UrtttdStUM
Environment* Promotion
SEPA
Superfund
Record of Decision:
Yaworski Lagoon, CT
-------
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
BPA/ROD/R01-88/027
14. Title and Subtitle
>ERFUND RECORD OP DECISION
»csici Lagoon, CT
rat Remedial Action - Final
7. Authors)
*. Performing Organization Nam* and Addresa
12. Sponsoring Organization Nama and AddraM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1. Recipient'* Accession He.
•. Performing Organisation Rapt. No.
10. 'Pro|act/Taak/Work Unit No.
1L ContracMC) or GrarnXG) No.
(G)
IS. Typo of Raport & Period Covered
800/000
14.
IS. SupplamanUry Not**
M. Abatraet (limit: 200 words) " •
The Yaworski Lagoon site is a dewatered and backfilled lagoon, approximately 700 feet
and 300 feet wide, and surrounded by an earthen dike. It is located on an approximately
100-acre section of land in Canterbury Township, Windham County, Connecticut, on the
floodplain of and bordered on the north, south and west by the Quinebaug River. The
area surrounding the site includes agricultural land to the east and south. Leachate
*rs the ground water from below the lagoon; seepage from the lagoon dikes and surface
ff from the site flow to adjacent wetlands. Approximately 2000 feet southeast of
the site is an operating solid waste landfill owned by James Yaworski, the same person
who operated the lagoon. The landfill contributes some contamination to ground water,
but EPA monitored the site in 1988 and determined the contamination to be much less than
from the lagoon. Between 1950 and 1973, sludge materials and drums of industrial waste
including solvents, paint, textile dyes, acids, resins, and other debris, about 50,000
barrels of waste material altogether, were deposited in the lagoon. The lagoon
currently contains approximately 65,000 cubic yards of contaminated sludge covered by
about 60,000 cubic yards of contaminated debris. The sludge is a mixture of water,
dirt, VOCs, and other organic compounds at concentrations above 10,000 ppm. Metals are
at concentrations above 1000 ppm. Monitoring wells were installed at the site in 1976
(See Attached Sheet)
17. Document Analysis a. Descriptor*
Record of Decision
Yaworksi Lagoon, CT
First Remedial Action - Final
Contaminated Media: gw, sediments, sw, soil
pft^flio^^erirfl6^18 (chromium, lead), organics (PAHs), VOCs (benzene, toluene,
xylenes)
ITI Field/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Page*
89
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-771
(Formerly NTIS-3S)
Department of Commerce
-------
'ROD/R01-88/027
lorski Lagoon, CT
'list Remedial Action - Final
16. ABSTRACT (continued)
and ground water contamination was detected. In 1982, following an investigation of the
site, CT DEP ordered Yaworski to close the lagoon. The primary contaminants of concern
affecting the ground water, soil and sediments are VOCs including benzene, toluene and
xylenes, organics including PAHs, and metals including chromium and lead.
The selected remedial action for this site includes: installation of a RCRA cap;
improvement of dike around the lagoon to ensure protection from floods; establishment of
a ground water protection standard (ACL); and monitoring of ground water for 30 years.
A ground water treatment method will be established as part of a corrective action
program if, after implementation of the source control remedy, ground water
contamination remains above ACLs. The estimated capital cost of this remedial action is
$1,673,000 with present worth O&M of $716,600.
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RECORD OF DECISION
Yaworski Lagoon Site
Canterbury Township, Connecticut
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for
the Yavorski Lagoon Superfund site in Canterbury Township,
Connecticut. The remedial action was developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the
extent practicable, the National Contingency Plan, 40 C.F.R. Part
300 et sea. (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 will attain applicable or relevant and
appropriate 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
Canterbury Public Library and the EPA Region I Waste Management
Division Records Center at 90 Canal Street in Boston,
Massachusetts.
The response action for the Yaworski Lagoon site is a
comprehensive remedy that combines components of source control
and management of migration. In sum, waste in the lagoon will be
contained by an impermeable cap that complies with the Resource,
Conservation and Recovery Act (RCRA) and other applicable or
relevant and appropriate environmental laws, the dike around the
lagoon will be improved to ensure that the dike can withstand
floods, a ground water protection standard known as Alternate
Concentration Limits (ACLs) will be established, and monitoring
will be conducted to ensure that the ACLs are not exceeded.
These actions will ensure that site contaminants do not pose a
threat to human health or the environment.
-------
DECLARATION
The selected remedy is protective of human health and the
environment, attains federal and state requirements that are
applicable or relevant and appropriate for this remedial action,
is cost-effeciive and utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable. The remedy does not utilize treatment and thus does
not meet the preference for remedies that employ treatment as a
principal element.
Date Michael R. Deland
Regional Administrator
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Yaworski Lagoon site
Canterbury, Connecticut
TABLE OF CONTENTS
Contents
I. SITE NAME, LOCATION AND DESCRIPTION ........ 1
II. SITE HISTORY ........ ........... 1
A. Response History ................ 1
B. Enforcement History ............... 3
III. COMMUNITY RELATIONS ................ 4
TV. SCOPE AND ROLE OF THE RESPONSE ACTION ....... 5
V. SITE CHARACTERISTICS ............... 5
VI. SUMMARY OF SITE RISKS ............... 12
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES ...... 13
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES ..... 14
A. Statutory Requirements .......... ..... 14
B. Response Objectives ......... ....... 15
C. Technology and Alternative Development and
Screening ..................... 15
»
IX. DESCRIPTION/ SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS OF ALTERNATIVES ....... 16
X. THE SELECTED REMEDY ................ 19
A. Description of the Selected Remedy ........ 20
B. Rationale for Selection of the Remedy ....... 29
XI. STATUTORY DETERMINATIONS ............. 35
A. The Selected Remedy is Protective of Human Health
and the Environment ................ 35
B. The Selected Remedy Attains ARARs ......... 36
C. The Selected Remedial Action is Cost Effective and
Utilizes Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable . . 40
D. The Selected Remedy does not Satisfy the
Preference for Treatment as a Principal Element . . 45
XII. STATE ROLE .................... 46
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ROD DECISION SUMMARY
YaworsJci Lagoon site
Canterbury Township, Connecticut
I. SITE NAME, LOCATION AND DESCRIPTION
The Yavorski Lagoon site is located on approximately a 100-acre
parcel of land in Canterbury Township, Windham County,
Connecticut. See Figure 1. The site is bordered by the
Quinebaug River on the north, south, and west, and Packer Road on
the east. The nearest town, Plainfield, is three miles to the
east.
The site is within a meander loop on the floodplain of the
Quinebaug River. The site is a dewatered and backfilled lagoon,
approximately 700 feet long and 300 feet wide, surrounded by an
earthen dike. Between 1950 and 1973, sludge materials and drums
of industrial waste including solvents, paint, textile dyes,
acids, resins, and other debris and industrial trash were
disposed in the lagoon. Approximately 50,000 barrels of waste
material were deposited in the lagoon during its operating life.
Historical photographs of the site indicate that the lagoon
originally consisted of two basins separated by a narrow, earth-
filled partition, which was used as a ramp for waste disposal.
The lagoon currently consists of an estimated 125,000 cubic yards
of waste and backfill materials. The fill material supports
grasses, plants, shrubs, and small trees.
Open fields that in the past have been used for the production of
silage corn are to the east and south of the lagoon.
Approximately 2000 feet southeast of the lagoon is an operating
solid waste landfill owned by James Yaworski, the same individual
who operated the Yaworski Lagoon. See Figure 1. A more
complete description of the site can be found in the Remedial
Investigation Report prepared by NUS Corporation (NUS) in 1986
and in the supplemental Remedial Investigation Report prepared by
Ebasco Services Incorporated (EBASCO) in July 1988.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
Flammable waste was periodically burned at the site until 1965
when the Connecticut Department of Health ordered a halt to on-
site burning of waste. The combined efforts of local residents
and state and local officials concerned about adverse human
health and environmental effects from disposal operations at the
lagoon led to Jthe end of all dumping at the lagoon in 1973.
In 1976, the Connecticut Department of Environmental Protection
(CT DEP) directed James Yaworski to install a series of
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ROD DECISION SUMMARY
Yavorslci. I^aoon site
Page 2
BASE MAP BAPORTON OF THE U3AS. PUUNRELO, CT QUADRANGLE (7.5 MINUTE SERIES, 1953, PHOTOREVISEO 1970).
CONTOUM WTCRVM. »'. FIGURE 1
LOCATION MAP
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ROD DECISION SUMMARY Page 3
Yaworslci Ixiaoon site
monitoring veils adjacent to the lagoon and to assess the
environmental hazards posed by the site. As a result of these
actions, ground water contamination was detected. In 1980, CT
DEP ordered Mr. Yaworslci to employ a professional engineering
firm to conduct an environmental study of the property.. The
engineering firm concluded that most of the contaminants had
migrated from the lagoon, and recommended closing the lagoon by
covering the waste. In May 1982, CT DEP ordered Mr. Yaworski to
close the lagoon in accordance with the engineering firm's report
and Mr. Yaworski agreed to carry out this Order. Subsequently,
Mr. Yaworski covered the lagoon with paper, rags, rubble and
soil.
In 1984, the site was added to the National Priorities List,
EPA's list of top priority hazardous waste sites, thus making it
eligible to receive federal funds for investigation and cleanup
under the Superfund program. NUS completed the initial Remedial
Investigation for EPA in April 1986. Ground water and soil
samples taken from areas immediately adjacent to the lagoon
revealed the presence of volatile organic compounds (VOCs).
The initial Remedial Investigation at the Yaworski Lagoon site
also concluded that several areas needed further study before a
cleanup decision could be made. Therefore, in 1987 and 1988, EPA
conducted a supplemental Remedial Investigation to obtain further
details about the nature and extent of contamination in the
lagoon and beneath it; to determine the condition of the dike
surrounding the lagoon and the impact of flood events; to
ascertain the impact of the lagoon on the adjacent wetlands; to
evaluate ground water contamination, if any, across the Quinebaug
River; and to study the impact of the active Yaworski landfill on
ground water quality in the lagoon area.
A more detailed description of the response history can be found
in the initial Remedial Investigation Report completed by NUS and
the supplemental Remedial Investigation Report prepared by
Ebasco.
B. Enforcement History
On November 10, 1983, EPA notified Yaworski, Inc., an owner and
operator of the facility of its potential liability with respect
to the site. Five parties who either generated wastes that were
shipped to the facility, arranged for the disposal of wastes at
the facility, or transported wastes to the facility were notified
of their potential liability with respect to the site on June 10,
1987. Negotiations commenced with these potentially responsible
parties (PRPs) shortly thereafter regarding the settlement of the
PRPs1 liability at the site, after which the PRPs formed a
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ROD DECISION SUMMARY Page 4
Yaworski. ^*goon site
steering committee. EPA subsequently identified three
additional PRPs. Although special notice has not yet been
issued at this site, EPA anticipates that substantial
negotiations will take place during the end of 1988 and the
beginning of 1989.
The PRPs have been active in the remedy selection process for
this site. In the fall of 1987, the PRPs submitted comments on
EPA's decision to conduct additional sampling and analysis of the
lagoon contents, to obtain a more in depth view of the site
hydrogeology, and to investigate the Yaworski solid waste
landfill's effect on site ground water. On June 21, 1988, the
PRPs submitted comments to EPA on the potential risks associated
with the implementation of an excavation and incineration
alternative. Several representatives of the PRPs also attended
the public informational meeting held on July 27, 1988 and the
public hearing on August 17, 1988, although they did not place
any oral comments into the record. The PRPs, however, did
submit additional written comments on the supplemental Remedial
Investigation and the Feasibility Study (RI/FS) and Proposed Plan
during the public comment period. EPA's responses to the
significant comments are contained in the Responsiveness Summary.
III. COMMUNITY RELATIONS
The local community has had an active and at times quite vocal
presence throughout the site's history. EPA has kept the
community and other interested parties apprised of the site
activities through informational meetings, fact sheets, press
releases, and public meetings.
On October 29, 1983, EPA issued a press release and solicited
comment on the Remedial Action Master Plan (RAMP) . On December
11, 1984, EPA held an informational meeting in Canterbury,
Connecticut to describe the Work Plan for the initial Remedial
Investigation. In June 1985, EPA released the Yaworski Lagoon
site Community Relations Plan, which outlined the program that
the Agency intended to implement in order to address community
concerns and keep citizens informed and involved during the
conduct of remedial activities. On May 21, 1986, EPA held a
public meeting to discuss the results of the initial Remedial
Investigation. On March 16, 1987, EPA issued a press release and
made available a plan that delineated additional investigations
to further characterize the nature and extent of contamination
at the site. The results of these additional investigations are
embodied in th* supplemental Remedial Investigation Report and
the analyses of remedial alternatives are embodied in the
Feasibility Study Report. These reports were issued in July
1988.
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ROD DECISION SUMMARY Page 5
Yaworslet Laaoon site
The Agency published a notice and brief analysis of the Proposed
Plan in the Norwich Bulletin on July 20, 1988 and made the
Proposed Plan and the Administrative Record available to the
public at the Town of Canterbury, Connecticut Public Library on
July 27, 1988. On July 27, 1988, EPA also held an informational
meeting to discuss the results of the supplemental Remedial
Investigation and the cleanup alternatives analyzed in the
Feasibility Study, presented the Agency's Proposed Plan for the
cleanup of the site, and answered questions from the public.
From July 28, 1988 until August 24, 1988, the Agency held a four
week comment period to accept public comment on the Proposed
Plan, on the alternatives presented in the Feasibility Study
Report, and on other documents that were contained in the
Administrative Record. On August 17, 1988, the Agency held a
public hearing to accept oral comments. A transcript of the
oral comments read into the record was made. A summary of the
comments submitted by the public and the EPA's response to those
comments are included in the attached Responsiveness Summary*
IV. SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy is a comprehensive approach to site
remediation that combines components of source control and
management of migration. In sum, waste in the lagoon will be
contained by an impermeable cap that complies with the Resource,
Conservation and Recovery Act (RCRA) and other applicable or
relevant and appropriate environmental laws, the dike around the
lagoon will be improved to ensure that the dike can withstand
floods, a ground water protection standard known as Alternate
Concentration Limits (ACLs) will be established, and monitoring
will be conducted to ensure that the ACLs are not exceeded.
These actions will ensure that site contaminants do not pose a
threat to human health or the environment. The selected cleanup
approach is discussed in more detail in Section X.
V. SITE CHARACTERISTICS
The significant findings of the Remedial Investigations completed
in 1986 and 1988 are reviewed briefly below. A complete
discussion of site characteristics can be found in those
Reports.
Nature and Extent of Contamination In the Lagoon
The lagoon contains approximately 65,000 cubic yards of highly
contaminated sludge covered by an additional 60,000 cubic yards
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ROD DECISION SUMMARY Page 6
Yavorski Lagoon site
of contaminated debris. The sludge is a mixture of water, dirt,
VOCs, semi-volatile organic compounds (SVOCs), and heavy metals
See Table 1. Organic compounds in the percent range (i.e.,
above 10,000 ppm) include 2-butanone, 4-methyl-2-pentanone,
carbon tetrachloride, total xylenes, 1,1,1-trichloroethane,
toulene, ethylbenzene, bis(2-ethylhexyl) phthalate,
butylbenzylphthalate, and di-n-octylphthalate. Additionally, a
number of heavy metals, including chromium, lead, and nickel, are
found at concentrations above 1000 ppm.
The debris covering the sludge consists of dirt, rags, trash, and
construction materials. It is saturated with contaminated water
that is perched above the sludge. This contaminated debris adds
a significant amount of material to be managed and complicates
any possible excavation of the underlying lagoon sludge.
Condition of the Present Cover and Dike
The present cover over the lagoon and the dike that surrounds it
are inadequate to protect against erosion and flooding and do not
stop rainwater from washing through the waste in the lagoon.
Around the western and southern perimeter of the lagoon, the
dike is nonexistent at some points and rises to a maximum of only
five feet above the surrounding ground surface. Some riprap
(boulders and construction debris used as erosion control) is
present on the dike slopes at the northern and eastern sides of
the lagoon; however, the thickness and composition of the riprap
is highly variable and contains a large amount of construction
debris and does not provide adequate erosion or flood protection.
Under current site conditions, heavy rainfall or flooding may
cause erosion of the existing cover and dike. Various portions
of the cover and dike currently have little or no protection
against erosioa. This is particularly evident at the west end of
the lagoon where surface seeps are prevalent.
