United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-88/015
July 1988
SEP A
Superfund
Record of Decision
Pacific Hide & Fur, ID
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50277-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R10-88/015
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Pacific Hide & Fur, ID
t Remedial Action - Final
S. Report Dete
06/28/88
horts)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
1ft. Abstract (Limit: 200 words)
The Pacific Hide & Fur (PHF) site, consists of approximately 11-acres of fenced land,
located in the northwest edge of Pocatello, Bannock County, Idaho. The site, a former
gravel mining area, was purchased by Mccarty's, Inc. (MI), a scrap metal dealer, in
1958. MI purchased scrap metal, batteries, drained transformers, and capacitors filled
with PCB oils from various sources, storing them onsite in a previously excavated gravel
p_it. The waste is stored in the excavated pit, comprised of approximately three acres,
resale, reuse, or salvage. In August 1979, PHF purchased the rights to salvage
'ap metal for .four years. In the course of salvage operations, materials may have
been moved from the pit. Also, PHF may have purchased scrap metals and transformers and
stored them onsite. Records indicate that none of the new transformers purchased by PHF
contained PCB oils. Transformers containing fluids were drained into site drums or into
the pit. In January 1983, the U.S. EPA and the Idaho Department of Health arid Welfare
(IDHW) began investigating the site to determine whether disposal of PCB oils were
occurring on or offsite due to operations at the metal facility. EPA declared the site
to be an immediate threat to public health and welfare. As a result, approximately 593
PCB capacitors were transported offsite for incineration, and 21 hazardous materials
drums and 30 cubic yards of soil were transported offsite for disposal. Additionally,
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Pacific Hide & Fur, ID
First Remedial Action - Final
Contaminated Media: soil
Key Contaminants: PCBs
0. Identifiers/Open-Endeo Terms
c. COSATI Field/Group
W
{lability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
51
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce •
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EPA/ROD/R10-88/015
Pacific Hide & Fur, ID
First Remedial Action - Final
16. ABSTRACT (continued)
11 ground water wells and a security fence were installed at the site. The primary
contaminants of concern affecting the soil are PCBs.
The selected remedial action for this site includes: excavation of soil to an
average of 1.5 feet followed by screening to separate large contaminated materials and
testing for further contamination; stabilization of a portion of the soil using an
immobilization technique; construction of a bottom clay liner, where necessary; capping
of the stabilized and remaining materials; removal of some ground water monitoring
wells; ground water monitoring; and deed and access restrictions. If the fixation
technology is found to be impracticable, onsite containment will be implemented as the
final remedial action. The estimated present value of this remedial action ranges from
£1,330,000 to $1,890,000. There is no O&M associated with this remedy.
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DECLARATION FOR THE
McCarty's/PacifIc Hide and Fur Superfund Site
Record of Decision
Site
McCarty's/Pacific
Pocatello, Idaho
Hide and Fur
Statement of Basis and Purpose
This decision document presents the selected Remedial Action for the
McCarty's/Pacific Hide and Fur Superfund site, in Pocatello, Idaho, developed
in accordance with CERCLA, as amended by SARA, and the National Contingency
Plan. This decision is based on the Administrative Record for this site. The
attached index identifies the items which comprise the Administrative Record
upon which the selection of the Remedial Action is based.
The state of Idaho has provided written concurrence on the selected
remedy.-
Description of the Selected Remedy
This Record of Decision addresses source control of on-site contamination
through excavation of contaminated soils and fixation of the soils in a
solidified matrix. If fixation is found to be
study, on-site containment will be implemented.
will be capped to further reduce surface water
potential for direct contact, and to eliminate
releases of contaminated materials.
The Remedial Action will include:
impracticable through a pilot
The entire area of concern
infiltration, to eliminate the
the potential for airborne
Determining which portions of the contaminated materials can be
practicably excavated and processed (screening). Factors used in
making this determination are worker and public health, and physical
limitations of excavation and processing equipment.
Excavation of all highly contaminated materials which can be
practicably excavated and -"recessed.
Excavation of all low level contaminated soils. Excavation will
cease when those soils' containing contaminants that exceed the
10-4 to TO'7 cancer risk values have been removed. This risk
range corresponds to a 25 ppm PCB soil contaminant level.
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' Immobilization of processed material in fixation matrix.
• Consolidation of remaining materials of concern.
* Construction of a bottom liner, where necessary.
' . Construction of a cap over entire unit.
* Construction of groundwater monitoring wells
* Removal from service of existing groundwater monitoring wells which
are no longer needed.
Treatment will be sufficient to significantly reduce the mobility of the
contaminants and should be permanent. The liner and cap will further contain
and isolate the contaminants from the environment.
Continued groundwater monitoring will be performed to ensure that no
contamination migrates into the aquifers after the Remedial Action Is complete.
Institutional controls, such as deed restrictions to prohibit excavation
or drilling, will be developed, consistent with the final design, to ensure
that the Remedial Action will continue to protect human health and the
environment.
In compliance with SARA, the effectiveness and performance of this final
Remedial Action will be reassessed at regular intervals, not to exceed five
years. .
DECLARATION .
The selected remedy is protective of human health and the environment,
attains federal and state requirements that are applicable or relevant and
appropriate, and is cost-effective. With fixation, this remedy satisfies the
preference for treatment that reduces toxicity, mobility, or volume as a
principal element. With the use of fixation technologies, it is determined
that this remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. A pilot test is necessary to
determine the maximum practicable extent to which fixation can be applied. If
the alternative treatment is found to be impracticable, a waste containment
remedy, whicli does not Include'treatment, will be implemented which is also
protective of human health and the environment, attains federal and state
v requirements: trtat are applicable- or relevant and appropriate, and is cost
'Oeffectiv<'
\*.A
Robie G.'- Russell^- j . Date
Regional Administrator
U. S. Environmental Protection Agency, Region 10
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DECISION SUMMARY
REMEDIAL ALTERNATIVE SELECTION
FINAL REMEDIAL ACTION
MCCARTY'S/PACIFIC HIDE AND FUR
POCATELLO. IDAHO
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TABLE OF CONTENTS PAGE
I. INTRODUCTION 1
II. SITE DESCRIPTION AND LOCATION 1
III. SITE HISTORY 4
A. Site Operations/Disposal History
8. Regulatory History - Previous Investigations,
Activities
IV. ENFORCEMENT 5
V. DOCUMENTATION OF SIGNIFICANT CHANGES 5
VI. COMMUNITY RELATIONS 6
VII. SITE CHARACTERISTICS - REMEDIAL INVESTIGATION 7
VIII. SUMMARY OF SITE RISKS - RISK ASSESSMENT 1!
IX. ALTERNATIVES EVALUATION - FEASIBILITY STUDY 13
X. SELECTED REMEDIAL ALTERNATIVE 16
A. Description of the Selected Remedy
8. Statutory Determinations
APPENDIX
I. '•' INDEX TO ADMINISTRATIVE RECORD
II. RESPONSIVENESS SUMMARY
III. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENT*
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LIST OF TABLES
Table Page
1 Estimated Risk by Total Exposure 11
2 Remedial Action Candidate Alternatives H
3 .Screening of Alternatives Summary 17
LIST OF FIGURES
Figure Page
1 Vicinity Map 2
2 Historic Information 3
3 Surface Soil Sample Locations 9
4 Exploration Trench Locations 10
5 Limits of Excavation 19
6 Remedial Alternative Cross Section 22
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I. INTRODUCTION
The purpose of this Decision Summary Is to summarize:
Past activities.at the site
• The nature and extent of contamination
* The pathways of contaminant migration
* Risk associated with potential exposures
• The method for establishing site cleanup standards
• The method of remedial alternative development
• The methodology for evaluation of remedial alternatives
* The results of the detailed evaluation of alternatives
• The preferred remedial alternative
• The enforcement status of the site
• The opinions and acceptance of the preferred alternative by the
commun1ty.
This Information Is presented \o support the Record of Decision.
II. SITE DESCRIPTION AND LOCATION
The McCarty's/PaclfIc Hide and Fur site consists of approximately 11
acres presently enclosed by a fence, located in the southern half of Section
16, Township 6 South, Range 34 East of the Boise Meridian, Bannock County,
Idaho. The site is located at the northwestern edge of Pocatello, Idaho at
3500 U.S. Highway 30 West. A vicinity map Is shown in Figure 1.
Union Pacific railroad tracks border the site on the south. The
Portneuf River is approximately 1,100 feet south of the site. On the north,
the site Is bounded by U.S. Highway 30 West. West of the site is the
headquarters of the existing scrap metal operation. Facilities at the
headquarters consist of a one story building including office and garage
facilities, a metal shed used foe scrap metal storage, a metal shear, parking
areas and roadways.
The majority of the site is relatively level and is covered with scrap
metal Including vehicles, truck bodies, machinery wire rope, tin cans, and
miscellaneous debris. Topographically, the elevation of the groundwater
surface is approximately at 4,400 mean sea level (msl) and slopes gently to
the north and west with a maximum of 4 feet of relief between monitoring wells
across the site. The center of the site consists of a gravel pit
approximately 20 feet deep and comprising approximately 3 acres. The gravel
pit was excavated in the 1940's and 50's and since approximately 1956, has
been used for storage or disposal of scrap metal. A site map showing areas of
concern is shown in Figure 2.
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null* tl>ll>
Vicinity Map
ure I
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EXPLANATION
I*tt
l*f •! *uc«;
A«« r«i. l«t d »i Coll Ha 11-411(1
»•!• 1'tl
k| IkKllllll
O«l« •<»*
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III. SITE HISTORY
A. Site Operation/Disposal History
The site was previously used by a gravel mining operation as early as
1949. The site was purchased by McCarty's, Inc. in approximately 1953, which
operated a scrap metal business there until August 1979. McCarty's. Inc.
purchased scrap metal from various sources, stored it until it was cut up,
sold and transported to various steel mills or salvaged and reused. Some
scrap metal was stored in the pit awaiting resale or salvage.
