United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-88/068
June 1988
Superfund
Record of Decision
Summit National Liquid, OH
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30277-101
REPORT DOCUMENTATION
PAGE
trREPORT NO.
EPA/ROD/R05-88/083
4. Title »nd Subtitle
SUPERFUND RECORD OF DECISION
National, OH
Re me dial Action - Final
Author<»)
3. Recipient's Accession No.
S. Report D«t«
06/30/88
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The 11.5-acre Summit National site is a former coal strip mine in rural Deerfield
Township, Portage County, Ohio, approximately 45 miles southeast of Cleveland. In the
area immediately surrounding the site there are several residences, two landfills, a
cement plant, a rollerskating rink, and a used tire storage lot. There are 9
residential wells within 1,000 feet of the site. Summit National Liquid Services
operated a solvent recycling and waste disposal facility on the site from 1973 to 1978.
^^Solvents, paint sludges, phenols, cyanide, arsenic, and other liquid wastes were stored,
^^incinerated, and buried or dumped during site operations. All onsite media are
contaminated with a variety of organic and inorganic compounds, and investigations
indicate that offsite areas also are affected. In addition, about 900 to 1,600 buried
drums and 4 buried tanks containing hazardous substances have been identified at the
site, in June 1978, EPA ordered Summit National to stop receiving waste materials and
remove all liquid wastes from the site. No waste was removed before the owner sold the
site in March 1979. Because hazardous chemicals were leaking into the environment, in
September 1979 EPA removed three bulk tanks and their contents (approximately 7,500
gallons of hexachlorocyclopentadiene) and contaminated soil, and treated some
contaminated water. Surface operations were conducted between November 1980 and June
(See Attached Sheet)
17. Document Analysis a,. Descriptors
Record of Decision
Summit National, OH
First Remedial Action - Final
Contaminated Media: gw, sw, soil, sediments
Key Contaminants: metals (arsenic, chromium), organics (PAHs, PCBs, phenols), VOCs
b. identifiers/Open-Ended Terms (benzene, TCE, toluene, xylenes)
c. COSATI Field/Group
Availability Statement
! 19. Security Class (This Report)
i None
21. No. of Pages
153
i 20. Security Class (This Page)
! None
22. Price
[See ANSI-Z39.18)
See /nitructioni on Reverse
OPTIONAL FORM 272 (-i-S
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R05-88/083
nit National, OH
Remedial Action - Final
16. ABSTRACT (continued)
1982, during which EPA removed drums, tanks, various surface debris, and a small amount
of contaminated soil. In March 1987, EPA performed an emergency action to contain and
terminate the actual or threatened release of hazardous materials due to the critically
deteriorating site conditions. The primary contaminants of concern affecting soil,
sediments, ground water, and surface water are VOCs including benzene, toluene, TCE and
xylenes, other organics including phenols, PAHs and PCBs, and metals including arsenic
and chromium.
The selected remedial action for this site includes: excavation and onsite
incineration of approximately 32,000 yd^ of contaminated soil and sediments and the
contents of approximately 1,600 buried drums and 4 tanks, with disposal of incinerator
residuals in an onsite RCRA landfill; ground water pump and treatment and onsite surface
water treatment using precipitation, f locculation, coagulation, oil and water
separation, filtration, and carbon adsorption, and discharge of treated water to
downgradient surface water; installation of a RCRA cap over the site, with regarding and
revegetation; construction of a slurry wall around the site perimeter; dismantling and
onsite disposal of all onsite structures; limited access and deed restrictions; ground
water and surface water monitoring; and residence relocation. The estimated present
worth cost for this site is $25,000,000 with annual O&M of $1,132,250.
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Record of Decision
Summary of Remedial Alternative Selection
Summit National Site
SITE: Summit National - Deerfield, Ohio
STATEMENT OF BASIS AND PURPOSE
The selection of the remedy is based on the Administrative Record for the
Summit National site. Attachment 1 contains the Responsiveness Summary, and
Attachment 2 contains the index to the administrative record. The decision
document represents the selected remedial alternative for the Summit National
site. It was developed 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 consistent
with the National Oil and Hazardous Substances Pollution Contingency Plan to
the extent practicable.
The remedial action will require future operation and maintenance activities
to assure the continued effectiveness of the remedy. These activities will be
considered eligible for Trust Fund monies for a period not to exceed 1 year.
With respect to restoration of ground or surface water quality, the operation
and maintenance costs will be eligible for Trust Fund monies for a period of
up to 10 years. I have also determined that the action -being taken is
appropriate, when balanced against the availability of trust monies for use at
other sites. This Record of Decision addresses all operable units for remedial
action at the Summit National site in Deerfield, Ohio.
DESCRIPTION OF THE SELECTED REMEDY
U.S. EPA's preferred alternative includes limiting access and future uses of
the site; monitoring surface water and groundwater; removal of on-site
structures, and placing debris in an off-site permitted landfill or under the
multi-layer cap; excavating and onsite incinerating "hot spot" soils,
sediments, buried drums and tanks including their contents; placement of all
incinerated material in an on-site RCRA landfill; installation of a multi-
layer cap over the entire site; a vertical barrier (slurry wall) around the
perimeter of the site; the installation of wells over the site to extract and
treat groundwater on-site; eliminating on-site surface water and treating it
along with the groundwater treatment system; rerouting of the southern and
eastern ditches to an area off-site; regrading and revegetatihg the site
surface; and relocating the Watson residence to another area not affected by
the site.
During the public comment period on U.S. EPA's Proposed Plan for the site, the
Summit National Steering Committee (SNSC), representing 35 potentially
responsible parties, made written proposals for a privately financed remedy at
the site and have stated their intention to supply additional technical
information supporting their proposals. U.S. EPA has addressed the SNSC
comments in the attached Responsiveness Summary. It is possible that an
agreement with the SNSC could be reached on a different, but
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comparable, remedy. In such case, additional public comments would be
solicited, prior to finalizing a settlement with the potentially responsible
parties, or amending this Record of Decision.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Pollution Contingency Plan to the extent practicable, I have
determined that the selected alternative for remediation of the Summit
National site, is protective of human health and the environment; meets
applicable or relevant and appropriate requirements; and is cost-effective.
The Ohio Environmental Protection Agency has been consulted throughout the
Remedial Investigation, Feasibility Study, and Record of Decision process.
This Record of Decision addresses all concerns at the site, and is the
proposed final remedial action for the Summit National site.
This remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, and volume as a principal element,
and utilizes permanent solutions and alternate treatment technologies to the
maximum extent practicable. To ensure the long-term effectiveness and
protectiveness of the selected remedy, a review will be conducted within 5
years after commencement of the remedial action.
Date Valdas V. AdamKus
Regional Administrator
U.S. Environmental Protection
Agency
Region V
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Sunnary of Remedial Alternative Selection
Sunrait National Site
SITE LOCATION AMD DESCRIPTION
The Summit National Site is located in Deerfield Township, Portage County,
Ohio, approximately 45 miles southeast of Cleveland and 20 miles west of
Youngstown (Figure 1).
The Summit National Site is approximately rectangular in shape and occupies
approximately 11.5 acres. It is located at the southeast corner of the
intersection of Ohio Route 225 to the west and U.S. Route 224 to the north
(Figure 2).
The site was a coal strip mine and contained a coal wash pond and coal
stock pile prior to its use as an incinerator site. The coal tipple
remains as a 15 ft. high embankment in the northwest corner of the site
with a loading dock and concrete debris remaining from the original coal
processing facilities. Other prominent features on site are two ponds
located in the midsection of the site, an abandoned incinerator and two
buildings in the southeast corner, a scale house in the northwest corner,
and two dilapidated buildings in the northeast corner. Additionally, it is
estimated that approximately 900-1,600 drums and three known tanks and one
suspected tank remain buried on site. Little vegetation is growing on site
since most of the site was graded following periodic surface cleanup
activities which were performed from 1980 through 1982. The site is
enclosed by a 6 ft. high fence with two locked gates for entrance from
Route 225.
The area immediately surrounding the site has been developed for a variety
of uses, primarily rural residences, light industries and agriculture.
Several residences are located to the north, east and west within 500 ft.
of the site. A roller skating rink is immediately north of the site.
Light industries in the area include a fuel distributor, a cement plant and
manufacturer of septic tanks, two sanitary landfills, and used tire storage
lots. Unused area near the site are either wooded or unvegetated strip
mined lands.
SITE HISTORY AND ENFORCEMENT ACTIVITY
All information pertaining to site history was obtained from and based on
the existing Summit National Remedial Action Master Plan (RAMP) (CH2M Hill,
August 1983) and the Ohio EPA files available from the Twinsburg, Ohio
office.
In June 1973, Summit National Liquid Services obtained a "Permit to
Install" an 18,000 gallon per month liquid waste incinerator from the Ohio
EPA. In April 1974 an operating permit for the incinerator was issued by
the Ohio EPA. The facility, called Summit National Liquid Services,
received liquid wastes from various manufacturing and chemical companies.
The wastes were either delivered in bulk using tanker trucks or in 55
gallon drums on flatbed trucks..
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LAKE
FIGURE I
SUMMIT Si'
SUMMIT 'i~~'
'
;C.'I
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H M KfODAL • AJSOC ,
INC. HIOIOGHAPM* DAt[D> ll-2/-i<.
li-U-»4, „
SCAU' l"« SO'. "
FIGURE 2
SITE MAP
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Once brought to the facility, wastes were stored unprotected in 55 gallon
drums, an open pit referred to as the polymer pit, or bulk tanks of varying
size. Many wastes were mixed with flammable liquids and incinerated. Some
wastes were buried on site, while others were dumped or leaked onto the
site soil. The incinerator reportedly operated until 1978.
During its operating history, a variety of industrial wastes were disposed
at the Summit National site. Drummed and tanked wastes disposed included
waste oils, resins, paint sludges, flammable solvents, chlorinated
solvents, plating sludges, pesticide wastes, phenols, cyanides, acids,
various polymers, and lab packs. Many of the drums and bulk tanks stored
on the surface leaked quantities of these materials into the surface of
the site. It was reported that the concrete block pit was used for liquid
waste mixing and solidification and overflowed on a recurring basis during
periods of heavy rainfall.
In June 1975 the Northeast District Office of the Ohio EPA investigated a
complaint of an unauthorized discharge of waste water from the site. The
U.S. EPA conducted an investigation of the site on October 29, 1976 and
found evidence of numerous leaks and spills. The owner was notified of the
need for a Spill Prevention Control and Counter-measures Plan (SPCC) and
informed that he was in violation of state laws relating to treatment and
disposal of industrial waste. The Ohio EPA Director issued Final Findings
and Orders on June 12, 1978. These required Summit National to cease
receiving waste materials, remove all liquid waste from the site, and
receive written approval prior to removing any material from the facility.
No further waste material was received after this date. On March 15, 1979,
the owner Mr. Georgeoff sold the site without removing any wastes.
In August 1979, the State of Ohio filed a complaint against the present and
former owners alleging the operation of a solid waste disposal site without
a permit, creation of a public nuisance, failure to comply with orders from
the Ohio EPA, and installation of facilities for the storage and disposal
of liquid waste without submitting plans to the Ohio EPA. Testing of
onsite waste materials established the presence of over 7,500 gallons of a
toxic chemical, hexachlorocyclopentadiene, commonly called HCCPD or C-56.
In September 1979, U.S. EPA notified the owner that, because C-56 and other
hazardous chemicals were leaking to the environment, remedial action was
being planned pursuant to Section 311 of the Clean Water Act. The owner
refused to take voluntary action or fund the cleanup operation, so U.S. EPA
funded the cleanup of C-56 wastes that took place between September and
November 1980. The remedial action consisted in disposing of three bulk
tanks and their contents (approximately 7,500 gallons), some contaminated
soil, and the treatment of contaminated water.
In November 1980, an agreement was reached between the State and eight
generators that provided S2.5 million for surface cleanup. Surface cleanup
operations, including removal of drums, tanks and various surface debris
and a small amount of contaminated soil, were concluded in June 1982. The
1981-82 surface cleanup project removed much of the source of site
contamination, but did not include subsurface exploration or cleanup.
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In October 1981, the Attorney General of the State of Ohio (OAG) filed an
action against the Potentially Responsible Parties (PRPs) under federal law
using Section 107 of CERCLA. This suit is to recover past and future costs
of removal and remedial actions at and about the site and to recover costs
for damages to the natural resources of air, surface waters, groundwater
and soils in and around the site. The status of this suit is on hold until
the U.S. EPA finalizes the RI/FS document. However, the Judge in this case
did have the first reported ruling that it was Congress's intent that
CERCLA 107 liabilities are not only for future liabilities, but also past
liabilities.
