EPA Superfund
Record of Decision:
PB96-964022
EPA/ROD/R04-96/279
September 1997
American Creosote Works,
(Jackson Plant), Jackson, TN
9/30/1996
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AMERICAN CREOSOTE SITE
JACKSON, TENNESSEE
RECORD OF DECISION
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1996
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5 9 0002
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
American Creosote Works, Inc.
Jackson, Madison County, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable Unit #2 at the American Creosote Works site in Jackson,
Tennessee. The decision was made in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) , as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). The remedial action selected is based on
the information contained in the Administrative Record for the
site.
Actual or threatened releases of hazardous substances from this
site will be addressed by the response action selected.
Implementing the response action in this Record of Decision (ROD)
will mitigate the imminent and substantial endangerment of public
health, welfare or the environment associated with the site.
The Tennessee Department of Environment and Conservation (TDEC)
has provided input as the support agency throughout the remedy
selection process. Officials of TDEC are in agreement with the
selected remedy.
DESCRIPTION OF THE REMEDY
The remedy selected is a combination of free liquid removal and
disposal, immobilization, deed restriction, and monitoring. Free
creosote, water, emulsion, and associated contaminants will be
recovered from site soils and treated before disposal at approved
locations. Remaining contaminants in the target area will be
immobilized by mixing the contaminated soils and sludge with an
appropriately formulated binding reagent. The resulting mass
will be buried within the area and the area will be properly
landscaped to control erosion. Institutional controls will be
imposed to limit the property to industrial and similar uses
only. Leach tests will be conducted periodically on the
immobilized material to evaluate performance of the remedy. In
addition, surface waters, sediments,, and aquifers affected by the
site will be monitored to ensure that they are protected
effectively by the remedy.
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5 9 0003
STATUTORY DETERMINATIONS
The selected remedy 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. The remedy is cost-effective and utilizes
permanent solutions. It employs treatments that reduce toxicity,
mobility or volume as principal elements of remedy.
This remedy will result in hazardous substances remaining on site
above health-based levels. Therefore, a review will be conducted
every five years after commencement of remedial action to
evaluate remedy effectiveness and to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Richard D. Green, Acting Director Date
Waste Management Division
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5 9 0004
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
TABLE OF CONTENTS
SECTION PAGE
1. 0 SITE LOCATION AND DESCRIPTION 1
l.l Site Location l
1.2 Site Description 1
1.3 Site History 1
1.3.1 Response Actions 4
1.3.2 Enforcement Activities 6
2 . 0 COMMUNITY RELATIONS HISTORY 7
3 . 0 SUMMARY OF SITE CHARACTERISTICS 8
3.1 Surface Features 8
3 .2 Soils 9
3.3 Land Use 10
3.4 Climatology 11
4 . 0 SCOPE AND ROLE OF OPERABLE UNITS 11
5 . 0 SITE STUDIES 13
5.1 Previous Investigations 13
5.1.1 Site Assessment, 1981 13
5.1.2 Field Investigation, 1983 13
5.1.3 Site Analysis, 1984 14
5.1.4 Remedial Investigation, 1988 14
5.1.5 Feasibility Study, 1988 15
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON; TENNESSEE
TABLE OF CONTENTS (CONT'D)
5.2 Results of Additional Investigations 16
5.2.1 Groundwater Studies 16
5 .2.2 Environmental Impact Assessment 17
5.2.3 Focussed Remedial Investigation 18
6.0 SUMMARY OF SITE RISKS 20
6.1 Chemicals of Potential Concern 21
6.2 Exposure Assessment 21
6.3 Toxicity Assessment 24
6.4 Risk Characterization 35
6.5 Clean-up Criteria 37
7. 0 REMEDIAL ALTERNATIVES 37
7.1 Option #l-No Further Action 43
7.2 Option #2-Liquid Recovery/Immobilization/Monitoring.43
8 . 0 COMPARATIVE ANALYSIS OF REMEDIAL OPTIONS 44
8.1 Threshold Criteria 45
8.2 Primary Balancing Criteria 46
8.3 Modifying Criteria 48
9.0 THE SELECTED REMEDY 48
9.1 Liquid Recovery 49
9.2 Immobilization 49
9.3 Monitoring 51
9.4 Remedy Implementation 53
ii
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0006
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
TABLE OF CONTENTS (CONT'D)
10 . 0 STATUTORY DETERMINATIONS 54
10.1 Protection of Human Health and the Environment.... 54
10.2 Compliance with ARARs 55
10.3 Cost Effectiveness 57
10.4 Utilization of Permanent Solutions 57
10.5 Preference for Treatment as Principal Remedy 58
11. 0 SIGNIFICANT CHANGES TO THE PROPOSED PLAN 58
12 . 0 RESPONSIVENESS SUMMARY 59
APPENDICES
Appendix A:
Presumptive Remedies for Soils, Sediments, and
Sludges at Wood Treater Sites.
LIST OF FIGURES
Figure
1
2
3
4
5
Page
Site Location and Topographic Map 2
Site Map 3
Pentachlorophenol Concentrations 39
Dioxin Toxicity Equivalent Value 40
Cross Section of Final Treatment Area ...50
ill
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
TABLE OF CONTENTS (CONT'D)
LIST OF TABLES
Table Page
1 Chemicals of Potential Concern 22
2 Estimated Daily Intakes for Current Receptors 25
3 Exposure Point Concentrations for Soil Contaminants 26
4 Upper Confidence limit Algorithm 28
5 Model for Calculating Incidential Soil Ingestion Doses..29
6 Model for Calculating Doses from Soil Dermal Contact....30
7 Model for Doses from Inhalation of Soil Particles 31
8 Cancer Slope Factors 32
9 Chronic Reference Doses 33
10 Cancer Risk for Current Trespasser and Future Worker....36
11 Hazard Quotients for Trespassers and Future Workers. .^. . .38
12 Preliminary Remedial Goals 48
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
1.0 SITE LOCATION AMD DESCRIPTION
1.1 SITE LOCATION
The ACW site is located in central Madison County, Tennessee.
The site covers approximately 60 acres immediately southwest of
downtown Jackson, Tennessee (Figure 1) . Land use in the area is
predominantly industrial/commercial with a few residential
buildings to the north and undeveloped areas to the south. The
site is bounded on the south by the Seaboard Railroad, the
southwest by the South Fork Forked Deer River, to the west and
north by Central Creek, a tributary to the South Fork Forked Deer
River, and to the east by industrial buildings.
1.2 SITE DESCRIPTION
The general area is characterized by a gently rolling topography
with wide, marshy floodplain. Maximum relief is on the order of
100 feet (350 ft MSL to 450 ft MSL), with relief at the site
being about 20 feet. Within the boundary of the site, there are
numerous small swales and several low lying areas. As Figure 2
indicates, there were five (5) lagoons on the site. The low
lying areas and the lagoons have historically accumulated
contaminated surface water and sediments.
1.3 SITE HISTORY
The American Creosote Works, Inc., began operations as a wood
preserving facility in the early 1930s. The operations continued
until December 1981. The wood preserving work used both creosote
and pentachlorophenol (PCP). Wastewater sludge from the creosote
and PCP treatment of wood products are listed as K001 waste under
RCRA. Untreated process wastewater and potentially contaminated
storm water run-off was discharged directly into Central Creek, a
tributary of the South Fork Forked Deer River, until 1973. The
major sources of contaminated water were the treatment cylinder
condensate and surface water run-off over contaminated soils.
A levee was constructed in 1973 to retain surface water run-off
from the site and to reduce the potential for site flooding by
the South Fork Forked Deer River. The soil borrow pits used for
the levee construction subsequently became sludge storage
lagoons. Figure 2 shows the general site features, the process
area and the lagoon locations.
During 1974 and 1975, a wastewater treatment system was
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5 9 0009
s
s
s
EPA
FIGURE 1
SITE LOCATION
AND TOPOGRAPHIC MAP
AMERICAN CREOSOTE WORKS
JACKSON, MADISON COUNTY, TENNESSEE
NOVEMBER, 1993
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PROCESS MCA AND
NO lONCO) EXIST
A PROCCSSINO CYUMX*.
REMNANTS Of THE SAM)
FILTERS. CONCRETE PADS
AND MBC. METALLIC DEBRS
AND CREOSOTE TMBERS
PRESENTLY EXIST
IN THE PROCESS AREA.
ROtMNCC REUCDM.
TON REPORT.
SMkE, 1»U.
- BUILDINGS
- ROADS
- RAILROAD
- PROPERTY LINE
EZ3- WATER
MM* - FENCE
- VACUUM POND
- VACUUM POND
- LAGOON WATER
SOUTH FORK
FORKED OOR RMR
FIGURE 2
SITE MAP
AMERICAN CREOSOTE WORKS
JACKSON, TENNESSEE
NOVEMBER,
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
installed. The system operated through 1981. The engineering
report for the treatment system states that 25,000 gallons of
groundwater per day entered the sump under the pressure treatment
cylinders. The report also states that there was an accumulation
of five tons of sludge per year in the sand filters and that a
few loads of sand filter sludge were spread on the back road at
the east end of the property.
The American Creosote Works, Inc. ceased operations in December
1981. In May 1982, the company filed for bankruptcy under
Chapter 11 of the U.S. Bankruptcy Code. Response actions at the
ACW site began immediately prior to the closing of the facility
and continue to the present. The response actions taken to date
include the following.
1.3.1 Response Actions
November 1981. The Tennessee Department of Health and
Environment (TDHE), presently the Tennessee Department of
Environment and Conservation (TDEC), installed four shallow
monitoring wells around the property line. The monitoring wells
ranged in depth from 24 to 35 feet approximately.
December 1981. A National Pollution Discharge Elimination System
(NPDES) Permit Number TN0001904 was issued December 12, 1981.
The permit allowed the discharge of storm water run-off from a
site lagoon into the Central Creek. Operations at ACW ceased at
this time as well.
June 1982. TDHE sampled the site. High concentrations of PCP
and creosote were present in the storage tank sludge, soils, and
wastewater.
May 1983. Sampling at the ACW site by United States
Environmental Protection Agency (EPA), Region IV, Environmental
Services Division (ESD), personnel indicated the sludge, surface
soils, lagoon waters and shallow groundwater south and southwest
of the lagoons were contaminated with organic compounds
associated with wood preserving by creosote and pentachlorophenol
(PCP). Based on the investigation by BSD, EPA was authorized to
remove hazardous waste at the site under the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA). The United States Coast Guard Gulf Strike Team was
called in to remove impounded water at the site.
June 1983. Approximately 30,000,000 gallons of water with PCP
less than 100 parts per billion (ppb) were pumped into the South
Fork Forked Deer River. The water exceeding the discharge
criteria set by the Tennessee Division of Water Quality (TDWQ)
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AMERICAN CREOSOTE
JACKSON, TENNESSEE
was treated prior to release. Hazardous Waste Technology Service
(HAZTECH) was the EPA contractor on site. The untreatable
portions of the highly emulsified oil/water mixture were placed
in the empty tanks on site for storage until subsequent removal
was possible. Due to the quantity of contaminated material,
plans were approved for the on-site containment of the
contaminated materials by stabilization with lime kiln dust. The
sludge was removed from the bottom of the pond areas and from the
product storage areas and placed in a pit excavated in Lagoon 3.
The sludge in Lagoon 1 was solidified in-place and capped with
clay. The sludge in the basins and tanks was solidified and
taken, along with the soil surrounding the tanks, to Lagoon 3.
The pit containing the sludge was closed and capped with clay.
Diversion ditches were cut through the old bottom of Lagoon 3 to
divert water away from the pit containing the sludge. A pump and
gravity drain pipe were installed in conjunction with the altered
drainage pattern to remove subsequently impounded water. The
work at the site was completed on August 8, 1983.
February 1985. Repair work to mitigate the effects of a leaking
storage tank containing 10,000 to 15,000 gallons of PCP-
contaminated water was undertaken by the EPA contractor, O.K.
Materials.
June 1985. O.K. Materials, under the guidance of EPA, issued a
Remedial Action Plan, which included site assessment, analytical
data summaries, remedial action alternatives, and cost
estimation.
January 1987. The U.S. Army Corps of Engineers (USAGE) and the
EPA began field work for the Remedial Investigation/Feasibility
Study (RI/FS) . Soil and Material Engineers (S&ME) was the
contractor for the USAGE.
October 1988. The RI/FS Report was completed.
January 5. 1989. The Record-of-Decision was signed for Operable
Unit 1 (OU1).
January-February 1989. USEPA sampled all the tanks and pits
within the process area for a dewatering treatability study.
July 1989. USEPA began the field work for OU1 Remedial Design
and Remedial Action at the site.
November 1989. USEPA finished demolition, disposal, and
regrading of most of the plant facility and awaited a time slot
for use of an incinerator for contaminated soils and sludge.
Construction of new drainage pipe and ditch at the southwest
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
corner of the site was completed.
January 1990. Remedial Action work started in July 1989 was
completed.
December 1990. At the request of the state, EPA initiated design
and installation of a replacement drainage control system which
included a submersible pump and a recontouring of the landfill
cap.
June 1991. EPA began Site Stabilization field work.
June - July 1991. EPA oversaw the salvaging of scrap metal from
the old process area.
August 1991. EPA installed a security fence around the entire
site to restrict public access.
Currently, TDEC performs Site Stabilization activities at ACW
under a 1993 Support Agency Cooperative Agreement (SAGA). These.
activities include operation and up-keep of the drainage control
system, maintenance of all site facilities, and periodic sampling
of lagoon water before discharge to the river.
1.3.2 Enforcement Activities
In December 1981, ACW received its National Pollution Discharge
Elimination Systems (NPDES) permit #TN0001904. However, the
facility ceased operation shortly thereafter. On May 21, 1982,
ACW filed for Chapter 11 bankruptcy.
In June 1983, EPA used CERCLA emergency response funds to remove
and treat water from the site, remove and bury sludge, and cap
certain areas with clay. On June 1, 1983, the Technical
Assistance Team (TAT) took samples at the site. On June 3, 1983,
the EPA arranged for water from the site to be pumped to the
South Fork of the Forked Deer River. EPA consolidated the sludge
into a control area (former lagoon 3) and capped the area with
clay. All on-site operations were completed by August 31, 1983.
Costs for the above-described activities were approximately
$750,000. In October 1984, the site was placed on the National
Priorities List (NPL). On September 19, 1985, EPA began a
Remedial Investigation and Feasibility Study of the site which
cost approximately $800,000 to complete.
On July 25, 1983, EPA filed a proof of claim for $3,500,000 in
the Chapter 11 bankruptcy proceeding. Due to ACW's lack of
adherence to the court's procedures, on April 20, 1988, the U.S.
Bankruptcy Court for the Northern District of Florida, Pensacola
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
Division, dismissed ACW's case. Based upon accumulated evidence
and the fact that the Tennessee Secretary of State revoked ACW's
charter of incorporation on April 9, 1985, ACW is a defunct
organization and is not a viable potentially responsible party
(PRP) for cost recovery purposes. Therefore, the Federal
Superfund and Tennessee State funds are being used for
investigations and remedial actions at the site.
2.0
Community relations activities for the American Creosote Works
Site have been conducted jointly by the USEPA and the TDHE/TDEC.
The initial contact with the public took place in Jackson,
Tennessee, in 1982. This was in the form of interviews with
representatives of the City of Jackson regarding the upcoming
Superfund removal action of June 1983. Two public meetings were
organized for the Jackson community. The first meeting was held
in December 1986, prior to initiating RI/FS field activities.
The second meeting was held on August 29, 1988, to discuss the
results of the RI/FS and USEPA's Proposed Plan for addressing
site contamination. These meetings preceded the OU1 ROD which
was signed in December 1988.
For the purpose of the current ROD, a Proposed Plan Fact Sheet
was published in May 1996. It summarized the findings of
additional studies on the site, discussed the objectives and
proposed methods of site cleanup, requested comments on the
Proposed Plan, and invited the public to discuss the site at the
Availability Session held on June 25, 1996, in Jackson,
Tennessee. Only one comment, requesting monitoring of a private
well, was received from the public in relation to the Proposed
Plan. No member of the public attended the Availability Session.
Overall, active involvement and participation by the general
public regarding the site have been minimal.
In 1988, the water and sewer authority formally expressed concern
about the potential impact of the site on the Jackson wellfield
located 1.5 miles northeast of the site, and on the sewer
interceptor line located near the southern edge of the site. To
date, there has been no report of any site related impact on the
wellfield or the sewer lines.
There has been discernible interest from the City and the local
business community in facilitating the commercial development of
the site and the surrounding area. In 1995, USEPA was informed by
TDEC that the site was being considered as a possible location
for a penitentiary. Apparently the site did not meet the
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
necessary requirements as current information indicates that the
idea has been dropped.
3.0 SUMMARY OF SITE CHARACTERISTICS
3.1 Surface Features
The terrain at the ACW site is flat to gently rolling with a
moderate relief which is provided by the area stream channels.
Land surface altitudes range from about 340 feet above mean sea
level along the South Fork Forked Deer River to about 350 feet
near the northeastern corner of the site. The site is partially
protected from flooding by levees on the west and the south.
The main processing area was located in the north central portion
of the site and several remnants of the previous operations still
remain. These include sand filters, one steel treatment cylinder,
small sheds, several concrete pads which housed the above-ground
storage tanks, and miscellaneous piles of concrete, steel, and
timber cross ties. Vegetation in the processing area mainly
consists of scattered, tall grasses and wild flowers.
The physical demarcation of the site can be described as follows
(Figure 2):
the northern boundary consisting of the small,
intermittent stream identified as Central Creek
immediately north of the ACW dike and the right-of-way
limits of Meadow Street
the eastern boundary consisting of the back road up to
the constructed fence line with the adjacent lumber
company yard
the southern boundary consisting of the right-of-way
limits of the Seaboard Railroad
the western boundary consisting of Central Creek
immediately west of ACW dikes and a small portion of
the South Fork Forked Deer River
Physical features initially identified as part of the wood
preserving facility include:
plant process area and tanks
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
drip yards
surface water lagoons
road and railroad beds
administration building
chemistry .laboratory
numerous shops and work sheds
surface water drainage ways
The ACW site is within the floodplain of the South Fork Forked
Deer River. The boundaries of the site include dikes on the
northwest, west, and southwest. Two small drainage ways are
within the immediate areas including the Central Creek, and an
unnamed tributary. Central Creek flows along the northern and
western border of the site. The dikes on the ACW site form one
of the Creek's channel banks. Surface flow is to the south and
into the South Fork Forked Deer River which is approximately 300
feet downstream of the site. The drainage area of Central Creek
is approximately 1.1 square miles and it includes industrial
property, commercial property and several residences.
3.2 Soils
Three different soils are identified at the site as mapped by the
Soil Conservation Service
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
site, the Lexington's slope is generally less than 1 percent.
The soil material is predominantly loamy and very acidic.
Falaya Association. The Falaya soil covers 10 percent of the
site, generally the area of Lagoon 4 and extending in a thin
strip along the southern boundary parallel to the Seaboard
Railroad. It is described as a silt loam with 0 to 2 percent
slopes. This soil is generally formed on the low areas of first
bottoms along streams and is somewhat-poorly drained. The Falaya
soil is excessively wet during the winter and spring with most
areas frequently flooded after periods of heavy rainfall;
groundwater is often at a depth of 1 to 2 feet. The soil has a
high available water capacity and is strongly acidic.
Collins Association. The Collins soil is primarily loamy silt
with 0 to 2 percent slopes. It forms on the floodplain of
streams and is moderately well drained. This soil is generally
found along the northwestern boundary adjacent to Central Creek
and extends to Lagoons 2 and 3. The Collins soil is frequently
flooded for a brief duration, mainly in winter and spring. The
soil has a high available water capacity and is very strongly
acidic.
3.3 Land Use
The land use in the general area of the ACW site includes
industrial, residential, commercial, pastures, and forest lands.
Based on the data compiled from the aerial photographs of the
surrounding area of the site, over one-half of the land within a
one-quarter mile radius of the site is used for commercial and
industrial purposes. The remaining portion of the one-quarter
mile radius is mostly forest land, or cultivated, cropland and
pasture. The only residential area within the quarter mile
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
radius is contiguous with the northwestern boundary of the site.
3.4 Climatology
The ACW site is within a mid-continent temperate region
characterized by moderately cold winters and warm, humid summers.
The predominant southerly winds bring warm, moist air, and the
occasional winds from the northwest bring dry air. The most
common severe weather conditions are in the form of mild droughts
or thunderstorms. Damaging hail and tornadoes associated with
thunderstorms can occur. Local flooding from high intensity,
isolated storms is generally the most severe problem in small
watersheds.
The Jackson weather station is the nearest facility to the ACW
site for which long-term climatological data are available. The
station is approximately two miles northeast of the site. The
coldest days occur in January when the monthly average
temperature is 34°F (1°C). During May through September, an
average of 25 days will have a maximum temperature of 90°F (30°C)
or greater. Precipitation is mostly in the form of rain and
averages 50 inches annually. The amount of precipitation, in
general, is evenly distributed throughout the year.
4.0 SCOPE AND ROLE OF OPERABLE UNITS
As a result of various studies on the site, particularly the 1988
RI/FS, USEPA concluded that it was prudent to commence mitigating
certain site hazards while addressing the issues of data gaps
regarding groundwater and soil contamination. Therefore, the
cleanup of the site was proposed to be organized into three
operable units. Operable Unit 1 Remedial Action (RA) consisted
of surface clean-up activities and site stabilization. It was
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RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
implemented to eliminate visible hazardous conditions at the
site, protect the River,, and control access to the site. The OU1
ROD was signed in 1988, and the RA was completed in 1990. OU2
was planned to address additional investigations and protection
of groundwater, while soil contamination issues and other site
clean-up needs were deferred to OU3.
The current decision document is the second ROD on the site, and
it addresses the cleanup of the surface soils, the surface
waters, sediments and the aquifers affected by the site. The
selected clean-up measures are planned to maintain the site as a
safe property for industrial use by treating the contaminated
soils, sludge, sediments, free creosote, emulsion, debris and
impounded water at the site. In addition, a Monitoring Plan,
which will include the treated soil area, Central Creek, South
Fork Forked Deer River, the Alluvial and Fort Pillow aquifers,
will be designed and implemented as part of the remedial action.
When completed, the selected remedy will be protective of the
surface soils, the surface waters, and the groundwater impacted
by the site.
This Operable Unit may be implemented in phases if government
budgetary constraints so dictate. Funding of the remedy must be
provided by the Federal and the State governments because there
are no viable responsible parties. The remedy is readily applied
in phases without reduction in effectiveness. Implementing the
phased approach will allow the highest human health or
environmental risk at the site to be addressed first with
available funds, using proven technologies and a permanent
remedy.
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AMERICAN CREOSOTE
JACKSON, TENNESSEE
5.0 SITE STUDIES
5.1 PREVIOUS INVESTIGATIONS
5.1.1 Site Assessment. 1981
Evaluation of the site for necessary actions began in November
1981, when various monitoring and sampling activities were
initiated by the Tennessee Department of Environment and
Conservation. Results of these activities revealed that high
concentrations of creosote and PCP were present in shallow
groundwater, soils, sludge, and wastewater stored at the site.
5.1.2 Field Investigation. 1983
EPA's Environmental Services Division (BSD) conducted various
sampling activities at ACW in 1982 to determine the extent of
contamination at the site. PCP was detected in all surface water
samples collected with the highest concentration being 640
micrograms per liter (j*g/L) . Sediment samples from ponds at the
site were contaminated with organic compounds associated with the
wood preserving process. Most of the compounds were polyaromatic
hydrocarbons (PAHs). The group of sediment samples with the
highest concentrations recorded between 40,000 to 2,800,000
micrograms per kilogram (/*g/kg) . PCP was detected at
concentrations of 500,000 and 17,000 M9/k9 for sediment samples
collected from two on-site lagoons. Two soil samples were
collected in the processing area. These samples indicated PAHs
at concentrations of 10,400,000 and 61,700,000 /*g/kg, and PCP was
detected at concentrations of 2,000,000 to 5,000,000
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AMERICAN CREOSOTE
JACKSON, TENNESSEE
5.1.3 Site Analysis, i<»fl4
The USEPA Environmental Photographic Interpretation Center
obtained historical photographs representing the period from 1950
to 1979. Color missions were flown on June 1, June 22, and
August 4, 1983. A land use analysis was performed on these
series of photographs. Throughout the study period, portions of
the main processing and wood storage areas appeared to have had a
very dark-toned coloration, indicating possible ground staining
and/or the deposition of dark-toned materials.
5.1.4
USEPA conducted a major study of the problems at the site using
the services of the US Army Corps of Engineers as the primary
contractor. The aim of the study was to determine the extent and
severity of contamination at the site, evaluate the physical
setting and hazardous materials migrational pathways, and to
assess the potential public health and environmental impacts.
Details of this study are in the "Final Remedial Investigation
Report", July 1988, by S&ME, Inc. Environmental Services. The
findings are summarized as follows:
1. Three contaminant source areas were identified
including (i) plant process facility (treatment building,
pressure cylinders, boiler room tanks, oil storage tanks,
tank cars, vacuum pond, sand filters, pits), (ii) sub-
surface free product (creosote, PCP and emulsion), (iii)
site soils, surface water and sediments.
2. Approximately 90 percent of the soil at the site was
found to be contaminated. However, the vertical extent of
contamination appeared to be less than 5 feet for most
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AMERICAN CREOSOTE
JACKSON, TENNESSEE
of the site.
3. Creosote and PCP were detected in groundwater samples
from the monitoring wells installed at the site indicating
on-site groundwater contamination.
4. The compounds of major health and environmental concern
were volatile organic compounds (VOCs), polynuclear
aromatic hydrocarbons (PAHs), pentachlorophenol {PCP),
dioxins and furans.
5. Contaminants could migrate offsite through groundwater,
movement, site flooding, surface water overflow, and
discharge of contaminated sediments from the site.
6. Neither the groundwater nor the surface water was
identified as being used for potable water within one mile
of the site. Two well fields, located east and north of
the site, supply the local drinking water.
7. Direct contact with waste sources, and contact with
contaminated surface water and/or sediments, were
determined to be the most probable human and environmental
exposure routes.
5.1.5 Feasibility Study. 1988
This study was conducted by USAGE for USEPA to develop and
evaluate methods of addressing the contamination problems
identified during the Remedial Investigation discussed above.
The study included an evaluation of potential cancer and non-
cancer risk associated with the chemicals of concern at the site.
It concluded that the site posed an unacceptable level of human
15
-------
5 9 0023
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
health and environmental risk which required remediation.
Although the study evaluated several cleanup technologies for the
site, it did not recommend choosing a permanent remedy at that
time, due to the data gaps which it identified. These gaps
included the extent of groundwater contamination outside the site
boundary and the maximum depth of soil contamination. In
addition, the study stated that pilot studies of the treatment
technologies evaluated for the site were needed before a
permanent remedy could be chosen. Due to the need for additional
data gathering and evaluation, remedial work at the site was
planned to be conducted under three operable units. Therefore,
the 1988 Feasibility Study formed the basis for the OU1 ROD, and
established the reasons for the new studies which are summarized
below.
