United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/038
September 1989
Superfund
Record of Decision
O'Connor, ME
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/{R01-8 9/038
3. Recipient'* Accession No.
4. Title «nd Subtitle
SUPERFUND RECORD OF DECISION
O'Connor, ME
First Remedial Action - Final
5. Report Date
09/27/89
7. Author(B)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Project/Taek/Work Unit No.
11. Contract(C) or Gram(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The O'Connor site covers a 9-acre area near the city limits of Augusta, Maine. The area
neighboring the site consists of woodlands, a small poultry farm, private properties and
residences, and wetlands. A portion of the site is also located within a 100-year
I floodplain. The F. O'Connor Company began operating a salvage and electrical
^ransformer recycling business at the site in the early 1950s. Because of previous oil
^ppills the State investigated the site in 1976 and found the surface water, sediment,
Knd soil contaminated with PCBs. As a result of this study the F. O'Connor Company
constructed two surface water impoundments (lagoons) to control further migration of
oils from the site. In 1977 the State ordered the F. O'Connor Company to discontinue
use of the lagoons. Subsequently the lagoon waters were pumped into several onsite
storage tanks and the sediment was excavated, deposited in a low area onsite, and
covered with a clay cover. The sediment created a barrier for surface water and formed
an upland marsh onsite. In May 1987 EPA and the State jointly issued an amended
Administrative Order to F. O'Connor Company requiring field investigations and
extensions of the existing fence to areas where additional contamination was found. The
primary contaminants of concern affecting the soil, sediment, ground water, and surface
water are VOCs including benzene, other organics including PCBs and PAHs, and metals
including lead. (Continued on next page)
ME
17. Document Analysis a. Descriptors
Record of Decision - O'Connor,
First Remedial Action - Final
Contaminated Media: soil, sediment, gw, sw
Key Contaminants: VOCs (benzene), other organics (PCBs, PAHs), metals (lead)
b. kJentifiers/Open-Ended Terms
c. COSAT1 Held/Group
Availability Statement
1t. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
195
22. Price
(See ANSI-Z39.18)
SM //utructfonc on flttvne
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce'
-------
16. Abstract (Continued)
EPA/ROD/R01-89/038
H1 Connor, ME
The selected remedial action for this site includes pumping and offsite treatment of
lagoon and upland marsh surface water; excavation and onsite treatment of approximately
23,500 cubic yards of contaminated soil and sediment using a solvent extraction process
followed by onsite disposal of residuals; onsite treatment of gases from the solvent
extraction process; extraction and offsite treatment of solvent residues using
incineration; onsite treatment by solidification of soil and sediment that do not achieve
target cleanup goals after treatment, followed by offsite disposal; backfilling and
upgrading the excavated area with clean soil and treated soil; ground water pumping and
treatment using activated carbon adsorption followed by onsite reinjection; and sediment
and ground water monitoring. The estimated total cost for this remedial action is
$14,221,000 which includes annual O&M costs of $56,000 in year 1, $54,000 for years 2-4,
$92,000 for year 5, and $65,000 for years 6-30.
-------
ROD DECISION SUMMARY
O'CONNOR CO. SUPERFUND SITE
AUGUSTA, MAINE
SEPTEMBER 27, 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
BOSTON, MASSACHUSETTS
-------
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
O'Connor Company Site
Augusta, Maine
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the O'Connor Company site (the "Site"), located in Augusta,
Maine. This decision was 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. (1985). The Regional Administrator has been delegated
the authority to approve this Record of Decision.
The State of Maine has concurred on the selected remedy and
determined, through a detailed evaluation, that the selected
remedy is consistent with Maine laws and regulations.
STATEMENT OF BASIS
This decision is based on the administrative record compiled
for the Site which was developed in accordance with Section
113(k) of CERCLA. The administrative record is available for
public review at the Lithgow Public Library in Augusta, Maine,
and at the EPA Region I Waste Management Division Record Center
in Boston, Massachusetts. The administrative record index
(attached as Appendix E to the ROD) identifies each of the items
which comprise the administrative record upon which the selection
of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Site is a comprehensive approach
for complete remediation of the principal threats posed by the
Site. This approach includes both source control and management
of migration components, as described below:
-------
Source Control Components:
EPA will initiate remediation at the Site by pumping the
contaminated surface water from the upper and lower lagoons and
the upland marsh. This water will be transported via tanker
trucks to a permitted, off-site treatment facility. At this
time, the volume of water to be pumped is estimated at between
150,000 and 195,000 gallons (total).
EPA will then treat all of the approximately 23,500 cubic
yards of contaminated soils and sediments containing PCBs, cPAHs,
and lead above the established target cleanup goals using a
solvent extraction technology. This technology principally
involves the use of a solvent to extract the PCBs and cPAHs from
the contaminated soils and sediments. The lead is not likely to
be treated by this technology to any significant degree.
However, since the lead-contaminated materials are co-located
with the PCBs and cPAHs, it would be technically impracticable to
separate out the lead; additionally, the treatability study
results indicate that the lead may in fact bind to the treatment
residue resulting from solvent extraction. The contaminated
liquid containing the extracted PCBs and cPAHs will be destroyed
at a licensed, off-site TSCA incinerator. During on-site solvent
extraction, exhaust gases from the process will be treated by air
pollution control devices to ensure that appropriate health and
safety and air quality requirements are being met.
Prior to full-scale implementation of the solvent extraction
process on the Site, additional treatability studies will be
performed both in the laboratory and at the Site. These
additional studies will provide further information regarding the
ability of this technology to achieve the 1 ppm cleanup goals for
PCBs and cPAHs that have been established for the Site, and will
also assist in establishing the optimum operational settings for
full-scale extraction of these contaminants at the Site.
Additionally, soil and sediment treatment residues resulting
from the solvent extraction process that have lead levels above
the 248 ppm target cleanup level, will undergo further treatment
using a solidification/stabilization technology if, after
undergoing the EPA standard EP (extraction procedure) toxicity
test or TCLP (toxicity characteristic leaching procedure), they
continue to exhibit the characteristics of a hazardous waste.
The solidification/stabilization treatment technology essentially
uses a combination of processes to bind contaminants within the
treated mass, resulting in a substantial reduction in the
mobility of the contaminants.
Those solid treatment residues resulting from the solvent
extraction process that do not achieve the target cleanup goals
established for the protection of human health and the
environment at the Site (i.e., 1 ppm PCBs, 1 ppm cPAHs, or 248
ppm lead) and/or that have undergone additional treatment through
solidification/stabilization, will be transported off-site in
-------
appropriately sized containers and trucks to be disposed of at a
licensed landfill. It is currently approximated by EPA that
5,000 cubic yards of the total 23,500 cubic yards of contaminated
soils and sediments undergoing solvent extraction will require
off-site disposal.
Following implementation of the above-described remedial
action source control components, the Site will be restored.
This will include the backfilling of those areas of the Site
where excavation occurred. The backfilling of these areas will
require that: (a) new native soil be brought to the Site from an
off-site location (approximately 5,000 cubic yards), and (b)
those residual soils from the on-site solvent extraction system
that achieve all the established target cleanup goals be placed
back onto the Site (approximately 18,500 cubic yards). These
backfilled soils will then be regraded to establish new surface
water drainage patterns on the Site.
In addition, the drainage and off-site treatment of those
contaminated surface waters contained within the upland marsh,
and upper and lower lagoons on the Site require that these waters
of the U.S./wetlands be compensated for due to unavoidable
impacts that may be caused by the destruction of these areas.
Therefore, compensatory wetlands will be established within the
F. O'Connor property following the completion of the source
control components of the selected remedy. Furthermore, any
potential effects on the 100-year floodplain partially located on
the Site will be limited through the use of careful construction
practices during the entire excavation activity to be performed
at the Site.
Management of Migration Components:
EPA will actively address groundwater contamination at the
Site by utilizing collection and carbon adsorption treatment
techniques. The system will first entail the installation of one
or more groundwater extraction wells on the Site. Collected
groundwater-will then be pumped through a granular filter to
remove particulates, suspended solids, and oil droplets.
Following this preliminary filtration step, the groundwater will
be treated by carbon adsorption, which uses activated carbon to
remove the organic contaminants found in the groundwater.
Prior to full-scale implementation of the groundwater
collection and treatment system, the exact location, number of
extraction well(s), operating conditions, capture zone
efficiency, etc. will be determined during the design phase of
the selected remedy. This will include the performance of one or
more pump tests at the Site. If, based on these pump test(s) and
the analytical results of the groundwater from these tests,
inorganics such as iron and/or manganese are present and could
cause fouling problems with the activated carbon unit, then an
in-line pretreatment unit for these metals would be added during
the design phase of the overall treatment system.
-------
The treated water that achieves the target cleanup goals
established for the Site will be recharged back into the ground
on t!ie Site. System monitoring, in the form of periodic sampling
and analysis, will occur at the Site to evaluate the performance
and efficiency of the entire groundwater extraction system.
Additionally, EPA will recommend the temporary establishment
of institutional controls on the Site groundwater. These
recommended controls will involve deed and land-use restrictions
to restrict the use of groundwater on the Site during overall
site remediation.
In addition to the groundwater treatment system,
environmental sampling of the sediments within Riggs Brook and
its associated nearby wetlands will be conducted once every year
for ten years. This will be combined with the establishment of
public education programs designed to increase public awareness
about the status of contamination within Riggs Brook.
DECLARATION
The selected remedy is protective of human health and the
environment, attains all Federal and State requirements that are
applicable or relevant and appropriate (ARAR) to this remedial
action, and is cost-effective. This remedy satisfies the
statutory preference for remedies that employ treatment and that
reduce the toxicity, mobility or volume as a principal element
and utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Additionally, because the remedy will result in hazardous
substances remaining in the groundwater and sediments on the Site
above health based levels, a review will be conducted (at a
minimum) within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Date ' Acting Regional Administrator
U.S. EPA, Region I
-------
O'CONNOR CO. SITE
Record of Decision Summary
TABLE OF CONTENTS
Cont(
I.
II.
III.
IV.
V.
VI.
VII.
VIII
IX.
X.
XI.
ents
A.
B.
A.
B.
C.
D.
E.
F.
A.
B.
A.
B.
A.
B.
A.
B.
C.
Page Num
SITE NAME, LOCATION AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Response History
Enforcement History
COMMUNITY RELATIONS
SCOPE AND ROLE OF RESPONSE ACTION
SITE CHARACTERISTICS
soil
Residential Well Water
Surface Water
Biota
SUMMARY OF SITE RISKS
DOCUMENTATION OF NO SIGNIFICANT CHANGES
DEVELOPMENT AND SCREENING OF ALTERNATIVES
Statutory Requirements/Response Objectives ....
Technology and Alternative Development and
DESCRIPTION/SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS OF ALTERNATIVES
Source Control (SC) Alternatives Analyzed
Management of Migration (MM) Alternatives
THE SELECTED REMEDY
Description of the Selected Remedy
Rationale for Selection
.STATUTORY DETERMINATIONS
The Selected Remedy is Protective of Hunan Health
and the Environment
The Selected Remedy Attains ARARs
The Selected Remedial Action is Cost Effective . .
her
1
2
2
3
5
6
7
7
8
9
9
10
11
13
15
16
16
17
19
19
32
35
35
48
52
52
53
59
-------
O'CONNOR CO. SITE
Record of Decision Summary
TABLE OF CONTENTS (continued)
Contents Page Number
XI. STATUTORY DETERMINATIONS (continued)
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable 60
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element 61
»
XII. STATE ROL2 62
-------
O'CONNOR CO.SITE
Record of Decision Summary
LI6T OF FIGURES
Figure Number Page Number
1-1 Site Location Map. 1A
1-2 Conceptualized Site Setting IB
1-3 Site Setting 7A
4-8 Interpretive Distribution of PCBs in Surficial
Soils 7B
1-6 Isopach Map Illustrating Thickness of Soil and
On-Site Sediments Contaminated By Greater Than
1 ppm PCBs 7C
4-10 Distribution of PAHs in Surface and Subsurface
Soils 7D
1-10 Interpretive Distribution of Lead in Surface
and Near-Surface Soil 7E
5-1 ' Monitoring Well and Staff Gauge Locations 8A
1-4 Interpretive Geologic Profile A-A1 8B
6-1 Surface Water Sample Locations and Analytical
Results Summary 10A
7-1 Sediment Sample Locations and Analytical
Results Summary 11A
1-14 Biota Sampling Station Locations and Sampling
Results Summary 11B
-------
O'CONNOR CO. SITE
Record of Decision Summary
LIST OF TABLES
Table Nivfr>«»r Page Number
1 Summary of Potential Risks Associated With
Human Exposure to Chemicals of Concern From
the O'Connor Site ..... .......................... 13A
2 Assumptions for Use in the Exposure Assessment
for Direct Contact with Soil by Children at
the O'Connor Site .............................. 13B
3 Assumptions for Use in the Exposure Assessment
for Inhalation of Surface Soil Indicator
Chemicals by Residents Living Near the
O'Connor Site .................................. 13C
4 Exposure and Risk Assessment for Consumption
of Freshwater Fish frcm Riggs Brook ............ 13D
5 Assumptions for the Future Use Exposure
Scenario for Direct Soil Contact at the
O'Connor Site .................................. ..13E
6 Summary of Remedial Alternatives Retained for
Detailed Analysis, O'Connor Site ............... ISA
7 Comparative Analysis of Source Control
Alternatives ................................... 19A
8 Comparative Analysis of Management of
Migration Alternatives ...................... ... 19B
9 Comparative Analysis of Riggs Brook Sediment
Alternatives ................................... 19C
10 Proposed Target Clean-Up Levels for On-Site
Surface Water .................................. 53A
11 Proposed Target Clean-Up Levels for
Groundwater .................................... 53B
12 Potential Action-Specific ARARs ................ 53C
13 Potential Chemical-Specific ARARs .............. 53D
14 Potential Location-Specific ARARs .............. 54A
15 O'Connor Site Estimated Total Cost of Selected
Remedy ................................... ...... 59A
16 O'Connor Site Estimated Cost of Selected
Remedy-Source Control Component ................ 60A
17 O'Connor Site Estimated Cost of Selected
Remedy-Management of Migration Component ....... 60S
18 O'Connor Site Estimated Cost of Selected
.Remedy-Riggs Brook Sediment Component .......... 60C
-------
O'CONNOR CO. SITE
Record of Decision Summary
APPENDICES
Responsiveness Summary . Appendix A
United States Fish & Wildlife Service (U.S. F&WS)
Letters Regarding Target Cleanup Levels .... Appendix B
State of Maine Rationale for Target Cleanup
Levels Appendix C
State Concurrence Letter Appendix D
Administrative Record Index Appendix E
-------
I. SITE NAME: O'Connor Co.
LOCATION: Augusta, Maine
DESCRIPTION:
The O'Connor Co. site ("the Site") is located along U.J5. Route 17
near the eastern boundary of the city limits of Augusta, Maine
(see Figure 1-1). The Site consists of approximately nine acres
of land located within a larger 65-acre expanse of property. The
Site is currently surrounded by a chain link fence, and is
bordered by woodlands and a small poultry farm to the north, U.S.
Route 17 to the south, private properties and residences to the
west, and the west branch of Riggs Brook and its associated
wetlands to the east.
Principal features of the Site include a large barn that formerly
housed scrap operations, an upland marsh, a "low area", two
surface water impoundments (lagoons), three former transformer
work areas (TWAs), and a former scrap area (see Figure 1-2).
A more complete description of the Site can be found in the
Remedial Investigation (RI) report, dated June 1989, at pages
1-3, and 2-1 to 2-2.
-------
QUADRANGLE LOCATION
TOQU8 POND. MAINE(1082)
N4416-W0837-30/7.6
14000 FEET
W315"
FIGURE 1-1
SITE LOCATION MAP
O'CONNOR SITE
E.CJORDANCQ -
<»
-------
Page ]
FIGURE t-2
CONCEPTUALIZED
SITE SETTING
F. O'CONNOR SITE
AUGUSTA. MAINE
ECJORCANOD
-------
ROD DECISION SUMMARY page
O*CONNOR CO. SITE
II. SITE EI6TORY AND ENFORCEMENT ACTIVITIES
A. Response History
The F. O'Connor Co. began operating a salvage and electrical
transformer recycling business at the Site in the early 1950's.
Operations included stripping and recycling transformers
containing PCB-laden oils which were generated by Central Maine
Power (CMP). In February 1972, an oil spill at the Site was
found to have migrated towards Riggs 3rook. Later that same
year, at the request of the Maine Department of Environmental
Protection (DEP), the F. O'Connor Co. began containing all
transformer fluids found on the Site j.n an aboveground storage
tank to prevent future spills.
In 1976, the Maine DEP began further investigations at the Site
through the sampling and analysis of soils, sediments, and
surface waters for PCBs. As a result of these activities, the
Maine DEP requested the F. O'Connor Co. to construct two surface
water impoundments (lagoons) to control further migration of oils
from the Site. The F. O'Connor Co. did so.
In 1977, also at the request of the Maine DEP, the F. O'Connor
Co. discontinued use of the lagoons in order to reclaim these
areas. More specifically, the lagoon waters were pumped into
several on-site storage tanks, and the lagoon sediments were
excavated and deposited into a "low area" on the Site. These
excavated sediments were underlain and also covered by
approximately one foot of clay soil. Deposition of these
sediments created a barrier for natural surface water drainage
from the Site to Riggs Brook. This resulted in the formation of
the upland marsh which is located behind the on-site barn
structure.
Four sampling events by the United States Environmental
Protection Agency (EPA) from 1982 to 1984, and additional Maine
DEP sampling efforts in 1978 and 1982, confirmed the presence of
significant PCB contamination at the Site. In December 1982, the
Site was proposed for inclusion on EPA's National Priorities List
(NPL), and was placed on the final NPL on September 8, 1983.
A more detailed description of the Site history can be found in
the RI report at pages 1-6 to 1-8, and related appendices to this
report.
-------
ROD DECISION SUMMARY page 3
O'CONNOR CO. SHE
B. Enforcement History
On December 21, 1984, EPA issued a Unilateral Administrative
Order to the F. O'Connor Co. requiring it to construct a fence
around and post warning signs along approximately five acres of
the Site, as defined at that time. This Order, which was
complied with by the F. O'Connor Co., further required sampling
and analysis of the contents of all drums and storage tanks found
at the Site.
In April of 3.985, EPA notified CMP and the F. O'Connor Co. of
their potential liability with respect to the Site on grounds
that they either owned or operated the facility, generated
hazardous substances that were shipped to the facility, arranged
for the disposal of hazardous substances at the facility, or
transported hazardous substances to the facility. Subsequently,'
negotiations commenced with these potentially responsible parties
(PRPs) regarding settlement of the PRPs1 liability at the Site.
On May 13, 1986, EPA issued an Administrative Order by Consent
(AOC) to the F. O'Connor Co. and CMP. This Order was entered
into voluntarily by these parties in order to conduct a Remedial
Investigation/Feasibility Study (RI/FS) to determine the nature
and extent of contamination, and to evaluate alternatives and
recommendations for the appropriate extent of remedial actions at
the Site. On May 19, 1986, the Maine DEP also issued an
Administrative Order to the F. O'Connor Co. designating the Site
as an Uncontrolled Hazardous Substance Site under Maine law.
On June 23, 1986, the Maine DEP issued an AOC to the F. O'Connor
Co. and CMP by which these parties agreed to remove the currently
known threat to the public health or welfare or the environment
which was posed by the hazardous substances present in tanks and
containers remaining at the Site, and to conduct and prepare an
RI/FS for the Site.
On May 23, 1987, EPA and the Maine DEP jointly issued an Amended
AOC to the F. O'Connor Co. and CMP modifying EPA's original May
13, 1986.AOC, and superseding those portions of the previous AOC
issued by .the Maine DEP which ordered these same parties to
conduct an RI/FS at the Site. Additionally, this Amended AOC
required the PRPs to conduct additional field investigations and
extend the then-existing five-acre fence to areas where
additional contamination was found. In compliance with this
Amended AOC, the PRPs performed the required sampling which
resulted in the installation of additional fences and warning
signs to secure the present nine-acres of the Site.
To date, CMP has been actively involved in the development and
-------
ROD DECISION SUMMARY page 4
O'CONNOR CO. SITE
preparation of the RI/FS and remedy selection process for the
Site. A significant amount of correspondence has occurred
between EPA, the Maine DEP and the PRPs throughout this process,
as documented in the Administrative Record prepared for the Site.
This correspondence includes technical comments submitted by the
PRPs during the public comment period for the Proposed Plan.
Those comments received during the public comment period and
EPA's responses to these comments are included in the
Responsiveness Summary attached to this Record of Decision (ROD)
as Appendix A. To dt-te, special notice has not been issued in
this case.
-------
ROD DECISION SUMMARY page 5
O'CONNOR CO. SITE
III. COMMUNITY RELATIONS
Throughout the Site's history, community involvement has been low
to moderate. EPA has kept the community and other interested
parties apprised of the Site activities through informational
meetings, fact sheets, press releases and public meetings.
In September 1985, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in the remedial activities
to be conducted at the Site.
On June 11, 1986, EPA held an informational meeting in the Civic
Room of the Augusta City Hall to describe the plans for the
Remedial Investigation and Feasibility Study (RI/FS).
On July 13, 1989, EPA made the Administrative Record available .
for public review at EPA's offices in Boston and at the Lithgow
Public Library in Augusta. EPA published a notice and brief
analysis of the Proposed Plan for the Site in the Kennebec
Journal on July 12, 1989 and made the plan available to the
public through individual mailings and at the Lithgow Public
Library.
On July 19, 1989, EPA held a public informational meeting to
discuss the results of the Remedial Investigation and the cleanup
alternatives presented in the Feasibility Study (dated June
1989), and to present the Agency's Proposed Plan. Also during
this meeting, representatives from EPA and the Maine DEP answered
questions from the public about the Site and the remedial
alternatives under consideration. From July 20, 1989 to August
19, 1989, the Agency held a 30-day public comment period to
accept public comments on the alternatives presented in the
Feasibility Study and the Proposed Plan, and on the other
documents which were a part of the Administrative Record for the
Site. On August 10, 1989, the Agency held a public hearing to
accept any oral comments about the Site. A transcript of this
hearing, and the Agency's response to comments made during the
public comment period are included in the Responsiveness Summary
that is attached as Appendix A hereto.
-------
ROD DECISION SUMMARY page 6
O'CONNOR CO. SITE
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy was developed by combining source control and
management of migration remedial alternatives to obtain a
comprehensive approach for overall Site remediation. In summary,
the response action contained in this ROD addresses the principal
threats to human health and environment posed by the Site through
treatment of the contaminated soils, sediments, surface waters,
and groundwater found on the Site.
Additionally, this response action is consistent with all
previous removal actions which have contributed to the efficient
performance of this final, planned response action. At the
present time, no further operable units are expected to be
performed at the Site in the future.
-------
ROD DECISION SUMMARY page 7
O'CONNOR CO. SITE
V. SITE CHARACTERISTICS
Chapter 1.0, subsection 1.2 of the Feasibility Study (FS) report
contains an overview of the Remedial Investigation (RI) performed
at the Site. The significant findings of" the RI are summarized
below.
A. Soil
During the RI, approximately 500 soil sanples were taken from the
Site surface (through grid or grab, samples) and subsurface
(through shallow borings or test pits). These samples revealed
the presence of a wide range of organic and inorganic chemicals
of cqncem. More specifically, polyc'nlorinated biphenyls (PCBs)
and lead were the principal substances found in the surface (0 to
6-inch deep) soils; whereas, PCBs and carcinogenic polycyclic
aromatic hydrocarbons (cPAHs) were the principal contaminants
detected in the subsurface (0.5 to 12-feet deep) soils.
The largest areas of PCB-contaminated soils were found primarily
within the former transformer work areas (TWAs), and the drainage
areas associated with these TWAs. Small, discrete areas of
highly contaminated PCB soils were found in the TWA Ill/scrap
area (see Figure 1-3). These contaminated soils were discovered
beneath former electrical equipment, and found to contain up to
200,000 parts per million (ppm) PCBs. Lead was detected above
background (i.e., approximately 70 ppm-average) principally in
the surface soils within TWAs I and II, with the maximum lead
concentration occurring at 4,100 ppm within TWA II,
Subsurface soils taken from TWAs I and II, and the "low area"
contained cPAHs. The depth of vertical migration of the cPAHs
appeared to be limited to the upper 6-feet within TWA I and the
low area, while a small pocket of cPAHs was found to exceed
8-feet deep within TWA II. The maximum cPAH concentration of 30
ppm was found within the low area. PCBs in the subsurface soils
were, on average, limited to 2-feet or less in depth, while the
areas of maximum vertical migration occurred within TWAs I and II
at depths -of up to 10 to 12-feet.
The reader is referred to Figures 4-8, 1-6, 4-10, and 1-10 for an
overview of the distribution of the PCB-, cPAH-, and lead-
contaminated soils found at the Site. Additionally, a more
complete description of the soil contamination and information
regarding the geologic characteristics of the Site can be found
in Chapter 4.0 of the Remedial Investigation (RI) report.
-------
-------
ROD DECISION SUMMARY page 8
O'CONNOR CO. SITE
B. Groundwater
During the RI field work, a total of five (5) nested pairs of
groundwater monitoring wells and one single monitoring well were
installed at the Site (see Figure 5-1). Each nested pair of
wells was screened within the overburden, but below the water
table, and within the bedrock. The single monitoring well was
screened within the bedrock only, due to the limited overburden
thickness at this location. These wells were installed at
locations specifically chosen to monitor conditions upgradient
(background) conditions and downgradient from the major
contaminated source areas (especially, TWAs I and II)as well as
within major drainage pathways/discharge zones to Riggs Brook.
Based' upon the hydrogeologic information obtained from the above-
mentioned monitoring wells, two distinct groundwater flow systems
were identified at the Site: a shallow, unconfined overburden
system-; and a deep/bedrock system. The deep/bedrock system was
determined to be unconfined beneath higher (elevated) portions of
the Site and confined under the lower portions near Riggs Brook.
The confining unit for the deep/bedrock flow system was
determined to begin just west of the lower lagoon and is composed
of marine clay averaging 10 to 15 feet thick (see Figure 1-4).
Groundwater in the deep/bedrock system under the Site was
determined to flow in a west-to-east direction, primarily through
the vertical fractures in the bedrock which were found to trend
in an east-west direction. Groundwater flow in the shallow
system was generally from the northeast to southwest within the
sands and till materials at the Site. Both groundwater flow
systems are recharged from precipitation falling onto higher
elevations of the Site, and discharge towards Riggs Brook.
Three (3) rounds of groundwater samples were taken from the
above-mentioned monitoring wells during the RI field work. All
monitoring wells during all rounds of sampling were analyzed for
PCBs (either filtered and/or unfiltered), while organic and
inorganic samples were obtained from selected wells based upon
previous rounds of analytical data.
The results from these sampling events indicate that chlorinated
benzene compounds (i.e., chlorobenzene, 1,2-dichlorobenzene, 1,4-
dichlorobenzene, and 1,2,4-trichlorobenzene) were consistently
detected in the bedrock well located downgradient of TWA II (well
MW-104B), and to a lesser extent in the shallow and bedrock wells
downgradient of TWAs I and III. The maximum concentrations of
these compounds were as follows: 1,2,4-trichlorobenzene (310
parts per billion-ppb); 1,4-dichlorobenzene (28 ppb); 1,2-
dichlorobenzene (17 ppb); and chlorobenzene (16 ppb).
-------
MltlM 0» CUMl Mm MM*
tN
II*
i
i
i
a
FtQURE'1-4
INTERPRETIVE GEOLOGIC PROFLE A-A* .
F. O'CONNOR SITE
AUGUSTA, MAME
ECJORDANCQ-
00 j
-------
ROD DECISION SUMMARY page 9
O'CONNOR CO. SITE
PCBs, more specifically Arochlor 1260, were identified in the
unfiltered groundwater samples taken during the first round of
sampling at 1.6 to 50 ppb (the higher concentrations were
detected in well MW-104B located in the bedrock, and downgradient
of TWA II). Additional rounds of samples taken from the five
nested monitoring wells installed at the Site showed no
detectable amounts of PCBs, vhile only one additional detectable
concentration of PCBs was identified at 23 ppb in the single
bedrock monitoring well (MW-104B; note that a duplicate of this
same sample indicated no detectable PCB contamination).
Other organic compounds detected sporadically or otherwise were
phthalates, primarily bis (2-ethylhexyl) phthalate, acetone,
benzene, methylene chloride, 2-butanone, and toluene. Inorganics
were."analyzed during the first round of samples taken from the
five monitoring wells. From these samples, lead was detected in-
only one well (MW-103B) at a concentration of 28 ppb.
A more complete description of the groundwater contaminants found
at the Site, and information regarding the hydrogeologic
characteristics of the Site, can be found in the RI report within
Chapter 5.0.
C. Residential Well Water
Five (5) residential wells located within a one-half mile radius
of the Site were selected for sampling and analysis as a result
of a comprehensive domestic well survey conducted during the RI
field work. The five domestic wells were all located to the
northwest or southwest of the Site, and all wells were installed
in the bedrock.
Analytical results from these five domestic wells.indicated that
no PCBs or organic chemicals were detected. The results obtained
for inorganics identified lead in one of the wells at 65 ppb.
This domestic well was located one-half mile upgradient (north-
northeast) from the Site, and was reportedly not used for
drinking water purposes but only for gardening.
A more complete description of the residential well water results
and the well survey conducted around the Site can be found in
Chapter 5.0 and Appendix D-7 of the RI report.
D. Surface Water
During the RI field efforts, surface water investigations were
conducted both on and off the Site which included sampling and
analysis and a hydrologic assessment. These investigations
focused on the upland marsh, the upper lagoon and the lower
-------
ROD DECISION SUMMARY _ . page 10
O'CONNOR CO. SITE
lagoon located on the Site, and the Riggs Brook watershed.
Based on the hydrologic investigations of the surface waters in
and around the Site, it was determined that flow from the on-site
surface water features occurs directly into Riggs Brook via a
central drainage swale. This flow, however, occurs only during
seasonal recharge periods (spring and fall) and during major
storm events. Additionally, the Riggs Brook watershed which is
in close proximity to the Site only drains approximately
7 percent (1 square mile) of the entire 15 square mile drainage
basin. However, since a narrow and shallow stream channel has
been eroded and provides a limited flow capacity during flood
periods within the Riggs Brook watershed nearest the Site, the
wetland areas at the base of the Site flood during periods of
heavy rain and/or snowmelt. Furthermore, the lower elevations of
the Site (specifically, the above-mentioned wetlands and the
lower lagoon) are approximately located within the 100-year
floodplairi designated by the Federal Emergency Management Agency
(FEMA).
Surface water quality, as shown on Figure 6-1, was determined
from several sampling locations both on and off the Site. These
results indicated that PCBs (from unfiltered samples) were
detectable in the upper and lower lagoons, and the lower lagoon
drainage but were not detected in surface water samples taken
from Riggs Brook. PCB concentrations in the on-site surface
waters ranged from 0.55 ppb in the lower lagoon to 16 ppb in the
upper lagoon. Other contaminants of concern in the on-site
surface waters were the inorganic chemicals: lead and aluminum.
While lead was only detected in one surface water sample within
Riggs Brook at 16 ppb (located approximately 450 feet downstream
of the Site, but not in samples nearest to the Site), lead was
found at concentrations ranging from 3.6 to 13 ppb in all the on-
site surface waters. Additionally, aluminum was detected in the
on-site surface waters at concentrations ranging from 236 to
3,740 ppb.
A more complete discussion of the surface water hydrology of the
Site and surrounding areas can be found in Chapter 6.0 of the RI
report.
E. Sediment
The sediment sampling program established during the RI was
performed in conjunction with the above-described surface water
sampling program in order to collect pairs of samples for
analysis within each of the major surface water bodies in the
site-area. A total of 23 sediment samples were collected from 19
locations both on-site and within Riggs Brook.
-------
UGENO
SWMCt WAttB SAWIC UXTAtlOM
COMC PCB. >l ug/1
CCNC Of If AO H
AlUMMJM M ug/l
.
CD ««*S WITH SIMOMQ WATCH
°"»»<0«OCOS> IMtOHV Stll
|IKSU.IS GREAItR IHAN MSIRUMlHr OcrtCIKMlEVEl
MTltSS IHAHCHU.
' racAiEs OUFVCAIE ANAKSO
MOSDOACE WA1[HIU3W Al
4M114
"- FIGURE 6-1
SURFACE WATER
SAMPLE LOCATIONS AND
ANALYTICAL RESULTS SUMMARY
"'''*' F. O'CONNOR SITE
~ AUGUSTA. MAINE
EC JORDAN CQ
-------
ROD DECISION SUMMARY page 11
O'CONNOR CO. SITE
As shown in Figure 7-1, PCBs were detected in the sediment
samples obtained from the upland marsh, both on-site lagoons, and
the lower lagoon drainage area leading into Riggs Brook. PCB
concentrations were highest in the upper lagoon (up to 1,100
ppm), but decreased significantly with increased di-stance from
this lagoon. PCB concentrations were lowest in the drainage area
of the lower lagoon at approximately 4 ppm.
Concentrations of PCBs less than 5 ppm were found in the
sediments within Riggs Brook immediately adjacent to the Site.
The concentrations of PCBs in these sediments diminished rapidly
with increasing distance from the Site to concentrations of less
than 1 ppm.
»
Other contaminants detected in the sediment samples either from
on- or off-site locations included PAHs and lead. However, these
contaminants were determined to be either below typical
background levels or more influenced by the proximity of the Site*
to U.S. Route 17 than by activities related to the Site.
A more complete discussion of the sediment investigations and
results can be found in Chapter 7.0 of the RI report.
F. Biota
An environmental evaluation was performed in and around the Site
during the RI field efforts in order to evaluate whether
conditions at the Site pose environmental risks to terrestrial
and/or aquatic flora and fauna, and to establish baseline wetland
conditions at the Site so that impacts from proposed remedial
actions could be assessed during the Feasibility Study.
In addition to the above-described studies, biota sampling and
analysis was performed both on- and off-site to quantify chemical
concentrations within organisms indigenous to the Site. As shown
on Figure 1-14, the biota sampling stations were located where
site-related contaminants were previously detected in the surface
waters and/or sediments, or in areas where deposition of eroded
sediments was likely to have/had occurred.
The results of the biota analytical evaluation indicated a
significant positive correlation between PCB tissue
concentrations in the biota tested and PCB sediment
concentrations at the locations sampled. For example, PCBs were
detected as high as 161 ppm in tadpoles obtained from the upper
lagoon where the PCB concentration of the sediments was 1,100
ppm. In contrast, the biota and sediment samples from Riggs
Brook contained much lower PCB concentrations equal to or
slightly above background (i.e., 0.18 to 0.74 ppm in fish, and
-------
^^
I'afjtr IIA
«THTU«X»t.lPHTHAl.ATE
jPCacSCHEEM) Ilun"
MOTE:
All O*MCAl PAfUUtC TEBS ..
E5TMA»O VA1UCS BtlOW OUAHflUinM
1*«(S MOT PRCSCNtEO
ND HOT OC ICC ICO OR
Of ItC HO KLOW CHOI
mrrn iK*Ji.iCAfe AHAITSIS
-FIGURE 7-1
SEDIMENT
SAMPLE LOCATIONS AND
ANALYTICAL RESULTS SUMMARY
F. O CONNOR SITE
AUGUSTA, MAINE
EC JORDAN CO
-------
ROD DECISION SUMMARY page 12
O'CONNOR CO. SITE
less than 5 ppm in sediments).
A more complete discussion of the biota studies undertaken at the
Site can be found in the RI report within Chapter 8.0.
-------
ROD DECISION SUMMARY page 13
O'CONNOR CO. SITE
VI. SUMMARY OF SITE RISKS
An Endangerment Assessment (EA) was performed to estimate the
probability and magnitude of potential adverse human health and
environmental effects from exposure to the contaminants
associated with the Site. Twelve (12) contaminants of concern,
as shown in Table 1, were selected for evaluation in the EA.
These contaminants constitute a representative subset of the many
other contaminants that were identified at the Site during the
Remedial Investigation. These 12 contaminants were selected to
represent the potential hazards at the Site based on toxicity,
concentration, frequency of detection, and mobility and
persistence in the environment.
Potential human health effects associated with the contaminants
of concern in soils, sediments, air, biota (fish), and
groundwater were estimated quantitatively through the development
of several hypothetical exposure scenarios. Potential
carcinogenic risks and a measure of the potential noncarcinogenic
adverse health effects were estimated for each of the various
exposure scenarios developed. 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 the Endangerment
Assessment are that the Site is presently enclosed by a six-foot
high chain link fence, that most residents within this primarily
residential neighborhood obtain their drinking water from the
Augusta Water District, and that fishing within Riggs Brook is on
an occasional basis and only smaller fish are likely to be caught
and consumed by people. Tables 2, 3, 4, and 5 present the
assumptions used in the EA to approximate the current and
potential future exposures to the contaminants of concern
identified at the Site.
As summarized in the Chapter 3.0 of the Feasibility Study (FS)
report, seven exposure scenarios were identified in the
quantitative risk evaluation section of the Endangerment
Assessment as posing potential risks to human health or the
environment as follows:
* direct contact with soils by children;
* inhalation of vapors from surface soils;
* ingestion of fish caught in Riggs Brook;
* future direct contact with soils by on-site inhabitants;
* future direct contact with sediments in the lower lagoon
by children;
* future inhalation of vapors by on-site inhabitants; and,
* future ingestion of groundwater from within the bedrock.
-------
Page 13A
TABLE 1
SUMMARY OF POTENTIAL RISKS ASSOCIATED WITH HUMAN EXPOSURE
TO CHEMICALS OF CONCERN FROM THE O'CONNOR SITE*
CDI:RfD Index for
Noncarcinogenic Effects
Lifetine Upper Bound
Excess Cancer Risk
Pathway/Chemical Frequency
Direct Contact vith
. Soils by Children
PCBs 115/186
cPAHs 3/9
Cadmium 14/19
Copper 19/19
Lead 19/19
Nickel 19/19
Zinc 19/19
, TOTAL RISK
Inhalation of Particulates
from Surface Soil
PCBs 115/186
cPAHs 3/9
Cadmium 14/19
Nickel 19/19
Copper 19/19
TOTAL RISK
Inhalation of Vapors
from Surface Soil
PCBs 115/186
cPAHs 3/9
TOTAL RISK
Ingestion of Fish Caught
in Riggs Brook
Average
V
NQb
NQ
3x10"*
6x10"*
3x!0"3
3x10"*
7x10"*
3xlO*3
NQ
NQ
NQ
NQ
7x!0"«
7x10"*
NQ
NQ
NQ
Maximum
NQ
IxlO"2
6xlO"2
4xlO"1
7xlO"4
4x!0"4
SxlO"1
NQ
NQ
NQ
NQ
NQ
NQ
NQ
NQ
NQ
Average
4xlO"8
3x1 O"1
NQ
NQ
NQ
NQ
NQ
7x!0"«
6x!0"»
2xlO^»
3x10**
7x!0"9
NQ
2x10"*
8x10**
2x10"
8x10"*
Haxiaua
.
3xlO"3
2x10"*
NQ
NQ
NQ
NQ
NQ
3xlO*>
t
.NQ
NQ
NQ
NQ
NQ
NQ
NQ
NQ
NQ
PCBs 39/39
Future Contact vith Soili
by Inhabitants On-site
PCBs 115/186
cPAHs* 3/9
Cadmium 14/19
Copper 19/19
Lead 19/19
Nickel 19/19
Zinc 19/19
NQ
NQ
NQ.4
1x10 4
2xlO"4
NQ
NQ
NQ-,
1x10 *
8x1 O"1
IxlO"4
2x10**
IxlO"2
6x10"*
2x10
8x10
6x10"
NQ
NQ
NQ
NQ
4x10
1x10
8x10*
NQ
NQ
NQ
NQ
NQ
TOTAL RISK
IxlO
1x10
1x10
-------
TABLE 1 (Continued)
SUMMARY OF POTENTIAL RISKS ASSOCIATED WITH HUMAN EXPOSURE
TO CHEMICALS OF CONCERN FROM THE O'CONNOR SITE*
Pathway/Chemical Frequency
CDI:RfD Index for
Noncarcipogenic Effects
Average Maximum
Lifetime Upper Bound
Excess Cancer Risk
Average Maximum
Future Contact vitb Sediments
by Children In Lower Lagoon
PCBs 7/7
Copper 2/2
Lead 2/2
Manganese . 2/2
Zinc 2/2
TOTAL RISK
Future Inhalation of Vapors
by Inhabitants On-site
PCBs
cPAHs
TOTAL RISK
115/186
3/9
Future Ingestion of Groundvater
from Bedrock Aquifer
Benzene 2/20
1,4-Dichloro-
benzene 6/20
DEHP 13/20
PCBs 3/20
Chromium 4/10
Manganese 8/10
TOTAL RISK
-«
8x10 *
5x!0"«
3x!0"s
6x!0"6
NQ
NQ
NQ
NQ
NQ
NQ
NQ
0.03
0.1
0.1
NQ
3x10 «
2xlO*2
9xlO*4
2xlO"4
2xlO"2
NQ
NQ
NQ
NQ
NQ
NQ
NQ
0.2
0.8
1.0
4x10"
NQ
NQ
NQ
NQ
4x10*
2x!0"4
4xlO~7
2xlO"4
NQ
5x!0"6
2x!0"7
2x!0"4
NQ
NQ
2xlO~4
5x10
NQ
NQ
NQ
NQ
5x10"
NQ1
NQ
4
NQ
4xlO*6
3xlO*5
IxlO"6
Ixio"2
NQ
NQ
IxlO"2
*The chemicals presented in this table are those that significantly contribute
to the overall carcinogenic and noncarcinogenic risk for a particular path-
way. Except where noted, all pathways are current-use scenarios.
*
bNQ - Not Quantified
cRisks given are those for the wind direction toward the Augusta population
center at 100m from the O'Connor site.
Source: Endangerment Assessment for the O'Connor Site in Augusta. Maine,
(Table 8-1) ICF - Clement. Inc., January 1988.
-------
Page 13B
Table 2
ASSUMPTIONS FOR USE IN THE EXPOSURE
ASSESSMENT FOR DIRECT CONTACT WITH SOIL
BY CHILDREN AT THE F. O'CONNOR SITE
(current-use scenario)
Parameter
Average Exposure
Plausible
Maximum Exposure
Age of Children Exposed
Frequency of Exposure
Duration of exposure
'
Average body weight over
'period of exposure
».
Incidental ingestion of
contaminated soil*
Percent of PCBs and cPAHs
absorbed from ingested soilb
Percent of inorganic chemicals
absorbed from ingested soil
Soil contact rate for use in
dermal absorption estimate
Percent of organic compound
absorbed dermally from skin
Percent of inorganic compound
absorbed dermally from skin
Average lifetime
6-11 years
24 events/yr
5 years
30 Kg
50 mg/visit
15%
100%
0.25 g/visit
1%
negligible
70 years
6-11 years
48 events/yr
5 years
30 Kg
250 mg/visit
45%
100%
3.5 g/visit
3%
negligible
70 years
Lagoy (1987)
kfiased on analogy to tetrachlorodibenzo-p-dioxin: Umbreit et al. (1986),
McConnell et al. (1986), and Poiger and Schlatter (1980).
-------
Page 13C
Table 3
ASSUMPTIONS FOR USE IN THE EXPOSURE ASSESSMENT FOR
INHALATION OF SURFACE SOIL INDICATOR CHEMICALS BY
RESIDENTS LIVING NEAR THE F. O'CONNOR SITE
Years3
Age Exposed
0
3 -
7 -
'': 11 '
19 -
2 3
6 4
10 4
18 7
70 , 52
Ventilation rate**
(m3/day)
1.1
25
29
28
26
Body weightb
(kg)
11.7
15.5
30.7
61-2
70
alnhalation exposure is assumed to occur every day; however, the total
calculated inhahaltion exposure to vapors is reduced by a factor of two to
adjust for the winter six-month period when volatilization is negligible due
to cold air and soil temperatures.
on ventilation rates and body weights for males
-------
Page 13D
Table A
EXPOSURE AND RISK ASSESSMENT FOR CONSUMPTION OF
FRESHWATER FISH FROM RIGGS BROOK
PCB concentrations in edible tissue :
Average cafe: 0.54 mg/Kg (geometric mean)
Plausible Maximum case: 0.74 mg/Kg (highest measured concentration)
Exposure scenario 1: (average case)
Consumption of fish (150 g/serving) from Riggs Brook once a year for 5 years.
»
Exposure scenario 2: (plausible maximum case)
Consumption of fish (150 g/sorving) from Riggs Brook 10 times per year for 10
years.