In June and July of 1982, the U.S. EPA and the PRPs negotiated the terms
under which an Administrative Order by Consent could be signed allowing the
PRPs to conduct and complete an RI/FS at the site. These negotiations were
terminated due to the PRPs not accepting U.S. EPA's basic conditions.
In September, 1983, the Summit National Site was placed on the National
Priorities List (NPL) which made it eligible for clean-up under the
Superfund program. U.S. EPA issued a work assignment to conduct a Remedial
Investigation (RI) and Feasibility Study (FS) for the Summit National site.
The remedial investigation was conducted in two phases in Fall 1984 and
Winter 1986.
In March 1987, the U.S. EPA issued a Section 106 (a) CERCLA Unilateral
Administrative Order (AO) to the PRPs at the site. This AO was issued to
contain and terminate the actual or threatened release into the environment
of hazardous substances due to the deteriorating site conditions. It was
observed in December, 1986 by U.S. EPA that the eastern pond on the site
was flooding, the embankment about the pond was eroding and an underground
tank was leaking. In March 1987, the site went critical due to the Spring
rains and thaw. The PRPs informally agreed to reimburse U.S. EPA for
response costs related to this emergency action rather than implement the
AO. Currently, the U.S. EPA and the PRPs are finalizing a Section 122(h)
CERCLA, as amended, Administrative Order by Consent that will reimburse
U.S. EPA for the cost of completing the removal actions specified in the
AO.
In November 1987, the U.S. EPA, State of Ohio, DOJ, OAG and PRPs started
the legal Remedial Design/Remedial Action-Consent Decree negotiations at
this site. These negotiations have made progress and are currently on-
going between all parties. After the Record of Decision is finalized
technical components of the Consent Decree negotiations will commence under
the Section 122(c) CERCLA, as amended, Special Notice Letter provisions.
COMUNITY RELATIONS
Community involvement at the Summit National Site has been moderate.
Residents and press have maintained an interest in U.S. EPA activities at
the si te.
An administrative record has been established for the Summit National site.
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This record contains information regarding the Remedial Investigation,
Feasibility Study, emergency activities and other historical and
administrative information pertinent to the site. The record is located at
the U.S. Post Office, 1365 Route 14, in Deerfield, Ohio. The U.S.EPA
issued a press release announcing the availability of the proposed plan,
Feasibility Study, and other site-related documents; location of the
repository; the public comment period, February 12 to March 21, 1988; and
the public meeting at the American Legion Hall in Deerfield, Ohio, on
February 29, 1988. The index to the Administrative Record is in
Attachment 2.
The public meeting was attended by about 150 interested parties, news
media, and public officials. During the meeting the U.S. EPA presented the
Feasibility Study. The presentation described the different alternatives
considered for the site and the preferred alternative. Questions were
answered and public comments were invited and accepted. The response to
written comments received during the comment period are presented in the
Responsiveness Summary, Attachment 1.
SCOPE OF RESPONSE ACTION
This record of decision addresses all affected media at the Summit National
site. The scope of response action includes contaminated groundwater,
surface and subsurface soils, surface water, sediments, buried drums and
tanks. This record of decision is the only operable unit and is the final
remedy for the Summit National site.
SITE CHARACTERISTICS
Results of U.S. EPA's Remedial Investigation at the site indicate that
surface and subsurface soils, sediments, surface water, and groundwater
beneath the site are contaminated with a number of organic and inorganic
compounds. Samples taken off-site (south and eastern perimeter) have also
been affected by site contamination. The following section presents the
major findings and conclusions of the media sampled based on the result
from the data obtained. A summary of the most representative organic and
inorganic parameters for each media is presented in Attachment 3.
GROUNDHATER
The hydrogeology of the Summit National site is complex. For purposes of.
discussion and analysis, the strata at the site has been separated into
three hydrogeologic units; the water table aquifer, the "intermediate"
units, and the Upper Sharon "aquifer," as shown on Figure 3.
Groundwater in the water-table aquifer flows southward and eastward and
does not vary much on a seasonal basis. The water-table aquifer is
generally 5 to 12 feet below grade. The intermediate unit is separated
into two stratas by an unamed limestone- The upper portion flows
southeastward and the lower portion flows westward. Groundwater in the
Upper Sharon flows northward. ...
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REFUSE l_
PILE p\
JUS ROUTE V- I'
MW2 '
SOUTHl
^...;.V.^r^v.<^jT.^^^^^n
-«——«^ . ^—r», ^ ml il i'1' •* -,•'" '-1", -Tn'' i* ** I i
•.',!,' •' SlIiit'wifH'iCNSCS OF CLMSIOIIt,
. •:•:•.-.•:-.:•.••• SANDSTONE GBAOIC
: sniuwann ro siLfr SANDSIOW
LEGEND.
V
WELL
MOni7flNIAL SCALE
0 5O KX>
W«TtH Uvtl
IN COMPUUD1
-|rucn WCK
SilO"*—MTORAUtlC CONDOCTIVITr fj—
(CM/SCO
CONTACTS DAS>«0
WICRE ICNIAIIVE
VtBICAL SCM.E
ICXACC.EHAIIUII -5X)
FIGURE 3
GENERAL GEOLOGIC SECTION
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Vertical gradients within bedrock vary across the study area. The gradient
between the water-table aquifer and all deeper strata is downward at all
locations. In bedrock, vertical components are upward at the southern
portion of the site and downward in the central portion.
Shallow onsite groundwater in the water-table aquifer and uppermost
intermediate units is contaminated with a number of organic compounds,
including 2-butanone, phenol, toluene, and bis (2-ethyl hexyl) phthalate.
The highest concentration of these contaminants occur in the southwestern
quarter of the site and generally decrease across the southern half of the
site, from west to east.
Of the deeper intermediate wells, levels of contaminants were detected in
only one well, MW-24. Wells in the Upper Sharon aquifer do not present
contamination problems. None of the residential wells, which represent
water in the intermediate unit and Upper Sharon aquifer, indicated levels
of organic contaminants above background. Background is defined as those
parameters that occur within the natural range for the area in soils,
groundwater, sediments, surface water, and air. Each media is compared to
background levels present in the same media.
SOILS
The background soils representing local residential, farm and strip mine
soil had detectable levels of numerous organic and inorganic compounds.
The origins of these contaminants were not able to be determined from the
data obtained during the RI. However, some inorganic compounds such as
aluminum, arsenic, iron, maganese, and nickel are associated with coal and
coal-refuse, and therefore are naturally occurring in a coal mining area.
The onsite surface and subsurface soils (down to 8 ft.) were found to have
levels of numerous organic and inorganic contaminants. Many of these
contaminants were not observed off site, such as benzene, toluene, and
phenol and some were found at levels up to several orders of magnitude
above background. Soil levels were compared to an average background which
included residential, fanning and mining, and were also compared to
residential alone. Both comparisons indicate the site is contaminated and
has affected off site soils. Off site soils south of the site at the cement
plant also contained numerous polynuclear aromatic hydrocarbons (PAH's) and
other organics at levels above background. The eastern offsite soils also
showed contamination, particularly PCBs, at levels that exceeded
background concentrations.
SURFACE WATER
Surface water flow at and near the site was observed to occur only in
response to seasonal precipitation events. Therefore, no reliable flow
estimates or stream loading characteristics could be made. The onsite
surface water was found to be contaminated with organic and inorganic
compounds at concentrations above background. The east pond had
consistently higher levels of contaminants than the west pond, based on
total fraction concentration..
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Offsite surface water is also contaminated with organics and metals at
concentrations above background. The major areas of contamination are the
south ditch (downstream) and the lower east drainage ditch (Figure 2).
SEDIMENT
Onsite sediments were found to be contaminated in all fractions analyzed
based on concentrations that exceeded background soil concentrations and
upstream sediment concentrations (not affected by the site). The west pond
samples detected higher concentrations of contaminants in the organic
fractions, while the east pond samples showed higher levels of inorganics.
The offsite sediment in the southern ditch (upstream and downstream) and
lower east drainage ditch were found to have organics that exceeded
background. The first and second impoundments located off site to the
southeast also showed minor contamination.
AIR QUALITY
The results of the RI indicated that the site emits lowjevels of VOCs to
the air. However, the levels were far below Federal health and safety
standards. U.S. EPA concluded that air contamination should not occur
unless there is a surface disturbance at the site.
BURIED MATERIAL
Result of the buried materials investigation at the site indicate that five
buried tanks and an estimated 900 to 1,600 drums are buried on site.
Estimates indicate that the total number of drums existing intact that may
contain waste can be 675 to 1,200. Out of five tanks, U.S. EPA removed
one tank in Spring 1987. The tank contained several organic and inorganic
compounds.
SUMMARY OF RISKS
As part of the RI process, a risk assessment was conducted to determine the
potential risk the site may have on human health. The study concluded that
unacceptable health risks (greater than 10~6 excess life time cancer risk)
may occur under a number of exposures. The potential pathways of exposure
are incidental ingestion and direct contact of soil, and consumption of
contaminated groundwater in the shallow and intermediate water bearing
units beneath the site.
Under current conditions exposure of on-site trespassers, offsite workers,
and residents, to soils have an average risk which range between lxlO~8 to
3xlO"6. For the sane exposure scenarios but under a plausible maximum
case, the risks range between 2xlO~4 to 4xlO~5. The maximum exposure
scenario represents a potential for moderate exposure. The noncarcinogem'c
index is less than 1 for both scenarios and therefore, noncarcinogem'c
health effects are not likely to occur.
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Exposure to sediments under current condition included offsite ditches and
the second impoundment. The risk range for the average case is 2xlO~7 to
6xlO-2 and for the maximum case is 6xlO"6 to lxlO~7. Carcinogenic health
affects are not likely to occur under these scenarios with the exception
of exposure to ditches under the maximum case. Noncarcinogenic health
effects are not likely to occur since the hazard index is less than one.
Under future conditions, onsite workers and residents have a range of
IxlO-5 to 2xlO"7 under an average exposure scenario, and 5xlO"3 to 2xlO~4
under the maximum exposure scenario. The noncarcinogenic hazard index
exceeds one under the onsite residents plausible maximum exposure scenario.
These results represent a significant potential for carcinogenic and
noncarcinogenic health effects.
Exposure to groundwater for onsite residents and workers for future
conditions range between lxlO'3 to 4xlO"9 under the average case, and 3xlO~l
to ixlQ-3 under the maximum exposure case. The noncarcinogenic hazard index
for the water table exceeds one for both the average and maximum cases. The
highest risks are associated with the water table aquifer, which represent a
significant potential for both carcinogenic and noncarcinogenic health
effects.
A summary of potential risks associated with the Summit National site is
presented in Table 1.
DESCRIPTION OF ALTERNATIVES
The following assembled remedial alternatives represent a range of
remediation applicable to the Summit National site. A cost summary is
presented in Table 2. The detailed cost analysis for each alternative is
presented in Attachment 4.
ALTERNATIVE 1 - NO ACTION
The Superfund program must evaluate the no action alternative to establish a
baseline for comparison. However, at the Summit National site this
alternative is not protective of human health and the environment as
demonstrated by the conclusion of the Public Health Evaluation. Therefore,
the no action alternative is not effective and eliminated from further
consideration for this site.
ALTERNATIVE 2 - RESIDENT RELOCATION WITH MONITORING
This alternative includes access and deed restrictions, relocation of the
Watson residence located on the eastern perimeter, runoff and groundwater
monitoring. This alternative can be implemented within one year at a
present worth cost of $820,000.
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TABLE 1
SUMMARY OF POTENTIAL RISKS ASSOCIATED WITH THE SUMMIT NATIONAL SITE
Exposure Scenario
Total Cancer Risks
Average
Plausible Maximum
Honcarclnogenlc Harard Index
Average Plausible Haxlnun
Current Conditions 'Soil
On-ilte trespasser*
Off-site workers (southern perimeter)
Off-site residents (eastern perimeter)
Current Conditions -Sediment
Children In ditches
Teenagers In second Itipoundnent
future Conditions
Ori-siie workers
Soil
Uater (able
Intermediate Unit
Upper Sharon Aquifer
On-slte residents
Soil
Groundualer
Water loble
Intermediate Unit
Upper Sharon Aquifer
} x 10
6 x 10*
3 x 10'
•6
2 x 10
6 x 10
12
2 x 10
5 x 10'
-7
2 x 10"
4 x 10
1 x 10"
"9
t x lo
'3
1 x 10'
8 x I0
"fl
3 x 10
4 x 10
•5
2 x 10'
6 x 10
1 x 10"
-6
2 x 10"
3 x 10'2
1 x 10'3
NA
5 x 10"3
3 x 10
2 x 10"
NA
"1
HA
<1
NA
NA = not aijillcable. only one representative
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ALTERNATIVE 3 - CAPPING AND OFFSITE DRUM INCINERATION
The major components of this alternative are: excavation and off-site
incineration of the contents of buried drums and tanks; construction of a
RCRA cap over the site to reduce contact with contaminated materials;
construction of a soil-bentonite slurry wall to limit migration of
contaminated ground water; lowering of the water table Aquifer by the use of
220 well points; extraction of contaminated groundwater from the Upper
Intermediate unit by 12 wellpoints; and access restrictions, monitoring, and
resident relocation as described in Alternative 2. This alternative can be
implemented within one year at a present worth cost of $15,000,000.