5.2 RESULTS OF ADDITIONAL INVESTIGATIONS
5.2.1 Ggo^Tidwater Studies
Under contract with USEPA, the United States Geological Survey
(USGS) conducted a comprehensive groundwater study at the site
between 1990 and 1993. The study evaluated the extent of off-
site groundwater contamination and the potential for
contamination of local water-supply wells. In addition, on- site
groundwater quality was assessed. Water samples were taken from
the two aquifers in the area, the alluvial aquifer at the depth
of about 40 feet and the Fort Pillow aquifer which is as deep as
150 feet. Details of this study are in the USGS Investigations
Report No. 93-4170, entitled "Hydrogeology, Ground-Water Quality,
and Potential for Water- Supply Contamination near an Abandoned
Wood -Preserving Plant Site at Jackson, Tennessee". The
conclusions of the study are summarized as follows :
16
-------
5 9 0024
RECORD OP DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
1. Contaminants from the wood preserving facility were detected
in on-site samples taken from the Alluvial and Fort Pillow
aquifers. Concentrations of organic compounds, particularly
naphthalene, PCP, and benzene exceeded drinking water standards
in many samples from the Alluvial aquifer. Few organic compounds
were detected in water samples from the Fort Pillow aquifer.
2. Concentrations of organic compounds were low in water samples
from off-site wells.
3. Wells sampled to assess the potential for pollution of water-
supply sources by the site did not reveal site-related
contaminants.
5.2.2 gnvt-rrmmoTit-ai impact Assessment
In 1990, the USGS conducted environmental sampling and analyses
in and around the site. Results of the study are as follows:
l. Surface waters and sediments near the site contained
detectable levels of creosote and PCP compounds apparently
transported from the site, primarily by surface runoff. Central
Creek which bounds the site to the north and west reflected the
most pronounced contamination impact. Naphthalene (creosote
constituent) and PCP were detected at concentrations above
maximum acceptable levels for fish and aquatic life.
2. In laboratory tests, sediments from Central Creek reflected
significant toxic effects on some aquatic organisms.
Similarly, sediment samples from South Fork Forked Deer River
adversely affected aquatic communities.
17
-------
5 9 0025
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
3. Species composition and diversity of phyton, benthos, and
fish at the Central Creek indicated pollution by the site.
4. Fish tissue samples from Central Creek contained organic
compounds indicative of creosote contamination.
5. Analyses of the soil and sediment samples from the site
indicated the presence of toxic substances.
A detailed description of the samples and results of the
laboratory analyses can be found in the USGS report of 1993,
"Water Quality, Organic Chemistry of Sediment, and Biological
Conditions of Streams Near an Abandoned Wood Preserving Plant
Site at Jackson, Tennessee".
5.2.3 Focused Remedial Investigation
In 1993, after evaluating the results of the USGS studies and
reviewing the reports of previous investigations, USEPA and TDEC
engaged in several discussions to consider issues related to the
site. The purpose of the discussions was to determine an optimum
strategy for effectively remediating the site in view of the new
data. The main issues discussed included the current and future
use of the property, and availability of clean-up funds. As a
result of the discussions, the following conclusions were
reached:
1. Sources of drinking water in the area do not appear to be
threatened significantly by contaminants at the site.
Nevertheless, contaminated soils, sediment, and surface water
18
-------
5 9 0026
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
remain on the site. In addition, liquid waste remains
underground as sources of multi-media contamination. Therefore,
a plan to mitigate the threat posed by the site to human health
and the environment was needed.
2. The property is in an industrial area. No new residential
developments have been observed near the site. The current
zoning for the site, according to the Jackson City Planning
Commission, is "General Industrial" which prohibits all
residential, school, and church uses. Therefore, its future use,
which would most likely remain industrial, must be considered in
establishing the clean-up standards for the site.
3. There is no viable Potentially Responsible Party for the
site. The cost of cleanup must be paid, in accordance with the
Superfund Law, by the State and USEPA on the basis of 10 and 90
percent share respectively. The clean-up plan developed for the
site must be implementable in phases to allow for State and
Federal budgetary constraints.
Based on these conclusions, it was decided that the clean-up
objective for the site would be: to ensure that persons who enter
the property are protected from potential health risks related to
the site. Therefore, a new study, which focused on the surface
soil, surface water, and sediments was conducted to delineate the
current extent of contamination and to collect data for
evaluating associated human health risk. Details of the study
are reported in the "U.S. EPA Region IV Remedial Investigation,
American Creosote Works, Jackson, Madison County, Tennessee,
November, 1993". The study is summarized as follows.
19
-------
5 9 0027
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
Soil samples taken from approximately 135 locations at the site
were analyzed in the laboratory to determine the current nature
and concentrations of site contaminants. Results of the analyses
indicated a widespread presence of creosote and PCP compounds at
varying concentrations. Four specific locations of the site were
identified as exhibiting unacceptable levels of creosote
constituents, PCP, and dioxin. The locations include: (1) the
former process area, (2) areas along the railroad tracks near the
eastern half of the site, (3) areas between the on-site lagoons,
and (4) areas along the southeastern boundary of the site. These
locations represent the "hot spots" which, potentialy, pose the
most significant human health and environmental risk at the site.
Three surface water samples were taken from the lagoons at the
site. Analyses of the samples indicated the presence of PCP and
several metals.
Four sediment samples from the lagoons were analyzed. Dioxin was
the only contaminant of concern detected at an elevated average
concentration of 0.0075 ppm. The lagoons and the contamination
are included in the remediation plan for the site.
6.0 SUMMARY OF SITE RISKS
A comprehensive study of the data collected during the November
1993 RI was conducted by Roy F. Weston, Inc. for USEPA to assess
potential human health risk associated with the contaminants at
ACW. In line with the current remedial objectives, the Focused
Risk Assessment (FRA) addressed contaminated soils which
constitute the primary source of human health threat based on the
analyses of sampling data and exposure pathways. The FRA which
20
-------
5 9 0028
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
was conducted according to USEPA protocol and guidelines included
the following:
. 1. Identification of chemicals of potential concern
2. Exposure assessment
3. Toxicity assessment and
4 Risk characterization.
Details of the study can be found in the "Focused Risk
Assessment- American Creosote Works, Jackson, Tennessee" which
was finalized in April 1996. The following is a summary of the
study.
6.1 Chyicals of Potential Concern
The Chemicals of Potential Concern associated with contaminated
soil at the ACW Site are listed in Table 1. These are the
compounds identified by the FRA as likely to pose human health
risks. They were identified by using USEPA methods to screen the
chemicals detected in the samples from the site.
6.2 Exposure Assessment
The purpose of Exposure Assessment is to quantify the likelihood
for human exposure to the Chemicals of Potential Concern at the
Site. The likelihood of exposure to a Chemical of Potential
Concern is expressed as Chronic Daily Intake (GDI) , and is
estimated based on the route of exposure, concentration,
frequency, and duration of exposure to the chemical. As
discussed previously, the primary carrier of the contaminants at
21
-------
5 9 "0029
Table \
American Creosote Works Site
Chemicals of Potential Concern
Surface Soil Range of
Concentrations
mg/kg
!JiN&fcc&me^ ,; ^ ^,/'^R!Hr
Aluminum
Arsenic
Barium
Beryllium
Chromium (Total)
Cobalt
"
Copper
Lead /
Manganese
Mercury
Nickel
Selenium
Vanadium
6,800-19,000
4.5
103-210
0.474).97
16.5-54.0
5.0-8.7
11.5-63.0
29.5-43.0
430-880
0.14-0.38
9.3 - 16.0
2.8
26.0-36.0
!,-«8^OMSflPOB»-^?;--|* , ', «v, ^Hx ,$$&&& f&
4,4'-DDT
2,3,7,8 - TCDD (TEQ)
Endosulfan n (beta)
Endrin Ketoae
0.024 - 0.03
0.0002 - 0.018
0.076
0.008 - 0.24
22
-------
Table I (Continued)
American Creosote Works Site
Contaminants of Potential Concern
5-9 -QU30
Surface Soil Range of
Concentrations
mg/kg
$^&Q&&8&QX$mc$ . r,:j^;^^;
Aceoaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
':Benzo(b and/or k)fluoranthene
Benzo(ghi)perylene
Carbazole '"'
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
3-Nitroaoaline
Pentachlorophenol
Phenanthiene
Pyrene
0.063-35
0.087 - 210
0.82 - 71.0
1.2 - 99.0
1.6-97.0
1.3 - 120
0.051-59.0
1.2 - 73.0
0.13-1.1
0.039 - 19.0
0.29 - 200
0.14-45.0
0.19-93.0
19.0
0.11- 120
0.11-68.0
0.35 - 150
,?<»piiis><'< '',''-': - ' ', - '-'' "%'^t/
Benzene
Trichloroethene
0.002
0.003 - 0.014
23
-------
5 9 0031
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
the site is the surface soil. In addition, the FRA indicates
that dust emanating from the contaminated soil potentially could
transport certain Chemicals of Potential Concern. Therefore,
possible pathways of exposure to ACW contaminants include
incidental soil ingestion, dermal contact, and inhalation of dust
by trespassers and workers at the site. For these conditions,
CDi was calculated for each Chemical of Potential Concern at the
site. Results of the calculations are shown in Table 2. Details
of the procedure, equations, and other assumptions for the
calculations are in the FRA report and in Tables 3 through 7.
6.3 Toxicity Assessment
Toxicity Assessment is the process by which possible harmful
effects of the Chemicals of Potential concern are evaluated. The
process provides an estimate of the relationship between the
extent of exposure to a contaminant and the occurrence of adverse
effects.
Several of the chemicals found at the ACW site for example
benzene, PCP, and dioxin, have the potential to cause cancer
(carcinogenic). Other Chemicals of Potential concern, such as
dibenzofuran, may cause human health problems which are not
related to cancer. Toxicity values, which numerically express
the dose-response relationships for chemicals, are derived
differently for carcinogens and noncarcinogens. These values are
referred to as Cancer Slope Factors for carcinogens and Chronic
Reference Doses for noncarcinogens. The Cancer Slope Factors and
Chronic Reference Doses in Tables 8 and 9 respectively are the
results of the Toxicity Assessment for the chemicals of potential
concern found at the site. The FRA report details the procedure.
24
-------
. ~ 2
Surface Soil Ingosllon. Inhalation, and Dermal Contact
Estimated Dally Intakes lor Current Trespassers and Future Workers
Based on the Exposure Point Concentrations
nerlcan Creosote Works
irface Soil
>ntamlnanls of
ilentlal Concern
mlnum
;enlc
rlum
rylllym
bait
iromlum
ipper
ad
inganeso
ircury
*el
lenlum
tadlum '
tnaphlhene
:hraoane
izene
izo(a)anthracene
ruo(a)pyrone
nzo(b)fluoranthene
nzo(k)fluoranthene
nzo(GHI)parylene
rbazole
rysene
nzo(a,h)anlhracene
oranlhend
crone
jno(1.2,3-CD)pyrene
^Itroanillne
itachlorophenol
inanthrene
ana
ihloroothene
-nor
enzofuran
xlns (TEQ)
losullan II (beta)
'rln Kalona
Ingestlon
Chronic
Dally Intake
Trespasser
Youth 7- 16
(mg/kg-day)
5.7E-03
1.4E-06
B.3E-OS
2.9E-07
2.6E-06
1.6E-05
1.9E-05
1.3E-05
2.6E-04
1.1E-07
4.8E-06
B.4E-07
1. IE-OS
4.5E-06
3.3E-06
6.0E-10
1.0E-06
8.7E-08
9.6E-07
9.6E-07
LIE-OS
1.6E-06
1.1E-07
3.3E-07
3.2E-05
3.4E-08
1.1E-06
5.7E-06
3.6E-05
7.1E-06
2.9E-05
4.2E-09
9.0E-09
1.1E-06
5.4E-09
2.3E-08
6.3E-08
Dermal
Contact
Chronic
)ally Intake
Trespasser
Voulh7-16
mg/kg day)
1.3E-04
3.1E-08
1.4E-06
8.7E-09
6.0E-08
3.7E-07
4.3E-07
3.0E-07
6.1E-06
2.6E-09
1.1E-07
1.9E-08
2.5E-07
1.0E-06
7.5E-07
1.4E-10
2.3E-07
2.0E-08
2.2E-07
2.2E-07
2.SE-08
3.6E-07
2.4E-08
7.6E-08
7.3E-06
7.7E-07
2.6E-07
1.3E-06
8.3E-06
1.6E-OS
8.7E-06
9.7E-10
2.1E-09
2.6E-07
1.2E-09
5.2E-09
1.4E-08
nhalatlon
Chronic
Dally Intake
Trespasser
Youth 7- 18
mj/kg-doy)
2.9E-04
8.6E-08
3.2E-08
1.5E-08
1.3E-07
8.2E-07
9.6E-07
6.5E-07
1.3E-05
5.8E-09
2.4E-07
4.3E-08
5.5E-07
2.3E-07
1.7E-07
3.0E-11
5.1 E-08
4.4E-07
4.9E-08
4.9E-08
5.4E-07
8.0E-08
5.4E-09
1.7E-08
1.6E-06
1.7E-07
5.7E-OB
2.9E-07
' 1.8E-08
3.6E-07
1.5E-06
2.1E-10
4.6E-10
5.7E-OB
2.7E-10
1.2E-09
3.2E-09
Ingestlon
Chronic
Dally Intake
Worker'
Adult
mg/kg-day)
7.6E-03
1.8E-06
8.4E-OS
3.9E-07
3.5E-06
2.2E-05
2.5E-05
1.7E-05
3.5E-04
1.5E-07
6.4E-06
1.1E-06
1.4E-05
5.9E-06
4.4E-06
8.0E-10
1.4E-06
1.2E-05
1.3E-08
1.3E-06
1.4E-05
2.1 E-08
1.4E-07
4.4E-07
42E-05
4.5E-08
1.5E-08
7.6E-06
4.8E-05
9.5E-08
3.9E-05
5.6E-09
1.2E-08
1.5E-06
7.2E-09
3.0E-08
8.4E-08
Dermal
Contact
Chronic
Dally Intake
Worker
Adult
mg/kg-dsy)
5.6E-04
1.3E-07
63E-06
2.8E-08
2.5E-07
1.6E-06
1.8E-06
1.3E-06
2.6E-OS
.1.1 E-08
4.7E-07
8.2E-08
' 1.1E-06
4.4E-06
3.2E-06
5.9E-10
9.9E-07
8.SE-06
9.4E-07
9.4E-07
1.1E-05
1.SE-06
1.0E-07
3.2E-07
3.1E-05
3.3E-06
1.1E-06
5.6E-06
3.5E-05
7.0E-06
2.8E-05
4.1E-09
8.8E-09
1.1E-06
5.3E-09
2.2E-08
6.2E-08
nhalatlon
Chronic
Dally Intake
Worker
Adult
mg/kg-day)
8.9E-04
2.1E-07
9.9E-08
4.6E-08
4.1E-07
2.5E-06
3.0E-06
2.0E-06
4. IE-OS
1.6E-08
7'.5E-07
1.3E-07
1.7E-08
7.0E-07
5.1E-07
9.4E-11
1.6E-07
1.4E-06
1.5E-07
1.5E-OF.
1.7E-08
2.SE-07
1.7E-OB
5.2E-08
5.0E-06
5.3E-07
1.8E-07
/.8.9E-07
5.6E-06
1. IE-OS
4.6E-08
6.6E-10
1.4E-09
1.8E-07
8.5E-10
3.6E-09
9.9E-09
ngestlon
Lifetime
Dally Intake
'respasser
Youth 7- 18
mg/kg-day)
8.6E-04
2.0E-07
9.5E-06
4.4E-08
3.9E-07
2.4E-06
2.8E-06
1.9E-06
4.0E-05
1.7E-08
7.2E-07
1.3E-07
1.6E-06
6.7E-07
4.9E-07
9.0E-11
1.5E-07
1.3E-06
1.4E-07
1.4E-07
1.8E-08
2.4E-07
1.6E-08
5.0E-08
4.8E-06
5.1E-07
1.7E-07
8.6E-07
5.4E-06
1.1E-06
4.4E-06
6.3E-10
1.4E-09
1.7E-07
8.1E-10
3.4E-09
9.5E-09
Dermal
Contact
Lifetime
Dally Intake
Trespasser
oulh7-16
mg/kg-day)
1.7E-05
4.1E-09
1.9E-07
8.7E-10
7.8E-09
4.9E-08
S.7E-08
3.9E-08
7.9E-07
3.4E-10
1.4E-08
2.5E-09
3.2E-08
1.3E-07
9.8E-08
1.8E-11
3.0E-08
2.6E-07
2.9E-08
2.9E-08
3.2E-07
4.7E-08
3.2E-09
9.9E-09
9.6E-07
1.0E-07
3.4E-08
1.7E-07
1.1E-06
2.1E-07
8.7E-07
1.3E-10
2.7E-10
3.4E-08
1.6E-10
6.8E-10
1.9E-09
nhalatlon
Lifetime
Dally Intake
'respasser
outh7-18
mg/kg-day)
4.1E-05
9.8E-09
4.6E-07
2.1E-09
1.9E-08
1.2E-07
1.4E-07
9.3E-08
1.9E-06
B.2E-10
3.5E-08
6.1E-09
7.8E-08
3.2E-08
2.4E-08
4.3E-12
7.4E-09
6.3E-08
7.0E-09
7.0E-09
7.8E-08
1.1E-08
7.7E-10
2.4E-09
2.3E-07
2.4E-08
8.2E-09
4.1E-08
2.6E-07
5.2E-08
2.1E-07
3.0E-1
6.5E-1
8.2E-09
3.9E-1
1.6E-1
4.6E-1
ngestlon
Lifetime
ally Intake
Worker
Adult
mg/kg-day)
1.9E-03
4.5E-07
2.1E-05
9.7E-08
B.7E-07
5.4E-08
6.3E-06
4.3E-06
B.8E-05
3.8E-08
1.6E-06
2.8E-07
3.6E-06
1.5E-06
1.1E-06
2.0E-10
3.4E-07
2.9E-08
32E-07
3.2E-07
3.6E-08
5.3E-07
3.5E-08
1.1E-07
1.1E-05
1.1E-06
3.8E-07
1.9E-06
1.2E-05
2.4E-06
9.7E-08
1.4E-09
3.0E-09
3.8E-0
1.8E-09
7.6E-09
2.1E-0
Dermal
Contact
Lifetime
ally Intake
Worker
Adult
mg/kg-day)
2.0E-04
4.7E-08
2.2E-08
1.0E-08
9.0E-08
5.6E-07
8.BE-07
4.5E-07
9.2E-06
4.0E-09
1.7E-07
2.9E-08
3.7E-07
1.5E-06
1.1E-06
2.1E-10
3.5E-07
3.0E-06
3.3E-07
3.3E-07
3.7E-08
5.SE-07
3.7E-08
1.1E-07
1. IE-OS
1.2E-08
3.9E-07
2.0E-08
1.2E-05
2.5E-06
1.0E-0
1.5E-09
3.1E-09
3.9E-0
1.9E-09
7.9E-09
2.2E-08
Inhalation
Lifetime
Dally Intake
Worker
Adull
[mg/kg-day)
3.2E-04
7.5E-OB
3.SE-06
1.6E-08
1.5E-07
9.1E-07
1.1E-06
7.2C-07
1.5E-05
6.4E-09
2.7E-07
4.7E-08
6.0E-07
2.5E-07
1.8E-07
3.4E-11
5.7E-08
4.9E-07
5.4E-08
5.4 E-08
6.0E-07
8.8E-08
5.9E-09
1.8E-08
1.8E-06
1.9E-07
6.3E-08
3.2E-07
2.0E-06
4.0E-07
1.6E-06
2.3E-10
5.0E-10
6.3E-08
3.0E-10
1.3E-09
3.5E-09
O
C
25
-------
5 9 0033
Table 3
American Creosote Works Site
Exposure Point Concentration of
Contaminants Detected in Soil
Surface Soil Analyte
Site-Related Samples
95% UCL of
Mean
Concentration
(rag/kg)
Maximum
Concentration
(mg/k)
Exposure Point
Concentrations
(mg/kg)
ttfOjRcmcs? -;;v >f ;±'-^ "2 {:" .^v- '*\?/^;^I^J3$?
Aluminum
Arsenic
Barium
Beryllium
Chromium (total)
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
152,645
766
2.96
926
' 15.2
55,501
62.9
2,506
2.6
28.7
45.8
^UT^OROAIItCs' /-:7» -', " ',
Benzene
Trichlotoethene
0.03
'^SETHJiT 'HTl'Ok 9*11 ETC *"^ "*>....' j-
^f^jfflft f^"Tf \irnff ITT. n mn fnm,^ " f ''
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b,k)fluoranthene
19.9
10.9
33.9
29.1
32.04
19,000
4.5
210
0.97
54.0
8.7
63.0
43.0
880
0.38
16.0
2.8
36.0
t /^ .' ffttt >.>>
'.f f vfr ~"^ f ff S f x^"
. '"' ''y'-
0.002
0.014
5 ff i . ~" > ^ * tf*f *. "
35
210
71.0
99.0
97.0
19,000
4.5
210
0.97
54.0
8.7
63.0
' 4310
880
0.38
16.0
2.8
36.0
^ \, ",v*- X. x V,
0.002
0.014
^ISS^:?^
14.9
10.9
33.9
29.1
32.04
26
-------
5 9
003
Table 3 (Continued)
American Creosote Works Site
Exposure Points Concentration of
Contaminants Detected in Soil
Surface Soil Analyte
Benzo(ghi)perylene
Carbazole
Chryseae
Dibenzo(»,ti)anthracene
Dibenzofuran
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
3-Nitroaniline
Pentachloropheaol
Phenanthrene
Pyrene
|^PESTI<^DES*CM;I:-;:
4,4-DDT
2,3,7,8 - TCDD
CTEQ)
Endosulfen n (beta)
Endrin Ketone
Site-Related Samples
95% UCL of
Mean
Concentration
(rag/kg)
35.9
5.25
35.3
1.2
3.8
/' 106
11.2
37.7
-
453
23.8
97.0
Maximum
Concentration
(mg/k)
120
59.0
73.0
1.1
19.0
200
45.0
93.0
19.0
120
68.0
150
*$&/,*$ -'-. , ,/, '-?-&'££&
0.05
0.06
0.21
0.03
0.018
0.076
0.24
Exposure Point
Concentrations
(rag/kg)
35.9
5.25
35.3
1.1
3.8
106
11.2
37.7
19.0
120
23.8
97.0
^"kr!? <,/-,
0.03
0.018
0.076
0.021
27
-------
y Table 4
Upper Confidence Limit
Algorithm
0035
Tb& following formula was used to determine the 95 percent UCL on the arithmetic mean
assuming the data are lognonnally distributed (EPA, 1991b):
UCL =
Where:
e = constant (natural log)
= mean of the log-transformed data for contaminant i.
s = standard deviation of the log-transformed data
s =
\
-2
(*: -x,)
n-1
H = statistic determined by the standard deviation and sample size.
n = sample size for contaminant in the particular media set
28
-------
5 9
0036
Table S
Model for Calculating Doses from
Incidental Ingestion of Soil
Soilli
(ing
Where:
CS
m
CF
EF
ED
BW =
AT
Assumptions
CS
IR
EF =
ED
BW =
AT
igestion Dose CSxIRxCFxEFxED
!/kg-day) BW x AT
Upper 95% confidence limit of the mean concentration or the maximum concentration in
surface soil (mg/kg)
. Ingestion rate (mg/day)
Conversion factor (1E-6 kg/mg)
Exposure frequency (days/year)
Exposure duration (years)
Body weight (kg)
Averaging time (days)
>\
Chemical concentration in soil.
100 mg/day for the current trespasser.
SO mg/day for the future adult worker (EPA, 1991a).
52 days/year for the current trespasser, based on 1 day/week exposure for 52 weeks/year '
(estimated). * ......
250 days/year for the future adult workers (EPA, 1991a).
10 years for the current trespasser (EPA, 1991a).
25 years for the future adult worker (EPA, 1991a).
45 kg for a youth (7-16 yrs. old) scenario (EPA, 1991a).
70 kg for an adult scenario (EPA, 1991a).
Exposure duration (years) x 365 days/year for evaluating noncancer risk
70 years x 365 days/year for evaluating cancer risk
29
-------
5 9 0037
Table 6
Model for Calculating Doses from
Dermal Contact with Soil
Soil Dermal Absorption Dose
(mg/kg-day) .
CS x CP x SA x AF x ABS x EF x ED
BWxAT
Where:
CS
CF
SA
AF
ABS
EF
ED
BW
AT
Upper 95% confidence limit of the mean concentration or the ma-rimnm concentration in
surface soil (mg/kg)
Conversion factor (IE-6 kg/mg)
Skin surface area available for contact (cmVday)
Soil to skin adherence factor (mg/cm*)
Dermal absorption factor (unitless)
Exposure frequency (days/year)
Exposure duration (years)
Body weight (kg)
Averaging time (days)
Assumptions:
CS
AF
Chemical concentration in soil.
SA = 3,200 cmVday for the current youth trespasser. It represents 2556 of the mean total
surface area of a youth 7-16 years old (EPA, 1992a).
= 5,000 cmVday for the future adult worker. It represents 25% of the mean total surface
area of an adult (EPA, 1992a).
0.6 mg/cm2, soil adherence factor (EPA, 1991b).
ABS = 0.01 - Organic compounds (EPA, 199 Ib)
= 0.001 - Inorganic compounds (EPA, 1991b).
EF = 52 days/year for the youth trespasser (estimated).
= 250 days/year for the future adult worker (EPA, 1991a).
ED = 10 years for a youth trespasser scenario (EPA, 1991a).
= 25 years for an adult worker (EPA, 1991a).
BW
45 kg for a youth trespasser scenario (EPA, 1991a).
70 kg for an adult worker scenario (EPA, 1991a).
AT
Exposure duration (years) x 365 days/year for evaluating noncancer risk.
70 years x 365 days/year for evaluating cancer risk.
30
-------
5 9
0038
Table 7
Model for Calculating Doses from
Inhalation of Soil Particulate Matter
Soil Inhalation Dose CS x PM,« x IR x CF x EF x ED
(mg/kg-day) BW x AT
Where:
CS = Upper 95% confidence limit of the mean concentration or the maximum concentration in
surface soil (mg/kg)
PM10 = Small participate matter concentration in air (/tg/mj)
IR = Inhalation rate (mVday)
CF = Conversion factor (10* kg//tg)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
BW = Body weight (kg)
AT = Averaging time (days)
Assumptions:
CS
PM10 =
m
EF
ED
=
BW =
=
AT
f
Chemical concentration in soil.
Area specific 24 fig/a? (TDEC, 1995).
20 mVday for the adult worker and trespasser (EPA, 199 la).
52 days/year for the youth trespasser based on 1 day/week exposure for 52 weeks/year
(estimated).
250 days/year for the future on-site adult workers (EPA, 1991a).
10 years for the youth trespasser (EPA, 1991a).
25 years for the future on-site adult worker (EPA, 1991a).
45 kg for the youth trespasser (EPA, 1991a).
70 kg for the future on-site adult worker (EPA, 199 la).
Exposure duration (years) x 365 days/year for evaluating noncancer risk.
70 years x 365 days/year for evaluating cancer risk.
macroinvertebrates and small fish. Adequate feeding habitat for endangered species of bats and the bald eagle
were determined to be absent within Brushy Fork Creek and the tributaries which are affected by the site.
The site is not located in a 100-year floodplain. According to the U.S. Fish and Wildlife Service
(FWS), the Brushy Fork Creek is not a habitat for endangered species and the site is not on a wetland, nor does
it affect a wetland.