Ground Water Contamination
Contaminants from the lagoon sludge dissolve directly into
ground water below the lagoon and are washed into the ground
water by rainwater that flows through the debris and soil cap
that covers the waste. The washing of contamination from the
lagoon by rainwater is the primary cause of contaminant
transport to ground water.
Contaminants in ground water include elevated levels of VOCs,
SVOCs, and metals. See Table 2. The concentrations exceed
drinking water standards for those compounds.
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POD DECISION SUMMARY
Yavorski Lagoon site
Page 7
Table 1
VMORSK1 LA600N SLUKE CONTAH1NATION
ContMittnt
VOIA1IU ORBAN1C COWOUXM
Cenctfltrttion
Rinoi (ppi)
BetbvIfBi Chloride
AeilOBi
l.l-Dichleroethwe
1r int-1 ,2-Di chl or oethene
Chi or of or •
1.2-DicblDroithint
2-lutwonr
l.l,t-Trichlororthant
Ctrbon T«tr«chl oride
Virul Acftitt
Triehleroithinf
l.i,2-Trithlorotth«ne
Itnttnt
Tttrachlorofthini
Tolaenr
42-410
127.8-133
310-560
1.4-250
15-125
125
SU.2-72.000
126.4-15,000
47.t-4.100
Total
Tetrahydrofor»n
700
49
17-54
54. 4-3. I 00
75-91
50.5-12.000
1I9.B-11.000
772.2-44.000
170-B20
Detection
Frequency
5/11
2/11
2/11
3/11
4/11
1/11
9/11
10/11
2/11
1/11
1/11
J/ll
3/11
7/11
3/11
10/11
10/11
10/11
4/11
tatuiunt
SEfll-VOlATIli ORGANIC
Concentration
(ppi)
•uhtbiltne
2-fletbTln«pththilene
Acenishthene
iathraenti
FluerintbMi
ftrtnt
kis(2-£thylht:vnrt>thaltt»
Ckyrivnt
lir«-0ctvl fhthilite
leruo (b) Fluorinthene
lento (k) Flgorinthmt
3,3'-6ichlorobea:Jdine
len:o Ul Aatbrtcnt
B2-220
14-33
1.9
IOC
2B
91
17
210-1B.WO
970-13.000
45
400-2,700
19
28
100
400
Detection
Frequency
3/11
2/11
1/11
1/11
1/11
1/11
1/11
6/11
7/11
1/11
7/11
1/11
1/11
1/11
1/11
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ROD DECISION SUMMARY
Yaworslci Laaoon site
Page 8
Table 1 (continued)
YMOfiSXI LA600M SiUDK CWTMINATIW
IIBftBMIC CWOUWS
Canctntratien BttKtion
CcntMiBMt two* (ppi) Frtqutncy
Arttnie 3.8-S.V 3/8
IviBi 147-723 I/B
C«diiu 100-769 B/6
Chrotiu* 34-9,130 I/B
Uid 42.9-i.290 B/B
Htrcury 2.3-B9 7/8
Sj 1m 3.4H.4 3/B
Cosprr 23-872 B/B
Niekil 12-9.310 B/B
line 1*9-1.820 1/8
Tulhui 2.2 ' 1/B
CvMidi 6.73-O.B1 2/B
Contuintnt
Aroclor-1254
FE5T1C1KS/PCB
Cmcratrition
Rinjt ipoi)
Btttction
Priqueticx
4/U
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ROD DECISION SUMMARY
Yavorslci I*aaoon sitie
Page 9
Table 2
WWOP.SK1 LA600N SITE 6ROU»WTEIi BNSTlTUEKTa
VOLATILE DKSMilC COIPOUO5
tontuiaint
SettMbr/Dttotirr 19BS (NU5)
Cmctntrition fttttction
Frequent*
Chloroethane
Hethvlne Chloride
Acetone
1.1-Dichlorotthene
2-fciitanone
4-fletbtl -2-f tntanone
Toluene
Ethvlbenrene
Icta) Ivlenes
Tetrarvdroforin
Vinvl Chloride
«:hlorotthir.e
!,2-bicnloroethene
Trichleroethane
TricMroethene
leniene
2-Nezir.Rte
letrachleroethenr
Carbon £isul4ide
-
Cant Mi sint
'fkenol
Maohtbaleitr
2HletbylDhenol
4-flethylpknol
2,4-Biiethylpheaol
imzoir Acid
kii(2-£thylhnvl)Phthtlite
ienxyl Alcohol
tfi-i-octyl phthtlite
ftjlllbensrl ihthaUte
0.003-0.730
0.1-0.44
0.39-1.3
1.7
0.025-66D.O
0.003-67.0
0.002-5.5
0.004-10.0
0. 002-42. 0
0.015-47.0
W
1.7
NI-
ir
NT
0.004-0.01
NT*
C-.23
DC
SfFteaber /October
Concentration
Range lpp«)
O.OS5
0.004-O.OB4
n
C.C35
D
0.19-0.3B
0.004-0.007
D
0.001
0.004-0.006
7/21
3/21
2/21
1/21
6/21
4/21
1/21
7/21
12/21
13/21
0/21
1/21
0/21
0/21
0/21
2/21
(»/21
1/21
0/21
19B5 (NUS)
Election
Frequency
1/21
4/21
0/21
1/21
0/21
2/21
4/21
0/21
1/21
3/21
Fcbruirv 19E6
Concentration
lange
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ROD DECISION SUMMARY
Yavorski Laaoon site
Page 10
Table 2 (continued)
Contaminant
VMDRSCl LAEOON SITE IMUIDMTER COttTlTUEKTa
1KORBAN1C CMF-DUNI'S
February 19BB*
Concentration Detection
tange (ppi) Frtqumcy
Musi BUS
Arirnic
iariui
UdiiM
Calcitu
Chroaiu*
total t
Copptr
Cranidt
Iron
Lead
flagnttiut
lUnginm
H^rcury
Nickel
Fotaiiini
Silm
Sodiua
2iBC
417-650
1J-65
24t-2A3
10-47
12,400-160,000
10
62
12-BOB
11
141-US.OOO
MD
5,46(-32.60<>
53-2(1,100
0.2
44-110
5,300-9,700
KD
5,56P-B1,2W
54-122
2/14
4/14
2/14
1/14
14/14
1/14
1/14
6/14
1/14
14/14
0/14
10/14
14/14
1/14
3/14
B/14
0/14
14/14
5/14
Background Hell
Range (ppi)
2710
79,BOO
154
BI.l -
15.400
21.5
6.620
1E1
112
nu-
39.400
1E2
• TE: trounfoitrr not anlivsetf for iflorginici in Junt 1966.
Inorfinit data fro* SrptMbrr/fetobr 19ES (NUS) net included.)
PE57IC1KS/PU
Ftbrutry 1«B»
Conctntratioo Pfttction
Rangt (ppi)
CantMiaaat
M'-BIT 0.1M.12 2/14
Ddrii 2,4 1/14
Hrptachler Epwidt 0 0/14
• (NOTE: GrBunduttr not anilfJfd for Fnticides/PCfii ii June 19BE.
Niticidfi/Pd data fro* Septtabir/Octobr 1985 INUS) aot inclndtd.)
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ROD DECISION SUMMARY Page 11
Yaworslci Ladcon site
Ground water generally flows and recharges into the Quinebaug
River. The river acts as a hydraulic barrier to ground water
flow to areas beyond the river meander.
Quinebaug River
The concentration of some contaminants in the Quinebaug River
exceed their Ambient Water Quality Criteria at points both
upstream and downstream from the site. However, the results of
surface water and sediment benthic organism sampling conducted by
EPA indicate that presently there is no increase in contaminant
levels in the river that can be attributed to the Yaworski
Lagoon.1
The Quinebaug River's large volume also attenuates contamination
so no measurable increase in levels are observed. Although
levels of several metals are elevated in the river, these levels
are generally no higher than background levels upstream and
downstream from the lagoon.
Wetlands
Contamination from the lagoon seeps through the dikes into the
wetlands. Wetland organisms may suffer from the presence of
metals such as cadmium, chromium, copper, and lead. In addition,
wildlife may be exposed to contaminants in the leachate and
wetland surface water and sediments. The primary transport
pathways appear to be leachate flow from the lagoon, erosion of
contaminated seep sediments and surface soils, and dissolution of
contaminants into surface runoff from soils and sediments.
Future Well Development Across the Quinebaug River
Hydrological conditions are not suitable for development of
large volume water supplies (e.g., a municipal system) across the
river because the soil's hydraulic conductivity and resulting
potential yield of water is low.
Yaworski Solid Waste Landfill
The operating solid waste landfill contributes VOCs, SVOCs, and
metals to ground water, but, based on monitoring conducted by EPA
1 Fish sampling conducted by the potentially responsible
parties at the site also supports this conclusion.
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Yaworski T^aoon si tie
in 1988, the contamination was found to be at substantially lover
levels than contributed by the sludge lagoon.
VI. SUMMARY OF SITE RISKS
The potential adverse human health and environmental effects from
exposure to contaminants at the site were estimated and
summarized in the Public Health and Environmental Risk
Evaluation, Section 6 of the supplemental Remedial Investigation
Report. Incremental lifetime cancer risks and the potential for
non-carcinogenic adverse health effects were estimated for
exposure to contaminated soils, sediments, and ground water.
These adverse health effects are summarized in Table 3.
Table 3
Bon-Carelno§«nle Risk* Carclao|«aic tick*
Ke«c
>roh«>>\> «or*t Probable
Adult Child Adult Chili! Adult Child
Croundvatcr 3.4 10. 9 143 MO 2.4 x 10'4 J.3 x 10'5 3.2 x 10"3 1.3 x 10
Surf.e. V.t.r B/C O.t »/c 2.7 x 10*'
S«dtMot «/e 0.2 »/C 3.3 x 10"*
These estimates of the adverse health effects are based on an
evaluation of the most toxic, mobile, and persistent chemicals
found at the site. These chemical include both carcinogens and
non-carcinogens, such as volatile organic, semi-volatile organic
and inorganic compounds. Present and future potential exposure
pathways, including dermal contact with soil and sediments,
ingest ion of fish, ingestion of ground water, and dermal contact
with leachate were investigated and the risks associated with
these pathways were quantified. The estimates of risk are
presented for the average-case and worst-case scenarios. The
average-case scenario represents the most probable risk that the
exposure may be causing. The worst-case is a very conservative
estimate that assumes all exposure occurs at the highest
contaminant concentrations that were measured.
Although contaminated ground water is not currently being
consumed, ingestion of ground water would result in risks that
exceed EPA's target range for incremental lifetime cancer risks
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Yaworski Ir^ooon sits
of from 10~4 to 10~7 and exceed acceptable reference doses for
exposure to non-carcinogens. For carcinogens, the ingestion nay
pose an incremental lifetime cancer risk of from 2.4 x 10~4
(averac/e-case) to 5.2 x 10~3 (worst-case). Arsenic, benzene, and
tetrachloroethylene cause most of this risk. For non-
carcinogens, drinking ground water would result in a hazard
index2 for 2-butanone from 5 (average-case) to 139 (worst-case) .
The hazard indices for acetone, lead, and cadmium were just over
one under the worst-case scenario.
In addition to risks posed by exposure to ground water, dermal
contact with contaminated leachate and sediments pose, under the
worst-case scenario, an incremental lifetime cancer risk of 5.5 x
10~6. The non-carcinogenic hazard index, however, was less than
one and, therefore, risk from dermal contact to non-carcinogens
is not significant.
The ingestion of fish would not cause unacceptable carcinogenic
or non-carcinogenic risks.
In addition to the risks posed to human health, contamination
from the site poses a threat to the environment. Concentrations
of cadmium, chromium, copper, lead, and zinc in the wetland near
the site exceed chronic and acute Ambient Water Quality Criteria
and ecotoxicity criteria. This contamination is due to leachate
flow from the lagoon and erosion of contaminated sediments. In
addition to chemical contamination, erosion from the lagoon
contributes to sedimentation of the wetlands and decreases the
wetlands1 flood storage capacity and potential as a habitat.
Also, continued erosion and leachate from the lagoon could
adversely impact the Quinebaug River.
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA adopted a Proposed Plan (preferred alternative) for
remediation of the site on July 27, 1988. The selected remedy
does not differ significantly from the preferred alternative.
2 Risk for a non-carcinogenic compound is represented by a
Hazard Index. A Hazard Index is the ratio of (the contaminant
concentration at which exposure of a compound occurs) to (EPA's
acceptable reference dose for the compound). A value greater
than one indicates that exposure is at a concentration greater
than the acceptable reference dose and thus, may be significant.
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YavorsXi T-^noon site
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements
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, dated November 20, 1985. Until the NCP is revised to
reflect SARA, the procedures and standards for responding to
releases of hazardous substances, pollutants and contaminants
shall be in accordance with Section 121 of CERCLA and to the
maximum extent practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards, requirements,
criteria and limitations (ARARs) 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 hazardous substances over remedies that
do not achieve such results through treatment. The remedial
alternatives developed for the Yaworski Lagoon site are
consistent with these Congressional mandates.
Section 121(b)(1) 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, the evaluation and
selection process was guided by the EPA document "Additional
Interim Guidance for FY '87 Records of Decision" dated July 24,
1987. This document provides direction on the consideration of
SARA cleanup standards and sets forth nine factors that EPA
should consider in its evaluation and selection of remedial
actions. The nine factors are:
1. Compliance with ARARs.
2. Long-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility, or Volume.
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Yaworslci. Laaoon site
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
9. .Overall Protection of Human Health and the Environment.
B. Response Objectives
Response objectives were developed to mitigate existing and
future threats to public health and the environment. The
response objectives developed for the Yaworski Lagoon site are
to:
1. minimize exposure to contaminated ground water;
2. ensure that contamination from the lagoon does not
adversely impact the Quinebaug River;
3. protect environmental receptors in the wetlands;
4. minimize exposure to contaminated leachate seeps; and
5. attain ARARs.
C. Technology and Alternative Development and Screening
The evaluation and screening of remedial alternatives for the
site was conducted in accordance with CERCLA, the NCP, and EPA
guidance documents, including the "Interim Guidance on Superfund
Selection of Remedy" [EPA Office of Solid Haste and Emergency
Response (OSWER) ], Directive No. 9355.0-19 (December 24, 1986).
Treatment alternatives were developed to address the five
objectives listed above. In addition to treatment alternatives,
containment options and a minimal/no-action alternative were
developed.
After setting response objectives, EPA developed and evaluated
potential cleanup alternatives for the Yaworski Lagoon site to
address those objectives. The Feasibility Study Report for the
site describes the alternatives considered, as well as the
process and criteria EPA used to narrow the list to six
potential remedial alternatives.
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ROD DECISION SUMMARY Page 16
toon s:
A three-step process was followed in the Feasibility Study.
First, technologies were identified, assessed, and screened
based on their ability to be effective, implementable, and to
address the response objectives developed for the site. This
technology screening is summarized in Chapter 9 of the
Feasibility Study Report.
The highly contaminated sludge that is found in the Yavorski
Lagoon and the contaminated debris that covers the site greatly
limited the number of effective, implementable technologies. EPA
concluded that containing the wastes in the lagoon or
incinerating the lagoon contents would be the only viable
technologies. A discussion of why other types of treatment
technologies would not be effective or implementable is in
Chapter 9 of the Feasibility Study Report. For ground water, an
ACL demonstration and pumping and treating ground water were
identified as effective, implementable technologies.
The viable technologies identified for the lagoon contents and
ground water remediation were then combined to form six remedial
alternatives. Only six alternatives where developed because of
the limited number of technologies available.3
Finally, the six alternatives were evaluated in detail against
the nine criteria listed above. This detailed evaluation is
summarized in Chapter 10 of the Feasibility Study Report.
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the nine evaluation criteria
described above. The alternatives address both contaminants that
remain on-site in the lagoon and contaminants that have migrated
from the lagoon. A detailed tabular assessment of the
alternatives can be found in Table 10.1 of the Feasibility Study
Report.
Alternative f 1: Minimal/No-Action. This alternative would
require EPA to enclose the lagoon with a 6-foot high chain link
fence.
3 At this point in the remedy selection process, an initial
screening, to narrow the number of alternatives to a manageable
number for further detailed analysis, is usually conducted.
However, because only six alternatives were developed, this
initial screening was not necessary.
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ROD DECISION SUMMARY Page 17
This alternative would not be protective of human health and the
environment because it does not address the contaminated
leachate seeps, include enforceable ground water protection
standards or controls, or address the potential impacts of flood
events. Furthermore, this alternative does not attain ARARs.