Groundwater extraction and treatment will be the same in subsequent
alternatives,
ALTERNATIVE 4 - ONSITE RCRA LANDFILL FOR YADOSE SOIL
This alternative consists primarily of the same components, including off-
site incineration of the contents of buried drums and tanks, as contained in
Alternative 3, except that contaminated onsite soil within the vadose zone
will be excavated and placed into a RCRA landfill constructed on site. As
with Alternative 3, site fencing, deed restrictions and monitoring will be
necessary since contaminants remain on site. This alternative can be
implemented within a two to three year time period at a cost of $22,000,000.
ALTERNATIVE 5 - THERMAL TREATMENT OF "HOT SPOT" SOIL
This alternative consists of similar components as Alternative 3, with the
additional excavation and onsite thermal treatment of approximately 32,000
cu. yds. of highly contaminated soil. This alternative had initially
included the excavation and treatment of only 27,000 c.y. However, after
further review, it was determined that an additional 5,000 c.y. would have to
be removed and treated. The rationale for the additional soil volume is
based on surface soil blocks exceeding the 1 X 10~5 upperbound cancer risk as
depicted in Figure 4. The drum and tank contents would be treated on site in
the mobile incineration unit. One incineration unit would be employed at the
site and the duration of treatment would be approximately 5 years. Treatment
residue from the onsite incinerator would be replaced in an onsite RCRA
landfill. The time frame for this alternative is five years and has a
present worth cost of 325,000,000.
ALTERNATIVE 6 - THERMAL TREATMENT OF YADOSE SOIL
This alternative includes components similar to Alternative 5, except that
instead of treating only "hot spot" soil,' all vadose soil determined to be
contaminated, based on RI soil boring data, would be excavated and
incinerated. A total of approximately 105,000 cu. yds. of soil would be
excavated, incinerated onsite, and backfilled in the same manner as described
in Alternative 5. Two incineration would- be employed onsite and the duration
of treatment would be approximately nine years. The present worth cost is
$46,000,000 for alternative 6.
-------
1SOIL BLOCK INCLUDED IN
"HOT SPOTS" SOIL
REMOVAL SCENARIO
2' DEPTH OF EXCAVATION
X EXISTING SITE BOUNDARY
• • — STREAM
zoo
100
HORIZONTAL
SCALE IN FEET
APPROXIMATE
FIGURE 4
DELINEATION OF "HOT SPOTS"
SOILS REMOVAL SCENARIO
SUMMIT NATIONAL RESPONSIVENESS SUMMARY
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-14-
ALTERNATIVE 7 - THERMAL TREATMENT OF ALL UHCONSOLIDATED MATERIAL TO BEDROCK
In this alternative, all contaminated, unconsolidated materials, including
buried tanks and drums, all contaminated vadose soil, and all saturated
unconsolidated materials associated with the contaminated portion of the
water table Aquifer would be excavated and treated on site.
Contaminated soil and other unconsolidated materials amounting to
approximately 430,000 cu.yds., would be treated on site using the thermal
treatment system described in Alternative 5. Treatment of this material
would require an estimated 12 years. The present worth cost is $127,000,000.
ALTERNATIVE 8 - IN SITU VITRIFICATION OF "HOT SPOT" SOILS
This alternative parallels Alternative 5 with the major difference being that
in situ vitrification of "hot spot" soils are used as the soil treatment
method, rather than onsite incineration. The onsite RCRA landfill would also
be eliminated as the soils are vitrified in place. Buried drum and tank
contents would be transported off site for thermal treatment. This
alternative once in place can be completed within a two year time frame.
The present worth cost is $29,000,000.
ALTERNATIVE 9 - IN SITU VITRIFICATION OF VADOSE SOILS
This alternative parallels Alternative 6 with the major difference being that
in situ vitrification of the vadose soils is used as the soil treatment
method, rather than onsite incineration. The onsite RCRA landfill would also
be eliminated as the soils are vitrified in place. Buried drum and tank
contents would be transported off site for thermal treatment. Rather than a
multi-layer cap, the site will be covered with a simple soil cover at the
completion of vitrification. Implementation can be achieved within seven
years at a present worth cost of $39,000,000.
GROUNDWATER RESPONSE
The pump and treatment system is incorporated in Alternatives 3 through 9.
The vertical barrier and pumping of the contaminated groundwater in both the
shallow water table and intermediate unit would lead to restoration of the
aquifer. Pumping in the intermediate unit is approximately 2 to 10 years to
fully dewater the onsite water table aquifer. However, pumping will be
perpetual for gradient control purposes. Cleanup of the intermediate aquifer
could occur wuthin 5 to 10 years. These calculations are based on data
collected during the RI which indicated a range of hydraulic conductivities
values. The extraction .system consists in the installation of 220 wells over
the site on a 50 ft. grid system.
The treatment process will meet water quality standards and effectively
protect human health and the environment. In absence of standards, discharge
levels will obtain the best available technology economically achievable
criteria. Treated water will be discharged to a surface water point located
-------
-15-
approximately 3500 feet downgradient of the site. The treatment system will
include precipitation, flocculation, coagulation, oil and water separation,
filtration, and carbon absorption. It is unlikely that any violations of air
emissions of volatile compounds will occur. However, monitoring controls
will be taken to assure compliance with air quality standards.
COHPARATIVE ANALYSIS OF ALTERNATIVES
The major objective of the FS for the Summit National site is to evaluate
remedial alternatives, that are designed to remediate site contamination and
associated problems. The evaluation criteria is consistent with the goals
and objectives of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended by Superfund Amendments and
Reauthorization Act of 1986. The remedial alternative must effectively
mitigate and minimize threats to human health, welfare and environment, be
implementable, and cost effective.
The nature and extent of site hazards summarized in the Summit RI, form
the basis for identifying specific objectives for remediating contaminated
soil and subsurface wastes (buried drums and tanks), sediment, surface
water, and groundwater and associated free product. The risks identified
at the site in the public health risk assessment establish the basis for
identifying site-specific goals of remedial measures.
The alternatives were screened based on their ability to protect human
health and the environment; achieve State and Federal ARARs (applicable or
relevant, and appropriate requirements); reduction in toxicity, mobility,
and volume; long and short-term effectiveness; implementability; cost
effectiveness; State and community acceptance. Based on screening and
detailed analysis of remedial alternatives for the Summit National site,
several assembled remedial alternatives, including the no action
alternative, were developed.
A summary of the Detailed Analysis of Alternatives is presented in Figure
5. The purpose of the following section is to summarize the relative
performance of the alternatives evaluation with respect to the criteria.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The no action alternative and relocation/monitoring alternatives (1 and 2
respectively), do not provide adequate protection of human health and the
environment. The relocation of the Watson resident removes the risk
associated with exposure to offsite soils, but does not satisfy the
overall protection criteria. Since these two alternatives do not satisfy
the protectiveness criteria, they are eliminated from further
considerati on.
The remaining alternatives provide adequate protection, although they do
so through different combinations of treatment, engineering, and
institutional controls. All alternatives eliminate the exposure routes to
any residual contamination which would result in. eliminating any residual
risks associated with the site.
-------
ALMMNAflV* I
AiriMNAriwt i
AlTI»MAriVll
ALTIMNATIVI «
ALTCHNATIVtf
r»»«< *».>«•• •» -**
ALTIflNAfrVI •
n^ft !,.•._« ^
MTtMNATlVtr
IVH*>« f (•H*H< if M
ALTtftNATIVI •
AlTCMNATrVflf
tlt*U« Mill* lMl**r*IIM *f
*mut MMU
! ««lMW •* M||| U
«M«* Mill kf MC«
•f» *l(Ml 11*4 *IU tMdtlM M«
* I*** if'MIKM*!! IIMt II
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•*• HM«lll«d »tl» U
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r*ii4»tni/ •* uu u
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Figure 5
»UUM**« of omitio
ANALVIIS Of AITIMNATIVCS
SUMMIT NATIONAl SIT!
-------
-17-
COHPLIANCE WITH APPLICABLE AND APPROPRIATE REQUIREMENTS
All protective alternatives are designed to attain the applicable and
appropriate requirements of Federal and State environmental laws.
LONG - TERM EFFECTIVENESS AND PERMANENCE
Alternative 7, thermal treatment of all contaminated material down to bedrock,
offers the highest degree of long-term effectiveness and permanence since it
will destroy virtually all organic contamination present at the site. This
alternative is very comprehensive in its scope and is extremely difficult to
implement.
Alternatives 6 and 9 afford a high degree of long-term effectiveness and
permanence by treating and immobilizing all currently known sources of
contamination. While incineration would destroy the organic fraction, the
containment of the inorganic fraction would be achieved by the installation of
the double synthetic liner. The vitrification alternative, would encapsulate
the contamination providing effective immobilization of both organic and
inorganic compounds. Alternative 6 is as effective as alternative 9, but due
to the liner, alternative 6 may have move intensive long-term management.
.Alternatives 5 and 8 are equally effective but are less long-term effective
and permanent than alternatives 6, 7, and 9. Alternatives 5 and 8 involve
treatment of a lesser amount of contaminated soil, resulting in a greater
amount of residual contamination. The remaining untreated soil would be
properly contained by the multi-layer cap and any Teachability of the soil
would be collected by the leachate collection system. Leachate production
will be minimal since the water-table will be maintained at a level below the
residual contaminated soil. This alternative may require longer-term
management than alternative 8.
Alternatives 3 and 4 are identical in the amount of material they leave behind
to be managed over time. Alternative 3 provides a multi-layer cap which
eliminates direct contact. Alternative 4 would, however, affords a slightly
higher degree of long term effectiveness in that residuals would be disposed
of in an onsite RCRA landfill. The landfill would include a ctouble synthetic
liner which would prevent leaching into groundwater.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
Alternatives 5, 6, 7, 8, and 9 would all satisfy the statutory preference for
treatment as a principal element. The remedy would address the principal
threats at the site under each option.
Alternative 7, would involve thermal treatment of all unconsolidated material
and is expected to destroy 100% of all contaminated material, therefore
affording the highest degree of reduction in toxicity, mobility, and volume.
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-18-
Themal treatment will achieve a destruction and removal efficiency (ORE) of
99.99" for each individual principal organic hazardous constituent (POHC).
When dioxins or PCBs are present, the ORE is 99.9999% for each POHC. The
degree of overall reduction in TMV correlates to the volume of material that
will be treated, which is greatest under alternative 7, and least under
alternative 5.
Alternatives 8 and 9 involve in-situ vitrification which encapsulates
contaminants thus immobilizing and preventing exposure to their toxicity. The
overall reduction in TMV is greater in alternative 9 than under alternative 8.
Alternatives 3 and 4 involve treatment of drum and tank contents, which are
equal in reduction of TMV. However, neither alternative addresses the highly
contaminated soils so that the principal threats are not fully addressed by
treatment.
SHORT - TERM EFFECTIVENESS
Alternatives 2 and 3 are most effective in the short-term in that they can
achieve their respective response objectives in less than one year with no
potential adverse impacts resulting from implementation activities.
Alternative 8, in-situ vitrification of hot spot soils could be implemented
within a two year time frame, which is comparable to alternative 4
construction of a RCRA landfill. There are no anticipated potential adverse
effects associated with implementation of vitrification. Alternative 4
requires the excavation and handling of contaminated soils which is
technically more comprehensive and could result in short-term adverse effects.
Implementation of alternative 5, thermal treatment of "hot spot11 soils is
estimated at five years. This alternative could pose potential short-term
effects due to excavation, materials handling, and possible air emissions.
Alternative 9, in-situ vitrification of contaminated vadose soils would
require a seven year implementation time frame but is not expected to result
in adverse impacts on workers, the community, or the environment.