In the course of these operations, transformers were purchased and
scrapped at this site. The majority of the transformers were empty of fluid
when received at the site. The processing of the transformers consisted of
salvaging the copper wire and scrapping the casing. Any fluids that the
transformers may have contained were apparently drained on the bank of the pit
in the general area of the southwest corner.
Associated with the purchase of transformers, some capacitors filled with
PCBs were received. Having no salvage value, the capacitors were discarded in
the pit. Records regarding the site indicate that capacitors containing PCS
oils were received between 1970 and 1973, but give no indication that PCS
oil-filled transformers were received at the site.
Batteries were also accepted at this site. Methods of disposal of
battery adds are unknown. The lead contained withi/i the batteries was
salvaged and sold for reprocessing." The battery casings were broken and
disposed of-at various locations on site. Used drums were accepted for use as
shipping containers for scrap metal. Some of the drums had residue- remaining
on the bottom of the containers.
In August 1979, the McCarty's Inc. scrap metal business was sold to
Pacific Hide and Fur, Inc. Included in this transaction was sale of the land
and buiIdings -comprising the headquarters west of the site. However, title to
the site was retained by the McCarty's Inc. Pacific Hide and Fur, Inc.
purchased the rights to salvage any ferrous metals in the pit for a . -?od of
4 years. In the course of these salvage operations, materials may h^ i been
moved around the pit. In addition, some scrap metals purchased by Pacific
Hide and Fur, Inc. may have been stored at the site.
The Pacific Hide and Fur, Inc.'s operation-was generally similar to that
of McCarty's, Inc. Scrap metal was purchased from various sources, sorted and
stored until It was resold or processed and shipped to purchases?. A few
transformers wtre purchased by Pa"c1f1c Hide and Fur, Inc.; however, Pacific
Hide and Fur, Inc.'s records indicate that none contained PCS oils. Some of
the transformer* did contain fluid which in one case was drained into drums in
a shed behind the office building; in the other instance, the fluid was
drained onto the ground in the pit.
In January 1983. the U.S. Environmental Protection Agency (EPA) and Idaho
Department of Health and Welfare (IDHW) began investigating the site to
determine if disposal of PCS oils was occurring on the property and if
contamination of the soils and groundwater on or off-site had occurred due to
operations at the facility.
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8. Regulatory History
Based on groundwater samples obtained from vicinity wells, on-slte PCS
soil contamination data, as well as the general site conditions, the EPA
declared tn« site to be an immediate threat to the public health and welfare.
EPA undertook an Emergency Removal in March 1983 to mitigate the immediate
threat. 593 PCS capacitors were removed from the site and transported to an
approved disposal facility for incineration. Thirty cubic yards of
contaminated soil was excavated and disposed of off-site in an approved
landfill. Twenty-one drums containing hazardous materials were also removed
from the site during the Emergency Removal and transported to an approved
disposal facility. Subsequent to the Emergency Removal, fifteen additional
capacitors were found in various scrap piles on-slte. These capacitors were
disposed of at approved facilities in 1986.
The Emergency Removal also included construction of 11 groundwater
monitoring wells, the collection and analysis of groundwater samples, and the
collection and analysis of soil samples. A security fence was also
constructed around the site to restrict access.
The Emergency Removal was followed by the listing of the site on the
National Priority List on September 21, 1984.
The McCarty family. Pacific Hide and Fur Depot, Inc.. and Idaho Power
Company have either previously owned the land at the site, currently own or
operate the facility, or owned the capacitors and transformers which were
discarded.at the site. Collectively these companies are termed Potentially
Responsible Parties (PRPs). With guidance and oversight by the U.S. EPA and
IDHW, the PRPs have undertaken and completed the Remedial Investigation (RI).
Risk Assessment, and Feasibility Study (FS) for the site. The U-.S. EPA and
IDHW have accepted the PRP RI, FS, and Risk Assessment reports as sufficient
to provide enough Information to make a clean-up decision. However, EPA and
IDHW evaluations and conclusions about the risks imposed by the site and the
relative merits of the remedial alternatives differs from those of the PRPs.
Consequently, revisions to portions of the PRP documents were developed to
reflect EPA and IDHW positions.
An alternative for clean-up of the site was initially proposed by the
PRPs. Based on the RI. FS, Risk Assessment and additional research, the
preferred alternative described in this document was developed by the EPA and
IDHW.
IV. ENFORCEMENT
EPA initiated a civil action-against a number of the PRPs in March 1983.
The action war filed under CERCLA, RCRA and TSCA. and sought injunctive relief
for response action and cost recovery under CERCLA sections 106 and 107. The
action was commenced at the same time that EPA undertook a removal action at
the site, during which EPA carried out the activities described in Section
III Site History of this document. Following a number of legal developments
that included the issuance of a preliminary injunction that assisted EPA in
the conduct of the removal action, the parties entered into a Partial Consent
Decree in which the P0<3s agreed to perform an RI/FS at the site. This Decree
was entered, by the U. . -Oistrict Court for the District of Idaho, on September
29. 1986.
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In a separate legal proceeding, a criminal enforcement under TSCA action
was taken against Pacific Hide and two of Its managers. The alleged criminal
violations Included Improper storage and disposal of PCS capacitors, and
Incomplete recording as to PCS materials at tne site. A Jury verdict
convicting Pacific Hide and these managers was obtained at the U.S. District
Court and for the District of Idaho In 1985. That conviction was later
overturned at the ninth circuit court of Appeals.
A separate legal proceeding was taken agafnst Pacific Hide under TSCA
administratively. The administrative complaint in this action was Issued In
1987. The violation alleged in that proceeding Included Improper storage of
PCS materials and failure to complete annual reports concerning the presence
of PCSs at the site. This proceeding was settled in May 1988.
The RI, FS, and Risk Assessment were conducted by the Potentially Responsible
Parties under the Consent Decree described above. EPA will soon begin
implementation of the settlement procedures set forth In Section 122 of
CERCLA. 42 U.S.C. §9622. Special Notice Letters will be sent to the PRP's in
late June 1988 to offer those same parties the opportunity to perform the
selected remedial action pursuant to a consent decree. Informal negotiations
between EPA and the PRPs on the clfe-a., up have begun. The state of Idaho has
been Involved in the negotiation.
If for any reason agreement cannot be reached with these parties, EPA
will Initiate alternative action ta ensure that the "remedial action proceeds
in a timely manner.
V. DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes from the proposed plan were produced in the
development of the Record of Decision.
VI. COMMUNITY RELATIONS
Community relations activities conducted at McCarty's/Pacific Hide and
Fur site to date include the following:
• In March 1983, EPA began an Emergency Removal Action at the site.
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The Remedial Investigation began in September 1986 with the
Potentially Responsible Parties doing the work with EPA and IDHW
oversight. A fact sheet was distributed to the mailing list
announcing this in August 1986.
A fact sheet was mailed out to all citizens and local officials cr.
tne £PA mailing list on March 31, 1938. This fact sheet outlined
the alternatives reviewed during the RI/FS, EPA's evaluation of each
alternative and indicated which alternative was the EPA/IDHW
preferred alternative. The fact sheet also announced the beginning
of the comment period and the public meeting.
On April 5, 1988, EPA placed a public notice in the Idaho State
Journal announcing:
a public meeting on the RI/FS results
a brief description of the investigation results
the public comment period running from April 15 to May 13
location of the Information repositories
and the EPA contacts.
• The PRPs were provided an RI/FS package which Included:
1) an Executive Summary of the RI/FS. 2) the EPA/IDHW proposed
plan, 3) EPA revisions to the FS, 4) EPA addendum to the Risk
Assessment, 5) the notice of the public meeting, and, 6) the fact
sheet.
k
* Flyers announcing the public meeting were given to a local contact
for distribution in the dty.
%
' The public meeting was held on April 19, 1988. Approximately 30
people attended the meeting. The meeting was recorded by a court
reporter and the transcript Is available at the information
repositories.
* A responsiveness summary was prepared by EPA in May 1988. This
document addressed the comments received from the public and the
potentially responsible parties during the comment period. The
questions/comments and EPA's response are listed by category in this
document.
VII. SITE CHARACTERISTICS - REMEDIAL INVESTIGATION
%•
The purpose of the Remedial Investigation (RI) was to determine the
nature and extent of contamination at the site. Because PCBs are the major
contaminant of concern, the RI was undertaken to establish the presence of
PCSs remaining at the site, the extent to which waste materials were
distributed over the site (both vertically and horizontally), the extent of
migration ,1f any, of PCBs from the site and the presence of contaminants
including PCSs, if any, in the groundwater. In addition to defining the
nature and extent of contamination, the RI was designed to characterize site
geology and hydrology. This information was used to evaluate mechanisms and
rates which toxic compounds may be transported from the site to potential
receptors. The RI was performed in several phases, with intermediate reports
reviewed b.y the U.S. cPA and IDHW. Many of the concerns of these7 regulatory
agencies were addressed by modifications to. the text of the document. The
final RI document was submitted to tne U.S. EPA in Fecruary 1983'. .A Summary •
of the RI results for soil, groundwater, surface water, and air folfows.
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Soil
The RI Incorporated existing data developed earlier by the EPA and IDHW.
The RI also Included the collection and analysis of twenty-five surface and
sub-surface soil samples, excavation, logging, and sampling and analysis from
twelve test pits, and construct4on and logging of four boreholes (as part of
groundwater monitoring well construction). Shallow soil samples from two of
the borings were analyzed for PCBs. The information gathered from these
activities helped define the extent and level of PCS soil contamination at the
site. PCBs were found to exist at varying levels In most of the samples
obtained. Figure 3 shows surface and subsurface soil sample locations.
