Superfund Record of Decision: Fields Brook Site, OU 2, Ashtabula, OH, 9/29/1997


EPA  Superfund
       Record of Decision:
       Fields Brook Site, OU 2
       Ashtabula, OH
       9/29/1997
                                 PB97-964113
                                 EPA/541/R-97/115
                                 January 1998

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   RECORD OF DECISION
          FOR THE
SOURCE CONTROL OPERABLE UNIT
           OF THE
 FIELDS BROOK SUPERFUND SITE

         Ashtabula, Ohio
         September, 1997

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DECLARATION FOR THE RECORD OF DECISION

SITE NAMK ANT> I jftT ATTON

Fields Brook Site, Operable Unit II, Source Control Areas, Ashtabula, Ohio

STATEMENT OF BASIS ANT> PITPPOSF

This decision document represents the selected Final Remedial Actions for the Fields Brook
Site, Operable Unit n (Source Control Areas), in Ashtabula, Ohio. These actions were chosen
in accordance with the Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), and to the extent practicable, with the National Oil and Hazardous
Substances Contingency Plan (NCP). The decisions contained herein are based on information
contained in the administrative record for this site.

This Record of Decision (ROD) is the third for the Fields Brook Superfund Site. The State of
Ohio did not concur with the Floodplain/Wedand Operable Unit ROD, dated June 30, 1997.
In addition, the State of Ohio elected not to concur with the Sediment Operable Unit cleanup
plan, as revised in the August IS, 1997, Explanation of Significant Differences. The remedial
activities selected in mis ROD for the Source Control Operable Unit support the cleanup of the
Floodplain/Wetland and Sediment Operable Units by preventing the recontamination of Fields
Brook sediment. The scope of the Source Control Operable Unit has been limited to those
areas that have the potential to recontaminate Brook sediment above cleanup goals. The State
of Ohio disagrees with the limited scope of the Source Control action and has elected not to
concur with this ROD. A letter of nonconcurrence from the Ohio Environmental Protection
Agency (OEPA) is attached to this Declaration.

ASSRSSMRNT OF THF. HlgMF.T>IFS

Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response actions selected in this ROD. may present an imminent and
substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF THF.
These remedies are intended to be the final actions for Operable Unit D (Source Control
Areas, "SC") of this site. These final actions address contamination at six (6) locations that
have been identified as sources of contamination to Fields Brook. For the evaluation of
disposal options, the Sediment and Floodplain/Wetland Consolidation area (to be built on one
of the industrial properties within the watershed) is considered to be an on-site landfill. The
six source areas and the major components of the selected remedies are, as follows:

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i
The selected alternative (Alternative VI) requires excavation of surface soil with PCB
concentrations greater than or equal to SO parts per million (ppm).

Excavation to a depth of approximately 1 foot will remove all soil regulated by the
Toxic Substances Control Act (TSCA) and will result in an estimated volume of 1,800
cubic yards.

The excavated soils will be disposed at either an on-site or off-site TSCA-approved
landfill.

Following completion of excavation activities, the excavated areas will be backfilled
with clean soil and graded to allow for adequate drainage.

The remaining surface soils included in the remedial response area will be contained
on-site with a 12-inch soil cover and an erosion control blanket and will be Vegetated to
reduce erosion. For traffic and work areas, a geotextile and 6 inches of gravel will be
used.
Milk«nfami
The selected alternative (Alternative VI) requires excavation of soil with PCB
concentrations greater than or equal to SO ppm.

The excavated soils will be disposed at either an on-site or off-site TSCA landfill.

Following completion of excavation activities, the excavated areas will be backfilled
with clean soil and graded to allow for adequate drainage.

The remaining surface soils included in the remedial response area will be contained
on-site with a 12-inch soil cover and an erosion control blanket and will be vegetated to
reduce erosion. For traffic and work areas, a geotextile and 6 inches of gravel will be
used.
North and South
The selected alternative (Alternative HI) involves the removal of sediment and debris
from inside the sewer lines and the associated catch basins.

Portions of sewers that are blocked and difficult to clean will be closed off, and the
sediment within the sewers contained. The sediments in these sewer segments will be
contained by filling the sewer pipe with a cement grout to restrict flow in the sewer and

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RMI
prevent migration of sediments into Fields Brook.

Replacement sewers will be constructed to divert water from the sections that have been
closed and to connect the remaining sections of the sewers that have been cleaned.
These sewers will continue to be used after remedial activities are completed.

f!nrpnratfnn
The selected alternative (Alternative IV) includes the construction of a partial slurry
wall to contain the Dense Non-Aqueous Phase Liquid (DNAPL) and contaminated
groundwater,

Vacuum-enhanced extraction wells will be installed to lower the groundwater table and
collect DNAPL. Extracted groundwater will be treated by Detrex's existing
stormwater treatment system that uses carbon filtration to remove contaminants from
collected surface water. Extracted DNAPL will be treated or recycled off-site.

Low-lying areas within the existing'collection system area and areas with surface soil
cleanup goal exceedances will be filled and regraded. These areas would then be
covered with a 12-inch thick soil layer, an erosion control blanket, and a vegetative or
crushed stone layer surface. The regraded areas will be vegetated to protect against
erosion.
The selected alternative (Alternative IV) requires excavation of soils with PCB
concentrations greater man 10 ppm.

The depth of the excavation will be approximately 1 foot and will result in an estimated
volume of ISO cubic yards

The excavated soils will be disposed at either an on-site or off-site Toxic Substances
Control Act (TSCA)-approved landfill.
f!nnrail
The selected alternative (Alternative IV) requires the consolidation and containment of
arsenic-contaminated soils.

Excavation to a depth of approximately 6-inches will remove approximately 90 cubic
yards.

Excavated soils will be moved a short distance to a consolidation area (on Conrail

iii

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property) for final disposal. Upon placement of excavated soils, this area will be
graded and covered with 6 inches of gravel to prevent soil erosion.
All
For all source areas where contamination will remain on-site within a containment area, the
remedies will include the following:

• Long-term operation and maintenance (O&M) and post-closure care of die remedial
actions to help ensure effectiveness.

• Long-term monitoring to verify the effectiveness of the remedial actions.

• Placement of institutional controls on deeds and title for properties where hazardous
substances, pollutants or contaminants will remain above levels mat allow for unlimited
use and unrestricted exposure. These controls will limit the future use of areas so as to
ensure that contamination does not migrate to the Brook.

• Implementation of access restrictions, including the construction of new fencing where
necessary to prevent access and maintain the integrity of cover systems.
STATUTORY DETERMINATIONS

These final Remedial Actions are protective of human health and the environment, comply
with Federal and State applicable or relevant and appropriate requirements and are cost-
effective. The selected remedial actions utilize permanent solutions and considered use of
alternative treatment technologies to the maximum extent practicable. However, due to the
significant volume and heterogeneous distribution of waste at the Site, treatment as a principle
element is not considered practicable at the Site. Thus, these remedies do not address the
statutory preference for treatment that reduces toxicity, mobility, or volume as a principal
element. However, treatment is a secondary element in that DNAPL from the Detrex facility
will be collected and treated resulting in destruction of hazardous substances.

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State of Ohio EavtrauMOtal Protection AgencJ* C C B I V £
Si^oTT^lOW TELE:(614)644«2DFA>t(614)644.a29 — I - 1997 Cou^ON43216-1049
Septembers, 1997
Mr. David A. Ullrich
Acting Regional Administrator
USEPA Region V
77 West Jackson Blvd.
Chicago, IL 60604

Dear Mr. Ullrich:

Thank you for the opportunity to review and comment on the draft Record of Decision (ROD)
for the Source Control Operable Unit (SCOU) of the Fields Brook Supertund Site (Fields
Brook).

As you know, Ohio EPA made a decision over a year ago to relinquish our role in providing joint
oversight with USEPA for Fields Brook in order to focus our attention on the Ashtabula River
project Prior to this decision we had expressed concerns about USEPA's overall approach to
risk management for the SCOU. We felt that source control remedies should be based on
managing risk at each individual source area by following the usual process of evaluating risk by
all appropriate pathways and developing cleanup goals based on site risk. USEPA took the
approach that source control remedies would be designed to address the risk of recontaminating
Fields Brook Sediment at concentrations in excess of the Brook Sediment Operable Unit (SOU)
cleanup goals (CUGs). SOU CUGs were based solely on human health effects from incidental
sediment ingestion. SCOU remedies were limi 'd to areas which could potentially cause the
SOU CUGs to be exceeded in the future. All potential source areas were screened by comparing
contaminant concentration to the SOU CUGs and evaluating pathways of contaminant migration
from the source area to the Brook Sediments. Any potential source area which was lower in
concentration than the SOU CUGs or for which there was no pathway by which that source could
recontaminate Brook sediments (to concentrations in excess of the SOU CUGs) was eliminated
from further consideration. Originally about 200 potential source areas were considered. After
the screening process only 6 areas were carried forward. These potential source areas were
eliminated without regard to risk to human health or the environment Recharge of the Brook by
contaminated groundwater and surface water were eliminated because these processes could not
result in sediment concentrations higher than the SOU CUGs. USEPA contended that any areas
which present risk to receptors other than Fields Brook sediment or which may violate any
regulatory standards should be addressed separately under other regulatory programs such as
RCRA Corrective Action or the Clean Water Act. It was even suggested that a source area or
areas could be individually scored as separate NPL sites in the future.

George V. Voinovfch. Governor
Nancy P. Hottster. U Governor
EPA 1613 (rev. S/96) Donald R. Schnjgwous. Director
^£ Pnrtea on tlecycieu Pyac

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Slate of Ohio Eavbonmental Protection Agency
IMOWMMMMkMM
Columbus, OH 4321S-100B
TELE: (614) 644-3000 FAX: (614) 644-2329
P.O. Bra 1049
Cohmbus. OH 43216-1049
Mr. David A. Ullrich
September 8,1997
Page-2-
Ohio EPA continues to disagree with this approach. When we informed USEPA of our decision
to allow you to manage the Fields Brook site without active Ohio EPA participation we
expressed the hope that you would consider these concerns when making final remedy decisions.
This SCOU ROD does not reflect any change in USEPA's approach to the SCOU cleanup,
therefore, for the reasons stated above Ohio EPA does not concur with the ROD for the SCOU.

Please feel free to contact Ohio EPA should you have any concerns or questions regarding this
letter.
Sincerely,
Director
Ohio Environmental Proteci
SW/DS.wmk
Agency
cc: Jenny Tiell, Deputy Director, CO "
Jan Carlson, DERR, CO
Mike Czeczeie, DERR, CO
Ray Beaumier, DERR, CO
Bill Skowronski, District Chief, NEDO
Bob Wysenski, Assistant District Chief, NEDO
Rod Seals, DERR, NEDO
Steve Love, DERR, NEDO
Sig Williams, DERR, NEDO
Heidi Sorin, DERR, CO
Jeff Hurdley, Legal, CO
Peter Whitehouse, DERR, CO
Vanessa Steigerwald, DERR, CO
Tim Kern, Ohio AGO
ERA 1613 (rev. 5/96)
George V. Vttnovfcft. Governor
Nancy P. HoHstar. U. Governor
Donald R. Schregaidus. Director

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RECORD OF DECISION SUMMARY
SOURCE CONTROL AREAS
FIELDS BROOK SITE, ASHT ABULA OHIO
I. SITE NAME, LOCATION, AND DESCRIPTION

The Fields Brook Site is located in die city, township, and county of Ashtabula, in
northeastern Ohio, approximately 55 mites east of Cleveland, Ohio (Figure 1). The main
channel of Fields Brook is 3.9 miles in length and begins at Cook Road, just south of the Perm
Central Railroad tracks. From this point, Fields Brook flows northwest to Middle Road, then
west to its confluence with the Ashtahula Rivet. From Cook Road downstream to Stale
Highway 11, Fields Brook flows through an industrialized area. Downstream of State Highway
11 to near its confluence with the Ashtabula River. Fields Brook flows through a residential
area within the city of Ashtabula. Fields Brook empties into the Ashtabula River,
approximately 8,000 feet (ft) upstream from Lake Erie.

The city of Ashtabula, with a population of approximately 23,000, is the only urban area in
the Fields Brook watershed. The industrial zone of Ashtabula is concentrated around Fields
Brook and contains several chemical industries yd waste disposal sites. This Record of
Decision addresses contamination at six source areas located in the industrial zone of the Fields
Brook watershed.

Sediments of the brook and the Ashtabula River are contaminated with polychlorinated
biphenyls (PCBs), chlorinated benzene compounds, chlorinated solvents, hexachlorobutadiene,
polyaron*rtic hydrocarbons (PAHs), arsenic, and other hazardous substances. Soils at the
source areas addressed by this Record of Decision are also contaminated with a wide variety of
although PCBs predominate. Specific contaminants found at each source area
are discussed in Section IV of this Record of Decision.

The Fields Brook Site (Site) was placed on the National Priorities List (NPL) for hazardous
waste sites on September 8, 1983. The site consists of Fields Brook, its tributaries, and any
surrounding areas which contribute, potentially may contribute, or have contributed to the
contamination of the brook and its tributaries. The site is a multi-source site and involves
multiple media, including soil, sediment, groundwater and surface water.

The U.S. Environmental Protection Agency (U.S. EPA) divided the site into four areas of

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concern, three of which have been designated as "operable units" (OUs) associated with the
Fields Brook Supernmd site (See Figure 2). The Sediment OU (OUfl) involves the cleanup
of contaminated $f^imfnt in Fields Brook and its tributaries. The Source Control OU (OU#2)
involves die location and cleanup of sources of contamination to Fields Brook to prevent
nf the hmok, and is the subject of this Record of Decision dnmmmt Figure
3 shows the location of the source areas in the watershed. The third area, die Ashtabula River
Area of Concern, evaluates die type and amount of contamination in the Ashtabula River, die
effect of contamination on the river sediment", and any risks to human health and die
environment. The Floodplain/Wetiand (FWA) OU (OU#4) involves die cleanup of
contaminated soils and sediments in die FWA which are located within die 100-year floodplain
area surrounding Fields Brook and outside of the channel and skteslope areas of Fields Brook.
n. SITE HISTORY AND ENFORCEMENT AciivnusS

The industrial zone of Ashtabula is concentrated around Fields Brook and is comprised of
several chemical industries and waste disposal sites. Manufacturing has occurred since die
early 1940's in this area. Activities ranging from metal-rabrication to production of complex
chemical products occurred on approximately 18 separate industrial properties, and the
of industrial activity along Field* Brook and its tributaries resulted in me release of chemical
contamination to the Fields Brook watershed, particularly the sediments of Fields Brook, the
FWA soils and sediments, and Ite soils sunoundnig the industries. These media are
contaminated with PCBs, chlorinated benzene compounds, chlorinated ethenes (solvents).
hexachlorobutadiene, arsenic, and other organic and inorganic contaminants.

Between April 1983 and July 1986. a Remedial Investigation/Feasibility Study (RI/FS) was
conducted on the Fields Brook Sediment OU by the U.S. EPA. The 1986 RI/FS included a
baseline tinman healm risk assessment which demonstrated human healm risks not only for
exposure to die brook sediment, but also exposure in die FWA. The U.S. EPA issued a
Record of Decision (ROD) hi September 1986 detailing a cleanup remedy that U.S. EPA vith
the concurrence of Ohio Environmental Protection Agency (OEPA), determined to be
necessary for die Fields Brook sediments. The 1986 ROD required die excavation, treatment
and disposal of sediment from Fields Brooi*. It also recommended that investigations be
conducted to identify current sources of contamination to die Brook.

In late 1986. the U.S. EPA began negotiating with a number of Potentially Responsible Parties
(PRPs) to conduct die source control OU12 RI/FS activities and sediment operable unit design
activities. The PRPs are comprised of die companies who are considered die owners and
operators of die chemical industries and waste disposal sites surrounding Fields Brook. The
PRPs also include die companies who, by contract, agreement, or other means, either
accepted, or arranged for transport, disposal or treatment of, hazardous substances within the
Fields Brook site.

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In 1989, the PRPs were issued a Unilateral Order to design a remedy for the Fields Brook
sediments, complete a Remedial Investigation to identify the sources of contamination, and
develop and evaluate cleanup alternatives for the sources of contamination.  From 1992 to
199S, the PRPs evaluated 94 areas of potential contamination within the Fields Brook
watershed to determine whether they were a source of past contamination or could cause future
recontamination once die Brook cleanup is underway. Contamination could be caused by
discharges from pipes, the movement of contaminated soil or sediment during rainstorms, and
subsurface releases to the brook from flowing groundwater.

As a result of this evaluation, the PRPs identified five industrial properties as sources of
contamination to Fields Brook.  The industrial properties include Detrex, Millennium Plant II
TiCM (formerly SCM), ACME. RMI Metals, and Conrail. In addition, several sewer systems
located to the norm and south of Fields Brook were also found to be potential sources of
contamination.  Detailed information about the types and extent of contamination at the source
areas can be found in the Source Control Remedial Investigation (RI) reports.  The final Phase
1 Source Control RI was approved in May of 1997.

In conjunction with die preparation of the Source Control Remedial Investigation report, the
PRPs prepared a Source Control Feasibility Study to identify and evaluate cleanup alternatives.
The Source Control Feasibility Study was finalized in June,  1997.  The report describes the
initial screening of alternatives, the identification of a range of remedial alternatives, and the
detailed analysis of the assembled alternatives for each of the five properties and the sewer
systems.

The Source Control Remedial Investigation and Feasibility Study reports form the basis for
U.S.  EPA's cleanup strategy. These reports have been included in the information repositories
and the Administrative Record.
 m. HIGHLIGHTS OF COMMUNITY PARTICIPATION

 Various public meetings and availability sessions have been held by U.S. EPA in Ashtabula
 between 1984 and the present to discuss the general progress of the ongoing Fields Brook site
 investigations.

 U.S. EPA has provided regular updates of Fields Brook site activities to the Ashtabula River
 Remedial Action Plan (RAP) Advisory Council at the monthly RAP meetings in Ashtabula.

 On May 26-27,  1993, U.S. EPA conducted several availability sessions and a public meeting
 in Ashtabula to update the public regarding activities at the site, including the Source Control
 Operable Unit. After the meeting, U.S. EPA provided the RAP Council and interested citizens
 with a written response to comments and questions raised at the various meetings.

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On September 26, 1996, U.S. EPA conducted another public availability session in Ashtabula,
and provided the public with a detailed update regarding the various FWA studies, risk issues
and cleanup alternatives being considered to be conducted. In November 1996, U.S. EPA
provided the public with a written 'question and answer* response to comments and questions
raised at the September meeting.

U.S. EPA issued a Proposed Plan for the Source Control Operable Unit (SCOU) in Jury 1997.
U.S. EPA provided a public comment period on the SCOU Proposed Plan from July 24, 1997
through August 22, 1997, and conducted an evening public meeting on the Source Control
Proposed Plan on July 31, 1997 in Ashtabula. Upon request, the comment period was
extended to September 15,1997. After a follow-up request for more time to submit comments
regarding the Acme property, die comment period was again extended. The comment period
closed on September 22,1997.  All comments were carefully reviewed and considered by the
U.S. EPA prior to ifmFarre of this ROD. U.S. EPA's response to the public comments
received are ymmanTeO in the attached Responsiveness Summary, which is Attachment 1 of
this Record of Decision.  This ROD will become part of the Administrative Record pursuant to
the NCP Section 300.825 (a)(2). The Administrative Record can be found at the site
repository in the local library and at the U1S.  EPA Region V office.  The addresses are, as
follows:

 1)    Ashtabula County District Library
       335 West 44th Street
       Ashtabula. OH

 2)    U.S. Environmental Protection Agency
       Waste Management Division Records  Center,  7th Floor
       77 West Jackson Blvd.
       Chicago, IL
 IV. SUMMARY OF SITE CHARACTERISTICS

 The Fields Brook watershed eu-xunpasses 6.0 sq. mi. All of the industrial facilities addressed
 in this ROD are located to the north of the Perm Central Railroad line that runs east-west
 through the middle of the watershed. The area is located in the Lake Plain physiographic
 province of Ashtabula County. The elevation of the Lake Plain ranges from 620 ft mean sea
 level (MSL) to 660 ft msl.

 In general, the subsurface geology of the Fields Brook watershed consists of three geologic
 formations. In descending order, these formations are: glacial-lacustrine, glacial till, and shale
 bedrock.  Additionally, several feet of miscellaneous soil fill materials were encountered on
 several properties investigated during the Phase 1 of the source control RI.  These fill
 materials are distributed sporadically and the result of several years of industrial activities.

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Mote detailed information concerning site characteristics can be found in the SCRI report.

According to information from die Ohio Department of Natural Resources, the groundwater
production potential of the area within die watershed is considered very limited and not
capable of yielding water at rates greater than 3 gallons per minute. No drinking water wells
are located within the industrialized portion of the watershed. The water supply for the
Industries and residences in die area is from Lake Erie.

A) Acme Scrap Iron & Metal Company

The Acme properly is located in the southwebt portion of the industrialized area near Fields
Brook. Structures at the site include former manufacturing plant buildings, loading and
unloading areas, drum storage areas, and an oil retention lagoon. See Figure 4.

The site is currently operating as a scrap recycling facility. The site was owned by die U.S.
Government in die late 1940's and was later sold to National Carbide Corporation. Specific
industrial activities by die U.S. Government and National Carbide are not known. However,
die Acme site was operated as a calcium carbide manufacturing plant from 1943 until 1952.
The facility was men vacant until 1974, when Acme purchased the property.

In die past. Acme dismantled and recycled transformers to recover copper, ahiminum, and
steel for resale as scrap metal. On several occasions, the cutting operation used to dismantle
the transformers would set the residual oil on fire. Oil containing PCBs may have been
released into the environment from me transformers during this process. A preliminary
assessment of die Acme facility in 1985 identified the chemicals of interest to include PCBs
and several metals, including ahiminum, arsenic, copper, iron, lead, mercury and zinc.

The Recontamination Assessment performed as part of die Fields Brook Source Control
Remedial Investigation (SCRI) identified several source areas at Acme as having die potential
to recontaminatc Fields Brook. This evaluation is presented in Chapter 6 of die SCRI Report.
Twenty surface soil samples were collected at the facility. The analytical results showed
contamination at die following locations on die Acme property.

1. Drum Storage Area

The drum storage area covers approximately 1.4 acres. It is located southeast of die
main structure and includes a small storage building and the property surrounding the
building. The building is used by Acme to store empty drums and drums of grease
used for equipment maintenance. Surface soil samples collected from inside and
around the building were found to have concentrations of PCBs ranging from 2.19
parts per million (ppm) to 16.9 ppm. The unit of measurement "parts per million" (or
"ppm") is equivalent to the unit of measurement "rag/kg."

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2. Oil Soaked Sofl

The Oil Soaked Soil location consists of several areas on the Acme property which
display surface soil staining. In total, the oil soaked soil covers a combined area of
approximately 12 acres. The stained soils generally are found near the scrap processing
areas. A number of surface soil samples were collected in these areas and
concentrations of PCBs range from below die detection limit to 79.5 ppm. For die
development and analysis of remedial alternatives, the oil soaked soil areas were
combined with the transformer processing area.
I
3.

The transformer processing area covers a combined area of approximately 12 acres
where transformers were processed in die area north of the main facility building. The
transformers were processed to recover copper wire. A surface soil sample collected in
this area was found to have 3.2 ppm PCBs. As noted above, die transformer
processing area was combined with die oil soaked soil areas for die development and
analysis of remedial alternatives. ''

4. Other Surf ace SoU Areas

PCBs were detected in surface soil samples collected during die Phase ISCRI in the
northwestern portion of uw property. PCB concentrations range from below die
detection limit to 4.1 ppm. No specific sources are associated widi diese areas but they
are being considered in the remedial alternatives. These areas cover approximately 4.7
acres.

5. Oil-She Storm Sewers

U.S. EPA required the PRPs to conduct and present detailed analysis of alternatives for
the Acme property on-site storm sewers. The storm sewers are believed to have
sections that have breaks and are blocked in certain parts by debris. No information is
available about the volume of sediment in the on-site storm sewers.

B) Millennium Plant D, TfCI. Facility

Millennium Plant D, the TiCl« (titanium tetrachloride) facility is located in die south-central
portion of die industrialized area near Fields Brook. The structures currently at die site
include several process buildings, a tank farm with numerous aboveground storage tanks
contained entirely within a diked area, and diree settling ponds. The western half of die
property contains most of die process-related structures, whereas the eastern half remains
largely undeveloped and is covered by a large pile of mining wastes and filter residue. See
Figure 5.

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The TiCl« plant was designed, constructed and initially operated by the Stauffer Chemical
Company. Construction was completed in 19S8. The facility was sold to National Distillers
and Chemicals in 1959 and was operated for the next five years by National Distillers (and its
affiliates Mallory-Sharon Metals and RMI Titanium). Cabot Titania acquired the plant in 1963
and operated it until 1972. when it was leased to Gulf and Western Industries, Inc. Gulf and
Western purchased the plant in 1975. SCM purchased the TiCl, facility in 1983.

At the commencement of operations, the plant utilized a heat transfer system mat used
Aroclor-based fluids. This system remained in use until Gulf and Western had pure Aroclor
removed from the heat transfer system in 1974 and replaced it with Monsanto PCB-Free
Thenninol.

There have been multiple investigations of contamination at the TiCU facility. A Toxic
Substances Control Act (TSCA) action in 1983 tod to the excavation and disposal of PCB-
contaminated sediment from rainwater trenches (660 ppm) and overflow channels (330 ppm).
In 1990, SCM identified PCB contamination (to 41,000 ppm). This was reported to the
Region V TSCA office. TSCA required die preparation of a work plan and an investigation to
determine the extent of soil contamination and identify buried drums. This work was
postponed in 1991, to allow coordination with the Fields Brook Source Control Remedial
Investigation.

As pan of the SCRI, the Recontamination Assessment of Millennium identified die Mining
Residuals Pile, die Non-Traffic Area and the Norm Traffic Area as areas that possess the
potential to "-contaminate Fields Brook. At the consensus of U.S. EPA and Millennium,
remedial action is also being planned for other plant areas that have PCB concentrations
greater than the Fields Brook cleanup goal. These additional areas include: the Laydown
Area; the Plant Process Area; and the Existing Soil Piles. It should be noted that these three
plant areas were analyzed by the Recontamination Assessment and were determined not to be
potential sources of ^contamination of Fields Brook. Descriptions of the six plant areas and
analytical results are summarized in the following sections.

1. Non-Traffic Area

Site investigations have identified PCBs in surface soils (approximately the upper 6 ft)
hi the west-central portion of the facility, extending norm beyond the existing security
fence-line. The area extending north beyond the fence-line to the 100-year floodplain
is the Non-Traffic Area. PCB concentrations in surface soils in the Non-Traffic Area
range from 3.1 ppm to 50 ppm. However, a few sampling locations near the old
outfall were found to have concentrations of PCBs greater man 50 ppm, and some
borings had soils containing greater than 500 ppm. At the consensus of U.S. EPA and
Millennium, Millennhim evaluated the past sampling in comparison with a 50-foot
sampling grid, with samples collected at 2-foot depth increments. The results of this

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additional delineation sampling are undergoing U.S. EPA review.

2. North Traffic Area

Site investigations identified PCBs in surface soils (approximately the upper 6 ft) in the
west-central portion of the facility, extending north beyond die existing security fence-
line. The area south of Ihe fence-line and north of the Plant Process Area is defined as
the North Traffic Area. The surface area in the North Traffic Area is covered with
pavement, structures, or gravel. The gravel was placed to prevent further contact with
on-site surface soils in this area and to reduce the potential for erosion of the surface
soils.

PCB concentrations in surface soils in die North Traffic Area have generally been
identified in die range of 3.1 ppm to SO ppm. However, a few sampling locations near
an old outfall had concentrations of PCBs greater dian SO ppm and a small area with
PCBs greater than 500 ppm. At die consensus of U.S. EPA and Millennium,
Millennium evaluated die past sampling in comparison with a 50-foot sampling grid,
with samples collected at 2-foot depth increments. The results of this additional
delineation sampling are undergoing U.S. EPA review.

3. Lay down Area

The Laydown Area is located """»*«M«*»iy soum of die concrete pad. The Laydown
Area consists of bare soils and vegetated soils. The average PCB concentration in the
Laydown Area is 3.S ppm, and die maximum concentration is 37.9 ppm (at l.S to 3.0
ft depth). The Rccontamination Assessment found neither groundwater nor overland
erosion to be complete pathways for recontamination of Fields Brook. The Laydown
Area is being addressed in this document at die consensus of U.S. EPA and
Millennium, not because it has die potential to recontaminate Fields Brook.

4. Plant Process Area

The Plant Process Area is die active, operating portion of die TiQ, facility. The Plant
Process Area is almost completely covered with either pavement or structures. PCB
concentrations in surface soils in die Plant Process Area have generally been identified
in die range of 3.1 ppm to SO ppm. However, a few scattered sampling locations have
identified PCB concentrations greater dun SO ppm and a small area with PCB
concentrations greater than 500 ppm. The primary area widi elevated PCB
concentrations is associated with die old Therminol system. At die direction of U.S.
EPA. Millennium evaluated die past sampling in comparison with a 50-foot sampling
grid, with samples collected at 2-foot depth increments. The results of this additional
delineation sampling are undergoing U.S. EPA review.
8

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5. Existing SMI Files

The Existing Soil Piles are located on die concrete storage pad in the east central
portion of die TiCl* facility. Standard plant maintenance and upgrades occasionally
require the excavation of small amounts of soil. These soils are stockpiled on die
concrete pad. Historic sampling results from die excavation locations indicate that
some of these soils may contain couLicnUations greater than 50 ppm PCBs. The soil
piles are being addressed in this document at die consensus of U.S. EPA and
Millennium; however, die soil piles were not designated as having die potential to
recontaminate Fields Brook.

