PB96-964009
EPA/ROD/R04-96/266
June 1996
EPA Superftmd
Record of Decision:
National Electric Coil Company/
Cooper Industries, Dayhoit, KY
4/26/1996
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NATIONAL ELECTRIC COIL CO.,/
COOPER INDUSTRIES
SUPERFUND SITE
RECORD OF DECISION
April 1996
United States Environmental Protection Agency
Region IV
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TABLE OF CONTENTS
Section Page
THE DECLARATION i
DECISION SUMMARY 1
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1
1.1 Site Location 1
1.2 Affected Population 1
1.3 Topography 1
1.4 Adjacent Land Uses 1
1.5 Natural Resources 1
1.6 Climatology 2
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
2.1 Operational History 5
2.2 Enforcement Summary 5
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION .6
4 0 SCOPE AND P-OLE OF RESPONSE ACTION WITHIN SITE STRATEGY 7
5.0 SUMMARY OF SITE CHARACTERIZATION 7
5.1 Geology 7
5.2 Hydrogeology 8
5.2.1 Shallow Ground Water (Alluvium 8
5.2.2 Bedrock Ground Water 8
5.2.3 Surface Water 9
5.3 Nature and Extent of Contamination 9
5.3.1 Removal Action 9
5.3.2 Remedial Investigation/Feasibility Study 10
5.3.3 Interim Remedial Action 12
6.0 SUMMARY OF SITE RISKS 21
6.1 Human Health Risks , 21
6.1.1 Chemicals of Concern 21
6.1.2 Exposure Assessment 22
6.1.3 Toxicity Assessment 23
6.1.4 Risk Characterization 23
6.2 Environmental Risks 26
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TABLE OF CONTENTS
Section Page
6.3 Summary 27
7.0 DESCRIPTION OF ALTERNATIVES 32
7.1 Ground-Water Recovery Alternatives 32
7.2 Ground-Water Treatment Alternatives 35
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 40
8.1 Overall Protection of Human Health and the Environment . . 40
8.2 Compliance with ARARS 40
8.3 Long-Term Effectiveness and Permanence 41
8.4 Reduction of Toxicity, Mobility or Volume through Treatment 41
8.5 Short-Term Effectiveness '. 42
8.6 Implementability 42
8.7 Cost 42
8.8 State Acceptance 43
8.9 Community Acceptance 43
9.0 SELECTED REMEDY 44
9.1 Major Components of the Ground-Water Extraction and Treatment System 45
9.2 Performance Standards 45
9.2.1 Ground-Water Extraction Standards 45
9.2.2 Ground-Water Treatment Standards 45
9.2.3 Stack Emission Rates and Ambient Air Standards 46
9.2.4 Treated Ground Water Discharge Standards 46
9.2.5 Compliance Monitoring 46
9.3 ARAR's 46
9.3.1 Applicable Requirements 46
9.3.2 Relevant & Appropriate Requirements 47
9.3.3 To Be Considered (TBCs) 47
9.4 Documentation of Significant Changes 48
10.0 STATUTORY DETERMINATIONS 52
10.1 Protection of Human Health and the Environment 52
10.2 Compliance with ARARs 52
10.3 Cost-Effectiveness 53
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable .... 53
10.5 Preference for Treatment as a Principal Element 53
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LIST OF FIGURES
Section Page
Figure 1.1 Site Location Map 3
Figure 1.2 Site Plan 4
Figure 5. la Generalized Stratigraphic Column 14
Figure 5. Ib Generalized Stratigraphic Column 15
Figure 5. Ic Generalized Stratigraphic Column 16
Figure 5.2 Location of VOC Plume Prior to Start-up of Ground-water Extraction System . 17
Figure 5.3 1991 Removal Action Soil Excavation Boundaries 18
Figure 5.4 Potentiometric Surface Map before Startup of Ground-Water System 19
Figure 5.5 Potentiometric Surface Map after Startup of Ground-Water System 20
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LIST OF TABLES AND APPENDICES
Section Page
Table 6.1 Contaminants of Concern 28
Table 6-2a Summary of Cancer and Noncancer Risks by Exposure Route for
Lifetime Resident 29
Table 6-2b Summary of Cancer and Noncancer Risks by Exposure Route for
Adult Worker 30
Table 6.3 Site Conceptual Model 31
Table 9.1 Summary of Ground-Water Performance Standards 49
Table 9.2 Emission Rate and Ambient Air Performance Standards 50
Table 9.3 Summary of KPDES Effluent Limitations 51
APPENDICES
Appendix A - Proposed Plan
Appendix B - Responsiveness Summary
Appendix C - Commonwealth of Kentucky Fish Study
Appendix D - Summary of Cancer and Noncancer Risks by Exposure Route
Appendix E - Commonwealth of Kentucky Letter of Concurrence
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NATIONAL ELECTRIC COIL CO.,/
COOPER INDUSTRIES
SUPERFUND SITE
RECORD OF DECISION
April 1996
United States Environmental Protection Agency
Region IV
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RECORD OF DECISION
THE DECLARATION
SITE NAME AND LOCATION
National Electric Coil Co./Cooper Industries Site
Dayhoit, Harlan County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the National Electric Coil Co./Cooper Industries Site,
in Dayhoit, Harlan County, Kentucky, which was chosen in accordance with CERCLA, as amended, and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on
the administrative record for this site.
The Commonwealth of Kentucky concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response
action selected in this Record of Decision (ROD), may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This rsmsdis! °ction employs the uss cf sn extraction well/air stnppcr system m order to prcVciit furtlicr giGUuu-waicr
plume migration through the bedrock aquifer and the alluvial aquifer beneath the Site, and to continue ground-water
restoration activities specified in the September 30, 1992 "Interim" Record of Decision. The aquifers beneath the Site
contain volatile organic compound (VOC) contamination.
The major components of the selected remedy are as follows:
• Extraction of contaminated ground water from the site's alluvial and bedrock aquifers;
• Treatment of contaminated ground water using an air stripper tower;
• Discharge of treated ground water to the Cumberland River under KPDES requirements; and
• Catalytic oxidation of air stripper off-gases.
STATUTORY DETERMINATION
The selected remedy is the final response action to the "interim" remedial measures initiated on September 30, 1992 ,
while the Remedial Investigation/Feasibility Study was being conducted. It is protective of human health and the
environment, complies with Federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment technologies
to the maximum extent practicable and satisfies the statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principle element.
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Upon completion of this remedy, no hazardous substances will remain on-Site above health -based levels that prevent
unlimited use and unrestricted exposure. However, because this remedy requires greater than five years to achieve these
levels, pursuant to CERCLA section 121(c), EPA must conduct a policy five-year review. The Five-Year Review will
five years after the Preliminary Close Out Report signature.
Richard D. Green, Acting Director
Waste Management Division
Date
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Record of Decision
National Electric Coil Co., Site
Page 1 of 53
DECISION SUMMARY
1.0 SITE NAME, LOCATION, AND DESCRIPTION
1.1 Site Location
The National Electric Coil Co./Cooper Industries Superfund Site (NEC or Site) is located on Old U.S.
Route 119 adjacent to the Cumberland River in the town of Dayhoit, Harlan County, Kentucky (Figure
1.1). The Site includes the 3.5 acre National Electric Services manufacturing facility (Figure 1.2), which
is currently operating, and also encompasses the area! extent of contamination. The Site consists of a
main plant building, two smaller buildings, and an asphalt paved parking lot with grass cover along the
riverbank area.
1.2 Affected Population '
The Dayhoit community, which is inhabited by approximately 350 people, is located immediately
downriver of the Site. Approximately, 40 families reside at the Holiday Mobile Home Park, which is
located adjacent to and due south of the Site's southern boundary.
1.3 Topography
The NEC site is located in the flood plain of the Cumberland River in Harlan County, Kentucky. The Site
is relatively flat except along the riverbank area, which slopes steeply down to the Cumberland River.
The topography of the area near the Site consists of northeast-trending ridges of Pine Mountain and
Cumberland Mountain and the bottom land associated with the Cumberland River and its tributaries.
1.4 Adjacent Land Uses
The facility property is bordered on the south by the Holiday Mobile Home Park, a residential commu-
nity; on the north by a Kentucky Utility Company electrical substation; on the east by the Cumberland
River; and on west by Old Highway 119. The property is fenced on all sides.
1.5 Natural Resources
Ground water in the bedrock aquifer is used for drinking water and industrial uses in Harlan communities,
located in the Cumberland River valley, downgradient of the Site. Before discovery of the VOC ground-
water contamination in February 1989 more than 140 wells in the Dayhoit area were utilized for domestic
purposes.
Coal is mined extensively in the Harlan County area. The coal mining industry is the primary employer
for the county.
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Record of Decision
National Electric Coil Co., Site
Page 2 of53
1.6 Climatology
Temperature in this area averages at 56°F. Average annual rainfall is 50 inches, with net precipitation at
16 inches. The prevailing average wind direction was determined to be from the southwest to northeast.
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DATE. 2/17/04
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SOURCE: U.S.CS TOPOGRAPHIC QUADRANGLES. WALLIMS CREEK (1974) AND HARLAN, KENTUIJKY (1978)
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NATIONAL ELECTRIC COIL SITE
HARLAN, KENTUCKY
SITE LOCATION MAP
FIGURE 1-1
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FENCE
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Record of Decision
National Electric Coil Co., Site
- Page 5 of 53
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Operational History
From 1951 to 1987 the National Electric Coil Company, (NECC), operated under the ownership of
McGraw Edison Company. The business involved rewinding electric motors, manufacturing coils, and
rebuilding machinery used in the coal mining industry. Cooper Industries purchased McGraw Edison in
1985 and continued operations until August 1987 when the facility was sold to Treen Land Company.
Past practices at the facility involved the use of a trichloroethylene (TCE)-based solvent to remove oil and
tar from the used motors, capacitors, transformers, and other equipment prior to their being rebuilt and/or
refurbished. Before servicing, the equipment was, reportedly, lowered for cleaning into an approximately
1,000-gallon tank containing the TCE-based solvent. The tank was located within a below-grade concrete
pit. Periodically this tank was drained for cleaning, and the contaminated liquid and waste matter was
allowed to flow overland and/or through a drainage pipe to the Cumberland River. PCB laden oil was
also allowed to drain from transformers and other electrical equipment on Site and/or flow through the
drainage piping that led to the river. Sludges from the solvent tank, as well as debris (coal ash) containing
high concentrations of heavy metals from a furnace operated on site, were disposed of along the river.
These disposal practices continued until the mid-1970's and resulted in ground-water contamination. The
local drinking water supply near the Site was found to be contaminated with TCE and related degradation
compounds. Contamination of the Site's drainage channels, river embankment property, and facility
grounds also occurred.
Currently the Site is being utilized by National Electric Service Company (NES) as an active facility for
rewinding and rebuilding electric motors and hydraulic systems used for the mining of coal. Equipment
brought to the facility for refurbishment is now cleaned with a soap-based cleaner instead of the solvent-
based degreaser used by the NECC. The manufacturing facility, currently operating on the Site, employs
less than 20 workers.
In February 1989, the Kentucky Department for Environmental Protection, Division of Water, sampled
the community well at the adjacent Holiday Mobile Home park as well as other surrounding residential
wells. Analyses of the approximately fifty (50) samples indicated the presence of VOCs at concentrations
above Federal Maximum Contaminant Levels (MCLs), in twelve of the wells.
Beginning in March 1989, bottled water and water from temporary above-ground storage tanks were
provided to residences impacted by the contaminated ground water. Residential ground-water users in
areas either already contaminated or at risk of future contamination were connected to the Black
Mountain Water District municipal water system in August 1989. Funding for construction of a water
line extension was provided by Cooper Industries. There are reports that some residents do not utilize the
public water system. Reasons residents gave for not using the public water system includes both
perceived poor water quality and cost of services.
2.2 Enforcement Summary
hi October 1990, EPA issued a Unilateral Administrative Order (Order) to Potentially Responsible Parties
(PRPs), McGraw-Edison Company/Cooper Industries, Inc., Treen Land Company, and National Electric
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Record of Decision
National Electric Coil Co., Site
Page 6 of 53
Service Company, to conduct an early action removal of contaminated soils located on site. Cooper
Industries requested an Order to facilitate removal of contaminated soils at the Site and undertook the Site
Removal Action activities with the approval of the current site property owner, National Electric Service
Company. Approximately 5,100 tons of soil were excavated for off-site disposal during the Removal
Action activities. The Removal Action was conducted under EPA supervision from October 1990
through October 1991. On March 19,1992, EPA notified McGraw-Edison Co./Cooper Industries, Inc.,
of its determination that all activities outlined in the Order had been completed.
The National Electric Coil Co./Cooper Industries Site was proposed for inclujion on the National Priority
List (NPL), as defined in Section 105 of CERCLA, as amended, 42 U.S.C. § 9605, on July 29, 1991. It
was finalized as an NPL site on October 14, 1992.
The Site RI/FS and associated Site studies were conducted under the Administrative Order by Consent
that McGraw Edison/Cooper Industries, Inc., signed with the Agency in May 1992. The RI/FS and
related Site studies were performed by Cooper Industries under the oversight of EPA. The RI/FS was
finalized in January 1995.
In December 1992, EPA directed Cooper Industries to begin preliminary ground-water clean-up activities
in accordance with the September 1992 "Interim" Record of Decision (ROD). The purpose of this
cleanup work was to minimize the bedrock VOC plume migration until a final Site remedy was selected.
Start up of the preliminary ground-water clean-up activities began in July 1993 by utilizing an existing
Site extraction well to recover contaminated ground water from the bedrock aquifer beneath NEC. The
"Interim" ROD required that the bedrock aquifer be pumped to recover VOC-contaminated ground water
and that the extracted ground water be treated by means of an air-stripper tower. The treated ground
water was then discharged into the Cumberland River. The ROD also specified that the VOC-laden air
stream exiting the tower be passed through a granular activated carbon unit prior to being released to the
atmosphere via an exhaust stack.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The NEC Proposed Plan (see Appendix A) for final remedial action was presented at the public meeting
held on July 11, 1995 at the Harlan County Courthouse. The proposed plan described the final remedy
and the process that EPA used to select that remedy. It was mailed to interested parties and other persons
who have requested to be included on EPA's mailing list for the Site. The Proposed Plan was also made
available to the public in the information repository maintained at the EPA Docket Room in Region IV,
and at the Harlan County Public Library. Notice of availability of this document and notice of the public
meeting was published in the Harlan Daily Enterprise on May 31,1995.
At the Public Meeting, representatives from EPA presented the Preferred Remedy and the Remedial
Investigation/ Feasibility Study (RI/FS) findings on which EPA's decisions were based. A 60-day public
comment period on the FS Report and EPA's preferred remedy was held from May 29, 1992 through July
27, 1995. At the conclusion of the public comment period, EPA reviewed and considered all comments
received from the community as part of the process of reaching a final decision on the most appropriate
remedial alternative to address contamination found at the Site. A response to comments received during
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Record of Decision
National Electric Coil Co., Site
Page 7 of 53
this period and to questions not answered at the public meeting is included in the Responsiveness
Summary, which is part of this Record of Decision (see Appendix B). EPA's remedy selected in this
ROD differs slightly from the remedy selected in the Proposed Plan. These minor changes are discussed
more fully in Section 9.4 in this ROD.
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
EPA's remediation of the Site was initiated under response actions outlined in the September 30,1992,
"Interim" ROD. The "Interim" Remedial Action (IRA) was limited to the extraction of VOC-
contaminated ground water from the bedrock aquifer beneath the Site by a single extraction well. The
bedrock aquifer that Was addressed in the IRA is used as a drinking water source, and thus was of
immediate concern, while the shallower aquifer beneath the Site is not used for drinking water and will be
addressed in this final remedy. The purpose of the IRA was to pump the bedrock aquifer in order to
restrict further contaminant-plume migration from the Site while Site characterization and final remedy
selection were conducted.
This ROD is the final response action for the Site. It addresses the long-term remediation of Site ground-
water contamination by expanding the IRA activities to address contaminated ground water located in the
shallow aquifer and the upper zone of the bedrock aquifer in addition to the deeper zone of the bedrock
aquifer. This response action is meant to mitigate current or future exposure to contaminated ground
water by employing hydraulic-control methods to prevent migration of ground water from the Site.
Ingestion of water extracted from these aquifers poses potential risk to human health because contaminant
levels have been determined to exceed corresponding MCLs.
5.0 SUMMARY OF SITE CHARACTERIZATION
5.1 Geology
The Harlan County, Kentucky area is located in the Cumberland Mountain section of the Eastern
Coalfields Region of Kentucky. It is underlain by rocks of the Mississippian and Pennsylvanian age that
consist of sandstones, siltstones, shales, and minor coal and limestone
The Site is located on the Cumberland Mountain overthrust block, south-southeast of the Pine Mountain
overthrust fault and north-northwest of the Cumberland Mountain within an east-west trending synclinal
trough. To the north, the bedrock dips three to five degrees to the southeast. To the south, the bedrock
dips one degree or less to the north-northwest. There are northwest-southeast trending faults in the area
that are associated with the Pine Mountain Overthrust Fault.
The soils underlying the Site contain fill material underlain by alluvial material and weathered rock. The
fill material consists of light gray, yellow brown and brown silty sand to silty gravel. The alluvial
material and weathered rock consist of red brown fine to medium sandy, clayey silt and red-brown and
brown clayey silty fine to medium sand. Soil thicknesses in the Site borings ranged from 10 to 30 feet.
The upper bedrock unit in the area is the Cawood Sandstone Member of the Hance Formation. This
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Record of Decision
National Electric Coil Co., Site
Page 8 of 53
sandstone unit grades laterally into siltstone and thin-bedded sandstone, and contains thin discontinuous
coal seams. The base of the Cawood Sandstone occurs at 100 to 130 feet below the ground surface, and
is underlain by a portion of the Hance Coal Zone that consists of four seams interbedded with sandstone,
silly sandstone and shale. The principal coal seam is the Terry's Fork coal bed that occurs at the base of
the Hance coal zone.
Soil borings from the Site encountered up to 8 feet of gravelly fill material underlain by gravelly silt, silty
sand, or clayey silt to a depth of about 20 to 50 feet. Bedrock consisted of interbedded sandstone,
siltstone, shale and coal. The rocks are essentially flat lying beneath the Site, and distinct units occur
which can be correlated between borings. From the top of rock to a depth of about 80 to 120 feet, the
rocks are primarily dark gray shale interbedded with light gray fine sandstone. The shales contain
carbonaceous layers and a few coal stringers. The underlying unit is more likely the shale unit between
the Cawood Sandstone Member and the Hance Coal Formation. A distinct 2 to 2.5-foot-thick coal unit
occurs at a depth of 80 to 120 feet. This unit is identified as the Hance Coal Formation. From a depth of
about 80 to 120 feet to a depth of about 200 to 240 feet, the rocks are primarily light to dark gray
carbonaceous shale with siltstone and minor sandstone. This shale unit is underlain by a 40 to 50-foot
thick sequence of dark gray shale, carbonaceous shale, brown siltstone, light gray sandstone, and several
units of black bituminous coal. Coal beds are generally 0.5 to 2 feet thick, but shale coal units may be up
to 4 feet thick. This coal zone is underlain by interbedded dark gray shale and light gray fine to medium-
grained sandstone to the termination depth of the borings. A generalized stratigraphic column of the
upper 400 feet encountered in the Harlan vicinity is presented in Figures 5.1 a, S.lb, & 5.1 c.
5.2 Hydrogeology
NEC is underlain by two water-bearing units that are important to this response action: the alluvial
aquifer that spans laterally across the Cumberland River valley and the aquifer that flows through the
fractured bedrock formation beneath the Site. The primary surface water body is the Cumberland River.
5.2.1 Shallow Ground Water (Alluvium)
The uppermost alluvial deposits are 25 to 40-feet thick in the vicinity of the Site and consist of well to
poorly sorted accumulations of sand, silt, and clay. The alluvium generally contains ground water under
unconfined (water table) conditions, at depths averaging twenty feet below existing land surface.
Recharge occurs by rainfall infiltration. Shallow ground-water flow is generally directed eastward toward
the Cumberland River with respect to the facility.
Samples collected on-site from the alluvial aquifer indicate that the shallow aquifer is contaminated with
metals and VOCs that are primarily TCE related. The maximum VOC concentrations of the significant
contaminants, 1,2-Dichloroethene (DCE) (total) and TCE were 87 ^g/« and 2,700 vg/V, respectively. No
PCBs was detected. Lead levels detected in shallow wells ranged from 29.1 ^g/8 to 259 ^g/H.
5.2.2 Bedrock Ground Water
The alluvium is underlain at a depth of approximately thirty feet by Pennsylvanian-age sedimentary
bedrock. The consolidated units of interest include (in descending order):
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Record of Decision
National Electric Coil Co., Site
Page 9 of 53
• Cawood Sandstone - Sandstone grading laterally into siltstone and thin bedded sandstone with
isolated coal seams.
• Hance Coal Formation - shale and siltstone underlain by coal seams interbedded with sandstone
and shale.
Bedrock aquifer ground water located beneath and downgradient of the Site flows through the upper unit
of the Hance Formation. Ground water in the bedrock generally occurs under confined conditions within
the bedrock's secondary fractures and faults. The unit is recharged from places where it crops out,
permitting rainfall infiltration from overlying hydrogeologic units in hydraulic connection. Production
wells and residential wells in the area are generally cased through the shallow coal seams and are
constructed (open borehole) in bedrock consisting of sandstone, siltstone/shale, and siltstone with in-
creasing depth.
Pump tests conducted on study wells constructed here indicate that ground-water migration is fracture
flow dominated and flows in a southwesterly direction downgradient of the Site. Study area bedrock
wells range in depth from 58 to 339 feet below ground surface. Ground-water flow in the bedrock is not
influenced by the directional flow of the Cumberland River. The potentiometric surface in the bedrock
aquifer is about twenty-four feet below grade at the Site. Because the alluvial water table is higher in
elevation than the potentiometric surface of the bedrock unit, leakage from the overlying unit into the
bedrock is possible.
The bedrock aquifer is contaminated with a.VOC plume, comprised mainly of TCE and its degradation
products, cw-l,2-DCE and vinyl chloride. The center of the plume is located at the southern boundary of
the Site. Prior to start-up of the "interim" ground-water recovery system, TCE, vinyl chloride, and 1,2-
DCE were detected in five, on-site and off-site, wells at levels that exceeded their respective MCL's.
VOC contaminants were detected in private wells at an approximate distance of 2,000 feet downgradient
of the Site during initial sampling events. The estimated extent of the VOC plume prior to start up of the
ground-water recovery and treatment system is shown in Figure 5.2.
5.2.3 Surface Water
The Site is bounded on the east by the Cumberland River. The River flows from north to south and
serves as a discharge point for surface water drainage leaving the Site. The Harlan County Municipal
water intake is located upstream of the Site at the Poor Fork Branch.
5.3 Nature and Extent of Contamination
5.3.1 Removal Action
Overburden Soils
A Removal Action was conducted at NEC during the period October 1990 through March 1992 to
address immediate threats to human health. The Removal included the Preliminary Site Assessment,
sampling of Site and nearby residential ground-water wells, and delineation and excavation of VOC,
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Record of Decision
National Electric Coil Co., Site
Page 10 of 53
PCB, and metal contaminated soils down to a depth of approximately eight feet.
Analytical results of the samples collected in conjunction with the Removal Action and other site
assessment investigations showed Site soils to be contaminated with VOCs, PCBs, and metals.
Contaminated soils and debris, totaling approximately 5,100 tons, were excavated for off-site disposal
from five principle areas: (1) the rear of the property along the bank of the Cumberland River where fill
material was located; (2) an outfall area, also located along the River, at the rear of the property where
two drainage pipes leading from the plant discharged; (3) an isolated area along the south fence line and
adjacent to the trailer park; (4) an isolated area where equipment and drums were stored; and (5) an area
where two drainage lines leading from the plant were located. The action levels that dictated removal
were (1) 10 mg/kg PCBs; (2) 10 mg/kg total VOCs; (3) 5 mg/0 TCLP lead; and 5 mg/0 TCLP chromium,
and (4) 100 mg/kg total lead and chromium. The areas where soils were excavated are shown in Figure
5.3.
5.3.2 Remedial Investigation/Feasibility Study
An RI/FS is conducted at Superfund sites to determine the nature and extent of contamination at a site and
to provide and evaluate appropriate alternatives for permanent site cleanup. The NEC RI/FS was
conducted under a May 1992 Administrative Order by Consent between EPA and McGraw
Edison/Cooper Industries, Inc. The field work began in October 1992, and included the following: (1)
installation of additional ground-water monitoring wells; (2) soil sampling on site and across the fenceline
on the mobile home park property; (3) sediment sampling; (4) resampling of select on-site and off-site
ground-water wells; and (5) collection of benthic organisms and fish from the Cumberland River.
" ' liivcsiluaiiun
The RI/FS hydrogeologic investigation included the following: (1) installation of three off-site monitoring
well clusters consisting of two wells each, including rock coring, discrete interval ground-water sampling
and packer testing; (2) installation of two on-site monitoring wells; (3) collection of ground-water
samples from 27 bedrock wells, including on-site monitoring wells, newly installed off-site monitoring
wells and off-site private wells; (4) measurement of water levels in 37 wells, including on-site monitoring
wells, newly installed off-site monitoring wells, and off-site private wells; and (5) collection of ground-
water samples from four shallow wells located at the NEC site.
The following conclusions regarding ground-water contamination have been made as the result of review
of the RI data:
• The areas of ground-water contamination have been delineated as follows: (l)the
shallow/alluvial aquifer (15 to 40 feet); (2) the intermediate zone of the bedrock aquifer (40 to 80
feet); and (3) the deeper zone of the bedrock aquifer (80 to 125).
• Significant quantities of Site-related contaminants are found in ground water contained in the
deep bedrock zone beneath and down gradient of the Site and in the shallow aquifer and
intermediate bedrock zone located beneath the Site. The center of the plume in the deeper
bedrock zone appears to be located at the southern boundary of the Site, and the plume
contamination consists primarily of trichloroethene (TCE), 1,2-dichloroethene (1,2-DCE), and
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Record of Decision
National Electric Coil Co., Site
Page 11 of 53
vinyl chloride.
• The former Holiday Trailer Court community well, at 356 feet, is the deepest off-site well from
which contaminated ground-water samples have been collected. But the well is cased only
through the overburden and is constructed in 200 feet of open borehole. More definitive discrete-
interval ground-water sampling techniques indicated that the vertical extent of the VOC plume in
the fractured bedrock extends to a depth of only 160 feet. The most concentrated zone of VOC
. contamination is identified at a depth approximately 50 to 75 feet below ground surface (bgs).
