United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/039
September 1989
&EPA
Superfund
Record of Decision
Kellogg - Deering
Well Field, CT
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-89/039
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Kellogg-Deering Well Field, CT
Second Remedial Action
5. Report Date
09/29/89
6.
7. Author(s)
8. Perfoiming Organization Rept No.
9. Performing Organization Name and Addreoa
10. ProiectfTask/Worlt Unit No.
11. Contract(C) or Grant(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 A Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Kellogg-Deering Well Field site is a 10-acre contaminated municipal well field in
Norwalk, Fairfield County, Connecticut, which includes adjacent source areas that
contribute to the well field contamination. The site lies within the Norwalk River's
100-year floodplain and consists of four municipal drinking water wells that supply
approximately 25 percent of the water for the 45,000 residents in Norwalk. The city
detected elevated TCE levels in the wells during routine monitoring in 1975 and
subsequently shut down unacceptably contaminated wells until a redwood slat treatment
system was installed in 1981. EPA conducted a remedial investigation between 1984 and
1986 leading to a 1986 Record of Decision (ROD) which required the city to operate an
air stripping unit. EPA conducted a subsequent remedial investigation in 1987 which
further defined the contaminated ground water area and identified the Elinco/Pitney
Bowes/Motleis Court Complex, located east of the site and upgradient of the well field,
as a source of ground water contamination. This ROD, the second of three planned
operable units, addresses the major source area. The primary contaminants of concern
affecting the soil and ground water are VOCs including benzene, PCE, TCE, toluene, and
xylenes.
(See Attached Sheet)
17 Document Analysis a. Descriptors
Record of Decision - Kellogg-Deering Well Field, CT
Second Remedial Action
Contaminated Media: soil, gw .
Key Contaminants: VOCs (benzene, toluene, PCE, TCE, xylenes)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
124
22. Price
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EPA/ROD/R01-89/039
Kellogg-Deering Well Field, CT
Second Remedial Action
16. Abstract (Continued)
The selected remedial action for this site includes onsite in situ vacuum extraction
followed by carbon adsorption to remediate soil underlying the major source area at the
court complex; ground water pumping and onsite treatment using air stripping followed by
offsite discharge; and periodic sampling of ground water, soil vapor, and indoor air.
The estimated present worth cost for this remedial action is $9,100,000, which includes a
present worth O&M cost of $3,034,000 for 30 years.
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RECORD OF DECISION
DECLARATION STATEMENT
KELLOGG-DEERING WELL FIELD 8UPERFUND SITE
OPERABLE UNIT 2 - SOURCE CONTROL
September 1989
SITE NAME AND LOCATION
Kellogg-Deering Well Field Superfund Site
Norwalk, CT
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
the second operable unit for source control of this National
Priorities List site 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, 40 C.F.R. Part 300 et
seq. (1987). The Regional Administrator for Region I of the
United States Environmental Protection Agency (EPA) has been
delegated the authority to approve this Record of Decision.
The State of Connecticut has concurred on the selected remedy and
has determined that it is consistent with Connecticut laws and
regulations.
STATEMENT OF BASIS
This decision is based on the Administrative Record for the site
developed in accordance with Section 113(k) of CERCLA. The
attached index identifies the items that comprise the
Administrative Record.
The Administrative Record is available for public review at the
Norwalk Public Library and the EPA Region I Waste Management
Division Records Center at 90 Canal Street in Boston,
Massachusetts.
DESCRIPTION OF THE SELECTED REMEDY
The response action for the second operable unit at the Kellogg-
Deering site is a comprehensive remedy for the second operable
unit that combines components of source control and management of
migration within an area of high contaminant concentrations. The
source control component will include an in-situ soil vacuum
extraction system to remediate contaminated soils underlying
buildings and parking lots at the Elinco/Pitney Bowes/Matheis
Court Complex. Soils will be cleaned to levels that will protect
the quality of groundwater in the event that the buildings and
parking lots are removed at some time in the future.
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The management of migration component consists of groundwater
extraction, treatment and discharge within a highly contaminated
portion of the aquifer known as the Source Area. The aquifer is
composed of unconsolidated overburden and bedrock. Groundwater
will be pumped with the objective of achieving Safe Drinking
Water Act Maximum Contaminant Levels in the aquifer.
DECLARATION
The selected remedy is protective of human health and the
environment and attains Federal and State requirements that are
applicable or relevant and appropriate. In addition, the
selected remedy is cost effective; satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element; and
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
The selected remedy will result in hazardous substances remaining
on-site above health based levels. Therefore, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Paul G. Keough,
Acting Regional Administrator
EPA Region I
ii
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RECORD OF DECISION SUMMARY
KELLOGG-DEERING WELL FIELD 8UPERFUND SITE
OPERABLE UNIT 2 - SOURCE CONTROL
September 1989
CONTENTS
Declaration .. .. i
Location and Description 1
Site History ..-....* 2
Response History .. 2
Enforcement History 3
Community Participation 3
Scope and Role of Operable Unit 4
Site Characteristics 5
Groundwater ... 5
Soil 7
Indoor Air 8
Summary of Site Risks 8
Groundvater 8
Soil 12
Documentation of Significant Changes 12
Development and Screening of Alternatives 16
Statutory Requirements/Response Objectives 16
Technology and Alternative Development and Screening .... 17
Description of Alternatives 19
Alternative I 19
Alternative II 20
Alternative III 21
Alternative IV 22
Alternative V 22
Alternative VI ... 23
Alternative VII 25
Alternative VIII 25
Selected Remedy 25
Remedial Action Objectives/Cleanup Goals 26
Groundvater 26
Soil 27
Description of Components of the Selected Remedy 28
Contaminated Soil Treatment 28
Contaminated Groundwater Extraction and Treatment .. 29
iii
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Rationale for Selection 31
Summary of Comparative Analysis of Alternatives 32
Overall Protection of Human Health and the Environment... 32
Compliance with ARARs.... 33
Long-term Effectiveness and Permanence 34
Reduction of Mobility, Toxicity or Volume 35
Short-term Effectiveness. 35
Implementability 36
Cost 36
Community Acceptance 37
State Acceptance 37
Conclusion 37
Statutory Determinations 38
Protection of Human Health and the Environment 38
Compliance with ARARs 39
Cost Effectiveness 41
Permanent Solution/Alternative Treatment/
Resource Recovery 41
Preference for Treatment » 42
State Role 42
FIGURES
1. General Location Map 43
2. Kellogg-Deering Well Field Superfund Site Map 44
3. General Cross Section Diagram 44
4. Area of Groundwater Contamination 45
TABLES
1. Indicator Chemicals 46
2. Summary of Remedial Alternatives 47
3 Groundwater and Soil Cleanup Goals 48
4. Estimated Costs for the Selected Alternative 49
5. Comparison of Estimated Costs for Alternatives 50
6. ARARs for the Selected Alternative 51
APPENDICES
Responsiveness Summary Appendix A
Administrative Record Index Appendix B
State Concurrence Letter Appendix C
iv
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RECORD OF DECISION SUMMARY
KELLOGG-DEERING WELL FIELD 8UFERFUND SITE
OPERABLE UNIT 2 - SOURCE CONTROL
September 1989
LOCATION AND DESCRIPTION
The Kellogg-Deering Well Field Superfund Site is located in
Norwalk, CT. The "site" consists of an approximately 10-acre
municipal well field (the Kellogg-Deering Well Field) and
adjacent areas that contribute to the well field contamination.
The well field portion of the site (Figure 1) is located along
the western bank of the Norwalk River in southwestern Fairfield
County, Connecticut and is bordered on the east by the Norwalk
River, on the north by residences along Broad Street, on the west
by residences along Lakeview Avenue, and on the south both by
wooded acreage and residences in the vicinity of East Lakeview
Drive and Nutneg Place.
The site, considered to be within the study area shown in
Figure 2, also includes light industrial and residential areas on
the east side of the Norwalk River. The 100 year floodplain of
the Norwalk River encompasses the Kellogg-Deering Well Field and
low-lying bands along the banks of both sides of the river,
including portions of the site.
The Kellogg-Deering Well Field, which is owned and operated
by the Norwalk First Taxing District (NFTD) Water Department,
consists of four municipal water supply wells that supply
approximately 25 percent of the water for the 45,000 residents in
the city of Norwalk. The estimated safe yield of the Kellogg-
Deering Well Field is estimated to be approximately 3.5 million
gallons per day on a long-term basis as reported in Safe Yield
Evaluation of the Kelloqg-Deerinq Well Field. Norwalk. CT by
Leggette, Brashears and Graham in 1981. The water supply wells
are located in an aquifer that is classified as II-A under the
EPA Ground Water Protection Strategy and GAA under the State of
Connecticut's Water Quality Standards. EPA's II-A classification
means that the groundwater is currently and potentially a source
of drinking water and other beneficial uses. The Connecticut GAA
classification encompasses the immediate vicinity of the Kellogg-
Deering Well Field and indicates that the Well Field is an
existing or potential public drinking water supply. The aquifer
outside of the immediate vicinity of the Well Field is classified
by Connecticut as GB/GA which indicates that although the
groundwater presently may not be suitable for direct human
consumption without treatment due to chemical contaminants or
land use impacts, the State maintains a goal to restore the
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ground water to drinking water quality. A more complete
description of the site can be found in Section 1 of the
supplemental Remedial Investigation Report (RI).
the site is underlain by two water-bearing geologic
formations: overburden and bedrock (Figure 3). The overburden
aquifer, composed of primarily sand and gravel, is very thick
near and under the Norwalk River (approx. 100 feet) and tapers
out toward the east. The depth to the water table varies from
between zero feet to approximately 35 feet below ground surface.
All four of the Kellogg-Deering water supply wells are located in
the overburden aquifer. The bedrock aquifer underlies the
overburden aquifer and is closer to the surface as the overburden
aquifer thins toward the east. The bedrock aquifer is composed
of fractured rock. Groundwater movement in the bedrock aquifer
occurs through interconnected fractures.
Operation of the water supply wells at the Kellogg-Deering
Wells Field effects the local hydrology in two important ways.
First, some surface water from the Norwalk River is drawn
downward from the Norwalk River as it passes near the Well Field.
Secondly, water from portion of the aquifer located to the east
side of the river is drawn underneath the river bed before
entering the operating supply wells. As a result, approximately
86 percent of the water entering the supply wells originates as
surface water from the Norwalk River while most of the remaining
14 percent comes from the aquifer.
SITE HISTORY
Response History
Elevated levels of trichloroethene (TCE) were first detected
in the wells at the Kellogg-Deering Well Field during routine
monitoring by the Norwalk City Health Department in 1975. The
wells with unacceptable concentrations of TCE were shut down
until a redwood slat treatment system was installed by NFTD in
1981. The site was placed on the National Priorities List (NPL)
in 1984. An initial Remedial Investigation and Feasibility Study
(RI/FS) was conducted at the site between 1984 and 1986. The
initial RI/FS supported the first operable unit Record of
Decision (ROD) issued in September 1986, that required completion
of construction and operation of a new air stripping facility
(well head treatment) at the Kellogg-Deering Well Field. The
well head treatment removes TCE and other volatile organic
compounds (VOCs) from the contaminated groundwater prior to
discharge into a conventional water treatment plant and the water
distribution system. The well head treatment was designed to
supply safe, potable water to the public.
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A supplemental RI/FS began at the site in 1987 to provide
further information regarding the source(s) and extent of
groundwater contamination at the site. In addition to better
defining the area of groundwater contamination found during the
initial RI, the supplemental RI also identified a major source
area of groundwater and soil contamination at the Elinco/Pitney
Bowes/Hatheis Court Complex (the complex) located at 272 and 282
Main Avenue in Norwalk. The supplemental RI concluded that the
contamination at the complex is contributing to the contamination
at the Kellogg-Deering Well Field and the aquifer supplying the
Well Field. The supplemental RI also identified soil gas
contamination sources at the complex and provided an analysis of
indoor air quality. The complex is considered to be a major soil
and groundwater contamination source area. A more detailed
description of the site history can be found in the supplemental
RI.
Enforcement History
Since July 29, 1986, EPA has notified approximately nine parties
who are either past or present owners or operators of the
facility of their potential liability with respect to the site.
In 1986, EPA issued an administrative order to the Norwalk First
Taxing District (NFTD) ordering the NFTD to complete construction
of and begin operation of an existing air stripping at the
Kellogg-Deering Well Field. By letter dated May 11, 1988, EPA
notified NFTD that it had satisfied the requirements of the
order.
The potentially responsible parties (PRPs) have been active
in the remedy selection process for the site. Comments were
submitted by the PRPs during the public comment period. A
summary of these comments and EPA's responses to these comments
are included in the Responsiveness Summary in Appendix A. The
PRPs1 comments, the summary of the comments and EPA's responses
to these comments are all included in the administrative record.
Special notice has not been issued in this case to date.
COMMUNITY PARTICIPATION
Through the Site's history, the level of community concern
and involvement has fluctuated. EPA has kept the community and
other interested parties apprised of the Site activities through
informational meetings,"fact sheets, press releases and public
meetings.
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EPA held several public meetings and hearings in connection
with the first operable unit for the site. Details of community
relations activities in connection with the first operable unit
are described in the first operable unit Record of Decision.
In June 1986, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in activities during
remedial activities. In January 1988, EPA issued a press release
announcing the completion of the Supplemental RI/FS workplan.
On October 31, 1988, EPA made the administrative record
available for public review at EPA's offices in Boston and at the
Norwalk Public Library. The administrative record was updated
with information relating to the second operable unit at both
locations on July 26, 1989. EPA published a notice and brief
analysis of the Proposed Plan in Norwalk Hour on July 21, 1989.
On July 26, 1989 the Proposed Plan was made available to the
public at the Norwalk Public Library.
On July 26, 1989, EPA held an informational meeting to
discuss the results of the Supplemental Remedial Investigation
and the cleanup alternatives presented in the Supplemental
Feasibility Study and to present the Agency's Proposed Plan for
remedial actions for the second operable unit. Also during this
meeting, the Agency answered questions from the public. From
July 27, 1989 to August 25, 1989, the Agency held a 30-day public
comment period to accept public comment on the alternatives
presented in the supplemental Feasibility Study and the Proposed
Plan and on the other documents which were a part of the
administrative record for the site. On August 14, 1989, the
Agency held a public hearing to accept any oral comments. A
transcript of this meeting and the comments and the Agency's
response to comments are included in the attached Responsiveness
Summary.
This decision document presents the selected remedial action
for the second operable unit at the Site, chosen in accordance
with CERGLA, as amended by SARA and, to the extent practicable,
the National Contingency Plan. The decision for the second
operable unit is based on the Administrative Record.
SCOPE AND ROLE O7 OPERABLE UNIT
The remedy described in this Record of Decision addresses
the second of three planned operable units at the Site. The
first operable unit Record of Decision, signed in September of
1986, required completion and operation of an existing air
stripping unit at the Kellogg-Deering Well Field (wellhead
treatment). The wellhead treatment is currently operational and
is designed to provide safe drinking water to the residents of
Norwalk. This second operable unit Record of Decision addresses
a major source of soil and groundwater contamination upgradient
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of the Kellogg-Deering Well Field. The source area is known as
the Elinco/Pitney Bowes/Matheis Court Complex and is considered
to be a source of the contamination of the aquifer that supplies
the Kellogg-Deering Well Field.
The selected remedy for the second operable unit was
developed by combining a management of migration alternative with
a source control alternative. In summary, the remedy addresses:
1) highly concentrated residual groundwater contamination
emanating from the complex in both the overburden and bedrock
aquifers, 2) residual soil contamination existing below the
buildings and parking lots at the complex and 3) the introduction
of contaminants into the buildings at the complex from underlying
contaminated soils.
As described below in the Documentation of Significant
Changes section, EPA will address a third operable unit for the
site in the future. The third operable unit will, at a minimum,
address the area of contamination located downgradient of the
Source Area addressed by this Record of Decision.
SITE CHARACTERISTICS
The significant findings of the initial and supplemental
remedial investigations are summarized below. A complete
detailed discussion of the site characteristics can be found in
the initial and supplemental Remedial Investigation reports.
i TCE, PCE, and other chemicals were detected in soils and
groundwater at the site and in indoor air in the buildings at the
site. Surface water and sediment samples were collected and
analyzed only during the initial Remedial Investigation. No
significant levels of contaminants were found in either the
surface water or the sediments to warrant further investigation
during the supplemental Remedial Investigation.
As stated above, the Elinco/Pitney Bowes/Matheis Court
Complex is a major source of groundwater and soil contamination
which is contributing to the contamination of the Kellogg-Deering
Well Field and the aquifer supplying the Well Field. The
existence of other source areas contributing to contamination of
the portion of the aquifer that supplies the Kellogg-Deering Well
Field is not precluded.
Groundvater
Groundwater data collected to date indicates that a
significant source area of contamination exists below the complex
located at 272 and 282 Main Avenue in Norwalk. A plume of
groundwater contamination is emanating away from the complex in a
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••si-radial pattern from the northwest to southwest directions.
Contaminant transport occurs in both the overburden and bedrock
aquifers. The southwest extent of the plume is migrating below
the Norwalk River and intersects the Kellogg-Deering Well Field.
The vest and northwest edge of the plume appears to extend to
Deering Pond and the Norwalk River.
Both the initial RI and the supplemental RI support a
finding of migration of groundwater contaminants from the complex
through the unconsolidated overburden aquifer and through deep
and shallow fractures of the bedrock aquifer to the wells of the
Kellogg-Deering Well Field. Some of the contamination has
entered bedrock fractures immediately below the buildings at the
complex. Contaminants discharge from the bedrock into the
overburden aquifer in the vicinity of the Norwalk River and the
CL&P Landfill. While the actual location of every fracture
containing contaminated groundwater is uncertain, groundwater
data collected to date indicates that a "piping system" of
bedrock fractures is responsible for contamination migration from
the complex to the overburden aquifer near the Kellogg-Deering
Wellfield.
A generalized map of groundwater contamination is shown in
Figure 4. This map combines groundwater quality data from both
the bedrock and overburden aquifers. The map divides the area of
contamination into two parts: A Source area and a Downgradient
area. The Source area is defined as the approximate area in
which TCE concentrations exceed 6,600 micrograms per liter
(ug/1). The Downgradient area is the approximate area in which
TCE concentrations have been found to be between 5 ug/1 and 6,600
ug/1. The concentrations of 5 ug/1 TCE is the highest
concentration permitted in compliance with federal drinking water
standards.
The most pronounced groundwater contaminants from the
standpoint of frequency of occurrence and concentration include
PCE, TCE, TCA and toluene. These compounds were detected in 52,
79, 42 and 18 of the 115 groundwater samples obtained during the
Supplemental RI. Concentrations of these compounds ranged as
high as 68,000, 430,000, 2,000 and 14,000 ug/1, respectively.
TCE was the most concentrated and widely detected contaminant.
Ethyl benzene and 1,2-dichloroethene were detected in 10 and 8
samples, respectively, at concentrations ranging as high as 5,800
ug/1 and 4,800 ug/1, respectively. By contrast, none of the
other volatile chemicals detected were found at concentrations in
excess of 65 ug/1 (with the exception of 1 detection of 4-methy1-
2-pentanone at 990 ug/1).
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Based on the distribution of the dense chlorinated organics
in groundwater below the complex, it is apparent that density
effects probably play a major role in contaminant movement. High
concentrations of PCE (up to 68,000 ug/1) and TCE (up to 430,000
ug/1).were detected in groundwater samples collected from
monitoring wells installed on the complex property. Invariably,
concentrations in samples from deeper wells exceeded those in
samples fron shallow wells at the same well cluster locations.
It appears possible that a dense non-aqueous phase liquid (DNAPL)
may be present below the complex buildings.
PCE and TCE were also frequently detected in downgradient
monitoring wells. Both overburden and bedrock monitoring well
samples revealed the presence of chlorinated solvents.
Concentrations decreased from the source area wells to
downgradient wells. However, TCE concentrations ranged as high
as 37 ug/1 in one of the production wells sampled (Layne 2).
The groundwater contamination above 5 ug/1 TCE encompasses
approximately 54 acres. It is calculated that 316,000,000
gallons of groundwater are affected and contaminated with
approximately 19,400 pounds of soluble TCE plus less quantities
of other contaminants. In addition, DNAPL may be present at the
complex and possibly downgradient of the complex. Of the total
quantity of contaminated groundwater, it is estimated that 15
percent is in bedrock and 85 percent is in overburden.
Soil
Source characterization at the complex was conducted through
a soil-gas investigation and subsurface soil sampling and
analysis. As a result of the physical nature of the complex
property, (three large buildings) characterization of the soil
source area was limited. The soil-gas investigation indicated
that the majority of the residual contamination at the complex
exists beneath the complex buildings. PCE and TCE were the most
frequently detected and most highly concentrated chemicals in the
soil-gas samples. Eight soil gas samples were collected under
the buildings. These samples were several orders of magnitude
greater than those in outside the complex buildings.
Approximately 30 subsurface soil borings were taken outside
the complex buildings. The PCE subsurface soil sample results
indicated that releases to the subsurface occurred in the
vicinity of the former processing areas within the buildings.
TCE was found in 28 of 104 soil samples in levels ranging from 7
to 3,903 ug/1; PCE was found in 22 of 104 soil samples ranging in
concentrations from 3 to 8,688 ug/kg. EPA acknowledged that
certain soil samples collected at the complex and analyzed by the
Contract Laboratory Program as part of the supplemental Remedial
Investigation were suspect (See Matthew Hoagland July 17, 1989
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8
memorandum and NUS Corp. July 20, 1989 letter to EPA in
Administrative Record). However, EPA maintains that the
estimated 44,000 cubic yards of contaminated soils based on an
average depth to bedrock of 12 feet, as concluded in the
supplemental Remedial Investigation, is correct.
Indoor Xir
An indoor air study performed in the three buildings at the
complex was limited to TCE and PCE due to their frequent
occurrence in groundwater and soil gas samples beneath and in the
vicinity of the complex. Since both PCE and TCE exhibit a strong
potential for volatilization, and are thus considered to be
mobile in the environment, they were identified as the
contaminants of concern. These contaminants were detected in the
three study buildings at concentrations ranging from 20 ug/m to
764.3 ug/m3 (TCE), and from below the detection limits to 45.2
ug/m3 (PCE).
SUMMARY OF SITE RISKS
A Risk Assessment was performed as part of the supplemental
Remedial Investigation to estimate the probability and magnitude
of potential adverse human health and environmental effects from
exposure to contaminants associated with the site. Sixteen
contaminants of concern or "indicator compounds" listed in Table
1 were selected for evaluation in the Risk Assessment. These
contaminants constitute a representative subset of the more than
25 contaminants identified at the site during the supplemental
Remedial Investigation. The 16 contaminants were selected to
represent potential onsite hazards based on toxicity,
concentration, frequency of detection, and mobility and
persistence in the environment.
Qroundvater
Groundwater contaminants at the site include relatively
water soluble volatile organics. Monocyclic aromatics (e.g.,
benzene, toluene, etc.) and chlorinated straight-chain
hydrocarbons (e.g., TCA, PCE, TCE, etc.) constitute the
predominant groundwater contaminants. All of the potential
carcinogenic substances detected in groundwater were included as
indicator compounds, regardless of their frequency of occurrence
or concentration, and several substances displaying only
noncarcinogenic effects (e.g., toluene, ethylbenzene, 1,1,1-
trichloroethane, acetone, and 4-methyl-2-pentanone) were also
included as indicator compounds.
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Hunan health risks were characterized both quantitatively
and qualitatively in the risk assessment with regard to
groundwater exposure. Qualitative risks were developed through
the comparison of concentrations and/or doses with the
appropriate standards and guidelines. The qualitative risks are
summarized in Table 6-2 of the supplemental Remedial
Investigation. Trichloroethane (TCE) one of the primary
contaminants of concern exceeded the Maximum Contaminant Level
(MCL) of 5 ug/1 and the Maximum Contaminant Level Goal (MCLG) of
0 ppb at 79 of 115 samples taken during the supplemental Remedial
Investigation.
