementation for the Rose site. See Response 7 for
further discussion.
Comment 9
For its part, EPA has recognized and understood that this (see
Comment 8) was GE's preferred approach. Sec, e.g.. EPA's letter
of April 6, 1987 to Mr. Ron Desgroseilliers of GE (Enclosure 4),
in which EPA discusses GE's proposal to separately address
groundwater issued (through "short time frame" activities) and
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source remediation (through "longer tine frame11 activities). More
recently, EPA has not only acknowledged GE's approach, it has gi
every indication that the Agency concurred in it. No disagreement
with GE's approach is expressed in EPA's undated draft comments on
the draft FS (submitted to EPA on April 1, 1988) (Enclosure *5).
Nor was there any mention of any disagreement with GE's approach in
the Agency's formalized comments dated May 12, 1988 (Enclosure 6).
And finally, in the Agency's undated comments on the next draft FS
(submitted to EPA on June 3, 1988) (Enclosure 7), EPA never
discussed mobile incineration nor disagreed with GE's approach.
Response 9
EPA's letter of April 6, 1987 to Mr. Ron Desgroseilliers of GE
stated that ..."G.E. proposed a two-phased approach to continue
conducting activities at the site....
a) 'Short time frame* activities - G.E. indicated a desire to
address the VOC contamination problem at the site on a separate
and expedited schedule. G.E. believes that the VOC contamination
of the (shallow) groundwater lends itself to treatment with proven
technologies that are currently available, as well as
accommodating SARA's preference for permanent treatment
technologies.
The following is the tentative implementation schedule that was
presented at the meeting:
March - April '87 Review and update the initial screening
of alternatives for the groundwater
contamination problem.
March - May '87 Screen the alternatives in light of the
SARA requirements.
June - '87 EPA issues an Administrative Order to
G.E. to conduct the selected groundwater
treatment alternative.
July '87 - ? G.E. implements the remedial alternative.
b) 'Longer Time Frame* Activities - G.E. indicated a desire to
keep on the longer time frame for the ROD process that is required
for the site as a whole. G.E. believes that the PCB portion of the
contamination at the site does not lend itself as readily to a
proven and available technology for remediation, as well as
considering the preference for permanent remedies under SARA.
As such, the following tentative implementation schedule was
proposed:
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March - June '87 Review the initial screening of
alternatives, and screen the alternatives
in light of the SARA requirements.
July - December '87 Conduct the detailed FS.
January - March '88 EPA issues its Record of Decision.'
April '88 - ? 6.E. implements the remedial
alternative...."
EPA did not formally agree nor disagree with GE on any preferred
remedial approach prior to the proposed plan issuance. In fact, a
review of the schedule outlined in the EPA letter (excerpt above)
shows a schedule for the detailed FS approximately six (6) months
ahead of the current schedule.
EPA acknowledges that the design of the groundwater treatment
portion of the remedy may be accomplished sooner that the design
of the incinerator. It is EPA's intention that the design and
implementation of the groundwater treatment system be carried out
expeditiously. The design of the incinerator portion of the
remedy will require a longer time period than that for the
groundwater treatment system.
Comment 10
The first signal from EPA of the need for a major shift in
direction came at a June 14, 1988 meeting with GE, when EPA
announced that its Region I "Management Committee" had decided
that the Agency would select a remedy based on the limited data in
hand, and that selection would be mobile incineration.
Response 10
In the June 14, 1988 meeting with GE, EPA and GE discussed the
upcoming EPA issuance of the Proposed Plan for the Rose site. EPA
developed the Proposed Plan based on the RI, the draft EA, and the
draft FS which addressed remedial alternatives for both the source
area and groundwater. The draft FS includes information pertinent
to the selection of an overall site remedy which meets the intent
of CERCLA. One of the alternatives retained in the draft FS was
mobile incineration. Further, EPA proposed mobile incineration at
this time; final remedy selection is made in the ROD to which this
responsiveness summary is an attachment.
Comment 11
As the preparers of the draft FS documents, B&B is uniquely
qualified to comment on the approach and intended scope of the
documents prepared to date, and/or the technical problems
associated with EPA's sudden insistence on selecting a final
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source remedy from th« data in th« latest draft FS. Their
overview of this issue is compelling:
It is our belief that the Feasibility Study process shpuld
continue with the collection of additional sit*
characterization data and finalization of the Feasibility
Study Report. Only at that tine can a defensible remedy be
selected by the EPA and subsequently be implemented without
significant delay.
B4B Comments, p. 5.
Response 11
EPA cannot allow FSs to continue indefinitely, particularly when
sufficient information exists to show that a feasible permanent
alternative is currently available. B&B's belief that the FS
process should continue with the collection of additional data
seems to address the purposes of remedial design rather than
remedy selection.
Comment 12
As a consequence of all of the above, EPA has failed to follow the
statutory procedures for selecting a remedy. EPA is relying on a
document that never intended to, and does not, provide the
technical information necessary to determine which source remedies
meet the basic statutory criteria ~ much less which one is the
best choice from among those that do.
Response 12
The ROD explains how the remedy selection of mobile incineration
meets the statutory criteria of Section 121 of CERCLA. In
addition, in the Administrative Order on Consent signed by EPA and
6E dated March 22, 1988 (U.S. EPA Docket No. CERCLA-I-88-1010;
paragraph 4), the stated purpose of the Consent Order is "In
entering into this Consent Order, the mutual objectives of EPA and
the Respondent [GE] are the following... To provide EPA with a
Feasibility Study so that EPA can evaluate alternatives and
determine the appropriate extent of the remedial action needed to
prevent or mitigate the release or threatened release of hazardous
substances, pollutants, or contaminants at or from the F.T. Rose
site..." This Feasibility Study was to be completed by 6E by June
30, 1988. The draft FS and the administrative record provide EPA
with sufficient information to support a remedy selection. See
previous responses, including Responses 2 and 3, for further
discussion.
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Comment 13
Mobile Incineration Will Not Satisfy The Statutory Requirements Of
CERCIA
On technical, policy and legal grounds, any final selection of
remedy would be premature and would not meet CERCIA's
requirements. Congress has mandated that EPA select a remedy that
is protective of human health and the environment, attains ARARs,
is cost-effective, and utilizes permanent solutions and
alternative technologies or resource recovery technologies to the
maximum extent practicable. CERCLA S 121(b). EPA cannot, on the
basis of the information before it, determine whether mobile
incineration satisfies any of these requirements.
Response 13
The ROD discusses how the mobile incineration and groundwater
treatment remedy does, in fact, meet the statutory requirements of
CERCLA. Refer to Section XX of the ROD for a discussion of these
issues.
Comment 14
Mobile Incineration At The Rose Site Will Not Protect Human Health
And The Environment
The Endangerment Assessment Report identified the following long-
term risks:
(1) human ingestion of or dermal contact with contaminated
groundwater,
(2) human ingestion of or dermal contact with contaminated site
soils, and
(3) animal ingestion of surface water.
Endangerment Assessment, pp. 95, 100-01. For a remedy to be
protective of human health and the environment, it must limit or
eliminate each of the risks identified in the Endangerment
Assessment Report. [GE believes that the risks identified above
will have been successfully mitigated by the measures taken to
date (e.g., fencing and capping) and by the installation and
operation of the groundwater treatment system. Notwithstanding
this, GE remains committed to a permanent source remedy at the
Rose Site.]
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Rasponsa 14
GE's EA navar idantifiad aatals contamination (in aithar coil or
vatar) nor soil VOC contamination as a potential risk factor to ba
considarad.
t
As notad by 62 in tha pravious coaaant, CERCIA Saction 121(b)
statas that EPA will salact a raaady that is protactiva of human
haalth and tha anvironaant, attains ARARs, is cost-affactiva, and
utilizas paraanant solutions and altarnativa tachnologias or
rasourca racovary tachnologias to tha maximum axtant practicabla.
Nobila incinaration and groundwatar traatmant will protact human
haalth and tha anvironaant by paraanantly aliminating aach of tha
risks idantifiad in tha EA raport.
Naasuras takan to data at tha sita do not constituta paraanant
mitigation of sita risks to tha maximum axtant practicabla.
Tha sita cap consists of aultipla piacas of 5 ail plastic shaating
hald in placa with voodan pallats and traa branchas and tha fanca
is a 4-foot high voodan snow fanca. Tha proparty is xonad
rasidantial and thara ara no currant rastrictions on usa of tha
proparty.