6. Mining Residuals Pile

The inactive Mining Residuals PUe is located in die eastern portion of the facility
between Middle Road and Fields Brook. The pile received •BevuT exempt mining
residuals (e.g., iron hydroxide) from previous plant operations prior to Millennium's
operations. As stated in die Bevill exemption, die mining residuals are neither
hazardous wastes nor hazardous substances.

Information gathered during the Mining Residuals Pile investigation indicates that the
material is primarily iron hydroxide, with a tow moisture content (measured at about 25
to 30 percent, as compared to an approximate field capacity of SO to 60 percent), and a
(disturbed) density ranging between 1.0 and 1.2S tons per cu yd. Although die mining
residuals are not hazardous wastes, sample results revealed that PCBs are present in the
Mining Residuals Pile at concentrations ranging from non-detect to 760 ppm.

Q Conrail

ConraiTs Bridge Yard is located north of Fields Brook, east of die Ashtabula River and west
of a residential area within die City of Ashtabula, Ohio. Conrail uses this area for marshaling
or staging rail cars containing coal before and after loading and unloading rail cars. Features
in die Bridge Yard area include numerous sets of tracks, a small lift bridge control (or
yardmaster) building, and a small building that formerly housed a compressor. Main access to
die area for vehicles is from die north; however, a light i«uty bridge east of die yardmaster
building makes die property accessible from East 15th Street to die south. The light duty
bridge is currently closed widt a metal barricade at each end. Trains enter and leave die
Bridge Yard from die south end of die Yard near die confluence of Fields Brook and die
River.
Only a small portion of die Bridge Yard lies within die Fields Brook watershed. The area of
interest includes a long (approximately 1600 ft), narrow strip of land along Fields Brook from
15th Street to die Ashtabula River. This area extends from die centerline of die southernmost
set of railroad tracks south to Fields Brook (see Figure 6). Within tiiis area, potential source

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areas originally identified in the Phase I SCRI included the aboveground storage tanks located
near the east side of the yanlmaster building, the former compressor building, and soil staining
in the area near the light duty bridge. Surface soil samples collected at the Conrail property
during completion of the SCRI contained arsenic concentrations ranging from 10.4 ppm to 62
ppm. U.S. EPA determined mat based on the close proximity of the Conrail facility to the
Brook, the facility posed a threat to the recormiinmarion of the Brook. Arsenic contaminated
soil located immediately next to the Brook on the Conrail facility may be running off the
property more man soil in the upper watershed and may not become sufficiently diluted with
the cleaner runoff to prevent an exceedance of die arsenic CUG in Fields Brook sediment.

D) Detrex Corporation

The Detrex Corporation is located in the northwestern portion of the Fields Brook watershed
adjacent to the norm bank of the main channel of Fields Brook. The facility encompasses 58
acres. Structures on the property include a process building, office building, and numerous
aboveground storage tanks mat are either within diked areas, paved areas, or on ground
surfaces. The northern one-third of the property is used as an active manufacturing area and
the southern two-thirds is largely undeveloped. See Figure 7.

The Detrex facility currently produces pyrrole, n-memyl pyrrole, and hydrochloric acid. The
product of the n-methyl pyrrole and pyrrole reactions are distilled to give n-methyl and pyrrole
as product and non-hazardous still bottoms. Past operations at mis plant included die
chtorination of acetylene to produce trichloroetnene and tetrachloroetfaene. The chemicals of
interest at Detrex from current operations include furan, monomethyl amine, n-methyl pyrrole
(NMP), pyrrole and ammonia, while the chemicals from past operations included
tricholoroethene, 1,1,2,2-tetrachloroethane, hexachlorobutadiene (HCBD), and
tetrachloroethene.

Results from sampling conducted during the SCRI indicate mat surface soil exceedances for
CUG compounds were identified in sever*, areas of the Detrex facility. These areas include:
the stormwater collection ditch on the northern property line, several abandoned retention
ponds, construction debris piles, sediment in the stormwater settling collection basin, and a
catalyst pile. In addition, the results of the Recontamination Assessment and identification of
Dense Non-Aqueous Phase Liquid (DNAPL) indicated that the following areas should be
addressed to reduce possible sources of future contamination to Fields Brook:

1. Seven Closed Lagoons

The closed lagoons are located in the northeastern portion of the Detrex facility.
Subsurface soil samples collected from the area surrounding the lagoons were found to
contain several volatile and semi-volatile organic compounds at concentrations
exceeding occupational CUGs. DNAPL was identified in the shallow groundwater
bearing formation both in the closed lagoon area and at off-site locations north of

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DET1 on RMI Sodhim property. A sample of DNAPL was collected from one of the
on-site monitoring wells in order to characterize mis material. Four volatile organic
compounds were Menfif*** (1,1.2,2-tetrachloroethane, 1,2-dtchloroethene,
tetracUoroethene, and trichloroethene). Three semi-volatile organic compounds were
identified (h^Karhtorrfrrnrenc, ^^yhiQTO^itidifnf and ^^y^|^ftvtrt>aiv>) Based on
existing Phase I data and the delineation borings, the DNAPL plume extends in a radial
pattern from the closed lagoon area and encompasses an estimated subsurface area of
approximately 500,000 sq. ft. (11.5 acres). Based on data collected to-date, the
DNAPL plume is migrating toward the northwest, consistent with groundwater flow
and the structure of the top of the underlying till layer. The extent of the DNAPL
plume will be delineated as part of a oesign investigation program to be completed
prior to completing the final design.

2. Sources Within die Surface Water Treatment System

The surface drainage system in the northern industrialized portion of the Detrex facility
has been modified to collect and treat surface water. Of the area within die bounds of
the surface water treatment system, approximately 60.000 sq.ft of surface area has soil
CUG exceedances. The ponded area in the lagoon area covers approximately 4,000
sq.ft. In addition, approximately 1,500 sq.ft. along die drainage ditch has surface soil
CUG exceedances. The area that is located within die bounds of the surf ace drainage
system is underlain by the subsurface DNAPL plume

3. Sources Outside the Surface Water Collection System

In the Phase ISCRI Report, die catalyst piles were not considered a potential source of
sediment recontamination. A surface soil sample located downslope of the floodplain
detected a concentration of 40.4 ppm PCBs. Subsequent sampling of die catalyst
material has indicated the presence of PCBs greater than occupational CUGs for the
Fields Brook sediment. Additional sampling of the three catalyst piles indicated PCB
concentrations ranged from 2 to 5 ppm. Since die catalyst piles are in close proximity
to Fields Brook, U.S. EPA requested out die catalyst piles be considered in the FS.

E) Sewers North and South of Fields Brook

1. Sewers North of Fields Brook

Results from the Phase I SCRI indicate dial die sediment in several storm sewers and
outfall process facility sewers is a potential source for recontaminau'on of Fields Brook
sediment. These sewers consist of: die 48-in. diameter combined sewer west of State
Road; the 5-in. diameter storm sewer west of State Road that discharges into die 48-in.
diameter combined sewer; and the Detrex facility outfall sewer. See Figure 8A.
11

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      Combined Sewer (48-in. Diameter) - State Road

         Minnies from the 48-in. diameter combined sewer bid concentrations
of berao(a)pyrene and hexachtaobenzene mat ranged from 1.9 ppm to 11 ppm
and 13 ppm to 5,800 pom, respectiveiy.  This sewer is a 48-in. diameter
reinforced concrete combined stocm and facility outfall sewer. The sewer is
approximately 2,400 ft in length and runs along the west side of State Road,
norm of Fields Brook. The sewer accepts surface and facility outfall water,
which at several locations includes bom plant surface water, process water,  and
sanitary effluent.  Oil-site treatment of sanitary waste is handled by all facilities
mat discharge to die sewer.  No untreated effluent water enters the combined
sewer system. The combined sewer collects outfall water from three facilities
(Occidental, UNO Sodium, and Detrex) through three outfalls located along
State Road along with street runoff from a catch basin located at East 6th Street
and State Road. This sewer is estimated to have 4 to 6 in. of hardened calcium
carbonate precipitate in it.  No information is available about die volume of
sediment in mis sewer.  Also, ale exact condition of mis sewer is not known.
The sewer is partially blocked in certain  parts by debris which includes bricks,
wood, sediment, and pieces of concrete.   Approximately 650,000 gallons of
water per day are believed to be discharged into Fields Brook by mis sewer.

b.     Storm Sewer (5-in.  Diameter) - State Road, North of Fields Brook

A sediment sample from this storm sewer had a 5.4 ppm concentration of
benzo(a)pyrene (BAP). The storm sewer is a 5-in. vitrified clay storm water
sewer that is approximately 250 ft in length.  It runs, from the southwest corner
of the intersection of State Road and East 6th Street, south to join the north end
of die 48-in. diameter combined sewer on the west side of State Road, north of
Fields Brook. l.± information is available about the condition of this sewer or
the amount of sediment it contains.

c.     Detrex Facility Outfall Sewer

 A sediment sample was collected from within a manhole on die east side of
 State Road in the northwest comer of the Detrex property. This manhole is
 between the Detrex facility sewer and the 48-in. diameter combined sewer that
 eventually discharges to Fields Brook on the west side of State Road.  The
 sewer transfers water from the Detrex water treatment system to the 48-in
 diameter combined sewer.  The sewer is constructed of PVC and is relatively
 free of sediment. This PVC sewer discharges to the manhole which contains an
 older section of sewer line that crosses under State Road and connects to the 48-
 in. diameter combined  sewer.  The sediment sample was collected from the

                             12

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bottom of die manhole where die sediment accumulates. Approximately
500,000 gallons per day of fluids are believed to be discharged through this
sewer into die 48-in. diameter combined sewer, which eventually discharges
into Fields Brook. The sediment sample had concentrations of 1,1,2,2-
tetrachloroethane, 1,1-dichloroethene, tetracbloroethene, benzo(a)pyrene (BAP),
hexachlorobenzene, HCBD, hexachloroediane, heptachlor, and gamma-BHC
(Lindane).

2. Sewers South of Fields Brook

Results from die Phase I SCRI indicate that the sediment in several storm sewers and
outfall process facility sewers located on die south side of Fields Brook is a potential
«»nr» fir»r nmnt*min»ticm nf Pieid* Bmnlr sediment TbJS SCWer SVStem COnSlStS Of
die 36-to 48-inch diameter sewer east of State Road which runs between die Acme
facility and Fields Brook, as well as die 30-inch outfall sewer that connects die oil
retention lagoon on die Acme property to die catch basin at die corner of die
intersection of State Road and Middle Road. See Figure 8B.

a. Acme Sewer

Sediment •••miea collfctffd from die catch basin at die corner of die intersection
of State Road and Middle Road had 2.0 ppm of total PCBs. The length of
sewer includes die 30-in. diameter reinforced concrete sewer (total length of
approximately 300 ft) that connects die oil retention lagoon on die Acme
property to die catch basin at the corner of die intersection of State Road and
Middle Road. The sewer also includes die larger (36-in. or 48-in. diameter)
reinforced concrete sewer (total length of approximately 1,200 ft) that connects
the catch basin at die intersection of Middle and State Roads to Fields Brook.
The on-site Acme facility outfall sewers are believed to have sections dial have
breaks and are blocked in certain parts by debris. No information is available
about die volume of sediment in die sewers located on die east side of State
Road.

F) RMI Metals Reduction

The RMI Metals Reduction facility is located at die southwest comer of die intersection of
State Road and East 21* Street. The RMI Metals property is bordered on die north by East
21" Street, North Coast Auto, and RMI Extrusion facilities, on die east by State Road and die
Acme facility, on die south by undeveloped property, and to die west by Reach 10-1 of Fields
Brook and State Route 10. The facility was used until 1992 to produce pure titanium metal
(Ti) called Ti sponge. The facility was closed in 1992.

The results of die Recontamination Assessment presented in die Phase I SCRI Report indicated

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that it was not necessary to consider remedial alternatives for any potential source areas located
at the RMI Metals facility in the feasibility study. However, based on discussions with U.S.
EPA after subm!™*1 of the Phase ISCRI Report, it was decided that additional surface soil
sampling should be conducted in the vicinity of the potential source area where one elevated
concentration (6.9 pom) of PCBs was detected in the Phase I SCRI sampling program. This
potential source area was identified in the Phase 0 SCRI as a demolition debris landfill. As the
result of two additional sampling and analysis efforts conducted in August and October 199S,
it was mutually decided between the RMI and the U.S. EPA mat additional sampling would be
conducted to refine and more completely delineate die remedial response areas for each
remedial alternative. In addition to die identification of several PCB residential CUG
exceedances in this vicinity, the area is also'in close proximity to Reach 10-1 of Fields Brook.
In follow-up sampling efforts conducted in August and October 1995, several additional
surface soil samples collected in mis area were found to have concentrations of total PCBs
ranging from 0.9 ppm to 91 .Oppm. See Figure 9A.

Data presented in the Phase I SOU Report and subsequent sampling performed in 199S for
PCBs has established the current limits of the expected remedial response area. This area is
approximately 3,900 sq. ft. (0.1 acre) in size. The remedial response area was estimated
using the a cleanup goal of 10.0 ppm for total PCBs. RMI is currently conducting additional
delineation sampling. These results may alter die limits of die remedial response'area. During
the remedial design plume for the selected remedy, the data obtained from the RMI sampling
effort, and, if necessary, additional data win be reviewed to fully delineate die remedial
response area.
V. HUMAN HEALTH RISK ASSESSMENT

Because of the limited scope of the Source Control Operable Unit, a separate risk assessment
was not prepared for die areas to be addressed as part of this ROD. Fields Brook and its
associated floodplain and wetland areas are to be remediated in the Sediment and
Floodplains/Wetlands Area (FWA) OUs. The goal of the SCOU is to remediate source areas
that have the potential to cause sediment contamination to Fields Brook and its tributaries,
thereby preventing the reoontamination of areas that will be addressed by the Sediment and
FWA OUs. The Source Control action supports the Sediment and FWA remediations by
helping to ensure that human-health hasgd cleanup goals are maintained.

The Chemicals of Concern (COCs) for the Source Control OU include the COCs for both the
Sediment and FWA OUs. Chapter 3 of the SCFS Report discusses the development of the site
cleanup goals (CUGs). A complete list of COCs and CUGs for die SCOU is provided in
Table 1. These COCs include arsenic, benzo(a)-pyrene, beryllium, 1,1,2,2,-tetrachloroethane,
tetrachloroethene, trichloroethene, hexachloroethane, vinyl chloride, hexachlorobenzene,
hexachlorobutadiene. and PCBs. As part of the Recontamination Assessment (Chapter 6 of the
SCRI), source areas were evaluated to determine the extent that contaminant movement could

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cause a CUG exceedance in Brook sediment. Soil loss equations were used to determine the
extent of excavation and/or cover necessary to prevent recontamination of Fields Brook.
Unless otherwise agreed to by a facility, the remediation of source control areas will be limited
to the actions needed to prevent the recontamination of Fields Brook. The cleanups at the
source areas are not intended to fully remediate the facilities involved.
VI. ECOLOGICAL RISK ASSESSMENT

Because of the limited scope of the Source Control Operable Unit, a separate ecological risk
assessment was not prepared for the areas to be addressed as part of this ROD. Fields Brook
and its associated floodplain and wetland areas are to be rrmndiatprt in the Sediment and
Floodplains/Wetlands Area (FWA) OUs. The goal of the SCOU is to remediate source areas
that have the potential to cause sediment contamination to Fields Brook and its tributaries,
thereby preventing the recontamination of areas that will be addressed by the Sediment OU and
the FWA OU.

The areas to be addressed under this ROD are industrial properties. Within the Fields Brook
Superfund Site, the areas of most ecological interest and concern are the Brook and its
surrounding Floodplain/Wedand areas. By preventing the recontamination of the Sediment
and FWA OUs, die remediation of the source control areas will help to ensure that the CUGs
are mainjaingH Areas disturbed by the implementation of source control remedies will be
restored.
VOL SCOPE OF THE SELECTED REMEDIES

The purpose of this Record of Decision (ROD) is to select the final remedial actions for the
Fields Brook Site Source Control Operable Unit. In general, these final remedies contain or
remove the contaminated soils from the source areas through a combination of excavating with
backfilling and landfilling, or covering the contaminated soils. Excavated material containing
* SO ppm PCBs will be sent either to a TSCA-approved landfill off-site or will be placed in a
TSCA-approved landfill to be built on one of the industrial facilities within the Fields Brook
watershed. The on-site landfill discussed in the alternative description section (Section VIII,
is to be built pursuant to the ROD for the FWA OU (6730/97) and the Explanation of
Significant Differences (BSD) for the Sediment Operable Unit (8/15/97). It will be used to
house excavated material from the Sediment, FWA and Source Control Operable Units.
Remediation to be conducted as part of the Source Control Operable Unit will be limited to
areas that pose a threat of recontamination to the Brook.

The selected remedies do not include treatment of principle threat wastes in order to reduce
toxicity, mobility, or volume of the contamination. As discussed later in mis ROD, treatment
of soils is not warranted in part because areas of high-level PCB contamination are widely

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dispersed within areas of overall low average PCB concentrations. The treatment of soils
containing high concentrations of PCBs, such as at die Millennium source area, is not practical
because of the selective excavation and separation of soil that would be required. Treatment is
not necessary to comply with TSCA and does not provide additional risk reduction relative to
the additional expense. Treatment or recycling of the extracted DNAPL from the Detrex
facility will reduce the toxicity, mobility and volume of contaminants currently found in
groundwater at the source area. Additionally, treatment is a secondary element in mat leachate
liquids from the disposal of source area soils in the on-site landfill will be collected and treated
resulting in destruction of hazardous substances.
Vm. DESCRIPTION OF ALTERNATIVES

The Source Control FS identified and evaluated alternatives to address the potential for
contaminant movement to Fields Brook. For each source area, the FS evaluated a "No Action"
alternative to serve as a baseline from which to evaluate action alternatives. For some source
areas, the "No Action" alternative includes monitoring; for others, the "No Action" alternative
does not include monitoring. This is due to the assumptions made by the various contractors
involved in the preparation of die FS. Both approaches are acceptable and satisfy the NCP's
requirement mat a 'No Action* alternative be considered.

This Record of Decision is complex because the SCOU addresses six source areas. Full
descriptions of all alternatives would be excessively lengthy and further complicate this
document. Therefore, the alternatives presented hi this section of the ROD are summarized.
Full descriptions of the alternatives considered can be found in the Source Control FS. The
selected remedies are fully described in Section X.

A) Acme Scrap Iron & Metal

U.S. EPA evaluated the following alternatives to address contamination at die Acme facility:

1. ALTERNATIVE I: NO ACTION

Time To Complete: Monitoring could be initiated in 2 to 4 months.
Capital Cost- $ 19.000
First Year O&M: $ 12.000
30-Year Present Worth Cost $203,500

Alternative I would involve only monitoring, and die source areas at die Acme property
would remain in tiieir present condition. The monitoring would include sampling of
die outfall discharge to evaluate die amount of contamination moving off of die
property and into Fields Brook. This alternative serves as a baseline against which die
effectiveness of die other alternatives can be compared. The total. 30-year present

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worth cost of this alternative is estimated at $203,500.

2. ALTERNATIVE II: CONTAINMENT A

Time To Complete: 6 to 8 months
Capital Cost: $ 641,500
First Year O&M: $ 27,100
30-Year Present Worth Cost $ 1.058.100

Alternative n incudes the construction of a containment berm and surface drainage
controls. The contaminated soil woiild not be moved. Clay/soil containment berms
would be constructed where needed to control drainage. Berms would be constructed
of clay with a topsoil cover. The topsoil would be vegetated to provide protection from
erosion. The berm would be approximately 3 ft in height Vrith a 1.5:1 slope. This
results in a berm approximately 9 ft wide at its base. The top of the berm would be flat
so that the berm could be mowed.

Institutional controls would be implemented, as appropriate, to protect containment
berms and surface drainage controls. The controls may include deed restrictions,
security fencing, and signs. The total. 30-year present worm cost of Alternative n is
estimated at $1,058.100. This cost includes monitoring of the outfall discharge and
routine inspection and m«j«*»nMff» of the berms.
3. ALTERNATIVE HI: CONTAINMENT B

Time To Complete: 6 to 8 months
Capital Cost: $ 1,578,000
First Year O&M: $ 19,500
30-Year Present Worth Cost $1,877,800

Containment of surface soil would be provided through the installation of a 12-inch
erosion control cover over the area of contamination. The contaminated soil would not
be moved. The erosion control cover would be vegetated to reduce the potential for
erosion. Areas of regular vehicular traffic would be covered with 6 inches of gravel.
The area to be covered by the erosion control cover is estimated to be approximately
480,000 sq. ft. or 11.0 acres. Of this area, approximately 120.000 sq. ft. (2.8 acres)
would be covered with gravel and 360,000 sq. ft. (8.2 acres) would be covered with
soil.

Institutional controls would be implemented, as appropriate, to protect cover systems
and drainage controls, and may include deed restrictions, security fencing, and signs.
The total, 30-year present worth cost of Alternative in is estimated at $1 ,877,800.
This cost includes monitoring of the outfall discharge and routine inspection and

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maintenance of die erosion control cover.

4. ALTERNATIVE IV: CONSOLIDATION/CONTAINMENT

Time To Complete: 6 to 8 months
Capital Cost: $ 1.560.200
First Year O&M: S 19.500
30-Year Present Worth Cost $ 1.860.000

Alternative IV is similar to Alternative HI except that the soil from the source areas at
the Acme property would be consolidated prior to placement of the erosion control
COVer. ConSOJkhltion fff I*"*!?"*! ""iM TM"ce *** airfare area to ht- covered Since
the consolidation area would be at die Acme property, no soil would be removed from
the facility. The area to be excavated is approximately 1.2 acres, or 52,170 sq. ft.
This area would be excavated to a depth of 6 inches. The excavated areas would be
filled to grade with clean soil or gravel. After consolidation, die area to be covered
consists of approximately 7.6 acres or 332.000 sq. ft. Of die area to be covered.
88,400 sq.ft. (1.9 acres) would be covered with gravel, while 245,600 sq. ft. (5.6
acres) would be covered by a 12-inch soil erosion control cover. The design and
implementation of die cover would be die same as described for Alternative m.

Institutional controls would be implemented, as appropriate, to protect cover systems
and drainage controls, and may include deed restrictions, security fencing, and signs.
The total, 30-year present worm cost of Alternative IV is estimated at $1.860.000.
This cost includes monitoring of die outfall discharge and routine inspection and
maintenance of die erosion control cover.

5. ALTERNATIVE V: EXCAVATION/TREATMENT/DISPOSAL

Tune To Complete: 10 to 12 months
Capital Cost: $3.075.476
First Year O&M: $ 19.500
30-Year Present Worth Cost S 3,375.276

Alternative V has been developed to include excavation of surface soil in die source
areas, thermal treatment, and disposal. Soils with PCB concentrations greater man
500 pom would be excavated. The excavated soils would be diennally treated
(incinerated) at an off-site facility. Existing data for surface soils at die Acme facility
indicate that no PCB concentrations greater than 500 ppm were identified. However.
Alternative V includes an allowance for excavation, treatment, and disposal of 1.000
cubic yards of soil. The allowance assumes diat concentrations greater than 500 ppm
will be identified during sampling activities for die remedial design phase. However.
die excavation, treatment, and disposal would only be performed if future analytical

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results indicate PCB concentrations greater than 500 ppm.

The remaining areas of surface soil contamination would be contained in place on the
Acme property. The cover system, would be the same as those described in
Alternative ffl. Institutional controls would be implemented, as appropriate, to protect
cover systems and drainage controls. These controls may include deed restrictions.
security fencing, and signs. The total, 30-year present worm cost of Alternative V is
estimated at $3,375,276. This cost includes monitoring of the outfall discharge and
routine inspection and maintenance of the erosion control cover.

6. ALTERNATIVE VI: EXCAVATION/CONTAINMENT
(U.S. EPA's Selected Remedy)

Time To Complete: 10 to 12 months
Capital Cost $ 2,865,076
First Year OftM: $ 19,500
30- Year Present Worth Cost $3,164,876
,«
Alternative VI has been developed to include excavation of surface soil with PCB
concentrations greater than or equal to 50 ppm. Excavation would be conducted to a
depth of approximately 1 foot. The excavatkm to a 1-foot depth would result in an
estimated volume of 1,800 cubic yards. The excavated soils would be disposed at
either an on-she landfill (to be constructed at an industrial facility within die Fields
Brook watershed) or at an off-site TSCA-approved landfill. Following completion of
excavation activities, the excavated areas would be backfilled with clean soil and
graded to allow for adequate drainage.
The remaining surface soils nyf™*^ in the remedial response area would be contained
in place with a cover. Alternative VI would include the same cover, surface drainage
controls, institutional controls, chemical monitoring and maintenance activities as those
described for Alternatives m and V. The erosion control cover materials would
generally consist of a 12-inch thick layer of clean soil, an erosion control blanket and
would be vegetated to reduce the potential for erosion. For anticipated future traffic
areas, a 6-inch gravel layer underlain by geotextile would be used instead of the soil.

Institutional controls would be implemented to protect cover systems and drainage
controls. These controls would include, as appropriate, deed restrictions, security
fencing, and signs. The total 30-year present worm cost of Alternative VI is estimated
at $3,164,876. This cost includes monitoring of the outfall discharge and routine
inspection and maintenance of the cover system.
19

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B) Millennium Plant H, TiCl^ Facility

U.S. EPA evaluated die following alternatives to address contamination at the Millennium
facility:

1. ALTERNATIVE I: NO ACTION
Time To Complete:
Capital Cost: $ 0
First Year O&M: S. 0
30-Year Present Worth Cost'* 0

Alternative I is a no action alternative, which would allow she conditions to remain as they
currently exist. This alternative serves as a baseline for comparison with other alternatives
as required by the NCP. No reduction in the potential of recontamination of Fields Brook
sediments or reduction in contaminants transport to Fields Brook is associated with this
alternative. There is no cost associated with the no action alternative.

2. ALTERNATIVE Ifc DISPOSAL OF HIGHLY-CONTAMINATED SOIL /
EROSION CONTROL CAP COVER OF
REMAINING TSCA SOILS

Time To Complete: 6 to 8 months
Capital Cost: $ 4,018.200
First Year O&M: $ 81,000
30-Year Present Worth Cost $5,263.400

Alternative Q would require the excavation and disposal of highly contaminated soils and
the consolidation of the remaining TSCA-regulated material. Soils with concentrations
greater than 500 ppm PCBs would be disposed at an on-site landfill (to be constructed at
an industrial facility within the Fields Brook watershed) or at an off-she landfill which
complies with TSCA Soils with between 50 and 500 ppm PCBs would be excavated and
consolidated at the Mining Residuals Pile located on the Millennium property. A 12-inch
soil erosion control cover would then be placed on the consolidated pile. Other plant
areas would receive either sou\ gravel, or paved covers. This alternative would require the
temporary relocation of Fields Brook.

Deed restrictions would be established to limit the future use of the site and protect the
cover system and drainage controls. The existing she fence would be maintained.
Chemical monitoring of discharges from outfalls would be conducted to evaluate the
amount of contamination moving from the site to the Fields Brook. The 30-year present
worth cost to implement this alternative is estimated at $5,263,400. This cost includes
monitoring and routine inspection and maintenance of the cover system.

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3. ALTERNATIVE IDA: DISPOSAL OF HIGHLY-CONTAMINATED SOIL
/ ALTERNATIVE (VERSION A) RCRA COVER
OF REMAINING TSCA SOILS

Tune To Complete: • 12 to 16 months
Capital Cost: S4.786.SOO
First Year OftM: $ 81.000
30-Year Present Worth Cost $6.031.600

Alternative mA is similar to Alternative n, but includes a modified cover for the
consolidated material. This alternative includes the excavation of highly contaminated
soils (>500 ppm PCBs) with required disposal in a TSC A-approved fiualrty. This disposal
could be at an on-she landfill (to be constructed at an industrial facility within the Reids
Brook watershed) or at an off-she landfill which complies with TSC A, Soil containing
between 50 ppm and 500 ppm would be consolidated at the Mining Residual Pile which is
located on the Millennium property . The consolidated area would then be covered with
an alternate RCRA cover. The Version A cover would consists of (from bottom to top):

12 to 24 inches of consolidation soil;
20 mil flexible membrane finer (FML) over a geotextile;
Fabri-Net and infiltration collection;
12 inches of clean soil; and
Other plant areas would receive either soil, gravel, or paved covers. This alternative
would require the temporary relocation of Fields Brook. Deed restrictions would be
established to Bum the future use of the she and protect the cover system and drainage
controls. The existing she fence would be maintained. Chemical monitoring of discharges
from outfalls would be conducted to evaluate the amount of contamination moving from
the she to the Fields Brook. The 30-year present worth cost to implement this alternative
is estimated at $6,03 100. This cost includes monitoring and routine inspection and
maintenance of the cover system.

4. ALTERNATIVE DIB: DISPOSAL OF HIGHLY-CONTAMINATED SOIL
/ ALTERNATIVE (VERSION B) RCRA COVER
OF REMAINING TSCA SOILS

Time To Complete: 12 to 16 months
Capital Cost: $6,348,900
First Year O&M: $ 116.000
30-Year Present Worth Cost $8.132.000

Alternative DIB is similar to Alternatives O and IDA. Soils with concentrations greater

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than 500 ppm PCBs would be disposed at an on-she landfill (to be constructed at an
industrial faculty within the Fields Brook watershed) or at an off-site landfill which
complies with TSCA. Soils containing between SO ppm and 500 ppm would be
consolidated at the Mining Residual Pile located on the Millennium property. The
consolidated area would then be covered with Version B of an alternate RCRA cover
system. The cover would include (from bottom to top):

*• consolidation soil;
» 6 inches of dean soil;
*• 40 mil flexible membrane finer (FML) over a geotextile;
»• Fabri-Net and infiltration collection;
- 24 inches of dean ffi! soil;
*• 6 inches of dean topsofl; and
»• erosion blanket and vegetation.