Potential human health effects associated with the
contaminants of concern in groundwater were estimated
quantitatively through the development of several hypothetical
exposure scenarios. Incremental; lifetime cancer risks and a
measure of the potential for noncarcinogenic adverse health
effects were estimated for the various exposure scenarios.
Exposure scenarios were developed to reflect the potential for
exposure to hazardous substances based on the characteristic uses
and location of the Site. Factors of special note that are
reflected in the Risk Assessment are that the Site is located in
a residential and light industrial urban area and that the area
is served by a public water supply. Groundwater from the
Kellogg-Deering Well Field, blended with water from surface water
reservoirs as part of the water supply, is currently being
treated for contaminants that are associated with the contaminant
plume being addressed in this Record of Decision.
The quantitative risk assessment considered potential
exposures associated with household use of potable water. There
are numerous routes of exposure associated with household use of
contaminated water, including ingestion, inhalation of volatiles
emitted from showers, dishwashers, washing machines, bathing, car
washing etc. However, since previous experience has shown that
ingestion and inhalation of volatiles during showering are the
predominant exposure mechanism in the home, these are assessed
quantitatively for this exposure route.
EPA estimated potential health effects for future use
groundwater using both future conditions (worst case) and future
conditions (plausible case) scenarios. Doses under the worst
case scenario were developed using the indicator chemical
concentrations detected at upgradient locations. The maximum,
arithmetic average, and geometric mean groundwater concentrations
were used. This exposure scenario provides an indication of
groundwater quality at the source and in the aquifer in general.
This scenario does not consider the existence of the air
stripping column and therefore corresponds to a case under which
air stripper failure or decommissioning occurs or if installation
of residential wells in locations near the source takes place in
the future. For estimating risks from the Well Field, this
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10
scenario does not include a dilution factor for the Morvalk
River; it assumes the dilution offered by the river is removed
(due to silting, dry weather, etc.) The plausible case exposure
scenario is similar to the worst-case scenario. Maximum
observed, arithmetic average, and geometric mean groundwater
concentrations were used. However, it is expected that the air
stripping column will continue to operate, and the stripper
removal efficiency (99.9%) was included. This scenario included
a dilution factor, since only a minor portion of all wellfield
water actually originates from the upgradient aquifer. This
exposure scenario corresponds to a condition in which the
contamination at the complex acts as a continuous source of
wellfield contamination.
Quantitative risk estimates are generated through the use of
Carcinogenic Potency Factors and Reference Doses. Risks from
exposure to chemicals that are associated with noncarcinogenic
health effects are assessed by calculating the ratio of the
estimated dose from exposure to each noncarcinogenic compound to
a reference dose. A reference dose is the dose below which no
adverse health effect is expected to occur. If this value
exceeds unity (1.0), there is a potential health risk associated
with exposure to that particular chemical. This risk estimate is
not a mathematical prediction of the severity of toxic effects;
it is simply a numerical indicator of the possibility of the
occurrence of noncarcinogenic effects. The overall potential for
the occurrence of effects is assessed by summing the risks to
individual chemicals. The resulting summation is the Hazard
Index. This approach assumes additive dose and effects for all
contaminants.
Carcinogenic risk estimates are provided in the form of
incremental cancer risks and are determined by multiplying the
potency factor for a specific carcinogen by the intake level.
The resulting number (risk) is a unitless expression of an
individual's incremental likelihood of developing cancer as a
result of exposure to the carcinogenic indicator chemicals. An
incremental cancer risk of 1 x 10 indicates that an exposed
individual has a 1/1 x 10* (or 1 in 1 million) chance of
contracting cancer.
Total carcinogenic risks for multiple compounds are
presented as the summation of the risks for the individual
contaminants. Calculating risks in this manner assumes that
individual intakes are small, that there are no antagonistic/
synergistic effects between chemicals, and that all chemicals
produce the same result (i.e., cancer). Cancer risks from
various exposure routes are also additive, if the exposed
populations are the same.
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The cumulative incremental cancer risk for groundwater
inhalation and ingestion for adult receptors under the two
exposure scenarios and existing conditions are as follows:
Existing Condition 2.8 x 10"9
Future Worst Case 3.2 x 10"1 (Maximum Concentrations
of Contaminants)
Future Plausible Case 4.7 x 10"5 (Maximum Concentrations
of Contaminants) ;
The major components of the incremental cancer risk result
from the presence of PC-E .and TCE.
Noncarcinogenic effects are unlikely under current
conditions since the hazard index is well below 1.0.
Noncarcinogenic effects would be quite likely under the future
worst case conditions. The major component of the potential
noncarcinogenic effect is PCE. Under the future plausible case
scenario the hazard indices do not exceed unity.
In conclusion, both the Hazard Indices and incremental
cancer risk estimates reveal that groundwater contamination at
the Kellogg Deering Well Field would pose a significant threat to
the public health if not for the dilution offered by the Norwalk
River and the removal of.contaminants by the existing treatment
system (i.e., the air stripper). The contamination in the
aquifer in the vicinity of the source area is outside the EPA
risk range of 10"* to 10 and poses a threat to human health in
the event it was used for private water supply wells.
Although the risks based on the maximum observed
concentrations may be overestimates under present site
conditions, it is anticipated that continued migration of
contaminants to the Well Field could result in a long-term threat
to the public health. In the event the contaminated groundwater
was used for private water supply it could pose a risk to human
beings. The risks generated using arithmetic average and
geometric mean concentrations may be better estimates of future
risks in -the near term. However, based on the concentrations
encountered in the source area and evidence suggesting the
presence of a Dense Non-Aqueous Phase Liquid below the complex,
it is considered possible that the well field concentrations
could attain levels approaching the source concentrations over
the long-term. In this respect, the contaminated bedrock
groundwater at the complex could act as a continuous source of
downgradient contamination. In the event that the dilution
offered by the river is removed (as a result of silting,
prolonged dry weather, or other unforeseen circumstances) or the
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•tripper removal efficiency is impeded (as a result of fouling or
equipment failure), it is possible that Well Field production
would have to be discontinued.
Bell
Chemical contaminants in the soils below buildings and the
parking lot in the complex area currently present no health risk
from exposure through direct contact or incidental ingestion of
contaminated soil. The potential does exist for human inhalation
of contaminants that are being released from soils beneath the
complex to the air within the buildings. The levels of
contaminants measured during one sampling event are well within
the standards set for industrial safety by the Federal
Occupational Safety and Health Administration. However, the
risks in the Elinco building from exposure to these levels (4.0 x
10 ) exceeds the Superfund target risk range (10** to 10 ) using
a reasonable worst case scenario. If, in the future, the
buildings were demolished and/or soil excavated, the potential
risks to public health and the environment would increase
substantially. Finally, contamination in the soils will continue
to leach into groundwater under the complex and further
contribute to groundwater contamination unless the levels of
contamination in the soils is reduced.
No significant levels of contaminants were found in either
surface water or sediments during the initial Remedial
Investigation, so no further sampling or risk assessment was
performed during the supplemental Remedial Investigation.
A complete discussion of Site risks can be found in Section
6 of the supplemental Remedial Investigation. 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 endangerment to
public health, welfare or the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
EPA published a Proposed Plan for remediation of the Site on
July 26, 1989. The preferred alternative consisted of a source
control component and a management of migration component. The
source control component consisted of the treatment of
contaminated soils at the complex using in-situ vapor extraction.
The management of migration portion of the Proposed Plan covered
alternatives for the treatment of contaminated groundwater. In
developing the management of migration components, the area of
groundwater contamination at the site was divided into two zones,
the Source Area and Downgradient Area, according to the
concentration levels found in the supplemental RI. The Source .
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Area is characterized by TCE concentrations greater than 6,600
ug/1 and consists of an area that includes most of the complex as
well as an adjacent area extending 400 feet west and about 500
feet southeast of the complex. See Figure 4. The Downgradient
Area consists of the remainder of the TCE groundwater plume in
excess of 5 ug/1, the Safe Drinking Water Act maximum contaminant
level (MCL) for TCE. The Downgradient Area as mapped in the
supplemental FS extends westward either to the Norwalk River or,
where influenced by the pumping of the Kellogg-Deering Wells,
under and beyond the Norwalk River. The management of migration
component of the preferred alternative included the extraction
and treatment of groundwater from both the Source Area and
Downgradient Area. The Proposed Plan indicated that there were
four potential treatment technologies for groundwater, including
air stripping, carbon adsorption, ultraviolet uv/chemical ' • '.
oxidation and steam stripping. The Proposed Plan also stated
that air stripping was the likely choice of treatment
technologies in the ROD. All four treatment technologies would
involve: 1) the installation of wells to extract contaminated
groundwater at the site; 2) the pretreatment of extracted
groundwater to remove suspended solids and metals that could
reduce the effectiveness of the principal treatment unit; 3) the
treatment of contaminated groundwater to remove VOCs; and 4) the
discharge of treated groundwater.
The Proposed Plan indicated that the disposal.method for the
treated groundwater would be determined during the.design phase
and would consist of either discharge to the local publicly owned
treatment works (POTW), discharge to the Norwalk River through a
new pipe, discharge to the Norwalk River through existing storm
sewers or reinjection into the aquifer, either solely or in
combination. The Proposed Plan also stated that if after an
adequate period of performance of the preferred alternative,
complete restoration of the bedrock aquifer was determined to be
technically impracticable, then EPA would consider amending the
Record of Decision to waive applicable or relevant and
appropriate requirements (ARARs) in the aquifer. In addition,
the Proposed Plan stated that the cleanup goals may be adjusted
if chemical contaminant concentrations reach a constant value and
contaminants are no longer being removed at significant levels.
The remedy selected in this ROD adopts the same source
control component that was presented in the Proposed Plan. For
the management of migration component, however, this ROD contains
the following changes:
* Extraction and treatment of Source Area groundwater
only will occur pursuant to this ROD; EPA will make a
decision regarding remediation of the Downgradient Area
as a separate operable unit at a later date;
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* Air stripping has been chosen as the groundwater
treatment technology for Source Area groundwater; and
* EPA will consider, during the design phase, the use of
either ultraviolet(UV)/chemical oxidation, carbon
adsorption or steam stripping as alternative
groundwater treatment technologies for Source Area
groundwater if it can be shown that the proposed
alternative technology will meet the four statutory
criteria for CERCLA cleanups and will provide a similar
balance in the nine evaluation criteria as air
stripping.
Each of the changes listed above will be discussed in turn in the
remainder of this section.
EPA has determined that the construction of a new highway,
Route 7, will impede the performance of remedial design
activities in the near future in the Downgradient Area.
Therefore, in order to avoid any delay in remedial actions for
contaminated soil and Source Area groundwater, EPA has decided to
postpone a decision on remediation of the Downgradient Area until
a later date. Remediation of the Downgradient Area will
constitute a third operable unit for the site. The selection of
a remedy in the Downgradient Area will depend on several factors
which may include 1) the effectiveness of the Source Area
groundwater extraction and treatment system in remediating
contamination in the Downgradient Area groundwater, 2) any future
data indicating that the contamination plume at the site is
having a negative impact on the Norwalk River and 3)
accessibility of the Downgradient Area after the construction of
Route 7 is complete.
In addition, many individuals raised issues during the
public comment period which challenged the effectiveness and
protectiveness of extracting and treating groundwater from the
Downgradient Area. While it is EPA's intent to address the
contamination in the Downgradient Area groundwater, EPA does see
merit in further evaluating options for remediating this area
while implementing the Source Area cleanup. Therefore, EPA has
decided to refrain from making a decision on a remedy for the
Downgradient Area until the concerns raised during the public
comment period can be more fully evaluated.
As a result of its decision to create a third operable unit
to address the Downgradient Area, EPA will not evaluate
Alternatives III, IV, VII and VIII in this Record of Decision
because these alternatives differ from Alternatives I, II, V and
VI only with regard to the inclusion of the Downgradient Area
groundwater extraction and treatment system. All significant
comments submitted to EPA during the July 27, 1989 to August 25,
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15
1989 public comment period that pertain to the Dovngradient Area
groundwater extraction system will be more thoroughly responded
to at the time a final decision is made on remediation of the
Dovngradient Area.
As -mentioned above, EPA has decided to address the
Downgradient Area as a separate operable unit. EPA believes that
this approach is environmentally sound and logical for several
reasons: the highest levels of contamination at the site are
associated with the Source Area; cleanup of the Source Area will
prevent the further migration of contaminants from the Source
Area into the Downgradient Area; and further evaluation of the
impact of Source Area remediation on Downgradient Area
remediation will ensure that the Downgradient Area cleanup will
be protective and effective.
The Proposed Plan indicated that there exist four potential
groundwater treatment technologies for the site, including, air
stripping, ultraviolet(UV)/chemical oxidation, carbon adsorption
or steam stripping. EPA has chosen air stripping as the
groundwater treatment technology for Source Area groundwater in
this ROD because it vill meet EPA's cleanup goals, will provide
overall protectiveness of public health and the environment, will
provide long and short term effectiveness, is implementable, will
provide reduction of toxicity, mobility and volume and is cost
effective. EPA will consider, during the design phase, the use
of either ultraviolet (uv)/chemical oxidation, carbon adsorption
or steam stripping as alternative groundwater treatment
technologies for Source Area groundwater if it can be
demonstrated that another alternative will meet the four
statutory requirements for cleanups under CERCLA and will provide
a similar balance of the nine evaluation criteria as air
stripping. Any decision to utilize one of these alternative
treatment technologies will be documented and an explanation of
significant differences issued, if appropriate.
The Proposed Plan suggested that EPA would reevaluate the
remedy if after an adequate period of performance of the remedy
complete restoration of the aquifer is determined to be
technically impracticable and that cleanup goals might be
readjusted if chemical contaminant concentrations reach a
constant value and are no longer being removed at significant
levels. EPA is not including these reevaluations as a part of
this ROD. This remedy will attain EPA's cleanup goals, will meet
ARARs and assure protectiveness of human health and the
environment. EPA, retains the right to amend this Record of
Decision or change its decision on the remedy for the Source
Area, as provided by CERCLA.
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None of the changes presented in this ROD differ
significantly from those presented in the Proposed Plan.
Furthermore, to the extent that differences exist, they are
the logical outgrowth of the Proposed Plan and were reasonably
forseeable. The Agency does not believe that it is necessary to
reissue the Proposed Plan for further comment and provides the
following rationale: 1) the supplemental Feasibility Study and
the Proposed Plan discussed the alternatives of proceeding with
Source Area groundwater extraction and treatment only and source
area soil treatment only; 2) the public already had an
opportunity to comment on this alternative, which is merely a
different combination of a source component and management of
migration component which were already evaluated in the FS; 3)
the supplemental Feasibility Study and the Proposed plan
discussed the alternatives of air stripping; 4) the suggested
changes, do not alter the overall remedial objectives for the
Site, as presented below; and 5) the eventual decision on
remediation of the Downgradient Area will again be subject to
public comment.
DEVELOPMENT AND SCREENING OF ALTERNATIVES
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, 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 and, to the
maximum extent practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
waiver is invoked; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
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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 potential exposure pathways were analyzed for
risk and threats to public health and the environment in the Risk
Assessment and Indoor Air Addendum to the supplemental Remedial
Investigation report. 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 public health and the
environment. These response objectives are:
1. Treat soils to minimize the risk from exposure
by direct contact with the contaminants and minimize
the leaching of contaminants to the groundwater;
2. Restore the overburden and bedrock aquifers to
drinking water standards;
3. Minimize the further introduction of contaminated
groundwater from the bedrock aquifer to the overburden
aquifer supplying the Kellogg-Deering Well Field;
4. Protect the Norwalk River from the adverse effects
of contaminated groundwater discharges; and
5. Prevent exposure to contaminated groundwater.
The remedial objectives listed above are overall objectives
for the entire site at the completion of all operable units. The
specific remedial objectives for the operable unit associated
with this Record of Decision are listed with the discussion of
the selected remedy.
Technology and Alternative Development and Screening
CERCLA, 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, 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 were developed for the Site, a containment option
involving little or no treatment, and a no-action alternative.
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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" dated July 24,
1987. This document provides direction on the consideration of
SARA cleanup standards and sets forth nine factors that EPA
should consider in its evaluation and selection of remedial
actions. The evaluation criteria are:
1. Overall Protection of Human Health and the Environment.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
3. Long-term Effectiveness and Permanence.
4. Reduction of Toxicity, Mobility or Volume.
5. Short-term Effectiveness.
6. Implementability.
7. Cost.
8. Community Acceptance.
9. State Acceptance.
Chapters 10 and 11 of the supplemental Feasibility Study
identified, assessed and screened technologies based on
effectiveness, implementability and cost. These technologies
were combined into source control (SC) and management of
migration (MM) alternatives. The purpose of the initial
screening was to narrow the number of potential remedial actions
for further detailed analysis while preserving a range of
options.
In Chapter 12 of the supplemental Feasibility Study, the
"Detailed Analysis of Overall Remedial Action Alternatives,"
remedial alternatives are developed by combining the technologies
identified in the previous screening process into the categories
required by OSWER Directive No. 9355.3-01. This process involves
combining the source control component with the Source Area and
Downgradient Area management of migratfon components and no-
action to produce a range of remedial alternatives. Table 2
displays the eight Remedial Alternatives that undergo the
detailed analysis.
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DESCRIPTION OF ALTERNATIVES
This section presents a narrative summary and brief
evaluation of the alternatives that do not involve management of
migration components in the Dovngradient Area. The alternatives
which incorporate treatment of groundwater in the Downgradient
Area (i.e. Alternatives III, IV, VII and VIII) are not described
in this Record of Decision because EPA is not making a formal
decision regarding remediation of the Downgradient Area at this
time.
The summaries below include brief evaluations of the first
seven of the nine evaluation criteria described above. The last
two criteria, State and Community Acceptance, are described later
during the comparative analysis of alternatives. Table 12-20 of
the supplemental Feasibility Study presents a detailed tabular
assessment of each of the original eight alternatives. Table 12-
20 is supported by text in Chapter 12 of the supplemental
Feasibility Study.
In October of 1987, Elinco and the Connecticut Department of
Environmental Protection (DEP) entered into a consent agreement
to implement a groundwater extraction and treatment system within
the boundaries of the complex. This system, composed of four
extraction wells, is presently under construction. Elinco's
extraction system was not considered in EPA's supplemental
Feasibility Study because the Elinco system was under design at
the time of the supplemental Feasibility Study's writing.
Alternatives described in the supplemental Feasibility Study and
below that involve no action for Source Area groundwater (i.e.,
Alternatives I and V) do not include the Elinco extraction
system. Alternatives that involve Source Area groundwater
treatment (i.e., Alternatives II and VI) would involve an
evaluation by EPA of the Elinco extraction system during Remedial
Design.
Alternative I; No Action
Alternative I, the no action alternative, means leaving the
site in its present condition. This alternative does not include
the remediation system to be undertaken by Elinco Associates.
Contaminated soils would not be treated. Long term institutional
controls including restrictions on deeds, building permits and
private wells would be enacted. Aquifer restoration would rely
primarily on natural aquifer flushing because only a portion of
the contaminants in the groundwater would be intercepted and
treated by operations at the Kellogg-Deering Well Field. The
remainder of the contaminants in the groundwater outside of the
effective pumping radius of the Kellogg-Deering Well Field would
either persist in dead end bedrock fractures or migrate through
the aquifer and eventually discharge into the Norwalk River. In
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addition, contaminants in soils of the unsaturated zone at the
complex could percolate downward to the water table if
infiltration was not prevented by the buildings and parking lots.
Environmental monitoring of groundwater and of indoor air
within the buildings at the complex would occur indefinitely.
This monitoring would be implemented to aid in identifying
potential receptors and minimize potential health risks. Details
of the monitoring program would be developed in the Remedial
Design phase.
Alternative I would not provide overall protection of human
health and the environment because no cleanup of contaminants in
soils and groundwater would occur and further release of
contaminants to groundwater from soils would not be minimized.
Alternative I is impleroentable and would provide short term
effectiveness. However, long-term institutional controls
including restrictions on deeds, building permits and private
wells would be needed. There would be no reduction of the
mobility, toxicity and volume of contaminants in the unsaturated
soils of the complex. The mobility of the contaminants in
groundwater would not be reduced. The toxicity and volume of
contaminated groundwater would not be reduced except by well head
treatment. Alternative I would not provide long-term
effectiveness or permanence or achieve groundwater quality ARARs.
Estimated Capital Cost: $0
Estimated Operations and Maintenance Cost (net present worth):
$240,000
Estimated Total Cost $240,000
Alternative lit Groundwater Treatment of Source Area
Alternative II was developed for the purpose of controlling
the contaminant migration only in the Source Area which is the
most heavily contaminated portion of the aquifer. This system,
would involve intercepting contaminated groundwater to the
maximum extent practicable in the source Area. The contaminated
groundwater would be treated by air stripping and discharged
offsite. An evaluation of the Elinco wells to remediate the
contamination within the complex boundaries would be part of
predesign activities. Contaminated soils would not be treated.
Long term institutional controls, including restrictions on deeds
building permits and private wells, would be enacted.
Alternative II would reduce the overall mass of contaminants
in the bedrock aquifer and eventually reduce the input of
contaminants into the overburden aquifer in the vicinity of the
Norwalk River. Contaminants in soils of the unsaturated zone at
the complex could percolate downward to the water table if
infiltration were prevented by the buildings and parking lots.
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Monitoring of indoor air within the buildings at the complex
would occur indefinitely to minimize potential health risks.
Groundwater monitoring would occur in both the Source and
Downgradient Areas to evaluate the progress of the remedy.
Details of the monitoring program would be developed in the
Remedial Design phase and will include at a minimum, overburden
and bedrock monitoring wells.
Alternative II would provide protection of human health and
the environment through the cleanup of contaminants in Source
Area groundwater. Alternative II would comply with groundwater
ARARs, but not soil ARARs. The groundwater treatment component
of Alternative II would substantially reduce the toxicity and
volume of contamination. The mobility of contaminants would be
reduced by the extraction wells. Since Alternative II does not
include soil treatment/ mobility, toxicity and volume of
contaminants in soils would .not be reduced.
Alternative II is implementable and would provide short term
effectiveness. Alternative II would provide limited long-term
effectiveness or permanence because soil contamination would
continue to contribute to the groundwater in the Source Area.
The time required to attain the groundwater cleanup goals
cannot be estimated with precision since volatile organic
compounds are expected to, be present as dense non-aqueous phase
liquids in bedrock fractures.
Estimated Time for Completion Including Design, Bidding,
Construction and Operation: Exceeds 10 years
Estimated Capital Cost: $4,600,000
Estimated Operations and Maintenance Cost (net present worth):
$3,100,000
Estimated Total Cost $7,700,000
Alternative III; Groundvater Treatment of Source and Dovnaradient
Areas
Alternative III would involve groundwater treatment of the
Source Area and the Downgradient Area without treatment of soils
at the complex. This alternative is not being considered in this
Record of Decision because EPA has decided not to issue a final
decision on the Downgradient System at this time. Alternative
III, minus the Downgradient System, is essentially the same as
Alternative II which is-considered in this Record of Decision.
The reasons for not including the Downgradient System in this
Record of Decision can be found above in the Documentation of
Significant Changes section.
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Alternative TVs Groundvater Treatment of Dovnaradient Area
Alternative IV would involve groundwater treatment of the
Downgradient Area without groundwater treatment of the Source
Area or treatment of soils at the complex. This alternative is
not being considered in this Record of Decision because EPA has
decided not to issue a final decision on the Downgradient System
at this time. Alternative IV, minus the Downgradient System, is
essentially the same as Alternative I, the no action alternative,
which is considered in this Record of Decision. The reasons for
not including the Downgradient System in this Record of Decision
can be found above in the Documentation of Significant Changes
section.
Alternative V: Soil Treatment
Alternative V would involve treatment of contaminated soils
only. Groundwater would remain much the same as described in
Alternative I, the no action alternative. The in-situ soil
vacuum extraction system would utilize unsaturated zone
extraction wells, vacuum pumps, associated piping and vapor
treatment. The vacuum extraction process develops a vacuum in
the unsaturated zone which induces contaminant flow in the form
of a vapor. The contaminant-bearing vapor is forced through the
soil matrix to extraction wells and withdrawn. The process
essentially air-strips volatile organic compounds from the soils
due to the mass transfer of contaminants to the soil vapor.