• The shallow aquifer and the upper zone of the bedrock aquifer are impacted primarily by TCE
' andl,2-DCE.
On-site Soil Sampling
On-site soil samples were collected from subsurface areas where 1991 Removal Action confirmatory
sampling indicated that contaminants remained at levels above "non-detect." The purpose of this
sampling was to determine whether contaminants remained in subsurface areas in quantities that might
leach into ground water. Six soil borings (total of 12 soil samples) were cored at the NEC site. From
these borings subsurface soil samples were collected at depths ranging from four to 8 feet. Analysis of
the samples indicates that neither VOCs nor inorganics, such as lead and chromium, remain in the
subsurface at levels that would significantly impact ground water via leaching.
Off-site Soil Sampling
Off-site soil samples consisted of twenty surface (0 to 0.5 feet deep) and nine subsurface (2 to 3 feet deep)
soil samples. These samples were taken from the Holiday Mobile Home Park located adjacent to the
NEC facility. Off-site soil samples were collected from the Holiday Mobile Home Park to determine
whether soils located there had been impacted by the contaminants originating at the NEC site. The area
sampled at the mobile home park stretched the length of the fenceline that separates the properties, and a
distance from the fenceline, of 100 feet onto the trailer park property.
Only one of the twenty-nine samples collected marginally exceeded the 1,000 ng/kg (part per billion)
Superfund PCB action level. No VOCs were detected in the off-site soils, and only low levels of
semivolatiles and pesticides were detected. Low levels of dioxins and furans were detected in surficial
soil samples collected near the fence line at the mobile home park. Inorganic concentrations detected in
the off-site soils were consistent with background or naturally occurring levels.
Sediment Sampling
Sediment samples were collected from nine locations within the Cumberland River. Sediments in the
vicinity of and down gradient of NEC were collected to determine if the Cumberland River has been
significantly impacted by releases from the site. Sampling stations were designated upstream,
downstream, and adjacent to the Site.
Site-related contaminants such as TCE and 1,2-DCE were detected in the sediment samples collected near
NEC Outfall 001, but not in samples collected further downstream. The migration of the contaminants, in
-------
Record of Decision
National Electric Coil Co., Site
Page 12 of S3
the sediments, appears to be limited to the immediate vicinity of the outfall. PCBs and other
semivolatiles were also located at the outfall, but they were also detected both upstream and downstream
of the Site. This indicates that sources of these contaminants, other than NEC exist upstream of the Site.
The presence of these contaminants in nearby river sediments is most likely due to general pollution of
the river by a variety of unknown origins. The estimated risks among the three sampling stations indicate
that the sediment obtained from the Cumberland River near-Site station and downstream stations differ
less than one order of magnitude from that of sediment collected at the Cumberland River upstream
station.
Aquatic Assessment
An aquatic assessment was conducted to determine the impact of contaminant releases on the Cumberland
River. Benthic macroinvertebrate samples were collected from three locations (or stations), and predator
and bottom-feeding fish tissue composites were collected from four locations.
PCBs were found in sediment samples at each of the sampling stations where fish were caught for
analysis, including those caught at the sampling station approximately five miles upstream. PCBs were
detected in the tissues of 8 of the 9 fish samples analyzed. The levels detected ranged from 140 ug/kg to
950 ug/kg, which were below the United States Food and Drug Administration (USFDA) action level and
State Fish Advisory Level of 2,000 ug/kg. Further, a 1994 Commonwealth of Kentucky study, which
was based on more than 150 samples taken from various Kentucky streams, indicates that PCB levels in
fish averaged 370 ug/kg (Appendix C). The qualitative benthic organism study indicated that aquatic
populations did not significantly differ among the upstream and downstream sampling stations.
A meteorological (MET) station was installed at the Site in order to collect site-specific atmospheric data,
such as wind speed and direction, temperature, relative humidity, and precipitation, for use in air
dispersion models used to predict impacts from the air stripper emissions. Data used in conjunction with
this ROD was collected from June 1993 to May 1994. The prevailing wind direction at the Site was from
the southwest to the northeast at an average speed of 2.5 miles per hour.
Results from air sampling activities do not indicate any vinyl chloride, 1,2-DCE or TCE in ambient air at
the NEC fence line or on the Holiday Mobile Home Park. Concentrations of vinyl chloride, 1,2-DCE,
and TCE detected at the stack's emission point were below health-based action levels for inhalation.
5.3.3 Interim Remedial Action
The on-site ground-water recovery and treatment system was started in July 1993 with ground water
being pumped from CMW-5-11 at a rate of approximately 100 gallons per minute (gpm). A baseline
sampling event was conducted before start-up of the extraction well system to determine baseline VOC
concentrations to record water levels prior to and after start-up of the pumping activities (Figure 5.3).
The resultant potentiometric surface map for December 1993 (Figure 5.4) shows a reversal of the
hydraulic gradient toward the pumping well from the area southwest of the Site. The monitoring
program consisted of thirty-three residential, production, and monitoring wells, which were sampled
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Record 'of Decision
National Electric Coil Co., Site
Page 13 of 53
during the RI to record ground-water quality and water levels.
Monitoring wells, screened at a shallower depth than the pumping well, indicated that the rocks beneath
the Site acts as a semiconfined aquifer with leakage from the overlying unit. As a result, it appears that
pumping from CMW-5-11 is not recovering a significant quantity of ground water from the shallower
bedrock zone.
As the result of pumping from the on-site extraction well, ground-water levels in the valley have been
drawn down as much as 6 feet at a distance of 3,500 feet downgradient of the pumping well, and the
hydraulic gradient has been reversed to produce flow toward the pumping well throughout this distance
(Figure 5.5). Prior to initiating the ground-water remediation, the VOC plume extended down gradient
(southwest), in the deep bedrock aquifer to a distance of approximately 2,000 feet with highest area of
concentration located near the Site's southern boundary. Subsequent sampling events indicate the
"interim" ground-water system has halted the downgradient migration of the VOC plume, as evidenced
by the absence of VOC's in off-site wells, in which Site-related chemicals were detected when sampled
prior to system start up. This apparent reduction in VOC levels and the lateral extent of the plume are
probably due in part to other factors: (1) the bedrock aquifer downgradient of the Site is now under
relatively static conditions since the Dayhoit community is no longer using their private wells (i.e., for
pumping) which inadvertently draws the plume downgradient; and (2) natural attenuation and degradation
ofVOCs.
-------
Figure S.la
Generalized Stratigraphic Column
DESCRIPTION
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-------
Figure 5.1c
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-------
MATIONAL ELECTRIC COIL SITE
HARLAN. KENTUCKY
NATIONAL
tXECTRIC COIL
- HOLIDAY
MOBILE HOME
PARK
o
LEfiENQ
» WEU. MONITORED FOR WATER DUALITY
/APPROXIMATE BOUNDARY Of VOC PLUME
PRIOR TO START UP OF THE GROUND-WATER
RECOVERY AND TREATMENT SYSTEM
APPROXIMATE LOCATION OF
VOC PLUME-JULY 1993
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JOB NO. 4I..06J5-08
FIGURE I-30|
-------
QUTFAbL 001 AREA
-------
127
NOTES:
•• MEASUREMENT NOT TAKEN
MSI MEAN SEA LEVEL
CROUNO-WATER ELEVATIONS NOT USED FOR POTENTIOMETRIC MAPS:
1. NOT DIRECTLY HYORAUUCALLY CONNECTED TO PUMPED AOUIFER
(NO OR VERY LITTLE REACTION TO PUMPING)
> 2. LEAST REASONABLE WATER ELEVATION IN CLUSTER IN RELATION TO
NEARBY WATER ELEVATIONS AND DRAWDOWN.
3. WELL IS BEING USED AS A WATER SUPPLY WELL, (PUMPED WELL).
4. EXTREME DISTANCE FROM OTHER MONITORING WEUS AND
VARIABLE DRAWDOWNS.
PUMPED WELL LOCATION
WELL LOCATION WITH
GROUND-WATER ELEVATION (MSL)
1131 GROUND-WATER CONTOUR (FEET)
1131 INTERPRETED GROUND-WATER
CONTOUR (FEET)
. GENERALIZED DIRECTION OF
GROUND-WATER FLOW
SCALE IN FEET
NATIONAL ELECTRIC COIL SITE
HARLAN. KENTUCKY
POTENTIOMETRIC SURFACE MAP
S MONTHS AFTER PUMPING STARTED
12-30-93
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-------
SITE LOCATION
o
HOLIDAY
^13 MOBILE HOME
rt>
r*
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89"
n
n
TO
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•127
IIIS.TI
iEQEMR
PUMPED WELL LOCATION
WELL LOCATION WITH
GROUND-WATER ELEVATION (MSL)
-1131 GROUND-WATER CONTOUR (FEET)
-1131— INTERPRETED GROUND-WATER
CONTOUR (FEET)
GENERALIZED DIRECTION OF
GROUND-WATER FLOW
NOTES:
•• MEASUREMENT NOT TAKEN
MSt MEAN SEA LEVEL
GROUND-WATER ELEVATIONS NOT USED FOR POTENT10MEIRIC MAPS:
1. NOT DIRECTLY HYDRAULICALLY CONNECTED TO PUMPED AQUIFER
(NO OR VERY LITTLE REACTION TO PUMPING)
1. LEAST REASONABLE WATER ELEVATION IN CLUSTER IN RELATION TO
NEARBY WATER ELEVATIONS AND DRAWDOWN.
3. WELL IS BEING USED AS A WATER SUPPLY WELL. (PUMPED WELL).
4. EXTREME DISTANCE FROM OTHER MONITORING WELLS AND
VARIABLE DRAWDOWNS.
! P
|
•a
o
?
a
n
to
t
SCALE IN FEET
1200
NATIONAL ELEC'IRIC COIL SITE
HARLAN. KENTUCKY
POTENTIOMETRIC SURFACE MAP
11 MONTHS AFTER PUMPING STARTED
6-28-94
JOB NO. 41-0635-08
FIGURE 1-M
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Record of Decision
National Electric Coil Co., Site
Page 21 of 53
6.0 SUMMARY OF SITE RISKS
6.1 Human Health Risks
During the Superfund process, EPA uses the baseline risk assessment (BRA) to evaluate whether a site, in
its current state, poses risks that are significant enough to endanger human health and/or the environment
These risks can either be current or potential threats resulting from contaminants migrating in ground
water or surface water, released to the air, leaching through the soil, remaining in the soil, or
bioaccumulating in the food chain at the site. Risk to human health is defined as the likelihood that
people living, working, or playing on or near the site may experience health problems as the result of their
exposure to contaminants from the site. The environmental risk evaluation appraises actual or potential
effects of a site on plants and animals. The NEC BRA was prepared in conjunction with the RI/FS and
finalized in June 1995.
EPA bases its decision to conduct site clean-up on the risk to human health and the environment that
might be expected if no clean-up action is taken at the site. This means that cleanup actions are taken
only when it is determined that risks at the site exceed the cancer risk level of 10"4 (the incremental
probability of an individual developing cancer over a 70-year lifetime is 1 in 10,000) or if
noncarcinogenic hazard indices exceed a level of 1. Once either threshold has been exceeded, remedial
action alternatives are designed to attain a risk level within EPA's acceptable risk range of 10"6 to 10"4
(between 1 in 1,000,000 and 1 in 10,000) and a hazard index of 1.
6.1.1 Chemicals of Concern
As part of the BRA, environmental data from the RI were tabulated, showing the occurrence and
distribution of chemicals in the various environmental media relevant to the risk assessment. The
complete listing of detected chemicals in ground water is presented in Table 1 of the BRA, while the
other media are presented in Tables 2 through 6. From this list of organic and inorganic substances
detected at the Site, chemicals of potential concern (COPCs) were determined for each medium. COPCs
were selected when the maximum chemical concentration detected in a medium exceeded the federal and
state regulatory standards and criteria, EPA Region III risk-based concentrations, or site-specific
background concentrations. The chemical concentrations detected in ground water were compared to
federal Maximum Contaminant Levels (MCLs), Kentucky Drinking Water Regulations, and Region III
risk-based concentrations for tap water and background. On-site subsurface, off-site surficial soil, and
sediment concentrations were compared to background and Region III risk-based concentrations for
residential soil. Detected concentrations of chemicals in surface water were compared to EPA Ambient
Water Quality Criteria. Detected concentrations of chemicals in fish tissue were compared to Region III
risk-based concentrations for fish.
After completion of the risk characterization portion of the BRA, the COPC listing was then pared down
to chemicals of concern (COCs). COCs were limited to those COPCs that: (1) were detected in a
pathway that exceeds a carcinogenic risk of 10"4 or HI of 1; (2) were detected within that pathway at an
individual concentration that exceeded a 10"6 carcinogenic risk and/or a HQ of 0.1; (3) exceeded a federal
MCL; or (4) exceeded chemical concentrations detected in nearby non-Site impacted media. The COCs
for this site are presented in Table 6.1. The exposure point concentration (EPC) for each COC is
included in Table 6-2a and 6-2b.
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Record
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Record of Decision
National Electric Coil Co., Site
Page 23 of 53
calculated for each chemical and receptor. Estimates of human intake were expressed in terms of mass of
chemical per unit body weight per time (mg/kg/day). Estimates of human intake for non-carcinogens
were calculated differently from those associated with carcinogenic effects. For non-carcinogens, intake
is averaged over the duration of exposure and is referred to as the average daily dose (ADD). For
carcinogens, intake is averaged over the average lifespan of a person (70 years) and is referred to as the
lifetime average daily dose (LADD). ADDs and LADDs were calculated using standard EPA
assumptions and calculated exposure point concentrations (EPCs).
6.1.3 Toxicity Assessment
A toxicity assessment is conducted to further determine the potential hazard posed by COCs for which
exposure pathways have been identified. Available evidence is weighed in regards to the potential of
particular contaminants to cause adverse effects in exposed individuals and to provide, where possible, an
estimate of the relationship between the extent of exposure to a contaminant and the increased likelihood
and/or severity of adverse effects.
Cancer Slope Factors (CSFs) have been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic COCs. CSFs,
which are expressed in units of (mg/kg-day)'1, are multiplied by the estimated intake of a potential
carcinogen to provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure
at that intake level. The term "upper bound" reflects the conservative estimate of the risks calculated for
the CSF. Use of this approach makes underestimation of the actual cancer risk highly unlikely. CSFs are
derived from the results of human epidefniological studies and chronic animal bioassays, which include
animal-to-human extrapolation and uncertainty factors (e.g., to account for the use of animal data to
predict effect on human).
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health
effects from exposure to COCs exhibiting noncarcinogenic effects. RfDs, which are expressed in units of
mg/kg-day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals.
Estimated intakes of COCs from environmental media (e.g., the amount of a contaminant of concern
ingested from contaminated drinking water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies, which include uncertainty factors to account for the use of
animal data to predict effects on humans.
The CSF and RfD toxicity values used in determining the upperbound level of cancer risk and non-cancer
hazard from exposure to a given level of contamination are included in Table 6.2. The major
assumptions about exposure frequency and duration that were used to quantify the exposure assessment
and toxicity values can also be found in this table.
6.1.4 Risk Characterization
In this step of the BRA, human intakes for each pathway of exposure are integrated with EPA reference
toxicity values to characterize both the carcinogenic and noncarcinogenic risk posed by the Site. So, the
results of the exposure assessment are combined with chemical-specific toxicity information to
characterize potential risks. Carcinogenic risk is presented as a probability value (i.e., the chance of an
individual contracting some form of cancer over a lifetime), while noncarcinogenic risk is expressed as
-------
Record of Decision
National Electric Coil Co., Site
Page 24 of 53
the ratio of exposure over toxicity.
For carcinogens, risks are estimated as the incremental probability of an individual developing cancer
over a lifetime as a result of exposure to the carcinogen. Excess life-time cancer risk is calculated from
the following equation:
Risk = Lifetime Average Daily Dose x Carcinogenic Slope Factor
where:
Risk = a unit-less probability (e.g., 2 x 10"5) of an individual developing cancer;
LADD = intake level averaged over 70 years (mg/kg-day) or lifetime average daily dose; and
CSF = carcinogenic slope-factor, expressed as (mg/kg-day)"1.
Excess lifetime cancer risks are determined by multiplying the intake level by the CSF. These risks are
probabilities that are generally expressed in scientific notation (e.g., 1 x 10"*). An excess lifetime cancer
risk of 1 x 10"6 indicates that, as a plausible upper bound risk, an individual has a one in one million
chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site. EPA prefers that remediation of Superfund sites achieve
a residual cancer risk that is within the acceptable risk range of 10"6 (1 in 1,000,000) to 10"4 (1 chance in
10,000).
The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a specified
time period (e.g., life-time) with a reference dose derived for a similar exposure period. The ratio is
derived by dividing the assumed daily exposure dose by the chronic RfD and is referred to as a Hazard
Quotient (HQ). By adding the HQs for all COCs that effect the same target organ (e.g., liver) within a
medium or across all media to which a given population may reasonably be exposed, the Hazard Indices
(HI) can be generated. Calculation of a HI in excess of unity indicates that potential for adverse health
effects. HI values above 1.0 indicate an unacceptable risk that increases in magnitude with higher
numerical scores above 1.0. The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium or across media.
The HI is calculated as follows:
Non-cancer HI=SHQj = ADD/RfD;
where
ADD = Average daily dose;
RfD = Reference dose; and
i = Individual contaminant
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Record of Decision
National Electric Coil Co., Site
Page 25 of 53
ADD and RfD are expressed in the same units and represent the same exposure period (i.e., chronic,
subchronic, or short-term).
Summary of Carcinogenic Risk and Non-Carcinogenic Risk
Current and future risk scenarios were evaluated for the exposed populations identified at the Site, child
and adult residents and adult workers. Under current and nature land use scenarios, the risks associated
with exposures to on-site subsurface soils, off-site surficial soils, and sediments were within EPA's
acceptable risk range of 10"6 to 10"*. Also, noncancer hazard indices for soils and sediments were
determined to be less than EPA's limit of 1.0 for soils and sediments.
Current and future risks associated with VOCs in ground water were greater than 10"4 for the lifetime
resident and adult worker. Hazard indices for both receptors, a lifetime resident and adult worker, also
exceeded 1.0. The bedrock aquifer is no longer used as a primary source of drinking water (since the
impacted area was provided connection to municipal water services in 1989) so it is not considered to
pose a current risk to residents or workers. However, in the future, more distant areas, not serviced by a
municipal water supply, may be impacted by the VOC plume, if it is allowed to migrate.
Carcinogenic risk associated with the ingestion offish was determined to also exceed 10"4 for current
adult residents, due to the levels of PCBs detected in fish samples. However, PCBs will not be designated
as a COC for fish because the levels detected in fish tissue for this investigation were comparable to
background levels for fish found in the waters of Kentucky, as reported in a recent Kentucky Division of
Water study. Further, the PCB levels detected were below the applicable US FDA level.
The complete summary of cancer and noncancer risks by exposure route is provided in Appendix D.
Table 6.2 summarizes the resultant risks and HQs for the evaluated exposure pathways that were
determined to pose potential threat to human health. Each entry in the table represents the aggregate of
the chemical specific risks and noncarcinogenic effects (i.e., His) detected in the given pathway. Ground
water is the only media presented in this table because it alone was determined to pose unacceptable risk
to humans. The "Upper Bound Sum of Cancer Risk and of the HF' entry represents the combined
carcinogenic risks and/or the combined noncarcinogenic effects of the COCs posed by the ground-water
pathways. The sum of risk from Site-related chemicals to the future on-site workers exposed to impacted
ground water was calculated to be 1 x 10"4. The summed upper bound carcinogenic risk to the lifetime
resident exposed to impacted ground water in the future was determined to be 9 x 10"4. Thus, the sum of
carcinogenic risk posed by ground water to future on-site workers and lifetime residents exceed EPA's
carcinogenic risk range.
The non-carcinogenic risk resulting from exposure to Site-related chemicals was also evaluated. The HI
for future child residents and adult residents who ingest VOC-contaminated drinking water from the
bedrock aquifer was evaluated to be 3 and 1.3, respectively.
Risk Uncertainty
There is a generally recognized uncertainly in human risk values developed from experimental data. This
is primarily due to the uncertainty of data extrapolation in the areas of (1) high to low dose exposure and
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National Electric Coil Co., Site
Page 26 of 53
(2) animal data to human experience. The site-specific uncertainty is mainly in the degree of accuracy of
the exposure assumptions. Most of the assumptions used in this and any risk assessment have not been
verified. For example, the degree of chemical absorption from the gut or through the skin or the amount
of soil contact is not known with certainty. Generally accepted default values provided in Agency
guidance were used here. However, it should be noted that little data or guidance is available on the
dermal absorption of particulate-bound contaminants. In the risk assessment conducted for the Site, the
dermal pathway yielded a significant contribution to the calculated direct exposure risks.
In the presence of such uncertainty, the Agency and the risk assessor have the obligation to make
conservative assumptions such that the chance is very small, approaching zero, for the actual health risk
to be greater than that determined through the risk process. While the process is conservative, it must be
based on realistic risk values. That balance was kept in mind in the development of exposure
assumptions and pathways and in the interpretation of data and guidance for this baseline risk assessment.
6.2 Environmental Risks
An environmental risk assessment (ERA) was conducted for the Site and surrounding area, in order to
evaluate off site impacts to the Cumberland River by means of potential migration of site-associated
chemicals within surface water and sediment. This ERA quantitatively evaluated the sediment chemistry
data and qualitatively evaluated aquatic macroinvertebrates and fish in terms of population diversity and
quantities. This ERA also evaluated the possibility for chemicals detected in sediment to migrate into
downstream aquatic environments. This evaluation was accomplished by comparing chemicals and their
concentrations between station groups.
The Site is considered industrial due to its current and projected usage and the permanent structures that
are in place there. This classification, and the presence of conditions where potential flora and fauna
would be disturbed from the natural state, suggest an inability for the site to provide habitat and support
wildlife. The industrialized state of the Site limits its usefulness to many potential receptors (i.e., small
mammals and birds) that require undisturbed woodlands for seclusion or shelter. Receptor species are not
expected to forage frequently on or inhabit this site, because of a general lack of a sufficient area for a
suitable habitat. Thus, there was limited potential for occurrences of terrestrial or semi-aquatic wildlife
on the Site.
The types of habitats, the dominant species of flora and fauna, and possible habitats for endangered and
threatened species were identified in the RI. The wildlife community within the general area (Bledsoe,
Harlan, Helton, and Wallins Creek counties, Kentucky), which was identified by the Kentucky
Department of Fish and Wildlife Resources, included 95 known species of amphibians, fish, mammals,
and reptiles. A review of literature completed by the Kentucky State Nature Preserves Commission
indicated that no protected species or sensitive environments inhabit the approximate 2-mile radius that
encompasses the Site.
Sediments were collected from nine stations located in the Cumberland River and grouped together as
upstream, near-site, and downstream. The purpose of the station grouping was to assist in distinguishing
among potential sources of chemicals off-site in the Cumberland River (i.e., hydrologically upgradient
[upstream], immediately adjacent to the site [near-site], and downgradient [downstream] from the site).
Sediment samples were analyzed for the complete Target Compound List/Target Analyte List (TCL/TAL)
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National Electric Coil Co., Site
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compounds. These sediment sample locations were grouped according to the geographical/hydrological
position of each station in the river, relative to outfall 001, from which surface water and NEC floor
drains once discharged.
The ERA indicated that predicted risks to aquatic receptors at near-site sediment stations were
approximately two times higher than those predicted for upstream sediments. The results of the
macroinvertebrate survey presented in the RI indicated that the community was non-impaired adjacent to
the Site and slightly impaired downstream from the Site, relative to the upstream station. Upstream and
downstream surface water sample results were also evaluated for this ERA. Contaminant concentrations
were not significantly different between the two sets of samples.
RI fish tissue sampling activities were conducted during two periods from the sampling stations, August
1993 and November 1993, and were analyzed for lipid content, PCBs, and CLP-TAL metals. The
concentrations of Arochlor-1260 (PCBs) detected in the fish tissue samples did not vary between
sampling stations and were similar to levels reported for fish species collected at other locations in eastern
Kentucky. The concentrations of inorganics detected in fish samples exhibited some variability, although
most analytes were present at similar levels between species and stations.
6.3 Summary
Cancer risks associated with exposure to environmental media by human receptors were calculated for the
current and future use scenarios. The carcinogenic and noncarcinogenic risks associated with exposures
to on-site subsurface soils, off-site surficial soils, and sediments were within EPA's acceptable risk range
of 10"6 to 10"4. However, risks associated with ground water were greater than 1 x 10^* for the lifetime
resident and adult worker, which exceed EPA's carcinogenic risk range. Non-carcinogenic risks for
ground water, only, were determined to exceed the HI threshold of 1 for both future child and future adult
residents. Risks associated with the ingestion offish, also, exceeded 1 x 10"4 for the current residential
scenario.
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National Electric Coil Co., Site
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•.' ••• "• '•' v'-;. >--;::; TABLE 6.1
: ChenUctli of Concern
National Electric CoB Co VCooper Industries Site
Future Use Residential Scenario (Chfld and Adult) for Ground water
COCs with Risks Exceeding 10*
1,1-Dichloroethene
1,1,2,2-Tetrachloroethane
Trichloroethene
Vinyl Chloride
COCs with HQs Exceeding 0. 1
1 ,2-Dichloroethene
Notes:
1. Pathway risks for on-site subsurface soils, on-site surftcial soils, and sediments were within the risk range of 10"* to 10* and hazard indices did
not exceed 1.0.
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National Electric Coil Co., She
Page 29 of 53
TABLE 6-2a
Summary of Cancer and Noncancer Risks by Exposure Route
for Lifetime Resident
National Electric Cou/Cooper Industries Site
Chemical of .
Concern
CSP~*.m*-
(mg/kg-day) '
Cancer
Weight of
Evidence
RfD-*— -
(mg/kg-day)
RME
Oig/rt)
Cancer
Risk
Lifetime
HQ
Adult
Resident
HQ
Child
Resident
Source
Exposure Pathway: Ingestion of VOC Contaminated Private Well Water Recovered from the Bedrock Aquifer
1,1 -DCE
1,2 DCE
1,1,2,2,-Tetra-
chloroethane
TCE
Vinyl
Chloride
6.0E-01
-
2.0E-01
1.1E-02
1.9E+00
C
D
. C
-
A
9E-03
9E-03
-
6E-03
-
2.6
250
2.0
108
20
2E-05
-
6E-06
2E-05
6E-04
0.008
0.8
-
0.5
-
0.02
2
-
1
-
1
2
1,2
3
2
Exposure Pathway: Inhalation of VOCs During Showering and Non-showering Use (water obtained from bedrock aquifer)
1,1 -DCE
1,2 DCE
1,1,2,2,-Tetra-
chloroethane
TCE
Vinyl
Chloride
2.0E-01
-
2.0E-01
6.0E-03
3.0E-01
C
D
C
-
A
-
-
- .