-------
Page 13E
Table 5
ASSUMPTIONS FOR THE FUTURE USE
EXPOSURE SCENARIO FOR DIRECT SOIL
CONTACT AT THE F. O'CONNOR SITE
Plausible
Parameter Average Exposure Maximum Exposure
A
Area of exposed skin (nr):
1-5 years 0.039 0.151
6-11 0.052 0.230
12-18 0.084 0.370
19-70 0.214 0.449
Soil dermal contact (g/day):
1-5 years 0.20 2.3
6-11 0.25 3.5
12-18 0.42 5.6
19-70 1.07 6.7
Body weight (kg):
1-5 years 15 15
6-11 30 30
12-18 54 54
19-70 65 65
Frequency of exposure: 100 events/year 200 events/year
Incidental ingestion of
contaminated soila:
1-5 years 100 ing/day 500 mg/day
6-11 50 250
12-18 25 100
19-70 25 100
aLagoy 1987
-------
ROD DECZ8ZON SUMMARY page 14
O*CONNOR CO. 8ZTE
Based upon the risk assessment methodology/guidelines contained
in the Superfund Public Health Evaluation Manual (EPA, 1986), the
potential risks for the seven exposure scenarios noted above were
estimated as shown in Table 1. These potential risks were
estimated for the average (defined as exposure to the geometric
mean concentrations of individual contaminants detected at the
Site), and the maximum exposure case (defined as exposure to the
maximum concentration found at the Site for the particular media,
i.e., soil, being assessed). The major conclusions drawn from
the Endangerment Assessment are summarized below:
* direct contact with, ingestion of, or inhalation of vapors
from soils contaminated with PCBs and cPAHs may pose an
incremental increased cancer risk over a lifetime of
exposure. Children potentially playing on the Site
currently, or future residents living on the Site would
be at the greatest risk. Lead in soils may also pose a
risk of adverse, noncarcinogenic health effects
(through direct contact and ingestion) by potential
future residents living at the Site.
* an increased cancer risk over a lifetime of exposure may
also be associated with direct contact and ingestion by
children with the PCB-contaminated sediments in the
lagoons located on the Site.
* ingestion of the contaminated groundwater from the
deep/bedrock system under the Site may pose potential
long-term risks to future inhabitants of the Site.
Contaminants of concern are 1,4-dichlorobenzene,
benzene, and PCBs.
* environmental risks to biota (i.e., fish, wildlife and
plants) exposed to the contaminated soils, sediments,
or surface waters at the Site may potentially exist
from the presence of PCBs, lead, and aluminum.
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangennent to public health, welfare, or, the environment.
A more complete discussion of the methodologies, and potential
human health and environmental risks posed by the Site can b«
found in the Endangerment Assessment report (dated January 1988)
or summarized in Chapter 3.0 of the FS report.
-------
ROD DECISION SUMMARY page 15
O'CONNOR CO. SITE
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA adopted a proposed plan (preferred alternative) for-
remediation of the Site on July 12, 1989. The source control
portion of the preferred alternative essentially included on-site
solvent extraction of those on-site soils and sediments
contaminated with PCBs, cPAHs and lead, on-site or off-site
disposition (landfilling) of those solid residues resulting from
the solvent extraction process that continue to be hazardous
and/or will exceed target cleanup goals, and collection and off-
site treatment of the contaminated surface water found within the
on-site lagoons and upland marsh. The management of migration
portion of the preferred alternative essentially included
collection and on-site treatment of the contaminated groundwater
existing on the Site, and minimal no-action for those localizedt
PCB-ctontaminated sediments found within Riggs Brook.
No significant changes from the proposed plan briefly describe'd
above have been made to the selected remedy as detailed in this
Record of Decision. However, at the time of the issuance of the
proposed plan, EPA had not made a final determination as to
whether solvent extraction treatment residues would be landfilled
on-site or off-site, and specifically requested public comment on
that issue. As discussed in further detail in Sections X, XI,
and XII of this ROD, EPA has since selected the option of off-
site landfilling of those solid residues noted above to satisfy
the statutory preference for treatment, while at the same time
achieving a higher degree of protectiveness. Furthermore, this
decision will be consistent with the overall scope and role of
this response action and will be cost-effective. Additionally,
this final determination addresses both State and community
concerns raised during the public comment period with respect to
the siting of a landfill within the city limits of Augusta,
Maine.
-------
RCD DECISION SUMMARY page 16
O'CONNOR CO. SITE
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 C.F.R.
Part 300 (1988), promulgated in the Federal Register on November
20, 1985. Although EPA proposed revisions on December 21, 1988,
to the NCP to reflect SARA, until those proposed revisions are
finalized, the procedures and standards for responding to
releases of hazardous substances, pollutants and contaminants
shall be in accordance with Section 121 of CERCLA (as amended by
SARA)' and to the maximum extent practicable, the current NO?.
t
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: (1) a requirement that
EPA's remedial action, when complete, comply with applicable or
relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
waiver is invoked-; (2) 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 (3)
a statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous substances over remedies that do not achieve such
results through treatment. Response alternatives were developed
to be consistent with these Congressional mandates.
A number of exposure pathways were quantitatively analyzed for
their potential risk and threats to human health and the
environment in the Endangerment Assessment (which included a
Wetland/Ecological Assessment). Guidelines in the Superfund
Public Health Evaluation Manual (EPA, 1986) regarding development
of risk analyses for remedial alternatives were used to assist
EPA in the development of response actions. As a result of these
assessments, remedial response objectives were developed to
mitigate existing and future threats to human health and the
environment. These response objectives are:
1. Reduce potential present and future public health and
environmental risks from direct contact, ingestion, and/or
dermal absorption with the PCB-, cPAH-, and lead-
contaminated soils and sediments located on- and off-site.
-------
?L -HUtesi
i rnucocwnesPcacoHOMiRMiom^ ^-^
MSURMCf SOLS.
7"~
CONCCNIHAflOMS or I pp«. 5 K>K I
rcaCONCtNTfUnONCONTOUR UC 5«PI-vV»pp- OHCfltAI)i 1
1. Stt IKUOf ' IOH ACIUU D«t« \
FIGURE 4-8
INTERPRETIVE DISTRIBUTION OF
PCBs IN SURFICIAL SOILS
F. O'CONNOR SITE
AUGUSTA, MAINE
_ EC JOPX)ANCQ
Page 7B
-------
fane 7<:
ISOPACH MAP I.LUSTRATMO IMCKNEtS OF SOL
.CONTAMMATEO BY CHtAltM THAN 1 ppmK»S
OCQNNOfl Sill
AUOUSW.M
-------
Page 70
SUBSUVACC P«M CONCCNtdMOHS |p^»
. SURFACE SOL SAIWIE IOCAIWM
(MO SUBSURFACE SAMPI «>
4903-19 ~
ISOPACHCUNCtMfHAIKlHCUNtUtJMStMAWHtOH
- * 1000 M* IOIAI nil, «i iitpiiis iw ». « n til i
FIGURE 4-10
. DISTRIBUTION OF PAHs IN
SURFACE AND SUBSURFACE SOILS
F. O'CONNOR SITE
AUGUSTA, MAINE
L_J
-------
Page
v V-
for-,
J, *
._ o rss
* BsissKcsssBr sszX & 'sr _ sunr*ct
-------
UGENO
MOMTDRMC WEIL UOCATION
S1ATF CURE tOC*tKM
MW IDI* OfMCTItS CPVERnUOCN WtU
ioin BotMorisetOBocn wtn
FIGURE 5-1
MONITORING WELL AND
STAFF GAUGE LOCATIONS
F. O'CONNOR SITE
AUGUSTA, MAINE
EC JORDAN CO
-------
ROD DECISION SUMMARY pag« 17
O'CONNOR CO. SITE
2. Reduce potential present and future public health risks
from the inhalation of PCB vapors from the Site.
3. Reduce potential present and future public health risks
from the ingestion of PCB-contaminated fish from Riggs
Brook.
4. Reduce potential future public health risks from the
ingestion of PCB-, benzene-, and 1,4-dichlorobenzene-
contaminated groundwater found on the Site.
5. Reduce potential present and future environmental risks
to aquatic and terrestrial wildlife from exposures to the
.PCB-, lead-, and aluminum-contaminated on-site surface
water.
»
B. Technology and Alternative Development and Screening,
CERCIA, the NCP, and EPA guidance documents, including the
"Guidance on Feasibility Studies Under CERCLA" dated June 1985,
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), and the Interim Final
"Guidance for Conducting RIs and FSs under CERCLA," OSWER
Directive No. 9355.3-01 (October 1988), set forth the process by
which remedial actions are evaluated and selected. In accordance
with these requirements and guidance documents, a range of
treatment alternatives, a containment option involving little or
no treatment, and a no-action alternative were developed for the
Site.
Section 121(b)(l) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other
statutory directives of Section 121 of CERCLA, the evaluation and
selection process was guided by the EPA document "Additional
Interim Guidance for FY '87 Records of Decision," OSWER Directive
No. 9355.0-21, dated July 24, 1987. This document provides
direction -on the consideration of SARA cleanup standards and sets
forth nine factors that EPA should also 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.
-------
SUMMARY page *
SITE
;-term Effectiveness.
amentability.
lunity Acceptance.
te Acceptance.
;t.
erall Protection of Human Health and the Environment.
: 4.0 of the Feasibility Study identified, assessed and
3d technologies based on effectiveness (i.e., technical
mance) and implementability (i.e., engineering
ility). These technologies were combined into source
)1 (SC) and management of migration (MM) alternatives.
3r 5.0 of the Feasibility Study presented the remedial
natives developed by combining the technologies identified
the previous screening process into the categories required
;WER Directive No. 9355.0-19. An initial screening of these
rnatives was also conducted in Chapter 5.0 of the Feasibility
y J^narrow the number of potential remedial alternatives for
h^pbetailed analysis while preserving a range of options.
i remaining alternative was then evaluated in Chapter 6.0, 7.0
3.0 of the Feasibility Study.
summary, of the 17 source control and management of migration
ledial alternatives initially screened in Chapter 5.0, 14 were
rained for detailed analysis. Table 6 identifies the 14
medial alternatives that were retained through this initial
reening process, as well as those that were eliminated from
irther consideration based upon their effectiveness,
nplementability, and cost.
-------
Page 18.4
TABLE 6
SUMMARY OF REMEDIAL ALTERNATIVES RETAINED FOR DETAILED ANALYSIS
O'CONNOR SITE
AUGUSTA, MAINE
TYPE/RESPONSE CATEGORY
Source Control Alternatives
No Action
Containment
Containment/Disposal
Disposal
Treatment
Treatment
Treatment
Treatment
Treatment
Treatment
Treatment
ALTERNATIVE RETAINfD .ELIMINATED
SC-1:
SC-2:
SC-3:
SC-4:
SC-5:
SC-6:
SC-7:
SC-8:
SC-9:
SC-10:
SC-11A
Minimal No-action
Site Capping
On-site Disposal
facility
Off-site Disposal
at TSCA Landfill
On-»ite Incineration
On-site Solidifi-
cation
On-site Vitrifi-
cation
In-situ Solidifi-
cation
In-situ Vitrifi-
cation
Alkali Metal
Decblorination
: Solvent Extraction
X
X
X
X
X
X
X
X
X
X
X
Treatment
v/On-site Disposal
of Treated Soil
SC-118: Solvent Extraction
v/Off-site Disposal
of Contaminated Lead
Soil
X
Management of Migration Alternatives
No-Action MM-1: Minimal No-action
Treatment MM-2: Groundwater Extraction
and Off-site Treatment
-------
TABLE 6 (Continued)
SUMMARY OF REMEDIAL ALTERNATIVES RETAINED FOR DETAILED ANALYSIS
O'CONNOR SITE
AUGUSTA, MAINE
TYPE/RESPONSE CATEGORY
ALTERNATIVE
RETAINED ELIMINATED
-Treatment
Sediment Alternatives
No-Action
Disposal
MM-3: Groundwater Extrac-
tion and On-site
Treatment with
Activated Carbon
Adsorption/
Injection to
Groundwater
SE-1: Minimal No-action
SE-2: Excavation and Off-
site Disposal of
PCB-contaminated
Sediments from
Riggs Brook
X
X
*The rationale for the elimination of these alternatives is
provided in detail within Chapter 5.0 of the FS.
-------
ROD DECISION SUMMARY page 19
OCONNOR CO. BITE
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each remedial alternative according to the evaluation criteria
described above.
A detailed tabular, comparative assessment of each alternative
can be found in Tablas 7 through 9 of this ROD. As noted in
these tables, information regarding two of the nine criteria
(i.e., State and Community Acceptance) that are required to be
evaluated for each of the remedial alternatives undergoing the
detailed analysis phase are typically only available during the
later stages of the ROD process. These two "modifying11 criteria,
as described in the proposed NCP (1988), are not included in the
discussions below fo:r each alternative, but are presented in
Appendix A (Responsiveness Summary) and discussed in Section X-of
the ROD.
A. Source Control (8C) Alternative* Analysed
The source control alternatives analyzed for the Site include a
minimal no-action alternative (SC-1); capping (SC-2); on-site
disposal facility (SC-3); off-site disposal at TSCA landfill
(SC-4); on-site incineration (SC-5); on-site solidification
(SC-6); on-site vitrification (SC-7); alkali metal dechlorination
(SC-10); on-site solvent extraction and disposal of treated soils
(SC-11A); and on-site solvent extraction and off-site disposal of
lead-contaminated soils (SC-11B). Note that the estimated times
and costs presented below are taken directly from the FS which
appear to be within +50 percent to -30 percent accuracy required
for these FS estimates.
SC-1
Minimal No-Action
This source control alternative would involve no remedial action
on any of .the contaminated soils, sediments, or surface waters
found at the Site. This alternative would, however, entail
maintaining the existing fence and warning signs on the Site;
establishing institutional controls (such as restricting future
land use); conducting public education (awareness) programs;
monitoring soils, sediments and surface waters, and reviewing
Site conditions every five years for as long as hazardous wastes
remain on-site above acceptable levels.
This alternative is included in the Feasibility Study (FS), as
required by CERCLA, to serve as a basis for comparison with the
other source control alternatives being considered. This
alternative would not provide overall protection of human health
-------
TABLE 7
Description/
Approx. Cost
Alternative
SC-1:
Minimal
No-action
No-action
$920.000
SC-2:
Site
Capping
Containaent
$2,000,000
COHI'ANATIVi: ANALYSIS OF SOURCE CONTROL ALTERNATIVES
O'CONNOR SITE
AUGUSTA, MAINE
Reduction of Mobility,
Toxicity. or Volume
Minimal reduction in
toxlcity, Mobility,
and/or volume Cmv)
associated with natural
attenuation.
Does not reduce TMV of
soil and on-site
sediment contaminants
since no treatment
employed to maximum
extent practicable.
Reduces THV of on-site
surface water
contaminants through
off-site treatment.
Overall Protection
of PuMic Health and the ,
Environment (EMectiveness) Implementabi lity
Community and Slate
Acceptance
ARARs
Provides minimal level
ol protection of public
health through usr of
institutional controls.
Does not mitinate on-
KoinK impacts on the
surrnunitinK environment.
Provides protection of
public health through
mitigation of direct
contact and inhalation
hazards.
Provides some protection
of surrounding environ-
ment by reducing off-site
migration of contami-
nants.
Easily implemented.
Requires long-term
enforcement of
institutional controls.
Not a permanent remedy;
therefore, requires
5-year re-evaluation
program.
Relalively easy to
implement, using
convent ional
construction equip-
ment and techniques.
Numerous contractors
are available.
Not a permanent remedy;
therefore, requires
5-year re-evaluation
program.
Does not attain
ARARs
Achieves all
ARARs.
0)
oo
n>
-------
TABLE 7 (Continued)
Description/,
Alternative Appro*. Co«t
SC-J: On-
ite
Disposal
Facility
Containment
$4,400,000
SC-4: Off-
Site Disposal
t TSCA
Landfill
Off-site
Disposal
$15,000,000
COMI'ARATIVF ANALYSIS OF SOURCE CONTROL ALTERNATIVES
O'CONNOR SITE
AUGUSTA, MAINE
Redwet Ion of Hobllity,
Tonicity, or Voli
Does not reduce THV of
oil and on-sit*
sediment contaminant*
sine* no trMtawnt
employed to maxiaua
extent practicable.
Reduces HIV of on-slte
surface water
contaminants through
off-site treatment.
Doe* not reduce WV of
oil and on-slte
sediment contaadnantt
since no treatment
eaploycd to axiaua
extent practicable.
Reduces IftV of on-slte
surface water
contaminants through
off-site treatavnt.
Overall Prelection
of Public Nrallh and the ,
Envlronooit (Effectiveness) l«ylm»fnl«biHty
mlty and State '
Ac ceptanre
ARARs
Provides protect Ion of
public health through
iliKation of dirert
contact and inhalation
hazards.
Provides protection of
Mil-rounding envi ronewnt
by controlling off-site
igration of rontaai-
nants.
Provides protection of
public health and the
surrounding envi roMent
by removing the contami-
nants from the site.
Relat ively easy to
i mpIemcnt, all hough
uses some specialited
construction materials
and techniques.
Sevi-ral contractors
are available.
Not a permanent
remedy; therefore,
requires 5-year
re-evaluation program.
Easy to implement.
Several contractors
are available.
Availability of TSCA
landfill capacity may
be a problem.
Involve* transportation
of wastes over long
distances.
Would he a "clean
closure"; therefore,
the 5-year re-evaluation
program would not be
required.
ARARs would be
met.
ARARs would be
met.
-------
TAB
'Continued)
COMPARATIVE ANALYSIS OF SOURCE CONTROL ALTERNATIVES
O'CONNOR SITE
AUGUSTA, HAIME
Alternative
Description/
Appro*. Cost
Reduction of Mobility,
Toxicity, or Volume
Overall Protection .
of Public Health and the ,
Environment (Effectiveness) Implementability
Comnunity and State '
Acceptance
ARARs
SC-5: On-
site
Incineration
On-fite
Treatment
$19,000,000
SC-6: On-
ite
Solidifi-
cation
On->ite
Treatment
$4,100,000
Reduces toxlcity,
mobility, and volume of
organic contaminant* in
coil and on-site
sediment* through
on-site treatment.
Reduces THV of on-site
surface water
contaminants through
off-site treatment.
Reduces Mobility of (oil
and on-«ite sedinent
contaminants through on-
site treatment.
Voluw will Increase
following treatment of
soils and on-site
sediments:.
Reduces 1WV of on-site
surface water
contaminants through
off-site treatment.
Organic contaminants
are destroyed, ef-
fectively eliminating
their long-term threat
to public health ao'd
the environment.
Provides protection of
local human and en-
vironmental receptors
from inorganics by re-
moving them from the
site.
Hay result in increased
short-term impacts due
to air emissions frost
on-site incinerator.
Hastes are treated,
reducing the threat to
public health and the
environaent.
Requires special
equipment that is
available from
several vendors.
Effectiveness of the
on-site incinerator
must be demonstrated
through test burns.
Relatively complex
operation with
potential for tech-
nical problems during
implementation.
Involves some long-
distance transportation
of wastes. ,
Treated wastes would
remain on-site; there-
fore, 5-year review
is required unless
treated soil is de-
listed.
Relatively easy to
implement.
Several contractors
have solidification
experience; proprietary
chemicals questioned.
Potential for tech-
nical problems to
develop during
implementation due
to the innovative
status of the
technology.
Treated'wastes would
remain on-site; there-
fore, requires 5-year
re-evaluation pro-
gram.
ARARs would be
met.
Achieves all
ARARs.
Would need to
demonstrate that
treated soil and
sediments were
pemaoently
rendered non-
hazardoua.
-------
7 (ContlntMd)
Coni'AUATIVf ANALYSIS OK SltfNirt. rilNTKni. AI.TF.NNATIVF.S
O'CONNOR SITE
AIICUSTA, HAINE
Description/
Alternative
Reduction of Mobility.
To«icily, or Vol
SC-T: On-
site
Vilrifi-
cat ion
On-site
Treatment
$19.800.000
Keducea toxlclty,
. mobility, and volume of
Boil and on-Bit*
sedimentB through
on-Bit* treatment.
ReduccB 1HV of on-Bit*
surface w«t*r
contaminmntB through
off-Bit* treatment.
SC-IO: On-
Bit*
Alkali
Metal
Dechlorin-
ation
On-slte
Treatment
$9,900,000
t**icity and
volw* of KlB in
Boil and on-«ite
Not known to reduce
toiirity, awbility, or
voltM* of FAIlB or
inorganicB in toll.
MeduceB WV or on-Bit*
aurfac* «mt*r
contaMnanta through
off-Bit* treatment.
Overall Protection
of Public Health and the
Environment (Effectiveneii]
are treated and
rendrred nernanently
nnn-hazardouK,
ellrdively eli«inatin|t
the lonR-lem threat to
puhlir health and the
Nay result in increased
short -\rrrn in|lic health
and the environment fro*
PAMs or inorganicB itnlesa
off-site disposal of
soils with these con-
tasilnante is included.
rniability
unity and Slate
Acceptance
The technology has
not yet heen applied
to an actual site
clean-up. Full-scale
equipment is Still
undrr development.
There will lie a
significant potential
for technical
problems during
implementation of an
unriemonst rated
technology.
There are currently
only two vendors of
the process.
Treated wastes would
remain on-site; there-
fore, requires S-year
re-evaluation program.
The technology has
not yet been applied
to an actual site
clean-up. Full-scale
equipment is still
under development.
There will be a
significant potential
for technical
problems during
i«lementation of an
undemonstrated
technology.
There is currently only
one commercial vendor
developing this process.
Treated wastes would
remain on-sile; therefore.
the 5-year re-evaluation
pror.r.im is required.
ARAMs
Achieves all
AKARs.
Vould need to
demonstrate that
treated soil and
sediments were
permanently
rendered non-
hazardous.
Achieves all
AJtARs.
Vould need to
demonstrate
that treated
so«I and
sediments were
permanently
rendered non-
hazardoua.
-------
TABLE 7 (
Description/
Appro*. Cost1
COMPARATIVE ANALYSIS OF SOURCE CONTROL ALTERNATIVES
O'CONNOR SITE
AUGUSTA, MAINE
Reduction of Nobility,
ToMicity, or Volume
Overall Protection
of Public Health and the ,
Environment (Elfectiveness) ImplementahilIty
Coattunity and State '
Acceptance
ARARa
Oo-site
Treatment
SC-11A:
$13,000.000
Selected Remedy;
criteria discussed and
compared to all other
alternatives within
Section X and XI of the
ICO.
Selected Remedy;
criteria discussed and
compared to all other
alternatives within
Section X and XI of the
ROD.
Selected Remedy;
criteria discussed and
compared to all other
alternatives within
Section X and XI of the
ROD.
Selected Remedy;
criteria discussed and
compared to all other
alternatives within
Section X and XI of the
ROD.
Oo-site
Treatment
SC-MB:
$5,900.000
Reduces toxiclty,
obi 1 ity, and voi.une of
organic contaminants in
soil and on-slte
sediments through
on-Bit* treatment.
Reduction in toiicity,
atobility, or volume
of inorganic contami-
nants in soil is aot
demonstrated.
Reduces TMV of on-site
surface water
contaminants through
off-cit* treatment.
Organic contaminants are
removed from the soil and
destroyed off-site; however,
residual organic contaminants
remaining on the site follow-
ing treatment may present
long-term threats to public
health and the environment,
and long-term permanence of
the soil cover is uncertain.
Nay not provide protec-
tion of public health
and the environment from
inorganic contaminants
unless off-site disposal
of lead-contaminated soil
is included.
Full-scale operation of
this technology has
occurred at a Superfund
Site.
There are currently
only two vendors
developing full-scale
treatment units.
Treated wastes would
remain on-site; there-
fore, the S-year re-
evaluation program is
required.
Achieves all
ARARa.
Would need to
demonstrate
that treated
aoil aod
sediments were
permanently
rendered non-
hazardous.
Total Cost (Present Worth)
This category subsumes the three distinct categories of overall
protection of human health and the environment, lono-term
effectiveness Ind permanence, and short-term effectiveness.
Presentations of these two criteria are provided in Appendix A
(Responsiveness Summary) and discussed in S»rMon r nf t*
-------
«UN£ 8
COMPARATIVE ANALYSIS OF MANAGEMENT OF MIGRATION ALTERNATIVES
O'CONNOR SITE
AUGUSTA, MAINE
Reduction of Mobility,
Overall Protection
of Public Health and the ,
MN-3:
GrounoVater
Extraction
with
On-site
Treatment
On-site
Treatment
$680,000
Reduces VIV of
groundwmter
contaminants through
on-ait* treatment.
Doe* not eliminate
potential for degrada-
tion of downgradient
groundwater.
Provides protection of
public health and the
surrounding environment
by capturing contami-
nants in groundwater
before they Migrate
off-site.
The efficiency of the
extraction system for
recovering contaminants
in the groundwater is
difficult to predict.
Not permanent
remedy; therefore,
requires 5-year re-
evaluation program.
Relatively easy to
implement.
Requires long-term
operation, monitor-
ing and maintenance
program.
Community and State '
Alternative
MM-1:
Minimal
No-action
No-action
$670.000
Toxicity. or Volume
Mb reduction in
toxicity, mobility,
and/or volume (mi) of
contaminants.
Environment (Effectiveness)
Relies on institutional
controls to prevent the
future use of potential !
contaminated groundwater
by the public.
Implemenlability Accept anc«
Easily implemented.
Requires ionft-term
enforcement of
institutional
controls.
ARARs
Achieves ARARs
Achieves ARARs
Total Cost (Promt North)
This category subsumes the three distinct categories of overall
protection of human health and the environment, long-term
effectiveness and permanence, and short-term effectiveness.
y
oo
rt>
OS
Preeentatiora of these two criteria are provided In Append
(Responsiveness summary) and discussed in Section X of this'
-------
TRBUE 9
COMPARATIVE ANALYSIS OF HIGfiS BROOK SEDIMENT ALTERNATIVES
Description/
Alternative *H>to*' Co8t>
SC-I:
Hlnlaal
No-art Ion
Mo-art Ion
$223.000
Reduction ol Nobility,
Toxiclty, or Voliaae
HlniMl reduction In
awblllty, toalclty.
and/or voluite aa-
oclated with natural
attenuation.
O'CONNOR SITE
AUGUSTA. MAINE
Overall Protection
of Public Health and the ,
Envl ronwnt
Rrllea on tong-terai
atonltorlng to enaure that
rlika to publlc'hralth
and the envlron*enl do
not Increaae to unac-
ceptable level*.
Long-tena onllorlng
la eaally Iwplearnted.
Not peraia -ent rewdy;
therefore, requlrea
S-year re-evaluation
prograai.
unity and State '
Acceptance
ARARa
Achieve* ARARa.
SE-2:
Eacavatlon
and Off-«lte
Diapoial of
PC8-
contaailnated
Srdlarnta
Off-alt*
Dlapoaal
$291.000
Mo reduction in imr
Ince no treatment !
mvployed.
protection of public
health by reaovlno, the
contaminants froai the
site.
Results in extensive
hort-terB (and
potential long-tena)
damage to the wetland
ecosyateai.
Excavation of
Brook aedlaenta »ay
be difficult due lo
acceaa probleaia.
A dlapoaal alte mat
be Identified that will
accept the aedlawnta.
Would be a "clean
cloaure"; therefore.
the J-year re-
evaluation prograaj
would not be required.
Achlevea all
ARARa.
Total Cost (Present Worth)
This category subsumes the three distinct categories of overall
protection of human health and the environment, long-term
effectiveness and permanence, and short-term effectiveness.
OQ
(D
vD
O
Presentation* of these two criteria are provided in Appendix A
(Responsiveness Summary) and discussed in Section X of this ROD.
-------
ROD DECISION SUMMARY page 20
0*CONNOR CO. SITE
and the environment, and would not comply with ARARs. This
alternative does not use treatment as a principal element, and
consequently, there would be no reduction in the toxicity,
mobility or volume of contaminants on the Site. Additionally,
since no treatment is employed, this alternative would not be a
permanent remedy that would provide long-term effectiveness or
permanence and, therefore, would require five-year reviews as
mandated by statute. Furthermore, the long-term adequacy and
reliability of institutional controls is uncertain. This
alternative would not be effective in the short-term since no
remedial action would be undertaken at the Site, and the existing
impacts to the environment would continue to be of concern.
Finally, the implementability of this alternative would not be
difficult since the technical feasibility and availability of
services required are not specialized.
ESTIMATED TIME FOR CONSTRUCTION: 0.5 to 1 year
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $ 5,000
ESTIMATED O & M (PRESENT WORTH): $ 913,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 918,000
SC-2
Site Capping
This source control alternative would involve draining and
treating (at an off-site facility) the contaminated surface
waters in the lagoons and upland marsh (each considered
wetlands), and consolidation/relocation of contaminated soils,
sediments and debris from remote locations on-site prior to
placement of these materials under an impermeable cap. The
implementation of this alternative would require the creation of
a new surface water drainage system for the upland marsh, and
re-routing surface waters around the area to be capped.
Additionally, the on-site barn would be cleaned to levels based
upon acceptable wipe test procedures and then demolished due to
its deteriorated condition. The demolition material from the
barn would be disposed of appropriately off-site based on the
results of'the wipe tests.
The relocation/consolidation of contaminated materials in remote
areas of the Site would involve the clearing of vegetation and
the placement of erosion control measures (i.e., siltation
fences) prior to any excavation of contaminated materials.
Confirmatory sampling of soils and sediments would also occur in
these areas to ensure that the established target cleanup levels
have been achieved prior to the backfilling of these areas.
Finally, the cap would consist of approximately two feet of clay,
-------
ROD DECISION SUMMARY page 21
O'CONNOR CO. SITE
which would be overlain by a synthetic liner, a 12-inch layer of
sand, filter fabrics, and a two-foot vegetative soil layer. The
cap would extend over an area of approximately one and one-half
acres that would contain the on-site contaminated soils and
sediments. In addition, monitoring of the surface waters and a
review of Site conditions would occur every five years as long as
hazardous wastes remained on the Site above acceptable levels.
The purpose of the cap would be to significantly reduce the
potential for direct contact with the contaminated materials on
the Site, and to prevent the further migration (spread) of these
contaminants by reducing the amount of precipitation that could
filter through and away from the Site. However, since no
treatment of the contaminated materials on the Site (other than
the off-site treatment of surface waters) would be employed under
this alternative, no reduction in the toxicity, mobility or
volume of these soil and sediment contaminants would be achieved.
This alternative would comply with ARARs through implementation
of the appropriate closure and post-closure requirements of RCRA
Subpart G, 40 CFR 264 and by ensuring that any wetlands and/or
floodplain damages which are unavoidable would be mitigated and
compensated for through the establishment of new, compensatory
wetlands and minimization of floodplain storage capacity loss.
Furthermore, although this alternative involves limited
excavation and placement of hazardous substances, the existing
information suggests that the substances addressed by this
alternative are not RCRA-regulated waste; therefore, the RCRA
Land Disposal Restrictions (LDR) are not applicable requirements.
Until EPA completes the LDR rulemaking for soil and debris, the
CERCLA program will not consider LDRs to be relevant and
appropriate to soil and debris that do not contain RCRA-regulated
wastes. This alternative uses readily available technologies and
services and, therefore, is easily implemented. However, the
permanence of capping is uncertain (in fact, capping is not
considered a permanent remedy) since the cap would only contain
and not treat the contamination. This degree of uncertainty
would require long-term monitoring and maintenance (which would
include five-year re-evaluations of the Site), the potential for
additional replacement costs should the cap leak or fail, a
restriction on the future use of the land through appropriate
institutional controls, and the establishment of compensatory
wetlands on-site. Finally, the short-term effectiveness of this
alternative would involve some potential impacts to the
surrounding area through increased truck traffic and potential
dust generation, but would involve significant detrimental
impacts to the environment through draining and capping of the
on-site wetlands.
ESTIMATED TIME FOR CONSTRUCTION: 1 to 2 years
ESTIMATED TIME FOR OPERATION: 30 years
-------
ROD DECISION SUMMARY page 22
O'CONNOR CO. SITE
ESTIMATED CAPITAL COST: $ 1,449,000
ESTIMATED O & M (PRESENT WORTH): $ 571,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 2,020,000
SC-3
On-Site Disposal Facility
The initial steps of this source control alternative would
involve draining the surface waters in the lagoons and upland
marsh (each considered wetlands) and treating the contaminated
water off-site, re-routing drainage patterns around contaminated
areas of the Site, and decontamination and demolition of the
barn, as described in SC-2 above.
i
Excavation of all contaminated on-site soils and sediments which
exceed the site-specific cleanup goals would also be performed '
under this alternative. An approximately two-acre RCRA/TSCA
landfill would then be constructed on the Site to dispose of
these contaminated soils and sediments. The excavated areas
would then be filled with clean soil, regraded, and revegetated
in order to return these areas to their original condition. A
leachate collection system and leak detection system installed
with the landfill would be monitored periodically, and leachate
generated from the landfill would eventually be transported to an
off-site treatment facility. Additionally, the surface waters on
the Site would be monitored, and a review of the Site conditions
would occur every five years for as long as hazardous wastes
remain on the Site.
Overall, since this alternative involves the excavation and
placement of hazardous substances and a portion of these
substances may be RCRA-regulated waste, the RCRA land disposal
restrictions may be applicable requirements. Therefore, in order
for this alternative to comply with ARARs, the appropriate RCRA
treatment variances (if required) under LDR and/or the TSCA
chemical waste landfill waivers must be obtained, along with the
compensatory wetlands/floodplain issues being adequately
addressed. Treatment of the on-site surface waters will result in
a significant reduction in the toxicity, mobility and volume
(TMV) of this contaminated media; whereas, no reduction in the
TMV would be gained through simply disposing of the contaminated
soils and sediments in the landfill. Furthermore, disposal
without the prior use of permanent and/or alternative treatment
technologies to the maximum extent practicable does not satisfy
the preference stated in CERCLA. This is especially significant
in comparison to many of the other source control alternatives
which employ various treatment schemes. The long-term
effectiveness and permanence of this alternative is uncertain
especially if the landfill were to leak or fail in some way, or
-------
ROD DECISION SUMMARY page 23
O'CONNOR CO. SITE
if the leachate collection system were to be impaired. The
effectiveness of this alternative over the short-term would
involve some impacts to the surrounding area during all facets of
the excavation activities involved, including dust generation and
increased truck traffic, but which are comparable with all other
alternatives that involve extensive excavation. Finally,
although some specialized services would be required to implement
this alternative (especially construction of the landfill), the
overall implementability of this alternative is not of concern.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 30 YEARS
ESTIMATED CAPITAL COST: $ 3,930,000
ESTIMATED O & M (PRESENT WORTH): $ 442,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 4,372,000
SC4
Off-Site Disposal at a TSCA Landfill
This SC remedial alternative involves draining the surface water
in the lagoons and upland marsh (each considered wetlands) and
treating the water off-site, rerouting drainage patterns around
contaminated areas of the Site, and decontamination and
demolition of the barn, as described under SC-2. Thereafter,
those contaminated soils and sediments exceeding the site-
specific target cleanup levels would be excavated and disposed of
at TSCA-approved, off-site chemical waste landfill. The
excavated areas would then be filled with clean soil, regraded,
and revegetated.
This alternative provides for overall protection of human health
and the environment at the Site, while also providing a
significant reduction in the toxicity, mobility and volume of the
surface water contaminants found on the Site through treatment.
However, no reduction in the TMV of the contaminated soils or
sediments would be realized since treatment is not employed to
the maximum extent practicable prior to disposal. The long-term
benefits of this alternative are greater than the on-site
disposal option since all contaminated materials are removed from
the Site; however, the long-term uncertainties of landfilling
(even at an off-site facility) significantly limit these
benefits. Furthermore, landfilling is not considered a permanent
remedy. The overall implementability of this alternative is
comparable to all other alternatives evaluated in detail which
involve excavation and/or off-site transport of contaminants;
however, the availability of TSCA landfill capacity may be a
problem. The effectiveness of this alternative over the short-
term is similar to all alternatives which involve excavation and
truck traffic activities. Finally, while this alternative
-------
ROD DECISION SUMMARY page 24
O'CONNOR CO. SITE
provides overall protectiveness to human health and the
environment, this alternative will comply with ARARs through; (a)
disposal at a TSCA-permitted facility, (b) obtaining a RCRA
treatment variance (if necessary) since the excavation and
placement of hazardous substances from the Site may be RCRA-
regulated under the applicable Land Disposal Restriction (LDR)
ruleraaking, and (c) providing for compensatory wetlands and
minimal floodplain impacts.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1 YEAR
ESTIMATED CAPITAL COST: $ 14,739,000
ESTIMATED O & M (PRESENT WORTH): $ 43,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 14,782,000
SC-5
On-Site Incineration
Under this source control alternative, as in SC-2 through SC-4,
the initial steps involve draining the contaminated surface
waters from the lagoons and upland marsh (each considered a
wetland) and treating the water off-site, rerouting drainage
patterns around contaminated areas of the Site, and
decontamination and demolition of the barn. Subsequently, the
soil and sediment.contamination on the Site would be addressed by
excavating those contaminated materials above the established
target cleanup levels, and then burning these materials in a
mobile, thermal destruction unit that would be set up on the
Site. Additionally, off-site disposal of the lead-contaminated
soils with or without prior treatment would be included in this
alternative.
Prior to implementation of a full-scale thermal destruction unit
on-site, a test burn and/or pilot test will be conducted at the
Site to demonstrate the effectiveness of the unit in providing
for the 99.9999 % destruction and removal efficiency required
under TSCA, 40 CFR Part 761.70(b), and to determine whether the
residues from the destruction process are nonhazardous or remain
hazardous. These tests would also focus on ensuring that ambient
air quality standards are not being exceeded through the use of
appropriate air pollution control devices; particularly for lead.
Following the above-mentioned tests, full-scale thermal treatment
of the excavated materials would proceed on the Site. Solid
residues resulting from the thermal treatment unit would be
analyzed to verify attainment of all target cleanup goals for the
Site and the EP toxicity or TCLP characteristics of this
material. Treatment residues which meet all cleanup goals and
pass the characteristics tests would be redeposited back into the
-------
ROD DECISION SUMMARY page 25
O'CONNOR CO. SITE
excavated areas; whereas, soils/sediments which do not achieve
the site-specific cleanup goals would be disposed of at-an
approved, off-site facility with or without prior .treatment for
the lead-characteristic hazardous waste.
Overall, this SC alternative uses various treatment technologies
to permanently reduce the toxicity, mobility and volume of the
principal threats to the contaminated surface waters, soils and
sediments on the Site (as preferred by CERCLA), while also
providing overall protection of the human health and the
environment. In addition, the demonstrated use of thermal
destruction in treating PCB-contaminated (organic) materials
provides a greater degree of long-term effectiveness and
permanence in comparison to several of the other treatment
alternatives evaluated. However, the limited availability of
mobile thermal destruction units raises concerns about the
implementability of this alternative. More importantly, the
potential short-term impacts due to the difficulty in controlling
air emissions associated with incineration (which could
potentially contain lead) are major drawbacks of this
alternative. Finally, since this alternative involves the
excavation and placement of hazardous substances, a portion of
these substances and/or treatment residuals may be RCRA-regulated
waste; therefore, the RCRA land disposal restrictions may be
applicable requirements. Hence, in order for this alternative to
comply with ARARs (in addition to TSCA), the appropriate RCRA
treatment variances under LDR for a portion of the potentially
RCRA-characteristic treatment residues must be obtained, if
necessary, and the compensatory wetlands/floodplain impacts roust
be addressed.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1-2 YEARS
ESTIMATED CAPITAL COST: $ 19,509,000
ESTIMATED 0 & M (PRESENT WORTH): $ 203,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 19,712,000
SC-6
On-Site Solidification
As described in the previous SC alternatives, the first step in
this alternative includes draining the on-site surface waters in
the lagoons and upland marsh (each considered a wetland) and
treating the contaminated water off-site, rerouting drainage
patterns around contaminated areas, and decontamination and
demolition of the on-site barn. Thereafter, approximately 23,500
cubic yards of contaminated soils and sediments above EPA's
target cleanup goals for the Site would be excavated and treated
on-site using a technology which involves
-------
ROD DECISION SUMMARY page 26
O'CONNOR CO. SITE
solidification/stabilization.
The solidification/stabilization technology would essentially
involve batch-mixing the excavated PCB-, cPAH-, and lead-
contaminated materials on the surface of the Site with the
required solidifying/stabilizing additives (such as cement or
lime) in order to bind the contaminants within a solid mass or
block. .These blocks of treated materials would then be
redeposited into the previously excavated areas on the Site, and
then covered with a one-half to one foot layer of sand and one-
foot of topsoil for seeding to establish a vegetative cover.
This alternative would require that laboratory/pilot-scale
treatability studies be conducted both on- and off-site to
further demonstrate the potential applicability of this
innovative technology to conditions at the Site. In addition,
this alternative would require, at a minimum, the continued
upkeep of the existing fences and warning signs, and more likely
the establishment of institutional controls (deed restrictions)
on the Site-property over the long-term. Additionally, since
hazardous substances will remain at the Site under this
alternative, a review of Site conditions every five years would
occur, as required by CERCLA.
In summary, this alternative eliminates the potential human
health and environmental risks associated with exposures to the
contaminated on-site surface waters through treatment, and would
effectively prevent both human health and environmental exposures
via direct contact, ingestion and/or inhalation of vapors from
the contaminated on-site soils and sediments through treatment
and isolation. However, the solidification component of this SC
alternative would require a determination by EPA that this
alternative method provides a level of performance equivalent to
incineration or is consistent with a chemical waste landfill
under the TSCA applicable requirements at 40 CFR part 761.60.
Additionally, since this alternative involves the excavation and
placement of hazardous substances and a portion of these
hazardous substances are RCRA-regulated, characteristic wastes,
the RCRA Land Disposal Restrictions (LDR) may also be applicable
requirements; therefore, the approval of a RCRA treatability
variance will be required in the event that any solidified
material continues to exhibit RCRA characteristics. The short-
term impacts associated with this alternative are similar (but
controllable) to those involved with all other alternatives which
require significant excavation activities. There are, however,
differences between this SC alternative and all other SC
alternatives evaluated relative to the long-term effectiveness
and permanence, and the reduction in the toxicity, mobility and
volume criteria considered. More specifically, the uncertainty
associated with the long-term effectiveness and permanence of
-------
ROD DECISION SUMMARY page 27
O'CONNOR CO. SITE
this alternative is unclear based upon the treatability test
results obtained for this Site. These test results indicated
that PCBs may not have been successfully stabilized and that only
a 50% to 75% reduction in the leachability of PCBs was achieved.
In addition, the reduction in the mobility and volume of
contaminants (especially, the PCBs and cPAHs) may not be as
significant as several other SC alternatives considered. For
example, volume increases of from 5% (based on the site-specific
tests) to 100% (based on the SITE programs demonstration data-see
Administrative Record) have been reported using this technology.
Finally, this alternative uses treatment technologies to the
maximum extent practicable (as preferred by CERCLA) and would be
relatively easy to implement, but the availability of the
appropriate solidifying/stabilizing agents for the Site may be
limited, as well as being proprietary.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1 YEAR
ESTIMATED CAPITAL COST: . $ 4,058,000
ESTIMATED O & M (PRESENT WORTH): $ 193,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 4,251,000
SC-7
On-Site Vitrification
This alternative includes the excavation and on-site
vitrification of all contaminated on-site soils and sediments
exceeding the target cleanup goals for the Site, the draining and
treating (off-site) of contaminated surface waters on the Site,
the rerouting of existing drainage patterns around the
contaminated portions of the Site, and the decontamination and
demolition of the barn.
The vitrification process would involve raising the temperature
of the excavated materials to roughly 3,000 degrees Fahrenheit,
and then cooling this material until it forms a solid, inert,
glass-like mass. The process would involve several mobile,
batch-type units into which the excavated materials would be fed,
heated, and then cooled. The process destroys and/or volatilizes
the organic contaminants in the material processed, and binds or
fuses the inorganics within the glass-like mass. The treated
mass would ultimately be broken into smaller pieces, placed into
the previously excavated areas, and then covered with
approximately 6-inches to one-foot of sand and one-foot of
topsoil to establish a newly seeded, vegetative cover.
This alternative would also require that laboratory/pilot-scale
treatability studies be conducted to demonstrate the potential
applicability of this technology to the conditions found at the
-------
ROD DECISION SUMMARY pag« 28
O'CONNOR CO. SITE
Site. In addition, this alternative would require, at a minimum,
the continued upkeep of the existing fences and warning-signs,
and more likely the establishment of institutional controls (deed
restrictions) on the Site-property. Additionally, since
hazardous substances will remain at the Site under this
alternative, a review of Site conditions every five years would
occur, as required by CERCLA.
This alternative would be protective of the human health and tho
environment (with the appropriate management controls in-place).