Alternative 6, thermal treatment of vadose soils is estimated at nine years
which could pose potential short-term effects. Alternative 7, thermal
treatment of all unconsolidated materials, is the least effective of all
alternatives in the short-term due to the 12 year time frame. This
alternative has the highest potential for adverse impacts on workers, the
community, and the environment.
IMPLEMEHTABILITY
Alternatives 5 through 9 involve onsite remedial technologies which do not
result in off-site complications. Alternatives 5,.6, and 7, involve thermal
treatment of approximately 32,000f 105,000, and 430,000 c.y. respectively.
The imp!ementability considerations associated with the handling and treatment
-------
-19-
of contaminated soils, construction of an onsite RCRA landfill, and the
pumping of the groundwater, presents least, implementability problems in
alternative 5 and the most difficult in alternative 7.
In-situ vitrification is a less proven technology than thermal treatment.
Implementability considerations with this technology for alternatives 8 and 9,
include the availability of vitrification units, and the uncertainty over the
technical feasibility in the specific waste matrix.
Alternatives 3 and 4 involve off-site thermal treatment of drums and tanks.
The transportation and off-site disposal of hazardous materials may present
difficulties with the availability of transportation services, and capacity of
a RCRA facility. Alternative 4 is more difficult to implement than
alternative 3 since it involves the additional handling of soils and
construction of an onsite RCRA landfill.
COST
Alternative 7, thermal treatment of all unconsolidated materials, is by far
the most costly alternative with a present worth cost estimated at
$127,000.000. This compares to $46,000.000 for alternative 6, thermal
treatment of the contaminated vadose soils, and $39,000.000 for alternative 9,
in-situ vitrification of contaminated vadose soils.
Alternative 4, RCRA landfill of vadose soil; alternative 5 thermal treatment
of "hot spot" soils; and alternative 8, in-situ vitrification of "hot spot"
soils offer more comparable costs at $22,000.000, $25,000.000, $29,000.000
respectively. Capping with off-site incineration of drums and tanks under
alternative 3 would cost $15,000.000.
STATE ACCEPTANCE
The State of Ohio has been consulted throughout the Remedial Investigation
and Feasibility Study process. Based on discussions with by the Ohio
Environmental Protection Agency plan on the RI/FS and proposed plan, the
State concurrs with the selected remedial alternative at the Summit National
site.
COWUNITY ACCEPTANCE
The local community, in general, supports U.S. EPA's preferred alternative
based on the comments received during the public comment period. Citizens
were concerned with the quality of their drinking water and would like a
residential monitoring program to be implemented by the U.S. EPA. Some
concern were raised regarding air emissions from the incinerator. These
concerns are adequately addressed in the Feasibility Study and will be
adressed in the Responsiveness Summary.
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TABLE 2
COST ESTIMATE SUMMARY AMD TIME TABLE
Present
Capital Annual Worth
Alternatives Cost 0 4 M 30 yrs at 1OT
1.
2.
3.
4.
5.
6.
No Action 0 0 0
Resident Relocation $ 150,000 $ 71,000 $ 820,000
with Monitoring
Capping with off site $11,000,000 $ 359,000 $ 15,000,000
Drum and Tank
Incineration
RCRA Landfill' for $18,000,000 $ 364,000 $ 22,000,000
Vadose Soil
Thermal Treatment of $13,000,000 $ 1,132,250 $ 25,000,000
"Hot Spot" Soils
Thermal Treatment of $21,000,000 $4,083,500 $46,000,000
Estimated Time
At Completion
N/A
< 1 year
< 1 year
2-3 years
5 years
9 yearfP
Contaminated Vadose
Soils
7. Thermal Treatment of
All Unconsolidated
Material s
8. In-Situ Vitrification
of "Hot Spot" Soils
9. In-Situ Vitrification
of Contaminated Vadose
Soils
$43,000,000
$15,000,000
.-$12,000,000
$12,187,000 $127,000,000
$ 5,178,700
$ 29,000,000
$ 5,646,500 $ 39,000,000
12 years
2 years
7 years
Pumping is perpetual since its function is gradient control.
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-21-
SELECTED REMEDY
Based on the evaluation of effectiveness, implementability, protect!veness,
reduction of toxicity mobility, and volume, and cost of each proposed
alternative, the comments received from the public and the Ohio EPA and the
State and Federal environmental requirements, Alternative 5 - Thermal
Treatment of "Hot Spot" Soil has been determined to be the most appropriate
alternative. However, the selected remedy has been modified to include
an additional volume of soil from 27,000 c.y. to 32,000 c.y. (See Alternative
5 on page 12). This results in an additional $1,000,000 for a total of
$25,000,000.
This alternative provides adequate protection to public health and environment
and significantly reduces the volume, toxicity, and mobility of contaminants.
This alternative utilizes treatment technologies, permanent solutions to the
maximum extent practicable, and is cost-effective.
A site plan and cross section of Alternative 5 are presented in Figures 6 and
7 respectively. The components of the selected alternatve are described as
follows:
- Access and Deed Restrictions: A fence will be extended around the site
perimeter to assure unauthorized personnel from interfering with ongoing
remedial actions and preventing human and animal exposure to site
contaminants. Deed restrictions are necessary to control the use of the
property once the remedy is in place.
- Elimination of Onsite Surface Water: Surface water in both onsite ponds
will be collected by mechical methods and treated prior to discharge.
The south and east drainage ditch will be re-routed to an uncontaminated
area beyond the site. Sediments excavated from the ditches will be
treated along with onsite soils. Surface water in ditches will be
treated prior to discharge.
- Excavation and Incineration of Buried Drums, Tanks, "Hot Spot" Soils,
and Sediments: A mobile incinerator will be assembled on-site to
incinerate approximately 1,600 drums (88,000 gallons of waste), four
tanks with volume ranging from 1,000 to 7,500 gallons of waste, 32,000
cubic yards of contaminated soils, including 1,500 cubic yards of
contaminated sediments. Performance standards for incinerators of
hazardous waste are designated in 40 CFR 264.343. The destruction and
removal efficiency (ORE) for each principle organic hazardous constituent
(POHC) is 99.99 percent, thereby providing level of assurance that other
constituents are also being destroyed. For PC3s and dioxins the ORE is
99.9999" for each POHC. Incineration of waste can be completed within 5
years. Air monitoring will be conducted to assure no air quality
standards are violated as a result of the excavation and incineration of •
soils, sediments, and drums.
- Instal 1 5f.:on of a Double Synthetic Liner: The incinerated material would
be disposed of in an on-site RCRA landfill. This requires the
construction of an underlying double synthetic liner. See Figure 3.
Ths I •'.I-." Dropossd satisfies EPA/530-SVJ-35-01-, "Minimum Guidance on
-------
TVPICAL UPPER
INTERMEDIATE UNIT
---> EXTRACTION WELL
-- SPACINO
<*c> or
l« TRACTION WELL! ON
90' OHIO
SLURRV WALL
SITE FENCC OELINEATINO
AREA Of DEED
RESTRICTIONS
ONJITE STRUCTURE!
REMOVAL
fttf..f APPROXIMATt LIHI1I
OF"HOI '
RUNOFF UONITORIN8
LOCATION
M« WATER TABLE
I MONITORING WELL
mi INTERMEDIATE UNIT
I MONIIORINO WELL
.U* UPPtR SHARON AOUIfIR
A MONITORIN9 WELL
POTENTIAL ARCAI OF
BURIED ORUMI
ESTIUATCO AREA OF
CONTAMINATED GftOUNDWATER
IN UPPER INTERMEDIATE
UNIf/UPPER INTERMEOIATI
UNIT EXTRACTION VEU.I
ON 100' 6RO
IX)
II >
(CAIE IN FEET
APPROHIMAII
ALTERNATIVE 9
THERMAL TREATMENT
OF "HOT SPOT" SOIL
SITE PLAN
SUMMIT NATIONAL Fl
FIGURE
-------
•ouu m
• i.U HHCt
MIH II- IAICR CAP : I4"vlO«IAJIV« IOIL LAIfK
KNIhEllC OKAIIIAOE LAYCR
40 UIL JINIHEIIC UCMUHAIIE
14 COUPACIED CLAYIAIER
WAUR TABI ( AUUIIER
MIL COIIIIS OH 90rr. CENTER*
I WAI I H PUUHP 10
ui.sirc inuibinr UNII I
• A1H fHOM INCINCRATIONOF
VAOUSt SOIL AHDSCOIMENT
nemo
'> /X ^^ /\ /
^.^x2iAA
rRCLOCAIIO
FENCE
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LINED StStEU: JINIMttlC IE
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-24-
Double Liner Systems for Landfills and Surface Impoundments, Design,
Construction and Operation." Groundwater and Leachate monitoring
will be required to evaluate the performance of the landfill.
Removal of Onsite Structures: All onsite structures would be demolished
or dismantled and disposed of onsite. Structures placed into an on-site
RCRA landfill do not require decontamination as designated in 40 CFR
264.114.
Installation of a Vertical Barrier: A soil-bentonite slurry wall
approximately three feet thick would be constructed around the perimeter
of the site to a depth of approximately 40 feet. This depth would
include six feet of penetration into the bedrock to assure a good seal.
The permeabilit of the slurry wall will achieve approximately 10~?
cm/sec. The slurry wall will prevent lateral migration off site of
groundwater and free product.
Installation of Groundwater Extraction System: A network of 220 wells
installed on a 50 ft. grid system over the site, and a pumping rate
of 30 gpm was assumed. These figures will have to be refined by
performing in-field pumping tests for final design. Twelve of the
220 wells will extract groundwater from the intermediate units. The
extracted water will be treated onsite.
Groundwater Pump and Treat System: The remediation for groundwater
includes dewatering of the watertable aquifer and stagnating contaminant
migration in the intermediate units. Clean-up of the intermediate
unit can occur within 5 to 10 years. The groundwater pumping will
be perpetual for gradient control purposes. The treatment will
consist of physical treatment including precipitation, flocculation,
coagulation, oil and water separation, filtration, and carbon adsorption.
The effluent levels will attain Federal and/or State water quality
standards. In absence of standards, discharge levels will attain the
best available technology economically achievable criteria. It is
unlikely that air emissions from the treated water will result, however
the appropriate monitoring controls will be taken. The discharge point
will be downgradient approximately 3500 feet southeast of the site.
Installation of a Multi-layer Cap: A multi-layer cap would be
installed over the site to prevent contact with surface soils and
greatly reduce the volume of water infiltration through the
unsaturated zone. Prior to placing the cap the site would be regraded.
to provide site drainage and prevent water from ponding on site. The
layer would consist of one foot of top soil (loam), one foot of earth
clean fill, filter fabric, high density polyethylene (HOPE) drainage net,
and a two foot compacted clay layer. The multi-layer cap is in
accordance with performance standards listed in 40 CFR 264.310. A RCRA
cover design is site specific and the ultimate design will be determined
during the remedial design phase. The diagram provided in Figure 9 is in
accordance with RCRA Guidelines.
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FILTER FABRIC
CONTAMINATED SOIL
SYNTHETIC
DRAINAGE LAYERS
LEACHATE DETECTION
PIPE
2FT. COMPACTED CLAY
K
-------
VEGETATIVE COVER
I FT. LOAM
SYNTHETIC '
DRAINAGE LAYER
2FT. CLAY
. .
-o . v .*' •..--. :*.••
X X X XX X X
I FT. CLEAN RANDOM
EARTH FILL
40 MIL SYNTHETIC
MEMBRANE
CONTAMINATED
SOIL
REGRADED GROUND
SURFACE
FIGURE 9
MULTI-LAYER CAP
SUMMIT NATIONAL FS
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-27-
- Runoff Monitoring: Surface water and sediment samples will be collected
and analyzed on a quarterly basis from the southeast discharge point.
Monitoring will detect any migration of site contamination originating
in soils and sediments. Monitoring will be an ongoing activity.
- Groundwater Monitoring: Groundwater in the watertable, intermediate, and
Upper Sharon aquifer, will be monitored to detect any contaminant
migration. Samples will be taken and analyzed on a quarterly basis at
seven monitoring location points. Monitoring will be an ongoing
activity for a minimum of 30 years.
- Relocation of the Watson Residence and Cement Plant Property:
The installation of the slurry wall, multi layer cap, and rerouting
of the southern and eastern drainage ditch, could not be completed
due to the location of the Watson's and cement plant property.
Additionally, there is a risk associated with soils that exceed 10~6
that also warrants remediation. Therefore, relocation of the Watson's
residence and acquisition of the cement plant property are necessary
to accomplish remediation at the site. The proper steps are being
undertaken with the affected parties and appropriate agencies.