Other plant areas would receive either soil, gravel, or paved covers. This alternative
would require the temporary relocation of Fields Brook. Deed restrictions would be
established to limit the future use of-the site and protect the cover system and drainage
controls. The existing the fence would be mahitamed Chemical monitoring of discharges
from outfalls would be conducted to evaluate the amount of contamination moving from
the she to the Fidda Brook. The 30-year present worth cost to implement this alternative
is estimated at $8,132,000. This cost includes monitoring and routine inspection and
maintenance of die cover system.

5. ALTERNATIVE IV: DISPOSAL OF HIGHLY-CONTAMINATED SOIL /
RCRA SUBTITLE C COVER OF REMAINING
TSCA SOILS

Time To Complete: .18 to 24 months
Capital Cost: ' $ 8,684,600
First Year O&M: $ 116,940
30-Year Present Worth Cost $10,483,000

Alternative IV is similar to Alternatives ILIIIA, and mB. Alternative IV would require
that PCB contaminated soils with concentrations greater than 500 ppm would be disposed
at an on-site landfill (to be constructed at an industrial facility within the Fields Brook
watershed) or at an off-site landfill which complies with TSCA. Soils containing between
50 ppm and 500 ppm would be consolidated at the Mining Residual Pile located on the
Millennium property. The consolidated area would then be covered with a RCRA Subtitle
C cover system. The Subtitle C cover system would include (from bottom to top):
22

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      12 to 24 inches of consolidation soil;
      geocomposhe clay liner, or equivalent;
      40milFML;
      Geonet or Fabri-Net with infiltration collection;
      48 inches of dean soil;
      6 inches of topsoil;
»     an erosion blanket; and
»     vegetation.

Other plant areas would receive either soil, gravel, or paved covers. Because of the
additional area required to accommodate die Subtitle C cover, it would be necessary to
permanently relocate Fields Brook to the northernmost portion of the Millennium
property. In addition, a futty-cncompaiiiOTg shiny wall would be constructed around the
capped area. Groundwater would be influenced using withdrawal weUs to promote flow
around the slurry watt, and leachate from within the shiny wall would be collected and
treated. Deed restrictions would be established to limit the future use of the she and
protect the cover system and drainage controls. The existing site fence would be
maintained. Chemical monitoring of .discharges from outfalls would be conducted to
evaluate the aiwm** of contamination moving from the she to the Fields Brook. The 30-
year present worth cost to implement this alternative is estimated at $10,483,000. This
cost includes monitoring and routine inspection and maintenance of the slurry wall and
cover system.

6.     ALTERNATIVE V:       EXCAVATION AND TREATMENT OF > 500
                                 PPM PCB SOILS

       Time To Complete:         24 to 36 months
       Capital Cost:               $ 8,966,100
       First Year O&M:           $    81,000
       30-Year Present  Worth Cost S 10,211,200
        •
Alternative V is the same as AK Amative II (temporary relocation of Fields Brook,
containment, placement of an erosion control cover, deed restrictions, monitoring and
routine maintenance), except that soils with greater than (>) 500 ppm of PCBs would
be excavated and thermally  treated (incinerated) off-site.  The costs to implement this
alternative are estimated at $10,211,200. This cost includes monitoring and routine
inspection and maintenance of the erosion control cover system.
                                   23

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7. ALTERNATIVE VI: EXCAVATION AND LANDFILL OF * 50 PPM
PCB SOILS
(U.S. EPA's Selected Remedy)

Time To Complete: 12 to 18 months
Capital Cost: $6,846,500
First Year O&M $ 43,000
30-Year Present Worth Cost $7,505,500

Under Alternative VI, soils with greater than or equal to (*) SO ppm of PCBs would be
excavated and disposed at an en-site landfill (to be constructed at an industrial facility
within the field* Brook watershed) or at an off-she landfill which complies with TSC A.
The remaining materials in the Mining Residuals Pile would be covered in-place with an
erosion control cover (12 inches of dean soil, an erosion blanket, and vegetation), similar
to Alternative n. Other plant areas would receive either soil, gravel, or paved covers.
This alternative would not require the temporary relocation of Fields Brook.
*• •
Deed restrictions would be established to limit the future use of the she and protect the
cover system and drainage controls. The existing she fence would be maintained.
Chemical monitoring of discharges from outfalls wotdd be conducted to evaluate the
amount of contamination moving from the site to the Fields Brook. The 30-year present
worth cost to implement this alternative is estimated at $7,505,500. This cost includes
monitoring and routine inspection and maintenance of the cover system.

Q Conrail

U.S. EPA evaluated the following alternatives to address contamination at the Conrail facility:

1. ALTERNATIVE I: NO ACTION

Time To Complete:
Capital Cost: $ 0
FirstYearO&M: $ 0
30-Year Present Worth Cost $ 0

The no action alternative would allow site conditions to remain as they currently exist.
The existing berm on the property would remain in place, as would site vegetation.
Evaluation of the no action alternative is required by the NCP and provides a baseline
for comparison with other alternatives. No capital or O&M costs are associated with
this alternative.
24

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2. ALTERNATIVE H: CONTAINMENT/FILTRATION BERM

Time To Complete: 6 to 8 months
Capital Cost: $ 13,500
First Year O&M: $ 4.400
30-Year Present Worth Cost $ 81,100

Alternative n consists of construction of surface drainage controls and berms to prevent
surface soils from entering Fields Brook. Arsenic-contaminated soil would remain in-
place. A gravel filtration berm would be built along the top of the north bank of Fields
Brook to allow for the surface wateolhat might be draining from die property to slowly
pass through die berm to Fields Brook white filtering sediment* that may be carried by
die surface flow. By slowing runoff from the site, tiiis alternative also promotes
infiltration of surface water, thereby reducing runoff and sediment transport to Fields
Brook. The berm would be constructed along die north bank of Fields Brook from the
Ashtabula River to just beyond die former compressor building, approximately 1,100ft
in total length. This alternative does not include any action to be taken on die slope of
die norm bank of Fields Brook, which is relatively steep and currently vegetated with
trees and plants.

Access to the site would be restricted by the constructkmof a fence across the entrance
of the limited access bridge. Institutional controls would limit die future use of die site
to protect die berms and drainage controls. The **#F*P**30-year, net present worm
cost for this alternative is $81,100. This cost includes die monitoring of surface soil
arsenic levels and routine inspection and maintenance of berms and other drainage
control TyiffflfflircSj.

3. ALTERNATIVE HI: CONTAINMENT/GRAVEL EROSION CONTROL
COVER

Time To Complete: 6 to 8 ninths
Capital Cost: $ 12,000
First Year O&M: $ 5,500
30-Year Present Worth Cost $96,500

Alternative in consists of covering a portion of die area of the site that is in die
watershed, and controlling drainage to prevent surface soils from entering Fields
Brook. Contaminated soil would remain in-place and would be covered with 6 inches
of gravel and sloped at a 2 percent grade towards Fields Brook in order to reduce the
potential for erosion and sediment transport. The gravel covered area, approximately
60 feet east of die former compressor building and extending to die eastern limits of the
property adjacent to Fields Brook, would not be covered. Also, die north bank of
Fields Brook would not be covered since covering the bank in this manner would not

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be possible without extensive excavation or installing an engineered slope protection.

A fence would be placed across the entrance of the limited access bridge across Fields
Brook in such a manner as to prevent unauthorized entry, instjtutio11*! controls would
limit the future use of the site to protect the cover system and drainage controls. The
estimated 30-yr, net, present worm, total cost for this alternative is $96,500. This cost
includes the monitoring of surface soil arsenic levels and routine inspection and
maintenance of the gravel cover and other drainage control measures.
«
4. ALTERNATIVE IV: SOIL.EXCAVATION / CONSOLIDATION /
CONTAINMENT
(U.S. EPA's Selected Remedy)

Time To Complete: 6 to 8 months 4
Capital Cost: $ 19,500
First Year O&M: $ 5,500
30-Year Present Worth Cost $ 104,000

Alternative IV includes the excavation, consolidation, and containment of surface soils
in a disposal cell located on the Conrail property. All existing vegetation in the "flat
area" and along bank slopes to Fields Brook in the areas of interest would be removed.
The soils would men be excavated to a depth of approximately 6 inches. Excavated
soils (approximately 90 cu yds) would be moved to a consolidation area at a higher
elevation along, the bank for final disposal on the Conrail property. Upon placement of
excavated soils, this area would be graded and covered with 6 inches of gravel to
prevent soil erosion. Erosion control measures would be placed on the bank, where
sary, to minim,fae erosion.
A fence, would be placed across die entrance of the limited access bridge across Fields
Brook in such a manner as to prevent unauthorized entry. Institutional controls would
limit the future use of the site to protect the cover system and drainage controls. The
estimated 30-year, net present worth, total cost for this alternative is $104,000. This
cost includes the monitoring of surface scil arsenic levels and routine inspection and
maintenance of the gravel cover and other drainage control measures.

5. ALTERNATIVE V: SOIL EXCAVATION/DISPOSAL

Time To Complete: 6 to 8 months
Capital Cost: $173.100
First Year O&M: $ 0
30-Year Present Worth Cost $173,100

Alternative V involves the excavation, transport and landfill disposal of excavated soils.

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This alternative consists of removing all existing vegetation from the area to be
remediated and excavating approximately 6 inches of soil from the area. Excavated
soils would be transported to the landfill that is to be built at one of the industrial
facilities within the Fields Brook watershed.
The «eriprorte^ vohime of soil to be removed in mis alternative is approximately 310 cu
yds. The *«»*««••*«• 30-yr, net present worth, total cost for mis alternative is $173,100.
Because the arsenic contamination would be removed from the area, mis alternative
would not require deed restrictions, routine maintenance or chemical monitoring.

D) Detrex Corporation

U.S. EPA evaluated the following alternatives to address soil and groundwater contamination
at the Detrex facility:

1. ALTERNATIVE I: NO ACTION
\

Tune To Complete: , Monitoring could be initiated in 2 to 4 months.
Capital Cost: $ 0
FirstYearOftM $ 21,200
30-Year Present Worth Cost $325,900 .

Alternative I involves performing only long-term monitoring at the Detrex property.
The groundwater would be monitored to track the DNAPL and contaminant
concentrations. The stormwater outfall would be sampled to evaluate the amount of
contamination moving off the property and into Fields Brook. This alternative is
required by the NCP for consideration and serves as a baseline against which the
effectiveness of the other alternatives can be compared. The 30-year present worth
total cost of mis alternative is estimated at $325,900.

2. ALTERNATIVE HA: CONTAINMENT/ SH \LLOW COLLECTION
TRENCH/ TREATMENT

Tune To Complete: Less than 1 year
Capital Cost: $ 2,065,602
First Year O&M. $ 41,300
30-Year Present Worth Cost $2,700,502

This alternative would contain the entire DNAPL plume and prevent recontamination of
the DS Tributary and Fields Brook sediment from either DNAPL or dissolved phase
DNAPL constituents. A slurry wall would be constructed to cut off DNAPL migration
towards Fields Brook and the DS Tributary. The slurry wall would completely encircle
the DNAPL plume and extend beyond the limits of DNAPL to contain dissolved phase

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constituents. Shallow dewatering trenches would be installed within the on-site area
encompassed by the shiny wall to maintain a consistent shallow water table elevation
below ground surface and to keep an inward gradient across die shiny wall.  Extracted
groundwater would be treated by Detrex's existing stormwater treatment system that
uses carbon filtration to remove contaminants from collected surface water.

Low-lying areas within the existing collection system area and areas with surface soil
cleanup goal f7Mff*|*iir*'iy would be filled and regraded. These areas would men be
covered iit-place with a 12-inch thick soil layer, an erosion control blanket, and a
vegetative or crushed stone layer surface.'

Routine groundwater monitoring would evaluate the level of DNAPL, VOC and SVOC
contamination.  ID addition, water level data would be collected to evaluate
groundwater flows within the remedial response area.  The stormwater outfall would be
sampled to evaluate the movement of contamination from the site. The existing site
fence would be maintained.  Deed restrictions would be implemented to restrict the
future use of the site to protect the cover system, slurry wall, dewatering trenches,
drainage controls, and monitoring wells. The total 30-year present worth cost of this
alternative is *****i* at $ 2,700,502.  This cost includes the monitoring and routine
inspection and maintenance of the shiny wall, dewatering trenches, cover systems and
Detrex's carbon treatment facility.

3.     ALTERNATIVE OB:  CONTAINMENT / DNAPL COLLECTION
       TRENCH/ TREATMENT

       Time To Complete:         Less than 1 year
       Capital Cost:               $ 5,489.412
       First Year OftM.           $    80,200
       30-Year Present Worth Cost $6.722,312

 Alternative HE varies from Alternative DA in that the trenches would be deeper to
 promote DNAPL collection. Groundwater and DNAPL collection trenches would be
 installed within the slurry wall  area.  The trenches would be located near or at the
 leading edge of the DNAPL plume.  The trenches would be installed to maintain a
 consistent shallow water table elevation below ground surface, to collect and remove
 DNAPL, and to keep an inward groundwater gradient in the area of DNAPL.  The
 trenches would be approximately 25-feet deep and would have a length of
 approximately 2,300 ft. The collection trenches would be equipped with submersible
 pumps that would transfer DNAPL and groundwater to a separation unit.  Extracted
 DNAPL would be treated or recycled at an off-site facility.

 Low-lying areas within the existing collection system area and areas with surface soil
 cleanup goal exceedances would be filled and regraded.  These areas would then be

                                   28

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covered in-place with a 12-inch thick soil layer, an erosion control blanket, and a
vegetative or crushed stone layer surface.

Routine groundwater monitoring would evaluate the level of DNAPL, VOC and SVOC
contamination. In addition, water level data would be collected to evaluate
groundwater flows within the t**«*«ifoi response area. The stormwater outfall would be
sampled to evaluate the movement of contamination from the site. The existing site
fence would be maintained. Deed restrictions would be implemented to restrict the
future use of the site to protect the cover system, shiny wall, dewatering trenches.
drainage controls, and monitoring wells. The total 30-year present worth cost of this
alternative is ?yf««"yft«* at $ 6,722,312. This cost includes the monitoring and routine
inspection and maintenance of the slurry wall, dewatering trenches, cover systems and
Detrex's carbon treatment facility.

4. ALTERNATIVE ffl: HYDRAULIC CONTAINMENT / DNAPL
COLLECTION WELLS / TREATMENT

Tune To Complete: - Less than 1 year
Capital Cost: $1,615.440
First Year O&M $ 245.600
30-Year Present Worth Cost $5,390,940

This alternative would hydraulically contain the DNAPL plume and prevent
recontamination of the DS Tributary and Fields Brook sediment by reversing the
direction of groundwater flow and recovering mobile DNAPL. Vacuum-enhanced
extraction wells would be used to remove DNAPL constituents. Based on a pilot study
conducted in January 1997, it is ^rtin^M that approximately 60 wells would be
installed to collect groundwater and DNAPL. Extracted groundwater would be treated
by Detrex's existing stormwater treatment system that uses carbon filtration to remove
contaminants from collected surface water. Extracted DNAPL would be treated or
recycled at an off-site facility.

Low-lying areas within the existing collection system area and areas with surface soil
cleanup goal exceedtnces would be filled and regraded. These areas would then be
covered in-place with a 12-inch thick soil layer, an erosion control blanket, and a
vegetative or crushed stone layer surface.

Routine groundwater monitoring would evaluate die level of DNAPL, VOC and SVOC
contamination. In addition, water level data would be collected to evaluate
groundwater flows within the remedial response area. The stormwater outfall would be
sampled to evaluate the movement of contamination from the site. The existing site
fence would be maintained. Deed restrictions would be implemented to restrict the
future use of the site to protect the cover system, drainage controls, and extraction and

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monitoring wells. Total 30-year present worth cost of this alternative is estimated at
$5,390,940. This cost includes the monitoring and routine inspection and maintenance
of extraction wells, dewatering trenches, cover systems and Detrex's carbon treatment
facility.

5. ALTERNATIVE IV: DOWNGRADIENT CONTAINMENT / DNAPL
COLLECTION WELLS / TREATMENT
(U.S. EPA's Selected Remedy)'

Time To Complete: Approx. 1 year
Capital Cost: '$1,890,776
First Year OftM: $ 211,600
30-Year Present Worth Cost $5,143,576

This alternative is a combination of Alternatives n and m with the exclusion of the on-
site shallow dewatering trenches included under Alternative 0. The shallow dewatering
trenches would not be required in this alternative because vacuum-enhanced extraction
wells installed inside the shiny wail would lower the water table inside the slurry wall
and reverse the flow of groundwater away from the shiny wall. The slurry wall
component would extend beyond the edge of the downgradient portion of die DNAPL
plume to ensure that the DNAPL and contaminated groundwater flowing towards
Fields Brook or the DS Tributary would be contained or captured. The wall is
expected to be approximately 1,500 feet; however, this length may increase depending
on the results of design investigations. Vacuum-enhanced extraction wells would be
installed near the leading edge of the DNAPL plume near the shiny wall and within the
plume to lower the groundwater table and collect DNAPL. Based on pilot test results,
approximately 40 extraction wells are anticipated. Extracted groundwater would be
treated by Detrex's existing stormwater treatment system that uses carbon filtration to
remove contaminants from collected surface water. Extracted DNAPL would be
treated or recycled at an off-site facility.

Low-lying areas within the existing collection system area and areas with surface soil
cleanup goal exceedances would be filled and regraded. These areas would then be
covered in-place with a 12-inch thick soil layer, an erosion control blanket, and a
vegetative or crushed stone layer surface.

Routine groundwater monitoring would evaluate the level of DNAPL, VOC and SVOC
contamination. In addition, water level data would be collected to evaluate
groundwater flows within the remedial response area. The stormwater outfall would be
sampled to evaluate the movement of contamination from the site. The existing site
fence would be maintained. Deed restrictions would be implemented to restrict the
future use of the site to protect the cover system, drainage controls, slurry wall, and
extraction and monitoring wells. Total 30-year present worth cost of this alternative is

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lated at $5,143,576. This cost includes die monitoring and routine inspection and
maintenance of the shiny wall, extraction wells, cover systems and Detrcx's carbon
facility.
E) Sewers North and South of Fields Brook

The U.S. EPA evaluated die following alternatives to address contamination in die north and
south sewers:

1. ALTERNATIVE I: NO ACTION
4
Time To Complete: - '• -
Capital Cost: $0
first YearO&M: $0
30-Year Present Worth Cost $0

Alternative I is a no action alternative, which would-allow sewer conditions to remain as
they currently exist. This alternative-serves as a baseline for comparison .with other
alternatives as required by the NCP. No reduction in the potential of recontammation of
Fields Brook sediments or reduction in contaminants transported to Fields Brook is
"•*» t**** *H**MtJvn Them ia nft cent aaanriateH with the nft action alternative
2. ALTERNATIVE II; SEDIMENT REMOVAL

Time To Complete: Less than 4 months
Capital Cost: $ 399,900 for sewers north $ 228,500 for sewers south
First Year O&M $ 0 for sewers north $ 0 for sewers south
30-Year Present Worth Cost S 399,900 for sewers north $ 228,500 for sewers south

This alternative involves die removal of sediment and debris from inside die sewer lines
and die associated catch basins to reduce die potential of rcyontamination of die Fields
Brook sediments. The sewers would continue to be used after remedial activities are
completed. Sediment removal could be accomplished by cleaning die inside of die
sewers using manual and mechanical techniques to remove sediment, followed by
rinsing. Major blockages may exist ttiat prevent die cleaning equipment from
traversing die entire line. In this case, die blockages would need to be manually
removed or, if necessary, die sewers repaired in order to successfully clean die entire
line.

All sediments and debris removed by die sewer cleaning would be staged in stockpile
areas located near access at one end of die sewer. Solids collected during the
dewatering process should be characterized and disposed properly in either an off-site
landfill or hi the on-site landfill to be built in die Fields Brook watershed. The type of

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off-site landfill (whether solid waste, RCRA, or TSCA) would depend on the chemical
characteristics of the material. The 30-yr, present worth, total cost of Alternative II is
at $399,900 for the sewers north of Fields Brook and $228,500 for the
sewers south of Reids Brook.

3. ALTERNATIVE HI: SEDIMENT CONTAINMENT/REMOVAL
(U.S. EPA's Selected Remedy)

Time To Complete: Less than a year
Capital Cost: $ 285,700 for sewers north $ 324,000 for sewers south
First Year O&M: $ 0 for sewers north $ 0 for sewers south
30- Year Present Worth Cost $ 285,700 for sewers north $ 324,000 for sewers south

This alternative is similar to Alternative n, except that portions of sewers that are blocked
and difficult to dean would be dosed off, and the sediment within the sewers contained.
These containment areas would include a section of the 48-in. diameter combined sewer
north of Fields Brook and a section of the 30-inch sewer on the Acme site. The sediments
in these sewer segments would be contained by filling the sewer pipe with a cement grout
to restrict flow in the sewer and prevent migration of sediments into Fields Brook.

Replacement sewers would be constructed to divert water from the sections that have
been dosed and to connect the remaining sections of the sewers that have been cleaned.
These sewers would continue to be used after remedial activities are completed. The total
cost of Alternative ffl is estimated at $285.700 for the sewers north of Fidds Brook and
$324,000 for the sewers south of Fidds Brook.

F) RMI Metals Reduction

The U.S. EPA evaluated the following alternatives to address contamination at RMI Metals:

1. ALTERNATIVE I: NO ACTION

Time To Complete: Monitoring could be implemented in 2 to 4 months
Capital Cost: $ 1,900
First Year O&M: $ 2,000
30-Year Present Worth Cost $32,600

Alternative I would involve only monitoring, and the source area at the RMI Metals
property would remain in its present condition. As part of this alternative, a section of
Fidds Brook immediately downgradient of the remedial response area would be
monitored to assess the extent of contaminant migration from the area. This alternative
serves as a basefine against which the effectiveness of the other alternatives can be
compared. Because this alternative includes only chemical monitoring, the total, 30-year

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present worth cost of this alternative is estimated at $32,600.

2. ALTERNATIVE II: CONTAINMENT

Tune To Complete: ' 6 to 8 months
Capital Cost: $ 19,200
First Year O&M: - $ 6,500
30-Year Present Worth Cost $ 1 19, 100

Alternative n includes the construction of an erosion control cover and the use of
surface drainage controls to prevent recontamination of Fields Brook sediment.
Contaminated soils would remain in place. The erosion control cover would consist of
a 12-inch thick layer of clean soil, an erosion control blanket and would be vegetated to
reduce erosion and other effects of weather. The existing facility fencing would be
tn pnwt* ntiaiithfiriw^ gntty tn thft nsffms* area Deed restrictions WOUld
be established to restrict future uses of die site and protect the cover system and
drainage controls. The total, 30-year present worth cost of Alternative n is estimated
at $119,100. This cost includes surface soil monitoring and die routine inspection and
maintenance of the cover system.

3. ALTERNATIVE HI: EXCAVATION/DISPOSAL/CONTAINMENT

Time To Complete: 10 to 12 months
Capital Cost: $ 58,680
First Year O&M: $ 6,500
30-Year Present Worth Cost $158,580

Alternative m has been developed to include partial excavation of surface soil in the
source area and disposal, and containment The excavation would be limited to surface
soils with PCB concentrations greater than or equal to 50 ppm. The excavated soils
would be disposed at either an on-site landfill (to be constructed at an industrial facility
within the Fields Brook watershed) or at an off-site landfill which complies with TSCA,
whichever is more cost effective. The remaining surface soils included in the remedial
response area (soils with PCB concentrations greater than 10 ppm) would be contained in
place with a cover consisting of a 12-inch thick layer of clean soil, and an erosion control
blanket The cover would be vegetated to reduce erosion and other effects of weather.
The *"*'**'Tifl facility fencing would be maintained to prevent mvnithorfecd entry to the
response area. Deed restrictions would be established to restrict future uses of the site
and protect the cover system and drainage controls. The total, 30-year present worth cost
of Alternative in is estimated at $158,580. This cost includes surface soil monitoring and
the routine inspection and maintenance of the cover system.
33

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4. ALTERNATIVE IV: EXCAVATION AND DISPOSAL
(U.S. EPA's Selected Remedy)

Tune To Complete: 10 to 12 months
Capital Cost: $ 101,530
First Year O&M: $ 0
30-Year Present Worth Cost $101,530

Alternative IV has been developed to include the excavation and disposal of contaminated
surface soil. The excavated materials would be limited to surface soils withPCB
concentrations greater than 10 ppm. *The excavation would be backfilled and graded to
meet existing, surrounding surface contours. The excavated soils would be disposed at
either an on-she landfill (to be constructed at an industrial facility within the Fields Brook
watershed) or at an off-site landfill which complies with TSCA, whichever is more cost
effective. Alternative IV would not require any erosion control cover, surface drainage
controls, deed restrictions or maintenance activities. The total, 30-year present worth cost
of Alternative TV is estimated at $101.530.
DC. SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES

The National Contingency Plan (NCP) requires mat the alternatives be evaluated on the basis
of the following nine evaluation criteria: (1) Overall protection of human health and the
environment; (2) Compliance with applicable or relevant and appropriate requirements
(ARARs); (3) Long-term effectiveness and permanence; (4) Reduction of toxicity, mobility, or
volume through treatment; (5) Short-term effectiveness; (6) Implementability; (7) Cost; (8)
State acceptance; and (9) Community acceptance. This section compares the alternatives for
each of the six source areas with regard to these nine evaluation criteria.

A) Acme Scrap Iron and Metal

1. THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVIRONMENT AND COMPLIANCE WITH
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS):

Overall protectiveness for the alternatives associated with the Fields Brook Source
Control Operable Unit is measured by the protectiveness at preventing recontamination
of Fields Brook sediment. Alternative I, the No Action Alternative, would result in
unacceptable risks to human health and the environment under current conditions. This
alternative would allow the potential flow of PCBs to Fields Brook. However, the
monitoring to be performed as part of Alternative I would provide data regarding the
protectiveness of this alternative.

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Alternatives n, ffl, IV, V. VI have been developed to protect human health and the
environment by preventing recontamination of Fields Brook sediment. Soil cover
technologies of up to 12-inch thickness, would be most suitable for areas with relatively
low levels of contamination, and would provide a potentially less protective remedy for
areas with elevated levels of contamination, in part because of the uncertainty
associated with the possible surfacing of chemicals of concern over time.

Alternatives n, m, and IV would leave contaminated soil in place and construct a
cover over the area to reduce runoff and erosion of contaminated material. Alternative
IV would consolidate material before placing the cover to reduce the area requiring
long-term maintenance. These alternatives would not provide sufficient containment
for soils with elevated levels of PCB contamination (* SO ppm total PCBs) and, thus,
would not comply with TSCA.

Alternative V would excavate all material > 500 ppm for off-site treatment and
disposal. The remaining soils would be covered in place. This alternative would not
properly contain soils with PCB concentrations 2 SO ppm and would therefore not
comply with TSCA. .•

Alternative VI, die selected alternative, requires excavation and disposal of soils with *
SO ppm PCBs. Remaining contammatrd soils would be contained in place. This
alternative meets the requirements of TSCA by properly «*!«pn«'"g of TSCA-regulated
contaminated sofls. The cover for the remaining contaminated soils would protect
human health and the environment by reducing the movement of contamination to
Fields Brook.

The ARARs for die remedial actions considered for the Acme source area are indicated
in Table 2.

2. PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOXICITY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENTABILITY; AND COST.

All action alternatives would exhibit long-term effectiveness and perm
characteristics, as long as they were maintained. Soil cover technologies of up
to 12-inch thrJmrats would be most suitable for areas with relatively low levels
of contamination, and would provide a potentially less protective, long-term
effective and permanent remedy for areas with elevated levels of contamination,
in part because of the uncertainty associated with the possible surfacing of
chemicals of concern over time. All alternatives require O&M.

Implementation of Alternative V would result in the reduction of toxkity, mobility, and

-------
volume of contaminants in soil with PCB concentrations greater than 500 ppm.
'Treatment is a secondary element in Alternative VI in that landfill leachate liquids
would be collected and treated resulting in destruction of hazardous substances. Thus,
if contaminated i"Biidff teach from the landfilled materials, ftics* liquids would be
collected and treated. Alternative IV includes consolidation of source areas which
would result in the reduction of the area! extent of source areas requiring long-term
management. The excavated areas in Alternative V and VI would also reduce long-term
management requirements. None of the alternatives except Alternative V include
treatment of principle threat wastes in order to reduce toxkity, mobility, or volume of
the contamination. Principle threat wastes generally include wastes with concentrations
greater man a 1CT* cancer risk at a site, and there are no principle threat concentrations
of contaminants mriioittil in any location on the Acme properly with greater than a 10"*
cancer risk. The soils to be contained in place have a low average concentration of
between 10-40 ppm total PCBs. and the soils to be excavated under alternatives V and
VI have a low average concentration of between 50-70 ppm total PCBs. Thus, for
these reasons treatment would not be required.

No significant short-term problems 'are expected during construction or soon after
construction of Alternatives D dirough VI. Alternatives n, and m, are effective in the
short-term because they involve minimal disturbance to the source areas. The
excavation and consolidation portions of Alternative IV and the excavation and disposal
portions of Alternative V and VI present risk of paiticulate emission, thereby creating
exposure pathways to workers and community residents. Standard dust control
methods would be required during remedial action to reduce mis risk. Alternatives II
through VI also impact the property operations in the short-term. All alternatives,
except for Alternative I, will require worker protection during remediation.
Implementation of Alternative I is expected to take 2 to 4 months. Alternatives n
through IV are expected to take 6 to 8 months to implement. Implementation of
Alternatives V and VI are estimated to take about 10 to 12 months. The alternatives
may require coordination with the schedule for the construction of the en-site landfill.

