United States
Environmental Protection.
Agency
Office of -
Emergency .and
Remedial Response
EPA/ROD/R05-89/102
September. 1989
&EPA
Superfund
Record of Decision
Alsco Anaconda, OH
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50272-101
REPORT DOCUMENTATION i. REPORT NO. *•
PAGE EPA/ROD/R05-89/102
4. Title and Subtitle • . . ' .
.S.UPERFUND RECORD OF DECISION
Alsco Anaconda, OH .
.. First Remedial Action .'.'••'
7. Authors) ' ' . . . ' .
9. Performing Organization Name and Address
12. Sponsoring Organization Name end Address •''..'
U.S. Environmental .Protection Agency ' • • '•• , •.'••
401 M Street, S.W. . ' . ' . ' ; ;.
Washington, D.C... 20460 .
3. Recipient* Accession No.
S. Report Date
09/08/89
&
& Performing Organization Rept No.
10. ProjectfTaak/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
IX Type of Report & Period Covered
800/000
14.
15. SupplemenUry Note*
16. Abstract (Umit: 200.words) .' .....
The Alsco Anaconda site is a 4.8-acre. former sludge disposal area in Gnadenhutten,
Tuscarawas County, Ohio. The site lies within the'Tuscarawas River's 50- and 100-year
floodplains'and neighbors the Alsco Anaconda aluminum, manufacturing plant which has
operated since 1948. Contamination at the site occurred. :from 1965 to 1978 when
wastewater and wastewater treatment sludge from the' plant,, containing hazardous .
aluminum processing wastes (F019), was disposed of in an uhlined settling basin and a
sludge pit.; in 1978 .the plant owners: began dewatering the treatment sludge prior to
disposal of. sludge off site in the .settling basin.; arid a former swamp area. This. Record
of Decision .(ROD> is the first of two operable units at the site and addresses .
remediation of the contaminated soil and sludge. Because leachate from the sludge may
have contaminated the ground water and surface water, a subsequent ROD will address the
appropriate remedial action for those media.' The primary contaminants of concern
affecting- the soil and sludge are .organics including PCBs, and metals including
chromium, cyanide, and arsenic. •
The selected .remedial action for this site includes, excavating 50 cubic yards of.
sludge contaminated with greater than 500^mg/kg of PCBs followed by offsite
incineration .and disposal; excavating 8,820 cubic (See Attached Sheet) . . .
OH
17. Document Analysis a. Descriptors
Record of Decision - Alsco Anaconda,
First Remedial Action . .
Contaminated Media: soil, sludge
Key Contaminants: organics (PCBs), metals (chromium, arsenic)
b. Identifiers/Open-EndedTerms.
c. COSAT1 Field/Group
18. Availability Statement •
19. Security Class (Thia Report)
• None
20. Security Class (This Page) '• '
None
21. No. o( Pages
' 50
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R05-89/102
SUPERFUND RECORD OF DECISION
Alsco Anaconda, OH .
.First Remedial Action
16. Abstract (continued)
yards of aluminum processing waste sludge and underlying soil from the settling basin
and sludge pit contaminated with less than 500 mg/kg of PCBs followed by offsite
treatment and disposal or reuse; backfilling and revegetating excavated areas; and
implementing institutional controls including site access and deed restrictions. The
estimated capital cost for this remedial action is $4,161,066 with no associated O&M
costs.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Alsco Anaconda Site
Qiadenhutten, Ohio
StUft^'MMtV OF BASTS AND
This decisicn document presents the United States Environmental Protection
Agency's (U.S. EPA's) selected remedial action for the source material
operable unit at the Alsco Anaconda site located in Gnadenhutten, Ohio.
This decision document was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) , as
amended by the Superfund Amendments and Reauthorization Act (SARA) , and the
National Contingency Plan (NCP) . This decision is based on information and
documents contained in the administrative record for this site. The
attached index identifies the items that comprise the administrative record-
upon which the selection of the remedial action is based.
The State of Ohio concurs on the selected remedy.
OF
Actual or threatened releases of hazardous substances from this site, if
not afvi-ppssprl by implementing the response action selected in this Record
of Decision (ROD) , nay present an imminent and substantial endangerment to
public health, welfare, or the environment.
OF 'JMC
This operable unit is the first of two operable units planned for the site.
This action addresses the source material consisting of contaminated sludge
and soil. The second planned activity will arMr-pps contaminated ground and
surface water. This action proposed for the source material will
contribute to the overall strategy for the site as it will remove and treat
the principal direct contact threat to humans, eliminate the threat of
release of contaminated material to the river, and will no longer
contribute contaminants to the groundwater.
The major components of the selected remedy include:
- Excavation of approximately 50 cubic yards of sluckje contaminated with
greater than 500 milligrams per kilogram (mg/kg) of polychlorinated
biphenyls (PCBs) and transportation off site for treatment to a
facility permitted to incinerate PCB waste; and
- Excavation of approximately 8,820 cubic yards of remaining sludge and
underlying soil, which includes sludge contaminated with less than 500
mg/kg of PCBs, to levels meeting clean closure requirements for
treatment and H<«^ngai at an off-site facility in O'-TT'liariog with the
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CERdA off-site policy (approved facility) or a reclamation/reuse
facility.
- Backfill selected areas, and recontour and vegetate any excavated or
cleared areas; maintain the present security fence; and notice of the
remedial action recorded with the property deed.
STMUTCRY
The selected remedy for the source material operable unit is protective of
human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent
solutions and alternative (or resource recovery) technologies to the
maximum extent practicable and satisfies the statutory preference for
remedies that employ treatment to reduce toxicity, mobility, or volume as a
principal element.
Because this remedy does not address contaminated ground water, hazardous
substances are remaining on-site. Consequently, U.S. EPA will review the
remedy, no less than once every five years after commencement of the
remedial action, to ensure that the remedy continues to provide adequate
protection of human health and the environment. The necessity of
continuing the five-year review will also be evaluated after the selection
of the remedial action for the ground and surface water operable unit.
Valdas V. Adamkus, Regional^Administrator
U.S. Environmental Protection Agency/ Region V
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1.0 SITE NAME, LOCATION, AND DESCRIPTION
The 4.8 acre Alsoo Anaconda site is located approximately forty-nine miles
south of Akron, Ohio within the Gnadenhutten village limits. Gnadenhutten,
a community of about 1,320 residents, is located-within Clay Township in
Tuscarawas County, along the flood plain of the Tuscarawas River. The
Alsco Anaconda site is bounded by the Perm-Central Railroad right-of-way,
the Alsco manufacturing building and parking lot, Anaconda Drive (County
Road 39), and the Tuscarawas River on the northwest, northeast, southeast,
and southwest respectively. This approximately 4.8-acre area, including
the settling basin (consisting of the northern and southern impoundments),
sludge pit, a former swamp area, and adjacent land up to the river
constitute the Alsoo Anaconda National Priorities List (NFL) site. See
site map (Figure 1).
Both land and water resources are used by individuals and local industries.
Natural resource development activities include farming, mining of coal,
clay, sand and gravel, and drilling of oil and gas wells. The Tuscarawas
River is used for recreation as well as for industrial and agricultural
water supplies.
Subsurface materials in the Tuscarawas River valley consist of
unconsolidated fluvial silt and sand deposits, along with glacial outwash
sands, silts, and gravels. This valley fill overlies relatively flat-lying
sedimentary bedrock, mostly shale and sandstone with minor beds of
limestone and coal, generally occurring greater than 160 feet below the
site surface. The surficial deposits of sand and gravel and bedrock
formations of shale, limestone, and coal are m-in^d locally as economic
resources. Within a two- mile radius of the site, there are several sand
and gravel pits in the valley with clay and coal strip mines in the valley
sides.
The unconsolidated alluvial valley deposits form extensive aquifers which
are the principal water supplies for municipalities in the valley.
Groundwater flow in the valley is generally southwestward. The
Ghadenhutten municipal well field is located approximately 4,000 feet
northeast of the Alsco Anaconda site. Several wells, including the
municipal, residential, and plant wells are located within a 1.5 mile
radius of the site (Figure 2).
2.0 si'in BTTgirov AND ENFORCEMENT ACTIVITIES
The Alsco Anaconda plant has manufactured aiiTtnirmm products since 1948 when
it was established by Harvard Industries. The plant was acquired by the
Anaconda Company in August 1971. The Anaconda Company was acquired by the
ARCO Chemical Company, a division of the Atlantic Richfield Company (ARCO) ,
in January 1977. In December 1986, ARCO sold the plant to Horsehead
Industries; however, ARCO retained ownership of the portions of the plant
used for sludge fHgpnaai. This 4.8-acre area constitutes the Alsco
Anaconda site.
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Prior to 1965, neutralized process wastewater was discharged directly to
the Tuscarawas River. The settlement basin was completed in 1965 at the
request of the State of Ohio Department of Health. During the period from
1965 to 1978, the unlined settling basin and sludge pit were used for the
Of wastewater and wastewater treatment sludge. This sludge is a
process waste which is included in the Resource Conservation and Recovery
Act (RCRA) list of hazardous wastes (F019) because the sludge contains
chromium and cyanides. As a result of effluent overflow fron the basin and
plant wastewater discharge, sludge is »!»•> located in the wooded area
adjacent to the settlement basin (commonly referred to as the "swamp"
because standing water collected as a result of the wastewater discharges) .
The total sludge volume at the site is approximately 8,850 cubic yards.
Since 1978, no solid wastes have been placed in the settlement basin or
sludge pit; wastewater treatment sludges have been mechanically dewatered
at the plant and shipped to an off -site facility for disposal. However,
the treated wastewater discharge route included the impoundments until
October 1980, when the effluent discharge was rerouted around the
impoundments to the swamp area, which drained to the river. In October
1986, the outflow from the wastewater treatment plant was rerouted away
from the swamp directly to a permitted outfall at the river to dry the
swamp area. No standing water was present in the former swamp area within
one month of the diversion of the outfall. The treated process wastewater
has been discharged to the Tuscarawas River through a NPDES permitted
outfall since 1972.
Based on reports filed by AROO, U.S. EPA conducted a preliminary assessment
of the site in 1983. Because of concern about potential contamination of
water resources from sludge leachate, the site was proposed for inclusion
on the NPL of uncontrolled hazardous waste sites eligible for cleanup under
the Comprehensive Environmental Response, Compensation, and Li ability Act
(CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization
Act (SARA) in October 1984. The site was formally placed on the NPL in
June 1986. ,
In November of 1984, AROO retained International Technologies to perform a
Remedial Investigation/Feasibility Study (RI/FS) . In March 1985, RI
activities began at the site. An Administrative Order by Consent was
issued in January 1987 between U.S. EPA, Ohio EPA (OEPA) , and ARCO for
conducting the RI/FS.
The RI was conducted at the site from March 1985 to January 1989. During
the study, samples of sludge, underlying soil, ground water, and Tuscarawas
River sediments were collected at and near the site. An investigation was
also conducted to determine if drums containing waste were burled at the
site. Enough information was obtained to study cleanup alternatives for
the contaminated sludge and soil at the site. A Focused Feasibility Study
(FES) developed for the source control operable unit, presenting an array
of alternatives to address the contaminated sludge and soil, was completed
in June 1989.
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The U.S. EPA is the lead agency responsible for managing the investigation
being conducted by AROO of the Alsco Anaconda site. OEPA is the support
agency for the site cleanup.
Pursuant to its authority under Section 122 (e) of CERCIA, U.S. EPA sent a
special notice letter to AROO on June 26, 1989, notifying them of their
potential liability and responsibility in conducting the design and
implementation of the U.S. EPA's preferred alternative for the Alsco
Anaconda site. As a result of this notice letter, ARCO informed U.S. EPA
that Harvard Industries nay also be a potentially responsible party (PRP)
as a former owner and operator. Pursuant to its authority under Section
122(e) (2) (C), U.S. EPA notified Harvard Industries of their potential
liability as an additional PRP and invited them to enter into negotiations
with U.S. EPA and AROO.