-
-
2.6
250
2.0
108
20
IE-OS
. -
9E-06
2E-05
2E-04
-
-
-
-
-
-
-
-
-
-
1
2
1,2
3
2
Upper Bound Sum of Cancer Risk for Ground-water Ingestion & Inhalation of VOCs:
Future Lifetime Resident (Child and Adult) = 9E-04
Upper Bound Sum of Hazard Indices for VOCs
Future Child Residents = 3; Future Adult Residents = 1.3.
Notes:
RfD Reference Dose
- Not Applicable/Not Available
RME Reasonable Maximum Exposure
HQ Hazard Quotient
. CSF Cancer Slope Factor
Sources:
1. EPA, 1994. Integrated Risk Information System
2. EPA, 1993. Health Effects Assessment Summary Tables
3. EPA, 1993 Superfund Health Risk Technical Support Center
Cancer Risk Formula:
Ingestion Showering and Non-showering Inhalation
Risk = EPC x EF x ED x SF. x IR- IEPCxNTEE+EPCjtIR.IxrEFxEDxSF.1 HI
BW x AT x 365 days/yr BW x AT x 365 days/yr
Where:
BW Body Weight = 70 kg adult, 15 kg child; AT = Averaging Time = 70 years;
EF Exposure Frequency = 350 days/year. ED Exposure Duration = 30 years adult, 6 years child;
CSF,f Inhalation or Oral Cancer Slope Factor, EPC Exposure Point Concentration (, in air);
IR, Daily Indoor Inhalation Rate = 15 mVday.
RfD0, Oral or Inhalation Reference Dose; NIEE Non-ingestion equivalent exposure rate
IR, Daily Water .Ingestion Rate = 2 L/day adult, 1 L/day child.
Non-Carcinogenic Risk (Hazard Index) Formula:
Ingestion Showering and Non-showenng Inhalation
EPCxEFxEDxIR- ; EPCxEFxEDxNIEE + EPCjcEFxEDxIR.
RfD,,xBWxATx365d/yr RID. x BW x AT x 365days/yr
Cancer Weight of Evidence Classification:
A Human Carcinogen
C Possible Human Carcinogen
D Not Classifiable as a Carcinogen
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TABLE 6-2 b
Summary of Cancer and Noncancer Risks by Exposure Route
for Adult Worker
National Electric Coil/Cooper Industries Site
Chemical of
Concern
CSF^,
: (mg/kg-day)'1
Cancer
Weight of
Evidence:
•:RlDrrJ^.. T,r
(mg/kg-day)
RME
OIB//«)
Cancer Risk
Lifetime
HQ
Adult
Worker
Source
Exposure Pathway: Ingestion of Contaminated Private Well Water Recovered from the Bedrock Aquifer
1,1-DCE
1,2 DCE
1.1,2,2,-Tetra-
chjoroethane
TCE
Vinyl Chloride
6.0E-01
-
2.SE-01
1.1E-02
1.9E+00
C
D
C
-
A
9E-03
9E-03
-
6E-03
-
2.6
250
2.0
108
20
5E-06
-
1E-06
4E-06
1E-04
0.003
0.3
-
0.2
-
1
2
1,2
3
2
Exposure Pathway: Inhalation of VOCs During Showering (water obtained from bedrock aquifer)
1,1-DCE
1,2 DCE
1,1,2,2,-Tetra-
chloroethane
TCE
Vinyl Chloride
2.0E-01
-
2.0E-01
6.0E-03
3.0E-01
C
D
C
-
A
-
-
-
-
-
2.6
250
2.0
108
20
2E-06
-
1E-06
2E-06
2E-05
-
-
-
-
-
1
2
1,2
3
2
Upper Bound Sum of Cancer Risk for Ground-water Ingestion & Inhalation of VOCs:
Future Adult Worker = 1E-04
Upper Bound Sum of Hazard Indices for Ingestion and Inhalation of VOCs
Future Adult Worker = 0.5
Notes:
RID Reference Dose HQ Hazard Quotient
- Not Applicable/Not Available CSF Cancer Slope Factor
RME Reasonable Maximum Exposure
Sources:
1. EPA. 1994. Integrated Risk Infoimation System
2. EPA, 1993. Health Effects Assessment Summary Tables
3. EPA. 1993 Superfund Health Risk Technical Support Center
Cancer Risk Formula:
Ingestion Inhalation During Showering
Risk = EPCxEFxEDxSF.xIR-: EPCxEFxEDxSF. x NIEE HI =
BWxATx365days/yr BW x AT x 365 days/yr
Where:
BW Body Weight = 70 kg adult; 15 kg child; AT = Averaging Time = 70 years;
EF Exposure Frequency = 250 days/year, ED Exposure Duration = 25 years adult worker.
CSF,_0 Inhalation or Oral Cancer Slope Factor. EPC Exposure Point Concentration (, in air);
Rfl\, Oral or Inhalation Reference - Dose; NTEE Non-ingestion equivalent exposure rate
IR, Daily Water Ingestion Rate = 1 Uday
Non-Carcinogenic Risk (Hazard Index) Formula:
Ingestion
EPCxEFxED+IR.
RfD. x BW x AT x 365days/yr
Cancer Weight of Evidence Classification:
A Human Carcinogen
C Possible Human Carcinogen
D Not Classifiable as a Carcinogen
Inhalation During Showering
EPCxEFxEDxNIEE. EPCxEFxEDxIR-
RfD. x BW x AT x 365days/yr
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National Electric Coil Co., Site
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TABLE 63
Site Conceptual Model
National Electric Coll/Cooper Industries Site
SOURCE
ON-SITE
WASTE AND
SOILS
PRIMARY RELEASE/
TRANSPORT
MECHANISMS
NA
Leaching
Surface Runoff
Dust Generation
AFFECTED
MEDIUM
Subsurface Soil
Surficial Soil
Groundwater
Sediments
Fish
. Subsurface Soil to Air
Surficial Soil to Air
EXPOSURE
POINT
On-site
Off-site
On-site
Off-she
Off-site
Off-she
On-site
Off-site
EXPOSURE ROUTE
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Ingestion
Inhalation of VOCs
Ingestion
Inhalation of VOCs
Ingestion
Dermal Contact
Ingestion
Inhalation
Inhalation
RECEPTOR
Workers
Residents
Workers
Residents
Residents
Residents
Workers
Residents
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7.0 DESCRIPTION OF ALTERNATIVES
A feasibility study is conducted at Superfund sites to develop and evaluate remedial alternatives. For the
NEC ROD, remedial alternatives were assembled from applicable technology process options and were
then evaluated for effectiveness, implementability, and cost. The alternatives meeting these criteria were
then evaluated and compared to the nine criteria required by the NCP. In addition to the remedial
alternatives, the NCP requires that a no-action alternative be considered at every site in order to serve as a
point of comparison for other alternatives.
7.1 Ground-Water Recovery Alternatives
Remedial Alternative 1: No Action
Capital Cost: $0
Present Worth: $0
Annual O&M Cost: $0
Time to Construct: None
The no action alternative requires no remediation or institutional constraints and would leave the ground
water in place. No further sampling and analysis of ground water would occur under the no action
alternative. The no action alternative has been developed as a baseline remedial action for the Site to
serve as a comparison for the other alternatives.
Remedial Alternative 2: Ground-Water Monitoring
Capital Cost: $12,500
Annual O£M Cost: $137,500
Present Worth: $1,725,000
Time to Construct: One Year
Alternative 2 consists of a quarterly ground-water sampling program in which an estimated twenty-four
(24) monitoring wells and private wells would be sampled to monitor the VOC plume. Ground-water
samples would be collected and analyzed for the volatile organics on the TCL using CLP methods.
Approximately 15 wells would be used to monitor ground water in the deeper bedrock zone at depths
ranging from approximately 86 feet to 337 feet. The five existing shallow/alluvial on-site wells and the
two intermediate bedrock wells would also be sampled. At least two additional upper bedrock zone wells
(approximately 60 feet deep) would be installed on Site to provide increased coverage in this zone of the
bedrock.
Remedial Alternative 3A: Ground-Water Recovery Using Extraction Wells with Pumps - Shallow,
Intermediate and Deep Zones
Capital Cost: $136,900
Annual O&M Cost: $77,000 per year
Present Worth: $1,101,000
Time to Construct: Two Years
Alternative 3 A consists of recovering impacted ground water using a series of extraction wells installed in
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the shallow/alluvial aquifer and the upper and deeper zones of the bedrock aquifer. The estimated total
ground-water recovery rate for the shallow aquifer and the upper and deeper zones of the bedrock aquifer
is approximately 200 gpm, although the actual recovery rate may be more or less than 200 gpm. Ground
water recovered from the three zones would be transferred to an on-site treatment system. The treated
ground water would then be discharged to the Cumberland River in accordance with KPDES
requirements.
This alternative would utilize the existing on-site recovery well, CMW-5-11, or possibly employ a new
recovery well, installed on-site near the center of the VOC plume (near the southern boundary of the
Site). The new extraction well would pump at a rate of 100 to 125 gpm to recover impacted ground water
in the deeper bedrock. The use of off-site recovery wells for deeper bedrock ground-water recovery is not
anticipated since the on-going extraction activities indicate that on-site pumping is effective. The need
for off-site wells would be addressed during remedial design.
Additional recovery wells would be required to effectively capture the VOC plume in the shallow aqufer
and the upper bedrock zone. Approximately four recovery wells would be needed to extract impacted
ground water from the upper bedrock zone at an approximate recovery rate per well of 10 to 20 gpm. An
estimated 6 wells would be required in the shallow aquifer, operating at a rate per well up to 5 gpm. The
actual number of wells required, anticipated recovery rates, and the potential use of vacuum enhanced
recovery wells in the shallow zone would be determined during remedial design.
Existing monitoring wells and private wells would be used to monitor the effectiveness of the ground-
water recovery system. Additional monitoring wells may be required in the upper bedrock zone to
monitor the effectiveness of the recovery system associated with this area. It is assumed that the ground-
water monitoring program required for this alternative would be similar to that described in Alternative 2
except that sampling would be conducted on a semiannual rather than quarterly basis.
Remedial Alternative 3B: Ground-Water Recovery Using Extraction Wells with Pumps-
Intermediate and Deep Zones and Wellpoint Recovery System - Shallow Zone
Capital Cost: $122,800
Annual O&M Cost: $96,2000 per year
Present Worth: $1,272,000
Time to Construct: Two Years
Alternative 3B consists of a ground-water recovery system identical to the one described in Alternative
3 A for extraction within the upper and deeper zones of the aquifer. However, ground-water recovery
within the shallow aquifer would be accomplished using a wellpoint recovery system.
The wellpoint system would consist of a series of closely spaced wells installed in the alluvial zone, along
a line perpendicular to the direction of shallow ground-water flow. The wellpoints would be connected to
a header pipe or manifold pumped by a central vacuum pump. The wellpoints would be installed at a
depth of approximately 30 feet and spaced at 25 to 50 feet apart so that the zones of influence overlap
slightly.
The total ground-water recovery rate from the wellpoint system is anticipated to be 25 gpm. The ground
water recovered by the wellpoint system would be discharged into an equalization tank along with the
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ground water collected by extraction wells from the intermediate and deep zones of the aquifer. The
estimated total ground-water recovery rate for the shallow aquifer and the upper and deeper bedrock
zones is approximately 200 gpm, although the actual recovery rate may be more or less man 200 gpm.
Ground water recovered from the three zones would be transferred to an on-site treatment system. The
treated ground water would then be discharged to the Cumberland River in accordance with KPDES
requirements.
Ground-water monitoring would be conducted as part of this alternative to evaluate the effectiveness of
the recovery systems. It is assumed that the ground-water monitoring program required for this
alternative would be similar to that described in Alternative 3A.
Remedial Alternative 3C: Ground-Water Recovery Using Extraction Wells with Pumps-
Intermediate and Deep Zones and Interceptor Trench - Shallow Zone
Capital Cost: $495,7000
Annual O&M Cost: $74,400 per year
Present Worth: $1,419,000
Time to Construct: Two Years
Alternative 3C consists of a ground-water recovery system identical to the one described in Alternative
3 A for extraction within the upper and deeper zones of the bedrock aquifer. However, ground-water
recovery within the alluvial aquifer would be accomplished using an interceptor trench.
The interceptor trench would be constructed on-site near the riverbank area and perpendicular to the
direction of shallow ground-water flow. The interceptor trench would be installed to the depth of
bedrock, approximately 25 to 40 feet below ground surface.
The interceptor trench would be constructed by excavating existing soils to bedrock and installing a
perforated collection pipe at the bottom of the excavation. The bottom portion of the excavation would
then be backfilled with gravel or comparable granular fill material. A vertical impermeable barrier would
be installed on the downgradient side of the trench to prevent the lateral migration through the trench and
to minimize the infiltration of ground water from the down-gradient direction. The bottom surface of the
trench would be sloped toward a sump equipped with a submersible pump. Ground water that collects in
the trench would be removed by a submersible sump pump and discharged into an equalization tank at the
treatment system.
The estimated total flow rate from the interceptor trench would be approximately 25 gpm. As in
Alternatives 3A and 3B, ground water recovered from the three zones would be transferred to an on-site
treatment unit at a comparable total recovery rate. The treated ground water would then be discharged to
the Cumberland River in accordance with KPDES permit requirements.
It is assumed that the ground-water monitoring program required for this alternative would be similar to
that described in Alternative 3A.
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7.2 Ground-Water Treatment Alternatives
The following alternatives are designed to be combined with one of the ground-water recovery
alternatives previously presented as Alternatives 3A, 3B, and 3C to provide a complete ground-water
remediation system:
Remedial Alternative 4A: Ground-Water Treatment by Air Stripping with Activated Carbon Off-
Gas Treatment
Capital Cost: $183,800
Annual O&M Cost: $169,500 per year
Present Worth: $2,287,000
Time to Construct: Two Years
Alternative 4A employs a ground-water treatment system consisting of an air stripping tower and a
granular activated carbon (GAC) off-gas treatment unit. Alternative 4A would be combined with one of
the previously described ground-water recovery alternatives (Alternative 3A, 3B, or 3C) to provide a
complete ground-water remediation system.
As part of the on-going ground-water extraction activities, an air stripping tower and GAC off-gas
treatment unit are currently in operation at the Site. It appears that the existing air stripper is sufficiently
designed to effectively treat the anticipated increased flow of 200 gpm. Although, the existing system
may suffice for the final remedy, this alternative evaluation assumes that a new air stripping system and
GAC unit would be constructed.
The treatment system would be designed to remove VOCs from recovered ground water using the mass
transfer process of air stripping. The components of the ground-water treatment system would include an
equalization tank, packed-column air stripper, vapor-phase GAC treatment unit and off-gas exhaust stack.
Associated treatment system components would consist of air blowers, a transfer pump, duct heating unit,
and process piping and controls.
Ground water recovered from the shallow aquifer and the upper and deeper zones of the bedrock aquifer
would be transferred to an equalization tank, from which it would then be pumped to the top of the air
stripper at an estimated flow rate of approximately 200 gpm. The ground water would flow by gravity
through the packing material while air is simultaneously blown countercurrently and upward through the
packing from the bottom of the air stripper. The aeration of the water would cause VOCs to volatilize
into the air stream. Air and volatiles would then exit the air stripper through an exhaust line at the top of
the tower. The air mixture would be heated to remove moisture and then transferred to the GAC
treatment unit. Volatile organics in the air stream would adsorb to the activated carbon. The treated air
would then be recirculated through the unit or discharged to the atmosphere through a stack.
Treated ground water would flow from the packed section of the air stripper into an accumulation sump
located at the bottom of the air stripper. Treated ground water would be discharged by gravity to the
Cumberland River through an existing multiport diffuser pipe that extends approximately 36 feet into the
river. Discharge of the treated ground water would be in accordance with KPDES discharge limitations
and monitoring requirements.
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The vapor-phase GAC treatment unit would consist of a vessel filled with granular activated carbon. The
unit would include a duct heater to prevent condensation in the GAC unit. Depending on the size of the
GAC unit and the volume of air discharged from the stripping tower, the discharge line from the GAC
unit may include a recirculation blower loop to prevent channeling in the GAC unit.
The treated off-gas from the GAC unit would be discharged to the atmosphere through an exhaust stack.
The height of the stack would be determined based on air modeling to ensure that any VOCs discharged
to the atmosphere are sufficiently dispersed and that ambient air standards are maintained. Spent carbon
would be returned to the vendor for regeneration, and the carbon unit would DC refilled with regenerated
or new carbon.
The air stripper liquid effluent would be sampled to demonstrate compliance with KPDES discharge
limitations. The liquid influent to the air stripper will also be sampled routinely to evaluate the removal
efficiency of the unit. Sampling of the off-gas discharge stack would also be conducted to demonstrate
compliance with the USEPA emission standards.
Remedial Alternative 4B: Ground-Water Treatment by Air Stripping with Catalytic Oxidation Off-
Gas Treatment
Capital Cost: $328,800
Annual O&M Cost: $187,900 per year
Present Worth: $2,660,000
Time to Construct: Two Years
Alternative 4B consists of the air stripping process described for Alternative 4A along with a catalytic
oxidation treatment unit to remove VOCs from the air stripper off-g?.s. The primary components of the
catalytic oxidation unit are a heat exchanger, a burner, and a catalytic reactor.
The VOC-laden off-gas from the stripping tower would be transferred to the tube side of a heat exchanger
via a blower. The off-gas would be heated up to 700°F in order to prevent condensation of water vapor
and to reduce heating requirements in the burner. This high temperature off-gas would then be
transferred to the catalytic reactor. As the hot off-gas contacts the catalyst within the unit, an exothermic
(heat releasing) reaction would occur and would oxidize VOCs in the air stream to carbon dioxide, water
vapor, and inorganic acids. The treated hot air stream discharged from the catalytic reactor would
discharge to the shell side of the heat exchanger and would preheat the incoming, untreated air stripper
off-gas. Once the treated air passes through the shell side of-the heat exchanger, the air would be
discharged to the atmosphere through an exhaust stack. The height of the stack would be determined
based on air modeling to ensure that any VOCs discharged to the atmosphere are sufficiently dispersed
and that ambient air standards are maintained.
Remedial Alternative 4C: Ground-Water Treatment by Air Stripping with Resin Adsorption Off-
Gas Treatment
Capital Cost: $325,500
Annual O&M Cost: $176,200 per year
Present Worth: $2,512,000
Time to Construct: Two Years
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Alternative 4C consists of the air stripping process described for Alternative 4A along with a resin
adsorption treatment unit to remove VOCs from the air stripper off gas. The resin adsorption process
consists of a VOC adsorption unit that contains an adsorptive polymeric resin, a regenerative loop to
provide on-site regeneration of the resin, and a VOC desorption unit to condense VOCs removed during
the regeneration process. Recovered VOCs are ultimately transported off site for disposal. The process
includes two adsorption units or beds to permit continuous operation. One bed is operated in the
adsorption mode while the other bed is regenerated.
Treatment by resin adsorption would be performed by contacting the VOC-laden off gas with the resin
beds. The VOCs in the off gas would adsorb to the polymeric resin and the treated off gas would be
discharged to the atmosphere through an exhaust stack. The height of the stack would be determined by
air modeling to ensure that any VOCs discharged to the atmosphere are sufficiently dispersed and that
ambient air standards are maintained.
Once the resin is saturated with VOCs, the air stripping tower off gas would be diverted to the other resin
bed and the saturated bed would be regenerated. The regeneration process consists of drawing a vacuum
on the resin bed and increasing the temperature of the resin using electric heaters located inside the bed.
The combination of the vacuum and increased temperature causes VOCs adsorbed to the resin to
vaporize. The vaporized VOCs then are purged from the vessel using nitrogen as the carrier gas. The
recovered vapor stream is transferred to a condenser and chiller to remove the VOCs. The recovered .
VOCs would be stored temporarily on-sfte and routinely transported off- site for disposal at an approved
facility. The regenerated bed would be cooled and placed back into operation once the other resin bed is
saturated and ready for regeneration.
Remedial Alternative 5: Ground-Water Treatment by Ultraviolet Oxidation
Capital Cost: $280,000
Annual O&M Cost: $267,000 per year
Present Worth: $3,593,000
Time to Construct: Two Years
Alternative 5 consists of ground-water treatment utilizing ultraviolet (UV) oxidation. UV oxidation
treatment uses UV radiation, ozone, and hydrogen peroxide to oxidize (chemically decompose) VOCs in
the aqueous phase to carbon dioxide, water, and chlorine ions. The system consists of a UV oxidation
reactor, an air compressor/ozone generator unit, a hydrogen peroxide feed system, and a catalytic ozone
decomposition unit.
Ground water recovered from the shallow, intermediate, and deep zones would be treated in the UV
oxidation unit. Since both suspended solids and metal ions in the ground water may reduce the efficiency
of the UV oxidation system, removal of these metals may be required prior to UV oxidation treatment.
Filtration may be utilized to reduce the suspended solids and metal ions concentrations in the ground-
water stream. If filtration (as demonstrated during treatability studies) did not satisfactorily reduce these
concentrations, chemical precipitation would be required as a pretreatment process to UV oxidation.
Recovered ground water would be transferred to an equalization storage tank and then to the UV
oxidation reactor. Hydrogen peroxide would be mixed with the ground water as it flows through the
influent line to the reactor. Once the ground water and hydrogen peroxide mixture were introduced to the
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UV oxidation reactor, the mixture would be exposed to UV radiation and ozone. The UV radiation would
be provided by several UV lamps installed throughout the reactor. Ozone would be generated on site and
introduced to the reactor by a series of spargers designed to uniformly diffuse ozone from the base of the
reactor into the liquid mixture. The ground water and hydrogen peroxide mixture would be transferred to
the UV oxidation reactor at a specified rate to achieve the hydraulic retention time necessary for VOC
destruction.
Ozone that is not transferred to the liquid mixture would be present in the reactor off gas. The ozone
would be destroyed in the catalytic ozone decomposition unit, and the off gas would be discharged to the
atmosphere through a stack. The ozone decomposition unit would utilize a nickel-based proprietary
catalyst to reduce the ozone in the off gas to oxygen.
Remedial Alternative 6: Ground-Water Treatment by Activated Carbon Adsorption
Capital Cost: $108,800
Annual O&M Cost: $518,800 per year
Present Worth: $6,547,000
Time to Construct: Two Years
Alternative 6 consists of ground-water treatment using liquid-phase granular activated carbon (GAC).
Liquid-phase GAC adsorption is a physical treatment process that involves contacting the impacted liquid
stream with activated carbon.
The GAC system would consist of an equalization tank, two GAC units arranged in series, and associated
pumps, piping and control systems. Organic compounds in the liquid that have an attraction for the
activated carbon adsorb to the surface of the GAC and are remnvftH frnrn th
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Samples would be collected at these locations on a regular basis to determine when breakthrough of the
first GAC unit has occurred. Once breakthrough occurs, the first GAC unit would be replaced with a unit
that contains regenerated carbon. The secondary GAC unit would then be plumbed to receive untreated
ground water from the equalization tank, and the regenerated GAC unit would be plumbed to function as
the secondary or polishing GAC unit. This rotating procedure would be used to ensure that compliance
with KPDES discharge standards is maintained.
The GAC units would be designed to treat a liquid flow rate of approximately 200 gpm. Based on
preliminary design calculations, each GAC unit would contain approximately 10,000 pounds of activated
carbon. It is estimated that breakthrough of the first GAC unit in the treatment series would occur after
approximately seven days of continuous use.
In addition to monitoring the GAC units for breakthrough, monitoring of the treated effluent would also
be required to demonstrate compliance with KPDES discharge limitations. Since no air emissions would
be generated by the GAC treatment system, air monitoring would not be required.
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
USEPA Region IV selected Alternative 4B, combined with 3(A, B, or C) as its Preferred Alternative.
This section profiles the Preferred Alternative against the nine criteria, noting how it compares to the
other alternatives that were evaluated.
THE ANALYSIS
Threshold Criteria
8.1 Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative provides
adequate protection of human health and the environment and describes how risks posed through each
exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and/or
institutional controls.
Ground-water recovery Alternative 3 (A, B, or C) combined with treatment Alternatives 4(A, B, and C), 5,
or 6 is more protective of human health and the environment relative to that of the other alternatives
considered because these alternatives significantly reduce contaminant levels in the recovered water,
thereby mitigating subsequent exposure to contaminants. They each capture or destroy VOCs dissolved
in the recovered ground water or after VOC transfer to air.
The "No Action" Alternative (Alternative 1) and Alternative 2 are not protective because neither reduces
DOtential exposures tn site pmnnH water Thprefore neitVipr alternative will Kf» rnncirWpH fjirtn^r in fhic
* 1 - '*
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Primary Balancing Criteria
8.3 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refer to expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment over time, once cleanup levels have
been met. This criterion includes the consideration of residual risk and the adequacy and reliability of
controls.
Alternatives 4 (A, B, and C), 5, and 6 would be combined with one of the ground-water recovery
Alternatives 3 (A, B, or C) that will both remove contaminants from impacted ground water and retard the
migration of the VOC plume, thereby permanently eliminating the potential for the recovered
contaminants to threaten human health and the environment. All of the ground-water extraction
alternatives (3A, 3B, and 3C) should eventually provide a permanent remedy for ground water, although
Alternative 3C may recover a significant amount of water from the adjacent river.
Alternatives 4 (A, B, and C) involve the use of air strippers in which VOC contaminants are transferred
from a water medium to that of an air medium that must be treated in a further step. Each alternative
would employ air pollution control (APC) devices to capture the airborne pollutants. Alternatives 4 (A,
B, and C) would comply with health-based air emission levels set by EPA and developed from site-
specific meteorological data. Thus, compliance with health-based stack emission levels would ensure that
no significant long-term health risk would be posed by these alternatives to nearby residents. Similarly,
APC devices would be required if Alternative 5 were selected. Under this alternative an ozone off gas
would be produced that would require treatment prior to release to the atmosphere. No APC devices
would be required for Alternative 6 since off gas would not be generated.
8.4 Reduction of Toxicity, Mobility or Volume through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the preference for a remedy that
uses treatment to reduce health hazards, contaminant migration, or the quantity of contaminants at a site.