Moisture is removed from the contaminated soil vapor in a
condenser or separator. Vapors are then drawn through activated
carbon beds where volatile organic contaminants are absorbed
before discharging the clean air into the atmosphere in
compliance with Federal and State standards. The separated water
will be treated and discharged.
Alternative V would remove contaminants from soils of the
unsaturated zone below the complex thereby reducing further the
upward migration of contaminants into the indoor air of the
complex buildings. If in the future the buildings and parking
lots were ever removed, Alternative V would reduce the increased
potential for downward migration of contaminants to groundwater
and would minimize the potential human health risk from exposure
to contaminated soils.
Periodic sampling and analysis of indoor air within the
buildings at the complex would occur to monitor the progress of
soil remediation. Wellhead gases, process gases and gas
emissions would be monitored throughout the period of operation
to measure the effectiveness of the vacuum extraction system.
The progress of the remedy would also be measured by a monitoring
well network. Details of the soil vapor monitoring program would
be developed during the Remedial Design phase.
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Groundwater monitoring in both the Source and Dbwrigradient
areas would be needed indefinitely. Details of the monitoring
program would be developed in the Remedial Design phase.
Alternative V would provide protection of human health and
the environment through the cleanup of contaminated soils and by
minimizing the release of contaminants to the underlying
groundwater. The mobility, toxicity and volume of contaminated
groundwater would not be reduced by Alternative V. The mobility,
toxicity and volume of soil contaminants would be reduced by the
soil vapor extraction and treatment.
Alternative V is implamentable and would provide short term
effectiveness. Due to the fact that contaminants would remain in
groundwater, institutional controls would need to be enacted
during and after the time of in-situ soil vacuum extraction
treatment. These institutional controls would include
restrictions on deeds and building permits.
Alternative V would neither attain groundwater ARARs nor
provide long-term effectiveness or permanence because groundwater
contamination would persist. Additionally, the levels of
contamination may increase in the downgradient areas of the plume
which could potentially impact the ecosystems in Deering Pond and
the Norwalk River. ;
Soil remediation at the complex using in-situ vacuum
extraction would take approximately 2.5 years. However, the
ability of VOC contaminants to move upward in soils from
groundwater would likely extend the remediation time than would
be the case for soil treatment conducted concurrently with source
area groundwater treatment.
Estimated Time for Completion Including Design, Bidding,
Construction and Operation: 2.5 years
Estimated Capital Cost : $1,400,000
Estimated Operations and Maintenance Cost (net present worth):
$200,000
Estimated Total Cost $1,600,000
Alternative VIt Soil and Source Area Groundvater Treatment
Alternative VI was developed to control the contaminant
migration in the Source Area, the most heavily contaminated
portion of the aquifer, and remove contaminants from soils at the
complex. The groundwater system would be essentially the same as
described for Alterative II, that is, it would involve
intercepting contaminated groundwater in the Source Area. The
contaminated groundwater would be treated by air stripping and
discharged offsite. An evaluation of the Elinco wells to control
the contamination within the complex boundaries would be a part
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of predesign activities. Institutional controls including
restrictions on deeds, building permits and private wells would
be enacted.
The source control component, in-situ vacuum extraction,
would be essentially the same as described in Alternative II.
The in-situ soil vacuum extraction system would utilize
unsaturated zone extraction wells, vacuum pumps, associated
piping and vapor treatment. The vacuum extraction process
develops a vacuum in the unsaturated zone which induces
contaminant flow in the form of a vapor. The contaminant bearing
vapor is forced through the soil matrix to extraction wells and
withdrawn. The process essentially air-strips volatile organic
compounds from the soils due to the mass transfer of contaminants
to the soil vapor. Moisture is removed from the contaminated
soil vapor in a condenser or separator. Vapors are then drawn
through activated carbon beds where volatile organic contaminants
are absorbed before discharging the clean air into the atmosphere
in compliance with Federal and State requirements. The separated
water will be treated and discharged.
Alternative VI would reduce the overall mass of contaminants
in the bedrock aquifer and, over the long term, reduce the input
of contaminants into the overburden aquifer in the vicinity of
the Norwalk River.
Contaminants would be removed from soils of the unsaturated
zone at the complex which would further aid the groundwater
restoration effort, reduce the upward migration of contaminants
into the indoor air of the buildings of the complex, and reduce
human health risks if the buildings were ever removed and soils
became exposed. Periodic sampling and analysis of groundwater,
soil vapor and indoor air would be required to monitor the
progress of the cleanup. Details of the monitoring program would
be developed in the Remedial Design phase.
Alternative VI would provide protection of human health and
the environment because cleanup of contaminants in soils and
groundwater would occur and further release of contaminants to
groundwater from soils would be minimized. Treatment of the
extracted water and soil gas under Alternative VI will
substantially reduce the overall toxicity and volume of site
contamination. Alternative VI would reduce the mobility of
contaminants in the saturated or unsaturated zones through the
use of extraction wells.
Alternative VI is implementable and would provide short term
effectiveness. Alternative VI would provide long-term effective-
ness or permanence because both Source Area groundwater and
contaminated soils would be addressed.
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Soil remediation at the complex using in-situ vacuum
extraction would take approximately 2.5 years. The time required
to attain the groundwater cleanup goals cannot be estimated with
precison since volatile organic compounds are expected to be
present as dense non-aqueous phase liquids in bedrock fractures.
Estimated Time for Completion Including Design, Bidding,
Construction and Operation: Exceeds 10 years
Estimated Capital Cost : $6,000,000
Estimated Operations and Maintenance Cost (net present worth):
$3,000,000
Estimated Total Cost $9,000,000
Alternative VII; Soil and Groundwater Treatment
Alternative VII would involve groundwater treatment of the
Source and Downgradient Areas and treatment of soils at the
complex. This alternative was EPA's Preferred Alternative in the
July 1989 Proposed Plan, but is not being considered in this
Record of Decision because EPA has decided not to issue a final
decision on the Downgradient System at this time. Alternative
VII, minus the Downgradient System, is essentially the same as
Alternative VI, the selected alternative. The reasons for not
including the Downgradient System in this Record of Decision can
be found above in the Documentation of Significant Changes
section.
Alternative VIIIt Soil and Dovnaradient Area Groundwater
Treatment
Alternative VIII would involve groundwater treatment of the
Downgradient Area and treatment of soils at the complex. This
alternative is not being considered in this Record of Decision
because EPA has decided not to issue a final decision on the
Downgradient System at this time. Alternative VIII, minus the
Downgradient System, is essentially the same as Alternative V
which is considered in this Record of Decision. The reasons for
not including the Downgradient System in this Record of Decision
can be found above in the Documentation of Significant Changes
section.
SELECTED REMEDY
The selected remedy is Alternative VI which consists of in-
situ vacuum extraction for soils; pumping, treating and
discharging of contaminated groundwater in the Source Area; and
implementation of institutional controls.
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The overall goal of the cleanup action at the Kellogg-
Deering Well Field Superfund Site is to restore the groundwater
in the aquifer to its beneficial uses (or health based levels)
within a reasonable period of time. The selected remedy for the
second operable unit is a comprehensive approach to Source Area
remediation that combines components of source control and
management of migration.
Remedial Action O^eetives/Cleaaup Qeals
The selected remedy was developed to satisfy the following
remedial objectives which will guide the design of the remedy and
be used to measure the success of the remedy.
Qroundvater - The remedial objectives for contaminated
groundwater at the Source Area are as follows:
* Prevent further introduction of contaminated ground
water from the Source Area to the Downgradient Area and
ultimately to the production wells at the Kellogg-
Deering Well Field and the Norwalk River.
* Restore the Source Area aquifer to drinking water
quality.
* Reduce the mass of contaminants at the Source Area.
* Prevent human consumption of or contact with
contaminated ground water above the cleanup goals
presented in this ROD.
EPA believes that active restoration of the groundwater is
appropriate for the Kellogg-Deering Well Field Superfund Site.
The groundwater cleanup levels at the site are primarily based
upon the classification of the groundwater as a current drinking
water source. Therefore, the Maximum Contaminant Levels
promulgated under the Safe Drinking Water Act are relevant and
appropriate to the aquifer.
EPA's decision to attempt restoration of the groundwater at
the site to drinking water standards is based on several factors.
In addition to the requirement to attain Federal and State ARARs,
EPA considered its Groundwater Protection Strategy (Office of
Groundwater Protection, August 1984) which provides guidance
concerning how different groundwaters throughout the country
should be classified and to what extent cleaning up a particular
class of groundwater is appropriate. The policy under the
Groundwater Protection Strategy establishes groundwater
protection goals based on "the highest beneficial uses to which
groundwater having significant water resources value can
presently or potentially be put." Guidelines for protection of
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aquifers are differentially based, relative to characteristics of
vulnerability, use and value. Under the Groundwater Protection
Strategy classification, the groundwater at the Kellogg-Deering
Well Field Superfund Site is considered to be Class II-A, a
current drinking water source.
EPA also considered the Agency's Guidance on Remedial
Actions for Contaminated Ground Water at Superfund Sites
(December 1988). This guidance directs the Agency to consider a
10*4 to 10 range of risk levels in selecting the appropriate
risk level for the groundwater at the site. The Source Area
groundwater will be pumped and treated until MCLS are met. At
that point in time, groundwater will be sampled to determine if
the cumulative carcinogenic risk falls within a range generally
considered by EPA to be protective at Superfund sites and does
not exceed unity on the Hazard Index. If the level of risk does
not fall within EPA's risk range or exceeds unity on the Hazard
Index, then additional treatment will be conducted in order to
meet EPA's risk levels. A supplementary decision document will
be issued, as appropriate.
The area of attainment for the groundwater goals shall be at
every point within the Source Area. The groundwater cleanup
goals are presented in Table 3.
Soil - The remedial objectives for contaminated soil at the
complex are as follows:
* Prevent public contact with contaminated soils above
cleanup goals.
* Prevent leaching of contaminants to the groundwater at
values that affect the quality of groundwater.
Soil cleanup goals were developed in order to reduce the
potential future risk to public health and the environment and to
protect groundwater. The soil cleanup levels presented in Table
3 are calculated by using a soil leaching model in order to
achieve the target groundwater levels. This approach utilizes a
soil/water sorption coefficient which describes the distribu-
tion of an indicator chemical between soil and groundwater at
equilibrium. The type of soils and amount of organic carbon
present in the soils have a large impact on the amount of
contamination that will be attenuated in those soils and,
therefore, unable to migrate and contribute to groundwater
contamination. The soil cleanup levels listed in Table 3 are
presented as ranges because the soil types differ within the area
of soil contamination. Further soil sampling and analysis will
be undertaken during Remedial Design to refine the soil cleanup
levels. A more complete description the soil leaching model can
be found in Section 6 of the supplemental RI.
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Description of Components of the Selected Remedy
EPAfs selected remedy consist* of source control through the
implementation of in-situ vacuum extraction at the Elinco/Pitney
Bowes/Matheis Court Complex, management of migration through
implementation of groundwater pumping, treatment and discharge
for the Source Area, and institutional controls to prevent
potential exposure to contamination during implementation of the
remedy. ' Institutional controls will involve restrictions on soil
excavation in areas of soil contamination and restrictions on
veil installations in areas of groundwater contamination. If EPA
cannot obtain the required institutional controls, EPA will
consider treatment technologies that do not require institutional
controls.
7?ntfnJP>ted Soil Treatment - The source control component will
involve designing, installing, operating and maintaining a soil
vapor vacuum extraction system in the unsaturated zone at the
Elinco/Pitney Bowes/Matheis Court Complex which will intercept
laterally and vertically all areas of subsurface soil
contamination so as to attain the soil cleanup goals presented
above and in Table 3. The area of attainment for the soil
cleanup goals will be everywhere on the complex property.
The vacuum extraction system will utilize extraction,
injection and monitoring wells. It is anticipated that
extraction wells would be located in or near the three processing
areas of the two Zell and Elinco Buildings as well as in the two
exterior corridors. The number and location of these wells will
be finally determined during design. Each of the extraction
wells will be surrounded by approximately 15 passive air
injection wells.
The vacuum extraction system will utilize carbon adsorption
for vapor treatment for protectiveness consistent with OSWER
Directive 9355.0-28 and Region I guidance. The contaminated
water from the separator will be treated as necessary and
discharged in accordance with the discharge limitations required
by the chosen groundwater discharge method as described below.
Predesign work will include sampling to refine the volume of
soil to be treated. This sampling program will include analysis
for total organic carbon so that soil cleanup goals can be better
refined in accordance with the soil leaching model described
above.
An adequate and effective sampling and analysis program will
be designed and implemented to monitor the performance of the
vacuum extraction system recovery and treatment and process gas
discharges. It is currently estimated that the soil cleanup
goals can be achieved within 2.5 years for the estimated 44,000
cubic yards of contaminated soils. Consideration will be given
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to sequencing soil and groundwater remedial components to avoid
recontamination of soil from contaminated groundvater.
Completion monitoring will also be conducted. The costs
associated with this source control component are listed in
Table 4.
Management of Migration component will include designing,
installing, operating and maintaining a groundwater extraction,
treatment and disposal system for the Source Area shown in Figure
4. The remedial action would be combined with institutional
controls consisting of restrictions on the installation and use
of private wells in the area of groundwater contamination in the
Source and Downgradient Areas. The costs associated with this
Management of Migration component are listed in Table 4.
The Source Area extraction system will utilize two
remediation well networks. One remediation well network will be
located at the complex property. EPA will evaluate during design
the groundwater treatment system currently being constructed by
Elinco at the complex to determine if some, or all, of that
system may be incorporated in the groundwater treatment system
required by this Record of Decision. The second remediation well
network will be installed near the center of the Source Area
contamination near the railroad tracks west of Main Ave in
Norwalk. Extraction wells at this network will be installed to
capture contaminants along the entire width of the groundwater
contamination plume at the railroad tracks. The remediation well
networks together may include as many as 25 wells, possibly more,
to remove contaminants from both the overburden and bedrock
aquifers. Bedrock wells may extend as far as 250 feet or more
below ground surface. Extraction rates for the system have been
estimated at approximately 370 gallons per minute. The specific
pumping rates, number of wells and locations of wells will be
developed during design.
Air stripping will be utilized to treat the groundwater to
remove VOCs. The system would utilize carbon adsorbtion for
vapor treatment for protectiveness consistent with OSWER
Directive 9355.0-8 and Region I guidance. Pretreatroent to remove
solids may be required prior to air stripping. Any pretreatment
sludge will be tested to determine if it is subject to RCRA and
the RCRA Land Disposal Restrictions. The sludge will be managed
in compliance with RCRA and the Land Disposal Restrictions if
they are applicable.
The Proposed Plan indicated that four different treatment
technologies could potentially be used to address groundwater
contamination at the site. These include air stripping,
ultraviolet (uv)/Chemical Oxidation, carbon adsorption and steam
stripping. EPA's chosen groundwater treatment method in this ROD
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is air stripping. EPA will consider, during the design phase,
the use of ultraviolet (uv)/chemical oxidation, carbon adsorption
or steam stripping as alternative groundwater treatment
technologies for Source Area groundwater if it can be
demonstrated that these alternatives will meet the four statutory
requirements for cleanups under CERCLA and will provide a similar
balance of the nine evaluation criteria as air stripping.
The Proposed Plan indicated that a decision on the discharge
option for treated groundwater would be made during the design
phase from among four options. These options include discharge
to the local publicly owned treatment works, discharge to the
Norwalk River through a new pipe, discharge to the Morwalk River
through existing storm sewers or reinjection into the aquifer,
either solely or in combination. A decision among these
discharge options will be made on the basis of the statutory and
regulatory criteria for CERCLA cleanups. This decision will be
issued in a supplementary decision document.
Predesign activities will include at a minimum: 1)
comprehensive groundwater sampling to refine and confirm the
nature and extent of contamination at the site in both the
bedrock and overburden; 2) an evaluation of the adequacy of the
Elinco groundwater extraction system to control the groundwater
contamination within the complex boundaries; 3) an evaluation of
the need for pretreatroent (as described above) of extracted
groundwater prior to air stripping; 4) pump tests to determine
well yields, remediation pumping rates, and location and number
of extraction wells; and 5) bench and pilot testing of the
presented and/or proposed treatment technologies.
Groundwater monitoring of the overburden and bedrock
aquifers within the Source Area, and the Downgradient Area will
occur during implementation of the remedy in order to determine
compliance with the cleanup goals. A specific monitoring program
will be developed during design that will include overburden and
bedrock monitoring wells including, at the least, those wells
that have been installed as part of the remedial investigation.
Monitoring wells will be sampled at least quarterly. Treatment
system influent and effluent concentrations will be monitored at
least once per day. The objectives of monitoring are to define
the mass of contaminants extracted over the life of the remedy,
to evaluate the efficiency of the remedy, and to ensure
compliance with appropriate Federal and State requirements.
Pumping rates at each extraction well will be monitored
during the course of the remedial action. An adequate array of
piezometers will be installed to adequately measure in three
dimensions the hydraulic gradient between adjacent pumping wells
to insure an inward hydraulic gradient is maintained at each
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remediation well network and that no portion of the plume is free
to migrate from the Source Area. Extraction wells may need to be
repositioned occasionally to maximize the extraction efficiency.
Remediation of the Source Area can involve the intermittent
operation, or pulse pumping, of the remediation well fields to
improve the efficiency of contaminant removal. The purpose of
the pulse pumping is to allow a sufficient resting phase between
pumping phases when 1) contaminants can diffuse out of low
permeability zones and into adjacent high permeability zones, 2)
maximum concentrations can be achieved in high permeability
zones, or 3) non aqueous phase liquid residuals can reach
equilibrium concentrations. As a result, active phases will
remove a minimum amount of contaminated groundwater at maximum
possible concentrations. The cycle of pumping and resting will
continue for each extraction well until it is determined that
contaminant levels in the extraction wells are not rising above
the cleanup goals for individual contaminants. At that point in
time, groundwater will be sampled to determine if the cumulative
carcinogenic risk falls within a risk range generally considered
by EPA to be protective at Superfund sites and does not exceed
unity on the Hazard Index. If the level of risk does not fall
within EPA's risk range or exceeds unity on the Hazard Index,
then additional treatment will be conducted in order to meet
EPA's risk levels. A supplementary decision document will be
issued as appropriate.
A completion monitoring program will be implemented which
will consist of quarterly monitoring for three years. The
completion monitoring program will be defined during design and
refined during the remedy implementation. The completion
monitoring program may require the installation of additional
wells. This program will be implemented at the point the cleanup
goals are achieved at all wells that are part of the
implementation program.
To the extent required by law, EPA will review the Site at
least once every five years after the initiation of remedial
action at the Site if any hazardous substances, pollutants or
contaminants remain at the Site to assure that the remedial
action continues to protect human health and the environment.
EPA will also evaluate risk posed by the Site at the conclusion
of the completion monitoring program to guarantee it is
protective (i.e., before the Site is proposed for deletion from
the NPL).
Rationale 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
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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, implementability, 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.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In this section, the four alternatives are compared against
each other in relation to the nine evaluation criteria. A more
complete comparison of the Alternatives according to these
criteria is provided in Table 12-20 and Section 12.3 of the
supplemental Feasibility Study.
Overall Protection of Hmpan Health and the Environment
Section 121(d) of CERCLA provides that remedial actions
shall attain a degree of cleanup of hazardous substances,
pollutants, and contaminants released into the environment and of
control of further release at a minimum which assures protection
of human health and the environment. Alternatives I, II, V and
VI provide varying degrees of protection of human health and the
environment. Although, institutional controls would be
implemented (to prevent excavations in areas of soil
contamination and well installations and use in areas of
groundwater contamination) under all these alternatives, such
institutional controls can fail. Therefore, absent engineering
controls, institutional controls fail to provide overall
protectiveness. The use of institutional controls to restrict
use or access should not substitute for active response measures
(e.g. treatment and/or containment of source material,
restoration of groundwaters to their beneficial uses) as the sole
remedy.
Alternative I, the no-action alternative, would not be
protective of human health and the environment because
contaminants in the groundwater outside of the effective pumping
radius of the Kellogg-Deering Well Field would persist in dead
end bedrock fractures or migrate through the aquifer and
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discharge to the Norwalk River. In addition, contaminants would
remain in the soils at the complex and would provide a continuing
source of groundwater contamination and soil gases. Alternative
I would include institutional controls which, absent engineering
controls, fail to provide overall protectiveness.
Alternatives II and VI provide for greater protection of the
environment than Alternatives I and V because the groundwater
extraction wells will remove significant amounts of contaminants
from the aquifer. Alternatives II and VI would thereby reduce
the size of the contaminant plume, expedite aquifer restoration,
and provide greater overall protectiveness should institutional
controls fail. Alternatives I and V would rely on natural
flushing for groundwater restoration.
Alternatives V and VI would remove contaminants from soils
of the unsaturated zone below the complex thereby reducing
further the upward migration of contaminants into the indoor air
of the complex buildings. If in the future the buildings and
parking lots were ever removed, Alternatives V and VI would
reduce the increased potential for downward migration of
contaminants to groundwater and would minimize the potential
human health risk from exposure to contaminated soils.
Alternative VI would provide the greatest protection of
human health and the environment by removing contaminants from
soils in the unsaturated zone at the complex and by removing
contaminant mass and reducing contaminant concentrations within
the bedrock and overburden aquifers in the Source Area.
Compliance with Applicable or Relevant and Appropriate
Requirements
Section 121(d) of CERCLA requires that remedial actions
comply with all applicable or relevant and appropriate Federal
and State standards, requirements, criteria or limitations that
apply to the Site.
Alternatives I and V, the no-action and soil treatment
alternatives, rely on aquifer flushing and the treatment system
at the Kellogg-Deering Well Field to alleviate groundwater
contamination at the site. These alternatives are less likely to
assure that groundwater in the Source Area will meet Safe
Drinking Water Act MCLs for groundwater within a reasonable
timeframe. Alternative-VI is more capable of meeting groundwater
quality ARARs than Alternative II because the soil treatment
component of Alternative VI will reduce the potential for
additional leaching of contaminants from the unsaturated zone to
the saturated zone.
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The air stripping system proposed under Alternatives II and
VI are equally capable of meeting Federal and State requirements
for air emissions. These systems are also equally capable of
treating extracted groundwater to levels required for discharge
to surface water or groundwater.
Alternative VI is the most capable of meeting the relevant
and appropriate RCRA closure requirement, especially the Closure
Performance Standard of 40 CFR Part 264.111
Long-term Effectiveness and Permanence
Long-term effectiveness and permanence addresses the long-
term protection and reliability of an alternative and the
magnitude of residual risks.
Alternative VI would remove the largest amount of
contaminants from the aquifer, would provide the greatest control
of migration of contaminants, and would restore the Source Area
portion of the aquifer in the shortest period of time. In
comparison to Alternatives I, II and V, Alternative VI would be
the most capable of all the other alternatives evaluated in this
Record of Decision to meet soil and groundwater cleanup goals and
thereby provide a permanent remedy.
Long-term environmental monitoring of indoor air and
groundwater would be implemented for each alternative to measure
effectiveness of the remedy and to identify potential receptors.
Institutional controls would be implemented with each
alternative, although such controls are not considered a
permanent remedy. Alternative VI, which addresses contaminated
soils and groundwater in the Source Area, would require the least
in terms of long-term institutional controls. Maintaining
institutional controls on private well use for the duration of
the aquifer restoration period would be more difficult under
Alternatives I and V because they would require a greater amount
of time to cleanse the aquifer through natural aquifer flushing
than with the aid of extraction wells. Maintaining long-term
contaminated soil excavation institutional controls would be more
difficult under Alternatives I and II.