3.0 GCMfjNiTY PARTICIPATION ACTIVITIES
The U.S. EPA has conducted community relations activities throughout the
RI/FFS to provide interested citizens and officials information about
progress at the site.
The U.S. EPA distributed summary fact sheets providing background
information on the Alsco Anaconda site and the administrative order between
U.S. EPA, OEPA, and ARCO in February 1987. A public ccranent period for the
order was held from February 4, 1987 through March 5, 1987.
The RI and FFS reports and Proposed Plan for the Alsco Anaconda site were
released to the public in June 1989. These documents were ™aA» available
to the public in both the administrative record and an information
repository maintained at the U.S. EPA offices in Region V and at the
Gnadenhutten Public Library. Sunnary fact sheets describing the results of
the RI were distributed in May 1989. A fact sheet about the FFS and
Proposed Plan was released in June 1989.
The notice of availability of site related documents and announcement of a
public comment period and public meeting was published in the Dover-New
Philadelphia Tin*5*?~R«^JOF ^gT7 on June 26, 1989 and July 7, 1989. A public
comment period was held from June 26, 1989 to July 25, 1989. A public
meeting was held in Gnadenhutten on July 11, 1989. At this meeting,
representatives from the U.S. EPA and OEPA answered questions about
problems at the site and the remedial alternatives under consideration. A
response to the comments received during the comment period is included in
the Responsiveness Summary, which is Appendix A of this Record of Decision
(ROD). This decision document presents the selected remedial action for
the Alsco Anaconda site, in Gnadenhutten, Ohio, chosen in accordance with
CERCIA, as amended by SARA, and to the extent practicable, the National
Contingency Plan (NCP). The decision for this site is based on the
administrative record. An index of the Alsco Anaconda administrative
record is attached as Appendix B.
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4.0 SCOPE AND KDIE OF OPERABLE UNIT
This ROD represents the first of two planned activities (operable units) at
the site. In accordance with 40 CFR 300.68 (c), the remedial action has
been divided into two operable units: source material and ground and
surface water. This ROD addresses the source material consisting of
contaminated sludge and soil. The second planned activity will address
contamirated ground and surface water. The response action proposed for
the source ma-tw-iai will contribute to the overall strategy for the site as
it will remove the principal threat to human health and the environment due
to possible ingestion or dermal contact with the sludge or soil, eliminate
the threat of release of contaminated matprial to the river, and eliminate
contaminant migration to the ground water.
5.0 SHE CHARACTERISTICS
The RI was conducted from March 1985 to January 1989 to determine the
nature and extent of contamination and to gather enough data to evaluate
cleanup alternatives for the site. Analyses for the EPA Hazardous
Substance tlist. (HSL) compounds were conducted in each environmental media.
Samples of sludge, underlying soil, ground water, and river sediments were
collected at and near the site.
Tuscarawas River flood estimates by the Army Corp of Engineers indicate 50-
year and 100-year flood elevations of 825 and 827 feet MSL, respectively.
Source areas such as the settling basin and former swamp area have
elevations from 823 to 839 feet and 823 to 834 feet MSL, respectively,
indicating the majority of the site in located within the 100-year flood
plain, and a good portion of it is within the 50-year flood plain.
5.1 Sludge and Soil
The settling basin and sludge pit combined occupy approximately four-tenths
of an acre. The -depth of the sludge in the unlined excavations is
approximately eight feet in the settling basin and seven feet in the sludge
pit. The estimated total volume of sludge in these areas is 5,570 cubic
yards. In addition, nearly 1.2 acres of the swamp area adjacent to the
impoundments are covered by sludge, with an average thickness of about 1.7
feet. The estimated volume of sludge in the swamp is 3,280 cubic yards.
The sludge consists primarily of aluminum oxyhydroxides, calcium carbonate,
calcium sulfate, and lesser amounts of various other inorganic and organic
constituents. Trace component concentrations vary depending on activities,
processes, or sources that differed over time and space. In addition to
chromium and cyanide, the sludge was found to contain several other
potentially hazardous or toxic substances, including arsenic, cadmium,
fluoride, mercury, and nitrate. In addition to these contaminants,
volatile organic compounds (TCCs) were detected primarily in the southern
impoundment and polychlorinated biphenyls (PCBs) were detected in the
former swamp area only. Some of the contaminants have seeped into the soil
beneath the sludge, but there are fewer chemicals in the soil and they are
in the soil at much lower levels. See summary Tables 1 and 2 for
concentrations detected in sludge and soil.
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Current estimates indicate that approximately 50 cubic yards of swaitp
sludge are contaminated with PCBs in excess of 500 milligrams per kilogram
(mg/kg), with a sampled high concentration of 3000 mg/kg. Samples taken
under the swamp sludge indicate PCB soil contamination of less than 25
mg/kg. See Figures 3 and 4. .
A 90 foot trench was dug across a portion of the property to determine if
drums containing waste were buried there. No drums were discovered at the
site. •'••..• ''.-.'•••
5.2 Ground water
Uhconsolidated sand and gravel deposits underlie the site, serving as
aquifers that are the primary sources of both public and private drinking
water in the area. There are no wells between the site and the river.
Under a ground water drinking use scenario, sample results indicate
chromium, cyanide, fluoride, nitrate, selenium, and tetrachloroethylene in
the upper forty feet of the aquifer are at levels of public health concern.
Currently, there is no known use of this contaminated water.
The extent of the ground water contamination remains unclear. Questions
which remain about ground water contamination include; the horizontal and
vertical extent of contaminated ground water, the discharge points of the
contaminated ground water (i.e., does all the ground water discharge to the
Tuscarawas River or does a portion flow beneath the river), and the
actual/potential exposure routes (i.e., the upgradient manufacturing
plant's pumping well, downgradient drinking water wells). These unknowns
will be the focus of subsequent investigation (Phase II RI).
Based on ground water HSL sampling results from April 1985 to November
1986, cyanides were detected at a T^xir*™ of 700 micrograms per kilogram
(ug/kg), whereas the lifetime health advisory is 200 ug/kg; chromium was
Aafoarrt-giri at a navi-mim of 140 ug/kg, whereas the MavJTntm Contaminant Level
(MCL) is 50 ug/kg, but proposed to increase to 100 ug/kg; fluoride was
detected at a maximim of 8,700 ug/kg, whereas the MCL is 4,000 ug/kg;
selenium was detected at a nav-j^im of 14 ug/kg whereas the MCL is 10 ug/kg,
.but proposed to change to 50 ug/kg; nitrate was detected at a mavimm of
2100 ug/kg, whereas the MCL is 1000 ug/kg; and tetrachloroethylene was
detected at a itiav-tmim of 9.7 ug/kg, whereas the proposed MCL is 5 ug/kg.
5.3 Sediments
Sediment samples (near site, upstream, and downstream) were taken off-site
in the Tuscarawas River to determine the levels of PCBs and chromium (known
site specific contaminants) in the sediments of the river. Although
analysis of this sampling suggests there may be no site impact upon the
ambient river sediment quality, further investigation is anticipated as
part of the Phase II RI.
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6.0 SOtVKfd OF SITE RISKS
A risk assessment of potential risks to human health or the environment if
no action is taken to clean up the site was developed for the Alsoo
Anaconda site. The risk assessment examined whether existing or future
contact with the source material contaminants poses unacceptable risks.
The risk assessment for ground water will be generated after Phase II
investigative work is completed. The risk assessment was developed in
accordance with U.S. EPA procedures, as outlined in the Superfund Public
Health Evaluation Manual (SPHEM; U.S. EPA 1986) . Conclusions of the
assessment were that an unacceptable risk to humans does exist due to PCBs
in the swamp sludge and arsenic in the settling basin sludge if there is
repeated contact with the sludge in these areas over a long period of time.
6.1 Contaminant
The constituents of concern via direct contact (ingest ion and dermal
pathways) with contaminated sludge and soil were those metals present above
background, all inorganic constituents of toxicological concern, PCBs, and
all organic constituents detected above detection limits. See Tables l and
2 for contaminants of potential concern and concentrations of chemicals on
which the risk assessment was based.
6.2 EX]
At the Alsco Anaconda site, there are four potential ways to cone in
contact with contaminants: through the air, ground water, the river, and
site sludge and soil. Contact with airborne contaminants does not
represent a potential pathway of concern. Contaminants are present in
sludge which has a relatively high water content and are covered with the
vegetation. The organic constituents are present in levels not expected to
result in volatilization to air, and particulate dispersion is unlikely.
Contaminants were found in ground water samples beneath the site.
Preliminary investigation indicates contaminants entering the river's water
and sediments through the ground water are diluted to very low levels. The
potential risks to public health and the environment posed by contaminated
ground water or sediments and their impact on the river will be examined in
the next phase of investigation.
Direct contact with site sludge is a potential exposure pathway. Exposure
may result from dermal absorption of contaminants and ingestion of
contaminated sludges. At the time the risk assessment was developed, the
site was unfenced, and trespasser exposure was feasible. Thus, it was
possible that children playing at the site or workers from the adjacent
plant going on the site might be exposed to contaminants in the sludge.
Although the fence has reduced access from certain routes, access to the
site via the river still exists.
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The assumptions made for the purpose of the risk assessment included:
People would be exposed to areas where the highest levels of
contamination were found. For PCB exposure, an upper bound and
average concentration were used in the risk calculations;-
Sludge ingestion is a route of exposure to all contaminants of
concern, not-mai absorption is also considered as a route of
exposure for PCBs and organic noncarcinogens;
100 percent absorption is assumed,
•'."-. Children are exposed one day per week over a seven-year period.
Workers are exposed one day per week over a forty-year working
life, and
- Sludge ingested in a day is estimate to be 100 milligrams.
These conservative assumptions fashion the risk assessment to be biased
toward health protection.
6.3 Toxicity
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals. CPFs, which are
expressed in units of milligrams per kilogram per day (mg/kg-day), are
multiplied by the estimated intake of a potential carcinogen, in mg/kg-day,
to provide an upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated from the CPF.
Use of this approach ™av«*g underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which animal-to-
human extrapolation and uncertainty factors have been applied.
Reference doses (RFDs) have been developed by EPA for indicating the
potential for adverse.health effects from the exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are also expressed in
mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals, p.gt'i'ma'hftd intakes of chemicals fjcM"
environmental n*ari-iq (e.g., the amount of a chemical ingested from
contaminated drinking water) can be compared to RfO. RfDs are derived from
human gpiHgmjnincrira^ studies or aniinai studies to which uncertainty
factors nave been applied (e.g., to account for the use if animal data to
predict effects on humans). These uncertainty factors help ensure that the
RfDs will not underestimate the potential for adverse noncarcinogenic
effects to occur.
The CPFs and RfDs for the contaminants of concern at the Alsco Anaconda
site are listed in the risk calculation tables (Tables 1 and 2).
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8
6.4 Sunnary of Risk Characterization
Excess lifetime cancer risks are determined by multiplying the intake level
with the cancer potency factor. These risks are probabilities that are
generally expressed in scientific notation (e.g., 1 x 10"^). An excess
lifetime cancer risk of 1 x 1CT6 indicates, as a plausible upper bound, an
individual has a one in one mil linn chance of developing cancer as a result
of site-related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at the site.
Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the Hazard Index (HI) (or the ratio of the
estimated intake derived from the contaminant concentration in a given
Tripoli™ to the contaminant's reference dose). By adding the His for all
contaminants within a medium or across all media which a given population
may reasonably be exposed, a total or cumulative HX can be generated. This
HI provides a useful reference point for gauging the potential significance
of multiple contaminant exposures within a single medium or across media.