It is assuaad that tha groundwatar traataant systaa rafarrad to is
actually tha oil racovary systaa that is currently in oparation at
tha sita. Tha oil racovary systaa axtracts liquids froa tha fraa
product portion of tha sita balov tha watar tabla. This racovarad
product is sant off sita for incinaration at GE'a Pittsfiald TSCA
incinarator. Tha primary intant of this racovary systaa is not
groundwatar traataant but rathar raduction of tha sourca voluaa.
This systaa doas not collact nor traat contaainatad groundwatar
that has aigratad aast and south of tha disposal araa.
Conmant 15
In addition, howavar, a raaady Bust not craata nav risks. As ERM
notas in its coaaants, "it is assantial to understand tha risks of
iaplaaanting tha tachnology, givan tha possibility that tha cura
aay ba vorsa than tha disaasa.* ERM Commants, p. 3. EPA's
proposad salaction of aobila incinaration posas just such a
scanario. For axaapla, aobila incinaration potantially posas
savaral haalth risks which EPA has not adaquataly considarad,
spacifically, tha impact that vapors, particulatas, and/or dusts
from axcavating contaainatad soils would hava on vorkars, naarby
rasidants, and tha anvironaant. Control of tha aaissions would ba
particularly critical sinca VOCs ara baliavad to hava contaainatad
tha soil. Whila both B&B and ERM baliava tha ami»aion controls can
ba anginaarad to ainiaiza tha impacts of thasa amissions, such
control aachanisas hava significant inharant risk of failura, as
wall as significant costs that hava not baan avaluatad in tha draft
PS. B&B Commants, p. 7.
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There is also the potential for the generation of ash containing
leachable metals. As discussed infra. incineration does not
destroy metals. Thus, following incineration of soils, metals
will be concentrated in the ash. In this form, the metals may be
more leachable than metals in soil and thereby present a greater
risk to human health and the environment. EPA has not considered
this issue. See B&B Comments, pp. 8-9, and ERM Comments, pp. 6-
7. One final example (although by no means exhausting all of the
potential risk issues) is the negative affect that mobile
incineration could have on the surrounding environment. At EPA's
August 3, 1988 public meeting, a local resident expressed her
concern about the environmental impacts associated with operating
a mobile incinerator 24-hours a day for a period of four or more
years.2/ EPA has not considered the increased vehicular traffic
and noise that will result or the impact on local wildlife
(particularly in the wetlands area).
V Comments of Dianne Nichols, an owner of property adjacent to
the Rose Site.
Response 15
EPA has considered the "several health risks'* which GE has
identified. A detailed approach on how to address these risks
will be developed during remedial design:
1. Impact of excavation: Excavation would be necessary for more
than one of the alternatives proposed in the draft FS, including
one or more of the demonstration projects. Anv remedy involving
excavation to permanently remediate contaminated soils would need
to address excavation concerns, and the costs and risks of
excavation would be the same for all such remedies. As a part of
safety precautions, an air monitoring program will be developed to
permit rapid detection and early response to potential releases of
air contaminants during excavation. (See Response 24 for a more
complete discussion of this issue.)
Emissions controls can be implemented and have been at other
hazardous waste sites. The risk of failure and the cost are both
minimized by the fact that the total areal extent of the site is
relatively limited and that excavation would be phased to minimize
the extent of open cuts at any given time. B&B failed to indicate
that "significant cost" or "significant inherent risk of failure"
were factors to consider in the evaluation of alternatives
involving excavation discussed in the draft FS. Experience in the
Superfund program to date does not indicate that emission controls
for excavation for a site of this size for on-site treatment of
contaminants found at the Rose site are subject to "significant
inherent risk of failure". EPA believes that proper engineering
design and implementation of appropriate safety precautions can
greatly reduce the risk of failure.
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Moreover, the cost information of concern is not included in any
information submitted by GE to EPA. The reference to cost and to
potential failure of excavation emission controls is vague and
ambiguous.
2. Generation of ash containing leachable metals: As discussed
in Response 2, EPA has no record of disposal of metal-bearing
wastes at the Rose site. Metals as a potential site contaminant
has never been studied by GE since GE's inception of work at the
site in 1983, nor were they identified as a potential concern in
the EA. Metals characterization sufficient to complete remedial
design will need to be undertaken in conjunction with remedial
design (see Response 6). Potential metals contamination of
incinerator ash will need to be evaluated at that time. Without
any site-specific treatability studies on incineration, it is
uncertain whether or not any metals would concentrate in the
decontaminated soil fraction at unacceptable levels. In any case,
EPA believes that measures to prevent the potential release of
metals, particularly from the ash, are available and feasible if
needed. Air pollution control devices will capture metals that are
attached to dust or soil particles carried with the gas stream.
The November 1986 sampling results show low levels of metals in
groundwater, including a sample from well 12A, one of the most
contaminated wells at the site. All metals levels were below
drinking water standards.
At no time since 1984 when GE initiated incineration of the free
product portion of the site (see previous Response 14 on oil
recovery system) has GE provided information to EPA on metals
analysis data nor suggested that metals are present at the site.
3. Vehicular traffic and noise: EPA has considered the impact of
traffic associated with the site on the surrounding areas.
Concern about increased vehicular traffic was a factor in
selecting an on-site remedy. (Off-site incineration would result
in the transportation of untreated highly contaminated soils over
long distances.) B&B did not consider these controls to be of
such concern previously as to include pertinent discussion in the
draft TS. Further, the incremental costs and risks which are of
such concern to BtB and GE are not presented in sufficient detail
here to evaluate.
EPA weighs the short and long term impacts of various remedial
alternatives as a part of the overall remedial selection process.
EPA acknowledges that increased traffic will necessarily result
with any type of remedial construction activity. An on-site
versus an off-site remedy will help to minimize these potential
impacts. In addition, EPA believes that the benefits of the long
term goals of overall protection through the implementation of a
permanent remedy, thereby not allowing contaminants to migrate
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from the site and the reduction and ultimate elimination of long
term operation and maintenance, outweigh the short term impacts of
remedy implementation.
*
Comment 16
Mobile Incineration Will Not Attain ARARs
Protection of human health and the environment is achieved, at
least in part, by identifying and complying with the "applicable
or relevant and appropriate standard, requirement, criteria, or
limitation" (commonly referred to as "ARARs") for the hazardous
substances, pollutants, or contaminants that will remain at the
site. CERCLA § 121(d)(2)(A). As EPA noted in its "Interim
Guidelines on Superfund Selection of Remedy":
Remedies must be protective of human health and the
environment. This means that the remedy meets or exceeds
ARARs or health-based levels established through a risk
assessment when ARARs do not exist.
Memorandum dated December 24, 1986 from J. Winston Porter,
Assistant Administrator, U.S. EPA Headquarters, to Regional
Administrators, EPA Regions I-X, p. 7 (emphasis in original). EPA
has not shown, and cannot show on the available data, that mobile
incineration of contaminated soils satisfies ARARs or health-based
standards for those soils.
In its "Interim Guidance on Compliance With Order Applicable or
Relevant and Appropriate Requirements," 52 Fed. Reg. 32,496,
32,497 (1987), EPA identifies three different types of ARARs:
(1) ambient or chemical-specific requirements,
(2) performance, design, or other action-specific
requirements, and
(3) locational requirements.
All three types of ARARs potentially apply to the selection of
mobile incineration to remediate contaminated soil at the Rose
Site. EPA states in the Proposed Plan that "PCBs, thirteen
different VOCs, and six semi-VOCs have been detected in the soil
and groundwater at the F.T. Rose site." Proposed Plan, p. 4.
Yet, in the same section, EPA admits that it has not established
cleanup goals for the soil contaminants:
EPA is also developing soil cleanup goals for the site based
on EPA's PCB policies and other guidelines .... The
groundwater and soil and sediment cleanup method selected by
EPA must reduce the concentration of the contaminants at the
F.T. Rose site to the designated cleanup goals.
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As EPA has not y«t established chemical-specific soil cleanup
goals, it cannot state that mobile incineration satisfies those
cleanup goals. EPA has thus concluded that mobile incineration is
the "preferred1* remedial alternative having MYfj: established the ,
chemical-specific soil cleanup goals, the site conditions have not
been adequately analyzed to determine whether mobile incineration
at the Rose Site could achieve those cleanup goals.