No significant implementability problems which would prevent construction of the
remedy are expected during construction or soon after construction of Alternatives II
through VI. Alternative I would be the easiest to implement since only monitoring
would be included. Alternatives n dirough VI include construction of a containment
berm or soil/clay cover. Construction of the berm or cover would have material
handling requirements. The materials, services, equipment, and specialists required for
the construction are readily available. The equipment and specialists required for the
excavation portion of Alternatives IV, V, and VI also are readily available. The berm
and cover could be expanded or enlarged easily, if needed. Periodic inspection and
maintenance of the berm or cover would provide reliability in the future.

Implementation of Alternatives n through VI would interfere with the normal

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     operations at the Acme facility. Alternatives IV, V, and VI would cause the most
     interference with facility operations due to soil excavation.

     The estimated cost for each alternative is divided into capital costs and annual O&M
     costs.  The total cost for each alternative is then compute using an annual interest rate
     of 5% for a period of 30 years. The costs presented in this document are expected to
     range within +50% and -30% in accordance with the U.S. EPA guidance. Alternative
     V is the most expensive remedial alternatives, followed in order by Alternative VI, ffl,
     IV. Alternative H, and Alternative I.

     3.    MODIFYING CRTTERIAi'STATE AGENCY ACCEPTANCE;
           COMMUNITY ACCEPTANCE.

     The State of Ohio did not concur with the remedies selected for the Floodplain/Wetland
     and Sediment Operable Units of the Fields Brook site.  Because the Source Control
     Operable Unit supports the remedies selected for the Floodplain/Wetland and Sediment
     Operable Units, the OEPA has provided notice of its nonconcurrence with the remedies
     selected in this Record of Decision:'

     U.S. EPA provided a public comment period on the Source Control Proposed Plan and
     conducted a public meeting on the Source Control Proposed Plan on July 31.1997 in
     Ashtabula. The public comment period was originally scheduled from July 24 to
     August 22,1997. The public comment period was extended to September IS, 1997 in
     response to a request from the public. After a follow-up request for more time to
     submit comments regarding the Acme property, the comment period was again
     extended.  The comment period closed on September 22, 1997.

     U.S. EPA received one oral comment at the public meeting in support of U.S. EPA's
     proposed cleanups.  Eleven written sets of comment were received during the comment
     period, including comments from natural resource trustees, PRPs and their agents, and
     concerned citizens.  All comments were carefully reviewed and considered by U.S.
     EPA prior to finalization of this Record of Decision.  U.S. EPA's response to the
      public comments received are summarized in the attached Responsiveness Summary,
      which is Attachment 1 of this Record of Decision.

B) Millennium Plant H, TiCl, Facility

      1)    THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
            HEALTH AND THE ENVIRONMENT AND COMPLIANCE WITH
            APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
            (ARARS):

      Overall protectiveness for the alternatives associated with the Fields Brook Source

                                       37

-------
Control Operable Unit is measured by the protectiveness at preventing recontamination
of Fields Brook wdinK** All alternatives, except for the no action alternative, would
be protective of human health and the environment by preventing the recontamination
of Fields Brook •*A\m***l and also by preventing direct exposures to elevated levels of
soil contamination. O&M will be an integral part of any selected alternative in order to
ensure long-term protection of hi"***" health and the environment. Alternatives nt
OLA, and V may not be protective because they include either a cover alternative
involving 12 inches of soil cover, or a 12-inch soil cover with a liner over the total
PCB contaminated materials between 50-500 ppm. These alternatives may result in
unacceptable risks to hitmana in the event ***•*• the higher concentration contaminants
potentially reach the cover surfaces over time and release to Fields Brook. Alternatives
ITIB and IV would be more protective than Alternatives n and IDA, because these
alternatives offer thicker covers (i.e.. Alternative IHB involves use of a 30-inch soil
cover with a geomembrane liner, and Alternative IV involves the use of a 48-inch soil
cover with a geomembrane liner).

Alternatives n, mA and V are expected to comply with all ARARs and TBC
recommendations, except that Alternatives n, mA and V would not provide an
equivalent level of protection as a disposal which complies with TSCA 761.60 and
761.75. Although U.S. EPA has the option to waive TSCA requirements if there is
•no unreasonable risk" to human health and the environment, the U.S. EPA does not
believe that a 12-inch soil cover would provide sufficient protection over the long term
for the levels of PCB contamination in the Millennium soils. Alternative mB is also
expected to comply with all ARARs and TBC recommendations, except that Alternative
IIIB would require a waiver under TSCA for the implementation of the specified cover
system. Alternative IV is expected to comply with all ARARs and TBC
recommendations, including TSCA. The Region V TSCA office has determined that.
in general, the combination of a Subtitle C cover system and a fully encompassing
slurry wall could meet the disposal requirements of TSCA. Alternative VI would offer
an equivalent lev•.•'• of protection as disposal that complies with TSCA 761.60 and
761.75. Consolidation does not trigger any additional ARARs.

The ARARs for the remedial actions considered for the Millennium source area are
indicated in Table 2.

2) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOXICITY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENTABILITY; AND COST.

An alternatives, except for the no action alternative, would be effective in the long-term
and would be permanent, as long as they are maintained. However, Alternatives II, IIIA,
and V involve the use of a 12-inch thick soil cover which would provide a potentially less

-------
long-term effective and permanent remedy than alternatives ITJB, IV, and VI, because of
the uncertainty ym^Btf** with the possible sur&cing of chemicals of concern over time
from the areas with elevated levels of PCB contamination.

Alternatives n, mA, IHB, and IV all should have long-term effectiveness and permanence,
but each leaves in place a largo volume of contaminated material. Alternative V requires
off-site thermal treatment of soils with greater than 500 ppm, but u otherwise comparable
to Aherrotivenmk»g-tenne£fe(^rveneM and permanence. Alternative VI provides the
best long term effectiveness and permanence in terms of preventing recontamination of
Fields Brook, because higher concentration PCB materials are removed from the site.

Alternatives n, mA, fflB, and IV do not reduce toxicity, mobility , or vohime throu^j
treatment. Alternative V reduces the toxicity, mobility, and volume of hazardous
in i imnn ipwtfry nf •"** (2,1
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the time necessary for implementatioa
Alternative I would be the easiest to implement because no action is required. Alternative
n is relatively easy to implement and can be installed in a short time frame. Alternatives
niA, IDS, and IV win be more difficult to implement due to the complexity of the cover
system components. Also, Alternative IV may be difficult to implement because the
Mining RipukhmH Pfle is not conducive to excessive grading, compaction, or the added
weight of a 7-foot thick cap, and may be thus subject to liquefaction. Alternative V would
be more difficult to implement due to scheduling and the time and personnel commitment
for excavation, transportation, and treatment. Alternative VI may be more difficult to
implement than Alternative n, becausdt although it involves the installation of a relatively
simple cover system, it also requires a time and personnel commitment for excavation,
transportation, and landfilling. AD alternatives other than no action may encounter
difficulties during implementation due to the dose proximity of contaminated soils to the
floodplain and Fields Brook, the relatively steep northern slope between the Mining
Residuals Pile and Fields Brook, and due to the ongoing business operations at the facility.
In addition, construction activities for Alternatives n through VI may cause dust to be
released to the atmosphere, thereby..creating exposure pathways to workers and
community residents. Standard dust control methods would be required during
remedial action to reduce mis risk. Alternatives n through V also impact the property
operations in die short-term. All alternatives, except for Alternative I, will require
worker protection during remediatkm;

The costs to implement the alternatives are:
ALTERNATIVE
I
n
IIIA
DIB
IV
V
. VI
30-YEAR PRESENT
WORTH COST
$0
$5,263.400
$6.031.600
$8.132.000
$10.483.000
$10.211.200
S7.S05.500
Alternatives n through VI will all prevent recontamination of Fields Brook by preventing
erosion of soils containing PCBs above the CUG. Alternatives IDA, HIE, and IV are
more expensive due to engineered barriers to prevent infiltration. Alternative V is more
expensive than Alternative n (to which it is substantivdy similar), because highly-
40
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contaminated soils (> 500 ppm PCBs) would be thermally treated instead of being placed
in a landfill. Alternative VI is more expensive than Alternatives n and fflA, yet less
expensive than Alternatives IJJB, IV, and V. Alternative VI provides the greatest benefit
for the cost, as materials greater than SO ppm would be excavated from the site and
disposed at an on-she or off-site landfill which complies with TSCA.

3) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;
COMMUNITY ACCEPTANCE.

The State of Ohio did not concur with the remedies selected for the Floodplain/Wetland
and Sediment Operable Units of the Fields Brook site. Because the Source Control
Operable Unit supports die rcntffffcy selected for the Floodplain/Wetland and Sediment
Operable Units, die OEPA has provided notice of its wnconcurrence with the remedies
selected in this Record of Decision.

U.S. EPA provided a public comment period on die Source Control Proposed Plan and
conducted a public meeting on die Source Control Proposed Plan on July 31, 1997 in
Ashtabula. The public comment period was originally scheduled from July 24 to
August 22, 1997. The public comment period was extended to September IS, 1997 in
response to a request from die public. After a follow-up request for more time to
submit comments regarding die Acme property, die comment period was again
extended. The comment period closed on September 22, 1997.

U.S. EPA received one oral comment at die public meeting in support of U.S. EPA's
proposed cleanups. Eleven written sets of comments were received during die
comment period, including comments from natural resource trustees, PRPs and their
agents, and concerned citizens. All comments were carefully reviewed and considered
by U.S. EPA prior to finalization of tiiis Record of Decision. U.S. EPA's response to
die public comments received are summarized in die attached Responsiveness
Summary, which is Attachment 1 of this Record of Decision.
QConrail
1) THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVIRONMENT AND COMPLIANCE WITH
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS):

Overall protectiveness for die alternatives associated with die Fields Brook Source
Control Operable Unit is measured by die protectiveness at preventing recontamination
of Fields Brook sediment. Alternatives I, II, and III may not be protective of human
health and the environment because they do not include removal or containment of arsenic
contaminated soils along die north bank of Fields Brook. Such removal would prevent

41
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releases of elevated concentrations of arsenic within surface soils above the CUGs to the
Brook. Alternatives IV andV would be protective because they would prevent releases of
elevated concentrations of arsenic within surface soils above the CUGs to the Brook.

Alternatives n, in, IV and V are expected to comply with site ARARs andTBC
recommendations. ARARs are not relevant for Alternative I, the no action alternative.
The ARARs for the remedial actions considered for the Conrail source area are
indicated in Table 2.

2) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOXKTTY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENTABILrrY; AND COST.

Alternatives I, D, and m may not be permanent or long term effective because they do
not include removal or containment of arsenic contaminated s»ii» along the north bank
of Fields Brook which would prevent releases of elevated concentrations 'of arsenic
within surface soils above the CUGs to the Brook. Alternatives IV and V would be
permanent and long term effective because tiiey would prevent releases of elevated
concentrations of arsenic within surface soils above the CUGs to die Brook.

Alternatives I, n, and m may reduce short term effectiveness because they do not
include removal or containment of arsenic contaminated soils along die norm bank of
Fields Brook which would prevent releases of elevated concentrations of arsenic within
surface soils above the CUGs to die Brook. Alternatives IV and V may enhance short
term effectiveness because they would prevent releases of elevated concentrations of
arsenic within surface soils above the CUGs to the Brook. Construction activities for
Alternatives n through V may cause dust to be released to die atmosphere, thereby
creating exposure pathways to workers and community residents. Standard dust control
methods would be required during remedial action to reduce this risk. Alternatives n
through V also impact die property operations in the short-term. All alternatives,
except for Alternative I, will require worker protection during remediation. In
addition. Alternative V also will be less effective in the short-term since it is dependent
upon the construction of the Sediment/FWA Landfill and therefore has a longer
imptemfntfitHm tune.

Alternative I requires no implementation because no action is required (i.e., maintain
existing conditions). The implementation of Alternatives D and HI involves the
construction and maintenance of surface drainage controls, gravel covers, and erosion
control, measures mat are simple and well-known. Alternatives IV and V are the most
difficult to implement due to die destruction of vegetation and wildlife habitat, soil
excavation and handlii^g activities, the proximity of work areas to moving trains and
the need for sedimentation control during construction.

42
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Alternative I, the no action alternative, would not involve any costs. Alternatives n
and in have estimated 30-yr, net present worth, total costs of $81,100 and $96,500,
respectively. Both of these alternatives include the implementation of surface soil,
erosion and storm water drainage control measures to prevent soil transport to Fields
Brook. Annual O&M cost for Alternative m is approximately one-half the estimated
remedial costs.

3) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;
COMMUNITY ACCEPTANCE.
/
The State of Ohio did not concur with the remedies selected for the Floodplain/Wetiand
and Sediment Operable Units of the Fields Brook site. Because the Source Control
Operable Unit supports the remedies selected for the Floodplain/Wetiand and Sediment
Operable Units, the OEPA has provided notice of its nonconcurrence with die remedies
selected in mis Record of Decision.

U.S. EPA provided a public comment period on the Source Control Proposed Plan and
conducted a public meeting on the Source Control Proposed Plan on July 31, 1997 in
Ashtabula. The public comment period was originally scheduled from July 24 to
August 22,1997. The public comment period was extended to September 15,1997 in
response to a request from the public. After a follow-up request for more time to
submit comments regarding the Acme property, the comment period was again
extended. The comment period closed on September 22.1997.

U.S. EPA received one oral comment at the public meeting in support of U.S. EPA's
proposed cleanups. Eleven written sets of comments were received during the
comment period, including comments from natural resource trustees, PRPs and their
agents, and concerned citizens. All comments were carefully reviewed and considered
by U.S. EPA prior to finalization of this Record of Decision. U.S. EPA's response to
the public comments received are summarized in the attached Responsiveness
Summary, which is Attachment 1 of this Record of Decision.

D) Detrex Corporation

1) THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVHtONMENT AND COMPLIANCE WITH
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS):

43
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existing potential for migration of DNAPL compounds to Fields Brook. Alternatives
HA, IIB, m, and IV provide good overall protection of Fields Brook through physical,
hydraulic, or combined physical and hydraulic containment and removal. Alternatives
TJB and IV provide die highest expected degree of protectiveness because the DNAPL
plume would be bom contained and collected/treated.

Compliance with location and action-specific ARARs would be met for each of the four
alternatives. No action-specific ARARs were identified for the no action alternative
(Alternative I). USEPA's TBC guidance indicates mat long-term remediation
objectives of DNAPL remedies should be to remove free-phase, residual and vapor
phase DNAPL "to the extent practicable'. Since Alternatives I and n do not involve
DNAPL removal, they do not meet this TBC. The ARARs for me remedial actions
considered for the Detrex source area are indicated in Table 2.

2) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOHCTTY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENTABELITY; AND COST.

Residual risks to Fields Brook sediment would remain for each alternative. The no
action alternative (Alternative I) would not change die existing risk to Fields Brook
sediment. The shiny wall included in Alternatives HA and DB would effectively
contain DNAPL sources on die Detrex property and at off-site locations. However, die
DNAPL zone would remain in the subsurface as a residual risk. Alternatives OB, D3,
and IV would reduce the amount of DNAPL in the subsurface, but this partial
reduction may not produce a significant reduction in risk especially if all DNAPL is not
removed from die low permeability clay soils. The combination of physical (slurry
wall) and hydraulic containment/DNAPL collection and treatment (trenches or
extraction wells) hi Alternatives nB and TV provides die highest expected'reduction of
off-site migration.

No controls to prevent recontamination of Fields Brook sediment would be provided
under Alternative I. The slurry wall, shallow and deep extraction trenches, and
regrading of low-lying areas (Alternatives HA and IIB) are adequate and reliable
controls in the long term and require low maintenance. Vacuum-enhanced extraction
wells (Alternatives m and IV) are effective and reliable, and they would require
long-term O&M. Maintenance requirements for the groundwater/DNAPL extraction
systems would be moderate. Uncertainties associated with the effectiveness of
extraction wells in low-permeability glacial clays would be evaluated through the
long-term monitoring program. Complete removal of DNAPL in low permeability clay
soils is not possible with currently available technology and treatment to asymptotic
levels is expected.
44
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The long-term groundwater monitoring program would be implemented with each of
the alternatives (including no action) to monitor the effectiveness of each alternative. A
performance review would be required for each alternative to evaluate the effectiveness
of die alternative in ffp****^ die goal of preventing recontamination of Fields Brook
sediment and to evaluate the need for continued remediation (i.e. extraction and
treatment under Alternatives OB, in and IV).

All alternatives, except for die no action alternative, either reduce the mobility of
DNAPL compounds or reduce the toxteity and volume of contaminants. Alternative I,
die no action alternative, does not include treatment; therefore, die toxicity, mobility,
and volume of DNAPL in die subsurface are not reduced. DNAPL would be treated
and destroyed under Alternatives OB, in and IV. However, more DNAPL removal is
anticipated with the more aggressive vacuum-rnhanml groundwater/DNAPL removal
systems (Alternative m and IV). All DNAPL that would be separated from
groundwater would be destroyed by treatment or recycling. Dissolved-phase and
vapor-phase DNAPL constituents would be adsorbed onto activated carbon and would
be destroyed during carbon regeneration. The amount of DNAPL compounds tiiat
could be removed over time under. Alternatives HA, OB, HI, and IV is uncertain.

The activated carbon processes proposed for treatment of extracted groundwater and
DNAPL compounds for Alternatives HA, OB m, and IV are irreversible. Treatment
or recycling of liquid DNAPL and DNAPL compounds from extracted soil vapor under
Alternatives HE, m and IV is also irreversible.

Residuals remaining after on-site treatment of groundwater and DNAPL under
Alternatives HA, HE, m, and IV would include spent activated carbon for Alternatives
HA, UB, m, and IV and separated DNAPL for Alternatives UB, m and IV. Smaller
quantities of these residuals would be expected for Alternative HA than for. Alternatives
HB, m and IV. The extraction systems under Alternatives OB, m and IV would
extract DNAPL compounds from the entire DNAPL zone. Residual DNAPL would be
destroyed off site by treatment or recycling, while DNAPL compounds adsorbed onto
the spent carbon would be destroyed during off-site regeneration. DNAPL compounds
from die soil vapor would be destroyed by treatment or recycling under Alternatives m
and IV.

Alternatives DB, m and IV satisfy die preference for treatment of principle direat
contaminants (i.e., the DNAPL) that could potentially recontaminate Fields Brook
sediment Alternative n (slurry wall) does not satisfy die preference for treatment of
principle threat contaminants; however, treatment is provided for as a secondary
element in that contaminated groundwater collected in die trench would result in
destruction of h^yarrfmi^ substances.

Alternative I poses no additional short-term risks to the community. Alternatives HA.

45
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OB, m and IV pose slightly increased risks to the community by off-site disposal of
sediment, catalyst pile area excavations and DNAPL treatment Alternative m would
require disposal of the smallest volume of soil compared to Alternatives HA, DB, m,
and IV. For Alternative I, worker protection would be required only by workers
performing groundwater sampling activities. Appropriate protective equipment would
be required by construction workers to wEjnhnfoe exposure to DNAPL constituents
during construction of the remedial process options under Alternatives HA, HE, m,
and IV. Appropriate worker protection would also be required during O&M activities
of the dual-phase wells and treatment system under Alternatives DA, HE, m and IV.
«
Short-term environmental impacts would be the same as existing environmental impacts
for the no action alternative. Short-term environmental impacts associated with
disposal of excavated soil and possible air emissions from die excavations would be
possible under Alternatives HA, HE, m. and IV. Standard dust control methods would
be required during remedial action to reduce die risk from paiticulates. VOC
monitoring would be required during remedial action to ensure worker safety.

The design and construction period for the remedial process options included under
Alternatives HA, HE, m, and IV would be about 1 to 2 years. Protection from
recontaminatkm would be achieved when die systems are installed.

The technologies included under Alternatives HA, HE, m, and IV are demonstrated
technologies tiat have been constructed at similar sites. There will be difficulties
associated wim constructing die shiny wall in Alternatives IIA, HE, and IV beneath the
Conrail railroad tracks north of die facility without interrupting rail service. There are
no expected difficulties or uncertainties associated with construction of die vacuum-
enhanced extraction well system in Alternatives m and IV. Recent pilot-scale tests
completed at die site have evaluated die feasibility and effectiveness of die technology
in extracting DNAPL and groundwater. Based on these preliminary tests, die
technology is feasible, although yields will be relatively low.

A groundwater monitoring program would be implemented under each alternative
(including die no action alternative) to monitor die effectiveness of the remedial action.
Additional extraction wells or trenches can be added to any of die alternatives if the
monitoring program suggests that additional remedial measures are required to protect
Fields Brook sediment.

No regulatory agency approvals would be required for Alternative I. The requirements
of die existing NPDES permit would have to be met to account for increased flow rates
from die extraction trenches and wells for Alternatives HA, DB, m. and IV. Air
discharge permit requirements for soil vapor emissions from die extraction wells would
be met for Alternatives III and IV.
46
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Services and capabilities to implement each of the Detrex alternatives are readily
available. Alternatives n and IIB would not require special equipment, material, or
specialists. Alternatives in and IV would require groundwater and soil vapor
extraction system operators. The technologies proposed for Alternatives HA, ITJB, HI,
and IV are available from more than one bidder for competitive bidding.

The estimated cost fat each Detrex alternative is divided into capital costs and annual
O&M costs. The total present worm cost for each alternative is then computed using
an annual interest rate of 5% for a period of 30 years. The feasibility study costs are
expected to be accurate to within +50% and -30% in accordance with the U.S. EPA
guidance. The present worm of Alternative IIB is the most expensive remedial
alternative, followed in order by Alternative ffl, Alternative IV, Alternative HA, and
Alternative I (no action).

3) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;
COMMUNITY ACCEPTANCE.

The State of Ohio did not concur with the remedies selected for the Floodplain/Wetland
and Sediment Operable Units of the Fields Brook site. Because the Source Control
Operable Unit supports the remedies selected for the Floodplain/WetUnd and Sediment
Operable Units, the OEPA has provided notice of its nonconcunence with the remedies
selected in this Record of Decision.

U.S. EPA provided a public comment period on the Source Control Proposed Plan and
conducted a public meeting on the Source Control Proposed Plan on July 31, 1997 in
Ashtabula. The public comment period was originally scheduled from July 24 to
August 22,1997. The public comment period was extended to September IS, 1997 in
response to a request from the public. After a follow-up request for more time to
submit comments regarding the Acme property, the comment period was again
extended. The comment period closed on September 22, 1997.

U.S. EPA received one oral comment at the public meeting in support of U.S. EPA's
proposed cleanups. Eleven written sets of comments were received during the
comment period, including comments from natural resource trustees, PRPs and their
agents, and concerned citizens. All comments were carefully reviewed and considered
by U.S. EPA prior to finalization of this Record of Decision. U.S. EPA's response to
the public comments received are gimmariygd in the attached Responsiveness
Summary, which is Attachment 1 of this Record of Decision.

E) Sewers to the North and South of Fields Brook

1) THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVIRONMENT AND COMPLIANCE WITH

47
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APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS):

Overall protectiveness for the alternatives associated with the Fields Brook Source
Control Operable Unit is measured by the protectiveness at preventing recontamination
of Fields Brook sediment. Alternatives 0 and m would be protective of the
Bom alternatives would prevent recontamination of Fields Brook
xtiment removal is the primary activity under Alternative n, while
Alternative m includes sediment containment in addition to removal.

Compliance with ARARs would be met for Alternatives n and m. Action-specific
ARARs are not relevant to the no action alternative (Alternative I) because there would
be no remedial actitn. Alternatives n and m would be protective of the environment.
TVtfh afrgrmtrvffft wffliM rrcvynf ffc^nfrmimtMM1 ftf FH«fc Prwfr n^1"n^ntff Sediment
removal is the primary activity under Alternative n, white Alternative ffl includes
sediment containment in addition to removal.

Compliance with ARARs would be met for Alternatives n and m. Action-specific
ARARs are oat relevant to the no action alternative (Alternative I) because there would
be no remedial action. The ARARs for the remedial actions considered for the sewer
source areas are mdiratrd in Table 2.

2) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOXICITY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENTABIUTY; AND COST.

Alternative n provides the highest degree of long-term effectiveness and
because mis alternative includes sediment removal and would eliminate the potential of
COC migration to impact on Fields Brook sediments. The existing contaminated
sediment is the result of historical accumulation. Remediation of the potential source
areas discussed in mis FS for the Detrex Site is expected to eliminate significant future
accumulation of contaminated sediment. Alternative in would have lower long-term
effectiveness and permanence because it would leave some of the sediments contained
in the sewer, however this alternative would eliminate the potential for discharge water
tO COme hi mntart urith pn»vimi«ly gftnnn^jn*^ porffoq of fljf SfWT that fOnPMIW*
.sediment. Alternative m requires very little maintenance.

Alternative I would not result in any reduction of toxicity. mobility, or volume of
COCs. Implementation of Alternatives n and HI would result in the reduction of
toxicity, mobility, and volume through treatment of contaminants that are present in
any wastewater generated during sewer cleaning.
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Alternative I does not add additional risk to the existing risk to the community.
Alternatives U and m present slight additional risk to workers from the construction
activities necessary to clean, close and/or replace sewers. Emission controls on die
wastewater treatment unit fat Alternatives n and in would reduce risk associated with
vapor emisskm. Risks to the community would be marginally increased by off-site
disposal of contaminated sediments and control of dust generated by construction
activities. Standard dust control methods would be requited diiriiig remedial action to
reducetfae risks from particulates.

Implementation of Alternative n is expected to take less than 4 months, while
implementation of Alternative HI is expected to be completed in less than 1 year. It is
anticipated that Alternative m will require the additional time for the installation of
sewer sections.
Alternative I would be the easiest to implement since no action would be taken.
Alternative n *iwhHtff sewer sediment removal and sewer cleaning which may be
difficult to implement. There could be added difficulties associated with sediment
removal due to possible blockage of the sewer. Alternative m includes grouting a
portion of die sewer hi addition to fflffaffffitt removal. Grouting is a demonstrated
technology that his been applied at other sites and can be readily implemented.
Disposing contanimated sediments and treating of wastewater can also be readily
The rsHmatfd costs for Alternatives n and m were computed based on the assumption
that all sewers are one-quarter full of sediments at the present time. Calculation of the
estimated total quantity of sediments in the north sewers mdifatfd mat approximately
320 cu yd of sediments may be present in the combined sewer. Calculation of the
assumed total quantity of sediments in the south sewers inrtiratnd that approximately
180 cu yd of «**i«niCT!ff may be present. The costs were divided into capital costs and
annual O&M costs. The total for each alternative is men computed using a discount
rate of 5% for a period of 30 years. F • the Sewers norm of Fields Brook, the cost of
Alternative n is higher than the cost for Alternative m. For the Sewers south of Fields
Brook, the cost of Alternative in is higher than the cost for Alternative EL

3) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;
COMMUNITY ACCEPTANCE.

The State of Ohio did not concur with the remedies selected for the Floodplain/WeUand
and Sediment Operable Units of the Fields Brook site. Because the Source Control
Operable Unit supports the remedies selected for the FloodplauVWetland and Sediment
Operable Units, the OEPA has provided notice of its nonconcurrence with the remedies
selected in this Record of Decision.
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U.S. EPA provided a publk comment period on the Source Control Proposed Plan and
conducted a public meeting on the Source Control Proposed Plan on July 31,1997 in
Ashtabula. The public comment period was originally scheduled from Jury 24 to
August 22,1997. The public comment period was extended to Septenrttet IS, 1997 in
response to a request from the public. After a follow-up request for more time to
submit comments regarding die Acme property, the comment period was again
extended. The comment period closed on September 22,1997.

U.S. EPA received one oral comment at the public meeting in support of U.S. EPA's
proposed cleanups. Eleven written sets of comments were received dining the
comment period, including comments from natural resource trustees, PRPs and their
agents, wd concerned citizens. All comments were carefully reviewed and considered
by U.S. EPA prior to finalization of this Record of Decision. U.S. EPA's response to
the public enmmantt received are summarized in the attached Responsiveness
Summary, which is Attachment 1 of this Record of Decision.

F) RMI Metals Reduction

1) THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVIRONMENT AND COMPLIANCE WTTH
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS):

Overall protectiveness for the alternatives associated with the Fields Brook Source
Control Operable Unit is measured by die protectiveness at preventing reoontaminarion
of Fields Brook sediment Alternatives I and n may be potentially less protective than
Alternatives m and IV, because areas with elevated levels of PCB contamination would
be uncovered or covered with up to 12 inch of soil. Such a cover is most*uitable for
areas with relatively low levels of contamination, and would provide a potentially less
protective remedy for areas with elevated levels of contamination, in part because of
the uncertainty associated with the possible surfacing of chemicals of concern over
time.

There are no known location-specific ARARs that apply to the remedial alternatives
that have been developed for the RMI Metals facility. Alternatives m and IV have
been designed to meet all potential action-specific ARARs. Alternative n would not
meet the substantive requirements of TSCA, and thus mis alternative would not comply
with ARARs. Although U.S. EPA has die option to waive TSCA requirements if there
is "no unreasonable risk" to human health and the environment, the U.S. EPA does not
believe that a 12-inch soil cover would provide sufficient protection over the long term
for the levels of PCB contamination in the RMI soils. The ARARs for the remedial
actions considered for the RMI Metals source area are indicated in Table 2.
SO
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2) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESS
AND PERMANENCE; REDUCTION OF TOXICTTY, MOBILITY AND
VOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;
IMPLEMENT ABILITY; AND COST.

Alternatives I and H may be potentially less permanent and long-term effective than
Alternatives in and IV, because areas with elevated levels of PCB contamination would
be uncovered or covered with up to 12 inch of soil. Such a cover is most suitable for
areas with relatively low levels of contamination, and would provide a potentially less
permanent and long-term effective remedy for areas with elevated levels of
contamination, in part because of the Jmcertainty associated with the possible surfacing
of chemicals of concern over time.

Alternatives I, n, in and IV would not result in any reduction of toxicity, mobility, or
volume of COCs through treatment. However, implementation of Alternatives n, EQ
and IV would result in the reduction of transportability of contaminants in soil with
Alternative ffl rBBiHing in a further reduction in soil with PCB concentrations greater
than 50 ppm, and Alternative IV resulting in the complete reduction of PCB greater
man 10 ppm in soil.