This alternative would also meet ARARs when; (1) a determination
by EPA is made that this alternative method of treatment provides
an equivalent level of performance to incineration or is
consistent with a chemical waste landfill under TSCA, (2) since
the excavation and placement of hazardous substances may involve
RCRA-regulated, characteristic wastes, a RCRA treatability
variance may be required in the event that the treated material
continues to exhibit RCRA characteristics, and (3) the
compensatory wetlands and potential floodplain impacts are
adequately addressed. This alternative would result in a
significant reduction in the toxicity, mobility and, especially,
volume of organic contaminants in the contaminated media at the
Site. However, this treatment technology (as preferred by
CERCLA), has only been demonstrated in the treatment of PCB-
contaminated materials on limited occasions and only during
small-scale laboratory tests. Therefore, the long-term
effectiveness and permanence uncertainties would require further
study and, at a minimum, a five-year review of Site conditions
into the future. Additionally, the potential short-term impacts
that could result from the volatilization of the contaminated
materials during implementation of this technology at the Site
are unknown. Finally, the implementability of this alternative
is apparently limited due to the fact that full-scale,
commercially available units are still under development, and may
not be immediately accessible.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1-2 YEARS
ESTIMATED'CAPITAL COST: $19,609,000
ESTIMATED 0 & M (PRESENT WORTH): $ 203,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 19,812,000
SC-10
On-Site Alfcali Metal Deehlorination
This SC alternative is very similar to SC-7, except that the
excavated soils and sediments exceeding the site-specific target
cleanup goals would be mixed with a combination of chemicals
forming a reagent, called APEG, that is capable of detoxifying
-------
ROD DECISION SUMMARY page 29
O'CONNOR CO. SITE
PCBs through the removal of chlorine atoms from the PCB molecule
structure. The mixture is allowed to react in a batch-type,
steam-jacketed vessel which provides heat to enhance the
reaction. Water and organic vapors generated from the reaction
are captured and treated. The resulting solid residues from the
vessel are then separated from the reagent through a series of
washings. The washed, dechlorinated solid residues would then be
placed back on the Site (assuming the target cleanup goals are
achieved), and the contaminated reagent would be disposed of at
an off-site treatment facility.
Prior to full-scale implementation of the dechlorination process,
laboratory and pilot-scale treatability studies would be
performed to evaluate the effectiveness of the process on the
contaminated materials specific to the Site. This testing would
be conducted to adjust the conditions necessary for the treatment
process to achieve the required cleanup levels for the Site, and
to determine whether the treatment residues would require
additional treatment (especially, for the cPAHs and lead). A
five-year review of the Site conditions would also likely be
implemented as a part of this alternative to evaluate the
continuing performance of this technology.
This alternative would be protective and also meet ARARs once the
three (3) conditions as stated in SC-7 are satisfied. The
dechlorination component of this SC alternative would
significantly reduce the toxicity, mobility and volume of the PCB
contamination in the soils and sediments undergoing treatment.
Additionally, this alternative incorporates permanent and
alternative treatment technologies into the remedial action
process, as preferred by CERCLA. However, other than during
small-scale laboratory and pilot-scale tests, the degree of
certainty attained by the dechlorination technology over the
long-term is unclear at present (especially regarding the
treatment potential of the cPAHs and lead on the Site). This
technology has also shown significant variability in achieving
low PCB target cleanup levels through these tests, and could
potentially leave minor amounts of APEG and/or biphenyl residuals
in the treated soils. Finally, the limited availability of full-
scale treatment units is also a concern that needs to be
considered.
ESTIMATED TIME FOR CONSTRUCTION: ' 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1-2 YEARS
ESTIMATED CAPITAL COST: $ 9,694,000
ESTIMATED 0 & M (PRESENT WORTH): $ 203,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 9,897,000
-------
ROD DECISION SUMMARY page 30
O'CONNOR CO. SITE
SC-11A
On-Site Solvent Extraction and Disposal of Treated Soils
This SC alternative has b
-------
ROD DECISION SUMMARY page 31
O'CONNOR CO. SITE
The capacity of this source control alternative to satisfy the
requirement of overall protection of human health and the
environment would depend upon the effective, long-term -
maintenance of the 10-inch clean soil fill which would cover
those contaminated materials that still exceed the 1 ppm PCBs
and/or cPAHs site-specific cleanup goals. This would, at a
minimum, require the establishment of institutional controls for
restricting future use of the Site, and the continued maintenance
of the existing nine-acre fence and appropriate warning signs in
perpetuity. The reliability of such institutional controls is
questionable at best. This alternative would comply with ARARs
once the three (3) conditions stated above under alternative SC-7
are satisfied. Some reduction in the toxicity, mobility and
volume of the contaminants on the Site would occur. However, the
magnitude of these reductions would not be significant.
Additionally, as noted in connection with the protectiveness
criterion above, due to the need for a 10-inch soil cover as a ,
major component of this alternative, the long-term permanence of
this alternative is uncertain because of potential disturbances
(including burrowing animals) of this soil layer. Finally, this
alternative is easily implementable, and employs treatment but
not to the same extent as provided by the selected remedy.
ESTIMATED TIME FOR CONSTRUCTION: 1-2 YEARS
ESTIMATED TIME FOR OPERATION: 1-2 YEARS
ESTIMATED CAPITAL COST: $ 5,679,000
ESTIMATED 0 & M (PRESENT WORTH): $ 203,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 5,882,000
-------
ROD DECISION SUMMARY page 32
O'CONNOR CO. SITE
B. Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
O'Connor Co. Site, contaminants have migrated from the
contaminated soils/sediments on the Site into the groundwater
beneath the Site and into sediments within Riggs Brook located
off-site. The management of migration alternatives evaluated for
the Site to address the contaminated groundwater included a
minimal no-action with monitoring alternative (MM-1), and an
extraction and treatment alternative (MM-3). The management of
migration alternatives evaluated in detail to address the
sediment contamination within Riggs Brook included a minimal no-
action with monitoring alternative (SE-1), and an excavation and
disposal alternative (SE-2). Each of these alternatives are
described in detail below.
1. Croundvater
MM-1
Minimal No Action vith Monitoring Alternative
This alternative includes the establishment of educational
programs within the community to inform the public of the
progress and results from sampling of the on-site groundwater.
Additionally, institutional controls to limit the future use of
the contaminated groundwater would be established in the form of
deed restrictions. Furthermore, since groundwater contaminants
exceeding health-based levels and ARARs remain on the Site under
this alternative, the statutory requirements for five year
reviews of the Site would occur.
This alternative would be protective of human health and the
environment upon establishment of the institutional controls for
restricting the use of the groundwater over the long-term.
However, since the contaminated groundwater exceeds both the
federal MCLs and state MEGs (both considered ARARs for this
Site), this alternative would not be in compliance. The long-
term effectiveness of institutional controls are also a major
concern under this alternative. No reduction in the toxicity,
mobility or volume of the contaminants in the groundwater would
be achieved by this alternative since no treatment is employed.
Finally, no implementability problems or short-term impacts would
be associated with this alternative since very limited action
would occur at the Site.
ESTIMATED TIME FOR CONSTRUCTION: 0 years
ESTIMATED TIME FOR OPERATION: 30 years
-------
ROD DECISION SUMMARY page 33
O'CONNOR CO. SITE
ESTIMATED CAPITAL COST: None
ESTIMATED O & M (PRESENT WORTH): $ 674,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 674,000
MM-3
Groundvater Extraction and On-Site Treatment
This MM alternative has been selected as the remedial alternative
component of the overall selected remedy for addressing the
groundwater contamination at the Site. This MM alternative is
described in considerable detail within Section X, The Selected
Remedy, of this ROD.
,2. Riggs Brook Sediment
SE-1
Minimal No-Action
This SE alternative has been selected as the remedial alternative
component of the overall selected remedy for addressing the
sediment contamination within Riggs Brook. This SE alternative
is described in considerable detail within Section X, The
Selected Remedy, of this ROD.
SE-2
Excavation and Off-Site Disposal of Contaminated Sediments
This alternative would include the removal of an estimated 900
cubic yards of PCB-contaminated sediments which exceed the 1 ppm
target cleanup level established for sediments within Riggs
Brook. This volume of sediments is primarily located within the
400 feet of brook from Route 17 to the point where no detectable
levels of PCBs were found during the RI, and within the full
width of approximately 60 feet of the affected stream channel.
Excavation activities would be attempted during ideal conditions,
if possible, when stream flow is minimal. However, in order to
establish a firm base for the excavation equipment, the brook may
be diverted away from the contaminated areas to allow easier
access to the sediments. Once the excavation activities have
been completed and verified through sampling, the PCB-
contaminated sediments (currently containing no greater than 5
ppm) would be disposed of in a solid waste landfill, if
acceptable. Finally, the brook and associated wetlands which
were destroyed during the excavation activities would be
restored. This would be conducted in close coordination with
federal and state agencies who are responsible for these natural
-------
ROD DECISION SUMMARY page 34
O'CONNOR CO. SITE
resource areas.
This alternative would be protective of human health and the
environment and would comply with ARARS. However, the existing
levels of PCB-contamination within Riggs Brook do not represent a
risk to humans which is outside the 10-4 to 10-7 risk range or
that exceeds the FDA action limit of 2 ppm for the protection of
human health, and the PCS levels within the environment (biota)
is very close to the levels found in background samples. The
long-term effectiveness and permanence of this alternative could
produce irreversible damages to this ecosystem. Additionally, no
reduction in the toxicity, mobility or volume of the contaminants
would be gained by this alternative since no treatment is
employed. Furthermore, the short-term effects and difficulties
in implementing this type of excavation alternative are major
obstacles that would have to be addressed.
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 1 year
ESTIMATED CAPITAL COST: $ 291,000
ESTIMATED 0 & M (PRESENT WORTH): $ 291,000
ESTIMATED TOTAL COST (PRESENT WORTH): $ 291,000
-------
ROD DECISION SUMMARY page 35
O'CONNOR CO. SITE
X. THE SELECTED REMEDY
The selected remedial action for the O'Connor Co. site ("the
Site") is a comprehensive, multi-component approach for. overall
remediation of the soil, sediment, surface water, and groundwater
contamination at the Site. This comprehensive approach is
described in detail below together with the rationale used for
the selection of this remedial action.
A. Description of the Selected Remedy
1^ Remedial Action Obi actives/Cleanup Goals
The selected remedy was developed ro provide overall protection
of human health and the environment. This remedy was also
developed to satisfy the remedial action objectives established
for the Site, as discussed in Section VIII above, and to comply
with' all requirements of CERCLA that were identified for the
Site, as discussed in detail in Section XI. The selected remedy,
as described herein, will be used to guide the design and to
measure the success of the remedy.
a. Soil
In the Endangerment Assessment (EA), the exposures from the
contaminated on-site soils which were evaluated and determined to
be of primary concern for the protection of human health were
those which involved children potentially trespassing onto the
Site under current conditions, and future inhabitants living on-
site. Additionally, exposures from the contaminated on-site
soils were also evaluated and determined to be a primary concern
for the protection of the environment, particularly migratory
birds whose diets are comprised of soil-dwelling organisms or
consumers of soil-dwelling organisms obtained from the Site.
Based upon these site-specific findings, the soil cleanup goals
of 1 ppm PCBs, 1 ppm cPAHs and 248 ppm lead were established in
order to provide overall protection of human health and the
environment.
In developing these soil target cleanup goals, EPA initially
evaluated.the information provided in the site-specific
endangerment assessment, and current Federal statutes,
regulations, criteria, directives, advisories, guidances and
policies. The results of this preliminary formulation of
remediation goals for the protection of human health indicated,
that for a cumulative, lifetime (70-year) excess cancer risk of 1
X 10-5 (one in one hundred-thousand) according to the reasonable
maximum exposure scenario for the Site of potential future,
residential-use, that the corresponding cleanup level should be
-------
ROD DECISION SUMMARY page 36
O'CONNOR CO. SITE
approximately 3-4 ppm PCBs, and 1 ppm cPAIis (see Appendix B-lf of
the Feasibility Study). Furthermore, the target cleanup level
for lead-contaminated soils, based upon protection of human
health from future-use exposures such that no appreciable risk of
significant adverse health effects over a lifetime of exposure
exists, resulted in a cleanup level of 246 ppm.
EPA then evaluated these preliminary soil target cleanup levels
in relation to the remedial response objectives which addressed
reducing the potential environmental risks associated with
exposures to the contaminated soils. Based upon the results of
the Wetlands/Ecological Assessment that was performed as part of
the Endangerment Assessment for the Site, the existing
concentrations of PCB-contaroinated soils on the Site were found
to potentially pose a significant hazard to soil-dwelling and
burrowing animals, to migratory birds and other terrestrial
wildlife, and to aquatic wildlife. This baseline information, -
together with a detailed evaluation by the U.S. Fish & Wildlife.
Service (F&WS) of the available literature: on the effect levels
to wildlife from PCBs in soils, determined that reproductive
effects and, in some cases, mortality occurs from exposures to
PCBs in the range of 0.1-10 ppm. Consequently, upon further
consultation from the F&WS, a soil target cleanup level of 1 ppm
PCBs was selected for the Site for the protection of the
environment. Several letters, and a memorandum, prepared by the
F&WS which discuss the effect levels to wildlife from PCBs in
support of the 1 ppm soil target cleanup level are attached as
Appendix B to this ROD.
Additionally, based upon a separate assessment of the human
health risks posed by the Site as performed by State of Maine's
Department of Human Services-DHS, the PCB soil target cleanup
level for the protection of human health was determined to be no
greater than 1 ppm anywhere on the Site, variations in the
reasonable worst-case exposure assumptions used by the DHS, in
comparison to EPA's quantitative risk assessment, were the
underlying reasons for the differences in the PCB soil cleanup
level for the protection of human health. The State of Maine's
position and technical basis for their PCB soil target cleanup
level is set forth in a letter (with attachment) as provided in
Appendix C of this ROD. Therefore, the State of Maine requested
that a more stringent target cleanup level for PCBs of 1 ppm be
established for this Site to be protective of human health. The
State of Maine noted that this soil cleanup level was also
consistent with the F&WS target cleanup level for the protection
of terrestrial wildlife, and would satisfy existing State of
Maine policy and gain the State's acceptance on the selected
remedy. The cPAH and lead cleanup goals of 1 ppm and 248 ppm,
respectively were determined by the DHS to be acceptable for the
protection of human health.
-------
ROD DECISION SUMMARY page 37
O'CONNOR CO. SITE
Finally, because the source of the current and future human
health risks estimated from the inhalation of PCS vapors from the
Site were the contaminated surface soils themselves, the
objective of reducing the risks associated with these vapors is
addressed by the 1 ppm target cleanup goal for PCBs found
anywhere on the Site.
b. Ground Water
The response objective established for the contaminated on-site
groundwater was based upon the potential future consumption of
the water for drinking water purposes. Despite the limited
potential for off-site migration of the contaminated groundwater
and use of the groundwater for drinking water purposes, the
potential for future human health risks was considered together
with' the State's classification of the groundwater as being
suitable for drinking water purposes and the current exceedance.
of the groundwater above Federal and/or state drinking water
standards.
EPA, in turn, set groundwater target cleanup goals for the Site
based on the Federally established "maximum contaminant levels"
(MCLs) and the State of Maine's "maximum exposure guidelines"
(MEGs) which were determined to be ARARs for the Site. The
contaminants of concern for the on-site groundwater and their
respective cleanup goals are: PCBs (0.5 ppb);
1,4-dichlorobenzene (27 ppb); and benzene (5 ppb).
c. Surface Water
Based upon the assessment, as provided in the EA, of the
potential risks from exposures to wildlife with the contaminated
surface waters on the Site, a remedial action objective was
established to reduce these potential environmental risks. (Note
that no significant risk to human health was identified in the EA
from direct exposures to, excluding ingestion of, these surface
waters).
Target cleanup goals were, therefore developed for the PCB-,
lead-, and aluminum-contaminated surface waters within the upland
marsh, and upper and lower lagoons. These goals were established
to be consistent with EPA's Ambient Water Quality Criteria
(AWQC), to the maximum extent possible, as to be considered
criteria for this Site. These target cleanup goals are: PCBs
(0.065 ppb); lead (1.94 ppb); and aluminum (87 ppb).
In the case of PCBs, the AWQC of 0.014 ppb (as a 24-hour average)
is not analytically achievable, while available data indicates
that acute toxic effects to freshwater aquatic life will more
likely occur at concentrations above 2 ppb based on a 24-hour
-------
ROD DECISION SUMMARY page 38
O'CONNOR CO. SITE
average. Furthermore, in considering human health impacts from
these contaminated surface waters, the AWQC for protection of
hume.n health through ingestion of contaminated water and aquatic
organisms is 0.079 ppb at an incremental increase of cancer risk
over a lifetime of exposure of 1 X 10-6 (1 in 1,000,000).
Therefore, the PCB target cleanup goal for surface waters at the
Site was based on the lowest, existing detection limit
technically achievable by current laboratory analytical equipment
and techniques. This target cleanup goal of 0.065 ppb PCBs is
considered protective of human health and the environment.
Achievement of the above described target cleanup goals will be
further ensured through the off-site treatment of all
contaminated .surface waters located within the upper and lower
lagoons, and the upland marsh.
t
d. Sediments
In establishing the reasonable maximum exposure scenario for
future direct contact with the contaminated sediments located on
the Site, the EA considered the risks associated with children'
who would play in these areas without any restrictions on access
(i.e., future , residential-use exposures). Additionally, the
U'.S. F&WS performed an evaluation of the environmental risks
posed by these same PCB-contaminated sediments (see Appendix B of
this ROD). The assumptions used to quantify the potential human
health and environmental risks associated with exposures from
these PCB-contaminated sediments were generally similar to those
described previously in a. above. Therefore, the target cleanup
levels established for the protection of human health and the
environment were the same as those established for the on-site
soils, i.e., 1 ppm PCBs, 1 ppm cPAHs and 248 ppm lead.
The contaminated sediments located within Riggs Brook (maximum
concentration of PCBs, the key contaminant of concern, was 5 ppm)
were separately evaluated to address the remedial objectives of
reducing potential present and future environmental risks to
aquatic biota within Riggs Brook, and to reduce potential present
and future human health risks from ingestion of PCB-contaminated
fish obtained from Riggs Brook. Based upon the information
discussed above relative to the U.S. Fish & Wildlife Services
evaluations applicable to this Site (see Appendix B of this ROD),
and the recommended range of PCB sediment levels proposed in a
document prepared by the National Oceanic and Atmospheric
Administration (NOAA-see Administrative Record), the target
cleanup level established for the PCB-contaminated sediments
within Riggs Brook was 1 ppm.
-------
ROD DECISION SUMMARY page 39
O'CONNOR CO. SITE
2. Description of Remedial Components
The selected remedy for the Site includes a combination'of
remedial alternatives SC-11A, MM-3 and SE-1, as noted previously
in Section IX. The major remedial components of the selected
remedy include:
A. Source Control (SO
1. Draining and off-site treatment of on-site surface waters in
the upland marsh and lagoons.
2. Re-routing of the existing surface water drainage patterns.
3. Decontamination/demolition of the barn.
4. Clearing of vegetation, installation of erosion control
measures, and excavation of contaminated soils and sediments.
5. On-site treatment of contaminated soils and lagoon/marsh
sediments using a solvent extraction technology.
6. On-site treatment of contaminated soil and sediment residue
failing the Extraction Procedure (EP) Toxicity test or the
Toxicity Characteristic Leaching Procedure (TCLP) using a
solidification/stabilization technology.
7. Transportation and off-site disposal at a licensed RCRA/TSCA
landfill of solidified/stabilized soil and sediment residue, and
soil and sediment residue that does not achieve all target
cleanup levels following solvent extraction.
8. Site restoration.
9. Establishing compensatory wetlands/waters of the United
States.
10. Five-year review of site conditions, as appropriate.
B. Management of Migration
1. Groundwater (MM);
a. Establishment of temporary institutional controls until
groundwater remediation goals are achieved.
-------
ROD DECISION SUMMARY page 40
O'CONNOR CO. SITE
b. Installation of groundwater extraction and monitoring well(s).
c. On-site groundwater treatment system and recharge system
installation.
d. Treatment system and recharge system monitoring, and operation
and maintenance.
e. Five-year review of site conditions.
2. Riqgs Brook Sediment (SE)
a. Establishment and implementation of extensive sediment and
biota sampling and analysis program within Riggs Brook.
b. Implementation of public education programs.
c. Five-year review of site conditions.
3. Implementation of Remedial Components
The following discussion presents in further detail the likely
sequence of events which will occur during the implementation of
each of the above-described remedial components that are included
in the selected remedy.
Draining and Off-Site Treatment of On-Site Surface Waters
fSC)
This component involves pumping the water from the upper and
lower lagoons and the upland marsh, and transporting this
contaminated water via tanker trucks to a permitted, off-site
treatment/disposal facility. The volume of water to be pumped is
estimated at between 150,000 and 195,000 gallons (total).
Re-routing of Existing Surface Water Drainage Patterns (SO
The existing major drainage pattern on the Site occurs
approximately down the center of the Site, through the upper and
lower lagoons, and into Riggs Brook (see Figure 6-1). Secondary
pathways occur along both the northeastern and southwestern fence
lines towards Riggs Brook. This remedial component would involve
creating a new drainage system around the perimeter of the Site
that would divert surface waters away from the contaminated
portions of the Site. This system would be established through
the installation of a storm water drainage culvert leading from
the upland marsh, through appropriate manholes, and into the
existing drainage ditch along U.S. Route 17 leading towards Riggs
Brook.
-------
ROD DECISION SUMMARY page 41
O'CONNOR CO. SITE
Decontamination/demolition of the Barn (SO
Due to the existence of contaminated materials within and on
interior portions of the on-site barn structure, the floor of the
barn will be cleaned by removing all the soil, dust, and other
loose material and including this with the contaminated soils and
sediments undergoing excavation. Large recoverable items
remaining in the barn will either be removed by the appropriate
owner of the item or disposed of as solid waste in a local
sanitary landfill, as found acceptable.
Once the barn is cleaned of the above-noted materials, the entire
structure will undergo standard wipe test procedures to ensure
that the barn is not contaminated above acceptable levels. In
lieu, of a site-specific determination of these acceptable levels,
the procedures and action levels may be those described in the
TSCA Spill Cleanup Policy at 40 CFR Part 761, Subpart G...
Following decontamination of the barn, the entire structure will
be demolished due to its deteriorating condition, and taken off-
site for disposal as demolition debris or in accordance with the
TSCA Disposal Regulations at 40 CFR Part 761, Subpart D, if
applicable.
Clearing of Vegetation. Installation of Erosion Control
Measures, and Excavation of Contaminated Soils and Sediments
fSC)
* Erosion Control Siltation fences and hay bales will be
used to mitigate the potential for overland transport, by
precipitation-generated surface waters, of contaminated on-site
soil and/or sediment particles during excavation activities. The
siltation fencing will be installed downgradient of the areas
undergoing -excavation, i.e., between the Site and Riggs Brook
(all along its northern bank near the Site). The siltation fence
would be periodically inspected and cleaned in areas where
materials have accumulated, and would remain in-place until
vegetation is re-established over those areas disturbed by the
excavation activities. Hay bales would also be used within the
newly constructed drainage system discussed previously. These
hay bales -will also be inspected periodically and cleaned where a
build-up of materials has occurred.
* Vegetation Clearing Tall grass, shrubs, trees, and
other vegetation located above the existing grade of the Site
will be cleared from those areas where contaminated soils and/or
sediments (above the established target cleanup levels) will be
excavated. This material would all be shredded or chipped on-
site to reduce the overall volume to be handled. This material
will eventually be disposed of at a solid waste landfill, if
found acceptable, or treated in the same manner on-site as the
-------
ROD DECISION SUMMARY page 42
O'CONNOR CO. SITE
contaminated soils and sediments.
* Excavation of Contaminated Soils and Sediments Prior to
the initiation of the excavation activities, gravel access roads
would be constructed on the Site, around areas contaminated above
the target cleanup levels, to provide easier access to the low-
lying, eastern portions of the Site. These roads would be
designed to accommodate the moderate-heavy construction equipment
required to perform the excavation and treatment activities on
the Site.
Following these activities, excavation of those soils and
sediments contaminated in excess of EPA's site-specific target
cleanup goals will commence. The volume of excavated,
contaminated soils and sediments is estimated to be approximately
23,500 cubic yards. The existing analytical data provided in the
RI will be used to preliminarily establish the areas and depths-
of the excavation. The excavation would first proceed in those '
areas where the on-site treatment system would be setup (possibly
within the TWA III area).
To ascertain that those areas which undergo excavation achieve
the target cleanup goals established for the Site, confirmatory
sampling will occur throughout and along the perimeters of these
areas. The sampling would be conducted to statistically
determine whether an area has achieved the goals or requires
further excavation. Both field screening techniques and
certified laboratory confirmation analyses for PCBs, cPAHs, and
lead will occur throughout the excavated areas.
Treatment of Contaminated Soils and Sediments fSC)
All of the approximately 23,500 cubic yards of contaminated soils
and sediments containing PCBs, cPAHs, and lead above the
established target cleanup goals will be treated on the Site
using a solvent extraction technology. This technology involves
the use of a solvent to extract the PCBs and cPAHs from the
contaminated soils and sediments. The lead is not likely to be
treated by this technology to any significant degree. However,
since the.lead-contaminated materials are co-located with the
PCBs and cPAHs, it would be technically impracticable to separate
out the lead; additionally, the treatability study results
indicate that the lead may in fact bind to the treatment residue.
The contaminated liquid containing the extracted PCBs and cPAHs
from the soils and sediments would be eventually destroyed at a
licensed, off-site TSCA incinerator.
Prior to full-scale implementation of the solvent extraction
process on the Site, additional treatability studies will be
performed both in the laboratory and at the Site. These
-------
ROD DECISION SUMMARY page 43
O'CONNOR CO. SITE
additional studies will provide further information regarding the
ability of this technology to achieve the 1 ppm cleanup goals for
PCBs and cPAHs (especially on soils/sediments containing PCBs
between 20 and 100 ppm initial concentrations), and will also
assist in establishing the optimum operational settings for full-
scale extraction of these contaminants at the Site.
Additionally, once full-scale on-site solvent extraction
commences, any exhaust gases generated by this system will be
treated by air pollution control devices;. Furthermore, ambient
air monitoring during the excavation and on-site treatment phases
of the entire remedial action will be performed to ensure
compliance with all Federal and State air quality standards, and
to ensure the safety of on-site workers and the public.
*
Treatment of Solid Residues Exhibiting a Characteristic
Hazardous Waste (SO
As noted above, the solvent extraction technology will not likely
remove (extract) the lead from the contaminated soils or
sediments which are excavated above the 248 ppm target cleanup
level. These solid residues will undergo further treatment using
a solidification/stabilization technology if, after undergoing
the EPA standard EP (extraction procedure) toxicity test or TCLP
(toxicity characteristic leaching procedure), they exhibit the
characteristics of a hazardous waste. If these same solid
residues (still containing greater than 248 ppm lead) do not
exhibit the characteristics of a hazardous waste, they will be
disposed of as described below. The solidification/stabilization
treatment technology essentially uses a combination of physical
and chemical stabilization processes to bind and isolate
contaminants within the treated mass, resulting in a substantial
reduction in the mobility of the contaminants. In the case of
inorganics such as lead, the metal is converted into an insoluble
hydroxide and silicate which can then be physically bound to the
stabilization additive.
Off-site Transport and Disposal of Treatment Solid Residues
(SO
Those solid treatment residues resulting from the solvent
extraction process, that do not achieve the target cleanup goals
established for the protection of human health and the
environment at the Site (i.e., 1 ppm PCBs, 1 ppm cPAHs, or 248
ppm lead) and/or that have undergone additional treatment through
solidification/fixation, will be transported off-site in
appropriately sized containers and trucks to be disposed of at a
licensed RCRA/TSCA landfill.
Based on the treatability study already performed on soils from
-------
ROD DECISION SUMMARY page 44
O'CONNOR CO. SITE
the Site using a solvent extraction technology and the additional
information available for this sane technology on other PCB-
contaminated materials, it is currently approximated by-EPA that
only 4,500 cubic yards (20 percent) of the total 23,500 cubic
yards of contaminated soils and sediments undergoing solvent
extraction at the Site will require off-site disposal. Further
information obtained during the additional treatability studies
to be performed during the design phase for the selected remedy,
as noted above, will provide added evidence to modify this
estimate, if necessary. Additionally, as also rotsd above, the
lead-contaminated soils and sediments co-located on the Site with
the PCBs and cPAHs will not likely be treated by the solvent
extraction technology and will, therefore, undergo further
treatment by solidification/fixation. This amount of
contaminated material is approximated to be 500 cubic yards,
based on existing data from the Site.
Overall, it is currently estimated that the volume of
contaminated soils and sediments that will be transported off the
Site will be approximately 5,000 cubic yards; either as solid/
non-solidified residue or as solidified residue.
Site Restoration (SO
Following implementation of the above-described remedial action
source control components, the Site will be restored. This will
include the backfilling of those areas of the Site where the
excavation originally occurred to remove the approximately 23,500
cubic yards of contaminated soils/sediments exceeding established
target cleanup levels. The backfilling of these areas will
require that: (a) new native soil be brought to the Site from an
off-site location which totals approximately 5,000 cubic yards,
based upon present EPA estimates that this volume of
soil/sediment will be transported off-site for disposal, and (b)
those residual soils from the on-site solvent extraction system
that achieve all the established target cleanup goals be placed
back onto the Sit* (i.e., approximately the remaining 18,500
cubic yards). These backfilled soils will then be regraded to
establish new surface water drainage patterns on the Site, and
the restored areas fertilized, seeded and mulched to establish a
protective vegetative cover.
Establishment of Comoensatpry Wetlands/Waters of the United
States fSCl
The draining and off-site treatment of those contaminated surface
waters and excavation of the contaminated sediments contained
within the upland marsh, and upper and lower lagoons on the Site
will result in the loss of these wetland areas. Given the levels
of contaminated wastes within these areas and the overall goal of
-------
ROD DECISION SUMMARY page 45
O'CONNOR CO. SITE
this remedial action, there are no practicable alternatives to
the draining and excavation that will occur in these areas in
order to achieve the target cleanup goals established for the
soils and sediments on the Site. Therefore, the unavoidable
impacts that may be caused by the destruction of these areas must
be mitigated and compensated for to the maximum extent
practicable. The establishment of wetland areas of equal or
higher value will be recreated to the extent required by federal
and state wetland ARARs, if technically feasible, within the
O'Connor property. Prior to initiation of the remedial action, a
further evaluation of the functional attributes of these areas
will be required. Additionally, in siting and developing these
compensatory wetlands following completion of the source control
compbnents of the overall selected remedy, EPA will consider
potential affects on groundwater flow or adverse impacts on other
aspects of the remedial action prior to their implementation.
Furthermore, any potential effects on the 100-year floodplain
partially located on the Site will be limited through the use of
careful construction practices during the entire excavation
activity to be performed on the Site.
Establishment of Temporary Institutional Control on Site
Groundwater (MM)
Institutional controls, in the form of deed and land-use
restrictions, will be temporarily established on the Site to
restrict the use of the contaminated groundwater. This will
reduce the potential for exposures by humans to the contaminated
groundwater until the remediation of this water is completed.
Installation of Groundwater Extraction Wellfsi (MM)
In order to achieve the groundwater remediation goals discussed
previously in this section of the ROD and to intercept the
sporadic concentrations of contaminated groundwater located on
the Site from possibly migrating off-site, strategically located
and carefully constructed extraction well(s) will be installed
and pumped for subsequent treatment on-site. Based on the
current information provided in the RI report, the proposed
extraction well(s) would be installed at a downgradient location
to TWA II and would be capable of pumping at a rate of
approximately 0.5 gallons per minute. The location, number of
extraction well(s), operating conditions, capture zone
efficiency, etc. will be determined during the design phase
through the performance of one or more pump tests at the Site.
-------
ROD DECISION SUMMARY pag« 46
O'CONNOR CO. SITE
On-site Groundwater Treatment System/Reel
Installation CMM)
The groundwater treatment system for the extracted groundwater
will include a preliminary filtration step for the removal of
partieulates, suspended solids and oil droplets; a granular
activated carbon (GAC) unit for removal of the organics; and, an
on-site system for recharge of the treated groundwater that
achieves the target cleanup goals established for the Site. The
primary organic contaminants of concern in the Site groundwater
are benzene, 1,4-dichlorobenzene, and PCBs. If, based on the
pump test mentioned above and the analytical results of the
groundwater from these tests, inorganics such as iron and/or
manganese are present and could cause fouling problems with the
activated carbon units, then an in-line pretreatment unit for
these metals would be added during the design phase of the
overall treatment system. The injection/recharge system for the
treated groundwater will consist of a trench or well(s) located'
outside and upgradient of the triangular area formed by existing
on-site wells MW-101, MW-102, and MW-105.
Groundwater Treatment System Monitoring, and Operation and
Maintenance (MM)
System monitoring, in the form of periodic sampling and analysis
efforts, will occur at the Site to evaluate the performance and
efficiency of the entire groundwater extraction and treatment
system. These sampling events will involve the analysis of both
the influent and effluent streams to the treatment system for
both organics and inorganics. The frequency of monitoring will
occur on a monthly basis (at a minimum) during the first six
months of operation or until the target cleanup goals are being
consistently achieved. Thereafter, the sampling and analysis
frequency will likely be reduced to a quarterly basis. This
anticipated monitoring schedule is expected to adequately
evaluate the system, and indicate the need for replacement of the
activated carbon canisters required for effective treatment.
Additional environmental monitoring of the groundwater extraction
and treatment system will occur through the sampling and analysis
of the on-site groundwater using existing and newly installed
monitoring wells located around the Site. Specific wells to be
installed and the analytical parameters to be evaluated as part
of this monitoring phase will be described in the design, based
upon the pumping tests and subsequent results obtained from these
tests. Monitoring will occur quarterly starting from the
initiation of the design work for the selected remedy, and for a
period of three years after remediation activities are completed.
At that time, the frequency and location of groundwater sampling
will be re-evaluated. Groundwater monitoring activities will
-------
ROD DECISION SUMMARY page 47
O'CONNOR CO. SITE
continue to be evaluated no less than every five years for at
least the remainder of the 30-year monitoring program.
Establishment and Implementation of Riqqs Brook Sampling and
Analysis Program (SE)
Reducing the potential human health and environmental risks that
may be posed by the localized areas of PCB-contaminated sediments
(containing greater than 1 ppm) within Riggs Brook will require
that a monitoring program be implemented. To do so,
environmental sampling of the sediments from Riggs Brook and its
associated nearby wetlands will be conducted once every year for
ten years to ensure that the level of PCBs is not increasing and
remains below 5 ppm. Fish will also be sampled approximately
once, after five years of sediment monitoring. If an increase in
the current PCB sediment levels occurs above the 5 ppm threshold
and/or the fish tissue samples are found to be greater than 2
ppm, then a more rigorous sampling effort of such contamination ,
will be conducted to determine the need for and/or extent of
further remedial actions to be undertaken within Riggs Brook, if
any.
Implement Public Education Programs fSEl
Complementing the above-described sediment monitoring program
will be the establishment of public educational programs which
would involve public meetings and presentations to increase
public awareness about the status of contamination within Riggs
Brook, and also the overall Site conditions. This would involve
periodic presentations at a public hearing before all interested
members of the community.
Five-Year Review of Site Conditions
Under CERCLA § 121(c), any remedial action that results in any
hazardous substances, pollutants, or contaminants remaining at
the site shall be reviewed no less often than each 5 years after
the initiation of such remedial action to assure that human
health and the environment are being protected by the remedial
action being implemented.
Since the remedial action for the Site (as presented herein) will
result in hazardous substances remaining in the on-site
groundwater and the sediments of Riggs Brook (at a minimum), this
will require that the overall Site conditions be reviewed at
least once every five years after the initiation of the remedial
action at the Site (including the Site proper, as appropriate).
This review will be consistent with the CERCLA standards
applicable for five-year site reviews in effect at the time of
the review. The extent and nature of this review program will be
-------
ROD DECISION SUMMARY page 48
O'CONNOR CO. SITE
developed during the design phase of the selected remedy, but
will include, at a minimum, those data collected during the
monitoring programs identified above for the groundwater and
Riggs Brook sediments.
The Site will also be re-evaluated to determine the risk posed by
the Site at the completion of the remedial action (i.e., before
the Site is proposed for deletion from the NPL).
B. Rational* for Selection
The rationale for choosing the selected alternative is based on
an 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 invoked. In assessing the alternatives
that met these statutory requirements, EPA focused on the other
evaluation criteria, including, short-term effectiveness, long-
term effectiveness, iroplementability, use of treatment to
permanently reduce the mobility, toxicity and volume, and cost.
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.
As described in detail above, the selected remedy is a
comprehensive approach for overall remediation of the Site which
involves both source control and management of migration remedial
alternatives. In summary, this remedy has been selected because
it represents the best balance among all of the "primary
balancing criteria" considered, while also gaining State and
community acceptance.
Source Control
The source control (SC) component of the selected remedy, which
essentially involves on-site treatment of contaminated on-site
soils and sediments together with off-site disposal of treatment
residues, and off-site treatment of contaminated on-site surface
waters, was chosen from among the other SC alternatives for
several reasons. First and foremost, this component of the
remedial action selected for the Site will provide overall
protection of human health and the environment by eliminating,
reducing and controlling all current and potential risks posed by
all exposure pathways at the Site, and will be in compliance with
all applicable or relevant and appropriate requirements (ARARs).
-------
ROD DECISION SUMMARY page 49
O'CONNOR CO. SITE
The long-term effectiveness and permanence of the selected remedy
were determined to be critical factors in balancing the- trade-
offs among all other source control alternatives evaluated. More
specifically, the magnitude of the risks remaining from the
treatment residuals following successful implementation of the
selected remedy will be well within EPA's acceptable cumulative
risk range of 10-4 to 10-7 individual, lifetime excess cancer
risk. Since no remaining sources of risk from either treated or
untreated residuals would exist on the Site (due to the off-site
landfilling of untreated residuals), no management
(institutional) controls will be needed upon completion of this
response action. By contrast, all other source control
alternatives evaluated (excluding on-site incineration, and off-
site landfilling which is not considered a permanent remedy)
would have to rely on soil covers and/or institutional controls
(deed restrictions) placed on the Site to ensure their continued
protectiveness over the long-term and would not provide the same
degree of long-term permanence afforded by the selected remedy.
The reliability of such controls and the potential impacts on
human health and the environment, should they fail, is uncertain,
and could potentially result in future remedial action costs
being incurred for the Site.
The statutory preference of CERCLA, at § 121 (b) to permanently
and significantly reduce the volume, toxicity or mobility of
hazardous substances through treatment technologies (to the
maximum extent practicable) is satisfied by the selected remedy.
Additionally, this preference for treatment is more fully
addressed by the selected remedy in comparison to those other
alternatives which only provide containment, or disposal
(especially off-site disposal without prior treatment), or a less
significant reduction in the volume, toxicity or mobility. The
magnitude of the reductions achieved through implementation of
the selected remedy has been determined to be very significant
(based upon the site-specific treatability study conducted with
solvent extraction which showed a mass reduction of greater than
95% for PCBs). Furthermore, the concentrations of contaminants
in the treatment residuals from these treatability studies were
shown to be consistently reproducible, in contrast to the results
from the other alternative treatment technologies evaluated.
More specifically, extraction efficiencies obtained from this
Site and those compiled from other treatability study results
available from vendors of this technology (see Site
Administrative Record) consistently shows that greater than 95%
removal of PCBs from soils can be achieved and that a 1 ppm PCS
residual level is attainable using the solvent extraction
technology. These technical facts are further supported by
statements in the Administrative Record from EPA technical
personnel actively involved with solvent extraction technologies
-------
ROD DECISION SUMMARY page 50
O'CONNOR CO. SITE
under the SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE)
program.
The selected remedy also utilizes alternative treatment
technologies while providing similar advantages and disadvantages
to the other alternative technologies considered relative to
their short-term effectiveness at the Site (i.e., excavation and
increased truck traffic at the Site are irherent impacts over the
short-term for all SC alternatives, except, no-action).
Additionally, however, the potential short-term air quality
impacts from the on-site incineration of the contaminated
soils/sediments were considered to be significant, given the
proximity of the neighboring community to the Site, and the
existence of numerous on-site workers operating the incineration
uniti,
The selected remedy, in comparison to all other SC alternatives .
evaluated, was considered to be relatively easy to implement from
both a technical and administrative feasibility standpoint. All
alternatives which utilized an innovative treatment technology
would be somewhat limited by the availability of only a few
vendors offering the required, specialized services. Only on-
site incineration appeared to be more easily implementable
overall due to the increased numbers of operators of this more
common technology.
A* major "balancing factor" considered during the remedy selection
process for this Site was the cost of implementing the remedial
action, including operation and maintenance costs incurred over
the life of the remedy. The results of this comparative
balancing indicated that the costs associated with the selected
remedy do not far exceed the costs associated with the other
source control alternatives analyzed, and are proportional to the
substantially greater human health and environmental protection
and technical reliability provided by implementation of this
remedy. That is to say, the selected remedy is cost-effective in
that its overall effectiveness is proportionate to its costs,
even though the costs of the selected remedy are greater than the
costs associated with several of the other source control
alternatives considered (excluding off-site landfilling, on-site
incineration, and on-site vitrification).
Finally, the two "modifying criteria" were factored into the
final remedy selection process for this Site following the formal
public comment period for the proposed plan and the RI/FS. In
summary, both state and community acceptance were expressed for
the selected remedy, and the eventual long-term, permanent
remediation of the Site. Comments from both the State of Maine
and the community urged EPA to return the Site to a useable
condition, and expressed serious reservations about capping the
-------
ROD DECISION SUMMARY page 51
O'CONNOR CO. SITE
Site with soil or creating a landfill within the Augusta city
limits. Specific comments made relative to the selected remedy
can be found in Appendix A to this ROD.
Management of Migration
As noted previously, the selection process discussed herein for
the management of migration alternatives focused primarily on the
"primary balancing criteria."
In the comparison of the groundwater alternatives (MM-1; Minimal
No-Action, and .MM-3; Groundwater Extraction and Treatment), it
was clear that alternative MM-3 provided the best balance from
among all the criteria. This was especially true relative to the
cost, long-term effectiveness and permanence, and short-term
effeqtiveness gained by selection of this alternative.
Additionally, this alternative satisfies the statutory preference
for treatment and does not require the use of management controls
over the long-term to be protective and comply with ARARs.
Furthermore, by utilizing treatment of the groundwater, the
reduction in the toxicity, mobility, and volume is orders of
magnitude more significant than results from the minimal no-
action alternative.
With respect to the two alternatives evaluated for remediation of
the PCB-contaminated Riggs Brook sediments (SE-1; Minimal No-
Action, and SE-2; Excavation and Off-Site Disposal), both would
comply with ARARs and would be protective of human health and the
environment using varying approaches. However, the short- and
long-term effectiveness of each alternative varies significantly.
This was especially significant under SE-2 where excavation of
the wetlands within Riggs Brook would be required to successfully
implement this alternative in order to achieve the 1 ppro PCB
cleanup goal. Such excavation would cause significant short-term
environmental damage to this wetland area, but would not likely
require long-term monitoring upon completion. In contrast, under
SE-1, contaminated PCB sediments would remain within Riggs Brook
at a maximum concentration of 5 ppm without causing any short-
term impacts, but would require extensive monitoring over the
long-term. Based upon a review of these facts, EPA, in
consultation with the U.S. Fish & Wildlife Service and the
National Oceanic and Atmospheric Administration, determined that
the potential, irreversible environmental damage through the
implementation of SE-2 outweighed the disadvantages associated
with leaving the contaminated sediments in place according to SE-
1.
-------
ROD DECISION SUMMARY page 52
O'CONNOR CO. SITE
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the 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 treatment
which permanently and significantly reduces the toxicity,
mobility, or volume of nazardous substances as a principle
element. Additionally, the selected remedy utilizes alternative
treatment technologies to the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The .'selected remedy for the Site will permanently reduce the
risks presently, and in the future, posed to human health and the
environment by the contaminated soils, sediments, surface waters',
vapors, and groundwater and thereby result in a protective
remedy.
The soil and sediment cleanup levels to be attained through
excavation and treatment will reduce the risks associated with
these contaminated materials to a level protective of human
health and the environment. These target cleanup levels address
the risks from direct contact and incidental ingestion of
contaminated soils and sediments as well as from the inhalation
of vapors originating from the contaminated soils and sediments.
Treatment of the soils and sediments will also protect
groundwater and surface waters from additional contamination by
removing the sources of the contamination. The Feasibility Study
identified three substances in the soils and sediments requiring
remediation: PCBs, cPAHs, and lead. The selected remedy
(excavation and on-site solvent extraction of all on-site soils
and sediments exceeding the target cleanup levels; off-site
incineration of the extracted contaminants; on-site
solidification/stabilization of any solid residue failing EP
toxicity or TCLP tests; and ultimate disposal in a licensed, off-
site chemical waste landfill of residues exceeding cleanup levels
or undergoing further on-site treatment by solidification/
stabilization) will significantly reduce the risks associated
with all three compounds to a level protective of human health
and the environment. This level (for PCBs and cPAHs) is well
within the 10-4 to 10-7 cancer risk range that EPA has determined
to be protective of human health (i.e., individual residual risks
estimated to be 5 x 10-6 or a cumulative residual risk of
approximately 1 x 10-5), and well below the level at which no
noncarcinogenic, adverse health effects to lead will occur.