A cumulative HI of less than one is considered an acceptable risk to public
health. If the HE results in a value greater than one, cotpounds in the
mixture are segregatied by critical effect and separate His are derived for
each effect. '.••'.'-.•'••• • • :.'•.-• ' . . ../ ."; • •'...;.• •
For most contaminants, the level of risk to public health was below the
safety standards .used by U.S. EPA. The adverse potential risks associated
with the Alsco Anaconda site sludge and soil are listed below:
Trespassing plant workers could be exposed to arsenic in the
settling basin sludge that could yield an excess lifetime cancer
risk of 1.16 x 1CT6.
- Trespassing children and plant workers could be exposed to PCBs in
the swamp sludge in a worst case scenario that could yield an
excess lifetime cancer risk of 6.31 x 10~3 and 1.28 x 1(T2,
respectively.
Finally, portions of the site are located on the Tuscarawas River flood
plain. Therefore, in -the event of a major flood, contaminated sludge and
soil could migrate from the site, posing undetermined risks to the
environment and public health.
The Ohio Department of Natural Resources Division of Natural Areas and
Preserves, Natural Heritage Program was contacted during the RI in order to
address concerns for sensitive biota or habitats. The Heritage Program had
no records for rare or endangered species within a two-mile radius of the
Alsco plant site, and was unaware of any unique ecological sites in the
vicinity of the study area. There are no existing or proposed state nature
preserves or scenic rivers in Tuscarawas County.
Actual or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment. to public health, welfare,
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or. the environment through dermal: contact and ingestion of the contaminated
sludge and soil and migration. of these to the ground and surface water.
7.0 DESCRiprrcN OF AinHaau'-ivis
Based on exposure pathways and receptors of concern and the specific areas
of existing or potential oantamination, medium-specific remedial action
goals were established for the Alsco Anaconda site. The objective of
remedial action is to prevent exposure to contaminants in excess of
established standards, a cumulative HT value of greater than one for
critical effect, and/or a total excess cancer risk of greater than 1 x
in the following media: . ;•
. -sludge and soil, -• •..' '-' ..;•••."' -.- ..'••
".. •'•• .-ground water, '.';'••••"'.'.
•^surface water,
.•• '•"'.' ; ' • -••air.' .' '. - '/' • ' ;• ; '";• ,:- ';. .' - .•'
Direct contact exposure of trespassers to site sludge and soil (site
workers and children); and ground water ingestion exposure to on-site
ground water have been identified as the routes of exposure of concern at
the site. Remedial Action Goals for the sludge and soil include preventing
these materials from contributing to further ground water contamination in
excess of the ground water Remedial Action Goals. The potential for
ingestion exposure to ground water contamination migrating off the site
will be evaluated in the Hiase n KT.
An array of alternatives for addressing source matwiai contamination at
the Alsco Anaconda site was developed. This ROD will not address ground or
surface water contamination. The remedial alternatives selected were
evaluated based on their ability to be protective of human health and the
environment, attain compliance with Federal and State environmental
regulations, be cost-effective, and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the
extent practicable. The remedial alternatives considered for this site are
briefly described below.
Alternative 1 - No Action
U.S. EPA is required to evaluate a "No Action" alternative. This
alternative will result in y^rn'maT changes to the existing site
environment. However, it does include installation of a security fence to
limit human exposure via direct contact with the waste. Also, this
alternative involves use restrictions to control future use of the site.
This alternative will not satisfy the remedial action goals for the site.
Health risks posed by direct contact with contaminated sludge and soil
would be greater than 1 x 10"6. Also, the threat of a release to the. river
and further contribution to ground water contamination are not addressed.
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The estimated capital cost of this remedy is estimated to be $39,000, with
no annual operation and maintenance (O&M) costs. The estimated time to
implement this remedy is approximately 3 months.
Institutional controls and the security fence will be part of each remedy
which proposes leaving contaminated waste on site (Alternatives 2, 5, 6,
and 9).
During implementation of any of the following alternatives, if ground or
surface water is extracted to accommodate the excavation of sludge and
contaminated soil, it will be handled to meet all Federal and State rules.
Hot Swamp Material
Water
alidate/Cap Impoui*3n*aits. Cap Sludge Pit; Incinerate
W^n/Cap SWS™P? Flood toym; Treat/Monitor Ground
This alternative is primarily a containment option. The major components
of this alternative include excavating settling basin wastes and
redepositing waste in same general area of contamination in a lined
impoundment, capping it as well as the sludge pit; the hot swamp material
(approximately 50 cubic yards of swamp sludge contaminated with PCBs in
excess of 500 rag/kg) is excavated and transported off -site to a facility
permitted to incinerate PCS waste, the remaining swamp area is capped; an
approximately 25-foot deep hanging slurry wall is constructed around the
entire swamp area, extraction wells are installed to maintain hydraulic
separation between swamp waste and the ground water; ground water quality
is monitored; and a berm (10 feet high and 700 feet long) is installed
along the Tuscarawas River for flood protection.
F019 sludge is a RCRA-regulated waste. However, placement of the waste is
not occurring in this alternative, so land Disposal Restrictions (1TR) are
not applicable. T.ITV»T- and caps used on site will meet RCRA Subtitle c
regulatory criterion. RCRA surf ace impoundment (40 CFR 264.228) closure
regulations are relevant and appropriate.
At the completion of the remedial action, and all remaining alternatives
evaluated (Alternatives 3, 4, 5, 6, and 9) , health risks posed by direct
contact with sludge and soil would be below a copulative HI value of one
for critical effect for noncazcinogens and below 1 x 10~^ cumulative excess
cancer risks for carcinogens. Meeting this target cleanup level would
protect against exposure by direct contact and ingestion, as determined by
the risk assessment. The estimated capital cost of this component of the
remedy is $3,717,480, with annual O&M costs estimated to be $487,000. The
'to implement this remedy and meet cleanup goals is
approximately six to nine months.
P019 Sludoe In Swam
This alternative consists of the following components: hot swamp material
is excavated and transported off site to a facility permitted to incinerate
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PCB waste; the F019 sludge and underlying soil remaining in the swamp
(approximately 3,250 cubic yards contaminated with PCBs) and in the sludge
pit, northern and southern inpoundments (approximately 5,570 cubic yards)
are excavated to levels meeting clean closure requirements of 40 CFR
254.228 and QAC 3745-66-11 for treatment and riigpngai Or reclamation/reuse
at an off -site facility; and the excavated sludge pit and impoundments are
backfilled with clean borrow (approximately 5,600 cubic yards) . Clean
closure levels require excavation to a depth such that the remaining soils
have pollutants at concentrations below a cumulative HI value of one for
critical effect for noncarcinogenic pollutants and 1 x 10~^ cumulative
excess cancer risk for carcinogenic pollutants. The indicator chemicals
and their concentrations necessary to meet these clean closure levels for
carcinogens and noncarcinogens will be established during Remedial
Design/Remedial Action (RD/RA) .
The off-site facility used for treatment and disposal of the sludge and
soil will be in compliance with the CTPTTA off-site policy (approved
facility) or reclamation/reuse facility. Placement of a RCRA-regulated
waste is occurring; therefore, I£R are applicable. RCRA surface
impoundment (40 CFR 264.228) closure regulations are relevant and
appropriate.
Meeting the target cleanup levels would protect against exposure by direct
contact and ingestion, as determined by the risk assessment. The estimated
capital cost of this component of the remedy is $4,161,066, with no annual
O&M costs. The estimated time to implement this remedy and meet cleanup
goals is approximately four to six months.
4 ~ Off-^ite Treat JHMIII /rrigpngal StiirVpg pit and
Off— site Incir*yF*ation F019
This alternative is similar to Alternative 3, with the exception of all of
the F019 sludge in the swamp contaminated with PCBs (approximately 3,300
cubic yards) is excavated and transported off-site to a facility licensed
for incineration of PCBs.
The estimated capital cost for this alternative is $7,467,616, with no
annual O&M costs. The estimated time to implement this remedy and meet
cleanup goals is approximately four to six months.
Alternatv - -site eamewH''n slude t and
Off-site Incineration of Hot Swamp MatwHai » off-site Treatment/Di^r*"*^]1
019 Sl11fVFB ill SW^HT)* Monitor ^rTOUn
The swamp Tnat-P»rial is handled as described in Alternative 3. The sludge
pit and impoundments wastes are managed as follows: the sludge pit and
settling basin sludge and underlying soil are excavated to levels meeting
clean closure requirements, pre- treated, then stabilized/solidified; an on-
site landfill is constructed in the general area of the existing sludge pit
for the disposal of these wastes; and ground water quality is monitored.
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The excavated sludge pit and impoundment wastes are treated on-site for
cyanides (by oxidation) and metals (by lime-based
stabilization/solidification) to levels which will meet F019 treatment
requirements of LCR prior to disposal.
A landfill meeting RCRA requirements for disposal of hazardous materials
will be constructed on-site occupying an area encompassing the land east of
and including the sludge pit. The landfill will be capped using a RCRA-
type multilayer cap which meets RCRA Subtitle C closure requirements. A
groundwater monitoring program will be implemented to meet the substantive
requirements for ground water monitoring and corrective action under RCRA
40 era 264, Subpart F - Ground water Protection.
The design proposed for the on-site landfill used in this alternative, and
in Alternatives 6 and 9, must meet OEPA siting regulations for a hazardous
[OAC 3745-54-18 (B) (1-2) ] or solid waste landfill [QAC 3745-27-06 (I) (4-
6) ] . As presently proposed it does not meet these regulations.
Meeting the target cleanup levels would protect against exposure by direct
contact and ingest ion, as determined by the risk assessment. The estimated
capital cost of this component of the remedy is $5,064,046, with annual O&M
costs estimated to be $120,750. The estimated time to implement this
remedy and meet cleanup goals is approximately six to nine months.
6 ~ On— site Tr*^ iin-mlT^ndf ill Sl'^f^re Pit and
Off— si"te Incineration F019 Sl1** in Sw^^; Monitor Ground
This alternative manages the sludge pit and impoundments waste material and
groundwater monitoring as described in Alternative 5. The swamp material
is managed as described in Alternative 4.
Meeting the target cleanup levels would protect against exposure by direct
contact and ingestion, as determined by the risk assessment. The estimated
capital cost of this component of the remedy is $7,003,322 with annual O&M
be $120,750. The esfcimaf-»j j"ime> to implement this
remedy and meet cleanup goals is approximately six to nine months.
9 — On si~te TRnegtanent/Iand'H n giivVy* Pit and T^r^xmdments;
Off— sib? IncippT'a'fion of Hot SU^T* MatfriaT« On site Trna'*nn(3rit/Larri'f;'i 1 1
poi9 Slude in Sw^n? Monitor Ground
This alternative is similar to Alternative 5, except for the remediation of
swamp material s. On-site H-igpn«ai of the sludge pit and impoundment
materials (approximately 5,570 cubic yards) and off-site incineration of
hot swamp Tnat-^rjaig (g|T|>f ijiyiTnat-^i y 50 cubic yards) are A*g
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The estimated capital cost of this alternative is $2,765,256, with annual
O&M costs estimated to be $126,500. The estimated time to implement this
remedy and meet cleanup goals is approximately nine to twelve months.
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF AinXSNAlTVES
The following nine criteria were used by the U.S. EPA to evaluate
alternatives developed for the Alsco Anaconda site in the FFS report. The
remedial alternative selected for the site must represent the best balance
among the evaluation criteria.
- Overall protection of human health and the environment addresses
whether or not a remedy provides adequate protection by eliminating,
redi icing, or controlling exposures to unacceptable risks posed by
hazardous substances.
— Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) addresses whether or not a remedy will meet all
of the Federal and State environmental and public health
regulations. This criteria also considers advisories or other
guidelines pertaining to site specific cases.