Although the minimal/no-action alternative does not meet CERCLA
requirements, it was evaluated in detail in the Feasibility Study
to serve as a baseline for comparison with the other remedial
alternatives under consideration.
ESTIMATED TIME FOR CONSTRUCTION: 1 Year
ESTIMATED TIME FOR OPERATION: 30 years of maintenance
ESTIMATED TOTAL COST: $315,000
Alternative f 2: Minimal/No-Action for Lagoon Sludge with an ACL
Demonstration for Ground water. Alternative f 2 would set ACLs
as the ground water protection standard but would not include any
containment or treatment measures for the lagoon source, other
than fencing.
Although ACLs would address the ground water protection
requirements, the alternative would not be protective because the
contaminated leachate seeps would continue to impact the
wetlands. Furthermore, this alternative would not meet ARARs for
flood protection or closure of the lagoon.
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED PERIOD OF OPERATION: 30 Years of Monitoring
ESTIMATED TOTAL COST: $1,566,000
Alternative f 3: Improved Capping and Dike, and Setting an ACL
as the Ground Water Protection Standard This alternative is the
selected remedy for the site and is discussed in Section X.
Alternative I 4: Improved Cap and Dike for Lagoon Sludge with
Ground water Treatment by Ultraviolet (UV)/Ozonation.
Alternative f 4 combines improving the cap and dike as described
under the selected remedy in Section X with treatment of ground
water by UV/Ozonation. Under this alternative, contaminated
ground water would be pumped out of the ground into an on-site
facility and treated to reduce the contaminants in the ground
water. After the ground water is treated by this process, it
would be released back to the site aquifer.
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Yaworslci Xjaaoon site
This alternative would be protective of human health and the
environment and would attain all ARARs, including those for
floodplains and wetlands.
This alternative was not selected because it would be more
expensive, but no more protective, than the selected remedy
given site conditions. Ground water contamination is contained
within the Quinebaug River meander and enforceable measures to
restrict ground water consumption at the site can be
implemented. Moreover, it is not technically feasible to achieve
drinking water standards without treatment of the waste in the
sludge lagoon. Treatment of ground water is thus not necessary
as long as it is demonstrated that no statistically significant
increase in contaminants entering or accumulating downstream in
the Quinebaug River is occurring.
ESTIMATED TIME FOR CONSTRUCTION: 2 years
ESTIMATED PERIOD OF OPERATION: 30 years of monitoring and
treatment
ESTIMATED TOTAL COST: $4,159,000
Alternative f 5: On-site Incineration of Excavated Sludge with
an ACL as the Ground Water Protection Standard. Alternative # 5
would combine excavation and on-site incineration with an ACL
demonstration as described under the selected remedy. This
alternative would first involve removing the contaminated soil
and debris from above the lagoon wastes, then excavating the
lagoon contents and incinerating the contaminated soil, debris,
and lagoon contents in an on-site incinerator. The incinerator
would consist of an on-site mobile treatment unit equipped with
air pollution control equipment. Ash resulting from the
incineration process would be managed in accordance with
appropriate Resource Conservation and Recovery Act (RCRA)
requirements. After removal and incineration of contaminated
material, the lagoon area would be backfilled with clean soil.
This alternative would be protective of human health and the
environment, attain ARARs, and satisfy the statutory preference
for treatment-based remedies that reduce the toxicity, mobility,
or volume of the wastes.
This alternative, however, would not be effective in the short-
term because of the potential for significant air emissions
during waste excavation.
Further, this alternative would be difficult to implement at the
site. Siting a treatment facility and excavating large
quantities of contaminated wastes in a floodplain require
extraordinary care.
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Yaworski Laaoon site
Finally, this alternative is much more expensive than the
selected remedy and yet would not result in the reduction of
contaminants in ground water to drinking water standards.
ESTIMATED TIME FOR CONSTRUCTION: 2 years
ESTIMATED PERIOD OF OPERATION: 3 years to operate
incinerator; 30 Years of
Monitoring
ESTIMATED TOTAL COST: $100,984,000
Alternative I 6: On-site Incineration of Excavated Sludge with
Ground water Treatment By UV/Ozonation. This alternative would
combine on-site incineration of lagoon sludge as described under
Alternative # 5 with ground water treatment by UV/Ozonation as
described under Alternative 14.
This alternative would be protective of human health and the
environment, attain ARARs, and satisfy the statutory preference
for treatment-based remedies that reduce the toxicity, mobility,
or volume of the wastes. This alternative would also
significantly reduce contamination in the ground water.
This alternative, like Alternative # 5, however, would not be
effective in the short-term, would be very difficult to
implement, and is much more expensive than the selected remedy.
Further, even in the event that source and ground water
treatment could decrease contaminant levels in the aquifer below
drinking water standards, the hydrology of the aquifer is not
conducive to sinking a large capacity municipal well.
ESTIMATED TIME FOR CONSTRUCTION: 2 years
ESTIMATED PERIOD OF OPERATION: 3 years to operate
incinerator; 30 years of
treatment and monitoring
ESTIMATED TOTAL COST: $101,790,000
X. THE SELECTED REMEDY
The selected remedy is a comprehensive approach to site
remediation that combines components of source control and
management of migration.
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Y avoirs lei I^aoon site
A. Description of the Selected Remedy
EPA's selected remedy is to contain the lagoon waste by
constructing an impermeable cap and improving 'Che dike around the
lagoon to ensure that the cap and dike can withstand floods. EPA
will also establish ACLs to ensure that contaminants in ground
water do not pose a threat to human health or the environment.
The selected cleanup approach is discussed in more detail below.
1. Lagoon Closure - Improved Cap and Dike
The contaminated sludge in the Yaworski lagoon will be contained
by installing a cover, or "cap," over the lagoon and reinforcing
the earthen dike that surrounds the filled lagoon. The cover
will be designed, constructed, and maintained to comply with
RCRA. RCRA landfill closure requirements include 40 C.F.R. §
264.310 and RCRA location standards for facilities in
floodplains, 40 C.F.R. § 264.18. Specifically, under 40 C.F.R. §
264.310, the cover will be designed and constructed to:
a. Provide long-term minimization of migration of liquids
through the closed lagoon.
b. Function with minimum maintenance.
c. Promote drainage and minimize erosion or abrasion of the
cover.
d. Accommodate settling and subsidence so that the cover's
integrity is maintained.
e. Have a permeability less than or equal to the permeability
of any bottom liner system or natural subsoils present.
Additionally, to meet the location requirement for facilities in
floodplains, the cover and dike that will surround the lagoon
will also be designed, operated, and maintained to prevent
washout by a 100-year flood.
To meet the requirements outlined above, a multi-component cover
system will be implemented. See Figure 2.
The cover will contain both a synthetic liner and a low-
permeability soil layer to ensure that it provides long-term
minimization of migration of liquids through the waste in the
lagoon; the liner or the low-permeability soil layer alone would
not provide adequate protectiveness. Having two components
ensures that should one fail, the other will continue to minimize
the migration of liquids through the waste.
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ROD DECISION SUMMARY
Yaworslci I^aoon site
Page 21
FIGURE 2
RCRA CAP CROSS SECTION
VAWORSKI LAGOON
IMM
Each component of the cover is described below along with a
discussion of its function. The particular materials specified
below for each component serve as the basis for subsequent
remedial design and remedial action. However, other materials
or specifications may be utilized if EPA determines that they
satisfy the various goals described below or improve on the
overall effectiveness of the remedy.
The description of the cover follows EPA's guidance "Covers for
Uncontrolled Hazardous Waste Sites," (EPA/540/2-85/002) and takes
into account site-specific conditions. The guidance ensures that
the final cover will meet the RCRA requirements under 40 C.F.R. §
264.310.
Vegetated TOP Cover
The vegetated top cover will, at a minimum, be two feet thick. ;
suitable soil type will be utilized that contains nutrients,
water content, and other properties to support vegetation that
minimizes erosion without continued maintenance. The cover will
be planted with a stabilizing grass mixture that does not have a
root system that penetrates beyond the vegetative and drainage
layers.
The slope of the final vegetative cover, after settling and
subsidence, will be maintained at between three and five percent
to promote drainage and minimize erosion to less than 2
tons/acre/year, based on the USDA Universal Soil Loss Equation.
The vegetated top cover also will conduct runoff across the cap
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ROD DECISION SUMMARY Page 22
Yaworslci. L^aoon site
with no backup, retention or ponding of water and will have a top
surface that is capable of withstanding flood water velocities of
at least 4 feet/second.
Filter Fabric
A filter fabric will be installed between the top vegetative
cover layer and the drainage layer below to prevent fine soil
material from washing into the drainage layer. Fine material
could decrease the permeability of the drainage layer and
decrease its drainage performance.
Drainage Laver
The drainage layer will promote lateral drainage of liquids off
of the cover. It will be two feet thick, have a saturated
hydraulic conductivity of not less than IxlO*"3 cm/sec, and have a
bottom slope of at least two percent to ensure adequate drainage.
The saturated hydraulic conductivity of the material used for the
drainage layer will be confirmed by appropriate testing. The
two-foot drainage layer, in combination with the two-foot
vegetative layer above, will provide frost protection for the
liner and low-permeability soil layer below.
Geot ex-bile
A geotextile will be placed below the drainage layer to provide
abrasion and puncture protection for the synthetic liner.
Synthetic Liner
The synthetic liner will be high density polyethylene or
chlorosulfonated polyethylene of at least 40-mil thickness.
These liner materials were selected from among other liner
materials because they provide the best chemical resistance and
have an acceptable yield point in elongation (stretching
capacity) for application to the Yaworski lagoon. Chemical
resistance is important because of the high concentration of
solvents found in the sludge material in the lagoon. Polyvinyl
chloride (PVC) and chlorinated polyethylenes do not have adequate
chemical resistance. A minimum of a 40-mil thickness was
selected to provide adequate puncture and abrasion protection and
protection against chemical degradation. During installation of
•the liner, appropriate quality assurance procedures will be
followed.
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Yaworslci I^aoon site
Page 23
Low-Permeability Soil Laver
The low-permeability soil layer will, at a minimum,' be two feet
thick. The material used for this layer will be installed in
lifts not to exceed 6-inches before compaction. It will have an
in-place saturated hydraulic conductivity of less than lxlO~7
cm/sec. The saturated hydraulic conductivity will be confirmed
by laboratory testing on field-compacted samples, by in-place
infiltrometer testing, and by correlation to moisture content and
density.
Bedding/Foundation Laver
At a minimum, a two-foot thick bedding/foundation layer of soil
will be installed on the existing cap to provide a suitable base
for the low-permeability layer above and to cover any protruding
construction debris. This layer will also protect the layers
above from puncturing.
Dike
•
The dike will be designed, constructed, operated, and maintained
to provide flood protection for the cap and to prevent washout of
the lagoon. See Figure 3. The dike will have less than a 3 to 1
FIGURE 3
CONCEPTUAL DESIGN SECTION
DIKE SLOPE PROTECTION
CltiTMC VCOrTATKM
CUT TO MOUND
KIT TftCNCM
CIISTIMQ
•MOUtt *JftF«CC
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ROD DECISION SUMMARY Page 24
Yaworski I^aoon site
slope. The vegetation on the existing dike will be cut close to
the ground surface and the cover system will be extended over the
existing dike and anchored in a key trench. A gravel blanket and
geotextile will be placed on the cover. Finally, riprap will be
placed on the geotextile and extended into the key trench at the
base of the dike slope.
The final riprap-covered dike will be designed to withstand a
water velocity of at least 15 feet/second. This will ensure that
it can withstand at least a 100-year flood event.
Quality Control and Assurance
During the design of the cover and dike, a quality control plan
will be developed. The plan will ensure that the specification
for each of the components of the cover and dike are met.
Appropriate testing and observations will be included.
2. Establishing Alternate Concentration Limits (ACLs)
as the Ground Water Protection Standard
EPA will set ACLs at the Yaworski Lagoon site. ACLs are ground
water protection standards that are used to assure that hazardous
constituents found in the ground water do not pose a risk to
human health or the environment. To ensure that ACLs remain
protective, the following conditions must continue to be met at
the site:
a. The Quinebaug River must remain a discharge point for ground
water from the site. If monitoring well clusters located on
the other side of the river from the lagoon show
contaminant levels above MCLs, the corrective action plan
will be implemented as outlined below.
b. The Quinebaug River cannot be adversely impacted by the
discharge of contaminated ground water into the river.
Presently no adverse impacts to the river have been observed
that can be attributed to the site. To ensure that future
impacts do not occur at the point of exposure for
environmental receptors in the river, seep meters and driven
monitoring points will be installed to measure the discharge
of contaminants to the river. Additionally, river water
will be sampled to ensure that there is no statistically
significant increase in contamination, as compared to up-
gradient locations.
c. The ground-water use restrictions outlined below must be
implemented and continued to ensure ground water within the
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ROD DECISION SUMMARY Page 25
Y avoirs lei. L^aoon site
meander is not consumed and the integrity of the Quinebaug
River as a hydraulic barrier to ground water flow is
maintained.
The specific provisions for setting the ACLs are outlined below.
ACL Contaminants and Concentrations
ACLs will be set for all contaminants found at the site that EPA
determines are representative of the most toxic, mobile, and
persistent chemicals found in ground water. The concentration
for each hazardous constituent will be set at the concentrations
found at the points of compliance at the site assuming that
aforementioned conditions continue to be met.
Point of Compliance
The point of compliance is the location where ACLs are set and
is also the well location were ACLs are monitored. At the point
of compliance, ACLs will be set at concentrations that ensure
that human health and the environment are protected at the point
of exposure and no statistically significant increase in
contamination occurs in the river.
The specific locations for the point of compliance monitoring
are around the boundary of the lagoon and are designated as well
clusters B, C, and G illustrated in Figure 4.
of Exposure
A point of exposure is a location where environmental or human
receptors may be exposed to or use ground water. Exposure to
ground water at that point of exposure cannot result in an
endangerment to human health or the environment. At the
Yaworski Lagoon site, the points of exposure will be set at the
interface of ground water and the Quinebaug River. They will be
monitored by seep meters and monitoring points along the east
bank of the Quinebaug River. The location of the seep meters and
monitoring points are adjacent to well clusters C, 6, I, F, and L
illustrated in Figure 4.
W Use Restrictions
Ground water use at the site will be restricted to ensure that
contaminated ground water is not consumed and the hydraulic
barrier that the Quinebaug River provides is not upset. Ground
water use will be restricted within the meander loop of the
-------
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01
o»
fi
5 21
O ffl
H. Ti
^^1
*^J
W W
S LI
f^ ^^i
EXISTING
HELL CLUSTER
FIGURE 4
WB1 AND WO! POMT LOCATIONS
YAWORSKISITI
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Yaworslei Ijiaoon site
Quinebaug; from the river to the Yaworski solid waste landfill;
and one hundred (100) feet outside of the river on the north,
vest, and south. South of the site, along the Quinebaug River
valley, production veils (i.e., greater than 50 gpm) vill be
restricted within 1500 feet of the site. These restrictions will
be implemented by the appropriate state and local authorities.
Ground Water Monitoring
Ground vater vill be monitored to ensure compliance with ACLs
and to meet the three conditions listed at the beginning of this
Subsection. Compliance monitoring vill be conducted quarterly
for ACL constituents or an approved subset of them at the point
of compliance veils. If a subset of the ACLs are used, an
analysis of all the constituents vill be conducted at least once
per year.
After the first time an ACL for a particular contaminant is
exceeded, the veil vill be resampled. If the second analysis
results in contaminant concentrations that still exceed the ACL,
EPA and Connecticut vill make a determination if the corrective
action program outlined belov vill be implemented.
At the point of exposure (i.e., at the interface of ground vater
and the Quinebaug River), ground vater discharging to the river
vill be monitored quarterly by seep meters and monitoring points
alone the east bank of the river.
Additionally, veil clusters A, M, L, F, I, M6, H, J, E and K
vill be monitored quarterly to ensure that the Quinebaug River
continues to act as a discharge point and hydrological barrier to
ground vater flov. The monitoring frequency of these veils may
be modified by EPA.
Surface Water and Sediment Monitoring
The surface vater and sediment from the Quinebaug River vill be
monitored quarterly to ensure that there is no statistically
significant increase in contamination due to the ground vater
recharge to the Quinebaug River. The river transects for this
monitoring are illustrated in Figure 4.