-------
ROD DECISION SUMMARY page 53
O'CONNOR CO. SITE
The pumping and off-site treatment, at a permitted facility, of
the on-site surface waters will also be consistent with the
target cleanup goals which have been established for the three
contaminants of concern in the surface waters/ namely, PCBs,
lead, and aluminum. These goals are based on EPA's Ambient Water
Quality Criteria (AWQC), as to be considered guidelines. These
criteria are shown in Table 10.
The groundwater target cleanup levels established for the Site
are the Federal MCLs and Maine MEGs for PCBs, benzene, and 1,4-
dichlorobenzene (see Table 11). Whereas, in the case of 1,4-
dichlorobenzene, the state and federal standards differ, EPA
adopted the more stringent of the two standards as the target
cleanup level for the Site.
The goroundwater treatment method selected (groundwater collection
and on-site treatment by carbon adsorption) will reduce the
concentrations of all contaminants to these target cleanup
levels.
The minimal no-action approach to managing the localized areas of
low-level (less than 5 ppm) PCS contamination within the Riggs
Brook sediment will protect human health and the environment
through the long-term monitoring of Riggs Brook sediments and
biota (fish), and the implementation of educational programs for
the local community. Thus, this approach provides environmental
protection without disturbing the currently localized PCB-
contaminated sediments within Riggs Brook and the associated
wetlands through excavation activities. .
B. The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate Federal and state requirements that apply to the
Site.
Federal environmental laws which are applicable or relevant and
appropriate to the selected remedial action at the site are:
Resource Conservation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Clean Water Act (CWA)
Fish and Wildlife Coordination Act (FWCA)
Safe Drinking Water Act (SDWA)
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
Table 12 lists action-specific ARARs and TBCs for the remedy
selected for the Site. Table 13 lists potential chemical-
specific Federal and State ARARs and gives a brief synopsis of
-------
Page 53A
TABLE 10
PROPOSED TARGET CLEAN-UP LEVELS FOR ON-SITE SURFACE WATER1
O'COKNOR SITE
AUGUSTA, MAINE
(Concentrations in vg/i or ppb)
Chemical
PCBs
Lead
Aluminum
Guidelines
Considered
0.014/2.0 (AWQC)2
1.94 (AWQC)3
87/750 (AWQC)4
Achievable
Detection Limit5
0.065
1
45
Target
Clean-up Level
0.065
1.94
87
NOTES:
On-site surface water bodies include the upland marsh, upper lagoon, and
lower lagoon.
i
The AWQC (Ambient Water Quality Criterion) for PCBs to protect freshwater,
aquatic life is 0.014 pg/£ as a 24-hour average. This concentration was
derived based on the high bioconcentration factor of PCBs in aquatic
organisms; however, the available data indicate that acute toxicity in
freshwater aquatic life probably will occur only at concentrations above
2.0
The AWQC for lead established by USEPA is 1.94 jjg/1 for a four-day average
concentration, not to be exceeded more than once every three years, for a
hardness of 67 (Jg/I CaC03 (measured in Riggs Brook) (ICF-Clement, January
1988).
The AWQC for aluminum established by USEPA (1988) is a maximum
concentration in freshwater of 87 Mg/1, a four-day average, not to be
exceeded more than once every three years on the average. The one-hour
average concentration of aluminum should not exceed 750 pg/£ more than once
every three years on the average, at a pH of 6.5 to 9.0.
The Achievable Detection Limits are: 0.065 Mg/£ PCBs derived from the RCRA
Method 8080 Method Detection Limit; 1 pg/£ lead derived from the RCRA Method
7421 Method Detection Limit; and 45 pg/£ aluminum derived from the RCRA
Method 6010 Instrument Detection Limit.
-------
Page 53B
TABLE 11
PROPOSED TARGET CLEAN-UP LEVELS FOR CROUNDVATER
O'CONNOR SITE
AUGUSTA, MAINE
(Concentrations in pg/£ or ppb)
Chemical
PCBs
Benzene
1 ,4-Dichlorobenzene
Target
Clean-up
Levels
0.5
5
27
Basis for
Selection1
ME MEG
MCL
ME MEG
Individual
Carcinogenic
Risk Associated
with Chemical2
l.lxlO"4
7.43xlO~6
1.54xlO~ 5
Total
Carcinogenic Risk
for Combination
of Chemicals3
1.3xlO~«
Notes:
1 Target clean-up levels were developed based on ARARs, as follows:
MCL - Maximum Contaminant Level is an enforceable standard promulgated under the Safe
Drinking Water Act. MCLs are available for benzene and 1,4-dichlorobenzene.
MEG - Maximum Exposure Guideline is an enforceable standard promulgated under the Maine
Rules. MEGs are available for PCBs and 1,4-dichlorobenzene.
2 The individual carcinogenic risks associated with the target clean-up level for each
chemical were calculated.
3 The total carcinogenic risk for the combination of individual target clean-up levels was
calculated by adding the individual risks associated with each of the chemical target
clean-up levels.
4 If the TCL for PCBs is set_at the RCRA Method Detection Limit of 0.065 pg/£, the
associated risk is 1.43xlo"s.
5 If the TCL for 1,4-dichlorobenzene is set at the CLP Contract Required Detection Limit of
10 Mg/£» the associated risk is 5.71xlo"6.
-------
Page 53C
Table 12
POTENTIAL ACTION-SPECIFIC MAXS
O'CONNOR SITE
REQUIREMENTS
RKfUIREMKNT STNQPSIS
Federal Retulatery
Requirements
RCRA Standard* for Owners Md
Operators ml Permitted Hazardous
Vaste Facilities (40 CPR Part*
264.10 - 264.11)
RCRA - Preparedness and Preven-
tion (40 CFR Part* 264.30
264.37)
RCRA Contingent? Pis* and
Emergency Procedures (M Cfl
Parts 264.50 264.56)
RCRA Manifest System,
Recordkeeping, and Reporting
(40 CHI Parta 264.70 - 264.77)
RCRA Cremdwater Protection
(40 CfK Parta 264.90 264.109)
RCRA Closure and Post-closvre
(40 CTR Parts 264.110 264.120)
RCRA USEPA Regulations on Land
Disposal Restrictions "Land Ran"
(40 CFR Part 261)
Crneral facility requirements outline waste
analysis, security measures, and training
requirements. Requirements apply tn the storage,
treatment, and disposal of hazardous waste.
This regulation outlines safety equipment
and spill-control requirement* for
hazardous waste facilities. Part of the
regulation includes a requirement that
facilities be designed, Maintained,
constructed, and operated to minimire
the possibility of an unplanned release
that could threaten human hralth or
the environment. It also applies to the
storage, treatment, and dispossl of
hazardous waste.
i
Thi* regulation outlines the rrquirtmeuts
for emergency procedures to be used
explosions and fires. This regulation
also requires that thrtats to public health
and the environment be minimised. Require-
ments apply to the storage, treatment, and
disposal of hazardous waste.
This regulation details the manifesting
requirements for an on-site facility that atore*.
tores, treats, or disposes of hazardous waste.
Under this regulation, grouodwater
monitoring program requirements are
outlined for facilities that store, treat,
r dispose of hazardous waste.
t
Thi* requirement details the specific
requirements for closure and post-closure
of hazardous waste facilities.
These regulations outline land disposal
requirements and restrictions for specified
hazardous wastes. The following restrictions
may govern on-site wastes: (I) if a hazardous
waate is present which contains NOCs in conceaj-
UattitM e»|Msl to or greater than 1,000 mg/tg,
it must be incinerated prior to disposal,
effective November I, 1490; and (2) if the
on-«ite waste e«hibita a hazardous characteristic
as defined in 40 CPR 261 (e.g., KP toaicity), tner
it must he treated such that it no longer eshibili
the characteristic.
RCRA landfills
(40 CTR Parta 264.300 - 264.339)
Thi* regulation covers design and
operating requirements, as well as
post-closure care options for landfills.
Closure and poet-closure care must
be attained in accordance with
either the outlined disposal
requirements or by the site-
specific alternate method.
-------
TABLE 12 (continued)
POTENTIAL ACTIOH-SPEC1F1C ARAKS
O'COHKOR SITE
R£QUIREHIKTS
BrniilEEHEKT SYNOPSIS
Federal Regulatory
Requirements
(contioued)
SKUA Surface Impoundments
(40 CHI Parti 264.220 » 264.249)
RCRA - Waste Piles (40 CTO
Parts 264.250 264.269)
CVA. Section 404(b)(l) Permits for
Dredged or Fill Material (40 CFR 230)
This regulation establishes design and
operating requirements, as well as closure
and poll-closure options for surface
impoundments. If all hazardous
wastes cannot He removed or
decontaminated, the surface
impoundment must be capped and
receive post-closure care.
This regulation establishes procedures,
operating requirements, closure and
ost-closure options for waste piles.
If remov.il or decontamination of
11 contaminated subsoils is not
possible, closure and post-closure
requirements for landfills must be
attained.
Under this regulation, discharges of-
dredged or fill material -into U.S.
waters are regulated.
TSCA Markings or PCBs and KB
Items (40 CFH Parts 761.40 -
761.45)
TSCA - Storage aad Disposal
(40 CFK Parts 761.60 761.79)
Greater than SO-pnm PCB storage areas, storage
items, and transport equipment must
be Marked with the H, mark.
This requirement specifies the requirements for
storage and disposal/destruction of K3s in
txcess of 50 ppa.
TSCA Records sod Reports (40
CFR Parts 761.110 - 761.193,
also 40 CFR Parts 129.105, 750)
CAA National Primary and
Secondary Ambient Air Quality
Standards for Paniculate Hatter
(40 CFR Parts 50.1 50.7)
OSHA General Industry Standards
(29 CFR Part 1910)
OSHA Safety and Health Standards
for Federal Servica Contracts
(29 CFR Part 1926)
OSHA - Recordkeeping, Reporting,
and Related Regulatioaa
(29 CFK Part 1904)
DOT Rules for the Transportation
of Hazardous Materials
(49 CFR Parts 107, 171.1 - 172.558)
Fish and Wildlife
Coordination Act
(16 U.S.C. 661)
This regulation outlines the
requirements for recordkeeping
for storage and disposal of >50-
ppa PCB items.
This regulation specifies minimum
primary and secondary 24-hour
concentrations for particulate
sutler.
This regulation specifies the 8-hour,
tine-weighted average concentrations
for various organic compounds.
This regulation specifies the type of
afety equipment 'and procedures to be
followed during site remediation.
This regulation outlines the record-
keeping aad reporting requirements for
an employer under OSHA.
This regulation outlines procedures
for the packaging, labeling,
manifesting, and transport of
hazardous Materials.
This regulation requires any
federal agency that proposes to
modify a body of water to consult
with the U.S. Fish and Wildlife
Services. This requirement is
addressed under CVA Section 404.
-------
TABLE 12 (continued)
POTENTIAL ACTION-SPECIFIC ARAKS
O'COWOR SITE
RlQUTRIMEffS
5TNOPS1S
Tettrtl Regulatory
Requirement*
(continued)
CVA » Natural Re source Damage
Ai»e**ment (*3 CFR Pert II)
Till* regulation outline* procedure!
for restoring rehabilitating, replacing,
or acquiring the equivalent of natural
resource* daoafed by hasardout
uhitance releaaea.
iO CFR Part 6
Appendix A Protection of Wetland*
Executive Order (EO tlttO)
40 CFR Pert i
Appendix A Floodplaifl Management
Executive Order (EO JJI88)
This EO prohibits the undertaking of
new construction in wetland*, which
includes dredging.
This EO outlines requirement* for
ctions taken in floodplaint.
State' Regulatory
Requirement*
Maine Solid Waste Management
Rules: Landfill Disposal
facilities (38 MRS A, Seetioa
1301 tt seq. , Chapters 400
Haioe Hazardous Waste
Management Rule* (31 HMA,
Section 1301 tt seq., Chapter*
00 - 102, 850, 151, 153 - 157)
Maine Natural Resource* Protection Act
(NRPA) (38 MRSA, Chapter 3, Section
480)
Maine Water Pollution
Control Law: Solid Waste Disposal
Areas; Location (38 MRSA, Chapter 3,
Article 2, Sections 420, 421)
These rules outline regulations for
landfills, including initial investiga-
tion, site iroundwater, and operating
nd closure plans.
These requirements correspond to
RCRA hacardou* waste regulation*.
Compliance with ROM will generally
achieve compliance with these
regulation*.
This act replaced the Great Pond* Act;
Alteration of Rivers, Stream*, and Brooks;
freshwater Wetlands Act; and Coast*! Wetland*
Act. Additionally, thi* lav protect fragile
mount*in area* and significant wildlife
areas. This act prohibits degradation or
destruction of those natural resources by
prohibiting alteration in or adjacent to a
protected natural area without a permit.
Permits are required for various alterations .
including: dredging, draining, or tfewatering;
filling; or altering a permanent structure.
This law requires a 300-foot tone
between a public or private solid
waste disposal arcs boundary and any
classified body of surface water.
Maine Standards for Classification
of Surface Waters (38 NASA,
Chapter 3, Sections 441, 470)
Maine Air Quality Control laws;
Protection and Improvement of Air
(38 MRSA, Chapter 4, Sections SSI -
410
Maine Site Location of Development
Law (38 MRSA. Chapter 3, Settled
414 375)
Maine Water Pollution Control Lav
(38 MRSA, Chapter 3, Article I,
Section 413 tt oeo,.)
These standard* cover restoration,
enhancement and preservation of state
waters.
This law aixf its associated regulations eV
the requirements, limitation*, and exempt!'
of slate air emission regulations for spec
substance*.
Thi* law rrKMIate* impact* on existing
uses scenic character, and natural
resources.
This law regulate* discharge of waste in
Maine, including surface waste water
-------
TABLE 12 (continued)
FOTOTUL ACTIOW-SPECtriC ARAKS
O'CONNOR SITE
KEQUIREKEKTS
REQUIREMENT STNOPSIS
Federal Criteria,
Adviieriei, and
Guidance To I*
Considered
UStPA Guidance Doruarot "Coven
for Uncontrolled Hazardous Waste
Sites" (USEFA/S40/2-8S/002)
TTut guidance outlines the three components that
offer detailed guidance for the design of a
cover system which will achieve the specified
perfomance standards of ROM landfill covers.
-------
Table 13
Page 53D
wn.rruL cnrmcAi-srtcmc AKARS
O'CONNOR SITE
rCDlA
STATUS
SYNOPSIS
Crouodwafer/Surface Viler
Federal Regulatory
Requirement*
State Regulstory
Requirements
SDVA Section 1412
Maiimisi Contaminant Level*
(HCLi) (40 Cm 141.11
141.16)
RCRA Subpart T, Creund-
water Protection Standards,
(40 CFH 2*4.94)
M*lee Standards for
Clarification of Miner
Discharges (31 H.R.S.A.,
Chapter 3, Section US)
Mi i lie Standards for
Classification of Grovnd-
water (31 H.R.S.A., Chapter
3, Section 470)
Maine Drinking Water Hole*
(Code of Heine Rules |CMR|,
10 - I44A, Chapter 231,
Section 7)
Rules Relating to Testing
of Private Water System*
for Potentially Maiardous
Contaminants (CMM IO-1MA,
Chapter 233, Appendin C)
Relevant MCl.s have been proowliiaied for a number
and of common organic s>nd inorganic con-
Appropriate tamtnants. These level* reflate the
concrntration of contaminants in public
drinking water supplies, but fcay also be
considered relevant and appropriate for
groundwaier aquifers used for drinking '
water.
Relevant This regulation outlines three possible
and standards (i.e., maiimum concentrations of
Appropriate contaminants, alternate concentration
limits, and background concentration*)
available vndrr Subpart F for aetting
a clean-up level for remediating
groundwaler contamination from a RCRA
facility.
Applicable RIRRS Irook is classified as a Class. I
water under the state water quality
standards.
Applicable Croundwater is classified under the Maine
standards. The growndwater at the
O'Connor site is classified as Cw-A
(i.e., water that shall be of auch quali
that it can be used for domestic purpose
Relevant Maine Maiimum Contaminant Levels (HCLs)
ond have been promulgated for a numher of
Appropriate contaminants. Additionally, organic
chemicals which have no established
MCU are addressed on case-by-ease basis.
When the atate levels are more stringent
than federal levels, the slate levels will
he used.
Relevant These rules establish criteria for
and potentially hazardous contaminants
Appropriate occurring in private residential water
systems.
Maine Drinking Water Rules Relevant
(Code of Maine Rules |CMR), ond
10 144A, Chapter 231, Appropriate
Section 7)
Rules Relating to Testing Relevant
of Private Water Systems and
for Potentially Hszardous Appropriate
Contaminants (CHX 10-144A,
Chapter 233, Appendix C)
Maine MaKion* Contaminant Levels (MCLs)
have been promulgated for a number of
contaminants. Additionally, organic
chemicals which have no established
MCLs are addreaeed en case-by-ease basis.
When the state levels are more stringent
than federal levels, the state levels will
be used.
These rules establish criteria for
potentially hazardous contaminants
occurring in private residential water
systems.
Federal Criteria,
Advisories, and
Guidance
Health Advisories (RAs) To Be
(USEPA Office of Drinking Considered
Water)
BAs are estiastes of risks due to
consumption of contaminated drinking
water; they consider oncareinogeoic
effects only.
-------
TABLE 13 (continued)
POTWIAL ciamcAL-srtcinc AKAXS
O'COKWOR SITE
MEDIA
STATUS
Crouadviter/Surfacf Water
EEOU1REKTKT SYNOPSIS^
Federal Criteria,
Adviioriei, end
Guidance
(continued)
USEPA Risk Reference Dotes
(RfDs)
USEPA Carcinogen Assessment
Croup (CAC) Potency factori
(PFs)
Acceptable Intake Chronic
(A1C) and Subchronic (AIS) -
USEPA Health Assessment
Documents
USEPA Office of Water
Guidance Water-related
Fate of 129 Priority
Pollutant* (1979)
To Be RfDs ere dose level* developed by
Considered USEPA for ooncarcinoienic effects. They
re considered to be the levels unlikely
to cause significant adverse health effects
ssocitted with a threshold ecbsnism
of action in human exposure for a lifeline.
To Be PFs are developed by USEPA fro* Health
Considered Effects Assessments (HEA) or evaluations
by tbe CAG and present the most up-to-date
cancer risk potency information.
To Be AIC and AIS values are developed from
Considered RfDs and HAj for noncarcinogenic
compounds.
To Be This guidance Manual gives-transport and
Considered fate information for 129 priority
pollutants.
Air
Federal Regulatory
Requirements
State Regulatory
Requirements
CAA National Primary and Applicable
Secondary Ambient Air
Quality Standards (NAAGS)
for Paniculate Hitter
(40 CFR Parts 50.6 - 50.7)
Maine Air Quality Control Applicable
Laws; Protection and
Improvement of Air (38 MRSA,
Chapter 4, Section 581-611)
This regulation specifies maximum primary
and secondary 24-hour concentrations for
for paniculate matter.
This law and its associated regulations
detail the requirements, limitations, and
exceptions of state air emission
regulations for specified substances.
-------
ROD DECISION SUMMARY page 54
O'CONNOR CO. SITE
these requirements. This table also includes those chemical-
specific advisories, guidances, etc. which, while not ARARs, are
to be considered (TBC) in setting target cleanup levels, at the
Site. Finally, Table 14 lists potential location-specific ARARs
and TBCs for the Site, along with a synopsis of these
requirements.
A brief narrative summary of the ARARs, as related to the
selected remedy, follows.
1. Action-specific ARARs
The source control portion of the remedial action will
essentially involve the excavation of approximately 23,500 cubic
yards of soil and sediments from the Site for on-site treatment
through a solvent extraction process; the off-site incineration
of the PCS- and cPAH-concentrated extract from the solvent
treatment process; the on-site stabilization/solidification of '
any solid residue exhibiting EP or TCLP toxicity; the disposal in
an off-site chemical waste landfill of the solid residue
exceeding cleanup goals and/or undergoing solidification; and the
pumping and off-site treatment of contaminated surface waters.
The management of migration portion of the remedy will involve
the construction of one or more deep bedrock extraction wells to
collect contaminated groundwater, preliminary filtrationof
suspended solids and oil droplets, carbon adsorption treatment,
and discharge of the treated water back into the aquifer.
a. Federal
The Resource Conservation and Recovery Act (RCRA) governs the
transportation, storage, treatment and disposal of hazardous
wastes. A substance is a hazardous waste as defined by RCRA at
40 CFR 261-if it either is included on a specified list or
exhibits any of the characteristics (i.e., ignitability,
corrosivity, reactivity or EP toxicity) of a hazardous waste.
Due to the presence at the Site of certain lead-contaminated
soils which may exhibit the characteristic of EP or TCLP toxicity
and the placement of these materials in a land treatment facility
according .to the selected remedy, the Land Disposal Restrictions
(LDR) set forth in Part 268 of RCRA are potentially applicable to
the implementation of this remedy. LDR will prohibit (once
promulgated) the land disposal of characteristic wastes unless
and until either: (1) the wastes have been treated to the extent
that they no longer exhibit the offending characteristic(s); or,
(2) the requirements of a treatability variance pursuant to 40
CFR 268.44 have been met. LDR will be satisfied by the selected
remedy through the implementation of stabilization/solidification
to the maximum extent practicable of any excavated and treated
materials which exhibit EP or TCLP toxicity; thereby addressing
-------
Table 14
Page 5AA
POTENTIAL LOCATION-SPECIFIC ARAKS
O'CONNOR SITE
SITE FEATURE
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
Wetlands
Federal Regulatory
Requirements
State Regulatory
Requirenenti
Floedplaini
Federal Regulatory
Requirement!
State Regulatory
Requirements
CVA, Section 404 (b)(l) - Applicable
(or Dredged or Fill Material
(40 CFR 230)
Fish and Wildlife Applicable
Coordination Act (Ik U.S.C.
661)
40 CFR Part 6
Appendix A, Protection of
Wetlands Executive Order
(EO »mo)
Applicable
Maine Natural Reaourcea
Protection Act (NRPA) (38
H.R.S.A., Chapter 3,
Section 480)
Applicable
Maine Hazardous Waate
Management Rules,
(38 M.R.S.A., Section 1301
et seq., Chapter 854)
Relevant and
Appropriate
RCRA Location Standards
(40 CFR Part 264.18)
40 CFR Part 6 Append!* A
Flor»dplain Manageaient
Executive Order (EO 11988)
Applicable
Applicable
Maine Hazardous Waate
Hanageaient Rules (38
M.R.S.A., Section 1301
ct aeq., Chapter 8S4)
Applicable
Under tbia requirement, no activity that
adveraely affects a vetland shall be
pemitted if a practicable alternative
that has leaser effects it available.
This act requires that any federal
agency that propose* to modify a body of
water mutt consult vith the U.S. Fish and
Wildlife Service. This requirement is
addressed under CVA, Section 404.
This act sett forth USEPA policy for
carrying out the provisions of the
Protection of Wetlands Executive Order
(EO 11990). Under this Order federal
agencies are required to minimize the
destruction, loss, or degradation of
wetland*, and preserve and enhance
natural and beneficial values of
vetland*.
This act replaced the Great Pond* Act;
Alteration of Rivera, Streams, and
Brook*; Freshwater Wetlands Act; and
Coattal Wetland Act*. Additionally, tbi*
law protect* fragile mountain areaa and
significant wildlife areas. Thi* act
prohibit* degradation or destruction of
these natural reaources by prohibiting
alteration ID or adjacent to a protected
natural area without a permit. Permit*
are required for variou* alternatives
including dredging, draining or dewatering;
filling; or altering a permanent itructure.
These regulations outline the criteria for
the construction, operation, and mainten-
ance of a new facility or increaie in
an existing facility for the storage,
treatment, or disposal of hazardous waste.
Specifically, BO portion of the site may
be located within a wetland.
A facility located in a 100-year flood-
plain must be designed, constructed,
operated, and maintained to prevent
washout of any hazardous wastes by a
100-year flood.
Thi* aet aeta forth USEPA policy for
carrying out the provisions of the '
Floodplaln Management Executive Order
(EO 11988). Under this order, federal
agencle* are required to minimize
potential harm to or within floodplainc
and to avoid the long- and short-tern
adverae impact* associated with the
occupancy and modification of floodplaina
These regulations outline the criteria
for the construction, operation, and
maintenance of a new facility or
increase in an existing facility for
the atorage, treatment, or disposal of
hazardous watte. Specifically, no
portion of the alte may be within '
300 feet of any 100-year floodplain.
-------
TABLE 14 (continued)
POTENTIAL LOCATION-SPECIFIC ARARS
O'CONNOR SITE
SITE.FIATURI,
RIOUIRIMENTL
STATUS
REQUIREMENT SYNOPSIS
Rim Breek
Federal Regulatory
Requiremeati
State Regulatory
Requirement*
Fiih and Wildlife Coordina- Applicable
tion Act (16 U.S.C. 661)
Maine Standards for Applicable
Clatiificatien of Fresh
Surface Waters (38 M.R.S.A.,
Chapter 3, Section 468)
Tbia act requires that any federal
agency that prepotet to modify a body of
water Bust cenault with the U.S. Fiih and
Wildlife Service. Thli requirement it alto
addreaaed under CVA, Section 404.
Kill* Brook is classified as a Class B
water body under the state water quality
standards.
Crouodwater
State Regulatory
Requirements
Other Natural
Resources
State Regulatory
Requirements
Maine Natural Resources
Protection Act (NRPA) (SI
M.R.S.A., Chapter 3,
Section 410)
Applicable
Maine Water Pollution
Control Law: Solid Waste
Disposal Areaa; Location
(30 M.R.S.A., Chapter 3,
Article 2, Section 421)
Maine Standards for
Classlficstion of
Crouodwater (38 M.R.S.A.,
.Chapter 3, Section 470)
Applicable
Applicable
Maine Site Location of Applicable
Development Law (38 M.I.S.A.,
Chapter 3, Section 484)
Maine - Regulations Applicable
of the Site Location of
Development Law (38 M.R.S.A.,
Chapter 3, Section 414 tt
seq., Chapttr S7S)
Maine Solid Waste Manage- Applicable
ment Rulea: Landfill
Disposal Facilities (38
H.R.S.A., Section 130) et
-seq., Chapters 400 - 406)
This act replaced the Croat Ponds Act;
Alterstion of Rivers, streams, and
brooks; Freshwater Wetlands Act; and
Coastal Wetland Acts. Additionally, this
lav protects fragile mountain areas sod
significant wild life areas. This act,
prohlbita degradation or destruction of
these nstursl resources by prohibiting
alteration in or adjacent to a protected
natural area without a permit. Permits
re required for various alternatives
including dredging, draining or dewaterlng
filling; or altering a permanent atructure
No boundary of any public or privatt
solid waste disposal area shall lie
closer than 300 feet to any classified
body of surface water. Alao known as the
Three Hundred Foot Lav.
Croundwater is classified under the
Maine standards as Class CW-A, which
stipulates that the groundwster be of
such quality that it can be used for
domestic purposes.
The development con not adversely affect
existing uses, scenic character, or nstursl
resources in the municipality or in neigh-
boring municipalities.
This requirement defines the natural re-
sources to which the site location act
applies.
Waste shsll be placed a minimum of 5 feet
above the seasonal high water table and
bedrock according to this requirement.
Also, the closing requirements for land-
fills ore outlined.
-------
ROD DECISION SUMMARY page 55
O'CONNOR CO. SITE
(1), as noted above. In the event that any substances continue
to fail EP toxicity or TCLP tests even following exhaustive
stabilization/solidification efforts, a treatability variance
under 40 CFR 268.44 will be sought so that the substance may
properly be land-disposed pursuant to LDR; thereby addressing
(2), as noted above. It should be noted that, regardless of
whether it becomes necessary to obtain a treatability variance
within the LDR framework, the ARAB itself will not be waived, but
rather the LDR requirements will be fully satisfied.
Apart from the applicability of LDR to characteristic wastes at
the Site, many other RCRA requirements address the same kinds of
actions that will be taken at the Site and are therefore relevant
and appropriate to the remedial activities. EPA will comply with
the substantive provisions of RCRA regulations governing:
Standards for Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities, General Facility Standards (40 .
CFR 264.10-264.18); Preparedness and Prevention (40 CFR 264.30- .
264.37); Contingency Plan and Emergency Procedures (40 CFR
264.50-264.56); Groundwater Protection (40 CFR 264.90-264.101);
Closure and Post-Closure (40 CFR 264.110-264.120, as interpreted
by EPA guidance for use at CERCLA sites where RCRA closure is
relevant and appropriate but not applicable); Landfills (40 CFR
264.300-264.317); Surface Impoundments (40 CFR 264.220-264.231);
and Waste Piles (40 CFR 264.250-264.259). In addition, for the
extract from the solvent extraction process that will be
transported off-site for incineration and the contaminated
surface waters being transported off-site for treatment, EPA will
comply with the relevant and appropriate RCRA regulations for
Standards Applicable to Generators and Transporters of Hazardous
Wastes (40 CFR 262 and 263) and Department of Transportation
Rules for Transportation of Hazardous Materials (49 CFR Parts
107, 171.1-172.558).
Under the Toxic Substances Control Act (TSCA), soils contaminated
with PCBs at concentrations greater than 50 ppm and that are
disposed of after February 17, 1978 roust be disposed of in
accordance with 40 CFR 761 Subpart D. Since the Site contains
PCBs at concentrations over 50 ppm, and since disposal will occur
after 1978 as part of the remedial action, TSCA regulations are
applicable to the selected source control action once excavation
takes place. These regulations require treatment by incineration
or its destruction equivalent, or chemical waste landfilling.
EPA's selected remedy will meet this requirement through
treatment by solvent extraction of PCB-contaminated soils and
sediments and incineration of the extracted PCBs. EPA has
determined that the destruction of PCBs down to concentrations of
less than 2 ppm constitutes an equivalent level of performance to
incineration within the meaning of § 761.60(e) of TSCA. The
selected remedy satisfies the equivalency determination by
-------
ROD DECISION SUMMARY page 56
O'CONNOR CO. SITE
requiring that the solid residue from the solvent extraction
process which contains PCBs in concentrations greater than 1 ppm
be disposed of in a chemical landfill as defined in § 761.75 of
TSCA. Thus, the selected remedy will fulfill TSCA's requirements
through both treatment by a process which achieves a level of
performance equivalent to incineration (solvent extraction) and
disposal within a TSCA-permitted, chemical waste landfill.
The TSCA PCB Spill Cleanup Policy (40 CFR 761 Subpart G) is not a
binding regulation but a statement of EPA policy. Thus, it is
not an ARAR at the Site but is a TBC. The Policy requires that
spills of PCBs at unrestricted access sites be cleaned up to a
level of 10 ppra, with a minimum of 10 inches of soil removed from
the surface of the entire spill area and replaced with soil
containing less than 1 ppm PCBs. The selected remedy is
consistent with this requirement because all soils above 1 ppm
PCBs will be excavated and treated, with only soils below 1 ppm
PCBs being returned to the unrestricted area.
Regulations under the Occupational Safety and Health Act (OSHA)
apply to the performance of the remedial action as it involves
workers at the Site. EPA will comply with the OSHA regulations
including the General Industry Standards (29 CFR 1910); Safety
and Health Standards (29 CFR 1926); and the substantive
provisions of the Record Keeping, Reporting and Related
Regulations (29 CFR 1904).
The National Primary and Secondary Ambient Air Quality Standards
(40 CFR Part 50), promulgated under the Clean Air Act, are
relevant and appropriate to the selected remedy. During the
excavation and treatment of contaminated soils and sediments at
the Site and during the groundwater treatment, air emissions will
be monitored and the NAAQS (i.e., PM-subscript 10, total
suspended particulate-TSP, lead, etc.) will be attained through
the use of appropriate air pollution control equipment.
With respect to the unavoidable impacts of the cleanup on the
wetland areas at the Site (since there are no practicable
alternatives), the selected remedy will also meet the
requirements of the Clean Water Act (CWA), the Fish and Wildlife
Coordination Act (FWCA), and the Protection of Wetlands and
Floodplain Management Executive Orders (EO 11990 and EO 11988).
No pollutants or any other materials will be discharged to
surface waters. The removal of contaminated soils, sediments and
surface water from the wetland areas/waters of the U.S. on the
Site (the upper and lower lagoons and the upland march) will
comply with the regulations and guidelines under section 404 of
CWA. EPA will avoid degradation of these areas to the maximum
extent possible through careful construction practices and will
create wetlands at the Site to compensate and restore those
-------
ROD DECISION SUMMARY page 57
O'CONNOR CO. SITE
wetland areas that are affected by the remedial action. As
required by FWCA, EPA has preliminarily consulted with the U.S.
Fish and Wildlife Service concerning the effect of the proposed
remedy on these wetland areas.
b. State
The selected remedy will also attain action-specific Maine ARARs,
including the Maine Freshwater Wetlands Act (38 M.R.S.A., Chapter
3, sections 405-410); the Maine Hazardous Waste Management Rules
at 38 M.R.S.A., sections 1301 et sea.. Chapters 850, 851, 853-
857, sections 1319 et seq.. Chapters 800-801, sections 1304 et
seq.. Chapter 802, and Chapter 3, article 2, section 420;
Groundwater Protection Regulations at 38 M.R.S.A. Chapter 3,
article 4A, section 470; and Ambient Air Quality Standards at 38
M.R.S'.A. section 584, Chapter 110. In addition, construction of
grouhdwater monitoring wells will comply with Maine DEP, Bureau
of Water Quality Control regulations, chapter 543, which apply "
only to injection wells but may be relevant and appropriate to '
the selected remedy.
2. Chemical-specific ARARs
In determining which contaminants at the Site required
remediation, EPA consulted both Federal and State ARARs as well
as other criteria for protectiveness. As a result, EPA has set
target cleanup goals for three soil contaminants (PCBs, cPAHS,
and lead), three surface water contaminants (PCBs, lead, and
aluminum), and three groundwater contaminants (PCBs, benzene, and
1,4-dichlorobenzene).
While no ARARs apply to any of the soil contaminants and/or
cleanup levels established for the Site, it should be noted that
EPA's target cleanup level for PCBs in the soil is consistent
with the TSCA Spill Cleanup Policy which is TBC. The selected
cleanup levels are also consistent with one other TBC, the Maine
Rules for the Land Application of Sludge and Residuals.
There are no federal or state regulatory requirements governing
the ambient concentrations of chemicals in surface water bodies.
In the absence of such ARARs, as noted earlier, EPA relied upon
the AWQC guidelines to the extent possible in establishing
cleanup levels.
ARARs for the groundwater contaminants at the Site include the
Federal Maximum Contaminant Levels (MCLs) promulgated under the
Safe Drinking Water Act (40 CFR Part 141, Sections 141.11-141.16)
and the State of Maine's MCLs (10-144A C.M.R., Chapter 231) and
Maximum Exposure Guidelines (MEGs) (10-144A C.M.R., Chapter 233).
Both the MCLs and MEGs are legally applicable only at the tap and
-------
ROD DECISION SUMMARY page 58
0CONNOR CO. SITE
not to an aquifer directly. Since the groundwater at the Site,
classified as Class IIB under the EPA groundwater protection
strategy, is being considered a possible source of drinking
water, the Federal MCLs are relevant and appropriate in' setting
cleanup levels. Similarly, Maine classifies all groundwater in
the state as a minimum Class GW-A, suitable for drinking water,
rendering the State MCLs and MEGs relevant and appropriate as
well. The selected groundwater remedy at the Site will meet the
standards set by these ARARs.
Air emissions from the Site will comply with the NAAQS for
Particulates (40 CFR 50.6), an applicable requirement, and the
EPA Interim Policy for Planning and Implementing CERCLA Response
Actions, Proposed Rule, 50 FR 45933 (November 5, 1985), a TBC.
3. Location-specific ARARs
As part of the source control portion of the remedy, certain
contaminated soils/sediments will be excavated and contaminated '
surface waters pumped from three wetland areas, the upper and
lower lagoons and the upland marsh. Because there is no
practicable alternative to this action in order to achieve the
goals established for the Site, these man-made wetlands will be
destroyed during remediation. EPA will, to the maximum extent
possible, restore the areas affected by the remedial action
through the creation of compensatory wetlands and the use of
careful construction methods. As discussed earlier in connection
with action-specific ARARs, the remedial action will comply with
section 404 of the Clean Water Act, and with standards set by
Maine requirements, including the Maine Freshwater Wetlands Act
(38 M.R.S.A. Chapter 3, sections 405-410) and the Maine Hazardous
Waste Management Rules (38 M.R.S.A. sections 1301 et sea..
Chapters 401, 850, 851, 853-857, sections 1319 et sea. Chapters
800-801, and sections 1304 et sea.. Chapter 802), which govern
actions taking place in a wetland. The remedial action will also
comply with the Wetlands Executive Order (E.O. 11990), which is
binding on EPA as a Federal agency, and the Fish and Wildlife
Coordination Act (16 U.S.C., section 661). EPA has preliminarily
consulted with the U.S. Fish and Wildlife Service concerning the
effect of the selected remedy on the wetland areas on- and off-
site, as required by the Fish and Wildlife Coordination Act.
The other wetlands identified in the Site area will not be
directly affected by site remediation activities, and EPA will
ensure their protection through any necessary sedimentation and
erosion controls.
The selected remedy will comply with the Floodplain Management
Executive Order (E.O. 11988) and EPA regulation 40 CFR Part 6,
which implements the Executive Order. The source control portion
-------
ROD DECISION SUMMARY page 59
O'CONNOR CO. SITE
of the remedy will have minimal effects on the 100-year
floodplain located on the Site. This is due to the fairly
limited extent of the floodplain within contaminated portions of
the Site, and the use of careful construction practices during
excavation to minimize any adverse impacts on the floodplains.
The remedial action will also comply with the Maine Site Location
Law (38 M.R.S.A. Chapter 3, sections 481-490), which prohibits
adverse impacts on certain natural resources.
C. The Selected Remedial Action is Cost-Effective
Of those remedial alternatives that are protective and attain
ARARs, and satisfy the preference for treatment to the maximum
extent practicable, EPA selected the remedy that is cost-
effective in mitigating the risks posed by the soil, sediments,
surface waters, and groundwater on- and off-site within a
reasonable period of time. Overall, the total cost (present
worth) of the selected remedy is estimated at $14.22 million as
presented in Table 15.
The estimated total present worth cost of the source control
component of the selected remedy is approximately $ 13.32
million. This total cost is comprised primarily of $ 5.9 million
for the excavation and on-site treatment of the contaminated
soils and sediments, and $ 1.72 million for off-site disposal of
the approximately 5,000 cubic yards of contaminated solid
treatment residues from the solvent extraction.process exceeding
the established target cleanup goals for the Site and/or the
solidified lead-contaminated materials which may be determined to
be a characteristic hazardous waste prior to solidification.
This cost is higher than that of some of the other source control
alternatives; however, none of the less expensive technologies
can ensure that the treated soil will reach the target cleanup
goals and also provide long-term effectiveness and permanence
without additional management (institutional) controls being
established on the Site. Additionally, EPA has determined that
this remedy will yield results that are in proportion to its cost
in terms of implementability and effectiveness. Thus, while the
treatment"alternatives which included dechlorination and the
other solvent extraction alternative evaluated are cheaper than
the selected source control alternative, they do not provide the
same degree of permanence or effectiveness over the long-term.
Additionally, the selected source control remedy is less
expensive than the on-site incineration or in-situ vitrification
of the contaminated soils and sediments. Moreover, the selected
approach avoids the potential for air emissions impacts which
would likely result from on-site incineration, and possibly in-
situ vitrification, due to the co-located lead-contaminated soils
-------
Page 59A
Teble 15
O'CONNOR SITE
ESTIMATED COST OF SELECTED REMEDY
SUMMARY
"ESTIMATED
ITEM COST
1. Source Control Component $13,319,000
2. Management of Migration Component 679,000
3. Riggs Brook Sediment Minimal No-Action Component 223,000
ESTIMATED TOTAL COST: $14,221,000
-------
ROD DECISION SUMMARY page 60
O'CONNOR CO. SITE
on the Site.
The estimated total present worth costs of the management of
migration component (which includes groundwater and Riggs Brook
sediment remediation) of the selected remedy is estimated to
total $ 902,000. Operation and maintenance costs (net present
worth) comprise approximately 95 % or $ 855,000 of this total.
This cost is approximately equal to the costs of all other
management of migration alternatives considered, while providing
treatment of the primary contaminants to the target levels
established in a shorter period of time than MM-1 and extensive
monitoring with no significant detrimental effects to the
environment in and around the Site as contrasted with SE-2.
Tables 16, 17, and 18 present an itemized cost breakdown of the
source control and management of migration (groundwater and Riggs
Brook sediment) components, respectively, of the selected remedy
in terms of the major activities, estimated volumes of materials
addressed, and the estimated unit costs. While these costs are
within the +50 percent to -30 percent accuracy required for
Feasibility Study estimates, some changes may be made as a result
of the remedial design and construction processes involved after
the ROD is signed. These changes, in general, reflect
modifications resulting from the engineering design process.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable
Both the source control and management of migration components of
the selected remedy are expected to provide permanent solutions
to the contamination problem at the Site. Solvent extraction
permanently removes PCBs and the other organic contaminants of
concern from the soil, while incineration destroys these
contaminants almost completely. The pumping and off-site
treatment of surface waters will also permanently remove
contaminants of concern from the environment. As a result,
remediation of the Site soils, sediments, and surface waters will
permanently reduce the risks associated with exposure to these
three .media to levels which are protective of human health and
the environment. In addition, removal of the contaminants in
these source areas will reduce the migration of contaminants into
the groundwater, thereby increasing the effectiveness of the
groundwater treatment component of the remedy.
Both solvent extraction and incineration are alternative
treatment technologies; thus, the selected remedy also satisfies
the requirement that the remedy selected utilize alternative
treatment or resource recovery technologies to the maximum extent
practicable.
-------
Page 60A
Table 16
O'CONNOR SITE
ESTIMATED COST OF SELECTED REMEDY
SOURCE CONTROL COMPONENT
CAPITAL POSTS;
ESTIMATED ESTIMATED
ITEM QUANTITY COST
1. Drain and treat/dispose
of lagoon and marsh
water 165,000 gal. $ 102,000
2. Reroute surface water lump sum 25,000
3. Decontaminate/demolish
barn lump sum 3,000
4. Excavate contaminated 23,500 cy 212,000
soil
5. Trcjitmsnt of 23,500 cy 5,726,000*
contaminated soil
6. Transportation and off-
site landfilling of
treated soil not meeting
cleanup goals 5,000 cy 1,715,000
7. On-site backfilling of 18,500 cy 69,000
treated soil
8. Compensatory wetlands 0.5 acre 75,000
9. Health and Safety 50% of Items 1 thru 4
premium (level D) 171,000
SUBTOTAL $ 8,118,000
Undeveloped Design Details (25%) $ 2,030,000
Total Estimated Capital Costs
w/Undeveloped Design Details $10,148,000
Engineering (5%) $ 507,000
Contingency (25%) $ 2,664,000
Total Estimated Capital, Engineering,
and Contingency Costs (Present Worth) $13,319,000
OPERATION t MAINTENANCE COSTS;
Monitoring, Maintenance, and 5-yr Review -0-
ESTIMATED TOTAL COST (Present Worth) $13,319,000
-------
Page 60S
Table 17
O'CONNOR SITE
ESTIMATED COST OF SELECTED REMEDY
MANAGEMENT OF MIGRATION COMPONENT
CAPITAL COSTS:
ESTIMATED
ITEM COST
1. Install extraction well and treatment system $ 48,000
OPERATION AND MAINTENANCE COSTS;
1. Treatment system operation and maintenance
Year 1: $36,000
Years 2-30: $20,000/yr
i
Estimated Present Worth: $323,000
2. Environmental Monitoring
Years 1-30: $20,000/yr
Estimated Present Worth: $308,000
Total Esitmated Operation & Maintenance Cost $631,000
ESTIMATED TOTAL COST (Present Worth) $679,000
-------
Table 18
O'CONNOR SITE
ESTIMATED COST OF SELECTED REMEDY
RIGGS BROOK SEDIMENT
MINIMAL NO-ACTION COMPONENT
Page &OC
ITEM
1. Sediment and Biota Monitoring
Sediment (Years 2-10J1
Biota (year 5)2
2. Annual Education Programs
(Years 2-30)
3. Five-Year Site Review
(Years 5-30)
ESTIMATED
COST
$ 9,000/yr
$ 27,000
$ 5,000/yr
$ 20,000/5 yr
Estimated Present Worth (Items 1-3)
ESTIMATED TOTAL COST (Present Worth)
Sediment monitoring will be begin after implementation of the source
control remedial action.
Biota sampling is anticipated once after five years of sediment
sampling. However, additional rounds of biota campling will be
conducted if significant increases over 5-ppm PCBs occur in the
sediments.