The 30 years present worth value for the selected alternative at a discount
rate of 10 percent, is $25,000,000. The breakdown of the estimated cost is
presented in Table 3.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The risks associated with direct contact with, or ingestion of surface and
subsurface soils, and sediments will be eliminated by the installation of the
multi-layer cap. Additionally, the contaminated soils referred to as "hot
spots" will be treated and contained in an onsite RCRA landfill, which
potentially eliminates migration into groundwater. Any leachate generated
would be extracted and treated onsite.
Onsite incineration may result in short-term low level emissions of organics in
the soil feed, and products of incomplete combustion. There will be an air
emissions control system on the incineration to decrease particulate matter to
the permitted levels. Thus, risks associated with inhalation will be
controlled. -;
The components contributing to protection from groundwater associated risks
include the installation of vertical barriers, groundwater extraction wells
followed by treatment. The barrier reduces contaminated groundwater from
migrating off-site, and in combination with the extraction system, it reduces
the rate of downward contaminant movement. This remediation along with
treatment decreases the long-term health risks associated with groundwater.
Elimination of surface water will eliminate intermittent exposure to surface
water through ingestion or absorption. The surface water will be treated in
the same manner as groundwater. Thus, risks associated with surface water will
be eliminated.
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-28-
The excavation of buried drums and tanks, and the demolition of on-site
structures, may lead to short-term increases in fugitive dust and possible
volatile organics which may lead into short-term health risks. Dust control
measures would be employed during this task, thus mitigating the potential for
health risks from exposure to dust.
The technologies under this alternative achieve adequate protection of human
health and the environment. Access and deed restrictions, and institutional
controls will ensure that no future action will interfere with the components
of the remedial alternative, thus, assuring long-term protectiveness.
Attainment of Applicable or Relevant and Appropriate Requirements
The selected alternative is designed to meet Federal and State requirements
that are applicable or relevant and appropriate. The requirements for the
selected alternative, thermal treatment of "hot spot" soils, are presented in
Table 4.
COST EFFECTIVENESS
~he selected remedy represents the best balance across the evaluation criteria.
It is U.S. EPA's policy to select a remedy which significantly reduces
toxicity, mobility, and volume of hazardous constituents and minimizes long-
term management.
The selected remedy for the Summit National site includes general site
preparation, incineration, excavation and loading of contaminated material, a
double liner system, a multi-layer cap, groundwater extraction and treatment
system, and monitoring at a present worth cost of $25,000,000. The variable
factors that significantly effect the relative cost differences between
alternatives are in-situ treatment, the installation of the double liner
system, and the volume of soils to be treated and handled.
Thermal treatment is a proven technology which can effectively destroy organic
contamination at a reasonable cost. The amount of soils defined as "hot spot"
soils equivalent to 32,000 c.y., is based on historical data, chemical
concentrations, and estimated health risks and residual risks. The delineation
of "hot spot" soils provides an increased level of protection reducing the
upper-bound lifetime cancer risk associated with the site from 2xlO~4 to 2xlO~5-
This removal scenario represents the best balance between protectiveness,
technical feasibility, and cost-effectiveness.
The costs associated with the double liner system are directly related to the
volume of soils to be treated. The double liner system is a requirement and
provides an increased level of protection by containing inorganic residuals in
the treated soils. A detailed cost summary for the selected alternative is
presented in Table 3.
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TABLE 3
Cost Estimate Suiaarv
Alternative 5
Incineration oi Hotspot Soil
Ite»
I. GENERAL SITE PREPARATION
Decontaaination Facility
Hove Hat son Residence
Extend Site Boundary
Extend Site Fence
Reroute 5. Drainage Ditch
Diversion Beri
Demolition oi Site Structures
Buildings for Incinerator
Soil Storage Building
II. INCINERATION
Capital
Maintenance
Operation
III. EICAVATIQN t LOADING OF
CONTAMINATES MATERIAL
Dru» Excavation/Classification
Soil Excavation
Soil Handling and Loading
Backfill Ash and Ccspact
IV. DOUiLE LINER SYSTEM
Clay Layer
Drainage Systei
HOPE Liner
Bestextile
V. MULTI-LAYER CA?
Clav Laver
HDPE Liner
Drainage Laver
Vegetative Soil Layer
Revegetatian
VI. GROUND* ATER
Slurry Mall
Mel Is in Hatar Table Aquifer
Oil Skisners
Wells in Upper Intenediats Unit
5 Year Puup Replacaaent
VII. KATE?. TREATMENT
Total Systaa 50 SrS
VIII. HONITORINS
Onsite Laboratcry
fiunaff Hani tori no
Srsund^atsr Mcniiorino
CONSTRUCTION SU2TOTAL
Health and safety UOZ:
Bid Ccntisency (151!
S::pe Csr.fj agency (201)
CONSTRUCT iGN TOTAL
Peraittir.s t Laqal (51!
Services Curing Ccnstructicn lel'i
TOTAL IMPLEMENTATION COST
Engineering » Dssiq- i!OI!
TOTAL CAPITAL COST;
Caoitai Annual
Cost 0 & H
$14,000 *4,500
$21.000
$20,000
$20,000 $1,000
$75,000
$30,000 $5,000
$54,000
$120,000
$44,000
$1,300,000
$50.000
$1,800,000
$580,000
$180,000
$200,000
$170,000
$170.000
$67,000
$130,000 $3,000
$46.000
$670,000
$310,000 $5.000
$220,000
$530,000
$20,000 $1,000
$690,000
$1.200,000 $180,000
'$90,000
$82,000 $15,000
$250,000 $87,000
$400,000 $110.000
$14.000
$32.000 $54.000
Present Horth 30 Years
QM/Replaceaeient
31 51 101
. $24,000
$20,000
$27,000
$270,000
$9,800,000
$59.000
$95,000
$250,000
$55,000
$3,500,000
$290,000
$810,000
$1,700,000
$600,000
$310,000
$1.100,000
$7.800.000 $19.000,000
$736,000
$1.200,000
$1, 600,000
$11,000,000
$550.000
$900,000
$12,000,000
$1,100,000 III
$13,000.000
$23,000
$15,000
$25,000
$250,000
$9,100,000
•$46,000
$77,000
$130,000
$40,000
$2,800,000
$230,000
$610,000
$1,300,000
$560.000
$250.000-
$ 330 i 000
$16,000,000
$20,000 t
$9,400
$22,000 I
$220,000 1
$7,800,000 t
$28,000
. $47,000
$66,000 tt
$21,000 tl
$1,700,000
$140,000
$340,000
$820,000
$480.000 t
$150,000
$510,000
$12.000.000
FKE:E!i" iiORTH
$32.000.0vv $29,000,000 123.000.000
Jl rrsser.: »or;r. :ai:-jiiir-: issusir.:
r. traat^er.: caned.
r?cia:=^9-t of 30'i t:c3::i. r^cr-.:::.-. in: rsvasatiijr.-: .;ver
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TABLE 4
Compliance with Applicable or Relevant
and Appropriate Requirements for the Selected
• Alternative at the Summit National Site
Requirement
Source of
Regulation
Applicability or Relevance
and Appropriateness
Resource Conservation and
Recovery Act (RCRA)
Standard* for Owners and •
Operators af Hazardous Wast*
Tree cant. Storage, and
Disposal Facilities
•OU Subtitle C,
40 CFR 260
IOU Section 5004.
40 CM 264 and 265
RCRA regulates the generation, transport, storage.
treatment, and disposal of hazardous waste. CERCLA
specifically requires (In Section 104(cX3)(I}) that
hazardous substances from removal actions be disposed
of at facilities in cospUanc* with Subtitle C of RCRA.
Regulates the construction, design, eoni taring.
operation, and closure of hazardous wast* facilities.
Subparts 1 and 0 specify technical requiresents for
landfills and incinerators, respectively.
Standards AcplicaMe to
Transporters of Hazardous Wast*
EPA Administered Permit Programs:
The Hazaroous waste Permit Progra
EPA Interim Policy for Planning
and JoBlementing CE3CUI Offsite
Response Actions
IOIA Section 3003,
40 CM 262 and 263.
40 CT» 170 to 179
RCSA Section 3005,
40 CfR 270, 124
50 FK 45933
Kovenoer 5, 1985
Establishes tile responsibility of offsite transporters
of hazardous waste in the handling, transportation.
and managenenc of the waste. Requires a eantfest,
recordkeeping, and ioaediate action in the event of
a discharge of hazardous waste.
Covers the basic permitting, application, monitoring
and reporting requirements for offsite hazardous
wast* oatnagenent facilities.
Disoases the need to consider treatment, recycling.
and reuse before offsite land disposal is used.
Prohibits use of a RCRA facility for offsite
Management of Superfund hazardous substances if it has
significant ROU violations.
Hazardous and Solid Waste
Anranents af 19S4 (1984
Aoendnents to RCRA)
PL 98-616, Federal Law
71:3101
Clean Air Ac:
40 CM 1 to 99
National Hrvirarmentat
Policy Act
Intergoverrmencjl «eviev of
Feoeral Program
KEPA S«ctton 102C2UC)
Executive Order 12372
«na -0 C'S 29 (Replaces
Jtate «nd >re«-vioe
coarairvat ion process
recuirrt sy l>8 Circjlar
A-9S)
Specific westes are prohibited from land disposal
under the 1984 RCRA Aoendnents. This Includes a ban
on the placement of wastes containing free liquids.
Also, solvent-containing wastes are prohibited frost
land disposal, effective Mowataer 1986. EPA is also
required to set treatment levels or netted*, exempting
treated hazardous wastes from the land disposal ban.
To date, these treatnent standards have not been
proBulgated. The IQA anendaents will also restrict
Oie landfill ing af oast ROU-listed wastes by 1991
unless treatment standards are specified.
Applies to oejor stationary sources, such is treat-
lent units, Olat have cite potential to emit significant
amounts af pollutants such «s W , SO,, 03, lead,
nercury and partieulates (mare tAin 250 tans/year).
Regulations unoer OU do not specifically
regulate emissions froa hazardous waste incinerators,
but it is likely that Prevention of Significant
Deterioration (PSO) provisions would apply to an
onsite thermal treatnnt facility.
CERCLA actions are exempted from the KEPA rrquirenmts
to prepare an enviromental inpact itaterent (E!S)
because U.S.EPA'i deciiiomaking processes in
selecting • rendial action alternative are S;e
functional equivalent of the HE?A analysix.
lequires ttate and local coordination ma reviex
of proposed EPA assisted projects. The £?A
Aaninistrator is reouired to cannLnicate *itn
itace «nd local officials to exolain :he crai'ect,
csrcult MI LI other
-------
TABLE 4
(con't)
Compliance with Applicable or Relevant
and Appropriate Requirements for the Selected
Alternative at the Summit National Site
Requirement
National Pollutant Discharge
elimination System (NPOES) Permit
Toxic Pollutant Effluent
Standards
Conservation of Wildlife
Resources
Occupational Safety and Healtft
Act CCSHA)
relocation Assistance and
Property Acquisition
Source of
Regulation
Clean Water Act
Section 402. 40 CF» 122,
123, 125 Subehapter II
tO CfR 129
Fisn ana Uilalife
Coordination Act
29 CFR 1910
Uniform ffelocacion
Assistance and Seal
Property Acquisition
Policies Act of 1979,
40 CfS 4
Applicability or Relevance
and Appropriateness
Regulates the discharge of water into public
surface Maters.
Regulates the discharge of the following
pollutants: aldrin/dieldrin, DOT, endrin,
toxaoftene, benzidine, and PCS'*.
This act requires agency consultation prior
to modifying any body of water.
Regulates working conditions to assure safety
and health of workers.
Requires that property owiers be compensated
for property acquired by the federal government.
* Interim RC2A/CSJCLA Guidance
on Ken-Contiguous Sites and
Onsite Management of Waste ard
Treated Residue
U.S.iP* Crounowater Protection
Strategy
U.S. EPA Pal icy
Statement
March 27,
U.S.SPA Policy Statement
August 1984
If a treatment or storage unit is to be constructed for
onsite remedial action, there should be clear intent
to disn»ntle, remove, or close the unit after the
CERCLA action is ecnpleted. Should there be plans
to accept comnercial waste at the facility after the
CEHCLA waste has been processed, it is EPA policy
that a ROW permit be obtained before the unit is
constructed.
Identifies grounduater quality to be achieved
during remedial actions based on the aquifer
characteristics and use.
5T*Tg
ICC.11
**
State Hazardous Waste Site
Permit
. Local Generating Perait ar
License for Semeoy
State Hazardous Waste Manifest
and State Permit ar License for
Transport of Hazaroous Waste
Ohio Solid and Hazardous
Waste Disposal Law and
Ohio Hazardous Waste
Management Peculations.