Alternatives II and VI are capable of removing more
contaminants from the Source Area, and at a faster rate than
Alternatives I and V, which rely mostly on dilution and natural
aquifer flushing. The natural aquifer flushing that would be a
part of Alternatives I and V are likely to result in increased
contaminant levels in downgradient portions of the groundwater
plume before cleansing by flushing is complete. Therefore,
Alternatives II and VI would be more effective at restoring the
aquifer and reducing the long term risk to potential receptors
downgradient. Alternative VI would be more effective than
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Alternative II because the soil treatment component of
Alternative VI will reduce the potential for additional leaching
of contaminants from the unsaturated zone to soils to the
saturated zone.
Reduction of Toxicitv, Mobility or
This evaluation criterion relates to the ability of a
remedial alternative to reduce the toxicity, mobility or volume
of hazardous substances at a site and to thereby control the
risks associated with such hazardous substances. Reducing the
level of toxicity in the aquifer and soils will reduce the public
health risk posed to future users of the aquifer should
institutional controls fail.
Alternative VI which is the only alternative that addresses
both contaminated soil and groundwater would provide the greatest
and quickest reduction of mobility, toxicity and volume of
contaminants at the site. Under Alternatives II and VI, toxicity
and volume of groundwater contaminants would be reduced by the
treatment. The mobility of contaminants would be reduced by the
extraction wells. Under Alternatives I and V, the toxicity and
volume would not be reduced. Alternatives I and V would continue
to allow some of the contaminants to continue to migrate
doWngradient of the Source Area.
Under Alternatives V and VI the toxicity and volume of soil
contaminants would be reduced by soil vapor treatment. The
mobility of soil contaminants would be reduced by the extraction
wells. Under Alternatives I and II, contaminants remaining in
the unsaturated zone could possibly migrate upwards into the
indoor air of the complex buildings or percolate downward to the
water table (if the buildings and parking lots were removed).
Short-Term Effectiveness
The short-term effectiveness criterion relates to the time
required to meet remedial objectives, and the impacts of the
implementation of the remedy.
The time required to meet the groundwater cleanup goals in
the aquifer cannot be determined with specificity for any of the
alternatives due to the probable presence of DNAPL's and the
complexity of the fractured bedrock system. However, the time
required to meet the groundwater cleanup goals would be
substantially longer under Alternatives I and V than under
Alternatives II and VI, which, in addition to natural aquifer
flushing, rely on groundwater extraction wells to actively remove
contaminants from the aquifer.
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Implementation of Alternative I would have very minor short-
term impacts to workers and to the environment. Implementation
of Alternatives II, V and VI could pose some risk to workers due
to the possible release of contaminant vapors during drilling and
installation of soil vapor and/or groundwater wells. This
potential for release would pose a minimal risk to the community.
Alternatives V and VI would require some coordination with
existing industrial activities within the complex buildings
during the construction of some of the soil vapor extraction
equipment. The short-term adverse impacts associated with
Alternative VI would be greatest in comparison to the other
alternatives because Alternative VI involves the most
construction.
Alternatives II and VI may, if no practicable alternative
exists, have short tern impacts on wetlands or the floodplain
during installation and operation of a discharge pipe or
injection wells. All impacts from these activities will be
mitigated at the time the remedial action is completed.
Implementability
Implementability addresses the ability to implement and
operate each alternative from design through construction and
operation and maintenance.
Alternative I would be the easiest to implement since long-
term environmental monitoring would be the principle element.
Alternatives II, V and VI would be more difficult to implement
because these alternatives would have substantially greater
design, construction, and operation and maintenance requirements
than Alternative I. Also, Alternatives I, V and VI would require
trained personnel to perform operation and maintenance
activities. Alternative VI would be the most difficult to
implement since it includes both an in-situ vacuum extraction
system and groundwater extraction system.
The equipment and resources under Alternatives I and II are
readily available. The availability of vendors to implement the
in-situ vacuum extraction system for Alternatives V and VI is
limited.
cost
The cost evaluation of each alternative is based on the
capital cost (cost to construct), long-term monitoring, operation
and maintenance (O&M), and present worth costs. Table 5 presents
estimates of these costs for Alternatives I, II, V and VI.
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Community Acceptance
This evaluation criterion addresses the degree to which
members of the local community support the remedial alternatives
being evaluated. Three general groups from the community
commented on the remedial alternatives for the site. These
groups include: local citizens, the Norwalk First Taxing District
(NFTD) Water Department and Potential Responsible Parties (PRPs).
Local citizens favor timely restoration of the aquifer to
the maximum extent practicable.
The NFTD supports the in-situ vacuum extraction system for
soil treatment (Alternative V). The NFTD has expressed concern
with regard to the cost-effectiveness of groundwater extraction
and treatment systems within the bedrock aquifer.
PRPs have raised numerous technical and legal concerns that
tend to support Alternative I, the no-action alternative . In
.general, many of the PRPs feel that the groundwater extraction
and treatment system currently being constructed by Elinco at the
complex is a sufficient effort toward aquifer restoration.
State Acceptance
This evaluation criterion addresses the concern and degree
of support that the state government has expressed regarding the
remedial alternatives being evaluated.
The State of Connecticut believes that Alternative VI is an
appropriate remedial action to address the Source Area, and that
this remedy is consistent with Connecticut's groundwater quality
standards and goals. Connecticut disagrees with EPA on technical
aspects of the remedial action originally proposed for the
Downgradient Area.
Technical comments presented by DEP on the Downgradient Area
will be discussed and evaluated during the remedy selection
process for the third operable unit. A letter of concurrence
with this Record of Decision for the second operable unit
(consisting of the source area) is attached as Appendix C.
Conclusion
Alternative VI, the selected remedy, provides the best
balance of tradeoffs among the alternatives with respect to the
evaluation criteria.
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38
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the
Kellogg-Deering Well Field Superfund Site is consistent with
CERCIA 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 mobility, toxicity or volume of
hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternate treatment technologies or
resource recovery technologies to the maximum extent practicable.
Protection ef Human Health and the Environment
The remedy at this Site will permanently reduce the risks
presently posed to human health and the environment by removing
contaminants from soils in the unsaturated zone beneath the
buildings and parking lots at the Elinco/Pitney Bowes/Matheis
Court complex and by removing contaminant mass and reducing
contaminant concentrations within the bedrock and overburden
aquifers in the Source Area. This remedial action will:
* reduce the level of contamination in the soil at the
Source Area to cleanup goals, thus preventing exposure
to contamination that may present a risk to human
health and the environment if any excavation occurred
at the Complex;
* eliminate the leaching of soil contamination to the
groundwater at levels in excess of groundwater cleanup
goals;
* reduce the level of contamination in the soil at the
Source Area, and thus eliminate the migration of soil
vapors into the buildings at the complex and prevent
human exposure to this vapor;
* reduce the contamination in the bedrock and overburden
aquifers in the Source Area to cleanup levels;
* prevent the migration of contaminated groundwater from
the Source Area;
* reduce the contamination in the aquifer which will
decrease long-term reliance on institutional controls
on future well installations to protect public health;
* minimize the future introduction of contaminated
groundwater from the bedrock aquifer to the overburden
. aquifer supplying the Kellogg-Deering Well Field; and
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39
* reduce the risk to the Norwalk River and the life it
supports.
The Source Area groundwater will be pumped and treated until MCLS
are net. At that point in time, groundwater will be sampled to
determine if the cumulative carcinogenic risk falls within a risk
range generally considered by EPA to be protective at Superfund
-sites and does not exceed unity on the Hazard Index. If the
level of risk does not fall within EPA's risk range or exceeds
unity on the Hazard Index, then additional treatment will be
conducted in order to meet EPA's risk levels. A supplementary
decision document will be issued, as appropriate.
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. Environmental laws from which ARARs for the selected
remedial action for the second operable unit at the Kellogg-
Deering Superfund Site include:
* Resource Conservation and Recovery Act (RCRA)
* Clean Water Act (CWA)
* Safe Drinking Water Act
* Executive Order 11988 (Floodplain Management)
* Executive Order 11990 (Protection of Wetlands)
* Clean Air Act (CAA)
* Occupational Safety and Health Administration
(OSHA)
* Connecticut Water Quality Standards and Classification
* Connecticut Standards for the Quality of Public
Drinking Water
* Fish and Wildlife Coordination Act
* Connecticut Public Health Code
* Connecticut Inland Wetlands and Water Courses
Regulations
* Connecticut Hazardous Waste Facility Siting Rules
* Protection of Archaeological Resources .
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40
* Connecticut Air Pollution Control Regulations
* Connecticut Water Diversion Regulation
* Connecticut Discharge Permit Regulations
* . Connecticut Hazardous Waste Rules
* Federal Department of Transportation Rules for
Transportation of Hazardous Materials
Table 6 provides a brief synopsis of the requirements and
outlines the action to be taken to attain these ARARs.
The list below includes some of policies, criteria, and
guidances that will also be considered (TBCs) during the
implementation of the remedial action:
* Connecticut Water Quality Management Plan
* Connecticut Draft Clean Water Strategy
* Connecticut Water Quality Standards and Classification
* EPA Risk Reference Doses (RfDs)
* EPA Carcinogen Assessment Group Potency Factors
* RCRA Proposed Air Emission Standards for Treatment
Facilities (52 FR 3748, Feb. 5, 1987)
* EPA OSWER Directive 9355.0-28; Air Stripper Control
Guidance
* EPA Groundvater Protection Strategy
* Connecticut Standards for the Quality of Public
Drinking Water
* EPA Health Advisories and Acceptable Intake Health
Assessment Documents
* Safe Drinking Water Act Maximum Contaminant Level Goals
(MCLGs)
* OSHA Threshold Limit Values (TLVs)
Additional information regarding TBCs can be found in Tables 8-1,
8-2, 8-3, and 12-15 of the supplemental Feasibility Study.
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41
The Selected Remedial Action ia Cost Effective
Once EPA identifies alternatives that are protective of
human health and the environment and attain ARARs (unless a
waiver is invoked), EPA evaluates each of those alternatives to
determine their cost effectiveness. Each of the alternatives
underwent a detailed cost analysis to develop costs to the
accuracy of -30 to +50 percent. In that analysis, capital and
operation and maintenance costs have been estimated and then used
to develop present worth costs. In the present worth analysis,
annual costs were calculated for thirty years (estimated life of
an alternative) using a five percent interest rate factor and
were based on 1988 costs.
Of those remedial alternatives that are protective and
attain ARARs, and satisfy the preference for treatment to the
maximum extent practicable, EPA selected a remedy that is cost-
effective in mitigating the risks posed by the soil and
groundwater in the Source Area within a reasonable period of
time. Overall, the total cost (present worth) of the selected
remedy is estimated at $9,100,000, as presented in Table 4.
This cost is:higher than that of some of the other
alternatives; however, none of the less expensive technologies
can ensure that the treated soil and groundwater will reach the
target cleanup goals and also provide long-term effectiveness and
permanence. Additionally, EPA has determined that this remedy
will yield results that are in proportion to its cost in terms of
effectiveness. Thus, while other alternatives evaluated are
cheaper than the selected alternative, they do not provide the
same degree of effectiveness.
Table 4 provides an itemized breakdown of the total cost of
the remedy by elements, capital cost, operation and maintenance
costs and present worth. Some changes in cost figures may be
made as a result of the remedial design and construction
processes.
The Selected Remedy utilizes Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
The selected remedy utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
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42
In-situ vacuum extraction and treatment with carbon
adsorption is an alternative treatment technology which provides
permanent removal of the mass of volatile organic contamination
in soil, thereby permanently and significantly reducing the
toxicity, mobility and volume of contamination. Contaminant
reduction efficiencies of 99.99% have been achieved at other
sites using in-situ vacuum extraction with treatment by carbon
adsorption.
The groundvater extraction/treatment portion of the selected
remedy also provides permanent removal and reduction of the mass
of volatile organic contaminants in groundvater through
groundvater recovery and treatment via air stripping and carbon
adsorption. Carbon columns vill remove contaminants from the
airstream before being released to the atmosphere. Treated
groundvater vill be discharged in compliance vith discharge
limitations required by ARARs.
The Selected Remedy Satisfies the Preference for Treatment as a
Principal Element
The principal element of the selected source control remedy
for contaminated soil is in-situ vacuum extraction and carbon
adsorption. The principal elements of the selected management of
migration component for contaminated groundvater are air
stripping and carbon adsorption. These elements are all
technologies that use treatment to address the human health and
environmental threats at the Site resulting from contamination of
soil and groundvater.
STATE ROLE
The Connecticut Department of Environmental Protection has
revieved the various alternatives and has indicated its support
for the selected remedy for the Source Area. The State has also
revieved the supplemental RI, Risk Assessment and FS to determine
if the selected remedy for the Source Area is in compliance vith
the applicable or relevant and appropriate State environmental
lavs and regulations.
Connecticut concurs vith the selected remedy for the second
operable unit of the Kellogg-Deering Well Field Superfund Site,
vith the understanding that a third operable unit consisting of a
Dovngradient Area betveen the source and the veil field vill be
addressed separately. Connecticut concurs that this remedy
attains State ARARs.
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vfptJ-i
'MtSFOtf
GENERAL LOCATION OF
KELLOGG-PEERING WELL FIELD
•'• ^^-^-^^^^^ ^£'-
••;• ^S^^^s^SSL^m
w TO3iiF ;if^p^^»N
4&?f;% ••CTws§raeHS
Wrniwi.!!
"K" I T\
BASE MAP IS A PORTION OF THE U.S.G.S. NORWALK NORTH, CONN.- N.Y. AND NOR'wALK SOUTH, CONN. QUADRANGLES
(7.5 MINUTE SERIES, I960. PHOTOREVISED 1971 ) CONTOUR INTERVAL 10*.
SOURCE- NUS CORPORATION 1966
NOTE- SEE FIGURE 1-2 FOR DETAIL.
GENERAL LOCATION MAP
KELLOGG -PEERING WELL FIELD. NORWALK. CT
SCALE: l's 2000'
-------
44
FIGURE 2
Kollogg-Dttrlng Sltt Location Map
Amomun truot MU MUNOMT
Ktueaa-Aunma wtu mi*
• KlUOaa-OIUMM WIUS
FIGURE 3
General Cross-Section Diagram from
Line Looking Northwest
Ktllogg-OMring
-------
FIGURE 4
Generalized Map of Areas of Groundvater Contamination at the
Kellogg-Deering Well Field Superfund site
•r*u»«vttir vitk TOI •o»o»mtrttl»»§
tkaa
«ttk Kl ••••
SCALE IN FEET
NARJIOAO
-------
TABLE 1
INDICATOR CHEMICALS
KELLOGG-DEERING SUPERFUND SITE
NORWALKr CONNECTICUT
Indicator Chemicals
Carcinogens
tetrachloroethene
trichloroethene
1,1-dichloroethene
vinyl chloride
chloroform
methylene chloride
1 , 1-dichloroethane
1,2-dichloroethane
benzene
Noncarcinogens
1 , 1 , 1-tr ichloroethane
1,2-dichloroethene
toluene
ethylbenzene
xylenes
acetone
4rmethyl-2-pentanone
-------
TABLE 2
SUMMARY OF REMEDIAL ALTERNATIVES
Remedial
Alternative Soil Source Downgradient
I
n
m
IV
V
^ VI
>• vn
vm
•
•
•
•
•
•
•
•
•
•
•
•
Blank Spaces indicate no action
• Soil treatment using in-situ vacuum extraction
• Groundwater extraction/treatment/discharge
> EPA's Preferred Alternative in July 1989 Proposed Plan
•» EPA's selected Alternative
-------
48
Groundvater and Boil Cleanup Goals
KELLOGG-DEERING SOPERFUND
NC?.W;.LK, CONKICTI CUT
SITE
Contaminant
benzene
toluene
ethylbenzene
1,1, 1-tr ichlorocthane
1 , 2-dichloroethane
tetrachloroethene
trichloroethcne
1 f 2-dichloroethene
1 , 1-dichloroethene
vinyl chloride
4-methyl-2-pentanone
Groundwater
Cleanup Goal
(ug/D
5
2,000
680
200
5
5
5
70
7
2
350
Soil Cleanup Goal
(ugAg)
1.2 - 36.7
5,523 - 169,552
13,771 - 422,750
560 - 17,332
0.6 - 7.9
33 - 1,036
12 - 358
76 - 2,321
8.3 - 256
0.3 - 9
1,246 - 38,243
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49
TABLE 4
Estimated capital, o&M, and net present worth costs for the
Selected Remedy (Alternative VI) for the second operable unit at
the Kellogg-Deering Well Field Superfund Site.
Alternative VX:
• Soils - Jo-situ Treatment
• Groundwater - Source area treatment using air stripping
1. Capital Cost
Item
In-situ vapor extraction
Air stripping system (source area)
River discharge system
Total
Cost
$1,396,000
3,508,000*
1.133.000
$6,037,000*
2. 0(M Costs
Task
Air Monitoring
Groundwater
Monitoring
Outfall Monitoring
5-Year Site Review
Energy
Maintenance
Operators
(8 man-hr/day)
Total OfcM
Present-Worth
Year
1
2-30
1-30
1
2-30
1-30
1-30
1-30
1-30
Cost per
Event
$4,650
1,000
6,600
350
350
20,000
57,900
62,000
60,000
Frequency
Quarterly
Annually
Annually
Weekly
Monthly
Every
5 years
Annually
Annually
Annually
Present-Worth
5% for 30 years
$18,600
14,300
101,200
18,200
61,600
55,600
890,000
953,000
922.400
$3,034,900
2. Total NPW
[capital + OEM NPW
$9,100,000*
Rounded up from $9,071,900.
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50
TABLE 5
COMPARISON OF ESTIMATED COSTS OF ALTERNATIVES
•tternativa
-
I
n
V
«t
Capital
Costs
f 11. 0001
AabMH**
0
4M1
1396
6,037
Long-Tar* Ground
Watar Monitoring
f ivofloi
101
101
101
101
Long-Tar* Air
Monitoring
{11.0001
AA
• 1
87
49
33
Annual
Ot M
(f 1.0001
200
13
200
OM
30-yaar
f 81.0001
238
3,088
206
3.034
Net Prasant
Worth Cost
ftl.OQO)
2&0
7,700
1,600
9,100
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TABLE 6
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
FOR THE SECOND OPERABLE UNIT AT
THE KELLOGG-DEERING WELLFIELD SUPERFUND SITE
ARARS
Federal Safe Drinking
Water Act regulations
establishing maximum
contaminant levels (MCLs)
(40 CFR 141.11-141.16)
Federal Resource Conser-
vation and Recovery Act
(RCRA) Groundwater Pro-
tection Standard (40 CFR
Part 264, Subpart F)
Connecticut Water Quality
Standards and Classifica-
tion (22a-426)
REQUIREMENT SYNOPSIS
Establish contaminant
concentration levels
in public drinking water.
They are relevant and
appropriate to the aquifer.
Established for ground-
water monitoring at RCRA-
permitted treatment,
storage and disposal facil-
ities. This standard is
relevant and appropriate
to the aquifer.
Establishes designated
uses for surface water
and groundwater. This is
applicable to aquifer
restoration and to any
discharges to the Norwalk
River and the aquifer.
ACTION TO BE TAKEN
TO ATTAIN ARARS
MCLs for indicator compounds
are the target cleanup levels
for groundwater at the source
area. Attaining the Soil
Cleanup Goals will ensure that
any future migration of resi-
dual contaminants in the soil
will not exceed MCLs in the
source area.
Treatment will be conducted to
achieve RCRA MCLs in ground-
water. Groundwater monitoring
will be conducted in com-
pliance With 264.97, 264.98
and 264.99.
MCLs and public health code
levels will be attained to
restore the aquifer to its
designated use as a drinking
water aquifer and surface
water discharges will meet
NPDES limitations.
-------
ARARS
Standards for Quality
of Public Drinking Hater;
Connecticut Public Health
Code
Federal Clean Water Act
(CWA) 404 (33 U.S.C. 1344,
40 CFR 230)
Table 6 - page
REQUIREMENT SYMQPSIS
Federal Fish and Wildlife
Coordination Act, 16 U.S.C.
661
RCRA Location Standards
(40 CFR 264.18)
Establishes water quality
standards for water sup-
plies. (CT Public Health
Code Regulation 19-13-B102)
This requirement is relevant
and appropriate to the aquifer.
ACTION TO BE TAKEN
TO ATTAIN ARARS
Cleanup of the aquifer will be
conducted in accordance with
these standards.
This requirement is appli-
cable to any dredging or
filling activities in the
wetlands or the river.
This requirement is appli-
cable to any action which
modifies the Norwalk River.
This requirement is appli-
cable if a RCRA facility
is located in the 100 year
floodplain.
If any dredging or filling
action is required in the
wetlands then Section 404 will
be compiled with. The govern-
ing regulations favor practi-
cable alternatives that have
less impact on wetlands. If
no mitigated practicable
alternative exists, impacts
must be mitigated.
If it is determined that the
remedial action potentially
modifies the Norwalk River,
actions will be coordinated
with the U.S. Fish and
Wildlife Service,
It is assumed that remediation
facilities will be located
outside floodplains.
Temporary staging areas or
remediation facilities that
are located by a floodplain
will be designed to allow
quick mobilization out of the
area and to prevent damage
caused by initial floodwaters.
-------
ARARS
Wetlands Executive Order
(E.O. 11990)
Floodplalns Executive Order
(E.O. 11988)
Connecticut Inland Wetlands
and Water Courses Regula-
tions (Title 22a)
Table 6 - page 3
REQUIREMENT SYNOPSIS
Under this Executive Order,
federal agencies are re-
quired to minimize the des-
truction, loss or degrada-
tion of wetlands, and pre-
serve and enhance natural
and beneficial values of
wetlands. If no practi-
cable alternative exists,
impacts must be mitigated..
This is applicable to any
activity in the wetland.
Federal agencies are re-
quired to reduce the risk
of flood loss, to minimize
impact of floods, and to
restore and preserve the
natural and beneficial
value of floodplains.
This is applicable to any
activity in the floodplain.
These requirements are
applicable for alternatives
that affect wetlands.
These requirements limit
activities that deposit
material in, alter, or
pollute inland wetlands
and water courses.
ACTION TO BE TAKEN
TO ATTAIN ARARS
EPA will choose a discharge
method for treated groundwater
that avoids impacts to the
wetlands. If no practicable
alternative exists, impacts to
the wetlands will be miti-
gated.
EPA will choose a discharge
method for treated groundwater
that avoids impacts to the
floodplain. If no practicable
alternative exists, impacts to
the floodplain will be miti-
gated.
These requirements will be met
for any activity in the
wetland at the site.
01
U)
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Table 6 — page 4
ARARS
Connecticut Hazardous Haste
Facility Siting Rules
(Title 22a)
Federal Clean Water Act
(40 CFR 122-125) National
Pollutant Discharge and
Elimination System (NPDES)
Occupational Safety and
Health Act (OSHA) - General
^Industry Standards (29 CFR
1910)
Occupational Safety and
Health Act (OSHA) -
Safety and Health
Standards (29 CFR 1926)
Occupational Safety and
Health Act (OSHA) - Record-
keeping, Reporting and
Related Regulations (29 CFR
1904)
REQUIREMENT SYNOPSIS
This requirement is appli-
cable where more stringent
than Federal Regulations.
These requirements regulate
discharges to surface water
are applicable to treated
groundwater at the site.
This applicable regulation
specifies the 8-hour, time-
weighted average concentra-
tion for various organic
compounds and 2 PCB com-
pounds; site control proce-
dures; training and protec-
tive clothing requirements
for worker protection at
site reinediations.
This applicable regulation
specifies the type of safety
equipment and procedures to
be followed during con-
struction and excavation
activities.
This applicable regulation
outlines the recordkeeping
and reporting requirements
for an employer under OSHA.
ACTION TO BE TAKEN
TO ATTAIN ARARS
These requirements will be met
when siting the treatment
facility.
Water discharges from the
treatment systems will be in
compliance with the Clean
Water Act.
Proper respiratory
equipment will be worn if it
is not possible to maintain
the work atmosphere below
these concentrations.