31
-------
5 9
0039
Table 8
Cancer Slope Factors (CSFs)
(mg/kg-day)'1
Chemical
Oral
Reference
Inhalation
Reference
Dermal1
ORGANICS
Benzene
Benzo(a)anthracene
Beazo(a)pyrene
Benzo(b)fluoranthene
BenzD(k)fluoiaatheae
Carbazole
Chrysene
4,4-DDT
Dibenzo(a,h)anthraapne
2,3,7,8 - TCDD
Indeno(l ,2,3-cd)pyrene
Methylene chloride
Pehtachlorophenol
Trichloroethene
2.9E-2
7.3E-1
7.3
7.3E-1
7.3E-2
2E-2
7.3E-3
3.4E-1
7.3
1.5E+5
7.3E-1 j
7.5E-3
. 1.2E-1
1.1E-2
EPA, 1995
ECAO
ECAO
ECAO
ECAO
HEAST. 1994
ECAO
EPA, 1995
ECAO
HEAST, 1994
ECAO
EPA, 1995
EPA, 1995
ECAO
2.9E-22
NTV
NTV
NTV
NTV
NTV
NTV
3.4E-12
NTV
1.2E-12
NTV
1.6E-32
NTV
6E-32
EPA, 1995
EPA, 1995
-
EPA, 1995
EPA, 1995
3.6E-2
1.46
14.6
1.46
0.146
4E-2
0.0146
6.8E-1
14.6
3E+5
1.46
9.38E-3
2.4E-1
1.4E-2
INORGANICS
Arsenic
Beryllium
Chromium (VI)
Lead
Nickel
1.5
4.3
MTV
NTV
NTV
EPA, 1995
EPA, 1995
1.5E+12
8.4 2
4.1E+12
NTV
8.4E-12
HEAST, 1994
EPA, 1995
HEAST, 1994
EPA, 1995
8.75
2.15E+1
NTV
NTV
NTV
1 The dermal CSF was derived by dividing the oral CSF by the appropriate absorption factor: 0.8 - volatile
organics, 0.5 - semi-volatile organics, and 0.2 - inorganics (Personal Communications, 1993b)
2 Derived from a unit risk by dividing by 20 n?/day, and multiplying by a body weight of 70 kg and a conversion
factor of 1,000 (EPA, 1992a).
NTV = No toxicity data were available.
NC = Not of concern for this route of exposure.
32
-------
5 9 - 0040
Table 9
Chronic Reference Doses (Rfl>)
(mg/kg-day)
Chemical
Oral RfD
Reference
Inhalation
RfD
Reference
Dermal1
RfD
ORGANICS
Acenaphthene
Anthracene
Benzene
Benzofatanthracene
*A /
Benzo(a)pyrene
Benzo(b and/or k)fluoranthene
Benzo(ghi)perylene
V
Carbazole
Chrysene
4.4--DDT
Dibenzo(a,h)anthracene
Dibenzofuran
2,3,7,«-TCDD (TEQ)
Endosulfan n
Bndrin kctone
Fluoranthene
Fluorene
Indeno(l,2,3-CD)pyrene
3-Nitroanaline
Pentachlorophenol
Phenanthrene
Pyrene
Trichloroethene
3E-1
NTV
NTV
NTV
NTV
NTV
NTV
NTV t
SE-4
NTV
NTV
NTV
NTV
NTV
4E-2
4E-2
NTV
NTV
3E-2
3E-2
3E-2
6E-3
EPA, 1995
-
-
EPA, 1995
-
-
-
-
EPA, 1995
EPA, 1995
-
-
EPA, 1995
-
EPA, 1995
-
NTV
NTV
NTV
NTV .
NTV
NTV
NTV
NTV
' NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
6E-3
-
EPA, 1995
1.5E-1
NTV
NTV
NTV
NTV
NTV
NTV
NTV
2.5E-4
NTV
NTV
NTV
NTV
NTV
2E-2
2E-2
NTV
NTV
1.5E-2
1.5E-2
1.5E-2
4/8E-3
INORGANICS
33
-------
x0041
Table 9 (Continued)
Chronic Reference Doses (RfD)
(mg/kg-day)
Chemical '
Aluminum
Arsenic
Barium
Beryllium
Chromium
Cobalt
Copper
Lead *^
Manganese
Mercury
Nickel
Selenium
Vanadium
Oral RfD
NTV
3E-4
7E-2
5E-3
5E-3
NTV
3.7E-2
NTV
1.4E-1 (food)
5E-3 (water)
3E-4
2E-2
7E-3
Reference
EPA, 1995
EPA, 1995
EPA, 1995
EPA, 1995
EPA, 1992
EPA, 1995
HEAST, 1994
EPA, 1995
HEAST, 1994
Inhalation
RfD
NTV
NTV
NTV
NTV
NTV
NTV
NTV
NTV
1.4E-5
8.75E-5
NTV
NTV
Reference
-
-
HEAST, 1994
Dermal1
RfD
NTV
6E-5
1.4E-2
1E-3
1E-3
NTV
7.4E-3
NTV
2.8E-2
6E-5
4E-3
1.4E-3
1 The dermal RfD was derived by multiplying the oral RfD by the appropriate absorption factor 0.8 - volatile organics, 0.5 semi-
volatile organics, and 0.2 - inorganics (Personal Communication, EPA, 1993b).
1 Calculated from the drinking water MCL assuming the consumption of two liters of water per day and a body weight of 70 kg
(EPA, 1989).
NTV = No toxicity data were available.
NC = Not of concern through this route of exposure.
34
-------
5 9 0042
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
6.4 Risk Characterization
Risk characterization combines the results of toxicity and
exposure assessments to yield numerical expressions of probable
site related health effects. The process estimates individual and
overall risk of health hazard from site contaminants using
different methodologies for carcinogens and noncarcinogens. The
output of the process is a major factor in deciding if a site
requires cleanup.
Carcinogenic risks are expressed as probabilities of occurrence
of cancer due to exposure to a certain level of contaminant over
a period of time. USEPA generally considers a cancer risk
acceptable if the probability of its occurrence is not more than
1 in 10,000 (1E-4). In other words, a site may not require a
remedial action if no more than 1 person out of 10,000 people
would develop cancer due to exposure to the chemicals at the
site, provided no other conditions necessitate a clean-up action.
Carcinogenic risks were evaluated for the Chemicals of Potential
concern at the site using methodologies approved by USEPA. Total
cancer risks were 2 in 10,000 for the current youth trespasser
and 9 in 10,000 for the future adult worker. These results
indicate levels of cancer risk which are unacceptable to USEPA.
See Table 10 for detailed results.
Toxic effects from contaminants which do not cause cancer are
expressed numerically by the ratios of specific exposure levels
to the reference doses for the Chemicals of Potential Concern.
The ratio representing potential concern for the effects of a
single noncarcinogen in a single medium (e.g., soil) is termed
35
-------
TABLE 10
Surface Soil It jn. Inhalation, and Dermal Contact
Cancer Risk for Current Trespasser and Future Worker
Based on the Exposure Point Concentrations
American Creosote Works
Surface Soil
Contaminants of
Potential Concern
Aluminum
Arsenic
Barium
Beryllum
Cobalt
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
Acenaphthene
Anthracene
Benzene
Bena>(a)anthracene
Bens>(a)pyrene
Bena>(b)fluoranthene
Bens>(k)fluoranthene
Bens>(GHI)perylene
Carbazole
Chryaene
Dlben»(a,h)anthracene
Ftuoranthsne
Ruorene
lndeno(1 ,2.3-CD)pyrene
3-Nltroanlllne
Pentachlorophenol
Phenanthrene
Pyrene
Trfchloroethene
4.4-ODT
Olbenzofuran
Oloxlns (TEQ)
Endosullan II (beta)
Endrln Ketone
j Total
Ingestkm
Ufetlme Risk
Trespasser
Youth 7-16
NOSF
3E-07
NOSF
2E-07
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
3E-12
tE-07
IE-OS
1E-07
IE-OS
NOSF
3E-09
1E-10
4E-07
NOSF
NOSF
1E-07
NOSF
7E-07
NOSF
NOSF
7E-12
SE-10
NOSF
1E-04
NOSF
NOSF
1E-04
Dermal
Contact
Ufetlme Risk
Trespasser
Youth 7- 16
NOSF
3E-08
NOSF
2E-08
NOSF
NOSF
NOSF
MOSF
MOSF
NOSF
MOSF
MOSF
MOSF
NOSF
MOSF
7E-13
4E-08
4E-06
4E-08
4E-09
NOSF
2E-09
5E-11
1E-07
MOSF
MOSF
5E-08
MOSF
3E-07
MOSF
MOSF
2E-12
2E-10
NOSF
5E-05
NOSF
NOSF
SE-OS
Inhalation
Ufetlme Risk
Trespasser
Youth 7-16
NOSF
1E-07
NOSF
2E-08
NOSF
5E-06
NOSF
NOSF
NOSF
NOSF
3E-08
MOSF -
MOSF
MOSF
MOSF
1E-13
MOSF
MOSF
NOSF
NOSF
NOSF
NOSF
NOSF
MOSF
NOSF
MOSF
NOSF
MOSF
MOSF
NOSF
MOSF
2E-13
2E-11
MOSF
5E-12
NOSF
MOSF
5E-06
Ingestlon
Ufetlme Risk
Worker
Adult
MOSF
7E-07
NOSF
4E-07
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
MOSF
6E-12
2E-07
2E-05
2E-07
2E-08
MOSF
IE-OS
3E-10
8E-07
MOSF
MOSF
3E-07
MOSF
IE-OS
MOSF
MOSF
2E-11
IE -09
NOSF
3E-04
MOSF
MOSF
3E-04
Dermal
Contact
Ufetlme Risk
Worker
Adult
NOSF
4E-07
NOSF
2E-07
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
NOSF
MO SF
MOSF
MOSF
MOSF
8E-12
5E-07
4E-05
5E-07
5E-08
MOSF
2E-08
5E-10
2E-06
MOSF
MOSF
6E-07
NOSF
3E-06
MOSF
MOSF
2E-11
2E-09
MOSF
6E-04
MOSF
MOSF
6E-04
Inhalation
Ufetlme Risk
Worker
Adult
NOSF
1E-06
NOSF
1E-07
NOSF
4E-05
NOSF
NOSF
NOSF
NOSF
2E-07
MOSF
MOSF
MOSF
NOSF
1E-12
NOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
MOSF
1E-12
2E-10
MOSF
4E-11
MOSF
MOSF
4E-05
Total
Ufetlme Risk
for
Trespasser
Youth 7- 16
NA
5E-07
NA
2E-07
NA
NA
NA
NA
NA
NA
NA
MA
MA
MA
MA
3E-12
2E-07
1E-05
1E-07
IE-OS
MA
7E-09
2E-10
5E-07
MA
MA
2E-07
MA
9E-07
MA
MA
9E-12
7E-10
MA
2E-04
MA
MA .
2E-04
Total
Ufetlme Risk
for
Worker
Adult
NA
2E-06
NA
8E-07
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
tE-11
8E-07
7E-05
7E-07
7E-08
NA
3E-OB
6E-10
2E-06
NA
NA
8E-07
NA
4E-06
NA
NA
4E-11
3E-09
NA
8E-04
NA
NA
9E-04
NO SF-No Slcp* Factor raddil*
NA-Not Applicable
. NC« Not of Concern du« to the non-votaffl* DreoertiM
36
cn
vo
o
c
-------
5 9 0044
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
Hazard Quotient (HQ) . The sum of all HQs for the noncarcinogens
in a medium at a site represents the overall effect of one or
more chemicals and is termed Hazard Index (HI) . Generally, a
value of HI which exceeds 1.0 is indicative of potential health
concerns from exposure to one or more of the chemicals evaluated.
Values of the total HI estimated for ACW are 0.02 and 0.04, for
the youth trespasser and the adult worker respectively. See
Table 11 for detailed results. These values indicate that health
risks for noncarcinogens at the site are negligible.
6.5 CLEAN-UP CRITERIA
The human health risk assessment concluded that site remediation
is warranted due to an unacceptable level of carcinogenic risk.
Nevertheless, the Contaminants of Concern ( PCP, PAHs, dioxin,
and arsenic) were detected at unacceptable concentrations only at
certain areas of the site. Based on the Iso- concent rat ion maps
developed during the Focused Remedial Investigation, a total area
of approximately 28 acres of the 60 acre site requires
remediation. See Figures 3 and 4.
The clean-up goals developed for ACW are presented in Table 12 .
Remediation of the site will be designed to achieve or exceed the
cancer risk protection level of 1E-4 for the Future Adult Worker.
This remedial goal is also protective of the Youth Tresspasser.
7.0 RgMrenTAL ALTERNATIVES
The main objectives of remediating the ACW site are: (1) to
mitigate the potential health hazards due to incidental soil
ingestion, dermal contact, and dust inhalation by current
37
-------
TABLE 11 *
Surface Soil.. . jtlon. Inhalation, and Dermal Contact
Hazard Quotients for Currant Trespassers and Future Workers
Baaed on the Exposure Point Concentrations
American Creosote Works
Surface Soil
Contaminants of
Potential Concern
Aluminum
Arsenb
Barium
Beryllium
Cobalt
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
Acenaphfhene
Anthracene
Benzene
Benzo(a)anthracene
Benajajpyrene
BeniD(b)fluoranthene
BenzD(k)fluoranthene
Benzo(QHI)perylene
Carbazole
Chrysene
Dlbenzo(a,h)anthracene
Fluoranthene
Ruorene
lndeno(1 ,2,3-CD)pyrene
3-Nlfroanlllne
Pentachlorophenol
Phenanthrene
Pyrene
Trtchloroefhene
4.4-ODT
Dlbenzofuran
Oloxlns (TEO)
Endosulfan II (beta)
Endrln Ketone
Total
Ingaatlon
Chronic
HQ
Trespasser
Youth 7-18
NORfD
0.005
0.0009
0.00006
NORfD
0.003
0.0005
NORfD
0.002
0.0004
0.0002
0.0002
0.002
0.0001
0.00001
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
0.0008
0.00008
NORfD
NORfD
0.001
0.0002
0.001
0.0000007
0.00002
NORfD
NORfD
NORfD
NORfD
0.02
Dermal
Contact
Chronb
HQ
Trespasser
Youth 7-18
NORfD
0.0005
0.0001
0.000007
NORfD
0.0004
0.00006
NORfD
0.0002
0.00004
0.00003
0.00002
0.0002
0.0001
0.000005
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
0.0004
0.00004
MORfD
MORfD
0.0006
0.0001
0.0004
0.0000002
0.000008
MORfD
MORfD
MORfD
MORfD
0.003
Inhalation
Chronic
HQ
Trespasser
Youth 7- 16
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NC
NORfD
NORfD
NORfD
NORfD
MORfD
MORfD
MORfD
NORfD
NORfD
NORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
MORfD
0.00000004
MORfD
MORfD
MORfD
MORfD
MO RID
0.00000004
Ingeetlon
Chronb
HQ
Worker
Adult
NORfD
0.006
0.001
0.00008
NORfD
0.004
0.0007
NORfD
0.003
0.0005
0.0003
0.0002
0.002
0.0001
0.00001
NORfD
MORfD
MORfD
NORfD
NORfD
NORfD
4ORfD
lORfD
JORfD
4ORfD
4ORTD
4ORfD
40RTO
4ORfD
40RfD
40RfD
4ORfD
0.002
0.0002
4ORfD
slORfD
0.002
0.0005
0.002
0.0000009
0.00004
tJORTD
MORfD
MORfD
MORfD
0.01
Inhalation
Chronb
HQ
Worker
Adult
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NORfD
NC
NORfD
NORfD
NORfD
NORfD
40RfD
JORfD
NORfD
MORfD
4ORfD
^ORfD
4ORfD
40RfD
NORfD
40RTD
40RTD
4ORfD
<4ORfD
40RfD
NORfD
MORfD
NORfD
0.0000001
MORfD
MORfD
MORfD
MORfD
MORfD
0.0000001
Total HI
for
Trespasser
Youth 7- 16
NA
0.005
0.001
0.00006
NA
0.004
' 0.0008
NA
0.002
0.0004
0.0003
0.0002
0.002
0.0002
0.00002
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.001
0.0001
NA
NA
0.002
0.0003
0.001
0.0000009
0.00003
NA
NA
NA
NA
0.02
Total HI
for
Worker
Adult
NA
0.008
0.002
0.0001
NA
0.008
0.0009
NA
0.003
0.0007
0.0004
0.0003
0.003
0.0005
0.00004
MA
MA
MA
NA
MA
MA
4A
MA
4A
0.003
0.0003
4A
MA
0.004
0.0008
0.003
0.000002
0.00006
MA
MA
MA
MA
0.04
cn
NORfD-NoR«rw«nc« DoM«vmW>l«
NA-NrtApptabto
NC"Not of Concern du* to th» non-votatfl*on
38
o
Cn
efnwtalt
-------
I I I
HAB-1 STATION LOCATION
5000 nhjuymiB per kflogi tin
PROPERTY AND LAGOON BOUNDARY
L1 LA30ON
t
NORTH
1156100
9CM£ 1lTBh-200M
115*800
115^100 115^00 115^300
EASTING^ ft
RGURE3 <
PBynACHLOROPHENOL CONCENTRATIONS
SURFIQAL SOILS; 0 to 6 inches
AlVeRJCANOREOSOTEVVORKSSUPERFUI^DSITE
JACKSON, TENNESSEE
115*300
200000
100000
90000
en
vc
CD
o
NdTE
Th» nsUts of 9» oortauring db nt ran«el B» l»goon tadnirl
39
-------
I I I I 1 1 , I I I I I I
I I I
BMOO-I ' 1
HAB-1 STATION LOCATION
10000 OSTTTUENTODNCENTRATION.
PROPERTY AND LAGOON BOUNDARY
LI LA900N
SOME 1Mi»200(M
15000
10000
9000
11» 00 1150200 1158300 11SMOO 1158500 1158800 115*700 1158800 1158800 1157000 1157100 1157300 1157300 1157400 1157500 1157800 1157700 1157800 1157900 1159000 11S8100 1158200 1158300
EAST(NO,ft
RGURE4
DIOXIN Toxicmr EQUIVALENT VALUE (TEQ)
SURFICIAL SOILS, 0 to 6 inches
AMERICAN CREOSOTE WORKS SUPERRJND SITE ""*
JACKSON, TENNESSEE
tn
VO
O
CD
-------
TABLE 12
PRELIMINARY REMEDIAL GOALS
Risk Based RGs - Based on Lifetime Cancer Risk
Current Youth, ages 7-16, Trespasser
Soil (Units: mg/kg)
Benzo(a)pyrene
Dloxlns (TEQ1 - 2.3.7.8 TCDD
Risk Based RGs - Based on Lifetime Cancer Risk
. ^Future Adult Worker
""Soli (Units: mg/kg) ;
Inorganics
Arsenic
Benzo(a)pyrene
Dlbenzo(a,h)anthracene
Pentachlorophenol
Dloxlns (TEQ) - 2,3,7,8 TCDD
0.415
0.55
30
0.0000225
4.15
5.5
300
0.000225
41.5
55
3000
0.00225
on
vo
o
o
4*.
CO
-------
5 9 0049
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
trespassers and future workers at the site. (2) to protect the
Alluvial and the Fort Pillow aquifers, the Central Creek, the
South Fork Forked Deer River, and the sediments which were found
to be impacted by the site. (3) to maintain the site as an
industrial property which will not pose a significant threat to
human health or the environment. The following is a discussion
of the remedial alternatives evaluated for meeting these
objectives. Although several pertinent options were screened for
the site, only two are deemed necessary for discussion in this
ROD.
Option #1 is "No Further Action". This option is considered, as
required by Superfund Law, for comparison with other clean-up
alternatives. Option #2 is a combination of Liquid Recovery,
Immobilization and Monitoring. It is considered because it is
well suited for addressing the conditions at ACW, based on
USEPA's research and field experience with similar sites. In
addition, the preliminary results of site-specific treatability
studies indicate that the train of remedies in Option #2 can be
successfully applied at the site. The choice of the option for
consideration conforms with USEPA's newly developed Presumptive
Remedy Policy and the recent initiative to streamline clean-up
processes. The presumptive remedy policy allows USEPA to
consider an optimum clean-up method from several suitable
technology alternatives previously evaluated for sites with
similar problems. Detailed information on the background and
application of presumptive remedies may be obtained from Appendix
A, "Presumptive Remedies for Soils, Sediments, and Sludge at Wood
Treater Sites".
42
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5 9 OU50
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
7.1 Option «l--No Further Action
Under this option, no new clean-up activities would occur at the
site. However, the on-going USEPA site management and
stabilization tasks, which the State currently performs under a
Support Agency Cooperative Agreement, would continue
indefinitely. These tasks include upkeep of the perimeter fence,
the levee, the equipment for draining the lagoon, and sampling of
the lagoon water before it is discharged into the River. In
addition, the existing deed restriction which limits the site to
industrial and similar uses only will be maintained. This option
requires no additional capital cost to USEPA or the State.
However, certain contaminants found at the site would remain at
the current unacceptable levels.
7.2 Option #2--Liquid Recovery/TTnmr>v»H,iiZation/MonJ
Under this remedial option, the liquid recovery process would
remove free creosote, emulsion, water and associated contaminants
from the soils. Through the process of immobilization, migration
of the soil contaminants would be reduced considerably. Option
#2 includes excavating trenches to drain liquids trapped between
the surface of the soil and the underlying clay, separating
creosote and water for proper disposal, excavating and
solidifying contaminated soils, backfilling and capping treated
soils, and installing a containment berm around the capped area.
The existing deed restriction will be maintained in order to
continue limiting the property to industrial and similar uses
only, and the site will be monitored for a minimum of five years
to ensure remedy effectiveness.
43
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5 9 OU51
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
The monitoring program will include:
1. Leach tests to ensure the integrity of the immobilization
remedy .
2. Sampling and analyses of the Alluvial and Fort Pillow
aquifers in selected on- site and off -site wells to
ensure that the aquifers are protected by the remedy.
3. Sampling and analyses of sediments and water from the
Central Creek and the South Fork Forked Deer River to ensure
protection of fish and aquatic life.
8.0 COMPARATIVE ANALYSIS ng pgMEDIAL OPTIONS
The two remedial options discussed above were evaluated with
respect to the current conditions of the site and USEPA' s
mandate to prevent the release of hazardous chemicals into the
environment. Option #1 does not comply with USEPA' s mandate
because the option would result in an unacceptable level of risk
for the soil pathway at the site. Option #2 will remove free
products and treat the soils which constitute the sources of
contamination at the site. In addition, Option #2 will protect
the surface waters, the sediments and the aquifers affected by
the site. Based on current information, this option provides the
best balance of trade-offs relative to the nine criteria which
USEPA uses to evaluate clean-up alternatives. The following is
an evaluation of the options.
44
-------
5 9 0052
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
8.1 Threshold Criteria
.1. Overall Protection
Option #1, the "No Action" alternative, does not provide adequate
protection of human health and the environment because it does
not prevent migration of contaminants in the soils. In addition,
persons entering the site are potentially at risk of exposure to
the contaminants through dermal contact, accidental ingestion
and/or inhalation. Therefore, this alternative was eliminated
from further consideration.
Option #2, Immobilization/Liquid Recovery/Monitoring, provides
both short and long-term protection by removing the source of
release of contamination into the environment, and by containing
residual contaminants in a fixed mass. It reduces the potential
for further surface water and groundwater contamination, and
.migration of contaminants offsite. In addition, it eliminates
potential risks associated with dermal contact, inhalation and
accidental ingestion of contaminated soils, sediments, and/or
sludge.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Remedial action operations for Option #2 will be conducted in
compliance with all federal and state ARARs. Removal,
treatment, transportation and land disposal regulations or CERCLA
off-site rules will be adhered to. Appropriate emission controls
will be provided, if needed, to ensure compliance with air
quality standards during excavation and treatment. Recovery,
45
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5 9 0053
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
processing, and disposal of the free products will be designed
and implemented to comply with all federal and state ARARs.
8.2 Primary Balancing Criteria
1. Long-Term Effectiveness and Permanence
Option #2 provides long-term and permanent solutions by the
processes of contaminant source removal and immobilization.
2. Reduction of Toxicity, Mobility, or Volume Through Treatment
Significant reduction in mobility of contaminants is provided by
Option #2 through the process of solidification, and removal of
free products reduces toxicity and volume of contaminants.
3. Short-Term Effectiveness
Option #2 treatment can be accomplished within 6 to 9 months for
the entire target area of the site. The remedy immediately
becomes effective after the treatment is applied. In addition,
because the technology is flexible, the site may be segmented for
treatment. Each segment can be treated and rendered protective
of human health and the environment in a relatively short time.
4. Implementability
Immobilization is a frequently used remedial technology which has
been applied at many wood treater sites similar to ACW. In a
recent USEPA publication, (Presumptive Remedies for Soils,
Sediments, and Sludges at Wood Treater Sites, December 1995),
46
-------
5 9 0054
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
which ranked ten technologies, immobilization was used at 13 out
of 50 sites evaluated by the report. Required equipment is
relatively simple and readily obtainable. Similarly, the other
components of the remedy (liquid recovery and monitoring) are
used frequently in hazardous waste site remediations. This
option is flexible and can be adapted to remediating the site in
phases if necessary, due to government budgetary constraints.
5. Cost
The cost of this option depends on the area, depth, and volume of
the soil to be treated. Based on field sampling data, the area
and depth of the contaminated soil which requires treatment are
approximately 28 acres and 2 feet respectively. These equate to
approximately 90,000 cubic yards or 120,000 tons of soil. The
total cost (Present Value) of Option #2 is $18,448,638 as
summarized below. The Monitoring component of the cost is
estimated at $100,000 per year for five years, discounted at 7%.
COST FOR
Liquid Recovery
and Immobilization $14,321,933
Monitoring $436,977
SUBTOTAL COST $14,758,910
Contingency (25%) $3,689,728
TOTAL COSTS 518.448.638
47
-------
5 9 GU55
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
8.3 Modifying Criteria
1. State Acceptance
Officials of the Tennessee Department of Environment and
Conservation are in agreement with Option #2 clean-up plan, and
have concurred with the treatment technology to be applied.
2. Community acceptance
Selection of Option #2 was proposed publicly in and around the
community where the site is located. No comments for or against
the alternative specifically were received during the public
comment period which lasted 30 days. However, three general
site-related comments (one from the public and two from state
officials), were received during the period. These are addressed
in the Responsiveness Summary section of this document.
9.0 TITO SELECTED REMEDY
The selected remedy (Option #2} for ACW site is a combination of
(1) Liquid Recovery, (2) Immobilization, and (3) Monitoring.
This combination is necessary because much of the soil to be
remediated is saturated with spilled creosote, water and
emulsion. Liquid recovery is planned to remove most of the
organic load in the waste in order to enhance the application and
effectiveness of Immobilization on the residual contaminants in
the soils. The Monitoring component of the remedy will evaluate
the immobilized waste for integrity, and assess the effectiveness
of natural attenuation of the remaining contaminants in the
groundwater, the surface waters and sediments.
48
-------
5 9 0056
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
9.1 Liquid Recovery
The Liquid Recovery stage of the clean-up will remove the free
product by gravity drainage using a series of trenches
constructed between the soil surface and the clay below. The
free product will be processed on-site to separate the various
liquids using a system of oil/water separators. The recovered
creosote will be stored temporarily on-site in a tank and
ultimately hauled to an authorized off-site creosote recycling
facility. The remaining liquid will be treated on-site to meet
effluent discharge standards before being discharged into the
South Fork Forked Deer River.
9.2 ITtTmobilization
The primary goals of the immobilization process are to limit the
solubility of the chemicals of concern at the site and to change
the chemical forms of the contaminants to minimize their
leachability. The process will be designed to stabilize the
contaminants, thereby limiting their mobility, and to solidify
the contaminated soil into a monolithic block of treated waste
which will not disintegrate. These conditions will be achieved
by mixing the contaminated soil in batches with properly
formulated binding reagents composed of Portland cement, fly ash
and lime or kiln dust. The resultant mass of waste will be
buried in the excavated area, covered with clay and top soil
which, in turn, will be graded. Finally, the area will be seeded
with grass. The cross-section of the anticipated final landscape
for the treated area is depicted in Figure 5.