Because EPA has not fully characterized site conditions, EPA
similarly could not determine whether mobile incineration would
satisfy action-specific ARARs. For example, the draft FS contains
no data on the metals content of the soil. Incineration of soil
does not destroy metals. As a result, toxic metals may end up
being concentrated in the burned soils, which could lead to one or
both of the following results. First, concentrated metals can
increase the leaching potential of those metals in the ash. If the
metals were rendered more leachable by mobile incineration, it is
difficult to characterize that remedy as being protective of human
health and the environment or permanent. Second, if the
incinerator ash concentrates the metals, the ash may fail the
Extraction Procedure Toxicity Criteria, and be considered a
hazardous waste. The standards established under the Resource
Conservation and Recovery Act (RCRA) for handling hazardous wastes
would then apply to the disposal of the hazardous ash from
operations at the Rose Site, requiring either on-site construction
of a RCRA landfill or disposal of the ash in an off-site licensed
facility. fiAft B&B Comments, p. 8, and ERM Comments, p. 7. EPA has
ignored the potential applicability of such RCRA standards, and
their potentially significant compliance costs, in its Proposed
Plan.
Although some of these risXs nav be mitigated through the design
and engineering of additional controls,3/ EPA has not assessed
the existence of such potential risks, the question of whether,
and if so, how the risks may be mitigated, and the incremental
costs and time that the mitigation measures will add to the
project.
Finally, EPA not has considered whether mobile incineration would
comply with locational ARARs. Specifically, the draft FS
identifies the Massachusetts Hazardous Waste Siting Act, N.6.L.,
c.21(d), as an ARAR in Table 3-1. Further, mobile incineration
was not among the top five source remediation alternatives in the
draft FS because it is "potentially unacceptable due to the
proximity of residential areas, Balance Rock State Park and
Pittsfield State Forest." Draft FS, p. 7-3. Yet, in meetings
prior to the issuance of its.Proposed Plan, EPA informed GE that,
in the Agency*s opinion, the Massachusetts Siting Act is not an
ARAR. Instead, EPA views the siting laws as analogous to a state
permitting requirement, and, as such, not applicable to the F.T.
Rose cleanup pursuant to SARA § 121(e), which states:
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No Federal, State, or local permit shall be required for the
portion of any removal or remedial action conducted entirely
on-site, where such remedial action is selected and carried
out in compliance with this section.
This interpretation would suggest that because this section-
relieves the person remediating a Superfund site from obtaining
permits required under federal, state, or local law relating to
hazardous waste handling, it logically follows that such federal,
state, or local laws need not be considered in the remedy
selection process. Such an interpretation, however, conflicts
with CERCLA § 121(d) which expressly characterizes facility siting
laws as ARARs that must be satisfied at the completion of a
remedial action. See CERCLA § 121(d)(2)(A). Senator Robert
Stafford (R-Vt.), one of the architects of SARA, made this exact
point in the floor debate which followed passage of SARA: "This
section requires the Administrator to meet the requirements of
State facility siting laws . . . ." 132 Cong. Rec. 514,910 (daily
ed. Oct. 3, 1986). EPA, in its own guidance on compliance with
ARARs, recognizes as much. In providing examples of locational
ARARs, which "set restrictions on activities depending on the
characteristics of a site or its immediate environs," EPA included
n[f]ederal and State siting laws for hazardous waste facilities."
52 Fed. Reg. 32,497. Thus, it is clear from EPA's own guidance
that facility siting laws are ARARs which must be substantively met
in the remedy selection process.
Given that EPA's Proposed Plan would place a mobile incinerator in
the midst of a state park, a state forest, and residential
communities, and given that this mobile incinerator would operate
24 hours a day for a period of years, it is imperative that EPA
consider the acceptability of such a plan under the Massachusetts
siting law. The fact that EPA has not determined whether the
location of a mobile incinerator next to irreplaceable state
resources would be consistent with the standards of the
Massachusetts Hazardous Waste Siting Act is just another
indication that EPA has not demonstrated that mobile incineration
would be protective of human health and the environment or would
achieve all federal, state and local ARARs.
/ See B&B Comments, pp. 6-10, and ERM Comments, p. 3, for a
more detailed discussion of potential risks not identified by
EPA.
Response 16
The ROD documents that mobile incineration of contaminated soils
satisfies ARARs. The soil cleanup goal has been established by
EPA and is set forth in the ROD. B&B did not present costs for
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incinerator ash treatment for application should levels of metals
(not an identified site contaminant) warrant treatment.
CERCLA I 121 (d) (2) (A) applies "With respect to any hazardous-
substance, pollutant or contaminant that will remain on-site..."
and it requires compliance with ARARs, including those promulgated
under a state facility siting law "...at the completion of the
remedial action." The mobile incinerator called for by SPA's
selected remedy will thus not be subject to facility siting
requirements as ARARs. The Massachusetts statute cited in the
comment, M.6.L. c. 21 (d) is applicable only to new facilities. In
the regulations which implement the Siting Act, the State has
specifically exempted on-site remedial actions (900 CMR f 1.02 (2)).
Chapter 21(d) is thus neither applicable nor relevant and
appropriate.
EPA is unaware of any impacts on "irreplaceable state resources"
that would occur during implementation of the remedy, and no such
impacts were identified in the draft FS. Although the site is
adjacent to a state parX, the park is not heavily utilized and
access to the site from the park is through heavily wooded areas.
Measures to minimize any impacts will be factored in to the design
process. EPA regards any potential for short term impacts as
outweighed by the long term permanence of the remedy.
17
Mobile Incineration Will Not Be A Cost-Effective Remedy At The
Rose Site
A determination that a selected remedy is cost-effective can only
be determined after (1) cleanup goals are established, (2)
remedies are identified which can attain those cleanup goals and
(3) the cost of each such remedy is determined. As noted above,
EPA did not establish critical cleanup goals (or adopt those
listed in the draft PS) prior to selecting mobile incineration as
the preferred remedy. But had EPA done so,, it still would not be
in a position to determine whether other remedial alternatives
achieve those health goals at a lower cost since data to determine
the cost of all of the source remedies, particularly mobile
incineration, are substantially lacking.
Although EPA includes the draft FS estimate of $19.2 million for
mobile incineration in its Proposed Plan, the accuracy of that
estimate is highly dependent on the level of cleanup that
ultimately is selected. The draft FS estimate is based on the
assumption that "VOCs would be reduced to insignificant levels"
and PCBs would be reduced to 50 ppm. Draft FS, p. 6-59. As
indicated earlier, however, EPA is currently contemplating
different and presumably more stringent level of cleanup for
PCBs. The quantity of soil at the Rose Site in which PCB levels
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exceed a 50 ppm cleanup goal could be much smaller than the
quantity of soil exceeding a lower cleanup level. Accord-
ingly, by lowering the cleanup goal, EPA could significantly
increase the quantity of soil required to be excavated and, in
turn, the cost of mobile incineration.
The failure to recognize that the cost of mobile incineration
varies greatly with the desired level of cleanup is just one of
many variables which EPA has failed to consider in its cost
estimate for mobile incineration. The B&B comments touch on a
number of these variables which, in addition to not being
considered or analyzed in terms of technical implementability,
also were not factored into the $19.2 million estimate. Each of
these variables could significantly increase the cost of mobile
incineration.
B&B notes that the cost of mobile incineration can vary greatly
depending on the composition of the soil matrix. For example,
soils with high moisture content consume larger quantities of fuel
and require longer periods to incinerate as much as 1.5 to 2
times. In addition, high moisture content soils require special
and costly handling procedures to avoid exposing personnel and the
local community to hazardous emissions from the excavated soil.
Finally, the presence of cobbles, boulders, and other nonuniform
constituents of the soil matrix can increase the cost of mobile
incineration significantly. See B&B Comments, pp. 12-14.
Another potentially costly variable relates to the depth of
contamination. If soils below the water table must be excavated,
groundwater infiltration and corresponding problems of subsidence
will greatly increase the time needed to excavate and incinerate
contaminated soil. B&B notes, for example, that at the Peake Oil
Site in Brandon, Florida, incineration of only 7,000 cubic yards
of soil took over a year to complete due to excavation problems
(below the water table), as well as problems with "debugging11 the
incinerator. B&B Comments, p.13. If the Rose Site water table
creates the same level of difficulty encountered in excavating the
Peake Oil Site soils, then the estimated four to five years
required for incinerating soil at the Rose Site would be far short
of the actual incineration time.
Response 17
GE is attempting to argue both that there is insufficient data on
incineration to evaluate cost-effectiveness, and (see Comment 24)
that there is sufficient data on solidification to evaluate its
cost effectiveness and select it. 6E fails to specify which cost
data is "substantially lacking" or to provide missing cost data.
EPA believes that there is sufficient data on both alternatives to
evaluate cost effectiveness. It is also important to consider the
accuracy of costs developed for a feasibility study. Typically,
these cost estimates provide an accuracy of +50 to -30 percent.