Ohio Revised Cade:
3734-01 through 99 and
Ohio Aoninistracive Code
374S-50 through 69.
Zoning, building ar fire
code, ar local licensing
laws.
Ohio hazardous uaste
Jianaqement. hazareeus
materials transoort, ar
camnerciai driver
licensing regulations.
CMo ^oninistrative
Coae 3741-52, 53
If a new hazardous waste facility ant be created
to handle the wastes for longer than 90 cays,
itate approval and/or generator 1.0. nay be required
as a precondition.
Obtain local permit ar license approving operation
of lice facilities.
In general, the manifest systems recuire :?,r generator
to aotain a pernit :~ transport wastes on pudiic
rignts-of-'oy vitnin ;ne state, to use only
licensed transporters, ind to desiqnate only a
peraittea TSO facility :a rake delivery or .jsces.
* These are aoc ARARS, however they will be applied as necessary.
** Perniins are nor reauired but nonecheless the condicions will be mec.
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TABLE 4
(con't)
Compliance with Applicable or Relevant
and Appropriate Requirements for the Selected
Alternative at the Summit National Site
Requirement
Local Approval of Grading
** (Erosion Control) Permit
(Ohio his requirements tor
trosion control)
Source of
Regulation
Applicability or Relevance
and Appropriateness
Local grading ordinances
or erosion control
ordinances.•
** Local Approval of Use Permit Local Building Code
** Local Building Permits (includes
electrical, pluming and KVAC)
Local Building Codes
Requirements affecting land slope and cover,
sur-face water management, alteration of natural
contours, or cover by excavation or fill.
Demonstration through presentation of evidence or
onsite inspection that remedial action complies
with the requirements of local health and safety
laws and ordinances.
Obtain permits for construction.
** Ohio NPCES Permit
** State Solid Waste Site Permit
Ohio Water Quality Standards
Regulates all point source discharges to surface
waters of the state.
Ohio Water Pollution
Control. Ohio
Administrative Code
3745-33, 40 CFR 123.
Ohio Solid Waste and
Licensing Requirements.
Ohio Administrative Code
3745-27 and 37.
Ohio Administrative Code Establishes minimum water quality criteria
3743.1 requirements for all surface waters of the state.
Regulations solid waste treatment, storage and disposal
activities.
** Permits are not required but nonetheless the conditions will be met.
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-33-
Utlllzatlon of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable
All alternatives were carefully evaluated according to the evaluation
criteria. After balancing the outcomes of the various alternatives, the
selected remedy is the most appropriate solution for the Summit National site.
This selected remedy provides permanent protection of human health and the
environment from risks associated with soils, sediments, surface water and
groundwater. Protection is achieved by utilizing alternative treatment system
that destroys contaminants to non-hazardous levels. The long-term
effectiveness is achieved within a 5 year time frame without causing
potential risks. This remedy can be readily implemented at a reasonable cost
and represents the practicable extent to which permanent solutions and
treatment technologies can be utilized at the site.
Preference for Treatment as a Principal Element
The selected remedy addresses the principal threats posed by the site through
the use of treatment technologies, thus satisfying the statutory preference
for remedies that employ treatment as a principal element.
OPERATION AND MAINTENANCE
Several operation and maintenance (O&M) costs are associated with post closure
activities after completion of the remedial action. The O&M costs were
estimated on an annual basis over 30 years. The O&M for the selected
alternative will require ongoing maintenance and monitoring of the onsite
landfill and cap construction, groundwater extraction system, water treatment
system (up to 12 years), runoff and groundwater monitoring. The O&M costs are
presented in Table 3.
STATE AGREEMENTS
A financial agreement with the State of Ohio would be needed in the event
negotiations with the potential responsible parties are unsuccessful. Section
104(c)(3) of CERCLA sets forth the State's financial responsibilities in
remedial actions provided under CERCLA. The State financial responsibilities
in the proposed remedial action would include payment or assurance of payment
of 10% of the costs of remedial action, and assurance of all future O&M costs
after the initial 1 year period of the remedial action. With respect to O&M
costs for ground and surface water restoration, the State financial
responsibilities would be incurred after an initial 10 year period.
The capital costs of the remedial action will be covered under a State
Superfund Contract between the State and the U.S. EPA at the completion of
design of the Remedial Alternative. The annual operation and future O&M costs
will be covered under a Cooperative Agreement between the State and the U.S.
EPA at the completion of design of the Remedial Alternative.
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-34-
FUTURE ACTIONS
The need for any future actions for the Summit National site will be explored
during pre-design. Pre-burn tests will be required to demonstrate the various
type of thermal treatment processes that are applicable for the particular
waste at the Summit National site. Pumping tests will be done to refine the
exact location and numbers of extraction wells to enhance pumping of the
watertable and intermediate aquifers. These pre-design actions and additional
information will be used during the design, and cost estimates will be revised
to reflect a more accurate cost for the project.
SCHEDULE
The following is a preliminary schedule estimated for implementation of the
selected remedial alternative. This is a tentative schedule and is subject to
change pending negotiations with the responsible parties, and unforeseen
obstacles related to design and construction.
Approval of Remedial Action June, 1988
(Sign ROD)
Estimated Design Period 15 months
Complete Design August, 1989
Advertise for Competitive Bids September, 1989
Open Bids October, 1989
Contract Award November, 1989
Notice to Proceed December, 1989
Estimated Construction Period 5 years
Construction Complete December, 1994
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Attachment 1 - Responsiveness Sunmary
-------
RESPONSIVENESS SUMMARY
SUMMIT NATIONAL SITE
DEERFIELD, OHIO
The U.S. Environmental Protection Agency (U.S. EPA) held a public comment
period from February 12, 1988 through March 21, 1988, for interested
parties to comment on U.S. EPA's Feasibility Study and Proposed Plan
(dated February 12, 1988) for the Summit National Site. During the public
comment period, the U.S. EPA held a public meeting at the American Legion
Hall in Deerfield, Ohio, on February 29, 1988. The purpose of the
public comment period is to provide an opportunity for citizens, state
and local officials, Potentially Responsible Parties (PRPs) and other
interested and affected parties, regarding the selected remedial
alternative for the Summit National Site. This Responsiveness Summary
summarizes the major issues raised by the public and addresses them as
part of the Record of Decision (ROD) process.
The Responsiveness Summary is divided into three major sections that
address general and specific comments received from the Public, State,
and PRPs.
I. Public Comments on the Remedial Alternatives - Community Concerns
Nine community groups submitted written comments to U.S. EPA during
the public comment period: Kent Environmental Council, Deerfield
Township, Citizens Actively Protecting Sites, Mrs. P. King, Mrs. A.
Turnball , Mr. and Mrs. Huchok, Mr. T. Edward, Mr. R. Ringen, and
Mrs. Doris Carver.
The comments are organized and addressed according to the following
categories:
A. Start-Up of Remedial Action
Comment:
In general, the community is concerned that one and one half
years is too late to start cleaning up the Summit National Site.
They request that U.S. EPA initiate the clean-up as soon as
possible and that the removal of drums be the top priority.
U.S. EPA's Response:
Once the remedial alternative is selected and finalized with the
signing of the ROD, U.S. EPA is required by the law to notify the
Potentially Responsible Parties (PRPs) and reach an agreement within
120 days that will provide the PRPs the opportunity to undertake the
selected remedy. If negotiations with the PRPs fail, then U.S. EPA
will fund the clean-up while litigation continues. The average time
frame for a complex site such as Summit National, is approximately 15
months. The Summit National Site is a very complex project and any
remedial action must be designed and planned carefully to avoid any
-------
-2-
adverse impacts during its implementation. The selected alternative
does include the removal of drums. Currently, drum contents are not
migrating from the site. In the event that drums are suspected of
leaking and threatening water supplies at any time prior to
implementation of the selected remedial action, U.S. EPA has the
authority to take action. U.S. EPA is currently considering a
monitoring program to detect such an event. This proposed monitoring
program would be in operation until and during remedial action at the
Summit National Site.
B. Emission Controls on the Incinerator
Comment:
An environmental group questioned if the proposed incinerator had any
emissions control.
U.S. EPA's Response:
The on-site incinerator will be designed so that all applicable
requirements, State and Federal regulations listed on Table 6-1 of the
Feasibility Study (FS) and Table 4 of the Record of Decision will be
met (i.e., Resource Conservation and Recovery Act (RCRA), Clean Air
Act). The emission control system for an incinerator typically
consists of a gas scrubber system and a particulates scrubber system
as shown on the attached schematic (Figure 1). Exhaust gases from the
kiln'enter a secondary chamber afterburner operating at temperatures
between 1400°F and 2400°F to complete oxidation of the combustible
waste. Prior to release to the atmosphere, exhaust gases from the
afterburner pass through air pollution control units for particulate
and acid gas removal. All of the existing mobile rotary kiln systems
use a scrubber as part of their air pollution control system. General
operating standards for incinerators treating hazardous waste are
outlined by federal regulations contained in 40 CFR 265, Subpart 0 of
RCRA (FIGURE 1).
C. Groundwater and Surface Water Treatment Process
Commentl
Local environmental groups questioned whether the treatment process
and if such process complies with water quality standards and the Safe
Drinking Water Act.
U.S. EPA's Response:
The surface water and groundwater treatment system will be designed to
remove both organic and inorganic contamination. This system will
include physical and chemical treatment technologies. The used
activated carbon units resulting from the treatment process will be
disposed as a hazardous waste according to federal hazardous disposal
standards. The treatment process itself is not regulated by the Safe
Drinking Water Act since its effluent is not a drinking water source.
The discharge of the treated water will meet the water standards or
-------
-3-
limits set forth under the National Pollution Discharge and
Elimination System. The treatment system could cease to operate once
the upper intermediate aquifer is restored in approximately 5 to 10
years based on data obtained during the Remedial Investigation (RI).
Standards under the Clean Water Act would have to be met at this time.
t
D. Concerns About Drinking Water Supplies
Comment;
Many citizens are unhappy about the existence of dumps in the
area and how it is affecting their residential wells. One resident
requested a Federal and State grant to install an alternate water
supply to residents in Deerfield, Ohio.
U.S. EPA's Response;
The U.S. EPA gives high priority to cleaning up facilities where the
release of hazardous substances has contaminated drinking water
supplies. The Summit National Site has released contaminants into the
groundwater, but has not affected the surrounding residential water
supplies. If these residential wells became affected by the site,
then U.S. EPA has the authority to evaluate response actions that may
include a provision for an alternate water supply. The proposed
groundwater monitoring program would detect contaminant migration to
local residential wells. The Ohio Department of Health (ODH) is
currently developing a protocol to ndrjrpss individual requests for
private well sampling. Citizens interested in finding out more
information about ODH's efforts, should contact that agency.
E. Who are the Responsible Parties?
Comment;
The community requested a list of the responsible parties.
U.S. EPA's Response;
A list of the potentially responsible parties identified and notified
by the U.S. EPA is incorporated in the Administrative Record. This
administrative record is available both in the repository located
in the U.S. Deerfield Post Office and the regional offices in Chicago,
Illinois.
F. Concerns About Wildlife
Comment;
A resident asked if wildlife is affected by the Summit National
Site.
-------
SOURCE: ENSCO ENVIRONMENTAL
SERVICES
PROCESS FLOW DIAGRAM OF A MOBILE
ROTARY KILN INCINERATION SYSTEM
FIGURE 1
-------
-5-
U.S. EPA's Response:
During the course of the Remedial Investigation, there was no wildlife
observed at the Summit National Site. The site area is fenced and
therefore limits access to animals. In addition, no aquatic life was
observed in the on-site ponds or nearby ditches.
G. Past Mining Activities
Comment;,
One resident asked how far the Old Strip Mine extended.
U.S.EPA's Response;
The area of Portage County surrounding the Summit National site, has
been strip mined extensively in the past. The strip mine pits in the
immediate area of the site are located on the southern half of the
site as well as two identified areas south of the site where the
closed landfill is now located. The approximate locations of the
former strip mine pits covered by the landfill are shown on Figure 4-
34 of the RI report.
H. Surface Water Concerns
Comment;
A citizen suggested a different route to trap surface water from going
to the Berlin Reservoir.
U.S. EPA's Response;
The proposed discharge point for treated water will comply with the
technical requirements of NPDES and is approximately 3,000 feet
southeast of the site. Though this discharge is in the watershed
where the Berlin Reservoir lies, the amount and quality of the
discharge water will not impact the Berlin Reservoir.
I. Inorganic Contamination
Comment;
One resident asked what inorganic compounds were detected at the
Summit National .Site.