All appropriate safety equip-
ment will be on site pro-
cedures will be followed dur-
ing groundwater monitoring.
These regulations are appli-
cable to the company con-
tracted to execute site reme-
diation.
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ARARS
Clean Air Act (CAA) -
National Air Quality Stan-
dards for Total Suspended
Particulates (40 CFR
129.105, 750)
Protection of Archaeo-
logical Resources
(32 CFR 229)
Connecticut Air Pollution
Control Regulations
(22a - 17a)
Connecticut Water Diversion
Regulation (22a-365)
Table 6 - page 5
REQUIREMENT SYNOPSIS
This applicable regulation
specifies maximum primary
and secondary 24-hour con-
centrations for particulate
matter.
These regulations develop
procedures for the protec-
tion of archaeological
resources.
These regulations are
applicable during treat-
ment operations.
Diversion of water of the
state will be allowed only
when such diversion is
found to be necessary and
is compatible with the
state's long-range water
resource planning and
management. These regula-
tions are applicable.
ACTION TO BE TAKEN
TO ATTAIN ARARS
Fugitive dust* emissions from
site activities will be main-
tained below 150 ug/m3 (sec-
ondary standard) by water
sprays and other dust
suppressants.
If archaeological resources
are encountered during exca-
vation, these regulations will
be applicable and the area
must be reviewed by federal
and state archaeologists.
Air emission limits from the
the treatment systems will be
in compliance with the
Connecticut Air Quality
Standards.
The groundwater extraction
system will be operated as to
minimize impacts on the well
field and Norwalk River flow
rate. Partial shut down of
extraction wells may be re-
quired during extremely dry
precipitation events.
o
u
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ARARS
Connecticut Discharge
Permit Regulations
Connecticut Hazardous
Waste Rules (22a-449)
(Title 22a-430)
FEDERAL DOT - Rules for
the Transportation of
Hazardous Materials (49
CFR 107, 171.1 - 171.500)
CWA Pretreatment Regula-
tions (40 CFR 403)
Table 6 - page 6
REQUIREMENT SYNOPSIS
These applicable require-
ments supplement the CWA
NPDES permit requirements.
This regulation outlines
requirements for the con-
struction, operation, and
location of a hazardous
waste facility. These
regulations, where more
stringent than federal re-
quirements, are applicable
to the site.
Specific requirements for
markings, vehicle regis-
tration, manifests, and
transportation of hazar-
dous wastes and chemical
substances are applicable.
This applicable regulation
specifies pretreatment
standards for discharges to
publicly-owned treatment
works (POTWs).
ACTION TO BE TAKEN TO
ATTAIN ARARS
Groundwater treated onsite and
discharged to a surface water
will need to comply with the
water quality standards and
complete routine monitoring
and recordkeeping activities.
These requirements will be
complied in constructing and
operating the treatment
systems.
All on- and off-site transport
of excavated soil treatment
sludgesf and other materials
will follow these standards.
If treatment system discharge
is sent to a POTW, the POTH
must have an approved pre-
treatment program and the
discharge must comply with the
POTH program.
in
-------
ARARS
RCRA Facility Standards and
Land Disposal Restrictions
(40 CFR 264)
RCRA General Facility
Requirements (40 CFR
264.10-264.18)
RCRA - Preparedness and
Prevention (40 CFR 264.30-
(40 CFR 264. 30-37)
Table 6 - page 7
REQUIREMENT SYNOPSIS
This regulation is appli-
cable to land disposal of
certain RCRA wastes and of
materials contaminated with
or derived from RCRA wastes.
General facility require-
ments outline general waste
security measures, inspec-
tions, and training require-
ments. These regulations
are applicable.
This regulation outlines
requirements for safety
equipment and spill con-
trol. These requirements
are applicable.
ACTION TO BE TAKEN
TO ATTAIN ARARS
These requirements will be
complied with in disposing of
material on-site and off-site,
Substantive requirements will
be applicable to PTD and vapor
extraction facility. Periodic
analysis of the influent
groundwater and treatment
residues will be conducted in
accordance with 264.13.
Locked facilities, fencing and
the presence of operators
should be in accordance with
264.15. The facility will
undergo regular inspections by
the operators in accordance :
with 264.15. The operators
will, be trained in accordance
with 264.16. Any of the PTp
systems effluent piping near
the river will be designed in
accordance with 264.18.
Substantive requirements will
be applicable to PTD and vapor
extraction facility. The
treatment facilities will be
designed and operated in
accordance with 264.31.
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ARARS
RCRA Contingency Plan
and Emergency Procedures
(40 CFR 264.50 - 264.56)2
RCRA Manifesting, Record-
keeping, and Reporting
(40 CFR 264.70 - 264.77)2
RCRA Container Require-
ments (40 CFR 264,
Subpart I)
Table 6 - page 8
REQUIREMENT SYNOPSIS
This regulation outlines
the requirements for emer-
gency procedures to be
used following explosions,
fires, etc. These require-
ments are applicable.
This regulation specifies
the recordkeeping and re-
porting requirements for
RCRA facilities. These
requirements are applicable.
This regulations sets forth
RCRA requirements for use
and management of con-
tainers at RCRA facilities.
These requirements are
applicable.
ACTION; TO BE TAKEN
TO ATTAIN ARARS
Support equipment in com-
pliance with 264.32 will be
provided for the facilities.
This equipment will be tested
and maintained in accordance
with 264.33. State and local
authorities will be educated
as to th« hazards at the
facilities in accordance with
264.37.
Substantive requirements will
be applicable to PTD and vapor
extraction facility. Contin-
gency plans will be developed
in accordance with 264.50 to
264.55.
Substantive requirements will
be applicable to PTD and vapor
extraction facility. Record-
keeping utilized at the
facilities will be in
accordance with 264.73 and
264.74.
Packing and accumulation of
treatment sludges and other
materials will adhere to
these standards.
00
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ARARS
Table 6 - pace 9
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN
TO ATTAIN ARARS
RCRA - Closure and Post-
Closure (40 CFR 264.111)
RCRA - Tanks (40 CFR
264.190-264.199)
^Connecticut Public Health
Code (19a-36)
These requirements are
relevant and appropriate
to soil cleanup and
groundwater.
This requirement may be
applicable to tanks of
treatment systems.
Provides controls to
restrict groundwater use as
potable water. This re-
quirement is applicable to
the site.
The facilities will be closed
in accordance with the closure
performance standard 264.111.
This requirement will be com-
plied with to the extent that
it is an ARAR which depends on
discharge option implemented.
This requirement will be com-
plied with to restrict private
well use at the site.
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RECORD OF DECISION
KELLOGG-DEERING SITE - OPERABLE UNIT 2
SOURCE CONTROL
APPENDIX A
RESPONSIVENESS SUMMARY
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KELLOGG-DEERING
RESPONSIVENESS SUMMARY
I. INTRODUCTION
This responsiveness summary addresses the comments received by
EPA on the Supplemental Feasibility Study and Proposed Plan for
the Kellogg-Deering Well Field Superfund site in Norwalk,
Connecticut. The comments were received from citizens, the State
of Connecticut and also from a number of potentially responsible
parties (PRPs) during the 30-day comment period held from July
27, 1989, to August 25, 1989.
Written comments were received from ten parties and two people
presented oral comments at the public hearing held in Norwalk on
August 14, 1989. The transcript of the public hearing is
provided as Exhibit B to this Responsiveness Summary. The
comments are summarized and organized by subject. EPA responses
to each comment, or set of like comments, are provided.
As a result of the decision made in this Record of Decision (ROD)
to create a third operable unit to address the Downgradient Area,
EPA did not address the comments that were received pertaining to
the Downgradient Area at this time. At the time a final decision
is made on the remediation, the Downgradient Area comments that
have been received will be more thoroughly responded to.
II. BACKGROUND ON COMMUNITY RELATIONS ACTIVITIES
Community concern and involvement at the Kellogg-Deering Well
Field Superfund site has fluctuated since the Well Field was
first discovered to be contaminated in 1975. Initial concern in
the community was very high, as residents feared they had been
using unsafe drinking water.
Public interest escalated in 1983 when the site was proposed to
the National Priorities List of Superfund sites that are eligible
for federal funding for investigations and cleanups. A local
group of citizens, known as the Waterforce, became active in
monitoring EPA cleanup plans. In 1984, EPA prepared a community
relations plan to assess community concerns and develop
activities to respond to informational and public involvement
needs related to those concerns. Most community concerns related
to possible adverse health effects, the adequacy of the water
supply, the need for more public information on the site, and
concern about the length of time necessary for studies before
cleanup action could be taken. A public meeting was held in July
of 1984 to answer questions from about 60 people who attended the
meeting.
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The community relations plan was updated in June of 1986.
Although citizen concern vac not as intense as it had been when
contamination was first discovered at the Well Field, citizens
interviewed said that having a safe drinking water supply was
still their principal concern. Other issues noted by residents
included concern about the following:
• future constraints on growth caused by water supply
problems;
- possible dangerous emissions from the air stripper
installed to treat the water supply wells;
- potential spread of contamination as a result of the
construction of Route 7 where it passes near the well-
field;
- protection of wetlands on the site;
- monitoring of the quality of the water supply by the
Norwalk First Taxing District; and
- the amount of time spent studying the site.
The community has not been visibly active in raising concerns
about the site since initial questions were responded to in 1984
and the Norwalk First Taxing District began its own well-head
treatment program in 1986 to control the pollution of the water
supply wells. The community has, however, expressed an interest
in being informed of activities at the site and the schedule for
decisions to be made to advance site cleanup.
To keep the public informed and involved in decision points in
the Superfund process, EPA has held numerous public meetings and
issued written material and press releases to the Norwalk
community. A complete chronology of community relations
activities conducted by EPA is attached as Exhibit A of this
Responsiveness Summary document. After EPA mailed a fact sheet
and held public meetings to explain the first of two remedial
investigations and EPA's options for a well-head treatment
system, EPA invited public comment. During the public comment
period conducted in 1986, EPA received one citizen comment and
several comments from potentially responsible parties at a public
hearing and in writing. A Record of Decision to improve the
existing well-head treatment system was approved in September
1986 as the first step in the cleanup of the Xellogg-Deering
site.
There has been little or no community action relative to EPA
activities since the 1986 Record of Decision was signed. In
January 1988 EPA released a fact sheet on the results of a study
to determine the sources of groundwater contamination. In July
1989 EPA mailed a proposal, the Proposed Plan, to address the
sources of contamination to interested and affected individuals.
The release of the Proposed Plan was followed by a public
informational meeting and a public hearing on the proposal.
Approximately 30 people attended the meeting and the hearing.
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The comments received from citizens, local officials, the state
of Connecticut, and potentially responsible parties are
summarized and responded to in the following sections of this
document. A transcript of comments made at the public hearing
held August 14, 1989, is attached as Exhibit B of this
Responsiveness Summary.
III. SUMMARY OF COMMENTS AND EPA RESPONSES
A. SUMMARY OF COMMENTS FROM PRPs
Provided below are comments from parties that EPA considers to be
potentially responsible parties (PRPs) for the site, and EPA's
responses to those comments. The comments were provided by three
PRPs: Electric Indicator Company, Inc. (Elinco), EDO Corporation
and Pitney Bowes.
Beveridge & Diamond and Versar commented on behalf of Elinco;
Sidley & Austin and Goldberg, Zoino & Associates (GZA) commented
on behalf of EDO Corporation; and Murtha, Cullina, Richter and
Pinney, and Dames & Moore commented on behalf of Pitney Bowes.
All PRP commentors asked for an extension to the public comment
period, however none was granted by EPA.
Complex as a Source of Contamination
1. Comment: The remedial investigation and feasibility study
(RI/FS) fails to demonstrate that the Elinco/Pitney
Bowes/Mathies Complex (the Complex) is a major source of
Well Field and aquifer contamination, basing its conclusion
on general qualitative, not quantitative, analysis. The
bedrock between the Complex and the Well Field has been
treated as a "black box" accounting for TCE migration,
without showing actual transport mechanisms.
The RI/FS found fractured bedrock to be the major migration
pathway from the Complex to the northwest, west, and
southwest, while explicitly acknowledging that bedrock
fractures at Kellogg-Deering are tight and widely spaced,
and that contaminant flow is therefore difficult to trace.
Further, the RI/FS has failed to identify major bedrock
fractures that can be shown to be carrying contaminants
outward from the Complex, and instead relies on regional
fracture orientation for this purpose. It is technically
just as plausible that the contaminants in the fracture came
from other sources located in different directions and at
different distances from that fracture zone.
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EPA Response: Groundwater data obtained by EPA indicates
that the Complex is a significant source of contamination.
Sampling and analysis demonstrated that a plume of
contamination is emanating away from the Complex in a semi-
radial pattern from the northwest to southwest. Moreover,
this testing indicates that contaminant movement occurs
initially in the bedrock and then in both the overburden and
bedrock aquifers. The southwest extent of the plume is
migrating below the Norwalk River and intersects the
Kellogg-Deering Well Field. The west and northwest edge of
the plume extends to the Deering Pond and the Norwalk River.
Both of EPA1s field investigations, documented in the
initial and supplemental remedial investigation reports,
show that groundwater contaminants are moving through the
unconsolidated overburden aquifer at the Complex and through
deep and shallow fractures of the bedrock aquifer to the
sand and gravel aquifer that supplies the wells of the
Kellogg-Deering Well Field. Some of the contamination has
entered bedrock fractures immediately below the buildings at
the Complex. Contaminants discharge from the bedrock into
the overburden aquifer in the vicinity of the Norwalk River
and the CL&P Landfill. While the actual location of every
fracture containing contaminated groundwater is uncertain
and other sources of contamination may be present, EPA
believes that a "piping system11 of bedrock fractures from
the Complex allows contamination to migrate toward the
Kellogg-Deering water supply wells and the data clearly
indicates that the Complex is a major source of
contamination.
2. Comment: Pitney Bowes indicated that they do not store,
use, or dispose of significant quantities of TCE in the Zell
Building Complex, and did not have TCE on-site until 1983-
84. Their entire inventory of TCE since occupying the
building has totaled 55 gallons; one gallon purchased in
1983, and 55 gallons purchased in 1984.
EPA Response: These comments relate to enforcement issues
that are not the subject of this ROD. In this Responsiveness
Summary, EPA must address significant comments relateing to
the selected remedy. Comments on enforcement issues need
not be responded to in this Responsiveness Summary and con
be dealt with during negotioations.
3. Comments Pitney Bowes provided a number of comments
indicating that Elinco is the source of the TCE
contamination found at the Complex.
EPA Response: These comments, like the previous one, relate
to enforcement issues that are not the subject of this ROD.
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Comments on enforcement issues are not the subject of this
Responsiveness Summary.
Groundwater Contamination
4. Conaents The RI/FS does not actually identify a pathway to
the wells west of the Norwalk River, but merely hypothesizes
one by assuming unidentified localized open fractures.
Until a link is proven, PRPs cannot be liable for Well Field
contamination, given several precedents.
EPA Response: Determining if a given party is liable for
the contamination of the Kellogg-Deering Well Field is not
the subject of this Record of Decision, which focuses on the
selection of a remedy for the site. However, as indicated
in EPA's response to Comment #1 above, sampling and analysis
show that contaminants move through both the overburden and
bedrock aquifers from the Complex toward the Well Field.
5. Comment: The RI/FS incorrectly uses the greatest value for
hydraulic conductivity from tests. The number used is both
incorrectly calculated and is not representative of
hydraulic conductivity throughout the study area bedrock.
Similarly, the RI/FS used stratified drift hydraulic
conductivity measurements from the Well Field and applied
those throughout the study area, although hydraulic
conductivity for stratified drift varies considerably
throughout the study area. Both approaches are technically
inappropriate.
An alternative model of hydraulic conductivity shows that
any contaminant release from the Complex on the dates
alleged in the RI/FS would not yet have arrived at the Well
Field or at other areas of high contaminant concentration in
the aquifer beyond the immediate vicinity of the Complex.
This model is supported by EPA's tracer studies, which could
detect no tracer salts downgradient from the Complex in the
short term, and in only one instance in the long term. The
one positive sample suffered from three technical
difficulties that make it an improper basis for establishing
a migration pathway.
EPA Response: EPA recognizes that hydraulic conductivity
may vary with the different lithology in the aquifer;
however, the values EPA used and how they were applied were
not inappropriate. EPA utilized the average transmissivity
and hydraulic conductivity values for the stratified drift
deposits and the geometric mean for the conductivity in the
bedrock aquifer. For bedrock flow, a high value was used to
illustrate the potential transport capabilities of the rock
mass.
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The model EPA utilized is appropriate for this situation.
Although an alternative model that uses a lower hydraulic
conductivity value nay show that contamination from the
Complex could not have reached the Well Field, this is not
supported by extensive sampling and analysis that shows that
contaminants (primarily TCE), are move through both the
'overburden and bedrock aquifers toward the Well Field.
Moreover, the alternative model presented ignores highly
permeable bedrock fractures that could serve as a major
route for contaminant flow to the Well Field.
The alternative model, presented by the PRPs, which predicts
maximum travel distances of 125 meters for contaminants
discharged at the site for over 40 years, relies on
assumptions and input values that EPA believes are not
valid. The model describes the glacial deposits in the area
adjacent to and down-gradient of the source area as till
that have very low hydraulic conductivities, when in fact
they are stratified glacial drift deposits with much higher
hydraulic conductivities than tills. Also, the hydraulic
conductivity value used (0.35 ft/day) was incorrectly
calculated from an aquifer test (the "K-19A slug test1*).
The correct value, 144 ft/day, results in contaminant flow
rates that are about 250 times greater than predicted by the
alternative model.
Although it may be difficult to draw definite conclusions
from the tracer study conducted by EPA, the alternative
model presented is not necessarily supported by the study.
EPA believes the tracer study illustrated the complexity of
groundwater flow at the site, but did not demonstrate
definitively whether or not the Complex is a source of the
contamination found at the Well Field. Additionally, EPA
did not rely on a single reading from the tracer study to
conclude that there is a hydrogeologic link between the
contamination found at the Complex and at the Well Field.
The tracer study was only one part of a very extensive
investigation conducted by EPA to define the nature and
extent of contamination found at the site. In addition to
the tracer work, the lithology of the aquifer was studied,
and extensive sampling and analysis was conducted that
showed that contaminants move through both the overburden
and bedrock aquifers toward the Well Field. In fact, the
distribution of TCE in the groundwater was the "tracer" that
EPA used to conclude that the Complex is a source of
contamination for the Well Field.
Commentt The RI/FS concludes that the migration pathway is
demonstrated by a general increase in TCE concentrations in
five bedrock wells as one moves from the Well Field toward
the Complex. However, the conclusion rests on an inadequate
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data base, and in fact suggests that the contaminant flow is
both more complex than suggested in the RI/FS, and may point
to other contamination sources.
EPA Response: EPA concurs with the comment that groundwater
flow and contaminant transport at the site are very complex
due to the interaction of the overburden and fractured
bedrock aquifers and does not dispute that there may be
other sources that contribute to contamination in the
aquifer and at the Well Field. However, the data base that
EPA utilized to determine that the Complex is a significant
source of contamination and that this is affecting the Well
Field water quality is adequate. Analytical data collected
from monitoring wells in and around the Complex show the
highest concentrations of contamination. This data, as well
as groundwater level measurements throughout the area,
clearly show that the Complex is a major source of
contamination and that that contamination is flowing from
the Complex toward the Well Field.
7. Comment: The areal extent of the source area groundwater
remediation is too large. The source area is defined as
that area with TCE concentrations greater than 6,600 ppb
because that is the maximum level EPA deemed the Well Field
air stripper could safely treat. However, the air stripper
can easily be modified to treat higher concentrations,
making possible the use of TCE concentrations above 6,600
ppb as a source area boundary. If EPA's definition of the
source area is based on health risks to Well Field users,
the only receptors, given admittedly effective institutional
controls, those risks are better and more cost-effectively
addressed by modifications to the air stripper at the Well
Field than by groundwater treatment at the source area. This
is true because 1) air stripping at Well Fields is a tried,
effective, and readily implementable remedial action, 2) the
Well Field air stripper can be modified easily and at low
cost, and 3} the effectiveness of air stripping at the
source area as proposed in the RI/FS is highly uncertain at
best given the recognized difficulty of treating groundwater
in bedrock fractures.
Even if the 6,600 ppb delineation is judged appropriate, the
area designated in RI/FS is too large, as it includes many
monitoring wells that do not show TCE concentrations above
6,600 ppb. In particular, although EPA's mobile lab found a
TCE concentration of 37,840 ppb in a sample from the K-8
monitoring well 250 feet southwest of the Complex, a second
sample taken at the same time and analyzed using more
accurate contract laboratory procedures measured only 4,700
ppb. Thus, it is inappropriate to extend groundwater
treatment beyond the immediate vicinity of the complex.
8
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XPA Response: The Source Area groundwater extraction and
treatment system will be developed to attain ARARs (e.g.,
MCLs) in the aquifer. The area is defined by the 6,600 ug/1
TCE contour line as shown in the supplemental RI/FS. The
areal extent of this system will be refined as part of the
pre-design activities to maximize contaminant removal rates
and to pinpoint the location and number of extraction wells.
In any event, there will be two sets of extraction well
networks to be installed: one within the Complex boundaries
and one near the railroad tracks to the west of the Complex.
8. Commentt EPA states without explanation that 80 percent of
the soluble contaminants originating at the Complex have
already migrated beyond the property line. That statement
is without apparent basis, in light of the much higher
levels of TCE measured in monitoring wells at the Complex as
compared to those in the downgradient portion of the source
area.
ZFA Response: Although the highest concentrations of TCE
and PCE are found at the Complex, most of the contamination
is found outside of the its boundaries at lower concentra-
tions, but still exceeding MCLs, in the huge volume of
groundwater in the surrounding aquifer. Because a
significant portion of the contamination has moved from the
complex, the pumping and treatment of the aquifer is
necessary to achieve the cleanup goals.
9. Commentt Based on a computer model of contaminant
transport, the cleanup goal for the source area bedrock
aquifer should be 160 ppb. As a result of dispersion and
assuming no retardation, a TCE concentration of approxi-
mately 160 ppb at the Complex would be reduced to 25 ppb at
the Norwalk River. Then, assuming 80% dilution of the
groundwater by clean water from the Horwalk River
(reasonable and similar to the dilution factor used by NUS),
the contaminant concentration would be lowered to 5 ppb, the
MCL for TCE.
EPA Response: The cleanup is based on achieving MCLs and
state ARARs throughout the aquifer and not only at the Well
Field. With MCLs and state ARARs as the goal, the effect of
dilution on the contaminant concentrations is not relevant
to the aquifer cleanup levels. In addition, RCRA
regulations on closure require that the soils be
decontaminated so as not to result in unacceptable
groundwater contamination.
10~ comment: Their appears to be some inconsistencies in the
calculated dilution of water at the Well Field by the
Norwalk River and in the assumptions that EPA presented in
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the RI/FS about this. EPA has not used the lowest
assumptions in deriving its future (plausible case)
scenario. Neither future scenario depicts the true risks
posed by the site and thus basing the need for further
remedial action on either future scenario is unwarranted.
EPA Response: Dilution of the Well Field by the river is
dependant on seasonal changes and the amount of pumping and
types of wells being used. Although dilution of
contaminated groundvater due to recharge from the river will
reduce contaminant levels, if the treatment system at the
Kellogg-Deering Well Field were not in use through
mechanical failure or otherwise, the contaminants in the
aquifer could pose a risk to human health. In addition, the
cleanup must attain legally applicable or relevant and
appropriate requirements set by state and federal laws,
including MCLs set under the federal Safe Drinking Water
Act.
11. Comment: In Section 12 of the RI/FS, EPA makes assumptions
about how each remedy will reduce the toxicity, mobility, or
volume of TCE. These assumptions, however, are not
supported by earlier statements in the RI/FS about the
nature and extent of contamination.
For example, on p. 176, the RI/FS states: "of the total
quantity of contaminated groundwater, 15% is in the bedrock
and 85% is in the overburden." This statement contradicts
the statement on page 147: "although contamination has been
detected in both overburden and bedrock monitoring wells, it
is apparent from the distribution of contamination that
migration in the bedrock groundwater regime is the primary
contaminant migration pathway."