Corrective Action and Contingency Planning
In the event ACLs are exceeded, if any of the three conditions
outlined at the beginning of this Subsection are not met, or if
changes in receptors or conditions at or in the vicinity of
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ROD DECISION SUMMARY Page 28
ivoi
•the site occur prior to or after setting ACLs such that ACLs are
no longer protective of human health or the environment, a
corrective action program that meets the requirements of 40
C.F.R. § 264.100 will be implemented. As part of the design of
the remedial action, a corrective action contingency plan will be
developed. Under the corrective action program, contaminated
ground water will be extracted and treated or other necessary
action will be undertaken to reduce contaminant levels to ensure
that ACLs are not exceeded at the compliance point and that at
the point of exposure the remedy is protective of human health
and the environment.
If ground water needs to be treated at the site, different
process options, including a combination of treatment
technologies, will be considered during the design of the
treatment system. The process presented in the Feasibility Study
Report in Alternative # 4 is one possible process configuration
that could be utilized and was presented to serve as the basis
for costing and for comparison to other alternatives. During
design of the treatment system, the particular technology or
technologies will be chosen on the basis of performance goals
that EPA sets for the treatment system.
The proposed ground water extraction system in Alternative 4 is
intended to capture contaminated ground water that flows from the
site. The exact well locations will be further refined in the
development of the corrective action program.
3. Post-Closure Care
After final closure of the lagoon, the post-closure requirements
contained in 40 C.F.R. § 264.310 and 40 C.F.R. §§ 264.117 through
264.120 will be met. Specifically, the following actions will be
undertaken:
a. The integrity and effectiveness of the final cover will be
maintained, including making any repairs to the cap as
necessary, to correct the effects of settling, subsidence,
erosion, or other events.
b. The ground water monitoring system will be monitored and
maintained to comply with the requirements of 40 C.F.R. Part
264, Subpart F.
c. The site will be secured to meet the requirements of 40
C.F.R. S 264.14 during post-closure.
d. A written post-closure plan will be developed to meet the
requirements of 40 C.F.R. § 264.118.
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Yaworslci I^aoon si.tie
e. Post-closure notices that provide a record of the type,
location, and quantity of hazardous wastes disposed in the
lagoon will be submitted to the authority in Connecticut
with jurisdiction over local land use to meet the
requirements of 40 C.F.R. § 264.119.
Additionally, because hazardous substances will remain on-site,
EPA will reevaluate this site at least once every five years
after the commencement of the remedial action to assure that
human health and the environment continue to be protected.
ESTIMATED TIME FOR CONSTRUCTION: 2 years
ESTIMATED PERIOD OF OPERATION: 30 Years of Monitoring
ESTIMATED TOTAL COST AS PRESENTED IN TABLE 4: $ 2,976,000
B. Rationale for Selection of the Remedy
In accordance with Section 121 of CERCLA, to be considered as a
candidate for selection, an alternative must be protective of
human health and the environment and able to attain ARARs. At
the Yaworski Lagoon site, the concentrated, highly contaminated
sludge and contaminated debris covering the sludge limited the
number of viable remedial alternatives that could result in
protective remedies that attain ARARs. For source control, the
Agency was limited to a choice between alternatives that utilize
incineration as a principle element, alternatives based on
containing the lagoon wastes in-place, and minimal/no-action.
For ground water, attainment of ARARs requires that a ground
water protection standard be set at either Maximum Contaminant
Levels (MCLs), ACLs or at background levels. To meet the ground
water protection standard, ground water components, based on
setting ACLs without treatment or in conjunction with a ground
water treatment program, were added to the source control
alternatives.
Because Alternatives f 1 and f 2, the minimal/no-action
alternatives, are not protective and do not attain ARARs, they
were rejected from further consideration.
The remaining four alternatives, based on incinerating the wastes
or containing them in-place in combination with a ground water
component, meet the statutory requirements of protectiveness and
attainment of ARARs. To select among them, EPA focused on the
other evaluation criteria, including: short-term effectiveness,
long-term effectiveness, implementability, use of treatment to
permanently reduce the mobility, toxicity or volume of waste, and
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Yavorski Lagoon site
Table 4
COSTS FOR IMPROVED CAP AND DIKE WITH
AN ACL DEMONSTRATION FOR GROUNDWATER
Direct Capital Costs
Unit
Task Cost puantitv
1. Periaeter Fence $ 22/ft 2,800 ft $ 62,000
2. Install Wells $l,600/ea 8 ea 12,800
3. Install Piezoaeters $ 800/ea 9 ea 7,200
4. Rip-Rap/DiXe laproveaent $ 33/yd 9 ea 110,000
5. Monitoring Systea Design 15,000
6. Initial Saapling Prograa 102,000
7. Grade/Install Cap 1,002,600
8. Gas Venting System 12,000
9. Public Education 50,000
10. Aquifer Characterization 50,000
11. Developaent of ACLs 250.000
Total Direct Capital Costs $1,673,600
Indirect. Capital Costs
1. Engineering (15%) $ 251,000
2. Contingency (15%) 251,000
3. Adninistration (5%) 83.700
Total Indirect Capital Costs $ 585,700
Operation and Maintenance Costs
Cost Present Worth
TasV per Event Frequency fS%l for 30 vrs
1. Annual Site $ 2,000 annually $ 30,700
Inspection ft
Maintenance
2. Groundvater $36,000 annually $553,400
Monitoring
3. Continued Public $ 5,000 annually $ 76,900
Education
4. 5-year Site Review $20,000 every 5 yrs S ss.600
Total OtM Present Worth $716,600
TOTAL COST $2,976,000
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Yavorslci Lagoon site
cost. EPA also considered state and community acceptance. In
addition, a number of site specific conditions and/or features
played a critical role in shaping EPA's development of
alternatives and selection of the remedy. These conditions
and/or features included:
1. the location of the lagoon in a 100-year floodplain;
2. the action of the Quinebaug River to disperse and dilute
contaminants and to act as a hydrologic barrier;
3. the proximity of the Yaworski Lagoon to an active solid
waste landfill; and
4. the lithology of the aquifer in the river valley around the
lagoon, which limits the ability to develop a large volume
ground water extraction well.
Based upon this assessment, taking into account the statutory
preferences of CERCLA, EPA selected the remedial approach for the
site.
Capping and Diking •
Capping and diking will be effective and protective of human
health and the environment in the long-term. The cap and dike
system will address the risk posed by contaminants seeping
through the dikes into the wetlands and, at the same time,
decrease or eliminate the flushing of lagoon contaminants into
site ground water, thus providing a protective remedy. The
impermeable cap, by containing the waste in place and minimizing
the migration of rainwater through the lagoon, will reduce the
discharge of contaminated leachate away from the lagoon and
contaminant loading to ground water. The cap and dike system
will also provide protection against 100-year flood events.
In contrast to the source control component of the selected
remedy. Alternatives f 1 and f 2, both of which would require
fencing to restrict access to the site, would not be protective
and would not attain ARARs. These alternatives do not address
threats from contaminated leachate seeps or potential impacts
from floods and would not meet ARARs for closure of the lagoon.
Capping and diking also can be easily implemented at the Yaworski
Lagoon site. These techniques are widely practiced methods for
lagoon closure and the protection of ground and surface water.
Materials for -the cap and dike are also readily available.
Capping and diking is estimated to take approximately two years
to implement.
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Yaworslci I^aoon site
Further, capping and diking will be effective in the short-term.
The relatively short duration of construction activities and the
fact that capping will not involve the excavation of the lagoon
materials will minimize the short-term impacts from exposure to
volatile emissions or contact with contaminated leachate. Any
erosion of surface soils into the wetlands as a result of grading
and preparation of the cap and dike system will be minimized
through the advent of erosion and sedimentation control measures.
In contrast to the selected remedy, Alternatives # 5 and I 6,
both of which would require incineration of the source material,
have the potential for significant air emissions during waste
excavation and present substantial problems associated with
siting a treatment facility and excavating large quantities of
contaminated wastes in a floodplain.
Finally, capping and diking is cost effective. Incineration of
the source material, which is the only source treatment
technology that would be both effective and implement able at the
site, is very expensive. Incineration is projected to cost
approximately $100 million dollars at the site.
The particular cap and dike configuration presented follows
EPA's guidance, "Covers for Uncontrolled Hazardous Waste Sites,"
(EPA/540/2-85/002) and takes into account site-specific
conditions to ensure protectiveness. The guidance was used
because it ensures that the configuration of the cap and dike
will meet the RCRA requirements under 40 C.F.R. § 264.
Ground Water Protection Standard
Under RCRA regulations, the ground water protection standard
establishes a safe level of contamination in ground water in the
vicinity of a waste disposal site. Under these regulations, the
protection standard can be set at MCLs, ACLs, or at background
levels. EPA has established ACLs, as the ground water protection
standard for the site. Specifically, EPA has determined that
ACLs are the relevant and appropriate ground water protection
standard for the Yaworski Lagoon site for the following reasons.
ACLs are based on the premise that, although ground water is
contaminated around a waste disposal site, at a point where a
potential receptor may come into contact with ground water,
levels of contaminants are not found at unsafe levels. At
locations where exposure to ground water may not be safe,
enforceable controls to prevent exposure are implemented. At the
Yaworski Lagoon site, that basic premise is satisfied. Ground
water around the site is contaminated, however, the river and
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Yaworski Laaoon site
other site features contain and attenuate contamination in the
ground water to protective levels and enforceable controls can be
implemented.
In addition to the RCRA requirements, under Section
121(d)(2)(B)(ii) Of CERCLA, 42 U.S.C. § 9612(d)(2)(B)(ii), EPA
may not establish ACLs as the ground water protection standard
for a Superfund site if human exposure to hazardous constituents
will occur beyond the site boundary (as that boundary is defined
in the RI/FS), unless EPA had determined that:
there are known or projected points where .the ground
water will enter into the surface water;
there is or will be no statistically significant
increase in the level of hazardous constituents in the
surface water at the points of entry or at any point
where there is reason to believe accumulation of
constituents may occur downstream; and
the remedial action includes enforceable remedial
measures to preclude human exposure to ground water
between the site boundary and all known or projected
points of entry.
The RCRA requirements and the CERCLA prerequisites for an ACL are
met at the Yaworski site because of the following reasons:
1. The ground water characterization study in the supplemental
Remedial Investigation concluded The Quinebaug River is a
hydraulic barrier. Contaminated ground water from the site
is contained in the river meander and discharges into the
river. Thus, there are known or projected points where
site ground water will enter into the Quinebaug River.
2. Sampling and analysis conducted by EPA indicates that the
Quinebaug River acts as a hydrologic barrier that will tend
to dilute and disperse contaminants. Sampling also
indicates that, although levels of metals exceed Ambient
Water Quality Criteria in the Quinebaug River meander, these
levels are generally no higher than background levels
upstream or downstream from the lagoon. Thus, there will be
no statistically significant increase in hazardous
constituents entering or accumulating downstream in the
Quinebaug River.
3. Ground water that is contaminated by the site is not
currently used as a source of drinking water. The
Connecticut Public Health Code will be used to ensure that
ground water within the river meander around the site is not
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ROD DECISION SUMMARY Page 34
Yavorslei I^aaoon site
consumed. Additionally, this authority will be used to
restrict large volume production veils that could pull
contaminated ground water from the river meander. These
actions will preclude human exposure to ground water between
the site boundary and all known or projected points of
exposure.
4. Because the impermeable cap will prevent infiltration of
rainwater into the waste lagoon, flushing of lagoon
contaminants into ground water will be significantly
decreased.
5. The setting of ACLs for individual contaminants at the
points of compliance will ensure that human and
environmental receptors are not exposed to unsafe levels of
contaminants at the points of exposure. In the event an ACL
for an individual contaminant is exceeded, corrective action
at the site will be implemented consistent with Section
X.A.2. Thus, the setting of ACLs provides EPA and the State
of Connecticut with an enforceable mechanism that sets into
motion corrective action.
ACLs will be effective and protective of human health and the
environment in the long-term. Although the development of ACLs
as the ground water protection standard will not reduce
contaminants in ground water, their development will ensure
protection of public health and the environment at each and every
point of exposure. Further, the corrective action program will
ensure that the remedy continues to be effective. Alternative i
4, which calls for pumping and treating ground water in addition
to the implementation of the cap and dike system, may be no more
protective than selected remedy because ground water beneath the
lagoon could never be cleaned up to drinking water standards.
However, pumping and treating ground water may be implemented
under the corrective action plan to ensure that ACLs are not
exceeded.
Developing ACLs for site contaminants can be implemented at the
Yaworski Lagoon site. The construction, installation, and
sampling of monitoring wells is a common practice at CERCLA
sites. Little difficulty would be expected in securing the
services of an experienced and qualified firm to install and
sample monitoring wells. Implementation of this alternative
would require institutional controls to restrict land and ground
water use. Deed restrictions and/or land-use controls are
mechanisms that can be easily put into place with the cooperation
of the Connecticut Department of Public Health. ACL and
institutional -oontrol implementation is expected to take
approximately two years.
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Yaworski Lagoon site
Community reaction to the selected remedy was mixed; although
some members supported the Agency's approach, the majority
preferred either off-site disposal or incineration.
Off-site disposal without treatment was not carried through
detailed analysis in the Feasibility Study because it would be
difficult to implement due to the RCRA land disposal restrictions
governing untreated solvent-containing waste. Moreover, it
would be difficult to locate a RCRA-permitted facility willing to
accept untreated waste from the Yaworski Lagoon site. Off-site
incineration was not carried through to detailed analysis because
it would be difficult to implement in light of the low operating
capacities of existing off-site facilities. Finally,
incineration is very expensive.
Summaries of the public's comments on the Feasibility Study
Report and the Proposed Plan and EPA's response to those
comments can be found in the Responsiveness Summary, which is
attached as Appendix A.
The State of Connecticut concurs in the selection of the remedy.
The State's role in the selection process is addressed in Section
XII.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Yaworski
Lagoon site is consistent with CERCLA and, to the extent
practicable, the NCP. The selected remedy is protective of human
health and the environment, attains ARARs, and is cost effective.
The selected remedy does not, however, satisfy the statutory
preference for treatment which reduces the mobility, toxicity, or
volume of waste as a principal element. Nevertheless, given
site-specific waste types and quantities and geographic
features, the selected remedy utilizes permanent solutions and
alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
From the risk assessment, EPA concluded that contaminants
seeping through the present lagoon dikes into the wetlands pose a
risk to environmental receptors. EPA also concluded that if
ground water were to be used as a source of drinking water, it
would pose a threat to human health. The selected remedy
specifically addresses these risks.
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ROD DECISION SUMMARY Page 36
site
Because the impermeable cap prevents the infiltration of
rainwater into the waste lagoon, flushing of lagoon contaminants
into the ground water will be significantly decreased. Moreover,
the advent of institutional land use controls at the site, such
as deed restrictions and zoning changes, will prevent the
consumption of ground water at the site.
Sampling and analysis conducted by EPA indicates that the
Quinebaug River acts as a hydrologic barrier and dilutes and
disperses contaminants. Thus, setting contaminant levels in the
Quinebaug River at the ACL of individual contaminants is
appropriate and is consistent with the prerequisites of Section
121 of CERCLA. These levels will ensure that human and
environmental receptors are not exposed to unsafe levels of
contaminants in the river. The setting of ACLs also provides EPA
and the State of Connecticut with an enforceable mechanism that
will trigger corrective action at the site consistent with
Section X.A.2. in the event those levels are exceeded.
In yrf^it j^n to decreasing contaminant loading to ground water,
the cap will contain the waste in place, thus eliminating the
threat to environmental receptors of being exposed to
contaminated leachate. The dike system, in conjunction with the
cap, will also provide protection to both human and environmental
receptors from 100-year flood events.
In sum, EPA has determined that the selected remedy at this site
is protective of human health and the environment.
B. The Selected Remedy Attains ARARs
The selected remedy will attain all applicable or relevant and
appropriate federal and state environmental requirements at the
site. Federal environmental laws that are applicable or relevant
and appropriate to the selected remedial action at the Yaworski
lagoon site include the:
1. Resource Conservation and Recovery Act (RCRA) ;
2 . Clean Water Act ( CWA) ;
3. Clean Air Act (CAA) ;
4 . Safe Drinking Water Act (SDWA) ;
5 . Occupational Safety and Health Act (OSHA) ;
6. Executive Order 11988 (Floodplain Management); and
7. Executive Order 11990 (Protection of Wetlands)
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ROD DECISION SUMMARY Page 37
Yavorslci Lagoon site
State environmental laws that are applicable or relevant and
appropriate to the selected remedial action at the site are:
1. Connecticut Water Quality Standards and Classifications;
2. Connecticut Standards for Quality of Public
Drinking Water;
3. Connecticut Hazardous Waste Facility Siting Rules;
4. Connecticut Hazardous Waste Management Regulations;
5. Connecticut Inland Wetland and Water Courses
Regulations; and
6. Connecticut Public Health Code
Table 5 provides a synopsis of the applicable or relevant and
appropriate requirements for the selected remedy. A discussion
of how the selected remedy meets those requirements follows.