- Lang-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over tims once cleanup goals have been met.
- Reduction of toxicity, mobility, or volume is the anticipated
performance of the treatment technologies a remedy may employ.
the •i'Bnp3^-'? to the lOCal
community, environment, and workers during the construction and
implementation of the alternative.
— Tmpi KIM-* it a^i i i -fry is the technical and administrative feasibility
of a remedy, . including the availability of materials and services
needed to implement a particular option.
- Cost includes estimated capital and operation and maintenance
costs, and net present worth costs.
- State acceptance indicates whether, based on its review of the
RI, FFS, and Proposed Plan, the State concurs with, opposes, or has
no comment on the preferred alternative at the present time.
- Community acubUJtrinnR indicates whether the public concurs with
the remedy presented in the U.S. EPA's Proposed Plan.
8.1 Overall Protection of Human ^teait-h and the Environment
All of the alternatives, except Alternative 1 (no action) provide adequate
protection of human health and the environment from exposure to
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14
contaminated source material. Risk due to direct contact is reduced to
less than established standards, cumulative excess cancer risk levels less
than 1 x 10"^, and less than a cumulative HI value of one for critical
effect for noncarcinogens. Alternative 1 is eliminated from consideration
for selection.
Alternative 2 addresses risk by removing high-level PCB sludges and
containment of remaining swamp, impoundment and sludge pit areas. The
flood berm inhibits the release of contaminants to the river. Pumping
ground water inside the slurry wall and ensuring a separation between the
waste and ground water will minimize potential for waste migration to the
ground water. The remaining alternatives all combine complete source
removal and treatment to reduce impacts to human health and the
environment, but differ in disposing of material on- or off-site.
Risk due to contaminated ground water is not addressed here, but the
overall site remedy will provide adequate protection of human health and
the environment for each exposure pathway. All alternatives, except
Alternative 1, reduce risk due to further contaminated ground water by
reducing further contribution to ground water contamination. Alternatives
3 and 4 accomplish this to the greatest degree by removing all solid
contamination from the site. Alternatives 2, 5, 6, and 9 reduce risk to
varying degrees with combinations of en-site and off-site disposal of
contaminated source material. The final site remedy for the ground water
operable unit will be selected at a later date and will aHdregg the
currently contaminated ground water.
8.2 Compliance with ARARs
Ihe remedial actions selected for the source mat-ori^i operable unit will
meet ARARs for those activities. Since the ground water operable unit is a
part of the site, the future actions proposed for it oust also meet ARARs
so that the total of all remedial actions taken at the site will attain
ARARs.
Landfill citing regulations for the State of Ohio for both hazardous [QAC
3745-54-18 (B) (1-2) ] and solid waste [QAC 3745-27-06 (I) (4-6) and
3745-27-11] apply at this site for alternatives 5, 6, and 9. The design
proposed for the on-site landfill will not meet OEPA siting regulations for
a hazardous or solid waste landfill.
Toxic Substances Control Act (TSCA) PCS Disposal regulations 40 CFR 761.60
will be met by incineration of waste contaminated with PCBs greater than
500 mg/kg at a ISC-regulated incinerator for all alternatives except
Alternative 1. Waste contaminated with PCBs in concentrations between 50
and 500 mg/kg can be land Hiapmaad in a chemical waste landfill that meets
TSCA (PCBs only) and/or RCRA (PCBs and RCRA ha*ayf*-1"g waste) requirements.
Any waste taken to a off-facility must be in compliance with the CERCLA
off-site policy (approved facility).
RCRA Land Disposal Restrictions will be applicable to Alternatives 3, 4, 5,
6, and 9 and will be met by providing appropriate treatment for the F019
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15
waste prior to disposal. PCRA surface impoundment (40 CFR 264.228) closure
regulations are relevant and appropriate to the sludge pit/inpoundment and
swamp area respectively. The landfill closure requirements (40 CFR
264.310) would be applicable to any on-site land disposal unit constructed
in Alternatives 5, 6, and 9. All alternatives, except Alternative 1, meet
these ARARs.
.3 TrricF/iterjn T^ffgc*"*v>:i»i!-<:i and
Alternatives 3 and 4 afford the highest degree of long-term effectiveness
and permanence utilizing off -site treatment (incineration) of PC&-
oontaminated sludge and off-site disposal to manage residue from
incineration, and off-site treatment and disposal of F019 sludge and soil.
Alternatives 5, 6, and 9 offer a moderate degree of long term effectiveness
and permanence. An on-site lined and capped landfill is a reliable
technology given proper construction, but maintenance associated with a
landfill over time can be high. The flood berm proposed in Alternatives 2,
5, 6, and 9 would have high maintenance requirements due to erosion from
the river and unstable foundation soil. Alternative 2 provides the least
degree of long-term effectiveness and permanence as untreated waste
material is left on-site and capped. Although a properly constructed cap
can be reliable, maintenance associated with it (including a potential need
for replacement) can be high. The suitability of these control measures
are questionable in a flood plain setting.
8.4 R^^tion of Toxicity. Mobility and Voltm**
All alternatives (except no action) treat a principal threat posed by the
site source material by incinerating sludge contaminated with at least 500
mg/kg PCS. Alternatives 4 and 6 provide the most treatment, and therefore,
the greatest reduction in toxicity, through removal and incineration of all
F019 sludge contaminated with PCS concentrations above 25 mg/kg. The
volume of waste would not be substantially reduced because only organic
constituents are destroyed, and the volume of organics in the sludge is
minimal . Alternatives 3, 4, 5, 6, and 9 all use a combination of oxidation
(to destroy cyanide) and stabilization/solidification to reduce the
mobility of inorganic contaminants. Alternative 2 does not pretreat F019
waste providing the least reduction in toxicity, mobility, and volume.
8.5 Short-fry**""' fr
Alternatives 2, 5, 6, and 9 take the longest time to implement as
traction activities (i.e. , berm, cap, landfill) are executed as part of
the remedies. All alternatives (except no action) call for excavation and
material handling and the potential for releasing waste Tnat-c. into the
atmosphere. Alternative 2 presents the greatest risk to workers and the
environment due to particulate emission during construction activities.
Alternatives 3 and 4 include off-site transport of all contaminated
materials on site, and therefore, the community is subject to more short-
term risks than in other alternatives. Precautionary measures will include
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protection from direct contact of contaminated sludge and soil to workers,
and dust suppression. The implementation period until cleanup goals are
achieved for all alternatives is similar.
8.6 Tnyil <=mip»ritab'i 1 ity
Alternatives 3 and, 4 would be the simplest to implement, both technically
and administratively. However, there is sane uncertainty of availability
of facilities to pretreat and landfill or reel a i Try/reuse F019 sludge and
soil. Alternative. 2 is the most difficult to implement, requiring fairly
complicated construction activities (benn, slurry wall, cap, and landfill).
Furthermore, swamp waste would be disturbed during these activities.
Alternatives 5,- 6, and 9 are complex because of the on-site fixation of the
waste ma+w-iaTg- and the installation of an on-site landfill. Any of the
on-site disposal remedies will face administrative opposition by OEPA due
to flood plain siting concerns.
Alternatives incorporating on-site construction as part of the remedy (2,
5, 6, and 9) have higher operation and maintenance costs associated with
these structures; "Because of operation and maintenance requirements,
Alternative 2 has the highest total present worth cost. Off-site
incineration capital costs are high for Alternatives 4 and 6 because they
utilize this technology for treatment, making these two alternatives the
most expensive after Alternative 2. Alternative 3 provides a similar level
of protection as Alternative 4, but is less costly because it provides for
less incineration treatment.
8.8
The State of Ohio does not support any alternatives which include on-site
disposal or closure of waste material (2, 5, 6, and 9) as part of the
remedy. The State contends Alternatives 2, 5, 6, and 9 do not provide
adequate protection of human health and the environment because there is a
potential for release of contaminants when waste v^^ri^I is located in a
floodplain.
•
The State believes Alternative 4 is more protective than Alternative 3
because all the PCS contaminated swanp sludge will be incinerated before
landfilling (if landfill ing, as opposed to reclamation/reuse is the
selected disposal option) . The State has indicated that although it
prefers incineration as the form of treatment for the PCS contaminated
waste, considering all factors, it will accept Alternative 3. The State
would also accept Alternative 4.
tance
The U.S. EPA's preferred alternative was presented at the start of the
public comment period through distribution of a fact sheet. The notice of
availability of site related documents and announcement of a public comment
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period and public meeting was published in the Dover-New Philadelphia
TJ Ttwag-Popnrter on June 26, 1989 and July 7, 1989. A formal public meeting
was held, to discuss the proposed plan in Gnadenhutten, Ohio on July 11,
1989..
Comments received indicated residents and local officials are supportive of
the U. Si EPA' s preferred alternative. Public cannents on the proposed plan
are addressed in the Responsiveness Seminary, attached to this document.
9.0 THE SELECTED REMEDY
Alternative 3 adrirpfisps all public health and environmental threats posed
by contaminated source material at the site. This alternative represents
the best balance among the evaluation criteria and satisfies the statutory
requirements of protectiveness, compliance with ARARs, cost-effectiveness,
and utilization of permanent solutions and treatment to the mavintiTm extent
practicable.
All of the F019 waste in the southern and northern impoundments and sludge
pit (approximately 5,570 cubic yards) will be excavated and hauled to an
off-igite facility in compliance with the Section 121(d) (3) of CERCLA, 42,
U.S. .C.. 9621 (d) (3) and the CERCLA Off-site Policy or a reclamation/reuse
facility. •. Clean up levels for the F019 waste sludge and underlying soil
will meet the remedial action goals. All sludge and underlying soil are
removed to a depth that prevents the ingestion or direct contact of waste
having a cumulative HI value of one for critical effect for noncarcinogens
or having 1 x 10"6 cumulative excess cancer risk from, carcinogens, and
prevents contribution to further ground water contamination to in excess of
Maximum Contaminant Levels (MCLs) . Prior to disposal, treatment standards
for the F019 waste, as required by the RCRA Land Disposal Restrictions,
will be met by the accepting off-site approved facility. The topical
depression left by the excavation of the sludge pit and northern and
southern impoundments will be backfilled with clean borrow (approximately
5,600 cubic yards) and recontoured in a manner which complies with OAC
3745-66-11 and ensures contaminated ground water does not contact the
surface.
Hot swamp material (approximately 50 cubic yards contaminated with PCBs
greater than 500 mg/kg) will be excavated, drummed, transported and
incinerated off-site at a facility which is approved to incinerate such
materials.
Remaining F019 sludge and underlying soil in the swamp (approximately 3,250
cubic yards contaminated with less than 500 mg/kg of PCBs) will be
excavated to clean up levels (discussed above) and hauled to an approved
landfill or reclamation/reuse facility. These materials will be pretreated
as required at the disposal facility. Because of possible instability of
the swamp, roadways may be installed and used for swamp excavation. The
swamp area will be regraded and seeded to promote revegetation of the area.
All excavated sludge and soil will be packaged and transported off-site in
compliance with 40 C.F.R. 262 and 263 and 49 C.F.R. 170-189 107.1 and
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1711.500. The excavation and packaging shall be conpleted in such a manner
that particulate matter or other pollutants are not emitted to the air in
excess of the levels allowed by 40 C.F.R. 50, Section 12 of the Clean Air
Act (42 UiS.G. 7412), and Rule 08 (B) of Chapter 3745-17 of the Ohio
Administrative Code (QAC 3745-17-08 (b) ) and OAC 3745-57-01. Any equipment
used for excavating, sampling or handling contaminated sludge and soil
shall • be decontaminated in accordance with 40 C.F.R. 264.114 (CAC 3745-66-
14). ..;: - / ..'.•••.