Each of the Alternatives, 3(A, B, and C), 4 (A, B, and C), 5, and 6 is a proven technology with
demonstrated field application. They are capable of permanently removing VOCs from ground-water
down to levels that meet KPDES discharge limits. However, each of the alternatives, except Alternative
6, produces a pollutant air stream that must be treated in a further step prior to release to the atmosphere.
Alternatives 4 (A, B, and C) utilize air stripping techniques that remove approximately 99% of VOCs
from the recovered ground water. The air pollution control units associated with each alternative remove
approximately 65%, 95%, and 95% of the VOCs, respectively, from the air stream prior its stack release.
Alternative 6 also removes VOCs at a rate of approximately 90% until saturation occurs. Alternative 5
permanently destroys VOCs in the liquid stream through oxidation. Alternative 4B permanently destroys
VOCs in the air stream through oxidation.
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8.5 Short-Term Effectiveness
Short-term effectiveness refers to the period of time needed to complete the remedy and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation of the remedy.
Construction activities associated with Alternatives 3(A, B, and C), 4 (A, B, and C), 5, and 6 will be
limited to the Site. As a result, there should be no adverse effects to the community from implementing
these alternatives. Short-term effects to on-site workers involved in the construction should be minimal.
However, health and safety procedures will be implemented during the construction as a precaution. The
time required for implementation of these alternatives is expected to be less than one year.
8.6 Implementability
Treatment equipment associated with Alternatives 4 (A, B, and C), 5, and 6 is available from multiple
vendors for use at the Site, with many components available as self-contained, skid-mounted units. The
existing multiport diffuser piping can be used to discharge treated ground water to the Cumberland River.
Use of Alternative 4B would require that a significant volume of natural gas or propane will be brought to
the Site routinely to fuel the catalytic oxidation system. Gas lines do not currently extend to the Site.
Alternative 5 would require daily inspections of the system, sampling, and maintenance to monitor
operations and, thus, is more labor intensive than the other alternatives. Further, the specialized labor
necessary to perform these tasks may not be available on daily basis in the area.
Use of Alternatives 4C and 5 would require that a heated shelter be erected to protect the systems during
extended periods of below-freezing temperatures or heavy precipitation. Alternative 6 would be subject
to weekly system shut downs as the saturated carbon in the GAC unit was being replaced with
regenerated carbon.
Ground-water recovery equipment specified in Alternatives 3(A, B, and C) would be readily available for
use at the Site.
8.7 Cost
A comparison of the estimated present worth costs associated with the five ground-water treatment
alternatives indicates that Alternative 4A ($2,287,000) will be the least expensive, followed by
Alternatives 4C ($2,512,000), 4B ($2,660,000), and 5 ($3,593,000). Alternative 6 represents the most
expensive ground-water treatment alternative ($ 6,547,000).
Capital costs will be highest for Alternative 4B ($ 328,000) and lowest for Alternative 6 ($108,800).
Annual O&M costs will be highest for Alternative 6 ($ 518,800) and lowest for Alternative A ($169,500).
A comparison of costs associated with the three ground water extraction alternatives indicates that Alter-
native 3 A is the least expensive ($1,101,000), followed by Alternative 3B ($1,272,000) and Alternative
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3C ($ 1,419,000). Capital costs will be much higher for Alternative 3C ($495,700) compared to
Alternatives 3A and 3B ($136,900 and $122,800, respectively). Annual O&M costs will be
approximately equal for Alternative 3 A and Alternative 3C, and will be higher for Alternative 3B.
MODIFYING CRITERIA
8.8 State Acceptance
The Commonwealth of Kentucky has worked closely with the Agency throughout the remedy selection
phase through review and comment of PRP prepared site sampling and decision documents and
collaboration on preparation of the remedial investigation. The Commonwealth has reviewed the
Proposed Plan and ROD and concurs with the selected remedy. A copy of the Commonwealth's letter of
concurrence is provided in Appendix E.
8.9 Community Acceptance
Verbal comments received at the July 11,1995 Proposed Plan public meeting and comments submitted to
EPA during the public comment period on the Proposed Plan, indicate that the community consists of
varied view points on its acceptance of EPA's preferred remedial alternative. Several community
residents have expressed support for the approach advocated by EPA both during the Public Meeting and
throughout the operation of the IRA. Still, a significant number of verbal and written comments received
by EPA prior to, during, and after the Public Meeting and public comment period indicated that a segment
of the Community disagrees with EPA's preferred remedial alternative and other actions conducted at this
site. The formalized comments forwarded and/or expressed verbally to EPA, in general, do not favor
Alternative 4B because of the perceived unacceptable risk posed by air emissions associated with this
technology.
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9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP, the detailed analysis of alternatives,
and public and state comments, EPA Region IV has selected Alternative 4B combined with Alternative 3
(A or B) as the remedy for the National Electric Coil Co./Cooper Industries Site. This response action
will involve ground-water remediation and will address contaminated ground water located in the
fractured bedrock and alluvial (shallow) aquifer beneath the Site. Alternatives 3A and 3B, both, involve
employing on-site recovery wells to recover bedrock ground water, but differ in the method used to
recover ground water from the alluvial aquifer. The total present worth of 4B is estimated at $2,287,000.
It will be combined with ground-water recovery alternative 3A or 3B, which is estimated at $1,101,000
and $1,272,000 respectively.
The major components of the ground-water remediation to be implemented involve the following: (1)
recovery of contaminated ground water from the impacted alluvial and bedrock aquifers beneath and
adjacent to the Site; (2) treatment of the recovered water with air stripping; (3) catalytic oxidation of the
VOC-Iaden off gas; and (4) discharge of the treated water to the Cumberland River.
The air stripping process is the most effective, compared to other technologies, at removal of dissolved
VOCs from a water stream, and it consistently achieves up to 99% removal rates. The resultant VOC-
laden air stream will require additional treatment. Catalytic oxidation will be employed as an air
pollution control method to reduce VOCs in the air stream to levels below that of EPA's risk-based stack
emission rate limits. Catalytic oxidation effectively and reliably operates at an efficiency rate of
approximately 95%. The remaining trace VOCs will be released to atmosphere from a stack. The treated
water stream leaving the air stripper system will be released to the Cumberland River in compliance with
applicable KPDES limits. This final resoonse action will he effective in redncim* the tnvir.ity^ mobility,
and volume of VOC contaminants extracted from the alluvial and bedrock aquifers by air stripping
dissolved VOCs in the ground water and by capturing the resulting airborne VOCs through emission
control measures.
The goal of this remedial action is to restore the ground water to its beneficial use, which is, at this site, a
drinking water aquifer. Based on information obtained during the RJ/FS, and the analysis of all remedial
alternatives, EPA and the Commonwealth of Kentucky believe that the Selected Remedy may be able to
achieve this goal. Ground water contamination may be especially persistent in the immediate vicinity of
the contaminants' source, where concentrations are relatively high. The ability to achieve cleanup goals
at all points throughout the area of attainment, or plume, cannot be determined until the extraction system
has been implemented, modified as necessary, and plume response monitored over time. If the Selected
Remedy cannot meet the specified remediation goals, at any or all of the monitoring points during
implementation, the contingency measures and goals described in this section may replace the Selected
Remedy and goals for these portions of the plume. Such contingency measures will, at a minimum,
prevent further migration of the plume by means of ground-water extraction and treatment technologies.
These measures are considered to be protective of human health and the environment, and are technically
practicable under the corresponding circumstances.
The Selected Remedy will operate for an estimated period of 30 years, during which time the system's
performance will be carefully monitored on a regular basis and adjusted as warranted by the performance
data collected during operation. Modifications may include any or all of the following:
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(a) at individual wells where cleanup goals have been attained, pumping may be discontinued;
(b) alternating pumping at wells to eliminate stagnation points;
(c) pulse pumping to allow aquifer equilibration and encourage adsorbed contaminants to partition into
ground water; and
(d) installation of additional extraction wells to facilitate or accelerate cleanup of the contaminant plume.
To ensure that cleanup goals continue to be maintained, the aquifer will be monitored at those wells
where pumping has ceased every five years following discontinuation of ground water extraction.
9.1 Major Components of the Ground-Water Extraction and Treatment System
Contaminated ground water shall be recovered, using multiple extraction wells completed in the upper
and deeper zones of the bedrock aquifer. The exact location and quantity of extraction wells will be
determined during the design of the ground-water recovery system. The recovery method that will be
utilized to extract ground-water from the alluvial aquifer will also be determined during remedial design.
Recovered ground water shall be treated using an on-site packed column and an air stripping unit fitted
with a catalytic oxidation pollution control device. The treated air stream will exit the stack at an
appropriate height in which dispersion of the remaining trace VOC's can be maximized. Site-specific
meteorological data will be used to derive an appropriate stack height.
9.2 Performance Standards
This response action controls risks posed by direct contact with ground water and minimizes migration of
contaminants in ground water. This objective will be accomplished by ground-water extraction and
treatment of the recovered water.
9.2.1 Ground-Water Extraction Standards
Ground water will be extracted from the surficial aquifer at an estimated rate of 25 gpm. Ground water
will be extracted from the upper zone of the bedrock aquifer at an estimated rate of 50 gpm and from the
deeper bedrock zone at an estimated rate of 125 gpm. The combined ground-water recovery rate for the
three is estimated to be approximately 200 gpm. However, the actual recovery rate may be greater than or
less than 200 gpm.
9.2.2 Ground-Water Treatment Standards
The performance standard for each COC in the ground water shall be the MCL for that chemical (the
federal ARAR for public drinking water supplies under the Safe Drinking Water Act) or a risk-based level
if there is no MCL. Ground-water recovery shall continue until the performance standards presented in
Table 9.1 are attained at the Wells designated by EPA as monitoring wells. These wells shall be
monitored, biannually, to demonstrate compliance with the ground-water performance standards and to
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record water levels.
9.2.3 Stack Emission Rates and Ambient Air Standards
The Agency has developed temporary health-based vinyl chloride, TCE, and cw-l,2-DCE emission limits
for this response action, using a dispersion factor based on one year of site specific atmospheric data.
Five years of site specific atmospheric data shall be collected in order to derive a final dispersion factor.
The emissions performance standards may need to be changed at that time to reflect the magnitude of
change in the updated dispersion factor.
The emission limits presented in Table 9.2 shall serve as performance standards for this ROD. The point
of compliance for these emission levels shall be the stack pipe exit point from which emissions are
released to the atmosphere. Ambient air monitoring shall also be performed at the Holiday Trailer Park
located next to the Site facility. The fence line separating the Site from the Holiday Trailer Park property
shall serve as the point of compliance.
The air stripper tower will be fitted with a catalytic oxidation unit to control VOC vapors exiting the
stack. Air emissions from the stripper will be monitored on a monthly basis, using TO-14 canister
sampling procedures, unless otherwise directed by EPA. Comparable air sampling methodologies may be
substituted or monitoring frequency may be altered at the discretion of EPA.
9.2.4 Treated Ground Water Discharge Standards
Treated ground water, exiting the tower, will be discharged to the Cumberland River in compliance with
the applicable KPDES rcquiraruerits. KPDES uisuiiargc mails will serve as performance standards for
this ROD and are presented in Table 9.3.
9.2.5 Compliance Monitoring
Stack air emissions, ground level ambient concentrations, and treated ground water exiting the air stripper
tower system shall be monitored at this site in order to demonstrate compliance with performance
standards. After demonstration of compliance with these performance standards set forth in Table 9.1,
Table 9.2, and Table 9.3, ground water shall be monitored for at least five additional years. If
monitoring indicates that the ground-water performance standards are being exceeded at any time after
pumping has been discontinued, extraction and treatment of the ground water will recommence until the
performance standards are once again achieved.
9.3 ARAR's
9.3.1 Applicable Requirements
Applicable requirements are those substantive requirements that specifically address the situation at a
CERCLA site.
401 KAR 63:022 is applicable to this response action because it regulates facilities which emit the toxic
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air pollutants, specifically cis- 1,2-Dichloroethene.
40 CFR §264.18(b), Floodplain Management mandates that hazardous waste treatment, storage or
disposal facilities located within a 100-year floodplain must be designed, constructed, operated and
maintained to avoid washout. This regulation is applicable because the Site is located within the 100-year
floodplain of the Cumberland River.
40 CFR 6.302, Fish & Wildlife Coordination Act, requires adequate protection offish and wildlife if any
stream or other body of water is modified. Additionally, actions in floodplains are required to avoid
adverse effects, minimize potential harm, and restore and preserve natural and beneficial values.
Kentucky Pollutant Discharge Elimination System (401 KAR 5. specifically Parts 031. 065. and 075).
Kentucky Water Quality Regulations are applicable to this response action because it regulates the point-
source discharge of treated ground water to the Cumberland River by setting discharge limitations and
monitoring requirements. This response action shall abide by the substantive requirements of these
regulations set by the Commonwealth of Kentucky, which has been authorized to implement the National
Pollutant Discharge Elimination System program under authority of the Clean Water Act (CWA) § 402.
Section 402 of the CWA incorporates sections 301, 302, 306, and 307.
Resource Conservation Recovery Act rRCRA) (42 U.S.C. §§ 6921-39 (§§ 3001-19); 40 CFR Parts 260-
270) regulates the treatment, storage, and disposal of hazardous waste from generation through ultimate
disposal. RCRA applicable requirements may include LDR and waste generator requirements set forth at
40 CFR Part 268.7 and Part 262. Any offsite facility receiving the hazardous waste for disposal will meet
the requirements set forth in 268.41. Certain RCRA regulations are applicable, specifically, LDRs.
Solid wastes resulting from the treatment of F001 ground water may be generated and shall be handled as
F001 listed RCRA solid waste until decontaminated. Applicable manifest and generator requirements
will also be met. Because the Commonwealth of Kentucky may be authorized for some or all of the
RCRA provisions, the applicable regulations are hereby incorporated by reference.
KRS 151.140 is applicable to this response action because it regulates the withdrawal of water from
public waters within the Commonwealth of Kentucky. This response action will comply with all
substantive requirements of this regulation.
9.3.2 Relevant & Appropriate Requirements
Relevant and appropriate requirements are environmental protection requirements that are both relevant
in terms of addressing problems or situations sufficiently similar to the circumstances of the proposed
response action and appropriate in terms of being well suited to the conditions of the particular site.
The Safe Drinking Water Act of 1974 (42 USC Sees. 300f-300j-l 1), as amended in 1986, is relevant and
appropriate for water that is used, or is to be used for drinking. MCLs for the following contaminants will
are ARARs for this response action: 1,1-Dichloroethene; cis, trans-1,2- dichloroethene; 1,1,2,2-
tetrachloroethane; trichloroethene; and vinyl chloride.
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9.3.3 To Be Considereds (TBCs)
To Be Considereds (TBCs) are non-promulgated advisories or guidance issued by Federal or State
government that are not legally binding and do not have the status of potential ARARs. However, as
described below, in many circumstances, TBCs will be considered along with ARARs as part of the site
risk assessment an may be used in determining the necessary level of cleanup for protection of health or
the environment.
Estimation of Air Impacts for Air Stripping of Contaminated Water (EPA-450/1-91-002) Air/Superfund
National Technical Guidance Series May 1991. This guidance outlines the procedure under which air
emission limits for this response action were derived.
9.4 Documentation of Significant Changes
There has been one change made to the Selected Remedy since the Proposed Plan was released for public
comment in May 1995. It identified Alternative 3 A combined with Alternative 4B, pump and treat of the
alluvial and bedrock aquifers through air stripping with catalytic oxidation used as an air pollution control
method. Alternative 3A specified that extraction wells with pumps would be utilized to recover
contaminated water from the alluvial and bedrock aquifers. However, EPA has determined that low
volume recovery wells, or well points, presented in Alternative 3B may be more suitable for recovery of
ground water from the alluvial aquifer. Well points have a smaller diameter and withdraw ground water
at a much slower rate than extraction wells. Because they have smaller capture zones than extraction
wells, well points would be less likely to pull water from the adjacent Cumberland River and may provide
a more efficient means of extracting contaminated alluvial ground water. Alternative 3B, like Alternative
3 A, requires that ground water be recovered from the bedrock aquifer by means of extraction weiis and
only differs from 3 A in that it specifies that well points be used, instead of larger extraction wells, to
recover alluvial ground water. Final determination of the use of extraction wells or the smaller well
points will made during the remedial design phase.
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Table 9.1
Summary of Ground-Water Performance Standards
Ground-water
Contaminants
VOLATILE ORGANIC S
1 , 1 -Dichloroethene
cis, trans- 1 ,2-Dichloroethene
1 , 1 ,2,2-Tetrachloroethane
Trichloroethene
Vinyl Chloride
Remediation Levels
7(ig/0'
70(cis)/100(trans)ng/C'
10 ng/«b
Sugrt-
2ug/«'
Frequency of
Detection
5/83
21/83 (total)
1/83
14/83
13/83
Range of Detected Levels (ug/0
Minimum Maximum
1 29
2 13,000
2 55
3 14,000
7 600
Basis of Remediation Goal
' Federal MCL
b The 1,1,2,2-Tetrachloroethane practical quantitation limit; equals a risk level of 5.9 x 10' for the lifetime residential scenario (there is no
Federal or Kentucky MCL).
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Table 9.2
Emission Rate and Ambient Air Performance Standards
Air Contaminant
c/i-l,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Action Levels
Emission Rate
(Ib/hr) / (g/sec) / (ppbv) / Og/m3)
98.6 / 12.4 / 5,850,000/23,600,000'
0.45/0.06/19,600/107,500"
0.009/0.001/837/2,174'
Ambient Air
(ME/m*)
5"
5'
5'
BASIS: Assumes 20 degrees Centigrade, stack height of 18.3 meters, and air flow rate of 1115 acfin
' Emission rate based on 401 KAR 63:022. An inhalation unit risk factor has not been derived for C/M.2-DCE, therefore a health
based emission rate could not be derived.
b Emission rate derived from 10'" risk level and 70-year inhalation unit risk factor of 1.7/1,000,000 (mVug)
' Emission rate derived from 10* risk level and 70-year inhalation unit risk factor of 8.4/1,000,000 (m'/ug)
d The cu-l,2-OCE practical quantitation limit (PQL); this level equals 0.6% of the allowable ambient air level, based the
occupational permissible exposure limit (PEL) divided by 1000
' The TCE PQL; equals a risk level of 8.5e-06, based on EPA's unit risk of 1.7e-06 ^g/mj
' The vinyl chloride PQL; equals a risk level of 4.2e-04, based on EPA's unit risk of 8.4e-05 A*g/m3
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Table 9.3
Summary of KPDES Effluent Limitations8
EFFLUENT PARAMETER
Flow (MOD)
Trichloroethylene
1 , 1-Dichloroethylene
Vinyl Chloride
PCBs1
cis- 1 ,2-Dichloroethylene
Benzene
Lead (T.R.)
Zinc (T.R.)
Chromium (Hexavalent)
Copper (T.R.)
Methylene Chloride
Tetrach loroeth vl ene
DISCHARGE LIMITATIONS
kg/day 0ta/day) Other Units (Spedf>
Monthly
Average
• N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Dally
Msudhunn
N/A
N/A
N/A
N/A
N/A
N/A
N/A
• N/A
N/A
N/A
N/A
N/A
N/A
Monthly
• Average
0.18 MOD
0.172 mg/t
0.0021 mgft
0.128mg«
0.0043 Mg/«
0.07 mgft
0.833 mg/«
0.072 mg/«
0.1 17 mg/t
0.016 mg/C
0.018 mg/C
0.011 mg/«
0 555 mp/f
)
Dal{y
Maximum
0.18MGD
Report
Report
Report
Report
Report
Report .
0.082 mg/{
0. 117mg/«
0.016 mg/«
O.OlSmgrt
Report
Report
'The discharge limits contained in this table are those currently in effect by the Kentucky Division of Water. The permit with which
these discharge limits shall comply is subject to modification and public comment, so these discharge limits and parameters may be
amended. If the amended KPDES requirements vary from those listed in this table, the discharge limits or parameters are hereby
incorporated by reference and will replace those listed above.
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Record of Decision
National Electric Coil Co., Site
"Page 52 of 53
10.0 STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is to select remedial actions that
are protective of human health and the environment. In addition, Section 121 of CERCLA established
several other statutory requirements and preferences. These specify that when complete, the selected
remedial action for a site must comply with applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a statutory waiver is granted. The selected
remedy must also be cost-effective and utilize permanent treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the statute includes a preference for remedies that
permanently and significantly reduce the volume, toxicity, or mobility or hazardous wastes. The following
sections discuss how the selected remedy for contaminated ground water at the National Electric
Coil/Cooper Industries Site meets these statutory requirements.
10.1 Protection of Human Health and the Environment
The Selected Remedy protects human health and the environment from future exposure to contaminated
ground water by pumping the impacted ground water aquifers and treating the recovered water by air
stripping and catalytic oxidation prior to its discharge to the Cumberland River. The future risk associated
with this pathway is 9x10"* for lifetime residents and 1x10^* for adult workers. By treating the ground
water and discharging it to the River, the cancer risks from exposure will be reduced to less than 1 x 10"6,
which is within the EPA acceptable risk range. There are no short term threats associated with the Selected
Remedy that cannot be readily controlled. In addition, no adverse cross-media impacts are expected from
the remedy.
1G.2 Compliance with ARARs
The Selected Remedy attains all of the requirements that have been identified as applicable or relevant and
appropriate to actions that will occur as the result of implementation of the selected remedial action. The
following are major applicable or relevant and appropriate requirements (ARARs), risk-based levels and
other "to be considered" (TBCs) being met for the specific components of the remedial action.
Chemical-Specific ARARs are health or risk-based concentration limits or ranges in various
environmental media for specific hazardous substances, pollutants, or contaminants. These ARARs set
protective cleanup levels for the contaminants of concern in the designated media or indicate an acceptable
level of discharge into a particular medium during a remedial activity.
• 401 KAR 63:022 (regulates the emission of 1,2-DCE to atmosphere)
• Safe Drinking Water Act MCLs (40 CFR Part 141)
Location Specific ARARs are restrictions placed on the concentration of hazardous substances or the
conduct of activities solely because they are in specific locations.
• 40 CFR S264.18rbX Floodplain Management
*
• 40 CFR 6.302. Fish & Wildlife Coordination Act.
-------
Record of Decision
National Electric Coil Co., Site
Page 53 of 53
Action Specific ARARs are performance, design, or other similar action-specific requirements that impacts
particular remedial activities. These requirements are triggered by the particular remedial activities that are
selected to accomplish a remedy. These requirements do not determine the remedial alternative, but, they
do indicate how a selected alternative must be achieved.
• Kentucky Pollutant Discharge Elimination System (401 KAR 5, specifically Parts 031, 065,
which has been authorized to implement the National Pollutant Discharge Elimination System
program under authority of the Clean Water Act (CWA) § 402. Section 402 of the CWA
incorporates sections 301,302, 306, and 307.
• KRS 151.140; withdrawal of water from public waters within the Commonwealth of
Kentucky.
To Be Considered (TBCs) are non-promulgated advisories or guidance issued by Federal or State
government that are not legally binding and do not have the status of potential ARARs. However, as
described below, in many circumstances TBCs will be considered along with ARARs as part of the site risk
assessment an may be used in determining the necessary level of cleanup for protection of health or the
environment.
• Estimation of Air Impacts for Air Stripping of Contaminated Water (EP A-45 O/1 -91 -002)
10.3 Cost-Effectiveness
EPA believes this remedy will eliminate the risks to human health at an estimated cost of $3,932,000,
therefore the Selected Remedy provides an overall effectiveness proportionate to its costs, such that it
represents a reasonable value for the money that will be spent. The Selected Remedy ensures a higher
degree of certainty of effectiveness than the other alternatives because the technology employed is known
to be effective for organic-contaminated wastewaters.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
EPA believes the Selected Remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective manner for the Site. The Selected Remedy is
composed of several proven technologies that can efficiently and reliably extract impacted ground water,
remove VOCs from the water, and significantly reduce potential human exposure to contaminants released
to air.
10.5 Preference for Treatment as a Principal Element
By treating the contaminated ground water by air stripping, the Selected Remedy addresses one of the
principle threats posed by the Site through the use of treatment technologies. By utilizing treatment as a
significant portion of the remedy, the statutory preference for remedies that employ treatment as a principle
element is satisfied.
-------
APPENDIX A
Proposed Plan
-------
This fact sheet will provide:
• The results of the Remedial
Investigation.
• A summary of the Feasibility
Study.
A summary of the baseline risk
ssessment
Announcement of Public
Comment Period
A presentation of EPA's
preferred Alternative
The possible health risks posed
by the Site.
• A summary of treatment
alternatives.
• Places to get information.
Enviramcntal Plotted on
Agency
R 09 on IV
M5CoufandSL,N.E.
AflanU, Gwrpa 30365
Aiibama, FTorida, Gtcrgia
Kmtudcy, Usaaipi, Not* Caroina
South CarcTna, and Tovwssm
PUBLIC MEETING
DATE: Tuesday, July 11, 1995
TIME: 6:30 p.m.
NATION:
j-lan County Courthouse
circuit Courtroom, 2nd Floor
Central Street
Harlan, Kentucky
SUPERFUND FACT SHEET UPDATE —
PROPOSED PLAN FOR FINAL REMEDIAL
ACTION AT THE NATIONAL ELECTRIC COIL
CO./COOPER INDUSTRIES SITE
Dayhoit, Harlan County, Kentucky
May 1995
INTRODUCTION
The U.S. Environmental Protec-
tion Agency (EPA), in cooper-
ation with the Commonwealth of
Kentucky Natural Resources and
Environmental Protection Cabinet
(KNREPC), has recently complet-
ed a comprehensive Superfund
environmental study, known as a
Remedial Investigation/Feasibility
Study (RI/FS), at the National
Electric Coil Co./Cooper Indus-
tries Superfund Site (Site) in
Dayhoit, Harlan County, Ken-
tucky. A summary of the find-
ings of the RI/FS are included in
this fact sheet, which is referred
to as a proposed plan. Its pur-
pose is, in part, to fulfill the pub-
lic participation requirements
delineated in section 117(a) of the
Comprehensive Environmental
Response, Compensation and
Liability Act of 1980 (CERCLA),
as amended by the Superfund
Amendments and Reauthorization
Act of 1986 (SARA). Further,
this proposed plan also identifies
EPA's preferred alternative for
final site remediation and sum-
marizes the key findings of the
RI/FS on which EPA has based
its decision.
The purpose of the RI is to
collect the data necessary to
adequately determine the nature
and extent of site-related contam-
ination for the purpose of remedy
-------
selection. An essential compo- .
nent of the RI is the baseline risk
assessment which is conducted to
determine whether site contam-
inants of concern pose a current
or future risk to human health and
the environment and also to deter-
mine whether site cleanup is
necessary. The final component
of the environmental study is the
feasibility study (FS). Its primary
objective is to ensure that appro-
priate remedial alternatives are
evaluated that protect human
health and the environment from
current and future site related
contamination.