With such internally contradictory remarks, there is no way
to adequately determine if EPA's preferred alternative is
justified. The effectiveness of each remedial alternative
will obviously be affected by the assumptions made
concerning the nature and extent of contamination. Since
EPA's preferred alternative relies on assumptions
contradicted elsewhere in the RI/FS, there is no rational
basis for the alternative.
EPA Response: There is no contradiction in the remarks that
are quoted, in fact the two statements deal with different
topics. One addresses the distribution of contamination, a
majority of which is found in the overburden, and the other
deals with contaminant transport, which occurs primarily in
the bedrock.
EPA's cleanup plan for the site is justified and is based on
a careful evaluation as outlined in the ROD. That
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•valuation includes a complete analysis of how the cleanup
satisfies the statutory and regulatory criteria for
selecting remedial actions under CERCLA.
12. Consents The preferred alternative assumes that no dense
non-aqueous phase liquid (DNAPL or "free product") TCE
exists in the groundwater beneath the Complex, but the RZ/FS
concludes that some DNAPL TCE must exist there. Because it
may continue to release aqueous TCE, the presence of DNAPL
TCE .may prevent the preferred alternative from accomplishing
its 'objective, possibly to the point where TCE levels do not
decrease. Thus, a remediation plan such as the preferred
alternative that does not address specific removal of "free
product" from the bedrock aquifer will be no better than
continuing the current treatment of groundwater by NFTD.
BPA Response! The remedy includes pre-design work to refine
the understanding of the nature and extent of contamination.
If free product, or DNAPL, is found, the design of the
groundwater treatment system will take this into account.
Additionally, even if free product is found, the cleanup
goals for the remedy will not change.
13. Comment: The RI/FS notes that because of complex
hydrogeology and potential presence of DNAPL TCE, no
estimates can be made for the natural flushing of the source
area, which directly contradicts the logic of the preferred
alternative.
EPA Response: Recognizing the real limitations of the
understanding of the hydrogeology and distribution of
contaminants does not contradict the logic of the cleanup
plan. The remedy is an aggressive plan to cleanup a
contaminated aquifer. Its design will take into account the
complexity and uncertainties of the situation, including
contaminant distribution and the site's hydrogeology. As
stated in the ROD, the estimated time for remediation may
exceed 10 years.
14. Comments Given the area's complex hydrogeology, it is not
known, and is not reasonable to assume, that the 250 ft.
deep pumping wells will be in contact with the same bedrock
aquifer now being monitored. Further, without knowing where
the DNAPL TCE exists, the deep wells could introduce TCE to
greater depths and/or other aquifers. Even if the deep wells
were to contact the aquifer now being monitored, it is not
known whether they will be able to extract DNAPL TCE. In
short, pumpinj and treating the bedrock aquifer will not be
effective using existing geologic information.
EPA Responses As responded to earlier, the remedy includes
pre-design work to refine the understanding of the hydro-
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geology and the nature and extent of contamination. If free
product, or DNAPL, is found, the design of the groundvater
treatment system will take this into account. Additionally,
wells will be installed in a manner to ensure that
contamination is not introduced from the overburden into
bedrock.
Other Potential Sources of Contamination
15. Comment: EPA has failed to investigate adequately other
potential source areas of Well Field and aquifer
contamination. EPA investigated only two other potential
contaminant sources in the study area, although provided
with extensive information regarding both other industries
that have used large amounts of solvents, and solvent spills
and discharges, and provided with specific suggestions for
alternate source investigations. The Agency should
thoroughly evaluate those potential sources of contamination
or, provide an explanation of its decision not to.
EPA data supports the possibility that other sources may be
responsible for contamination. For example, the lack of TCE
in bedrock monitoring well K-22B coupled with the elevated
TCE concentrations in well K-21, located downgradient of
well K-22b, suggests a contamination source other than the
Complex.
EPA Response: EPA does not dispute that there may be other
sources that contribute to contamination of the aquifer and
the Well Field; however, the Complex is a significant source
of contamination that requires remediation. Sampling and
analysis shows that a plume is emanating away from the
Complex in a semi-radial pattern from the northwest to
southwest. Moreover, this testing indicates that
contaminants move in both the overburden and bedrock
aquifers to the Well Field. Extensive sampling of over 120
wells and borings at the site , as well as work done by the
Connecticut Department of Environmental Protection have
failed to identify other sources of contamination.
Two other potential sources of contamination (Wesco and a
Shell gas station) were evaluated by EPA in the supplemental
RI because they are identified in the 1986 RI as potential
sources of contamination. They were, however, found not to
be TCE or PCE contaminant sources after further analysis.
EPA may consider whether to evaluate other potential sources
of contamination.
The lack of TCE at well K-22B does not necessarily indicate
that a source other than the Complex is responsible for
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contamination in down-gradient locations. Because of the
fracture orientation in the bedrock, some wells in up-
gradient locations may be free of contamination while other
nearby wells could be highly contaminated.
Risk Assessment
16. Commentt EPA's risk calculation for workers at the Complex
is overly conservative because 1) it does not take into
account worker movement, but rather assumes that workers
stay directly above contaminated areas all day; 2) it
assumes a 40-year working period, 3) it overestimates
inhalation rates, and 4) it does not address likely changes
in contaminant concentration with the seasons. Further, the
risk assessment does not consider the possibility that
measurements were influenced by contaminated surfaces near
former operational areas, rather than soil gas; nor does it
take into account the possible use of TCE in certain of the
buildings during sampling of building air.
EVA Response: EPA's risk calculation is meant to be
conservative to ensure protection of human health. It
assumes that workers could be exposed to contamination eight
hours per day over forty years.
Although other sources of contamination could contribute to
the air pollution problem found, given the concentration of
TCE and PCE found in the Complex area, contaminant transport
from the soil to the building air is significant.
17. Comment: Soil remediation is not necessary under the three
buildings at the Complex, as they already meet Occupational
Safety and Health Administration (OSHA) Permissible Exposure
Limits (PELs) for PCE and TCE. PELs are the correct
enforceable standard, not EPA's target excess cancer risk
range, which should be used only when a standard such as
OSHA's does not exist.
EPA Response: Soil remediation is necessary for three
reasons: First, contamination in soil contributes to
groundwater contamination that exceeds Maximum Contaminant
Levels (MCLs), EPA's cleanup goal for groundwater. Second,
although the levels of contaminants measured were within the
standards set for industrial safety by the Federal
Occupational Safety and Health Administration, the risks
from exposure to these levels (4x10 ) exceeds EPA's
Superfund target risk range of 10 to 10 , using a
reasonable worst-case scenario. Third, the Resource,
Conservation and Recovery Act (RCRA) closure regulations,
which are relevant and appropriate to the site, require that
soil be cleaned so that contaminated leachate is not
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generated that could result in unacceptable groundwater
quality.
18. Comment: Should remediation to meet EPA standards be
necessary, sealing the Complex building's floors and related
measures would be a more reliable and cost effective
remediation method.
EPA Response: EPA does not dispute that sealing floors and
other similar actions could address the inhalation risks
posed in the buildings; however, this would not address the
contribution that the contaminated soil has to pollution in
groundwater and this would not attain RCRA closure
requirements/ an ARAR at the site.
19. Comment: Concerns about future human contact with
contaminated soil through building demolition and soil
disturbance can be met with institutional controls, such as
have been successfully used elsewhere, and by means of an
analysis of the need for soil remediation measures at the
time a change in use of the Complex property dictates that
such an analysis is needed.
EPA Response: CERCLA requires EPA to select permanent
remedies that employ treatment to reduce the mobility,
toxicity or volume of the contamination (if such a remedy is
practicable), over remedies that rely on non-treatment based
mechanisms such as institutional controls and containment.
Additionally, EPA must assure that the remedy provides long-
term protectiveness. If soils are not remediated, the
groundwater cleanup goal of achieving MCLs would not be met
and, also,: given the potential failure of institutional
controls, institutional controls alone would not provide for
adequate protectiveness.
20. Comment: The risk assessment used to determine goals for
soil remediation alternatives is seriously flawed. The
baseline risk assessment concentrates on the risk that
contaminants in the soil serve as a continuing source for
contamination of groundwater. The risk assessment therefore
estimates that amount of TCE and PCE that may remain in the
soils without resulting in TCE and PCE groundwater
contamination above 5 ppb. The assessment assumes that all
buildings and asphalt are removed from the property.
First, the use of MCLs for TCE to determine groundwater
cleanup levels is inappropriate, since the MCL is not itself
an ARAR for groundwater at Kellogg-Deering, as detailed
elsewhere. Similarly, the 5 ppb groundwater cleanup level
set for PCE is inappropriate for setting soil cleanup
levels, as the PCE groundwater goal set by EPA is not an
ARAR, nor does it appear to be based on any meaningful
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assessment of PCE's threat to human health or the
environment.
Second, the assumption that soil contamination should not be
permitted to contaminate groundwater at levels above 5 ppb
of TCE and PCE is unreasonable in light of two other Agency
findings. EPA has agreed that institutional controls will
prevent exposure to, and therefore risk from, contaminated
groundwater. Moreover, even in the absence of such
controls, the Agency has admitted that it is extremely
unlikely that the aquifer can be cleaned up to referenced
levels.
Third, EPA1s assumption that the Complex has been stripped
is unreasonable, given current capping and EPA's ability to
use institutional controls to limit infiltration should the
use of Complex property change.
EPA Response: The risk assessment that EPA utilized was not
flawed. The assumptions used ensure that a protective
remedy will result. Additionally, the risk assessment was
not the only tool that EPA utilized to set the soil cleanup
goals. In addition to mitigating the risks posed by the
contamination in the aquifer, Section 121(d) of CERCLA
requires that the remedial action attain legally applicable
or relevant and appropriate requirements set by state and
federal laws. At Kellogg-Deering, EPA has determined that
MCLs are relevant and appropriate throughout the aquifer.
Further, EPA has determined that restoration of the
groundwater is required to achieve them.
The cleanup levels were also set to ensure that leachate
generated by water percolating through the contaminated soil
would not result in unacceptable groundwater contamination
(i.e., MCLs), and to meet the RCRA closure requirements.
If the present Well Field treatment system were not in use,
the chemical contaminants in the aquifer could pose a risk
to human beings. . Human beings could be exposed to site
contamination by drinking the water, skin contact or
inhalation of contaminants while showering if there were no
treatment system at the Well Field or if drinking water
wells were installed in the area of groundwater
contamination.
As responded to earlier, the MCL for TCE is a relevant and
appropriate standard in groundwater and is the goal of the
remedy. Although PCE does not have a MCL, 5 ppb is an
appropriate cleanup level. This level was selected to be
protective and because PCE has chemical, physical and
toxicological properties that are similar to TCE.
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Contrary to the statement in the comment, EPA has not
admitted that the cleanup goals for TCE and PCE can not be
met. The remedy, utilizing soil and groundwater treatment,
is an aggressive cleanup that can achieve these goals.
Institutional controls would not attain ARARs and are
therefore not an acceptable remedy for the site. Also,
'given the potential failure of institutional controls,.
institutional controls alone would not provide for adequate
protectiveness.
Contamination in Soil
21. Comment: The contaminants in the groundwater, soil, and
soil gas under the Complex are in equilibrium. Hence, a
portion of the contamination detected in the soil gas is a
result of off-gassing from the contaminated groundwater and
does not reflect contamination from a soil source. EPA does
not determine the extent to which soil gas reflects primary
contamination above the water table, rather than secondary
contamination caused by off-gassing from contaminated
groundwater. In other words, soil contamination at the
Complex is likely, to a large extent, to be a lingering
residual effect rather than a continuing cause of
groundwater contamination. . .
Because of the potential for this groundwater off-gassing
effect, soil cleanup may not be effective until groundwater
remediation at the Complex has been largely completed.
Otherwise, the soils could be continually recontaminated.
Although EPA recognizes this in the Supplemental RI/FS, it
nevertheless uncritically concludes, erroneously, that the
short-term effectiveness of in situ vacuum extraction at the
Complex is high.
EPA Response: EPA concurs that the contamination found in
the soil, soil gas and groundwater is in equilibrium;
however, the chemicals in the soil at the Complex are a
continuing source of contamination to groundwater. The
concentrations of TCE and PCE measured in the soil gas study
were greater than could be caused by off-gassing from the
groundwater. The release of very concentrated spent
solvents from the ground surface into the soil accounts for
the observed levels.
The remediation of the aquifer at Kellogg-Deering requires
both the vacuum extraction of soil and pump-and-treatment
for groundwater to.be effective. This two-component source
control remedy will remove contamination from the highly
contaminated soils at the Complex and in the groundwater
flowing from that area, and will result in the rapid
remediation of the aquifer. The operation of the remedy
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will take into account the potential of re-contamination by
off-gassing. The pumping and treatment of groundvater and
vacuum extraction of the contaminated soil will be sequenced
to prevent contamination from moving from the groundvater
back to clean soil.
22. Comments Under current site conditions, the amount of TCE
contamination in the soil is relatively small and immobile
in comparison to the amount of TCE contamination in the
groundvater. Moreover, only a small percentage of the
contamination in the soil beneath the Complex buildings is
likely to enter the groundvater. A large portion of the
area is covered by buildings and asphalt parking lots vhich
prevent precipitation from filtering into the ground and
entraining contaminants into the groundvater. The only
contaminated soil that vould release contaminants into the
groundvater is that small volume of soil flushed by the
groundvater through seasonal fluctuations in the vater
table.
Any soil contaminants released into the groundvater vill be
intercepted and treated by the source area groundvater
treatment system. Thus, any contaminants in the soil vill
not migrate off-site and vill not adversely affect human
health or the environment. Therefore, collecting and
treating groundvater at the Complex vill intercept any soil
contamination entrained into the groundvater and vill
effectively reduce the majority of the mobile contamination
at the Complex. Eventually, the flushing of the soil
contaminants by the fluctuating vater table should
substantially cleanse the soil and minimize any remaining
soil source. Although failure to treat the soil nov may
result in the need for a longer groundvater pump and treat
period at the source area, the additional operation and
maintenance operations are less costly, and equally
effective, as the soil treatment proposed by EPA.
EPA Response: The concentrations and amount of TCE found in
the soil is significant and acts as a continuing source of
groundvater contamination. To achieve MCLs in the aquifer,
a combination of contaminated soil remediation and
groundvater treatment vill be needed. Although the source
area groundvater treatment system vill intercept some of the
contamination released from the soil, vithout the soil
remediation component of the remedy, the soil vill act as a
continuing source of contamination and vill result in
unacceptable aquifer restoration times. Additionally, the
RCRA closure requirements for tie soil vill not be met by
groundvater treatment alone.
Although the paved parking lots at the Complex may reduce
some of the rainwater that infiltrates into the soil,
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relying on this as part of the remedy is unacceptable. Some
significant amount of water still washes through the soil
and there is no long-term way to ensure that the parking
lots will remain in-place and that institutional controls
will be complied with.
23. Comment: Because of questions regarding the integrity of
analytical data for 17 soil samples, analyzed in a mobile
laboratory, EPA should reevaluate the conclusions in the
RI/FS based on those 17 samples.
EPA Response: EPA has re-evaluated how the samples were
used in the RI/FS and determined that they do not affect the
conclusions that the Agency reached regarding the nature and
extent of contamination or have any bearing on the
evaluation and selection of the remedy. Besides these
samples, EPA relied on validated, accurate data from
hundreds of samples collected at the site since work began
in 1984.
Applicable or Relevant and Appropriate Requirements fARARs)
24. Comment: EPA has misidentified and misapplied ARARs for
soils at the Complex. It is unclear from the preferred
remedy exactly what cleanup criteria EPA seeks to impose at
the Complex, as the Supplemental RI/FS sets forth different
numbers in different places. For example, soil cleanup
goals for TCE are stated to be between 12 and 358 ppb in the
text, but are identified variously as 6.5 ppb and between
6.9 and 151 ppb in the design calculation appendix. It is
clear, however, that whatever numbers EPA is using, it
considers them to be driven by RCRA closure standards, which
the Agency identifies as an action-specific ARAR for soils,
although "applicable" or ''relevant and appropriate" is
unclear.
RCRA closure standards are clearly not applicable if, as in
this case, a RCRA hazardous waste is not newly placed at a
site after the effective date of the closure standards.
Moreover, the RCRA closure standards do not require
treatment or removal of wastes to comply with closure
requirements. Instead, waste can be left in place, provided
that post-closure groundwater monitoring of the type
proposed by EPA for this site occurs.
EPA Response: The soil cleanup levels were developed using
a soil/water sorption coefficient which describes the
distribution of chemicals between soil and groundwater.
They were set in order to reduce the potential future risk
to public health and the environment and to protect ground-
water by reducing contamination levels to the point where
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they no longer contribute to groundvater contamination above
MCLs. The ranges are given because the soil types differ
within the area of soil contamination. The particular type
of soil and amount of organic carbon present in the soils
attenuate contaminant migration and result in the different
cleanup goals provided.
The closure standard cited above refers to landfill closure
and not to the closure standards which EPA utilized. EPA
has determined that portions of the RCRA regulations on
closure that require decontamination of soils are relevant
and appropriate for the site (40 CFR 264.110 - 264.120).
EPA determined that the release of hazardous substances at
the site was similar to releases regulated by RCRA and
because of this, closure performance standards under RCRA
are both relevant and appropriate for the cleanup.
25. Commentt EPA has misidentified and misapplied applicable or
relevant and appropriate requirements for source area
groundwater remediation. The Agency wrongly relies on
inappropriate cleanup standards, given that there is
virtually no risk-based justification for source area
remediation. -
SDWA's MCLs are inappropriate as ARARs given CERCLA's
Section 121(d) requirement that cleanup criteria selection
must consider the "circumstances of the release,11 the
characteristics of the remedial action, the physical
circumstances of the site, the type of place regulated, and
the objective and origin of the requirement. Judged by these
criteria, MCLs are not relevant and appropriate requirements
for restoration of the study area aquifer.
EPA Response: It is within EPA's authority to determine
ARARs at the site and to determine cleanup levels necessary
to attain those ARARs. With respect to achieving drinking
water standards in the aquifer, EPA states in 40 CFR Part
300, National Oil and Hazardous Substances Pollution
Contingency Plan; Proposed Rule (Fed. Reg. 53:51394-51520,
December 21, 1988) that "it has been the policy of EPA's
Superfund program for several years to operate within the
framework of EPA's Groundwater Protection Strategy in
determining the appropriate remediation for contaminated
groundwater at CERCLA sites". The water supply wells are
located in an aquifer that is classified as XI-A under the
EPA Ground Water Protection Strategy. This classification
means that the groundwater is currently and potentially a
source of drinking water and other beneficial uses. EPA
states further that, "for groundwater that is or may be used
for drinking water (Class I or II), the maximum contaminant
levels (MCLs) set under the Safe Drinking Water Act or more
stringent promulgated State standards are generally
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applicable or relevant and appropriate standards" (ARARs).
The aquifer at Kellogg-Deering is a valuable resource both
under EPA's Guidelines for Ground-Water Classification and
under the State classification for groundwater, which
classifies the aquifer as Class GAA at the Well Field — the
State's most stringent classification for groundwater
protection — and GB/GA in other portions of the aquifer at
the site, which indicates that although the groundwater
presently may not be suitable for direct human consumption
without treatment due to chemical contaminants or land use
impacts, the State maintains a goal to restore the
groundvater to drinking water quality. Given these factors,
EPA has determined that MCLs are relevant and appropriate to
aquifer remediation at the site.
There are six limited circumstances where ARARs may be
waived Under CERCLA § 121(d)(4). These are:
i) the remedial action selected is only part of a
total remedial action that will attain such level or
standard of control when completed;
ii) compliance with such requirement at that facility
will result in greater risk to human health and the
environment than alternative options;
iii) compliance with such requirements is technically
impracticable from an engineering perspective;
iv) the remedial action selected will attain a
standard of performance that is equivalent to that
required under the otherwise applicable standard,
requirement, criteria, or limitation, through use of
another method or approach;
v) with respect to a State standard, requirement,
criteria, or limitation, the State has not consistently
applied (or demonstrated the intention to consistently
apply) the standard, requirement, criteria, or
limitation in similar circumstances at other remedial
actions within the State; or
vi) in the case of a remedial action to be undertaken
solely under section 104 using the Fund, selection of a
remedial action that attains such level or standard of
control will not provide a balance between the need for
protection of public health and welfare and the
environment at the facility under consideration, and
the availability of amounts from the Fund to respond to
other sites which present or may present a threat to
public health or welfare or the environment, taking
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into consideration the relative immediacy of such
threats.
None of these six conditions apply at the Kellogg-Deering
Well Field Superfund site. Thus, EPA is justified in
setting action levels that will result in the attainment of
MCLs in the aquifer throughout the site.
26. Comment* If EPA does treat MCLs as relevant and appropriate
requirements, it should waive the requirement that they be
met pursuant to CERCLA Section 121(d)(4), as complete
restoration to health-based levels is not feasible here
where EPA has determined that contaminants have migrated
into fractured bedrock with low transmissivity. EPA
recently waived groundwater ARARs in the Sullivan's Ledge
Record of Decision (ROD) because there, as here,
contamination was located in difficult-to-locate bedrock
fractures. An EPA decision not to waive groundwater ARARs
in this instance would be arbitrary and capricious, given
the dictates of its own guidance and the factual similarity
with bedrock contamination at Sullivan's Ledge.
EPA Response: EPA is aware of the difficulty in predicting \
the performance of the groundwater remedies, especially for
sites that have complicated hydrogeology and contamination
transport mechanisms. However, EPA will not waive MCLs in
this ROD because the statutory criteria for a waiver of
ARARs, as set forth in EPA's response to the preceding
question, has not been met.
Although EPA waived some requirements for groundwater
cleanup at Sullivan's Ledge, the aquifer at that site is not
a drinking water supply source like Kellogg-Deering and a
number of different site conditions exist.
27. Comment! EPA misapplies the RCRA groundwater protection
standards as relevant and appropriate for the Kellogg-
Deering site. The RCRA standards require compliance at the
edge of a discrete waste management area for containment and
early detection reasons that do not apply to a Superfund
site where contamination has already spread beyond a source
boundary.
EPA Responses EPA did not misapply the RCRA groundwater
protection standards. Although the remedy was developed to
meet the closure requirements of 40 CFR 264.111 and attain
MCLs and state ARARs in the aquifer, EPA also determined
that the RCRA groundwater protection standards are relevant
and appropriate.
Under RCRA regulations, the groundwater protection standard
establishes a safe level of contamination in groundwater in
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the vicinity of a waste disposal site. Under these
regulations, the protection standard can be set at MCLs,
ACLs or at background. EPA has determined that the release
of hazardous substances at the site was similar to releases
regulated by RCRA. Therefore, EPA has determined that MCLs
are relevant and appropriate at the site.
In addition to the groundwater protection standard, Subpart
F provides relevant and appropriate groundwater monitoring
requirements and procedures that EPA will utilize in the
remedy (40 CFR 264.97 through 264.99).
28. Comment: EPA has also aisidentified the Connecticut Water
Quality Standards for groundwater as an "applicable"
requirement at Kellogg-Deering. "Applicable" standards or
requirements must be enforceable, and a review of the WQS
statute reveals that the standards are neither requirements
nor legally enforceable. Moreover, the WQS require that
groundwater be restored to drinking water quality without
treatment only "whenever feasible" and "to the extent
possible." Given the admitted technical impracticability of
remediating Kellogg-Deering groundwater to MCL standards,
WQS cannot be considered an ARAR from groundwater
remediation.