Any clearing of the wooded area to the west of the swamp for the purpose of
constructing access roads shall not occur within fifty feet of the eastern
shore of the Tuscarawas River; shall minimize the amount of clearing and
ensure that the cleared area is returned to its previous condition after
all required remedial actions are completed.
If ground or surface water is extracted to accommodate the excavation of
sludge and underlying soil, it must be sampled to determine whether there
are any hazardous constituents. Based on the results of this sampling,
extracted ground water will be transported, discharged, and/or disposed in
was way which meets all Federal and State rules.
Meeting the target cleanup levels would protect against exposure by direct
contact and ingest ion, as determined by the risk assessment. The estimated
capital cost of this component of the remedy is $4,161,066, with no annual
O&M costs. Table 3 illustrates a detailed cost summary for this remedy.
The estimated time to implement this remedy and meet cleanup goals is
approximately four to six months.
Some changes may be matte to this remedy as a result of remedial design and
construction processes. Such changes, in general, reflect modifications
resulting from the engineering design process.
10.0 S'lMUlUKY UblliMGNATICNS
Under its legal authorities, EPA's primary responsibility at Superfund
sites is to undertake remedial actions that achieve adequate protection of
human health and the environment. In addition, Section 121 of CERCIA
establishes several other statutory requirements and preferences. These
specify that when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a statutory
waiver is justified. The selected remedy must be cost-effective and
utilize permanent solutions and alternative treatment technologies to the
maximim extent practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly reduce
the mobility, toxicity, or volume of hazardous wastes as their principal
element. The following sections disniga how the selected remedy meets
these statutory requirements.
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The selected remedy protects human health and the environment from exposure
to contaminated source material. All contaminated sludge and soil is
removed from the site, reducing the risk due to direct contact to less than
established standards, cumulative excess cancer risk levels less than
1 x 10"6, and less than a cumulative HI value of one for critical effect
for noncarcinogens. Risk due to contaminated ground or surface water is
not addressed here, but the overall site remedy will provide adequate
protection of human health and the environment for each exposure pathway.
Removal of contaminated source material will prevent these materials from
contributing to further ground or surface water contamination. There are
no short-term threats associated with the selected remedy that cannot be
readily controlled.
Reom'naaents
The selected source material remedy will comply with ^11 applicable or
relevant and appropriate chemical-, action-, and location-specific
requirements (ARARs). The ARARs are presented below.
:ific ARARs:
Maximum Contaminant Levels (MCT.fi) promulgated under the Safe
Drinking Water Act (SDWA) will not be achieved with this source
material operable unit, but the overall site remedy will achieve
MCLs. This remedy will facilitate ultimate achievement of the .
MCLs by removing contamination which contributes to the ground
water concentrations being above MCLs.
- Treatment and/or disposal of PCB contaminated waste complies with
the Toxic Substance Control Act 15 U.S.C. 2601 and 40 CFR 761.60.
Ohio Revised Code (ORC) 6111.042 regulations requiring compliance
with national effluent standards will be met.
Ohio Administrative Code (OAC) 3745-17-08(8) addresses
restrictions of fugitive dust mission and will be met.
The remedy will ccnply with CERdA Section 121 (d) (3) and the
CEKCLA Off-site Policy for waste transported off-site.
Action-specific ARARs:
- Surface impoundment closure requirements (40 CFR 264.228) will be
met. RCRA Land Disposal Restrictions (ITR) under 40 CFR 268 apply
because placement is occurring and will be met.
Excavated sludges and soils will be packaged and transported off-
site in corpliance with 40 CFR 262 and 263 and 49 CFR 170-189,
107.1 and 1711.500.
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The excavation and packaging will be completed in a manner that
particulate matter or other pollutants are not emitted to the air
in excess of levels allowed by 40 CFR 50, Section 12 of the Clean
Air Act, and Rule 08 (B) of Chapter 3745-17 of the QAC 3745-17-
08 (b), QAC 3745-57-01, and work is in compliance with 3745-1-
05 (A) and (B), 3745-31:-05(A) (3) and QRC 3767.
The excavated sludge pit and settling basin will backfilled with
clean borrow and recontoured in a manner which complies with CAC
3745-66-11 and any access roads constructed and revegetated in
compliance with 33 CFR 322.
Any equipment .used for excavating, sampling, or handling
contaminated source material shall be decontaminated in accordance
with 40 CTO 264.114 (QAC 3745-66-14) .
Use restrictions 40 • CFR 264.116 and 264.117.
sific ARARs: : • ' .-•'• : ' •'. . ''•.• ; •''•;.:. ,; •:'/'".''•
The remedy will comply with Executive Order 11988, Floodplains
Management and QAC 3745-54-18 locations standards. : , .
10. 3 Oost-ef fectiveness
The selected remedy is cost-effective because it has been determined to
provide overall effectiveness proportional to its cost, the net present
worth value being $4,161,066. t^ig alternative attains the same reduction
in current risks from direct contact with source matwiaig as Alternatives
2, 5, 6, and 9, requires no O&M expenditures, and therefore, is the least
expensive. Alternative 4 has similar benefits as the preferred
alternative, but the additional cost (approximately $3.3 million) in
achieving a greater reduction in the toxicity of the organic contaminants
outweigh the expected benefits.
10.4 uHl •iy.af-ton of ppTT"^ngTTt Solutions and Altritdtive
Tteciumlocfieg for PE^OUTPP Recovery TfaciiiiolocrL*8^ to tlv? ifevHi«Tm Extent
Practicable
The U.S. EPA has <^gt-oirm'irta
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• • /. .21
site. While the selected remedy may not offer as high a degree of long-term
.effectiveness and permanence as alternatives which call for incinerating
all the PCB contaminated swamp sludge, it will significantly reduce the
inherent hazards posed by the source material through oxidation to destroy
cyanide and stabilization/solidification of the metals:arid PCBs such that
the residual material that remains to be managed at an 'off-site disposal
facility can be contained with a high degree of certainty over the long
term. Since the remaining material will be bound up, the impact on human
health and .the environment would be minimal if the containment system were
to fail. Additionally, if all the PCB contaminated swamp F019 sludge was
incinerated, the ash would still have to be handled and treated according
to the ITR standards..
Recycling the F019 sludge may be feasible and will be implemented if
practicable. ' . ....•'•
The selected remedy does satisfy the statutory preference for a permanent
solution because all contaminated sludge and soil are removed from the site
and treated. No waste will be left oh the site.
10.5 Preference for tPreaiJ'»-'ML as a Principal TH.^HMJIK • ••'....'..: ..
All of the corTtaminated sludge and soil are treated or recycled in
Alternative, 3 * The swamp sludge highly contaminated with PGBs is
incinerated, The remaining sludge and soil may transported of f-site to a
reclamation/reuse facility. If recycling is not feasible, prior to
disposal, treatment standards for the F019 waste remaining on the site in
former swamp area, the settling basin, and sludge required by the RCRA LER
are met through oxidation, and stabilization/solidification. Therefore,
the statutory preference for remedies that employ treatment as a principal
element is satisfied.
11.0 DoccMonaixcN OF SIGHIFICAOT
The Proposed Plan for the Alsco Anaconda site was released for public
comment in June 1989. The Proposed Plan identified Alternative 3,
excavation and of f-site incineration of swamp sludge highly contaminated
with PCBs, excavation of settling basin, sludge pit, and remaining swamp
sludge and soil and transportation off-site for treatment and disposal or
reclamation/reuse, and backfilling the excavated settling basin and sludge
pit with clean T^^rial/ as the preferred alternative. EPA reviewed all
written and verbal comments submitted during the public comment period.
Upon review of these comments, it was determined that no significant
changes to the remedy, as it was originally identified in the Proposed
Plan, were necessary.
-------
ARCO CHEMICAL COMPANV
NEWTOWN SQUARE. PENNSYLVANIA
I... Creating a Sator Tornono*
-------
CO
s
o
rO
,
' a/ftfi^&K.V<^ - * '"3 i V=H-'-A "-^N: * '•'•« ^-v ^f~ .'•fQ-JTsG'1-' .*^^ A '
Wlfe^^XA:'•'•'•:- /-yV^rr^X .V.- V-i/^^^r : ^sJv^,
^^M^^'v^ (^'•i^i;^-^v^>^^fe^ ; Bs,S3
i^t^^°-- e^^^'i^^l ^ ' ! ^C
L%p|£\ -\ ^^^J^^^^ T?^4^
—/S^S: v>K,s-r 7~-= *^-te—^^.•.r^.-^i^^-iA*^" -.T-->^ »i-<-'f-*' \^V
!^:^^¥^
'' •*"* •" ^tW/\A ^V*^
^K|i
rv;M3a§^^^^.-'
SCALE
REGIONAL MAP SHOWING WATER
AND OIL /GAS WELL LOCATIONS
GNADENHUTTEN, OHIO
REFERENCESv
4000 FEET
2000
LEGEND
/0« WATER WELL
(LOGINAPPENDIXC)
PREPARED FOR
ARCO CHEMICAL COMPANY
• I UJS.G.S. 7.5-MINUTE SERIES
-° . GNAOENHUTTEN AND NEW
PHILADELPHIA,OHIO QUADRANGLES
-. DATED 1962, SCALE; I "s20OO" .
2. ODNR DIVISION Or .. AT ER, 1945-1985 AOIL/GASWELL NEWTOWN SQUARE, PEN NSY LVANIA
WELL LOGS AND DRILLING REPORTS
• 3'.. BURGESS 8NIPLE LTD.. 1984
. ' HYDROGEOLOGIC STUDY, ARCO METALS CO.
/?fct A P\C kl LJ I IT TC tl <^tiiy^ '
GNAOENHUTTEN,OHIO.
•,1984 IT CORPORATION
Af f COPYRIGHTS RESERVED
Q3
... Creating a Safer Tomorrow
-------
SLUDGE PIT
\
o H Tp-V
^-prp-2 rr^®^-2
APPROXIMATE EXTENT
OF SLUDGE
NORTHERN
IMPOUNDMENT
-.MW-3
SOUTHERN
IMPOUNDMENT
GROUND WATER SAMPLES;
GROUND WATER MONITORING WELL
IMPOUNDMENT SAMPLES' .
S'2O HAND AUGER SAMPLE LOCATION
TP-7Q TEST PIT LOCATION
SWAMP AREA SAMPLES'
• HAND AUGER SAMPLE COLLECTED
NOVEMBER 1986. AND JANUARY 1987
HAND AUGER SAMPLE COLLECTED
MARCH 1987
PCBs CONCENTRATION-
POINT LOCATION PCS CONCENTRATION
31 IN mg/kg
CONTOUR SHOWING PCS CONCENTRATION
IN mg/kg ->
FIGURE J
DISTRIBUTION OF PCBi IN SLUDGE
AT THE ALSCO ANACONDA SITE
CNAOCMHUTTEM. OHIO
PACPMEO FOA
IOOFEET
ARCO CHEMICAL COMPANY
NEWTOWN SQUARE,PENNSYLVANIA
-------
SLUDGE PIT
I 2253?54
NORTHERN
IMPOUNDMENT
// SOUTHERN
IMPOUNDMENT
GROUND WATER SAMPLES:
GROUND WATER MONITORING WELL
IMPOUNDMENT SAMPLES'
S"2O HAND AUGER SAMPLE LOCATION
TP'7Q TEST PIT LOCATION
SWAMP AREA SAMPLES'
• HAND AUGER SAMPLE COLLECTED
NOVEMBER 1966 AND JANUARY 1987
®HAtJD AUGER SAMPLE COLLECTED
MARCH 1987
PCBs CONCENTRATION-
6.4
POINT LOCATION PCB CONCENTRATION
IN mg/kg
I.O—^CONTOUR SHOWING PCB CONCENTRATION
IN mg/kfl /.