U.S. EPA's Response;
The inorganic contaminants detected in each media are presented in the
Remedial Investigation Report Volumes I and II. A summary of the
major inorganic contaminants in each media is presented in Attachment
3 of this document.
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-6-
II.Ohio Environmental Protection Agency Comments
U.S. EPA received comments from the Ohio Environmental Protection
Agency on March 15, 1988. U.S. EPA has taken the State's comments and
organized them into four main subject categories to facilitate
response apd account for any repetition of comments. The categories
are as follows: A. Public Health Evaluation B. Soils and Sediments
C. Remedial Action and D. Selected Alternative.
A. Public Health Evaluation
Indicator Chemical Selection:
The commenter suggests that the methodology used to select indicator
chemicals deviates from the Superfund Public Health Evaluation Manual.
U.S. EPA's Response;
The methodology used to select indicator chemicals generally
follows the guidance in the Superfund Public Health Evaluation
Manual (EPA 1986) and the Endangerment Assessment Handbook (PRC,
1985). The Superfund Public Health Evaluation manual" provides
guidance in developing a Public Health Evaluation at Superfund
sites. Citing the manual's preface, it is designed to be
flexible allowing the use of professional judgement. The manual
provides a range of procedures that may be applicable at any
particular site. The procedure employed, which selected
chemicals of concern for each medium being evaluated rather than one
master list, allowed for evaluation of the greatest potential risk
associated with any particular exposure pathway involving that medium.
This approach is most useful at sites such as Summit National where a
very large number of chemicals have been detected in different media
at different concentrations and occurrence frequency. The various
technologies that make up a remedial alternative will be screened and
selected to remediate contamination on a media-specific basis. A
multi-media list of indicator chemicals would indicate that chemical
compounds detected in all media occurred in similar concentrations,
.frequency, and representativeness. This is not the case at the
Summit National Site. For instance, PCBs were detected in soils and
chosen as an indicator. Since PCBs were not detected in
groundwater, using this parameter as an indicator chemical in
groundwater would be of no use.
Qualitative Risks;
The commenter suggests qualitative statements of risk should be made
for those scenarios that can not be evaluated quantitatively.
-------
-7-
U.S. EPA's Response:
Quantitative risks for groundwater are presented in the RI/FS based on
future use assuming no action and the concentrations remain as they
are now. The selected alternative provides a groundwater treatment
technology that eliminates these risks. Therefore, no additional
qualitative risk calculations for groundwater would be necessary.
Chemicals of concern in groundwater may present a risk to residents in
the future if they migrate to residential wells. As a worst case, it
could be assumed that the concentrations of indicator chemicals being
measured in monitoring wells are future concentrations in residential
wells. However, because the private wells are mostly open boreholes
in bedrock, chemicals from the water-table and intermediate unit could
potentially mix with water from the deeper aquifers at these
locations.
There are several exposure routes that could be considered complete
and could produce significant risk if the spread of contamination is
not adequately contained by the remedial actions. Since
concentrations of contaminants are low for quantitative risk
assessments for contaminants that might migrate along these routes,
qualitative statements of risk are included below to help identify the
potential areas where future risk could increase in a no action
scenario.
There is a possible subsurface hydraulic connection for contaminated
surface water to move southeast along the old stream course from the
first impoundment to the second impoundment below the Jones (Manfredi)
landfill. If significant release of contaminants were to occur, those
waters could carry contaminants from the site into the Berlin
Reservoir via a surface water connection from the second impoundment.
It is likely that dilution in the reservoir basin would reduce the
threat of significant exposure for cities using that water supply.
However, this route is a potential risk to the populations of the .
cities and counties that rely on the waters of Berlin Reservoir for a
drinking water supply.
•
Since some of the soils on the site are known to be highly
contaminated, an exposure route exists through the movement of
fugitive dusts from the site. Dust movement would be particularly
significant during any construction activity as was noted in the RI.
It is also possible that significant dust movement can and does .occur
during high wind conditions. The vegetative cover on the site is poor
and large areas of the site are bare. If the site is left uncapped,
local residents could be at some risk from exposure to dusts blown
past the site boundaries. Because construction is not a long term
activity, potential exposure to fugitive dust would occur only over a
short time period. This occurrence will be monitored closely and the
necessary precautions will be taken during the implementation of the
Remedial Action.
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-8-
Currently, the area of contamination in the groundwater appears to be
localized in the upper aquifers almost entirely beneath the site. If
contaminants are liberated from remaining contamination in soils or if
drums of waste are not removed from the site, there is a potential
risk to groundwater resources that might become contaminated. Since
the groundwater hydrology beneath the site is not entirely defined, it
is possible that pathways exist for contaminant movement into drinking
water wells. Many of the area wells are open boreholes in rock so it
is possible that residential wells could act as a conduit for
contaminant migration to the deeper aquifer. Past mining activities
at the site may also have left conditions that could allow future
migration of contaminants to deeper strata. If conditions at the site
are not adequately remedied, it is possible that residents outside of
the site boundary could be exposed to site related contamination
through future leaching and movement of contaminants in groundwater.
Qualitative risk assessments for surface water in the second
impoundment and the Berlin Reservoir were considered but not performed
since no direct surface hydraulic connection was able to be made
between the site and these two surface water bodies. As stated in the
RI, contaminants from the site that may discharge into the Berlin
Reservoir via groundwater are further diluted by surface water in the
reservoir prior to a water supply intake, to concentrations that are
well below achievable detection limits. Therefore, the Summit
National site would have no impact on public health from use of water
obtained from the current water supply intake from the Berlin
Reservoir. It was concluded that contamination in the second
impoundment is potentially more affected by the landfill operation and
the adjacent spoil piles than by the site.
B. Soil and Sediments
Definition of "Hot Spot" Soils:
The commenter suggests that the areas subject to soil treatment have
not been defined adequately.
U.S. EPA's Response:
The "hot spot" scenario was based on achieving an acceptable level of
protection by reducing the residual risk associated with the site of
2 X 10~4 to 3 X ID"5. The selection of soil block units represented a
balance between protectiveness, cost effectiveness, and implement-
ability. The rationale for selection was set at cells exceeding the
upperbound cancer risks of 1 X 10~5. The initial 27,000 c.y.
represented an economic cost removal scenario with a residual risk of
3 X 10~5. After reviewing the soil blocks units, further
consideration has been given to those isolated soil block units that
exceed 1 X 10"5. As a result, a new "hot spot" scenario has been
developed reducing the residual risk to 2 X 10~5. The total volume of
"hot spot" soils is 32,000 c.y. which includes approximately 3,000
c.y. of off site soils along the eastern and southern perimeter.
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LEGEND
II SOIL BLOCK INCLUDED IN
I "MOT SPOTS" SOIL
REMOVAL SCENARIO
2' DEPTH OF EXCAVATION
X — EXISTING SITE BOUNDARY
— ... — STREAM
STREAM
100
HORIZONTAL
SCALE IN FEET
APPROXIMATE
FIGURE Z
DELINEATION Of^^^f SPOTS*
SOILS REMOVAL SCENARIO
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-10-
This soil removal scenario is depicted in Figure 2. The additional
costs associated with incinerating, and handling the soils is
$1,000,000.
Soil teachability:
The commenter suggests that a more protective alternative be developed
based on potential leaching of soils units.
U.S. EPA's Response:
Alternative 7 Incineration of All Unconsolidated Material as presented
in the FS, is a more complex alternative but not necessarily a more
protective alternative. This alternative would eliminate all leaching
of soil and could be considered as a clean closure option. However,
this level of action does not necessarily provide additional
environmental benefits or protectiveness.
The selected remedial alternative includes a controlled system
consisting of a multi-layer cap, slurry wall, and groundwater pumping
to achieve gradient control. . These components will minimize water
passing through the residual contaminated soil blocks, therefore
minimizing leaching. The commenters specific statements concerning
leaching of antimony to groundwater were not accurate. The RI states
that antimony is mobile once in groundwater because of its solubility.
It also states that sbrption to clays and metal oxides is the most
important mechanism for removing antimony from natural waste. This
characteristic would seem not to favor leaching.
Soil Clean-up Levels:
The commenter questions how the evaluation of soil blocks are related
to clean-up target levels for soils and sediments.
U.S. EPA's Response:
As explained«in Appendix A of the RI (page A-l), the cancer risks
associated with soil blocks were estimated by comparing the
concentrations of the indicator chemicals present in a soil block to
those representing a range of lifetime upperbound cancer risks, as
indicated in Table 3-2 of the FS. A cancer risk was then extrapolated
for the concentration present in the soil block. The cancer risks for
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-11-
each individual indicator chemical were then summed arithmetically to
develop a total upperbound lifetime cancer risk for the soil block
being analyzed. An example calculation for cell block 4-5 at 0-2 ft.
follows:
• Extrapolated Risk From
Indicator Chend/*^! Concentration T^le 3—2
Bis(2-ethylhexyl)phthalate 81,000 1.1 x 10~7
1,2-Dichloroethane 4,300 8.0 x 10"7
Hexachlorobenzene 0 0
PCB 590,000 5.4 X 10"3
PAH 00
Trichloroethene 86,000 1.9 x 10~6
Total Risk = 5.4 x 10~J
The cleanup levels presented in Table 3-2 are based on a 10~6 cancer
risk for each chemical presented. Therefore, this table provides
general guidance in selecting cleanup goals. Because all of the
carcinogenic chemicals included in this table were not found in.all
samples from all locations, or detected at concentrations that exceed
a 10~6 risk level, it is inappropriate to siaply divide the
concentrations listed by the total number of carcinogenic chemicalst
listed to determine clean-up concentrations that correspond to a totial
risk of 10~6.
C. Remedial Action
Slurry Wall;
The commenter questions how soils during the construction of the
slurry wall will be handled.
U.S. EPA's Response:
The slurry wall will be constructed outside of the limits of
contaminated soils and groundwater plume. Therefore, no contaminated
soils will be handled during its construction.
The commenter sites a RCRA waste pile requirement due to stockpiling
of wastes.
U.S. EPA's Response;
The stockpile is a short term staging area, (i.e. less than 90 days),
where the contaminated soils will be stored prior
to them being incinerated.
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-12-
A temporary synthetic membrane will be placed underneath the staging
area to contain drainage from contaminated materials. This would
conply with RCRA waste pile requirements.
The commenter sites a RCRA landfill requirements or 5 ft. separation
between the water table and bottom of the landfill.
U.S. T^PA'g 'Response? .....
The capping of contaminated materials and continual pumping of the
water table to stabilize the downward vertical gradient will provide
enough separation between the RCRA landfill and the water table to
meet the 5 ft. requirement for citing a landfill. Additional
hydrogeological characterization to adequately control groundwater
movement and remove contaminated water from the intermediate zone will
be conducted for the final design of the landfill and groundwater
extraction system.
Reliability
The commenter suggests that reliability for the liner was incorrectly
evaluated .as an extremely positive benefit (++) .
U.S. EPA's Response;
The criteria of reliability assessed on Figure 6-1 of the FS report,
applies to the overall alternative. The notation of "++" on Figure
6-1 for Alternatives 5 through 9 is based on the addition of reliable
treatment technologies to each alternative. Considering the RCRA
landfill alone, the notation for reliability would be "+" as shown for
Alternative 4.
Sediments
The commenter questions how sediments will be handled.
U.S. EPA's Response;
In Alternatives 8 and 9, as well as Alternatives 5 through 7,
contaminated sediments will be excavated and treated on-site.
Approximately 1500 c.y. of off -site sediment will be treated along
with the on-site soils.
The RI/FS has addressed sediment contamination associated with the
Summit National site. Significant movement of surface water off -site
had occurred prior to the RI sampling and also was occurring during
the RI field activities. . The samples collected during the RI were
indicative of any off-site transport of contaminants via surface
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-13-
water. In addition, the emergency action performed shortly after the
RI sampling (March 1987), corrected the uncontrolled overflow problem
from the eastern pond and regraded portions of the site to prevent
runon/runoff. Overflow from the east pond is now controlled through
discharge pipes that direct the discharge to the first impoundment.
Double Synthetic Liner;
The commenter believes that the construction of extraction wells and a
liner will not provide for a sound integratable structure, considering
the large number of wells to be utilized.
U.S. EPA's Response:
The installation of a double synthetic liner and leachate extraction system
around the pre-installed groundwater extraction wells does not impact the
integrity of the liner. Gundle Lining Construction Corporation and
Schlegel, two of the largest liner contractors, have provided construction
details that illustrate adequate seals at a point where extraction wells and
liners meet (see attached Figures 3, 4,and 5.). .This type of liner has been
constructed and proven to be a reliable technology in various construction
applications. The design effort will try to minimize the-number of wells
used while maintaining the effectiveness of the groudwater treatment system,
based on the additional hydrogeologic characterization, as-noted previously.