EPA Response: Section 121(d)(2)(A) of CERCLA, as amended,
states that remedies must comply with "any promulgated
standard, requirement, criteria, or limitation under a State
environmental or facility siting law that is more stringent
than any Federal standard, requirement, or limitation" if
applicable or relevant and appropriate to the hazardous .
substance or release in question. EPA proposes in 40 CFR
Part 300, National Oil and Hazardous Substances Pollution
Contingency Plan; Proposed Rule (Fed. Reg. 53:51394-51520,
December 21, 1988) "to define promulgated State requirements
as those laws or regulations that are of general
applicability and are legally enforceable." "The phrase
'legally enforceable* refers to State regulations that are
statutes which contain specific enforcement provisions or
are otherwise enforceable under State law. EPA expects that
State laws or standards which are considered potential ARARs
have been issued in accordance with State procedural
requirements. The phrase 'of general applicability* is
meant to preclude consideration of State requirements
promulgated specifically for one or more CERCLA sites as
potential ARARs . . . For a State requirement to be a
potential ARAR it must be applicable to all remedial
situations described in the requirement, not just CERCLA
sites. General State goals that are contained in a
promulgated statute and implemented via specific
requirements found in the statute or in other promulgated
regulations are potential ARARs. "
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EPA has determined that the Connecticut Water Quality
Standards are applicable to aquifer restoration at the
Source Area to the extent that they provide a level or
standard of control that is promulgated and more stringent
than Federal requirements. The aquifer at Kellogg-Deering
is a valuable resource both under EPA's Guidelines for
Ground-Water Classification and under the State
classification for groundwater, which classifies the aquifer
as Class GAA at the Well Field, the State's most stringent
classification for groundvater protection, and GB/GA in
other portions of the aquifer at the site. The GB/BA
classification indicates that although the groundvater
presently may not be suitable for direct human consumption
without treatment due to chemical contaminants or land use
impacts, the State maintains a goal to restore the
groundwater to drinking water quality. The Connecticut
Water Quality Standards were adopted pursuant to Connecticut
General Statutes 22a-426 and are enforced by the State
through other provisions in Title 22. The Water Quality
Standards are of general applicability and apply to all
remedial situations described in the requirement, not just
CERCLA sites. For the reasons stated above, the Connecticut
Water Quality Criteria are applicable to the cleanup of the
aquifer to the extent that they provide a level or standard
of control that is promulgated and more stringent than
Federal requirements.
29. Comment: If the Connecticut Water Quality Standards are
considered ARARs, they should be waived, for the same
reasons that MCLs should be waived as detailed above.
Furthermore, CERCLA authorizes the waiver of state standards
that have not been consistently applied, or demonstrated an
intention to consistently apply, the standard in similar
circumstances at other remedial actions. Connecticut has
not applied the WQS consistently at similar sites, nor has
it demonstrated any intention of applying them consistently
in the future.
ZPA Response: It is within EPA's authority to determine the
ARARs for the site and to determine when a waiver is
appropriate. As stated in EPA's response to comment number
25 above, there are six potential circumstances in which a
waiver may apply. EPA has determined that none of these six
conditions apply at the Kellogg-Deering Well Field Superfund
Site.
Remedy Components
30. Comment: Although EPA has determined that vapor phase
carbon adsorption will be used to treat emissions from the
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in situ vacuum extraction system, it does not justify this
requirement. If one were to calculate the maximum allowable
stack concentration for TCE under Connecticut Air Pollution
Control regulations using EPA's design parameters for the
extraction system's air discharge rate, the maximum
allowable stack concentration would be no less than 88 ppm
by volume (ppmv).
EPA Response: Carbon adsorption will be used for the vacuum
extraction system to ensure that the hazardous substances
are treated to the maximum practicable and to ensure
protectiveness consistent with OSWER Directive 9355.028 and
Region I guidance.
31. Comment: Although EPA's preferred remedy ostensibly leaves
open the possibility that source area groundwater may be
discharged to the Norwalk River or the local publicly-owned
treatment works (POTW), or injected into the aquifer, EPA
analyzes alternative groundwater remedial components using
only the Norwalk River option, which requires piping the
treated water to the Norwalk River south of the Well Field.
EPA's rationale that discharges upstream of the Well Field
would have to meet MCLs is not supported by any analysis.
As the Agency notes, discharge from both source and
downgradient air strippers would meet appropriate water
quality criteria in the Norwalk River, and projected in-
stream TCE concentrations comply with the standards of the
Connecticut Discharge Permit Regulations and risk-based
calculations for consumption of aquatic organisms from the
Norwalk River.
EPA Response: The method for disposal of treated ground-
water will be determined during Remedial Design. The method
of disposal specified in the FS was used for costing and as
a basis for the comparison of the other alternatives.
Options that will be considered in the design individually
or in combination include 1) reinjection back into the
aquifer, 2) discharge into the Norwalk River through a new
pipe, 3) discharge to the Norwalk River through existing
storm sewers, or 4) discharge to the local Publicly Owned
Treatment Works (POTW). The treatment standards will comply
with the applicable or relevant and appropriate requirements
for the disposal or discharge method chosen.
32. Comment: EPA has prematurely and erroneously determined
that air emission control is necessary for groundwater
source area air stripping. It is impossible to determine,
without further design, whether a source area air stripper
would violate Connecticut Air Pollution Control requirements
without air emission treatment. It is not possible to
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accurately determine whether an air stripper will neat
maximum allowable stack concentrations before the air
stripper actually goes on line or is pilot tested, since
input variables to the maximum allowable stack concentration
calculation (e.g., air emission rate) will not be known
until that time.
The RI/FS acknowledges that the calculated air stripper
emissions fall below the level requiring carbon off-gas
filters, but then proceeds to call for them anyway. There is
no ARAR or risk-based justification for the use of carbon
off-gas filters at either the Complex or the Well Field.
EPA Responses Air emission control by carbon adsorption
will be used for the vacuum extraction system to ensure that
the hazardous substances are treated to the maximum
practicable and to ensure protectiveness consistent with
OSWER Directive 9355.028 and Region I guidance.
33. Comment: Areas chosen in the RI/FS for extraction wells do
not exhibit contamination action levels chosen elsewhere in
the RI/FS.
EPA Response: The exact number and location of the
extraction wells and their respective pumping rates will be
determined in the remedial design to attain the cleanup
goals of the remedy. The proposed configuration in the
RI/FS was appropriate for the development and relative
comparison of groundwater treatment alternatives.
34. Comment: The RI/FS states "no reliable estimates can be
made for the overall remediation time required." (p. 358)
The only guess exceeds thirty years, but EPA does not really
know. This willingness to begin pumping and treating
groundwater is unjustified in light of the questionable
effectiveness of the system and EPA's inability to determine
how soon the aquifer would clean itself. It is possible
that natural flushing would be faster without pumping and
treating.
EPA Response: Pumping and treating contaminated groundwater
will be effective in reducing the size of the plume and the
mass of contaminants in the aquifer. Moreover, this will
enhance natural flushing of the aquifer. EPA believes that
approximately 2.5 years will be needed to remediate the soil
at the Complex and, although the time needed to remediate
groundwater can not be precisely set, pumping and treating
groundwater may have to be operated for ten or more years.
35. Comment: The RI/FS does not discuss the potential impact of
extensive pumping of the overburden and bedrock aquifers in
the source area, and subsequent reinjection. Such pumping
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and reinjection in a concentrated area has been shown to
cause structural failure of foundations and other rigid
structures as a result of the subsidence and mass movement
of sediment, extensive water damage of structures and even
micro-seismic events.
EPA Response: Subsidence is not expected to be a problem.
Also, the design of the remedy will take these factors into
account and will be developed to avoid de-watering that
could result in structural damage and subsidence.
Institutional Controls
36. Comment: The Phase II RI notes risk due to the possibility
that future private wells may be drilled near the source of
contamination, exposing humans to the contamination.
However, Connecticut state law requires all properties
within 200 feet of a public water supply system to hook up
to that system, and does not allow the installation of
private wells under such circumstances. These institutional
restrictions are present here and are unlikely to change
given the areas's recognized contamination and
impracticability of restoring the aquifer to MCLs.
EPA Response: EPA chose the cleanup because CERCLA requires
the selection of permanent remedies that employ treatment to
reduce the mobility, toxicity or volume of the contamination
(if such a remedy is practicable), over remedies like the
one outlined above that rely on non-treatment based
mechanisms such as institutional controls and containment.
Additionally, institutional controls would not attain ARARs
(e.g., MCLs and RCRA closure requirements) and is,
therefore, not an acceptable remedy for the site. Also,
given the potential failure of institutional controls,
without adequate engineering controls institutional controls
alone would not provide for adequate protectiveness.
State Ordered Groundwater Treatment System
37. Comment: Even assuming a hydrogeologic connection to the
Well Field, source area remediation is not necessary because
the RI/FS has determined that the Well Field air stripper
can meet Safe Drinking Water Act (SDWA) MCLs even under
"reasonable worst case scenarios." The State-ordered
treatment system at the Complex provides a further safety
margin.
EPA Response: As discussed in a number of earlier
responses, the selected remedy provides that MCLs must be
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attained throughout the aquifer, not only at the Well Field.
The State-ordered groundwater treatment system, even in
combination with the veil head treatment, will not attain
ARARs or EPA's remedial objectives at the site.
38. Comments The RZ/FS does not explain why the groundwater
treatment and extraction system installed under the DEP
order is not sufficient for source area remediation.
EPA Responses The RZ/FS prepared by EPA developed and
evaluated a range of cleanup alternatives to restore the
aquifer at the Kellogg-Deering site. The system installed
pursuant to the State Order addresses only a limited portion
of the highly contaminated portion of the aquifer and does
not provide for soil treatment. Therefore, it is unlikely
that the system can meet EPA's cleanup goals ~ it would not
intercept enough of the contaminated groundwater to achieve
a cleanup to MCLs. However, as part of the remedy's design,
EPA will consider use of the system installed under the DEP
order and, if possible, will incorporate it into EPA's
cleanup plans.
Alternative Remedies
39. Comments A number of alternative remedies were proposed
that the FRPs contended were more cost-effective than the
selected remedy. The first would modify the existing Well
Field air stripper, or add another stripper, to ensure that
water extracted from the Well Field continues to meet risk-
based standards in the event that contaminant levels
increase at the wellhead.
EPA Response: For any alternative to be more cost-
effective, it would have to achieve the same results as the
selected remedy but at lower cost. None of the proposed
alternatives do this. Further, EPA determined that the
selected remedy will yield results that are in proportion to
its cost in terms of the implementability and
protectiveness.
The premise of this first alternative is that MCLs do not
have to be attained throughout the aquifer but only at the
Well Field. Again, as discussed earlier, at Kellogg-Deering
EPA has determined that MCLs are relevant and appropriate
throughout the aquifer and that restoration of the
groundwater is required to achieve them.
40. Comments A second alternative remedy would have the
following components:
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- The groundwater pump and treat air stripping system
approved by DEP at the Complex, which will clean up the
highest contaminant levels observed in the study area and
prevent the unlikely possibility that soil contaminants
migrate into groundwater and then move offsite;
- Discharge of treated groundwater from the Complex air
stripper into the storm sewer, which flows into the Norwalk
River;
• • ' '.
- Continued operation of the existing Well Field air
stripper until contaminant levels entering the Well Field
distribution system drop below safe drinking water levels
without treatment by the stripper;
- Removal of any contaminated flooring and sealing of any
flooring cracks within the southernmost building at the
Complex as. necessary to minimize exposure to any possible
air emissions from contaminated soil gas beneath the
building;
- Institutional controls 1) at the Complex to prevent direct
exposure to soil contaminants, and 2) throughout the study
area to/prevent use of unsafe contaminated groundwater; and
- Necessary and cost-effective monitoring of concentrations
of VOCS in 1) groundwater to determine the effectiveness of
the cleanup effort and 2) air inside the southernmost
building at the Complex to ensure that acceptable
concentration levels exist.
EPA Response: This alternative is based on the premise that
either the determination that MCLs are not ARARs throughout
the aquifer, or if they are ARARs, then they should be
waived.
Again, as discussed earlier, EPA has determined that MCLs
are relevant and appropriate throughout the aquifer.
Further, EPA has determined that restoration of the
groundwater is required to achieve them and to provide a
protective remedy.
In light of the criteria that EPA uses to evaluate remedial
alternatives, this proposed remedy is not acceptable because
it would not satisfy the statutory and regulatory criteria
for CERCLA cleanups, including, but not limited to,
providing acceptable overall protectiveness and long-term
effectiveness, or attaining ARARs.
Although EPA is aware of the difficulty in predicting the
performance of the groundwater remedies; EPA will not waive
MCLs because the Kellogg-Deering aquifer is a significant
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resource utilized as a public drinking water source and
because the statutory criteria for a waiver have not been
vet.
41. Consent* The third alternative remedy proposes the
following remedial actions:
- Air quality
1. Fill the pit and trenches in the Elinco building;
2. Remove the TCE contaminated wood and sandblast or
encapsulate contaminated floor areas, or remove
wooden flooring as necessary;
3. Monitor air quality to ensure compliance with
applicable OSHA standards;
4. Modify building ventilation if standards are
violated.
- Soil
1. Impose land use controls on the Complex to prevent
site cover stripping and abandoning as outlined in
the RI/FS;
2. Address soil contamination at the time of future
site development.
- Source area groundwater
1. Place into operation the existing groundwater
treatment and extraction system, with a goal of
contamination levels of 5 ppb or less in water
flowing into the Well Field;
2. Monitor system performance as an aid to information
gathering.
• Downgradient groundwater
Given the problems of intercepting specific bedrock
fractures, and the RI/FS's assumption of institutional
controls to prevent installation of wells on the east
side of the river, any groundwater treatment program
should treat water in the overburden aquifer, rather
than in the bedrock.
EPA Responset This alternative is not acceptable. It
relies on the State-ordered groundwater treatment system
which *ill not meet ARARs or EPA's remedial objectives at
the site. Land-use institutional controls would not attain
ARARs or prevent further groundwater contamination.
Again, as discussed earlier, EPA has determined that MCLs
are relevant and appropriate throughout the aquifer.
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Further, EPA has determined that restoration of the
groundwater is required to achieve them and to provide a
protective remedy.
In light of the criteria that EPA uses to evaluate remedial
alternatives, this proposed remedy is not acceptable because
it would not satisfy the statutory and regulatory criteria
for CERCLA cleanups, including, but not limited to,
providing acceptable overall protectiveness and long-term
effectiveness, or attaining ARARs.
42. Comment: The following case was made for the No-Action
alternative:
The RI/FS erroneously focused exclusively on
remedial activities only where the
contamination is actually located. The RI/FS
implicitly assumes that in assessing whether
a remedy accomplishes a reduction in mobility
or toxicity of a substance the focus must and
can only be on accomplishing these goals at
the contamination location.
However, nothing in CERCLA or the National
Contingency Plan dictates this focus. In the
present case, the Well Field air stripper
accomplishes all goals of permanently and
significantly decreasing the toxicity,
mobility, and volume of TCE. To be sure, the
Well Field treatment system would not stop
the spread of contaminants towards the Well
Field. But by using a wider geographic area,
an area that extends beyond where the
contamination is found, the no action
alternative would meet all remedial action
requirements without any further remedial
work. The no action alternative would
decrease the mobility, toxicity, and volume
of TCE moving past the Well Field, and
satisfy both CERCLA and the NCP.
EPA Response: The No Action alternative was not selected by
EPA because it did not meet the statutory and regulatory
criteria for selection of a remedy. First, it would not be
protective of human health and the environment. Second,
there would be no reduction of the mobility, toxicity and
volume of contaminants in the unsaturated soils of the
complex. The mobility of the contaminants in groundwater
would not be reduced. The toxicity and volume of
contaminated groundwater would not be reduced except by well
head treatment, and finally, this alternative would not
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provide long-term effectiveness or permanence or attain
groundwater or RCRA closure ARARs.
Remedy Selection Process
43. Comments EPA has not shown how or why its proposed
expenditure of 13 million dollars will provide any more
protection to human health or the environment than that
currently being provided by the Norwalk First Taxing
District's (NTFD) treatment system.
The RI/FS Section 6 confirms that treated water leaving the
Kellogg-Deering Well Field does not pose any threat to human
health or the environment. Further, existing site
conditions as a whole pose a cancer risk of 1 in 360,000,000
to an individual with lifetime exposure to the site. For
non-carcinogenic risks, the hazard index is well below 1.0
and non-carcinogenic effects are thus also unlikely. In
short, there is no health risk posed by the site as it
currently exists.
The only risk-based justification EPA offers for remedial
work relies on future (worst-case) and future (plausible
case) scenarios. However, the assumptions underlying both
scenarios are so untenable that reliance on them would
constitute a capricious and insupportable basis for further
action.
EPA Responset EPA agrees that the treatment system
currently operated at the Kellogg-Deering Well Field
protects public health. If, however, private wells were
installed in the area of groundwater contamination or the
treatment system were not in use, due to equipment failure,
or otherwise, the chemical contaminants in the aquifer could
pose a risk to human beings. Human beings could be exposed
to site contamination by drinking the water, skin contact or
inhalation of contaminants could occur while showering if
there were no treatment system at the Well Field or if
drinking water wells were installed in the area of
groundwater contamination.
In addition to mitigating the risks posed by the
contamination in the aquifer, Section 121(d) of CERCLA
requires that the remedial action attain legally applicable
or relevant and appropriate requirements set by state and
federal laws. At Kellogg-Deering, EPA has determined that
standards, called Maximum Contaminant Levels (MCLs), set
under the federal Safe Drinking Water Act are relevant and
appropriate throughout the aquifer. Further, EPA has
determined that restoration of the groundwater is required
to achieve them. In addition to the federal standards that
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the remediation must attain, the cleanup of the aquifer must
meet State ARARs.
44. Comment: EPA has not met the CERCLA Section 121 requirement
for a cost-effective remedy. EPA's costs are based on a
thirty-year remediation estimate that has no rational basis
in light of its admission that "no reliable estimates can be
made for the overall remediation time required." (RI/FS p.
358.) Without a remediation time frame, one cannot
rationally estimate remedial cost, and thus one cannot
determine whether the proposed alternative is cost effective
within the meaning of CERCLA Section 121.
Further, the uncertain cost must be compared to existing
site conditions, under which the air stripper at the Well
Field is removing any threat to human health. This
comparison demonstrates that EPA has not justified the cost
effectiveness of the preferred alternative.
EPA Response: EPA has determined that the selected remedy
will yield results that are proportionate to its costs in
terms of implementabliity and effectiveness.
Thirty years is not the estimated remediation time for the
remedy. Instead, thirty years is a basis for a present-
worth analysis that EPA used for cost estimating. Present-
worth, also called present-value, is a cost accounting
technique that sums the cost of a remedy that may take a
number of years to complete as a total in today's dollars.
This gives a common basis (a present-worth) to compare
alternatives that have different project lives.
Thirty years is used in the estimate because costs incurred
after thirty years are relatively insignificant in terms of
their present-worth and do not affect the comparison of
different alternatives.
As an example of the insignificance of expenses incurred
after thirty years in the present-worth analysis, if the
cost to operate a remedy is $100,000 per year, the thirty-
year present-worth of this is equal to $9,427,000. If,
however, the remedy is operated for another year, only about
$5,700 (0.06%) is added to the present-worth total.
45. Comment: The energy cost of the proposed alternative is
high, especially given the uncertainty of its effectiveness
and the limited additional protection it affords. A total
energy usage for the preferred alternative has not been
included in the RI/FS. No specific energy cost appears
associated with the in-situ soil treatment component of the
proposed remedy although the system surely uses energy. For
groundwater treatment, the RI/FS assumes a total energy
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usage of 365,810 kilowatt-hours per year. This translates
into about 810 barrels of oil per year, assuming 450
kHh/barrel, or more than 24,000 barrels of oil over 30
years.
This energy use raises serious policy questions about
whether it is worth depleting one natural resource to clean
another. In the present case, this decision is made somewhat
easier by the operating treatment system and its removal of
any threats to human health. Without such a threat, use of
excessive amounts of natural resources on a highly uncertain
cleansing system cannot be justified.
EVA Responses Although energy costs are not itemized for
the soil treatment, these costs are included as part of the
estimated operating costs that are provided.
No serious policy questions arose over implementing the
Xellogg-Deering reaedy at the expense of the world's oil
reserves.
B. SUMMARY OF COMMENTS FROM THE STATE. CITIZENS AND OTHER
INTERESTED PARTIES
Connecticut Department of Environmental Protection
1. Comment: The cleanup goal concentrations cover broad
ranges, up to two orders of magnitude, and the proposed plan
does not specify a procedure for selecting remedial goals
from the cleanup goals.
EPA Response: The soil cleanup levels are ranges because
the soil types differ within the area of soil contamination.
The particular type of soil and amount of organic carbon
present in the soils attenuate contaminant migration and
result in the different cleanup goals provided. The
specific goals were set with a soil/water sorption model.
Details of this are provided in the Remedial Investigation
and Feasibility Study reports. The cleanup goals derived
from the model will insure that MCLs are not exceeded in the
groundwater as a result of soil leaching.
2. Comment: The Connecticut Department of Health Services has
established an action level of 1,000 micrograms per liter
for toluene in drinking water supplies. To properly reflect
the state's more stringent standards, the site cleanup
standard should be 1,000 and not 2,000 micrograms per liter.
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EPA Response: The Connecticut Department of Health Services
action level is not an ARAR because it has not been
promulgated.
Local Citizens and Other Parties
1. Comments The Proposed Plan states that wells containing TCE
were shut down in 1975, and restarted when the NFTD Water
Department installed treatment systems in 1981. However,
numerous newspaper articles from 1984 and 1985 report
citizen demands that contaminated wells be shut down and
treatment initiated, and some citizens believe that aeration
did not begin until 1987.
EPA Response: Treatment at the Well Field was started in
May of 1981 by the Norwalk First Taxing District (NFTD). In
1988, further pollution controls were installed at the Well
Field.
2. Comment: The NFTD did not notify its customers when the
contamination was first found. What will be done to insure
that future contamination is not kept secret for years?
EPA Response: The Norwalk First Taxing District (NFTD) is
required to report contamination that they find to the
Connecticut Department of Health Services.
3. Comment: The November 1980 letter to NFTD Water Company
customers listed as contaminants 1-4 dioxane,
methylethylketone or ethylene glycol, yet the RI/FS did not
mention these chemicals.
EPA Response: EPA did not find these chemicals in its
testing. The contaminants EPA did find that cause the
problems at the site are trichloroethene, commonly called
TCE, and perchloroethene, or PCE.
4. Comment: The construction of the new Route 7 so close to
the Well Field and above the aquifer worries some residents.
Particular concerns include the alleged use of junked cars
as fill, Connecticut DOT's oil storage at the construction
site, current illegal dumping near the Well Field, chemical
spills from trucks that will use the highway, and salt use
in the Winter.
EPA Response: Although these are all valid concerns and
should be addressed, this ROD and Responsiveness Summary
address the selection of a remedy fro the Source Area.
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5. Comment: According to several residents, the RI/FS does not
reflect the full history of the area. The following
information was provided:
1. The area bounded to the north by Broad Street, to
the east by the Norwalk River, to the south by East
Lakeview Drive and Nutmeg Place, and to the west by
Lakeview Avenue was a large pond until 1965, when it
was filled in.
2. The area now known as Kellogg-Deering Pond has long
been used as a dumping ground by residents and local
businesses. The configuration of the pond has changed
many times, and a 1970 map shows the pond covering the
current location of the Nell Field.
3. The area between Wesco Ford and the Norwalk River
was once a wetland lying just above the river, and was
used until 1981 as a dumping ground for a variety of
objects including cars, appliances, and drums.
Numerous other areas along the river have been filled,
sometimes with a variety of waste. Possibly
contaminants are leaching from these areas, or could
leach in the future. In addition, manufacturing plants
north of the Well Field have long regarded the river as
a waste receptacle, and local residents have long
spoken about the tainted river. In short, several
possible contamination sites exist in the area and
north of the Well Field. Thus, there is concern that
the site be constantly monitored even after the
cleanup.
EPA Response: The remedy that EPA has selected will address
the significant source of contamination found at the
Complex. EPA recognizes the uncertainties in treating
groundwater in bedrock and, although EPA believes that the
remedy will achieve ARARs and will be protective of human
health and the environment, the remedy also relies on the
existing Well Field treatment system (the first operable
unit ROD for the Site) to ensure protectiveness.