FIGURE 4
DISTRIBUTION OF PCBs IN SOIL
AT THE ALSCO ANACONDA SITE
GNAOENMUTTEN, OHIO
PREPARED'FOR
100 FEET
ARCO CHEMICAL COMPANY
NEWTOWN SQUARE, PENNSYLVANIA
-------
TABLE 1
tlSK CKA!ACTER[ZATIO« FO« IOHCARCIKOGEIIS II SLUOSE A«0 SOIL
CHILD
OMSTITUEIT
I II ORGANIC
Cadaiua
Chroaiua (total)
Chroaiuat
(hexavalent )
Cyanide (total)
Hercury
OR CAM 1C
VotattlM
Ethylbenzene
2-H.exanone (butyl Mthyl ketone)
TetracMoroethylene
Totu*n«
Xylenet, Total
«eld/8aie-ll«utral E«traet«blt«
tia(2-ethylhexyl)ptithalate
Oll-lutylphthalate
phthalene
Phenanthrene
Pyrene
MAXIMUM COICCItTIATIO*
11 SLUDCE OS SOIL
(•9/ks)
6.8
17,000
13
S.OOO
18
110
43
0.28
5.3
410
2.9
0.8
0.51
16
200
0.38
0.66
tEFE«E«C£
DOSE*"
<-S/kg/day)
2.9
1.0
5.0
2.0
3.0
1.0
S.O
2.0
3.0
1.0
2.0
2.0
4.0
2.0
4.0
4.0
4.0
x
x
X
X
X
X
X
X
X
X
X
X
X
x
X
X
X
Hazard
10*
10°
10"3
10"2
10"*e
10"1
10"2c
10"2
10"1
ID'2
10"2
10-2"
10"1'
10-'
10"'*
10"'
10"'
Index
3
2
3
4
1
3
1
3
2
1
IAZAIO
IKOEX
OEIMAL
.
-
„
.00 x
.34 x
.82 x
.82 x
.12 x
.95 x
.09 x
.48 x
.18 x
.36 x
2.59 x
4
.50 x
Total
• 1
9
1
1
3
ID'* 6
1C'*
10** 7
10"* 1
10"2 2
10"S 8
10"5 2
10"7 7
10"5 4
10-* 2
10"7 5
10"7 9
0.0344
•A2ACO
110 EX
IICESTIO*
.34
.69
.48
x
X
X
.4 x
.43
.27
4.9
.89
.01
.34
.26
.28
.27
.56
.85
.41
,40
X
X
X
X
X
X
X
X
X
X
X
X
f
10-'
10"*
10"*
10"2
10
ID'5
10-5
10'7
10"*
10"J
10"
10;"
10"
10"
10"
10"
10"
IA2AM
I0EX
OEIMAL
a
.
•
6.11 x 10"*
4.77 x 10"*
7.77 x 10"*
9.81 x 10"*
2.28 x ID"2
alos x io"s
2.22 x 10"5
7.08 x 10"7
4.44 x 10'!
2.77 x 10"*
5.27 x 10"7
9.16 x 10"7
0.0460
IA2AKO
IIOEX
IICESTIO*
2.72 «
1.97 i
3.02 <
2.90 ,
6.96 «
1.28 «
9.98 i
1.62 i
2.05 i
4.76 x
1.68 i
4.64 i
1.18 i
9.28 i
5.8 »
1.10 .
1 .91 «
.3
!o-j
10-*
ID'2
1C'4
10-5
10'*
10-*
10'»
10-5
ID'6
10'7
10'6
1C'5
10"7
1C'7
*D«rmal contact to Inorganic contaminant* not calculated.
faS*NEN, 19866
,et«f«r«nea doat, «r Accaptabla Intake for Chconic €xpo«ur« (»IC). for awthyl «thyl katona u*«d.
-^tafaranca do«a for II* (2-«thyl haxyl) phthalat* mad.
. *«aa«d on tha un»«r«flad rafaranc* do»« for "aphthalani. Integrated llak. Information
tyate* (U1J) Office of lealtti and EnvlronaMntal Aaaetaownt, U.S. Env
-------
TABLE 2
RISK CHARACTERIZATION FOR CARCINOGENS IN SLUDGE AND SOIL
CONSTITUENT
MAXINUN
CONCENTRATION
IN SLUDGE OR SOIL
(•g/kg)
CARCINOGENIC
POTENCY
FACTOR*
(•g/kg/day)
-1
LIFETIME
CANCER
RISK6
(CR)
CHILD
ADULT
TOTAL
LIFETIME
CANCER RISK*
CHILD ADULT
INORGANIC
Arsenic
PCBt
57
3,000
80.8
f
1.75
7.70
7.70
5.68 x 10~7 1.16 x 10"6
7.63 x 10"3 1.55 x 10~2
2.06 x 10"4 4.18 x 10~4
ORGANIC
Bl«(2-«thyt hcxyl)
phthalitt
N-Nltrosodlphenyl-
aralne
Tetrachtoroethylene
2.9
0.67
0.28
8.40 x 10
-3c
5.10 x 10*
8.02 x 10'9 1.63 x 10"'
4.92 x 10'3d 1.09 x 10'9 2.21 x 10"9
4.71 x 10'9 9.61 x 10"9
7.63 x 10"3 1.55 x 10'2
•SPHEN, 1986
lifetime Cancer Risk (CR) • (Estimated Dally Intake [mg/kg/day]>
(Carcinogenic Potency Factor [mg/kg/day] ). Estimated Daily Intake
calculated for dermal and Ingestlon routes for alt contaminants except
arsenic. Ingestlon route only calculated for arsenic.
cToxlcologlcajHtrof I le for Ol(2-ethyl hexyl) phthalate, December 1987.
aU.S. EPA Health Assessment Document for Epjchlorohydrin,
1983, U.S. EPA 600/8/83-032A.
eTotal Lifetime Cancer Risk calculated using maximum
contaminant concentration only.
TThe average concentration calculated without using the
maximum concentration of 3000 mg/kg.
-------
TABLE -3
ALTERNATIVE 3
CAPITAL COST
ITEM
NO.
1
2
3
4
5
6
7
8
9
10
11
DESCRIPTION1/
Excavation, Impoundment ,•• ',
Borrow/Backfill/Compact,.Impoundment
Off-Site Landfill, Impoundment
Excavation, Swamp
Incineration, Hot Swamp • \ :••• :
(Includes Exc./Handling) •
Off-Site Landfill, Medium Swamp
Off-Site Landfill, Low Swamp,
Seeding, Site
Fence ',.-..•
Engineering @ 15 percent Items 1 to 9
Contingency @ 15 percent Items 1 to 9
UNIT
CY
CY
CY
CY
CY
CY
CY
SY
FT
PERCENT
PERCENT
QUANTITY
5,570
5,570
5,570
3,300
50
650
2,600
8,900
2,000
15
15
UNIT COST
($)
15
14
285
25
1,200
820
285
0.60
15
480,123
480,123
TOTAL COST
($)
83,550
77,980
1,587,450
82,500
60,000
533,000
741,000
5,340
30,000
480,123
480,123
TOTAL
4,161,066
-------
APPENDIX A
BESPGKixIVENESS SDMAK?
-------
ALSCO ANftCCNDA SITE, OOHNHOTIEN, CHTO
RESPCIBTVENESS SCM4ARY
CVilfl/lfcW
The U.S. Environmental Protection Agency (U.S. EPA) has gathered information
on the nature and extent of contamination, evaluated remedial measures for
source materials (contaminated sludge and soil), and recommended remedial
actions for the source control operable unit at the Alsco Anaconda site.
Public participation in Superfund projects is required in the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). Comments received
from the public are considered in the selection for the site. This document
summarizes the comments received regarding the proposed source control remedy
and describes how they were incorporated into the decision making process.
During the public comment period, the U.S. EPA presented seven alternatives
to address contaminated sludge and soil at the site. The U.S. EPA
recommended Alternative 3, excavation and off-site incineration of swamp
sludge highly contaminated with PCBs, excavation of settling basin, sludge
pit, and remaining swamp sludge and soil and transportation off-site for
treatment and disposal or reclamation/reuse, and backfilling the excavated
settling basin and sludge pit with clean material, as the preferred
alternative. The public comments received were generally supportive of U.S.
EPA's recommendation.
The community relations responsiveness summary has the following sections:
- Background on Community Involvement and Concerns.
Summary of Comments Received during Public eminent Period and Agency
Responses.
Remaining Concerns.
/ ~ . •
B. BACR3RCUND CN CCMCNTIY mTOEtfEMEOT AND GCNCERKS
According to county officials during community interviews, citizens have
accepted the Alsco plant as an integral part of the QTadenhutten community.
While residents closely follow news about the Alsco plant, county officials
report they nave received only infrequent inquiries and complaints about
ongoing operations at the Alsco plant and the adjacent Superfund site.
Several of the individuals interviewed for the preparation of the community
relations plan suggested the reason so few corplaints are lodged is because
the Alsco plant is a major revenue source for Gnadenhutten's tax base and
residents fear the plant would move if community attitudes were unsupportive
of the plant operations. Written or vocal concern about the Alsco Anaconda
site has been extremely limited to date.
The U.S. EPA distributed summary fact sheets providing background information
on the Alsco Anaonnria site and the administrative order between U.S. EPA,
Ohio EPA, and ARCO in February 1987. The Rpmpdial Investigation (RI) and
-------
.Focused Feasibility Study (FFS) reports and Proposed Plan for the Alsco
Anaconda site were released to the public in June 1989. These documents were
made available to the public in both the administrative record and an
information repository maintained at the U.S. EPA offices in Region V and at
the Gnadenhutten Public Library. Summary fact sheets describing the results
of the RI were distributed in May 1989. A fact sheet about the FFS and
Proposed Plan was released in June 1989.
The notice of availability of site related documents and announcement of a
public comment period and public meeting was published in the local
newspaper. In July, residents attended a public meeting held in
Gnadenhutten. At this meeting, representatives from the U.S. EPA and OEPA
answered questions about problems at the site and the remedial alternatives
under consideration.
C. SCMJftRY OF GCtMEttES RECEIVED CORING PUBLIC CCMQNT PERIOD
This responsiveness summary addresses oral and written comments received by
the U.S. EPA concerning the RI, FFS, and Proposed Plan for the Alsco Anaconda
site. The comment period was held from June 26, 1989 to July 25, 1989. A
public meeting was held July 11, 1989 in Gnadenhutten to allow the public ah
opportunity to present oral and written comments.
Public Conimerrt'-'g Received and U.S. EPA
1. Mr. Charles Miller commented he did not have the technical expertise;
to judge or comment on the alternatives presented, and would have to
go with the trainer! professional's opinion for the site cleanup. He
expressed interest in implementing the best, most emnmvical way of
handling pollution at the site.
U.S. EPA response: U.S. EPA is also interested in implementing the
best remedy for the site. Several factors are taken into
consideration when selecting a cleanup alternative, such as protection
of human health and the environment; effectiveness ; reduction in
toxicity, mobility, or volume; implementability; compliance with
federal, state, and local environmental laws and regulations; cost;
and acceptance by the ocnraunity and the State. Alternative 3 provides
the best balance among these criteria.
2. Mr. Ted Martin recommended Alternative 3 or 4 be executed at the site.
He indicated Alternative 4 may be more complete, more material is
treated through incineration, but Alternative 3 would probably be
ideal as far as money was adeemed.
U.S. EPA's Response: As mentioned in the response above, the U.S. EPA
uses nine balancing criteria in selecting the best cleanup remedy for
a site. U.S. EPA does recognize that Alternative 4 will yield a
greater reduction of toxicity than Alternative 3, but believes
Alternative 3 provides the best balance among the criteria by using a
different, less expensive, form of treatment.