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EPA believes that the only currently available feasible alternative
- and therefor* the most cost-effective - is incineration. Since
GE estimated the costs of off-site incineration to be greater than
those for on-site, EPA concludes that for the Rose site Mobile
incineration is a cost effective remedy. The cost estimate used
the draft TS of approximately $380 per cubic yard is considered to
be within the range used for estimating the costs of incineration.
Zn addition, the ROD sets forth the limits of excavation to 13 ppm
PCBs to the water table and the free product area, resulting in
excavation of approximately 15,000 cubic yards of soil, a large
portion of which is above the water table. Accordingly, EPA
believes that a 2 year estimate for implementation is reasonable.
Even if incineration should prove to develop "delays" as the Peake
Oil site has experienced, EPA believes that the 2 year estimate is
still conservative.
Appropriate pretreatment and materials handling, such as feed size
preparation and the reduction of potential emissions, will be an
integral part of remedial design for any alternative involving soil
excavation prior to treatment.
18
Beyond increasing the cost of mobile incineration, certain
variables could render mobile incineration impracticable. B&B
points out that there are presently a total of twelve mobile
incinerator units in the United States. Of these twelve, there
are no circulating bed variety (the type specified in EPA*s
preferred remedy) available for use at the Rose Site. The
available units are either rotary kiln or infrared units and cost
two to three times more than circulating bed units. Moreover,
most of the vendors contacted by BiB stated that they could not
guarantee the availability of even a rotary kiln or .infrared unit
for this project, and would likely have to construct a unit for
the Rose Site. B&B Comments, p. 8.
Response 18
EPA's Proposed Plan did os£ specify circulating bed incineration.
Rather, the preferred alternative stated "... on-site incineration
is the preferred alternative for addressing soil and sediment
contamination ..... Three different types of incinerators were
evaluated: rotary kiln, circulating fluidized bed, and infrared
processing. The extremely high temperatures in any of these
thermal destruction facilities would destroy 99.9999% of all of the
organic contaminants." The ROD states that design will determine
the most appropriate type of incinerator for use at the Rose site.
The design phase will include examination of the availability of
existing units appropriate for the site. This information will be
factored into the overall design and the potential need for
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construction of a unit. Time frames for design will be sensitive
to vendor response. Further, Ogden Environmental Services, Inc.
owns and operates a transportable circulating bed combustor.
Comment 19
^^^^^^^i^^^""
B&B also noted that EPA failed to consider the fact that the
utilities required by incinerators 7 million gallons of diesel
oil or 22 million kwh of electricity, and 250 million gallons of
water are not currently available at this site or in the
immediate area. B&B Comments, pp. 10-11. But perhaps the most
glaring deficiency in EPA's analysis of the cost-effectiveness of
mobile incineration at the Rose Site is the failure to consider
the effect of the northern climate on that operation. The
northern climate will significantly limit, or preclude, operations
during winter months due to the inability to dewater and otherwise
prepare materials for incineration. B&B Comments, p.12.
Response 19
Detailed information regarding utility needs was not provided in
the draft FS. The assumptions used to generate these figures are
not presented by GE. EPA assumes that the numbers presented in
this comment have been calculated to reflect extensive excavation
below the water table. Design work will need to estimate the
actual utility needs and to make provisions for providing them to
the site. Certain design items, such as sizing of the incinerator
and examining the potential for recycling of quench and scrubber
water, could potentially reduce the utility needs.
Climatic considerations will also need to be factored into the
design. As previously stated, limiting a large portion of the
excavation to above the water table will minimize problems
affiliated with deep saturated soil excavation. (Climatic
concerns could also be applicable to certain fixation-
solidification techniques.) For remedial work conducted at other
sites in northern climates, various techniques have been employed
to minimize weather-related impacts. Such techniques include
temporary structures to house equipment and to protect open
excavation areas.
The Administrative Order on Consent (previously referenced) in
Appendix B stated that the FS shall include "... a description of
all special engineering considerations required to implement the
alternative...". As such, EPA assumed that the cost estimates in
the draft FS addressed these concerns.
Because EPA has found no other alternative to currently be
feasible, increases in costs resulting from utility or weather
considerations will not alter the basis for EPA's selection of
incineration. These potential cost increases may increase the
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cost of on-site incineration, but are assumed to still be lower
than the costs associated with off-site incineration.
Comment 20
The availability of mobile incinerators and utilities to run them,
and the operability of such units under climatic extremes common in
the Northeast are central to any determination of whether mobile
incineration is implementable at the Rose Site, much less how much
it would cost.
In terms of cost, B4B believes that these variables, together with
others that it identified e.g., revision of soil cleanup goals,
engineering controls for emissions, material handling issues
could double or triple the $19.2 million cost estimate for mobile
incineration in EPA's Proposed Plan. B&B Comments, p. 15. EPA's
failure to consider these issues belies EPA's claim
that it has determined mobile incineration to be cost-
effective.4/
4/ For a more detailed discussion of these and other variables
which potentially would have a significant impact on the cost
estimate, see B&B Comments, pp. 7-15, and ERM Comments, pp. 3-
5.
Response 20
Please see previous responses to address the issues that are
reiterated in the above comment, including Responses 6, 17, 18,
and 19.
Comment 21
But even assuming, for the sake of argument, that the proffered
cost estimate of mobile incineration is as accurate as the cost
estimates of other remedial alternatives listed in the Proposed
Plan, this information demonstrates conclusively that, contrary to
EPA's assertion (Proposed Plan, p.13), mobile incineration is ns£
cost-effective. Comparison of mobile incineration with the other
remedial alternatives included in the Proposed Plan is
instructive. Of the alternatives for which cost has been
estimated, two are containment alternatives which EPA says do not
satisfy the statutory preference for permanent solutions. One
(dechlorination) is reported to range anywhere from $16 to $30
million. Chemical fixation is a permanent treatment technology
which protects human health and the environment, V and, at $11.2
million, nearly halves the $19.2 million cost of mobile
incineration and clearly is cost-effective. Only the remaining
two remedial alternatives off-site landfilling, at $25 million,
and off-site incineration at $149 million cost more than mobile
incineration.
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Landfilling is not a permanent solution and off-site incineration
runs counter to the disfavor under § 121 of off-site transport of
hazardous substances. Thus, EPA's claim that mobile incineration
is "cost-effective1* simply does not comport with the facts as
stated in the draft FS.
5/ The permanence of chemical fixation/stabilization is
discussed infra.
Response 21
EPA considers cost-effectiveness only among feasible alternatives
that achieve equivalent levels of cleanup and degree of
protectiveness. With the information that EPA has received from
GE to date, EPA does not consider fixation/stabilization to be
feasible nor equivalent to incineration in protectiveness nor
permanence. It is for this reason that EPA did not directly
compare the costs of incineration to fixation/stabilization and
compared only the costs of on- and off-site incineration. Cost
effectiveness also takes into account the total short and long
term costs of alternatives, including the costs of operation and
maintenance. See Section XI of the ROD discussion regarding cost
effectiveness for further detail.
Section 121 of CERCLA does not disfavor off-site transport of
hazardous substances. Rather, Section 121 disfavors off-site
disposal, particularly when the remedial action does not involve
treatment.
Comment 22
Mobile Incineration Will Not Be A Permanent Solution For Metals
Contamination
The cleanup standards under § 121 (b)(1) mandate in pertinent
part:
Remedial actions in which treatment which permanently and
significantly reduces the volume, toxicity or mobility of the
hazardous substances, pollutants, and contaminants is a
principal element, are to be preferred over remedial actions
not involving such treatment.
Even the permanence of mobile incineration is questionable. GE
would agree that mobile incineration would permanently reduce the
"toxicity, mobility [or] volume" of the organic contamination in
the soil. Proposed Plan, p.7. However, as noted above, mobile
incineration does not destroy metals. The potential presence of
high concentrations of several heavy metals is an unresolved
issue, as ERM notes in its comments. ERM Comments, p.6. If
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metals have contaminated the site, mobile incineration would not
reduce the toxicity of the metals contamination. Mobile
incineration also does not significantly reduce the volume of the
contaminated soil. Finally, as noted earlier, mobile incinerati
may render metals more leachable and thus mobile incineration woul
not reduce the mobility of the metals. Whether metal-contaminated
ash is placed in an off~site or on-site secure landfill, the
statutory preference for permanent solutions would not be
satisfied.