The complete RI/FS and related
site documents are contained in
the Site information repository at
the Harlan County Public Library.
The public should visit the repos-
itory for a more detailed review
of the site file and to view addi-
tional information not presented
herein.
EPA encourages the public to
submit written comments on all
the alternatives presented in this
proposed plan. Comments sub-
mitted by the public may influ-
ence EPA's preferred alternative
presented later in this proposed
plan. The final remedial action
plan, as presented in the Record
of Decision (ROD), could differ
from the preferred alternative pre-
sented in this proposed plan,
depending upon new information
or comments received during the
Public Comment Period.
SITE BACKGROUND
The Site is located on Old U.S.
Route 119 in Dayhoit, Harlan
County, Kentucky. The Site is
adjacent to the Cumberland River
and includes the 3.5 acre National
Electric Services (NES) manu-
facturing facility and also encom-
passes the areal locations to
which hazardous constituents
originating at the Site might have
migrated. The facility property is
bordered on the south by the
Holiday Mobile Home Park.
From 1951 to 1987.the National
Electric Coil Co. (NEC) operated
under the ownership of McGraw
Edison. The business involved
rewinding electric motors and
rebuilding hydraulic systems and
machinery for the coal mining
industry. Cooper Industries pur-
chased the facility in 1985 and
continued operations until 1987
when it was sold to Treen Land
Company.
Past practices in the plant involv-
ed the use of a trichloroethylene
(TCE)-based solvent to remove
oil and tar from the used motors,
capacitors, transformers, and other
equipment prior to their being
refurbished. NEC disposed of the
spent solvents, used to degrease
the equipment, directly into the
Cumberland River and/or by
dumping process debris along the
river bank located at the rear of
the property. Contamination of
the Site's drainage channels and
river embankment occurred.
Prior to servicing, the equipment
was lowered for cleaning into an
approximately 1,000-gallon steel
degreasing tank which rested in a
below-grade concrete pit contain-
ing a TCE-based solvent Periodi-
cally this tank was drained for
cleaning, and the contained liquid
and waste matter was allowed to
flow overland and/or through a
drainage pipe to the Cumberland
River. PCB laden oil was also
allowed to drain from transform-
ers on site and/or to flow through
the drainage piping that lead to
the river bank. Sludges from the
degreaser tank, as well as debris
containing high concentrations of
heavy metals from a furnace oper-
ated on site, were disposed of
along the river. These disposal
practices continued until
-------
Initial site cleanup began during
the Removal Action activities
conducted from October 1990 to
October 1991. More than 5,100
^s of contaminated soils were
itified and dug up for off -site
uisposal in a permitted landfill.
Concurrently, a Preliminary Site
Assessment was conducted for the
purpose of collecting data neces-
sary to include the site on the
National Priorities List (NPL).
Sampling of on-site and nearby
residential ground-water wells and
the NEC facility and adjacent pro-
perty indicated the presence of the
following three primary groups of
hazardous substances at the site:
(1) volatile organic compounds
(VOCs), nairoly trichloroethene,
trichloroethaue, 1,2-dichloro-
ethene, vinyl chloride, toluene,
and ethylbenzene; (2) polychlori-
nated biphenyls (PCBs); and (3)
metals, namely, lead and chro-
mium. The Site was included on
> NPL, as defined in Section
j of CERCLA, as amended, 42
U.S.C. §9605, in October 1992.
In December 1992, EPA
Cooper Industries to begin prelim-
inary ground-water clean-up activ-
ities in accordance with the Sep-
tember 1992 "Interim" ROD. The
purpose of this cleanup work was
to minimize the bedrock VOC
plume migration until a final site
remedy is selected.
Start up of the preliminary
ground-water clean-up activities
began in July 1993. An existing
site extraction well was utilized to
recover contaminated water from
the bedrock aquifer. The recover-
ed ground-water, containing
trichloroethene-based solvents
(degreasers), has been treated by
-leans of an air-stripper tower in
ler to separate the VOCs from
pue ground water. The treated
water leaving the air stripper has
been discharged into the Cumber-
land River in accordance with
state surface water discharge
standards The organic laden air
stream exiting the tower is passed
through a granular activated car-
bon unit prior to being released to
atmosphere. To date more than
99,000,000 gallons of water have
been treated.
This proposed plan contains an
outline of the final clean up
actions that EPA and the Com-
monwealth of Kentucky anticipate
conducting at the site. The
ground-water clean-up activities
will be expanded to address con-
taminated ground water located in
the shallow aquifer and in the
intermediate and deep zones of
the bedrock aquifer, where the
recent site investigation indicates
significant contaminants are
located.
FINDINGS OF THE
REMEDIAL INVESTIGATION
The RI field activities consisted
of on-site and off-site soil
sampling activities, an ecological
investigation, sediment sampling.
meteorological studies, and a
hydrogeologic investigation.
Much of the hydrogeologic
investigation was conducted as
part of the Interim Remedial
Action (IRA). The RI and IRA
field work included the following
tasks:
Hydrogeologic Investigation:
Included the (1) installation of
three off-site monitoring well
clusters consisting of two wells
each, including rock coring,
discrete interval ground-water
sampling and packer testing; (2)
installation of two on-site moni-
toring wells; (3) collection of
ground-water samples from 27
bedrock wells, including on-site
monitoring wells, newly installed
off-site monitoring wells and off-
site private welo- (4) measure-
ment of water levels in 37 wells,
'including on-site monitoring
wells, newly installed off-site
monitoring wells, and off-site
private wells; and (5) collection
of ground-water samples from
four shallow wells located at the
NEC site. The areas of ground-
water contamination have been
delineated as follows: (1) the
shallow/alluvial aquifer (15 to 40
feet); (2) the intermediate aquifer
(40 to 80 feet); and (3) deep/bed
rock aquifer (80 to 125).
RI results indicate that site-
related contaminants are found in
significant quantities in ground
water found in the deep bedrock
zone beneath and down gradient
of the site and in the shallow
aquifer and intermediate bedrock
zone located beneath the site.
These contaminants consist pri-
marily of trichloroethene (TCE),
12-dichloroethene (12-DCE),
and vinyl chloride.
- Prior to initiating the ground-
water remediation, the VOC
plume extended, down gradient
(southwest), in the deep bed-
rock aquifer to a distance of
approximately 2,000 feet with
highest area of concentration
located near the site's southern
boundary.
- The vertical extent of the VOC
plume extends to a depth of ap-
proximately 160 feet with the
most concentrated zone identi-
fied at a depth approximately
50 to 75 feet below ground
surface (bgs).
- The shallow and intermediate
aquifers are impacted by TCE
and 1,2-DCE.
- The interim system is controll-
ing the plume migtation through
extraction of the VOC plume.
-------
On-site Soil Investigation:
Consisted of the six soil borings
(total of 12 soil samples) cored at
the NEC site for physical and
chemical characterizations of the
i-site subsurface.
On-site soil samples were
collected from subsurface areas
where 1991 Removal Action con-
firmatory sampling indicated that
contaminants remained at levels
above "non-detect." The purpose
of this sampling was to determine
whether contaminants remained in
subsurface areas in quantities that
might leach to ground water. The
soil samples were collected at
depths ranging from 4 to 8 feet.
- Analysis of the samples indi-
cates that neither VOCs nor
inorganics, such as lead and
chromium, remains in the sub-
surface in levels that would
significantly impact ground
water via contaminant leaching.
vff-site Soil Investigation:
Consisted of the collection of 20
surface (0 to 0.5 feet deep) and 9
subsurface (2 to 3 feet deep) soil
samples at the Holiday Mobile
Home Park located adjacent to the
NEC facility.
Off-site soil samples were
collected from the Holiday Mobile
Home Park to determine whether
soils located there had been
impacted by the contaminants
originating at the NEC site. The
area sampled at the mobile home
park stretched the length of the
fenceline that separates the
properties, at maximum distance
from the fenceline of100 feet
onto the trailer park property.
- Only one of the twenty-nine
samples collected marginally
exceeded the 1,000 ug/kg PCB
action level.
- No VOCs were detected in the
off-site soils, and only low
levels of semivolatiles and
pesticides were detected.
- Low levels of dioxins and
furans were detected in surficial
soil samples collected near the
fenceline at the mobile home
park.
- Inorganic concentrations
detected in the off-site soils
were consistent with
background or naturally
occurring levels.
Sediment Sampling:
Consisted of the collection of
sediment samples from nine
locations in the Cumberland River
Sediments in the vicinity of and
down gradient of NEC were col-
lected to determine if the Cum-
berland River has been signif-
icantly impacted by releases from
the site. Sampling stations were
designated upstream, downstream,
and adjacent to the site.
- Site-related contaminants such
as TCE and 1,2-DCE were
detected in the sediment
samples collected near NEC
Outfall 001, but not in
samplings collected further
downstream. The migration of
these contaminants, in
sediments, appears to be limited
to the immediate vicinity of the
outfall.
- PCBs and other semivolatiles
were also located at the outfall.
But they were also detected in
both upstream and downstream
locations. This indicates that
other sources of these contami-
nants exist upstream of the site
in addition to NEC. Thus, the
presence of these contaminants
in nearby river sediments is
most likely due to general
pollution of the river by a vari-
ety of unknown origins.
- The magnitudes of estimated
risks among the three sampling
stations suggest that the Cum-
berland River near-Site and
downstream pose essentially thf
same magnitude of risk as th^
of sediment in the Cumberland1
River upstream station.
Aquatic Assessment:
(1) Collection of benthic macro-
invertebrate samples from three
locations in the Cumberland
River, and (2) collection^ of pre-
dator and bottom-feeding fish
tissue composites from four loca-
tions in the Cumberland River.
- PCBs were found at each
•sampling stations where fish
were caught for analysis,
including those caught at the
sampling station approximately
five miles upstream.
- PCB levels were detected in 8
of the 9 fish samples analyzed
ranged from 140 ug/kg to 950
ug/kg, which were below the
United States Food and Drug
Administration (USFDA) action
level and State Fish Advisory
Level of 2,000 ug/kg.
Meteorological Studies and Air
Sampling: Installation and
operation of a meteorological
monitoring tower at the NEC site
for the collection of site specific
atmospheric data.
The meteorological data provided
site specific data necessary for
development of an air dispersion
model.
- Results from air sampling
activities do not indicate the
presence of vinyl chloride, 1,2-
DCE or TCE in ambient air at
the NEC fenceline or at the
Holiday Mobile Home Park.
*
- Concentrations of vinyl chlo-
ride, 1,2-DCE, and TCE
-------
detected at the air stripper
exhaust were well below the
USEPA emission standards
established for the IRA.
SK ASSESSMENT
A baseline risk assessment is a
structured methodology used by
EPA during the Superfund pro-
cess to evaluate whether a site, in
its current state, poses risks to
human health and the environ-
ment that are significant enough
to endanger human health and the
environment. Risk to human
health is defined as the likeli-
hood that people living, working,
or playing on or near the site may
experience health problems as the
a result of their exposure to con-
taminants from the site. The
environmental risk evaluation
appraises actual or potential
effects of a site on plants and
animals.
\ bases its decision to conduct
; clean-up on the risk to human
"health and the environment that
might be expected if no cleanup
aciiuii is taken at the site. This
means that cleanup actions are
taken only when it is determined
that risks at the site exceed the
cancer risk level of 10"4 ( 1
chance in 10,000 of developing
cancer over a 70-year lifetime) or
if noncarcinogenic hazard indices
exceed a level of 1. Once this
threshold has been exceeded,
remedial action alternatives are
designed to attain a risk level
within EPA's acceptable risk
range of 10"6 to 10^ (between 1 in
1,000,000 and 1 in 10,000) and a
hazard index of 1.
Exposures to ground water, on-
site subsurface soils, off-site sur-
^ soils, river sediment, and fish
esidents or workers were con-
•tuered possible exposure path-
ways for human receptors under
the current and future use scenari-
os. Neither on-site surficial soi\s
nor surface water were evaluated.
On-site surficial soils were not
evaluated in the risk assessment
because all identified site soils
(including subsurface soils) that
exceeded EPA clean-up levels
were excavated during the 1991
Removal Action. The excava-
tions were then backfilled with
clean soils brought from off site.
However on-site subsurface soil
samples were collected during the
RI to evaluate whether they con-
tained VOCs in sufficient concen-
trations capable of producing
ground-water contamination.
Surface water was not evaluated
for carcinogenic risk; however,
EPA did review the downstream
and upstream Cumberland River
surface water data, collected by
NEC to demonstrate its compli-
ance with the Kentucky Pollution
Discharge Elimination System
(KPDES). The observed surface
water contaminant concentrations
were below federal water quality
criteria and showed no signifi-
cant difference in concentrations
between the upstream and down-
stream locations.
Cancer risks associated with
exposure to environmental media
by human receptors were calculat-
ed for the current and future use
scenarios. Table 1 presents a
summary of these calculated risks
associated with exposure of a re-
ceptor to contaminated media.
The risks associated with expo-
sures to on-site subsurface soils,
off-site surficial soils, and sedi-
ments were within EPA's accept-
able risk range of 10"6 to 10"*.
However, risks associated with
ground water were greater than
1 x 10"4 for the lifetime resident
and adult worker. Risks associ-
ated with the ingestion of fish
slightly exceeded 1 x 10^.
THE FEASIBILITY STUDY:
Developing and Evaluating
Cleanup Alternatives
i
The Feasibility Study (FS) was
conducted to identify, develop,
and evaluate appropriate remedial
alternatives for minimizing risks
to public health and the environ-
ment caused by contaminated
ground water at the Site.
Each of the ten alternatives evalu-
ated in this proposed plan was
analyzed against the nine criteria
presented in Table 2. Alternatives
1 and 2 did not meet the thresh-
old criteria (protection of human
health and the environment and
appliance with ARARs), so they
were eliminated from further ana-
lysis and consideration. Neither
the "No Action" Alternative
(Alternative 1) nor Alternative 2
is protective because they do not
reduce potential exposures to site
ground water.
Table 1
Sumnurr of Baseline Rbk AM**un#nt
ENVIRONMENTAL
MEDIA
•QMMrflWfrr
f f$ ~- j 'ff
On-sfo Surface
Soib
On-site Subsurface
Soib
Off-site Surficial
Soib
Sediment
(Cumberland River)
*** - '',', /
Surface Water
CANCER
RISK LEVEL
,, 'i **»*;' '
, , '•'- ' '
','_ -....f....
NE~
7x10-"
1 x 1O*
4x Iff'
4*-ie* ,,
NE-
•bhaong mduaias mat me acceptane n* level has been
exceeded
** Not evaluated
-------
EVALUATION OF ALTERNATIVES
GROUND-WATER RECOVERY ALTERNATIVES
pemedial Alternative 1:
3 Action
Capital Cost: $0
Present Worth: $0
Annual O&M Cost: $0
Time to Construct: None
The no action alternative requires no remediation or
institution of constraints and would leave the ground
water in place. No further sampling and analysis of
ground water would occur under the no action alter-
native. The no action alternative has been developed
as a baseline remedial action for the site to serve as a
comparison for the other alternatives.
Remedial Alternative 2:
Ground-Water Monitoring
Capital Cost: $12,500
Annual O&M Cost: $137,500
Present Worth: $1,725,000
Time to Construct: One Year
Mternative 2 consists of a quarterly ground-water
mpling program in which an estimated twenty-four
(24) monitoring wells and private wells would be
sampled to monitor the VOC plume. Ground-water
samples would be collected and analyzed for the
volatile organics on the TCL using CLP methods.
Approximately 15 wells would be used to monitor
ground water in the deeper bedrock zone at depths
ranging from approximately 86 feet to 337 feet. The
five existing shallow/alluvial on-site wells and the two
intermediate bedrock wells would also be sampled. At
least two additional intermediate bedrock wells
(approximately 60 feet deep) would be installed on site
to provide increased coverage in the intermediate
bedrock zone.
REMEDIAL ALTERNATIVE 3A:
Ground-Water Recovery using Extraction Wells
with Pumps - Shallow, Intermediate and Deep
Zones
Capital Cost: $136,900
Annual O&M Cost: $77,000 per year
Present Worth: $1,101,000
ime to Construct: Two Years
Alternative 3A consists of recovering impacted ground
water using a series of extraction wells installed in the
shallow/alluvial aquifer and the intermediate and. deep
zones of the bedrock aquifer. The estimated total
ground-water recovery rate for the shallow, interme-
diate and deep zones is approximately 200 gpm.
Ground water recovered from the three zones would be
transferred to an on-site treatment system. The treated,
ground water would then be discharged to the Cumber-
land River in accordance with KPDES requirements.
This alternative would utilize the existing on-site re-
covery well, CMW-5-11, or possibly employ a new
recovery well, installed on-site near the center of the
VOC plume (near the southern boundary of the site).
The new extraction well would pump at a rate of 100
to 125 gpm to recover impacted ground water in the
deeper bedrock. The use of off-site recovery wells for
deeper bedrock ground-water recovery is not anticipa-
ted since the on-going extraction activities indicate that
on-site pumping is effective. The need for off-site
wells would be addressed during remedial design.
Additional recovery wells would be required in order
to effectively capture the VOC plume in the inter-
mediate and shallow zones. Approximately four
recovery wells would be needed to extract impacted
ground water from the intermediate zone at an approx-
imate recovery rate per well of 10 to 20 gpm. An
estimated 6 wells would be required in the shallow
zone, operating at a rate per well of approximately 2 ta
5 gpm. The potential use of vacuum enhanced
recovery wells in the shallow zone would be evaluated
during remedial design.
Existing monitoring wells and private wells would be
used to monitor the effectiveness of the ground-water
recovery system. Additional monitoring wells may be
required in the intermediate zone to monitor the effec-
tiveness of the recovery system associated with this
area. It is assumed that the ground-water monitoring
program required for this alternative would be similar
to that described in Alternative 2 except that sampling
would be conducted on a semiannual rather than
quarterly basis.
REMEDIAL ALTERNATIVE 3B:
Ground-Water Recovery Using Extraction Wells
with Pumps-Intermediate and Deep Zones and
Wellpoint Recovery System - Shallow Zone
Capital Cost: $122,800
Annual O&M Cost: $96,2000 per year
Present Worth: $1,272,000
Time to Construct: Two Years
Alternative 3B consists of a ground-water recovery
system identical to the one described in Alternative 3A
-------
for extraction within the intermediate and deep zones
o'f the aquifer. However, ground-water recovery within
the shallow zone of the aquifer would be accomplished
using a wellpoint recovery system.
vellpoint system would consist of a series of
c .<;ly spaced wells installed in the shallow alluvial
zone, along a line perpendicular to the direction of
shallow ground-water flow. The wellpoints would be
connected to a header pipe or manifold pumped by a
central vacuum pump. The wellpoints would be
installed at a depth of approximately 30 feet and
spaced at 25 to 50 feet apart so that the zones of
influence overlap slightly.
The total ground-water recovery rate from the
wellpoint system is anticipated to be 25 gpm. The
ground water recovered by the wellpoint system will
be discharged into an equalization tank along with the
ground water collected by extraction wells from the
intermediate and deep zones of the aquifer. The esti-
mated total ground-water recovery rate for the shallow,
intermediate and deep zones is approximately 200
gpm. Ground water recovered from the three zones
would be transferred to an on-site treatment system.
The treated ground water would then be discharged to
the Cumberland River in accordance with KPDES
Tf- -'rements.
'^•Kind-water monitoring would be conducted as part
of this alternative to evaluate the effectiveness of the
recovery systems. It is assumed that the ground-water
monitoring program required for this alternative would
3e similar to that described in Alternative 3A.
REMEDIAL ALTERNATIVE 3C:
Ground-Water Recovery using Extraction Wells
vith Pumps-Intermediate and Deep Zones and
nterceptor Trench - Shallow Zone
lapital Cost: $495,7000
Annual O&M Cost: $74,400 per year
'resent Worth: $1,419,000
Time to Construct: Two Years
Utemative 3C consists of a ground-water recovery
ystem identical to the one described in Alternative 3A
or extraction within the intermediate and deep zones
f the aquifer. However, ground-water recovery within
le shallow zone of the aquifer would be accomplished
sine an interceptor trench.
.erceptor trench would be constructed on-site
ear the riverbank area and perpendicular to the direc-
on of shallow ground-water .flow. The interceptor
trench would extend approximately 400 feet along the
western down gradient boundary of the site and would
be installed to the depth of bedrock, approximately 25
to 40 feet below ground surface.
The interceptor trench would be constructed by exca-
vating existing soils to bedrock and installing a per-
forated collection pipe at the bottom of the excavation.
The bottom portion of the excavation would then be
backfilled with gravel or comparable granular fill
material. A vertical impermeable barrier would be
installed on the down-gradient side of the trench to
prevent the lateral migration through the trench and to
minimize the infiltration of ground water from the
down-gradient direction. The bottom surface of the
trench would be sloped toward a sump equipped with a
submersible pump. Ground water that collects in the
trench would be removed by a submersible sump pump
and discharged into an equalization tank at the
treatment system.
The estimated total flow rate from the interceptor
trench is approximately 25 gpm. As in Alternatives
3A and 3B, ground water recovered from the three
zones would be transferred to an on-site treatment unit
at a comparable total recovery rate. The treated
ground water would then be discharged to the
Cumberland River in accordance with KPDES permit
requirements.
It is assumed that the ground-water monitoring pro-
gram required fur ihis alternative would be similar to
that described in Alternative 3A.
GROUND-WATER TREATMENT
ALTERNATIVES
The following alternatives are designed to be combined
with one of the ground-water recovery alternatives pre-
viously presented as Alternatives 3A, 3B, and 3C to
provide a complete ground-water remediation system:
REMEDIAL ALTERNATIVE 4A:
Ground-Water Treatment by Air Stripping with
Activated Carbon Off-Gas Treatment
Capital Cost: $183,800
Annual O&M Cost: $169,500 per year
Present Worth: $2,287,000
Time to Construct: Two Years
Alternative 4A employs a ground-water treatment -
system consisting of an air stripping tower and a
granular activated carbon (GAC) off-gas treatment unit.
Alternative 4A will be combined with one of the
-------
previously described ground-water recovery alternatives
(Alternative 3A, 3B, or 3C) to provide a complete
ground-water remediation system.
As part of the on-going ground-water extraction activ-
in air stripping tower and GAG off-gas treatment
j-e currently in operation at the site. It appears
that the existing air stripper is sufficiently designed to
effectively treat the anticipated increased flow of 200
gpm. Although the existing system may suffice for the
final remedy, this alternative evaluation assumes that a
new air stripping system and GAG unit would be con-
structed in order to maintain an objective comparison
of the costs and implementation factors.
The treatment system would be designed to remove
VOCs from recovered ground water using the mass
iransfer process of air stripping. The components of
the ground-water treatment system would include an.
equalization tank, packed-column air stripper, vapor-
phase GAG treatment unit and off-gas exhaust stack.
Associated treatment system components would consist
of air blowers, a transfer pump, duct heating unit, and
process piping and controls.
Ground water recovered from the shallow, interme-
diate, and deep zones would be transferred to an
canalization tank, from which it would then be pumped
top of the air stripper at a flow rate of approx-
Ay 200 gpm. The ground water would flow by
gravity through the packing material while air is simul-
taneously blown countercurrently and upward through
the packing from the bottom of the air stripper. The
aeration of the water causes VOCs to volatilize into the
air stream. Air and volatiles then exit the air stripper
through an exhaust line at the top of the tower. The
air mixture would be heated to remove moisture and
iien transferred to the GAG treatment unit. Volatile
organics in the air stream adsorb to the activated
carbon. The treated air would then be recirculated
trough the unit or discharged to the atmosphere
inrough a stack.
Treated ground water would flow from the packed
section of the air stripper into an accumulation sump
;ocated at the bottom of the air stripper. Treated
around water would be discharged by gravity to the
Cumberland River through an existing multiport
iiffuser pipe that extends approximately 36 feet into
:ne river. Discharge of the treated ground water would
ne in accordance with KPDES discharge limitations
'onitoring requirements.
Inc vapor-phase GAG treatment unit would consist of
vessel filled with granular activated carbon. The unit
would include a duct heater to prevent condensation in
the GAG unit. Depending on the size of the GAG unit
and the volume of air discharged from the stripping
tower, the discharge line from the GAG unit may
include a recirculation blower loop to prevent
channeling in the GAG unit.
The treated off-gas from the GAG unit would be dis-
charged to the atmosphere through an exhaust stack.
The height of the stack would be determined based on
air modeling to ensure that any VOCs discharged to
the atmosphere are sufficiently dispersed and that am-
bient air standards are maintained. Spent carbon would
be returned to the vendor for regeneration, and the car-
bon unit would be refilled with regenerated or new
carbon.
The air stripper liquid effluent would be sampled to
demonstrate compliance with KPDES discharge limi-
tations. The liquid influent to the air stripper will also
be sampled routinely to eval' ate the removal efficiency
of the unit. Sampling of the off-gas discharge stack
will also be conducted to demonstrate compliance with
the USEPA emission standards.
REMEDIAL ALTERNATIVE 4B:
Ground-Water Treatment by Air Stripping with
Catalytic Oxidation Off-Gas Treatment
Capital Cost: $328,800
Annual O&M Cost: $187,900 per year
Present Worth: $2,660,000
Time to Construct: Two Years
Alternative 4B consists of the air stripping process
described for Alternative 4A along with a catalytic
oxidation treatment unit to remove VOCs from the air
stripper off-gas. The primary components of the cata-
lytic oxidation unit are a heat exchanger, a burner, and
a catalytic reactor.
The VOC-laden off-gas from the stripping tower would
be transferred to the tube side of a heat exchanger via
a blower. The off-gas would be heated to prevent con-
densation of water vapor and to reduce heating require-
ments in the burner. The preheated off-gas would be
transferred to the burner unit where natural gas or pro-
pane would be used to increase the temperature of the
off-gas to approximately 700°F. This high temperature
off-gas would then be transferred to the catalytic reac-
tor. As the high-temperature off-gas contacts the cata-
lyst within the unit, an exothermic (heat releasing)
reaction occurs which oxidizes VOCs in the air stream
to carbon dioxide, water vapor, and inorganic acids.
The treated hot air stream discharged from the catalytic
reactor discharges to the shell side of the heat
-------
exchanger and is used to preheat the incoming,
untreated air stripper off-gas. Once tijb treated air
passes through the shell side of the heat exchanger, the
air would be discharged to the atmosphere through an
exhaust stack. The height of the stack would be
etermined based on air modeling to ensure that any
VOCs discharged to the atmosphere are sufficiently
dispersed and that ambient air standards are
maintained.