-------
3. Mrs. Dorothy Shull questioned the: quality of the drinking water in her
neighborhood, a grot?) of homes with private wells located
approximately three quarters of a mile southwest of the site across
the river. She also indicated\a desire to have the Tuscarawas River
cleaned up, expressing concern that chemicals have caused the river to
have a terrible color.
U.S. EPA's Response: More ground water and river sediment work is
going to take place in the next phase of investigation. A
determination will be made if contaminated ground water underneath the
site is discharging completely to the river, or if some portion of 'the
ground water is traveling beneath, the river towards the wells in
question. The quality of the ground water at the exposure points will
then be evaluated. No residential well sampling is planned at this
time, as the data suggest contaminants from the Alsco site have not
reached residential wells. ;
This action pertains only to tte 4.8-acre Alsco Anaconda site formerly
used for sludge disposal, and not the ongoing operations of the Alsco
plant. The plant is currently permitted to discharge wastewater to
the Tuscarawas River. U.S. EPA will investigate and evaluate the
impact of the former sludge disposal area on the river and ground.
water, taking action if necessary to protect human health and the
environment. . ..
Ohio EPA Comments Received and U.S.
1. Ohio EPA believes Alternative 4 is more protective than Alternative 3,
because all of the PCS contaminated swamp sludge will be incinerated
before landfi11 ing (if landfilling, as opposed to reclamation/reuse,
is the selected disposal option). While Alternative 4 does not
significantly reduce the volume of the waste as compared to
Alternative 3, it does provide the greatest reduction in toxicity by
destruction o£ the PCS material.
U.S. EPA's Response: U.S. EPA contends Alternative 3 is just as
protective of human health and the environment as Alternative 4
because both alternatives will achieve the «™«» remedial action goals
of preventing exposure to contaminants in excess of established
standards, reference doses for noncarcincgens, and/or total excess
cancer risk of 1 x ID"6.
U.S. EPA does recognize that Alternative 4 will yield a greater
reduction in toxicity than Alternative, 3, but believes Alternative 3
provides the best balance among the criteria used for evaluation.
U.S. EPA would not take exception to another party, a potentially
responsible party (PRP), for example, taking on additional expense to
perform the incineration treatment described in Alternative 4 as long
as it is approved by U.S.. EPA. .
-------
2. Alternative . 3 would be Unproved by incinerating the swamp: sludge
-------
has not submitted any information demonstrating that the "swamp" area
satisfies all three of these criteria. The information U.S. EPA has
indicates the area does not have the necessary wetland hydrology nor
soil characteristics. The area has been predominantly dry since the
: wastewater discharges were directed away from the area in 1986.
Furthermore/ U.S. EPA is not aware of the presence of water in the
area for a week or more during the growing season.
Even if the "swamp" was considered a wetland there is no support for
requiring a more "protective" cleanup level for this operable unit
; remedial action. There is no State or Federal rule which specifies
the degree of cleanup as a concentration level that must be attained.
i Section 121 (d) of CERCLA does require a degree of cleanup which
protects human health and the environment. The Summary of Site Risks
Section of the Record of Decision (EDO) for this operable unit
indicates the PCBs and F019 contaminated sludge and soil will be
excavated and removed to a depth which protects human health and the
environment. In particular, the primary contaminant pathways, A=T"«]
- contact and ingestion, will be eliminated by removing the sludge and
contaminated soil to a depth which ensures carcinogenic levels of
- pollutants below 1 x 10"^ cumulative excess cancer risk and
noncarcinogenic pollutants below a cumulative HI value of one for
critical effect. The carcinogenic and noncarcinogenic levels are
based on epidemiological and animal studies. If additional studies
warrant a more stringent cleanup stantard, it will be evaluated.
Furthermore, cental with-contaminated ground water will not occur
because it is not anticipated that the excavated area will intersect
the ground water table, and the area will be recontoured and
vegetated after excavation. The risks to human health and the
environment associated with the contaminated ground water will be
assessed as part of the Phase U ground and surf ace water RI/FFS.
4. The Proposed Plan should specify clean-up criteria will not exceed a
1 x 10~° cumulative excess cancer risk level for carcinogens, and will
not exceed a. hazard index of one for ncn-carcinogens.
U.S. EPA's Response: The Proposed Plan states on page 8 the specific
cleanup goals for the Alsco Anaconda site: risk due to direct contact
is reduced to less than established standards, cumulative excess
cancer risk levels less than 1 x HT6, and less than reference doses
for noncarcinogens. The cleanup goal for noncarcinogens in the ROD
was changed to be less than a cumulative HI value of one for critical
- effect. ' •; '. .,'•".-;-- '•;'.. -: .'
For noncarcinogens, any single chemical with an exposure level greater
than the reference level will cause the hazard index to exceed unity.
For multiple chemical exposures, the hazard index may exceed one even
if no single chemical exceeds its acceptable level. The assumption of
additivity reflected in calculating a single hazard index for all
noncarcinogens .is most properly applied to am* mi ids that induce the
same effect by the same mechanism. Consequently, applying this
equation to a mixture of compounds not expected to induce the same
-------
type of effects could overestimate the potential for effects. If the
hazard index results in a value greater than one, the compounds in the
mixture will be segregated by critical effect, and separate hazard
indices for each effect will be derived. The total hazard indices
calculated for the Alsoo Anaconda site are well below unity. If the
hazard index for an effect exceeds unity, the cleanup action will, if
appropriate, remove hazardous substances to the reduce the hazard
index to less than one.
1. Atlantic Richfield Company (ARCO) supports U.S. EPA's recommended
cleanup remedy (Alternative 3) for the following reasons: it is
protective, effective and permanent, not difficult to implement, uses
treatment technologies, and would remove waste majwiais from the 100-
year flood plain.
U.S. EPA's Response: U.S. EPA acknowledges this support.
O. REMAINING GGNCESKS
Issues and concerns raised during the public meeting about remedial action
activities include the following:
What if buried drums containing waste were discovered during remedial
action ?
U.S. EPA has investigated the possibility of buried drums at the site
during RI activities, and no drums were discovered. A geophysical
technique for sensing buried wastes will probably be used at the site
before excavation begins to confirm the presence or absence of buried
drums. If drums containing waste are discovered, they will be handled
in a way which meets the site cleanup goals and all state and federal
rules. .-.••../
Will the waste materials be transported off-site safely?
U.S. EPA will ensure the material is moved off-site in a way which is
safe to workers and the community with a minimal impact on the
community. Trucks will be covered and prepared to prevent leaking,
or waste will be containpd in drums at the site and then transported
off-site. A site specific health and safety plan will be developed
and implemented. Transportation off-site oust also comply with U.S.
EPA's and U.S. Department of Transportation's hazardous waste
transportation regulations.
-------
B
ACKDtCSIRKFIVE KECCRD INEEX
-------
Aisro
ncss/mxs
ss nits
rms
8J/CS/I8 Litter as fjJlov-up to
.VS/SJ Jetter, confining
pJao of action fur
/mi
Correspccifecce
87/02/03
l«ct
-------
Pare lie.
07/JUt?
mss/mns PAGSS cm
KCOJJD
A1SCO AHACOflDA SlfS
, OHIO
rm*
AfffflOR
DOCMSAT m£
44 8S/05/1S-
1 87/03/12
14 7S/05/27
IS 84/12/27
j 84/12/28
88/10/21 letter re.-fS rorJt Plan,
requesting an extension
'til 11/15/88 to suniit
tie IS iforJc Plan
88/10/25 /ollo»-up letter to
10/21/88 Itr, stating
tnat 05SPA (fill grant
extension, not 10/7/88
deadline for suniittal
of for* Plan ras oniet
88/10/28 letter re.-final revitv
coiients pertaining to
H report of lay 1S88
87/02/00 ffSSPA /act Sneet
8£/04/07 ACflOI HMSAJWK
J.frao:,ARCO
Ccrrespccieoce £
f.Constantelos,
signed nf F.AdaiJtus,
Veto re.-Data Assessient
for Alsco Gnadeniotten
Plant,Ofcio Keiedial
Inrestigation
fritn attacnients)
tfeio re:Punlic conent
period on Alsco Anaconda
RI/TS consent order
OfFA Aotnoriration to
Discnarge Under tie
lational Pollotant
Ciscnarge JJiiination
Sfstei
(lot AJjco Anaconda,Inc.)
OJPA Aatnoriration to
Ciscnarge Under toe
lational Pollntant
Discnarge fliiination
Sfstei
(/or Arco Ketals Co.)
Director's /inal
/indings and Orders
(2 attacnientj)
J.Adais,Cnief, (?A Office
CJojj,Director,C«ntraJ
JiegionaJ Lanoratorf
J./ranz,AJ?CO Correspondence 7
J.Innz,kRCO
Correspondence 8
/act Sieets 5
Keiorandoi 10
Oiederaang,I75£PA Keiorandui
I.KeCoc.Couanitf delations
Coordinator,ff5?PA
f.riliiais.Director
om
lilt
Keiorandoi
Peni ts
S,Crossian.Asst.Director
om
Peni ts
om
11
12
14
PJeadings/Orders J5
-------
face He.
07/27/1!
ncas/tms ft.css DUTS
RECORD IMSI
ALSCO Mtcom sirs
cmsmrm, OHIO
AST SOU
DOCUKSST HeS
3! 87/OU2!
2 37/02/04
17 00/00/00
23 85/oi/n
84 86/06/00
301 81/10/31
.15 86/12/08
18 87/02/13
iiiisistn-tir-e Order
iy Cement
Press Release
'usm sms muc
COMMIT OH ALSCO
SITE
and OSfA
Pleadiajs/Ordfrs l(
Alscc Anaconda SI/IS
Stateient of fork
Beilth and Safety Piao
AIsco Anaconda
fiespoose to the in
Data Issesneot for
fleiediaJ Investigation
Jualitf Assurance
Project Plaa -
Derision 0 dtd 1/85,
Revisioal dtd 5/85,
Serisioall dtd 7/8f J
FK IF Report on
fjeJd ictiriti'es at
Aisco Anaconda Site
11/12/86-12/5/81
y
final Coiiooitf
ReJatioas Plan
vsm
vsm
IT Corporation
IT Corporation
If Corporation
Jacoos Jnjineering
Caip, Dresser, Jcfee (CM]
VSSU
vsm
osm
Press Release
Reports/Studies
Reports/Stadies
Reports/5tadies
Reports/Studies
17
Reports/Studies 22
Reports/Studies
-------
• = c« .Vc.
f V ."7/6?
mm
TUi. os;c
Guidance Docu«bts:-a're araiJaiie /or reriei? at
' A: Region V-Chicago II
.AOTBOR.
DATE
Keiedial Action-
Objectives'
Activities it Superfuad
Ectorceieat Sites
federal Lead fleiediai
Project laaageieot
tfacoa] :
•'••>•
Dir.m'S.-l'-or
OQ/00/00
85/02/22
Sl/12/00
Interii Guidance:
Streuliaiag the CERCLA
Settltient Decision
Process
Supertand Public .
Eeslth Sraloitioo XaooaJ
Ifeto re-.PCB Contaii-
aztioo—Regolatorj tad
Pclicj Background
laterii Goidaace on
Adiinistntirt Records
for Decisions on Selection
of CSSCLA Response Actions
Jnnsiitttl letter for
Applicable or Relevant ..
and Appropriate State
Reqoireients(AURs) for
anj retedial action oflder-
takta at Alsco Anaconda
Sitt
Draft Gaidance on
Preparing Suptrfond
Decision Docnientstfbt
Proposed Plan and HOD
Draft Guidance on PRP
Participation in the Rl/tS
87/02/12
OSm Oir.i'UW'
B.Hanson,
OSm DJr.SSJJ.4.