In sum, EPA has no basis for "preferring" mobile incineration over
other remedial alternatives. It has not gathered the data which
would permit it to undertake the detailed comparative assessment of
remedial alternatives contemplated under CERCIA f 121. As a
consequence, and notwithstanding EPA's statements to the contrary
in the Proposed Plan, EPA has not demonstrated, and cannot
demonstrate, that mobile incineration of the Rose site would
satisfy CERCIA 's remedy selection criteria, i.e., that the remedy
protects human health and the environment, attains ARARs, is cost-
effective, and utilizes permanent solutions to the maximum extent
practicable.
Response 22
See previous responses to address similar comments made
previously, including Responses 1, 3, 12, 13, and 15.
23
GE's Proposed Remedy
Congress "encourage [d] the development and implementation of
innovative permanent treatment technologies . . . whether or not
they have been achieved in practice at other similar sites or
facilities." 132 Cong. Rec. §14,926 (daily ed. Oct. 3, 1986)
(statement of Sen. Chafee) . 6E believes that innovative
technology is the key to remediating the soil contamination at the
Rose Site and is committed to developing, through its Corporate
Research and Development Program, the appropriate permanent
treatment technology.
The three technologies that EPA indicated in the Proposed Plan it
is considering as demonstration projects in-situ soil flushing
with leachate treatment, chemical extraction with incineration of
extracted liquids, and on-site biodegradation were among the
five alternatives which the draft PS identified as "show [ing] the
greatest promise for remediating the disposal area in accordance
with guidance set forth in SARA." Draft FS, p. 7-3. Mobile
incineration was not among these alternatives for reasons already
explained. GE believes EPA should be willing to return to the
original approach for this site, i.e., providing GE with the time
and incentive to further develop these innovative PCB treatment
38
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technologies, and to demonstrate through pilot studies, field
studies and, if warranted, full scale demonstration the
feasibility of such alternatives at a Superfund site.
The development of innovative PCB treatment technology as ah
alternative to mobile incineration would be of national
significance. PCB contamination is widespread in this country.
The cost to society of incinerating every PCB-contaminated site
would be staggering. Clearly, the significance of innovative PCB
technology, would extend far beyond Lanesborough, Massachusetts.
6E proposes that EPA divide groundwater remediation and soil
remediation into separate operable units, an option expressly
endorsed in the National Contingency Plan, 40 C.F.R. § 300.68(c)
(1) (19871) ("Response actions may be separated into operable
units consistent with achieving a permanent remedy"). EPA could
immediately issue a ROD on the groundwater operable unit and that
remedial plan could then be implemented. Air stripping and carbon
treatment would prevent the spread of contamination through the
groundwater. GE would, within five years, develop the alternative
treatment technology for the soil remediation operable unit.
During this five-year period, interim source remedial measures will
be implemented to manage site soils while these studies are
underway. GE would propose to:
(1) remove the existing synthetic membrane cover from the
disposal area;.
(2) cover the disposal area with a new synthetic cap (such
as 40-mil Hypalon or HDPE);
(3) upgrade the existing fence around the disposal area; and
(4) continue oil removal operations from Well 42-A.
The groundwater collection and treatment system described above
would be designed and constructed concurrently with the interim
source control remedy. Thus, during the five-year period all of
the risks identified in the Endangerment Assessment will have been
mitigated.
By the end of five years, GE would finalize a new FS for the
second operable unit, incorporating the results of the CRD
program. Based on that FS, EPA would select a permanent remedy
for immediate implementation.
GE cannot overemphasize the benefits of further developing
innovative PCB treatment technology. Allowing additional time for
such development makes particular sense at the Rose Site.
Implementation of the first operable unit will eliminate all of
the identified risks to human health and the environment. This is
particularly true given that the primary contaminants of concern ~
PCBs -- are immobile. B&B Comments, p.14. In combination with
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the fact that the data is simply insufficient to select final
source remediation as part of any current ROD, it makes a
compelling case for not artificially forcing a remedy selection
now.
Response 23
There are several reasons EPA does not agree with GE's proposed
approach. Although the issues have been previously addressed they
are briefly be reiterated here:
1. Research and development. EPA believes that the development
and implementation of innovative technologies was not intended to
be an open-ended process. While EPA appreciates GE's commitment
to the development of alternative treatment technologies
independent of EPA's Superfund Innovative Technology Evaluation
(SITE) program, the CRO work to date that has been presented to
EPA is focused on bioremediation which has long (4 to 6 years)
development time frames. Even longer time frames would be
required to implement these potential technologies, if they are
even applicable to the Hose site, considering the site conditions
and the levels of contamination present. It is extremely
difficult to predict when technologies under development might be
ready for scale-up and actual implementation that could achieve
clean-up goals.
EPA acknowledges the desirability of alternative technologies in
the ROD. The selected remedy specifically states "In an effort to
encourage development of alternative technologies for treatment of
hazardous waste....EPA is considering allowing GE to conduct a
demonstration project .... this alternative would be considered for
use if it is demonstrated to meet the criteria for remedy
selection." Clearly, EPA is receptive to the concept of
alternative technologies that could be developed, designed, and
implemented in a time frame equivalent to that needed to design
and implement on-site incineration. However, EPA will not delay
implementation of an available remedy for speculative, long term
research. Studies have been ongoing at the Rose site for
approximately 7 years. EPA finds the proposal that GE be allowed
another S years to conduct a FS for the site to be unacceptable.
2. Operable units. EPA does not believe that operable units are
appropriate because of the direct connection between the source
disposal area, especially the free product area, and the
groundwater contamination. Operable units are intended for
technically distinct portions of a site, which is not the case for
the Rose site.
3. Site risks. Although immediate implementation of the
groundwater treatment system would address the risk posed by
contaminated groundwater migration, merely "containing" the source
disposal area would put the groundwater treatment system in a
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"containment" node as veil rather than beginning active
remediation of the groundwater. Extremely high free product
levels of contamination would exist in close proximity to the
groundwater capture area.
Regarding disposal area soils, the temporary cap is merely a
temporary measure to limit contact; it is not a permanent remedy
that is preferred by the statute.
Comment 24
^EMMlBh^EAA^b^MMM *
Alternative Proposal
If EPA feels compelled to select a final source remedy now, mobile
incineration is not the appropriate choice, as demonstrated
previously, because it does not meet the statutory requirements.
Based upon current data, the only remedy that meets the statutory
criteria is chemical fixation/stabilization. Chemical fixation is
a proven technology which'would immobilize PCBs and any inorganic
contamination in the soil and thus eliminate the identified health
risks associated with those contaminants. Chemical fixation, under
this scenario, would be the remedy designated to be implemented at
the end of the 5-year period for development of innovative
technologies.
To complement the selection of chemical fixation/stabilization, 6E
would immediately undertake additional assessment and remedial
activities. First, GE would undertake an extensive soil
characterization program, focusing on both VOCs and metals.
Second, if VOC contamination is confirmed in the soil
characterization study, GE would implement a VOC extraction
procedure. VOCs would be extracted and destroyed prior to
excavating and immobilizing the contaminated soil. This would
address the concerns, discussed earlier and in the enclosed B&B
and ERM Comments, that VOC emissions during excavation activities
would pose a potential health risk. Further, the remedy would be
protective of human health and the environment with regard to any
remedy that involves soil excavation.
Chemical fixation/stabilization would also satisfy the requirement
under § 121 that the EPA select a permanent remedy. VOCs will be
destroyed and PCBs and inorganic contaminants will be permanently
immobilized. In its analysis of chemical fixation/stabilization,
EPA agrees that it "would greatly reduce the mobility of the
contaminants, minimizing long-term environmental effects."
Proposed Plan, p. 12. However, the agency asserts that the
technique would not reduce the volume and toxicity of the
contaminants and the "stabilized material would still be considered
hazardous." Id. Curiously, this statement is inconsistent with
EPA's analysis of chemical fixation/stabilization contained in its
May 12, 1988 comments on the draft FS (Enclosure 6).
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It i» not clear why alternative SM-8 (chemical
fixation/stabilization) was given a low institutional
ranking. This alternative would be completed on-site and
could significantly reduce the nobility and toxieity of
contaminants (with resultant increase in volume, however).