49
-------
Treatt r,ent Zone
Grass
Treated
Soil/Cement
Berm
Clean Soil
Clay
Treated Soil/Cement Product Cap
Untreated Soil
Existing Underclay
Treated
Soil/Cement
Berm
Figure 5. Cross-Section of Final Treatment Area: 2-Foot Treatment Depth (not to scale)
50
cn
vo
CD
o
cn
-------
5 9 0058
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
The success of an immobilization project depends on using the
right mix and quantity of the binding reagent and ensuring
appropriate curing conditions. These, in turn, depend on the
chemical and physical characteristics of the waste. Therefore,
USEPA recently initiated site-specific treatability studies on
the waste at ACW. Preliminary results of leach tests indicate
that immobilization can be applied successfuly at the site. As
part of the Remedial Design (RD), bench-scale treatability
studies will be conducted to formulate the appropriate reagent
and leach tests will be run on the site contaminants prior to
treatment. After the treatment, the leach tests will be
performed periodically for five years in addition to tests for
unconfined compressive strength to monitor the durability of the
treated soil.
9.3 Monitoring
Monitoring is the third aspect of the selected remedy. It will
be initiated immediately after the two other RA components are
completed for the following three purposes.
1. To provide a systematic procedure for collecting data on the
performances of the preceding remedial activities: during the
Liquid Recovery stage of the RA, the volume and rate of liquid
recovery will be recorded. In addition, the physical and
chemical characteristics of the liquids will be analyzed. These
data will enhance the design of any necessary future phases of
the RA. As previously discussed, leach and other tests will be
run periodically on the immobilized waste to evaluate its
integrity.
51
-------
5 9 0059
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
2. To evaluate and report regularly the effects of the remedial
activities on the Alluvial and Fort Pillow aquifers, the Central
creek, the South Fork Forked Deer River, and sediments: based on
the USGS studies summarized in Section 5.2, the only significant
groundwater contamination associated with the site is within the
site boundaries. Apparently, the masses of clay in the
subsurface effectively inhibit fluid flow from the site.
Nevertheless, surface runoff, erosion, and floodwater from the
site have transported toxic substances from the site which have
contaminated the nearby surface waters, sediments, fish and
aquatic life. This limited adverse environmental impact will be
addressed by the selected RA. The liquid recovery process will
remove the source of further on-site groundwater contamination,
and the residual waste immobilization will restrain further
effect of surface runoff, erosion, and floodwater from the site.
These, in addition to the inevitable process of natural
attenuation will clean up the affected media, habitats, and
receptors. An appropriate sampling and analyses program will be
designed and implemented as part of this RA to ensure that the
desired results are obtained.
3. To develop a data base for USEFA's Five-Year Review: the
first of these reviews is due five years after the initiation of
the RA construction activities. The Five-Year Reviews will
document progress and indicate if any modification of the RA or
other additional work is warranted.
In summary, the remedy will include the following activities:
1. Delineating the area to be treated.
52
-------
5 9 0060
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
2. Constructing trenches within the area to drain and collect
liquids including creosote, emulsion, and water.
3. Installing collection and treatment tanks and other
equipment to treat collected liquid for proper disposal.
4. Excavating and screening contaminated soils to be treated.
5. Mixing contaminated soils with properly formulated cement,
kiln dust, and fly ash to bind and harden contaminants to
soil, and to reduce soil permeability.
6. Placing treatment product into the excavation and
compacting.
7. Installing a berm of clean soil around the treated soil
areas to control water runoff.
8. Capping the bed of treated soil with clay, top soil, and
then reseeding to control erosion.
9. Maintaining deed restrictions to limit the property to
industrial use only.
10. Designing and Implementing a comprehensive monitoring
program.
9.4
Despite current government funding limitations, it is prudent to
begin implementing the selected remedy in order to reduce the
53
-------
5 9 0061
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
risks at the site. Therefore, a segment of the site is
recommended for immediate remediation. An area of about 8.4
acres, with an estimated 27,000 cubic yards of contaminated soil,
has been delineated for the initial phase of the remedy
implementation. The area extends from the central to the western
part of the site, and poses the site's highest human health and
enviromental risk. Currently, additional sampling is being
conducted in this area of the site for the treatability study and
remedial design. Cost of remediating the area is estimated at
$5,900,000, including monitoring expenses and a 25% contingency.
10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, USEPA must select remedies that protect
human health and the environment. The remedies must comply with
applicable or relevant and appropriate requirements unless a
statutory waiver is justified. Furthermore, they must be cost-
effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, CERCLA includes a
preference for remedies that permanently and significantly reduce
the volume, toxicity,or mobility of hazardous substances as their
principal element. A discussion of how the selected remedy meets
these requirements follows.
The selected remedy protects human health and the environment
through treatment of contaminated soil, sludge, and sediment by
solidification and stabilization, extraction and recycling of
creosote, extraction and treatment of contaminated sub-surface
54
-------
5 9 0062
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
water and emulsion, drainage and treatment of impounded water and
implementation of institutional controls to restrict future use
of the site. In addition, all visible debris at the site,
including tanks, railroad ties, lumber, and building/foundation
materials will be removed and disposed of at approved locations.
Finally, a significant reduction in erosion and transportation of
contaminated soil from the site will result from the
solidification/stabilization process, thereby reducing surface
water pollution potential.
10.2 Compliance with Appl *«»>*''«* or Relevant and Appropriate
Requirements (ARARs)
The selected remedy will comply with all federal and state ARARs.
The Land Disposal Restrictions will not be violated because
"placement" will not occur as a result of the RA. The
contaminated soil will be processed in a single area of
contamination. The ARARs that are pertinent to the selected
remedy are presented below.
Federal ARARs
* Clean Water Act Discharge Limitations, NPDES Permit 40 CFR
122, 125, 129, 136; pretreatment Standards 40 CFR 403.5.
Prohibits unpermitted discharge of any pollutant or combination
of pollutants into waters of the U.S. from any point source,
including storm water runoff from industrial areas. Applicable.
* Clean Water Act Wetlands Regulations, Part 404, CFR 230.
Controls the discharge of dredged or fill materials into waters
of the U. S. Applicable.
55
-------
5 9 OU63
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
* Fish and Wildlife Coordination Act, 16 U.S.C. 661, 742a, 2901.
Requires action to protect fish and wildlife from actions
modifying streams or areas affecting streams. No impact
expected, but applicable.
* Resource Conservation and Recovery Act (RCRA):
--40 CFR 262 and 263. RCRA generator and transporter
requirements are applicable to the off-site transport and
recycling of recovered creosote.
--40 CFR 264.553. RCRA requirements for temporary units are
applicable to any tank used for temporary storage of recovered
creosote before transported for recycling offsite.
* Clean Air Act (CAA), National Ambient Air Quality Standards
(NAAQS), 40 CFR, Part 50.6. Sets primary and secondary standards
for protection of public health from exposure to criteria
pollutants. Applicable to particulate matter emissions from the
soil excavation process.
* USEPA Regulations on Ambient Air Monitoring, 40 CFR 53.22, 40
CFR 53.34. Applicable to discharge of air contaminants, gaseous
and particulate emissions from the soil excavation process.
State ARARs
* Rule Chapter 1200-1-7 Solid Waste Regulations, State of TN.
* Tennessee Hazardous Waste Management Act of 1977, TCA 68-212-
101 to 121.
56
-------
5 9 0064
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
* Tennessee Hazardous Waste Management Act of 1982, TCA 68-212-
201 to 224.
* Tennessee Water Quality Act, TCA 69-3-101 to 131.
* Tennessee Air Quality Control Act, TCA 68-201-101 to 118.
10.3 COBt
Excluding the monitoring expenses, the selected remedy is
expected to cost between $145 and $155 per ton of treated waste
material. The industry average ranges between $75 and $400 per
ton of waste for similar treatment. Therefore, the projected
cost of the process to be used at the site is competitive.
Recovery of free product, which is a part of the remedy, will
remove a significant amount of the primary source of
environmental pollution. Immobilization process will virtually
eliminate the effects of the residual waste on the environment.
Therefore, the remedy is believed to be cost-effective.
tion of Permanent Solutions to the
The free product recovery component of the selected remedy is a
permanent solution designed to eliminate the source of site
contamination to the maximum extent possible. Immobilization of
the residual contamination will provide a long lasting
environmental and human health protection. In addition, the deed
restriction to be maintained on the site will limit the use of
the property and permanently control the effect of the site on
human health.
57
-------
5 9 0065
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
10.5
The major components of the selected clean-up plan constitute
preference for treatment as a principal remedy element. The free
product to be recovered from the site will be treated
appropriately before disposal at approved off-site locations. As
previously discussed, the soils, sediments, and sludge with their
associated contaminants will be immobilized by treatment with
properly designed binding reagents.
11.0 SIGNIFICANT CHANGES TO THE PROPOSED PLAN
In May 1996, the Superfund Proposed Plan Fact Sheet regarding the
selected remedy stated the following: "The area of the Site to be
treated is estimated at 365,100 square feet or 8.4 acres.
Contaminated soils to depths of 2 to 5 feet from the surface
would be excavated and treated. These would result in the
treatment of between 35,000 and 88,000 tons of contaminated soil.
Depending on the amount of soil treated, cost of the project is
expected to be between $5 million and $12 million." According
to this Record of Decision, the total area of the site to be
remediated is 28 acres at an estimated cost of $18,448,638.
However, remediation of the 28 acres is to be conducted in
phases. During the initial phase, 8.4 acres of the site would be
remediated at an estimated cost of $5.9 million. The reasons for
the apparent differences are as follows:
1. Due to RA funding constraints, the cleanup of contaminated
soils will need to be conducted in phases. In the Proposed Plan,
an area of 8.4 acres was discussed as the area to be remediated.
This area represents the portion of the site with the highest
58
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5 9 0066
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
contamination, and therefore, the focus of the first phase of
remediation. However, site studies have esimated the total area
which may require remediation at 28 acres. Therefore, the area
addressed by the clean-up levels set in this ROD is more properly
stated as 28 acres, with the the first phase of cleanup to focus
on the most contaminated area of approximately 8.4 acres.
2. The calculation of contaminated soils has been refined
further by studies conducted after the Proposed Plan which
indicates that the average depth of soils requiring remediation
is 2 feet.
3. The combination of increasing the total area addressed by the
ROD (28 acres versus 8.4 acres), and refining the depth of soil
treatment ( 2 feet versus a range of 2 to 5 feet) has resulted in
a change to the estimated cost of the RA.
4. The Proposed Plan did not discuss or provide funding for
Monitoring activities. This ROD has outlined the reasons for '
monitoring and has included its estimated cost of $100,000 per
year for 5 years in the RA cost estimate.
12»0 Responsivepesp Summary
Pursuant to Superfund policy, this section of the ROD is intended
to addresses the comments, issues and questions raised by
citizens during the Proposed Plan public comment period. Three
letters were received regarding the Proposed Plan during the
public comment period held between June 3 and July 3, 1996. A
summary of the letters, and USEPA's responses to the issues
raised are presented below.
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5 9 0067
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
1. A letter was received from the Tennessee Wildlife Resources
Agency which recommends the establishment of good base-line
information by sampling fish on the South Fork Forked Deer River
before implementing the RA plan.
Response: This recomendation will be considered during the
Remedial Design which includes establishing appropriate base-line
data for the RA.
2. A letter was written by a citizen to the Division of
Superfund, Tennesse Dept. of Environment regarding his concern
about "lack of testing of private wells for contamination." The
letter was a followup to a phone discussion by the writer and a
Tennessee State official. It was sent by the official to USEPA
with comments that the writer lives approximately four miles,
directly south of the site. The official believes that the
writer's fear can be allayed by the fact that groundwater flows
southwest in the vicinity of the site. In addition, wells
screened at six different levels on the southern boundary of the
site did not indicate contamination.
Response: USEPA personnel discussed the issue with Tennessee
State officials and agreed with their conclusions.
3. An official of the Tennessee Division of Water Pollution
Control, in a letter to the Tennessee Division of Superfund
expressed concern about the waste previously consolidated and
capped at the site, and the impounded water on top of the cap.
In the same letter, the writer felt that USEPA did not propose a
plan to address the impact of the site on the Alluvial and Fort
Pillow aquifers, the Central Creek, the South Fork Forked Deer
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5 9 OU68
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
River, sediments, and aquatic organisms.
Response: USEPA personnel discussed the concerns with the
officials of the Tennessee Division of Superfund. The officials
indicated that the impounded water issue would be addressed by
the repair work being conducted under the State Superfund
Cooperative Agreement for Site Stabilization. USEPA indicated
that the remedy plan for the affected aquifers, creek, river,
sediments, and aquatic organisms would be detailed in this Record
of Decision.
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5 9 OU69
RECORD OF DECISION
AMERICAN CREOSOTE
JACKSON, TENNESSEE
APPENDIX A
PRESUMPTIVE REMEDIES FOR SOILS, SEDIMENTS, AND SLUDGES
AT WOOD THEATER SITES
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5 9 0070
United States Office of Directive: 9200.5-162
Environmental Protection Solid Waste and EPA/540/R-95/128
Agency Emergency Response PB 95-963410
Washington, DC 20460 December 1995
Superfund
&ER& Presumptive Remedies for
Soils, Sediments, and Sludges
at Wood Treater Sites
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5 9 0071
EPA/540/R-95/128
December 1995
Presumptive Remedies for
Soils, Sediments, and Sludges
at Wood Treater Sites
Office of Emergency and Remedial Response, 5202G
Washington, DC 20460.
-------
Notice:
The policies set out in this document are intended solely as
guidance to U.S. Environmental Protection Agency
personnel; they are not final EPA actions and do not
constitute rulemaking. These policies are not legally
binding and are not intended, nor can they be relied upon,
to create any rights enforceable by any party in litigation
with the United States. EPA officials may decide to follow
the guidance provided in this document, or to act at
variance with the guidance, based on an analysis of specific
site circumstances. EPA also reserves the right to change
this guidance at any time without public notice.
Additional copies of this document may be
obtained from:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
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5 9 0072
TABLE OF CONTENTS
INTRODUCTION 1
PURPOSE 1
USE OF THIS DOCUMENT 2
ANTICIPATED BENEFITS OF PRESUMPTIVE REMEDIES 2
DESCRIPTION OF WOOD TREATER SITES 4
PRESUMPTIVE REMEDIES FOR WOOD TREATER SITES 6
Bioremediation 6
Thermal Desorption 7
Incineration .. o 7
Immobilization 8
«
PRESUMPTIVE REMEDY PROCES^ FOR WOOD TREATER SITES 8
CONCLUSION 15
GLOSSARY 49
REFERENCES 51
APPENDIX A: TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES 31
APPENDIX B: EVALUATION OF SELECTION CRITERIA FOR
TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD
TREATER SITES 41
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UST OF TABLES
TABLE 1: Evaluation of Presumptive Remedy Technology Options 11
TABLE 2: Comparison of Presumptive Remedy Technologies 20
TABLE 3-A: Data Requirements for Bioremediation 26
TABLE 3-B: Data Requirements for Thermal Desorption 28
TABLE 3-C: Data Requirements for Incineration 29
TABLE 3-D: Data Requirements for Immobilization 30
TABLE A-1: Remedies Selected at NPL Wood Treater Sites 32
TABLE A-2: Summary of Initial Screening Phase For Wood Treater Sites 34
TABLE A-S: Summary of Detailed Analysis Phase For Wood Treater Sites 37
LIST OF BOXES
x >
BOX A: Ground-Water Considerations 3
BOX B: Contacts for Additional Information 4
BOX C: Contaminants Commonly Found at Wood Treater Sites 5
BOX D: Background Information on NAPL Contamination 16
BOX E: Practical Considerations 18
LIST OF FIGURES
FIGURE 1: Decision Tree for Technology Selection at Wood Treater Sites 9
FIGURE D-1: Components of DNAPL Sites 17
FIGURE D-2: Types of DNAPL Contamination and Contaminant Zones at DNAPL Sites
(Cross-Sectional View) 17
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5 9 OU73
INTRODUCTION
Since the enactment of -the Comprehensive
Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA or Superfund), the Snperfund
remedial and removal programs have found that certain
categories of sites have similar characteristics, such as
types of contaminants present, disposal practices
performed, or environmental media affected. Based on
information acquired from evaluating and cleaning up
these sites, the Superfund program is undertaking an
initiative to develop presumptive remedies to accelerate
future cleanups at these types of sites. The
presumptive remedy approach is one tool for speeding
up cleanups within the Superfund Accelerated Cleanup
Model (SACM). This approach can also be used to
streamline remedial decisionmaking for corrective
actions conducted under the Resource Conservation
and Recovery Act (RCRA).
Presumptive remedies are preferred technologies for
common categories of sites, based on EPA's experience
and its scientific and engineering evaluation of
alternative technologies. The objective of the
presumptive remedies initiative is to use the Superfund
program's experience tp streamlinesite characterization
and speed up the selection of cleanup actions. Over
time, presumptive remedies are expected to ensure
consistency in remedy selection and reduce the cost and
time required to clean up similar types off sites.
Presumptive remedies are expected to be used at all
appropriate sites except under unusual site-specific
circumstances.
This directive identifies the presumptive remedies for
wood treater sites with contaminated soils, sediments,
and sludges. EPA has developed guidance on
presumptive remedies for municipal landfill sites [33]
and sites with volatile organic compounds (VOCs) in
soils [32]. EPA is also in the process of developing
guidance on presumptive remedies for potychlorinated
biphenyl (PCB), grain storage, manufactured gas plant,
and contaminated ground-water sites. In addition,
EPA has developed a directive entitled Presumptive
Remedies; Policy and Procedures [31], which outlines
and addresses the issues common to all presumptive
remedies (e.g., the role of innovative treatment
technologies).
Bold and italicized terms are defined in the Glossary at
the end of this document The References section at
the end of this document provides a list of supporting
guidance documents that may be consulted for
additional information on relevant topics. Bracketed
numbers [#] appear throughout the text to indicate
specific references in the References section.
PURPOSE
The purpose of this directive is to provide guidance on
selecting a presumptive remedy or combination of
presumptive remedies for wood treater sites with
contaminated soils, sediments, and sludges.
Specifically, this guidance:
Describes the contaminants generally found at
wood treater sites;
Presents the presumptive remedies for
contaminated soils, sediments, and sludges at
wood treater sites;
Describes the presumptive remedy process
concerning the site characterization and
technology screening steps; and
Outlines the data that should be used to select a
presumptive remedy.
The presumptive remedies for wood treater sites with
soils, sediments, and sludges contaminated with organic
contaminants are bioremediation. thermal desorption.
and incineration. The presumptive remedy for wood
treater sites with soils, sediments, and sludges
contaminated with inorganic contaminants is
immobilisation. The section of thfc document entitled
Presumptive Remedies for Wood Treater Sites"
provides a brief description of each of these
technologies.
The decision to establish these technologies as
presumptive remedies for this site type is based on
EPA's accumulated knowledge about site
characterization and remedy selection for wood treater
sites with contaminated soils, sediments, and sludges,
including actual performance at Superfund and RCRA
sites. This decision is also based on an analysis
conducted by EPA on Feasibility Studies (FSs) and
Records of Decision (KODs) for sites where wood
treating contaminants in soils, sediments, and sludges
drove remedy selection. The results of this analysis,
which are summarized in Appendix A (Technical Basis
for Presumptive Remedies), demonstrate that these
four technologies represent approximately 84% of the
remedies selected in the FSs and RODs analyzed. The
FS/ROD analysis also provides information on why
other, non-presumptive technologies generally are not
effective and/or appropriate for cleaning up wood
Page 1
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treater sites with contaminated soils, sediments, or
sludges.
USE OF THIS DOCUMENT
This directive is designed to assist Superfund site
managers (It., Remedial Project Managers (KPMs) and
On-Scene Coordinators (OSCs)) and other personnel in
selecting remedies for cleaning up soils, sediments, and
sludges at wood treater sites that are contaminated
primarily with creosote, pentachlorophenol. and/or
chromated copper arsenate. Site managers in other
programs, such as the RCRA corrective action program
or the private sector, may also find this document
useful. For example, the information contained in this
document could be used to eliminate the need for an
alternatives screening step and streamline the detailed
analysis of alternatives in the RCRA Corrective
Measures Study, which is analogous to the FS under
CERCLA.
Wood treater sites that have contaminated soils,
sediments, and sludges often have contaminated ground
water as well. At some of these sites, the contaminated
soils, sediments, or sludges may not require treatment
or may only need to be contained, depending on the
degree of human health and^ejrvironmental risk posed
by the contaminated soils, sediments, or sludges as
determined in the removal site evaluation and/or
remedial site evaluation (Le., the preliminary
assessment/site inspection (PA/SI)). At some sites, a
combination of treatment options may need to be
implemented to address the contamination of ground
water as well as soils, sediments, and sludges. When
addressing contamination at wood treater sites, site
managers should consider the impact of contamination
across all environmental media. In particular, site
managers at wood treater sites should consider the
impacts of ground-water contamination. EPA is
currently developing guidance on a presumptive remedy
approach for responding to contaminated ground-water
sites. When available, this guidance should be used to
address ground-water contamination at wood treater
sites. Site managers should also consult existing
guidance on the remediation of contaminated ground
water [6, 7, 17, 20, 38]. Box A provides a brief
discussion of ground-water considerations for wood
treater sites that is consistent with existing guidance
and the forthcoming presumptive remedy ground-water
approach. In addition, Box D provides background
information on non-aqueous phase liquid (NAPL)
contaminants, including dense NAPLs (DNAPLs or
sinkers) and light NAPLs (LNAPLs or floaters).
The presumptive remedy evaluation and selection
process described in this document is consistent v
and fits into the more detailed conventional renu.
selection process outlined in the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP, 40 CFR Part 300). The Agency believes that
the presumptive remedies set out in this document
represent appropriate response action alternatives for
sites meeting certain criteria and, therefore, generally
should be used. However, remedy selection for an
individual site may vary because of specific site
characteristics or community or state concerns.
Although it may still be possible to accelerate remedy
selection for non-presumptive technologies, such
selection will not be able to take advantage of the
generic justification provided by this document Under
these circumstances, a conventional Remedial
Investigation/Feasibility Study (RI/FS) or Engineering
Evaluation/Cost Analysis (EE/CA) should be performed.
Guidance on circumstances in which a presumptive
remedy might not be appropriate is found in
Presumptive Remedies: Policy and Procedures [3IJ.
When determining whether a remedial or removal
action is the appropriate method for cleaning up a
wood treater site, site managers should consult the
NCP and Superfund program guidance. Also, the.
Agency is currently developing a fact sheet to ass' m
RPMs and OSCs in identifying the factors affecting tL
site-specific determination of whether a Superfund
early action is best accomplished as a non-time-critical
removal action or an early remedial action.
This directive is not a stand-alone document To
ensure a full understanding of wood treater site
characterization and remedy selection, site managers
should refer to the FS/ROD analysis, which is
summarized in Appendix A of this document, and the
documents cited as references at the end of this
document Site managers unfamiliar with certain
complex site conditions at wood treater sites should
consult with experienced site managers, the contacts
listed in Box B of this document, the Superfund
Technical Assistance Response Team (START), or the
Environmental Response Team (ERT). EPA is
continuing to gather and develop more information on
the remedies selected and implemented at wood treater
sites.
ANTICIPATED BENEFITS OF
PRESUMPTIVE REMEDIES
'The use of this document is expected to reduce th |
costs and time required for remedy selection at wooa
treater sites. This directive should be used to:
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5 9 0074
BOX A
Ground-Water Considerations
Wood treater sites typically involve subsurface DNAPL and/or LNAPL contaminants (see Boxes C and D) in
t nr dudges All of.these materials are sources of contamination of the
underlying ground water and need to be considered when planning an overall site response. A key element of
all existing ground-water remediation guidance is that site characterization and response actions should be
implemented in a phased approach. In a phased approach, site response activities are conducted in a sequence
of steps, such that information obtained from earlier steps is used to refine subsequent investigations, objectives,
or actions. The rBcommcnrtfid strategy for sites with NAPL contamination, such as wood treater sites, includes
the following response actions and objectives [17].
Site investigations should be designed to delineate both NAPL zones and aqueous plumes. NAPL zones are
those portions of the site where LNAPL or DNAPL contaminants (in the form of immiscible liquids) are
suspected in the subsurface, either above, at, or below the water table. Aqueous plumes are portions of the site
where contaminants are present in solution and not as immiscible liquids.
Eartv actions should be used to:
Prevent exposure, both current and future, to ground-water contaminants;
Prevent the farmer spread of the aqueous plume (plume containment);
Control the further migration of contaminants to ground water from contaminated soils and
subsurface NAPLs, where practicable (source containment); and
Reduce the quantity of source material present in the subsurface (free-phase DNAPL), to the extent
practicably (source removal/treatment).
v
Long-term remedial actions should be used to:
Attain those objectives listed above that were not accomplished as early actions;
Minimize further release of contaminants from soils and subsurface NAPLs to the surrounding
ground water (source containment);
Reduce the quantity of source material present in the NAPL zone (free- and residual-phase), to the
extent practicable (source removal/treatment); and
Restore as much of the aqueous plume as possible to cleanup levels (e.g, drinking water standards)
appropriate for its beneficial uses. These beneficial uses should take into account anticipated future
land use(s) (aquifer restoration).
For more information on NAPL contamination, see Box O.
Identify the presumed or likely remedy options up appropriate wfll depend on the degree of
front and allow for a more focused collection of complexity and uncertainty at a site. Also, it may
data on the extent of contamination. be appropriate to collect certain remedial design
data before the drafting of the ROD or Action
This presumptive remedy guidance allows for the _ Memorandum, thereby allowing the action to
evaluation of only the primary cleanup alternative proceed more quickly after signature of the
or a narrow range of options. The judgment as to decision document
whether evaluation of only the primary remedy is
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BOXB
Contacts for Additional Information
Headquarters Policy Contacts:
Frank Awisato, Wood Treater
Project Manager (703)603-8949
Scon Fredericks, Presumptive Remedies
Team Leader (703) 603-8771
Technical Contacts:
Harry Allen, Environmental Response
Team (908)321-6747
Frank Freestone, Office of Research
and Development (908) 321-6632
Regional Contacts:
I Mike Nalipinski
n Mel Hauptman
III Paul Leonard
IV Felicia Barnett
V Dion Novak
VI Cathy Gilmore
Vn Diana Engeman
Vffl Victor Ketellapper^
IX Craig Cooper
X EricWiniecki
(617) 223-5503
(212) 637-3952
(215) 597-3163
(404) 347-7791
(312) 886-4737
(214) 665-6766
(913) 551-7746
(303) 293-1648
(415) 744-2370
(206) 553-6904
Eliminate the need for the initial step of
screening alternatives during the FS or EEVCA.
The NCP (section 300.430(e)(l)) states that the
lead agency shall include an alternatives screening
step when needed [emphasis added] to select a
reasonable number of alternatives for detailed
analysis. The Agency performed an analysis of
FSs and RODs on the potentially available
technologies for soils, sediments, and sludges at
wood treater sites (see Appendix A) and found
that certain technologies are appropriately and
consistently screened out based on the criteria of
effectiveness, implementability, and cost
(consistent with section 300.430(e)(7)). Based on
this analysis, the Agency has determined that the
initial step of identifying and screening
alternatives for FSs and EE/CAs for wood treater
sites may not be necessary on a site-specific basis;
instead, the FS or EE/CA may proceed
immediately from the identification of alternatives
to the detailed analysis, focusing on
technologies recommended in this directive.
document and the accompanying FS/ROD ana.
must be included in the Administrative Record to
provide the basis for streamlining the analysis for
wood treater sites in this way.