S.Poortan.OSPA.
tir.S355.3-92
tir.S835.U
87/07/00
87/01/10
87/11/09
87/11/24
88/03/00
88/04/00
-------
fsge He. I
mmsmim mm imi-.umn n
f.LSCO IRICOSOA SITS
CEIO
! PICES EATS
TITLE
MTSOR
RSCIPIEST
• OOC'JKEHT TIPS
SQCXIIX:-
87/n/2t
I 88/11/22
1 88/12/20
• Letter- listing MRs S.Poonan.OEPl
• -for • any feiedial action
vhicb- May be- taken at
'Alsc'o Aaacoada .site
(pertinent statutes and
regulation! cited are
attached) ; ' :
Letter giving cotpilation D.Kallf,IJS£Pl
of vsm-t&t osn
coueatr
oo IS.totk'plaa of 10/88,
stating coneflts tost be
addressed before appro raJ
P.LeBlanc.OSEPl Correspondence
J.O'Brien,AKCO Correspondence
letter stitHig'tbat.FS
Sort Pl»a.':toiet.lj/.i8
is appro r«(f if -USEPi ts
of 12/20/88, issaiiog
tinor changes listed
are tadt ' •;•;';. "'•
O.Millr.tSStl
T.KcLane.ARCO Correspondence
2 89/01/06
.2 . 89/01/18
2 89/02/16
2 83/03/01
2 89/03/13
i«tt«r
agreeients tade at
12/1/88 tettioi •.
concerning ...
Alsco inaconda Site
Letter ezpressiag concern B.Coastaatelos,ffSEPl
aboat progress UCO has
lade oa RI71S as agreed
to ia the Idiiaistrttire
Order bf Coaseat
T.XcLane.MCO Correspondence
t.Leake,lRCO Corresponding
Letters stating VSEPA
ii nadated to coiplf
fita all federal tad
Sttte IRIRs, reqaestiog
eoneats oa tSiS package
sitbia 30 da ft of receipt
of letter
Letter ia response to
reqaest for eoneats
oa cotpliaace ritb
mis
t.Sade,8.Coastaatelos-
ISEPi
S.talsh,R.Sbaok-OEP Correspondence
t
I.trooaeiejer.OS Dept.
of lateriorlDOI)
Letter re:Secariag of f.XcLane.MCO
IPL Site, ritb tttacateat
D.Hallf.USEPi Correspoadeact
D.Kallf.SSSPA Correspondence
-------
Page Jo. I
07/27/89
• mmsmrm 'mm
' ILSCO mcom. sm
ti
mss/tms mis cm
Tins
illustrating location
of additional fence
•MTBOR
RSCIPISS?
12 89/63/16
fransiittaJ letter vith
Ohio't IRiRs for the
ilsco Anaconda site
J.Rochottt,OEP/(
Correspondence
2 89/03/16
1 89/04/07
T.KcLane.KRCO
25 89/02/08
2 89/02/28
1 89/03/02
7 89/03/11
letter re.-fleoris Reioval
at ilsco Anaconda,ritn
attacnient
Response to Itrs. dated
3/13 and 3/16/89; stating
tnat no objections exist
to 1RCO proceeding vitb
fencing to secare the
site or. proposed debris
retoval and storage,
as sach actions are con-
sidered interit response
and not reiediaJ actions
Jfeio re.-Coipiiance vith S.Kallj,JISSfi
im* for JeiediaJ ~
Actions at Aisco Joacooda
ffi 5ite,$nadeonitten, OS
(site bistorj/btckgroQDd,
site cnaracterizatioo,
screened reiediaJ teenno-
Joyies, and IRlRs identi-
fied of contractor
attacnedj
ffeio re.-J?esponse to S.Rothblatt,USSPl
IRIRs tor Ilsco tnaconda,
vitb conents attached
D.Kally,USSPi Correspondence
T.Kclaoe,iRCO Correspondence
Addressees
Keioraadat
ffeio conentin? on
request package
fl.Spencer,Km
Keto re-.Request for iR&Rs I. leaner,VSSP&
for ilsco Anaconda 5oper-
foad Site, ritn
ittlfhttnt '..-.'
D.lallj.UStti. Hetoraadut
Setonndai
].6arl,OStti Keioraadai
-------
S £5.'Cj/J5 ; Trami::*!'letier vitk IT Cotpcraticn
Aitesdci '., notifications ; ••
sad Clarifications to RI . . ": .
L'SEft.
Ho. 3
07/.27/S!
S PAGES DATE
17 86/08/07
uuiismnn RECORD imi-.mm n
ILSCO mcom sirs
, OBIO
rim • ..
iork Plan, Rerisioa 1
MHOS
Tnasiittal letter vith . If Coifsntioa
Addenda! II, .
notifications
tad Clarifications to
RI fork Plaa, Revision I
87 88/12/00 IS fork Plan
89/01/25 Preliiiaarr Eealtb
Assessieat
ir Corporation
5 Public Be alto
Serfict
ucmur
Reports/Studies
Atlantic Richfield Reports/Studies
Co.
SStPA
Reports/Studies
-------
Page-.H.G.-' ' • :r.
07/27/89 •'••'
DATS
RECORD SAKPLHC-/DATA IXDSI-. UPDATE t-r
'•' ALSCO Amom'Sirs, emmaim OB
' .DOCVKEXTS'-HOT COPIES, HAY BE REVIEW AT THE . .
' US'SPA RlGIOll V OHICES, CBICAGO, ILLWOIS.
ASTBOR
RECIPIENT
HPS
87/01/23 Reritv of Regies f
CLP'Dati Received for
Reriev on 1/21/S1
S7/01/27 Reriev of Region 7
CLP flata Received for
Reriev OB 1721/87
87/01/29 Reriev of Region 7
CLP Data Received for
Reriev oa 1/27/87
87/03/04 Reriev of Region 7
CLP Data Received for
Reriev oa 1/21/87
C.-Ross.,Central Regional Laboratory P.LeBlanc,VSEPA Satpling/Data
C.Ross,Central Regional Laboratorj P.LeBlanc,OSEPA Satpling/Data
C.Ross,Central Regional .Laboritorj P.LeBlanc.HSEPA Saipling/Data
C.Ross,Central Regional Laboratorj P.LeBlanctUSSPi Saipling/Dita
-------
.?«ce-A'c.
imiinm. PACES urn
:r-im •
mm iww.-ppw.rf
iisco ASf.com sirs ' .'
.V, OHIO '•'•
MTBOR
• RECIPIEST
DOCVKEXT TYPE
DGCHOXSSi
4 SJ/OJ/07
5 89/04/27
4 S3/05/16
11 89/OS/U
4 83/OS/14
1 89/0(/30
S 89/05/09
'letter
vithSSEn'aod
OEPl cotitnts oo
RI Report
Letter revised
Inacoada Detailed
Analysis of ilterna-
tires, RI Rerisioas..
9itb attaebieot '.
rraasiittal letter
rith OSPi's eonests
on Draft IS :•
Jnosiittal letter •
wti mil aad- :• '•'.
OSPl eonents on .
IS,rtqatstiag that :
these conents be:
incorporated in the
uezt sabiittal of. '
tit IS .:
letter stating that
USSPl decided to
postpone tie decision
on groondvater reiedial
action selection until
questions it to tht
exact nature and extent
of cantaiination are
resolred-.portions^ot II
listed are approred
and art adeqnate to
allot selection of
reiedial action
Letter re-.State pi
Ohio's fart it
Consent Decree
legotiations
lact Sheet:'SStPt .
SeJeases iisco
Anaconda Pollution
'Report'
S,P.oortan,QSPL/
LMeinratb.nSEPA
J'.Rochotte.OEPA
.J.Rochotte.OSPA
BMllf.VSEPl
l.Clariiio.OSEPA
asm
R. Sloan, A'lscc
Cbeiical •
Cctres-psndence
•I.Sclue.lKO
T.KcLane.ARCO
C.Safner.OSPA
•Correspondence-
Correspondence
Correspondence
Correspondence
Correspondence
lact Sheet
( 83/OS/OO lact Sheeti "mil
mn
lact Sheet
-------
Page So.
97/27/89.
om
•I •'• • 89M/2S
I- ' 89/97/H
U 99/99/09
IS 87/02/28,
21 88/OS/99
US 89/91/09
212 . 89/96/99
Tins
Proposes Cleanup
Plan for disco
Anaconda'
Keio re.-proposed
plaa for Usco.
Anaconda stating that
a decision »as lade
to address oaly tbt
source lateriai at
tie site,so6se?aeat
to tie draft 75
release
Ktio reicoaferttce
call rit« 'OIH oa
ilsco
Proposed tlaa
Coimaitj Xtlatioas
Plan. .. :; •'•; : ' .-•
Response to SSEPl
and Gin rerier
coueots SI Report,
prepared for IRCO
Cbtiicil
S.I Seport, prepared
for ItJaatie lica-.
field Co. . : • '..•:.
/oeose.d /easioiiitf
Stodf *eport,.pr.epared
for JtJaotic JficifieJd
Co..". ;
RECORD imi-.upms 12
Ai5co mcom SHI
osio
RSC1PISST
D.Kallr.VSSPH
Addressees
LClarizio.USSPt
file
If. Corporation
If Corporation
If Corporation
vsm
Kttorandut
Ktioraadai
socmssn
10
Rtports/Stadm n
RtpOTts/Stadid 12
ttportt/Stadits JJ
aeports/5todjj.« it
Reports/Stadits 15
-------
face 'Ho.
37/27/35
rms
oocuKssrs imi-.mm 12
ULSCO mCOWM SIK-CWDmfffTM, OSIO
Guidance flocuieots are arailafile for ren'ev at
OSSPt Regies V-Chicaqo II
DIK
Guidance Doceieot
for CJeanup of
Surface Iipouflo'ient
Sites .
usm osm sii.i3so.c-s i(/of/oo
Iiterii Cdidacce on
CojpJJaflce vitb ARIS
.tequiteteots
Sorface
CJeafl. Closure
Gsiiaoct tiuml,
prepared bj CS2H Bill
CERCU CoifliiDci vith
Other lavs - Kaooai
«eio re.-flraft fortiag
Paper -OB tie Approacfi
to -Addressing. PCS
CofltaiiaatioD at
SoperfaDd Sites
Guidance .00 Jeiedial
leeiofls for Cootaii-
oated Crooud ITater
at Soperfond Sites
Interii foidaoce on
JdiiBiscracire Xecord
for SeJectioa of
Response iccioos
leio re. -PCS CoBtaii-
oation at Superfcad
Sites . :. .
land CisposaJ Sestric-
tions 35 KeJerant and
Ippropriate ieqoire-
leats- for CW.CW
coataiinated soiJ
and deoris
asm osm Dir.s23i.o-ts SJ/QJ/OS
asm osm mr.svs.oo-s.c 87/10/12
OSm Sit.3234.l-tl
6.1anson,!7SfPA
M/05/06
U/09/29
USSPi OSm Oil. 3283.1-2 88/12/00
>•• Km -OSm Dir. 9833.3i '. 83/03/01
83/04/07
•vsm osm 0^9347.2-01 i9/os/os
-------
ige So.
S/02/S9
icss/ims ruts cm
ntu
nomismrm RECORD iiDsi-.mm
usco mcom sirs
GiMMiffrrM, OBIO
AUTHOR
RlCIPItlT
Docvmr
M/07/IJ
85/07/00
J 8S/07/17 Letter re»Alsco
Aoicooda Coastat
Stert«
S JS/07/J5 General lotiee
Letter
J 8S/tf7/2S letter profiting
OEM's approral of
7oea«ed Itisibilitr
Stadj,itctioat «t
toe HI,tad contntlaq
on tie proposed plan
Sf «5/(J7/JJ faolic Keetia? fotes
Xeio r«iR
------- |