Figure 4 shows exploration trench locations and monitoring well locations.
The PCB contamination was found to be present In "hotspots". In areas
where capacitors had existed, or bulk oil disposal was believed to have
occurred. These hotspots were mainly located within the silt and scrap fill.
Data collected during the RI indicates that the levels of PCBs in the soils
diminishes rapidly at short distances from the hotspots.
The trenches and boreholes were also used to further develop an
understanding of the local geology and hydrogeology.
Groundwater
Four groundwater monitoring wells were constructed and used in
conjunction with existing on-slte wells to monitor water lev*l eie/a*1ons and
to obtain, water samples from the two shallowest water bearing ^onei. A total
of fifteen .wells were sampled during the first sampling round and fourteen
wells sampled during the second round. All samples were analyzed for PCBs.
None of the water samples obtained during .the RI were found to be contaminated
wltti PCBs above the detection limit.
The four new wells were also sampled for an extensive list of
contaminants-. (Priority Pollutant List). The results from this analysis
indicate that there Is no groundwater contamination at this site at the
present time. Analytical results of some earlier samples show the presence of
PCBs. However, the data was suspect due to poor quality resulting from
Improper sampling and/or analytical procedures. Subsequent sampling showed no
PCB contamination above detection limits. The RI groundwater analysis
results, the disposal practices, and the waste and site characteristics all
Indicate that the PCBs are not present In the site groundwater at this time.
Groundwater level measurements were taken at the site from June. 1986 to
September, 1987. These measurements were used to develop an understanding of
the groundwater flowrate and direction. The Information obtained during the
groundwater Investigation showed that at least one additional well will be
required for groundwater monitoring during and after Remeoia. Accion.
Surface Hater
A surface water investigation was undertaken to determine If the site
impacts nearby water bodies. It was found that the site is located outside
the 100 year flood plain and would therefore not be flooded by the Portneuf
River under severe high water conditions. The investigation showed that the
topography prevents drainage toward the Portneuf River, and that all nearby
surface water drains Into the pit. Because of these factors, as well as
annual precipitation, surface water '.vas found to not be a route of contaminant
migration.
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*t* 11
l«fif«uc«;
111* titf tot lapof i>pMc«l Sufvcy
by Shuilllll ta|U««(lB|
0.1*; 1/14.
EXPLANATION
••*!••• •«•»!• *•
•*«•** •«•»»• «• ••« Alt* •!
*l«tv ••>!••• •*•»!•• • ••« f
»••• •! ••»»*••••!•'»
Sutfac* and Supplamunul
Figure 3
Soil Sample Location*
Cafl-024
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Mot*I t>c«v«t«4 (Mil*
ill* tUf «iwl Iu(H>|i
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11
Air
Through the RI/FS process it was determined that contaminants, of concern
could potentially be transported from the site, especially during remedial
activities. Also, persons on-slte could be exposed to contaminated dust (see
Section X - Selected Remedial Alternative). These factors will be taken Into
account during .design of the chosen remedy. Adequate dust control measures
will be used during construction to protect both the on-site workers and the
public from excessive contaminated dust. Also, the remedy will be designed to
adequately reduce or eliminate movement of contaminated dust from the site.
. t
VIII. SUMMARY OF SITE RISKS - RISK ASSESSMENT
The purpose of the Risk Assessment was to determine the probability of
potential harm to humans caused by the site as It presently exists and -to
provide information which could be used in establishing clean-up levels for
contaminated soils. The Risk Assessment produced by the PRPs with EPA and
IOHH oversight as a part of the Remedial Investigation/Feasibility Study
provides background information on PCS properties, fate and transport,
toxiclty, guidelines and standards. The development of the exposure scenario
and resultant ingestion, dermal absorption and inhalation exposure levels are
also provided. This information provides an overall picture of one potential
exposure scenario.
Wtfr the scenario developed b\ the PRPs a range* of risks associated with
the PCBs onrsite was estimated. The estimates were based on Ingestion,
Inhalation, and direct contact exposure. The Information produced through the
RI orocess Indicated that groundwater Is not presently a route of exposure.
Additionally, there does not appear to be a food chain route of exposure. The
ingestion route is therefore based on consumption of contaminated soils only.
The rlsfc estimation of carclnogenesis provided in the PRP Risk Assessment
for the site as it presently exists ranges from 2.1 x 10-3 to 8.8 x 10~7.
The risk of the total site area was estimated to be 2.1 x 10~3. The areas
corresponding to the risks shown In Table 1 are delineated In Figure 2.
TABLE 1
Total Dose and Estimated Maximum Carcinogenic
Risk for Total Exposure
N«
Maximum Maximum
Total Dose) Risk Estimate for
Location (mq/kq/dat») Total Exposure
Area A 0.013 . 1.1x10-4
Area 3 1.2x10-4 1 .1x10-6
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12
Table I
Total Dose and Estimated Maximum Carcinogenic
Risk for Total Exposure
(Continued)
Area C 1.0x10-3 8.6x10-6
Area 0 1.1x10-4 8.8x10-7
Area E 0.25 2.1x10-3
Area G 1.2x10-4 1.0x10-6
Office Area 2.8x10-3 2.4x10-5
Total Area 0.25 2.1x10-3
The Risk Assessment established PCBs as a human probable carcinogen as
determined by the EPA Cancer Assessment Group. The CAG determined the
Carcinogenic Potency Factor (CPF> for human exposure to be 4.3 (mg/kg/day)-'
and classified PCSs as Group 82 - Probable Human Carcinogens. The Office of
Toxic Substances (OTS) of EPA estimated the CPF to be 3.57 (mg/kg/day)'1.
In the development of the exposure scenario, the PffPs made basic
assumptions which differ from those normally used by EPA In similar
situations. Also, the PRP Risk Assessment did not provide information which
could directly be used to develop clean-up levels for site remediation.
Consequently, revisions to the Risk Assessment were necessary. Changes in the
basic exposure assumptions were made. Additionally a range of probabilities
of cancer incidence for various population group-s was produced for a specified
contaminant level. This information was then used in the development of the
site clean-up level i.e., that level at which excavation may cease. The EPA
Risk Assessment evaluations for this site were based on the results of the RI
and methodology currently in use by the U.S. EPA. These methods establish
guidance for the estimation of levels to which hazardous waste sites should be
cleaned up. The Risk Assessment examined pathways through which humans may be
exposed to PCBs, the resulting exposure levels, and corresponding risks.
Based on specific conservative exposure assumptions, the Risk Assessment
findings showed that clean up of all soils contaminated with PCBs at a level
of ten parts per million (ppm) or more and leaving the remainder unprotected
would result in a cancer Incidence range of two persons per 1,000,000 persons
exposed to nine persons per 100,000 persons exposed (I.e. 2x10-6 to
9x10-5). using these same assumptions and data, a cancer incidence range
estimate was established for unprotected soils remaining at 25 ppm. The
estimated range was found to hr five persons per 1,000,000 persons exposed to
three person* per 10,000 persons exposed (i.e., SxIO"6 to 3xlQ-4). These
results were then compared to a previously established PCS clean-up policy.
With the Input -from a wide variety of environmental and industrial
organizations, the EPA has established a clean-up policy for PCS spills. This
policy was developed because there was a recognized need for a standard by
which PCS spill clean-ups could be undertaken. The policy was designed mainly
for the clean-up of PCS contamination due to accidents involving PCS laden
equipment. The requirements and standards in this policy are- based upon the
agency's evaluation of the potential routes of exposure and potential risks
associated with the more common types of PCS spi-lls, as weM as tne costs
associated with clean-up following such ipiils..
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13
For restricted access areas, the PCS clean-up policy calls for
contaminated soil to be cleaned to 25 ppm PCBs by weight. This clean-up level
is based in part on the fact that soil ingestion, inhalation, and direct
contact will be lower.in these areas (due to restricted access) as compared to
non-restricted access areas. The policy also calls for clsan-jp to ts;i ppm
with a ten inch cover of clean soil ID non-restricted access areas.
Although this policy was not expressly designed for Superfund remedial
actions, the EPA believes it is appropriate to use these standards as a
reference in conjunction with the Risk Assessment data to develop the clean-up
standard. Therefore, the clean-up level provided in the EPA/IDHW preferred
alternative takes into account both the results of the Risk Assessment and the
PCS spill policy.
The EPA/IDHW preferred alternative calls for excavation outside the area
to be fully capped down to the 25 ppm level with a soil cover over the
excavated area. By covering the contamination remaining after excavation, and
by using site security and institutional constraints such as deed
restrictions, direct contact can be significantly reduced or eliminated.
Exposure due to inhalation and ingestion can also be reduced or eliminated.
This will reduce the potential for cancer incidence well below that estimated
in the Risk Assessment.
IX. ALTERNATIVES EVALUATION - FEASIBILITY sniUY
The purpose of the Feasibility Study was to develop and evaluate possible
alternatives for site clean-up. The process by which remedial alternatives
are evaluated is designed to select the most efficient and cost-effective
strategy to protect human health and the environment by eliminating or
controlling releases of contaminants. A total of eleven applicable
technologies were assembled for the McCarty's/Pacific Hide and Fur site from a
master list of over forty potential technologies.
The preliminary alternatives were evaluated using the following criteria:
1. applicability of the technology to clean-up of PCS contaminated silt
ar.d scrap
2. limitations associated with the technology
3. effects of site conditions
4. the level of development of a technology and its performance record
As a result of these analyses a total of six of these alternatives were
retained for further consideration. These alternatives constitute a wide
range of options for action at the site. Options range from no action (which
actually Includes continued groundwater monitoring and limited stabilization
activities) to complete removal and destruction of all materials believed to
be contaminated with PCBs.
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14
Table 2 contains a brief description of the six candidate alternatives..