REMEDIAL ALTERNATIVE 4C:
Ground-Water Treatment by Air Stripping with
Resin Adsorption Off-Gas Treatment
Capital Cost: $325,500
Annual O&M Cost: $176,200 per year
Present Worth: $2,512,000
Time to Construct: Two Years
Alternative 4C consists of the air stripping process
described for Alternative 4A along with a resin
adsorption treatment unir to remove VOCs from the air
stripper off gas. The re.;in adsorption process consists
of a VOC adsorption unit that contains an adsorptive
polymeric resin, a regenerative loop to provide on-site
regeneration of the resin, and a VOC desorption unit to
condense VOCs removed during the regeneration
process. Recovered VOCs are ultimately transported
->ff site for disposal. The process includes two
sorption units or beds to permit continuous
Operation. One bed is operated in the adsorption mode
while the other bed is regenerated.
Treatment by resin adsorption would be performed by
transferring the VOC-laden off gas from the air-
stripping tower to one of the resin beds. The VOCs in
the off gas adsorb to the polymeric resin, and the
treated off gas is discharged to the atmosphere through
an exhaust stack. The height of the stack would be
determined by air modeling to ensure that any VOCs
discharged to the atmosphere are sufficiently dispersed
and that ambient air standards are maintained.
Once the resin is saturated with VOCs, the air stripping
tower off gas would be diverted to the other resin bed
and the saturated bed would be regenerated. The
regeneration process consists of drawing a vacuum on
the resin bed and increasing the temperature of the
resin using electric heaters located inside the bed. The
combination of the vacuum and increased temperature
causes VOCs adsorbed to the resin to vaporize. The
vaporized VOCs then are purged from the vessel using
igen as the carrier gas. The recovered vapor
.am is transferred to a condenser and chiller to
remove the VOCs. The recovered VOCs would be
stored temporarily on-site and routinely transported off-
site for disposal at an approved facility. The
regenerated bed would be cooled and placed back into
operation once the other resin bed is saturated and
ready for regeneration.
REMEDIAL ALTERNATIVE 5:
Ground-Water Treatment by Ultraviolet Oxidation
Capital Cost: $280,000
Annual O&M Cost: $267,000 per year
Present Worth: $3,593,000
Time to Construct: Two Years
Alternative 5 consists of ground-water treatment
utilizing ultraviolet (UV) oxidation. UV oxidation
treatment uses UV radiation, ozone, and hydrogen
peroxide to oxidize (chemically decompose) VOCs in
the aqueous phase to carbon dioxide, water, and
chlorine ions. The system consists of a UV oxidation
reactor, an air compressor/ozone generator unit, a
hydrogen peroxide feed system, and a catalytic ozone
decomposition unit
Ground water recovered from the shallow, inter-
mediate, and deep zones would be treated in the UV
oxidation unit. Since both suspended solids and metal
ions in the ground water may reduce the efficiency of
the UV oxidation system, removal of these metals may
be required prior to UV oxidation treatment. Filtration
may be utilized to reduce the suspended solids and
metal ions concentrations in the ground-water stream.
If filtration (as demonstrated during treatability studies)
did not satisfactorily reduce these concentrations,
chemical precipitation would be required as a
pretreatment process to UV oxidation.
Recovered ground water would be transferred to an
equalization storage tank and then to the UV oxidation
reactor. Hydrogen peroxide would be mixed with the
ground water as it flows through the influent line to
the reactor. Once the ground water and hydrogen
peroxide mixture are introduced to the UV oxidation
reactor, the mixture would be exposed to UV radiation
and ozone. The UV radiation would be provided by
several UV lamps installed throughout the reactor.
Ozone would be generated on site and introduced to
the reactor by a series of spargers designed to
uniformly diffuse ozone from the base of the reactor
into the liquid mixture. The ground water and
hydrogen peroxide mixture would be transferred to the
UV oxidation reactor at a specified rate to achieve the
hydraulic retention time necessary for VOC
destruction.
Ozone that is not transferred to the liquid mixture
would be present in the reactor off gas. The ozone
-------
would be destroyed in the catalytic ozone decompo-
sition unit, and the off gas would be discharged to the
atmosphere through a stack. The ozone decomposition
unit would utilize a nickel-based proprietary catalyst to
reduce the ozone in the off gas to oxygen.
REMEDIAL ALTERNATIVE 6:
Ground-Water Treatment by Activated Carbon
Adsorption
Capital Cost: $108,800
Annual O&M Cost: $518,800 per year
Present Worth: $6,547,000
Time to Construct: Two Years
Alternative 6 consists of ground-water treatment using
liquid-phase granular activated carbon (GAC). Liquid-
phase GAC adsorption is a physical treatment process
that involves contacting the impacted liquid stream
with activated carbon.
The GAC system would consist of an equalization
tank, two GAC units arranged in series, and associated
pumps, piping and control systems. Organic com-
pounds in the liquid that have an attraction for the acti-
vated carbon adsorb to the surface of the GAC and are
removed from the liquid phase. When all of the active
sites on the GAC surface are filled, adsorption of the
organics will no longer occur, and the compounds
'icgin to "break through" and appear in the liquid efflu-
-nt stream. At this point the saturated carbon must
then be replaced and either disposed or regenerated to
remove the adsorbed organics compounds, and thereby
restore the active sites for adsorption.
As with UV oxidation, the performance of liquid-phase
GAC adsorption may be impacted by the presence of
suspended solids or metal ions in the recovered ground
water. It is anticipated that filtration of the ground
water recovered from the shallow zone will reduce
suspended solids and metal ion concentrations to levels
that will not inhibit the performance of the GAC unit
Recovered ground water would be transferred to an
equalization tank and then to the first GAC unit. The
GAC unit would consist of a steel vessel filled with
activated carbon and equipped with a liquid distrib-
ution pipe. As the ground water flows through the
GAC unit, VOCs in the ground water would adsorb to
the surface of the activated carbon. The liquid effluent
from the first GAC unit would then be transferred to
the second GAC unit to remove any residual organics
-------
Samples would be collected at
these locations on a\regular basis
to determine when breakthrough
of the first GAC unit has occur-
red. Once breakthrough occurs,
\e first GAC unit would be
^placed with a unit that.contains
regenerated carbon. The second-
ary GAC unit would then be
plumbed to receive untreated
ground water from the equaliz-
ation tank, and the regenerated
GAC unit would be plumbed to
function as the secondary or
polishing GAC unit. This rotat-
ing procedure would be used to
ensure that compliancewith
KPDES discharge standards is
maintained.
The GAC units would be design-
ed to treat a liquid flow rate of
approximately 200 gpm. Based
on preliminary design calcula-
tions, each GAC unit would
contain approximately 10,000
pounds of activated carbon. It is
estimated that breakthrough of the
st GAC unit in the treatment
ries would occur after approx-
imately seven days of continuous
use. This breakthrough time is
based on the combined adsorption
of 1,2-dichloroethene, trichloro-
ethene, and vinyl chloride at the
estimated recovered ground-water
concentrations previously observ-
ed on-site.
In addition to monitoring the
GAC units for breakthrough,
monitoring of the treated effluent
would also be required to
demonstrate compliance with
KPDES discharge limitations.
Since no air emissions would be
generated by the GAC treatment
system, air monitoring would not
be required.
preferred alternative of
combined with Alternative 4B. Hits; combination
alternative involves the following; (1) Extraction'
ground water from fli^impsctwt shallow, intermediate,
aquifers beneath and adjacent *0;0ie"$ftej (2)ftr«
'
technologies that can ^t^^^^l-^i^^^^^o^^^^^^
stripping
produced during the air stripping process xpill be VOG*Jaden anit
requires additional treatment; Use of the catalytic Oxidize
in
EPAsstacft emission rate Umit& The remaining trace VOCs
f f •. v..f v f & < •• f .r.f S f _p^*%> •••.•• $f ^
be released to the atmosphere from the s^ck at a Jhe%ht ai *i~*~+:
njaximum disi>eraon would occnr* The st^ck height .
on meteorological data coJlected at the site, TJi« ,TOC*free w«*eir
stream leaving the air stripper system would be released to the
Cumberland Mver in compliance witb applicable *™**>« *-^-
This alterriatite is ««ore protective of human health a
environment relative to that of the other alternatives
primarily, based on the manner in which contaminant releases to the
atmosphere are managed^ The catalytic oxidizer
Alternative 4B will effectively and reliably remove
-------
EVALUATION OF
ALTERNATIVES
USEPA Region IV has selected
Alternative 3A combined with
hat of Alternative 4B as its
Preferred Alternative. This section
profiles the preferred alternative
against the nine criteria, noting
how it compares to the other
Alternatives that were evaluated.
THE ANALYSIS
Threshold Criteria
Overall Protection of Human
Health and the Environment
The "No Action" Alternative
(Alternative 1) and Alter iative 2
are not protective because neither
reduces potential exposures to site
ground water. Therefore, neither
alternative will be considered
further in this analysis as an
option for the site.
The other alternatives will be
retained for evaluation in combi-
nation as a pump and treat sys-
tem. A well designed pump and
treat system, consisting of extrac-
tion wells and ground-water and
exhaust treatment units, limits the
potential spread of contaminant
from the site. The ground-water
recovery technology (presented as
3 A, B, or C) judged most effec-
tive will be combined with the
ground-water treatment technol-
ogy (presented as 4A, 4B, 4C, 5,
or 6), similarly deemed most
effective, to develop a remedial
action that best protects human
health and the environment from
current and future exposure to
site-related contaminants.
Compliance with ARARS
The ground-water extraction and
treatment systems described in
Alternatives 4 (A, B, and C), 5,
and 6 would primarily be subject
to the state regulations that involve
ground-water withdrawal and the
discharge of treated water to the
Cumberland River under KPDES.
Each of these alternatives would
comply with the state's ground-water
withdrawal and KPDES require-
ments. The alternatives would also
comply with applicable flood plain
design and hazardous materials
transportation requirements. All of
the ground-water extraction alterna-
tives (3A, 3B, and 3C) should event-
ually achieve compliance with
ground-water ARARs.
Air emissions generated by Alter-
natives 4 (A, B, and C) would not
be subject to Clean Air Act
regulations because the annual
contaminant emissions rates would
not exceed 250 tons per year.
Instead, these alternatives are more
appropriately evaluated in terms of
the residual risk they may pose, over
time, in the "Long-Term Effective-
ness and Permanence" analysis.
Primary Balancing Criteria
Long-Term Effectiveness and
Permanence
Alternatives 4 (A, B, & C), 5, and 6
involve ground-water recovery
measures that will both remove
contaminants from impacted ground
water and retard the migration of the
VOC plume, thereby permanently
eliminating the potential for the
recovered contaminants to threaten
human health and the environment.
All of the ground-water extraction
alternatives (3A, 3B, & 3C) should
eventually provide a permanent
remedy for ground water.
Alternatives 4 (A, B, & C) involve
the use of air strippers in which
VOC contaminants are transferred
from a water stream to that of an air
stream that must be treated in a
further step. Each alternative would
employ air pollution control (APC)
devices to capture the airborne
pollutants. Alternatives 4
-------
alternative. Short-term effects to
on-site workers involved in the
construction should be minimal.
However, health and safety
ocedures will be implemented
' .ing the construction as a
precaution. The time required for
implementation of this alternative
is expected to be less than one
year.
Implementability
Alternatives 4 (A, B, & C), 5,
and 6 are all available for use at
the Site as self-contained, skid-
mounted units from multiple
vendors. Existing multiport
diffuser piping can be used to
discharge treated ground water to
the Cumberland River.
Use of Alternative 4B would
require that a significant volume
of natural gas or propane will be
brought to the Site routinely to
fuel the catalytic oxidation
Astern. Gas lines do not
extend to the Site.
Alternative 5 would require daily
i n rt«-kAxtt* nnr* s^-f +lt A rtwtnt-nrn rtf*w\-**
l.*LO|JVVLlVSAlt3 V/A Uftts &J OIX/J.A1., OtU.ia.£7~
ling, and maintenance to monitor
operations and, thus, is more
labor intensive than the other
alternatives. Further, the speci-
alized labor necessary to perform
these tasks may not be available
on daily basis in the area
Use of Alternatives 4C and 5 will
require that a heated shelter be
erected to protect the systems
during extended periods of below-
freezing temperatures or heavy
precipitation. Alternative 6 would
be subject to weekly system shut
downs as the saturated carbon in
the GAC unit was being replaced
with regenerated carbon.
A comparison of the estimated
prts'-iH worth costs associated
with the five ground-water treatment
alternatives indicates that Alternative
4A ($2,287,000) will be the least
expensive, followed by Alternatives
4C ($2,512,000), 4B ($2,660,000),
and 5 ($3,593,000). Alternative 6
represents the most expensive
ground-water treatment alternative ($
6,547,000).
Capital costs will be highest for
Alternative 4B ($ 328,000) and
lowest for Alternative 6 ($108,800).
Annual O&M costs will be highest
for Alternative 6 ($ 518,800) and
lowest for Alternative 4A
($169,500).
A comparison of costs associated
with the three ground water extrac-
tion alternatives indicates that Alter-
native 3A is the least expensive
($1,101,000), followed by Alter-
native 3B ($1,272,000) and Alter-
native 3C ($1,419,000). Capital
costs will be much higher for Alter-
native 3C ($495,700) compared to
Alternatives 3 A and 3B ($136,900
and $122,800, respectively). Annual
O&M costs will be approximately
equal for Alternative 3A and Alter-
Alternative 3B.
MODIFYING CRITERIA
State Acceptance
EPA is currently seeking State
concurrence with this proposed
remedial action.
Community Acceptance
Community acceptance of EPA's
preferred remedial alternative will be
evaluated after the public comment
period and will be described in the
Record of Decision. The public is
asked to comment on the proposed
Remedial Action during the Public
Comment Period, which is from
May 29, 1995 through July 27,
1995.
THE NEXT STEP
Opening of the public comment
period on the FS and Proposed Plan
is the next step in selecting a final
remedial action for the National
Electric Coil Co./Cooper Industries
Superfund Site. The comment period
provides an opportunity for local
residents to submit comments to EPA
on all the remedial alternatives
considered for the Site.
Following the public comment
period, EPA will finalize the ROD,
which will detail the remedial action
chosen for the Site and include
EPA's responses to comments receiv-
ed during the public comment period.
After the ROD is signed, a design
plan for implementing the remedial
action will be prepared. Once the
design is complete, construction of
the remedial action can begin. A site
review will be conducted every five
years at this Site since is anticipated
that VOCs in ground water will
remain above health based levels for
the foreseeable future. This review
will evaluate the long-term effective-
ness of the ground-water clean-up
removal, and will make recom-
mendations regarding its continued
use.
EPA encourages the public to submit
written comments on all the alterna-
tives presented in this Proposed Plan.
Based on new information or public
comment, EPA, in consultation with
the Commonwealth of Kentucky,
may later modify the preferred alter-
native or select another remedial
action presented in this Proposed
Plan and the Feasibility Study
Report. The public, therefore, is
encouraged to review and comment
on all of the alternatives identified
in this Proposed Plan. The FS
Report should be consulted for more
information on these alternatives.
1.1
-------
FOR MORE INFORMATION
The following EPA and KNREPC representatives
•nay be contacted for additional information about
jie National Electric Coil/Cooper Industries
Superfund Site.
CONTACTS
Derek Matory
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
l-(800)435-9233, Extension: 2071
Billy Hill
Kentucky Natural Resources
and Protection Cabinet
Division of Waste Management
18 Reilly Road
Frankfort, Kentucky 40601
(502)564-6716
Cindy Gibson
Community Relations Coordinator
U.S. EPA Region IV
J45 Courtland Street, N.E.
Atlanta, GA 30365
l-(800)435-9233, Extension: 2071
Wida Cobb
Assistant Regional Counsel
U.S. EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
(404) 347-2641, Extension 2277
Bill O'Steen
Groundwater Technology Unit
U.S: EPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
(404) 347-3866, Extension 6654
GLOSSARY
Air Stripping: A process that uses physical
separation to clean up contaminated ground water
by contacting clean air and contaminated water to
transfer the volatile contaminants from the water
to air stream. The VOC laden air stream may be
further treated before its release into the
atmosphere.
Administrative Record: A file that is maintained
and contains all information used by the lead
agency to make its decision on the selection o'f a
response action under CERCLA. This file is
required to be available for public review and a
copy is to be established at or near the site,
usually at an information repository. A duplicate
file is maintained in a central location, such as a
regional EPA or State office.
Applicable or Relevant and Appropriate
Requirements (ARARs): This term refers to the
Federal and State requirements that a remedy the
EPA selects must attain. These requirements may
vary from site to site.
Aquifer: A geologic formation that contains
sufficient permeability to yield significant
quantities of ground water to wells and springs.
Baseline Risk Assessment: Analysis of the •
potential human health effects and ecological
effects (both current and future) caused by
hazardous substance releases from a site if no
cleanup were undertaken at the site. The BRA
provides the basis for determining whether or not
remedial action is necessary at a site.
Carcinogen: Any substance that causes cancer.
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA):
A federal law passed in 1980 and amended in
1986 by the Superfund Amendments and
Reauthorization Act. This law created a special
tax that goes into a trust fund, commonly known
as Superfund, to investigate and clean up
abandoned or uncontrolled hazardous waste sites.
1,2-DichIoroethene (DCE): A volatile organic
compound that is known to be toxic when -
absorbed by skin. DCE is used as a solvent and is
also a natural degradation product from TCE.
14
-------
GLOSSARY
Monitoring Wells: Special wells drilled onsite
where groundwater can be sampled at selected
depths and studied to determine such things as
the direction of groundwater flow and the types
and amounts of contaminants present
Parts Per Billion (ppb or //g/L): A unit of
measurement used to describe levels of
contamination. For example, one gallon of a
liquid in one billion gallons of water is equal to
one part per billion.
Parts Per Million (ppm or mg/L): A unit of
measurement used to describe levels of
contamination. For example, one gallon of a
liquid in one million gcilons of water is equal to
one part per billion.
Plume: A body of contaminated ground water
flowing from a specific source. Its movement is
influenced by such factors as local ground-water
flow patterns and the density of contaminants.
Potentially Responsible Party: Parties,
including owner, who may have contributed to
the contamination at a Superfund site and may
are considered PRPs until they admit liability or
a court makes a determination of liability. PRPs
may agree to participate in site cleanup activity
without admitting liability.
Preferred Alternative: EPA's selected best
alternative, based on information collected to
date, to address contamination at a site.
Proposed Plan: A fact sheet summarizing
EPA's preferred cleanup strategy for a Superfund
site, the rationale for the preference, and a
review of the alternatives developed in the RI/FS
process.
Record of Decision (ROD):, A public document
that explains which cleanup alternative will be
used at an NPL site and the reasons for choosing
that cleanup alternative over other possibilities.
Remedial Action (RA): The actual construction
or implementation phase that follows the
remedial design of the selected cleanup
alternative at a Superfund site.
Remedial Alternatives: A list of the most
technologically feasible alternatives for a cleanup
strategy.
Remedial Design (RD): An engineering phase
that follows the record of decision when
technical drawings and specifications are
developed for the subsequent remedial action at
a Superfund site.
Remedial Investigation (RI): A Remedial
Investigation (RI) examines the nature and extent
of contamination problems at a site.
Remediation: Cleanup
Superfund: A term commonly used to describe
the Federal program established by CERCLA.
Superfund Amendments and Reauthorization
Act (SARA): Amendments to CERCLA enacted
On Gclobci 17, 19S6.
Trichloroethylene (TCE): A volatile organic
compound commonly used as a solvent and
degreaser. TCE can be absorbed by humans
through inhalation and ingestion, and is
associated with kidney and liver damage.
\
Vinyl Chloride: A volatile organic compound
that may be produced from naturally degrading
TCE. Studies have shown that vinyl chloride
causes liver cancer.
Volatile Organic Compounds (VOCs):
Organic compounds, such as TCE, vinyl
chloride, benzene, and toluene that are
characterized by being highly mobile in ground
water and that readily volatilize when contacted
with air.
15
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MAILING LIST
ADDITIONS/CORRECTIONS
If you did not receive this fact sheet in the mail, you are not on the EPA's Mailing list for the
National Electric Coil Co., Superfund site. If you would like your name added to the list, please
fill out this form, detach and mail to:
Derek Matory
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Name
Address.
Telephone.
Affiliation
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COMMENT
USE THIS SPACE TO WRITE YOUR COMMENTS
Tear Out Sheet to Complete
Your input on the recommended cleanup plan for the National Electric Coil Co., Superfund site is important to
EPA. Comments provided by the public are valuable in helping EPA select a cleanup remedy for the site.
You may use the space below to write your comments, then fold and mail. Comments must be post-marked by
July 27, 1995. If you have questions about the comment period, please contact Derek Matory at the number
listed on page 14.
Name
Address
City State Zip.
Phone
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APPENDIX B
Responsiveness Summary
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Responsiveness Summary
National Electric Coil Co., Site
Page 1 of 21
RESPONSIVENESS SUMMARY
GROUND-WATER ISSUES
Public Comment (1) When the air stripping unit became operational in 1993, this was done
through the interim action record of decision. That report and previous documents stated that the
shallow aquifer was not contaminated or connected to the deep bedrock aquifer. Therefore
groundwater treatment would be implemented only to address pollution in the deep bedrock
aquifer. Also as citizens requested many times to the EPA to conduct well testing of shallow
wells, your agency told us. there was no need to do this that these wells were not connected to the
deep aquifer which was the aquifer of concern. Now in your agencies most recent reports the
proposed plan for Final Remedial Action, it stated that the shallow aquifer is contaminated and is
connected to the deep bedrock aquifer. Also, residents spoke out in the public hearing about
well water levels dropping. These are wells that are not being monitored by EPA or Cooper
contractors.
EPA Response: At the time when the "Interim " Action ROD was prepared, the Agency had not
conducted its RI/FS and thus had not formally sampled the site for full characterization and was
not at that time prepared to draw conclusions regarding the extent of contamination. In
response to this comment, the "Interim " ROD was thoroughly reviewed for specific statements
that may have been made regarding this issue, but no mention of hydraulic connection between
The zone referred to in the RI Report and the ROD as the shallow aquifer was sampled during
the RI. The results of this sampling are presented in Table 4-9. This data and other water level
data obtained during pumping activities served as a basis for the conclusion drawn in the RI that
the shallow aquifer and bedrock aquifer are hydraulically connected.
Further, EPA and the State have expressed concern regarding the impact of the extraction well
on nearby residential wells that are completed in the bedrock aquifer, since the start of the
ground-water remediation efforts. Thus, in order to monitor the Site extraction well impacts, the
extraction well's withdrawal rate and the resultant discharge limits have been and continue to
be monitored by the State under its permitting authorities.
Though the particular community was not specified, nor the date of the public hearing, the
commentor mentioned that during a public hearing several residents stated that water levels in
their wells were dropping. In response, on two separate occasions, in December 1993 and in
February 1994, the state of Kentucky Division of Water conducted well inspections in the White
Star Hollow area to investigate complaints made. The State's investigation concluded that none
of the residences' water quality or quantity problems were related to NEC site contamination,
but rather resulted from either their wells' close proximity to abandoned coal mining properties
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Responsiveness Summary
National Electric Coil Co., Site
Page 2 of 21
or from inadequately sized water pumps or other equipment-related reasons.
Public Comment (2) One well (Don White) has gone dry. I am also requesting that the state of
Kentucky investigate this. This very well could be a violation of the current Kentucky well
water withdrawal permit.
EPA Response: This request has been relayed to the State.
Public Comment (3) Even after State water department's statement at June 26, 1995 meeting
that water table was very unusual, federal EPA refused to do more well testing outside of their
allegedly contaminated plume.
EPA Response: The Agency believes the thirty-three (33) -wells that are currently being
monitored in conjunction with the ground-water/air stripper system thoroughly encompasses the
lateral extent of the VOC-impacted ground water. The wells are currently being sampled twice a
year in order to assess how well the plume is being contained and to record water level
measurements for future engineering and design purposes. The contaminant plume appears to
now extend approximately 2500 feet to just beyond the bridge that connects State Highway 119
with Dayhoit. It is not evident beyond that approximate lateral distance.
In addition to those wells approved by EPA and the State to monitor the impacted water, the
State has sampled other wells that are clearly outside the ground-water plume's boundaries in
order to respond to the concern of residents who live in surrounding communities. Many of the
additional wells sampled, as a service to the community, were determined to come under the
following categories: the wells were located upgradient of the impacted site ground-water; the
wells are completed at elevations above that of the impacted water; and the wells are located in
communities hydrogeologically remote from the site and the contaminated water beneath it.
Specifically, wells located in the White Star Hollow (Ewing Creek), Fresh Meadows, Tremont
and Watts Creek have been investigated by EPA and/or the State as a service to concerned
residents. Wells located within the Tremont area were sampled by the State in January 1992.
None of the water samples collected from the Tremont, White Star Hollow, or Fresh Meadows
area wells showed detectable levels of chlorinated solvents.
The State also conducted additional sampling at seventeen (17) wells and one cistern located in
the White Star Hollow and Fresh Meadows communities (in August 1994); six (6) wells in Watts
Creek during the air stripper shut-down period (in October 1994); and two (2) additional wells
in Watts Creek (in October 1995) . Analysis of the ground-water samples showed no
correlation to the NEC site contamination.
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Responsiveness Summary
National Electric Coil Co., Site
Page 3 of 21
Public Comment (4) By conducting dye tracing the extent of pollution will be determined and
any wells that are being affected by the pumping and treating of the air stripper will be
identified.
We previously submitted documentation from Dr. Ralph Ewers in 1992 and 1993 in a request to
State and Federal EPA which plainly stated that dye tracing needed to be done. This as all of our
other requests have been ignored.
EPA Response: The VOCs spilled at the Site provide tangible evidence of the path that VOCs
have traveled and indicate the route the dyes would travel if they -were introduced into the
aquifer. Dye-trace studies are better suited for characterization of complicated aquifers -where
ground-water flow patterns are not well defined. This is not the case with this bedrock aquifer.
The extensive sampling and pump testing conducted have adequately determined the extent of
ground-water contamination. Dye-traces would be an unnecessary expense and would mostly
provide redundant information.
Public Comment (5) We are requesting that dye tracing be conducted by an independent.
company to determine the extent of ground-water pollution in Dayhoit and surrounding
communities. This request is based on discrepancies in reports that have been submitted by
Cooper Contractors and the Federal Environmental Protection Agency.
EPA Response: Please refer to EPA's response to Comment #4.