-------
ROD DECISION SUMMARY page 61
O'CONNOR CO. SITE
The management of migration portion of the remedy also utilizes a
treatment method which will result in the permanent removal of
most target contaminants. Through the collection and treatment
of the contaminated groundwater, this remedy ensures that the
groundwater leaving the site is restored to a level protective of
human health and the environment. Use of temporary institutional
controls will also ensure that the on-site groundwater poses no
risk during this phase of the overall Site remediation process.
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The principal component of the selected source control remedy
consists of treating all soils and sediments above the target
cleanup levels through a solvent extraction process, and
incinerating the extract. The selected remedy thus addresses the
principal threat posed by the Site soils and sediments through .
the use of treatment technologies. In addition, the principal
threat posed by groundwater contamination at the Site will be
addressed through treatment of the groundwater by carbon
adsorption. The selected remedy thus satisfies the preference
for treatment as a principal element of this Superfund remedy.
-------
ROD DECISION SUMMARY page 62
O'CONNOR CO. SITE
XII. STATE ROLE
The State of Maine, Department of Environmental Protection (DEP)
has reviewed the various alternatives and has indicated its
support for the selected remedy. The State has also reviewed the
Remedial Investigation, Endangerment Assessment and Feasibility
Study to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State environmental laws
and regulations. The State of Maine concurs with the selected
remedy for the O'Connor Co. Site. A copy of the declaration of
concurrence is attached as Appendix D.
-------
EXHIBIT A
Community Relations Activities Conducted
at the O'Connor Co. Site
in Augusta, Maine
Community relations activities conducted at the O'Connor Co. Superfund
site include:
October 27, 1984 - EPA issued a press release stating that EPA
ordered the F. O'Connor Company to fence and post its property on
Route 17 and to sample and analyze the contents of drums and
storage tanks onsite.
September 1985 - EPA released a community relations plan
describing citizen concerns about the site, outlining a program to
address these concerns, and discussing how EPA intends to keep
citizens informed about and involved in site activities.
May 13, 1986 - EPA issued a press release announcing that the
Central Maine Power Company and the F. O'Connor Company entered
into a consent agreement with EPA to study hazardous waste
contamination at the O'Connor Co. site.
June 11, 1986 - EPA held an informational meeting to describe the
plans for the Remedial Investigation and Feasibility Study (RI/FS).
March 25, 1987 - EPA issued a press release announcing that the
Central Maine Power Company and the F. O'Connor Company entered
into a modified consent agreement with EPA and the Maine
Department of Environmental Protection (DEP) to investigate waste
contamination at the site.
July 1989 - 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 12, 1989 - EPA issued a public notice in the Kennebec Journal to
announce the time and place of the public informational meeting for
the site, provide a brief analysis of the Proposed Plan, and invite
public comment on the Feasibility Study (FS) and the Proposed Plan.
-------
July 13, 1989 - EPA made the Administrative Record available for
public review at EPA's offices in Boston and at the Lithgow Public
Library in Augusta.
July 19, 1989 - EPA held a public informational meeting to discuss
the results of the RI/FS and EPA's Proposed Plan.
July 20 - August 19, 1989 - EPA held a public comment period on
the Proposed Plan.
August 10, 1989 - EPA held an informal public hearing to accept
comments on the remedial alternatives evaluated in the FS and on
the Proposed Plan.
-------
RESPONSIVENESS SUMMARY
FOR THE
O'CONNOR CO. SUPERFUND SITE
AUGUSTA, MAINE
Public Comment Period:
July 20 through August 19, 1989
September 1989
Prepared for:
U.S. Environmental Protection Agency
Region I
Prepared by:
Booz-Allen & Hamilton Inc.
under Subcontract Number TES V-BAH-1, WA Number C01018
with COM Federal Programs Corporation
-------
Table of Contents
Page
Preface 3
I. Overview of the Remedial Alternatives Considered in
the Feasibility Study, Including the Preferred
Alternative 5
Alternatives Considered in the Feasibility Study 6
EPA' s Preferred Alternative 7
II. Background on Community Involvement and Concerns 9
III. Summary of Comments Received During the Public Comment
Period and EPA Responses to these Comments 10
Part A - Citizen Comments 10
Part B - State of Maine Comments 12
. Part C - Potentially Responsible Party Comments 14
IV. Remaining Concerns 25
-------
Preface
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 20, 1989 through August 19,-1989 to
provide an opportunity for interested parties to comment on the
Remedial Investigation (RI) and Feasibility Study (FS) reports,
and the July 1989 Proposed Plan prepared for the O'Connor Co.
Superfund site (the "Site") located in Augusta, Maine. The RI,
which examined the nature and extent of contamination at the Site,
and the FS, which examined and evaluated various options (referred
to as remedial alternatives) for addressing the contamination at
the Site, were released to the public on July 13, 1989. EPA
identified its preferred alternative for cleaning up the Site
within the Proposed Plan before the start of the public comment
period.
The purpose of this responsiveness summary is to identify the
major comments raised during the public comment period and to
provide EPA responses to these comments. EPA considered all of
the comments summarized in this document before selecting a final
remedial alternative for addressing the contamination at the Site.
This responsiveness summary is divided into the following
sections:
I. Overview of the Remedial Alternatives Considered in the
Feasibility Study. Including the Preferred Alternative -
This section briefly outlines the remedial alternatives that
are described and evaluated in the FS and the Proposed Plan.
II. Background on Community Involvement and Concerns - This
section provides a brief history of community interests and
concerns regarding the Site.
III. Summary of Comments Received Purina the Public Comment
Period and EPA Responses to these Comments - This section
summarizes both the written and oral comments received by EPA
during the public comment period, and provides EPA responses
to these comments. Part 1 contains comments received by
citizens. Part 2 contains those comments received from the
Potentially Responsible Parties (PRPs). A brief summary of
the PRPs1 comments precedes EPA's responses.
IV. Remaining 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 Site.
EPA will address these concerns during the Remedial
Design/Remedial Action (RD/RA) phase of the cleanup process.
-------
Also attached to this responsiveness summary are the following
exhibits:
Exhibit A - This exhibit is a list of the community
relations activities that EPA has conducted to date at the
Site.
Exhibit B - This exhibit is a copy of the transcript from
the public hearing that was held August 10, 1989.
-------
I. OVERVIEW OF THE REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY, INCLUDING THE PREFERRED ALTERNATIVE
Using the information gathered during the Remedial Investigation
(RI) and the results of the Endangerment Assessment (EA) prepared
for the Site, EPA identified several objectives for the cleanup of
the Site. These response objectives are:
1. Reduce potential present and future public health and
environmental risks from direct contact, ingestion, and/or
dermal absorption with the polychlorinated biphenyl (PCB)-,
carcinogenic polycyclic aromatic hydrocarbon (cPAH)-, and
lead-contaminated soils and sediments located on and off the
Site.
2. Reduce potential present and future public health risks from
the inhalation of PCB vapors generated from the Site.
3. Reduce potential present and future public health risks from
the ingestion of PCB-contaminated fish from Riggs Brook.
»
4. Reduce potential future public health risks from the
ingestion of the PCB-, benzene-, and
1,4-dichlorobenzene-contaminated groundwater found on the
Site.
5. Reduce potential present and future environmental risks to
aquatic and terrestrial wildlife from exposures to the PCB-,
lead-, and aluminum-contaminated on-site surface water.
Central Maine Power (CMP), a PRP, performed the RI and prepared
the FS for the Site with EPA and State of Maine Department of
'Environmental Protection (DEP) oversight. The Feasibility Study
(FS) report was specifically prepared to describe all the possible
remedial alternatives that could be considered for addressing the
groundwater, soil, sediment and surface water contamination
present at the Site. The FS also describes the screening criteria
used to narrow the list of possible alternatives from 17 to the 14
remedial alternatives that were retained for further
consideration. The 14 remaining alternatives that underwent a
detailed evaluation in the FS included: ten (10) remedial
alternatives (referred to as source control or SC alternatives)
for addressing the on-site soil, sediment, and surface water
contamination; two (2) remedial alternatives to address the
groundwater contamination (referred to as management of migration
or MM alternatives); and two (2) remedial alternatives for
addressing the sediment contamination within Riggs Brook (referred
to as sediment or SE alternatives). Each of these alternatives
are listed below:
-------
Alternatives Considered in the Feasibility study
Source Control (SC) Alternatives ~
SC-1: Minimal No-Action.
SC-2: Site Capping.
SC-3: On-Site-Disposal Facility.
SC-4: Off-Site Disposal at a TSCA Landfill.
SC-5: On-Site Incineration.
SC-6: On-Site Solidification.
SC-7: On-Site Vitrification.
SC-10: On-Site Alkali Metal Dechlorination.
SC-11A: On-Site Solvent Extraction and Disposal of Treated Soils.
SC-11B: On-Site Solvent Extraction and Off-Site Disposal of
Lead-Contaminated Soils.
Management of Migration (MM) Alternative*
MM-1: Minimal No-Action.
MM-.3: Groundwater Extraction and On-Site Treatment.
Riggs Brook Sediment (BE) Alternatives
SE-1: Minimal No-Action.
SE-2: Excavation and Off-Site Disposal of Contaminated Sediments.
-------
EPA's Preferred Alternative
In the Proposed Plan issued prior to the public comment period,
EPA recommended the following preferred alternatives for
addressing the soil, sediment, surface water, and groundwater
contamination at the Site. The individual source control (SC),
management of migration (MM), and sediment (SE) components of the
preferred alternative are briefly described below:
SC Preferred Alternative; On-Site Solvent Extraction of
Contaminated On-Site Soils and Sediments. For this alternative,
contaminated on-site soils and sediments would be excavated and
treated at the Site using a solvent extraction technology. This
process would involve the use of solvents to remove the PCBs and
other organic chemicals found in the contaminated soils and
sediments. The technology concentrates the organics into a liquid
which would be destroyed at an approved off-site facility. For
this component of the preferred alternative, an estimated 23,500
cub.ic yards of contaminated soils and sediments exceeding the
target cleanup goals established for the Site would require
excavation and on-site treatment. Treatment residues exhibiting
hazardous waste characteristics would be solidified to the maximum
extent practicable while treatment residues continuing to exceed
target cleanup levels would be disposed of in a licensed chemical
waste landfill.
SC Preferred Alternative: Off-Site Treatment of Contaminated
On-Site Surface Waters. For this alternative, EPA proposed to
pump between 150,000 and 195,000 gallons of contaminated, on-site
surface water from the upper and lower lagoons and the upland
marsh located on-site, and transport the contaminated water to a
permitted, off-site treatment facility. Culverts and drainage
ditches would be installed to reroute the current, on-site
drainage patterns toward the southwest, around contaminated areas
on the Site, along Route 17. This rerouted drainage would
eventually discharge into the west branch of Riggs Brook.
MM Preferred Alternative! Groundwater Extraction and On-Site
Treatment with Carbon Adsorption. This alternative would entail
construction of one or more deep bedrock extraction wells to
collect contaminated groundwater. Collected groundwater would
then be pumped through a filter to remove solids and/or oil
droplets suspended in the water. Following this preliminary step,
the contaminated groundwater would be treated on-site using
granular activated carbon which would remove the organic
(carbon-containing) contaminants from the water. All treated
groundwater would be discharged back into the ground once it
achieved the target cleanup goals established for the Site.
-------
SE Preferred Alternative; Minimal No-Actiont EPA proposed the
minimal no-action alternative to manage the localized areas of PCQ
contamination within the Riggs Brook sediment. The .alternative
entailed continuously monitoring Riggs Brook sediments and biota
(fish), instituting educational programs for the local community,
and not disturbing the currently localized PCB-contaminated
sediments through excavation activities.
8
-------
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Site is a nine-acre portion of land located within a larger
65-acre parcel owned by the F. O'Connor Co. It is located on U.S.
Route 17, approximately three miles east of the center of Augusta,
Maine.
The property was used as farmland until the F. O'Connor Co.
purchased the property in 1952 and established a salvage yard and
transformer recycling operations. The handling and dismantling
of transformers resulted in oil spills containing PCBs and was
the focus of initial sampling efforts by the Maine Department of
Environmental Protection (DEP) and EPA. These sampling
activities focused on the soils and sediments at the Site, and on
surface waters in the lagoons. In September 1983, the Site was
added to the National Priorities List (NPL), EPA's list of top
priority hazardous waste sites. The listing of this Site made it
eligible to receive federal funds for investigation and cleanup
under the Superfund program.
The Site is located on the outskirts of the city of Augusta. The
population density near the Site includes approximately 50 homes
which lift within one-quarter mile of the Site. Currently, there
is no extensive development occurring along Route 17 in the area
of the Site, however, a new elementary school was recently built
approximately one-half mile west of the Site along Route 17.
Community interest in Site activities has been low to moderate but
sustained among the citizens living near the Site. At the July
1989 public meeting, community concerns focused on future use of
the Site, health effects of Site contamination, the extent of
Site contamination, and responsibility for the Remedial
Design/Remedial Action (RD/RA) phase.
-------
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA iXESPONSES TO THESE COMMENTS
This responsiveness summary addresses the comments received by
EPA concerning the Remedial Investigation (RI) and Feasibility
Study (FS) reports, and the Proposed Plan for the O'Connor Co.
Superfund site (the "Site") in Augusta, Maine. 'Two formal sets of
written comments were received during the public comment period
(which occurred from July 20, 1989 through August 19, 1989): one
from a vendor of environmental services and one set from Central
Maine Power. Three oral comments were presented at the August 10,
1989 informal public hearing. A copy of the transcript from the
public hearing is attached as Exhibit B to this responsiveness
summary.
PART A - CITIZEN COMMENTS
The comments received verbally from citizens and in writing from a
vendor, and EPA's responses to these comments are summarized
be 1'ow.
Comment 1.
One citizen stated he would like to see the site cleaned up so
that the property is useable again; not just filled over.
EPA Response;
The comprehensive, multi-component approach for overall
remediation of the Site, as described in the Record of Decision
(ROD), will allow for unrestricted use of the Site while, at the
same time, providing overall protection of human health and the
environment through treatment (to the maximum extent practicable)
and, as appropriate, off-site disposal of any residual materials
that continue to be hazardous and/or exceed target cleanup levels.
Both the State of Maine and Central Maine Power (CMP) expressed
the preference, during the public comment period, for off-site
disposal of all residuals above target cleanup levels over the
creation of an on-site landfill to dispose of these residuals
which would require extensive and expensive long-term monitoring
and maintenance and limit the Site's usefulness for other
purposes.
Comment 2.
One citizen stated that she didn't care how much it cost; she
wanted to see the site cleaned up and left the way it was found.
EPA Response;
As discussed above in response to citizen comment 1, the selected
10
-------
remedy for the Site is a comprehensive approach that is protective
of human health and the environment and that utilizes treatment,
to the maximum extent practicable, which will permanently and
significantly reduce the volume, toxicity and mobility of
hazardous substances that existed on the Site. Additionally, as
is discussed in further detail in response to PRP comments, the
selected remedy will achieve these statutory requirements while
being cost effective. In evaluating a range of remedial
alternatives, EPA is required to consider cost, in addition to
technology, reliability, administrative and other concerns, and
their relevant effects on public health and welfare and the
environment [NCP, 40 CFR Part 300, Section 300.68 (i)].
Therefore, in contrast to the wishes expressed in this comment,
cost was considered in selecting the appropriate response action
for the Site. Still, as noted in response to Citizen Comment 1,
the selected remedy will allow for unrestricted use of the Site.
Comment 3.
One citizen expressed concerns about the PRP's proposal to cover
remaining contamination at the Site with 10 inches of soil. These
concerns focused on whether someone living in the area could plant
trees or do landscaping, which would involve digging down more
than 10-inches, without coming into contact with the remaining
contamination; and whether the next generation of children could
safely play in the area.
EPA Response;
These concerns reflect some of the same uncertainties and
potential unacceptable risks which led EPA to reject CMP's
proposal in favor of the selected remedy.
Comment 4.
Harmon Environmental Services believes that the physical/chemical
stabilization which it demonstrated in its treatability study for
E.G. Jordan is superior to solvent extraction, the selected
alternative. Harmon also believes that if funding had been
provided, it could have demonstrated more aggressive chemical
stabilization and substantial reduction in total PCBs, and
thereby, meet all relevant response objectives with a soil cover
for the stabilized material.
EPA Response:
First, as was indicated in the Proposed Plan issued in July 1989,
the treatability study results provided by CMP from Harmon did not
appear to demonstrate that solidification is superior to solvent
extraction. While the results from the solvent extraction
treatability study demonstrated the effectiveness and consistent
removal of PCBs from the Site soils tested, the results provided
11
-------
to EPA from the solidification treatability study did not prove
that the PCBs had been effectively stabilized. In fact, the
results suggest that only a 50% to 75% reduction in the
leachability of PCBs was achieved. Furthermore, the~available
data from other treatability studies using stabilization do not
suggast that PCBs can be immobilized.
Secondly, EPA's response objectives included the restoration of
the Site to a level that is protective of human health and the
environment and that provides long-term permanence. As Harmon
indicates in their comment, "Harmon believes physical/chemical
stabilization combined with a soil cover (emphasis added) for the
stabilized material, will meet all relevant response objectives."
EPA believes that this will not meet all objectives since
stabilization is not considered a permanent remedy. Furthermore,
<:he integrity of a soil cover (as discussed in the ROD) is
uncertain over the long-term.
Finally, the funding provided to Harmon was provided from CMP and
not from EPA. If this funding was inadequate to better prove the
effectiveness of this technology, then Harmon should have worked
this matter out with CMP and, in turn, notified EPA. In fact, EPA
suggested to CMP in November 1988, that if CMP wished to pursue a
solidification treatability study on its own, CMP was more than
welcome to do so. In addition, CMP had ample time in which to do
so. In any event, EPA is not persuaded that further expenditures
would have shown solidification to have been a 'more suitable
technology than solvent extraction.
PART B - STATE OF MAINE COMMENTS
Comment 1. The Management of Migration Alternative
The Maine Department of Environmental Protection (DEP) stated at
the public hearing that the State concurs with EPA's selection of
the Management of Migration Alternative MM-2: Groundwater
Extraction and On-site Treatment with Activated Carbon Absorption,
with the understanding that Alternative MM-2 will extract
contaminated groundwater, treat the groundwater to comply with
federal and state ARARs, and reinject the water into the aquifer.
Institutional controls that prohibit the construction and use of
any and all groundwater wells within the aquifer must be
established until such time as the clean-up objectives are met.
EPA's Response;
DEP's understanding of what the selected management of migration
option will entail is consistent with EPA's view of this remedial
component. EPA agrees that institutional controls should be
established pending the completion of groundwater treatment, and
the ROD so provides.
12
-------
Comment 2. The Source Control Alternative
The DEP conditionally concurs with the proposed Source Control
Alternative SC-11A: On-site Solvent Extraction of Contaminated
On-site Soils and Sediments with Off-site Treatment of
Contaminated On-site Surface Water. As presented, DEP understands
that the SC-11A Alternative will consist of the following: (a)
all contaminated, on-site surface water from the upper and lower
lagoons and the upland marsh will be pumped and transported to a
permitted, off-site treatment facility; (b) the on-site barn will
be cleaned, demolished and disposed of off-site; (c) all on-site
soils and sediments exceeding any of the target clean-up goals of
1 ppm PCBs, 1 ppm cPAHs or 248 ppm lead (approximately 23,500 cy)
will be treated by on-site solvent extraction; (d) solid residues
from the solvent extraction process that both achieve all EPA
target clean-up goals and pass EPA's standard extraction procedure
(EP) toxicity tests will be placed back in the excavated areas;
and (e) ultimate disposition of solid residues that fail EPA
toxicity, fail to meet a clean-up goal or both will be determined
following the public comment period.
The DEP understands that one of EPA's options for disposing of the
solid residues referred to in point (e) above, is placement back
on-site in a stabilized/solidified state or in a RCRA/TSCA
landfill. The DEP will not concur with a plan which would include
leaving any residues on-site, particularly if it involves creating
a RCRA/TSCA landfill within Augusta city limits. A landfill of
this nature would require extensive and expensive long-term
monitoring and render the site forever useless for any other
purpose. The DEP urges EPA to make every attempt to acquire the
necessary waivers or treatability variances necessary to allow
this material to be disposed of at an existing off-site facility.
EPA Response;
In accordance with the expressed preference of the State and the
community, and in the interest of achieving consistency with the
overall scope and role of the response action at the Site, EPA has
opted to dispose of the residues in question at an off-site
facility. This determination is set forth in Section VII of the
ROD.
13
-------
PART C - POTENTIALLY RESPONSIBLE PARTY COMMENTS
EPA received extensive comments from one of the PRPs, Central
Maine Power (CMP), during the public comment period. These
comments and EPA's responses are set forth below.
Comment 1. Overview of CMP's Comments
In all respects except one, the EPA plan and the CMP plan are
identical. The one significant difference being the remediation
of contaminated soils and sediments. The EPA plan, which calls
for excavation of all soils and sediments with greater than 1 ppm
PCBs and cPAHs at a cost of approximately $ 12,303,000, is simply
not cost-effective. The EPA plan over-estimates the performance
of the solvent extraction process, leading to an improper
balancing of the reduction of toxicity, mobility or volume
factors, implementability factors, and cost factors. The CMP plan
calls for the excavation of all soils and sediments with greater
than 10 ppm PCBs and cPAHs at a cost of $ 5,882,000, and is
therefore more cost-effective. The CMP plan utilizes the same
technologies as the EPA plan, is protective of human health and
the environment, and can be implemented.
CERCLA and the 1985 NCP require EPA to select a remedy that in a
cost-effective manner provides effective protection of human
health and the environment. In addition, as provided in the 1988
proposed NCP, the selected remedy should achieve the best balance
of trade-offs among alternatives in terms of long-term
effectiveness factors; reduction of toxicity, mobility, or volume
factors; short-term effectiveness factors; implementability
factors; and cost factors. Finally, under the 1988 proposed NCP,
EPA must document its selection of a remedy and explain "how the
remedy provides overall protectiveness proportional to its costs."
Under these circumstances the similarity in effectiveness and
implementability and the dramatic difference in the cost to remove
an additional 2% of the PCBs from the Site CERCLA, the 1985
NCP, and the 1988 proposed NCP require the selection of the CMP
alternative.
EPA Response t
EPA disagrees with CMP's interpretation of the law as applied to
these facts. In EPA's view, a fair reading of CERCLA and the NCP
requires that CMP's remedy be rejected in favor of the selected
remedy.
As CMP recognizes, EPA's remedy selection process is governed by
CERCLA and the National Contingency Plan (NCP) currently in effect
(referred to by CMP as the 1985 NCP). In addition, the Proposed
NCP (referred to by CMP as the 1988 NCP) provides a statement of
14
-------
EPA policy, therefore it does not have the effect of law. Section
121 of CERCLA requires EPA to select a remedy
"that is protective of human health and the~
environment, that is cost effective, and that
utilizes permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent practicable."
EPA has carried out this mandate of CERCLA in selecting the remedy
which is set forth in the O'Connor Co. site Record of Decision
(ROD).
The thrust of CMP's comments is that EPA's selected remedy is not
cost effective because it costs $6 million more than CMP's
proposed alternative, and only buys a little more. EPA disagrees
with several of CMP's assumptions. First, EPA believes that the
selected remedy buys significantly more than CMP's alternative
it buys more protection, more permanence, more long-term
effectiveness and, of particular importance, compliance with the
statutory requirement of treatment to the maximum extent
practicable. CMP's alternative does not meet this requirement by
virtue of the fact that the selected remedy is an available,
practicable option which entails a greater extent of treatment.
Secondly, and following from the fact that the .selected remedy
accomplishes a better result than CMP's alternative, the selected
remedy is cost effective because it achieves a particular result
that .could not be achieved at a lesser cost. As stated in the
Preamble to the Proposed NCP, 53 Fed. Reg. 51422, the cost
effectiveness mandate requires EPA "to select protective remedies
whose costs are proportionate to their overall effectiveness."
CMP's alternative is cheaper but it does not accomplish what needs
to be accomplished at the Site. More specifically, it does not
meet the target cleanup levels established for the Site in a
manner that is permanent, effective over the long term, and that
utilizes alternative treatment technologies to the maximum extent
practicable. The selected remedy, on the other hand, does
accomplish these objectives and it does so economically. At no
time has CMP suggested that there is a less expensive way of
achieving the same result.
Finally, CMP repeatedly asserts that its proposed remedy would be
protective of human health and the environment. As EPA recognized
in the FS and further elaborated upon in the ROD, once EPA had the
benefit of further input from the community, the United States
Department of the Interior and the State of Maine, the ability of
CMP's alternative to be protective would depend upon the
reliability and long-term maintenance of institutional controls in
perpetuity. Whether this eternal condition could forever be
satisfied is dubious. In promoting its proposed remedy, CMP
suggests that it is just as protective to cover contaminated soils
15
-------
containing up to 10 ppm of PCBs with 10 inches of clean soil as it
is to destroy the PCBs through solvent extraction treatment. Not
only does common sense dictate that removing and destroying
contaminants is more reliable than covering them with-dirt, but
CERCLA expressly mandates the selection of remedies involving
treatment to the maximum extent practicable and states a
preference for permanence.
In conclusion, the overall protectiveness of CMP's proposed remedy
is questionable as contrasted witn the selected remedy which
inspires a high degree of confidence. Thus, contrary to CMP's
assertion, the cost of the selected remedy is proportionate to its
overall protectiveness. The selected remedy is, therefore, cost-
effective.
Comment 2. Reduction of Toxicity and Effectiveness
CMP states that there is no evidence in the RI/FS to support the
claim that solvent extraction can reduce soil toxicity to less
than 1 ppm for PCBs. The results of treatability studies
conducted on soils from the Site indicated that PCB
concentrations could be reduced to below 10 ppm but not
necessarily below 1 ppm. By setting the cleanup level at 1 ppm
rather than 10 ppm as proposed by CMP, EPA's alternative requires
processing approximately 14,500 cubic yards more soil at an
increased cost of $6,421,000. Such extensive excavation only
results in removal of an additional 2 percent of the PCBs on the
Site.
EPA Response!
As CMP admits, it has been demonstrated that solvent extraction
treatment will reduce PCB concentrations, at the very least, down
to levels below CMP's proposed target level of 10 ppm. It is
therefore certain that the selected remedy, which requires
treatment until the point at which no further benefit is derived
from the treatment process, will destroy more PCBs and better
satisfy the reduction of toxicity, mobility and volume criterion
than will CMP's alternative.
Furthermore, the treatability study that was performed on
contaminated soils from the Site was conducted using three (3)
different soil samples with initial PCB concentrations of 760,
3,000, and 15,000 ppm. These high concentrations were
specifically selected from the Site because of the three (3)
different soil-types that they represented but more importantly,
because they represented "worst case" samples chosen to "stress"
the solvent extraction technology to the maximum extent
practicable. Based upon CMP's own estimates provided in
Attachment 1 to their comment letter, the average Site-wide
concentration is approximately 280 ppm, and only approximately
1,700 cubic yards out of the 23,500 cubic yards exceeding 1 ppm
16
-------
PCBs (or about 7%) is estimated to contain PCBs greater than 1,000
ppm. Therefore, the site-specific treatability study results
alone do not provide a complete basis for making the statements
that a 1 ppm PCB target cleanup level cannot be achieved.
In fact, if CMP had considered information which was available
from the vendor it had engaged to perform the original
treatability study, CMP would have found that treatability study
results using the same solvent extraction technology are available
from several other PCB-contaminated sites. These other results,
as provided in the Administrative Record and not the RI/FS, show
that, for soils containing approximately 20-30 ppm PCBs, a
residual PCB concentration of less than 1 ppm can be achieved
consistently. Using the estimates in the FS (prepared by CMP) and
the information in Attachment 4 to CMP's comment letter, it is
estimated that only approximately 20-35% or 4,500-8,100 cubic
yards of the total 23,500 cubic yards of contaminated
soils/sediments exceeding the 1 ppm target cleanup level on the
Site contain PCB concentrations greater than 20-30 ppm. This
suggests that 70 to 80% of the total 23,500 cubic yards on the
Site will achieve the 1 ppm level.
Comment 3. Reliability of EPA's Risk Assessment
The risks posed by the Site were evaluated in the Endangerment
Assessment for two different exposure scenarios: current and
future use. Both of these scenarios were based on EPA-specified
exposure assumptions. Subsequent to the submittal of the
Endangerment Assessment (January 1988) and the submittals of the
first and second drafts of the FS (June 1988 and November 1988),
however, EPA revised the exposure assumptions. CMP questions the
assumptions and the methodology used by EPA to calculate the
target clean-up level of 3-4 ppm for PCBs for the corresponding
risk of 1x10-5 set forth in Appendix B-lf of the FS. CMP also
notes that EPA's Revised Assumptions are not universally accepted
by the scientific community, and that this frequent revision of
assumptions underscores the lack of a sound scientific basis for
the assumptions and highlights the arbitrariness of EPA's target
PCB clean-up level of 1 ppm.
EPA Response;
CMP is correct in stating that EPA's guidance entitled "Superfund
Public Health Evaluation Manual" (October 1986) recommends
selecting a remedy which results in a cumulative risk that falls
within a range of 10-4 to 10-7 individual lifetime excess cancer
risk when an ARAR does not exist for a particular chemical in a
particular medium (i.e., PCBs or cPAHs in soil). However, CMP
fails to recognize that lifetime refers to 70-years and not the
18-year exposure period from which CMP has consistently been
establishing its own target cleanup goals. The inclusion of
lifetime exposures accounts for a significant amount of the
17
-------
difference between the CMP-derived 19 ppm PCB target goal at
1X10-5 excess cancer risk and the EPA-derived 3-4 ppm PCB target
goal at the same risk level.
Additionally, as the ROD states in Section X, The Selected Remedy,
the State of Maine's Department of Human Services-DHS performed a
separate assessment of the human health risks posed by the Site.
DHS's results using the plausible maximum exposure assumptions
taken directly from the Endangerment Assessment (Table 4-5)
resulted in a PCB target cleanup level of 0.49 ppm based on a
1X10-5 upper limit cancer risk. Therefore, the State of Maine
requested a more stringent target cleanup level for PCBs of 1 ppm
for the Site to be protective of human health. The state also
noted that this level was consistent with the target cleanup goal
established for the Site for the protection of the environment
(more specifically, terrestrial wildlife).
Furthermore, it should be noted that the Endangerment Assessment
(EA) is used to determine the baseline risks to human health and
the environment at a particular site and not to establish target
cle'anup levels. EPA may properly use other approaches and take
into account other considerations in establishing target cleanup
levels. Finally, the fact that EPA frequently revises and updates
its risk assumptions, if anything, is an indication of the
scientific soundness of EPA's rationale for selecting the target
cleanup levels for this Site. Scientific knowledge, by its
nature, is in a constant state of change. Contrary to what CMP
suggests, EPA's frequent revisions of assumptions (which are all
taken from the technical literature) is a testimony to the
agency's scientific credibility.
Comment 4. Protectiveness of CMP's Proposed Alternative
Based on a review of the level of protection provided by the
target cleanup goal recommended in the CMP Alternative, 10 ppm
PCBs is effective in protecting human and environmental receptors.
It should be noted that the CMP Alternative (SC Alternative 11B)
proposes to cover any soil or treated residuals containing between
1 and 10 ppm PCBs with 10 inches of clean soil. Thus, under CMP's
alternative, the level of PCBs actually available for contact
exposure by human* or biota would be less than 1 ppm.
EPA Response:
EPA disagrees with CMP's assertion that soil concentrations of 10
ppm PCBs would be protective of either human health or the
environment at the Site. The rationale for EPA's target level of
1 ppm PCBs for th« Site soils and sediments is set forth in
Section X of the ROD.
With respect to the possibility of contact exposure to the
treatment residue containing 1-10 ppm PCBs which CMP proposes to
18
-------
cover with 10 inches of clean soil and leave on the Site, CMP
optimistically assumes that these ten inches of soil would never
be disturbed. For further discussion of this issue,- see Responses
to Citizen Comment 3 and CMP Comment 1, and letters from the
United States Fish & Wildlife Service regarding target cleanup
levels attached to the ROD as Appendix B.
Comment 5. Comparison to Other Superfund Sites
In determining the appropriateness of the CMP Plan target cleanup
level, EPA must look to its own past decisions. Numerous Records
of Decision (RODs) have been issued with cleanup goals of 10 ppm
or greater: Ottati and Goss (1987), 20 ppm; Re-Solve (1987), 25
ppm; Belvidere Landfill (1988), 50 ppm; and Sol Lynn (1988), 15
ppm, to name a few examples.
EPA Response;
As stated in the Preamble to the Proposed NCP, 53 FR 51422, EPA
recognizes
"that the solutions that are most appropriate
for a given site will vary depending on the
size, complexity, and location of the site,
the magnitude of the threats posed, the timing
of the availability of suitable treatment
technologies, and the proximity of human and
environmental receptors, among other factors."
Furthermore, as CMP points out in its comments, when no ARARs
exist for a particular chemical in a particular medium, such as
PCBs or cPAHs in soil, EPA guidance recommends that a remedy be
selected which results in cumulative risks that fall within a
range of 10-4 to 10-7 individual lifetime excess cancer risks.
More specifically, EPA must perform a site-specific Endangerment
Assessment for every site which is listed on the National
Priorities List (NPL) to identify the magnitude of actual or
potential human or environmental exposures, the frequency and
duration of these exposures, and the routes by which receptors are
exposed. These site-specific assessments of both the current and
the reasonable maximum exposure scenarios vary among sites
depending on the particular circumstances of each site.
Additionally, the state-of-the-art in toxicology has increased
dramatically since the issuance of some of these past RODs while,
at the same time, the availability of treatment technologies has
improved drastically. Finally, at a number of other Superfund
sites, EPA has incorporated some degree of land-use restrictions
to further protect the human health and the environment from
contaminated materials remaining on-site due to the
impracticability of more permanent remedial actions.
19
-------
Comment 6. Implementability
EPA's estimate of the degree to which solvent extraction will ,
reduce contaminant concentrations affects the implementability of
EPA's alternative. The treatability studies show that after four
washings, the contamination in most soils will be reduced to
between 1 and 10 ppm. But even after ten washings, the
concentrations rarely go to below 1 ppm; most remain between 5 and
10 ppm. Thus, with a cleanup target of 1 ppm, there is
uncertainty and unreliability associated with solvent extraction.
EPA Response;
There is virtually no uncertainty or unreliability associated with
the selected remedy because any treatment residues with PCB
concentrations in excess of 1 ppm will be disposed of in an
offsite chemical landfill. Thus, the selected remedy is equal to
CMP's alternative with respect to implementability and is superior
to CMP's alternative with respect to other criteria, as discussed
in the EPA Response to CMP Comment 1.
Comment 7. Cost
EPA's alternative is not cost-effective. The RI/FS does not
support or justify EPA's decision to excavate and treat 23,500
cubic yards of soil at a cost of $12,303,000 in an effort to reach
a target cleanup level of 1 ppm. The cost to remove 97.8 percent
of the PCBs is $6 million; an additional $6 million would be
required to remove the remaining 2 percent of the PCBs. The 100
percent increase in cost to remove 2 percent of the PCBs is not an
appropriate balance of cost versus effectiveness.
EPA Response;
As discussed in greater detail in the EPA Response to CMP Comment
1, the selected remedy is cost-effective because its cost is
proportionate to its overall protectiveness.
Comment 8. Regulatory Support
Support for the CMP Plan target cleanup level of 10 ppm can be
found in the TSCA PCB Spill Policy, 52 Fed. Reg. 10688 (1987).
This policy requires the cleanup of spills in nonrestricted access
areas to 10 ppm for PCBs to a minimum of 10 inches and the
covering of the area with clean soil. Although EPA does not
consider the TSCA Spill Policy to be an Applicable or Relevant and
Appropriate Requirement (ARAR), the Preamble to the 1988 NCP
recognizes it as a federal guidance to be considered. In the
absence of an ARAR, this official EPA policy specifically
addressing the issue of appropriate levels of cleanup for PCBs
becomes of great importance in evaluating protective cleanup
levels. Regardless of the future use of the site as restricted or
20
-------
nonrestricted, the Spill Cleanup Policy supports the 10 ppm for
PCBs cleanup level.
EPA Response; - .
The site-specific requirement that a remedy be protective of human
health and the environment takes priority over a standard.which is
"to be considered" (TBC). At this Site, where the protectiveness
requirement demands a stricter cleanup level than the TSCA Spill
Cleanup TBC, the level which satisfies the protectiveness standard
must control. Accordingly, EPA has adopted a PCB cleanup level of
1 ppm. Further, the TSCA Spill Policy specifically states that it
applies to spills which occur after May 4, 1987, and that old
spills will require site-by-site evaluation. The TSCA Spill
Policy also states at Section 761.120(e) that cleanups under
CERCIA or RCRA may result in different outcomes.
Comment 9. Future Use of Site
EPA, at the public information meeting held July 19, 1989,
defended its Plan and the proposed target cleanup level of 1 ppm
on the basis of the need to allow residential use of the site.
There is no statute, regulation or policy that requires a
Superfund site to be remediated such that it can be used as
residential property or even returned to its original condition.
In addition, there is nothing unusual in the use of institutional
controls to restrict access to a site under the Superfund program
as proposed in the CMP Alternative. The site is located in a
rural area and there is no evidence in the record that the area is
experiencing any residential development pressure. In addition,
it is unlikely that any financial institution would accept the
risks inherent in financing residential development of the site.
The site's history, the fact that groundwater treatment will
continue for 27 years, and the high risk inherent on foreclosure,
render it unlikely that the site will be developed. Thus, EPA's
future residential use scenario is impractical, unreasonable, and
unrealistic as well as legally unsupportable.
EPA Response;
As emphasized throughout these responses, Section 121 of CERCLA
requires EPA to select a remedy that is protective of human health
and the environment and that uses permanent solutions and
alternative treatment technologies to the maximum extent
practicable. .Protection of human health necessarily involves a
consideration of the likely uses of a site. In this case, not
only is the Site within the city limits of the state capitol of
Maine, but citizens have also expressly testified that their
children played on the Site (see Transcript, Public Meeting of
August 10, 1989, Augusta, Maine) and it is reasonable to assume
that more children will do so in the future.
21
-------
In addition, as set forth in the ROD, EPA has established target
cleanup levels for contaminants of concern in site soils,
sediments, groundwater and surface waters based on protection of
human health and the environment. CMP proposes to achieve the
cleanup levels in part by covering contaminated soils and
sediments with 10" of clean soil and imposing institutional
controls. Not only does this raise questions about the capacity
of CMP's alternative to be protective, but this reliance on
institutional controls would clearly result in a remedy that was
less permanent and less effective over the long haul and that
would not make use of alternative treatment technologies to the
maximum extent practicable. While the use of institutional
controls may be an appropriate component of some Superfund
remedies, there is no need or justification for reliance on such
controls under the circumstances at this Site.
Comment 10. Five-year Review
CERCLA requires reviews, at least every five years, at sites
where the remedial action leaves hazardous substances,
pollutants, or contaminants onsite. The EPA Alternative calls for
such a review. According to the NCP (1988), a five-year review is
required at sites where substances remain above levels that allow
for unrestricted use. If a 1 ppm cleanup level is implemented and
the site is safe for unrestricted use, then a five-year review is
not required.
EPA Response;
As CMP recognizes, Section 121(c) of CERCLA requires a review of
any
"remedial action that results in any hazardous
substances, pollutants, or contaminants
remaining at the site ... no less often than
each five years after the initiation of such
remedial action to assure that human health
and the environment are being protected by the
remedial action being implemented.11 (Emphasis
added.)
Thus, the so-called five-year review is a minimum requirement
under the statue. The proposed NCP which CMP cites, offers an
interpretation of this minimum requirement and goes on to state,
"In addition to the statutorily required five-year reviews, EPA
might specify in its record of decision more frequent reviews, or
specific reviews of the remedy selected..." 53 FR 51430. In this
case, where a relatively new technology is being used to treat the
on-site soils and sediments, where groundwater treatment is
expected to take from 20 to 30 years, where a minimum-no action
approach to the sediments in Riggs Brook has been adopted, where
the Site is within the Augusta city limits, where children are
known to have played at the Site in the past and are likely to do
22
-------
so in the future, and where monitoring is easily accomplished, EPA
is acting well within its statutory authority in requiring a five-
year review to ensure that the selected remedy is protective.
Comment 11. Compensatory Wetlands
EPA has requested comments on its proposal establishing
compensatory wetlands because of the impact on the site caused by
destruction of the existing lagoons and upland marsh. CMP opposes
this proposal. The lagoons and upland marsh are not "natural"
resources. The lagoons were created as a result of DEP interim
remedial action at the site in 1976 to collect and contain oil
run-off. The upland marshes were a side effect of this remedial
effort. Thus, federal policies aimed at preserving wetlands,
restoring contaminated areas to their natural condition, and
protecting existing, thriving ecosystems are inappropriate.
EPA Response;
First, it should be recognized that the Wetlands Executive Order,
E.O. 11990 is not merely a statement of policy, as CMP suggests,
but rather is a binding directive with which EPA must comply.
Secondly, there is no need to speculate about what this Order or
the regulations which relate to its enforcement (Procedures for
Implementing the Requirements of the Council on Environmental.
Quality on the National Environmental Policy Act, 40 C.F.R. Part
6) are "aimed at," because the scope of their coverage is
unambiguous. In defining the term "wetlands," neither the
executive order nor the federal regulations cited distinguish
between man-made and naturally occurring bodies of water. Thus,
regardless of their origin, wetlands are entitled to the
protection afforded by these provisions. The definitions cited by
CMP, 43 C.F.R. § 11.14, are not on point.
Comment 12. Solidification Process
Although the on-site solidification alternative is not being
recommended by CMP or EPA as the proposed alternative for
remediation, the solidification process is being proposed for
treatment of lead-contaminated soil in both the CMP and EPA plans.
CMP thus feels it necessary to clarify certain statements made by
EPA about the alternative.
1. The proposed treatment will not occur in on-site mobile
units, as described in the June 1989 FS, but will occur
by processing contaminated soils on-site by spreading
soils and additives on the ground and mixing them with
a tractor containing a paddlewheel mixing device.
2. EPA quoted the O'Connor Solidification/Stabilization
Treatability Study out of context. The EPA Proposed
Plan, July 1989, states: "The recently completed
23
-------
bench-scale treatability study ... suggests the PCBs
may not have been chemically stabilized successfully,
and that only a 50 percent to 75 percent reduction in
PCB Reachability was attained." The total-waste
extraction test performed as part of the treatability
study did indicate that PCBs may not be chemically
stabilized. However, EPA.did not cite the results of
the physical stabilization tests in the analysis, even
though the explanation of this technology states that
it "uses a combination of physical and chemical
stabilization processes to bind contaminants..."
Individual leachate tests conducted under the
treatability study were conducted under rigorous sample
preparation techniques (grinding, sieving) untypical of
field conditions and no "binding" proprietary additive
was used to further stabilize PCBs. Even under those
conditions, the study results still indicated
successful solidification/stabilization of PCBs, cPAHs,
and lead at the O'Connor site.
, EPA Rasponse;
EPA acknowledges its error in the Proposed Plan regarding the
description of the solidification alternative, and EPA has made
the appropriate corrections to the ROD for alternative SC-6. .
The second part of the above comment has been addressed separately
under Part A of this Responsiveness Summary regarding comments
made by Harmon Environmental Services. Furthermore, it is EPA's
understanding that the leaching protocols used during the
solidification treatability study are the same ones accepted by
EPA under the SITE demonstration program. Finally, it is EPA's
understanding that E.C. Jordan contacted EPA staff personnel with
expertise in solidification under the SITE program, and that the
leaching procedures used were agreed upon by all parties.
Comment 13. Rioas Brook
CMP concurs with EPA's proposal to implement minimal no-action for
Riggs Brook sediments.
EPA Response;
No response called for.
Comment 14. Disposal of Residuals
CMP concurs with the DEP preference that all residuals above
target clean-up levels be disposed of off-site.
EPA Response;
No response called for.
24
-------
IV. REMAINING CONCERNS
During the public informational meeting on the Proposed Plan held
by EPA in Augusta on July 19, 1989, and at the informal public
hearing held on August 10, 1989, local residents discussed issues
that may continue to be of concern during the design and
implementation of EPA's selected remedy for Site.
Future Use of Site
Citizens expressed concern about whether the site would be
useable again. They would like to see it returned to its
original condition.
EPA Response;
See the EPA Response to Citizen Comments 1,2 and 3.
Health Effects
Citizens expressed concern about the health effects of the site.
They feel that the seemingly high rate of cancer affecting
persons living near the Site could be related to Site
contamination.
EPA Response;
As set forth in the ROD and reiterated throughout this
Responsiveness Summary, EPA selected a remedy that it has
determined to be protective of human health and the environment.