Streamline the detailed analysis phase of the FS
or EE/CA.
Once cleanup alternatives pass the initial
screening step, they must be evaluated against the
appropriate criteria defined in the NCP.
Appendix A of this document summarizes the
analysis EPA conducted on FSs/RODs for wood
treater sites with contaminated soils, sediments, or
sludges, and Appendix B provides generic
evaluations of the different presumptive remedies
against seven of the nine remedial criteria
(excluding state and community acceptance).
Both of these appendices should be used to
streamline the detailed analysis phase of the FS.
Appendices A and B can also be used to
streamline the evaluation of removal action
alternatives in an EE/CA. The generic analyses in
Appendix B should be supplemented with site-
specific information for the final respor
selection. For a more detailed discussion
preparing an FS or EE/CA, see'the references
listed at the end of this document [16,19].
EPA expects that at least one of the presumptive
remedies will be suitable for a wood treater site
with principal threats that require the treatment
of contaminated soils, sediments, or sludges.
Circumstances under which other approaches may
be appropriate include: unusual site soil
characteristics; demonstration of significant
advantages of innovative technologies over the
presumptive remedies; and extraordinary
community and state concerns. If such
circumstances are encountered, additional analyses
may be necessary or a conventional RI/FS or
EE/CA may be performed.
DESCRIPTION OF WOOD TREATER
SITES
The wood treating industry has been in existence in the
United States for over 100 years. Wood is usually
'treated in cylinders, under pressure, with one. or i
combination of the following types of preservatives:
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5 9 v OU75
Pemachlorophenol (PCP) in petroleum or other
solvents;
Creosote (in petroleum or other solvents);
Aqueous solutions of copper, chromium, and
arsenic;
Copper and arsenic, or copper, arsenic, and zinc
solutions in ammonia; and
Fire retardants (combinations of phosphates,
borates, boric add, and/or zinc compounds).
Older facilities traditionally used oil-based
preservatives, while more modern facilities tend to use
water-soluble preservatives. Water-soluble processes
produce little or no wastewater, except for small
amounts of metal-containing sludges. Oil-based
processes produce sludge wastes and significant
quantities of process wastewater. The processes
performed at wood treater sites generally will result in
contaminated soils, sediments, and sludges, and/or
contaminated surface and ground water.
Box C provides a list of contaminants commonly found
at wood treater sites; general^ chemical categories of
contaminants are provided aid specific chemicals or
substances are identified under each category. As
indicated in Box C, most of the organic contaminants
found at wood treater sites are NAPLs, either in their
pure form or as components of other substances that
are NAPLs (e.g., petroleum fuels, creosote). Site
managers should refer to Box D for background
information on NAPLs and cleanup problems
associated with these contaminants.
The three types of contaminants predominantly, found
at wood treater sites, either alone or in combination
with each other - or with total petroleum hydrocarbon
(TPH) carrier oils - are creosote, PCP, and chromated
copper arsenate (CCA). Creosote is an oily,
translucent brown to black iiquid that is a very complex
mixture of organic compounds, containing
approximately 85% potynuclear aromatic hydrocarbons
(PAHs), 10% phenolic compounds, and 5% nitrogen-,
sulfur-, or oxygen-containing heterocycles. PCP is also
an organic contaminant In its pure form, PCP is a
DNAPL; however, PCP is commonly found at wood
treater sites as an LNAPL mixed into fuel oil or other
BOXC
Contaminants Commonly Found
at Wood Treater Sites
ORGANICS
DkHdns/Hrans1
Dibenzo-p-diaotins
Dibeozofuraos
Furan
Halogeaated phenols1
Pentacbtarophenol
Tctracfalomphftnnl
Simple oon-aatageaated aromatics2
Benzene
Toluene
Ethyibenzene
Xytene
Polynndear aromatic
hydrocarbons1
2-Mettaylnaphtbaleoe
Chrysene
Acenaphthene
Fluorantheoe
Acenapbthyleoe
Fluorene
Anthracene
Indeno(lA3-cd)pyrene
Beazo(a)apthraceoe
Naphthalene
Benzo(a)pyreoe
Pbenanthrene
Benzo(b)fluoranthene
Pyrene
Benzo(k)fluoraathene
Other polar organic compounds
2,4-Dimethylpfaenolf
2-Methylphenol1
4-Metbyipbenol1
Benzoic acid1
Di-n-octyl phtbalate
N-oitrosodiphenylamine
INORGANICS
Nonvolatile metals (compounds
of)
Copper
Volatile metals (compounds of)
Arsenic
Cadmium
Lead
Zinc
1 DNAPL(s) in pore form.
1 LNAPL(s) in pare form.
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light organic substances. If PCP or other chlorinated
phenols are present at a site, associated dioxins and/or
furans may also be present in the approximate vicinity.
If so, these dioxins and/or furans will likely exist in
much lower concentrations than the associated
chlorinated phenols. This document is not designed to
address sites containing high levels of dioxins and/or
furans. EPA is currently gathering information on the
issue of diorin/furan contamination; site managers
should contact the Headquarters policy contacts listed
in Box B for more information on this topic. CCA is
an inorganic arsenical wood preservative. Other metal-
containing preservatives that may be found at wood
treater sites include ammoniacal copper arsenate
(ACA) and ammoniacal copper-zinc arsenate (ACZA).
PRESUMPTIVE REMEDIES FOR WOOD
TREATER SITES
The presumptive remedies for contaminated soils,
sediments, and sludges constituting the principal
threats at wood treater sites are described below.
Bioremediation is the primary presumptive remedy for
treating organic contamination of soils, sediments, and
sludges at wood treater sites. Bioremediation has been
selected as the primary presumptive remedy for treating
organic contamination because it has been selected
most frequently to address organic contamination at
wood treater Superfund sites, and the Agency believes
that it effectively treats wood treating wastes at a
relatively low cost If bioremediation is not feasible,
thermal desorption may be the more appropriate
response technology. In a limited number of situations
(e.g., the treatment of 'hot spots* such as sludges),
incineration may be the more appropriate remedy.
Immobilization is the primary presumptive remedy for
treating inorganic contamination of soils, sediments,
and sludges at wood treater sites.
An important consideration in determining which
presumptive remedy technology is the most appropriate
for a particular site is the future land use or uses
anticipated for that site (see reference [27] and Box E
of this document for more information on land-use
considerations). Another important consideration in
selecting the most appropriate presumptive remedy
technology is determining what are the principal
threats and low-level threats (including possible
. treatment residuals) at a site. Treatment technologies
are the preferred remedies for addressing principal
threats, while containment technologies in conjunction
with institutional and/or engineering controls, are most
likely to be appropriate for addressing low-level
threats. Table 2 (Comparison of Presumptive Remedy
Technologies), which is found at the end of this
document, provides detailed information on tt
advantages, limitations, and costs of each of th
presumptive remedies.
At many wood treater sites, it may be necessary to use
a combination of control and treatment options as pan
of an overall treatment train to sufficiently reduce
tenacity and immobilize contaminants. Institutional
and/or engineering controls can be used in conjunction
with one or more of the presumptive remedy
technologies to enhance the long-term reliability of the
remedy. Site managers should note that all ex situ
remedy options require measures to protect workers
and the community during the excavation, handling,
and treatment of contaminants, and may be subject to
RCRA land disposal restrictions. Box E (Practical
Considerations) provides a discussion of land use,
institutional and engineering controls, treatment trains,
the remediation of 'hot spots,* and land disposal
restriction issues.
Bioremediation Bioremediation is the chemical
degradation of organic contaminants using
microorganisms. Biological activity (i.e.,
biodegradation) can occur either in the presence
(aerobic) or absence (anaerobic) of oxygen. Aerobic
biodegradation converts organic contaminants to
various intermediate and final decomposition products,
which may include various daughter compounds,
carbon dioxide, water, humic materials, and microbial
cell matter. Aerobic biodegradation may also cause
binding of the contaminants to soil components, such
as humic materials. Anaerobic biodegradation converts
the contaminants to carbon dioxide, methane, and
microbial cell matter.
Bioremediation may be an ex situ or in situ process. £r
situ bioremediation refers to the biological treatment
of contaminants following excavation of the soil or
other media, and includes composting, land treatment
in lined treatment cells, treatment in soil piles, or the
use of soil slurry reactors. In situ bioremediation is the
in-place treatment of contaminants, and may involve
the addition of nutrients, oxygen, or other
enhancements into the subsurface.
EPA has more experience in implementing ex situ
bioremediation than in situ bioremediation. In general,
ex situ bioremediation is fester than in situ
bioremediation, although the implementation of either
ex situ or in situ bioremediation typically can require
several years, as compared to approximately six months
to a year for technologies like thermal desorption or
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5 9 0076
incineration. In situ bioremediation may be less costly
than ex situ bioremediation. However, at some wood
treater sites,, ex situ bioremediation may be able to
achieve higher performance efficiencies than the in situ
process due to increased access and contact between
microorganisms, contaminants, nutrients, water, and
electron acceptors.
Hie effectiveness of bioremediation is site- and
contaminant-specific. Careful contaminant and matrix
characterization (with particular attention to
heterogeneity), coupled with treatability studies of
appropriate scale and duration, are strongly
recommended. Bioremediation can successfully treat
soils, sediments, and sludges contaminated with organic
contaminants, such as halogenated phenols and cresols,
other polar organic compounds, non-balogenated
aromatics, and PAHs. Studies on the bioremediation
of creosote contamination indicate that bioremediation
works well on 2-, 3-, and often 4-ring compounds, but
generally not as well on 5- or 6-ring compounds.
Bioremediation may not be effective for the treatment
of high levels of concentrated residual creosote in soils,
sediments, or sludges. It may be necessary to separate
this material for disposal or treatment by a different
.technology (e.g,, thermal desorption or incineration)
before attempting bioremediation. The remaining
soils, sediments, or sludges, with lower levels of
contamination, may then be amenable to
bioremediation. Bioremediation generally is not
appropriate for treating inorganic contamination at
wood treater sites. Only limited data on the
bioremediation of dioxins or furans are currently
available; EPA is currently gathering information on
the treatability of dioxins and furans (for more
information, contact the individuals listed in Box B).
Thermal Desorption Thermal desorption physically
separates, but does not destroy, volatile and some semi-
volatile contaminants from excavated soils, sediments,
and sludges. Significant material handling operations
may be necessary to son and size the soils, sediments,
or sludges for treatment Thermal desorption uses heat
or mechanical agitation to volatilize contaminants from
soils, sediments, or sludges into a gas stream;
subsequent treatment must be provided for the
concentrated contaminants resulting from the use of
this technology. Depending on the process selected,
this technology heats contaminated media to varying
temperatures, driving off water and volatile and semi-
volatile contaminants. Off-gases may be condensed for
disposal, captured by carbon adsorption beds, or
treated with biofilters.
Treatability studies are recommended before full
implementation of the thermal desorption technology.
Thermal desorption can successfully treat halogenated
phenols and cresols as well as volatile non-halogenated
organic compounds at wood treater sites. It cannot,
however, effectively separate non-volatile metals (e.g.,
copper) from the contaminated media. Some desbrber
units can treat PCBs, pesticides, and dioxins/furans in
contaminated soils, sediments, or sludges.
If chlorine is present in the feed material (e.g., as a
result of PCP), dioxin and furan formation may occur
in the thermal desorber, stack, or air pollution control
devices at temperatures of 350 °F and above. Thermal
treatment systems can be designed and operated to
dioxin and furan formation and to remove
these compounds from the stack gases. However,
because pilot-scale devices do not always duplicate
operating conditions at full scale, bench- or pilot-scale
treatability studies alone may not be sufficient to verify
dioxin/furan formation or control. A full-scale test,
called a "Proof of Performance* test, with analyses for
dioxins and furans should be completed. Safe thermal
treatment operation should be confirmed prior to the
use of thermal desorption.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) and other laws should be
considered when determining whether thermal
desorption is conducted on- or off-site. On-site
thermal desorption may be performed with a mobile
unit; however, space availability may make this option
infeasible. Thermal desorption may also be conducted
off-site; however, the facilities used must be in
compliance with the Superfund off-site rule before
accepting material from a Superfund site. EPA is
currently in the process of completing guidance that
provides information on the safe implementation of
thermal treatment technologies, including thermal
desorption and incineration.
Incineration Incineration generally treats organic
contaminants by subjecting them to temperatures
typically greater than 1,000°F in the presence of oxygen
and a flame. During incineration, volatilization and
combustion convert the organic contaminants to carbon
dioxide, water, hydrogen chloride, and sulfur oxides.
The incinerator off-gas requires treatment by an air
pollution control (APC) system to remove particulates
and to neutralize and remove acid gases (e.g., HC1).
This technology may generate three residual streams:
solids from the incinerator and APC system, water
from the APC system, and air emissions from theTAPC
system.
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Incineration has consistently been demonstrated to
achieve a performance efficiency in the 90 to 99%
range. Incineration has successfully treated wood
treater soil, sediment, and sludge contamination to
cleanup levels that are more stringent than can be
consistently attained by the other wood treater
presumptive remedies. A substantial body of trial burn
results and other .quality-assured data verify that
incineration can remove and destroy organic
contaminants (including diorins and furans) to the
parts per billion or parts per trillion level
Consequently, incineration may be particularly effective
in treating "hot spots* at wood treater sites.
Incineration, however, does not destroy metals. Metals
will produce different residuals depending on the
volatility of the compounds, the presence of certain
compounds (e.g., chlorine), and the incinerator
operating conditions. Improperly operated incinerators
also have the potential to create dicntins and furans.
Incineration of large volumes of contaminated media
may be prohibitively costly.
Incineration may be performed on- or off-site. There
may be significant considerations regarding the
compliance of incineration with ARARs and other
laws. On-site incineration may be performed with a
transportable incineration ""unit; however, space
availability and public opposition may make this option
inappropriate. Whenever incineration is considered as
an option to fulfill remediation goals, particular efforts
should be made to provide the community with good
information on incineration and to be responsive to
any concerns raised by the community. Commercial
incineration facilities (Le., units permitted for the
incineration of hazardous wastes, including incinerators
and cement kilns) may be used when off-site
incineration is desirable. However, only a limited
number of these facilities are available nationwide.
Permitting of additional on- and off-site incineration
facilities will be affected by EPA's Strategy for
Hazardous Waste Minimization and Combustion [37].
Immobilization Immobilization reduces the mobility
of a contaminant, either by physically restricting its
contact with a mobile phase (solidification) or by
chemically altering/binding the contaminant
(stabilization). The most common solidification
binders are cementacious materials, including Portland
cement, fly ash/lime, and fly ash/kiln dust. These
agents form a solid, resistant, aluminosilicate matrix
that can occlude waste particles, bind various
contaminants, and reduce the permeability of the
waste/binder mass. Immobilization is particularly
suited to addressing inorganic (e.g.,
contamination.
At wood treater 'Sites, inorganic contamination is
sometimes commingled with organic contamination. In
these situations, a treatment train should be
implemented that uses bioremediation, thermal
desorption, or incineration to address organic
contamination, followed by the immobilization of any
significant residual inorganic contamination. There
are limited full-scale performance data available on the
immobilization of PAHs and PCP, either alone or
commingled with inorganic contamination, where the
concentration of total petroleum hydrocarbons is
significantly more than 1%. Immobilization has been
effective in treating soils with commingled organic and
inorganic contamination with a total organic content of
as much as 20-45%. Immobilization alone is not
effective for treating volatile organic contaminants.
Site-specific treatability studies should be conducted to
ensure that a solidification/stabilization formulation
can be developed that meets site-specific requirements
for low teachability and permeability, and high
compressfve strength. EPA is currently in the process
of developing guidance on conducting
solidification/fetabilization treatability studies.
PRESUMPTIVE REMEDY PROCESS FOR
WOOD TREATER SITES
This section and the accompanying "Decision Tree for
Technology Selection at Wood Treater Sites* (Figure
1) describe the process for selecting a presumptive
remedy or combination of remedies for cleaning up
contaminated soils, sediments, and sludges at wood
treater sites. This remedy selection process is
consistent with and fits into the overall site
remediation process outlined in the NCP.
Under the NCP, alternative remedies are to be
evaluated and the preferred alternative is to be selected
based on nine criteria. Presumptive remedies are
technologies that have been found to be generally
superior under the nine criteria to other technologies.
This generic evaluation makes it unnecessary to
conduct a detailed site-specific analysis of the other
technologies.
The 'decision tree* approach recommended here is a
further streamlining of the usual NCP analysis. The .
decision tree is based on the Agency's findings Jhat,
Page 8
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Figure 1: Decision Tree for ^Pfnology Selection at Wood Treater Sites
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5 9 OU78
This page intentionally left blank.
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among the recommended technologies, a single
preferred technology can be identified based on the
nine criteria, but that the determination of which
technology is preferred will depend on a few key
variables such as the types of contaminants present and
the feasibility of the technology. Once these factors
are determined, the single recommended approach can
be identified. This conclusion represents a judgement
that, under the circumstances at the site, the preferred
technology will be superior under the nine criteria.
However, the decision tree avoids the need to go
through a full nine-criteria analysis at the site-specific
level; in effect, most of that analysis has already been
performed and the only information needed to
complete the analysis relates to variables specified in
the decision tree.
The presumptive remedy process generally begins at
the point in the overall NCP .process where the
removal and/or remedial site evaluation and Hazard
Ranking System scoring steps have been completed and
development of the RI/FS or EE/CA is about to begin.
The presumptive remedy process streamlines the site
characterization, technology assessment, and remedy
selection steps.
The decision tree describes a presumptive remedy
process that is dynamic, where site characterization, the
evaluation of presumptive remedies, and the
establishment and refinement of remedial action
objectives (including future land use assumptions and
Preliminary Remediation Goats (PRGs)) are conducted
interactively and concurrently. Site managers should
attempt to involve the state, community, and
potentially responsible parties (PRPs) in the
presumptive remedy process as early as possible.
Presumptive remedy options should be evaluated
considering their associated performance efficiencies
and the cleanup levels they might achieve, and the
future land uses that their implementation may make
available. In most cases, treatability studies should be
performed for the treatment technologies being
considered. As discussed previously, the identification
of presumed or likely remedies early in the cleanup
process will allow for a more focused collection of data
on the extent of contamination, eliminate the need for
the initial step of identifying and screening alternatives
during the FS or EE/CA, and streamline the detailed
analysis phase of the FS or EE/CA.
The numbered steps and decision points in Figure 1,
the 'Decision Tree for Technology Selection at Wood
Treater Sites,* correspond to the similarly numbered
paragraphs below. These paragraphs provide
information and the underlying assumptions for each of
the different steps and decision points in the
presumptive remedy process. The decision tree should
be used as a guide through the specific decision poi**"
and considerations that are necessary to choc*
presumptive remedy.
1. Are Creosote, PCP, or CCA Present at the Site?
This document focuses on cleaning up soils,
sediments, and sludges at wood treater sites
contaminated primarily with creosote, PCP, or
CCA; if these contaminants are not present at the
site, the presumptive remedy selection process
outlined in the document is not appropriate for
the site, and the conventional RI/FS or EE/CA
process should be followed. Information on
contaminants present at the site may be available
from data collected during the removal and/or
remedial site evaluation. If this information is
not available, past chemical use at a particular
facility can be ascertained from a number of
sources, such as information from facility records,
past sampling efforts by state or local agencies, or
through information request letters.
2. Initiate Early PHP, State, and Community
Involvement Site managers should initiate a
dialogue with the community, state
representatives, and PRPs early in the process ' '
identifying potential presumptive remedy optic
for a site. This dialogue should include ..
discussion of reasonably anticipated future land
use. This discussion should be beneficial in
establishing remedial action objectives and state
ARARs, which, in conjunction with federal
requirements, may provide PRGs. In addition,
site managers should begin assembling the
Administrative Record for the site.
3. Review Advantages/Limitations Table for
Presumptive Remedies. Using information on the
contaminants present at the site, site managers
should begin reviewing the presumptive remedies
for wood treater sites. Table 1 provides a listing
of the presumptive remedies for wood treater sites
and the contaminants for which they are
applicable. Table 2 provides detailed information
on the advantages, limitations, and costs of each
of the presumptive remedies.
Steps 4 and 5 of the decision tree represent
separate aspects of initial site cleanup activities.
However, these steps should be undertaken
concurrently, with each step using information
obtained from the other step.
Page 10
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5 9
OU79
1 Perfbr
(B), pile
effitienc
otberwis
TABLE 1
Evaluation of Presumptive Remedy Technology Options
v^on^8mjyM*ffts
Present at Site
Organic:
Creosote,
PCP, or
Creosote and PCP
Inorganics:
CCA
Oreanics and Inorganics:
Creosote and CCA;
PCP and CCA; or
Creosote, PCP, and CCA
Presumptive Remedy
Technology Options
Bioremediation
Thermal Desorption
Incineration
Immobilization
Bioremediation, Thermal
Desorption, and/or
Incineration, followed by
Immobilization
Demonstrated Performance
Efficiencies1
64-95% for PAHs and 78-98% for
chlorophenols (F)2
82-99% (BJP ,F)
90-99% (BJ> JO
80-90% TOP3 (B,P,F)
See above
mance represents a range of treatability data. Percentages may vary depending on the contaminant(s).
it- (P), or full-scale (F) demonstration data may not be available for all contaminants. All pert
y data are taken from EPA's Contaminants and Remedial Options at Wood Preserving Sites [8]. unle
e.
Bench-
annance
ss noted
2 These data represent current full-scale performance data for a situ bioremediation conducted at three U.S. wood
treater sites (all of which are listed on the National Priorities List (NPL)) and one Canadian wood treater site. The use
of bioremediation at these four sites achieved remediation goals in all cases. Because the monitoring of biodegradation
at these sites stopped after remediation goals were achieved, actual performance efficiencies at these sites may be higher
than these numbers indicate. For a more detailed discussion of these performance data, see "Full-Scale Performance
Data on the Use of Bioremediation at Wood Treater Sites," a technical background document for the wood treater site
presumptive remedy initiative that is available at EPA Headquarters and the Regional Offices. EPA's Contaminants
and Remedial Options at Wood Preserving Sites (1992) [8] provides the following pilot-scale performance data for
bioremediation: an average of 87% for PAHs and 74% for halogenated phenols and cresols. The effectiveness of
bioremediation tends to be highly variable and very site-specific. A significant component of this variability is the range
of effectiveness in the remediation of different kinds of PAHs; studies on the bioremediation of creosote contamination
indicate that bioremediation works well on 2-, 3-, and often 4-ring PAHs, but generally not as well on 5- or 6-ring
PAHs. For example, the use of ec situ bioremediation at one of the wood treater NPL sites resulted in 95% removal
of 2-ring PAHs, 83% removal of 3-ring PAHs, and 64% removal of 4+-ring PAHs. In practice, in situ bioremediation
typically results in lower performance efficiencies than the ec situ process because in situ reactions are less controlled
and involve lower mass transfer rates. To obtain additional performance data for bioremediation, contact the U.S.
EPA's Center for Environmental Research Information (CERI) at 26 W. Martin Luther King Drive, Cincinnati, Ohio
45268. CERI maintains a bioremediation data base called "Bioremediation in the Field Search System" (BFSS), which
may be accessed electronically through bulletin boards at (301) 589-8366 or (513) 569-7610.
3 TCLP (toririty characteristic leaching procedure) is a specific analytical method; this method has been widely used
in the past to evaluate the performance of immobilization. However, current information indicates that the SPLP
(synthetic precipitation leaching procedure) or other procedures using distilled or site-specific water will produce more
accurate results.
Page 11
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4. Conduct Site Characterization. Site
characterization activities for wood treater sites
using the presumptive remedy process should be
designed to:
Positively identify the site type (Le., a wood
treater site with creosote, PCP, or CCA
contamination);
Obtain data to determine whether the
presumptive remedies are feasible for the
site;
Focus and streamline the collection of data
to support the selection of presumptive
remedies only; and
Collect design data, thereby streamlining the
data collection required during the remedial
or removal design stage.
The overall site characterization process should
proceed using multimedia sampling events
whenever possible. Field screening ^methods
should be integrated into the sampling and
analysis plan to accelerate information gathering.
Data quality objectives must reflect the ultimate
use of the results; consequently, all samples taken
during a single event may not require the same
level of data quality.
Surface lagoons, soil areas, drip pads, and
sediments should be sampled in a grid-like
manner to determine the horizontal and vertical
extent of contamination. Site managers should
ensure that sampling for diorins and furans is
conducted at all wood treater sites known to have
used chlorinated phenols, such as PCP. Soil,
sediment, and sludge characterization relevant to
treatment selection should reflect the information
needs described in Tables 3A-D.
If a wood treating or other chemical at an
abandoned site is still in its original containers, it
should be returned to the manufacturer, if
possible. Where any of the principal wood
treating chemicals (creosote, PCP, or CCA) can
be recovered in high enough concentrations to
warrant reuse in any process, recycling becomes
the preferred technology. The «*y>gnirai U.S.
Waste Exchanges are listed in Appendix A of the
Technology Selection Guide for Wood Treater
Sites [43].
During site characterization, a site-specific
baseline risk assessment (or streamlined risk
evaluation for a removal action) should' be
conducted to characterize materials that constitute
principal threats (Le^ source materials, includr
liquids, that.are highly toxic or highly mol
wastes that generally cannot be reliably container
or would present a significant risk to human
health and the environment should exposure
occur). This risk assessment should be conducted
to determine whether sufficient threats or
potential threats exist to warrant a response
action.
The site-specific risk assessment should be used to
determine remediation goals for the site. Risk-
based remediation goals are often different for
soils, sediments, and sludges at different depths.
Shallow remediation goals are usually based on
direct contact risks, while deeper remediation
goals are usually based on ground-water impacts.
Site managers should consider the ground-water
strategy for the site because remediation goals for
soils, sediments, and sludges are often set to
protect ground-water quality. As discussed above,
existing guidance on the remediation of ground
water [6, 7, 17, 20, 38] and the forthcoming
guidance on a presumptive ground-water
approach, when available, should be consulted.
EPA is currently in the process of developir.
guidance on soil screening levels [30]; these levels
represent contaminant concentrations in soil
below which there is generally no need for federal
concern for the protection of human health in a
residential setting. When the final guidance is
available, site managers should use it as a
screening tool in determining the need for further
assessment of sofl contamination during the RI
stage of cleanups at National Priorities List sites.
For more information on conducting site
characterization activities and risk assessments,
site managers should refer to the references listed
at the end of this document [1, 8,16, 19, 23, 34
35,36].
Establish Remedial Action Objectives (Including
Land Use Assumptions) and Set PRGs.
Promulgated federal and state standards should be
assessed as potential ARARs for the site. As
appropriate, other criteria, advisories, or guidance
should be assessed as potential to be considereds
(TBCs). For a more detailed discussion on
identifying ARARs and TBCs, see the references
listed at the end of this document [3,4,41].
Superfund site managers should also continue to
evaluate the presumptive remedies and begin to
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5V 9 ' OU80
develop remedial action objectives for the site.
The following steps, as depicted in Figure 1,
should be undertaken by site managers.
Review Presumptive Remedies and Associated
Performance Efficiencies
Site managers should continue the review of the
presumptive remedies that was initiated in Step 3,
using additional information on site characteristics
obtained under Step 4. Tables 1 and 2 provide
data on performance efficiencies for the different
presumptive remedy technologies. Information
contained in these tables should be used to focus
the information gathering activities being
conducted under the site characterization step.
Set Preliminary Remediation Goals
As pan of the overall remedial action objectives
for the site, site managers should set PRGs.