Lagoon Closure in a Floodplain
The applicable or relevant and appropriate requirements for the
closure of the lagoon are regulations promulgated pursuant to the
Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6901
et seq., Executive Order 11988 (Floodplain Management), the
Connecticut Hazardous Waste Facility Siting Rules, Title 22a, and
the Connecticut Hazardous Waste Management Regulations.
The cover will be designed and constructed to meet RCRA closure
requirements found at 40 C.F.R. S 264.310 and the Connecticut
Hazardous Waste Management Regulations and Facility Siting Rules.
Because the lagoon is situated in the floodplain, the cover and
dike will be designed, constructed, and maintained to prevent
washout from a 100-year flood event as required by 40 C.F.R §
264.18. Moreover, the cap and dike system will be designed so as
to minimize the potential for harm to or within the floodplain
consistent with the Floodplains Executive Order and 40 C.F.R.
Part 6. EPA has determined that constructing the cap and dike
system in the floodplain is the only practicable alternative
consistent with the law and policy set forth in the Executive
Order.
Ground Water
RCRA ground water protection standards (GWPS), 40 C.F.R. Part
264, Subpart F, are established for constituents entering ground
water from a regulated hazardous waste unit. Although RCRA is
not applicable to the Yaworski Lagoon site, the waste lagoon
presents problems that are similar to those that the requirements
address, and thus, the requirements are relevant and appropriate.
GWPS under the RCRA regulations are set at MCLs, ACLs, or at
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ROD DECISION SUMMARY Page 38
Yavorski Laaoon si tie
background levels. Because the Quinebaug River acts as a
hydrologic barrier for site ground water, EPA has determined that
ACLs are the relevant and appropriate standards at the Yaworski
Lagoon site.
Beyond the Quinebaug River meander, where ground water exposure
may occur, Connecticut Standards for Quality of Public Drinking
Water, which set allowable levels for the ingestion of benzene
and 1,2-dichloroethane that are more stringent than federal
requirements; Ambient Water Quality Criteria promulgated
pursuant to the Clean Water Act; and MCLs4 promulgated pursuant
to the Safe Drinking Water Act are ARARs. These standards are
relevant and appropriate for ground water at the point where
exposure to ground water may occur. ACLs will be set to ensure
that these requirements are met beyond the Quinebaug River
meander. In addition, EPA Risk Reference Doses (RfDs),
Carcinogen Assessment Group Potency Factors, and Interim Sediment
Criteria Values will be considered in the development of ACLs.
As part of the process to establish ACLs as the ground water
protection standard, ground water use at the Yaworski Lagoon
site will be restricted to ensure that contaminated ground water
is not consumed. The Connecticut Public Health Code provides the
authority to permit the construction of ground water wells that
are used for potable water. This applicable requirement will be
used to ensure that ground water within the Quinebaug River
meander around the site is not consumed. Additionally, this
authority will be used to ensure that large volume ground water
extraction wells, which could prevent the river from acting as a
hydrological barrier, are not installed within 1500 feet of the
site.
4 Maximum Contaminant Level Goals (MCLGs) established under
•the Safe Drinking Water Act are not relevant and appropriate at
the Yaworski Lagoon site. MCLGs are only considered when a site
poses extraordinary risks through multiple contaminants and/or
exposure pathways. These extraordinary conditions do not exist
at the Yaworski Lagoon site. Moreover, MCLs provide legally
enforceable standards for drinking water that are protective of
public health and the environment and are set as close to MCLGs
as feasible taking into consideration best technology, treatment
techniques, and other factors. See letter dated May 21, 1987
from Lee M. Thomas, Administrator, United States Environmental
Protection Agency to Honorable James J. Florio, Chairman,
Subcommittee on Commerce, Consumer Protection and
Competitiveness, House Committee on Energy and Commerce.
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Yaworski La croon site
Surface Water
The Connecticut Water Quality Standards and Classifications
provide regulatory criteria for maintaining the quality of
surface waters. The Quinebaug River is classified as "B";
suitable for recreation, agricultural purposes, certain
industrial processes, fish and wildlife, and aesthetic value.
Parameters regulated for Class B waters are aesthetics, dissolved
oxygen, sludge deposits, silt or sand deposits, turbidity,
collform bacteria, taste and odor, temperature, discharges, and
benthic invertebrates. The selected remedial action is in
accordance with the standards for Class B surface waters.
Wetlands
During the identification, development, and screening of
alternatives, EPA considered each alternative's impact on
wetlands in accordance with Section 404 of the Clean Water Act,
33 U.S.C. § 1344, and the Connecticut Inland Wetland and Water
Courses Regulations, Title 22a. By minimizing and/or eliminating
the discharge of leachate from the waste lagoon, the selected
remedy addresses the primary threat to the site wetlands, and
thus, complies with 40 C.F.R. Part 6 and the Wetlands Executive
Order 11990, which require CERCLA response actions to minimize
harm to wetlands. EPA has determined that constructing the cap
and dike next to the wetland is the only practicable alternative
consistent with the law and policy set forth in the Executive
Order and EPA regulation.
Air
The construction of the cover for the site will not involve the
excavation of any waste materials and, therefore, hazardous air
pollutants will not be emitted. During this construction phase,
however, the National Ambient Air Quality Standards for total
suspended particulate (dust) set under the Clean Air Act are
applicable.
OSHA
All applicable safety and health requirements established under
the Occupational Safety and Health Act will be met for the
construction of the cover, installation of wells, and for any
other remedial activities.
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Yavorski Lagoon site
Post-closure care
After closure of the lagoon the relevant and appropriate post-
closure requirements of 40 C.F.R. §§ 264.14, 264.117 - 264.120,
and 264.310 will be net. Monitoring of ground water will be
conducted in accordance with the relevant and appropriate RCRA
ground water monitoring requirements under 40 C.F.R. Part 264,
Subpart F.
Corrective Action and Contingency Planning
In the event that additional remedial activities are required, as
described in Section X, these activities will attain all ARARs.
These remedial activities will be conducted in accordance with
the relevant and appropriate corrective action regulations, 40
C.F.R. § 264.100. The other ARARs for these activities are
discussed in the analysis of Alternative # 4 in Chapter 10 of the
Feasibility Study Report.
C. The Selected Remedial Action is Cost Effective and
Utilizes Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
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. Because the two alternatives that cost
less than the selected remedy are not protective, they were
eliminated from further consideration.
For each alternative a detailed estimate of present-worth costs
with an accuracy of -30 to +50 percent was developed. Capital
and operation and maintenance costs were estimated for each
alternative assuming thirty (30) years of operation and
maintenance using a five (5%) percent interest rate. These costs
were then converted to 1988 dollars through a present-worth
analysis.
In the course of conducting the Remedial Investigations and the
Feasibility Study, EPA evaluated a range of waste treatment
technologies at the site, including various in-situ,
solidification, and incineration technologies. Because of the
quantity of waste in the lagoon and the very high level of
contaminants in the waste, all of the technologies other than
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YavorsJci Laaoon site
Page 41
Table 5 - ARARs
REQUIREMENT
REQUIREMENT SYNOPSIS/CONSIDERATION
RCRA Closure
Regulations, 40
C.F.R. § 264.310
Connecticut Hazardous
Waste Management
Regulations,
promulgated pursuant
to Connecticut
General Statutes
(CGS), § 22a-449(c)
Connecticut Hazardous
Waste Facility Siting
Rules, promulgated
pursuant to CGS §§
22a-116-122
RCRA Location
Regulations, 40
C.F.R. S 264.18
Executive Order 11988
and EPA Regulation,
40 C.F.R. Part 6
RCRA Ground water
Protection Standards,
40 C.F.R. Part 264,
Subpart F
Federal Ambient Water
Quality Criteria
(AWQC)
The cap will be designed and constructed
to meet these relevant and appropriate
regulations.
These regulations outline general
requirements for the management of
hazardous waste facilities in
Connecticut. The cap and dike will be
designed and constructed to meet these
relevant and appropriate requirements.
These rules specify siting and location
requirements for the construction of
hazardous waste facilities. The cap and
dike will be constructed to meet these
relevant and appropriate rules.
The cap and dike will be designed,
constructed, and maintained to prevent
washout by a 100-year flood in
accordance with this relevant and
appropriate regulation.
The Floodplains Management Executive
Order and this EPA regulation are
applicable and were weighed in the
evaluation and development of remedial
alternatives. The cap and dike system
will be constructed in such a manner to
avoid or minimize adverse impacts to the
floodplain because no practicable
alternative exists.
Setting ACLs as the ground water
protection standards for the site meets
these relevant and appropriate
regulations.
AWQC are health-based criteria developed
for 95 carcinogen and non-carcinogens.
AWQC are relevant and appropriate
requirements for ground water at the
point of exposure.
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Yaworski Laaoon site
Page 42
Table 5 - ARARS Continued
REQUIREMENT
REQUIREMENT SYNOPSIS/CONSIDERATION
Safe Drinking Hater
Act regulations
establishing Maximum
Contaminant Levels
(MCLs), 40 C.F.R.
Part 141, Subpart B
EPA Risk Reference
Doses (RfDs)
Carcinogen Group
Potency Factors
Federal Interim
Sediment Criteria
Values
Connecticut Standards
for Quality of Public
Drinking Hater,
promulgated pursuant
to COS S 19a-37
Connecticut Public
Health Code,
promulgated pursuant
to CGS § 19a-36
These regulations establish contaminant
concentration levels in public drinking
water. They are relevant and
appropriate at the site at the point of
exposure.
RfDs are dose levels of non-carcinogens
developed by EPA. RFDs will be
considered in the development of ACLs.
These factors are used to compute
individual incremental cancer risk
resulting from exposure to carcinogens.
They will be considered in the
development of ACLs.
These criteria will be considered during
the development of ACLs. These interim
health-based criteria are used to
characterize risk to aquatic life.
These standards regulate contaminant
concentration in drinking water.
Connecticut standards for benzene and
1,2 dichloroethane are relevant and
appropriate at the point of exposure
because they are more stringent than
SDHA MCLs.
This law provides the Connecticut
Department of Health with permit
authority over wells supplying potable
water. This applicable law will allow
Connecticut to apply enforceable
controls to restrict ground water use
within one mile of the site.
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Yaworski Laaoon site
Page 43
Table 5 - ARARs Continued
REQUIREMENT
REQUIREMENT SYNOPSIS/CONSIDERATION
Connecticut Water
Quality Standards and
Classifications,
promulgated pursuant
to CGS § 22a-426
Section 404 of the
Clean Water Act, 33
U.S.C. § 1344 and 40
C.F.R. Part 230
Connecticut Inland
Wetland and Water
Courses Regulations,
promulgated pursuant
to CGS § 22a-30
Executive Order 11990
and EPA Regulation,
40 C.F.R. Part 6
National Ambient Air
Quality Standards
(NAAQS), 40 C.F.R. §
50.6, promulgated
pursuant to the Clean
Air Act.
These standards, which are applicable,
provide criteria for classifying and
maintaining the quality of surface
water. Chemicals released to Quinebaug
River must not degrade its designated
quality, Class B.
Under this applicable law and
regulation, no activity that adversely
affects a wetland is permitted if a
practicable alternative exists. The law
and regulation were weighed during the
evaluation of alternatives. The design
of the cap and dike system shall be in
accordance therewith.
These Regulations limit activities that
deposit material in, alter, or pollute
wetlands, and thus, they were weighed
during the evaluation of alternatives.
The cap and dike system will be designed
and constructed in accordance with these
applicable regulations.
The Protection of Wetlands Executive
Order and this EPA regulation are
applicable and were weighed in the
evaluation and development of remedial
alternatives. The cap and dike system
will be constructed in such a manner to
avoid or minimize the destruction, loss,
and degradation of site wetlands and to
preserve and enhance the natural and
beneficial uses of the wetlands.
This regulation outlines the maximum
primary and secondary 24-hour
concentrations for particulate matter.
This regulation is applicable during
construction of the remedial action.
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ROD DECISION SUMMARY
Yaworski Laaoon site
Page 44
Table 5 - ARARs Continued
REQUIREMENT
REQUIREMENT SYNOPSIS/CONSIDERATION
Worker safety
regulations, 29
C.F.R. Part 1910,
promulgated pursuant
to the Occupational
Safety and Health Act
RCRA Post-closure
Regulations, 40
C.F.R. §§ 264.117 -
264.120, and 264.310,
and Part 264, Subpart
F.
RCRA Corrective
Action Regulations,
40 C.F.R. § 264.100
These applicable regulations contain
safety and health standards that will be
met during all remedial activities,
including, construction of the cover and
installation of monitoring wells.
These regulations are relevant and
appropriate after closure of the
lagoon. These regulations include
provisions for development of a post-
closure plan, reporting, and groundwater
monitoring.
This relevant and appropriate regulation
specifies activities that must be
undertaken if corrective action becomes
necessary at the site.
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ROD DECISION SUMMARY Page 45
Yaworslci I*iaoon site
incineration are either not implementable and/or effective, and
thus, not practicable. See Section 9.2.4 of the Feasibility
Study Report. Although incineration would be protective of human
health and the environment, and could potentially be
implementable, alternatives that include incineration of the
source material were rejected because of the costs of
incineration and the short-term impacts associated with
implementation of incineration alternatives. Thus, source
control treatment was rejected at the site because treatment
alternatives were either not cost effective or not practicable.
The development of ACLs as the ground water protection standard
at the site will be protective because ground water contamination
is contained within the Quinebaug River meander and the contained
ground water recharges to the river. To prevent the exposure to
ground water contained within the river meander, enforceable
measures to restrict ground water consumption at the site can be
implemented. Treatment of ground water is not necessary to
assure protectiveness as long as it is demonstrated that no
statistically significant increase in contaminants entering or
accumulating downstream in the river is occurring.
Moreover, it is technically infeasible to achieve drinking water
standards at the Yaworski Lagoon site without treatment of the
waste in the lagoon. Alternative I 4, which calls for ground
water treatment to be implemented initially as part of the
alternative, rather than as a corrective action measure, is thus,
not practicable. If and when corrective action measures are
implemented, positive results would be expected from
implementation of a ground water treatment system. Such a system
would impart significant benefit to the ground water quality and
reduce loading of contaminants to the Quinebaug River, thus
rendering the system practicable.
Thus, EPA has determined that the selected remedy is cost
effective and utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable.
D. The Selected Remedy does not Satisfy the Preference for
Treatment as a Principal Element
The selected remedy does not include treatment and thus does not
satisfy the preference for treatment as a principal element.
Treatment-based alternatives were because treatment is not cost-
effective or practicable. For an elaboration on those
considerations, see Section XI, Subsections C.
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ROD DECISION SUMMARY Page 46
Yaworslci L^aoon si'he
XII. STATE ROUE
The Connecticut Department of Environmental Protection has
reviewed the various alternatives and has indicated its support
for the selected remedy. The State of Connecticut has also
reviewed the Remedial Investigation Report, the Public Health and
Environmental Risk Evaluation, and the Feasibility Study Report
to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State environmental laws
and regulations. On the basis of these analyses, the State of
Connecticut concurs with the selected remedy for the Yaworski
Lagoon site. A copy of the declaration of concurrence is
attached as Appendix C.
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RECORD OF DECISION
YAWORSKI LAGOON SITE
APPENDIX A
RESPONSIVENESS SUMMARY
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TABLE OF CONTENTS
Page
PREFACE 1
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 2
A. Site
Description 2
B. Community Awareness of the Yavorski Lagoon site.....2
C. Concerns 3
Figure 1. Yavorski Lagoon site Location Map 3-1
II. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES 5
A. Summary of Citizen Comments 5
1. Comments Concerning the Cap 5
2. Comments Regarding the Testing of Groundwater
and Alternate Concentration Limits 10
3. Costs, Liability, and Enforcement Issues 14
4. Risks Posed To Human Health and the
Environment 16
5. Community Relations Issues 18
6. Other Issues 20
B. Summary of Potentially Responsible Party (PRP)
Comments 23
1. Comments on the Remedial Investigation 23
2. Comments on the Feasibility Study 24
III. REMAINING CONCERNS 26
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE YAWORSKI LAGOON SITE 27
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Preface
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 28, 1988 to August 24, 1988 to provide
an opportunity for interested parties to comment on the July 1988
Feasibility Study (FS) and Proposed Plan for the Yaworski Lagoon
Superfund site in Canterbury, Connecticut. The FS examines and
evaluates various options, called remedial alternatives, for
addressing contamination in the lagoon area. EPA identified its
preferred alternative for the cleanup of the site in the Proposed
Plan that was issued before the start of the public comment
period.