Attachments to EPA Comments, p.7 (emphasis added)
Regardless of whether one accepts the May or July version of EPA's
position, chemical fixation/stabilization would satisfy the
requirement to "utilize permanent solutions" under S 121. A
permanent solution is one which employs treatment which
"permanently and significantly reduces the volume, toxicity or
mobility" of hazardous substances at the site. CERCLA I
121(b)(l). It was no accident that Congress used the disjunctive
"or" rather than the conjunctive "and" in the phrase "volume,
toxicity or mobility." Based on the plain meaning of the
statutory phrase, treatment which significantly reduces either
volume or toxicity or mobility of hazardous substances at a
Superfund site would satisfy the statutory preference for
permanence. Representative Dennis Eckart D-Ohio) made this exact
point during the floor debate which followed passage of SARA:
[T]he statute refers to the significant reduction of volume,
toxicity or mobility using the disjunctive "or" rather
than the conjunctive "and."
132 Cong. Rec. H9589 (daily ed. Oct. 8, 1986). Since chemical
fixation/stabilization would "permanently and significantly m
reduce" the mobility (and, GE believes, the toxicity) of hazardou^
substances at the F.T. Rose Superfund site, it satisfies the
statutory preference for permanence.
In this regard, it is important to note that Congress did not
intend EPA to select the
"most permanent" remedy available; it is not intended that
EPA spend millions of dollars incinerating vast amounts of
slightly contaminated materials where other cost-effective
alternatives would provide a high degree of permanence and
protection of public health and the environment.
132 Cong. Rec. H9S67 (daily ed. Oct. 8, 1986) (statement of Rep.
Lent). Thus, the fact that mobile incineration destroys PCBs
whereas chemical fixation/stabilization only immobilizes them
would not, by itself, justify or require the selection of
incineration. Both remedies achieve a "high degree of permanence
and protection of public health and the environment."
Section 121 also requires that EPA select a cost-effective remedy.
Assuming, for the sake of argument, that both mobile incineration
and chemical fixation/stabilization would constitute permanent
42
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solutions, be protective of human health and the environment, and
achieve ARARs, the fact that mobile incineration is far more
expensive than chemical fixation/stabilization would require the
selection of chemical fixation/stabilization, since it is the more
cost-effective remedy.
EPA reached a similar conclusion in the ROD for the Liquid
Disposal, Inc. (LDI) Site, Utica, Wisconsin (EPA Reg. V) (Sept.
30, 1987). Chemical fixation was selected to remediate soils
contaminated with volatile organic compounds (including PCBs) and
various inorganic metals. Regarding the preference under § 121 for
remedies involving permanent treatment, EPA notes that the
selected remedy "uses treatment as a principal element." LDI ROD,
p. 18. The Agency further notes:
The remedy will reduce the mobility and toxicity of the waste
by greatly reducing or eliminating the ability for hazardous
chemicals to leach out of the solidified mass. However,
hazardous chemicals still remain in that mass.
I£.
Incineration was rejected by the Agency because
[I]t is not cost-effective for the LDI site contaminants.
The RI concluded that there was no clearly identifiable
pattern or "hot spots" of contamination at the site. Due to
the non-uniform and unpredictable waste distribution, the
cost-effectiveness of selectively incinerating certain types
of waste types or site areas could not be determined.
Therefore . . . the entire soil/waste volume [125,000 cubic
yds.] on-site would require incineration.
Id.. p. 16.
Similar facts at the Sand Springs Petrochemical Complex Superfund
Site, Tulsa, Oklahoma (EPA Region VI) (September 29, 1987)
convinced EPA to scrap a plan to incinerate soils heavily
contaminated with VOCs and inorganic metals and select "on-site
solidification" instead. Mobile incineration would have cost
nearly $67 million, while solidification will cost approximately
$38 million. In comparing incineration and solidification (using
the same nine criteria listed in EPA's Proposed Plan for the Rose
site), EPA concluded that solidification represented the best
balance among these criteria. In selecting solidification, EPA
stated that it constitutes a "promising innovative technology," it
is significantly less costly, and human health and the environment
would be protected. See "Declaration For the Record of Decision"
(which precedes the full text of the Sand Springs site ROD). These
same three factors would justify use of chemical
fixation/stabilization as the chosen remedy to be implemented at
the Rose Site at the end of the 5-year period for the development
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of innovative technology, should such technologies not prove
effective.
Response 24
Effectiveness of Fixation/Stabilization
GE has not provided any proof that existing fixation or
stabilization processes are capable of immobilizing PCBs at the
levels found at the Rose site. EPA is unaware of the use of this
technology for containing levels of organic contamination as high
as are documented at this site. Further, GE's EA did not identify
any health risks associated with any VOC or inorganic
contamination in the soil.
Contrary to GE's claims, EPA has never concluded that fixation-
stabilization would permanently immobilize the contaminants since
EPA has no data on which to base such a conclusion. Fixation-
stabilization has not been proven effective in containing PCBs or
other organic chemicals. Although fixation/stabilization has been
used for over 20 years (primarily for inorganic contamination),
there is little information on the physical durability and chemical
stability of the stabilized mass when placed in the ground. Little
research has been conducted on the long term effects of organic
contaminants on performance.
Several types of fixation/stabilization technologies are currently
being tested under EPA's SITE program. Because this program has
been operating for less than 2 years, little specific information
is available of the effectiveness of these technologies in
immobilizing PCBs or other organic*. The HAZCON process was
evaluated at the Douglassville, PA Site in 1987. The process was
not effective in immobilizing organic chemicals. Similar amounts
of these chemicals leached from treated and untreated soils during
short term leachate tests. Further, microscopic analyses of
treated soils revealed globules of untreated organic*, -indicating
that the mixing and treatment process was not completely effective.
It should be noted that none of the technology demonstrations that
have been carried out or planned in the near future have involved
soils with PCB concentrations as high as those found at the Rose
site. Thus, even if the tests conducted under the SITE program
show promising results for PCBs, questions will remain concerning
the applicability of those results to the Rose site.
Effectiveness of Vapor Extraction
GE's reference to Implementation of a VOC extraction procedure to
accompany fixation is speculative since it was never discussed in
the draft FS prepared by GE's consultants. Further, GE's
statement that VOCs would be destroyed is unclear. VOC extraction
does not destroy VOCs but merely separates them from the soil.
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EPA believes that the effectiveness of this technology may be
limited by the Rose site soil characteristics. The Rose site
soils are predominantly glacial till deposits. The till is
composed of a poorly sorted and nonstratified mixture of gravel,
sand, clay and silt. The till deposits are overlain by sand,
silt, top soil or fill. The wide variety of soil types make the
technical feasibility of vapor extraction questionable. Pilot
scale study would be required to determine the feasibility of this
technology for the Rose site.
Because of the variability in the soil, the implementation of
vapor extraction could be hindered or delayed, particularly due to
the presence of clay and silt at the site. Depending on the soil
porosity and moisture content, the amount of vapor present in the
pore space of the unsaturated zone, and vapor phase contaminant
concentrations, it could take a significant period of time to
remove soil vapors. Also, the limited soil VOC data indicates that
much of the VOC contamination is likely to be found below the water
table, inaccessible to (in situ) vapor extraction. This could
result in delay of excavation of soils for subsequent treatment
(e.g. chemical fixation/stabilization).
In addition, the vapor extraction would have no effect on the free
product portion of the site.
It vapor extraction was determined to be feasible for the site,
the costs would need to be added to those for fixation-
stabilization. Assuming that a vapor phase carbon adsorption
system would be required to treat the extracted vapors, these
costs could be quite significant, particularly if vinyl chloride
is found. This contaminant has been detected at high levels in
groundwater at the site. These high vinyl chloride concentrations
resulted in a significant increase in costs for the groundwater
treatment alternatives that involved air stripping due to the need
for air emissions control.
Finally, GE's claim that removal of VOCs from soil prior to
excavation will eliminate health risks due to VOC emissions during
implementation of fixation/stabilization is unsubstantiated. EPA
believes this is unlikely for 2 reasons:
1. Inability to remove all VOCs from soil before beginning the
fixation/stabilization process. EPA does not believe that vapor
extraction will be completely effective at the Rose site. Based
on the limited soil VOC data, much of the VOC contamination is
likely to be found below the water table, inaccessible to (in
situ) vapor extraction.
2. Release of VOCs during and after the fixation/stabilization
process. Since vapor extraction may not be completely effective
above the water table and will not be effective below the water
table, soils to be treated by fixation/stabilization may contain
VOCs. These VOCs are likely to be released during excavation of
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contaminated soil* (particularly those below the water table),
during mixing of soil with stabilization agents in the treatment
process, and during curing of the solidified material. Technical^
evaluations of fixation processes have shown that VOCs are releasfl
during the mixing stage of the fixation process. Short term (up Co
28 days) tests indicate that VOCs continue to be released at a
steady rate as the stabilized waste cures. Differences in VOC
concentrations between untreated and treated soils have been
attributed to these volatilization mechanisms rather than to
binding of the VOCs by the fixation/stabilization process.