Public Comment (6) In the proposed and final Interim Action ROD prepared by Cooper's
contractors and approved by the Federal EPA, this report stated the shallow aquifer was not
connected to the deep bedrock aquifer and was not contaminated. Now the RI Report (1995)
done by Cooper contractors and approved by the EPA, states the shallow aquifer is contaminated
and is connected to the deep aquifer.
The purpose of pointing this out is Number 1 the discrepancies in the approved reports. Number
2 is the fact that we have asked since 1989 that shallow wells in the community be tested and the
EPA told us they were not connected and not contaminated and did not need to be tested, but the
most resent reports confirm our suspicions that we have had all along. Nobody would listen to
us the citizens, so what the EPA previously denied about the aquifers, current reports state
otherwise, and reconfirms our original concerns that the EPA refused to act upon.
EPA Response: No statements regarding the interconnection of the shallow aquifer to that of
the bedrock aquifer were made in the 1992 Interim Action ROD. The Agency made no
conclusions regarding characterization of the site until finalization ofthePJ/FS. Please refer to
Comment #1
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Responsiveness Summary
National Electric Coil Co., Site
Page4of21
Public Comment (7) In your Record of Decision dated 9-30-92 Responsive Summary Public
Comment (6), discussion of my (Ms. Teri Howard) well where chloroform was found. The
answer was my well was contaminated by chlorination, I had the well installed myself and it was
never chlorinated. But chloroform was found on site in the well testing, why is it so
inconceivable that it was not connected to the chloroform found on site.
EPA Response: Water levels recorded for nearby wells indicate that the Howard well is
hydrogeologically upgradient of the site-impacted ground water plume. In other words, the
general direction of bedrock ground water in the vicinity of the Howard well follows the
topography and flows downhill. Ground water does not flow from the Site toward the Howard
well.
The February 1989 ground-water sample indicated the presence of chloroform at 3ug/0. As was
promised in the July 1992 meeting, EPA added this well to its list of wells that were to be .
sampled in conjunction with the RI. The subsequent sample, collected in December 1992, did
not detect chloroform or any other volatile organic compound.
As initially stated in the 1992 Responsiveness Summary, the presence of chloroform in the water
sample may have resulted from either chemicals introduced during the ground-water sample's
chemical analysis (a laboratory contaminant) or possibly may have resulted from chlorination of
this well or that of an upgradient neighbor.
ADDITIONAL SAMPLING
Public Comment (8) After years of burning PCB laden transformer oil in an oil burning
furnace, dioxin and dioxin fiiran by products would have to be in the fly ash from the stack but
again dioxin and their by products were never addressed. Using the meteorological data you
could have determined where the deposits would have been, and testing should have been done
to protect human health and the environment.
EPA Response: The Agency believes the primary means of migration byPCBs and its related
products occurred via surface-water transportation rather than through fly ash deposition. RI
surface soil sampling focused on the common border shared by the site and the trailer park.
Twenty-nine (29) samples were collected on the trailer park side of the fence at 5 feet, 25 feet,
and 100 feet from the fence line at 75 feet intervals.
The sampling results, located in RI Table 4-27 and Table 4-28, indicated that these contaminants
were detected below levels currently known to cause adverse health effects in humans. The
maximum levels detected in off-site surface soils for total PCBs and dioxins/furans were 1053
ug/kg total PCBs and 0.00023 ug/kg 2,3,7,8-TCDD, respectively. The corresponding Federal
action levels for these contaminants are 1000 ug/kg and 1 ug/kg, respectively. A single soil
sample marginally exceeded the Federal residential PCB action level. It was collected within
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Responsiveness Summary
National Electric Coil Co., Site
Page 5 of 21
five feet of the fence and in close proximity to the location where a limited soil removal was
previously conducted. This finding is consistent with reports that PCS contaminated oils were
applied along the fence line to kill weeds. The analytical results of the PCB analyses for the
remaining twenty-eight (28) soil samples ranged from "non-detect" to 212 ug/kg.
Public Comment (9). Additional sampling of on-site soils along the fence line should be
undertaken. From a reading of the baseline risk assessment, it appears that the surficial soil
sampling was conducted some 5 feet or more from the fence line. To the extent that waste oils
containing PCBs were used for weed control at the fence line, sampling should have been
conducted much more closely to the fence, rather than (at a) five-foot distance.
EPA Response: The decision was made to conduct soil sampling at a distance of 5 feet from the
fence line in order determine whether significant surface water transportation of PCBs from
prior site disposal practices or weed control applications along the fence had occurred.
PAST INVESTIGATIONS/PAST SPILLS
Public Comment (10) When the 5100 tons of soil and debris were removed from the site after
the EPA had been asked over and over to test for dioxin furans; they did not.
EPA Response: The 1991 NEC soil excavations were conducted by EPA as an emergency
rpmnvnl nf.vnil? thnt nnvorl n ihreni in tormv nf rtirort rrrnfnfl n-nfl further m-r\n-nr1--\t»itov
. . ... ,j ., ^ — .... ... — ^.j , j „. ..r~. ^. v.~..» .,~»~,
contamination. The emphasis at the time was to address the soils that posed an immediate threat
to human health. Therefore, the early environmental sampling, on which the soil excavation
plan was based, was designed to achieve this goal, rather than to establish a detailed
characterization of the site. Further, dioxin/furan analyses are not conducted in removal actions
in the absence of compelling reasons.
Public Comment (11) Adequate testing was never done for dioxin, dioxin furans. Past
practices of burning PCB laden transformer oil which produces dioxin was never addressed. The
meteorological data could and should have been used to determine where they fly ash was
deposited.
EPA Response: Off-site soils were analyzed for dioxin/furans up to a distance of 100 feet onto
the Trailer Park property. No evidence of contaminated fly ash deposition was apparent. The
furnace stack that operated at the Site was not fitted with a blower. Thus, particulates exiting
the stack via air transport would not be expelled long distances from the site, but would be
expected to primarily deposit on the site or in close proximity to the stack. The absence of
evenly distributed contaminants in the off-site soils that border the Site indicates that no
appreciable air deposition occurred.
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Responsiveness Summary
National Electric Coil Co., Site
Page6 of 21
Public Comment (12) Considering work practices and past exposures further testing after
rinding dioxin/furans and their byproducts should have been done, instead of sending to risk
assessment and quitting. According to EPA studies dioxin and their by products are migratory.
Is it actually safe to say that after 30 plus years of illegal work practices these products did not
migrate from the plant site? You don't actually know how much was on site you never tested.
EPA Response: Please refer to EPA Responses to Public Comments #8, #10, and #11.
Public Comment (13) Also in public comment you were told about the cleanup of 1987 (by
Cooper Industries) and made aware of the fact that the waste was disposed of in various places.
These places should have been tested for VOCs and heavy metals.
EPA Response: The cleanup that you mentioned occurred before site ground-water
contamination was discovered by the Kentucky Division of Water in February 1989 and EPA 's
subsequent involvement in late 1989. At that time, EPA obtained information from local
residents on potentially related waste-disposal sites. This information led to EPA's investigation
and subsequent removal action at the Putnam Landfill (i.e., Harlan County Drum Site) and its
referral of the Airport Landfill to the State for possible site assessment. EPA currently is not
aware of any other Site-related disposal sites, but would welcome any additional information
that can lead to the discovery of additional hazardous waste sites.
Public Comment (14) The history of what happened at this site has never been fully
investigated. The purpose of requesting soil sampling for metal, PCB's and dioxins is because
we know and it has been very well documented by the residents and former workers of the past
practices at this plant. One which was outdoor burning of different materials and substances
which are known to contain cancer causing chemicals. These chemicals were carried through
the air and deposited into the soils on and offsite. How can you say the extent has been
determined when you all do not know the full scope of activities of past practices at this site.
EPA Response: The Superfund law specifies that EPA 's involvement with NPL sites be limited
to the following: (1) site investigations are conducted to determine the extent of contamination
that originated at the site; (2) determine the risk level associated with the identified site-related
contamination; and (3) conduct cleanup and/or containment or stabilization of site-related
contamination determined to pose unacceptable current or future risk to human health and the
environment. The Superfund law does not direct EPA to investigate risk associated with past
chemical contamination or the associated health effects. These issues of past health effects are
addressed by the Agency of Toxic Substances and Disease Registry.
Please refer to Public Comment #11 for response to other issues raised in this comment.
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Responsiveness Summary
National Electric Coil Co., Site
Page 7 of 21
Public Comment (15) We want off-site soil tested for metals, PCB's and dioxins. We want to
know the complete routes of exposure.
EPA Response: The results of the NEC remedial investigation soil samples indicate that soil
located at the Site and at adjacent off-site locations have been sufficiently characterized by soil
samples collected for the RI. EPA's review of this data shows that site soils and soils located on
the adjacent mobile home park do not contain site contaminants, such as dioxins, furans, PCBs,
and lead, in levels that are considered harmful to humans and/or the environment.
Off-site soil samples were collected on the trailer park property from the area located just
outside the Site's south fence line that runs along the common property boundary shared by the
Site and the trailer park. Samples were collected from this area at 5 feet, 25 feet, and 100 feet
from the fence line on parallel lines and a spacing interval of 75 feet. This sampling pattern was
employed because EPA believes that contamination of trailer park property soils could only
have occurred as the result of surface water drainage from the Site. Therefore, the area
sampled, which is located between the previously contaminated site soils and the interior of the
trailer park, would be expected to exhibit contaminant levels equal to or greater than those
located at more distant locations within the trailer park property.
Analyses for pesticides, PCBs, semivolatiles, and metals were run on the twenty-nine trailer park
soil samples that were collected. The results of the sampling show that off-site soils have not
been contaminated by surface water drainage or other releases from the Site. The maximum
levels detected for total PCBs and dioxins/furans were 1053 ug/kg total PCBs and 0.00023
Ug/kg 2.3.7.8-TCDD. respectively. The corresponding Federal residential soil action levels for
these contaminants are 1000 ug/kg and 1 ug/kg, respectively. The single trailer park soil
sample, in which PCBs were detected at a level that marginally exceeds the residential PCB
action level, was collected within five feet of the fence and in close proximity to the location
where a limited soil removal for PCBs was previously conducted within the fenced facility
property. This finding is consistent with reports that PCB contaminated oils were poured along
the fence line to kill weeds. The analytical results of the PCB analyses for the remaining twenty-
eight soil samples ranged from "non-detect" to 212 ug/kg, which were below the PCB action
level cited above.
AIR EMISSIONS ISSUES
Public Comment (16) With the pump and treat (system) emitting VOCs into the air, they
should have (to) be registered with the Toxic release inventory program.
EPA Response: The Toxic Release Inventory Program is limited to manufacturing facilities that
discharge to the environment. The remediated water discharged from the air stripper/ground
water recovery system is permitted under the Kentucky Pollutant Discharge and Elimination
System. Samples are collected weekly to comply with the permit. The air stripper stack is
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Responsiveness Summary
National Electric Coil Co., Site
Page 8 of 21
monitored monthly for airborne VOCs.
Public Comment (17) The Air Dispersion Modeling Analysis Report May 1995 assumes that
with a 60-foot stack height, ambient concentrations of volatile organic compounds stripped from
the ground water will be within acceptable ranges.
The Kentucky Resources Council requests that additional confirmatory sampling be conducted
for all wind directions to determine whether, under normal operating conditions and during
periods of stagnant air flow (i.e., inversions), in order to prove out the assumptions concerning
concentrations of pollutants emitted from (the) air stripping unit.
EPA Response: The air dispersion model was based on site-specific data -which incorporated
site-specific meteorological conditions, such as wind speeds. The model estimates ground-level
concentrations at the maximum impact point and estimates impact to the nearest resident
receptor (300 feet due south on the Holiday Trailer Park). The highest predicted impact point,
using a yearly average, was predicted to be northeast of the air stripper stack at 300 meters
north by 300 meters east, which is located within the wooded, non-inhabited foothills in a nearby
mountain. The trailer park, -which is located south of the air stripper stack is monitored monthly
for airborne VOCs.
Public Comment (18) What kind of chemical reaction will the VOC's emitted from the air
stripper produce when they meet with the existing ozone killing chemicals in the atmosphere?
EPA Response: Trace amounts of VOCs are emitted from the air stripper stack to atmosphere
where they degrade in sunlight.
MISCELLANEOUS ISSUES
Public Comment (19) As a lifelong resident of Dayhoit, after reading and studying about the
things my family had been exposed to I (Ms Teri Howard) should have felt secure in the fact that
EPA was finally there to protect me, but instead I was treated rude in public meetings and brow
beat in the media.
EPA Response: EPA has not intentionally sought to mistreat any residents, either publicly or
privately, with regards to any matters related to this Site. EPA sincerely apologizes if responses
to questions asked of EPA have caused harm.
Public Comment (20) L(Mr. Tom Fitzgerald of the Kentucky Resources Council) would also
recommend that as your agency makes final decisions about our community, that you review the
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Responsiveness Summary
National Electric Coil Co., Site
Page 9 of 21
Executive Order on Environmental Justice which was signed by President Clinton in 1994. It
appears that previously the guidelines in the Executive Order on Environmental Justice, have not
been implemented when EPA is making decisions about what will or will not happen in our
community or if the environment and the public's health will be protected here in the future.
EPA Response: Thank you for your comment.
Public Comment (21) We (Ms Joan Robinnette of CCATW) have a definite problem with EPA
terminology. You all constantly state you are "cleaning up" when it is very clear in your reports
and previous statements made by EPA staff, that this process is treatment of ground water. The
pollution according to Cooper contractor reports and EPA reports state that pollution cannot be
cleaned up but possibly stabilized at best. Treatment is also only addressing three (3) of the
many chemicals found in the drinking water.
EPA Response: EPA uses the term "clean up" in reference to NEC ground-water
contamination to describe ground-water extraction and treatment (pump and treat) operations.
The extraction operations reverse the flow of the ground water, thereby halting or reversing the
down-gradient movement of the plume and removing VOCsfrom the aquifer. The degree to
which the VOC plume is stabilized, as opposed to the degree to which contaminants are removed
from the aquifer is subjective. Pump and treat activities at NEC are "clean up " activities
because they are employed in order to restore the aquifer to Federal drinking water standards.
This ROD specifies that the four grrnmd-wntpr contaminants listed in Table 9.1 be monitored for
compliance during the pump and treat activities. Although EPA has focused its attention on
these chemicals, EPA analyzed the environmental samples collected during the RIfor the full
compliment of organic and metal contaminants listed in the EPA's Contract Laboratory
Program (CLP) protocol. The contaminants listed in Table 9.1 represent those detected in levels
that pose unacceptable risk to human health. Narrowing the scope of contaminants allows EPA
to select the appropriate clean-up remedy. Even though ground-water samples will continue to
be analyzed and monitored for other contaminants, EPA will consider the bedrock aquifer to be
restored when the contaminants listed in Table 9.1 have been reduced to their respective Federal
drinking water standards.
Public Comment (22) (When) EPA emergency response was overseeing the testing of soil on
site in 1989, citizens made several request that soil testing be conducted for dioxins. Cooper
contractors proposed a testing plan EPA approved and testing for dioxins was not done. In turn
5,100 tons of contaminated dirt was removed. In 1993 independent dioxin sampling was
conducted in the Holiday Mobile Home Park and these chemicals were found. If the soil that
was removed had been tested for dioxins it could have given us an idea of what we could expect
to find in soils offsite and prevent residents and workers from being presently exposed or future
exposure to dioxins. Again we were ignored.
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National Electric Coil Co., Site
Page 10 of 21
EPA Response: Please refer to EPA Response to Comments #10 and #14.
PRP OVERSIGHT ISSUES
Public Comment (23). How can the EPA put so much faith in the honesty of Cooper Industries
and no one actually looks at the raw data and only look at their summary reports of testing.
After all, this is a company that intentionally and willfully poisoned my community for 30 plus
years.
EPA Response: Please refer to EPA Response to Comment #26.
Public Comment (24) Because of past exposures to the chemical soups in our food chain, all
emissions from the pump and treat should have been permitted and regulated not just three.
EPA Response: Soil, sediment, ground-water, and fish samples collected for the NEC RI were
analyzed for the full compliment of organic and metal contaminants listed in the EPA 's Contract
Laboratory Program (CLP) protocol. The primary contaminant risk to human health posed by
this site related contamination was determined to be through ground-water consumption.
The three contaminants, to which you refer, were the volatile organic contaminants for which air
emission action levels were set to monitor the performance of the air stripper and to ensure that
the air stripper emissions released to air contained no contaminants above health-based levels.
The air emission action levels are set for the three contaminants: vinyl chloride, trichloroethane,
and dichloroethene, because the RI sampling data indicated that these contaminants were
present in the impacted ground water above health-based levels. The air stripper removes most
of the volatile organics present in the recovered water and transfers it to the air stream. Prior to
release to atmosphere, the air stream is, currently, blown through crushed carbon, where most
of the VOCs are removed. All of the other CLP chemicals were and continue to be analyzed for
the ongoing biannual site monitoring, even though other chemicals not been detected above EPA
health-based levels.
Public Comment (25) The Federal EPA has never swayed from any of Cooper contractors plans
and reports.
EPA Response: Cooper Industries signed an Administrative Order by Consent in May 1992
with EPA to investigate the extent of environmental contamination that resulted from spills and
dumping of chemicals on the site during the National Electric Services operational period.
EPA 's Administrative Order outlined specific guidelines about how the site was to be sampled
and how the samples were to be analyzed. Many of these procedures were specified in the July
1993 Remedial Investigation/Feasibility Study Work Plan. The results and interpretation of the
collected site data were presented in the December 1994 Remedial Investigation Report.
Appropriate remediation options were evaluated in the January 1995 Feasibility Study Report.
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National Electric Coil Co., Site
Page 11 of 21
The November 1994 Baseline Risk Assessment Report and the May 1995 Air Dispersion
Modeling Report were prepared by EPA contractors.
EPA is satisfied that these documents were prepared in compliance -with the rigorous EPA
guidelines specified for each. The documents were submitted in draft to EPA and the State. The
comments prepared by EPA and the State for each document were incorporated prior to their
being finalized.
Public Comment (26) In February 1995, I (Ms. Joan Robinette of CCATW) did a Freedom of
Information Act (FOIA) request to the Federal EPA requesting to review all the raw data that has
been generated on this site by Cooper's contractors. I was told there were seventeen (17) boxes,
when I went to review I was presented with seven (7) boxes of data which had a shipping invoice
stating they had been shipped to Atlanta from Houston, Texas. This was February 13, 1995. I
began reviewing documents on February 14,1 also discovered that EPA had never reviewed this
information either, but yet had approved final reports which were done by Cooper contractors.
EPA Response: One of the provisions of the May 1992 Administrative Order that Cooper
Industries signed with EPA to investigate the Site specifies that Cooper Industries prepare data
package for each samples collected for the RI and store them. The analytical records reviewed
in February 1995 were copies of the entire RI data set that Cooper is required to maintain. The
entire file was copied and sent to EPA solely for the purpose of this FOIA request.
EPA does not routinely request, nor does it review all of the data packages prepared for each
sample collected for NEC or oihsr Supsrfund siiss. EPA docs, hcr,vcver, rc\'ic\v a percentage of
the data packages at its discretion. A representative number of NEC data packages were
reviewed prior to February 1995 by appropriate EPA Region IV Environmental Services
Division staff. In compliance with the Administrative Order, Cooper Industries submitted the
select data packages to EPA for review. Also, as additional checks on the quality of analytical
analyses performed by PRP labs, EPA routinely submits its own samples to these labs to
evaluate their performance. EPA also collected and analyzed "split" samples at select sampling
locations to compare the analytical results with the PRP laboratory.
Public Comment (27) We want the EPA to go back and validate all of the sampling that
Cooper contractors have done.
EPA Response: Please refer to comment #26.
Public Comment (28) EPA only has to review Cooper's contractors activities once every five
years. This is not enough monitoring EPA should review at least every two years at best.
EPA Response: Cooper Industries will continue to conduct ground-water monitoring, twice
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National Electric Coil Co., Site
Page 12 of 21
each year, and will annually report its analytical results to EPA. The five-year reviews will be
used primarily at NEC to evaluate the long-term effectiveness of the pump and treat system by
monitoring the rate of ground-water contaminant level reduction in selected wells. EPA can
modify the selected remedy if data indicates that the pump and treat is ineffectual.
Public Comment (29) We want a fund established to pay residents water bills. Why should
residents have to pay for water that Cooper stole from them?
EPA Response: The commentor should contact Cooper Industries concerning this matter. If
the commentor, is not satisfied with Cooper Industries' reply, the commentor has other options to
pursue recourse from Cooper Industries.
Public Comment (30) We have not been made whole. Our piece of mind has been stolen from
us by the EPA and Cooper industries.
EPA Response: EPA has no response to this comment.
Public Comment (31) We want the Health Assessment that the ATSDR recommended on
former plant workers and residents.
EPA Response: A TSDR has made provisions to conduct the NEC Health Assessment. A TSDR
representative, Mr. Car I Blair, should be contacted for further information.
Public Comment (32) On the evening of June 26, 1995, before the EPA meeting in Dayhoit,
EPA staff people went to our public library which was closed and pulled documents from our
Administrative record which is there for the public to review and threw these documents in the
trash. EPA came into the meeting and did not tell citizens that these reports had been trashed.
EPA Response: EPA removed only draft copies of documents for which final versions of the
documents were available. The draft documents did not contain the changes that were made to
incorporate EPA and the State's comments and were not accurate representations of actions
taken on the Site or did not, in some instances, reflect EPA's final interpretation of collected site
data. Further, the removal of the draft documents freed up space on the visibly stuffed shelves
and was done in plain view of the librarian on duty.
SELECTED REMEDY
Public Comment (33). What effect if any will this addition of two more sources of contaminated
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Responsiveness Summary
National Electric Coil Co., Site
Page 13 of 21
ground water will have in changing the maximum concentrations of the various constituents in
the ground water entering the unit.
EPA Response: The expanded ground-water withdrawal system will consist of the one deep
bedrock recovery well plus a series of extraction wells installed in the shallow and intermediate
zones of the impacted site aquifer. The single deep bedrock recovery well will operate at a
pumping rate of 100 to 125 gallons per minute. It is estimated that 3 to 4 recovery wells spaced
approximately 100 feet apart will be required in the intermediate bedrock zone. The anticipated
ground-water recovery rate per well is 10 to 20 gpm. Based on the extent of the VOC plume in
the shallow zone and on the characteristics of the alluvium, it is estimated" that approximately 6
recovery wells will be required in this area at an anticipated ground-water recovery rate per
well is 2 to 5 gpm. The ground-water extraction system flow rate will increase from 125 gpm to
200 gpm (125 gpm deep zone, 40 gpm intermediate zone, and 25 gpm shallow zone). The
anticipated average concentrations of the constituents of concern in the recovered ground water were
estimated using ground-water sampling results and a weighted average approach and are as follows.
The "Projected" and "Current" headings below refer to constituents concentrations detected in
recovered ground water, prior to treatment:
Contaminant Projected Current (Max.) KPDESLimit
1,1-Dichloroethene 6 ug/l ND-2ug/l 2.1 ug/l
1,2-Dichloroethene 3,000 ug/l 510-1700 ug/l 40 ug/l
Trichloroethane 4,100 ug/l 227 -1,270 ug/l 60 ug/l
Vinyl Chloride 140 ug/l ND-177 ug/l 20 ug/l
Public Comment (34). What is the capture efficiency under operating conditions, what is the
reliability, and what are the outputs of the various configurations of the air stripper unit. It is not
possible to compare and comment among alternatives to better control the VOCs generated from
the stripper unit, and the use of a resin adsorption versus a catalytic oxidation unit, absent more
thorough information regarding these technologies.
For example, one of the proposed alternatives would supplement the stripper through use of a
catalytic oxidation unit which would heat the VOC compounds to temperatures well below those
needed to completely destroy the molecular bonds for those compounds, raising the possibility of
creation of products of combustion and products of incomplete combustion through the oxidation
process. Information concerning the byproducts of these treatment processes, including a full
characterization of the off-gases, and the capability of such units to effectively treat such waste
streams without creating other emissions of concern should be developed and made available
prior to a choice among alternatives.
EPA Response: Influent and effluent data collected for the KPDES permit indicate that VOCs
are removed from recovered ground water at approximately 99%. The vaporized VOCs are
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Responsiveness Summary
National Electric Coil Co., Site
Page 14 of 21
currently blown through the carbon bed where approximately 65% of the VOCsare absorbed.
This Final ROD (March 1996) requires the vaporized VOCs be removed from the air stream
using a catalytic oxidation unit, 'which is expected to attain a contaminant destruction efficiency
of 95%. The VOCs are oxidized primarily to carbon dioxide, water vapor, and hydrogen
chloride.
For more details concerning the technical advantages and disadvantages of the different
alternatives, please refer to Section 3.0 Detailed Analysis of Alternatives of the NEC Feasibility
Study, or Section 5.0 Recommendations.
Public Comment (35). Additional work must be undertaken regarding the air emissions from
the stripper unit under various alternatives. The choice of a 250 ton per year limit as the
benchmark against which to measure compliance with the Clean Air Act ignores both the much-
lower threshold for air emissions of any hazardous air pollutant (HAPs), which under the Clean
Air Act Amendments (CAA) of 1990 is reduced to 10 and 25 tons of any and all HAPs,
respectively, and also state air toxics regulations. Under the state air toxics regulations, which
are the ARARs in this case against which air emissions both from the facility and the air stripper
unit must be measured, the burden is on the applicant (in this case Cooper Industries and EPA) to
demonstrate that the emissions will not include potentially "hazardous matter or toxic substances
in such quantities or duration as to be harmful to the health and welfare of humans, animals and
plants." 401 KAR-63-020.
EPA Response: The CAA regulations that you cited do no apply to the NEC air stripper because
the annual volume of HAPs emitted to atmosphere does not reach the threshold of 10 tons per
year for any one HAP or 25 tons per year for a combination of HAPs. Thus, the air stripper is
not considered a major source, as defined by Title III, and is not subject to Title V operating
permits.
Because air strippers used at Superfund sites usually do not meet CAA thresholds, EPA policy
dictates that emissions be protective of human health. Health-based emission levels were
developed in conjunction with the baseline risk assessment that was prepared under EPA
direction by its contractor. As an added measure to insure compliance with the health-based
emission levels, the air stripper, currently, utilizes crushed carbon as a means of air pollution
control. This final ROD will require that catalytic oxidation technology be used as a control to
attain greater VOC reduction efficiency. The emission levels are presented in Table 9.2 of this
ROD. For further review of this matter, please refer to USEPA OSWER Directive 9355.0-28.