This responsiveness summary identifies the significant
comments raised during the public comment period, and provides
EPA responses to the comments. EPA will consider all of the
comments summarized in this document before selecting a final
remedial alternative for the Yaworski Lagoon Superfund site.
This responsiveness summary is divided into the following
sections:
I. Background on Community Involvement and Concerns - This
section provides a brief history of community interests
and concerns regarding the Yaworski Lagoon site.
II. Summary of Comments Received During the Public Comment
Period and EPA Responses - This section summarizes and
provides EPA responses to the written and oral comments
received by EPA from the public during the public
comment period.
III. Remaining Concerns - This section describes issues that
may continue to be of concern to the community during
the design and implementation of EPA's selected remedy
for the Yaworski Lagoon site. EPA will address these
concerns during the Remedial Design and Remedial Action
(RD/RA) phase of the cleanup process.
Attachment A - This attachment provides a list of the
community relations activities conducted by EPA to date at
the Yaworski Lagoon site.
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I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
A. Site Description
The Yavorski Lagoon site is located on approximately 100
acres of land in Canterbury Township, Windham County,
Connecticut. The site consists of a former liquid and industrial
waste disposal lagoon situated in a meander loop on the
floodplain of the Quinebaug River. Approximately 2000 feet
southeast of the lagoon is an operating solid waste landfill
owned by the Yaworski family, the same individuals who operated
the Yaworski Lagoon. (Refer to Figure 1). In the past, a
portion of the adjacent floodplain east and south of the lagoon
was used to cultivate silage corn. The remaining area adjacent
to the lagoon is composed of wetlands. The nearest residence is
approximately 1/2 mile to the west. Plainfield, the nearest
adjacent town, is located 3 miles to the east.
Between 1950 and 1973, sludge materials and drums of
industrial waste including solvents, paints, textile dyes, acids,
resins, and other debris were disposed in the lagoon, which
measures approximately 700 feet long by 300 feet wide. Flammable
waste was burned periodically at the site until 1965, when the
Connecticut Department of Health ordered a halt to the on-site
burning of waste. All disposal operations ceased in 1973. By
order of the State, the lagoon was subsequently covered by Mr.
Yaworski with paper, rags, rubble, and soil. After a fire
occurred at the site in 1982, EPA concluded that additional
information was needed about the site to better access the
potential threat to human health and the environment. In 1984,
the site was added to the National Priorities List (NPL) , EPA's
list of top priority hazardous waste sites, thus making the site
eligible for investigation and cleanup under the federal
Superfund program. EPA completed the first of the two Remedial
Investigations (RI) in April 1986. In 1987 and in the spring of
1988, additional work was conducted to further define the nature
and extent of contamination. As a result of this work, the
second or supplemental RI was completed in July 1988. The
Feasibility Study (FS), which contains the development and
analysis of remedial alternatives, was completed along with the
second RI in July 1988.
B. Community Awareness of the Yaworski Lagoon site
Community awareness generated by past and present activities
at the Yaworski Lagoon site has been high. When the site was
added to the NPL in 1984, an active local community group called
Committee of Correspondence, which was involved in halting an
interstate highway in the area, was invited to join the Eastern
Connecticut Citizens Action Group (ECCAG). ECCAG, which covers
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areas east of the Connecticut River, is part of a State-vide
citizens organization. Even before the site was placed on the
NPL, members of ECCAG and other local citizens believed that the
State's plan to cover the lagoon was an inadequate solution for
the problems at the Yaworski Lagoon, especially after the fire
that occurred in 1982. When EPA placed the'site on the NPL,
media coverage was extensive.
C. Concerns
This section summarizes concerns expressed at the FS public
informational meeting held on July 27, 1988 and at the public
hearing held on August 17, 1988.
1. Concerns Relating to the Capping Component of the Proposed
Plan
Community members expressed concern regarding EPA's Proposed
Plan to cover the lagoon. Instead, some residents would
prefer to see the waste excavated and either burned on-site
or taken off-site. Many residents have stated their belief
that flooding of the area would damage the cap and cause
further pollution of the Quinebaug River and surrounding
wetlands. Residents have also expressed concern that the
cap would not address waste that is being left in the
lagoon, and that this waste would continue to cause ground
water contamination.
2. Concerns Relating to Ground Water Contamination and EPA's
Proposal to Set Alternate Concentration Limits fACLs)
At the public meeting many residents expressed their
concern about whether contamination from the Yaworski Lagoon
site may have affected their drinking water wells. In
response to these concerns, EPA sampled domestic wells along
Packer Road just prior to the public hearing and found no
contamination. As a result of these findings, citizens
asked less questions at the public hearing than at the
public meeting, although one citizen expressed skepticism
about EPA's results.
Residents have asked EPA how an ACL demonstration would be
implemented and whether establishing ACLs would ever make
ground water drinkable.
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4
3. Risks to Human Health and the Environment
Many citizens have expressed concern about contamination
from the lagoon entering the River and the wetlands and
posing risks to wildlife in these areas, *s well as risks to
people who swim or fish in the River.
4. Cost and Enforcement
Citizens stated that cost should not be a factor in EPA's
decision-making process for choosing a remedy for the site
and that the potentially responsible parties (PRPs) should
be liable for all current, as well as future cleanup costs
at the site.
5. Yaworski Landfill
A number of citizens commented on the Yaworski Landfill that
is located near the site. At the public meetings,
residents stated that the Yaworski Landfill probably
contains hazardous materials and is just as much a threat
to the environment as the lagoon. Residents stated that
EPA should include the landfill in their investigations.
The landfill, however, is not part of the Yaworski Lagoon
Superfund site and is also not the subject of this cleanup
decision. Questions regarding the landfill should be
directed to the CT DEP.
6. Extension of Comment Period
During the presentation of oral comments, and during the
question and answer period that followed during the August
17, 1988 public hearing, several citizens requested that
EPA extend the comment period. Citizens indicated that more
people should be notified and provided with the opportunity
to comment on EPA's Proposed Plan.
7. EPA's Decision-Making Schedule
Citizens at the August 17, 1988 public hearing expressed
their belief that they should have a chance to respond to
EPA's selection of a remedy for the site, before that
decision is final.
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II. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This responsiveness summary addresses the comments received
by EPA on the Feasibility Study and Proposed Plan for the
Yaworski Superfund site in Canterbury, Connecticut, during the
public comment period held by EPA from July 28, 1988 to August
24, 1988. Five written comments were received. In addition,
sixteen people presented oral comments at the August 17, 1988
public hearing. Copies of the hearing transcript are available
at the information repositories located at the Canterbury Public
Library, and the EPA Records Center at 90 Canal Street, First
Floor, in Boston, Massachusetts. The written and oral comments
are summarized and organized into the following categories:
A. Summary of Citizen Comments
B. Summary of Potentially Responsible Party (PRP) Comments
EPA responses are provided for each comment, or set of like
comments.
A. Summary of Citizen Comments
1. Comments Concerning the Cap
a. Objections to the Cap
Comment 1; Many people that attended the public hearing do
not support the capping component of the preferred
alternative and would prefer that the lagoon contents be
removed and either incinerated or taken off-site.
EPA Response; EPA evaluated a range of alternatives that,
in addition to the selected remedy, included removing and
incinerating the waste. Removing the waste from the site
was rejected because it would be very difficult to
implement. Off-site disposal without treatment would have
to comply with the stringent Resource Conservation and
Recovery Act (RCRA) land disposal restrictions. Moreover,
it would be very difficult to locate a RCRA-permitted
facility that would be willing to accept untreated waste
from the site. Off-site incineration was rejected due to
the low operating capacity at existing off-site facilities.
On-site incineration alternatives were also considered.
They were not selected because they would be difficult to
implement, may result in adverse short-term impacts when the
wastes were excavated and are very costly.
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Comment 2; Several commenters questioned how EPA could
prove that contamination would not continue to leach into
the environment over time and expressed concern about the
problems that this contamination would present to future
generations.
EPA Response; An evaluation of how contamination leached
from the lagoon was completed and summarized in the
supplemental Remedial Investigation. EPA concluded that the
impermeable cover will stop rain from washing through the
waste and will minimize contamination leaving the lagoon and
provide a long-term, protective remedy.
Comment 3; Another resident remarked that capping the
lagoon is a "cop-out", and that just because the lagoon
would be covered up does not mean people would forget that
it exists. He stated his belief that Canterbury is being
treated unfairly, and that if Canterbury were a community
like Stratford or Stamford the waste would be moved off-
site.
EPA Response; Regardless of the size or location of the
community in which a site is located, the same remedy
evaluation and selection process is followed. Also, EPA is
not forgetting about the site. Part of the remedy for the
Yaworski Lagoon site includes evaluating the cleanup every
five years, as veil as providing routine maintenance and
monitoring to ensure the cap works properly and the ACLs are
not exceeded.
Comment 4; Another commenter asked that EPA remove the
waste and re-establish the River, the land, and the wetlands
to their original condition.
EPA Response; As discussed above, removing the waste from
the site was rejected because it would be very difficult to
implement. However, leaving the waste in place and properly
containing it with the impermeable cover will be protective
of the River, wetlands, and flora and fauna in the area.
Comment 5; Two additional commenters urged EPA to re-
evaluate possible cleanup solutions for the site and provide
a permanent solution.
EPA Response; EPA will not re-evaluate the cleanup plans
for the site, but will review the remedy every five years to
ensure protectiveness. The improved cap and dike and ACL
will result in a long-term, protective remedy.
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b. The Cap as an Interim Solution
Comment 6: Several commenters indicated that they felt
that capping should proceed as proposed, but that it should
be viewed as an interim solution. One commenter noted that
although he believes that the only solution to addressing
the contamination problem of the lagoon is to remove the
waste, he would like to see the cap constructed soon if it
will contain the waste.
EPA Response; The selected remedy is not an interim
solution. Improving the cap and dike, establishing ACLs and
providing long-term maintenance and monitoring at the site
is a long-term remedy. Removing the waste from the site
was rejected because it would be very difficult to
implement.
Comment 7; Another commenter stated his belief, that in
the short run, EPA should cap the lagoon. He expressed
concern that, if EPA selected the incineration alternative,
incineration would have to be conducted on site since there
is too much waste to truck to an off-site facility, and
that the five years it would take to burn the waste would
damage the environment, especially air quality. He proposed
that perhaps in a few years a new technology would be
developed which could be used to clean up the wastes in the
lagoon. Another commenter provided a similar comment,
asking how the public can be assured that when cost
effective technology does evolve that the proper actions are
taken at the Yaworski Lagoon site.
EPA Response; As discussed, alternatives other than the
selected remedy including removing the waste and
incinerating it were considered and were determined to not
be cost effective or practicable at the site. Although EPA
does not plan to re-evaluate the remedy, the Superfund law
requires EPA to review the remedy at the site every five
years to ensure protectiveness.
e. Impact of Cap on the River
Comment 8; One commenter stated that EPA and the
Connecticut Department of Environmental Protection (CT DEP)
believe that the cap is an acceptable alternative because
the Quinebaug River is polluted already. She argued that
EPA's decision to continue to let leachate seep into the
water should not be influenced by the fact that the River
already has contaminants in it from upstream. She stated
that EPA's goal should be to ensure the cleanup of the
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8
entire watershed. She expressed disagreement with what EPA
refers to as acceptable standards, and with EPA's approach
to minimize or reduce contamination. She stated her belief
that EPA should eliminate or put an end to site
contamination .
EPA Response; Regardless of the present water quality in
the Quinebaug River, the remedy was not selected because the
River is already polluted. The cap will greatly reduce
contamination that migrates from the lagoon and, along with
setting ACLs, ensure that the River water quality is not
adversely impacted.
Comments 9 & 10; Another commenter also objected to the
cap, noting that when she was a child, one could fish and
swim in the River and now one cannot even see the bottom. A
third commenter stated his belief that EPA plans to clean up
the French River, which is one of the main tributaries for
the Quinebaug River. He concluded that it would not make
sense to clean up one of the upstream rivers and then leave
the lagoon wastes in place, allowing pollution of the
Quinebaug.
EPA Response; ACLs, which will be set for ground water that
flows from the site into the River, will consider wildlife
in the River and the River's present and future uses. The
capped lagoon will not be allowed to adversely impact the
River. If adverse impacts to the River result from the
capped lagoon, a corrective action plan would be implemented
consistent with the Record of Decision and contaminated
ground water would be treated or other measures would be
taken to ensure protectiveness .
Comment 11; The commenter also questioned the impact on the
River of new incinerators being constructed in the area that
will use Quinebaug water for cooling processes.
EPA Response; New incinerators that use water from the
Quinebaug River are not the subject of this cleanup decision
and, therefore, are not addressed here.
d. Implementation Issues
12' Several commenters recalled the flood of 1955
and other floods through the years and argued that the cap
could not -withstand these floods. Several commenters argued
that flooding has caused contaminants to be washed
downstream and additional flooding would cause more
contaminants to be washed downstream. One commenter stated
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his belief that the lagoon has actually been flushed out
several times as a result of local flooding and asked EPA
for an estimate of the percent of the contaminants in the
lagoon that have been flushed out and how far downstream
these contaminants have gone.
EPA -Response; EPA considered the potential for flooding at
the site and incorporated this in the development,
evaluation, and selection of the remedy. The cap and dike
will be constructed to protect against flooding and washout.
As indicated, flooding in the past has contributed to
contaminant moving from the lagoon. Although an exact
estimate of how much waste has been flushed out by flooding
cannot be made, contaminant migration was recognized as a
problem and will be addressed by the selected remedy. Both
the cap and dike will be built to withstand water velocities
that could occur during floods.
Comment 13t One commenter asked what type of material would
be used to construct the cap and how long the liners of the
cap would last.
EPA Response: The cap will be made of five layers of
materials: a top vegetative cover to protect against erosion
and flood damage; a drainage layer to move rainwater off the
cap and away from the waste; two low-permeability layers (a
liner and a low-permeability soil layer) to stop rainfall
from flowing into the waste and; finally, a
foundation/bedding layer to support the layers above.
The liner will be made of a plastic that is very resistent
to chemicals. It should last at least 30 years. Also, it
will be maintained to ensure it continues to work after it
is installed.
14? One commenter asked whether the two-year
estimate for construction of Alternative I3 in the Proposed
Plan is for initiation or completion of the cap. He also
asked if the estimated $2,9 million covers the cost of
thirty years of monitoring and which agency would be
responsible for overseeing the monitoring.
EPA Response; The two-year estimate for construction of the
cap is from start to finish. The estimated cost of $2.9
million covers construction, maintenance costs and 30 years
of monitoring. If the governments conduct the remedy, CT
DEP will be responsible for overseeing both the monitoring
and any maintenance requirements beginning one year after
the cap has been installed.
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10
Comment 15; One commenter indicated that if EPA covers the
lagoon with a cap that is topped by dirt and vegetation, it
will look like a natural landscape and moles, mice, and
groundhogs would punch holes in the cap.
EPA Response! When the cap is completed and vegetation has
been established, the cap will look like a natural, small
hill. As part of its routine maintenance, pests that could
damage the cap will be controlled.
Comment 16; One commenter added that no one can know what
will happen in one-hundred years, and that someone may
decide to develop the area near the lagoon. He wondered how
future development might impact the cap.
EPA Responset As part of the remedy, permanent notices will
be provided to the appropriate State or local authority that
indicate that a waste disposal site is present. No
development will be allowed in the future at the site that
might damage the cap. Additionally, ground water use will
be restricted to ensure contaminated ground water is not
used around the site.
Comment 17t One commenter noted that, in ecological terms,
30 years for monitoring of the cap is not a long time.
EPA Response; The 30 years of monitoring of the cap
provides a common timeframe to compare different
alternatives and allows engineers to develop cost estimates.
As long as the cap is in place, it will be maintained and
appropriate monitoring will be conducted. Also, the
Superfund law requires that the cleanup be evaluated every
five years to ensure it continues to be protective.