References to Other Decisions and Intent
GE*s reference to Congress* statement that "...it is not intended
EPA spend millions of dollars incinerating vast amounts of
slightly contaminated materials..." is curious. Clearly, EPA
would not characterize the PCB soil contamination at the Rose site
as "slightly contaminated". To the contrary, EPA Region I is
unaware of any other NPL site nationwide with PCB levels that
exceed those documented at the Rose site (up to 440,000 ppm PCBs).
In addition, the estimated 15,000 cubic yards designated for
excavation and treatment is not considered to be a "vast amount",
and the majority of the contaminated material lies within a 1.5
acre area.
GE's reference to 2 other sites that selected fixation implies
that the factors that lead to the choice of fixation should lead
to a similar selection at the Rose site. While there may be some
common factors, each site is unique and must be evaluated
accordingly.
In reference to the Liquid Disposal site in Michigan, 6E notes
that "incineration was rejected by the Agency" at this site
because there was no clearly identifiable pattern or "hot spots"
of contamination at the site. Clearly, this is not the case at
the Rose site. The extent of PCB contamination is well defined
and is localized in a relatively small area approximately 1.5
acres in size. Further, the location of the free product area (or
"hot spot") is defined in the western portion of the disposal
area. As such, incineration should be technically and
economically feasible due to the uniformly high levels of PCB
contamination throughout much of the disposal area and the well-
characterized distribution of this contamination.
Further, although the Liquid Disposal Site ROD selected
stabilization for soil contaminated with organic chemicals, it
notes that the hazardous substances will not be permanently
destroyed. The ROD also states that "...data does not exist...to
accurately judge the long term reliability of the process. Long
term leaching and volatilization can be expected for soluble and
volatile organic wastes..." As a result, the ROD also calls for a
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slurry wall around and an impermeable cap over the solidified
material, measures not included in GE's proposal.
Regarding the Sand Springs Petrochemical Complex in Oklahoma,
EPA's original reasons for rejecting solidification are of '
particular interest:
a) lack of demonstrated permanence;
b) inability of solidification technologies to permanently bind
wastes with organic contents up to 50 percent;
c) doubts about whether the stabilized material would meet RCRA
requirements in the long term;
d) potential air emissions; and
e) the high potential for failure, compared to other remedies.
It should be further noted that this site is also contaminated
with sludges containing heavy metals, a condition which is not
believed to exist at the Rose site.
Comment 25
Conclusion
6E is committed to implementing a permanent solution at the Rose
site. However, it was, and is, premature for EPA to select mobile
incineration or any other technology as the preferred
remedial solution to soil contamination. EPA does not have at its
disposal the information that is necessary to select a remedy in
accordance with the requirements of CERCLA § 121. 6E urges EPA to
proceed with the issuance of a ROD on the groundwater operable
unit, but to withhold a decision on remediation of the source until
the soil and site conditions have been more fully characterized.
GE will proceed with the development of innovative technologies
which hold promise for this, as well as other, PCB-contaminated
sites. While GE develops these technologies, interim remedial
measures will be implemented to fully protect human health and the
environment.
Response 25
GE's commitment to implementing a permanent solution at the Rose
site is speculative until GE signs a legally binding Consent
Decree to implement a Record of Decision signed by EPA that calls
for a permanent remedy for the Site.
Since this final comment is a reiteration of previous comments,
see previous responses (including Responses 1 through 5, 11
through 13, and 23) and the ROD for further discussion.
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IV. REMAINING CONCERNS
At the public informational meeting held in Lanesborough on July
20, 1988, and at the informal public hearing held on August-3,
1988, local residents and officials discussed issues of concern as
the site moves into tha design and implementation phase of EPA's
selected ramady for tha Rosa sita. These issuas and concarns ara
described briefly below along with statements about how EPA intends
to address these concerns as they arise in the future.
(A) Haiift
Citizens expressed a strong concern that the incineration and
excavation process be carried out in a manner that would minimize
adverse impacts upon the community.
At the July 20, 1988 public informational meeting, EPA stated the
Agency's willingness to work with local officials to minimize the
adverse impacts of site remediation activities and stated that
local input will be solicited during the remedial design process
to address local concerns.
(B) Other Hazardous Waste Sites in Laneaborough
Citizens asked EPA to investigate other hazardous waste sites
owned by the contractor who disposed wastes at the Rose site.
EPA stated that the Agency is aware of the location of these
sites, but since these sites are not on the Federal Superfund list
(National Priorities List), EPA does not have any direct
involvement with these sites. Only the Rose site in Lanesborough
is on the National Priorities List and therefore qualifies for
federal funding. However, these other sites that are of concern
are on the Massachusetts DEQE "List of Confirmed Disposal Sites and
Locations to be Investigated" and are being investigated by the
State. EPA has relayed citizens' concerns about these sites to the
State.
(C) Groundwater Contamination
Citizens urged EPA to act quickly to prevent groundwater
contaminants from continuing to migrate from the Rose site.
EPA stated that the site cleanup will be carried out by 6E and
that the EPA will pursue immediate implementation of the
groundwater cleanup portion of the overall site remedy with GE.
EPA further stated that the EPA will oversee all cleanup activities
conducted by GE, including remedial design and actual construction
activities.
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EXHIBIT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
ROSE SITE
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EXHIBIT A
COMMUNITY RELATION ACTIVITIES
CONDUCTED AT THE
ROSE SITE
IN LANESBOROUGH, MASSACHUSETTS
Community relations activities conducted to date at the Rose
Superfund site include:
February 1988 - EPA conducted community interviews to assess
community concerns related to the site and to develop specific
plans to address those concerns.
June 1988 - EPA released a fact sheet to inform the public
about the results of the Remedial Investigation (RI)
conducted by GE at the site.
June 1988 - EPA issued a public notice announcing the
availability of the Administrative Record and the results of
the RI.
*
July 1988 - EPA released a community relations plan
describing citizen concerns about the site and outlining a
program to address these concerns and how EPA intends to keep
citizens informed about and involved in site activities.
July 1988 - EPA issued a public notice to announce the time
and place of the public informational meeting for the site and
to invite public comment on the Feasibility Study (FS) and the
Proposed Plan.
July 1988 - EPA mailed the Proposed Plan announcing EPA's
preferred alternative for addressing contamination at the
site to all those on the site mailing list.
July 20, 1988 - EPA conducted a site visit to familiarize
interested citizens and local officials with the site and to
discuss current and future EPA activities at the site.
* July 20, 1988 - EPA held a public informational meeting to
discuss the results of the RI/FS and EPA's Proposed Plan.
July 21 - August 19, 1988 - EPA held a public comment period
on the Proposed Plan.
August 3, 1988 - EPA held an informal public hearing to
accept comments on the remedial alternatives evaluated in the
FS and on the Proposed Plan.
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EXHIBIT B
TRANSCRIPT FROM THE INFORMAL PUBLIC HEARING
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1
UNITED STATES OF AMERICA
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ENVIRONMENTAL PROTECTION AGENCY
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RE: F.T. ROSE SITE SUPERFUND PROGRAM,
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7 I! A PUBLIC MEETING, held at the Lanesborough
8 High School Auditorium, on Wednesday,
9 August 3, 1388, commencing at 7:13'p.m.
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BEFORE: Sam Silvernan, EPA, Chairman
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Mary Sanderson, Remedial Project Manager
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2 I SPEAKERS; PAQfit
3 Sam Silvarman 3
4 i Mary Sanderson 6
5 Diana Niehola 7
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PROCEEDINGS
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(7:13 p.m.)
3 MR. SILVERMAN: We'll begin the meeting now.
4 Good evening and welcome. My name is Sam Silverman. I'm
Acting Deputy Director of the Environmental Protection Agency
Deputy Director of the Waste Management Division of the
Environmental Protection Agency, Region One, in Boston.
My responsibilities include managing the
9 I! Superfund Program in the State of Massachusetts. I will
10 serve as Chairman of this meeting and want to welcome you
all here this evening.
The purpose of this hearing is to formally accept
comments on the remedial investigation endangerment
assessment feasibility sutdy and proposed plan for remediation
of the F.T. Rose Superfund site located here in Lanesborough
Also present today is Mary Sanderson, who is
EPA's Site Manager for the F.T. Rose site.
What I would like to do now is to describe' for
you the format for this hearing. First, Mary will give
you a brief overview of the proposed plan.