These alternatives were subjected to detailed analysis, according to
regulatory guidelines. The detailed analysis of each alternative included:
•
• An assessment of how well the alternative is expected to effectively
• prevent or rsdcca the thrsat to public health and welfare and the
environment.
• Evaluation in terms of how reliable, implementable, effective and
safe the remedial action would be.
Refinement of the alternative with emphasis given to defining
established methods of handling or treating wastes.
* An assessment of how well the alternative is expected to meet the
preference for reduction In toxlclty, mobility or volume of the
waste through the use of permanent solutions and alternative
treatment technologies or resource recovery technologies.
• An analysis of any adverse environmental impacts and methods for
reducing or eliminating these impacts.
* Detailed cost estimation. Including costs associated with long-term
operation and maintenance associated with the alternative.
• The degree to which each alternative conforms to federal and state
requirements and regulations. Appendix III lists the federal and
state applicable or relevant and appropriate requirements for this
site by which the alternatives were evaluated.
' Concerns of the community.
Each of the candidate alternatives was rated using criteria corresponding
to the above factors according to an above the median/median/below the median
scheme. An above the median rating means the alternatives rate high f~- the
particular criteria in question when compared to the remaining altferr /es.
^Median and below the median ratings follow the same logic.
A summary of the ratings for each alternative was then developed to
compare the alternatives. Table 3 Illustrates the ratings.
The selection of the preferred alternative considered the degree to which
site clean-up goals would be attained, the degree of clean-up performed as
required by regulation, and the degree to which routes of contaminant exposure
are eliminated or controlled.
Table 2: Summary of Remediation Alternatives
Alternative 1 - No Action
Limited handling of oversize scrap, limited grading, soil cover and
seeding. Limited soil cap would cover entire 8,200 cubic yards of
contaminated material. Construction of additional groundwater monitoring
wells. Annual groundwater monitoring. Lcngterm maintenance and monitoring.
Deed restrictions to prevent inadvertent redevelopment.
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15
Table 2
Summary of Remedial Alternatives (Continued)
Alternative 2 - On-Slte Containment
Limited handling of oversize scrap. Construction of clay bottom liner
where needed. Consolidation of Intermixed silt and scrap (area found to
contain PCS contaminated soils) and additional contaminated area soils.
Construction of clay cap and soil cover including seeding. Clay cap would
contain entire volume of contaminated material (8,200 cubic yards).
Construction of additional groundwater monitoring wells. Semi-annual
groundwater monitoring for thirty years. Longterm maintenance and
monitoring. Abandonment of unneeded wells. Deed restrictions to prevent
Inadvertent redevelopment.
Alternative 3 - Fixation
Pilot test to determine fixation and processing parameters. Limited
handling of oversize scrap. Excavation of entire silt and scrap fill and
additional contaminated area soils unless additional sampling shows specific
areas to be uncontaminated. Processtng (screening, shredding, sorting, etc.)
to make material amenable to fixation. Mixing waste material and fixation
material with water and placement In depressions or forms to produce
solidified mass. Minimal soil cover Including seeding. Annual groundwater
monitoring for thirty years. 'Longterm monitoring and maintenance. Deed
restrictions to prevent Inadvertent redevelopment. Alternative will fix and
contain entire volume of contaminated material (8,200 cubic yards).
Alternative 4 - Off-Site Disposal
Limited handling of oversize scrap. Excavation of entire silt and scrap
fill and additional contaminated area soils unless additional sampling shows
specific areas to be uncontaminated. Processing (shredding, screening,
sorting, etc.) to make material acceptable for off-site disposal as specified
by disposal facility. Contaminated material transported to disposal facility
via truck or rail and disposed in regulated unit. Filling, grading, and
seeding of site. Alternative will remove entire volume of contaminated
material (8,200 cubic yards).
Alternative S - Incineration
A. On-Slte Incineration
Pilot testing to determine Incineration and processing parameters.
Limited handling of oversize scrap. Excavation of part or all of fill and
additional contaminated area soils unless additional sampling shows specific
areas to be uncontaminated. Processing (screening, shredding, sorting, etc.)
to make material amenable to incineration. Incineration of contaminated
material. Fixation of the residual ash if necessary. Grading and possibly
filling of site. Addition of topsoll and seeding. Alternative will treat
entire volume of contaminated material (8,200 cubic yards).
b. Off-Site Incinerati--'
Limited handling of oversize scrap. Excavation of entire silt and scrap
11 and additional contaminated area soils unless additional sampling shows
specific areas to be uncontaminated. Processing (shredding, screening,
sorting, etc.) to make material acceptable for off-site incineration as
specified by disposal facility. Contaminated material transported" to
incineration facility via truck or rail. Filling, grading, and seeding of
site. Alternative will rrsat sntira volume of contaminated material.(8,200
cubic yards). .
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16
Table 2
Summary of Remedial Alternatives
(Continued)
Alternative 6 - Fixation/Containment
EPA/IDHH Proposed Alternative
Pilot testing to determine safety and feasibility of alternative and
fixation and processing parameters. Limited handling of oversize scrap.
Excavation of part or all of fill and contaminated area soils (Volume to be
treated dependent on feasibility of material processing and fixation, as
determined In pilot study. It Is expected that a^majority of the silt and
scrap material can and Mill be solidified). Processing to make material
amenable to fixation. Mixing waste material and fixation material with water.
and placement in depressions or forms to produce solidified mass.
Construction of a clay bottom liner where needed. Construction of clay cap
and soil cover Including seeding or other erosion control mechanisms.
Construction of additional groundwater monitoring wells. Semi-annual or
annual groundwater monitoring for thirty years (depending on extent of
treatment). Abandonment of unneeded existing wells. Deed restrictions to
prevent Inadvertent redevelopment. Alternative will treat/contain entire
volume of contaminated material (8.2CO cubic yards).
X. SELECTED REMEDIAL ALTERNATIVE
A. DESCRIPTION OF THE SELECTED REMEDY -
The preferred remedial alternative (No. 6) is a combination of source
control measures, measures to control contamination release, and measures to
reduce human and environmental exposure to contaminants. This remedy
addresses all contaminants of concern remaining on site. The alternative
consists of excavating contaminated soils, stabilization of a portion of the
& contaminated material using a technique which immobilizes the contaminants,
construction of a bottom clay liner where necessary, capping the stabilized
and remaining materials, continued groundwater monitoring, deed restrictions,
and restrictions to site access.
If the contaminated material cannot be processed or stabilized as
determined In the pilot study, Alternative Two, On-Slte Containment, will
become the preferred alternative.
FIXATION/CONTAINMENT
Pilot Study
A Pilot study is necessary to determine 1) the extent to which the
contaminated material can be processed in preparation for the treatment and 2)
the optimum mix of binding agents. The pilot study.will begin with the
testing of various types of equipment and/or material handling operations to
determine the feasibility of processing the silt and scrap material.
Feasibility will be based on the 1) amount of contaminated dust emissions.
produced by the excavation and material processing activities, and 2) the
physical limitations of various excavation and processing equipment when
•/orlung with the silt and scrap materials.
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Screening of Alternatives
Summary
Legend
AM Above the Median
M Median
BM Below the Median
Alternative
1. No Action
2. On-Sile Containment
3. Fixation
4. Off-Site Disposal
5. Incineration
6. Fixation/Containment
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18
Dust emission Is a key parameter for the preferred alternative due to the
fact that the material slated for excavation and processing (silt and scrap)
has the potential of becoming airborne during material movement due to dry and
windy site conditions. Various types of equipment and/or dust control
measures will be evaluated- to determine If the contaminated material; can be
handled without undue risk to workers or the public or excessive spread of
contamination. To determine this, an air monitoring program will be
Implemented to quantify releases during short-term excavation/processing
test(s). Emission levels will be compared to exposure limits based on EPA
carcinogenic potency factors for polychlorlnated blphenyls and EPA National
Ambient Air Quality Standards for public exposure, and Occupational Safety and
Health limits and standards developed by the American Conference of
Governmental Industrial Hyglenlsts for on-slte worker exposure.
Because of the Intermixed nature of the materials of concern (scrap metal
and various debris Intermixed with contaminated soils) the pilot test will
also establish what sectors of the areas of contamination can practicably be
excavated and processed. Figure 5 shows areas of excavation and potential
excavation. Factors such as worker safety, equipment limitations (ability to
excavate, move, and separate materials), and equipment breakdown and wear will
be evaluated during the pilot study.
The determination of excavation and processing feasibility will dictate
the remaining activities. If excavation and processing Is found to be
unpracticable for all materials of concern, on-site containment a1, described
below will be implemented. If excavation and material processing is found to
be practicable on only a minor portion of the materials of concern, the cost
effectiveness of the fixation technology will be re-evaluated to take Into
•account the Increased per unit cost due to tn* small volumes being
considered. If excavation and processing Is found to be practicable for all
or part of the material In question (unless.fixation is found to not be cost
effective as described above), the second phase of the pilot study will be
Implemented,.namely determination of the best mix of fixation materials and
contaminated soils. This portion of the pilot test will Include laboratory
experiments to ensure that the fixation process effectively Immobilizes the
PCBs. A comparison of reduction of mobility of PCBs before and after
treatment will be undertaken. Also, strength tests, leachabilfty tests, and
durability tests will be performed on the solidified material during the pilot
study. Ou.'ing design of the pilot study it may be determined that additional
tests are necessary. These tests will help determine how well the solidified
material will hold up over long periods of time under varying conditions and
how well the solidified material contains the contamination.