2. Comments Regarding the Testing of Ground Water and Alternate
Concentration Limits fACLsi
a. Ground Water Monitoring. Including Monitoring of
Domestic Wells
Comment 1; One commenter indicated that it is difficult to
judge the results of residential well testing based on one
round of sampling and stated that he is not confident in
EPA's testing results from home wells on Packer Road. He
stated his belief that the lagoon contents will continue to
seep out and threaten local drinking water. He also stated
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11
that he believes the cleanup will take a long tine,
regardless of whether EPA caps the site or incinerates the
wastes, and that the ground water could become more
contaminated over this time period. He requested that EPA
consider installing a waterline connecting Canterbury to the
Town of Plainfield's water supply, and make this part of the
remedy.
EPA Response; The testing EPA did on the residential wells
along Packer Road and South Canterbury Road showed no
contamination from the lagoon. Also, testing done
previously by the Connecticut Department of Health showed no
contamination .
When the site is properly contained by the cap and
monitored, the movement of contamination from the lagoon
will be greatly reduced. Also, the cap will ensure that
ground water will not become more contaminated in the
future.
Because home wells are not contaminated and EPA believes
they are not threatened by the site, installing a waterline
or providing some other type of alternative water supply in
the area is not part of the Yaworski Lagoon site cleanup.
Comment 2: One resident wanted to know the names of the
people whose wells were tested and why his well was not
tested.
EPA Response; The results of all the home well tests are
available for public review in the Administrative Record for
the site at the Canterbury Public Library and at EPA's
Record Center at 90 Canal Street in Boston. The names of
the people whose wells were tested were not given out to
protect their privacy.
EPA's hydrogeologist identified a representative number of
wells along Packer and South Canterbury Roads, based on
their location and well type, that would show if any
problems existed. Because no problems were found, EPA
determined that testing all the wells was not necessary.
3? One commenter noted that most of the ground
water sampling at the site was conducted in the spring. The
commenter stated that Figure 5-15 of the RI shows that the
highest level of contamination was found in Well B. The
commenter expressed concern that contaminated water may be
washed away from the River or underneath the River,
particularly in the fall when the pressure in the aquifer is
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12
low.
EPA Response; Ground water sampling and analysis was done
in the fall, as well as the spring. The testing done in the
fall is summarized in the initial RI completed by NUS.
Regardless of the season, EPA believes that, based on water
elevation measurements, ground water flows to the Quinebaug
River.
Comment 4t One commenter objected to the Agency's use of
the terminology "acceptable levels of contamination in
drinking water." She pointed out, along with another
commenter, that humans are not the only creatures ingesting
the water in the area; there are animals drinking water from
the River and the wetlands. She stated her belief that
there are no levels of contamination in ground water that
should be considered to be acceptable.
EPA Response; In its decision to cap the site and establish
ACLs, EPA considered the environment, as well as human
health. The "acceptable levels" mentioned are standards set
to ensure that drinking water is safe to drink and that
ambient water is safe for animals and the environmental.
Comment 5; One commenter requested that EPA monitor wells
periodically, such as every spring, to make sure that the
ground water continues to be safe for those in the
surrounding area with home wells.
EPA Response: A number of monitoring wells around the site
will be tested periodically to ensure that the ACLs are not
exceeded and to ensure that contamination is not moving
toward drinking water wells. However, home wells will not
be monitored.
CoTnnent 6; One commenter asked how frequently ground water
•testing would occur, and who would perform the tests. He
also asked what the results of the tests completed to date
have been.
EPA Response; Ground water testing will occur quarterly.
It will be conducted by either EPA, the CT DEP or a
qualified testing company hired by the responsible parties
at the site. If the responsible parties do the testing it
will be closely monitored by EPA and the CT DEP.
All test results completed to date are summarized in the
Remedial Investigation Reports. These reports are in the
Administrative Record and are available for public review.
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13
Comment 7; One coaunenter asked what the depths of the wells
were that EPA tested south of the site. He asked if the
depths reach into the recognized aquifer.
EPA Response; EPA's wells south of the site were installed
into every part of the aquifer: near the top of the water
table, in the middle and, finally, in bedrock. They were
installed at depths from approximately 15 feet mean sea
level to approximately 90 feet mean sea level.
b. Alternate Concentration Limits (ACLs)
Comment 8; One commenter asked if establishing ACLs would
ensure an end to contamination at the site and whether the
ground water would ever be drinkable.
EPA Response; ACLs will not end contamination at the site.
Within the River meander ground water will not be
drinkable. However, beyond the River meander, where home
wells are, the ground water will continue to be drinkable.
Comment 9t One commenter asked if ACLs will be established
upstream. The commenter asked how ACLs compare with
concentrations established for public water supplies and
whether ACLs will be established between the site and the
landfill or down-river from the landfill.
EPA Response: ACLs are a set limit for chemicals in ground
water. They will be established for ground water within the
River meander. Upstream of the site and to the north
outside of the River meander ground water is drinkable and,
therefore, the standards for drinking water set under the
Clean Water Act and Safe Drinking Water Act apply. ACLs are
generally set at higher concentrations than those
established for public water supplies.
Comment 10t One commenter asked what EPA means when the
Agency says that if ACL's are exceeded, ground water use at
and near the site will be restricted. The commenter asked
what agency would have the jurisdiction to enforce the ACLs.
The commenter also asked what corrective action measures
would be taken if ACLs were exceeded.
EPA Response; Part of the process of setting ACLs is to
restrict -ground water use around the site. The ACL does not
have to be exceeded to require these restrictions. EPA, the
CT DEP, and the CT Department of Health will enforce the
ACLs.
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If ACLs are exceeded and EPA determines that corrective
action is necessary, ground water may be pumped from the
ground and treated. The pump and treatment system that
would be as specified in the Record of Decision.
3. Costs. Liability, and Enforcement Issues
a. Costs
Comment 1; One commenter stated his belief that EPA's
primary motivation in choosing the preferred remedy is that
it is the least expensive. Another commenter argued that
cost should not be considered at all when choosing the
cleanup option. A third commenter said it would not be fair
to leave the landfill mess to our grandchildren for the sake
of money.
EPA Response; Cost is one of nine criteria that EPA
considers when selecting a remedy. EPA does not necessarily
select the lowest cost alternative that it can and, in fact,
did -not at the Yaworski Lagoon site. Also, cost is not
considered until an alternative remedy has been shown to be
protective of human health and the environment and in
compliance with other applicable or relevant and appropriate
federal and state environmental laws and regulations
(ARARs).
Comment 2; One commenter stated that EPA has indicated that
the State and the Town are going to have to assume the cost
of the cleanup and asked whether that means that the federal
government does not have funds available for the cleanup.
EPA Response; EPA, through the Super fund program, pays for
cleanups if the work is not done by responsible parties. If
EPA pays for the cleanup at the Yaworski Lagoon site, the
Agency will fund 90% of the costs. The State would pay the
other 10%. The Town would not have to pay for the work or
the long-term maintenance that follows.
b. Liability
Comment 3; One commenter stated her belief that Mr.
Yaworski has made millions of dollars from the lagoon and
should be responsible for paying for removal of the wastes
from the site.
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EPA Response: Mr. Yaworski and a number of other parties
have been noticed by EPA that they are potentially
responsible for the cleanup of the site. EPA will negotiate
with Mr. Yaworski and the other parties to pay EPA's past
costs and to implement the remedy.
4* One commenter indicated that he believes the
cleanup will be a long-term process and that the responsible
parties should be required to post a bond to protect people
in the Town from any costs or further damages that may be
created if the cap does not work or the cleanup takes too
long. Another commenter also expressed concern that the cap
is just an interim solution and that responsible parties
should be held liable now for any future costs of cleanup.
This commenter argued, that in ten years, the responsible
corporations may not exist.
EPA Response; EPA will begin negotiations shortly with the
potentially responsible parties to determine their
willingness and ability to conduct the remedial action at
the site. During the course of these negotiations, future
liability of the parties will be discussed.
Comment 5; One commenter was interested to know who, in
addition to the Yaworskis, is responsible for the
contamination in the lagoon. She asked if the CT DEP
allowed disposal of wastes in the lagoon to occur.
EPA Response; InterRoyal Corporation; Kaman Aerospace
Corporation; Pervel Industries, Inc.; Triangle PWC, Inc.;
Rogers Corporation; C & M Corporation; and, Revere Textile
Prints Corporation are also considered potentially
responsible parties. CT DEP did not issue a hazardous
waste facility permit for the Yaworski lagoon facility
allowing waste disposal.
c. Enforcement
Comment 6; One commenter stated his belief that the federal
and State laws that are in effect are not strict enough
because these laws should not permit a dump to continue to
exist by the side of a River. He commented that the River
and surrounding area is an essential place for wildlife to
live and eat.
EPA Response; An uncontrolled waste dump like the Yaworski
Lagoon could not be built today because of recent changes in
federal and state environmental laws that provide much
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stricter controls on how hazardous wastes are managed.
Although it is located by the Quinebaug River, capping the
site and setting ACLs will be protective of both human
health and the environment.
Comment 7; Another commenter stated her belief that there
is no control over businesses such as the Yavorski Lagoon
because of the free enterprise system. She stated that her
understanding of the free enterprise system, however, is
that it is free until it causes harm or it invades other
people's property. She concluded that the officials in
charge of the Yaworski Lagoon site are more concerned with
Mr. Yaworski's checkbook than with other people's freedom.
EPA Response; Although cost was a factor in selecting the
cleanup plan, no consideration was given to Mr. Yaworski or
his finances in the remedy selection process.
Comment 8: One commenter expressed his disappointment with
what he believes is a lack of enforcement conducted by the
State of Connecticut with regard to the Yaworski Lagoon
site.
EPA Response; The CT DEP has been active in enforcement
activities at the Yaworski Lagoon site. In 1976, the CT DEP
ordered Mr. Yaworski to install monitoring wells at the
site. In 1980, the State ordered that a study be completed
on environmental damage that the site was causing. And,
finally, in 1982, the CT DEP ordered Mr. Yaworski to close
the lagoon.
4. Risks Posed to Human Health and the Environment
a. Health Risks
gQfflffignt J- Residents argued that, with the improved cap and
dike, contaminants would continue to enter the River and
present risk to people who fish or swim in the River.
Several commenter s noted that they no longer eat the fish
from the River for fear that it is contaminated. One
resident asked to know how many times one has to swim in the
River before one's health is affected.
EPA Response; The improved cap and dike will stop rain
water from washing chemicals from the lagoon and will
minimize contamination that enters the River and ensure that
the Yaworski Lagoon site does not contribute adversely to
River water quality. Additionally, contamination levels
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have not been increased in the River due to the lagoon.
Because of this, EPA believes the site will not harm fish or
make it dangerous for people to swim in the River.
Comment 2; One commenter stated that there are three people
who have lived or worked in the area near the dump who have
cancer. She noted that a report issued from EPA several
years ago stated that people's health in the site area is
fine, and that no danger exists from drinking water from
residential wells. The citizen asked why EPA did not
investigate the number of cancer cases in the area as part
of their studies.
EPA Response; A study of the number of cancer cases in an
area around Yaworski would have been considered if EPA
believed people had been exposed to cancer-causing chemicals
from the lagoon. No study was done because there is no
indication the that ground water people use is contaminated
and there is no other exposure to chemicals from the lagoon.
b. Environmental Risks
Comment 3; Several commenters expressed concern that EPA
had not conducted any fish sampling. These residents wanted
to know if the fish in the Quinebaug River are contaminated.
Several residents noted that they are concerned about
contamination in the Quinebaug River because there is an
anadromous fish (fish that swim upstream in rivers from the
ocean to breed in fresh water) restoration plan. These
commenters believe that leaving the contamination in the
lagoon poses a threat to the fish.
EPA Response; A fish sampling and tissue analysis was not
done by EPA. However, benthic/macro-invertebrate sampling
was done and the results showed that the site does not
adversely impact these species. Additionally, fish sampling
and tissue analysis was conducted by ERT, an environmental
engineering firm hired by the responsible parties. Their
results indicated the site is not adversely impacting fish.
In the development, evaluation, and selection of the remedy,
EPA did consider the anadromous fish restoration plan for
the River. When ACLs are set and as part of the river
monitoring program outlined in the selected remedy, the
protection of anadromous fish will be addressed.
Comment 4; One commenter noted that page 6-32 of the
Remedial Investigation states that anadromous fish may spawn
in the wetlands near the Quinebaug River. This commenter
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remarked that this statement detracts from the credibility
of the study because there have not been anadromous fish in
that part of the River for 150 years.
EPA Response; The Remedial Investigation should have stated
if anadromous fish are re-established, the wetland may serve
as a spawning ground and nursery.
?t Several commenters indicated that the organisms
in the wetlands would be harmed by the continued migration
of contaminants from the lagoon. One commenter requested
that EPA remove the waste from the lagoon area and try to
restore the wetlands to their original condition.
EPA Response; Migration of contaminants from the lagoon to
the wetlands could continue and harm organisms if no action
was taken. However, the improved cap and dike will stop the
contaminated leachate that causes the contamination that
flows to the wetland.
Although the wetlands may be contaminated with some elevated
levels of metals in the sediments, removal of the sediments
would be ecologically destructive and was therefore not
included in the remedy.
5. Community Relations Issues
Comment 1; One citizen argued that the comment period
should be suspended or postponed for 90 days so that EPA can
make another presentation to the residents of Canterbury so
that they better understand what EPA plans to do. In
particular, the commenter stressed that EPA needs to better
explain the ACLs and the long-term levels at which they will
be established.
EPA Response ; EPA will not postpone the selection of the
remedy or extend the public comment period. EPA explained
the ACL process and answered questions about it at the
public meeting on July 27, 1988. Additionally, EPA made
available the Administrative Record, including the Remedial
Investigation and Feasibility Study Reports and other
background documents, on July 27, 1988. EPA believes that
the four-week public comment period on the Proposed Plan
was appropriate and allowed for meaningful public
involvement.
During the design of the remedy and when the ACLs are set,
EPA will conduct informational meetings and provide fact
sheets on the progress of the work, and solicit public
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input.
2 - One commenter noted that the Proposed Plan does
not, but should, include provisions for sending the Town
copies of the annual site inspection reports, ground water
monitoring reports, and the five-year site appraisal
reports.
EPA Response; Although the Proposed Plan does not include
those provisions, the reports mentioned will be added to the
Administrative Record for the site, as soon as they are
completed and will be made available at the Canterbury
Library, the information repository for the site.
Comment 3; One commenter asked how the final selection of
the site cleanup will be made, and who will make the
decision.
EPA Response; The final selection of the cleanup plan is
made by EPA's Regional Administrator in Boston. The
decision is made based on a review by the Regional
Administrator of the reports and studies completed for the
site, and the other supporting documents found in the
Administrative Record. Additionally, the comments received
from the public and EPA's responses are also considered in
the decision.
Comment 4; One commenter explained that several years ago,
EPA had sent her a letter regarding some wells they would be
installing on her property. She said that she called to
complain and EPA constructed the wells next door, instead.
She pointed out that EPA never sent any information
explaining why the wells were being installed in the area,
and what the results of the sampling were.
EPA Response; EPA's Project Manager for the Yaworski Lagoon
site is available to answer any questions about wells
installed to characterize the site and to explain the
results of sampling. Also, all the data collected is
summarized and explained in the reports found in the
Administrative Record.
In the case discussed above, EPA probably installed the
wells on the other property because of schedule constraints
that the Agency faced during well drilling operations and
simply wished to avoid delays that could have been caused if
access was denied by the first homeowner.
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Comment 5: Two commenters asked why EPA had not notified
every household in Canterbury of the problem associated with
the Yaworski Lagoon site. These commenters stated their
belief that EPA has not provided adequate notice to
Canterbury residents. The commenters explained that they
are new to the area and, because they were unaware of the
situation regarding the site, they could not request to be
added to EPA's site nailing list.
EPA Response! EPA provided appropriate notice of the
cleanup plans to residents. EPA placed a public notice in a
local paper, the Norwich Bulletin, in July, prior to the
public meeting. In addition, the Proposed Plan was sent to
everyone on the site mailing list, including local papers
and radio stations.
6. Other Issues;
a. River Diversion
Comment It One commenter asked why there was no alternative
in the Proposed Plan recommending a river diversion. The
commenter stated that under a river diversion plan, the
meander could be eliminated by putting a straight channel
through the area, thus isolating the lagoon.
EPA Response; With proper flood protection, the River will
not cause a problem at the closed Yaworski lagoon. Divert-
ing the River is not necessary. In addition, it would cause
ecological damage to divert the River and would be very
expensive.
b. Zoning
Comment 2; One commenter noted that zoning in the Town of
Canterbury presently would permit development on the site.