As many of you know, EPA representatives made
a detailed presentation of the proposed plan at an
informational meeting which we held here on July 20th.
Following Mary's overview, we will accept any
oral comments you may wish to make for the record. Those
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1 of you wishing to comment should have already indicated
2 your desire to do so by filling out the form we made available
to you.
4 Also available, if you don't already have a copy,
5 is the proposed plan on the table in the middle of the
6 auditorium. Zf you have not yet completed a form, but do
7 | wish to make a comment, please do so now or any other time
8 I during the course of the hearing.
9 Z will call on the people wishing to make statement^
10 in the order in which they filled out the form. Z will
11 reserve the right to limit comments to ten minutes. However,
12 A given the low turnout, Z doubt Z'll have to do that.
13 9 Following the comments, Mary or Z may ask clarifying
14 ! questions regarding the comments just to make sure that
15 we're able to fully understand what the issues are that
1$ you are raising.
17 After all the comments 4iave been heard, Z will
IS j close the formal hearing. The purpose of tonight's hearing
19 is for EPA to receive your comments. As part of the formal
20 I hearing, Mary and Z will not be able to respond to your
2i | comments or questions tonight.
22 However, after Z close the formal part of the
23 hearing, Mary and Z will remain available to answer any
24 questions informally which you may have on issues which
have been raised this evening or in any other aspects of
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\ the feasibility study and proposed plan.
2 As you may know, the public comment on the proposed
3 plan opened on July 21st and runs through August 19th.
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4 If you wish to submit written comments, and Z encourage*
5 you to do so, they must be postmarked no later than August
6 19th and mailed to our office in Boston.
7 The appropriate address can be found on Page 2
8 of the proposed plan. At the conclusion of the meeting,
9 please see Mary or me if you have any questions on the process
10 for making written comments.
11 | All oral comments we receive tonight and those
12 we receive in writing during the comment period will be
13 responded to in a document we call the Responsiveness Summary
14- j This summary will be included with the decision
15 document or record of decision that EPA prepares at the
16 conclusion of the comment period. In the record of decision,
17 ! EPA will explain which clean-up alternatives have been selecte
18 ; for the F.T. Rose site.
19 Are there any questions, at this time on the format
20 for this evening?
2i (No response.)
22 Seeing that there are none, I just wanted to
23 encourage you all wishing to comment to do so now orally
, i
24 or in writing before August 19th.
25 If anyone else has decided to make an oral comment
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tonight, pleas* fill out one of those forms on the table
2 at this time.
3 Mary Sanderson will now open with a brief overvi
4 | of the proposed plan for the F.T. Rose site.
MS. SANDERSON: As Sam said* we were here two
4
weeks ago, at which time we did a longer presentation reviewing
7 the results of the remedial investigation, the endangerraent
8 assessment, the feasibility study and BPA's proposed plan.
9 . I won't be doing slides or any other presentation,
10 so to speak, tonight. I have brought a map later on for
'1 questions and answers, if you wish.
12 What I will just briefly review is the site history
13 the disposal area, approximately one and a half acres in .
14 the back portion of the Rose property.
15 The contamination is predominantly PCB's in a
16 source disposal area with volatile organic contamination
17 migrating from the site into plumes.
18 The endangerment assessment form, the risks posed
19 by the site to be contact with the PCB's in the disposal
20 area as well as groundwater consumption in the area where
21 the groundwater has become contaminated from the site.
22 w« talked about some of the options that were
23 presented in the feasibility study, and EPA has proposed
24 a two-part clean-up plan.
25 We have proposed that for the groundwater treatment
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portion of the contamination at the site, an air stripping
and carbon treatment system. There would be two interceptor
wells or trenches installed at the site where the two plumes
are emanating from the site, and those would be treated
by an air stripping and carbon 'treatment system.
For the source area, the one and a half acre
area, we are proposing excavation and on-site incineration
8 of those contaminated soils.
9 That, in a nutshell, is what several years of
10 study has done, and I will leave it at that, unless people
11 have questions on the proposed .plan being excavation and
12 on-site incineration for the source area soils and the
13 groundwater. treatment air stripping with carbon treatment
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14 for the groundwater contamination.
15 That, in a nutshell, I'll turn it back to Sam
for comments.
17 MR. SILVERMAN: Thank ySu, Mary. At this time,
13 i I'll start taking the comments from the audience. At present,
19 the only person who indicated an interest in making an oral
20 comment is Diane Nichols. Ms. Nichols, would you please
go to the microphone and make your comments?
22 MS. NICHOLS: As an abutter to the Rose site
23 and as the owner of the business that functions at that
*
site primarily on the telephone, I am opposed to any method
which would bring excessive noise or excessive construction
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1 disruption.
2 My husband and I bought the property in 1987
3 specifically for my telephone telemarketing business, and
4 if I can't do busy* then a noisy clean-up is unacceptable
5 to me.
6 Z would also insist that the Environmental
7 Protection Agency do everything possible to contain the
8 contamination during the clean-up process( and if that
9 contamination is found to extend to my property* then that
10 contamination be cleaned as well.
11 My property was found to contain a very small
12 insignificant amount of PCB-1260. That's what Z understand
13 is out in back of the Rose property. Right now, it's --
14 we call it an unknown source.
15 As an employer, Z have had to try to keep my
16 current employees informed and happy. Zn this type job
17 market situation, Z have had to t*y not to stir prospective
18 employees, and Z've gone through one headache after a'nother
19 with testing in my basement, testing on the property.
Z would support any method that the EPA would
want to do that would be, first of all, complete and, second
of all, permanent.
23 Zf we have to go with an incinerator and such
24 which is going to generate so much noise at a high cost,
fine. He'll have to live with it. Z would hope that, you
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1 know, it could be done so that everybody is happy without
2 either noise or disruption.
3 Whatever you can do that would be the most effectiv^,
4 the most permanent is fine. Z do not support most of the
3 unprbven experimental methods, except probably for SM-10,
6 which is the biodegradation.
7 I do not support any of the methods which would
8 not reduce the toxicity of the material. Z do not support
9 more solvents and more chemicals being pumped into the land
10 which has already been unacceptably defiled.
11 ! Z particularly do not support the proposal at
12 the M-6 which proposes to turn the Rose site into a hazardous
13 waste site because that opens up a whole can of worms for
14 other hazardous waste to be dumped there, for town garbage
15 to be dumped there* et cetera.
16 As property owner that abutts this, we've had
17 ! enough headaches. Z, personally,""don't want it. Z think
^ *
18 j that public health is at stake in this particular instance
19 so whatever will contain this mess from being from more'
20 public exposure is fine by me.
2i Z think you should do whatever is necessary to
22 clean it up for the public's good.
23 Zn response to the Berkshire Eagle accounts that
24 Z've been reading of General Electric's position regarding
25 this whole thing, Z think that the GE is ultimately responsib!
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for this mess that we have on Balance Rock Road. I'm very
2 tired of hearing about Berkshire County high cancer rate,
3 Berkshire County's toxic waste dumps here and there that
4 somehow are always traced back to a major industry* usually
5 General Electric.
* I feel that it is General Electric's responsibility
7 to do whatever is necessary to restore the land that they
8 defiled, not what they find the easiest on their pocketbooks
9 but it's time that GE took full responsibility for their
10 actions in regard to this environmental problem.
11 Lastly, Z would hope that the comments that we,
12 as abutters, are making and the Rose family's comments weigh
13 heaviest on whatever the EPA plans to do. Z think that
14 our feelings are more important than somebody that, say,
15 lives up on North Main Street or Summer Street because we're
16 the ones that are ultimately at stake here. Zt's our property
17 < and our health. *"
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18 Since the Rose family lives on the land and pays
19 the taxes on that land and has had their privacy invaded
20 because of all this and since they live with the albatross
2i around their neck daily, Z think that their opinions should
22 weigh the heaviest on EPA's final recommendations.
23 Z think the Rose family has been put through
24 all this and after all this deserves a break so Z say let's
25 give them a break, listen to them, listen to me and do whatev
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is necessary. Thank you.
2 MR. SILVERMAN: Thank you.
3 (Whereupon, on August 3, 1988, the above matter
4 was concluded.)
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CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceedings
before:
in the Matter of:
FT ROSE SUPERFUND SITE
Place: Lanesborough High School
Date: 8/3/38
were held as herein appears, and that this is the true,
^^
accurate and 'complete transcript prepared from the note^s
and/or recordings taken of the above titled proceeding.
V. McCann 8/3/88
Reporter Date
S. Hayes 8/16/88
TranscriberDate~
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