Alternative n is effective in the short-term became it involves minimal disturbance to
the source areas. The excavation and disposal portions of Alternatives HI and IV
present risk of paniculate emission, thereby creating exposure pathways to workers and
community residents. Standard dust control methods would be required during
remedial action to reduce this risk. All alternatives, except for Alternative I, will
require worker projection during remediation.

Implementation of Alternative I is expected to take 2 to 4 months. Alternative n is
expected to take 6 to 8 months to implement. Implementation of Alternatives m and
IV is estimated to take about 10 to 12 months but excavation activities would need to
be scheduled to coincide with the construction of t * on-site consolidation area, if this
consolidation area is selected for disposal.

Alternative I would be the easiest to implement since only monitoring would be
included. Alternatives n and HI include construction of a soil/clay cover.
Construction of the cover would have material handling requirements. The materials,
services, equipment, and specialists required for the construction are readily available.
The equipment and specialists required for the excavation portion of Alternatives m
and IV are also readily available. The cover could be expanded or enlarged easily, if
needed. Periodic inspection and maintenance of the cover would provide reliability in
the.future.

Implementation of Alternatives n, m and IV would interfere with the normal

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operations at the RMI facility, however this disruption is minimtMH if the facility
remains closed. Alternatives JO and IV would cause the most interference with facility
operations due to soil excavation.
The t**m9**4 cost for each alternative is divided into capital costs and annual O&M
costs. The total cost for each alternative is then computed using an annual interest rate
of 5% for a period of 30 years. The costs presented in this document are expected to
range within -1-50% and -30% in accordance with the U.S. EPA guidance. Alternative
m is the most expensive remedial alternative, followed in order by Alternative IV,
Alternative n, and Alternative I.

3) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;
COMMUNITY ACCEPTANCE.

The State of Ohio did not concur with the remedies selected for the Floodplain/Wetland
and Sediment Operable Units of the Fields Brook site. Because the Source Control
Operable Unit supports the remedies selected for the Floodplain/Wetland and Sediment
Operable Units, the OEPA has provided notice of its nonconcurrence with the remedies
selected in this Record of Decision.

U.S. EPA provided a public comment period on the Source Control Proposed Plan and
conducted t public meeting on the Source Control Proposed Plan on Jury 31, 1997 in
AshtabuUi. The public comment period was originally scheduled from July 24 to
August 22, 1997. The public comment period was extended to September IS, 1997 in
response to a request from the public. After a follow-up request for more time to
submit comments regarding the Acme property, the comment period was again
extended. The comment period closed on September 22, 1997.

U.S. EPA received one oral comment at the public meeting in support of U.S. EPA's
proposed cleanups. Eleven written sets of comments were received during the
comment period, including comments from natural resource trustees, PRPs and their
agents, and concerned citizens. All comments were carefully reviewed and considered
by U.S. EPA prior to finalization'of mis Record of Decision. U.S. EPA's response to
the public comments received are summarized in the attached Responsiveness
Summary, which is Attachment 1 of mis Record of Decision.
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X. THE SELECTED REMEDIES

A) Detailed Requirements of Hie Selected Remedies

1) Aone Scrap Iron and Metal

The selected remedy is Alternative VI, which involves the excavation of soil with PCB
concentrations greater than or equal to 50 pom. Excavated soil will be disposed of at
either an on-site landfill (to be built on one of the source areas) or at an off-site
landfill, whichever is more cost-effective. Remaining contamination will be contained
on site. This remedy will reduce the volume of contaminants at the site and comply
with TSCA by property handling of TSCA-regulated soils.

More specifically. Alternative VI includes the following components:

a) Clear Scrap, Debris and Vegetation / Remove Physical Hazards

In order to «np<«re"t the Remedial Action, scrap, debris and vegetation must
be cleared in response and work areas. Physical hazards (i.e., unstable building
sections) mat could threaten workers must also be addressed prior to Remedial
Action.

b) Excavation of Soils with Total PCB Concentrations * 50 ppm

This ROD requires excavation of soils with total PCB concentrations greater
than or equal to SO ppm. Based on existing data, it appears mat limiting
excavations to a depth of approximately 1 foot should remove all TSCA-
regulated soil. However, mis remedy requires removal of all TSCA-regulated
soils (* SO ppm PCBs), regardless of depth. Therefore, if areas of additional
contamination are identified, the excavation depth will be adjusted accordingly.
During the remedial design phase, additional samples will be collected to further
delineate the design remedial response area and ensure that the PCB
contamination is not present on other areas of the Acme property.

The *«ritnatffl remedial response area for Alternative VI is shown in Figure 4.
The excavation area was developed based on linear interpolation between
existing data points and covers approximately 47,000 square feet. Excavation in
this area would be conducted to a depth of approximately 1 foot. The
excavation to a depth of 1 foot would result in an estimated volume of 1,800
cubic yards.

The excavation of surface soils in Alternative VI would be accomplished using
conventional earth-moving equipment. Upon excavation, the soil would be

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placed in lined roll-off containers or dump trucks for transportation to either the
SOU/FWA on-site landfill or to an off-site landfill. Verification sampling may
be required to ensure removal of TSCA-regulated soils. Following completion
of excavation activities, the excavated areas would be backfilled with clean soil
and graded to allow for adequate drainage. Any disturbed areas not receiving
an erosion control cover will be graded and seeded, as necessary.

Areas of excavation and locations of the filled/ covered areas are preliminary
and will be revised in the event that the Acme property is selected as the
location for the on-site landfill (SOU/FWA Consolidation Area).

c) Refinement of Area to Be Covered

As part of the Remedial Design, soil loss calculations will be reviewed to
finalize the area to be covered. The cover areas have been developed based on
current operations and include the proposed excavation area since it is located
within the cover interior. The areas may be altered during Remedial Design if
assumptions on future operations are revised and/or the Remedial Design
includes consolidation.

d) Optional Consolidation

Based on public comment from representatives from Acme Scrap Iron and
Metal, the U.S. EPA has determined that it will allow consolidation as an
optional component of Alternative VI. Consolidation will minimize the area to
be covered and maximize the productivity of the properly. Depending on the
degree of consolidation, mis could either result in a cost savings or an increase
in remediation costs.

e) Construction of Cover, Surface Drainage Controls

For the cover areas, the erosion control cover materials will consist of a 12-inch
thick layer of clean soil, an erosion control blanket and will be vegetated to
reduce die potential for erosion. For anticipated future traffic areas, a 6-in.
gravel layer underlain by geotextile will be used instead of the soil.

As estimated during the Feasibility Study, the erosion control cover for
Alternative VI consists of approximately 120,000 sq. ft. (2.8 acres) that will be
covered with gravel and 360,000 sq. ft. (8.2 acres) that will be covered with
soil.

The location of the erosion control cover (as described in the SCFS) would
preclude use of the existing on-site sewer. Therefore, if the cleanup at the

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Acme facility is implemented as described in the SCFS, the existing sewer
system would be plugged prior to the installation of the erosion control cover
and other drainage controls would be implemented. However, if the design of
the Acme remedy utilizes consolidation, it may be possible mat the existing
sewer system could be cleaned and kept in service. This will be addressed
Design.
I) infl*itiitJMiai Controls* Chemical monitoring and O&M

Institutional controls will be implemented for any area where hazardous
substances, pollutants or contaminants will remain above levels that allow for
unlimited use and unrestricted exposure. More specifically, institutional
controls will be implemented to protect the cover system and drainage controls
and will include deed restrictions, security fencing, and signs. The Operations
and Maintenance Plan portion of the Remedial Design will specify maintenance
and monitoring requirements. The performance of the selected alternative will
be reviewed and evaluated every five years after initiation of the remedial action
to assure that human health .and the environment are being protected.
Points of Compli

In conjunction with completion of die Remedial Action and performance of
required O&M. erosion and runoff from the Acme facility must meet the
occupational Cleanup Goals (CUGs) established for the FWA and Sediment
Operable Units. The occupational CUG for total PCBs is 3.1 ppm. At a
the points of compliance are the property boundary and any
discharge locations. Additional performance monitoring locations may be
identified during remedial design.

2) MJUennium

The selected remedy is Alternative VI. which involves the excavation of soil with PCB
concentrations greater man or equal to SO ppm. Excavated soil will be disposed of at
either an on-site landfill (to be built on one of the source areas) or at an off-site .
landfill, whichever is more cost-effective. Remaining contamination will be contained
on site. This remedy will reduce die volume of contaminants at the site and comply
with TSCA by properly handling TSCA-regulated soils.

More specifically. Alternative VI requires:

a) Clear Debris and Vegetation / Remove Physical Hazards

In order to implement the Remedial Action, debris and vegetation must be

55
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cleared in response and work areas. Any physical hazards that could threaten
workers must afcn be addressed prior to Remedial Action.

b) Excavation of Soils with Total PCB Concentrations * SO ppm

This ROD requires excavation of soils with total PCB concentrations greater
man or equal to SO ppm. The estimated remedial response area for Alternative
VI is shown in Figure S. Based on data presented in the FS, volume estimates
for excavation are, as follows:

Non-Traffic Area - approximately 545 cubic yards of soil with 2 50
ppmPCBs.

Norm Traffic Area • approximately 3,427 cubic yards of soil with * 50
ppmPCBs.

Laydown Area - no anticipated soils with * 50 ppm PCBs.

Plant Process Area - approximately 1,003 cubic yards of soil with * 50
ppm PCBs.

Existing Soil Piles -Soil piles will be removed regardless of PCB
irton, Contaminant concentrations will determine ultimate
disposal location.

Mining Residuals Piles - approximately 11,163 cubic yards of soil with
* 50 ppm PCBs.

•Following completion of excavation activities, excavated areas will be backfilled
with clean soil and graded to allow for adequate drainage. In the Mining
Residuals Pile, however, excavated areas will not be backfilled. These areas
will instead be graded to lessen the overall height of the pile. Any disturbed
areas not receiving an erosion control cover will be graded and seeded, as
uy.
Upon excavation, the soil would be placed in lined roll-off containers or dump
trucks for transportation to the SOU/FWA on-site landfill or an off-site TSCA-
compliant landfill. Millennium has provided U.S. EPA with the specifications
of a landfill currently being constructed under a Ohio EPA permit for disposal
of Millennium process wastes. The specifications are being reviewed by the
U.S. EPA Region V TSCA Section. If the landfill is given an approval by the
TSCA section, disposal of source control soils in mis facility would be an
acceptable option for solid wastes or TSCA-regulated wastes.

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c) Refinement of Excavation and Coyer Areas

Millennhim has conducted additional delineation sampling to better define
excavation areas. U.S. EPA is currently reviewing a draft report submitted by
and dated August 4, 1997. This draft report presents the results of
die delineation sampling effort ?"d is included in die Administrative Record.
As part of the Remedial Design, excavation and cover areas will be finalized
and stability analyses will be conducted. The remedial action areas presented in
the FS and ttus ROD may be altered during Remedial Design based on new
sampling data, changes in the assumptions concerning future operations, or the
addition of consolidation as a component of the remedy. After excavation, all
areas With surface soil contaminant concentrations exceeding die occupational
CUG for PCBs (3. 1 ppm) will be contained within the erosion control cover
system.

d) Optional Consolidation

Based on public comment from representatives from Acme Scrap Iron and
Metal, the U.S. EPA has determined mat it will allow consolidation as an
optional component of the Acme cleanup. Upon consideration of the
Millennium alternatives, U.S. EPA has determined mat consolidation could also
be inryw u an optional component of the selected Millennium alternative,
Alternative VI. Consolidation will minimize die area to be covered and
maximise the productivity of die property. Depending on die degree of
consolidation, this could either result in a cost savings or an increase in
remediation costs.

e) Construction of Cover, Surface Drainage Controls

For the cover areas, the erosion control cover materials will consist of a 12-inch
thick layer of clean soil, an erosion control blanket and will be vegetated to
reduce the potential for erosion. For anticipated future traffic areas, a 6-in.
gravel layer underlain by geotextile will be used instead of the soil. The
selected alternative, as presented in die FS, assumes the following cover
requirements after excavation:

Norm Traffic Area - Areas not already covered with gravel, structures,
or non-erodible areas, will be covered with a geotextile and then 6
inches of gravel.

LaydownArea - The Laydown Area will be covered with a geotextile
and then 6 inches of gravel.
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Plant Process Area - The Plant Process Area will be covered with
structural-grade asphalt or concrete, as necessary. Areas currently
covered with asphalt, concrete, or structures and will be left in place.

Existing Soil Piles - No cover anticipated. Soil piles will be removed.
Mining B**MH«I« Pile - After excavation of soils for disposal
regradmg of area, a 12-inch soil erosion control cover will be placed
over the Mining Residuals Pile. An erosion control blanket and a
vegetative layer will then be placed on top of the 12 inches of soil.
Instead of a vegetative layer, crushed stone may be used in some areas to
f) Surface Drainage Controls

A silt curtain will be placed between the Mining Residuals Pile and Fields Brook to
minimize erosion. Topography will be graded as necessary to control run-on to
the Mining Residual Pile. However, because the plant areas wifl all be covered
with dean materials, it wffl be unnecessary to treat surface water in the wastewater
treatments system or by any other method. Sheet flow runoff from these areas will
be adequate. AD surface water controls win be maintained.

g) Miscellaneous Requirements

A concrete curb or wall would be placed between the concrete pad and the Mining
Residuals Pile to prevent accidental damage to the erosion control cover from
facility vehicles.

h) Institutional Controls, Chemical Monitoring and O&M

Institutional controls will be implemented for any area where hazardous
substances, pollutants or contaminants will remain above levels that allow for
unlimited use and unrestricted exposure. More specifically, institutional
controls will be implemented to protect the cover system and drainage controls.
Such institutional controls will include deed restrictions, security fencing, and
signs. The Operations and Maintenance Plan portion of the Remedial Design
will specify maintenance and monitoring requirements.

O&M activities would include the maintenance of the soil erosion control cover,
the stormwater drainage ways, and the vegetated areas (if any). Chemical
monitoring requirements would include the annual collection of total PCB surface
soil and groundwater samples.
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The performance of the selected alternative will be reviewed and evaluated
every five years after initiation of the remedial action to assure that human
health and the environment are being protected.

0 Points off Compliance

In conjunction with completion of the Remedial Action and performance of
required O&M, erosion and runoff from the Millennium facility must meet the
Cleanup Goals (CUGs) established for the FWA and Sediment Operable Units.
The extent and integrity of the cover must be maintained to contain soil that
exceeds occupational CUGs. 'At a mmimufn, the points of compliance are the
property boundary, discharge locations, and the edge of the floodplain.
Additional performance monitoring locations may be identified during remedial
design.

3) Conrafl

The primary selected remedy for the Conrail property is Alternative IV, which requires
consolidation, containment of surface soils in an on-stte disposal cell, institutional controls,
deed restrictions, isolation of the site from unauthorized entry, and O&M to prevent
surface soils from entering Fields Brook. U.S. EPA believes that Alternative IV will
effectively prevent the movement of arsenic-contaminated material into Fields Brook.

The selected remedy for the Conrail property (Alternative IV) requires the following
activities:

a) Clear Debris and Vegetation / Remove Physical Hazards

In order to implement the Remedial Action, debris and vegetation must be
cleared in response and work areas, including but not limited to the "flat area"
and along bank slopes to Fields Brook. Any physical hazards that could threaten
workers must also be addressed prior to Remedial Action.

b) Excavation and Consolidation of Anente-contaminated Soils

The soils on the arsenic-contaminated portion of the north slope of Fields Brook
will be excavated to a depth of approximately 6-inches. The excavation area
includes the eastern edge of the yardmaster building to approximately 375 ft east
of the yardmaster building and from approximately SO ft west of the former
compressor building to approximately 60 ft east of the former compressor
building, approximately 485 ft in total length. The excavated soils (estimated
volume of approximately 90 cu yds) will be transported to the consolidation area
shown on Figure 6 for final disposal. The consolidation area is located at the

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Conrail property.

c) Cover and Erosion Control Requirements

Upon placement of excavated soils, the consolidation area will be graded and
covered whh gravd to prevent soil erosion. Within the consolidation area, 6
inches of griwd wifl be placed to cover the area and prevent soil erosion. Erosion
control measures (e.g., concrete revetment mats or riprap) will be placed on the
bank, where necessary, to minimize erosion. The cover will men be sloped to a
minimum 2 percent grade from the southernmost tracks towards Fields Brook to
meet the riprap or other erosion control measures to be placed on sloped bank
areas along Fields Brook. The area covered by gravel and bank protection will not
be revegetated.

As part of the Remedial Design, the extent of excavation and cover areas will be
finalized. The remedial action areas presented in the FS and *his ROD may be
altered during Remedial Design based on new sampling data, changes in the
assumptions concerning future operations at the Conrail property, or changes in
the extent of consolidation. After excavation and consolidation, all areas with
surface soil contaminant concentrations exceeding residential CUGs will be
inchided in the containment area.

d) Institutional Controls, Chemical Monitoring and O&M

institutional controls will be implemented for any area where hazardous
substances, pollutants or contaminants will remain above levels that allow for
iinijtnfod use and unrestricted exposure. More specifically, institutional
controls will be implemented to protect the cover system and drainage controls.
Such institutional controls will include, as appropriate, deed restrictions,
security fencing, and signs. The Operations and Maintenance Plan portion of
the Remedial Design will specify maintenance and monitoring requirements. A
fence would be placed across the entrance of the limited access bridge across
Fields Brook in such a manner as to prevent unauthorized entry.

Chemical monitoring requirements will include the annual collection of surface
soil arsenic samples. The performance of the selected alternative will be
reviewed and evaluated every five years after initiation of the remedial action to
assure that human health and the environment are being protected.

Maintenance would involve visual inspection of the gravel and riprap cover.
Occasional repairs to restore the cover thickness or riprap will likely involve the
addition of gravel or riprap in areas of subsidence or erosion.
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e) Points of Compliance

In conjunction with completion of the Remedial Action and performance of
required O&M, erosion and runoff from the Conrail facility must
residential Cleanup Goals (CUGs) established for the FWA and Sediment
Operable Units. The extent and integrity of the cover must be maintained to
contain soil that exceeds CUGs. At a minimum, the point of compliance is the
property boundary. Additional performance monitoring locations may be
identified during remedial design.

Optional Imptementsaioo of Alternative V In Lieu of Alternative IV

U.S. EPA believes mat Alternative IV will be effective in reducing the
movement of contamination to Fields Brook and has selected Alternative IV as
its primary remedy for the Conrail property. However, U.S. EPA notes that
Alternative V is an acceptable enhancement of the selected remedy. The
complete excavation of contaminated soils and elimination of O&M has benefits
that cannot he readily itemized in a cost estimate, such as a reduction in long-
term liability concerns, a shortened remedial design phase, and the elimination
of U.S. EPA staff time required to track O&M compliance and review
monitoring results.

4) Detrex

The selected remedy for the Detrex source area is Alternative IV, which requires the
containment and treatment of groundwater contamination by the construction of a
partial slurry wall and vacuum-enhanced extraction wells. Alternative IV would also
reduce the potential for migration of contaminated surface soil due to reach the DS
Tributary and Fields Brook by containment of surface soil contamination, ditch
cleaning, catalyst pile removal and retention pond sediment removal.

More specifically. Alternative IV consists of the following:

a) Clear Debris and Vegetation, Remove Physical Hazards

In order to implement the Remedial Action, debris and vegetation must be
cleared in response and work areas. Physical hazards that could threaten
workers must also be addressed prior to Remedial Action.

b) Construction of Partial Slurry Wall

This ROD requires the construction of a partial slurry wall to restrict the flow of
the Detrex groundwater contamination. The slurry wall component will extend

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beyond the downgradient portion of the en-site and off-site DNAPL and
dissolved phase COCs plume, and be located outside of the DNAPL and
extended to ensure that the DNAPL and contaminated groundwater flowing
towards Fields Brook or die DS Tributary particularly along the northern and
western directions from die Detrex facility would be contained or captured.
The wall will extend along the western side of the RMI Landfill. The estimated
location of the shiny wan is shown on Figure 7. 'Design investigations will be
conducted to properly locate the wall in order to ensure mat the DNAPL and
contaminated groundwater flowing towards Fields Brook or the DS Tributary,
particularly along the northern and western directions from the Detrex facility,
will be contained or captured. The wall is expected to be approximately 1,500
feet long; however, the final specifications of the shiny wall will be determined
Airing Ffmfilinl Design.
The shiny wall would be constructed of a soil-bentonite shiny or other clay
mineral slurry. The permeability of the slurry wall will be designed to be
approximately 1 x 10* cm/sec. Due to die high percentage of naturally
occurring clay soil material 'in the proposed shiny wall area, it is possible mat a
portion of the excavation spoils could be reused and incorporated into the slurry
Wall. Tfie remaning erovarinn apniU will he temporarily stockpiled nn-site
and characterized to evaluate on-site and off-she disposal options consistent with
ARARs.

Compatibility testing to evaluate potential integrity issues related to DNAPL and
other COCs in contact with die slurry material -will be performed during design
phases. As part of this evaluation, a laboratory study will be conducted using
soils from the Detrex site mixed with a clay mineral slurry. A sample of
DNAPL will be collected and placed in contact with the shiny. Laboratory
compatibility tests will be performed to evaluate potential permeability changes
in the slurry m; .:rial. Selection of the clay mineral additive (e.g. bentonite.
attapulgite) will be performed in this remedial design phase.

c) Vacuum-Enhanced Extraction Wells

Vacuum-enhanced extraction wells will be installed near the leading edge of the
DNAPL plume near the shiny wall and within the plume to lower groundwater
and collect DNAPL in source areas. Based on pilot test results, approximately
40 extraction wells are anticipated.

Spoils from the installation of extraction wells will be temporarily stockpiled
on-site and characterized to evaluate off-site disposal options consistent with
ARARs.
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Fluids collected from the vacuum-enhanced extraction wells will be routed to a
knockout tank to separate the vapor phase from the liquid phase. The vapor
phase will be treated with granular activated carbon to remove organic
contaminant vapors before being released into the atmosphere.

The liquid phase from the knockout tank will be conveyed to a DNAPL/water
separator where DNAPL will be separated from water. The separated DNAPL
wUl be collected and transported to an off-site facility for treatment or
recycling. The separated water will be conveyed to the existing activated
carbon treatment system at the Detrex facility..

d) Surface Water and Erosion Control / Soil Cover

Low-lying areas within the existing surface water collection system area on the
Detrex facility and areas with surface soil occupational CUG exceedances will
be filled and regraded as part of this alternative, and these areas will be covered
with a 12-inch thick soil cover, an erosion control blanket, and a vegetative or
crushed stone layer surface..- Clean clay soil would be used for backfill.
Regrading and vegetative cover would prevent ponding of surface water in
former source areas and reduce infiltration of surface water into die ground.
.OHimenfti lying within retention basin DET7 **v* in the drainage ditch on the
northern boundary ***** collects surface water will be excavated aftd analyzed to
evaluate disposal options consistent with ARARs. Following cleaning, the ditch
would be filled with gravel or cement.

e) Catalyst POe Excavation and Disposal

The catalyst pile material will be excavated, evaluated, characterized and
disposed of in a manner consistent with ARARs. Approximately 100 cu. yds of
catalyst material contained in the mice small piles and underlying soil will be
removed from the catalyst pile area. The excavation will extend to a depth of
approximately six inches. Since the material is a solid, inert catalyst, leaching
through die soil is unlikely to have occurred. Upon completion of removal of
visible catalyst and excavation to the six inch depth, confirmation samples will
be collected from the base of the excavation, prior to backfilling. Clean soil
will be replaced in the excavation and the area will be regraded and revegetated.

I) Off-site Surface Water Control In The DS Tributary

In order to reduce the potential for subsurface water seepage to enter the DS
Tributary hi the northeast portion of the site, a 30-inch diameter culvert will be
installed in the DS Tributary to contain surface water flow and keep
groundwater from entering the stream flow. This culvert will connect to the

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existing culvert beneath State Road and will extend along the northern side of
the railroad spur, approximately 600 feet upstream. This configuration will
entirely contain the surface water in the DS Tributary north of the Detrex
facility, seal off potential groundwater seepage and prevent soil erosion. All
joints will be sealed to eliminate seepage. Sediment beneath the culvert will be
excavated to a depth of approximately 2.0 feet. The sediment excavated
beneath the culvert would be analyzed to evaluate disposal options consistent
witnARARs.

g) Institutional Controls, Chemical monitoring and O&M

O&M activities for the vacuum-enhanced extraction well system will include
routine inspections of blowers, electrical equipment, belts, fuses, and pertinent
operating parameters. O&M requirements for the shiny wall and regraded
areas will consist of inspections, with regrading and revegetating, as necessary.
Routine sampling of selected extraction wells will be required to monitor the
effectiveness of the system. At a minimum, annual groundwater monitoring
will be conducted at points of compliance, with samples to be analyzed for
DNAPL, VOC and SVOC parameters. In addition, water level data will be
gathered on a semi-annual basis from all monitoring wells and piezometers
installed inside and outside of the shiny wall to evaluate groundwater gradients
within the remedial response area. More frequent analyses may be required in
the first few years of operation to establish a post-remediation baseline.

Storm water treatment system O&M activities, such as carbon replacement, will
remain the same as are currently used at the facility; however, die frequency of
carbon replacement will increase depending on the concentration of
contaminants in the water pumped out of the extraction wells. O&M activities
will also include separator maintenance, handling and disposal of DNAPL, and
inspection and periodic sediment removal from the settling pond at DET7.

The outfall from the existing stormwater treatment system will be monitored
for existing NPDES monitoring requirements and DNAPL constituents not
included as part of the current monitoring program. Samples will be collected
at the same time as the NPDES monitoring.

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The performance of the selected alternative will be reviewed and evaluated
every five years after initiation of the remedial action to assure that human
health and the environment are being protected
h) Points of Compli

In conjunction with completion of the Remedial Action and performance of
required O&M, sheet flow erosion and runoff from the Detrex facility must
meet the occupational Cleanup Goals (CUGs) established for the FWA and
Sediment Operable Units. The points of compliance for surface runoff will be
the property boundary and tfte DS Tributary. Groundwater contamination must
also meet the occupational CUGs to prevent lecontamination of the Brook. At a
, the points of compliance for the contaminants present in groundwater
will be the edge of the shiny wall or, for areas without the shiny wall, the
property boundary and the DS tributary. Contaminant levels at the Detrex
outfall must meet residential CUGs to ensure mat the 48* combined sewer can
meet residential CUGs when it discharges to Fields Brook. Additional points of
compliance monitoring may-toe identified during P^ny^Hiai Design.

5) Sewers North and South of Fields Brook

The primary selected remedy for the sewer source area is Alternative ffl, which
requires the cleaning of the source area sewers specified in Section IV(E) of this ROD.
For the portions of the sewers that cannot be cost-effectively cleaned, the sections will
be filled with grout to contain the sediment and debris within the pipe.

The selected remedy for the sewer source area requires the following activities:

a) Cleaning of Sewer Lines and Catch Basins

This alternative includes the removal of sediment and debris from inside the
sewer lines and the associated catch basins to reduce die potential of
recontamination of the Fields Brook sediments in excess of CUGs. The sewer
lines will continue to be used after remedial activities are completed. Sediment
removal could be accomplished by cleaning the inside of the sewer using
manual and mechanical techniques to remove sediment, followed by rinsing.
Selection of the equipment to be used will be based on the size and conditions of
the sewer lines at the time of work activities. The equipment selected will be
capable of removing sediments, din, grease, rocks, and other foreign materials.
Mechanically powered cleaning equipment consists of belt-operated buckets and
a power rodding machine that is powerful enough to remove sediments and
large debris from the sewer lines. Rinsing equipment will include a high
velocity gun for washing and scouring sewer walls and floors.

65
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Sewer cleaning will begin at one access location, such as a manhole or a catch
basin, and continue to the next access location. All manholes along the sewer
lines will be located prior to sewer cleaning. Additional manholes or access
points may need to be constructed between existing manholes, if the distance
between the two existing access points is longer than the reach of the sewer
cleaning equipment.

All sediments and debris removed by the sewer cleaning will be staged in
stockpile areas located near access at one end of the sewer. The stockpile areas
will be equipped with filter fabric or other equivalent measures to assure that
efdhnenta are not released to Fields Brook during remediation of the sewers.
The ««Himai*« god debris will be dewatered to reduce the water content and
volume of the solids. Solids collected during the dewatering process will be
characterized and disposed of consistent with ARARs. Collected sediments and
solids will be transported to either the onshe-landfill (to be constructed on one
of the industrial properties within the watershed) or an off-site landfill for
disposal. The selection of off-site disposal facility (whether solid waste,
RCRA, or TSCA) will depend on the chemical characteristics of the sediment
material.

The w**"«*f«* dewatering liquid will be combined with the rinse water generated
during the final sewer cleaning. Rinse water collected during me sewer
cleaning process will be characterized for proper discharge. Rinse water may
be treated on site with a portable water treatment unit to meet surface water
discharge criteria before discharging to Fields Brook. Rinse water may also be
recycled after removing the suspended sediments to reduce the amount of
wastewater generated and the associated cost of treatment.

Sediment and debris removal from the sewer pipe after cleaning will be verified
by internal pipe inspection. Internal pipe inspection could be accomplished with
remote pipe inspection using either electric or manually operated winches to pull
inspection cameras specifically designed for use in sewer line inspection work.
The camera may be pulled through the sewer line in either direction.

b) Sediment Containment - Sewers North

Sewer sections that cannot be cost-effectively cleaned will be filled with grout to
contain contaminated sediment and debris. This containment approach will be
used for a portion of the 48-inch diameter combined sewer that runs from the
Detrex outfall to the sewer discharge point at Fields Brook (Figure 8A). The
existing sewer line will be abandoned and replaced with a new sewer diversion
line. The length of sewer considered for grouting is approximately 1 ,300 linear
feet. The sediments in this sewer segment would be contained by filling the

66
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sewer pipe with a cement grout to restrict flow in the sewer and prevent
migration of sediments into Fields Brook. The sewer segment would be
plugged at bom ends before grouting proceeds. Lean cement grout or fly ash
grout would be used to grout the inner space of the sewer. Grouting would be
accomplished from both ends and at several locations along the sewer pipe.
Grout notes could be drilled at the crest of the sewer pipe through the
overburden. Grout pipes would be inserted through the grout holes to pump the
grout. Vents would be installed to allow air and water in the sewer to escape as
it is replaced with the grout material.