Initially, PRGs should be developed based on
readily available information, such as ARARs and
TBCs. . Technical, exposure, and uncertainty
factors should also be used to establish PRGs (see
section 300.430(e)(2) of the NCP). Site managers
should modify PRGs, as necessary, as more
information becomes available. When setting
PRGs for wood treater sites, site managers should
also consider the performance efficiencies of the
different presumptive remedies. In most cases,
treatability studies wfll be necessary to determine
the site-specific capabilities of a specific
presumptive remedy. Reasonably anticipated
future land use(s) of the site should also be
considered when establishing PRGs. Site
managers should consult EPA's guidance on land
use in the Superfund remedy selection process
[27]. This guidance calls for early interaction with
citizens, local governments, and other entities to
gather information to develop assumptions
regarding anticipated future land use. These
assumptions may be used in the baseline risk
assessment, the development of alternatives, and
remedy selection. Refer to Box E (Practical
Considerations) for more information on future
land use considerations.
Prepare Information and Present to Public
It is important that site managers involve the
public at an early stage in the consideration of the
various presumptive remedy options. Site.
managers should encourage the public to review
the advantages and-limitations of the presumptive
remedies against each other and should consider
this public input when selecting a presumptive.
remedy for a site. In particular, efforts should be
made to engage the community and other
interested parties in discussions concerning the
establishment of PRGs and future land use issues.
Input from the community, state representatives,
and PRPs may be obtained through a variety of
methods, such as informal contacts or meetings
with community leaders or groups. This early
input on remedy selection should assist site
managers in fostering community acceptance at
later stages of the presumptive remedy selection
process. Before seeking public input, the site
manager should do the following: (1) contact
Regional community relations staff for
information on community acceptance (if further
assistance is necessary, the individuals listed in
Box B should be contacted); and (2) prepare a
matrix of the applicable presumptive remedy
options for the site. This matrix should contain
data on the performance efficiencies, advantages,
limitations, costs, and implementability of the
various options, and should emphasize the full
range of trade-offs between the alternatives. This
information should be presented to the public to
assist them in providing input on the remedy
selection process. For a more detailed discussion
on holding public meetings and community
relations at Superfund sites, see the references
listed at the end of this document [5,42].
Evaluate Public Reaction to the Presumptive
Remedy Options
If the public reacts favorably to one or more of
the presumptive remedy options, site managers
should proceed to the next step of the
presumptive remedy process. However, if the
public does not react favorably to any of the
presumptive remedy options under consideration,
site managers may wish to consider reviewing
non-presumptive technologies, including
innovative technologies, to determine if there are
other options that may receive greater community
acceptance while providing for sufficient overall
protection of human health and the environment.
If this is the case, a conventional RI/FS or EE/CA
could be performed, or the FS could consider the
presumptive remedy plus any specific alternatives
believed to warrant consideration to establish a
site-specific Administrative Record that supports
the selection of a technology that is not
specifically identified as a presumptive remedy.
Site managers should note that all alternatives
should generally be evaluated in a full nine-
Page 13
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criteria analysis, even if objections are raised by
members of the community. However, if
opposition is intense, it may be justifiable to
screen out an alternative early in the process for
reasons of implementability.
6. Conduct Tune-Critical Removal Action, if
Necessary. Information from site characterization
activities may indicate that the performance of a
time-critical removal action is warranted. If so,
site managers should conduct the removal action
in accordance with the NCP and EPA removal
program guidance. If subsequent non-time-critical
removal actions or remedial actions are still
required at the site, site managers should follow
the presumptive remedy process, if appropriate.
7. Identification of New Contaminants. Continuing
site characterization efforts performed under Step
4 may, at any time, identify new contaminants at
the site. Newly identified contaminants should be
evaluated to determine if their presence precludes
using presumptive remedy technologies or makes
the use of these technologies inappropriate. For
example, the detection of significant DNAPL
contamination of ground water at a site may
indicate that contaminated soils, sediments, or
sludges do not pose a principal human health and
environmental threat and, therefore, may not
require treatment or may only need to be
contained. In these situations, site managers
should follow the presumptive remedy approach
for contaminated ground-water sites, when
available. If newly identified contaminants do
preclude or make inappropriate the use of a
presumptive remedy identified in this document,
this directive may not be applicable and the
conventional RI/FS or EE/CA process may need
to be followed.
8. Refine PRGs. Is There a Need for Further
Action? Using additional information obtained
from the site-specific baseline risk assessment, site
managers should determine whether the site poses
an unacceptable risk to human health or the
environment If the site does not pose an
unacceptable risk, no further action is required.
However, if it appears that an unacceptable risk
does exist, site managers should proceed to the
next step in the presumptive remedy process.
Information from the baseline risk assessment
should be used to refine the PRGs for the site.
9. Proceed with Technology Assessment and Review
"Practical Considerations." After it has been
determined that a cleanup action is warranted at
the site, site managers should review the different
presumptive remedy options and identify a
proposed option. For a remedial acpv "
presumptive remedy options must be evalu
against the nine criteria required by sect* __
300.430(e)(9) of the NCP; this should be
documented in the detailed analysis section of an
FS or Focused FS. Appendix A of this document
the analysis EPA conducted on
FSs/RODs for wood treater sites with
contaminated soils, sediments, or sludges, and
Appendix B provides generic evaluations of the
different presumptive remedies against seven of
the nine remedial criteria (excluding state and
community acceptance). Both of these appendices
should be used to streamline the detailed analysis
phase of the FS. Appendices A and B can also be
used to streamline the evaluation of removal
action alternatives in an EE/CA. The generic
analyses in Appendix B should be supplemented
with site-specific information for the final
response selection. During technology
assessment, the factors listed in the "Practical
Considerations" section (Box E) of this document
should be reviewed to ensure a comprehensive
evaluation of response alternatives.
10. Begin the Technology Selection Process Based r
the Types of Contamination Present at the Si
If the only contaminants present at significant
levels (Le., levels that may justify treatment) are
inorganics, site managers should follow Path A in
Figure 1 (Le., proceed to Step 11) and evaluate
the feasibility of immobilization. If the only
contaminants present at significant levels are
organics, site managers should follow Path B in
Figure 1 (Le., proceed to Step .12) and evaluate
the feasibility of bioremediation. In situations
where significant levels of both inorganic and
organic contamination are present at the site, site
managers should follow Paths A and B
concurrently. In these situations, a treatment
train should be implemented that uses
bioremediation, thermal desorption, and/or
incineration to address the organic contaminants
and immobilization to address the inorganic
contaminants.
11. Is Immobilization Feasible? Immobilization is the
primary presumptive remedy for addressing
significant levels of inorganic contamination in
soils, sediments, and sludges at wood treater sites.
If immobilization is not considered feasible for
addressing inorganic contaminants present-ai th
site, this document is not applicable and site
managers should review other non-presumptive
Page 14
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\
technologies. If the use of immobilization is
feasible, site managers should proceed to Step 15.
12. Is Bioremediation Feasible? Bioremediation is
the primary presumptive remedy for treating
organic contamination of soils, sediments, and
sludges at wood treater sites. However, the
effectiveness of bioremediation is very site- and
contaminant-specific. In addition, implementation
of bioremediation remedies requires considerably
more time than the implementation of the other
presumptive remedies (Le., several years for
bioremediation as compared to approximately six
months to a year for thermal desorption and
incineration). Bioremediation can successfully
treat soils, sediments, and sludges contaminated
with organic contaminants such as halogenated
phenols and cresols, other polar organic
compounds, non-halogenated aromatics, and
PAHs (particularly 2- and 3-, and often 4-ring
compounds). However, bioremediation may not
be feasible if a site exhibits high levels of
concentrated residual creosote or dioxins and
furans. Pilot/treatability study testing should be
conducted to assess the feasibility t>f using
bioremediation at a site. If the use of
bioremediation is feasible, site managers should
proceed to Step 15. If the use of bioremediation
is not feasible, site managers should assess the use
of thermal desorption.
13. Is Thermal Desorption Feasible? / If
bioremediation wfll not be sufficiently effective in
achieving PRGs for the site, thermal desorption
should be considered as the presumptive remedy
for addressing organic contamination. Treatability
studies should be conducted (including a Proof of
Performance test if dioxin and/or furan formation
is a concern) to ensure that thermal desorption is
feasible for the site and will achieve the desired
PRGs. If the use of thermal desorption is
feasible, site managers should proceed to Step 15.
If the use of thermal desorption is not feasible,
site managers should assess the use of
incineration.
14. Is Incineration Feasible? If high contaminant
concentrations and/or treatability testing indicate
that thermal desorption will not achieve the
desired PRGs for the site, incineration should be
considered as the presumptive remedy. If the use
of incineration is feasible for the site, site
managers should proceed to Step 15. If none of
the three presumptive remedy options for treating
organic contaminants are considered feasible for
the site, this document is not applicable and site
5 9 0081
managers should review other non-presumptive
technologies.
15. Proceed with ROD or Action Memorandum. At
this point in the process, site managers should
possess sufficient information to set final
remediation goals and identify a preferred
presumptive remedy option. This preferred
option should be presented to the public for
review and comment in the proposed plan.
Because substantial community input has already
been factored into the remedy selection process
under Step 5, it is envisioned that significant
negative input from the public should not be
received at this point
The final step in the selection of a presumptive
remedy is to document the decision in a ROD for
a remedial action or an Action Memorandum for
a removal action. As was discussed above, if a
presumptive remedy is selected in the ROD or
Action Memorandum, a copy of this document
and its accompanying attachments must be
included in the Administrative Record for the
site. These materials will assist in justifying the
selection of the presumptive remedy, and will
support the elimination of the initial screening
step of the FS or EE/CA and the streamlining of
the detailed analysis phase of the FS or EE/CA.
CONCLUSION
The presumptive remedies for cleaning up soils,
sediments, and sludges at wood treater sites that are
contaminated primarily with creosote, PCP, or CCA
are bioremediation, thermal desorption, incineration,
and immobilization. Bioremediation is the primary
presumptive remedy for treating organic contaminants,
followed by thermal desorption and incineration,
respectively. Immobilization is the primary
presumptive remedy for treating inorganic
contaminants. Based on site-specific information and
remediation goals established for the site, one or more
of these treatment technologies should be selected. If
a wood treater site does not meet the conditions
described in this document, the document is not
applicable and the conventional remedy selection
process should be followed.
Page 15
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BOXO
Background Information on NAPL Contamination
A non-aqueous phase liquid (NAPL) is a liquid that, in its pure form, does not readily mix with water but slowly
partitions into the water phase. Dense NAPLs (DNAPLs) sink in water, while light NAPLs (LNAPLs) float on water.
When present in the subsurface, NAPLs slowly release vapor and dissolved phase contaminants, resulting in a zone of
contaminant vapors above the water table and a plume of dissolved contaminants below the water table. The term
NAPL refers to the undissolved liquid phase of a chemical or mixture of compounds, and not to the vapor or dissolved
phases. NAPLs may be present in the subsurface as either "free-phase* or "residual-phase" NAPLs. The free-phase is
that portion of the NAPL that can continue to migrate and can flow into a well The residual-phase is that .portion
trapped in pore spaces by capillary forces, which cannot generally flow into a well or migrate as a separate liquid. Both
residual* and free-phase NAPLs are sources of vapors and dissolved contaminants.
The most common LNAPLs are petroleum fuels, crude oils, and related chemicals, which tend to be associated with
facilities that refine, store, or transport these liquids. The following factors tend to make LNAPLs generally easier to
locate and clean up than DNAPLs: (1) LNAPL contamination tends to be more shallow than DNAPL contamination;
(2) LNAPLs tend to be found at the water table; and (3) LNAPLs are usually associated with specific types of facilities.
However, LNAPL contamination that is trapped in soil pores below the water table may not be significantly easier to
remediate than DNAPL contamination in the saturated zone.
DNAPLs pose difficult cleanup problems. These contaminants include chemical compounds and mixtures with a wide
range of chemical properties, including chlorinated solvents, creosote, coal tars, PCBs, PCP, and some pesticides. Some
DNAPLs, such as coal tars, are viscous chemical mixtures that move very slowly in the subsurface. Other DNAPLs,
such as some chlorinated solvents, can travel very rapidly in the subsurface because they are heavier and less viscous
than water. A large DNAPL spill not only sinks vertically downward under gravity, but can spread laterally with
increasing depth as it encounters finer grained layers. These chemicals can also contaminate more than one aqtr"
by penetrating fractures in the geologic layer that separates a shallow aquifer from a deeper aquifer. Thus, large rele
of DNAPLs can penetrate to great depths and can be very difficult to locate and dean up.
The contamination problem at DNAPL sites has two different components: (1) the aqueous contaminant plume, and
(2) the DNAPL zone, as shown in Figures D-l and D-2. The aqueous contaminant plume includes those portions of
the site where only dissolved contaminants are present in ground water. The DNAPL zone includes those portions of
the site where immiscible liquids are present in the subsurface, either as free-phase or residual-phase compounds.
Depending on the volume of the release and the subsurface geology, the DNAPL zone may extend to great depths and
over large lateral distances from the entry location.
For a more detailed discussion on DNAPL contamination, see the references listed at the end of this document [7,10,
11,12,13,15,17].
)
1
Page 16
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5 9 'OU82
BOXD
Background Information on NAPL Contamination
(continued)
FIGURE D-1
Components of DNAPL Sites
MUH.XBM
HUrLEMryLMMton
FIGURE D-2
Types of DNAPL Contamination and Contaminant Zones at DNAPL Sites
(Cross-Sectional View)
Page 17
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BOXE
Practical Considerations
Land use: In general, remedial action objectives should be formulated to identify response
alternatives that will achieve cleanup levels appropriate for the reasonably anticipated future land use
of a site. Early community involvement, with a particular focus on the community's desired future
uses of property associated with the site, should result in a more democratic detisionmaking process,
greater community support for remedies selected as a result of this process, and, in many cases, more
expedited cleanups. Factors to consider may include: any recommendations or views expressed by
members of the affected community, the land use history and current uses of the facility and
surrounding properties, and recent development patterns where the facility is located; and the
proximity of the contamination to residences, sensitive populations or ecosystems, natural resources,
or areas of unique historic or cultural significance. For example, if it is anticipated that a site will
be used for future industrial/commercial development, it may be appropriate to select a presumptive
remedy (e.g., in situ bioremediation) that results in higher residual contaminant levels but is less costly
than other options. EPA has developed guidance on land use in the Superfund remedy selection
process [27].
Institutional and/or engineering controls: It may be appropriate to use institutional and/or
engineering controls in conjunction with the presumptive remedy technologies described in this
document to reduce current or potential human exposure via direct contact with contaminated soils,
sediments, and sludges or through the use of contaminated ground water. Engineering controls are
physical systems requiring construction and maintenance, such as soil caps, caps with liners, and
vertical barrier walls. Institutional controls include the use of physical barriers, such as fences and
warning signs, and the use of administrative restrictions, such as deed or lease restrictions. When
vigorously enforced, institutional controls limit direct contact with and jngestion of soils, sediments,
and sludges; however, unlike some engineering controls (e.g., caps), institutional controls do not
reduce the potential ..for wind dispersal and inhalation of contaminants. Monitoring is generally
needed to determine the effectiveness of institutional and/or engineering controls.
Institutional and/or engineering controls alone do not satisfy CERCLA's preference for achieving
reductions of toxicity, mobility, or volume through treatment as a principal element of the remedy.
Consequently, they are not generally recommended as the sole response to address contaminants that
are deemed a principal threat at wood treater sites. However, the use of institutional and/or
engineering controls after the treatment of a principal threat by one or more of the presumptive
remedy technologies can enhance the long-term reliability of the remedy.
A cap is an engineering control that may be particularly useful in improving the overall protection
of a presumptive remedy. A simple cap may involve only covering the treated area with
uncontaminated native soil and/or seeding, fertilizing, and watering the area until vegetation has been
established. A simple cap (soil only) may be appropriate for situations where direct contact and/or
erosion are the prime threats, and is particularly appropriate following bioremediation because it
ensures oxygen availability for continuing biodegradation. Caps that are intended to prevent surface
water infiltration are typically comprised of soil and several other components, including a drainage
layer, a geomembrane, and a compacted clay layer. Such caps, in addition to being effective in
limiting direct contact exposure and reducing erosion, are also effective in limiting surface water
infiltration, minimizing the vertical migration of residual contaminant^ and minimizing ground-water
contamination. However, caps that prevent infiltration will inhibit aerobic biodegradation, which
generally makes the use of such caps following bioremediation inappropriate. For a more detailed
discussion on the factors affecting the appropriate uses of caps, refer to the references listed at the
end of this document [14,18, 29].
Page 18
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5 9 0033
BOXE
Practical Considerations
(continued)
Treatment trains: A single technology may not be sufficient to clean up an entire wood treater site.
Remediation of sites often requires a combination of control and treatment options in order to
sufficiently reduce toxicity and immobilize contaminants. The treatment train concept combines
pretreatment and/or post-treatment activities with treatment technologies to achieve site-specific
objectives and acceptable residual contaminant levels. For example, the implementation of a remedy
might include institutional controls to control direct contact exposure, bioremediation to treat organic
contamination (including excavation, capping, and monitoring activities), and immobilization to treat
residual inorganic contamination. The pretreatment and post-treatment portions of the treatment
train should be selected based on site-specific considerations.
"Hot spots': Hot spots (e.g., highly contaminated sludges) are generally defined as discrete areas
within a site that contain hazardous substances, pollutants, or contaminants that are present in high
concentrations, are highly mobile, or cannot be reliably contained, and would present a significant risk
to human health or the environment should exposure occur. Hot spots will usually be considered
principal threats at a site, as defined by the NCP. Site managers should be aware that the limitations
of certain presumptive remedies (e.g., bioremediation) may preclude their use in cleaning up certain
hot spots. In addition, responding to hot spots may require additional pretreatment and post-
treatment activities, such as the use of institutional controls or capping. (For additional information,
see the references listed at the end of this document [23].)
Land disposal restrictions (LDRs): All technologies that treat hazardous waste ex situ may cause the
waste being treated to be subject to RCRA LDRs. In situ treatment of hazardous waste does not
trigger LDRs because "placement* of the waste does not occur. LDRs establish treatment standards
that must be met before a waste can be land disposed. These treatment standards are either
concentration-based (hazardous constituents must be reduced to a set concentration) or, less
frequently, technology-based (waste must be treated using a specified technology). EPA has
promulgated LDR treatment standards for specific wood preserving wastes (K001 - sediments and
sludges from the treatment of wastewaters resulting from processes using creosote or PCP) and
anticipates proposing treatment standards for other wood preserving wastewaters in 1995. The
Agency has also promulgated LDR treatment standards for RCRA characteristic wastes. If a wood
treater waste exhibits one or more of the identified hazardous characteristics, it is subject to RCRA
LDRs.
Wood treater wastes that qualify as "remediation wastes" and are placed in a Corrective Action
Management Unit (CAMU, see 58 FR 8658-8685), whether at a Superfund site or RCRA corrective
action site, do not have to meet LDRs. (Whether LDRs are triggered depends on whether
remediation wastes are "placed" in a land-based unit, not on whether they are treated. LDRs do not
apply to remediation wastes treated on-site and then placed in a CAMU.) The EPA Region is
responsible for setting site-specific requirements for a CAMU, which could include LDRs. The LDR
program also provides four exceptions to meeting LDRs that may be applicable to wood treater sites:
(1) the treatabiliry variance (see 40 CFR 268.44); (2) equivalent treatment; (3) the no-migration
exemption (see 40 CFR 268.6); and (4) de-listing. The treatability variance is anticipated to be the
primary route of compliance with LDRs for contaminated soil and debris; for more information, see
the references at the end of this document [39, 40]. Site managers should consult with Regional
RCRA program staff when addressing LDR issues at specific wood treater sites.
Page 19
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TABLE 2
Comparison of Presumptive Remedy Technologies
Note: Performance represents a range of treatabillty data. A number of variables, such as concentration and distribution of contaminants, matrix particle size,
and moisture content can affect system performance. Bench- (B), pilot- (P), or full-scale (F) performance data may not be available for all contaminants. The
performance efficiency data are taken from U.S. EPA's Contaminants and Remedial Options at Wood Preserving Sites [8], unless noted otherwise.
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
Bloremedlaflon
(ex situ)
64 - 95% for PAHs,
78 - 98% for
chlorophenols (F)1
More suitable for higher concentrations of
organic contaminants than in situ processes.
Solid-phase treatment has been successfully
demonstrated at wood treater sites.''
Generally receives wide community
acceptance.
May require treatability studies due to a
scarcity of full-scale performance data.
Bench- or pilot-studies may be necessary.
Efficiency limited by lack of indigenous
microbes, toxic metals, highly chlorinated
organics, pH outside of 4.5 - 8.5 range,
limited growth factors, or rainfall/
evapotranspiration rate/percolation rate
ratio too high or too low.
Increases the volume of treated materials if
bulking agents are added.
Excavation and material handling add to
costs.
Land treatment of wastes Is subject to land
disposal restrictions (LDRs), unless "no-
migration" is demonstrated.
$50 - $150 per cubic
yard of soil, sediment,
or sludge; or
approximately $40 -
$125 per ton of soil,
sediment, or sludge.
1 These data represent current full-scale performance data for bioremediation conducted at three U.S. wood treater sites (all three of which are
listed on the NPL) and one Canadian wood treater site. The use of bioremediation at these four sites achieved remediation goals in all cases. Because
the monitoring of biodegradation at these sites stopped after remediation goals were achieved, actual performance efficiencies at these sites may be higher
than these numbers indicate. For a more detailed discussion of these performance data, see "Full-Scale Performance Data on the Use of Bioremediation
at Wood Treater Sites," a technical background document supporting the wood treater site presumptive remedy initiative that is available at EPA
Headquarters and Regional Offices. EPA's Contaminants and Remedial Options at Wood Preserving Sites (1992) [8] provides the following pilot-scale
performance data for bioremediation: an average of 87% for PAHs and 74% for halogenated phenols and cresols. The effectiveness of bioremediation
tends to be highly variable and very site-specific. A significant component of this variability is the range of effectiveness in the remediation of different
kinds of PAHs; studies on the bioremediation of creosote contaminatio'n indicate that bioremediation works well on 2-, 3-, and often 4-ring PAHs, but
generally not as well on 5- or 6-ring PAHs. For example, the use of ex situ bioremediation at one of the wood treater NPL sites resulted in 95% removal
of 2-rlng PAHs, 83% removal of 3-ring PAHs, and 64% removal of 4-f-ring PAHs. To obtain additional performance data for bioremediation, contact
the O.S. EPA's Center for Environmental Research Information (CER1) at: 26 W. Martin Luther King Drive, Cincinnati, Ohio 45268. CERI maintains
a bioremediation data base called "Bioremediation in the Field Search Sys""n" (BFSS), which may be accessed electronically through bulletin ' ~rds
at 589-8366 or (513) 569-7610.
-------
Comparison of Presumptive Remedy Technologies
(continued)
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
nioremedlatlon
(in situ)
51% for PAHS,
72% for PCP (F)*
Suitable for moderate concentrations of
organic contaminants.
Can destroy organic contaminants In place
without the high costs of excavation and
material handling.
V
Minimizes the release of volatile
contaminants into the air.
Generally receives wide community
acceptance.
May require treatability studies due to a
scarcity of full-scale performance data.
Bench- or pilot-scale studies may be
necessary.
Efficiency limited by lack of Indigenous
microbes, toxic metals, highly chlorinated
organlcs (e.g., even high levels of PCP), pH
outside of 4.5 - 8.5 range, limited growth
factors, non-uniform contaminant
distribution, or rainfall/evapotranspiratlon
rate/percolation rate ratio too high or too
low. For example, low-permeability soils
can hinder performance; however, hydraulic
1 fracturing or other methods may be used to
overcome this problem, at higher operating
costs.
Cannot be used to directly destroy
concentrated masses of non-aqueous phase
liquids (NAPLs).
$50 - $100 per cubic
yard of soil, sediment,
or sludge.
2 These data represent current full-scale performance data from a bioremediation demonstration project conducted at a Canadian wood treater site.
Because the monitoring of biodegradation at this site stopped after a certain point, actual performance efficiencies at this site may be higher than these
numbers Indicate. For a more detailed discussion of these performance data, see "Full-Scale Performance Data on the Use of Bioremediation at Wood
Treater Sites," a technical background document supporting the wood treater site presumptive remedy initiative that is available at EPA Headquarters
and Regional Offices. EPA's Contaminants and Remedial Options at Wood Preserving Sites (1992) [8] provides the following pilot-scale performance
data for bioremediation: an average of 87% for PAHs and 74% for halogenated phenols and cresols. The effectiveness of bioremediation tends to be
highly variable and very site-specific. A significant component of this variability is the range of effectiveness in the remediation of different kinds of
PAHs; studies on the bioremediation of creosote contamination indicate that bioremediatidn works well on 2-, 3-, and often 4-ring PAHs, but generally
not as well on 5- or 6-ring PAHs. In practice, in situ bioremediation typically results in lower performance efficiencies than the ex situ process because
in situ reactions are less controlled and Involve lower mass transfer rates. To obtain additional performance data for bioremediation, contact the U.S.
EPA's Center for Environmental Research Information (CERI) at: 26 W. Martin Luther King Drive, Cincinnati, Ohio 45268. CERI maintains a
bioremediation data base called "Bioremediation in the Field Search System" (BFSS), which may be accessed electronically through bulletin boards at
(30H589-8366 or (513) 569-7610.
en
vc
o
CO
-------
TABLE 2
Comparison of Presumptive Remedy Technologies
(continued)
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
Thermal
Desorptlon
82 - 99% (B.P.F)
Thermal treatments are well-established
technologies for treating organic-
contaminated media.
Thermal desorptlon can often produce a
treated waste that meets treatment' levels
set by the Best Demonstrated Available
Technology (BOAT) requirements of the
RCRA land disposal ban.
May warrant treatabilily studies due to a
scarcity of full-scale performance data.
Bench- or pilot-studies may be necessary.
Design and operation of unit and associated
air pollution control devices must take into
account the possible presence of
halogenated organics, mercury, or corrosive
contaminants.
Inorganic constituents that are not
particularly volatile will not be effectively
removed by thermal desorptlon.
I
If chlorine or chlorinated compounds are
present, some volatilization of inorganic
constituents In the waste may occur.
The contaminated medium must contain at
least 20 - 30% solids in order to facilitate
placement of waste material Into treatment
equipment.
Wastes with high-moisture content may
need to be dewatered prior to processing in
order to control costs and achieve desired
performance.
Material handling of soils, sediments, or
sludges that are tightly aggregated or largely
clay can result in poor processing
performance due to caking.
$150 - $400 per ton of
soil, sediment, or
sludge, excluding
excavation, material
handling, or disposal
costs.
-------
:2
Comparison of Presun.. ,e Remedy Technologies
(continued)
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
Thermal
Desorptlon
(continued)
If a high fraction of fine silt or clay exists in
the matrix, fugitive dusts will be generated
and a greater dust loading will be placed on
the downstream air pollution control
equipment.
The total organic loading is limited by some
thermal treatment systems to 10% or less
to ensure that Lower Explosive Limits
(LELs) are not exceeded.
A medium exhibiting a very high pH
(greater than 11) or low pH (less than 5)
may corrode thermal system components.
The treatment process may alter the
physical properties of the treated material,
particularly where waste matrices have a
high clay content. The treated product
should be evaluated to determine if the
product should be mixed with other
stabilizing materials or compacted.
Excavation and material handling add to
costs.
With chlorinated feed, potential for dloxin
and/or furan formation exists. Systems
must be designed and operated carefully.
A full-scale Proof of Performance test, with
dioxin and furan analysts If chlorinated feed
is present, should precede cleanup
operations.