Sol 1 Excavation
The contaminated areas near the pit will be excavated ^ *.n average depth
of 1.5 feet using, backhoes, bulldozers and/or front end loaders to ensure that
all potentially contaminated soil is contained (See Figure 5). The
contaminated soils requiring consolidation are located outside the pit and
outside the limits of high level contamination along the southwestern boundary
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Superfund Site *
McCarty's Pacific Hide and Fur
Pocatello, Idaho
Scale in Feel
100
200
\
U.S. Highway 30 West
Limi.s oi Excavation
Li. ,o»Pit
LH ol High Level Conlaminalion
Fence Line
300
Superfund Site
McCarty's Pacific Hide and Fur
Pocatello, Idaho
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20
of the site. Also the soil from the area near the office where a single
capacitor was found will require consolidation. Additionally, soils in the
pit bottom outside the limit of high level contamination may require
consolidation only. Specific work practices, as established during the pilot
study, may be necessary to minimize dust emissions during excavation. That
portion of the silt and scrap which is processable (as determined in the pilot
study) will be excavated using similar equipment until the underlying fill
material Is reached. Because these fills are very different in appearance,
the excavator will know when the underlying fill is reached. On-slte soil
sampling equipment will then be used in areas outside the area to be contained
under the full cap to determine the level of remaining PCS contamination, if
any. If the remaining contamination is above 25 ppm, excavation will
continue. Periodic sampling will be undertaken to determine when excavation
can cease. As summarized in Section VIII, Summary of Site Risks—Risk
Assessment, the 25 ppm level is based on'the Risk Assessment undertaken for
this site and the EPA PCS spill clean-up policy. This level. In conjunction
with the treatment and containment technologies to be used, will adequately
protect human health and the environment.
Material Processing
The excavated highly contaminated material will be processed by the use
of mechanical screening apparatus. The particular screening equipment used
will be determined in the pilot study. The material which can be processed
down to approximately a two inch size will then be treated in the fixation
process.
Soil Fixation
To further reduce the ability of the PCBs to migrate from the site, the
processed material will be mixed with an additional substance which binds the
PCBs and soils. The exact mixture of the fixation material will be determined
through the pilot study discussed above. The mixture will probably consist of
a combination of cement, lime or fly ash and possibly a proprietary binding
ingredient.
a
The processed materials will be mixed with the fixing agent and water to
form a slurry. After thorough mixing the slurry will be placed in specially
prepared depressions or forms where it will solidify into a hardened slab or
block.
Some or all of the material separated from the soil during the screening
operation will b» encased In the stabilized matrix by placing the oversize
material in the slurry before it solidifies.
Once the fixed material has hardened, any remaining oversized
contaminated materials will be placed over and/or near the solidified mass. A
soil cap will then be constructed over this. A layer of clean soil will be
placed in areas outside the cap where excavation has occurred. As with the
On-Site Containment alternative, a bottom clay liner will be constructed, as
necessary. This will t^ determined during Remedial Design by determining the
thickness of existing c .y iilow the proposed unit. Where insufficient native
material exists, construction of a clay bottom liner will be necessary.
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21
A graded filter of clayey sand will be placed on the top and exposed
sides of the remaining Intermixed silt and scrap. If any, and on the top and
exposed sides of the consolidated and .treated soils. A low permeability clay
cap will be placed on the top and exposed sides of the unit followed by a
drainage layer and topsoll. Upon completion of the cap construction, the site
will be restored to final contours that minimize erosion and control surface
water runoff. Seeding or other remedies will also be Implemented to reduce
erosion. The final design of the cap will be contingent upon the amount of
material treated; the greater the amount of treatment, the lower the
dependency on the cap will be. Figure 6 shows a cross section of the treated
material, consolidated material, liner, and cap.
Very large materials which cannot practically be reduced in size for
containment within the cap (car bodies, buses, etc.) will be steam cleaned and
tested to determine if the PCS materials are still present. Upon satisfactory
clean-up, the large material will either be placed on-site or removed from the
site. The decontamination water will be used as the water source for the
fixation process, thus eliminating the need for disposal of all or part of the
wash water.
The material processing and fixing equipment will require fugitive dust
controls to minimize the release of airborne contaminated materials. Oust
suppression may require hoods or other equipment. Specific control measures
will be established In the pilot stuJy.
Operation and Maintenance
Additional well(s) will be constructed to monitor the groundwater for
contamination. The specific number, location, and depth of these wells will
be established during the Remedial Design. During design the need for
continued use of existing wells will be established. Those wells no longer
needed, will be taken out of service during remedial action. Operation and
maintenance will include groundwater monitoring analysis, semi-annual or
annual, and cap inspection annually for cracks, erosion or other signs of
failure for thirty years. Any problems revealed during these Inspections will
be mitigated. If groundwater contamination Is verified, additional site
characterization will be required, and possibly groundwater treatment.
ON-SITE CONTAINMENT
If the fixation technology Is found to be impracticable, on-site
containment will be implemented as the final Remedial Action for this site.
Liner ConstTucttoir
The on-site containment facility would be constructed over the south
sidewall of the pit. All contaminated ir.termixed silt and scrap, as well as
additional excavated soils, would be consolidated in this area. Low permeable
clay would be placed underneath any areas where contaminated materials would
be placed where insufficient clay fill is present.
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Figure 6 '
EPA Superfund Selected Remedy
Fixation/Containment
Materials Laft
In Place
Orouhdvyaler
Monllorin
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23
Excavation and Cap Construction
No excavation of Intermixed silt and scrap would be required along the
south sldewall of the pit due to the fact that the cap would be constructed
over this area. All Intermixed silt and scrap contaminated areas outside the
pit, on the bottom of the pit, and In the north pit sldewall would be
excavated and placed on the clay liner.
The contaminated soils requiring consolidation only outside the pit, near
the office, and In the bottom af the pit will be excavated and consolidated as
outlined In the fixation/containment description. Oust control measures for
these areas will also be undertaken as described In the fixation/containment
section.
The Intermixed silt and scrap and excavated soils will then be placed on
the clay liner 1-n relatively horizontal lifts, 12 to 18 Inches thick and
compacted. Adequate compactlve effort would be required to minimize
settlement within this material and subsequent shifting of the low
permeability cap to be placed over this material. A graded filter of clayey
sand will be placed on the top and the exposed sides of all Intermixed silt
and scrap and excavated soils, Including the material remaining In the south
sldewall. Subsequently, a low permeability cap consisting of a minimum or 3
feet of clay will be placed on the top and exposed side of the facility
followed by a one-foot thick drainage layer and topsoll. A soil cover outside
the cap area will be placed In all areas excavated as outlined in the
fixation/containment description.
Upon completion of construction of the cap, the site would be restored to
final contours that minimize erosion and control surface water runoff.
Seeding or other remedies will be Implemented to reduce erosion. Abandonment
of unneeded existing wells will be undertaken as described in the
fixation/containment alternative.
Operation and Maintenance
Operation and maintenance will be the same as that outlined In the
fixation/containment alternative with the exception of groundwater
monitoring. On-Site containment will require semi-annual groundwater
monitoring whereas fixation/containment may have annual groundwater monitoring.
8. STATUTORY DETERMINATIONS
The selected remedy was evaluated In terms of the statutory requirements
for CERCLA Remedial Actions. Below is a summary of the determinations.
Protection of Human Health and the Environment
The selected remedial alternative meets all statutory requirements.
particularly those of CERCLA as amended by SARA, The highest priority is the
protection of human health and the environment. The use of the
fixation/containment remedy protects human health and the environment by
permanently immobilizing contaminated materials in a solidified matrix, and
Isolating the remaining materials from the environment in a unit which is
permanently above maximum groundwater elevations. Continued protection is
assured through groundwater monitoring, site maintenance, access restrictions,
and deed restrictions. .
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Assurance that Implementation of the remedy will not pose unacceptable
short-term risks to workers or the public is provided through the pilot
study. The pilot study will, in part, quantify the air-borne releases of
contaminants caused by implementation of the remedy. An evaluation of the
release estimates with respect to health based criteria will establish whether
excavation and processing can be undertaken without excessive contaminant
releases. If it Is found that airborne releases art* excessive and that
ravisad practices ana/or equipment cannot adequately lower these releases, the
remedy will require capping of the entire area of concern as outlined in the
On-Slte Containment Alternative. Protection of human health and the
environment will also be obtained with the capping alternative.
Attainment of Applicable or Relevant and Appropriate Requirements
The selected remedy will meet all ARARs as specified below.
1. Relevant and appropriate portions of the TSCA land disposal
requirements (40 CFR 761.60(a)(4)) will be met by accounting for
these regulations during remedial design.
2. In the event that additional PCS capadtor(s) are discovered during
remedial action, TSCA transportation (40 CFR 761.65) and disposal
(40 CFR 761.75 and 40 CFR 761.60(b)(2)) regulations will be followed.
3. Relevant and appropriate portions of the RCRA regulations pertaining
to hazardous waste landfill closure and groundwater monitoring (40
CFR Subpart F, 40 CFR 264.310) will be accounted for during detailed
design of the cap and groundwater monitoring program.
4. Worker protection standards for employees involved in operations at
CERCLA sites will be ensured by the application of the applicable
OSHA regulations (29 CFR Subpart'1910.120).
5. National primary and secondary air quality standards will be met by
application of the National Ambient Air Quality Standards for
Particulate Matter (40 CFR 50.6).
6. Relevant and appropriate portions of the State of Idaho wei
construction standards will be met by accounting for these
regulations during remedial design.
7. State of Idaho fugitive dust control (16.01.1251.52) and toxic
emission (16.01.1011.01) standards wTTl be met by fugitive dust
control measures and assistance in the final design of the air
monitoring program by the state of Idaho Air Quality Bureau.
To be considered:
8. EPA Cancer Assessment Group, EPA Office of Toxic Substances, and EPA
Office1 of Health and Environmental Assessments Carcinogenic Potency
Factors for PCBs in the development of the final pilot test plan and
remedial action air monitoring program.
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25
9. American Conference of Governmental Industrial Hyglenists
recommended PC8 exposure levels in the development of the final
pilot test plan and remedial action air monitoring programs.