A replacement (diversion) sewer would be constructed to drain the water in the
remaining sections of the combined sewer. The new sewer section would be
constructed to divert the combined sewer water discharge from a point south of
the Detrex outfall to the DS tributary. The new sewr segment would be
approximately 100 ft long and have a diameter consistent with the existing
outfall. Sediments in the combined sewer south of mis diversion point would be
contained by grouting. Sediments in the combined sewer north of this diversion
point and the other sewers would be removed. The estimated volume of
sediments in mis portion is 120 cu yds. These sewers would continue to be
used after remedial activities are completed.

c) Sediment Containment • Sewers South

In the FS discussion of Alternative in for the sewers to the south of Fields
Brook, it was assumed that a portion of the sediments in the 30-inch sewer on
the Acme site would be contained (Figure 8B). Based on this assumption, the
FS cost estimate for Alternative in exceeds Alternative H, which requires
complete cleaning of the sewer lines without opportunity for containment.
Although Alternative ffl is selected in this ROD, inherent in this selected
remedy is the option to fully clean the sewer lines. Alternative ffl provides
greater flexibility than Alternative n for the design'of a cost-effective and
protective solution.

Assuming a portion of the Acme sewer line would require containment, the
sediments in die impacted segment would be contained by filling the sewer pipe
with a cement grout to restrict flow in the sewer and prevent migration of
sediments into Fields Brook. The sewer segment would be plugged at both ends
before grouting proceeds. Lean cement grout or fly ash grout would be used to
grout the inner space of the sewer. Grouting would be accomplished from both
ends and at several locations along the sewer pipe. Grout holes could be drilled
at the crest of the sewer pipe through the overburden. Grout pipes would be
inserted through the grout holes to pump die grout. Vents would be installed to
allow air and water in the sewer to escape as it is replaced with the grout

67
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material.

A replacement (diversion) sewer would be constructed to drain surface water
runoff from the Acme site. The new sewer segment would be approximately
300 ft long and would replace the grouted portion. The estimated volume of
sediments in the section of the sewer to be cleaned is 140 cubic yards.

iil
Institutional controls will be implemented for any section of sewer where
hazardous mrtmanmt. pollutants or contaminants will remain above levels that
allow for unlimited use and unrestricted exposure. More specifically,
institutional controls will be imptementea to control excavation into sewers that
have been seated to contain contaminants »i*l to define hanHiji^g and disposal
requirements for such sewers. Such institutional controls will include, as
appropriate, deed restrictions and signs. The performance of the selected
alternative will be reviewed and evaluated every five years after initiation of the
remedial action to assure mat human health and the environment are being
protected. The sewers to the north of Fields Brook discharge west of State
Road and are therefore subject to residential CUGs. The sewers to the south of
Fields Brook discharge east of State Road and are subject to occupational
CUGs.
6) RMIMetab
For the RMI Metals source area. U.S. EPA selects Alternative IV. However, selection
of this alternative is based on the fstimatnd volumes and costs presented in the FS.
Should additional sampling find the extent of soil contamination to be greater than
currently known, cost estimates for Alternatives m and IV will be revised. If the
revised cost estimates demonstrate that Alternative in would provide significant cost
savings over Alternative IV, U.S. EPA may elect to allow implementation of
Alternative m instead of Alternative IV. Therefore, the implementation of Alternative
IV will be contingent upon its relative cost as compared to Alternative in. Because
there is a preference for permanent remedies that do not rely on O&M to maintain their
effectiveness, any cost difference between the two remedies will need to be significant
for U.S. EPA to approve implementation of Alternative m.

Alternative m requires the excavation of soil with PCB concentrations greater than or
equal to 50 ppm and oil-site containment of soil with greater than 10 ppm. Excavated
soil would be disposed of at either an on-site landfill (to be built on one of the source
areas) or at an off-site landfill, whichever is more cost-effective. Remaining
contamination would be contained on site. Alternative IV requires the excavation and
disposal of PCB-fiontaminated soil with concentrations greater than 10 ppm. Since

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surface soil contamination would be at or below 10 ppm total PCBs for both
alternatives, die result is essentially the same, assuming proper O&M for the
containment remedy. Bom the selected alternative (Alternative IV) and the contingent
alternative (Alternative ID) would reduce the volume of contaminants at the site and
comply with TSCA.

More specifically, the selected alternative and the contingent alternative include the
following components:

a) dear Debris and Vegetation / Remove Physical Hazards

In order to implement the Remedial Action, debris and vegetation must be
cleared in response and work areas. Physical hazards mat could threaten
workers must also be addressed prior to Remedial Action.

b) Excavation of Soils

Alternative IV requires excavation of soils with total PCB concentrations greater
man 10 ppm to meet the 1.3 ppm total PCBs residential CUG at the Brook and
its tributaries. During the remedial design phase, additional samples may be
required to further delineate the remedial response area.

Alternative 10 requires excavation of soils with total PCB concentrations greater
than or equal to SO ppm. Based on existing data, it appears mat limiting
excavations to a depth of approximately 1 foot should remove all TSCA-
regulated soil. However, this remedy requires removal of all TSCA-regulated
soils (* SO ppm PCBs). regardless of depth. Therefore, if areas of additional
contamination are identified, the excavation depth will be adjusted accordingly.
During the remedial design phase, additional samples may be required to further
the remoouJ (espouse •
For both alternatives, the excavation of soils would be accomplished using
conventional earth-moving equipment. Upon excavation, the soil would be
placed in lined roll-off containers or dump trucks for transportation to the
landfill. Following completion of excavation activities, the excavated areas
would be backfilled with clean soil or gravel and graded to allow for adequate
drainage. Gravel fill would be used in areas subject to vehicle traffic.
Verification sampling may be required to ensure removal of TSCA-regulated
soils and demonstrate compliance with excavation requirements.

For Alternative IV, it is estimated that an area of approximately 30 ft x 130 ft
in size would be excavated to a depth of 1-foot (Figure 9A). As shown in
Figure 9B, die FS estimated that to implement Alternative m, an area of

69
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approximately 20 ft x 80 ft in size would be excavated to a depth of 1-foot.
The excavated soils would disposed at either the on-site landfill (the SOU/FWA
consolidation area) or at an TSCA-compliant landfill.

c) Refinement of Area to Be Covered

If Alternative ID is ultimately implemented, soil loss calculations will be
reviewed during the Remedial Design to finalize the area to be covered. It is
currently estimated that soils with PCB concentrations greater than 10 ppm will
be contained by the cover system. The cover areas have been developed based
on current operations and include the proposed excavation area since it is
located within the cover ulterior. The extent of the cover areas may be altered
during Remedial Design if a; iimptions on future operations are revised.

d) Construction of Cover, Surface Drainage Controls

If Alternative m is ultimately implemented, the erosion control cover materials
will consist of a 12-inch thick layer of clean soil, an erosion control blanket and
will be vegetated to reduce the potential for erosion. For anticipated future
traffic areas, a 6-in. gravel layer underlain by geotextile will be used instead of
the soil.

e) Surface Drainage Controls

If Alternative ffl is ultimately implemented, on-site surface drainage will be
controlled. The erosion control cover design will include a sloped surface to
control drainage and prevent surface water from pooling on the surface.
*
f) Institutional Controls, Chemical Monitoring and O&M
No monitoring, institutional controls or 5-year review will be required for
Alternative IV.

If Alternative HI is ultimately implemented, institutional controls will be
implemented for any area where hazardous miKfrtanmt. pollutants or
contaminants will remain above levels that allow for unlimited use and
unrestricted exposure. More specifically, institutional controls will be
implemented to protect the cover system and drainage controls. Such
institutional controls will include deed restrictions, security fencing, and signs.

O&M for Alternative in will include regular inspections of the erosion control
cover to check for cracking and wear and die implementation of appropriate
repairs. Chemical monitoring requirements include the annual collection of

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total PCB surface soil samples.

Reviews of Alternative in will be required to be conducted every five years
after initiation of the remedial action to assure that human, health and the
environment are being protected by the remedial action. This is required
because hPTagdfflis tnibfflnyyyt pollutants or contaminants will remain on die
facility and on-site above levels that allow for unlimited use and unrestricted
exposure.

g) Points of Compliance
v
Alternative IV must meet residential CUGs at the Brook. Based on calculations
performed during die RI/FS process. Alternative IV will prevent CUG
in the Brook. The alternative requires no O&M, long-term
monitoring, or institutional controls.

If Alternative m is ultimately implemented, O&M, long-term monitoring and
institutional controls will be/required. In conjunction with completion of the
Remedial Action for Alternative m and performance of required O&M, erosion
and runoff from the RMI Metals facility must meet residential Cleanup Goals
(CUGs) established for die FWA and Sediment Operable Units. At a minimum.
the points of compliance are the property boundary and die edge of the
floodplain. Additional performance monitoring locations may be identified
during remedial design.

B) ARARs To Be Met

Section 121(d) of CERCLA requires that Superfund remedial actions meet ARARs. In
addition to ARARs, die ARARs analysis which was conducted considered guidelines, criteria.
and standards useful in evaluating remedial alternatives. These guidelines, criteria, and
standards are known as TBC '"to be considered"). In contrast to ARARs, which are
promulgated cleanup standards, standards of control, and other substantive environmental
protection requirements, criteria or limitations. TBCs are guidelines and other criteria that
have not been promulgated or are not directly applicable. The selected remedy will comply
with the ARARs and the TBCs listed in Table 2 which is attached to this ROD.

Two of the important action-specific ARARs for remediation of die source areas are the
Ambient Water Quality Criteria and die Ohio Water Quality Standards, which contain specific
standards that would be applicable if remediation water or treatment plant wastewater is
discharged directly to Fields Brook or the Ashtabula River. In addition to the water quality
criteria, substantive requirements of National Pollutant Discharge Elimination System
(NPDES), as implemented under Ohio regulations, would also be applicable to wastewaters
planned to be discharged to Fields Brook which will require treatment. These wastewaters

71
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include liquids generated during construction activities such as dewatering liquids, excavation
area liquids, and liquids generated during construction of the on-site consolidation area.
Discharges to Publicly Owned Treatment Works (POTWs) may be pursued as an alternative
discharge location. However, such discharges must also comply with limitations to ensure
acceptable discharge from the POTW after treatment. The specific discharge levels will be
determined during the design stage in coordination with OEPA.

A large portion of the soils and sediments to be excavated from the source areas for disposal
into the on-site consolidation area landfill will contain PCBs exceeding SO ppm. Excavation of
these wastes and soils and containment in an on-site landfill will be considered disposal of
PCBs pursuant to 40 CFR 761. l(b). In this case. 40 CFR 761 -60(aX2) requires any non-
liquid PCBs at concentrations of SO ppm or greater in die form of contaminated soil, rags, or
other debris to be disposed of in w incinerator which complies with 761.70 or in a chemical
waste landfill which complies with 761.7S.

Regulations related to the dewatering of the soils and sediments prior to consolidation must be
met, including 40 CFR 264.228(a)(2). which requires elimination of free liquids by removal or
solidification. Thus, it is required that dewatering of the excavated soils and sediments to be
landfilled will occur in part to ensure that no tree liquids will remain in the soils and sediments
prior to disposal into the landfill unit.

Treatment and air emission requirements relevant to hazardous waste in 40 CFR 260-268 could
be potential ARARs for facilttiflg where listed or characteristically hazardous wastes are
known to have been disposed of in the source control areas.

Actions must be taken to minimise the destruction, loss, or degradation of wetlands due to
construction activities and the final remedy.
XI. EXPLANATION OF SIGNIFICANT CHANGES

There is one significant change from the recommended alternatives described in the Proposed
Plan. The U.S. EPA is selecting Alternative IV at the RMI Metals source area, with the
contingent implementation of Alternative in if future volume and cost estimates prove
Alternative in to be significantly more cost effective than Alternative IV.

In addition, mere are some important clarifications in this ROD mat were not presented in the
Proposed Plan.

» For the Acme source area, Alternative VI was recommended in the Proposed Plan.
This ROD selects Alternative VI, but notes that consolidation may be an acceptable
component of the remedy.
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Based on public comment and a subsequent review of site data, the U.S. EPA has
determined that the Acme facility is subject to occupational CUGs, rather than
residential CUGs. This may result in a substantial decrease in the cost of remediation
for the Acme property.

For the Millennium source area. Alternative VI was recommended in the Proposed
Plan. This ROD selects Alternative VI, but notes that consolidation may be an
acceptable component of the remedy.

For the sewers source area, Alternative in was recommended in the Proposed Plan.
This ROD selects Alternative m and notes that, under this alternative, the containment
and replacement of sewers are not required if cleaning of sewers proves to be more
cost-effective.

As discussed above, Alternative m was recommended in the Proposed Plan for the
RMI Metals Reduction source area. Based on comments from the U.S. Fish and
Wildlife Service and discussions with the State of Ohio, mis ROD selects Alternative
IV, but allows for the contingent implementation of Alternative in should revised
volume and cost estimates demonstrate that a significant cost savings could be realized
by the implementation of Alternative m instead of Alternative IV.
XH. STATUTORY DETERMINATIONS

U.S. EPA's selected alternatives provide die best balance of trade-offs among alternatives with
respect to the criteria used to evaluate remedies. Based on the information available at this
time, U.S. EPA believes that these final Remedial Actions are protective of human health and
the environment, comply with Federal and State applicable or relevant and appropriate
requirements and are cost-effective. The selected remedial actions utilize permanent solutions
and considered use of alternative treatment technologies to die maximum extent practicable.
However, due to the significant volume i.d heterogeneous distribution of waste at the Site,
treatment as a principle element is not considered practicable at the Site. Thus, these remedies
do not address the statutory preference for treatment that reduces toxicity, mobility, or volume
as a principal element. However, treatment is a secondary element in that DNAPL from the
Detrex facility will be collected and treated resulting in destruction of hazardous substances.

A review of the remedies will be conducted five years after commencement of the remedial
actions to ensure that the remedies continue to provide adequate protection of human health
and die environment by preventing the flow of contamination to Fields Brook.
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Table 1
Fields Brook Cleanup Goals rCUGs)
PARAMETER
Resideiitui Occupational TypeofExceedancein
CUG CUG Source Control Areas
Volatile Orgufe Compound*
1.1.1-TricUaradttne
l,l>TricbIorortb
U-Dkfalaroethene
1 .2-Dichloroelhen0 (bins)
Chlorofcnn
EtbyibenxGoo
. TctnchlororabcDc
Toluene
Vinyl Chloride
Semi-VcfatOeOrvuik
• « *t*™ 1 ndiiyn in pffi i?id iff
U-Dichlorobenzenc
1 ,4-Diduunutifii/iBne
2-Chlc*ophenol

Anthncene
Benzidcac
Bu(2-etbylhexyl)phtfaalate
Chiysenc
Di-n-butyl phthalate
Di-n-octyl pfathalite
Dicthyl pfatfaalate
Dimethyl phthaUte
393,451
SI
179
17
87.433
352
87.433
1.672
437.167
196
874435
927
5.4
43.717
393.451
425
21.858
262.300
1.311.502
.04
13.97
1.4
13.97
13.97
729
139.73
437.167
87.433
1.4
3.497.338
437.167
766.500
119
418
40
170.333
822
170433
3.909
851.667
459
1.703433
2.168
13
85,167
766.500
994
42483
511.000
2.555.000
.1
33
3.3
33
33
1.703
327
851.667
170,333
3.3
6.813.333
851.667
residential
occupational
residential / occupational
msidmtinl
-------
Table 1- continued
Fields Brook Cleanup Goals (CUGrt
PARAMETER
Fhurane
I IcxachlorobtiiiKiit
Henchkrabutadkn
Ideno(l.2J-cd)pyitne
Inophcfuue
N-ohYondipheny
/PCBa

BHC (alpha)
oHC (ffUXUDft J I ilUfMIVT

Total PCBi
Antimony
Arsenic
Boy Ilium
Cadmium
Chromium
Copper
Mercury
Nickel
Selenium
Thallium
Zinc
Cyanide
RnMfiititl '
CUG
174^67
174,867
6.38
131
729
14
10.737
2.081.75
174.867
.2.186
2,623.004
U11^02
1.6
7.8
2.3
1.3
1.749
27.6
2.4
2.186
21.858
161.752
500
1.312
87.433
21.858
262
847335
87.433
Occupational
CUG
340.667
340.667
15
306
1,703
33
25.102
4.867
340.667
4.258
5.110.000
2.555.000
3.8
18
5.3
3.1
3.407
28
5.5
4,258
42.583
315.117
500
2.555
170.333
42.583
511
1.703^33
170.333
Tvnr ftf EicftiltiHT in
Scarce Control Areas

•

AM«*m«ti«wft*l

residential / occupational
residential

-------
POTENTIAL LOCATION-SPECIFIC ARARS
FIELDS BROOK SITE • SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
Requirement
CommenU
Appropriate
Lawa/R.niilrrTff.tT
-A.
y
v\
FEDERAL REGULATIONS

B.P. m»» Protection of Flood,!.!™

I. Llmlti activities In noodpltlnt. Floodplain h denned u "the
lowland and rtlitlvely flu irew idjolnln| Inland and cowttl
waien including flood prone ana* of ofT-inon liluidi, '
Includlni at a minimum, that area lubject to a one percent or
•fewer chance of flooding in any given year." Federal agencies
mm t evaluate the potential effect! of action taken In a
floodplain and avoid advene Impacts from remedial activities
(40 CFR 6.302 and Appendix A]
E&
Yes
Itf
2. Minimiies advene Impacts on areas designated as wetlands.
HO CFR 6.302(a) and Appendix A]

Clean Wijer Act Section 404

3. Requires Federal agencies to avoid, to the extent possible.
adverse impacts associated with destruction or loss of wetlands.
MO CFR 230-231; 33 CFR 320-330)
Yes
Yes
• The FWA Is located wlihjn a 100-year
floodplain. If remedial activities are conducted
within the floodplain, or adversely affect natural
floodplain values, this regulation will be
applicable.
Wetlands are present along portions of Fields
Brook. Regulations are applicable only if
remedial activities impact the wetlands areas.
Wetlands occur along Fields Brook; regulations
would be applicable only if the remedial
activities impact the wetlands areas and/or other
waters of the United Slates.
f
rr

A/
I \DKOOH CttTMWECnVTAOLE ) WM-09 »J
Page 1 of 5
-------
POTENTIAL LOCATION-SPECIFIC ARARS
FIELDS BROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
Potentially
Applicable
Potentially
Relevant and
Appropriate
Comment!
c
%
*l
4. Prohibits discharge of dredged or filled material Into water! of
the U.S. without a permit. (40 CFR 230, 33 CPU 320-330)

Riven and Harbon Ad of 1899: Section 10

3. Section 10 permit required for itructures or work In or
affecting navigable waien. (33 USC 403,33 CFR 320-330]

Endinaered Specie. Act
Ye!
6.
Protect! endangered species and threatened species and
preserves their habitat. Require! coordination with federal
agencies for mitigation of impact!. (16 USC IS3I
SO CFR 200, 90 CFR 402)
Fish and Wildlife Coordination Act

7. Requires coordination with federal and stale agencies on
activities affecting/modifying streams or riven If the activity
his a negative impact on fish or wildlife. (16 USC 661 £lj£0,;
40 CFR 6.302(8))
Yes
Yei
Yes
Regulation! would be applicable if the remedial
action involve! dredge and/or fill activities in
Fields Brook
' If the remedial activity iffecti navigable waters.
these regulations are applicable.
If there are threatened/endangered (T/B) species
or critical habitat! within the areas impacted by
the remedial activities, this regulation would be
applicable. No such endangered specie! are
known within the area.
If Field! Brook will be impacted by rented!*!
activities, thii regulation would be applicable.
I.:UIROOKFS\TM]\SECT)\TABIE.)-M»-OM7
Page 2 of 5
-------
POTENTIAL LOCATION-SPECIFIC ARABS
FIELDS BROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASIITADULA, OHIO
Requirement
Potentially
Appllcibli
Potentially
Relevant and
Appropriate
Comments
12. Any activity modifying a ilream or river, which will have a
diversion, channeling or other action and which affects fish or
wildlife must be implemented with action to protect fish or
wildlife 116 U.S.C 661 el seq.)
Yes
(Source Conservation ind Recovery Act iRCRAl
13 A treaimeni/storaie/diiposal (TSD) facility within a 100-year
floodpliin mutt be designed, constructed, operated, and
maintained to avoid washout.
14. Landfills may not be located within vulnerable hydrogcology
areas. (RCRA 3004 (oX7)|.
Yes
Yes
This Act would only be applicable if:
(I) pollutants or dredge and fill are discharged
into a body «f water or wetlands, and/or (2)
dams, levees, Impoundments, stream relocation,
rip-rap or channeling activity, and/or water
•diversion structures are constructed, and/or any
other construction activity within or in the
vicinity of the stream which affects fish or
wildlife.
This requirement would only apply to
permanent hazardous waste landfill located
within the site and located within a 100-year
floodplain. Interim storage does not n»rd tq
attain ARARt, if the appropriate interim storage
requirements are met.

This requirement would only apply, if a
landfill is proposed to be placed within a
vulnerable hydrogeology area.
L vtmooKi SUMJVSECT MABLC J.JVBJ w »J
Page 3 of 5
-------
POTENTIAL LOCATION-SPECIFIC ARARS
FIELDS OROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASHTADULA, OHIO
Requirement
CommenU
r
i.
I9S|C SupSiaiKTS Con.ml Aq
15. Requires that TSCA landfills meet specified siting, design,
handling, and monitoring requirements (40 CFR 761.60 and
761.75 (B)J.
STATE STATUTES AND REGULATIONS
gfflO Hawdoui Waite Sli|nB
Yes
These regulations would apply if a remedy
includes construction of a TSCA landfill or if a
remedy Includes disposal of material that
•• contains PCB concentrations at or greater than
50 mg/kg. Interim storage does not need to
attain ARARs If appropriate interim storage
requirements are met. .
I. A hazardous waste facility installation and operation permit
ihall not be approved unless It proves that the facility .
represents the minimum risk of all of the following:

(i) Contamination of Ground and Surface Water
(ii) Fires or Explosions from Treatment, Storage or Disposal
Methods
OH) Accident during Transportation
(iv) Impact on Public Health and Safety
(v) Air Pollution
(vi) Soil Contamination
(ORC 3734-06 (D) (6) (d)J
Yes
Yes
Would be an ARAR if (he remedy involved
treatment, storage or disposal of hazardous
waste.
L\BROOKFSvrMJ\SECT)\TABlE.)-]tt>-0«-*7
Page 4 of 5
-------
POTENTIAL LOCATION-SPECIFIC ARAKS
FIELDS BROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Applicable
2. Prohibit* the following location* for treatment, storage, and
diipoul of acute hatardous wute: (I) within 2,000 feet of any
residence, school/hospltal, jail, or prison; (2) any naturally
-\ occurring wetland; (3) any Hood hazard area; (4) within any •
r state park or national park or recreation area.
T " IORC 3734.03
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE • SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Applicable
Potentially
Relevant and
Appropriate
Comment*
FEDERAL REGULATIONS

To«ic Substances Control Ac. fTSCAl

I. Establishes regulations to govern the storage and disposal of ' Yes
PCBs including PCB-contaminated soil. [40 CFR 761)

2. Prescribes design, construction, and operation standards for Yes
TSCA landfills. (40 CFR 761.73)

Specifies requirements for disposal of materials containing Yes
PCBs. (40 CFR 761.60)

Establishes standards for PCB incinerators, Including Yes
combustion criteria, combustion efficiency, other operating
standards, and monitoring requirements.
|40 CFR 761.70)
3.
4.
TSCA regulations for storage and disposal could be
applicable to disposal of PCB contaminated soils.

Only applicable for alternatives that Include disposal
of TSCA materials.

The
-------
•\
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS OROOK SITE - SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Potentially Reterut and
Applkable Appropriate
Comments
Clean Air Agj

National Ambient Air Quality Standards fNAAOS)

3. Establishes ambient air quality standards to protect public • Yes Unknown
health and welfare. Includes National Primary and
Secondary Ambient Air Quality Standards for Paniculate
Miller. (40 CFR 90]

Ambient Air Moni|orjng •

6. Specifies methods for conducting ambient air monitoring. Yes ~
140 CFR 33|

Safe Drinklnt Water Act

Undcriround Inlecilon Control (UjC)

7. Establishes standards for injection wells to provide protection Unknown . —
of underground sources of drinking water. (40 CFR Parts
144-148)
Only applicable if criteria pollutant! are discharged
to the atmosphere during waste handling or a
treatment process. NAAQS would t* uteri to
compare ambient air quality during the remedial
action.
Would only be applicable to actions resulting In
emissions of pollutants.
If the remedial action alternative involves
underground Injection, these regulations could be
applicable.
L\BROOKFS\TM)\FDI7\SECT)\TAni.E.).)ttS09-9?
Page 2 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS DROOK SITE - SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Potentially Reform! and
Applicable Appropriate
Comment*
CJeanWaier Act
H
National Pollui.nl DI*charM Elimination System (NPDES>

8. Require* dischargers of pollutants from my point source into
surface waters of the United States to meet certain
requirement* and obtain a NPDES permit. (40 CFR 122, 123
•and 123 are Involved)
Ye*
Ambient W.ter Quail,, Criteria

9. Requires EPA to publish water quality criteria for specific
pollutants for the protection of human health and the
protection of aquatic life. (40 CFR 1311

National Pretrealment Siandanh
No
Yes
No permit would be required for in on-site
CBRCLA remedial action that involves a dlwharge.
but the substantive requirement* of the NPDES
program would apply if the remedial action
involve* surface water discharge, ThJsARAR
would be applicable or a substantive modification to
an eiNnt PDBS permit may be needed for the
following remedial alternatives: a) the Deirex
facility UNAPL alternative* where the DNAPL
would be collected and treated on-slle; b) the sewer
flushing alternatives where releases to Fields Brook
may occur, c) on-site treatment of contaminated
water generated during construction (e.g.,
leachate/diainage water, decon fluids, etc.). Other
alternatives may also be required to meet this
ARAR if a point source occurs during remediation.
Relevant and appropriate if contaminant* are
released to surface waters or if treated groundwatcr
is collected and discharged to surface waters.
L \DROOKrS\TMJ\F8l7\SECT J\TADLEJ«>H».»7
Page 3 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS DROOK SITE - SOURCE OPERABLE UNIT
ASIITABULA, OHIO
Requirement
10. Establishes general and specific «t*ndards for pollutants that
are discharged to a POTW. (40 CFR 403)

Storm Water Discharge Regulations

11. Establishes permitting, sampling and analysis requirements
for industries in certain categories which discharge storm
water to waters of the United States. Includes storm water
discharge from construction activities. (40 CFR 122)
Potentially .
Potentially Relevant and
Applicable Appropriate

Yes .-
Yes
CommfnU
If thf remedial action involves discharging to a
POTW, these standards would be an ARAR.
No storm water permit would be required for an on-
sile CBRCLAJtemedial action that involves a
discharge. Subsfntive requirements (e.g.. Storm
Water Pollution Prevention Plans) could be
applicable.
Discharies of Dredged or Fill Materials

12. Prohibits discharges of dredged or fill materials Into waters
of the U.S. without a permit. (33 CFR 320 to 330. Section
401 and 404 of Clean Water Act]
Yes
Regulations would be applicable If the remedial
action Involves dredge and/or nil activities in Fields
Brook.
L:»OROOKFS\TM)\rDI7\SECTJ\TABI.E.).M>30»9J
Page 4 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE • SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Rcqulrcmtnt
PotentlaUy
Potentially Rcltrwl ind
Applicable ApproprUU
CommenU
Ael (RCRAl
faHWM Conservation .nd Recc

PCRA OTCCllvr Aciion M.nt.^nt Unit Rule

13. Providei for designation of • Cornellve Action Minagement •
Unit tnd euei regulatory requirements for remedial actions
conducted within unit boundwtei. (40 CFR 260 et al]
No
Yes
Would be potentially relevant and appropriate
requirement for management of hazardous waste
within the plant sites.
L:\BROOK FSYTMWBIMCCTMABLE J-WM-OT »I
Page 5 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE - SOURCE OPERABLE UNIT
ASIITADULA, OHIO
Requirement
Potentially
Potentially Relevant aad
Applicable Appropriate
Comments
RCRA
Dliooul (TSD1
14. Prevlde* regulations for the notification of hazardous waste
•divides, identification and listing of hazardous wastes and '
management of hazardous wastes by generators, transporters
•nd operator* of treatment storage and disposal facilities. (40
CPU 260 et at). Specific RCRA TSD rrjiulatlons that may
need to be evaluated as potential ARARs on a case-by-case
basis include:
•) 40 CFR 268 (movement of excavated materials)
b) 40 CFR 6, Appendix A
c) RCRA 3003
d) 40 CFR 262 and 263
e) 40 CFR 170-179
0 EPA Hazardous Waste Permit Program
(promulgated In part as 40 CFR 300.440
(9/22/93)).
g) RCRA Section 3005
h) 40 CFR 270 and 124
i) 50 FR 45933(11/3/83).