6. Comment: Several residents questioned the current safety of
the water provided by the NFTD. One believes it unsafe for
drinking or any other use. If immediate cleanup does not
occur, the resident requests bottled water. Another is
angry that the NFTD and the State of Connecticut force him
to consume carcinogenic water as long as contaminant levels
are kept within recommended ppm limits. He resents having
to consume any amount of carcinogenic water and pay for it.
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EPA Response: EPA considers the water supplied by the NFTD
to be within the standards set under the federal Safe
Drinking Water Act and therefore safe to drink.
7. Comment: The Noxvalk First Taxing District questions its
identification as a potentially responsible party, and
requests either the reason for its listing or removal from
PRP listing. Also, the NFTD requested to be kept informed
about work at the site.
EPA Response: This Record of Decision does not address
liability issues, but deals with the selection of the remedy
for the Site. Therefore, EPA will not address in detail
comments regarding liability. However, the NFTD is a
current owner of a portion of the site and therefore, falls
within one of the classes of potentially responsible parties
under section 107(a) of CERCLA.
EPA will keep the NFTD informed about the work at the site.
8. Comment: A wetlands restoration expert working on the
Norwalk River is apparently concerned that either the study
or remediation area is not large enough, as he has observed
repeated failures of vegetation in Deering Pond and skin
irritation from water contact. He suspects chemical
contamination is responsible and not addressed in the RI/FS.
EPA Response: The studies done by EPA and the cleanup plans
address the contamination of the Kellogg-Deering aquifer.
The scope does not include Deering Pond at this time.
However, remediation of the aquifer will improve, to some
degree, surface water quality throughout the area. EPA
intends to further evaluate surface water quality in the
future.
9. Comment: No mention was made about fines against the
polluters.
EPA Response: EPA is considering its enforcement options
for the site. In general under Superfund, EPA attempts to
recover the money spent on the studies and attempts to get
the potentially responsible parties to implement the cleanup
work.
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EXHIBIT A
EPA COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE KELLOGG-DEERING SITE
EPA issued a press release announcing funding for study
of the sits
March 1984, EPA issued a community relations plan
identifying community concerns and EPA plans to inform
and involve the public in EPA decisions
July 11, 1989, EPA held a public meeting in Norvalk to
discuss study of the site
October 1985, EPA released a fact sheet describing
field studies to date and plans for further
investigation
April 1986, EPA released a fact sheet presenting the
results of the remedial investigation of the site
May 5, 1986, EPA issued a press release announcing the
availability of the Remedial Investigation report for
public review and announcing a public meeting on the
site
May 22, 1986, EPA held a public meeting to discuss the
results of the Remedial Investigation and answer
community questions
June 1986, EPA issued a fact sheet on the results of
the Feasibility Study evaluating options for well-head
treatment of water pumped from the site
June 1986, EPA released a revised community relations
plan to update information on community concerns and
EPA activities planned to inform and involve the public
July 2, 1986, EPA issued a press release announcing a
public comment period on the cleanup options for the
site to be held from July 18 - August 7; and announcing
EPA's schedule for a public meeting and public hearing
on the cleanup options for the Well Field
July 17, 1986, EPA held a public informational meeting
in Norvalk to.present results of the Feasibility Study
and answer questions
July 31, 1986, EPA held a public hearing to accept oral
comments on the recommendations for well-head treatment
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September 1986, EPA issued a fact sheet and press
release describing the well-head treatment option
selected for the site
May 5, 1987, EPA issued a press release to announce an
Administrative Order under which the Norwalk First
Taxing District would be required to repair, test and
operate the air stripping unit at the site
EPA announced the availability of the Administrative
Record for public review in Norwalk, Connecticut and in
Boston, Massachusetts
January 1988, EPA issued a press release announcing
plans for a Supplemental Remedial Investigation of the
source areas of site contamination, and the
availability of the workplan for public review. EPA
also released a fact sheet describing the planned
supplemental investigation
July 18, 1989, EPA issued a press release announcing 1)
completion and availability of the Feasibility Study;
2) a public comment period (to be held July 27-August
25) on the Feasibility Study and Proposed Plan for the
second operable unit at the site; and 3) the schedule
for a public meeting and public hearing on the
Feasibility Study and Proposed Plan
July 26, 1989, EPA issued its Proposed Plan
recommending a cleanup option to address sources of
contamination at the site.
July 26, 1986, EPA held a public informational meeting
in Norwalk to present the results of site study and the
Proposed Plan and to answer questions
August 4, 1989, EPA issued a press release providing
information on the public hearing
August 14, 1989, EPA held a public hearing to accept
oral comments on the Proposed Plan to address sources
of site contamination
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EXHIBIT B
TRANSCRIPT OF THE PUBLIC HEARING
KELLOGG-DEERING SITE
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UNITED STATES OF AMERICA
1 ENVIRONMENTAL PROTECTION AGENCY
2 . . BOSTON REGION
3
4 In the Matter of:
5 PUBLIC HEARING
EPA PROPOSED CLEANUP FLAN FOR
6 THE KELLOGG-DEERING SUPERFUND SITE
7
8
9 Norwalk Pu.Diic Licrary
1 Belden Avenue
10 (Morwalk, Connecticut
11 ! Monday
August 14, 1989
12
13
.e aDove er,-;itien matter came on for hearing,
14 pursuant to Notice at 7:40 p.m.
15
16 BEFORE: MATTHEW HOAGLAND,
Remedial Project Manager
17 MARGARET LESHEN,
Connecticut Superfund Section Chief
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2 iEfeAKER: PAGE
3 Ms. LeSken
Mr. Hoagland
5 Mr. Barske 8
6 Mr. Wolfe 1!
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2 ('.7:40 pm)
3 MS. LESKEN: ...for the Super fund Section,
4 and I want to welcome everyone here to the Public
5 Hearing for the Kellogg-Deering Superfund Site.
6 Can everyone hear me? -Just so everyone
knows, these are mikes for transcribing the meeting.
8 They are not amplifying mikes. So if you heed us to
9 talk louder, just let us know.
10 I'm going to just tell you about what we're
going to be doing tonigV.t. :
12 It is -- the meeting is going to be broker:
13 into three carts. Matt Hoagland, the Froject•Manager,
14 is going to make a very brief presentation about the
15 proposed plan and preferred alternative for the site.
16 He did come down here July 2bth. So you
17 did get an opportunity to hear a more detailed
18 presentation and to ask questions.
19 After Matt makes a presentation, we're
20 going to have the actual formal comment period. At
21 that time, I will call whoever has requested the
22 ability to make a comment up, and they will come up and
23 make their comment into the mikes.
24 If at anytime during the meeting' you decide
25 you want to make a comment, I would ask that you just
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go to the back, or raise your hand, and Will Schreocer
2 (phonetic) from our office will have you fill out a
3 card. Me do need to know your names so that we can
4 read it into the record.
5 After we do that and everyone has a chance
6 to have their -- make their comments into the record,
we will close the meeting and stay around for any
8 informal comments and questions -- a short question and
g answer period.
10 And as everyone heard at their meeting on
-- on the meeting on July 2£th, there is a formal
12 public comment period for the Keliogg-Deering Superfund
13 Site for the proposed plan that ran from July 27th to
14 August 25th. Ycu can re«d your comments into the
15 record tonight on the plan, or you can send written
16 comments to Matt Hoagland, the Project Manager, and his
17 address is on the second page of the proposed plan that
18 we have in the back. If anyone needs any copies of the
19 proposed plan, we can just -- Will can get them to yc-<.;.
2o With us tonight, we, also, have Chris
21 Atkinson (phonetic) and Mike Powers from the
22 Connecticut Department of Environmental Protection.
23 Does anyone have any questions on how the
24 hearing is going to be run tonight?
25 (Pause.>
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1 MS. LESKEN: Yes?
2 FROM THE FLOOR: If you don't understand
3 something that's in the report, when can we ask that
4 kind of a question?
5 MB. LESKEN: In terms of a clarifying
6 question on the report?
7 FROM THE FLOOR: Yes.
8 MS. LESKEN: At the end of the meeting.
g FROM THE FLOOR: At the end of the meeting"'
10 MS. LESKEN: Yes. When the people are.-
11 reading.'the couiir.ents or questions into the record, that
12 is a formal part cf the hearing, and we will not be
13 responding.
14 . We will be c\round afterwards to answer any
15 clarifying questions.
16 (. Fau.se. )
17 MS. LESKEN: Okay. I don't hear any other
18 questions.
19 I'm going to have Matt make a very brief
20 presentation about the proposed plan.
21 MR. HOAGLAND: Okay. I'd like to welcome
22 everyone here tonight.
23 As I presented it earlier, on July 26thf we
24 have basically two contaminates of concern out at the
25 site. There is trich1 oromethane and tetrachloroethane.
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1 These are known as volatile organic compounds.
2 They have been detected in soils beneath
3 the buildings of an area that we call the Elinco/Fitney
Bowes/Matheis Court Complex. That's an area that's
5 just on the east side of -- of Main Street, in Norwalk.
6 Contaminates have also been detected in the
indoor air of the buildings, and in ground water of the
8 aquifer.
9 Tlit EFA's preferred alternative is really
10 ir> three parts.
11 The first part is called an in-situ vacuum
12 extraction, which is designed to be used primarily for
13 contaminants in unsaturated soil, soils that are above
14 the ground water table. Those contaminants can be
15 removed using this technology from the soils themselves:
16 anci also this technology, the EFA believes, will cutoff
17 farther introduction of contaminants to the indoor --
18 into the indoor air of the buildings.
19 Thfe ground water contamination has been
20 divided into -- the area of ground water contamination
21 has been divided into two zones.
22 The -- there is a very highly concentrated
23 area of ground water contamination. This is called the
24 source area. The other area that remains -- that's
25 Beyond the source area or further downgrade in the
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7
1 source area is called the downgrading area. The source
2 area, has higher levels of contamination then the
3 downgrading area.
4 The EFA's proposed or preferred
5 alternative, as described 'in'.the proposed plan, will --
6 discusses how extraction wells would be placed in both
7 the source and downgrading areas,..to extract, and
• f' i '
8 treat, and discharge contaminated.ground water. I have
9 three additional points to make:..'
10 One is that-.-- that ;there is treatment at
11 the Kel logg-Deering wells. Th.'i
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1 that that was something that was screened out very
2 early on in the feasibility process, and that's real I/
3 all I have to say right now.
4 MS. LESKEN: Okay. We're going to start
5 the actual hearing part of the presentation.
6 Again, if anyone wants to make a comment,
7 they should just give their card or get a card from
8 Will in the back.
9 The first, person that wanted to speak was
10 Val Wolfe.
11 ''.Pause. '.) •'••"'.
12 --. U'C_FE; I have no comment.
13 M5. LESKEKi• Oh, none right now.
14 Ckay. The\-second as P. Barske.
15 I*.R. BARSKE:- It's Barske.
16 MS. LE3KEM: Barske. If you could come
17 forward'"'
18 (Pause. )
19 MR. BARSKE: The name you have is
20 Philip Barske, Fairfield, Connecticut.
21 You may wonder why I'm in Norwalk. I've
22 been in Norwalk since £:30 this morning working near
23 the river.
24 I've gone through the plan briefly. I'm
25 not a chemist, and I can only hope that the agency has
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1 taken the right one, but I do have a little odd ; ' ;
2 experience along this river that I thought would be
3 worth presenting, and I believe I wrote a brief note to
4 Mr. Hoagland.
5 I've been doing some Army .Corps restoration
6 work at Deering Pond, and my concern, basically, is the-
7 clean-up plan -- where does it start or where should it
8 start.
9 Now, I've been involved in wet land work
10 creation for about forty years, and I've never had the
11 odd experience that I had at Deering Fond over the past
12 three years.
13 Ve-r/ briefly, I put in some plantings. The
14 first year they failed because there was no b^se
15 material. Somebody had p-.it seed plant -- upland plants
16 in the water, and, of course, they failed. There wa-i-
17 no substrata, so the first year it failed. I wasn't
18 concerned why, other than the geese, the swans, and the
19 muskrats. •'-.-••
20 The second year, I brought in 100 yards of
21 tested soil from an excavation site in Trumbull,
22 Connecticut. I had that tested by the Baron
23 Laboratories for heavy metals. We put in a planting,
24 and I thought by fall we had a fairly successful
25 vegetative planting which I can illustrate here.
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10
1 What I'm driving at is vegetative: reaction,
2 c.nd then some chemical or medical reaction I've noticed
3 from the area.
4 We would get -- during the period that I
5 planted, when we had low water, we had excellent
6 growth, and on occasion -- I've kept very close notes
7 of this from 7/25/BS.
8 The first year I wipe off because there wat
9 no strata -- organic strata. The second year we- took
10 care of swans, geese, ad infinitum. When we had an
11 inundation of this vegetation, we have a practically
12 90% kill.
13 Now, at that same time, on 7/B/E7, wherr we
14 were planting over the organic matter, I had «,n odd
15 sense that something was not right there. The odor,
16 feel, and I made everyone wear boots and rubber gloves.
17 There is one young man -- if you see him here, you car,
18 see why -- he couldn't wear boots. They Just wouldn't'
19 fit over his thighs.
20 He waded in the water, and about three days
21 later -- I don't have pictures of his legs, but his
22 arms and his legs erupted in huge welts, highly
23 irritated, very itchy. Now, that happened in '87.
24 • At that same time, I got above water therev
25 and I got it right in the elbow. That was excised by c
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1 dermatologist, and sent to the lab, and found nothing.
2 Evidently it was a chemical burn of some type.
3 That -- evidently there was some organism
4 or some chemical aspect. You can see the eruptions.
5 Tom's leg from knee up -- ankle -- was covered with
6 this mass of welt.
7 Well, very briefly, the following year we
8 replanted, had a fairly good growth, until we he\d high
9 water. With high water, we practically lost all of the
10 growth, and on May 15, the same young man planted for
11 nie, ancj that's wnen he developed the rash on his hands.
12 That time he had boots. He was fearless, with rubber
13 gloves and he developed that rash again.
14 Now, since then the plantings have been i r,
15 poor shape. I worked with plants many years. I have a
16 feeling that something is amiss in this area.
17 Now, I did talk to hike Noonan, from the
18 Army Corps. I've forgotten what date. I have it in
19 here.
20 (Pause. )
21 MR. EARSKE: Oh, 7/27/E7, Mike Shean. He
22 was overseer of this project. I checked with him, told
23 him what had happened. He said that he would contact
24 EPA.
25 Now, I never heard from anyone. I
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1 contacted Rich LeClair, Dr. Steve Hitchcock, anc! Brian
2 Kielbana, and then they sent a young man,
.3 Michael Cunningham, on E/17/87, to look at this area.
4 Now, in the river, itself, I don't know.
5 There is an area we planted. There is one under drain,
6 and while I was working on Route 7, on 7/10 -- 10, 11,
7 I happened to get an aerial photograph of this proposed
8 -- of the highway route, which went right over Deering
9 Po.-id, and the site that I worked on. That had been a
10 gravel pit and then a dump.
11 I had talked with a Dr.. William Neering,
12 roughly, at I hat time, and he said that -- you know,
13 that was 7/16/37. ! talked to Dr. Nse'ring, and he just
14 said that w.:-s irritated here.
15 Finally, he called me at night, arid he s&iij
16 that I had visions of that as a suspected dump sits or
17 toxic site. Whether it -Wciis or not, I don't know.
18 Michael Cunningham from DEF did come down, and he
19 reported no toxics from this area.
20 Now, all I can report is the three years
21 that I have watched this area. This year the growth is,
22 horrible. At high water, all the spring water, the
23 vegetation just did not come through.
24 To me there is something in this system. I
25 know I'm beyond the well field area, but I am concerned
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1 with this, because thirty years ago I signed the flood
2 control small water shed project for this Norwalk
3 River. I worked in Norwalk a great cieal and will be
4 the next couple of weeks.
5 Working in this area, I just had a sense
6 that something was amiss. It tied in with this program
7 in the same pond area. Now, I won't venture into that
8 thing without boots and rubber gloves. My gloves come
9 up to her& now.
10 My feeling is, "In doing are we neglecting
11 a portion of the violated system of the river?"
12 Basically, that is all I have to say. I
13 can't comment on the clean-up systems. I do not know
14 proper techniques, but I plan to follow it very
15 c a f e f u 11 y . T h a n k y o u.
16 MS. LESKEN: Thank you.
17 MR. BARSKE: Now, if you want these,
18 they're yours. You may not want them, but--
19 COURT REPORTER: For the re-cord, I would
20 like the sp&llings of the names you used.
21 MR. BARSKE: Of the names?
22 COURT REPORTER: Of the people involved.
23 MR. BARSKE: Tom Rochovanski,
24 R-0-C-H-O-V-A-N-S-K-I. Dr. William Neering.
25 Now, those were medically treated, and we
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1 never found out what they were, and never found out
2 what the bit of tissue that they excised from my arm.
3 They did both bacteria and chemical on it, but it did
4 sear into the skin, and made a definite pit, and I had
5 something that had to be removed.
6 Now, as I say, I am concerned with the
7 whole river system in that area.
8 Thank you.
9 MS. LESKEN: Thank you.
10 MR. KCASLAND: Thank you.
11 MS. LESKEN: Is there anyone else that
12 wanted 4.o n.s-.f e & comment?
13 (Pause. ')
14 MS. LESKEN: Don't be shy. This is your
15 opportunity.
16 '• Pause. )
17 FROM THE FLODR: Can I ask another
18 question?
19 MS. LESKEN: Sure.
20 FROM THE FLOOR: The gentleman said that
21 there was no more -- no more dumping at the
22 contaminated area.
23 Is there any attempt to go after whoever
24 dumped? I mean, what does it take to -- to go back and
25 get compensation for that?
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1 • . . MS.. .LESKEN: Okay. This is -- this part of
2 the meeting is for formal comment. . So we can either
3 enter that into the record, or we can end this, and
4 then, we can help;you.
5 FROM THE FLOOR: Okay. Let me rephrase it.
6 Why doesn't the proposal include going after the
7 dumpers? .
8 MS. LESKEN: Okay. This proposed plan is. a
9 proposed plan., for .the -remedial action, the te'chn.i.c.e 1
10 action at the: site',..-' •• . '• './• ...
11 • There :is. a whole other component of ,our . ••- •
12 our work, whi.ch.. is enforcement, which errlail-'s 'those .
13 types of things. . If you want to .just wait until .-t'hj.-5 .
14 part is over,- 'we' can go over- that. '.' ••'"' '' . -
15 ; This plt^n-'i-f'iat y-'1-1 have is technical in
16 nature, in terms of th.at. •/'.'..••
17 Ar.& VKere any other people that would ii.ke
18 to make a comment into the record?
19 - ' (Pause.-. ') . ''••.'• .••-'-.'..-
20 MS. LFSKEN: Okay. So we'll go back to--
21 .. MR.. WOLFE: Val Wolfe.
22 MS. LEShCEN: --Val Wolfe.
23 MR. WOLFE: . I'm not a chemist, but I have
24 three items that I question on the list that lists the
25 contaminants.
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1 One, is we received a letter in the fall of
2 1380 from our First Water District Department, sign&d
3 by Mr. Kelly, the previous supervisor.
4 They indicated that there was 1 to 4
5 dioxin, in — in the tests that they had made. There
6 was also ethylene glycol, and I can't pronounce this
7 other one. Perhaps you can?
8 MR. HOAGLAND: Menthyletheyketone?
g MR. WOLFE: That's right. I don't see them
10 listed on this listing of contaminants, and I wondered
11 why they .are' not listed there.
12 '. • Thank y: u. . . •
13 MS. LESSEN: . Thank you.. •-' '. • .
14 _'.••- .r; u=». ) ' '
15 - . MS. LESKEN: Is. there anyone else that
16 we.u.ld like to aiu-'r..e a cc-iTiment?
17 ».Pause. )
18 MS. LESKEN: If not, we'll close this pert
19 of the meeting., £.nd j-.'.st so you know, all the comments
20 that were received tonight, as well as any written
21 comments that are received in our office before
22 August 25th -- and the address as to where to send them
23 is in the proposed plan -- will be responded to in a
24 formal nature, in a document called a Responsiveness
25 Summary, when we actually do our Record of Decision,
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1 which is a decision document for the remediation at the
2 Kel iogg-Dee.ring s'ite. . ''..-' .' •
3 For anyone that is interested,, all of the
4 information and the reports are downstairs in the
5 Library here, as well as in our office in Boston, if
6 you want to look at further information. . . .
7 We are talking comments tonight and in
8 writing, on both the preferred Alternative* .and any of
9 the other alternatives that are described . in-.the : .
10 feasibility study which is the large document. . . •
11 downstairs. So if anyone wanted to look at- it.,, they
12 are iViore than welcome to look at that at. anytime,' too.
13 (Pause. ':•
14 r-'S. LESKEN: I don't hear any ' other --• is
15 there anyone else with a formal comment-?
16 close this part of the meeting.
17 (Pause.)
18 M3. LESKEN: We will be off the record.
19 '.Whereupon, on August 14th., • 1389, at
20 8:00 pm, the public hearing was closed.)
21
22
23
24
25
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1 CERTIFICATE OF REPORTER AND TRANSCRIBER
2
. This is to certify that the attached proceedings
3
4 before: ENVIRONMENTAL PROTECTION AGENCY
. in the Matter of:
PROPOSED CLEANUP PLAN FOR
6 THE KELLOGG-BEERING SUPERFUND SITE
7
8
9
Place:Norwsik, Connecticut
10
Date: August 14, 1989
n
were held as Herein appears, and that this is the true,
accurate anc complete transcript prepared from the notes
13
and/or recorcings taken of the above entitled proceecing.
15
16
17
J. Luff E/14/.89
Reporter Date
D. Brideau 8/21/89
Transcriber Date
19
20
21
22
23
24
25
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Kellogg-Deering'Well Field
NPL Site Administrative Record
Index
Compiled: October 31, 1988
Updated: July 26, 1989
ROD Signed: September 29, 1989
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
One KendaL Square, Suite 2200 • Cambridge, Massachusetts 02139 • (617) 577-9915
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RECORD OF DECISION
KELLOGG-DEERING SITE - OPERABLE UNIT 2
SOURCE CONTROL
APPENDIX C
STATE CONCURRENCE LETTER
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STATE OF
DEPARTMENT OF ENVIRONMENTAL PROTECTION
Sefttsber 29, 1989
Paul Keough
Acting Regional Administrator
OS EPA Region I
JFK Federal Building
Boston, MA 02203
Dear Mr. Keough;
The Connecticut Department of Environmental Protection (DEP) concurs with
the remedy selected for the second operable unit of the Kellog-Deering
Superfund Site. Our concurrence is provided with the understanding that the
operable unit for which a remedy has been selected consists of the "source
area" of the contamination affecting the Kellogg-Deering Wall Field, as defined
in the proposed plan, and that the downgradient area will be evaluated as a
third operable unit for which a separate reaedy and Record.of Decision will be
prepared. Furthermore, DEP1a concurrence with the selected rtmedy for the
second operable unit shall not be considered concurrence with a no action
remedial alternative for the third operable unit. In providing this
concurrence, the State finds that the selected reaedy will satisfy all
applicable or relevant and appropriate State laws and regulations.
Since it is inconsistent with Connecticut's tfeter Quality Standards, goals,
and policies to endorse any significant delay in remediation of areas
contributing contamination to the Kellogg-Deering Vbll Field, I am requesting
that within 60 days of the signing of this Record of Decision, technical staff
from EPA and DEP meet to discuss areas within the third operable unit where
additional information is needed, and to possibly resolve technical areas of
disagreement.
Sincerely,
Leslie A. Carothers
Commissioner
LACtCAsao
fboor
165 Capitol Await* • Hvtford, ConMcrion 0(106
A*
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RECORD OF DECISION
KELLOGG-DEERING SITE - OPERABLE UNIT 2
SOURCE CONTROL
APPENDIX B
ADMINISTRATIVE RECORD INDEX
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