Cost Effectiveness
The final selected remedy meets the requirements of cost-effectiveness as
this alternative provides for permanent treatment and contaminant release
minimization for a cost significantly less than other alternatives exhibiting
a similar level of protection. The estimated present worth range of the
selected*remedy is $1.33 to $1.39 million, in comparison to $2.38, $4.11,
$8.44, and $24.15 million. Additional cost of these 1s the result of
excavation and processing of larger volume of material, transportation and
off-site landfill Ing, and more costly technologies such as incineration.
Utilization of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable.
The selected remedy Is specifically designed to determine the maximum
extent to which the permanent alternative treatment technology, fixation, can
be used. This will be accomplished through the pilot study wherein a
determination will be made as to what portion of the contaminated soil can be
practicably treated (See Description of Selected Remedy). Hhen compared to
all alternatives, the selected remedy provides the best balance in terms of
long-term effectiveness and permanence, reduction in toxldty, mobility, or
volume, short-term effectiveness, fmplementabtlity, cost, consideration of the
statutory preference for treatment as a principal element, and state of Idaho
and community input. The selected remedy provides the best balance of the
above criteria by the use of a treatment technology which will effectively
Isolate the waste in a permanent matrix. 'Implementabi1ity and cost are best
addressed in the remedy through the pilot study which will establish which
portions of the waste materials can be practicably treated.
Preference for Treatment as a Principal Element
The statutory preference for treatment that permanently and significantly
reduces the toxldty, mobility, or volume of hazardous substances as a
principal element is met by the use of the fixation technology. Fixation will
be used to the maximum extent practicable on contaminated soils. The use of
this technology provides a permanent reduction in mobility of the wastes.
Fixation in conjunction with the containment, monitoring, and maintenance will
provide a remedy which will effectively isolate the contaminants from the
environment.
A pilot study will be undertaken to determine which portions of the
contaminated materials can be treated. If the pilot test shows that fixation
is not practicable for any of the contaminated materials, an on-site
containment remedy will be Implemented. The on-s1te containment approach will
not Include treatment as a principle element.
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APPENDIX I
INDEX TO ADMINISTRATIVE RECORD
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APPENDIX II
NC OUmr'S/PUdFIC HIDE AND FUR RESPONSIVESS SMUT
Overview
McCarty's/Pacific Hide and Fur, a recycling and scrap material yard, is
located on the outskirts of Pocatello. The site Is bordered by Highway 30 on
the north and Union Pacific Railroad mainlines on the south.
In 1983, Idaho Department of Health and Welfare (IDHW) investigated the
site after receiving a complaint about improper disposal of capacitors
containing PC8s. EPA was called in, further Investigations were undertaken,
and an emergency removal action was done In March 1983. At that time EPA
removed 593 capacitors, 30 cubic yards of contaminated soil and 21 drums
containing hazardous waste. In September 1983, the McCarty's/PaclfIc Hide and
Fur was listed on the National Priorities List. This Is a list of hazardous
waste sites across the nation designated for long-term study and if necessary,
cleanup. In 1986, community interviews were taken for the community relations
plan. Work on the Remedial Investigation/Feasibility Study (RI/FS) began in
1987 by the Potentially Responsible Parties (PRPs) with EPA and IDHW
oversight. The RI/FS 1s the comprehensive study of site conditions, hazards,
possible exposure pathways, and cleanup alternatives. The RI/FS produced by
the PRPs required revisions before it was acceptable for release.
Specifically, an additional alternative was evaluated and the risk assessment
was elaborated upon. The revised RI/FS Included EPA and IDHW additions.
The summary will discuss the comments and concerns raised by the local
community, regarding the problems at the site and the recommended alternative
for cleanup.
The PRP's at the site are the McCarty family, Pacific Hide and Fur Depot
and the Idaho Power Company. Negotiations are in progress between EPA, IDHW,
and the PRP's to have the PRP's run and finance the remedial design and
remedial action.
The citizen's concerns about this site are the cost and how it will
effect the PRP's. There are also concerns about past and potential
contamination, and the quality of the alternatives reviewed.
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Background on Community Involvement and Concerns
*
In 1983 the Idaho Department of Health and Welfare, Division of the
Environment (IDHW) received a complaint about Improper disposal of PCBs at the
site. EPA began an Investigation and ordered an emergency removal of the PCS
containing capacitors, contaminated soil and drums containing hazardous
waste. PCB's have been known to cause cancer In laboratory animals, and Is a
potential human carcinogen.
The community became aware of the site during this action. Then, In
September 1983, McCarty1s/Pac1f1c Hide and Fur was listed on the National
Priorities List. The local newspaper covered the listing and continues to
follow the story.
In 1986, EPA conducted community Interviews and a community relations
plan was developed. The following concerns were expressed to EPA and IDHH
during the Interviews:
• Community expressed concern that the Superfund process was too
complex and takes too long. Officials and public needed to be kept
Informed and Involved throughout the process.
• Community members expressed concern over possible health threats
during the study from either PCBs or other unknown contaminants.
• •' The area has "more than Its share" of hazardous waste sites or other
environmental problems.
• Economic Impact on the community.
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SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
Comments and questions raised during the McCarty's/PacifIc Hide and Fur
comment period on cleanup alternatives are summarized below. The public
comment period was held from April 15, 1988 to May 13, 1988. The comments are
grouped and categorized by subject. Comments from the PRP's are listed at the
end of the comment from the public.
As part of the comment period, a public meeting was held on
April 19, 1988 with approximately 30 people attending. The meeting consisted
of about 45 minutes of presentation followed by a question and answer and
comment period. EPA and IDHH made the presentations on EPA's role and an
overview of the Superfund process. IDHM's role and applicable laws and
regulation, and reviewed the alternatives considered, and EPA/IDHW proposed
plan.
Questions from the audience centered around the cost of the EPA/IDHH
preferred alternative, technology concerns, contamination concerns, and
questions about the Superfund process. A transcript Is available in the
information repositories and the administrative record.
COST CONSIDERATIONS
1. How is the Superfund process funded and who decides how much the
Potentially Responsible Parties are going t
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4. How can EPA choose a remedy that It so costly when the contamination at
thi? site was taken care of during the emergency removal In 1.983?
EPA RESPONSE:
The emergency removal action was undertaken to reduce the Immediate
hazard created by the contamination on-site. Extensive soil contamination
remains which constitutes a long term risk to human health and the
environment. The proposed remedy is designed to reduce or eliminate this long
term risk in the most cost effective manner.
TECHNOLOGY 'ISSUES AND QUESTIONS
1. Has the solidification process that EPA is recommending been proven at
other sites?
EPA RESPONSE:
Solidification has been used for many years on inorganic waste. In the
past several years study on this technology has been expanded to include
solidification of organic wastes, including PCBs. These studies have shown
that it is feasible to Immobilize organic materials in a solidified mass,
provided the proper proportion of materials are maintained and material
handling is closely controlled.
Nine Superfund site remedies selected during the last year Include
solidification as part of the remedy. One Superfund site remedial action
which is approximately 601 complete, includes fixation of soils contaminated
with PCBs and metals with placement of the fixated material below the water
table.
The research undertaken in the past as well as the widespread use of
technology indicates that fixation is a proven technology.
this
2. Hhat if this technology falls after five or ten years?
EPA RESPONSE:
Every f!v»years the remedy will be re-evaluated to determine if failure
is possible, probable or has occurred. This check is done in addition to the
ongoing monitoring and maintenance at the site. If a failure does occur, EPA
will do additional work to correct the situation as needed.
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3. How long will the stabllzed material last before It begins to. deteriorate
as all cement materials do?
EPA RESPONSE:
Past research has shown that solidified materials can hold up well under
severe conditions. The remedial design will Include testing to determine the
best combination of materials for use with the site soils. Tests will be run
to estimate how long the material will last. The final product should exhibit
many of the characteristics of concrete. In addition, the material will be
under a cover that will protect it from the weatherizatlon process.
CONTAMINATION QUESTIONS AND CONCERNS
1. Some of the Initial groundwater tests showed some traces of contaminants
yet EPA indicated that the tests may be questionable, why? Have other tests
shown any contamination?
EPA RESPONSE:
Groundwater sampling results done in 1983 were questionable due to poor
sampling and/or laboratory procedures. Sampling and analysis done since then-
durlng the remedial Investigation strictly followed standard protocol.
Results showed no PCS contamination in the groundwater samples above detection
limits.
Due to these results and the quality of the sampling analysis procedures
used during the remedial Investigation, EPA has concluded that there is no PCS
contamination in the site groundwater at the present time.
2. If PCS's show up in the aquifer at any time, would additional steps be
taken to correct the problem?
EPA RESPONSE:
Yes. The first step would be additional testing, to determine the levels
and extent of PCS. If the levels were above health based standards,
additional corrective measures would be implemented.
3. Is there any potential for surface water contamination, or would flooding
of the Portneuf River impact the site, causing the river to become
contaminated?
EPA RESPONSE:
The contaminated soils are outside of the 100 year flood plain.
Therefore any storm event less than or equal to the 100 year flood would not
cause the Portneuf River to inundate the site. There are no other surface
water contamination routes. In addition, all the alternatives, except the
no-action alternative, will cover the site with clean soil or remove the
contaminated materials, covering the contamination and preventing either
surface water or groundwater contamination.
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4. Because the work Includes moving soils and scrap around, won't the
potential for airborne contamination Increase?
EPA RESPONSE:
EPA Is planning a small scale pilot study to determine just how much
soils can be moved around without increasing the airborne dust levels at the
site above health based limits. In addition, equipment and work practices
will be used to reduce the amount of dust raised during the pilot study and
the final work. If the pilot study shows fixation to be Infeasible because of
excessive dust emissions, then excavation will be limited to that required for
capping.