15. Specifies performance standards and other operating
requirements for incineration of hazardous waste. [40 CFR
261.340 to 261.351)

16. Specifies requirements for closure of hazardous waste
management units. [40 CFR 264.1 1 7(c). 228(a) and (b). and
3lO(a) and (b)|
L:WROOKFJ\TM)\FBI7\SOCTJ\TABLE)-)»}09.»7
Yes
Yes
Yes
Substantive requirements would be potentially
applicable to any hazardous waste landfill built at
the site. However, contaminated soils In the SCOU
are not known to be hazardous wastes pursuant to
RCRA or the Ohio solid wa*e disposal statute .
Oven If contaminated soil were considered solid or
hazardous wattr. designation of a corrective action
management unit would allow movement of soil
without triggering the Lawl Disposal Restriction
regulations.
These requirements would tpply If chosen
alternatives include incineration.

Some of these requirements would apply if
containment or other on-sile disposal of RCRA
regulated hazardous waste is a selected alternative.
Page 6 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE - SOURCE OPERABLE UNIT
ASHTADULA, OHIO
«
g
17. Thete regulations establish sunduds for design Instillation.
and maintenance of dikes around • unit, to ensure the unit
does not fail or overtop, and to remedy problems and any
contamination. (40 CFR 264.22I(|) and (h), and 261.277]

RCRA Land Dlsnoul Restrictions

II. Establishes a timetable for restriction of land disposal of
hazardous wastes and treatment criteria of hazardous waste
prior to land disposal. (40 CFR 268]
RCRA Solid Waste Treatment Storaie f nd Ditoostl (TSD1
Reiulailonf

19. Establishes requirements for owners and operators of solid
waste disposal facilities (40 CFR 238)
Potentially
Potentially Rdevutand
Applicable Appropriate

Yes
Yes
Yes
Commend
These regulations would apply If remedies selected
include installation of a dike around • hazardous
waste management unit.
Substantive requirements would be potentially
applicable if hazardous wastes are generated during
remedial activities and disposal is off site.
However, only applicable If no equally or more
stringent State regulation exists (see below).
Substantive requirements would be potentially
applicable If solid wastes are generated during
remedial activities. However, only applicable if no
equrlly or more stringent state regulation exists (see
below).
I.\jmOOKrS\TMJ\FBI7\JECTJYMBLe J-J»1-0»-9J
Page 7 of 12
I
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS DROOK SITE - SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Potentially Relevant and
Applicable Appropriate
ComrotnU
STATB REGULATIONS
g"IP HMlpnaJ Pollutant Pitch.™ BHmln.t|?n {fy..m
C I.
f>
M
Requires permit! for the discharge of polluitnU from any
point source into waters of the United Slates. Must meet
technology.based effluent limitations and standards (either
"best conventional pollutant control technology* or "best
available technology economically achievable"), determined
on a casc-by-case basis. (OAC. Title 3743, Chapter 33)
PMff rVTreatmr, nt Rmuir^^,
2
Rc|ul«esihcdiKhw|eorpollulMtiloPOTWs. (OAC.
Till* 374J. Chapter 3}
Ptrfp Non-Point Source ReffHm!
3.
Regulations call for the use of conservation practices to
control sediment pollution of water resources.
IOAC, Title 1501. Chapters I, 3, 5)
Ohl°
4.
establishes minimum water quality requirements for all
surface waters of the state. Establishes stream use
designations and water quality criteria protective of such
u«es. See Table 4-3. [OAC. Title 3745, Chapter I]
Yes
Yet
Yes
Yes
Yes
Applicable if the remedial action involves discharge
to surface water located oiT-sita oj[ relevant and
appropriate for discharges to on-slle surface water.
Subslanlive*iequirements must be met, but no
permit will be required for on-slte discharges.
Applicable if groundwater or waste/treatment water
from the site is discharged to the POTW.
These regulations could be applicable for any major
earth-Hlsiuibing activities.
Applicable if contaminated water is discharged into
surface waters.
L \HROOKFS\TM)\fDI7\JECT)\TAOLe) )»JO»-»7
Page R of 12
-------
POTENTIAL ACTION-SPECIFIC AltARS
FIELDS BROOK SITE • SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Potentially Referral tad
Applicable Appropriate
Comment!
Ohio Haianlous -Waste Min«iement Remlalloni

3. Provldw regulations for the notification of hasardoui waste
activities, (tatlficaiion and listing of haiardws wastes and
management of hasardous waste* by generators, transporters
•fid operators of treatment storage and disposal facilities.
IOAC, Title 374S, Chapters 30-69]

Haiatdous Waste Manaiement Systems. General

6. Establishes procedures and criteria for modification or
revocation of any provision in OAC, Title 3745,
Chapters 50-69.

Identification and Lhlint of Hazardous Wastes

7. Defines those solid wastes which ire subject to regulation as
hazardous wastes (OAC, Title 3745, Chapter 51].
Standards Applicable to Generators
w"le
8. Establishes standards for generators of haiardoui waste
IOAC, Title 3745, Chapter 52).
Yea
Unknown
Unknown
Unknown
Substantive requirements are applicable If remedial
actions Involve management of hazardous wastes
and construction of on-slte hasardous waste
facilliy(les), and the requlremf nu are more stringent
than the federal.
May be applicable if a contaminant is to be
excluded from list of items defined as hazardous
waste.
Applicable if remedial action involves generation of
hazardous wastes.
Applicable If remedial action Involves treatment.
temporary storage, or off-siif disposal of ha«ardn,«
waste.
Page 9 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE - SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Requirement
Potentially
Potentially ReUrutaod
Applicable Appropriate
CommcnU
Slindiidi Aw|fcrfr|y !? Transporters of Hatardous Waste

i 9. Biubllthei itairiaidi which apply to persons transporting . Yet
"I huantoui waste within the U.S. if the transportation requires
- . a manifett (OAC, Title 3745, Chapter 52 and S3).

Slandai^ for Qwneta and Onemtoni of HattfJous Waste
. Trcatmen^ Storae^ apd Disposal Facillllei

10. Bitibliihet minimum standards which define the acceptable No
management of hatardous waste for ownen and operaton of
permitted facilities which treat, store, or dispose hatardous
waste IOAC. Title 3745. Chapter 54). -
Interim Standards for Owners and Operators of Haiardous Waste
Treatment. Storaae. and Dlinoul Facilities
•
II. Establishes minimum standards that define the acceptable No
management of hazardous wute for impermltted treatment,
storage, and disposal facilities during the period of Interim •• .
status and until certification of final closure or, If the facility
is subject to post-closure requirements, until post-closure
responsibilities are fulfilled (OAC, Title 3745, Chapter'65].
Yes
Yea
Applicable If remedial action involves off-site
transportation of hazardous waste.
Relevant and appropriate if remedial action involves
stockpiling, treatment, or disposal of hacardous
waste. RCRA standard coven are not ARARi for
the mining residuals pile at the SCM - Plant II
TK34 facility. A detailed analysis of this
conclusion will be provided In a separate
submission to USEPA.
May be relevant and appropriate if units at the site
are operating under interim itmtus regulations.
RCRA standard covers are not ARARs for tl»e
mining residuals rile at the SCM - Plant IIT1CI,
facility. A detailfd analysis of this concluiion will
be provided in a separate submission to USEPA.
L.\DROOXrS\ft'"*l)l7\SECT)VTAOLE.)-)ttS-OM)
Page 'Oaf 12
-------
'•&
)TENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE - SOURCE OPERABLE UNIT
VSIITABULA, OHIO
Requirement
Potentially
Potentially Relevant and
Applicable Appropriate
Commenli
12. Eiiiblishes • limetoble for restriction of land disposal of
hmrdoui wuiei (OAC. Tllle 3743. Chapter 59J.
Ohto Solid Wf ,,t pJTrTr|
19. Establishes requirement* for lic*niln|. looting, constructing,
operaiing, and clot in( of wild wuie facilities (OAC, Tllle
3745. Chapffr 27J
Yes
Ye*
Ye*
fihip AfflMenl Air Oualltv Stand.^ ffifKj gy^lin.,

M. Buabliihe* ambient air quality itandaidi for criteria
pollutant* applicable in Ohio. Requite* attainment with the
Mndaidi through application of pollution control technique*.
IOAC, Title 3745, Chapter 21)
Ye*
Applicable If the remedial action involves off-site
land disposal of hazardous waste.
Applicable if the remedial action involves the land
disposal of Industrial or municipal nonhazardous
•olid waste.
May be applicable if the remedial action chosen
involve*, air emissions of any criteria pollutants.
L \BROOKFftTMJ\FBI7\SECTJ\TADLE I.WM-OM;
Page 11 of 12
-------
POTENTIAL ACTION-SPECIFIC ARARS
FIELDS BROOK SITE • SOURCE OPERABLE UNIT
ASHTABULA, OHIO
Other Ohio Air
13. AmMemAlrStamiardi(OAC3743-l7.02(AX(B),aiid(C)
"I 16. ReitrkUoni of Fugitive Du«U (OAC 3745-17-08)
£ 17. Control of Emission of VOCl(OAC 37^21^)9)
M II. Ambient Air SUndudi of Lead and Inorganics.
(OAC 3743.71-02 and -82-l2(A). (B), and (C))
• 19. Stile Permit Requiremenu for Bmlnioni in Atuinment
Areu (OAC 3745-31, «id 33)
20. Slue Permit Requiremenu for Emluions in Prevention of
Slinlficim Detericniion (PSD) AKM. (OAC 3704 and
3745-17, IB, 21, and 71)
Ye»
Yet
Yd
Yes

Yei

Yei
l\B»OOKPS\TMI\FBI7VSECTJ\TAOL6.3 l«l W»J
PagC 12 Of 12
-------
POTENTIAL ACTION-SPECIFIC ARARs
SURFACE WATER QUALITY STANDARDS
FIELDS BROOK SITE • SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO

*— 1*
Pwaarium Maul
AlttOUDUaiD Mflttl
Anenic Maul
Anaafclll Maul
Anenic V Metal
Barium . Metal
BoyliiuoV Mettl
Cadmium* Meul
Calcium Mettl
Chromium (Total)* Mettl
Chromium III Metal
CbnaiumVI Mettl
Cobalt Maul
Ira (Wai) Maul

Iran (oliMlved) Maul
Lead* Metal
Majnetium Metal
MMIUWM Mettl

mUAL CtrmiA
CWA AWQC fcr Fntecte of MM* Vtf
Aato
Vaaaa

750

360
850

130
5.7(33)

2300(8,500)

125(970)

Vaaaa

190
48

5.3
1.5(5.2)

2700400)

; ijno

4.9(38)

Water*
H*

^•JaJlP

IflOO
0068
10

170000

300

50
50
la*^
-------
ARARs
SURFACE WATER QUALITY STANDARDS •
FIELDS BROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO

Parameter Type

Mercury Meui
Nkk"' Metal
Sodium Meul
Varudium Mett|
ane' Meul
Chloroform Voletile
I.l.2.2-Tetnchloroethane' Volatile
1.1.2-Trichloroethane Volatile
1.2-Dkhloroethane' Volatile
I.l-Dkhloreethene' Volatile
Vinyl Chloride' Volatile
Tetnchloroethene' Volatile
Trichloroeihene (TCE) Volatile
1.2-Dlchlorobenune Semi-Volatile
1.2.4-TricNorobenzene Semi- Volatile
Mrt Arhtrvntwii •••••* * i • i i • .
nuKiuoroDeiUcnc Seml-VoliUle
He«achlorobuudiene' Semi-Volaiile
He»echloroethane' Semi-Volatile
FEDERAL CRITERIA
CWA AWQC for FnrtecUoa of Aqoatle Ufe'

Acute
Value

2.4
•1.900(7.400)

160(610)

118.000
11.600

5.280
45,000

90
980

Chronic
Value

0.012
210(820)

141(551)

2.400

20,000

840
21,900

9.3
540

Water*
Ftih
lafaetfoa
a 144
13.4

1.7

0.94
0.3J
20
0.8
27

.0072
4.5
1.9

nth
Consumption
Only
0.146
100

107

243
18.5
5.250
8.85
807

0.0074
500
8.74
STATE STANDARDS
Attainable or Detlfoaled Uie*
Aquatic Lift

Anil* Value

I.I
2.100(8.500)

160(600)

1,001

12.000
1.500

540
1.700
160
150

Chronic
Value
0.20
f. 232(940)

140(550)

360

3.500
78

7.'
73
II
77

Human Health

Fish*
Water
0.012
610

5.000

1.7

?.8
0.57
2.0
320
5.0

0.96
4.5
19
Fbh

0.012
4.600

107

990
32
5.250
3.500
80w
}
8
0.9W
xxa
87.4U
.7\$ECTJ\TABLE.W«J-0».97
Page 7 of 3
-------
, ACTION-SPECIFIC ARARs
SURFACE WATER QUALITY.STANDARDS
FIELDS BROOK SITE • SOURCE CONTROL OPERABLE UNIT
ASIITABULA, OHIO
Parameter Type
«-CMe«>.1.meihylphenol Send-VoUUIt
Wm-BAjrl-henyOphUwiM, Semi-Volatlle
PCS.' rcg
• FEDERAL CRTTBJUA
CWA AWQC for Protection of Aquatic Lift'
Acute
Value
2.0
Chronic
Value
0.014
Water*
ffch
iBfeetfM
DflQQ
0.00079
rah
CoMumptlOB
Only
90.000
0.00079
STATE STANDAWW
Attalubli or DtdtMM UM
Aqo»tle Life
AnrttViliN
MOO
Chronic
Valut
8.4
0.001
Huron Health
IWiA
WiUr
18
0
Fbh
59
0.00079
J CWA - The federal Clean Water Act, Section 303.
AWQC • Ambient Water Quality Criteria. eiubUihed pursuant to the Clean Water Act
Qu«mlUe« are uprated In uj/l unlett otherwite noted.
EPA. Water Quality Criteria for Protection of Aquatic Ufa. 1986.
' Carclnoieni; human health lundardi for thete parameter* are bated on a ritk factor of 10». herdnett
•Hardnen dependent. Valuei are for the Aihtatwla River and are bated on an awaja hardnen of 140 mf/L The valuee given In paranlheit* are for Heidi Broc^ end •» bated on a naronw
of700m|/l.
L \SROOKFS\TMJ\raiMECTJ\TABLE >-4»3fl».«
Page 3 of 3
-------
HBBMB^a^!^^^^*

OTHER MA'
: MATERIAL TO BE CONSIDERED (tBCs)
FIELDS BROOK SITE - SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
GuMellat, Standard, etc. TIC
PCB Spill Policy, « 40 CFR 761.120 lo 761.139
Why Ihb to • TBC
aodootaoARAR
ConuncnU
vl Guidance on Remedial Actions for Superfund Sites with
PCB Contamination, USEPA. August 1990

RCRA Design Guidelines for capping

RCRA Permit Writer's Guidance for TSD facillUes

NPDES Best Management Practice Guidance (EPA 83/2-R-
92-003 and 006; September 1992)
CERCLA Site Discharges to POTWs (EPA 340/0-90/005; •
August 1990) •
Requirements for Hazardous Waste Landfill Design,
Construction and Closure (EPA 623/4-89/022)
Not promulgated
The TSCA PCB Spill Cleanup Policy
b not • potentially applicable or
relevant and appropriate requirement
tor Superfund rapo&M Ktirai (tea 39
FR 62793-94)
Applies only to spills that occurred '• •
' after May 4, 1987

Not promulgated
Guidance only

Not promulgated
Guidance only
Not promulgated
Guidance only
Not promulgated
Guidance only
To be considered if alternative includes
cleanup of PCB • contaminate*! soil
To be considered in reference to PCB
remediation activities

To be considered for alternatives that
Involve containment

To be considered for alternatives that
involve treatment, storage, and/or disposal

To be considered for alternatives that
include discharge of waste water and/or
norm water

To be considered for alternatives that
includ". itischarge of *«iie water and/or
storm wntrr to POTWs

To be considered for alternatives that
include containment
L:\BROOKFS\TM *" '7\SECTJ\TABLE.J-5VM-0».»7
Page 1 of 2
-------
MATERIAL TO BE CONSIDERED (TBCs)
FIELDS BROOK SITE • SOURCE CONTROL OPERABLE UNIT
ASHTABULA, OHIO
GuhMlot, Standard, tte. TBC
Why thai b • TBC
and not an ARAR
Comments
Technical Guidance Document- Final Covers an
Hatardotts Wute Landfills and Surface Impoundments
(EPA 53WW-89-047; July 1989)

TSCA's "Outdance Documenl for • 40 CFR 761.73
L«»«TiU Application"

Interim Guidance on non Non-Liquid PCB Disposal
Methods to be uied u Altemativei to • 40 CFR 761
Chemical Waste Lmdnil (July 3. 1990)

RCRA Corrective Action Strategy, 61 FR.19.43" (1996)

HWIR Contaminated Media Rule, 61 FR 18,780 (1996

TSCA Spill Cleanup Policy (40 CFR 761, Subpait 0]
• Not promulfaied
• Guidance only

• Not promulgated
• Guidance only
• . Not phMnulgaled
• Guidance only

• Not promulgated
• Ouiduce only

• Not promulgated
• Guidance only

• The TSCA PCB Spill Cleanup Policy
U not • potentially applicable or
relevant and approprltte requirement
for Superfund mponM actions (tee 59
FR 62793-94).
To be considered for alternatives that
include containment

To be considered for alternative* that
include landfllling of PCBs
To be considered for alternatives that
include disposal of PCBs
L VMOOKFS\TM)\FBIT\SECTJVTABLE.J.«» W-9J
Page 2 of 2
-------
FIELDS BBOQK SUFOEUD SITE
AahtabulA, Ohio
N.
FIGURED
LOCAnONMAP
-------
Approximate Current
Watershed Boundary
3

t
*ii

J
figure te
-------
Source Control Slto Map
(Industrial Portion of Reids Brook Watershed)
-------
E.2HL
MIT OF
EXCAVATION AREA
LIMIT OF AREA
TO BE COVERED
LIMIT OF POTENTIAL
RESPONSE AREA
Acme Scrap Iron & Metal Company Site Map
-
-------
FIELDS BROOK
K« CONCENTRATION
NORTH TRAFFIC AREA
PC* CONCENTRATION
»Wmgta
ACTIVE
PORTION OF 0
THE FACILITY
MINING
RESIDUALS
PILE
CONCRETE PAD
(SOILS PILES)
PLANT
PROCESS
AREA
LAYDOWNAREA
Milennium TiCI., Site Map
-------
ASHTABULA
RIVER
OOMMCSSM WUWO
EXCAVATION AREA

CONTAINMENT AREA
Conrail Site Map
-------
RMI SODIUM
LANDFILL
APPROX EXTENT
OF DNAPL PLUME
30"*
0 CULVERT
TREATMENT
AREA
EXISTING
SURF
WATER
HOLflme
TANK
APPROX EXTENT
OF DNAPL PLUME
DETREX
CORPORATION
SLURRY WALL
CATALYST PIES
(PLANNED EXCAVATION)
OUTFALL
COLLECTION AREA
DETREX Site Map
^
-------
9 in. ou. vmHFco—
-------
f)gg 717

AREA TO BE
EXCAVATED
(>10 ppn-'PCBs)
RMI METALS
BULDMQ
APFROK
AREA
>SO pan PCBs
-------
EAST 21ST STREET
400FETT
AREA TO BE
COVERED
SCALE IN FEET
RMI METALS
BUILDING
AREA TO BE
EXCAVATED
COVERED
\
RAILROAD
rhav^r*.
taJ
-------
-------
ATTACHMENT 1 TO TWP RETPED OF nFTTSIfW SUMMARY

RESPONSIVENESS SUMMARY
SOURCE CONTROL OPERABLE UNIT
RECORD OF DECISION
FIELDS BROOK SITE, ASHTABULA OfflO
PITPPQSF.
This responsiveness summary has been prepared to meet the requirements of Sections
113(kX2)(BXiv) and 117(b) of the QMnprchensive Environmental Response, Compensation,
and liability Act of 1986 (CERCLA), as amended by the Superfund Ainemiingma and
Reauthorization Act of 1986 (SARA), which requires the United States Envir
Protection Agency (U.S. EPA) to respond to the comments submitted, either written or oral
presentations, on the proposed plan for remedial action. All comments received by U.S. EPA
during the public comment period were considered hi the selection of the final remedial
alternative for the Source Control Operable Unit

This document summarizes written and oral comments received during the public comment
period of July 24, 1997 to September 22,1997. The comments have been paraphrased to
efficiently summarize them in mis document. The public meeting was held at 7:00 p.m. on
July 31, 1996 in the Auditorium of the Asbtabula Campus of Kent State University in
Ashtabula Ohio. A full transcript of the public meeting, as well as all written comments
received during the public comment period and all site related documents, are available for
review at the Information Repositories, at the following locations: 1) Aahtuhiila County
District Library, 335 West 44th Street, Ashtabula, OH; and 2) U.S. Environmental Protection
Agency, Waste Management Division, Records Center, 7th Floor, 77 West Jackson Blvd..
Chicago, IL. •'
•

Comment HI
ECKENFELDER, INC OB behalf of RMI Titanium Company

ECKENFELDER, INC. comments that the proposed alternative for the Detrex facility should be
enhanced to provide better protection for the adjacent RMJ Sodium Plant ECKENFELDER
noted that DNAPL has been detected in at least one groundwater monitoring well on the southern
side of the RMI Sodium landfill. RMJ and ECKENFELDER recommend the installation of one
or more DNAPL recovery wells in the vicinity of the southern edge of the landfill (in the general
vicinity of monitoring well RMI 2-S. Vacuum-enhanced extraction in horizontal wells should be
considered.

Response: ECKENFELDER and RMI are correct that DNAPL has been detected in
the groundwater on the RMJ property. ECKENFELDER and RMJ's

Responsiveness Summary - Page 1
-------
recommendations fell within the scope of the selected Detrex remedy. The
number, placement and type of extraction wells will be determined during
the Remedial Design process.

Comment #2
ECKENFELDER. INC on bduut of BM1 Titanium Company

ECKENFELDER, INC. notes that, based on pilot testing of the vacuum-enhanced extraction
system, the design radius of influence for the test well as approximately 20 to 30 feet. Based on
this data, Woodward-Clyde calculated a spacing of 40 to 60 feet between wells.
ECKENFELDER commented that, "if the spacing design is based on the radius of influence, then
the basis for the design is flawed. The radius of influence does not directly equate to the zone of
capture. In a situation in which there is a sloping water table, which is the case tt the Detrex site,
the groundwater capture zone would be significantly less than the observed zone of influence.
Additionally, due to higher viscosity and capillary forces associated with the surface tension of the
DNAPL-water interface, the effective capture zone of the DNAPL would be significantly less than
that of the groundwater capture zone. The Source Control-Feasibility Study (SCFS) states that
Alternative IV would reduce the size if the DNAPL plume through extraction and treatment and
which would reduce the potential for migration of the DNAPL compounds to Fields Brook or the
DS Tributary. Based on the information presented in the Proposed Plan and SCFS,
ECKENFELDER, Inc. questions the effectiveness of Alternative IV to meet t*"» remedial
objective."

Response: Comment noted. During the design of the Detrex remedy, U.S. EPA will
reevaluate the spacing and placement of extraction wells to ensure capture
of DNAPL. However, complete removal of DNAPL is not expected.

Comment #3^~
ECKENFELDER, INC on behalf of RMT Titanium Company

ECKENFELDER, INC. notes that the slurry wall does not extend to the north of the Detrex
property and, as such would not prevent the migration of contaminants to the DS Tributary and
the RMI Sodium property. ECKENFELDER notes that the extent of DNAPL beneath the landfill
remains undefined. ECKENFELDER and RMI recommend additional investigation around the
perimeter of the landfill to assess the potential for DNAPL migration to RMTs property.
ECKENFELDER further recommends extending the shiny wad along the northern perimeter of
Detrex's property and, if DNAPL is identified along the northern perimeter of the landfill,
consideration should be given to the installation of DNAPL recovery wells in that area.

Response: U.S. EPA will require additional sampling during the remedial design phase
to better define the extent of DNAPL contamination that has moved into
the RMI property. As stated on page 8-30 of the SCFS,
Responsiveness Summary - Page 2
-------
"Additional design investigations would be needed to establish
design criteria for the selected alternative. These investigations
may include shiny wall compatibility tests and additional
geotechnical borings to locate the depth and position of the
containment structures. Waste characterization to evaluate soil
disposal options -would be needed to locate off-site disposal
facilities. Also, a pilot study to better evaluate DNAPL recovery
may be required during design. In addition, the extent of the
DNAPL phone particularly towards the northward direction onto
the RMI-Sodhanproperty in the vicinity of 'the landfill on RMI-
Sodium would'befurther definedduringdesign, and the position of
the extraction wetts and the slurry watt, if selected as components
within the final remedy would be adjusted or extended to ensure
that the DNAPL and contaminated groundwaterflowing towards
Fields Brook ortheDS Tributary particularfy along the northern
or western directions in these areas would be contained or
captured Design investigation drilling or installation of
extraction weMswiU not be conducted in the area encompassed by
the RM1Sodium Landfill"

The nmnbcr md placement of DNAPL recovery wcDs win be determined
during remedial design. Depending on the placement of wells and the
resuhmg capture zone, U.S. EPA may require the shiny waO to extend
along the north boundary of the Detrex property.

Comment #4
AquAcTcr on behalf of Mfflenniam Inorganic Chemicals

The goal of the source control cleanup is to remediate areas that could potentially recontaminate
Fields Brook. AquAeTer notes that Millennium is committed to a cleanup which meets or
exceeds this goal. A large portion of the Millennium facility drains to its Facility Storarwater
Collection Area (FSCA), which treats runoff prior to discharge under a National Pollutant
Discharge Elimination System (NPDES) permit. Outside of the FSCA, materials that erode have
the potential to recontaminate Fields brook. AquAeTer states that approximately 42% (by
volume) of the soils to be excavated do not have the potential to recontaminate Fields Brook and
notes that Millennium is demonstrating "good industrial citizenship" by its willingness to conduct
a cleanup which is more thorough and provides increased protection of human health and the
environment.

Response: Comment noted.
Responsiveness Summary - Page 3
-------
Comment #5
AauAeTer on behalf of MiDeanium Inorgank Chemicals
AquAeTer notes that the Proposed Plan Summary for the Millennium recommended alternative
states, "Annual O&M Cost: $2,011,000." AquAeTer commented that the annual OftM cost is
$43,000. The amount mentioned in the Proposed Plan ($2,011,000) is the sum of the indirect
capital costs for the alternative.

Response: AquAeTer is correct. The O&M amount stated in the Proposed Plan
summary is incorrect The ROD discussion of alternatives for the
Millennium source area lists the correct costs.

Comment #6
AqoAeTer OB behalf of MuTenninm Inorganic Chemicals

AquAeTer references a statement in the Proposed Plan Summary, "Soils with PCB contamination
greater than or equal to 50 rug/kg are regulated by the Toxic Substances Control Act (TSCA)."
AquAeTer comments that PCB contamination at the Millennium Plant n facility is considered a
historical spin under TSCA. AquAeTer states that because U.S. EPA designated the entire
watershed ^ncH^^g the millennium she) as a Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) she, the TSCA Office has no jurisdiction over the
current Millennhim she.

Response: Although the PCBs at the Millennium property may have been dumped at
the site prior to May 4,1997, TSCA is soil an applicable ARAR for the
CERCLA cleanup of the Fields Brook site. A strict interpretation of
TSCA as interpreted by the Standard Scrap decision would lead to the
conclusion that remediation of the PCB-contaminated soils would require
them to be removed from the improper disposal location and incinerated or
landfilled at a different she.

Comment #7
AquAeTer OB behalf of Millennium Inorgank Chemicals

AquAeTer notes that Millennium has proposed that its industrial waste landfill (currently under
construction) be used for disposal of soils to be excavated from the Millennhim TiCl« facility.
AquAeTer comments that the Millennium landfill has equivalent protection as would be provided
by a TSCA chemical waste landfill.

Response: The Region V TSCA Office has reviewed the landfill information submitted
by AquAeTer (May 22, 1997 letter from HoIIiday and Corn to Van
Donsd). TSCA has requested that additional information be provided in

Responsiveness Summary - Page 4
-------
order to complete its review of the Millennium landfill. Based on telephone
discussions between Van Donsd and Com, Millennium expects to submit
this information in early October, 1997.

Comment #8
AquAcTcr on behalf of Mfltennhim Inorganic Chemicals

The Proposed Plan states that, "chemical monitoring of outfalls would be conducted to evaluate
the amount of contamination moving from the she to Fields Brook." AquAeTer comments that
chemical monitoring of discharges from outfalls is neither required nor necessary. Millennium has
no effluent discharges to Fields Brook, therefore discharge monitoring should not be required.
Millennium's extensive monitoring of the faculty effluent within the last tea years (under the
NPDES permit program) has not detected PCBs. AquAeTer further states that, "the NPDES
permit program has determined mat it is not necessary for Millenniun. to test for PCBs in then-
discharge, and nehlier sho«ild the Proposed Plaan

Response: Comment noted. The Recontamination Assessment determined
that the only complete pathway for the movement of contamination'
is from the overland erosion of contanrnmtfid soil from areas
outside of the Facility Stormwater Collection Area (FSCA). This
assumes the continued operation of the treatment system, with
sufficient capacity to handle storm events. Surface water from
within the FSCA is currently treated in the facility wastewater
treatment system and discharged to Lake Erie under a NPDES
permit. After the completion of the remedial action, sheet flow
runoffwitt be monitored for CUG exceedances. The complete
monitoring program will be developed for the Operations and
Comment #9
U.S. Department of Interior - Trustee
The U.S. Department of Interior (U.S. DOI) is one of three natural resource trustees for the
Fields Brook she. The U.S. DOI is working with the Fields Brook Action Group in an effort to
address the issue of natural resource damages. The U.S. DOI defers to the State of Ohio and the
U.S. Fish and Wildlife Service to comment on the proposed alternatives for the Source Control
Operable Unit However, the U.S. DOI does request that U.S. EPA consult with the U.S. Fish
and Wildlife Service and the appropriate State agency during remedial design to select a seeding
mix and mowing regimen that will promote wildlife values consistent with erosion prevention and
maintenance of remedial action.