The commenter stated that the Proposed Plan should at least
state that the zoning regulations in Canterbury have to be
changed to prevent development on the site property in the
future.
EPA Response; The remedy for the site includes a
requirement that notices that provide a record of the type,
location, and quantity of hazardous wastes disposed in the
lagoon, be submitted to the appropriate authority in
Connecticut with jurisdiction over land use. No development
will be allowed at the site in the future that could disturb
the cap or impact its performance. '
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c. Mistake in FS
3; One comment e r pointed out that page 8-2 of the
FS states that the possibility of a total washout of the
lagoon exists. However, the commenter stated, the report
does not address how EPA plans to address the possibility of
a washout.
EPA Response; Floods could erode the present cover and wash
contaminants into the River. The improved cap and dike will
be designed, constructed, and maintained to protect against
damage caused by flooding and will prevent wastes from being
washed into the River. In the development of the remedy,
EPA reviewed FEMA data on flooding along the Quinebaug River
and also estimated flood water speed. This information was
used to develop the specifications for the materials used in
the cap and dike, and how they would be built.
d. Contingency Plan
Comment 4; One commenter argued that there should be a
contingency plan developed in case the cap fails.
EPA Response; A maintenance plan will be prepared for the
cap and dike to ensure it does not fail. Under this plan,
the cap and dike will be inspected periodically and any
necessary repairs will be made. Additionally, a corrective
action and contingency plan will be prepared to address any
exceedance of ACLs.
e. Yaworski Report
Comment 5; One commenter claimed that Mr. Yaworski and some
of the chemical companies that are considered to be
potentially responsible parties developed a paper on
incineration and asked why it should not be adopted. The
commenter stated that this document was presented to EPA
prior to EPA's proposal being released to the public.
EPA Response; The report on incineration prepared for the
PRPs is part of the Administrative Record for the site. EPA
considered information from the report when the Agency
developed the Proposed Plan and when it selected the
remedial action.
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t. Property Values
Comment 6: One commenter asked if it is fair for the value
of her property to decrease sin^e she owns land near the
dump, while other residential property continues to increase
in value. She asked if there is any provision in the
Proposed Plan that would ensure that her land will regain
its value someday.
EPA Response; No, there is no provision in the Proposed
Plan or in the Superfund law that addresses property values.
Comment 7; One comnenter suggested that a waterline
connecting Canterbury to Plainfield would ensure that
property values near the Yaworski Lagoon site are not
threatened.
EPA Response; Because hone wells are not contaminated,
there is no need for an alternate water supply such as a
waterline. EPA does not take action under Superfund
authority to ensure property values.
Comment 8; One commenter asked why his taxes are not
decreasing if his property value is decreasing due to the
dump.
EPA Response; Property taxes are a local issue outside of
the jurisdiction of EPA.
a. Interaaency Coordination
Conment 9; One commenter asked why EPA did not follow CT
DEP's recommendation several years ago to place a partial
cap on the lagoon. He argued that if a decision had been
made then to cap the site, the contamination problem would
not be as great today.
EPA Response; The lagoon was capped in 1982 as a result of
an order from CT DEP to Mr. Yaworski. The decision by EPA
to improve the cap and dike and set ACLs is based on studies
completed in 1988. Until these studies were completed by
EPA, an informed decision on a protective remedy could not
be made.
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B. Summary of Potentially Responsible Party (PRP) Comments
This section outlines the major comments received by EPA on
the Yaworski Lagoon site RI, FS, and Proposed Plan by ERT. ERT
has been hired as a consultant by the Yaworski Lagoon site PRP
Committee and submitted comments to EPA on behalf of the
committee. Two other comments were received from (1) Triangle
PWC Inc., and (2) Hinckley, Allen, Snyder & Comen (on behalf of
Pervel Industries) endorsing the comments submitted by ERT.
ERT stated that the proposed remedy is technically sound,
protective of human health and the environment, and cost
effective. The proposed remedy is consistent with and supported
by the data collected by EPA's consultants as well as data
collected and analyzed by ERT. ERT believes EPA's proposed
remedy is appropriate because it addresses the major sources of
site contamination and potential exposure pathways.
ERT also stated that the proposed remedy satisfies the seven
technical criteria which are utilized to assess the
applicability, feasibility and cost-effectiveness of the
potential alternatives by: protecting public health and the
environment; complying with ARARs, providing long- and short-term
effectiveness; by reducing mobility; and by being reliable and
cost effective.
ERT concurs with ATSDR's conclusion that "The Yaworski site
does not pose a public health threat at this time."
1. Comments on the Remedial Investigation
Comment l; ERT stated that a review of the mass flux
calculations completed in the RI conducted by E.G. Jordan
indicates that they represent worst-case conditions that
would seldom occur in the lagoon. ERT concluded that,
consequently, contaminant contributions to the ground water
calculated in the RI are overestimated.
EPA Response; The mass flux calculations were developed
using peak values and represent worst-case conditions.
However, this does not necessarily overestimate contaminant
contribution to the River and is an appropriate check to
ensure that an ACL can be used a part of a protective
remedy.
Comment 2; ERT stated that the RI conducted by E.C. Jordan
mischaracterizes the nature of the wetland. The primary
habitat/ecosystem functions of the wetland are related to
emergent, wetland vegetation as shelter and food for
terrestrial organisms, especially birds which would have
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only limited contact with the surface water. This type of
wetland is flooded during vernal high river flows, and
standing water is present in the wetland only one third of
the time. Under these conditions, persistent aquatic
invertebrates are restricted to those which can survive in
moist sediments or which can complete the aquatic portion of
their life cycles within a few months. Aquatic organisms
are, therefore, not major components in this area. An
argument for endangerment should be based on organisms which
are structurally and functionally important to the system.
ERT expressed the belief that there is no risk to aquatic
organisms in the wetland.
EPA Response; Because of the variability of water levels in
the wetlands, the wetlands probably act at times as
primarily an aquatic environment and at other times as a
terrestrial one. Regardless of this, the continued
contaminant loading via leachate from the lagoon would
cause environmental harm and there may be an imminent and
substantial endangerment to the environment.
Comment 3i ERT stated that the surface-water results
obtained by ERT are consistent with the results reported by
NUS in the first RI conducted at the site, with the
exception of selected metal analysis. ERT added that the
differences in the two sampling rounds, however, may be a
function of different sampling conditions and different
analytica.1 laboratories and are not significant.
EPA Response; EPA agrees that the surface water results
obtained by ERT are consistent with previous results;
however, variability is probable due to true variance in
contaminant levels in the surface water, in addition to
sampling and analysis differences.
Comment 4; ERT stated that fish sampling data gathered by
ERT support the conclusion that the site appears to have no
measurable effect on the quality of the fish in the River.
EPA Response; EPA believes that ERT data support the
conclusion that the site presently appears to have no
measurable effect on the quality of fish in the River.
Comments on the Feasibility Study
Comment 1; ERT argued that significant human health risks
may be associated with the excavation of the lagoon.
Removal of the existing cap that covers the lagoon will
result in a release of volatile, and possibly liquid,
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contaminants from the lagoon. ERT pointed out that
potential exposure to the contaminants would include
inhalation of volatile contaminants, direct contact with
waste material and inadvertent ingestion of the contaminated
media.
EPA Response; EPA concurs that excavation of the waste from
the lagoon could result in some short-term impacts,
including some risks to human health particularly to on-site
workers.
Comment 2; ERT stated that because the ground water at the
Yaworski Lagoon site contains a variety of different
compounds, a single ground water treatment technology may
not effectively remove all contaminants from the site ground
water. ERT concluded that a single treatment technology is
not necessarily more cost effective than two different
technologies in combination (i.e. steam-stripping and
ultraviolet radiation/ozonation).
EPA Response; If ground water needs to be treated at the
site as a result of the corrective action program, during
design of the treatment system, different process options,
including a combination of technologies, will be considered.
The process presented in the Feasibility Study Report in
Alternative f 4 is one possible process configuration that
could be utilized and was presented to serve as the basis
for costing and for comparison to other alternatives.
During design of the remedy, the particular technology or
technologies selected will be dictated by the performance
goals that EPA sets for the treatment system.
Comment 3; ERT stated that the rationale for the well
placement is ambiguous and not clearly supported by E.G.
Jordan's calculations. It is not clear whether the proposed
pumping system will capture all contaminated ground water in
the alluvium (clay, silt, sand, and gravel) beneath the
lagoon.
EPA Response; The proposed pumping system is intended to
capture contaminated ground water that flows from the site.
The exact well locations will be further refined in the
development of the corrective action program.
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III. REMAINING CONCERNS
During the public comment period, at the public
informational meeting held in Canterbury on July 27, 1988, and at
the informal public hearing held on August 17, 1988, local
residents discussed issues that may continue to be of concern
during the design and implementation phases of EPA's selected
remedy for the Yaworski Lagoon site. These issues and concerns
are described below:
(A) Design and Effectiveness of the Cap
Citizens have expressed concern regarding the specific
design components of the cap, and regarding the
effectiveness of the cap in preventing contamination from
leaching into area ground water, the Quinebaug River, and
the wetlands.
(B) Results of Ground Water Monitoring Tests
Citizens expressed interest in receiving updates regarding
results of ground water monitoring tests.
(C) Five-Year Site Reviews
A number of citizens who view the cap as an interim solution
expressed an interest in receiving updates of EPA's five-
year reviews of the Yaworski Lagoon site, and any
information regarding new technologies that could be
utilized at the site to completely destroy the wastes in the
lagoon.
To address these concerns, EPA will make available all
design documents, testing results, and summary reports of the
five-year site reviews. This information will be made available
at the Canterbury Library. Additionally, EPA will hold public
meetings and send out fact sheets to explain the progress at the
site.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
YAWORSKI LAGOON SITE
IN CANTERBURY, CONNECTICUT
Community relations activities conducted by EPA at the Yavorski
Lagoon Superfund site to date have included:
o December 1984 - EPA held a public meeting to discuss the
workplan for conducting remedial activities at the site.
o June 1985 - EPA released a community relations plan
describing citizen concerns about the site and outlining a
program to address these concerns and to keep citizens
informed about and involved in site activities.
o May 1986 - EPA established information repositories at the
Canterbury Library and the Selectmen's office.
o May 1986 - EPA released a fact sheet explaining the results
of the initial RI activities occurring at the site.
o May 21, 1986 - EPA held a public meeting in Canterbury to
explain the results of the initial RI.
o July 1988 - EPA mailed the Proposed Plan announcing EPA's
preferred alternative for the Yavorski Lagoon site to all
those on the site mailing list.
o July 1988 - EPA issued a public notice to announce the time
and place of the upcoming FS public informational meeting
and to invite public comment on the FS and Proposed Plan.
o July 27, 1988 - EPA held a public meeting in Canterbury to
discuss the results of the FS and Proposed Plan.
o August 5, 1988 - EPA sent a letter to citizens on the
mailing list announcing EPA's intention to test 15 home
wells along Packer Road and South Canterbury Road on August
8, 1988.
o July 28, 1988 to August 24, 1988 - EPA held a four-week
public comment period to accept comments on the Proposed
Flan, on the other alternatives considered in the
Feasibility Study Report, and on the other documents that
are contained in the Administrative Record for the site.
o August 17, 1988 - EPA held an informal public hearing in
Canterbury to accept oral comments on the remedial
alternatives evaluated in the FS and Proposed Plan. EPA
also explained the results of the home well tests taken on
August 8, 1988, and provided the public with a fact sheet
explaining these results.
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RECORD OF DECISION
YAWORSKI LAGOON SITE
APPENDIX B
ADMINISTRATIVE RECORD INDEX
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Yaworski Waste Lagoon
NPL Site Administrative Record
Index
As of September 29, 1988
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
One Kendall Square, Suite 2200 • Cambridge, Massachusetts 02139 • (617) 577-9915
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Yaworski Waste Lagoon
NPL Site Administrative Record
Table of Contents
Volume I
1.0 Pre-Rcmedial
1.2 Preliminary Assessment
2.0 Removal Response
2.2 Removal Response Reports
3.0 Remedial Investigation (RI)
3.1 Correspondence
3.4 Interim Deliverables
Volume n
3.5 Applicable or Relevant and Appropriate Requirements (ARARs)
3.6 Remedial Investigation (RI) Reports
Volume m
3.6 Remedial Investigation (RI) Reports (cont'd.)
3.7 Work Plans and Progress Reports
Volume IV
3.9 Health Assessments
3.12 Action Memoranda
4.0 Feasibility Study (FS)
4.1 Correspondence
4.5 Applicable or Relevant and Appropriate Requirements (ARARs)
4.6 Feasibility Study (FS) Reports
4.9 Proposed Plans for Selected Remedial Actions
5.0 Record of Decision (ROD)
5.1 Correspondence
5.3 Responsiveness Summaries
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Yaworski Waste Lagoon
NFL Site Administrative Record
Table of Contents Ccont'd.)
Volume V
5.3 Responsiveness Summaries (cont'd.)
5.4 Record of Decision (ROD)
9.0 State Coordination
9.1 Correspondence
10.0 Enforcement
10.3 State and Local Enforcement Records
11.0 Potentially Responsible Party (PRP)
11.7 PRP Steering Committee Documents
11.9 PRP-Specific Correspondence
13.0 Community Relations
13.2 Community Relations Plans
13.3 News Clippings/Press Releases
13.4 Public Meetings
13.5 Fact Sheets
16.0 National Resource Trustee
16.1 Correspondence
16.4 Trustee Notification Form and Selection Guide
Administrative Record Index
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Introduction
This document is the Index to the Administrative Record for the Yaworski Waste Lagoon
National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and
Section n cites guidance documents used by EPA staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region Is Office in
Boston, Massachusetts, and at the Canterbury Public Library, 8 Library Road, Canterbury,
Connecticut 06331. Questions concerning the Administrative Record should be addressed to the
EPA Region I site manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
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Section I
Site-Specific Documents
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Section II
Guidance Documents
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GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EPA G^i^flyi^ Documents
1. Comprehensive Environmental Response. Compensation, and Liability Act of 1980
(CERCLA). 42 U.S.C. §§9601 et seq., amended October 17,1986.
2. Letter from Lee M. Thomas to James I. Florio, Chairman, Subcommittee on Consumer
Protection and Competitiveness, Committee on Energy and Commerce, U.S. House of
Representatives, May 21,1987 (discussing EPA's implementation of the Superfund
Amendments and Reauthorization Act of 1986).
3. "National Oil and Hazardous Substances Pollution Contingency Plan (NCP)," Code of
Federal Regulations (Title 40, Part 300), 1987.
4. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6),
September 1983.
5. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft
Guidance on Conducting Remedial Investigations and Feasibility Studies under CERCLA
(Comprehensive Environmental Response. Compensation, and Liability Act).
Rev. March 1988.
6. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft
Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites (OSWER
Directive 9283.1-2), March 1988.
7. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-1), October 1986.
9. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Ground-Water
Protection Strategy. August 1984.
10. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Covers for Uncontrolled Hazardous Waste Sites (EPA/540/2-85/002), September 1985.
11. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions. July 24,1987.
12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Alternate Concentration Limits Guidance (OSWER Directive 9481.00-6C,
EPA/530-SW-87-017), July 1987.
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Quality Objectives for Remedial Response Activities: Development Process
(EPA7540/G-87/003), March 1987.
14. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Response.
Compensation, and Liability Act) (EPA/540/G-85/003), June 1985.
15. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investigations under CERCLA (Comprehensive Environmental
Response. Compensation, and Liability Act) (EPA/540/G-85/002), June 1985.
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16. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24,1986.
17. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Memorandum from J. Winston Porter, July 9,1987 (discussing interim guidance on
compliance with applicable or relevant and appropriate requirements).
18. U.S. Environmental Protection Agency. Office of Water. Memorandum from William
Hedeman, August 5,1985 (discussing policy on floodplains and wetlands assessments for
CERCLA actions).
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RECORD OF DECISION
YAWORSKI SUPERFUND SITE
APPENDIX C
STATE CONCURRENCE
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STATE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
September 28, 1988
Michael R. Deland
Regional Administrator
United States Environmental Protection Agency
JFK Federal Building
Boston, MA 02203
Dear Mr. Deland:
This letter provides the State of Connecticut's concurrence on
the selected remedy, as described in the Record of Decision and
supporting documents, for the Yaworski site in Canterbury,
Connecticut. In providing this concurrence, the State finds that the
remedy will attain all applicable or relevant and appropriate State
laws and regulations.
eslie A. Carothers
Commissioner
LAC:JRG:kal
Phone:
165 Capitol Avenue • Han ford, Connecticut 06106
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