5. Are there other contaminants at the site besides the PCBs?
EPA RESPONSE:
Various types of debris and waste existed on-slte In the past. The site
was used as a scrap yard disposal area from the 1950's to 1979. During the
emergency removal action, drums of hazardous wastes and contaminated soils
were removed. Presently, various types of debris remain. Although PCBs are
the only remaining contamination identified during the remedial investigation,
1t is possible although not probable that additional wastes will be discovered.
6. Have all the PCB contaminated capacitors been removed from the site?
EPA RESPONSE:
We believe that most, if not all, have been removed. However, when work
continues at the site, we may find more. Any that remain will be removed and
properly disposed of.
7. Since 1983. have there been any indications of groundwater contamination?
EPA RESPONSE:
Samples during the remedial Investigation (1987) showed no PCBs above the
detection limit. (See question 1 of this Section also.)
8. Has there be»ft any off-site migration of PCBs?
EPA RESPONSE:
There has probably been some airborne releases of PCB due to wind erosion
on the site. However, the amount has not been measured.
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9. Hhen the wells were drilled, were they properly sealed so that
contamination would not migrate to the groundwater1?.
EPA RESPONSE:
The older wells were constructed In a manner which would be unacceptable
if used today. However, groundwater data shows that the wells are not
providing a conduit for PCS migration into the groundwater. During design of
the remedy, the older wells will be re-evaluated to determine which ones
should be kept for long term groundwater monitoring. The remainder will be
properly sealed. The wells put In during the remedial investigation were
constructed in a manner which prevents contaminant migration through the
well. The answer provided In the public meeting regarding well construction
was In reference to the newer wells.
ALTERNATIVES REVIEWED
I. Hhy has EPA chosen an alternative that moves everything around. Hhy not
explore containing the material wherever it Is and capping it there?
EPA RESPONSE:
The selected remedy Is the one that best meets the criteria established
by EPA for the site. It is true that during the remedial action, contaminated
materials will be moved and separated. Th6 pilot study is specifically
designed to determine how dust emissions can be minimized and If the emission
levels are be.low health based standards. If excavation, separation and
treatment can be undertaken without excessive risk to workers or to the
public, this alternative will provide an added assurance that the PCBs are
immobilized in a solid matrix. If the pilot study proves that PCS and dust
emission are excessive, then the waste will be capped in place with only a
minimal amount of material movement.
2. If EPA's preferred alternatives does not work, what is the second choice?
EPA RESPONSE:
The selected alternative Includes on-site containment or capping, if the
fixation process proves to be Infeasible.
OTHER ISSUES OF CONCERN
1. Regarding Technical Assistance Grants, would it be appropriate for the
owners of the site to put up the 351 match?
EPA RESPONSE: ;:
It has never been done, although owners of other sites have given money
to community groups to provide technical assistance.
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2. Does EPA agree with the RI/FS conclusion that there is no Imminent hazard
to the peoele of Pocatello?
EPA RESPONSE:
EPA believes there exists a potentially long term risk to both human
health and the environment due to PCS contamination remaining on-site in its
present condition. The acute hazard at the site was taken care of during the
removal action In 1983. However, the long term potential risk still exists.
3. Mas the site placed on the National Priorities List because of
groundwater contamination and what was its score?
EPA RESPONSE:
Groundwater, surface water, and air contamination and the resultant
exposures, or potential exposures, are evaluated in the ranking process. In
this case potential groundwater exposure was the predominant factor. The
Hazard Ranking Score was 42.25. A score of 28.5 is required for inclusion on
the 11st. The RI/FS provided additional information on the potential
migration routes and exposures.
4. PCB's are classified as a potential human carcinogen yet have been in
production for over sixty years by the Monsanto Company; has Monsanto ever
done any studies on their employees to document PCB as a cancer causing-agent?
EPA RESPONSE:
Monsanto Corporation has done studies on health effects on Monsanto plant
workers. These studies showed no statistically significant Increases in
adverse health effects in Monsanto plant workers exposed to PCBs. Mine-
dermal irritations were noted, but these were attributed to poor hygiene
arather than PCB exposure. (Personal communication, Or. John Craddock, Product
and Environmental Safety Director, Monsanto Corporation.)
5. If government standards change or have not been established for
particular levels of allowable contamination, how will this affect the planned
cleanup alternative?
EPA RESPONSE:
Any cleanup standards which are not ARARS, will be established using
EPA's risk assessment analysis. Any standards promulgated after the ROD is
signed, that would impact activities on site will be evaluated to determine
whether they are ARARS and therefore need to be addressed on site.
6. Is there any litigation pending on the site, and if so. how will this
affect the cleanup efforts?
EPA RESPONSE:
The EPA is presently in litigation with the Potentially Responsible
Parties for cost recovery of the amergency removal costs and interest on that
sum. The litigation should have no substantive impact on the remedial action.
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7. Hhat roles does the federal court have in the decision over which plan is
ultimately decided upon?
FPA RESPONSE:
There is no provision for pre-enforcement judicial review in the
Superfund law. Once the Record of Decision is made, the only time the
Potentially Responsible Parties can address the issue in court would be in
cost recovery action, or if EPA were to request the court to enforce action
required under an Order.
8. Here alternatives which separately treated the hotspot areas evaluated?
EPA RESPONSE:
Yes. Treatment of hotspot contamination was evaluated-to determine if
it could be used in conjunction with other remediation activities. Treatment
of all hotspots and treatment of only the known hotspots were both evaluated.
Because of the scrap and silt volume and small hotspot size, locating
all the hotspots throughout the material would require extremely extensive
soil sampling. Large numbers of samples would be necessary to identify
hotspots on a statistical basis. This effort would not be cost effective and
would be time consuming. Safety concerns would also be present due to the
fact that extensive material sampling would be necessary. Because of these
factors, it is the Agency's"belief that treatment of all hotspots is- not
practicable.
During the Remedial Investigation, surface and subsurface soil samples
were obtained using a grid system. The sample locations were staked but were
not tied into a known benchmark. Disruption of the sample locations occurred
after sample collection when"the investigation team continued excavation in
their efforts to characterize the geology and search for any remaining
a capacitors. Because of the small size of the hotspots, the disruption of the
sample location and stakes and the fact that surveying to establish sample
location was not undertaken, relocating the known hotspots is not possible
using existing information. Additional soil sampling would be required. As
with any attempt to locate all hotspots, this effort would require extensive
sampling and analysis, with the results being identification of only a
fraction of the total number of hotspots. This would not be cost effective,
would not address the entire problem, and would be very time consuming.
Because of these factors, it is the Agency's belief that separate treatment of
the known hotspots 1s not practicable.
The following comments in summary and responses are in response to a
letter received from the Potentially Responsible Parties' consultant, for the
complete text of the comments, see the Administrative Record.
1. RCRA landfill closure and monitoring requirements do not aoply to this
ite. and there is no legal authority for that apolicabi1ity.
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10
EPA RESPONSE:
TSCA regulations do not include requirements for PCS landfill closure,
Including capping. Therefore, portions of the RCRA landfill closure
regulations are used at PCS landfill sites. Closure (capping) of this site
should resemble closure of a PCS landfill and should, therefore, follow
relevant and appropriate portions of the RCRA closure regulations.
The RCRA groundwater monitoring and post-closure requirements are
designed in part to:
1. Ensure contamination is detected if present in the groundwater,
and
2. Maintain hazardous waste landfill cap integrity.
Because the groundwater monitoring and post-closure programs for the
McCarty's/Paciflc Hide and Fur site will be designed and implemented with
these same objectives In mind, it is appropriate to use portions of the RCRA
groundwater monitoring and post-clo.iu, e regulations as.a reference.
Therefore, portions of these regulations are relevant and appropriate.
2.0n-site containment provides a signficant added measure of security as
compared to the fixation/containment alternative due to the fact that
substantially less excavation is necessary, and therefore less dust emissions
produced.
EPA RESPONSE:
The chosen remedy specifically addresses the dust emission issue by the
use of a pilot study (see Decision Document, Section X). If dust emissions
turn out to be a significant health hazard which cannot be adequately lowered
through changes in work practices, the selected remedy allows for on-site
containment as the remedy to be implemented.
3.The added measure of security provided by the fixation/containment
alternative as compared to on-site containment with regard to environmental
effects (adverse impacts on the adjacent environment including lakes, rivers.
wildlife habitats, etc..) is negligible because both remedies provide adequate
barriers along the qroundwater pathway. Also, the site is located outside the
100 year flood plain of the nearest river and will therefore not impact the
rivers.
EPA RESPONSE:
Immobilizing the contamination in a solidified matrix will further
reduce the potential for migration when compared to capping alone.. The
reduced migration potential in both the groundwater and air routes dictates
that the fixation/containment alternative be ranked higher under this criteria
than the on-site containment remedy. The EPA did not attempt.to quantify this
difference. " '
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II
4. The
provides
no risk
on-slte containment alternative that is
for
that
handl Ing
a hotspot
al 1
wou
susoected
Id not be
contai
remedi
nment
ated
preferred
soi Is
associ
and
ated
by the PRPs
, therefore.
with this
there
is
EPA RESPONSE:
Both the fixation/containment alternative, and the on-site containment
alternative provide for handling of the same volume of material. Therefore,
neither option would allow contaminated soil to not be remediated.
5. In comparing the on-s1te containment alternative to the
fixation/containment alternative, it is found that fixation/containment will
reauire additlona
workers.
This w1l
measures for prevention of direct contact by on-slte
1 slqniflcantly Increase the time and cost of this
alternative.
EPA RESPONSE:
The additional cost and time have been taken Into account and are
reflected in the anticipated schedule and cost estimates provided in the RI/FS
package. The agency feels that the incremental Increase of time and money is
offset by the increased protect! veness of the remedy.