Furthermore, EPA contacted the Agency for Toxic Substances and
Disease Registry (ATSDR) following the two (2) public meetings
held on the Proposed Plan in response to concerns raised by
members of the public. ATSDR personnel indicated that they would
speak with local citizens near the Site about their past and
future health concerns relative to the Site. As of the issuance
of this ROD, ATSDR personnel visited two (2) of the citizens who
had expressed these concerns, and will conduct further .inquiries
following discussions with the State of Maine, Department of Human
Services.
25
-------
In Re: ]
E.P.A. Region I Superfund Program ]
O'Connor Company Site ]
Augusta, Maine ]
EXHIBIT B
UNITED STATES OF-AMERICA
Environmental Protection Agency
Hearing before the United States Environmental
Protection Agency, Region I, on August 10, '1989, at the
American Legion Post number 205, 400 Eastern Avenue,
Augusta, Maine, commencing at 7:42 P.M.
PRESENT:
Frank Ciavattieri, E.P.A., Region I, Chairman
Michael Jasinski, E.P.A., Region I
David Webster, E.P.A.
Alan Prysunka, Maine D.E.P.
Thomas Benn, Maine D.E.P.
Cynthia Coombs, Maine D.E.P.
William R. Pieske, Shorthand Reporter
PIESKE REPORTING SERVICE 622-1616
-------
INDEX
Mr. Ciavattieri
Mr. Jasinski
Mr. Prysunka
Mr. Towt
Mr. Wallace
Mr. Irish
Mrs. Irish
Mr. Jasinski
Mr. Ciavattieri
3
8
15
18
21
29
30
31
32
PIESKE REPORTING SERVICE 622-1616
-------
3
MR. CIAVATTIERI: Good evening, ladies and
gentlemen, and I guess I should add young lady. I
would like to welcome you here tonight for-the public
hearing on the O'Connor superfund site. My name is
Frank Ciavattieri. I am from the United States
Environmental Protection Agency in Region I which is in
Boston, and my position with E.P.A. is the branch chief
for the Maine and Vermont waste management branch.
Part of my responsibility includes overseeing
implementation of the remedial superfund program within
the State of Maine.
I'd like now to introduce the people at the head
table with me here tonight. On my right is Michael
Jasinski who is the remedial project manner from E.P.A.
for the O'Connor site. To his right is David Webster
who is the section chief for the United States
Environmental Protection Agency for the Maine and
Vermont superfund section. To his right is Alan
Prysunka who is the director of the Bureau of Oil and
Hazardous Materials Control for the State of Maine. To
his right is Thomas Benn and to his right is Cynthia
Coombs who are site managers from the Maine Department
of Environmental Protection. To their right is Dick
Christian who is with Camp, Dresser and McKee who is
E.P.A.'s oversight contractor for the O'Connor site.
PIESKE REPORTING SERVICE622-1616
-------
4
I will serve as chairman for the hearing tonight
and want to welcome all of you here. The purpose of
tonight's hearing is to formally accept your comments
on the remedial investigation, endangerment assessment,
feasibility study and proposed plan for remediation at
the O'Connor superfund site located on Route 17 in
Augusta, Maine.
The E.P.A. will also accept your comments tonight
on the issues stated in the proposed plan on page 27
regarding the final location for disposal of treatment
residues which may not achieve the target cleanup goals
which have been established for the site and as well as
the issue of the compensatory wetlands described on
page 14 of the proposed plan. Copies of the proposed
plan are available if you didn't get one as you came in
at the front door.
Before I begin the formal part of the evening's
proceedings, I would like to describe to you the format
of this hearing. Essentially, the evening will be
structured into four parts. First, Michael Jasinski,
the remedial project manager from E.P.A., will give you
a brief overview of the site contamination in E.P.A.'s I
proposed plan.
As many you of you know, E.P.A. and D.S.P.
representatives made a detailed presentation of the
PIESKE REPORTING SERVICE622-1616~"
-------
site contamination and the proposed plan at a public
informational meeting which was held here_on July 19th.
Following Mike's overview, Al Prysunka of the Maine
D.E.P. will make a statement for the record on behalf
of the State of Maine.
After these opening statements, we will.open up
the formal part of the hearing to any other oral
comments that those of you in the audience tonight may
wish to make for the record. Those of you who wish to
comment tonight should indicate your desire to do so at
that time by raising your hand. At that time I will
ask any of you who wish to comment to identify yourself
and your association with the O'Connor site. As I call
upon you to make your statements or comments for the
record, I would kindly ask that you come to the front
of the room so everybody can hear you when you speak
and our recorder can also hear you. I will reserve the
right to limit each oral comment to ten minutes.
Although we do not expect this to be a problem in terms
of time, I may have to impose that restriction. If I
have to impose that restriction, I will ask you to
summarize your most important points you make and ask
you to provide E.P.A. with a full copy text of your
comments either at the end of tonight's hearing or
prior to the close of the public comment period which
PIESKE REPORTING SERVICE622-1616"~
-------
6-
ends on August 19th. Please note that the entire
context of this hearing is being transcribed and will
become part of the record for the site.
After you have made your comments, I or another
member of this panel may ask you some clarifying
questions to assist us in considering more fully and
more fully addressing your statements for the record.
After all the comments have been heard, I will close
the formal part of this hearing. Just to remind you,
the purpose of tonight's hearing is to receive your
comments for the record. As part of the formal
hearing, we will not be able to respond to your
comments or questions when asked. However, after the
close of the formal part of the hearing, we will remaif
available informally to answer your questions on any of
the issues raised during the evening or any other
aspects of the feasibility study or proposed plan.
As many of you already know, the public comment
period for the proposed plan began on July 20th and
runs through August 19th. If you wish to submit
written comments, I encourage you to do so. They must
be postmarked no later than Saturday, August 19, and
mailed to E.P.A.'s office in Boston. The appropriate
address of our office can be found on page two of the
proposed plan. Additional copies of the proposed
PIESKE REPORTING SERVICE622-1616
-------
are available on the table at the front of the room.
At the conclusion of the meeting tonight, please
see one of us from E.P.A. if you have further questions
on the process for making written comments. Any oral
comment we receive tonight during the formal part of
this hearing and those we receive in writing during the
comment period will be responded to in a document we
call the responsiveness summary. This summary will be
included with a decision document or record of
decision R-O-D we call it that E.P.A. prepares at
the conclusion of the comment period. In the record of
decision, E.P.A. will explain which cleanup alternative
or alternatives have been selected for the O'Connor
site.
I realize I have presented a lot of information to
you in these opening comments. Are there any questions
on how we are going to proceed this evening?
(No response)
MR. CIAVATTIERI: Okay. I again want to
thank you for coming here and encourage you to express
any comments or questions you have during the proper
time during the presentations tonight. At this point I
would like to turn the proceedings over to Mike
Jasinski who will provide you with a brief overview of
the site and the proposed plan which is now up for
PIESKE REPORTING SERVICE622-1616
-------
public comment. Michael?
MR. JASINSKI: Thank you, Frank._ What I
would like to try to do real quickly is summarize some
of the information that was presented at the public
information meeting relative to the site contamination
and the distribution of concaminants found during the
field efforts. Just quickly, this site and this is
in a packet that is available at the front of the room.
Basically, the site, again, is located about a mile
southeast of Augusta, Maine, on Route 17 on Eastern
Avenue. The contaminated portion of the site is nine
acres of a total property acreage of 65. Most of the
activity that resulted in the contamination at the sitj
i
was due to transformer spillage of contaminated PCB
oils, and this operation occurred mainly between the
fifties and 1978.
On this overhead you can see the key areas of the
site, principal site features. The site, basically the
nine acres, is surrounded by the fence as shown there.
The key site features include the large barn which you
may have noticed on your drive down Route 17 this
evening. Several of the transformer work areas where
most of the transformer dismantling and most of the
spillage occurred were in what is called transformer
work area one which is closer to the barn. Transformer
PIESKE REPORTING SERVICE622-1616
-------
9
work area two and transformer work area three.
Thore are two on-site lagoons, an upper and lower
lagoon, that were specifically constructed in the early
seventies at the request of the Department of
Environmental Protection. Some of the sediments that
were dredged from the upper lagoon were placed in an
area we designate as the low area which, in turn, has
created what we call the upland marsh.
Key contaminants identified during the field
investigation were PCB's. This overhead tries to
depict to you the area of distribution of PCB's at the
one part per million range. The fence in green and the
border cross-hatched showing the aerial distribution of
one part per million PCB's which is in your handout,
and inside these areas are lowered levels or depth
determinations of ten feet and eight feet where the .
transformer work areas primarily were; transformer work
area one here and transformer work area two here.
One other key contaminant during the remedial
investigation was polycyclic aromatic hydrocarbons;
more from a cancer perspective, carcinogenic PAH's, as
they are called, shown in this area with a blue line
indicating for that area it is over one part per
million of cPAH's; all, again, within the nine-acre
fence.
PIESKE REPORTING SERVICE622-1616
-------
10
Lastly, one other key contaminant of concern in
soils is lead. In this overhead I tried to show to
where the areas are that are greater than'248 parts p"eT
million in lead highlighted by these darker areas.
Areas surrounding that are at concentrations a little
bit lower; t:he outer reach being about a hundred parts
per million. Again, within the nine-acre fence area
and all of which of these three compounds, if you were
to put these over each other on an overhead, would show
that they were very well distributed in a very
co-located area of the site.
Based on the contamination determined at the. sit*
during the field investigation and the risks to the
public health and the environment, E.P.A. and Central
Maine Power and their contractor evaluated several
alternatives for remediating the site. For the soil
and sediment contamination within the areas I have
shown you, several of the alternatives that were
reviewed in detail were minimal no-action, on-site
capping, on-site construction of a landfill, off-site
disposal at an existing landfill, on-site incineration,
on-site solidification, on-site vitrification, on-site
dechlorination and two subcomponents of a solvent
extraction technology on the site.
Some of the other contaminants of concern were in
PIESKE REPORTING SERVICE622-1616'
-------
11
groundwater; mainly, again, PCB's and, to a lesser
extent, benzene and 1,4-dichlorobenzene. In evaluating
the alternatives for that, two of the alternatives
evaluated in the feasibility study were minimal
no-action and an active extraction and treatment system
for the groundwater using activated carbon.
One other area of concern that I didn't show in
any of the overheads was Riggs Brook. In Riggs Brook,
during the field investigations, slightly less than
five parts per million PCB's were found in a very
localized area of Riggs Brook near the site, which is
primarily a wetland area along the near reaches of the
site. To evaluate the alternatives to address the
sediment contamination in Riggs Brook which contained
PCB's less than five parts per million, we looked at
minimal no-action again and excavation and off-site
disposal of the sediments. Through the evaluation of
these alternatives for each of the contaminated
media that is, soil and the surface waters,
groundwater and the sediments in Riggs Brook, the
preferred alternative at the present time for public
comment that E.P.A. is recommending for the site
includes the following -- these are as specifically
stated on page 11 in the proposed plan.
Essentially, the preferred alternative to address
PIESKE REPORTING SERVICE622-1616
-------
12
the contaminated soils and sediments and surface water
on the site involves the following: Excavation of all
the contaminated materials on the site containing one
part per million PCB's, one part per million cPAH's or
carcinogenic polycyclic aromatic hydrocarbons and 248
parts per million lead. Those soils, all of which
involve approximately 23,500 cubic yards, would enter a
treatment system as I showed you previously that was
evaluated, which is on-site solvent extraction. The
on-site solvent extraction, essentially, is a process
which adds a solvent to the.contaminated soil. It
extracts the contaminants mainly the organic
contaminants, hot the lead and takes that
contaminated liquid and treats it in a different
location. In this case, that material or concentrated
liquid containing primarily PCB's and the PAH's would
be treated at an off-site incinerator located outside
of Maine. Typically those units are in Deer Park,
Texas, and Chicago, Illinois. Another one is in
Pittsfield, Massachusetts.
The next step in the process which would involve
disposal of the solid residues if they do not achieve
our target cleanup levels as stated up here, which are
one ppm PCB's and one ppm cPAH's and 248 lead, would be
disposed of with further treatment. Now, we are in
PIESKE REPORTING SERVICE622-1616
-------
13
public comment on what that eventually would be, and
that could potentially be at the present time an
on-site location which would probably include a
landfill or the potential for taking that contaminated
material off-site and disposing of at in a properly
fashioned landfill that exists already. What we
i
estimate at the present time of the 23,500 cubic yards '
that would enter the solvent extraction unit, that
approximately 5,000 cubic yards of that would have to
enter into the disposal option we present here and
would probably enter into some of the further treatment
that we would consider as stabilization and fixation
mainly due to the lead.
The lagoon on-site contain approximately 150,000
to 195,000 gallons of contaminated surface water and
contaminated sediments. We would enter into pumping
the contaminated groundwater excuse me, surface
'water out of the lagoons and treating it in an off-site
facility. The sediment, in turn, that exceeds the
levels shown up here would then, in turn, undergo the
voluntary solvent extraction process. These lagoons
are considered wetlands on the site. One item that is
in the proposed plan is to provide for compensatory
wetlands; that is, to construct wetlands comparable to
those in an area of the property that would be roughly
PIESKE REPORTING SERVICE622-1616
-------
14
about a half an acre.
Just briefly, to show you a schematic of the
on-site solvent extraction process, as I mentioned, the
materials would be excavated, enter a reaction chamber
which could run between 25 cubic yards to a hundred
cubic yards in size. The solvent would be added. What
comes off the reaction chamber would be the
concentrated liquid of organic PCB's and PAH's. That
would be taken off-site for incineration. Clean soil
and sediment that come from the reaction chamber after
so many washes, as it is called, would be put back on
the site if it achieves our cleanup levels. Those that
do not, as I mentioned, would undergo further treatment
and disposal either on-site or off-site.
For the contaminated groundwater on the site, we
are presently preferring the treatment pumping and
treatment option as proposed versus the minimal
no-action which would include deep extraction wells on
the site, an on-site treatment unit containing carbon
absorption and recharging that groundwater on the site
either through recharged wells or recharged trenches if
they achieve our cleanup goals for the groundwater as
shown here. A simplistic schematic of that shows the
pumping of the groundwater to a pretreated filter for
particulates that could be a potential hindrance to
PIESKE REPORTING SERVICE 622-1616
-------
15
further treatment using the more important activated
carbon unit. That carbon as filtered would go off-site
for treatment, if necessary, due to contaminants
plugging the systems and not achieving our goals.
Finally, as I mentioned Riggs Brook, the less than
five parts per million of sediment in there that's
about 900 cubic yards that's greater than about one
part per million would undergo the minimal no-action
alternative which basically involves an extensive
monitoring of the sediments and the biota and
instituting some educational programs to inform the
public of how the site contaminationstis proceeding as
far as the cleanup and the remedy and how our extensive
monitoring results change based on what we know today.
Essentially, that is all I have to say, and I would
like to turn it back over to Frank.
MR. CIAVATTIERI: Thank you, Mike. At this
time I would like to recognize Mr. Alan Prysunka from
the Maine Department of Environmental Protection to
make a presentation on behalf of the State. Al?
MR. PRYSUNKA: My name is Al Prysunka, and I
am the director of the Bureau of Oil and Hazardous
Materials Control within the Maine Department of
Environmental Protection. I will be presenting the
testimony on behalf of Dean C. Marriott, Commissioner
PIESKE REPORTING SERVICE622-1616
-------
16
of the Maine Department of Environmental Protection
concerning E.P.A.'s proposed plan for remediation of
the F. O'Connor site. The Maine Department of
Environmental Protection has reviewed the draft
remedial investigation and feasibility study for the
F. O'Connor site and offers the following comments on
the J.S. E.P.A.'s proposed plan for site remediation
which includes both management of migration for
groundwater and source control alternatives.
The D.E.P. concurs with the management of
migration alternative two which is groundwater
extraction and on-site treatment with activated carbon
absorption as proposed by E.P.A. The D.E.P.
understands that the management of migration
alternative will extract contaminated ground water,
treat the groundwater to comply with Federal and State
applicable or relevant and appropriate requirements,
commonly known as ARARS, and reinject the water into
the aquifer. Institutional controls which prohibit the
construction and use of any and all groundwater wells
within the aquifer must be established until such time
as the cleanup objections are met.
The D.E.P. conditionally concurs with the proposed
source control, alternative SC-11A, which is on-site
solvent extraction of contaminated on-site soils and
PIESKE REPORTING SERVICE622-1616
-------
17
sediments with off-site treatment of contaminated
on-site surface water. As presented, the'D.E.P.
understands the SC-11A alternative will consist of the
following:
A, All contaminated on-site surface water from the
upper and lower lagoons and the upland marsh will be
pumped and transported to a permitted off-site
treatment facility.
B, the on-site barn will be cleaned, demolished
and disposed of off-site.
C, all on-site soils and sediments exceeding, any
of the target cleanup goals of one part per million
polychlbrinated biphenyls, one part per million for the
carcinogenic polycyclic aromatic hydrocarbons or 248
parts per million of lead which will be about
approximately 23,500 cubic yards will be treated by
on-site solvent extraction.
D, solid residues from the solvent extraction
process that both achieve all E.P.A. target cleanup
goals and pass E.P.A.'s standard extraction procedure
toxicity tests will be placed back in the excavated
areas and,
E, ultimate disposition of solid residues that
fail EP toxicity, fail to meet a cleanup goal or both
will be determined following the public comment period.
* *> *7 * it ' ff
-------
18
The D.E.P. understands that one of E.P.A.'s
options for disposing of solid residues iTs" placement
back on site in a stabilized solidified site or in a
RCRA/TSCA landfill.
»
The D.E.P. will not concur with a plan which would
include leaving any residues on-site, particularly if
that involves creating a RCRA/TSCA landfill within the
Augusta city limits. A landfill of this nature would
require extensive and expensive long-term monitoring
and maintenance and render the site forever useless for
any other purpose.
The D.E.P. urges E.P.A. to make every attempt to
acquire the necessary waivers or treatability variance
necessary to allow this material to be disposed of at
an existing off-site facility. Thank you.
MR. CZAVATTIERZ: Thank you, Al. We will now
take comments regarding the proposed plan and studies
conducted at the O'Connor superfund site. I have a
request from Central Maine Power to make a ten-minute
presentation. Mr. Andrew Towt of Central Maine Power?
MR. TOWT: Yes and speaking with me
independently at the time is James Wallace of E.G.
Jordan Company, our consultant. May we begin? Good
evening. My name is Andrew Towt. I am Central Maine
Power Company's project manager for the O'Connor site.
-------
19
Speaking with me tonight will be James; Wallace of E.G.
Jordan Company who is our consultant for this site.
The purpose of our presentation is to highlight some
aspects of both of the proposed cleanup plans. This
was the cleanup plan proposed by the E.P.A. and the
cleanup plan which is proposed by Central Maine Power
Company. We will also be submitting written comments
for the record before the close of the record on the
19th.
Central Maine Power Company has been involved with
this site since 1984 when E.P.A. informed both us and
the O'Connors that we may be responsible for
environmental problems which were being found at the
site. Our effort has been twofold. The first was to
address any immediate problem which the site posed to
human health and the environment. Our efforts here
were in three parts. We constructed a fence which
.surrounded the site which prevented anybody from
gaining access to the site. We removed tanks and
barrels which were used to store oils at the site and
we removed scrap metals which were located in the
northwest corner of the site which were seen to pose a
safety risk to anybody in and around the area.
The second part of our effort was to become
involved with the design of the studies which were to
PIESKE REPORTING SERVICE 622-1-616
-------
be performed at this site. We gave input to both the
Maine Department of Environmental Protection and the
E.P.A. on what we thought were the both means to
design excuse me, the best means to perform these
studies and then we managed the studies and paid for
the studies. The conclusion of all this effort was the
design and submission of our cleanup proposal to the
E.P.A. and the Maine D.E.P.
As Mr. Wallace's presentation will detail, our
plan is very similar to E.P.A.'s, and we feel that both
our plan and E.P.A.'s plan can both be implemented and
are both protective of human health and the
environment. However, we are very confident that our
plan is in everyone's best interest and will meet all '
the cleanup projections.
Before I turn the floor over to Jim, I would like
to make a note about the compensatory wetlands which
have been raised. I think it is important .to note that
the wetlands being discussed here are not the wetlands
which are part of the Riggs Brook aquifer system which
everyone sees as you drive up Route 17. These are a --
this is a swamp, marsh area which is located on the
upper part or the back part of the site. This swampy
area was created actually by a remedial effort which
was undertaken by the D.E.P. in the late seventies.
PIESKE REPORTING SERVICE622-1616
-------
A J.
The swamp was created when the effort resulted in the
backup of water into that area and because of that
backup of water, certain wetland vegetation and animals
were allowed to grow and proliferate at the site.
Although CMP has not taken a position yet on how to
address the rebuilding of these wetlands, we think it
is important to note that these were not a natural part
of the site or a part of the terrain of the area before
the first cleanup effort was undertaken. Now I would
like to give the floor to Jim.
MR. WALLACE: Thank you. My name is Jim Wallace.
I work for C.E. Environmental, formerly known in Maine
and in other places as E '. Jordan; purchased about two
years ago and then before the name changed.
As I mentioned, we have been working as a
consultant with Central Maine Power for approximately
four or five years, and during this time there has been
a lot of interaction between Central Maine Power and
the agencies before you. Documents have gone back and
forth, work plans have gone back and forth. There have
been numerous meetings where consultants have been
available. We discussed technical issues, and, in
general, the proposed plan as put forth by E.P.A. and
D.E.P. for this site as well as the proposed plan put
forth by Central Maine Power are very similar in most
PIESKE REPORTING SERVICE622-1616
-------
22
aspects.
What I would like to focus on a little bit here
»
tonight are where these two plans differ slightly, and
it is in the area dealing with the surface soils, those
soils that are contaminated with the PCB's, the PAH's
and the lead, as mentioned earlier and so to
concentrate just on the surface soils because
everything else we are in agreement on.
Under the Central Maine Power plan, the target
level will be to excavate all of those surface soils
and all the soils that contain ten parts per million of
PCB's or greater. I am going to concentr&te just' on
PCB's, although there are PAH's and lead because as was
mentioned earlier, these contaminants are co-disposed
on the site. They are in the same place. So if you
deal with the PCB's, you will take along with it the
PAH's and the lead. So we will just talk about PCB
numbers for simplicity.
(Indicating on visual aid) Under the CMP plan, to
excavate to ten part per million for the solvent
extraction process. Under the E.P.A. plan, excavate to
one part per million and then subject it to the solvent
extraction process, the major difference here being
this is the 23,COO cubic yards you hearo. about earlier.
I
This represents a volume of approximately 9,000 cubic
PIESKE REPORTING SERVICE622-161?
-------
23
yards. Treat with solvent extraction under the CMP
plan; treat with solvent extraction under the E.P.A.
plan. It is the same process. The same machinery
would be on-site subjected to the same number of
cycles, et cetera. So the technical process of
extracting the PCB's and the PAH's from the soil will
be the same under both plans.
Under the CMP plan, to recover to cover all
soils that come out of the process that sit in the
range of one to ten parts per million with at least ten
inches of clean soil and leave them on the site. Under
the E.P.A. plan it calls for dealing with the soils
that come out of the treatment process that are greater
than one part per million and dealing with them either
with an on-site landfill, a secured landfill, an
engineered facility or putting them into trucks,
driving them down the road and transporting them to a
licensed facility somewhere else.
I would like to focus on three key words as we go
through the next couple of minutes, and they are
effectiveness, implementability and cost, and these
come right out of the regulations and arc primary
criteria for evaluating alternatives and remedies at
the site. Effectiveness is protection. How well do we
protect things against the hazards that are on the
PIESKE REPORTING SERVICE622-1616
-------
24
site. Implementability is a large word that says can
we do it. Can we go out and do what we are proposing
to do; and cost, of course, relates to tfie* dollars thd
are associated with the proposed plans.
What do we want to protect? We want to protect
human health, and we want to protect wildlife. These
are the two things we want to protect at the site; and
in protecting human health and wildlife, we need to
look at the method by which humans and wildlife will be
exposed to and subjected to the effects of the PCB's on
the site; and with respect to the soils, we are dealing
primarily with the contact; contact with the skin,
absorption through the skin, eating dirt either through
children or the animals; that type of a contact.
Breathing it, it is not respirable dust. So it is a
contact problem with those things that are at the
surface, both for the humans and for the wildlife.
We feel that the CMP plan provides an adequate
level of protection for human health and for wildlife
in respect to those pathways and essentially is
equivalent to the level of protection provided by the
E.P.A. plan. Under the E.P.A. plan what will be
available on the site when remediation is done are PCB
concentrations of one part per million or less at the
surface. Under the CMP plan, what will be available
PIESKE REPORTING SBRVICS622-1616
-------
25
humans and wildlife at the site after remediation is
done will be one part per million PCB's at the surface.
» ^
Anything that is greater than that will be under at
least ten inches of soil with a vegetative cover of
soil over it.
I have just put up here some recent decisions --
not recent; some within a. couple of years but some
decisions on PCB sites; and the reason I have selected
these are they are PCB sites. They are in the
Northeast. Two are in New England. One is in upstate
New York and these are sites where E.P.A. has decided
through the record of decision process what the
acceptable target cleanup level is for protection of
human health and wildlife on these sites and has signed
off on them. The target cleanup level on the Otati and
Goss in New Hampshire is 20 parts per million for
protection of human health and the environment. For
»
the Resolve site that is down in southeastern
Massachusetts down near the New Bedford area, a rural
area site, not all that dissimilar from the site we
have here, for protection of human health and the
environment, 25 parties per million; and the Wide
Beach, New York, site, which I understand is in a
residential area -- there are front yards, grass; they
are going to roll back the turf, dig up the soil, put
PIESKE REPORTING SERVICE622-1616
-------
26
it back for the protection of human health and the
environment, the E.P.A. has decided ten p.arts per
million are adequate for protection.
Can we do it? We can go out to the site, and we
can dig up the dirt. We are going to dig up the dirt
under both plans, the E.P.A. plan and the CMP plan. It
is a dirt-moving operation. Under the CMP plan, we
need to move 9,000 yards, approximately. Under the
E.P.A. plan, we need to move approximately 23,000
yards. It will take us a little bit longer, or we will
need to have more machines on-site to do the E.P.A.
plan, but they are both implementable. We can do both
of them. They can be done. We did some studies on the
soils. We took specific site soils that were
contaminated with PCB's, subjected them to test to
determine if the solvent extraction process could, in
fact, take the PCB's off of the soil and get it into
the extract. Can we do it? The answers that came back
from those treatability studies are contained in the
reports; ar.d basically, they show yes, we can do it.
One thing that they show, however, is that there
is a good degree of certainty that we can remove the
PCB's off of the soil to less than ten parts per
million. They do not show that we can remove the PCB's
off of the soil to less than one part per million.
FlESKE REPORTING SERVICE622-1616
-------
That is an important point to consider and has
ramifications on what happens to the soil that comes
out the end of the process.
Speaking about those soils that come out the end
of the process, can we cover them on-site, put down ten
inches of cover material, seed it on top and maintain
it so that it will not erode away and will not become
available at the surface? Yes, we can. Can we build
an engineered facility on that site, double liner, put
the wastes in, put a cap on it, put a cover material on
the cap and ensure that that will stay intact? Yes,
that can be done. Can we put it in trucks and drive it
away? Yes, we can do that. So both the CMP plan and
the E.P.A. plan, we can do them. They are
implementable.
The third thing I would like to focus on is cost.
Now, if you look at the cost of the CMP plan which uses
approximately 9,000 cubic yards of soil that need to be
treated, the estimated cost for the total cleanup --
that is all of the media and everything -- is in the
order of 6 million dollars. When you look at the
E.P.A. plan with approximately 23,000 cubic yards of
soil that need to be treated and then disposed of, it
is an approximate total cost of 13 million dollars; and
as was mentioned by a previous speaker, is 13 million
iPIESKE REPORTING SERVICE 622-1616 ~
-------
28,
dollars one of the assumptions that goes into that
is that approximately 5,000 yards out of this 23,000
cubic yards is what will need to be disposed of either
in an on-site landfill or trucking to another facility.
When you look at the results of that test that we did
to see if we could do the process, it suggests it
does not support the fact that this number will be
5,000. In fact, it supports the fact that the number
might be closer to 23,000 yards that we might have to
deal with when we are done with the treatment process.
We don't know the exact number. We will only know when
we get into it, but that would suggest this 13 million
dollars could grow and could grow substantially if, in
fact, this process does not get down to one part per
million.
As I mentioned earlier the results of the
treatability study suggests we can get it below ten
parts per million. They do not suggest we can get it
below one part per million. So to summarize what we
have talked about, the CMP plan and the E.P.A. plan
offer essentially equivalent levels of protection for
human health and the environment. Can we do them? We
can do both of them, and what is the cost?
Approximately 6 million dollars for the CMP plan; 13 j
million dollars maybe plus for the E.P.A. plan. Thank1
PIESKE REPORTING SERVICE622-1616
-------
29
you very much.
MR. CIAVATTIERI: Thank you. Do-we have any
other members of the audience tonight here who would
like to make a statement for the record? Sir, would
you please stand up, identify yourself?
MR. IRISH: I am Harold Irish. I live on the
Cony Road up here, and I didn't plan on speaking
tonight, so I have no notes. I am here as a concerned
person because I moved in this area in 1965. I moved
on the Cony Road. At that time O'Connor junkyard was
in the process of operation as well as the Central
Maine transformers and so forth. The reason I am
really concerned, I don't know the mechanics of what
the E.P.A. is going to do or Central Maine. I don't
know which is the best way to go about -- solvents or
removal but I am concerned as living close by here, I
would like to see the piece of property to be usable j
again.
It concerns me a little. I don't hold Central
Maine Power liable for anything myself. I lost a son
in 1972 to leukemia, and he played in this place over
here. I am not saying he got it from there, but since
that time, we have lost eight other-people on the Cony
Road where I live. This is kind of scary, and this is
just in this area. So my neighbors on both sides of me
PIESKE REPORTING SERVICE622-1616
-------
3.0
have gone. I am not saying this is what is causing
that, but myself, I would like to see it cleaned up;
not just filled over.
I am a landscaper in charge of the veterans'
cemetery. It kind of scares me what Z just heard a few
minutes ago. Maybe it will work, but ten inches of
»
soil over the top of this, can someone live there and
go out and plant a tree? Can they dig down more than
ten inches without coming into this bad stuff? I am
just concerned the kids are going to be playing around
here; not my kids but my grandchildren and those who
live on my street and runs around in the field here. Z
would like to see this piece of property back where it
belongs. Z am very concerned with my friend who would!
be lost. Z guess that was mainly what Z have got to
say. Z would like to see it cleaned up.
MR. CXAVATTIERZ: Thank you. Do we have any
other commenters? Yes.
MRS. ZRZSH: When Z come to meeting last week
or last month, I said that Z didn't think Z think
Central Maine Power Company is a good company. Z have
met different people that work there. Z think they are
very well represented and O'Connors' junkyard -- and Z
am quite sure they knew what they were doing when they
put those transformers there Z hope, and Z have to
PIESKE REPORTING SERVZCE622-1616
-------
31
believe this, that they didn't realize the danger they
were putting this neighborhood in. Now I say this is
the way I look at it. I brought up six children. If
you make a ness, cleanup the mess, and that is what I
say to Central Maine Power Company. I don't care how
much it costs you or O'Connor junkyard. Leave it like
you found you know, you went in and you messed it
up. Now, for God's sake, clean it up. That is all I
have got to say.
MR. CIAVATTIERI: Would you identify
yourself, please?
MRS. IRISH: Yes. My name is Betty Irish.
MR. CIAVATTIERI: Are there any other
comments? If not, I will close the formal part of the
record and thank you for coming. We will now move into
the informal aspect of the meeting and open the floor
'to any questions. i
MR. JASINSKI: There is one thing I want to
make everybody aware of, too. Just recently as of this
morning -- excuse me, this afternoon at three o'clock,
the administrative record that is located in the
Lithgow Public Library had five more volumes of
information added to it this afternoon. That
information, essentially, contains the many drafts of
the RI/FS's, the correspondence between D.E.P., Central
-------
32
Maine Power, E.G. Jordan and E.P.A. over the years of
development of the RI/FS that is from one day in June
of '89. Those five volumes are several drafts of all
the comments that were made on the drafts and the
second drafts and the first drafts that Central Maine
Power and E.G. Jordan prepared. I want to make sure
you all know that. It is another five volumes that are
located on the same two shelves that the first nine
volumes were located on, and they will be there all the
way through September when we, hopefully, write the
record of decision.
MR. CIAVATTIERI: If there are no comments or
questions, I would like to thank you all for coming
here to these proceedings and for your time and
attention. As I indicated in my opening comments, you
still have the opportunity to comment on the proposed
plan. That period extends on August 19th. The address
to which your comments can be sent to is in our
proposed plan, and most of us here at the front desk
will still stick around for a little while afterwards
if you want some questions or general information.
Thank you very much.
(The hearing concluded at 8:28 P.M.).
PIESKE REPORTING SERVICE 622-1616
-------
CERTIFICATE
I, William R. Pieske, a Notary Public in and for
the State of Maine, hereby certify that the foregoing
is a true and accurate transcript of the proceedings
taken by me by means of stenotype.
William R. Pieske
My Commission Expires March 14, 1994
PIESKE REPORTING SERVICE 622-1616
-------
us FISH
SERVICE
Ralph Pill Marketplace, 4th Floor
22 Bridge Street
Concord, New Hampshire 03301-4901
Steve Serian, RPM, F O'Connor Site
: Ken Carr, USFWS
SUBJEC&>ii target levels for PCBs at F 0' Connor
In researching "effects" levels as part of the effort to determine clean up
levels for PCBs in soils at F O'Connor, I found several studies that should be
helpful in selecting a final soil criterion.
Tori and Peterle (1983) showed that mourning doves fed diets containing 10 ppm
Aroclor 1254 had significantly reduced reproductive success. The same authors
reported reproductive impairment in chickens fed diets containing PCBs at 5
ppm, although no statistically significant effects were noted in chickens fed
2 ppm.
McLane and Hughes (1980) reported no adverse effects to screech owls fed diets
with 3 ppo Aroclor 1248. However, the owl eggs contained up to 17.8 ppm PCB-
a level exceeding the 16.0 ppm level documented by Peakall, et al (1972) as
causing delayed growth and development in ringed turtle-doves.
Mink are a well known example of a PCB-sensitive species where a dietary
intake of Aroclor 1251 at 2 ppm caused reproductive failure. However, mink may
not be unique among mammals in their reproductive sensitivity to PCBs. Linzey
(1987J showed statistically significant reduction in both the number of young
per litter and their survival in white-footed mice fed Aroclor 1254 at 10 pps.
Mice were not exposed to PCB levels less than 10.0- ppm, and this level should
not be interpreted as a NOEL. In fact, many of the effect levels cited above
may actually be lower because animal toxicity studies frequently do not use
enough exposure levels to allow extrapolation to a NOEL.
From, the few examples cited, it would appear that a fair number of species are
adversely affected by dietary PCB levels in the 1-3 ppm range.
The Endangerment Assessment (EA) for the site discusses a study by Diercxsens
et al (1985) that showed an average BCF for earthworms exposed to soils
containing a mixture of Aroclors 1242,1254, and 1260 of 5.82. Assuming a
dietary effect level of 2 ppm, and a BCF of 5.82, soil concentrations of PCBs
protective of terrestrial wildlife utilizing soil invertebrates would be
approximately 0.34 ppm.
It is interesting to note that the EA for the site included much of the same
toxicity data that I reviewed, yet the PRP chose a higher dietary effect level
- 10 ppra instead of 1-3ppm, and chose a BCF of 1 rather than the 5.82 cited in
the EA. Yet table 7-3 of the EA documents reproductive effects to mink in the
-------
-2-
0.1 - 1.0 ppn range, and to birds in the 1.0 - 10.0 ppm range.. While the
argument will likely be raised that effects in the lower concentrations (0.1-
1.0; 1.0 - 10.0) were usually not mortal, I would like to point out that
reproductive impacts may be just as significant as mortality. I also point
out that controlled laboratory exposures of animals to toxins eliminate many
of the other diverse stresses to which animals in more natural environments
would be exposed, such as extremes in weather, predation, parasitism,
increased energy expenditures, and other toxic materials. Additionally,
exposures in the "wild* tend to be more chronic than laboratory exposures.
The result of the preceding factors is likely the underestimating of the
severity of detrimental impacts of contaminants to biota.
However, even with the preceding in mind, I find the logic presented in
section 7.3 of the EA apropos. While there is little doubt in my mind that a
PCB concentration in soil of 10.0 ppm will not protect the health of
terrestrial wildlife using the site, the significance of the population at
risk should be considered. Erskine (1977) surveyed breeding birds in a
similar habitat, and determined the mean number of bird pairs per square
kilometer at 150-450. Using a median of 300 pairs per square kilometer, and
conservatively assuming only 2 young per pair, we could reasonably expect the
locale to support 1,200 birds per square kilometer. Using these conservative
data, the 17-acre site would therefore support approximately 83 individual
birds. If we assume a density of 450 pairs per square kilometer, and 4 young
per pair, the 17-acre site would support approximately 186 birds in a breeding
season. These are not insignificant numbers of birds.
Based on these facts and a proposed clean up level of 10 ppm in soils,
Z
therefore recommend that the PRP reconsider its proposal to remediate soils
only to the 10.0 ppm level.
Attachment: Bibliography
cc: Wm Patterson, DOI, Boston, MA
Jane Downing, HRS-CAN3, EPA, Boston, HA
-------
Literature Cited
Diercxsens, P, D de Week, N Borsinger, B Rosset, and J Tarradellas. 1985.
Earthworm contamination by PCBs and heavy metals. Chemosphere 14: 511-522.
Erskine, A J 1977. Birds in Boreal Canada. Canadian Wildlife Service Report
Series. No. 41. .
Linzey, A V 1987. Effects of chronic PCB exposure on reproductive success of
white-footed mice. Arch. Environ. Contain. Toxicol. 16: 455-460.
McLane, MAR, and D L Hughes. 1980. Reproductive success of screech owls fed
Aroclor 1254. Arch. Environ. Contam. Toxicol. 9: 661-665.
Peakall, D B, J L Lincer and S E Bloom. 1972. Embryonic mortality and
chromosomal alterations caused by Aroclor 1254 in ring doves. Environ. Health
Perspect. 1: 103-104.
Tori,.G M and T J Peterle. 1983. Effects of PCBs on mourning dove courtship
behavior. Bull. Environ. Contam. Toxicol. 30: 44-49.
-------
PCB Levels in Various Media at
F. O'Connor Site
concentration (ppb) BCF
MARSH
Surface water ND
Sediment 6,425
Tadpoles 41,000 6.38/
UPPER LAGOON
Surface water 6.9
Sediment 369,728
Tadpoles 61,000 .0001/23,333*
LOWER LAGOON
Surface water 2.2
Sediment 4,756
Tadpoles 22,000 4.63/ 10,000
RIGGS BROOK
Surface water ND
Sediment 776
Fish 544 ,7/
SOIL
Unspecified location 3,326 5.82
Earthworms 19,357
BCF sediment-biota/ surface water-biota
BCF from Diercxsens et al (1985)
Projected, based on BCF of 5.82
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
400 RALPH PILL MARKETPLACE
22 BRIDGE STREET
CONCORD, NEW HAMPSHIRE QS?01-49Q1
1. _! O ^ - v"ii :-
Mr Michael Jasinski 4 0 on April 7, 1989
Superfund Section APR I ^ oV
U.S. EPA
JFK Federal Bldg. "'
Boston, Massachusetts 02203 - - = '"'
Dear Mr. Jasinski:
This regards the tentative clean-up levels chosen Tor contaminants at the F.
O'Connor Superfund site in Augusta, Maine. We understand the clean-up target
levels for lead, PAHs and PCBs to be 250 ppm, 1 ppm and 1 ppm, respectively.
Our cosnents and recommendations regarding these tentative clean-up levels
follow.
We have previously commented regarding soil PCS levels that would be
protective of migratory birds using the site. However, in considering the
practical aspects of contaminant delineation for the entire site, the
imprecision associated with low detection limits, and the logistics of
excavating and treating large volumes of soil, we believe that the 1 ppm PCS
that you have tentatively selected as a clean-up target is appropriate. We
have not previously addressed the lead levels nor the PAH levels in soils at
the site. They are addressed here.
LEAD
Lead toxicity data for wildlife, especially for waterfowl and birds of prey,
are relatively plentiful. Lead dietary exposures show effect levels somewhere
between 200 and 500 ppm of lead in food items in some species. Morgan et.
al. (1975), documented no adverse effects as reflected in blood biochemistry,
to hatctiiing Japanese Quail fed diets containing 100 ppm of lead, although
blood biochemical changes were noted in quail fed diets with 500 ppm lead.
Eastin et al. (1983), saw no adverse effects in week old Mallards fed
approximately 200 ppm lead in waste oils, and Edens et. al. (1976), found that
diets containing 500 ppm or greater of lead reduced growth in Japanese Quail.
While the scientific literature appears to show that lead does bioaccunulate
in soil invertebrates, tissue levels are generally not significantly greater
than soil levels. Beyer et. al. (1982) reported relatively poor
bioaccumulation of lead by earthworms, with lead levels in worms from a lead-
rich area averaging 20% greater than in worms from control soils. Beyer,
et al. (1984) found little bioaccumulation of lead in woodlice or centipedes
that preyed on woodlice. Dallinger and Wieser (1984) found negligible
bioaccumulation of lead in land snails fed a lead-contaminated diet.
-------
-2-
If we assume a bioconoentration factor of 1 to 2, then soil invertebrates at
the site following remediation might contain between 250 and 500 ppm of lead
(fresh weight). These levels are at the lower end of the range of effect
levels for birds cited above. Because the lead clean-up target level of 250
ppm is close to the estimated background concentrations of lead in area soils,
and the bioconcentration of lead by soil invertebrates is not expected to
occur in the high end of the range of effect levels, we do not anticipate that
lead will exert significant adverse impacts to birds using the site.
PAH«»
While it is well documented that small quantities of crude oil that contain
PAHS cause significant mortality in bird embryos following application to egg
shells, or following ingestion by hatchlings, there is little scientific
literature regarding the potential inpacts of PAHs, per se, to birds. While
we found no data in the literature regarding bioconcentration factors (BCFs)
of PAH in terrestrial invertebrates, there are abundant data for BCFs in
aquatic invertebrates, which show a wide range of BCFs depending upon the
specific PAH and taxon studied. However, dietary exposures to PAHs at the
O'Connor site are expected to be limited due to the relatively small volume of
contaminated soils present.
lacking more specific data from the literature, we are unable to recommend a
clean-up target. However, extrapolating from experience with aquatic food
webs, the 1 ppra target that you are considering for terrestrial habitats will
IJJcely be protective of species for which DOI is a trustee.
Sincerely yours,
Gordon E. Beckett
Supervisor
New England Area
-------
-3-
Literature Cited
Beyer, W.N., R.L. Chaney and B.N. Mulhern 1982. Heavy Metal Concentrations in
Earthworms from Soil Amended With Sewage Sludge. J. of Environ. Quality. 11
(3) 381-385.
Beyer, W.N., G.W. Miller, E.J. Cromartie. 1984. Contamination of the 02 Cell
Horizon by Zinc smelting and its Effects on Woodlouse Survival. J. Environ.
Quality 18:247-251.
Dallinger, R., W. Wiesero 1984. Patterns of accumulation, Distribution and
Liberation of Zinc, Copper, Cadmium and Lead in Different Organs of the Land
Snail, Helix pomatia. Camp. Biochem. Physiol. 19C:117-124
Eastin, W.C., D.J. Hoffman, C.P. O'Leary. 1983. Lead accumulation of d-
aminolevulinic acid dehydratase (ALAD) in young birds fed automotive waste
oil. Arch. Environ. Contamin Toxicol. 12:31-35
Edens, F.W. , E. Benton, S.J. Bursian, G.W. Morgan. 1976. Effect of Dietary
Lead on Reproductive Performance in Japanese Quail Coturnix coturnix japordca.
Toxicol. Appl. Pharmacol. 38,307.
Morgan G.W., F.W. Edens, P. Thaxton, and G.R. ParXhurst. 1975. Toxicity of
Dietary Lead in Japanese Quail. Poultry Sci. 54,1636.
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
400 RALPH PILL MARKETPLACE
22 BRIDGE STREET
CONCORD, NEW HAMPSHIRE 03301-4901
Mr. Paul Keogh
Acting Regional Administrator «..0 ~
U.'S. Environmental Protection Agency "Ui7 £ 5
JFK Federal Bldg.
Boston, Massachusetts 02203
Dear Mr. Keogh:
This letter regarding the F. O'Connor Superrund Site in Augusta, Maine, is
submitted in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) to assist you in
formulating a decision with respect to remediation of environmental impacts at
the site.
BACKSROUND/SITE DESCRIPTION
The F. O'Connor Site consists of approximately 17 acres of moderately sloping
old field land near the eastern boundary of Augusta, Maine. The site was used
as a salvage area in the past, and contains automobile bodies, tires, sheet
metal, white goods and electrical transformers. The latter contained PCB-
laden fluids, which are the primary contaminant of concern at the site.