Public Comment (36) In treatment of the pollution, ground-water contamination is the only
thing that is being addressed. Although we are well aware that millions have been spent on this
site, the most economically feasible as in the cheapest way, is to pump and treat ground water
and ignore the other pathways of exposure including the past pathways.
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Responsiveness Summary
National Electric Coil Co., Site
Page 15 of 21
EPA Response: Analysis and interpretation of environmental data collected for the RI showed
that ground water was the only impacted site media that posed unacceptable risk to human
health and the environment.
Public Comment (37). The use of an interceptor trench, rather than shallow wells, to intercept
and gather contaminated groundwater flowing through the shallow zone, may provide a more
reliable method of capturing the contamination prior to discharge into the river, provided that the
trenching is properly located and designed to provide for interception of the flow based on
proper modeling of the flow.
EPA Response: Interceptor trenches are subsurface drains designed to capture ground-water
and generally consist of a trench backfilled with porous material and equipped with perforated
piping which diverts collected ground water to a collection sump that included a submersible
pump for ground-water recovery. Because of the Site close proximity to the river, EPA does not
favor this method to recovery shallow groundwater over that of utilizing low volume extraction
wells. We are concerned that the efficiency of the ground-water treatment system would be
significantly reduced because river water may be recovered into the trench along with that of the
shallow groundwater. Thus, a larger volume of water would require treatment.
RISK ASSESSMENT ISSUES
Public Comment (38). The Risk Assessment is no good, the site history has not been
characterized properly, and the cumulative risk factor of citizens being previously exposed has
not been considered at all. We want the risk assessment revised to take all of the past exposure
into consideration. EPA has not implemented the ATSDR's recommendations, such as more soil
testing and posting the river for the fish consumption advisory.
EPA Response: The baseline risk assessment is specifically designed to evaluate only current
and potential futufe risks associated with hazardous waste releases from the site. Thus, EPA
risk assessments by definition do not evaluate past hazardous chemical exposures. Potential
past chemical exposures can be evaluated by ATSDR.
EPA has taken steps to implement those recommendations made by ATSDR in its November
1994 Health Assessment Report that are within the Agency's authority to carry out under
Superfund law. Specifically, this ROD will require that ground water impacted by site-related
organic solvents be monitored throughout the plume remediation as stated in Recommendation
1; air emissions from the stack and process water from the system is being monitored, at regular
intervals, to insure compliance with the ROD's air emission limits and Kentucky Division of
Water's surface water discharge limits as stated in Recommendation 4. The air stripper
emission limits presented in Table 9.2 of this ROD were developed using conservative EPA
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Responsiveness Summary
National Electric Coil Co., She
Page 16 of 21
standards. The developed air model took into account factors such as the effects of the nearby
buildings, site-specific wind directions and other meteorological parameters based on a modeled
maximum impact on the nearest resident (100 feet due south from the stack onto the adjacent
trailer park).
The other three (3) A TSDR recommendations were directed toward the State of Kentucky's
because implementation of these recommendations would fall under the State's environmental
regulatory authority. The three recommendations are as follows: (1) Recommendation 2 states
that a fish advisory should be issued. The Kentucky Division of Water has indicated that its does
not plan to issue a Fish Advisory for the Dayhoit stretch of the Cumberland River at this time,
because the levels ofPCBs detected in fish were comparable to PCB levels detected in fish
around the state. However, the State has distributed a notice to residents impacted within the
Day hoi t area about this matter and should be contacted for additional information. A copy of
the notice is provided in Appendix C; (2) In Recommendation 3, ATSDR stated that the extent
and source of elevated zinc and lead levels should be determined, even though it acknowledged
that its source is not "believed to be originating from the NEC site." EPA's characterization of
Superfund sites is limited to investigating the nature and extent of contamination associated with
hazardous waste spills or releases that originated at the site and will not pursue further
characterization of these particular contaminants; and (3) Recommendation 6 states that nearby
river water should be tested for fecal coliform. Again, EPA 's investigative authorities at
Superfund sites are limited to characterizing hazardous materials that originated at the site.
Bacterial contamination, such as coliform, is not considered a hazardous substance. The
Kentucky Division of Water should be contacted for an update on the biological testing that it
periodically conducts within the State's waters.
As a final point, the commentor 's statement that A TSDR recommended that site soil samples
should be tested further is incorrect. In fact on page 41 of its November 1994 Health
Assessment, ATSDR stated that, "Low levels of these contaminants (PCBs, dioxin/furans, and
heavy metals) have been found, but not at levels of health concern. The testing indicates that the
soil does not contain hazardous contaminants that could be taken up by plants and consumed at
toxic levels by humans. "
Public Comment (39). Since there are no apparent restrictions on the future use of the site and
because the "industrial" nature of the site transitions abruptly to residential and other uses, the
target levels chosen for remediation must be for residential sites, and notwithstanding the
attainment of "target levels" for hot spots in soil, the cumulative burden of exposure to even
"target" levels of contaminants from the soil pathway and from the surface water pathway as
those contaminants are carried in suspension during rainfall events, must be included in a risk
assessment that seeks to accurately reflect the total exposure from all pathways to the public and
workers.
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Page 17 of 21
EPA Response: Continued industrial use of the NEC site is the most likely future land use for
the property. As presented on page 5 of the baseline risk assessment, the soil action level for
PCBs was established at 2.5 times lower than USEPA 's action level for industrial sites and the
action level for VOCs was based on lifetime exposure under residential use assumptions.
Therefore, the soil target levels are considered protective of current and potential future uses of
the site. It is noted that off-site surficial soils and surface water were evaluated for long-term
residential exposures and carcinogenic risks and noncarcinogenic hazards were found to be
within or below EPA's target risk levels established for Superfund under the National
Contingency Plan (NCP).
Public Comment (40). The exposure factors and the formula for determining the level of risk
do not account for the historic exposure within the surrounding community and workforce to
these pollutants through complete pathways that potentially existed for years prior to the
discovery of the contamination in drinking water supplies, soils and within the workplace. The
historic exposure and possible adverse health effects, as well as the body burdens already carried
by the exposed human population, should be considered in the determination of appropriate
levels of remediation of the releases in failing to account for these past exposures, the health
risks of leaving the additional contamination are significantly understated.
EPA Response: Please see EPA Response to Comment 38. The objective of the baseline risk
assessment is to estimate the reasonable maximum exposure expected to occur under both
current andfuture land-use conditions. Evaluation of historic exposures is typically planned
and evaluated by the Agency for Toxic Substances and Disease Regi\try (A T$r>P). Their
assessment typically requires human monitoring and assessment of the health status of the
people near the site based upon the monitoring results.
Public Comment (41). No consideration appears to have been given to the cumulative effect of
exposure to multiple compounds. The risk assessment assumes that the total effect of exposure
is additive, and fails to account for the cumulative and synergistic effects of exposure to multiple
compounds, including cancer-promoters. The exposure assessment and toxicity evaluations
should not merely be additive.
EPA Response: The risks and hazards from individual chemicals and pathways were summed
for each medium in the NEC baseline risk assessment under the assumption of dose additivity.
As stated in EPA 's Risk Assessment Guidance for Superfund EPA/540/1-89/002 (RAGS), "the
assumption of dose additivity ignores possible synergisms or antagonisms among chemicals, and
assumes similarity in mechanisms of action and metabolism. Unfortunately, data to assess
interactions quantitatively are generally lacking. In the absence of adequate information, EPA.
guidelines indicate that carcinogenic risks should be treated as additive and that noncancer
hazard indices should also be treated as additive. These assumptions are made to help prevent
an underestimation of cancer risk or potential health effects at a site. "
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Public Comment (42). The presence of VOCs and other contaminants in surface and near-
surface soils of areas that were not excavated or filled continues to be a direct pathway for
current exposure to workers and future exposure to the public through volatilization of the
compounds into the air and through inhalation of particulates.
EPA Response: As presented on pages 6 and 7 of the NEC baseline risk assessment, the
concentrations of three targeted VOCs in the small unexcavated regions of the warehouse and
along the southern fence -were at least an order of magnitude below the soil action levels
established by EPA and its guidance for risk-based concentrations for residential soils.
Therefore, VOCs were not selected as chemicals of potential concern for these surface soils and
the exposure pathways associated with surface soils were not carried through the quantitative
risk characterization.
Public Comment (43). The decision not to take further action to remove contamination from
on-site soils and subsoils does not adequately consider future land use changes which might
result in increased direct physical contact, including construction which would tend to
concentrate VOCs and increase exposure and redisturbance of subsoil areas containing
contaminants.
EPA Response: The decision not to take further action to remove contamination from on-site
soils and subsoils is based upon the conclusion that on-site soils do not pose risks above the
EPA 's target risk levels that would require remediation. Exposure to subsurface soils by
workers during construction activities was evaluated in the baseline risk assessment. Risks were
found to be -within EPA's target risk levels and noncarcinogenic hazards were found to be below
EPA 's target level.
Public Comment (44). There should be a formal uncertainty analysis, which would produce a
"confidence distribution" reflecting the degree of confidence with which any claim concerning
the level of risk is supported by available evidence. Also, missing is a formal analysis of the
variability of risk across sensitive sub-populations. Either the default parameters must be chosen
to be protective of the most sensitive subpopulations, which they do not under the current set of
default values, or a formal analysis of the variability of risk across the sensitive subpopulations
must be included. The baseline risk assessment does not appear to adequately account for the
uneven distribution of risks throughout the population. The analyses should focus on the
maximally exposed and most sensitive subgroups within the population, including immuno-
compromised individuals, individuals with respiratory illnesses, in utero exposure, etc.
EPA Response: The uncertainties associated with the human health exposure assessment and
toxicity assessment, and with estimating ecological risks were qualitatively discussed in the NEC
baseline risk assessment. As stated in EPA 's Risk Assessment Guidance for Superjund RAGS)
'Only on the rare occasions that an RPMmay indicate the need for a quantitative uncertainty .
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Responsiveness Summary
National Electric Coil Co., Site
Page 19 of 21
analysis should one be undertaken ...A highly quantitative statistical uncertainty analysis is
usually not practical or necessary for Superfund sites. "
Human health risks were calculated for the reasonable maximum exposure (RME) using the 95%
UCL exposure point concentration, toxicity values based on upper-bound estimates, and
standard default exposure factors based on 95th percentile values in accordance with USEPA
risk assessment guidance. The goal of the RME is the maximum exposure that is reasonably.
expected to occur at a site.
Public Comment (45). Little attention appears to be given to the significant uncertainties
surrounding the toxicity of many of the contaminants. While professing that the exposure
numbers have been "peer-reviewed," and thus are sound in theory, the brief lexicological profiles
reflect graphically that little testing has been conducted for many of these compounds regarding
a range of chronic health consequences, including whether chronic, low-dose exposure to many
of the compounds might be capable of including or facilitating cancer, reproductive, nervous, or
endocrine system disruptions, etc.
The significant data gaps in the human and ecological effects of chronic, low-dose exposure to
many and all of these compounds makes the supposed conservatism of the default numbers an
illusion.
EPA Response: The toxicity values used in the baseline risk assessment represent the best
available and defensible toxicological information that EPA has compiled and specified that
should be used in Sunerfund risk assessments. FPA rnntini/nij.sh> iinHntes the do.tc.bcises that
supply this information as toxicological research is completed and reviewed. The toxicity values
are derived to be protective of chronic, low dose exposures and are based on studies which have
evaluated a wide range of toxicological endpoints, including cancer, reproductive, nervous, and
endocrine disruptions.
Public Comment (46). The use of a risk factor of one in a hundred thousand or a million
additional cancer deaths as a target for satisfactory remediation fails to provide for complete
protection of public health and the environment. The Council rejects in principle the suggestion
that it is "acceptable" as a matter of public policy to shift any additional risk of death or illness
onto a population without their knowledge and consent. The use of risk assessment to quantify
and adjudge acceptable some level of residual contamination that may be left in the land or
groundwater of the surrounding community is, on a policy level, a question of whether the
polluter and his successors in interest should be held completely accountable for the pollution, or
whether that responsibility may be shifted to the public-at-large and to neighbors. It is,
alternatively, an economic choice of internalizing completely the costs of the use of toxics at the.
front end, and transferring those costs evenly among consumers, or externalizing a portion of
those costs through the knowing and intentional exposure of those whose live near the site to
chemicals that are known or suspected of being harmful, but "acceptably" harmful under this
risk-based approach.
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National Electric Coil Co., Site
Page 20 of 21
The allowance of any residual off-site contamination of soil, subsoil or groundwater also raises
significant legal questions, since the EPA approval of a plan submitted by the responsible party
which does not completely abate the health risks through remediation of off-site contamination,
implicates the EPA in "taking" of the surrounding land by direct physical appropriation. The
target goal for any off-site contamination must be complete restoration of land and water
resources.
The use of the quantitative risk assessment to justify less-than-complete restoration of the land
and groundwater resource is, on another level, a profoundly troubling moral question. The
Council will not endorse by our silence a deliberate decision to impose on an unconsenting
population of innocent third-parties, any additional risk of bodily harm and property loss. The
council reiterates its opposition to any "risk-based" remediation approach that does not assure
complete protection of public health and welfare.
EPA Response: EPA uses the general Iff6 to Iff4 risk range as a "target range " within which
the Agency strives to manqge risk as part of a Superfund cleanup. Once a decision has been
made to take an action, the Agency prefers that cleanups achieve the more protective end of the
range (i.e., JO'6), although waste management strategies achieving reductions in site risks
anywhere within the risk range may be deemed acceptable by the EPA. Furthermore, the upper
boundary of the risk range is not a discrete line at 1 x JO'6 in making risk management decisions.
A specific risk estimate around Iff4 may be considered acceptable if justified based on site-
specific conditions, including any remaining uncertainties on the nature and extent of
contamination and associated risk. Therefore, in certain cases EPA may consider risk estimates
slightly greater than 1 x Iff4 to be protective.
Public Comment (47). In certain cases where there is no established reference dose (RfD) for
exposure from a particular pathway, the agency has not yet calculated the risks associated with
that exposure, leading to a significant understatement of the total risks. An example of this is the
lack of consideration of noncancer effects of vinyl chloride. Cancer and/or noncancer effects are
ignored because of the lack of an RfD, leading to a total risk that is understated.
EPA Response: The noncarcinogenic effects for benzene and vinyl chloride were not ignored,
but could not be quantitatively evaluated due to the unavailability of an established reference
dose. Noncarcinogenic effects of exposure to these compounds were qualitatively discussed in
the Section 4.2 (Toxicological Profiles) of the risk assessment and carcinogenic effects were
quantitatively evaluated.
Public Comment (48). The problem of understatement of the risk from ground-water exposure
is compounded by the failure to include exposure associated with inhalation of air at the site.
When the BRA was conducted, air emissions from the site had stopped, but modeling data
appears to indicate that during the plant operation this would have been a significant exposure .
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pathway and would have dramatically increased both the cancer risk and the Hazard Quotient.
EPA Response: The purpose of a baseline risk assessment is risk to human health and the
environment under both current and future land-use conditions. Please see EPA Response to
Comments 38 and 40.
Public Comment (50). The effects of exposure to dioxin-like compounds are not considered in
the BRA. The assumption that this exposure can be ignored because the individual risk from the
individual dioxin congeners was low enough to be considered unimportant, is unsound.
EPA Response: As indicated in Table 3 of the Baseline Risk Assessment, the site concentration
of 2,3,7,8-TCDD, the most toxic dioxin congener, was approximately 18 times lower than EPA
guidance for 2,3,7,8 tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD). Therefore, it was not
selected as a chemical of potential concern and carried through the quantitative risk assessment.
In addition, the increased cancer risk from the toxicity equivalent quotient (TEQ), referred to in
the Council's comments of 7xlO'6' is within USEPA 's target risk range of JO'4 to JO'6, and less
than the risk level of W4 at which remedial action is warranted.
-------
APPENDIX C
Commonwealth of Kentucky Fish Study
-------
LNV HKUI WHSIL/WHILK P. 2/9
State Government News
Commonwealth of Kentucky Brereton C. Jones, Governor
Capitol Building
Frankfort, Ky. 40601 CONTACT: John Draper
502-564-2611 Dept for Health Services
Newsline: 1-800-633-1019 (502)564-7181
(In Kentucky;) _
PetePfeiffer
Fish and Wildlife Resources
(502) 564-3596
Mike Mills
Division of Water
(502) 564-3410
STATE AGENCIES REVIEW INFORMATION
CONCERNING FISH IN CUMBERLAND RIVER
FRANKFORT, KY. (Dec, , 1994) - A recent report concerning possible polychlorinated
biphenyl (PCB) contamination offish caught in the Cumberland River has been reviewed by the agencies
in Kentucky responsible for issuing fish consumption advisories.
The three agencies, the DepL for Health Services, the DepL for Fish and Wildlife Resources, and
the Division of Water, reviewed a report issued by the Agency for Toxic Substances and Disease Registry
(ATSDR) that dealt with an assessment of public health threats in the Dayhoit area. The area was placed on
the federal Superfund list in 1992 following discovery of chemicals in wells and in the soil.
The ATSDR report recommended that a "No Fishing" advisory for the Cumberland River near
Dayhoit be posted because of the detection .of PCBs in certain fish samples.
The levels of contamination were reported as being between. 14 and .95 parts per million (ppm).
The Food and Drug Administration (FDA) "action level," that level above which food will be removed
from the marketplace, for PCBs in fish has been set at 2 ppm.
Kentucky agencies have traditionally used FDA action levels as guidance in determining when a
fish consumption advisory should be issued for fish caught in Kentucky waters. In addition, the state
requires a considerable amount of sampling before the issuance of an advisory. There were seven
composite samples of five fish each in the study done by the ATSDR.
ATSDR has based its recommendation on newly published EPA guidance which uses risk
assessment to issue advisories. Under this method, eating a four-ounce portion of a fish that contained
PCB contamination of .002 ppm would be considered a risk if consumed more than once a month over a
period of 70 years. The risk level would be considered to be one in a million; that is, there would be the
risk of one additional cancer death per million people who consumed more than one meal a month for 70
- more -
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7
- UWI II I—' >«
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Pamphlet Issued by Commonwealth of Kentucky to Address PCB Levels in Fish
National Electric Coil Co./Cooper Industries NPL
Answers to questions about
PCBs and Fish
in the
Upper
Cumberland
River
• What art PCBs?
' Why are they a
problem?
* How do they gel into
fish?
• Are then PCBs in
Upper Cumberland •
River fish?
* Are the Csh from the
Upper Cumberland
River safe to eat?
What are PCBs?
PCBs - polychlorinated biphenyls - are >
poop of man-made chemicals Out wen
widely used by many different industries
from about 1929 until they were banned
for most uses in 1979.
PCB* range from oily liquids to waxy sol-
ids. They mix easily with raosi solvents
and oils.
they resist heu so well, ihey
were used in electrical equipment (tram-
formers. capacitors, and heat transfer and
hydraulic iysterosX They have also been
used in paino. adhesive*. caulking corn-
pounds, printing into, and flre-retardanu.
Why are PCBs a problem?
PCBs remain in the environment for a
very loot time. They accumulate In
stream sediments. soils, plants, fish, birds,
and mammals. PCBs become more con-
centrated u mey move up the food chain
from tfae simplest organism to humans,
who are u the end of in* chain.
Ceding rid of PCBs in the body is diffi-
cult became Ihey have to be dirmirally
convened by the liver into a water soluble
chemical the body can excrete. When
pi"*H-^Mtm^jflatp4J mjr»n'>i« jjrc taken in
f««t»y than (jicy arc f I'T'n*"^. they build
ur '" die fat tissue. In bumans, they can
cause skin lesions, swollen lirnbi. eve and
liver problems, and possibly cancer and
birth defttn.
How do PCBs get into fish?
PCBs tend 10 be tied up in sediments, soils,
and the fat time of living creatures, rather
lhan in the water in a stream, river, or lake.
PCBs bind especially
well with clay-sill
sediment. Burrowing
animals eating silt in
sediment frfTCTHf con-
taminated with PCBs
and are eaten by
small fish, which are
consumed by larger
fish, A larger, older
"fish win have had
more ornc to accumu-
late norePCE.Ji in fat tissue. Humans
become exprt/i to PCBs by eating these
fish.
Are PCBs in Upper
Cumberland River fish?
Determining the presence of PCBs simply
by InffHpf: at or smelling a fish (or trans-
former Odd or sediment) is impossible.
Experurre laboratory techniques are neces-
sary to make men a determination.
Samples of fish tissue from fish caught in
Page 1
Page 2
Page 3
the Upper Cumberland River in the vi-
cinity of Dayhoit show PCB levels
ranging from 0.14 to 0.93 pans per mil-
lion. The avenge levels of PCBs in fish
in Kr :.i:ky waters is 0.37 parts per
million. This average is based on more
than 150samples taken at monitoring
stations in various streams across the
state.
Are fish from the Upper
Cumberland River safe to
eat?
The Food and Drug Administration
(FDA) has set an "action level" for
PCBs in fish at 2.0 pans per million.
Fish containing amounts above ibis ac-
tion level will be removed from the
marketplace. Amounts of PCBs found
in fish in (he Cumberland are weH be:
tow the FDA action level
Doo't stop eating fish - it is a good
source of protein and is low in saturated
fat. However, some people should not
eat any fish suspected of containing
PCBs.
Pregnant women and
those planning to be-
come pregnant, as
well as preschool-age
children, should no! eat fish suspected
of being contaminated with PCBs.
Suggestions for people
who choose to eat fish:
The following precautions will help to
rirntase the risk of exposure to PCBs
through eating fish:
• Eat only skinless and boneless fillets
with as much fat rercoved
as possible. cui o»«v oi to
Avoid (he «-gb««
skin and
discard E
uc» on b«fr tat
• Roast or bate the
Tub instead of frybg or raicrowaviag
it (Cooking does ££ destroy PCBs
or lower their toxiciiy. The beat from
cooking simply melu wme of tfce fa(
in (lie fish, removing pollutants at the
umeiime.)
• Do not eat any of ite juices or fau
Out cook out of the fuX and do not
use them for cooking other foods.
Natural Resources
.tnd
Environmental Protection Cablaet
Department for EfiTtronroental
Protection
14 Rein? Road
Frankfort, KY 40601
Page 4
Page 5
Page 6
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APPENDIX D
Summary of Cancer and Noncancer Risks by Exposure Route
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RISKSUM
05/15/95
TABLE 18
SUMMARY OF CANCER AND NONCANCER RISKS BY EXPOSURE ROUTE
NATIONAL ELECTRIC COIL SITE
HARLAN COUNTY, KENTUCKY .
EXPOSURE
ROUTE
Groundwater
Ingestion
Inhalation of VOCs from Showering
Inhalation of VOCs from Non-showering
TOTAL
On-site Subsurface Soils
Ingestion
Dermal Contact
Inhalation of Particulates
TOTAL
Off-site Surficial Soils
Ingestion ,
Dermal Contact
Inhalation of Particulates
TOTAL
Sediments
Ingestion
Dermal Contact
TOTAL
Bsh
Ingestion
Child Resident
Cancer HI
3E-04
9E-05
1E-05
4E-04
NA
NA
NA
NA
1E-05
2E-06
2E-08
1E-05
4E-07
1E-07
5E-07
NA
21
0.3
0.05
21
NA
NA
NA
NA
0.1
0.006
—
0.1
0.002
0.0006
0.0026
NA
Adult Resident
Cancer ' HI
5E1-04
8E>05
1H-05
6IE-04
NA
NA
NA
NA
4E-06
4E-06
1E-08
4E-06
1E-07
{IE-OS
ilE-07
4E-04
9
0.06
0.01
9
NA
NA
NA
NA
0.01
0.003
—
0.01
0.0003
0.0002
0.0005
' ""
Lifetime Resident
(Child + Adult)
Cancer
8E-04
2E-04
2E-05
1E-03
NA
NA
NA
NA
1E-05
6E-06
3E-08
1E-05
•
5E-07
2E-07
7E-07
4E-04
Adult Worker
Cancer HI
2E-04
3E-05
NA
2E-04
7E-06
3E-07
3E-10
7E-06
1E-06
3E-08
4E-10
1E-06
NA
NA
NA
NA
3
0.02
NA
3
0.08
0.0003
—
0.1
0.09
0.0005
—
0.1
NA
NA
NA
NA
HI Hazard Index
VOCs Volatile Organic Compounds
NA Not Applicable - Pathways not evaluated for that receptor
81
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APPENDIX E
Commonwealth of Kentucky Letter of Concurrence
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JAMES E. BICKFORD /^W^ 'PAUL E- PATTON
SECRETARY fff M] J§| GOVERNOR
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FRANKFORT OFFICE PARK
14REILLYRD
FRANKFORT KY 40601
April 5, 19%
Derek Matoiy
U.S. Environmental Protection Agency
345 Courdand Street, N.E.
Atlanta, Ga 30365
Re: National Electric Coil Superfund Site
Harlan County, Kentucky
Record of Decision
Dear Mr. Matory:
The Kentucky Division of Waste Management (KDWM) Superfund Branch has reviewed
the draft Record of Decision (ROD) and supporting documents for the National Electric Coil
Superfund Site located in Harlan County, Kentucky. The Kentucky Division of Environmental
Services (KDES) has also reviewed the aforementioned documents as they relate to risk assessment
and their comments have been submitted under separate cover.
KDWM concurs with the choice of remediation for contaminated groundwater. We ask that the
same monitoring provisions utilized at the time of the initial pump and treat startup in July of 1993
again be implemented for the startup of the new and expanded treatment system, to provide
assurance to the local residents that operations are being conducted in a responsible and safe
manner
It is our position that two issues remain to be resolved. The first is related to our continuing
differences in risk assessment, which have been well documented in previous correspondence.
While we believe that resolution of risk assessment issues would not change the selected remedy,
endpoints for remediation could be affected. For this reason, site risks should be reassessed prior
to any future decision regarding shutdown of the treatment system. In the interim, our respective
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agencies can continue to resolve their differences.
The second issue concerns soil contamination. Although existing levels of contamination may not
pose an unacceptable risk, KDWM feels that a limited amount of additional sampling is needed
for verification. Since EPA does not believe that additional sampling is necessary, KDWM will
conduct mis activity. The results will be shared with EPA so mat a joint evaluation may be made.
Hopefully this will resolve the issue to everyone's satisfaction.
As always, KDWM is willing to discuss the issues at your convenience.
Sincerely,
'Jeffrey Pratt, RE., Manager
Superfund Branch
Division of Waste Management
cc:Robert Daniel! (Director, KDWM)
Rick Hogan (KDWM)
William Hill (KDWM)
Randall McDowell (DOL)
Sally Wiley (KDES)
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