6. Because the on-site containment alternative has substantially less
excavation and material handling and no material processing, it provides a
significant "added measure of security" over the fixation/containment
alternative with respect to failure of the dust control procedures.
EPA RESPONSE:
One of the primary tasks of the pilot test Is to determine what
reliable methods can be employed to control airborne emissions during remedial
action. In addition to the use of reliable safety practices and procedures,
an air monitoring program will be implemented during remedial action to ensure
that emissions are kept below pre-established health based limits. In the
event these limits are exceeded, the activity causing the emissions will cease
until such time as additional methods or practices can be implemented which
will lower the emission rate.
7 . The type of soils (silt) at fhe site are easily airborne under the right
conditions, making the project vulnerable to excessive airborne releases. The
dry climate in the region also increases the likelihood of airborne releases
of dust during excavation and processing. Additionally, the prevailing wind
direction is from the southwest toward the majority of the population of
Pocatello. The amount of dust released during the remedial investigation was
significant, as shown in the video tapes of these activities.
EPA RESPONSE:
The potential for airborne releases is recognized and appreciated by
EPA. Therefore one of the first tasks in the pilot test is to determine if
the air emissions would be excessive. Without the result; of this testing, a
fully informed decision on the practicability of excavation and orocessing
cannot be made. It is for this reason tna~ a .allot test >s required.
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12
8. Spraying 'water to control dust will not be effective at this site due to
the fact that the casting and loading techniques required during excavation
will cut below the surface of the material and thus release the dryer soils
beneath the wetted surface. Additionally, hooded processing equipment does
not contain the dust generated during loading and unloading operations.
Hooding practices also do not contain the dust produced during excavation
unless the entire area to be excavated Is enclosed In a temporary structure
with appropriate air handling equipment such that the exhaust air Is filtered
prior to release. Enclosing the entire area Is totally Impractical for the
site given the vertical and horizontal clearances required by excavation
equipment and the topography of the area to be excavated.
EPA RESPONSE:
Netting the excavation site may be used In conjunction with other dust
control measures (e.g., wind fences) to limit the emissions during
excavation. Specific fugitive dust control practices and/or equipment will be
evaluated during the pilot test to determine If excavation and processing Is
practicable In terms of limiting fugitive dust releases. Emissions produced
during the loading and unloading of the processing equipment will be part of
the total emissions for which the pilot test monitoring program will be
designed. EPA agrees that encapsulating the entire excavation and processing
area within a temporary structure Is not feasible due to the ficto-s listed by
the PRPs above, nor Is It within the scope of the selected r
9. Fixation/containment provides for solidification of a portion of the
contaminated silt and scrap which may be deemed treatment. This alternative
appears to rate higher than on-slte containment In the reduction In toxlcltv.
mobility, or volume criteria as defined in the Feasibility Study. However.
this Is Impossible to quantify due to several factors. First, the technology
has no track record with respect to PCSs. While It has been applied to a PCS
site recently. Its long-term performance and effectiveness has not been
demonstrated. Additionally, with only one implementation, the impact of
variable field conditions cannot be assessed. Secondly, the magnitude of the
volume of material to be fixed cannot be determined. Various estimates can be
generated b'.sed upon the results of pilot scale field demonstration of
excavation, material processing and fixation operations. However, the actual
volume treated can only be determined after completion of the remedial
alternative given the extreme variability of conditions and contaminant levels
within this fill unit.
EPA RESPONSE:
The relative difference In the two alternatives based on this criteria
Is believed to be significant due to the fact that past research as well as
feasibility studies for other Superfund sites and the remedial action using
fixation as a treatment technology for PCS contaminated soils
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13
sites have reached similar conclusions with regard to the use of fixation
technologies. Also, practical implementation has proved viable at another
Superfund site In which the fixation remedy is well underway. The degree of
reduction in toxldty. mobility, or volume will be determined in the pilot
test, thus firmly establishing whether or not the site specific conditions are
amenable to the use of the fixation technology.
10. On-slte containment must be rated above fixation/containment with respect
to demonstrated performance and reliability and, therefore, with respect to
reducing long-term risks.
EPA RESPONSE:
The revised Feasibility Study ranked on-site containment above the
median and fixation/containment below the median in terms of demonstrated
performance and reliability. Extensive research has been done and this
technology Is presently- in use (see comment 1). However, because long term
data was specifically what this criteria was designed to evaluate, the below
the median ranking Is justified because long-term data on this technology is
not avallable.
The reduction In long-term risk is addressed under several other
criteria as well as this criteria, making a conclusion on long-term risk based
solely on demonstrated performance inappropriate. However, It should be noted
that the pilot test will be designed to measure the performance of the fixated
materials under extreme conditions simulating long-term weathering. The
results of this testing will provide ample Information on long-term
reliability of the site specific fixated matrix.
11. Implementability criteria were established to evaluate the alternatives
with respect to undertaking the Remedial Action Plan. Both the EPA anr -^e
PRPs agree that On-Site Containment rates above Fixation/Containment ! arms
.of Technical Feasibility. Availabi1ity and Constructabi1ity. Additional"! y-.
both agree that there is only minor variation in rating the alternatives with
respect to Timeliness. Operation and Maintenance and Administrative
Feasibility. Therefore, it can be concluded that On-Site Containment rates
above Fixation/Containment overall with respect to implementabi1ity criteria.
EPA COMMENTS:'
The revised Feasibility Study produced by EPA indicates that On-Site
Containment cart be ranked slightly higher than Fixation/Containment in overall
implementability. However, when looking at the entire criteria set and
relative rankings as provided in the revised Feasibility Study,
Fixation/Containment 1s shown to rank higher overall than On-Site Containment.
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14
12. A pilot scale field demonstration is required to determine the
Imolementabintv of the Fixation/Containment alternative in addition to a
bench seals demonstration to design the mix and demonstrate the performance
and reliability of the technology. Preliminary consideration of the
demonstration programs Indicate there are five decision points. Any of these
decision points would prove fixation is not practicable but all of which must
be decided positively for the fixation technology to be feasible:
J^ The first decision point Is associated with the ability to
excavate the entangled silt and scrap. Based upon this decision.
a determination can be made as to how much material can
practicably be excavated.
2,.. The second decision point Is associated with the success of
screening to reduce the particle size for application of the
fixation process.
3± - The determination of the amount of material excavated and the
amount generated by screening amendable to treatment combine to
form a third decision point based upon the comparison on how much
can practicably be fixed.
li The excavation and material processing phases of the
demonstration program can be used to assess the risk of fugitive
dust emissions and the effectiveness of dust control techniques
to reduce this short-term risk to acceptable levels.
5± During the bench scale demon'stratlon. the success of fixation can
be assessed with respect to decreasing the mobility of PCBs.
Additionally, fixed samples can be submitted to repeated
freeze/thaw and wet/dry cycles to model the long-term reliability
of the technology.
EPA RESPONSE:
s.
Criteria similar to these will be Incorporated in the pilot test to
establish feasibility of fixation for the McCarty's/Paclflc Hide and Fur
Superfund site. (See Section X of the Decision Summary.)
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APPENDIX III
ARARs
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Chemlcal-
soedflc
40 CFR 761.60
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APPENDIX III
ARARs
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(CONTINUED)
40 CFR 761.75
40 CFR 761.70
40 CFR 761.65
RCRA regulations
40 CFR 264
Subpart F
40 CFR 264.310
OSHA regulations
Establishes the standards for
landfills used for disposal of
PC8s.
Establishes the standards for
Incinerators used for disposal of
PCSs .
Establishes requirements for PCS
storage for disposal facilities,
Including vehicles used for PCB
transport.
Establishes requirements for addressing
releases from solid waste management
units (landfill design).
Establishes hazardous waste landfill
closure standards (landfill design).
29 CFR Subpart 1910.120 Establishes worker protection
standards for employees Involved In
operations at CERCLA sites.
National Ambient Air
Quality Standards for
Partlculate Matter
40 CFR 50.6
Establishes national primary and
secondary ambient air quality
standards for particulate matter.
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APPENDIX III
ARARs
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
rCDNTINUED)
State of Idaho Standards
Non-point Sources
IDAPA
16.01.2050.06 &
16.01.2300.02 &
04
16.01.2200.01,
02 and 07
16.01.2850.01,
02, 03, and 04
16.01.1011.04
16.01.2301.01,02
&03
16.01.2300.05
Hell construction
Standards
16.01.1251, 52
16.01.1011, 04
16.01.1501, 02, 03
IDAPA
16.01.1011.01
Prohibits the violation of water
quality standards from {joint and non-
point sources and requires the
application of best management
practices to maintain beneficial use
of surface waters.
Prohibits the discharge to waters of
the state of hazardous materials in
concentrations found to adversely
affect beneficial use.
Requires that releases of hazardous
materials to state waters be cleaned
up.
Regulates the burning of materials
containing more than 5 ppm PC8s.
Allows short term violation of
water quality for activities which
result in overall enhancement of.
water quality.
Defines best management practices
for non-point sources.
Establishes the standards for well
construction.
Estab4-i-s-hes fugitive dust control
standards.
Establishes standards for PCS
incineration.
Establishes incineration emission
limits.
Prohibits the air emission of toxic
substances which could unreasonably
affect human life. ;
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APPENDIX III
ARARs
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(CONTINUED)
To Be Considered
EPA Cancer
Assessment Group
(CAG)
American Conference of
Governmental Industrial
Hygiehists Threshold
Limit Values
Determined the Carcinogenic Potency
Factor (CPF) for human exposure
through ingestion to be
4.34 mg/kg/day-1.
Classified PCS as a Group 82
Carcinogen. Adequate animal study
information is available to link PCS
exposure to cancer, but inadequate
epidemlologlcal information to link
PCS exposure to cancer in humans.
(Probable Human Carcinogen).
Provides recommended
Short and long-term worker exposure
values for PCSs
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