However, PAHs have been found in isolated areas of the site, and elevated lead
and volatile organic compounds are more widely distributed on the site. The
volatile organic compounds are associated with groundwater, and are not. of
major concern to wildlife.
The site is primarily upland, although a wetland ("upland marsh") exists en
the western portion of the site, and Riggs Brook and an associated
scrub/shrub and emergent wetland form the eastern border of the site. Riggs
Brook flows north and east to join the Kennebec River in Augusta, upstream 01
the Edwards Manufacturing Company's dam. The Edwards Dam is currently
obstructing tree access of anadromous fisn to the Kennebec River up river of
the dam, including Riggs Brook. However, fish are presently being captured
below Edwards Dam, an transported up river. Capture and transport of
anadromous fish will continue until fish passage facilities are constructed at
the dam in the 1990's. Although Riggs Brook is not identified in the Kennebec
River anadromous fish restoration plan as a tributary proposed for active
restoration, it undoubtedly will be used by some or all of the anadromous
species passing the Edwards Dam.
CDNIAMINANr LEVELS
Soils. PCB levels in surface soils at the site range from none detected to
6,200 ppm. Total carcinogenic PAHs range from none detected to 2'i ppn.
Surface soil lead levels range from 29 to 2,681 ppm.
:-iic Wr
89
CT f /* . _
-------
-2-
Sediments. PCS levels in site sediments are highest in the lagoons
' established to control surface runoff. Total PCS levels in the Upper Lagoon
range from 30 to 1,100 ppm. Lower Lagoon sediments contain PCBs ranging from
3.2 to 40.0 ppn. PCBs in the upland marsh range from 1.3 to 34.0 ppn. Total
PCBs detected in Riggs Brook range from none detected to 6.5 ppnu Total PAHs
detected in Riggs Brook range from 2.3 to 8.9 ppn.
Biota. Although PCB levels in fish taken from Riggs Brook adjacent to the
site were 4-6 times greater than background levels, all fish samples from
Riggs Brook showed total PCB levels less than 1.0 ppm (whole body analyses).
These levels are omimui throughout New England, and likely do not represent a
significant hazard to fish or other aquatic biota.
»
Tadpoles taken from the lagoons and upland wetland had significantly greater
PCB levels than fish in Riggs Brook. Wet weight, whole body analyses of
tadpoles revealed total PCBs in the Upland Marsh, Upper Lagoon and Lower
Lagoon of 41.0, 161.0, and 22.0 ppm, respectively.
POTENTIAL HAZARD TO WILDLIFE
PCBs. are the major hazard to wildlife using the site. They are widely
distributed on the site in levels that can potentially result in detrimental
effects to wildlife, especially migratory birds, due to mobilization and
bioconcentration in the food chain.
In response to EPA's needs at the site, we developed a worst rase hazard
assessment for migratory birds exposed to PCBs at the site. Based on PCB
dietary studies and soil-to-prey bioconcentration factors, we estimated that
soil PCB levels as low as 0.34 ppm could detrimentally impact migratory birds
using the site. However, because the assumptions in the hazard assessment
were chosen to reflect worst case conditions, a somewhat less restrictive soil
level will likely be protective of most migratory birds using the site. The
remedial alternative presently identified by your agency as the preferred
alternative establishes a surface soil/sediment (exclusive of Ricigs Brook)
clean up target of 1.0 ppn for PCBs. Future monitoring of the site's biota
will provide the opportunity to validate the present judgement that 1.0 pprc
will be protective.
The areal extent and relatively moderate level of PCBs in Riggs Brook reduce
our concern that these levels will result in acute effects to natural
resources for which FWS has protective jurisdiction. Although the maximum
level of 6.2 ppn PCBs in Riggs Brook sediments would be of concern if it were
wider spread, the environmental benefits that would be realized by removal of
these contaminated sediments would likely be offset by the adverse impacts to
the Brook and its wetland resulting from removal actions. We therefore
recommend no removal of sediments from Riggs Brook at this time, with the
stipulation that the Brook's biota continue to be monitored to assure that
PCBs (and other site-related contaminants) do not harm this area over time.
Though PAHs have the ability to bioconoentrate, and therefore present a
potential hazard to migratory birds consuming prey from the site, on-site
soils containing elevated PAHs are confined to relatively small areas. This
confined distribution on the site reduces the probability i;hat individual
migratory birds will be exposed to a detrimental dose of FAHs. A target
level of 1.0 ppm has been proposed for soil PAHs. We expect this level to be
protective of migratory birds using the site.
-------
-3-
A clean up target for lead of 248 ppm has been proposed for on-site soils.
In general, the target level appears to be below soil levels reported in the
scientific literature as being associated with detrijnental effects- on biota.
SUMMARY CONCLUSION
Based on our understanding of site conditions, as summarized above, we
recommend
. ' the following standards for soil and sediments
(exclusive of Riggs Brook): clean up targets for PCBs, PAHs and lead of 1.0
ppro, 1.0 ppm, and 248 ppm, respectively.
Sincerely yours,
Gordon E. Beckett
Supervisor
New England Area
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
400 RALPH PILL MARKETPLACE
22 BRIDGE STREET
CONCORD, NEW HAMPSHIRE 03SO1-4901
Mr Michael Jasinski September 6, 1989
U.S. Environmental Protection Agency
JFK Building, HPS-1
Boston, MA 02203-2211
Dear Mr. Jasinski:
Ihis .responds to your August 23 request for comments relative to the likely
environmental impacts of Central Maine Power Company's (CMP) proposal to
remove and treat only those soils at the F. O'Connor Superfund Site with PCB
and PAH levels in excess of 10 ppm. In contrast to the CMP proposal, a
remedial action threshold of 1.0 ppm is proposed by EPA and FWS as the maximum
value most likely to protect migratory birds and other biota using the site.
Our logic for supporting the 1.0 ppm target level was discussed in several
meeting with EPA, MEDEP, CMP and its consultants, and is presented in-two
pieces of correspondence between our two offices.
The arguments presenting the CMP plan focus on PCB levels and their likely
effects on biota at the site. Our response to the CMP plan necessarily
focuses on the arguments made in support of the higher allowable PCB soil
concentrations.
CMP's contentions regarding the likely impact on living environmental
receptors of the more relaxed cleanup target are summarized on page 9 of their
August 18, 1989 letter to you, as follows:
"Sijiple food-chain modeling was conducted for exposure of two groups
of organisms, birds and mammals, expected at the site Based on
territory size and density data for individuals expected at the Site,
and conservative assumptions on dietary habits, it can be concluded that
a target clean-up level for soil of 10 prm wall vtequr.tely prctoot the
majority of avifauna foraging on-site."
We disagree with several important points presented in this statement and
its supporting documentation (i.e., Appendix B-2 of the Draft RI/FS, Nov.
1988). The major point of disagreement is with the statement that a soil
concentration of 10 ppm would be protective of the site's avifauna. CMP bases
this contention on data from the scientific literature that were used in the
food-chain modeling. However, some of these data were misinterpreted in
Appendix B-2. For example, in the food-chain model, CMP used a
biocbncentration factor (BCF) for ground-dwelling arthropods of 0.5. This is
extrapolated from a study of dioxins in arthropod prey of meadowlarks. The
prey of meadowlarks are typically vegetarians such as ^grasshoppers, crickets,
butterfly and moth larvae, and acfult beetles that live on or above the soil
surface. Any food-chain contamination of these insects would be expected to
occur via their food, which is predominantly plant material. Because plants
apparently do not significant mobilize dioxins from soil, we should expect the
-------
-2-
iow BCF of 0.5 reported in the cited study. We would expect a very different
BCF for soil in-fauna such as earthworms and carnivorous beetle larvae that
consume soil-living organism. The subsequent use of the 0.5 BCF-in PCB food-
chain modeling to represent levels in invertebrates other than earthworms,
biased downward the estimates of dietary exposures.
A related issue deals with effect levels in migratory birds. In Appendix B-2,
CMP summarizes PCB dietary studies cited in the Endangerment Assessment for
the site (ICF, 1988). That summary gives the impression that the levels
referenced represent the lowest Observable Effect Level (L.O.E.L.), when in
fact many of them simply represent the lowest level tested in a particular
study. In many of these studies, effects would likely have been observed
had lower levels been tested. In this vein, we note that Appendix B-2 does
not reference a study included in ICF's Endangerment Assessment describing a
chronic toxicity test in which Bengelese finches were exposed to PCBs
(Prestt, et al, 1970). Although the lethal dose to the "average" finch (i.e.,
LD-50) was estimated to be equivalent to a diet containing 2.5 ppro, some
finches in the test died at dietary concentrations equivalent to only 0.06 ppro
of PCBs. This study illustrates the fact that effect levels, as developed
from LD-50 data, usually overestimate the safe exposure level for all
individuals within the species.
However, despite these differences as discussed above, in Appendix B-2, CMP
estimates a worst case "no-effect" dietary exposure level of 1.5 ppm. This is
within the range of 1-3 ppm that we determined from the scientific literature
to be the probable minimum effect level (dietary). With this semblance of
agreement on dietary effects levels for birds, the critical issue of dietary
dose centers on BCFs and soil levels.
As discussed above, we believe that a BCF of 0.5 underestimates probable body
burdens in soil in-fauna, and therefore, also underestimates dietary exposure
in birds consuming soil invertebrates. Although not directly applicable to
soil BCFs, PCB BCFs detianrined in several studies for sediment-dwelling
invertebrates ranged from 0.3J (sediment PCB concentration of 0.3 ppm) to 4.43
(sediment PCB concentration of 28.0 ppm). As cited in Appendix B-2, at least
one study showed earthworms to have a PCB BCF of 5.8. Applying these numbers
to the BCF models for robin/killdeer and woodcock, and assuming an average
soil PCB concentration of 2.86 ppm as calculated by CMP, estimated dietary
intakes range from 8.8 to 14.7 ppm for robin /Xilldeer, and 12.8 to 15.7 for
woodcock. These levels significantly exceed the minimum dietary effect levels
estimated by us and CMP. If -jreater soil PCB levels are used in the model (as
opposed to the levels calculated by CMP), commensurately greater dietary
intake levels are predicted. Based on these models, birds (or other animals)
consuming the site's soil invertebrates as a major portion of their diets
would be at risk. In addition to the soil - invertebrate - bird PCB
mobilization model used in Appendix B-2, we expect other pathways for
contaminant uptake by birds using the site. Higher trophic level species
such as shrews, mice, frogs and salamanders exposed to contaminated soils and
soil-dwelling invertebrates will in turn be consumed by bird species using the
site such as the crow, blue jay, brown thrasher, American kestrel, sharp-
shinned hawk, red-tailed hawk, great horned owl, etc.
-------
-3-
Birds frequently dust themselves with soil to control external parasites,
thereby increasing the likelihood of dermal absorption, inhalation and
ingestion (during post-dusting preening). Similarly, direct ingestion of
soils occurs in species foraging on the soil surface. Uptake models and
effect levels are not developed for these supplemental pathways, and we
therefore cannot predict the impacts of uptake via these mechanisms. However,
these examples illustrate that bird species other than robin, killdeer and
woodcock are exposed to soil-borne contaminants even if they do not consume
significant quantities of soil in-fauna.
A ' final point of disagreement involves estimates by CMP of the number of
individuals of three bird species that would use the site. CMP uses data
from the scientific literature regarding breeding bird densities to estimate
the numbers of robin, killdeer and woodcocks that use the site. While the
logic used may apply to populations of individual bird species over large
areas, it is not necessarily applicable to smaller areas. For instance, in
the case of woodcock population estimates for the site, CMP assumes that only
one individual will use the site based on a study showing average densities on
large land tracts of 11.2 adults per 100 acres. Average densities developed
in this, way include acreage not suitable as habitat, but included in the
overall area evaluated. However, the O'Connor site is high quality woodcock
habitat, and exceeds the quality of "average" woodcock habitat as measured
over large land tracts. We therefore expect a density of greater than one
woodcock per 8.9 acres ( 11.2 woodcock per 100 acres). If the one woodcock
expected is a rale, we would also expect at least one female ( woodcock- are
polygamous) and at least 3-5 young. If we conservatively assume only one
female will nest on site, we would expect 5-7 woodcock to be exposed to
contaminants at the site each year. Similar arguments are also germane to
the site's potential killdeer and robin population densities, as well as other
species whose diets are comprised of soil-dwelling organisms or species which
prey on soil-dwelling organisms.
Therefore, we expect greater numbers of many species of birds using the site
to be at potential risk froa soil PCB levels exceeding 1.0 ppm. We do not
concur with CKP's contention that a soil PCB level of 10.0 ppm (or 2.86 ppm)
would be protective of migratory birds whose diet is significantly composed of
soil-dwelling organisms or consumers of soil-dwelling organisms.
Sincerely yours,
Gordon E. Beckett
Supervisor
New England Area
-------
STATE OF MAINE
I Department of Environmental Protection
/f/'f nt
JOHN n. mcKEKNAN. JR.
GOVERNOR
MAIN OFFICE: BAY BUILDING. HOSPITAL STREET. AUGUSTA
MAIL ADDRESS: Siale House Sution 17, Augusta. 04333
207-269-7688
COMMISSIONER
August 30, 1989
Mike Jasinski, Remedial Project Manager , ' oP
U.S. EPA '
Waste Management Division (WS-CAN 1)
JFK Federal Building
Boston. MA 02203
RE: F. O'Connor Superfund Site, Augusta, Maine
Target CJ.ean-up levels for PCB's and cPAHs
Dear Mr. Jasinski:
The following outlines the Maine Department of Environmental Protection's (DEP)
and the Maine Department of Human Services concerns regarding the selection of
one (1) ppm clean-up standards for PCB and cPAH contaminants for the above
referenced site:
1. Based on a December 5, 1988 interoffice memo from State Toxicologist
Dr. Robert Frakes, the Bureau of Health risk assessment policy states
that a reasonable (plausable) worst case assumption be used in
estimating the health risk associated in chemical exposure. For your
reference a copy of that memorandum is enclosed.
2. The Bureau of Health considers an upper level lifetime cancer risk of
one per one hundred thousand be used as a basis for public health
considerations.
3. Dr. Frakes calculated that 0.49 ppm PCB, and 0.33 ppm cPAH is the
target clean-up levels using the plausable maximum exposure
assumptions and the 10-5 risk level. This data was obtained from the
F.O'Conner Sites Endangerment Assessment.
If the 10-6 risk level were used for the calculation, a clean-up level
of 49 ppB, PCB .and 33 ppb cPAH would be the target levels.
4. Dr. Frakes referenced that a clean up level in the neighborhood of 1
ppm is substantiated by other agency policies.
5. The Department of the Interior (DOI) US Fish and Wildlife Service
supports a 0.34 ppm clean up level in order to protect terrestrial
REGIONAL OFFICES
Banner*
.Pr.tqu.lito-
-------
-2-
wildlife. This information is outlined in a September 6. 1988 memorandum,
which is also enclosed for your reference.
Central Maine Power on the other hand argues for a clean-up standards of 10 ppm
for PCB's based on the criteria of: 10-5 risk level and a most probable case
exposure scenario.
The DEP concurs with the EPA's proposed target clean-up level of 1 ppm for
PCB's an cPAH's for the F. O'Connor Superfund Site, in Augusta, Maine basded on
both environmental and public health standards.
The DEP trusts that this information is helpful to you and if you have
additional questions please don't hesitate to contact me at (207)289-2651.
Sincere
THOMAS BENN
Div. of Licensing a Enforcement
Bureau of Oil & Hazardous Materials Control
TB:al:tbjasinsk
cc: Robert Frakes, Bureau of Health
Al Prysunka, Department of Environmental Protection
Scott Whittier. Department of Environmental Protection
Don Robbins, Department of Environmental Protection
-------
McKr.ivm. If.
si Air or MA INK
OliPARTMI-NT ()l: HUMAN SI-RVICI-S
ADCIISI A. MAINI'CM.VI.l
MEMORANDUM
TO: Cynthia Kuhns, BOIIMC, D.H.P.
FROM: Robert Frakes, Ph.D., State Toxicologist, DHS
SUBJECT: O'Connor Site Target Clean-up levels for PCBs and cPAIIs
DATH: December 5, 1988
This is'a reiteration of my earlier comments on the proposed Target
Clean-up Levels for the O'Connor Site. You and T already presented these
arguments to HPA, CMP, H.C. Jordan, and Federal Natural Resource Trustees at a
meeting in Portland on September 28th.
Bureau of Health risk assessment policy calls for the use of reasonable
worst case assumptions for estimating the health risks associated with
chemical exposure. Also, the Bureau of Health considers an upper bound,
^hfelime cancer risk of one per one hundred thousand as a basis for a public
^Pllth concern (Policy for Identifying and Assessing the Health Risks of Toxic
Substances, 1988JITarget"clean-up levels for hazardous waste sites in Maine
should reflect both of these policies, except in the unusual situation where
clean up to these levels is not possible.
I have recalculated the target clean-up levels using the plausible maximum
exposure assumptions given in the F.ndangerment Assessment (Table 4-5):
A) Ago 1-5 yrs:
Contact: 2300 mg/day x 0.03 (absorption factor) x 200 days/365 days
x 5 yrs/70 yrs x 1/15 kg = 0.180 mg/kg/day
Ingcstion: 500 mg/day x 0.45 (absorption factor) x 200 days/365 days
x 5 yrs/70 yrs x 1/15 kg = 0.587 mg/kg/day
B) Agr 6-11 yrs:
Contact: 3500 mg/day x 0.03 x 200 days/365 days x 6 yrs/70 yrs
x 1/30 kg « 0.164 mg/kg/day
Ingestlon: 250 mg/day x 0.45 x 200 days/365 days x 6 yrs/70 yrs
x 1/30 kg » 0.176 mg/kg/day
-------
C) Age 12 - 18 yrs:
Contact: 5600 mg/day x 0.03 x 200 days/365 Hays x 7 yrs/70 yes
x 1/54 kg - 0.170 mg/kg/day
Ingestlon: 100 mg/day x 0.45 x 200 days/365 days x 7 yrs/70 yrs
x 1/54 kg - 0.046 mg/kg/day
Total Intake Factor Over 1R Year* « 1.32 mg/kg/dny
PCT Target Clean-tip Level 6.49 x IP"7 mg PCB/kg/day
HIT" mg SoilAgAlay " **** PI*
cPAM Target Clean-up Level « 4.35 x 10"7 mg cPAM/kg/day
O7~~ mg Soil/kg/day « 0.33 ppm
The above are based on a 10~5 upper Umlt cancer risk. For a 10"^
risk, the target clean-up levels would be 49 ppb Tor PCBs and 33 ppb for cPAHs.
In future risk assessments Tor hazardous waste sites, calculations should
be presented for both the average exposure ami the plausible maximum exposure.
Please note that the above calculations do not include adult exposures
through soil contact, such as home gardeners. Including these exposures would
result in lower target clean-up levels.
The 10"5 clean-up level calculated above for I'CBs (0.49 ppm) Is similar
to the PCB soil concentration proposed by the USFWS trustee for protection of
terrestrial wildlife (0.34 ppm). Also, the average case 10'6 target
clean-up level Is 2 ppm for PCBs and I ppm for cPAMs. These different
approaches all argue for a target clean-up level in the neighborhood of 1 ppm,
rather than the 10 ppm level proposed by the PRP.
cc: tani Graham, M.D.
Greg Bogdan, Dr. P.II.
Ann Melville
3657H/8-9
-------
*. STATE OF MAINE
»
!) Department of Environmental Protection
OFFICE: a*" B.H.C N5. > CS'i'*i S' W** AVO..-ST4
MAlt AOOACSS: ».*» -luff Sw ;.i -7. Ajy.i:.. 0::jJ
K'-JSJ-'W)
JOHN *. HeKMNAN, J*
..... .. ... ..,,._
OC*N ft MAMIOTT
September 26, 1989
Paul Keough/ Acting Regional Administrator
U.S. EPA, Region I . :
J.F. Kennedy Federal Building
Boston, MA 02203-2211
RE:' F. O'Connor Superfund Site in Augusta, Maine
Dear Mr. Keough: '
The Maine Department of Environmental Protection (DEP) has
reviewed the August 31, 1989 Draft Record of Decision (ROD) with '
regard to the Remedial Action remedy selection for the F.
O'Connor Superfund Site in Augusta, Maine.
Based on that review the DEP concurs with the selected
remedial action which consists of the comprehensive multi-
component approach for the overall site remediation of soils,
sediments, surface waters and groundwater contamination at the
site as outlined in the following:
I. Source Control
1. . Draining and treatment/disposal of surface water in tha
upland marsh and lagoons.
2. Re-routing of the existing surface water drainage
patterns.
3. Decontamination/demolition of the on-site barn.
4. Clearing of vegetation, installation of erosion control
measures, and excavation of contaminated soils and
sediments.
5. On-sit« treatment of contaminated soils and
lagoon/marsh sediments using a solvent extraction
technology.
6. Treatment of contaminated soil and sediment residue,
for that failing EP Toxicity tests, on-site using a
solidification/fixation process.
OFFICES
-------
7. Transportation and off-site disposal at a licensed
RCRA/TSCA landfill of solidified soil and-sediment
residue, and soil and sediment residue that does not
achieve all target cleanup levels following solvent
extraction.
8. Site restoration.
9. Establishing on-site compensatory wetlands of the
United States.
II. Management QT? Migration
A. Groundwater
1. Establishment of temporary institutional controls to
restrict site access and prohibit groundwater usage
until remediation goals are achieved.
2. Installation of on-site groundwater extraction well(s).
3 On-site groundwater treatment system and recharge
system installation.
4. Treatment system monitoring, and operation and
maintenance.
B. Ricfgs Brook Sediment
1. Establishment and implementation of extensive sediment
and biota sampling and analysis program within Riggs
Brook to monitor the effectiveness of the remedial
action.
2. Implementation of public education programs to increase
awareness regarding conditions at the Site.
This concurrence is based upon the State's understanding
that:
A. The DEP will participate in the n«gotiations with the
responsible parties and in the review and approval of
operational designs and monitoring plans for the site
clean up to the extent provided for in CERCLA.
B. In the event the agencies are unsuccessful in reaching
a signed agreement with the responsible parties to
undertake the selected remedial actions, the DEP will
agree to expend State Funds for ten (10) percent of the
EPA's remediation costs for the site. Based upon the
Draft ROD the DEP's share of ':he estimated costs will
be approximately 6ir322.00o. Those funds can be
allocated by the DEP from the Uncontrolled Hazardous
Substances Sites Bond Account.
-------
-s.^-' 2 T e 9 WED 10:17 MrtlNE DEP P . 0 T ^ 0 T
C. The groundwater extraction and treatment system will be
designed to remove and treat all identified hazardous
substances present in the groundwater to a level
acceptable to the Maine DEP and the EPA.
D. The site conditions shall be reviewed within five (5)
years from the initiation of the remedial action to
assure that public health and the environment are not
adversely impacted by the remedial actions.
The DEP looks forward to working with the EPA to resolve the
environnental problems posed by this site. If you need
additional information do not hesitate to call myself or members
of my staff.
Lqfcerely,
fan C. Marriott
Commissioner
cc: Al Prysunka, Director BOHMC
Scott Whittier, Director, Div. of Licensing & Enforcement
-------
O'Connor Co. Site
NPL Site Administrative Record
Index
Compiled: July 13, 1989
Updated: August 9, 1989
ROD Signed: September 27, 1989
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
One Kendall Squaie, Suite 2200 Cambridge, Massachusetts 02139 (617) 577-9915
-------
Introduction
This document is the Index to the Administrative Record for the O'Connor Co. Site
National Priorities List (NFL) site. Section I of the Index cites site-specific documents, and Section
n cites guidance documents used by EPA staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region I's Office in Boston,
Massachusetts, and at the Lithgow Public Library, Winthrop Street, Augusta, Maine 04330.
Questions concerning the Administrative Record should be addressed to the EPA Region I site
manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
-------
Section I
Site-Specific Documents
-------
ADMINISTRATIVE RECORD INDEX
for the
O'Connor Co. NPL Site
1.0 Pre-Remedial
1.2 Preliminary Assessment
1. "Potential Hazardous Waste Site Identification and Preliminary Assessment" Form,
EPA Region I (June 10,1982).
1.3 Site Inspection
1. "Potential Hazardous Waste Site - Site Inspection Report" Form, EPA Region I
(July 15,1982).
2. "Storage Facilities Site Inspection Report (Supplemental Report)" Form, EPA
Region I.
1.6 Hazardous Ranking System (HRS)
1. Hazardous Ranking Package, Ecology and Environment, Inc. (July 23, 1982).
1.13 FIT Related Correspondence
1. Memorandum from W.D. Wall, NUS Corporation to File (April 14,1983).
Concerning conversation regarding site history with Oliver G. Coulling,
F. O'Connor Company.
2.0 Removal Response
2.1 Correspondence
1. Memorandum from Donald F. Berger, EPA Region I to Elliot M. Thomas, EPA
Region I (August 28, 1984). Concerning attached preliminary data and map.
2. Letter from Clifford H. Goodail, Dyer, Goodall and Zeegers (Attorney for
F. O'Connor Company) to Marilyn Wade, EPA Region I (March 18, 1985).
Concerning container inventory and identification project with attached:
A. Letter from Clifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for
F. O'Connor Company) to Charles C. Bering, EPA Region I
(March 18, 1985). Concerning response to fencing plan.
B. Memorandum from David S. Dyer, Acheron Engineering Services to William
B. Ball, Acheron Engineering Services (February 21, 1985). Concerning
identification of tanks and drums to be sampled.
C. Site Map, Acheron Engineering Services (January 1985).
3. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (December 9, 1985). Concerning sampling events.
4. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (January 17, 1986). Concerning tank inspection and removal
plans.
5. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (January 17, 1986). Concerning Tank Sampling Analysis Plan.
6. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (March 28, 1986). Concerning QA/QC plan for tank
sample analysis.
7. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (June 2,1986). Concerning tank sampling program.
-------
2.1 Correspondence (cont'd.)
8. Telephone Notes Between Steven A. Serian, EPA Region I and Andrew K.
Towt, Central Maine Power Company (June 16,1986). Concerning extension of
fence.
9. Letter from Marc Guerin, Clean Harbors, Inc. to Andrew K. Towt, Central
Maine Power Company (October 9,1986). Concerning disposal facilities for
materials from tank cleaning phase.
10. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (November 26,1986). Concerning the solid waste area and
extension of the security fence.
11. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (December 2,1986). Concerning fencing requirements.
12. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (December 9,1986). Concerning temporary fencing and
attached site map.
13. Letter from Bruce A. Fowler, E.C. Jordan Co. to Andrew K. Towt, Central
Maine Power Company (July 23,1987). Concerning decontamination
procedures following scrap removal operations.
14. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (July 29,1987). Concerning the decontamination of trench
water and attached "Appendix 12.B. Correlation Chart of Screen Openings and
Sieve Sizes."
15. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company
(August 17,1987). Concerning potential danger to public posed by electrical
devices uncovered during scrap removal operation.
16. Memorandum from Steven A. Serian, EPA Region I to File (August 22,1988).
Concerning removal of contaminated PCBs adjacent to Route 17.
2.2 Removal Response Reports
Reports
1. "F. O'Connor Hazardous Waste Site," (TDD 01-8504-05) Roy F. Weston, Inc.
(May 30,1985).
2. Letter from William B. Ball, Acheron Engineering Services to Marilyn Wade,
EPA Region I (August 22,1985). Concerning transmittal of attached "Quality
Assurance Quality Control Project Plan for Chemical Analysis of Samples from
the O'Connor Hazardous Waste Site," ERCO/ENSECO Inc.
3. "Tank Sampling," Roy F. Weston, Inc. (December 5,1985).
4. "Project Operation Plan for Sampling and Analysis at the F. O'Connor Company
Site - Phase I - Hazardous Substance Identification, Removal and Disposal
Program for Storage Tanks and Drum Samples," Clean Harbors, Inc.
(July 31,1986).
5. "Appendix I - Health & Safety Plan," Clean Harbors, Inc. (July 31,1986).
6. "Appendix II - Field Sampling Standard Operating Procedures," Clean Harbors,
Inc. (July 31,1986).
7. "Appendix IJJ - Quality Assurance/Quality Control for Inorganic and Organic
Analysis," Clean Harbors, Inc. (July 31,1986).
8. "Appendix IV - Quality Assurance/Quality Control for Sample Collection and
Pollutant Analysis," Clean Harbors, Inc. (July 31,1986).
-------
2.2 Removal Response Reports (cont'd.)
9. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (October 5,1987). Concerning transmittal of attached:
A. "Uniform Hazardous Waste Manifest" Form, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(August 21,1987).
B. "Scrap Removal Program Summary," prepared by E.C. Jordan Co. for
Central Maine Power Company (October 1987).
Comments
10. Comments Dated April 15,1986 from Steven A. Serian, EPA Region I on the
"Quality Assurance Quality Control Project Plan for Chemical Analysis of
Samples from the O'Connor Hazardous Waste Site," ERCO/ENSECO Inc.
11. Comments Dated August 21,1986 from Charles Forfeit, EPA Region I on the
"Quality Assurance Quality Control Project Plan for Chemical Analysis of
Samples from the O'Connor Hazardous Waste Site," ERCO/ENSECO Inc.
12. Comments Dated October 20,1986 from Steven A. Serian, EPA Region I on the
July 31,1986 "Project Operation Plan for Sampling and Analysis at the F.
O'Connor Company Site - Phase I - Hazardous Substance Identification,
Removal and Disposal Program for Storage Tanks and Drum Samples," Clean
Harbors, Inc.
13. Comments Dated October 29,1987 from Steven A. Serian, EPA Region I on the
October 1987 "Scrap Removal Program Summary," prepared by E.C. Jordan Co. for
Central Maine Power Company.
Responses to Comments
14. Response Dated May 7,1986 from Andrew K. Towt, Central Maine Power
Company to the April 15,1986 Comments from Steven A. Serian, EPA
Region I.
15. Response Dated November 13,1987 from Andrew K. Towt, Central Maine
Power Company to the October 29,1987 Comments from Steven A. Serian, EPA
Region I.
2.3 Sampling and Analysis Data
1. Memorandum from Joseph Montanaro and Moira Lataille, EPA Region I to
Donald F. Berger, EPA Region I (August 21,1984). Concerning PCB screening
data.
2. Memorandum from Joseph Montanaro and Moira Lataille, EPA Region I to
Donald F. Berger, EPA Region I (August 23,1984). Concerning correction of
PCB screening data analytical procedure.
3. Memorandum from Joseph Montanaro and Moira Lataille, EPA Region I to
Donald F. Berger, EPA Region I (August 24,1984). Concerning soil analysis of
samples 53775 and 53772.
4. "Shallow Soils and Tank Sampling Plan," Acheron Engineering Services and
J.K. Richard Associates (March 1985).
5. Memorandum from Joseph Montanaro and Richard Siscanaw, EPA Region I to
Donald F. Berger, EPA Region I (December 2, 1985). Concerning
polychlorinated biphenyl and pesticide analysis in sediment and soil.
6. Memorandum from Marsha M. Lee, EPA Region I to Ira Leighton, EPA Region I
(December 23,1985). Concerning polychlorinated biphenyl analysis in
transformer fluid and waste oils.
-------
2.3 Sampling and Analysis Data (cont'd.)
7. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (January 15,1986). Concerning transmittal of attached "Shallow
Soils Sampling Program," Central Maine Power Company (January 1986).
8. Letter from Anthony F. Andronico, Roy F. Weston Inc. to Steven A. Serian,
EPA Region I (March 13,1986). Concerning sample numbers 77234 and
77239.
9. Letter from John D. Tewhey, E.G. Jordan Co. to Andrew K. Towt, Central
Maine Power Company (October 15,1987). Concerning transmittal of attached
"Proposed Electrical Equipment Soil Sampling Plan," prepared by E.C. Jordan
Co. for Central Maine Power Company (October 1987).
2.6 Work Plans and Progress Reports
Reports
1. "Proposal for the F. O'Connor Site - Augusta, Maine," Gean Harbors, Inc.
(August 21,1986).
2. Letter from John D. Tewhey, E.C. Jordan Co. to Andrew K. Towt, Central
Maine Power Company (July 1,1987) with attached "Scrap Removal Logistics
Plan," prepared by E.C. Jordan Co. for Central Maine Power Company
(July 1987).
Comments
3. Comments Dated September 8,1986 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the August 21,1986 "Proposal for
the F. O'Connor Site - Augusta, Maine," Clean Harbors, Inc.
4. Comments Dated October 7,1986 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the August 21,1986 "Proposal for
the F. O'Connor Site Augusta, Maine," Clean Harbors, Inc.
5. Comments Dated October 20,1986 from Steven A. Serian, EPA Region I on the
August 21,1986 "Proposal for the F. O'Connor Site - Augusta, Maine," Clean
Harbors, Inc.
6. Comments Dated July 24,1987 from Steven A. Serian, EPA Region I on the
July 1987 "Scrap Removal Logistics Plan," prepared by E.C. Jordan Co. for
Central Maine Power Company.
7. Comments Dated July 28,1987 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the July 1987 "Scrap Removal
Logistics Plan," prepared by E.C. Jordan Co. for Central Maine Power
Company.
Responses to Comments
8. Response Dated September 17,1986 from Marc Guerin, Clean Harbors, Inc. to
the September 8,1986 Comments from Cynthia M Kuhns, State of Maine
Department of Environmental Protection.
-------
3.0 Remedial Investigation (RI)
3.1 Correspondence
1. Telephone Notes Between Jeff Orient, NUS Corporation andJ.K. Richard and
Eric Sandin, J.K. Richard Associates (March 21,1985). Concerning surficial
deposits and shallow soil sampling.
2. Telephone Notes Between Gordon Fuller, State of .Maine Department of
Environmental Protection and Jeff Orient, NUS Corporation (March 21,1985).
Concerning groundwater contamination.
3. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (January 8,1986). Concerning transmittal of the work plan
modification proposal.
4. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (June 10,1986). Concerning transmittal of the Project
Operations Plan.
5. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (June 12,1986). Concerning transmittal of the Preliminary
ARARs Report
6. Letter from Steven A. Serian, EPA Region I to Bruce Fowler, E.G. Jordan Co.
(June 24,1986). Concerning monitoring wells.
7. Letter from Steven A. Serian, EPA Region I to John D. Tewhey, E.C. Jordan
Co. (July 23,1986). Concerning transmittal of comments on the Project
Operations Plan.
8. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to John D. Tewhey, E.G. Jordan Co. (August 13,1986). Concerning
partial approval of the Project Operations Plan.
9. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (August 18,1986). Concerning surficial soil sampling
grid.
10. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company
(September 3,1986). Concerning shallow soil sampling.
11. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (September 10,1986). Concerning September 15,1986
meeting regarding sampling.
12. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (September 22,1986). Concerning collection and analysis of
samples.
13. Memorandum to File, Bruce A. Fowler, E.G. Jordan Co. (October 23, 1986)
with attached October 6,1986 "Conference Report," prepared by E.C. Jordan
Co. for Central Maine Power Company.
14. Letter from Denis G. Young for Gretchen A. Mikeska, E.C. Jordan Co. to
Steven A. Serian, EPA Region I (October 24,1986). Concerning biotic
sampling.
15. Letter from Gretchen A. Mikeska, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (November 4, 1986). Concerning collection and preservation of aquatic
biota samples.
16. Letter from Bruce A. Fowler, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (November 19, 1986). Concerning sampling of monitoring and
domestic wells.
17. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (November 19, 1986). Concerning transmittal of attached
November 18,1986 Meeting Summary, E?A Region I, Camp Dresser & McKee
Inc., E.C. Jordan Co., and Central Maine Power Company.
18. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (December 1, 1986). Concerning response to
November 18,1986 meeting summary.
-------
3.1 Correspondence (cont'd.)
19. Meeting Notes, EPA Region I, U.S. Department of the Interior Fish and Wild
Life Service, Central Maine Power Company, E.G. Jordan Co., and Camp
Dresser & McKee Inc. (December 17,1986).
20. Letter from David Webster for Steven A. Serian, EPA RegioriTto Andrew K.
Towt, Central Maine Power Company (May 4,1987). Concerning summary of
the April 9,1987 meeting.
21. Memorandum from Brian Butler, Camp Dresser & McKee Inc. to Richard
Christian, Camp Dresser & McKee Inc. (May 26,1987). Concerning
April 28,1987 groundwater sampling round oversight
22. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company (June 1,1987).
Concerning invertebrate community structure analysis meeting of April 23,1987.
23. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (June 11,1987). Concerning attached summary of the
June 10,1987 Tour n sampling meeting.
24. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (June 15,1987) with attached July 15,1987
Memorandum from Bruce Fowler, E.C. Jordan Co. to Andrew K. Towt, Central
Maine Power Company. Concerning inorganic sample duplication.
25. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (June 16,1987). Concerning Tour n monitoring program of
the Remedial Investigation.
26. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company (June 23,1987).
Concerning June 10,1987 Tour n sampling meeting.
27. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (July 22,1987). Concerning August 4,1987 meeting
agenda.
28. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (August 11,1987). Concerning response to August 4,1987
Remedial Investigation meeting.
29. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company
(August 18,1987). Concerning decisions made at August 4,1987 meeting.
30. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (September 1,1987) with attached August 31,1987 Letter
from John D. Tewhey, E.C. Jordan Co. to Andrew K. Towt, Central Maine
Power Company. Concerning Endangerment Assessment planning,
coordination, and implementation.
31. Letter from Steven A. Serian, EPA F'.egion I to Andrew K. Towt, Central Maine
Power Company (September 17,1917). Concerning the Remedial Investigation/
Feasibility Study time line.
32. Letter from Andrew K. Towt, Central Maine Power Company to Romeo and
Pauline St. Pierre (May 17,1988). Concerning the attached test results from well
sampling.
33. Letter from Thomas Benn, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company
(September 8,1989). Concerning September 6,1989 meeting regarding Draft
Final Remedial Investigation/Feasibility Study.
34. Letter from Andrew K. Towt, Central Maine Power Company to Thomas Benn,
State of Maine Department of Environmental Protection (September 18,1989).
Concerning receipt of September 6,1989 letter from Thomas Benn and
clarification of Central Maine Power Company's position.
-------
3.2 Sampling and Analysis Data
The Sampling and Analysis Data for the Remedial Investigation (RJ) may be reviewed,
by appointment only, at EPA Region I, Boston, Massachusetts.
3.4 Interim Deliverables
Reports
1. "Remedial Action Master Plan," NUS Corporation (September 1983).
2. "Task 9 - Project Operations Plan - Remedial Investigation/Feasibility Study,"
prepared by E.C. Jordan Co. for Central Maine Power Company (August 1986).
Comments
3. Comments Dated August 15,1986 from Steven A. Serian, EPA Region I on the
August 1986 "Task 9 - Project Operations Plan - Remedial Investigation/
Feasibility Study," prepared by E.G. Jordan Co. for Central Maine Power
Company.
4. Comments Dated October 10, 1986 from Steven A. Serian, EPA Region I on the
August 1986 "Task 9 - Project Operations Plan - Remedial Investigation/
Feasibility Study," prepared by E.C. Jordan Co. for Central Maine Power
Company.
5. Comments Dated October 15,1986 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the August 1986 "Task 9 - Project
Operations Plan - Remedial Investigation/Feasibility Study," prepared by E.C.
Jordan Co. for Central Maine Power Company.
3.5 Applicable and Appropriate or Relevant Requirements (ARARs)
Reports
1. "Preliminary Indication of ARARs, Remedial Investigation/Feasibility Study -
Task 3," E.C Jordan Co. for Central Maine Power Company (June 1986).
2. "Preliminary Indication of ARARs, Remedial Investigation/Feasibility Study -
Task 3," E.C Jordan Co. for Central Maine Power Company (August 1987).
Comments
3. Comments Dated July 30, 1986 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the June 1986 "Preliminary Indication
of ARARs, Remedial Investigation/Feasibility Study - Task 3," E.C Jordan Co.
for Central Mane Power Company.
4. Comments Dated October 19,1987 from Steven A. Serian, EPA Region I on the
August 1987 "Preliminary Indication of ARARs, Remedial Investigation/
Feasibility Study - Task 3," E.C Jordan Co. for Central Maine Power Company.
Responses to Comments
5. Letter from Gretchen A. Mikeska, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (December 12, 1986). Concerning receipt of ARARs comments from
EPA Region I and State of Maine Department of Environmental Protection.
-------
3.6 Remedial Investigation (RI) Reports
Reports
1. First "Draft Remedial Investigation Report - Volume I: Technical Report,"
prepared by B.C. Jordan Co. for Central Maine Power Company
(December 1987).
2. First "Draft Remedial Investigation Report - Volume II: Appendices," prepared
by EC. Jordan Co. for Central Maine Power Company (December 1987).
3. Second "Draft Remedial Investigation/Feasibility Study - Volume I: Technical
Report Remedial Investigation," prepared by EC Jordan Co. for Central Maine
Power Company (November 1988).
4. Second "Draft Remedial Investigation/Feasibility Study - Volume H: Appendices
- Remedial Investigation," prepared by EC. Jordan Co. for Central Maine Power
Company (November 1988).
Figures 4-7 and 4-9 from the record cited in entry number 5 may be reviewed, by
appointment only, at EPA Region I, Boston, Massachusetts.
5. "Draft Final - Remedial Investigation/Feasibility Study - Volume I - Technical
Report - Remedial Investigation," prepared by E.C. Jordan Co. for Central Maine
Power Company (June 1989).
6. "Draft Final Remedial Investigation/Feasibility Study - Volume U, - Appendices -
Remedial Investigation," prepared by EC. Jordan Co. for Central Maine Power
Company (June 1989).
7. Errata Sheet for the June 1989 O'Connor Co. Site "Draft Final Remedial
Investigation/Feasibility Study," prepared by E.C. Jordan Co. for Central Maine
Power Company (July 19,1989).
Comments
8. Comments Dated March 30,1989 from Michael Jasinski, EPA Region I on the:
Second "Draft Remedial Investigation/Feasibility Study Volume I:
Technical Report - Remedial Investigation," prepared by E.C. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume II:
Appendices - Remedial Investigation," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume ffl:
Technical Report - Feasibility Study," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.C. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.C. Jordan Co. for Central Maine Power
Company (February 1989).
-------
3.6 Remedial Investigation (RJ) Reports (cont'd.)
9. Comments Dated April 10,1989 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the:
Second "Draft Remedial Investigation/Feasibility Study - Volume I:
Technical Report - Remedial Investigation," prepared by E.C. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume II:
Appendices - Remedial Investigation," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume HI:
Technical Report - Feasibility Study," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.C. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.C. Jordan Co. for Central Maine Power
Company (February 1989).
10. Questions and Request for EPA Clarification Dated April 26,1989 from James
R. Wallace, prepared by E.C. Jordan Co. for Central Maine Power Company on
the:
Second "Draft Remedial Investigation/Feasibility Study - Volume I:
Technical Report - Remedial Investigation," prepared by E.C. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume II:
Appendices - Remedial Investigation," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume UJ:
Technical Report - Feasibility Study," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.C. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.C. Jordan Co. for Central Maine Power
Company (February 1989).
Responses to Comments
11. Response Dated May 9,1989 from Michael Jasinski, EPA Region I to the
April 26, 1989 Comments from James R. Wallace, E.C. Jordan Co. for Central
Maine Power Company.
12. Response Dated June 30, 1989 from James R. Wallace, E.C. Jordan Co. for
Central Maine Power Company to the March 30, 1989 Comments from Michael
Jasinski, EPA Region L
-------
3.7 Work Plans and Progress Reports
Reports
1. "Appendix B - CERCLA 106 Consent Order - Work Plan - Remedial
Investigation/Feasibility Study," NUS Corporation (April 1986).
2. Monthly Progress Reports in Compliance with Items 37 and 53 of Docket No.
1-86-1031 Consent Agreement, prepared by Central Maine Power Company for
EPA Region I and State of Maine Department of Environmental Protection
(June 1986 through September 1989).
3. Letter from Bruce A. Fowler, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (September 9,1986). Concerning attached "Revised Groundwater
Monitoring Location Plan."
4. Letter from Gretchen A. Mikeska, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (September 10,1986). Concerning attached "Task 12 - Environmental
Assessment, Phase II - Biotic Sampling" Work Plan, prepared by E.G. Jordan
Co. for Central Maine Power Company.
5. Letter from Bruce A. Fowler, E.C. Jordan Co. to Steven A. Serian, EPA
Region I (October 16,1986). Concerning attached "Task 16 - Environmental
Sampling - Amended Sediment Sampling Program (10/16786)" Work Plan.
6. "Trip Report Biota Sampling - Task 12 - Environmental Assessment - Phase n -
Extent of Wetland Contamination," ECO-ANALYSTS, INC. (November 1986).
7. Trip Report on a Visit to O'Connor Co. Site, Natasha Brock, C.C. Johnson &
Malhotra and David Brooks, Camp Dresser & McKee Inc. (December 9,1986).