CO
cn
-------
TABLE 2
Comparison of Presumptive Remedy Technologies
(continued)
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
Incineration
90 - 99% (B.P.F)
Ensures that specified cleanup levels can be
achieved for a given site.
Can effectively remove nearly all
contamination.
High moisture content reduces capacity of
Incinerator.
Incineration of large volumes of
contaminants may be prohibitively
expensive.
Efficiency may be limited by high alkali
metals or elevated levels of mercury or
organic phosphorous.
If a high fraction of fine silt or clay exists in
the matrix, fugitive dusts will be generated
and a greater dust loading will be placed on
the downstream air pollution control
equipment.
A medium exhibiting a very high pH
(greater than 11) or low pH (less than 5)
may corrode incineration system
components.
Excavation and material handling add to
costs.
On-slte incineration has the potential for
community concern/opposition.
$150 - $400 per ton of
soil, sediment, or
sludge, excluding
excavation, material
handling, or disposal
costs.
-------
1 12
Comparison of Presumptive Remedy Technologies
(continued)
TECHNOLOGY
PERFORMANCE
ADVANTAGES
LIMITATIONS
COST
Immobilization
80 - 90% TCLP1
(B.P.F)
Treatabillty test data indicate that metals in
wood preservatives are amenable to
solidification/stabilization.
Prevents/mitigates ground-water
contamination.
",
Controls population exposure.
Effectively contains contaminants.
Reduces air emissions.
High levels of organic compounds can
retard or prevent setting of typical
solidification/stabilization matrices.
The particular solidification/stabilization
system that will perform well on a given
contaminated material must be determined
by site-specific screening and treatablllty
tests.
Efficiency may be limited by total
petroleum hydrocarbon (TPH) content
greater than 1%, or humic matter greater
than 20%.
$75 $400 per ton
(with landfltling on-slte)
and $100 - $500 per
ton (with landfllling 200
miles off-site).
Capping
N/A (not a treatment
technology)
Capping reduces surface-water infiltration,
reduces gas and odor emissions, Improves
aesthetics, and provides a stable surface
over the waste.
Reduces direct contact exposure.
Capping costs escalate as a function of
topographic relief.
Does not treat contamination;
contamination Is left in place.
-May slow down natural bioremediatlon
processes.
$1 - $16 per cubic yard
of capping material.
tn
3 TCLP (toxlcity characteristic leaching procedure) is a specific analytical method; this method has been widely used in the past to evaluate the
performance of immobilization. However, current information indicates that the SPLP (synthetic precipitation leaching procedure) or other procedures
using distilled or site-specific water will produce more accurate results.
o
c
CO
o\
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TABLE 3-A
Data Requirements for Bioremediation
DATA REQUIREMENT
General Data Requirements
Biochemical oxygen
demand (BOD)
Chemical oxygen demand
(COD)
Contaminant solubility
Degradation rates of
contaminants
Indigenous microorganisms
Inorganic contaminants
Limiting initial and final
concentrations of
contaminants
Metals, inorganic salts
concentrations
Moisture content
Nutrients
Oil and grease content
Organic content
Particle size
Total organic carbon
(TOQ
IMPORTANCE OF INFORMATION
Provides estimate of biological treatabiliry of soil, sediment, or sludge.
Another estimate of biological treatability. The measure of the oxygen
equivalent of organic content that can be oxidized by a strong chemical
oxidant
Components with low solubility are difficult to remove from soil, sediment,
or sludge because of low bioavailability.
Should be determined through treatability studies. Important to determine
applicability of remedy.
The PAH biodegradation activity of indigenous organisms must be
measured to determine if appropriate microorganisms are present in
sufficient quantity.
Important to determine applicability of remedy.
Should be determined through treatability studies with respect to the
specific process.
High metal concentrations may inhibit microbial activity. Some inorganic
salts are necessary for biological activity.
May inhibit solid-phase aerobic remediation of soils, sediments, or sludges if
greater than 80% of field capacity; soil, sediment, and sludge remediation
inhibited if less than 40% of field capacity. Soil slurry reactors may operate
with 80-90% moisture content (water/weight of soil).
Lack of certain nutrients reduces activity.
Oil and grease concentrations may inhibit soil, sediment, and sludge
remediation at concentrations greater than 5% by weight, which may result
in unacceptable lag times.
Important to determine applicability of remedy. Important to determine
horizontal and vertical extent of contaminants and to ensure that
appropriate detection limits are used.
Particle size affects access and contact between microorganisms,
contaminants, nutrients, water, and electron acceptors.
Indicates total organic carbon present and can be used to estimate waste
available for biodegradation.
Page 26
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5 9
OU37
TABLE 3-A
Data Requirements for Bioremediation
(continued)
DATA REQUIREMENT
IMPORTANCE OF INFORMATION
General Data Requirements (continued)
Variable waste
composition
Redox potential (Eh)
Large variations affect biological activity.
Aerobic degradation: oxidation-reduction potential of the soil, sediment, or
sludge must be greater than that of the organic contaminant for oxidation to
occur.
Specific In Situ Data Requirements
Soil, sediment, or sludge
temperature
Position of water table
Site geology
Soil, sediment, or sludge
permeability
High or low temperatures affect microbial activity for in situ treatment (high
temperatures tend to increase activity, low temperatures tend to decrease
activity).
Important for remedy selection and implementation.
Important to determine mass transfer capability.
Affects movement of water, oxygen, and nutrients for in situ treatment.
X
Specific Ex Situ Data Requirements
Tenacity Characteristic
Leaching Procedure
(TCLP) analysis
Needed to determine if the soil, sediment, or sludge is a RCRA hazardous
waste.
Page 27
-------
TABLE 3-B
Data Requirements for Thermal Desorption
DATA REQUIREMENT
Bulk density of soil,
sediment, or sludge
Contaminant physical
properties
Inorganic contaminants
Metals content
Extent of organic
contaminants
Moisture content
Sulfur, chlorine, and
organic phosphorous
content
Particle size
^ x
pH
Salt content
Soil, sediment, or sludge
plasticity
Toricity Characteristic
Leaching Procedure
(TCLP) analysis
Flashpoint of soU,
sediment, or sludge
Total organic carbon
(TOC)
Total chloride
IMPORTANCE OF INFORMATION
Used in converting weight to volume in material handling calculations.
Information on physical properties, such as boiling point, determines the
required characteristics of the thermal desorption unit.
Important to determine applicability of remedy.
Metals (As, Cd, Cr, Pb, ZD) can vaporize at high temperatures and must be
removed from emissions.
Need to determine horizontal and vertical extent of organic contamination
to be excavated.
High moisture content increases feed handling and energy requirements.
Contribute to acid gas formations at high concentrations.
Oversized debris hinders processing. Fine particles can result in high
paniculate loading in flue gasses. Clay content will impede material
handling and may interfere with waste processing.
Extreme pH may be harmful to equipment.
High salt content, depending on temperature, may cause material in the
thermal unit to slag.
Plastic soil, sediment, or sludge, when subjected to compressive forces, can
become molded into large particles that are difficult to heat
Needed to determine if the soil, sediment, or sludge is a RCRA hazardous
or listed waste.
Important to determine safe temperature parameters for the desorber unit.
Provides estimate of material available for combustion, which may affect the
temperature range available for thermal desorption.
Influences metal partitioning to the gas phase.
Page 28
-------
5 9 0038
TABLE 3-C
Data Requirements for Incineration
DATA REQUIREMENT
Bulk density of soil,
sediment, or sludge
Contaminant combustion
characteristics
Heating value
Inorganic contaminants
Metals content
Extent of organic
contaminants
Moisture content
Sulfur, chlorine, and
organic phosphorous
content
Particle size
PH
Salt content
Soil, sediment, or sludge
plasticity
Toritiry Characteristic
Leaching Procedure
(TCLP) analysis
Total organic carbon
(TOC)
IMPORTANCE OF INFORMATION
Used in converting weight to volume in material handling calculations.
Required to determine the incinerator's combustion characteristics.
Affects throughput and energy requirements.
Important to determine applicability of remedy.
Metals (As, Cd, Cr, Pb, Zn) can vaporize at high temperatures and are
difficult to remove from emissions.
Need to determine horizontal and vertical extent of organic contamination
to be excavated due to cost concerns.
High moisture content increases feed handling and energy requirements.
Contribute to acid gas formations at high concentrations.
Oversized debris hinders processing. Fine particles can result in high
paniculate loading in flue gasses.
Extreme pH may be harmful to equipment
High salt content will cause material in the incinerator to slag.
Plastic soil, sediment, or sludge, when subject to compressive forces, can
become molded into large particles that are difficult to heat
Needed to determine if soil, sediment, or sludge is a RCRA hazardous or
listed waste.
Provides estimate of material available for combustion.
Page 29
-------
TABLE 3-D
Data Requirements for Immobilization
DATA REQUIREMENT
Coal or lignite content
Cyanides content
Halide content
Inorganic salts content
Metals content
Phosphate concentration
Oil and grease content1
Organic content1
Particle size
Phenol concentration ^ x
Sodium arsenate, borate,
phosphate, iodate, sulfide,
sulfate, carbohydrate
concentrations
Solids content
Semi-volatile organics
Volatile organic
concentrations
IMPORTANCE OF INFORMATION
May affect product quality.
Affects bonding (greater than 3,000 ppm).
Retards setting; leaches easily.
Reduces product strength and affects curing rates (soluble salts of Mn, Sn,
Zn, Cu, and Pb).
Important for process considerations.
Phosphate is a key reagent in some solidification/stabilization mixes to
reduce metals (especially Pb) solubility, in high concentrations, phosphate
may cause problems.
Affects cementation, mix design, and cost
Affects cementation, mix design, and cost
Affects bonding (if less than 200 mesh or greater than 1/4 inch diameter).
Concrete is able to use larger particles.
Affects product strength (greater than 5%).
Retards setting and affects product strength.
i
Low solids content indicates that de-watering is needed.
Requires the use of special mixes, and may inhibit bonding
(if greater than 10,000 ppm).
Volatiles have not been successfully treated with solidification/stabilization
alone; volatiles should be removed or otherwise treated.
1 Immobilization with lime or proprietary additives has been used to treat oily soils and petroleum sludge at petroleum
industry sites; however, the structural properties of the product are poor, even when the material passes the TCLP
(Tcoticity Characteristic Leaching Procedure). High concentrations (e.g., greater than 20%) of naturally-occurring
bumic matter may also interfere with cement-based processes, but some success with higher levels of organics has been
reported using modified lime products.
Page 30
-------
5 9 OU39
APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
This Appendix summarises the analyses that EPA conducted on Feasibility Study (FS) and Record of
Decision (ROD) data from Superfund wood treater sites, which led to establishing bioremediation, thermal
desorption, incineration, and immobilization as the presumptive remedies for wood treater sites with
contaminated soils, sediments, and sludges. The analyses consisted of the following activities:
Identifying wood treater sites;
Determining the frequency of technology selection for wood treater sites;
Identifying sites for the FS/ROD analysis; and
Conducting the FS/ROD analysis.
Results of the FS/ROD analysis, along with a technical analysis of performance data on technology
application, are part of the Administrative Record for this directive, which is available at EPA Headquarters
and the Regional Offices. These analyses provide support for the decision to eliminate the initial alternatives
identification and screening step for this site type. These analyses found that certain technologies are
appropriately screened out based on effectiveness, implementability, and/or cost. Review of technologies
against the nine remedial criteria led to elimination of additional alternatives. A discussion of each of the
analyses is provided below.
Identification of the Universe of Wood Treater Sites
EPA identified the universe of wood treater sites listed on the National Priorities List from information
contained in the following two sources: (1) Contaminants and Remedial Options at Wood Preserving Sites,
U.S. EPA, EPA/600/R-92/182,1992; and (2) Innovative Treatment Technologies: Annual Status Report (Sixth
Edition), U.S. EPA, EPA 542-R-94-005,1994. The first source contained comprehensive lists of NPL and
non-NPLwood treater sites prior to 1991 The second source contained information, current as of 1994, on
the status of the implementation of innovative treatment technologies at a wide range of sites, including
wood treater sites. By cross-checking the information in both of these documents, an overall list of 58 NPL
wood treater sites was identified.
Table A-l presents the distribution of remedial technologies selected at 52 of the 58 NPL wood treater sites
(data on remedy selection were not available for the remaining six sites). These data were obtained from
the two sources cited above and EPA's Superfund Records of Decision CD-ROM data base (March 1995).
Table A-l demonstrates that the four wood treater site presumptive remedies (bioremediation, thermal
desorption, incineration, and immobilization) together were selected more often (39 out of the 50 sites for
which remedy selection information was available, or approximately 78% of the time) than the other
applicable technologies. Bioremediation, the primary presumptive remedy for treating organic contamination,
was the remedy selected more often than any other technology (18 out of the 50 sites, or approximately 36%
of the time).
Page 31
-------
APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES (continued)
TABLE A-1
Remedies Selected at NPL Wood Treater Sites
Primary Technologies
Selected to Address
Contaminated Soils,
Sediments, and Sludges at
Wood Treater Sites
Bioremediation
Thermal Desorption
Incineration
Immobilization
Dechlorination
Solvent Extraction
Soil Flushing/Washing
Landfillinp
Institutional
Controls/Monitoring
To Be Determined2
Total Number of
Sites Selecting
Technology1
18
3
13
13
2
1
6
4
2
2
1 The total number of primary technologies selected is greater than the total of 50 sites for which remedy
selection data were available because several sites selected more than one primary technology to address
the principal threat of contaminated soils, sediments, and sludges (e.g., bioremediation to treat organic
contamination and immobilization to treat inorganic contamination). Secondary technologies selected as
pan of a treatment train are not documented in this table.
2 Remedial technology for contaminated soils, sediments, and/or sludges not yet selected.
Identification of Sites for the FS/ROD Analysis
The purpose of the FS/ROD analysis was to document the technology screening step and the detailed
analysis in the FSs/RODs of wood treater sites, and to identify the principal reasons given for eliminating
technologies from further consideration. To achieve a representative sample of FSs/RODs for the
analysis, sites were selected according to the following criteria:
Page 32
-------
5 9 0090
APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES (continued)
Sites were chosen to ensure a balanced distribution among the primary technologies for addressing
contaminated soils, sediments, and sludges at wood treater sites (Le^ bioremediation, thermal
desorption, incineration, immobilization, dechlorination, solvent extraction, soil flushing/washing,
landfilling, and institutional controls/monitoring); and
Sites were chosen to ensure an even distribution in geographic location and ROD signature date.
Using these criteria, a set of 25 NPL wood treater sites was chosen for the PS/ROD analysis; this represents
approximately 43% of the total universe of NPL wood treater sites.
FS/ROD Analysis
The FS/ROD analysis involved a review of the technology screening phase, including any pre-screening steps,
followed by a review of the detailed analysis and comparative analysis phases in each of the 25 FSs and
RODs. Information derived from each review was documented on site-specific data collection forms, which
are available for evaluation as pan of the Administrative Record for this directive (available at EPA
Headquarters and the Regional Offices).
For the screening phase, the full range of technologies considered was listed on the data collection forms,
along with the key reasons given for eliminating technologies from further consideration. These reasons were
categorized according to the three initial screening criteria: cost, effectiveness, and/or implementabiliry. The
frequency with which specific reasons were given for eliminating a technology from further consideration was
then tallied and compiled into a screening phase summary table (Table A-2).
\
For the detailed analysis and comparative analysis, information on the relative performance of each
technology/alternative with respect to the nine NCP criteria was documented on the site-specific data
collection forms. In most cases, several different remedial technologies were combined in the FSs and RODs
to form a remedial alternative or cleanup option. The disadvantages of a technology/alternative were then
compiled into a detailed analysis/comparative analysis summary table, under the assumption that these
disadvantages contributed to non-selection. The advantages and disadvantages associated with each cleanup
option were highlighted. Table A-3 provides the summary information for the detailed analysis and
comparative analysis phases.
Tables A-2 and A-3 demonstrate that non-presumptive remedy technologies are consistently eliminated from
further consideration in the screening phase due to effectiveness, implementability, and/or excessive costs.
In addition, the FS/ROD analysis indicates that, although certain technologies routinely passed the screening
phase, these technologies were selected infrequently because they did not provide the best overall
performance with respect to the nine criteria. This analysis (in addition to the technical background
documentation in the Administrative Record) will support a decision by site managers to bypass the
technology identification and screening step for a particular wood treater site and select one or more of the
presumptive remedies for contaminated soils, sediments, and sludges. As previously discussed, this document
and the accompanying FS/ROD analysis should be pan of the Administrative Record for the site. Additional
supporting materials not found in the Regional files can be provided by Headquarters, as needed.
Page 33
-------
APPENDIX A
TABLE A-2: SUMMARY OF INITIAL SCREENING PHASE FOR WOOD TREATER SITES
Remedial Technology or Treatment
*ofFSs
Technology
Was
Considered1
*ofFSs
Technology
Passed
Screening
#ofFSs
Technology Was
Screened Out
of FSs Where Criterion Contributed to Screening Out2
Cost
EfTectlreness
Implementablllty
A. Restrictions/Monitoring
23
22
A. Capping
1. unspecified
2. asphalt/concrete
3. soll/bentonlte/clay
t
4. multi-layer cover system
42
28
14
5
10
13
14
5
4
8
11
2
5
2
B. Closurc-In-Place/On-Site
Encapsulation/Vaults
10
C. Temporary On-Site Storage Pile
D. Long-Term On-Site Landfill
16
. . >. . " .Ik
A. Solidification/Stabilization
23
15
A. Biological Treatments
1. in situ bioremedlatlon
2. ex situ bioremedlatlon (e.g., lined land
treatment units)
54
18
36
18
15
28
12
6
19
9
3
-------
APPENDIX A
TABLE A-2: SUMMARY OF INITIAL SCREENING PHASE FOR WOOD TREATER SITES
(continued)
Remedial Technology or Treatment
3. off-site landfarming
4. soil/slurry bioreactor
5. anaerobic treatment
6. other
B. Other Thermal Treatments
1. thermal desorption
2. pyrolysls
3. -vitrification
4. wet air oxidation
5. Infrared treatment
6. other
C. Incineration
1. on-site
2. off-site
D. Chemical Treatments
1. dcchlorlnatlon
2. solvent extraction
3. other
# of FSs
Technology
Was
Considered1
4
12
4
1
49
10
9
14
5
9
2
43
23
20
30
12
14
4
# of FSs
Technology
Passed
Screening
0
5
0
0
9
5
0
2
0
2
0
26
15
11
9
4
5
0
# of FSs
Technology Was
Screened Out
4
7
4
1
40
5
9
12
5
7
2
17
8
9
21
8
9
4
# of FSs Where Criterion Contributed to Screening Out1
Cost
1
7
1
4
2
9
3
6
7
3
4
Effectiveness
2
4
1
23
3
5
8
3
2
2
4
3
1
13
5
4
4
Implementablllty
3
2
1
1
20
1
5
9
2
1
2
11
5
6
12
4
6
2
cn
vc
o
c
so
Page 35
-------
APPENDIX A
TABLE A-2: SUMMARY OF INITIAL SCREENING PHASE FOR WOOD TREATER SITES
(continued)
Remedial Technology or Treatment
E. Physical Treatments
1. soil flushing (in situ)
2, soil washing (ex situ)
3. attenuation (mixing with clean soil)
4. aeration/Soil venting
5. macro-encapsulation/
overpaying
6. other
*£v. \IIt\WWr Vjf (1,0119 *\,^k i 'i i*'% "< ? %% > '%v "^
A. Off-Site RCRA Facility
B. Off-Site Sanitary Landfill
C. Off-Site Recycle/Reuse Facility
# of FSs
Technology
Was
Considered1
42
14
19
2
5
1
1
'^';Vs<*'?r'V^
^ -, * '-"" - '"'^v
23
3
3
# of FSs
Technology
Passed
Screening f
12
5
7
0
0
0
0
' < ." < *
' < \ ^ - e , t
19
1
1
# of FSs
Technology Was
Screened Out
30
9
12
2
5
1
1
^ ;vr- >\V;
..v" :' it
4
2
2
# of FSs Where Criterion Contributed to Screening Out1
Cost
5
1
2
1
1
^ V* f
. ... % ^.
3
Effectlreness
21
8
7
1
3
1
1
:i , \T.$$\?
i
i
i
Implementablllty
13
5
3
2
2
1
\v://»s-^"p -o
sx%r*^v'/-/ . 1'<--
2
1
1
1 Because several specific technologies within a general technology group (e.g., capping: unspecified capping, asphalt/concrete caps, soll/bentonite/clay caps, and multi-layer cover
systems) were considered for each site, the total number of FSs in which a technology group was considered may be greater than 25.
2 FSs may indicate more than one criterion for screening out a technology. Also, some FSs did not fully explain the criteria for screening out a technology. Therefore, the totals
for these screening criteria may not be equal to the number of FSs in which a technology was screened out.
-------
APPENDIX A
TABLE A-3: SUMMARY OF DETAILED ANALYSIS PHASE FOR WOOD TREATER SITES
Remedial Technology or
Treatment
ir^iSipg; ^
> C*ttti!yl8^4^,V ^| ,
A. Restrictions/
Monitoring
^t\ *'< 4C.J, «, *>ff,t ''$ ''>*,'(
Jt ; ^ttfrtt»Bf«\^ ;J«**
A. Capping
1. unspecified
2. asphalt/
concrete
3. soll/bentonite/
clay
4. multi-layer cover
system
B. Closure-In-
Place/On-Slte
Encapsulation/
Vault
C. Temporary On-Site
Storage Pile
D. Long-Term On-Site
Landfill
#of
FSs/RODs
Technology
Was
Considered1
' }*<\/>'%.'{f ^ \
**\>^^ ^ / '*
22
%v\/- O 'j&k *$"^"
>/^,^'l?^\
28
5
4
8
11
4
7
9
#of
FSs/RODs
Technology
Was
Selected1
2^;||'
/% ! fjs'^l''.
22
^ ^'^.'"/J'X * ' s}~*
"J"rf'.%->-'tN
13
2
2
4
5
3
6
1
#of
FSs/RODs
Technology
Was Not
Selected
^%^v?"?*^*^ * '
'S' '1/£V '/-&V'vf .
0
"^^?*fc(X5'% /'
*T^5/\*^'
15
3
2
4
6
1
1
8
# of FSs/RODs Where Criterion Contributed to Non-Selection1
Overall
Protectlveness
.V
v?4;r\#
'** \ X ^s *' " '-
''<.' * X ^.;t$'
'}" ^ 's % - '^
7
1
1
2
3
1
.
1
Compliance
w/Federal
ARARs
> f*'--, * '^ ?*v'
v' ' J ''
VS^SS1' '/{'AW>
^"- -'V
3
1
1
1
2
Reduction
of
Toxlclty,
Mobility,
& Volume
<:':- ?j& j|
' t^ ''*>%A /
1 ;^ ^f,('^v^^^'
S\"'W'->^
12
2
2
3
5
1
1
3
Long-Term
Effectiveness/
Permanence
'>*'^"?'" ^ T?
"^^I^^^I^^P
"''"[^V^^^^P
7
1
1
2
3
1
. 1
Short-Term
Effectiveness
*<$x ?c»S^Ks^w^
^iim ^l^?MfP^§
*^^^tS
1
1
1
Implementablllty
^^ "^^.t {C''V,^rf£i
P*iP\^ * '\^ *^^^^^*?%
^^.^M'. fl<\^.
3
1
2
1
4
Cost
S3
K&rVUJ;
^*^Si'ifw
/ ^s^CV
3
1
1
^
1
1
2
Page 37
5 9 OU92
-------
APPENDIX A
TABLE A-3: SUMMARY OF DETAILED ANALYSIS PHASE FOR WOOD TREATER SITES
(continued)
Remedial Technology or
Treatment
4ir>i ~Y~1difHrs'^^ -
>%HI^;llBnl9wHI*<^"Iylj. ^s^ .,
A. Solidification/
Stabilization
"iV,\ ^ Titfsitf^P' "' -* "*"'
^tjV- ,TV -» WftlUWU.I^-vv..^ ...;
A. Biological
Treatments
1. in situ '
bioremedlation
'2. ex situ
bloremediatlon
3. soiMriuny
bioreactor
B. Other Thermal
Treatments
1. thermal desorptlon
2. vitrification
3. infrared treatment
#of
FSs/RODs
Technology
Was
Considered1
Ac C"-v;-^
~% '.. Xo\.\. ^ s^ys
15
£s^' 4V*^V
'ivAj \; 4\ *?\.*!* 'fK
18
5
8
5
9
5
2
2
*of
FSs/RODs
Technology
Was
Selected*
^!V '"f^r
%.% N "f"? X^V 4. ',
11
?i,"-T; ; >%V-\^
/-?. ^-.^ . ^,^x\>
9
2
5
2
2
2
0
0
#of
FSs/RODs
Technology
Was Not
Selected
V ^ %< %i VVA|\
%x-s *< ~<%% N1* C
4
^-y^^^V,^
t^'X- > ,
9
3
3
3
7
3
2
2
# of FSs/RODs Where Criterion Contributed to Non-Selection1
Overall
Protectlveness
<""" ;*>*> s
".'. * " X" , ,5,,
"U'J^^^vV
> 'v* ''"% v-.^, "^''^
1
1
Compliance
w/Federal
ARARs
i'r>>tr\'* ^
" ** "*{ *' s"
, * r\/ /^
^ X. s ' ^ '. ^%
Reduction
of
Toxlclty,
Mobility,
& Volume
1 -' ;"><' ""
v>s>" */^ ?,
3
; ^-cc.^ ' -^
*" v ~« "'* ^*-
2
1
1
2
2
Long-Term
Effectiveness/
Permanence
M< '* ^sV^*'
" v "^*'*r*' \'f
1
^"S-'^^^-lT^i
V' " ^-; ?* *A ' "-.><
5
3
2
2
2
Short-Term
ITfT^f tltr»ti*««
B*I ICCII VCI1V99
&!?''ik& '«' * *
^'\A "'^^.^ NVs,v
1
^i.^if^p'i^
^^wiS^*^*?* V 0
3
1
2
2
2
Implementablllty
4\L'sC ^cV--\t
SK ^%I* ^sS "*'" "v v
1
^lV|v\^;}f^txt ^
t^i-s*^ ^ ^:*^ " ^ IK
5
1
2
2
' ""-.- 4
1
2
1
Cost
-,iv'
v.s* %
1
'
^4i|-5
-' 'X V s-
1
1
2
1
'I
-------
APPENDIX A
TABLE A-3: SUMMARY OF DETAILED ANALYSIS PHASE FOR WOOD TREATER SITES
(continued)
Remedial Technology or
Treatment
C. Incineration
1. on-site
2. off-site
D. Chemical Treatment
1. solvent extraction
2. dechloriqation
E. Physical Treatment
1. soil flushing (in
situ)
2. soil washing
(ex situ)
#of
FSs/RODs
Technology
Was
Considered1
26
15
11
9
5
4
12
5
7
#or
FSs/RODs
Technology
Was
Selected2
7
3
4
4
1
3
6
1
5
#of
FSs/RODs
Technology
Was Not
Selected
19
12
7
5
4
1
6
4
2
# of FSs/RODs Where Criterion Contributed to Non-Selection1
Overall
Protectlveness
**
1
1
-
1
1
Compliance
w/Federal
ARARs
1
1
Reduction
of
Toxlclty,
Mobility,
& Volume
3
2
1
2
1
1
1
1
Long-Term
Effectiveness/
Permanence
4
2
2
3
3
Short-Term
Effectiveness
7
4
3
Implementablllty
12
6
6
2
2
4
3
1
Cost
14
8
6
2
2
1
1
cn
vo
O
C
Page 39
-------
APPENDIX A
TABLE A-3: SUMMARY OF DETAILED ANALYSIS PHASE FOR WOOD TREATER SITES
(continued)
Remedial Technology or
Treatment
;%(^tf|^litf
A. Off-Site RCRA
Landfill
D. Off-Site Sanitary
landfill
C. Off-Site
Reclamation/
Recycling
#of
FSs/RODs
Technology
Was
Considered'
:^5;iVt^>
. . y. .sp 1 Vbv jjjt ^ v r
19
1
1
#of
FSs/RODs
Technology
Was
Selected1
* ' ^ ^ v * %
*i »,.< " VgV-5
>s >^v.^^ Jsis;
10
0
1
#of
FSs/RODs
Technology
Was Not
Selected
W*V^?k< Vx-
P^i-^Wis^ «
"<"'*' V" S\L"'' rtvi ''*
9
1
0
# or FSs/RODs Where Criterion Contributed to Non-Selection3
Overall
Protectlveness..