Response: U.S. EPA will consult with U.S. Fish and Wildlife Service and the State of
Ohio on the recommended cover vegetation for source control areas to be

Responsiveness Summary - Page 5
-------
remediated. However, H is important to note that the Source Control
Operable Unit is within an industrial area and, in some cases, the response
areas are immediately adjacent to areas with frequent industrial activity.
Selection of cover vegetation will be most critical for the
FloodplauVWetland Operable Unit.

Comment #10
U.S. Department of Interior - Fish and Wildlife Service - Trustee
The U.S. Fish and Wildlife Services comments that the Proposed Plan fails to provide a
justification for the recommended alternatives not meeting the "Statutory Preference for
Response: Section DC (Summary of Comparative Evaluation of Alternatives) of the
ROD discusses the "Statutory Preference For Treatment" as part of the
Balancing Criteria evaluation. Three source areas had contaminant levels
that warranted consideration of treatment. The discussions of the
"Statutory Preference for Treatment" can be found on the following pages:

Acme Scrap Iron ft Metal Page 36
Millennium Page 39
Detrex Page 45
Comment
U.S. Department of Interior - Fish and Wildlife Service - Trustee _

The U.S. Fish and Wildlife Service questions U.S. EPA's Proposed Plan recommendation for the
RMI Metals Reduction She. U.S. EPA recommended Alternative in, which would excavate
soils with greater than or equal to SO ppm total PCBs and contain contaminated sotf with PCS
concentrations between 10 and SO ppm. Because of the location of the source area adjacent to a
Fields Brook tributary, the U.S. Fish and Wildlife comments that the U.S. EPA should select
Alternative IV, which requires excavation of all contaminated soil greater than 10 ppm PCBs.

Response: U.S. EPA agrees. After a review of the volume and cost estimates for tLe
RMI alternatives, U.S. EPA has selected Alternative IV in the ROD.
Based on current volumes. Alternative IV is less expensive than Alternative
m. In addition, with the costs of Alternatives DI and IV being relatively
comparable, it is preferable to select a remedy that does not rdy on O&M
for its long-term effectiveness. However, because it is unclear whether
further delineation will dramatically increase the volume of soil that would
require excavation under Alternative IV, the ROD allows the PRPs to
provide a justification, for U.S. EPA's consideration, that Alternative III
will provide significant cost savings over Alternative IV. U.S. EPA

Responsiveness Summary - Page 6
-------
believes that Alternative ED would be a protective remedy if properly
implemented with the required O&M. Based on a cost justification from
the PRPs, the U.S. EPA may elect to change its selected remedy.

Comment #12
Citizen - Ms. Gloria McCarthy .

Ms. McCarthy did not submit a comment on the proposed alternatives for the Source Control
Operable Unit at the Fields Brook Site. Ms. McCarthy provided information concerning two
other facilities in the Ashtabula area with possible environmental violations.
i
Response: The information provided by Ms. McCarthy will be forwarded to the Ohio
EPA, which wiD investigate Ms. McCarthy's concerns regarding the two
facilities. U.S. EPA will request that the Ohio EPA inform Ms. McCarthy
of the results of its investigation.

Comment #13 ~~
Citizen -Anonymous ^

The anonymous letter did not include a comment on the proposed alternatives for the Source
Control Operable Unit The anonymous comment letter provided information about possible soil
contamination from the sand Masting of chemical storage barrels.

Response: A 104(e) information request letter is being prepared to gather data from
Detrex on past contracting for barrel cleaning services. In addition, a
104(e) information request letter is being prepared for the company who
allegedly performed the barrel cleaning for Detrex. U.S. EPA will
determine the appropriate follow-up based on the responses received.
\

Comment #14
Cleveland Electric IHuminating Company and Ohio Power Company

Cleveland Electric Illuminating and Ohio Power comment that U.S. EPA should utilize a PCB
occupational cleanup goal of 3.1 at the Acme Scrap Site. They state that, "U.S. EPA
recommends that Alternative VI be implemented for this facility, which would require excavation
and off-site disposal of surface soil with PCB concentrations greater than or equal to SO mg/kg.
Alternative VI would also require that soils contaminated with PCBs below 50 mg/kg be covered
in place to achieve the PCB residential cleanup goal of 1.3 ppm at Fields Brook. The Millenium
[sic] TiCL4 Plant, which is located directly north of the Acme Scrap She and is contiguous to the
stormwater discharge to Fields Brook from the Acme Scrap Site, is subject to the PCB-
occupational-based goal of 3.1 ppm."

Response: U.S. EPA has Devaluated the cleanup goals required for the Acme

Responsiveness Summary - Page 7
-------
property and determined that the facility should be subject to occupational
CUGs.
*
Comment #15
Cleveland Electric IDnmiamtiiiK Company «ad Ohio Power Company

Cleveland Electric Illuminating and Ohio Power comment that technical information developed to
date as part of the SOU Design Investigation suggests that there may have been no historical
release of PCBs from the Acme Scrap facility to Fields Brook or the Fields Brook floodplain.
"The most common PCB at the Acme Scrap site is PCB aroclor 1260, with lesser amounts of
aroclor 1248 and 1254. However, aroclor 1260 has not been detected in Fields Brook or the
Fields Brook floodplain samples downstream of the discharge point from the Acme Scrap she.**

Response: U.S. EPA does not agree with the claim that the Acme property is not a
source of past contamination. The analytical method used during the
investigation ( Method 8080) makes it difficult to differentiate between
PCB arodors and therefore extensive re-evaluation of site contaminant
data would be required to support such an argument In addition, natural
weathering processes further complicate aroclor identification by changing
the aroclor distribution. Acme has been confirmed as a source of PCB-
contaminated oil in Fields Brook through Rhodamme B dye tests in storm
sewers and through comparative analyses of oil samples taken from the she
and Fields Brook.

U.S. EPA has documentation to support its claim that Acme burned
transformers, released oil into its sewer and contaminated its property.
Sampling conducted by the Ohio Department of Public Health in the early
1980*8 found PCB levels as high as 291 ppm total PCBs in water and oil
samples discharging from the storm sewer. U.S. EPA analyses in 1982
found soil contamination with up to 114 ppm PCBs, and discharge samples
with up to 189 ppm PCBs. Additional documentation of she
contamination can be found in the Source Control Remedial Investigation
(SCRI) report.

Further, regardless of whether Acme is or is not a source of past
contamination, the Recontamtnation Assessment has shown that the
property is a potential source of future contamination and must be
addressed to prevent recontamination of the Brook.

Comment #16
Cleveland Electric Dluminaring Company and Ohio Power Company

The conunentors state that Alternatives n, m and IV will fully comply with ARARs and should
Responsiveness Summary - Page 8
-------
be reconsidered and recommended by U.S. EPA. Since the route for releases of PCBs is via
stormwater discharges which might carry PCB~contaminated sediment off-she, the use of
stonnwater controls and/or covers would be sufficient to prevent the movement of PCBs into the
Brook.

Response: U.S. EPA agrees that the pathway for movement of PCS contamination is
via erosion and run-off from the she. However. U.S. EPA disagrees with
the commentors' statement that alternatives n, in and IV fully oomph/ with
ARARs. TSCA is an ARAR for the cleanup at the Acme property and the
berms and/or covers specified in Alternatives n, m and IV do not satisfy
the requirements of TSCA for the management and containment of soils
with PCB concentrations greater than or equal to 50 ppm. To accept
these alternatives, the U.S. EPA would have to waive TSCA and show that
these alternatives would be protective and would not present unreasonable
risks to health and the environment U.S. EPA does not believe that the
stormwater controls and covers specified in Alternatives n, ffl, and IV
meet this standard for soils containing greater than or equal to 50 ppm total
PCBs.

Comment #17 !
Cleveland Electric fflumnuitinti Company said Ohio Power Company

Cleveland Electric Illuminating Company and Ohio Power Company comment that U.S. EPA
should allow modifications to the remedial response area in the final engineering design. The
commentors state that the remedial design process should be flexible and allow the optimization
of the remedial response area and consolidation. The commentors also note that no outfall
monitoring has been proposed for Alternatives ffl, IV, V, VI and that outfall monitoring would be
conducted by the she owner/operator pursuant to any monitoring obligations imposed under any
Ohio NPDES permit for the she.

Response: The Soi :e Control ROD does notsdect designs for the remedial response
areas. The ROD selects the technologies (Le., excavation, erosion control
covers) required to meet the goal of the cleanup, which is to prevent the
recontamination of the Brook. The remedial response area at the Acme
site will be re-sized and reconfigured during remedial design based on the
results of soil loss equations, the degree of consolidation, and, to the extent
possible, practical considerations to accomodate the continued operation of
the facility. The selected remedy provides this flexibility.

The commentors noted that outfall monitoring was not proposed for
Alternatives ffl, IV, V. and VI and that outfall monitoring would be
performed by the owner/operator pursuant to NPDES requirements. U.S.
EPA agrees that the SCFS did not require outfall monitoring.

Responsiveness Summary - Page 9
-------
The monitoring programs for the source control areas are to be developed
during Remedial Design, as part of each facility's O&M Plan. Sufficient
monitoring must be included to demonstrate that contaminant movement
from each source area is not resulting in CUG exceedances in Brook
sediment. The location and frequency of monitoring at Acme is dependent
on the configuration of the final design.

Comment #18
Cleveland Electric MuminatinR Company and Ohio Power Company

The commentors note that the she must be setured before remedial measures can be implemented
and maintained. If Acme is to remain in operation at the site, both physical (remedial) and legal
(institutional controls, including caed restrictions) must be implemented to ensure that the site is
properly maintained. The ROD should include a statement that the she owner/operator will be
solely responsible for recontaminah'on of the site in the future.

Response: U.S. EPA agrees that physical and legal controls must be utilized to ensure
that the remediation is not "un-done" by future actions at the she, thus
causing the recontamination of the Brook. However, the ROD is not the
proper mechanism for assignments of liability.

Comment #19
Cleveland Electric Muminating Company and Ohio Power Company

The commentors note that the Final Remedial Action should be modified, as needed, to take
account of she drainage requirements. "There has been limited investigation or study of the
drainage system for the Acme Scrap Site, and little indication of how stormwater runoff is to be
handled. It will be necessary to address these matters in the site grading and drainage plans. It
may be cost-effective, and equally protective of human health and the environment, to modify the
remedy which is ultimately selected in the final design phases before the remedial action is
implemented. USEPA should allow modifications to the alternative which is ultimately selected
by USEPA if considerations of site drainage and stormwater runoff suggest that a more cost-
effective approach can be implemented to contain or control stormwater discharges from the
site."

Response: U.S. EPA agrees with the commentor that a plan for she drainage has not
yet been developed. That is an element of the Remedial Design process.

The commentor also requests that the alternative be modified if a more
cost-effective approach can be found to control stormwater discharges
from the she. U.S. EPA disagrees with the commentors request that the
alternative may be changed during the remedial design/remedial action
phase. The ROD requires excavation of soils with equal to or greater than

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SO ppm total PCBs. The remaining contaminated soil will be covered with
an erosion control cover, as described in the ROD, to the extent necessary
to ensure that soil losses from the site do not exceed occupational CUGs.
The site will be graded to allow for proper drainage. The remedial design
may include consolidation of soils prior to placement of the cover.

It is not anticipated that the basic dements of the ROD will change during
the remedial design/remedial action process. The U.S. EPA has
determined that the use of an erosion control cover is preferable to erosion
control measures mat do not make use of a cover (i.e., Alternative ITs use
ofberms). Any change^ that would not include the erosion control cover
would require a ROD Amendment or Explanation of Significant Difference
to document the deviation from the remedy selected in this ROD.

Comment 020
Cleveland Electric fflumuMtinK Company and Ohio Power Company

The commentors state that flexibility should-be allowed in performing remedial work on the South
Sewer System. "USEPA has recommended Alternative m for remedial action on the sewer
system winch extends south of Fields Brook ("the South Sewer"). Alternative in involves
grouting the existing 30 inch sewer on the Acme Scrap she, which extends from the on-site
lagoon northwest to the intersection of State and Middle Road, and constructing a new 30 inch
on-site sewer. Alternative DI would also require that the storm sewer (qrtfapatEd to be a 36 inch
or 48 inch sewer), which travels parallel to State Road from the Acme Scrap she to Reids Brook,
would be cleaned of sediments and repaired, if necessary." The commentors note that very little
is known about these sewers and replacement may not be necessary. The commentor suggest the
following language, "Replacement sewers, if determined to be necessary, would be constructed..."

Response: U.S. EPA agrees. Based on current information, h is premature to require
replacement of the sewers. Additional evaluation of the condition of the
sewers should be pejorated during remedial design to determine whether
cleaning or replacenumt would be most cost-effective. The Agency's
selection of Alternative HI provides the necessary flexibility. Replacement
sewers will be constructed only if necessary.

Comment 021
Cleveland Bectrk Dlnminating Company and Ohio Power Company

The commentors note that the condition of the Defense Plant Building may necessitate a
modification of the selected remedial action. "Portions of the silos located on one side of the
plant have partially collapsed, and the condition of the building may pose a safety risk to the
performance of remedial work, especially the implementation of Alternative VI." Because the
building "is in poor repair and may be structurally unsound," the U.S. EPA should allow the work

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to be modified to accomodate the possible partial or complete demolition of the Defense Plant
building and associated structures.

Response: U.S. EPA agrees that the remedial design should accomodate any actions
to be taken to address stability issues at the former defense plant building.
In fact, the ROD requires that the site be secured before work can proceed.

Comment #22
Woodw«rd-Ctyde on behalf of the Fields Brook Action Group (FBAG)

Regarding page 4, last paragraph, of the Proposed Plan, Woodward-Clyde notes that the FBAG
did not identify five properties in the FS. The FS identified surface soil as a potential source for
remedial alternatives at the Acme, Millennium and Detrex facilities. USEPA required that the
FBAG include alternatives for the RNfl Meals and Conrail facility."

Response: The commentor is correct.

Comment #23 '^
Woodward-Clyde on behalf of the Fiddi Brook Action Group (FBAG)

Regarding page S, third paragraph, of the Proposed Plan, Woodward-Clyde notes that cleanup
goals were not "calculated to reduce the movement of contanriniition from erosion and runoff."
The commentor suggests more appropriate language, "Cleanup goals were calculated in order to
provide assurance that movement of potentially contaminated sofl and sediment on the source
properties would not be sufficient to recontaminate Fields Brook sediment following the
remediation of Fields Brook."
•
Response: The commentor's recommended language is dear than that used in the
Proposed Plan.

Comment #24
Woodward-Clyde on behalf of the Fields Brook Action Group (FBAG)

Regarding pages "Acme-2" and "Acme-3" of the Proposed Plan, the commentors state that no
outfall monitoring was to be included in Alternatives in, IV, V and VI. "No outfall monitoring
was to be included in this alternative. The only chemical monitoring that was described in the FS
includes the annual collection of surface soil samples for PCB analysis. Sampling was to continue
for a 5-year evaluation period."

Response: The commentor is correct that the FS did not describe surface water
monitoring. Monitoring will include the sampling and analysis of soil and
sediment to demonstrate that erosion from the Acme property is not
causing exceedances of occupational CUGs. Specifics of the monitoring

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program will be developed as part of the Operations and Maintenance Plan.

Comment #25
Woodward-Clyde on behalf off the Fields Brook Action Group (FBAG)

Regarding page "Acme-3" of the Proposed Plan, the oommentors note tint incineration is not
mentioned in the FS and is only one form of thermal treatment.

Response: Comment noted.

Comment #26
Woodward-Clyde on behalf of the FieMi Brook Action Group (FBAG)

Regarding page "ConraiM" of the Proposed Plan, the commentors note "that the portion of the
property that lies in the Fields Brook watershed is nfii shown as the shaded area on the map in the
PRAP as stated. The map provide [sic] in the PRAP illustrates the potential remedial response
area designated in the Feasibility Study, and not the entire portion of the Conrail property which
lies in the Fields Brook watershed. It should be noted that Conrail performed a Recontamination
Assessment that indicated runoff would not recontaminate Fields Brook sediments."

Response: The commentor is correct that the shaded area on die figure is the potential
remedial response area. U.S. EPA is aware that the Recontamination
Assessment indicated that Conrail runoff would not recontaminate Fields
Brook sediments. However, because of concerns about the proximity of
the Conrail facility to the Brook, U.S. EPA utilized best professional
judgement in its decision to evaluate alternatives and ultimately require
remedial action at the property.

Comment #27 .
Woodward-Clyde on behalf of the Fields Brook Action Group (FBAG)
Regarding page "Conrail-2" of the Proposed Plan, the commentors note that the correct capital
cost for Alternative TV is $19,500 not $19,800.

Response: Comment noted.

Comment #28
Woodward-Clyde on behalf of the Fields Brook Action Group (FBAG)

Regarding page "Conrail-2" of the Proposed Plan, the commentors note that the correct 30-year
present worth cost for Alternative V is $173,100 not $173.000.

Response: Comment noted.

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Comment #29
Woodward-Clyde on behalf of the Fiddi Brook Action Group (FBAG)

Regarding page "Detrex-l" of the Proposed Plan's discussion of Alternative 1 (No Action), the
conunentors state, "The PRAP references stonnwater outfidl sampling to evaluate the amount of
contamination moving off the property and into Fields Brook. The FS did not describe surface
water monitoring."

Response: The commentor is correct that the FS did not describe surface water
monitoring. Specifics* of the monitoring program will be developed as part
of the Operations and Maintenance Plan, and wifl likely include soil,
sediment, and groundwater sampling and analysis. Sufficient monitoring
will be required to demonstrate that contamiraw* movement from the
Detrex property is not resulting in CUG exceedances in the Brook.

Comment #30
Woodward-Clyde on behalf of the Fields Brook Action .Group (FBAG)
"s
Regarding pages "Detrex-2" and "Detrex-3" of the Proposed Plan, die commentors note that
Alternatives HA, OB, m and IV also include "the characterization and disposal of approximately
100 cu. yards of catalyst material located in a pfle in source area DET6. In addition, sediment
from the retention pond and ditches on the northern property would be removed. Post
remediation monitoring will extend for at least a S year period and then be re-evaluated to
determine appropriateness for extending monitoring."

Response: U.S. EPA agrees. The necessary detail is included for the remedy selected
in the ROD.

Comment #31 "
Woodward-Clyde on behalf of the Fiddi Brook Action Group (FBAG)
••^^^•••^•^^••^^•^•••••^•••'•••^•••••••^^^^••^••^•^•Mi^^^MIMAa^BM^H^MH^^^^^^^M^^B^HVBB^^^VVBi^HMV^BMaa^b^^MB^MHMBB^H^MPM^MMMaMVM^B^HBHaM^BIMi^^HnHBa «•

The commentors note that the Proposed Plan's discussion of RMI Alternatives n, m, and IV did
not indicate that post remediation monitoring will extend for at least a 5-year period and then be
re-evaluated to determine appropriateness for extending monitoring.

Response: U.S. EPA agrees. The necessary detail is included for the remedy selected
in the ROD.

Comment #32
Mark W. Andrews representiiut Acme Scrap Iron & Metal Company

The commentor states, "Acme continues to believe that the scope of the remediation
contemplated by Alternative VI is an ultra conservative approach to the problems that had

Responsiveness Summary - Page 14
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occurred in the past at the Acme she. Acme has been told by the U.S. EPA that h has the least
contaminated property in the Fields Brook Superfimd Site, and yet it is the only property which is
being subjected to the residential standard for PCB's. This is particularly concerning in view of
the tact that (1) most of the detectable amounts of PCB's at the Acme site are located in the top
six inches of soil, and the minimal amounts of PCB's are not likely to migrate; (2) Reids Brook
does not traverse through the Acme operation, or any part of the property owned by Deha
Associates, Ltd., as it does through the other properties in the Superfimd site; (3) the only source
for future contamination of Reids Brook by Acme would have to involve surface water "nut-off*
which could possibly flow through the interrupted storm sewer system, which is regularly
monitored for PCB's, and consistently shows no detectable levels of PCB's; and (4) Acme has not
handled regulated substances for more than a decade, and has absolutely no intentions of doing so
in the future."

Response: U.S. EPA does not believe that Acme is the "least contaminatod property
in the Fields Brook Superfimd She." This statement is not supported by
she data.

Although U.S. EPA has reevahiated the cleanup goal requirements for
Acme and determined that occupational CUGs must be met at the Acme.
' * property, Mr. Andrews is incorrect in his statement that Acme wis the only .
property which is being subjected to the residential standard fbrPCB's."
The U.S. EPA is requiring that residential CUG« be met at the following
locations: Conrafl, RMI Metals, and the Detrex outfall

Regarding the presence of PCBs in surface soil, U.S. EPA believes that Mr.
Andrews is confusing two different mectiamyng of contaminant transport.
Mr. Andrews states that PCB contamination is primarily in the upper 6
inches of soil and is not likely to migrate. When migration is discussed, h
is usually referring to the movement of contaminants independent of soil or
sediment particles. For example, solvent contamination in soils win
generally migrate, meaning h will travel with groundwater and move
through soil. Although PCB contamination generally does not migrate
because the contaminants bind to the soil particles, the addition of other
contaminants into the system (such as solvents) can mobilize PCBs and
result in the migration of PCB contamination.

Mr. Andrews states that the storm sewer system is monitored for PCBs and
consistently shows no detectable levels of PCB's. The Acme faculty has
had an NPDES permit since 1986. and the discharge of PCBs is prohibited.
According to the SCRI report, Mr. Tackett has stated that Acme is in
compliance with its NPDES permit limits. U.S. EPA is pleased that the
monitoring has apparently shown that Acme is complying with NPDES
requirements. However, according to the evaluation of the Acme property,

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there is still a risk that contamination from the Acme property could
recontaminate Fields Brook in excess of CUGs. The implementation of the
remedial action will ensure the reduction of contaminant movement off-
site.

The concern at the Acme property is the erosion of contaminated soil and
its movement into Fields Brook. Although the Acme facility is not adjacent
to the Brook, contamination from the Acme faculty can enter the Brook
from the Acme sewer. The presence of the contamination in the surface
soil causes this material to be subject to erosion. The implementation of
the remedial action will ensure that erosion from the she will not result in
the recontamination of the Brook.

Comment #33
Mark W. Andrews representing Acme Scrap Iron A Metal Company

Mr. Andrews states that Acme agrees that there are "small areas of contaminated soil on its
property." He further states that, "This contaminated soil must be removed and properly disposed
of. Acme does not believe H is necessary to contain the remaining areas where the presence of
PCBs have been detected in minimal amounts that would normally be acceptable under industrial
standards, especially where the containment and fencing would render an otherwise productive
parcel of industrial property useless for all intents and purposes."

Response: U.S. EPA disagrees with Mr. Andrews that the contaminated areas could '
be characterized as "smafl." Mr. Andrews states that it should not be
necessary to contain low-level PCB contamination in site soils since the
levels would normally be acceptable under industrial standards. U.S. EPA
does not agree with Mr. Andrews assertion that containment should not be
necessary after excavation. Most industrial standards are designed to
protect workers and do not address ecological concerns or the movement
of contamination into an area with other types of exposures, rhe cleanup
at the Acme property is being performed to prevent recontamination of the
Brook. The extern of the area to be covered win be primarily determined
by soil loss calculations.

Comment #34
Mark W. Andrews representing Acme Scrap Iron A Metal Company

Mr. Andrews states that Acme has always cooperated with U.S. EPA in its endeavor to remediate
the Fields Brook site. He also notes that, "Acme is now righting for its business life to enable it to
continue to employ its workers and serve its customers.**

Response: Comment noted. Based on current information, U.S. EPA does not believe

Responsiveness Summary - Page 16
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that the performance of the cleanup will require Acme to permanently
cease its operations at its current location. There is sufficiently flexibility in
the ROD for the development of a design that can accomodate Acme's
continued operation.

Comment #35
Alternative Proposal for Site Remediation, submitted by Mark W. Andrews representing
Acme Scrap Iron A Metal Company _ ._ _

On behalf of Acme, Mr. Andrews presented an alternative proposal for remediation of the Acme
facility. The alternative included the foOowufg' components:

• Excavation and off-she disposal of soil with FOB concentrations exceeding SO ppm.
Excavation would be to a depth of 6 inches to 1 foot Backfill with clean material.

• Excavate remaining contaminated material on the north of the property and stock pile into
an earthen benn north of Acme's area of general operations. Excavate to a depth of 6
inches and backfill excavated areas. .For aesthetic reasons, cover mound with topsoil and
seed. Benn will be parabolic in shape and approximately 200 feet long, 45 feet in width,
and 10 feet in height Note that the figure provided with the proposal identifies
significantly different dimensions.

• Excavate remaining contaminated material on the south of the property and stock pile into
an earthen benn south of Acme's area of general operations. Excavate to a depth of 6
inches and backfill excavated areas. For aesthetic reasons, cover mound with topsoil and
seed. Benn will be parabolic in shape and approximately 800 feet long, 40 feet in width,
and 10 feet in height. Note that the figure provided with the proposal identifies
significantly different dimensions.

• The bermswOl act as a natural surface water barrier and wiO contain PCB contaminated
soil.

Response: U.S. EPA has evaluated the proposal and hopes that the Agency can work
with Acme during the design process to meet the goal of the source control
cleanup and, to the extent practical, accomodate Acme's operations. U.S.
EPA is pleased that Acme is willing to excavate sofl containing greater than
50 ppra total PCBs. However, U.S. EPA would like to note that TSCA
itCT soils with contaminant levels equal to or greater th*n SO ppm.
U.S. EPA supports the concept of consolidation. However, the movement
of all areas of contamination is quite dramatic. The extent of consolidation
(if any) and ulrinntg location of containment areas will be developed during
remedial design, after the remedial response area is reconfigured to address

Responsiveness Summary • Page 17
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the change in the CUG requirement (from residential to occupational).

The dimensions and cover specified for the earthen benns proposed by
Acme do not appear to be workable. The cleanup is meant to prevent the
erosion of contaminated soils. The slopes of the earthen benns would be
too steep to effectively control erosion, especially with a limited soil cover.
The remedial design for the Acme site must include the erosion control
cover specified in the ROD. A larger area of the Acme property will likdy
need to be allotted for containment of contaminated soil.
The proposal •gfopnttf that only 6 inches of soil will need to be excavated
in areas of low-level contamination. The ROD assumes 1 foot of
excavation. A re-evaluation of the data during remedial design and
possible confirmatory sampling during remedial action will likely be needed
to ensure contaminated soils have been addressed.

The evaluation of the source control properties and the preparation of
SCRI and SCFS documents occurred over a period of years. U.S. EPA
believes that had Acme been more actively involved in the Superfund
process, its concerns could have been more readily addressed in the
conceptual design of alternatives presented in the SCFS. Acme's
involvement in the Remedial Design process is critical to the
implementation of a Rfnwfinl Action that can accommodate Acme's
continued operation at the she.

Comment #36
Mr. Bradley Schneider of ENCORE Environmental in Rochester, Michigan _

Mr. Schneider commented on the remedy selected for the Floodplains/Wetlands Site (Operable
Unit #4) and recommends the addition of a bioremediation program. He asks that U.S. EPA
contact his telemarketing specialist if there is interest in the services that ENCORE could provide.

Response: !*he remedy for the Floodplains/Wetland Operable Unit has already been
selected. The inclusion of a bioremediation program to reduce PCB
concentrations in soils n**4 sediments does not seem warranted at this time
for either the Floodplains/Wetlands or Source Control Operable Units.

Comment #37
Mr. Steven Kellat, Edgewood Senior High School _

During the public meeting, Mr Steven Kellat, a student at Edgewood Senior High School,
provided an oral comment on the Proposed Plan for the Source Control Operable Unit. Mr.
Kellat stated that he supports U.S. EPA recommendations. However. Mr. Kellat stressed that his

Responsiveness Summary - Page 18
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position was presented as an individual and does not represent the position of his school's Student
Council unless ratified by said Student Council. Mr. KeDat also recommended that fences be
properly constructed and routinely inspected and that U.S. EPA consider the use of guards during
Remedial Action.

Response: U.S. EPA is pleased that Mr. Kdlat supports U.S. EPA's recommendations
for the she. Fencing wfll be required to restrict access to containment
areas, and the inspection and upkeep of the fences wiU be required as part
of she Operation and Maintenance (O&M) U.S. EPA wiU consider the
use of guards during Remedial Action. However, it may not be necessary
to add additional security since many of the companies involved already
employ security guards for their acuities.

Comment #38
Mr. Donald R. Schrcgardus, Director of the Ohio Environmental Protection Agency

The Ohio Environmental Protection Agency (OEPA) does not agree with the overall risk
management approach used at the Fields Brook she. In his comment letter, Mr. Schregardus
states that, "source control remedies should be based on managing risk at each individual source
area by following die usual process of evaluating risk by all appropriate pathways and developing
cleanup goals based on she risk." The OEPA also does not support the way that potential source
areas were screened relative to pathways of contamination to the Brook and how the source
control cleanup was Bruited to those areas which could result in CUG exceedances in Brook
sediment.

Response: The U.S. EPA has elected to limit the scope of the source control cleanup
to those areas that could potentially recontaminate Fields Brook sediment.
This was a practical decision. The Fields Brook Superfund She is very
large and complex. Expanding the Source Control OU cleanup beyond its
current scope would be unwieldy and result in extensive delays in the
Sediment and
The Remedial Investigation evaluated approximately 200 source areas and
six areas were ultimately carried forward in the Source Control FS and this
ROD for remediation to prevent lecontamination of Brook sediment.
Contamination is unfortunately aU too common in industrial areas, and it is
not reasonable to expect the Fields Brook Superfund action to prepare
individualized risk assessments for each of the 200 source areas evaluated
and to enforce and/or fund cleanups at all of these sites. The US EPA
believes that the scope of the Source Control OU cleanup is appropriate.
Source control areas that would not result in Brook CUG exceedances
should be handled independent of the Fields Brook Superrund action.
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