Concerning biotic sampling oversight
8. "Domestic Well Survey - Task 11," E.G. Jordan Co.
Comments
9. Comments Dated October 15,1986 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the "Domestic Well Survey -
Task 11," EC. Jordan Co.
10. Comments Dated October 17,1986 from Steven A. Serian, EPA Region I on the
"Domestic Well Survey - Task 11," prepared by E.C. Jordan Co. for Central
Maine Power Company and the "Task 12 - Environmental Assessment, Phase n -
Biotic Sampling" Work Plan, prepared by E.C. Jordan Co. for Central Maine
Power Company.
11. Comments from Susanna von Oettingen, U.S. Department of the Interior Fish
and Wildlife Service on the "Task 12 - Environmental Assessment,
Phase JJ - Biotic Sampling," Work Plan, prepared by E.G. Jordan Co. for Central
Maine Power Company.
3.9 Health Assessments
1. "Preliminary Health Assessment for F. O'Connor," U.S. Department of Health and
Human Services Public Health Service Agency for Toxic Substances and Disease
Registry (ATSDR) (April 10,1989).
2. Memorandum from Louise A. House, U.S. Department of Health and Human
Services Public Health Service Agency for Toxic Substances and Disease Registry
(ATSDR) to Michael Jasinski, EPA Region I (April 14,1989). Concerning
proposed target cleanup levels.
3.10 Endangerment Assessments
1. "Endangerment Assessment for the F. O'Connor Site in Augusta, Maine,"
Clement Associates, Incorporated for Camp Dresser & McKee Inc.
(January 29,1988).
-------
11
4.0 Feasibility Study (FS)
4.1 Correspondence
1. Letter from Steven A. Sedan, EPA Region I to Andrew K. Towt, Central Maine
Power Company (December 23,1987). Concerning remedial alternatives.
2. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (April 1,1988). Concerning Central Maine Power
Company's position regarding treatability studies.
3. Letter from Andrew K. Towt, Central Maine Power Company to Steven A.
Serian, EPA Region I (September 15,1988). Concerning proposed schedule
amendments.
4. Letter from Michael Jasinski, EPA Region I to James R. Wallace, E.C. Jordan
Co. (October 21,1988). Concerning transmittal of package containing EPA's
promulgated exemption rule for samples used in treatability studies.
5. Letter from Michael Jasinski, EPA Region I to James R. Wallace, E.C. Jordan
Co. (November 7, 1988). Concerning PCB treatment technologies.
6. Letter from William H. Laubenstein in, Central Maine Power Company to Elissa
Tonkin, EPA Region I (May 15,1989). Confirming the agreement reached on
May 11,1989 between EPA Region I and Central Maine Power Company.
7. Letter from William H. Laubenstein IJJ, Central Maine Power Company to Elissa
Tonkin, EPA Region I (May 23,1989). Concerning recommendation of PRPs
with attached May 23,1989 Letter from William H. Laubenstein III, Central
Maine Power Company to Elissa Tonkin, EPA Region I.
8; Letter from William H. Laubenstein IE, Central Maine Power Company to Elissa
Tonkin, EPA Region I (June 6,1989). Concerning transmittal of attached
May 19,1989 Letter from James R. Wallace, Combustion Engineering to
Andrew K. Towt, Central Maine Power Company.
9. Letter from Elissa Tonkin, EPA Region I to William H. Laubenstein UJ, Central
Maine Power Company (June 6,1989). Concerning response to May 23,1989
letters from William H. Laubenstein HI, Central Maine Power Company.
10. Letter from James R. Wallace, E.C. Jordan Co. to Andrew K. Towt, Central
Maine Power Company (June 29,1989). Concerning transmittal of the Proposed
Plan prepared by E.C. Jordan for Central Maine Power Company.
11. "Proposed Plan for Remedial Action - F. O'Connor Site," prepared by E.C.
Jordan Co. for Central Maine Power Company (June 1989).
12. Letter from William H. Laubenstein IJJ, Central Maine Power Company to Merrill
S. Hohman, EPA Region I (July 6, 1989). Concerning Central Maine Power
Company's Proposed Plan.
13. Cross Reference: Letter from Thomas Benn, State of Maine Department of
Environmental Protection to Andrew K. Towt, Central Maine Power Company
(September 8, 1989). Concerning September 6, 1989 meeting regarding Draft
Final Remedial Investigation/Feasibility Study [Filed and cited as entry number
33 in 3.1 Remedial Investigation (RI) Correspondence].
14. Cross Reference: Letter from Andrew K. Towt, Central Maine Power Company
to Thomas Benn, State of Maine Department of Environmental Protection
(September 18, 1989). Concerning receipt of September 6, 1989 letter from
Thomas Benn and clarification of Central Maine Power Company's position
[Filed and cited as entry number 34 in 3.1 Remedial Investigation (RI)
Correspondence].
-------
12
4.3 Scopes of Work
1. Letter from Andrew K. Towt, Central Maine Power Company to Michael
Jasinski, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (December 23,1988) with attached December 1988
"Request for Proposals for Bench Testing Solidification/Stabilization
Technologies," prepared by E.C. Jordan Co. for Central Maine Power Company.
4.4 Interim Deliverables
Reports
1. Letter from James R. Wallace and James R. Mihelcic, E.C. Jordan Co. to
Michael Jasinski, EPA Region I (February 14,1989). Concerning transmittal of
attached "Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.G. Jordan Co. for Central Maine Power
Company. ("Task Order Memorandum A", "Appendix A: Test Plan", "Appendix
B: Lab Notebook Record", and "Appendix C: PCB Chromatograms," of this
report contain Confidential Business Information (CBI) and are excluded.)
Comments
2. Comments Dated March 8,1989 from Edward R. Bates, U.S. EPA Office of
Research and Development on the "Summary of the Solvent Extraction
Treatability Study on Soils from the O'Connor Site," prepared by E.C. Jordan
Co. for Central Maine Power Company.
4.6 Feasibility Study (FS) Reports
Reports
1. First "Draft Feasibility Study Report," prepared by EC. Jordan Co. for Central
Maine Power Company (June 1988).
2. First "Draft Feasibility Study Report Supplement," prepared by E.C. Jordan Co.
for Central Maine Power Company (June 3,1988).
3. Second "Draft Remedial Investigation/Feasibility Study - Volume TEL: Technical
Report - Feasibility Study," prepared by E.G. Jordan Co. for Central Maine
Power Company (November 1988).
4. Second "Draft Remedial Investigation/Feasibility Study Volume IV:
Appendices - Feasibility Study," prepared by E.G. Jordan Co. for Central Maine
Power Company (November 1988).
5. "Draft Final - Remedial Investigation/Feasibility Study - Volume HI - Technical
Report - Feasibility Study," prepared by E.G. Jordan Co. for Central Maine
Power Company (June 1989).
6. "Draft Final - Remedial Investigation/Feasibility Study - Volume IV -
Appendices - Feasibility Study," prepared by E.G. Jordan Co. for Central Maine
Power Company (June 1989).
7. Cross Reference: Errata Sheet for the June 1989 O'Connor Co. Site "Draft Final
Remedial Investigation/Feasibility Study," prepared by E.G. Jordan Co. for
Central Maine Power Company (July 19,1989) [Filed and cited as entry number
7 in 3.6 Remedial Investigation (RJ) Reports].
-------
reasiouity Mudy (FS) Reports (cont'd.)
Comments
8. Comments Dated June 27,1988 from Steven A. Sedan, EPA Region I on the
June 1988 First "Draft Feasibility Study Report," prepared by E.G. Jordan Co.
for Central Maine Power Company.
9. Comments Dated October 3,1988 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the June 1988 First "Draft
Feasibility Study Report," prepared by E.G. Jordan Co. for Central Maine
Power Company.
10. Cross Reference: Comments Dated March 30,1989 from Michael Jasinski,
EPA Region I on the:
Second "Draft Remedial Investigation/Feasibility Study - Volume I:
Technical Report - Remedial Investigation," prepared by E.G. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume II:
Appendices - Remedial Investigation," prepared by E.G. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume HI:
Technical Report - Feasibility Study," prepared by E.G. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.G. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.G. Jordan Co. for Central Maine Power
Company (February 1989)
[Filed and cited as entry number 8 in 3.6 Remedial Investigation (RI) Reports].
11. Cross Reference: Comments Dated April 10,1989 from Cynthia M. Kuhns,
State of Maine Department of Environmental Protection on die:
Second "Draft Remedial Investigation/Feasibility Study - Volume I:
Technical Report - Remedial Investigation," prepared by E.G. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume U:
Appendices - Remedial Investigation," prepared by E.G. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume HI:
Technical Report - Feasibility Study," prepared by E.G. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.G. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Treatability Study on Soils from the
O'Connor Site," prepared by E.G. Jordan Co. for Central Maine Power
Company (February 1989)
[Filed and cited as entry number 9 in 3.6 Remedial Investigation (RI) Reports].
-------
14
4.6 Feasibility Study (FS) Reports (cont'd.)
12. Cross Reference: Comments Dated April 26,1989 from James R. Wallace,
prepared by E.C. Jordan Co. for Central Maine Power Company on the:
Second "Draft Remedial Investigation/Feasibility Study - Volume I:
Technical Report - Remedial Investigation," prepared by E.C. Jordan Co.
for Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume JJ:
Appendices - Remedial Investigation," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume JH:
Technical Report - Feasibility Study," prepared by EC. Jordan Co. for
Central Maine Power Company (November 1988),
Second "Draft Remedial Investigation/Feasibility Study - Volume IV:
Appendices - Feasibility Study," prepared by E.C. Jordan Co. for Central
Maine Power Company (November 1988),
"Summary of the Solvent Extraction Instability Study on Soils from the
O'Connor Site," prepared by E.C. Jordan Co. for Central Maine Power
Company (February 1989)
[Filed and cited as entry number 10 in 3.6 Remedial Investigation (RI) Reports].
13. Comments Dated June 29,1989 from Richard Christian, Camp Dresser &
McKee Inc. on the June 1989 "Draft Final Remedial Investigation/Feasibility
Study - Volume IV - Appendices - Feasibility Study," prepared by E.C. Jordan
Co. for Central Maine Power Company.
Responses to Comments
14. Response Dated August 5,1988 from James R. Wallace and Patricia lanni, E.C.
Jordan Co. for Central Maine Power Company to the June 27,1988 Comments
from Steven A. Serian, EPA Region I.
15. Cross Reference: Response Dated May 9,1989 from Michael Jasinski, EPA
Region I to the April 26,1989 Comments from James R. Wallace, E.C. Jordan
Co. for Central Maine Power Company [Filed and cited as entry number 11 in
3.6 Remedial Investigation (RI) Reports].
16. Cross Reference: Response Dated June 30,1989 from James R. Wallace, E.C.
Jordan Co. for Central Maine Power Company to the March 30,1989
Comments from Michael Jasinski, EPA Region I [Filed and cited as entry
number 12 in 3.6 Remedial Investigation (RI) Reports].
Comments on the Feasibility Study (FS) Report received by EPA Region I during the
formal public comment period are filed and cited in S3 Responsiveness Summaries.
4.7 Work Plans and Progress Reports
Reports
1. Letter from Denise Reynolds for James R. Wallace and Jeffrey Brandow, E.C.
Jordan Co. to Andrew K. Towt, Central Maine Power Company
(October 31,1988). Concerning transmittal of attached:
A. "Laboratory-Scale Treatability Testing of the Solvent Extraction Process for
the F. O'Connor Site - Workplan (Draft)," prepared by E.C. Jordan Co. for
Central Maine Power Company (November 1,1988). (Appendu B of this
document contains Confidential Business Information (CBI) material and is
excluded.)
B. "Request for Proposals for Bench Testing Solvent Extraction Technologies,"
prepared by E.C. Jordan Co. for Central Maine Power Company
(November 1988).
-------
4.7 Work Plans and Progress Reports (cont'd.)
Comments
2. Comments Dated November 14,1988 from Michael Jasinski, EPA Region I on
the November 1,1988 "Laboratory-Scale Treatability Testing of the Solvent
Extraction Process for the F. O'Connor Site - Workplan (Draft)," prepared by
E.C. Jordan Co. for Central Maine Power Company.
3. Comments Dated November 14, 1988 from Cynthia M. Kuhns, State of Maine
Department of Environmental Protection on the November 1,1988
"Laboratory-Scale Treatability Testing of the Solvent Extraction Process for the
F. O'Connor Site - Workplan (Draft)," prepared by E.C. Jordan Co. for Central
Maine Power Company.
4.9 Proposed Plans for Selected Remedial Action
1. "EPA Proposes Cleanup Plan for the O'Connor Superfund Site," EPA Region I
(July 1989).
Comments on the Proposed Plan received by EPA Region I during the formal public
comment period are filed and cited in 5.3 Responsiveness Summaries.
5.0 Record of Decision (ROD)
5.1 Correspondence
1. Memorandum from Jonathan Z. Cannon, EPA Headquarters to Regional
Administrators, Regions I-X (May 25,1989) with attached list of NPL sites
delegated to Regional Administrators.
2. Letter from William H. Laubenstein IE, Central Maine Power Company to Elissa
Tonkin, EPA Region I (June 6,1989) with attached May 19,1989 Letter Report
from James R. Wallace, Combustion Engineering to Andrew K. Towt, Central
Maine Power Company.
3. Memorandum from Edward R. Bates, U.S. EPA Office of Research and
Development to Michael Jasinski, EPA Region I (September 8, 1989).
Concerning selection of remedial alternative for the O'Connor site.
4. Memorandum from Elissa Tonkin, EPA Region I to Michael Jasinski, EPA
Region I (September 25,1989). Concerning review and response to
September 8,1989 Letter from Edward R. Bates.
5. Letter from Dean C. Marriott, State of Maine Department of Environmental
Protection to Paul G. Keough, EPA Region I (September 26, 1989). Concerning
State of Maine Department of Environmental Protection's review and concurrence
with selection of the remedy at the O'Connor site.
-------
16
5.3 Responsiveness Summaries
1. Cross Reference: Responsivness Summary is Appendix A of the Record of
Decision [Filed and cited as entry number 1 in 5.4 Record of Decision (ROD)].
The following citations indicate written comments received by EPA Region I during the
formal public comment period.
2. Comments Dated August 17,1989 from William H. Bostard, Harmon
Environmental Services, Inc. on the July 1989 "EPA Proposes Cleanup Plan for
the O'Connor Superfund Site," EPA Region L
3. Comments Dated August 18,1989 from William H. Laubenstein 01, Central
Maine Power Company on the July 1989 "EPA Proposes Cleanup Plan for the
O'Connor Superfund Site," EPA Region I.
4. Comments Dated August 18,1989 from Dean C. Marriott, State of Maine
Department of Environmental Protection on the July 1989 "EPA Proposes
Cleanup Plan for the O'Connor Superfund Site," EPA Region I.
5.4 Record of Decision (ROD)
1. Record of Decision, EPA Region I (September 27,1989).
9.0 State Coordination
9.1 Correspondence
1. letter from Marilyn Wade, EPA Region I to State of Maine Executive Department
(December 24,1984). Concerning proposed site activities and the
intergovernmental review process.
2. Letter from Harold Kimball, State of Maine Executive Department to Marilyn
Wade, EPA Region I (March 22,1985). Concerning intergovernmental review.
3. Letter from Thomas Benn, State of Maine Department of Environmental
Protection to Michael Jasinski, EPA Region I (August 30,1989). Concerning
target clean-up levels for PCBs 2nd cPAHs with attached:
A. Memorandum from Robert Fr.ikes, State of Maine Department of Human
Services to Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (December 5,1988). Concerning proposed target
clean-up levels for PCBs and cPAHs.
B. Memorandum from Kenneth Carr, U.S. Department of the Interior Fish and
Wildlife Service to Steven A. Serian, EPA Region I (September 6,1988).
Concerning soil target levels for PCBs. (A section of this memorandum has
been redacted.)
10.0 Enforcement
10.7 EPA Administrative Orders
1. Executive Summary of the O'Connor Co. Site with attached Unilateral
Administrative Order, In the Matter of The F. O' Connor Company\ Docket No.
1-85-1031 (December 21, 1984).
2. Administrative Order by Consent, In the Matter of The F. O'Connor Site,
F. O'Connor Company and Central Maine Power Company, Docket No.
1-86-1031 (May 13,1986).
3. Amended Administrative Order by Consent, In the Matter of The F. O'Connor
Site, F. O'Connor Company arid Central Maine Power Company, Docket No.
1-86-1031 (March 23,1987).
-------
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
1. Letter from Merrill S. Hohman, EPA Region I to Clifford H. Goodall, Dyer
Goodalland Zeegers (Attorney fprF. O'Connor Company) (April 18,1985).
Concerning notification of potential liability.
2 Letter from Merrill S. Hohman, EPA Region I to Mathew Hunter, Central Maine
Power Company (April 22,1985). Concerning notification of potential liability.
3. Letter from Cynthia M. Kuhns, State of Maine Department of Environmental
Protection to Andrew K. Towt, Central Maine Power Company
(November 3,1987). Concerning Tour II Data Package with attached:
A. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central
Maine Power Company (November 17,1986). Concerning approval for
Central Maine Power Company to send wastes to specified facilities.
B. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central
Maine Power Company (November 26,1986). Concerning solid waste area
and extension of security fence.
4. Letter from William H. Laubenstein HI, Central Maine Power Company to Steven
A. Serian, EPA Region I and Cynthia M. Kuhns, State of Maine Department of
Environmental Protection (October 11,1988). Concerning action in response to
respondents' request for a waiver of time requirements.
5. Letter from Elissa Tonkin, EPA Region I to William H. Laubenstein HI, Central
Maine Power Company (October 11,1988). Concerning confirmation that EPA
Region I and Central Maine Power Company have agreed to extend the dispute
resolution period.
6. Letter from William H. Laubenstein in, Central Maine Power Company to
Michael Jasinski, EPA Region I and Cynthia M. Kuhns, State of Maine
Department of Environmental Protection (October 13,1988). Concerning the
extension of time to resolve the dispute surrounding the Pilot Study/Feasibility
Study.
7. Letter from William H, Laubenstein in, Central Maine Power Company to
Michael Jasinski, EPA Region I and Cynthia M. Kuhns, State of Maine
Department of Environmental Protection (October 13,1988). Concerning the
schedule for the Pilot Study/Feasibility Study.
8. Cross Reference: Letter from James R. Wallace, E.G. Jordan Co. to Andrew K.
Towt, Central Maine Power Company (June 29,1989). Concerning transmittal
of the Proposed Plan prepared by E.G. Jordan for Central Maine Power
Company [Filed and cited as entry number 10 in 4.1 Correspondence].
9. Cross Reference: "Proposed Plan for Remedial Action - F. O'Connor Site,"
prepared by E.G. Jordan Co. for Central Maine Power Company (June 1989).
[Filed and cited as entry number 11 in 4.1 Correspondence].
13.0 Community Relations
13.1 Correspondence
1. "Requests to EPA from the Maine People's Alliance," Maine People's Alliance
(May 8, 1985).
2. Letter from Merrill S. Hohman, EPA Region I to Cathy Hinds, Maine People's
Alliance (June 28,1985). Concerning response to questions asked in
May 8, 1985 "Requests to EPA from the Maine People's Alliance."
3. Letter from Patty D'Andrea, EPA Region I to Henry D. Aho, State of Maine
Department of Environmental Protection (August 6,1985). Concerning
transmittal of Draft Community Relations Plan.
4. Letter from Andrew K. Towt, Central Maine Power Company to Marilyn Wade,
EPA Region I (November 18,1985). Concerning public notification of all
activity at the site.
-------
13.1 Correspondence (cont'd.)
5. Letter from Steven A. Serian, EPA Region I to Andrew K. Towt, Central Maine
Power Company (April 28,1986). Concerning transmittal of the Draft
Community Relations Plan.
6. Letter from Steven A. Serian, EPA Region I to John Edgerly, Cky of Augusta
(January 19,1988). Concerning Superfund site activities.
7. Letter from Steven A. Serian, EPA Region I to Daniel Fitzpatrick, City of
Augusta (February 1,1988). Concerning activities planned by EPA Region I and
Maine Department of Environmental Protection.
8. Letter from Michael Jasinski, EPA Region I to Madeline Cyr, City of Augusta
Clerk's Office (July 12,1989). Concerning transmittal of four volume Remedial
Investigation/Feasibility Study and the Proposed Plan.
13.2 Community Relations Plans
1. "Draft Community Relations Plan," NUS Corporation (August 1985).
2. "Community Relations Plan," NUS Corporation (September 1985).
13.3 News Clippings/Press Releases
1. "Environmental News," EPA Region I (December 27,1984). Concerning
Administrative Order requiring a plan to secure the site.
2. "Environmental News," EPA Region I (May 12,1986). Concerning
Administrative Consent Order for the Remedial Investigation.
3. "Central Maine Power News," Central Maine Power Company (May 13,1986).
Concerning agreement to conduct the Remedial Investigation and Feasibility
Study.
4. "Environmental News," EPA Region I (May 13,1986). Concerning Central
Maine Power Company and EPA Region I Consent Agreement to conduct the
Remedial Investigation/Feasibility Study.
5. "Environmental News - Public Meeting to Explain Plans for the F. O'Connor
Superfund Site Announced," EPA Region I (June 1986).
6. "For Release," Central Maine Power Company (March 4,1987). Concerning
completion of the first phase of sampling for PCB contamination.
7. "Environmental News," EPA Region I (March 25,1987). Concerning modified
Administrative Csnsent Order.
8. "The United States Environmental Protection Agency Invites Public Comment on
the Feasibility Study and Proposed Plan for the O'Connor Co. Site in Augusta,
Maine and Announces the Availability of the Site Administrative Record,"
Kennebec Journal - Augusta, Maine (July 12,1989).
9. "EPA Proposes $13.2 Million Junkyard Cleanup," Portland Press Herald -
Portland Maine (July 14,1989).
10. "EPA Officials Explain O'Connor Site Plan," Kennebec Journal - Augusta, Maine
(July 20,1989).
11. "Environmental News - Media Advisory," EPA Region I (August 8,1989).
Concerning public hearing to be held on August 10,1989.
12. "Residents Tell CMP to 'Clean up Mess' at O'Connor Junkyard," Kennebec
Journal - Augusta, Maine (August 11,1989).
13. "Environmental News - EPA to Hold Press Conference Regarding Cleanup Plans
for O'Connor Co. Superfund Site," EPA Region I (September 26,1989).
14. "Environmental News - EPA Announces Cleanup Plans for the O'Connor Co.
Superfund Site in Augusta, Maine," EPA Region I (September 28, 1989).
-------
13.4 Public Meetings
1. "Draft Summary of the RI/FS Startup Public Meeting," EPA Region I
(June 11,1986).
2. EPA Region I Meeting Agenda, Public Informational Meeting for the O'Connor
Co. Superfund Site (July 19,1989).
3. "Alternatives Evaluated and EPA's Preferred Alternative," Public Hearing Handout
for the O'Connor Co. Superfund Site (August 10,1989).
4. Cross Reference: Transcript, Proposed Plan Public Meeting for the O'Connor Co.
Site (August 10,1989) [Filed and included as Exhibit B in entry number 1 in 5.3
Responsiveness Summaries].
5. Letter from William H. Laubenstein HI, Central Maine Power Company to Michael
Jasinski, EPA Region I (August 18,1989). Concerning transmittal of attached
exhibits used by Central Maine Power Company during its comments at the
August 10,1989 Public Hearing.
13.5 Fact Sheets
1. "Superfund Program: Plans for Remedial Investigation/Feasibility Study," EPA
Region I (May 1986).
2. "Summary of the Record of Decision," EPA Region I (September 1989).
9
13.6 Mailing Lists
1. Mailing List, members of the public to receive information on the O'Connor Co. Site.
14.0 Congressional Relations
14.1 Correspondence
1. Letter from John R. McKernan Jr., Member of the U.S. House of
Representatives to Michael R. Deland, EPA Region I (June 14,1984).
Concerning the request for action to minimize threat of O'Connor site.
2. Letter from Michael R. Deland, EPA Region I to John R. McKeman Jr., Member
of the U.S. House of Representatives (July 13,1984). Concerning response to
June 14, 1984 letter.
16.0 Natural Resource Trustee
16.1 Coirespondence
1. Letter from Gordon E. Beckett, U.S. Department of the Interior Fish and Wildlife
Service to Steven A. Serian, EPA Region I (April 17, 1987). Concerning
confirmation of agreement reached at April 9, 1987 and April 10, 1987 meetings.
2. Letter from Patricia L. Meaney for MemJl S. Hohman, EPA Region I to William
Patterson, U.S. Department of the Interior (May 26, 1987). Concerning
notification of potential damages to natural resources.
3. Letter from Patricia L. Meaney for Merrill S. Hohman, EPA Region I to Sharon
Christopherson, U.S. Department of Commerce National Oceanic and
Atmospheric Administration. Concerning notification of potential damages to
natural resources (May 26, 1987).
4. Letter from Gordon E. Beckett, U.S. Department of the Interior Fish and Wildlife
Service to Steven A. Serian, EPA Region I (July 21,1987). Concerning receipt
of Trustee Notification Form,
5. Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Steven A. Serian, EPA Region I.
(June 28,1988). Concerning preferred target levels in Riggs Brook.
-------
20
16.1 Correspondence (cont'd.)
6. Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Steven A. Sedan, EPA Region I
(September 6,1988). Concerning monitoring as a component'to any selected
remedy.
7. Memorandum from Kenneth Carr, U.S. Department of the Interior Fish and
Wildlife Service to Steven A. Serian, EPA Region I (September 6,1988).
Concerning soil target levels for PCBs. (A section of this memorandum has been
redacted.)
8. Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Michael Jasinski, EPA Region I
(February 14,1989). Concerning target levels chosen on-site and in Riggs
Brook.
9. Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Michael Jasinski, EPA Region I
(February 27,1989). Concerning lead and aluminum levels in Riggs Brook
sediment and/or surface water.
10. Letter from Gordon E. Beckett, U.S. Department of the Interior Fish and Wildlife
Service to Michael Jasinski, EPA Region I (April 7,1989). Concerning tentative
clean-up levels chosen for contaminants at the O'Connor Co. site.
11. Letter from Gordon E. Beckett, U.S. Department of the Interior Fish and Wildlife
Service to Paul G. Keough, EPA Region I (August 25,1989). Concerning
formulating a decision with respect to remediation of environmental impacts at the
O'Connor Co. site. (A section of this letter has been redacted.)
12. Letter from Gordon E. Beckett, U.S. Department of the Interior Fish and Wildlife
Service to Michael Jasinski, EPA Region I (September 6,1989). Concerning
likely environmental impacts of Central Maine Power Company's proposal to
remove and treat only those soils with PCB and PAH levels in excess of 10 parts
per million (ppm).
16.4 Trustee Notification Form and Selection Guide
1. " Trustee Notification Form," EPA Region I.
16.5 Technical Issue Papers
1. "A Discussion of PCB Target Levels in Aquatic Sediments," L. Jay Field, U.S.
Department of Commerce National Oceanic and Atmospheric Administration and
Robert N. Dexter, EVS Consultants, Inc. (January 11,1988).
17.0 Site Management Records
17.2 Access Records
1. Letter from Henry D. Aho, State of Maine Department of Environmental
Protection to William O'Connor (June 18,1984). Concerning access to his
property on June 26,1984 and June 27,1984 by EPA Region I.
-------
21
17.3 Site Security Records
Reports
1. Letter from Clifford H. Goodall, Dyer, Goodall and Zeegers (Attorney for
F. O'Connor Company) to Charles C. Bering, EPA Region I (February 6,1985)
with attached February 6,1985 "Site Security Plan," F. O'Connor Company.
Comments
2. Comments Dated March 11,1985 from Charles C. Bering, EPA Region I on the
February 6,1985 "Site Security Plan," F. O'Connor Company.
Responses to Comments
3. Response Dated March 18,1985 from Clifford H. Goodall, Dyer, Goodall and
Zeegers (Attorney for F. O'Connor Company) on the March 11,1985 Comments
from Charles C. Bering, EPA Region L
17.4 Site Photographs/Maps
In addition to the maps contained in the June 1989 "Draft Final Remedial
Investigation/Feasibility Study," E.C. Jordan Co. for Central Maine Power Company
(See 3.6 Remedial Investigation (RI) and 4.6 Feasibility Study (FS)), the following
may be reviewed, by appointment only, at EPA Region I, Boston, Massachusetts:
1. Site Contour Map of Tank Locations, Acheron Engineering Services,
(May 16,1985).
2. Map of Shallow Soils Location Plan, J.K. Richard Associates (June 4,1985).
3. Book of Site Photographs and Slides of the O'Connor Co. Site from 1986 to
1988 containing:
A. Initial Site Walkover (August 20,1986).
B. Surficial Soil Sampling.
C. Surface Water and Sediment Sampling (October 21,1986).
D. Tank Removal (October 1986).
E. Area m, Snow Fence Confirmation Area (March 1987).
F. Flood Photos of Site (April 1987).
G. Test Pit Subsurface Soil Sampling (July 1987).
H. Scrap Removal and Transformer Locations (August 1987).
I. Transformer Locations After Removal (August 1987).
J. Transformer Locations Grab Sampling (Post Removal)
(October 30,1987).
K. Groundwater Sampling (December 1986).
4. Contour Map showing the location of scrap and white goods at the O'Connor Co.
Site, E.C. Jordan Co.
5. Site Map of the O'Connor Co. Site and Surrounding Area.
6. Contour Map of the O'Connor Co. Site and Surrounding Area, E.C. Jordan Co.
17.8 State and Local Technical Records
1. "Well Samples Taken 3/13/78."
2. Letter from Gardner S. Hunt, State of Maine Department of Environmental
Protection to Richard Dinitto, Ecology and Environment, Inc. (March 31,1981)
with attached sampling and analysis data.
-------
Section II
Guidance Documents
-------
Page 22
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EPA Guidance Documents
1. "National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
Regulations (Title 40, Part 300), 1985.
2. Comprehensive Environmental Response. Compensation, and Liability Act of 1980. amended
- October 17,1986.
3. "National Oil and Hazardous Substances Pollution Contingency Plan," Proposed Rule. 53
Federal Register 51394. December 21,1988.
4. Memorandum from John W. Lyon, U.S. Environmental Protection Agency Toxic Substance
Division to Sanfprd W. Harvey, Jr., Enforcement Division, EPA Region TV (August 3,1979).
Concerning applicability of PCB regulations to spills which occurred prior to the effective date
of the 1978 regulation.
5. U.S. Environmental Protection Agency. Office of Emergency and RemediaLResponse.
Community Relations in Superfund: A Handbook (Interim Version') (EPA/HW-6, OSWER
Directive 9230.0-3A), March 1986.
6. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. '
Interim Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA (EPA/540/G-89/004) (OSWER Directive 9355.3-01), October 1988.
7. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Remedial Design and Remedial Action Guidance (OSWER Directive 9355.0-4A),
June 1986.
8. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Office
of Solid Waste and Emergency Response. Draft Guidance - CERCLA Compliance: with Other
Laws Workshop August 8,1988.
9. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Handbook for Stabilization/Solidification of
Hazardous Wastes (EPA;540/2-86/001), June 1986.
10. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-01), November 1986.
11. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites
(EPAy540/G-88/003) (OSWER Directive 9283.1-2), December 1988.
12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24,1986.
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Quality Objectives for Remedial Response Activities: Development Process
(EPA/540/G-87/003), March 1987.
-------
14. "Hazardous Waste Management System; Land Disposal Restrictions; Final Rule," (40 CFR
Parts 260 et al.) Federal Register. Volume 51, No. 216 (November 7,1986).
15. Memorandum from J. Winston Porter to Addressees ("Regional Administrators, Regions I-X;
Regional Counsel, Regions I-X; Director, Waste Management Division, Regions I, IV, V, vn,
and VIZI; Director, Emergency and Remedial Response Division, Region II; Director,
Hazardous Waste Management Division, Regions m and VI; Director, Toxics and Waste
Management Division, Region DC; Director, Hazardous Waste Division, Region X; *
Environmental Services Division Directors, Region I, VI, and VII"), July 9,1987 (discussing
interim guidance on compliance with applicable or relevant and appropriate requirements).
16. Memorandum from Stephen Joyce and Jamie Katz, EPA Region I to Merrill S. Hohman and
Patricia L. Meaney, EPA Region I (July 24,1987). Concerning the evaluation of the Toxic
Substances Control Act (TSCA) Requirements as Applicable or Relevant and Appropriate
Requirements (ARARs) for the Resolve, Inc. Superfund Site.
17. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
A Compendium of Technologies Used in the Treatment of Hazardous Waste
(EPA/625/8-87/014), September 1987.
18. Memorandum from Denise M. Keehner, U.S. Environmental Protection Agency, Chemical
Regulation Branch to Bill Hanson, U.S. Environmental Protection Agency, Site Policy and
Guidance Branch (October 14,1987). Concerning comments on the PCB
Contamination-Regulatory and Policy Background Memorandum.
19. "Guidelines for PCB Levels in the Environment." The Hazardous Waste Consultant
pp. 26 - 32 (January/February 1988).
20. "Summary of the Requirements: Land Disposal Restrictions Rule," EPA Region L
O'Connor NPL Site Specific Guidance Documents
1. "Appendix D - Protection of Wetlands: Executive Order 11990," 42 Federal Register 26961
(1977).
2. "Classification of Surface Waters," Maine Department of Environmental Protection
(September 1979).
3. "Project Summary: Report on the Feasibility of APEG Detoxification of Dioxin-Contaminated
Soils," Albert Klee, Charles Rogers, and Thomas Tiernan, EPA Region V (April 1984).
4. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
Risk Analysis of TCDD Contaminated Soil rEPA-6QQ/8-84-Q31). 1984.
5. Record of Decision, Wide Beach, New York, EPA Region JJ, New York, New York
(September 30,1985).
6. "Project Summary: Destruction of PCBs-Environmental Applications of Alkali Metal
Polyethylene Glycolate Complexes," Frank J. laconianni, EPA Region V (December 1985).
7. "Chemical Reaction of Polychlorinated Biphenyls on Soils with Poly(Ethylene Glycol)/KOH,"
D.J. Brunelle and Daniel A. Singleton, General Electric Corporate Research and Development
(1985).
-------
Page 24
8. "PCB Destruction: A Novel Dehalogenation Reagent," Alfred Komel and Charles Rogers,
EPA Region V (1985),
9. Enforcement Decision Document, Pepper Steel, Honda, EPA Region IV, Atlanta, Georgia
(March 19, 1986).
10. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
Development of Advisory Levels for Polycfilorinated BiphenyJs (PCB s) Cleanup
(OHEA-E- 187), May 1986.
1 1. "Ground Water Classification System," Proposed by the Groundwater Classification
Subcommittee of the Land and Water Resources Council (May 1986).
12. U.S. Environmental Protection Agency. Office of Research and Development PCB Sediment
Decontamination-Technical/Economic Assessment of Selected Alternative Treatments
(September 15, 1986).
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Mobile Treatment Technologies for Superfund Wastes (EPA 540/2-86/003 (0),
September 1986.
14. "In Situ Vitrification of PCB-Contaminated Soils," Electric Power Research Institute (EPRI)
(prepared by Battelle, Pacific Northwest Laboratories) (October 1986).
15. "Guidelines for Ground- Water Classification under the EPA Ground-Water Protection
Strategy," U.S. Environmental Protection Agency (December 1986).
16. "Chemical Destruction of Chlorinated Dioxins and Furans," (Abstract), Charles J. Rogers &
Alfred Komel, EPA Region V (1986).
17. "Stationary Source Sampling Report - Benzene, Mercury, Toluene, Triethylamine and Xylene
Emissions Testing - Condenser Exhaust and Oil Polisher Outlet," Entropy Environmentalists
Inc. for Resources Conservation Co. (Febraary 26-28, 1987).
18. "Project Summary: PCB Sediment Decontamination - Technical/Economic Assessment of
Selected Alternative Treatments," Ben H. Carpenter, EPA Region V (March 1987).
19. "Project Summary: Catalytic Dehydrohalogenation: A Chemical Destruction Method for
Halogenated Organics," EPA Region V (March 1987).
20. "PCB Spill Cleanup Policy," (40 CFR Part 761), Federal Register. (April 2, 1987).
21. "Chemical Destruction of Halogenated Aliphatic Hydrocarbons" (United States Patent Number
4,675,464), Charles J. Rogers and Alfred Kernel, EPA Region V (June 23, 1987).
22. "Part 761 - Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in
Commerce, and Use Prohibitions," 40 Code of Federal Regulations (July 1, 1987).
23. "Land Disposal Restrictions for Certain 'California List1 Hazardous Wastes and Modifications
to the Framework," (40 CFR Parts 260, 261. 262, 264, 265, 268, 270, and 271) Federal
, Volume 52, No. 130 (July 8, 1987).
24. Record of Decision, Liquid Disposal, Incorporated, Utica, Michigan, EPA Region V, Chicago,
Illinois (September 30, 1987).
-------
Page 25
25. "Evaluation of the B.E.S.T. Solvent Extraction Sludge Treatment Technology Twenty-Four
Hour Test," Gerard W. Sudell, Enviresponse, Incorporated (1987).
26. "Incineration of a Chemically Contaminated Synthetic Soil Matrix (SSM) Using a Pilot-Scale
Rotary Kiln System," M.P. Esposito, M.L. Taylor, and C.L. Bruffey, Environmental
Technology Department, and R.C. Thumau, Risk Reduction Engineering Laboratory, U.S.
Environmental Protection Agency (Post-1987).
27. "Application of Low-Temperature Thermal Treatment Technology to CERCLA Soils,"
Michael F. Szabo, PEI Associates, Inc., Robert D. Fox, IT Corporation, and Robert C.
Thurnau, U.S. Environmental Protection Agency (January 1988).
28. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Superfund Innovative Technology Evaluation Program: Progress and Accomplishments
(EPA/540/5-88/001) (February 1988).
29. Memorandum from Alfred Komel, EPA Region V to Charles J. Rogers, EPA Region V
(June 24,1988). Concerning analysis of KPEG/Guam Soil PCB Detoxification from the
Guam Field Test
30. U.S. Environmental Protection Agency. Office of Toxic Substances. Draft Report -
Guidance Manual for Writers of PCB Disposal Permits for Alternate Technologies
(EPA/68-02-4252) (June 30,1988).
31. Letter from James E. Hansen, Geosafe Corporation to Michael Jasinski, EPA Region I
(July 13,1988). Concerning information on In Situ Vitrification Technology.
32. U.S. Environmental Protection Agency. Technology Screening Guide for Treatment of
CERCLA Soils and Sludges (EPA 540/2-88/004) (September 1988).
33. "B.E.S.T. is Currently Technically Unacceptable for Use at BROS" John S. Frisco, EPA
Region H (September 20,1938).
34. Record of Decision, Rose Disposal Pit, Lanesborough, Massachusetts, EPA Region I, Boston,
Massachusetts (September 23,1988).
35. "Laboratory Scale Testing Report: KPEG Processing of Wide Beach Development Site Soils,"
Galson Research Corporation (September 30,1988).
36. Letter from Alfred Komel, EPA Region V to Charles J. Rogers, EPA Region V
(October 13,1988). Concerning Guam n, Retreatment of Guam Soils and the Continuation of
APEG for PCB Detoxification.
37. Letter from Lanny D. Weimer, Resources Conservation Company to Angelo L. Masullo, ICF
Technology, Incorporated (December 16,1988). Concerning technical paper entitled "Basic
Extractive Sludge Treatment (B.E.S.T.)" - Demonstrated Available Technology."
38. "Laboratory Testing Results: KPEG Treatment of New Bedford Soil," Final Report Galson
Research Corporation (December 20, 1988).
39. "Feasibility Testing of In S tu Vitrification of New Bedford Harbor Sediments," Ebasco
Services, Inc., (prepared b> Battelle, Pacific Northwest Laboratories) (December 1988).
40. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
High Temperature Thermal Treatment for CERCLA Waste. Camp, Dresser & McKee, Inc.
(December 1988).
-------
Page 26
41. "Field Experience with the KPEG Reagent," (Abstract) Alfred Kernel, Charles J. Rogers and
Harold Sparks, EPA Region V (1988).
42. "PCB Sediment Decontamination Processes Selection for Test and Evaluation," Ben H.
Carpenter, Engineering Research Applications and Donald L. Wilson, EPA Region V (1988).
43. Memorandum from Michael Callahan, U.S. Environmental Protection Agency Office of Health
and Environmental Assessment to Henry L. Longest, U.S. Environmental Protection Agency
Office of Emergency and Remedial Response, December 6,1988 (discussing update of PCB
cleanup-levels).
44. "New Bedford Harbor Superfund Project, Acushnet River Estuary Engineering Feasibility
Study of Dredging and Dredged Material Disposal Alternatives," U.S. Army Corps of
Engineers, (January 1989).
45. Memorandum from Bruce M. Diamond, U.S. Environmental Protection Agency Office of
Waste Programs Enforcement, Henry L. Longest n, U.S. Environmental Protection Agency
Office of Emergency and Remedial Response, and Sylvia Lowrance, U.S. Environmental
Protection Agency Office of Solid Waste to Addressees (February 9,1989). Concerning
interim final guidance on soil ingestion rates.
46. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Technology
Evaluation Report SITE Program Demonstration Test HAZCON Solidification. Douglassville,
Pennsylvania (EPA 540/5-89/OOla) (February 1989).
47. Memorandum from Bill Hanson, Site Policy and Guidance Branch, Environmental Protection
Agency Headquarters to Regional Superfund Branch Chiefs, Regions I-X (April 7,1989).
Concerning PCB contamination at Superfund Sites.
48. Memorandum from Russell H. Wyer, U.S. Environmental Protection Agency Hazardous Site
Control Division to Martin Halper, U.S. Environmental Protection Agency Exposure
Evaluation Division (March 13,1989). Concerning Summary of Agreements Reached at
February 6,1989 Meeting on PCB Contamination at Superfund Sites.
49. Memorandum from Jonathan Z. Cannon, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Region I-X
(April 17,1989). Concerning policy for Superfund compliance with the RCRA land disposal
restrictions.
50. U.S. Environmental Protection Agency Demonstration Bulletin, SITE Program,
(EPAy540/M5-89/006) Organic Extraction Utilizing Solvents, April 1989.
51. Record of Decision, Pinnette's Salvage Yard, Washbum, Maine, EPA Region I, Boston,
Massachusetts (May 30,1989).
52. Memorandum from Henry L. Longest n, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response, and Bruce M. Diamond, Office of Waste Programs
Enforcement to Directors, Waste Management Division, Regions I, IV, V, Vn, VHI; Director,
Emergency and Remedial Response Division, Region JJ; Directors, Hazardous Waste
Management Division, Regions HI, VI; Director, Toxic and Waste Management Division,
Region DC; and Director, Hazardous Waste Division, Region X (June 5, 1989). Concerning
Land Disposal Restrictions as Relevant and Appropriate Requirements for CERCLA
Contaminated Soil and Debris.
-------
Page 27
53. Letter from Lanny D. Weimer, Resources Conservation Co. to Steven A. Serian, EPA
Region I (February 24,1989). Concerning transmittal of attached:
"B.E.S.T. Process Application Bulletin - PCB Contaminated Soils Treatment,"
Resources Conservation Co.
"Analytical & Testing Capabilities Bulletin - Bench-Scale Treatability Testing," Resources
Conservation Co.
"B.E.S.T. Process Technology Seminar Current Overview of RCC's B.E.S.T.
Process," Resources Conservation Co.
54. U.S. Environmental Protection Agency. Risk Assessment Work Group. Draft Final -
Supplemental Risk Assessment Guidance for the Superfund Program (EPA 901/5-89-001)
(June 1989).
55. "Draft Final - Hot Spot Feasibility Study," E.C. Jordan Co. for EBASCO Services
Incorporated (July 1989).
56. Letter from Lanny D. Weimer, Resources Conservation Co. to Michael Jasinski, EPA
Region I (August 14,1989). Concerning transmittal of attached:
"Basic Extractive Sludge Treatment (B.E.S.T.) Demonstrated Available Technology,"
Resources Conservation Co.
United States Environmental Protection Agency. Office of Research and Development
Project Summary - Evaluation of the B.E.S.T. Solvent Extraction Sludge Treatment
Technology Twenrv-Four Hour Test (EPA/600/S2-88/051) (November 1988).
United States Environmental Protection Agency. Office of Research and Development
Project Summary - Report on Decontamination of PCB Bearing Sediments.
(EPA/600/S2-87/093) (January 1988).
"Evaluation of Treatment Technologies for Listed Petroleum Refinery Wastes - Final
Report," American Petroleum Institute (December 1987).
"B.E.S.T. Process Application Bulletin - PCB Contaminated Soils Treatment,"
Resources Conservation Co.
57. "Guidance for Compliance with Requirements of the Safe Drinking Water Act"
(CWA/SWDA)Volume of the Superfund Compliance Manual (no date listed).
58. "A Summary of Bioassay Tests on APEG (Alkaline PolyEthylene Glycol) Byproducts." (no
date listed).
------- |