'c^vV l"\-.\' -v-5"'
>"N^*V^ Xs-
2
Compliance
w/Federal
ARARs
^A-^V£f>
1
Reduction
of
Toxlclty,
Mobility,
& Volume
«if 5A5-.C 5^'^
«X-.^-> 'ff-f *
. ..-:.^;.. .>»..<<. --'--'--,-.
1
Long-Term
Effectiveness/
Permanence
v* %4 * ^SS ss%* ^5 $'.
c Ax-:?^:- ->^4s
>.!......%>!...>..... ^-j^fir^
1
Short-Term
Effectiveness
Implementnbility
x|^ iKf^-'l*;-^ ;
6
Cost
^-i-,V
2
1 Because several specific technologies within a general technology group (e.g., capping: unspecified capping, asphalt/concrete caps, soll/bentonlte/clay caps, and multi-layer cover systems) were considered
for each site, the total number of FSs/RODs In which a technology group was considered may be greater than 25.
* The total number of remedial technologies selected is greater than 25 because treatment trains consisting of several different technologies were selected at most sites. For example, the selection of
an overall remedy may have included the selection of institutional controls to control direct contact exposure, bioremedlation to treat organic contamination (including soil washing), and immobilization
to address inorganic contamination.
1 Information on state and community concerns was not Included in this analysis because FSs do not contain this information, and RODs generally only reference supporting documentation (i.e., state
concurrence letters and responsiveness summaries). FSs and RODs may Indicate more than one criterion for non-selection of a technology. Therefore, the totals for these non-selection criteria may
not be equal to the number of FSs/RODs in which a technology was not selected.
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
BIOREMEDIATION
CRITERIA
Overall Protection of
Human Health and
the Environment
Provides protection by
reducing
concentrations of
organic contaminants
In soils, sediments, and
sludges.
Ex situ bloremediation
requires measures to
protect workers and
the community during
excavation, handling,
and treatment.
Does not Impact the
local environment with
the proper
Implementation of
erosion/sediment
control measures.
Compliance with
ARARs
Operation must
comply with all federal
and state regulations
that are identified as
ARARs.
Requires compliance
with RCRA removal,
treatment,
transportation, and
land disposal
regulations, if RCRA
Is determined to be an
ARAR.
Requires compliance
with CERCLA off-site
rule (if off-site
treatment, storage, or
disposal is used).
Long-Term
Effectiveness nnd
Permanence
Residual
contamination
following treatment
may require use of
capping and/or
institutional controls.
Residual
contamination may
migrate.
Hazardous substances
left in place will
require n five-year
review.
Bioremedlatlon
systems may require
lengthy operation, in
addition to long-term
maintenance of cap
integrity (if capping is
implemented).
Reduction of Toxklty,
Mobility, or Volume
Through Treatment
May reduce toxicity,
mobility, and volume
through degradation of
organic contaminants;
however, If bulking
agents are added,
volume may not
necessarily be reduced.
If used in conjunction
with capping,
minimizes mobility.
Short-Term Effectiveness
Microblal degradation Is a
relatively slow process that
Is highly site-specific and Is
affected by a multitude of
factors. Some of these
factors (e.g., electron
acceptor and nutrient
availability, and pH) may
need to be examined in
bench-scale studies during
the design phase of site
remediation to maximize
aerobic activity and
minimize process
interferences.
Ex situ bloremediation
presents potential short-
term risks to workers and
community from air
releases during excavation
and treatment; requires air
monitoring to address these
short-term risks.
Implemehtablllty
Requires relatively
simple technologies;
easy to construct and
operate.
May require bench*
and/or pilot-scale
studies during the
design phase. Pilot-
scale studies In the
field are almost
always required
before full-scale
implementation.
Easy to economically
maintain treatment
until cleanup levels
are achieved.
Size of site may limit
capability to perform
some types of ex situ
bloremediation.
Cost1
In sittt $50 - $100
per cubic
yard of
."i!,
sediment,
or sludge.
Ex situ $50 -$150
per cubic
yard of
soil,
sediment,
or sludge;
or $40 -
$125 per
ton of soil,
sediment,
or sludge.
tn
vo
vo
-ps.
1 Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technologj
Page 41
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
BIOREMEDIATION (continued)
CRITERIA
Overall Protection of
Human Health and
the Environment
In situ biorcmedialion
may not be feasible
for the treatment of
subsurface soils,
sediments, and sludges
(depending upon
variables such as
contaminant type, soil
type, depth to
contamination, etc.).
A simple cap, in
conjunction with
biorcmcdlmlon,
provides protection by
reducing and/or
controlling erosion and
direct contact
exposure to residual
contamination.
Compliance with
ARARs
Requires compliance
with Hazardous
Materials
Transportation Act
regulations (if off-site
treatment is used).
Requires compliance
with location-specific
ARARs.
Ex situ bioremediation
may need emission
controls to ensure
compliance with air
quality standards
during excavation and
treatment.
Long-Term
Effectiveness find
Permanence
In situ process
generates little, if any,
toxic waste streams
that need to be
disposed; ex situ may
generate such streams.
Reduction of Toxlclty,
Mobility, or Volume
Through Treatment
""
Short-Term Effectiveness
Where It Is feasible, in situ
bioremediation requires the
least soil disturbance and,
therefore, presents the least
short-term risks.
Involves potential short-
term risks from handling
and transporting waste (if
off-site treatment is used).
.
Implementeblllrjr
Cost1
1 Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technology
used.
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
THERMAL DESORPTION
CRITERIA
Overall Protection of
Human Health and the
Environment
Provides both short*
and long-term
protection by
eliminating exposure to
organic contaminants In
soils, sediments, and
sludges.
Prevents further
ground-water
contamination and off-
site migration.
Requires measures to
protect workers and the
community during
excavation, handling,
and treatment.
Compliance with ARARs
Operation and design must
comply with all federal and
state ARARs concerning
hazardous waste treatment
facilities.
Requires compliance with
RCRA removal, treatment,
transportation, and land
disposal regulations, if
RCRA is determined to be
an ARAR.
Requires compliance with
CERCLA off-site rule (if
off-site treatment, storage, or
disposal is used).
Long-Term Effectiveness
and Permanence
Effectively removes source
of contamination.
Has been demonstrated as-
an effective technique for
removing and
concentrating organic
contaminants in soils,
sediments, and sludges.
Would involve some
treatment or disposal of
residuals In addition,
generally through use of
carbon adsorption/
regeneration or disposal.
Eliminates risks associated
with direct contact or
migration of wastes.
Reduction of
T6llclty, Mobility,
or Volume Through
Treatment
Significantly reduces
toxidty, mobility,
and volume of
contaminants
through treatment.
Short-Term
Effectiveness
Presents potential
short-term risks to
workers and
community from
fugitive emissions
during excavation and
treatment (if on-site
treatment Is used).
Requires air
monitoring to address
these short-term risks.
Involves potential
short-term risks from
handling and
transporting waste (If
off-site treatment Is
used).
Requires relatively
short time frame to
achieve cleanup
levels.
Implementablllty
Substantive permit
requirements must be
addressed.
Mobile treatment
units are readily
available.
Limited off-site
treatment capacity
exists.
Used successfully at
other Superfund sites
to treat organic
contaminants in soils,
sediments, and
sludges.
Public may oppose
technology, viewing It
as similar to
incineration.
Cost1
$150 - $400 per
ton of soil,
sediment, or
sludge,
excluding
excavation,
material
handling, or
disposal costs.
CT! i
o
o
vo-
cn
1 Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technology
used.
Page 43
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
THERMAL DESORPTION (continued)
CRITERIA
Overall Protection of
Human Health and the
Environment
(
Compliance with ARARs
Requires compliance with
Hazardous Materials
Transportation Act
regulations (if off-site
treatment is used).
Requires compliance with
location-specific ARARs.
Emission controls may be
needed to ensure compliance
with air quality standards
during excavation and
treatment.
EPA's Draft Combustion
Strategy is a TBC (e.g., for
conducting risk assessments,*
etc.)
Long-Term Effectiveness
and Permanence
/
Deduction of
Toxlclty, Mobility,
or Volume Through
Treatment
Short-Term
Effectiveness
Implementablllty
Requires engineering
measures to control
air emissions, fugitive
dust, runoff, erosion,
and sedimentation.
Cost1
1 Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technology
used.
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
INCINERATION
CRITERIA
Overall Protection of
Human Health and
the Environment
Provides both short-
end long-term
protection by
permanently destroying
organic contaminants
in soils, sediments, and
sludges.
Prevents further
ground-water
contamination and off-
site migration.
Requires measures to
protect workers and
the community during
excavation, handling,
and treatment.
Compliance with ARARs
Operation and design must
comply with all federal and
state ARARs concerning
hazardous waste treatment
facilities.
Requires compliance with
RCRA removal, treatment,
transportation, and land
disposal regulations, if
RCRA is determined to be
an ARAR.
Requires compliance with
CBRCLA off-site rule (If off-
site treatment, storage, or
disposal is used).
Must meet Boiler and
Industrial Furnace (BIF)
regulations, which can be
more restrictive than RCRA.
Long-Term
Effectiveness and
Permanence
Effectively destroys
nearly alt
contamination.
Is a well-demonstrated
technique for treating
organic contaminants
in soils, sediments, and
sludges.
Eliminates risks
associated with direct
contact or migration
of wastes.
Generates little, if any,
toxic residues.
Reduction of Toxiclty,
Mobility^ or Volume
Through Treatment
Significantly reduces
toxlcity, mobility, and
volume of
contaminants through
treatment.
Short-Term
Effectiveness
Presents potential
short-term risks to
workers and
community from
fugitive emissions
during excavation and
treatment (if on-site
treatment is used).
Requires air
monitoring to address
these short-term risks.
Involves potential
short-term risks from
handling and
transporting waste (if
off-site treatment is
used).
Requires relatively
short time frame to
achieve cleanup levels.
Implementablllty
Construction and
substantive permit
requirements of on-
site incinerators may
be somewhat difficult
to meet.
Mobile Incinerators
are readily available;
these use common
procedures and
equipment.
Limited off-site
incineration capacity
exists.
Used successfully at
other Superfund sites
to treat organic
contaminants in soils,
sediments, and
sludges.
Cost1
$150 - $400 per
ton of soil,
sediment, or
sludge, excluding
excavation,
material handling,
or disposal costs.
tn
SO
CD
vo.
o\
1 ' '
Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technology
used.
Page 45
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
INCINERATION (continued)
CRITERIA
Overall 'Protection of
Human Health and
the Environment
»
Compliance with ARARs
Requires compliance with
Hazardous Materials
Transportation Act
regulations (If off-site
treatment is used).
Requires compliance with
location-specific ARARs.
Emission controls may be
needed to ensure compliance
with air quality standards
during excavation and
treatment.
EPA's Draft Combustion
Strategy is a TBC (e.g., for
conducting risk assessments,
etc.)
Long-Term
Effectiveness and
Permanence
Reduction) of Toxlclty,
Mobility, or Volume
Through Treatment
Short-Tertn
Effectiveness
Implementablllty
Public opposition may
make this technology
infeasible.
Requires a trial burn
to demonstrate
destruction efficiency
and define operating
parameters (if on-site
treatment is used).
Requires coordination
with state and local
officials to select
transportation routes
(if off-site treatment is
used).
Cost1
1 Actual cost of a remediation technology Is highly site-specific and dependent upon target cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation technology
used.
P
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD TREATER SITES:
IMMOBILIZATION
CRITERIA
Overall Protection of
Human Health and
the Environment
Provides both short-
and long-term
protection by
containing
contaminants in a
fixed-soil/sediment/
sludge mass.
Reduces the potential
for further ground-
water contamination
and off-site migration.
Reduces potential
risks associated with'
inhalation, dermal
contact, and ingestlon
of contaminated soils,
sediments, and
sludges.
Compliance with
ARARs
Operation must
comply with all federal
and state ARARs.
Requires compliance
with RCRA removal,
treatment,
transportation, and
land disposal
regulations, if RCRA
is determined to be an
ARAR.
Requires compliance
with CBRCLA off-site
rule (if off-site
treatment, storage, or
disposal is used).
Long-Term
Effectiveness and
Permanence
Represents a long-term
solution that effectively
reduces and/or
eliminates the mobility
of hazardous
substances into the
environment.
Has been
demonstrated as an
effective technique for
treating inorganic
contaminants
(primarily metals, such
as chromium and
arsenic) in soils,
sediments, and sludges.
Reduction of Toxlclty,
Mobility, or Volume
Through Treatment
Significantly reduces
the mobility of
inorganic contaminants
(and non-volatile
organics, to some
extent) by chemically
binding and
encapsulating them.
Does not reduce
volume or toxicily of
contaminants. Volume
may increase 30-50%
through the mixing of
the soil/sediment/
sludge with fixative
agents.
Short-Term
Effectiveness
Presents potential
short-term risks to
workers and
community from air
release during
excavation and
treatment (if on-site
treatment is used).
Involves potential
short-term risks from
handling and
transporting waste (if
off-site disposal is
used).
Requires relatively
short time frame to
achieve cleanup levels.
Implementablllty
Requires relatively
simple technologies;
easy to construct and
operate.
Requires treatability
testing.
Used successfully at
other Superfund sites
to treat inorganic
(primarily metals)
contaminants in soils,
sediments, and sludges.
Cost1
$75 $400 per ton of
soil, sediment, or
sludge (for on-site
treatment).
$100 - $500 per ton of
soil, sediment, or
sludge (for off-site
disposal).
tn
VO
o
c:
1 Actual cost of a remediation technology is highly site-specific and dependent upon target cleanup levels of contaminanls, soil characteristics, and the design and operation of the remediation technology
-------
APPENDIX B
EVALUATION OF SELECTION CRITERIA FOR TECHNOLOGIES USED TO TREAT CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD THEATER SITES:
IMMOBILIZATION (continued)
CRITERIA
Overall Protection of
Human Health and
the Environment
Requires measures to
protect workers and
(he community during
excavation, handling,
and treatment.
Lower portions of the
soil profile are often
untreated.
i
Compliance with
ARARs
Requires compliance
with Hazardous
Materials
Transportation Act
regulations (if off-site
disposal Is used).
Requires compliance
with location-specific
ARARs.
Emission controls may
be needed to ensure
compliance with air
quality standards
during excavation and
treatment.
Long-Term
Effectiveness and
Permanence
Requires air and
ground-water
monitoring to confirm
long-term effectiveness.
Requires proper
management and/or
institutional controls to
address any residual
risks associated with
direct contact.
Reduction of Toxlclty,
Mobility, or Volume
Through Treatment
Short-Term
Effectiveness
Short-term
effectiveness
maintained through
strict environmental
controls.
Implementablllty
Cost1
.
1 Actual cost of a remediation technology is highly site-specific and dependent upon (arget cleanup levels of contaminants, soil characteristics, and the design and operation of the remediation tcchnologj
used.
8
-------
5 9 ^ OU98
GLOSSARY
Action Memorandum A document that provides a concise written record of the decision selecting a
removal action. It describes the site's history, current activities, and health and environmental threats;
outlines the proposed actions and costs; and documents approval of the proposed action by the proper
EPA Headquarters or Regional authority.
Administrative Record A formal record established by the lead agency, it contains the documents that
form the basis for the selection of a response action (e.g., analysis report, Feasibility Study, Record of
Decision, Directives, etc.).
Applicable or Relevant and Appropriate Requirements (ARARs) Applicable requirements are cleanup
standards, standards of control, and other substantive requirements, criteria, or limitations promulgated
under federal environmental or facility siting laws that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site.
Relevant and appropriate requirements are cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under federal environmental or facility siting laws that,
while not "applicable* to a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstances at a CERCLA site, address problems or situations sufficiently similar to those encountered
at the CERCLA site and are well-suited to the particular site.
Engineering Evaluation/Cost Analysis (EE/CA> Required for non-time-critical removal actions, the
EE/CA contains information on site characteristics, removal action objectives, and removal action
alternatives. It is intended to identify the objectives of the removal action and to analyze the various
alternatives that may be used to satisfy these objectives for cost, effectiveness, and implementability. The
EE/CA process includes: conducting a removal site evaluation, notifying PRPs of their liability, preparing
an EE/CA approval memorandum, and preparing a study documenting the removal action options.
Although an EE/CA is similar to the RI/FS conducted for remedial actions, it is less comprehensive. The
EE/CA is pan of the Administrative Record file and is subject to the public comment and
comment/response requirements for the Administrative Record.
Feasibility Study (TS) A study undertaken by the lead agency to develop and evaluate options for
remedial design. The FS emphasizes data analysis and is generally performed concurrently and in an
interactive fashion with the Remedial Investigation (RI), using data gathered during the RL
Hazard Ranking System (ERS) The method used by EPA to evaluate the relative potential of
hazardous substance releases to cause health or safety problems, or ecological or environmental damage.
Innovative Treatment Technologies Technologies that have been tested, selected, or used for the
treatment of hazardous substances or contaminated materials but lack well-documented cost and
performance data under a variety of operating conditions.
National Priorities List fNPL> The list compiled by EPA, pursuant to CERCLA section 105, of
hazardous substance releases in the United States that are priorities for long-term remedial evaluation and
response.
On-Scene Coordinator fosf!) The federal official predesignated by EPA or the U.S. Coast Guard to
coordinate and direct federal responses under Snbpart D of die NCP, or the official designated by the lead
agency to coordinate and direct removal actions under Subpart E of the NCP.
Preliminary Remediation Goals fPRGs) - Initial cleanup goals developed as part of the overall remedial
action objectives. PRGs are established and refined based on a variety of information, including ARARs
Page 49
-------
GLOSSARY
(continued)
and TBCs, the baseline risk assessment, anticipated future land use(s) of the site, and technical, exposure,
and uncertainty factors.
Principal Threats - Principal threats include liquids, areas contaminated with high concentrations of toxic
compounds, and highly mobile materials.
Record of Decision (ROD) The final remedial action plan for a site or operable unit, which summarizes
problems, alternatives, remedies, and the selected remedy. The ROD also includes the rationale for the
selection of the final remedy, and explains how the selected remedy meets the nine evaluation criteria
stated in the NCP.
Remedial Investigation (RD A process undertaken by the lead agency to determine the nature and
extent of the problem presented by a release. The RI emphasizes data collection and site characterization,
and is generally performed concurrently and in an interactive fashion with the Feasibility Study.
Remedial Project Manager fRPM) The official designated by the lead agency to coordinate, monitor, or
direct a remedial action under Subpart E of the NCP.
Remedial Site Evaluation A process undertaken by the lead agency to collect data, as required, and
evaluate a release or threat of release of hazardous substances, pollutants, or contaminants. The
evaluation may consist of two steps: a preliminary assessment (PA) and a site inspection (SI).
Removal Site Evaluation A process undertaken by the lead agency to identify the source and nature of a
release or threat of release; it may include a removal preliminary assessment and, if warranted, a removal
site inspection.
Risk Assessment The qualitative and/or quantitative evaluation performed in an effort to define the risk
posed to human health and/or the environment by the cumulative presence or potential presence and/or
use of specific pollutants.
Superfund Accelerated Cleanup Model (SACM) - The purpose of SACM is to make hazardous waste
cleanups more timely and efficient. This will be accomplished through a greater focus on the front end of
the process and better integration of all Superfund program components. The approach involves: (1) a
continuous process for assessing site-specific conditions and the need for action; (2) cross-program
coordination of response planning; (3) prompt risk reduction through early action (removal or remedial);
and (4) appropriate cleanup of long-term environmental problems.
To Be Considereds fTBCs) Non-promulgated advisories or guidance issued by federal or state
governments that are not legally binding and do not have the status of potential ARARs. In many
circumstances, TBCs will be considered along with ARARs as part of the risk assessment and may be used
in determining the necessary level of cleanup for protection of health or the environment
Treatability Studies Preliminary studies in which a hazardous waste is subjected to a treatment process
to determine if the waste is amenable to the process, what pretreatment activities are necessary, what the
optimal process options are, and what is the efficiency of the process.
Page 50
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5 9 GU99
REFERENCES
1. Approaches for Remediation of Uncontrolled Wood Preserving Sites. EPA/625/7-90/011, US EPA,
Office of Environmental Research Information, Cincinnati, OH, November 1990.
2. Bioremediation in the Reid Search System fBFSSV Version 1.0., US EPA, available through CLU-IN
Bulletin Board (301-589-8366).
3. CERCLA Compliance with Other Laws Manual: Interim Final. EPA/540/G-89A)06, US EPA, OERR,
August 1988.
4. CERCLA Compliance with Other Laws Manual: Pan P. Clean Air Act and Other Environmental
Statutes and State Requirements. EPA/540/G-89/009, US EPA, OSWER, August 1989.
5. Community Relations in Superfund: A Handbook (Interim Guidance"). OERR/HSCD Publication
9230.0-03B, US EPA, June 1988.
6. Considerations in Ground Water Remediation at Superfund Sites. OSWER Directive 9355.4-03, US
EPA, October 18,1989.
7. Considerations in Ground-Water Remediation at Superfund Sites and RCRA Facilities - Update.
OSWER Directive 9283.1-06, US EPA, May 27,1992.
8. Contaminants and Remedial Options at Wood Preserving Sites. EPA/600/R-92/182, US EPA, ORD,
RREL, October 1992.
9. "Creosote Contaminated Sites Their Potential for Bioremediation," Environmental Science and
Technology. Vol. 23* No. 10. pp. 1197-1201,1989.
10. Dense Nonaqueous Phase Liquids A Workshop Summary. Dallas. Texas. April 16-18. 1991. ORD
Publication EPA/600/R-92/030,1992.
11. DNAPL Site Evaluation. EPA/600/R-93/022, Cohen, RAL, and J.W. Mercer, 1993.
12. Estimating Potential for Occurrence of DNAPL at Superfund Sites. OSWER Publication 9355.4-07FS,
US EPA, 1992.
13. Evaluation of the Likelihood of DNAPL Presence at NPL Sites. National Results. OSWER
Publication 9355.4-13, EPA/540/R-93/073, US EPA, September 1993.
14. Field and Laboratory Evaluation of Petroleum Land Treatment System Closure. NTIS #PB 86-130
564/AS, US EPA, 1986.
15. Ground Water Issue: Dense Nonaqueous Phase Liquids. EPA/540/4-91/002, US EPA, 1991.
16. Guidance for Conducting Remedial Investigations and Feasibility Studies fRI/FSsI Under CERCLA.
EPA/540/6-89/004, OERR Publication 93553-01, US EPA, October 1988.
17. Guidance for Evaluating Technical Impracticability of Ground-Water Restoration. OSWER Directive
9234.2-25, EPA/540/R-93/080, US EPA, September 1993.
18. Guidance Manual on Hazardous Waste Land Treatment/Post-Closure 40 CFR Part 265. US EPA,
1987.
Page 51
-------
REFERENCES
(continued)
19. Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA. EPA/540/R-93/D57,
OERR Publication 9360.0-32, US EPA, August 1993.
20. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites. OSWER
Directive 9283.1-2, EPA/540/G-88/D03, US EPA, December 1988.
21. Guide for Conducting Treatabilitv Studies Under CERCLA Biodegradation Remedy Screening -
Interim Guidance. EPA/540/R-93/519a, US EPA, August 1993.
22. Guide for Conducting Treatabilitv Studies Under CERCLA: Thermal Desorption Remedy Selection
Interim Guidance. EPA/540/R-92/D74A, US EPA, September 1991.
23. Guide to Principal Threat and Low-Level Wastes. Superfund Publication 93803-06FS, US EPA, 1991.
24. Guide to Treatment for Hazardous Wastes at Superfund Sites. EPA/540/2-89/052, US EPA, Office of
Environmental Engineering and Technology Development, March 1989.
25. "Incineration of Hazardous Waste: A Critical Review Update," International Journal of Air Pollution
Control and Hazardous Waste Management. Vol. 43. pp. 25-73, January 1993.
26. Innovative Treatment Technologies: Overview and Guide to Information Sources. EPA/540/9-91/002,
US EPA, OSWER, TIO, October 1991.
27. Land Use in the CERCLA Remedy Selection Process. OSWER Directive 9355.7-04, US EPA, May 25,
1995.
28. Mobile/Transportable Incineration Treatment Engineering Bulletin. EPA/540/2-90/D14, US EPA,
February 1990.
29. Mobility and Degradation of Residues at Hazardous Waste Land Treatment Sites at Closure.
EPA/600/2-90/018, US EPA, April 1990.
30. Notice of Availability with Request for Comment on Draft Soil Screeninp; Guidance. 59 Federal
Register 67706, December 30,1994.
31. Presumptive Remedies: Policies and Procedures. OERR Publication 9355.0-47FS, US EPA,
September 1993.
32. Presumptive Remedies: Site Characterization and Technology Selection For CERCLA Sites With
Volatile Organic Compounds In Soils. OSWER Directive 9355.0-48FS, EPA/540/F-93/048, US EPA,
September 1993.
33. Presumptive Remedy for CERCLA Municipal Landfill Sites. OSWER Directive 9355.0-49FS,
EPA/540/F-93/035, US EPA, September 1993.
34. Removal Program Representative Sampling Guidance. Volume 1: Soil. OERR Publication 9360.4-10,
US EPA, November 1991.
35. Risk Assessment Guidance for Superfund. Volume 1: Human Health Evaluation Manual. Pan A.
Interim Final. OERR/HSED Publication 9285.7-01B, US EPA, December 1989.
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REFERENCES
(continued)
36. Risk Assessment Guidance for Superfund. Volume 2: Environmental Evaluation Manual Interim
Final. Part A. OERR/HSED Publication 9285.7-01A, US EPA, March 1989.
37. Strategy for Hazardous Waste Minimization and Combustion. EPA/530/R-94/044, US EPA, November
1994.
38. Suggested ROD Language for Various Ground Water Remediation Options. OSWER Directive
9283.1-03, US EPA, October 10,1990.
39. Superfund LDR Guide #6A. Obtaining a Soil and Debris Treatabilitv Variance for Remedial Actions.
OSWER Publication 93473-06FS, US EPA, September 1990.
40. Superfund LDR Guide #6B. Obtaining a Soil and Debris Treatabilitv Variance for Removal Actions.
OSWER Publication 93473-06BFS, US EPA, September 1990.
41. Superfund Removal Procedures: Guidance on the Consideration of ARARs During Removal Actions.
OSWER Publication 9360.3-02, US EPA, August 1991.
42. Superfund Removal Procedures: Public Participation Guidance for On-Scene Coordinators:
Community Relations and the Administrative Record. OERR Publication 93603-05, US EPA, June
1992.
43. Technology Selection Guide for Wood Treater Sites. OERR Publication 9360.0-46FS, US EPA, May
1993.
44. Thermal Desorption Treatment Engineering Bulletin. EPA/540/2-91/008, US EPA, February, 1991.
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