Groundwater Extraction:
The commenter suggests that an indepth analysis of the effects of
groundwater extraction be performed.
U.S. EPA's Response;
Further hydrogeological characterization, as noted previously will be
required to finalize the design of the groundwater extraction system.
This data will be obtained during the remedial design phase. The 220
wells proposed across the whole site are based on the current
hydrogeological information. Due to the poor yield of groundwater and
lack of pump test results, additional hydrogeological data need to be
obtained in the pre-design or design phase. The number, location, and
spacing of wells is not to be interpreted as the final estimate, but
rather a preliminary estimate. The design will focus on a minimum
number of wells through the liner that will effectively extract the
contaminated groundwater plume and provide for a sound integratable
structure.
Well Closures:
The commenter recommends closing the tipple and Watson's wells.
-------
SCHLEGEL SHT.
GAS VENT
NOTCH
HOPE
2" HOPE VENT PIPE BY S.L.T
I" VENT PIPE
(BY OTHERS
EXTRUSION
WELDS
CHLEG
SHEET
GAS VENT DETAIL
N.T.S.
FIGURE
7-83
-------
I
CD
CO
H.D.PE. PIPE
SLEEVE
SEE ANCHOR BOL
DETAIL
//EXTRUSION WELDS
£r?
SCHLEGEISHT^
CONCRETE COLLARS
BOTTOM PENETRATION DETAIL
N.T.S.
FIGURE 4
-------
GUNDLINE
HD LINER
.;•:.: -LjaF.--VS* •**.
.-/•'^V-v^sc '•••>-.
• •» .' . • . **". •* *• -l^iw/V. .
•.
'* .* * '• ** •*-:O•6'-
WELDED BOLT
CONCRETE
INLET/OUTLET-FLANGE SEALING
OF STEEL AND HD PIPE SYSTEM
NOTTOSCALC
FIGURE
n UUICIIOOWMM IMIMIUI M}ICI
Lining Contlnictlon Corp
1340 E niCHEV RO. HOUSTON. TEXAS 77073
DATE: 11-16-84
DRAWING No. SD04
APPROVED BY:
TYPICAL DETAIL
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-17-
U.S. EPA's Response:
The FS narratives indicate that the tipple well and the Watson's wells
should be closed during the Remedial Action. This will be included in
the Remedial Design.
Residential Monitoring Program;
The commenter recommends that U.S. EPA conduct a residential well
sampling program for local groundwater supplies.
U.S. EPA's Response:
A groundwater monitoring program is included as part of the technologies
that address the groundwater operable unit. These monitoring wells include
existing and proposed new wells that are located around the perimeter of the
site. These wells would detect any groundwater contaminant migration from
the site toward residential wells. A residential well sampling effort could
be initiated at that time if contamination was detected in the monitoring
wel1s.
Strip Pits and Mine Shafts
The commenter raises the concern of strip pits and mine shafts in the
area.
U.S. EPA's Response:
Data collected during Phase I and II field investigations did not detect
the presence of any 70 feet deep strip pits or old mine shafts at the
site. This information was provided by a local resident recently during
the public meeting on February 29, 1988. Due to the potential impact
these features could have on implementation of the remedial alternative,
the identification of such geological structures should be considered-
during the Remedial Design data collection phase.
D. Selected Alternative *
Retained Alternatives:
The commenter is not satisfied with how Alternatives 5 and 8 are
compared.
U.S. EPA's Response:
Section 7.3 of the FS presents a further comparison of Alternatives 5
and 8. These alternatives were retained after comparison of all
alternatives presented in Section 7.1. The detailed analysis of all
alternatives is provided in Chapter 6 of the FS report. Alternatives 5
and 8 were similar in cost and comparable in terms of protectiveness,
attainment of applicable, relevant and appropriate requirements (ARARs),
reduction in toxicity, mobility, and volume (TMV), and technical
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-18-
feasibility. Reliability and availability were more variable factors in
distinguishing between the two alternatives.
Elimination of In Situ Vitrification (ISV) (Alternatives 8 and 9)
The commenter states that ISV was eliminated based on unavailability and
reliability.
U.S. EPA's Response:
Availability was not the sole factor for eliminating Alternatives 8 or 9
from consideration, which included ISV as the primary treatment
technology for soils. There was no sole factor for their non-
selection. Elimination was based on an evaluation of all criteria to
eliminate or select a preferred alternative. The selection of a
preferred alternative is based on overall suitability and on proven
effectiveness, implementability and cost factors.
An evaluation of reliability between Alternatives 5 and 8 can be
performed. ISV has no performance record that shows it is a reliable
technology at hazardous waste sites. On the other hand, incineration
has a performance record at waste sites- which in itself.indicates more
reliability than ISV as a treatment technology.
On-Site Sediments in the East and West Basin
The comnenters states that the FS did not address contaminated on-site
sediments in the east and west basins and that removal and treatment
must be included in the final remedial action.
U.S. EPA'S Response:
The west basin is included in soil removal area and will result in the
removal to a depth of 2 feet. The risk values for the east basin
sediments indicate they should be addressed. The volume of sediments
will.be calculated and included during initial design activities.
III.PRP Comments
Legal Comments
Following are the responses to the legal comments made by the PRPs in
their March 21, 1988 submission. The PRP commenters have made a
number of comments directed to the legal aspects of the RI/FS public
comment process. These comments fall into two general categories: (1)
challenges to the "fairness" of the timing of the Summit National
public comment period and availability of the administrative record,
and (2) challenges to the entire RI/FS process under SARA, as
administered by U.S. EPA. Region V believes that both the particular
process observed in the Summit National situation and the procedures
it follows in allowing public participation under SARA are fully
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-19-
consistent with and protective of the rights of the commenting
potentially responsible parties.
A. Comments on Public Participation and the Administrative Record
Comment:~
The PRPs dlaim that the public comment period was too short, and that
they were not provided with timely access to the administrative
record.
U.S. EPA's Response;
The originally identified PRPs were afforded an opportunity to perform
the RI and FS, at a series of meetings held in June and July, 1982.
They declined to do so, and U.S. EPA proceeded to undertake the RI
studies. U.S. EPA's consistent policy with respect to its RI work has
been to share only the final document with the public, along with
documentation in the administrative record that shows the information
considered or relied on by U.S. EPA. The final RI was not, in fact,
available until the date on which it was made public. The conclusion
of the RI/FS process was delayed by periods in which funds to continue
the work were not available due to lack of appropriations. U.S. EPA
is not aware who "led" PRPs to believe the RI was concluded and final
in mid-1987 (comments at 12). U.S. EPA did not lead the PRPs to this
conclusion. In any event, the PRPs received their statutorily
mandated opportunity to review and comment on the RI and FS, including
access to the administrative record, with minor exceptions of a very
few documents whose contents were reflected in the RI itself.
On page 9, in footnote 1, the PRP commenters raise claims that "30 new
.PRPs" were identified by U.S. EPA. U.S. EPA believes all identified
PRPs and the rest of the public have received notice of U.S. EPA's
view of their status and the availability of the RI, FS, and
administrative record. U.S. EPA's obligation is to provide notice of
the documents' availability and an opportunity to review the
documents. As a courtesy, U.S. EPA provided a number of copies of the
RI and FS directly to counsel for certain PRPs, with the understanding
that said counsel would distribute them further. U.S. EPA believes it
has met its obligation under SARA and the NCP.
The public comment period was not, as asserted in the comments, only
23 days. The RI and FS were originally made available on February 12,
not February 17, 1988 as the PRPs assert. U.S. EPA also extended the
comment period from March 11 to March 21, 1988. U.S. EPA believes the
guidelines set forth in the present NCP [40 CFR 300.67(d)] provide
adequate comment time in light of the competing interests resolved by
the cleanup process outlined in Section 104 of SARA and in the NCP.
The PRPs1 bare reference to documents that were not included in the
Record in no way identifies how these documents were or are somehow
essential to U.S. EPA's determination of a remedy or to the PRPs1
review of that determination. It is worth noting that while the U.S.
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-20-
EPA did not deliver the entire administrative record to the public
repository required to be established under SARA until February 29,
1988, no PRP, despite publication of the record's intended location
there and its clear availability in Chicago (where it was available
beginning on February 12, 1988), made any effort to see or refer to
the record tprior to February 29. U.S. EPA therefore questions whether
the record's date of delivery had any effect upon the rights of the
PRPs. U.S. EPA exercised its discretion not to allow the PRPs to
comment on the FS during development, which discretion is clearly
provided in 40 CFR 300.67(a). In sum, U.S. EPA believes the
opportunities afforded the PRPs, to do the RI and FS, and to comment
on the U.S. EPA's RI and FS once they declined to undertake them, are
fully consistent with both SARA and the NCP.
B. Comments directed to the Administrative Process followed by the U.S.
EPA under SARA."
Comment:
The PRP commenters have challenged the entire process followed by the
U.S. EPA in conducting the RI/FS, and demand trial-type proceedings in
remedy selection, including cross examination of U.S. EPA employees
and contractors.
U.S. EPA's Response;
The PRPs in their -comments seek to challenge the entire U.S. EPA
statutory and regulatory process of determining remedial actions at
Superfund sites. Congress has established the general framework for
that process, which is fleshed out by the regulations incorporated
into the NCP. The NCP was duly promulgated as a regulation and the
time for challenge has long since passed. The PRPs cite a number of
cases in support of their view that the process is constitutionally
flawed. U.S. EPA respectfully but completely disagrees with the PRP
view on the constitutional adequacy of SARA's remedial selection
process. Analysis of a claim of deprivation due process requires
determining what process, in the context of the particular claim of
deprivation, is due. The RI/FS process is intended by Congress to
determine the remedies to be employed to deal with releases or threats
of releases of hazardous substances from facilities like Summit
National. It is not an adjudication of rights or liabilities of any
person, nor does it result in the denial or deprivation of those
rights. The processes of determining any liability for payment of
cleanup costs incurred by U.S. EPA, or performance of injunctively
defined remedial work, are set out in Sections 107 and 106 of SARA, 42
U.S.C. 9607 and 9606. Remedial decisions are more akin to notice
and comment rulemaking. This form of administrative process is simply
not subject, in most cases, to trial-type proceedings of the sort
demanded by the commenting PRPs.
The PRPs cite U.S. v. Hardage, 663 F.Supp. 1280 (W.D. Okla. 1987) as
requiring PRP involvement, trial type proceedings and the
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establishment of a "neutral decision-maker," to provide minimal due
process. U.S. EPA disagrees with the PRP reading of Hardage, which
was a pre-SARA action under Section 106 of CERCLA seeking an
injunction requiring PRPs to perform a cleanup. Hardage holds only
that when EPA seeks injunctive relief, it subjects itself to the
equitable powers of the court, which allows the court, despite the
SARA scope-of-review provisions in 113(j), to make a de novo
determination of the applicable remedy.
No 106 relief has been sought here, nor has U.S. EPA sought access to
the courts in connection with this facility. Courts generally have
recognized, and Congress has determined, that no pre-enforcement
review of U.S. EPA remedial decisions is available. The PRPs have
been given notice of U.S. EPA's process and an opportunity to comment.
That is all the process due for this stage of the proceedings. The
PRPs are given an opportunity to challenge U.S. EPA's decision at the
stage where U.S. EPA undertakes enforcement action. The PRP comments
will be evaluated and responded to in the course of developing the
Record of Decision for this facility.
U.S. EPA believes it appropriate to direct the
PRP's attention to U.S. v. Rohm & Haas Co., Inc.,
669 F.Sup. 672 (D.N.J. 1987).The Court
distinguished and disagreed with Hardage. and
made the following observations:
While we agree that defendants must be afforded
some kind of a hearing prior to the assessment of
costs against them, we do not believe that they
are constitutionally entitled to the full, trial-
type hearing that they seek. The flaw in
defendants' argument is that it assumes that due
process requires a complete adjudicatory hearing,
with cross-examination, on the issue of the
propriety of the response action. SARA itself
contemplates a limited paper hearing before the
Agency, prescribing that "[t]he development of an
administrative record and the selection of
response action under this Act shall not include
an adjudicatory hearing." 113(k)(2)(C) of SARA,
42 U.S.C. 9613(k)(2)(C). Moreover, in Lone Pine
Steering Committee v. EPA, 777 F.2d 882 (3d Cir.
1982), cert, denied, ... the Third Circuit
suggested that due process would be satisfied
with a limited agency hearing. The Third Circuit
rejected the plaintiffs' argument that due
process required pre-enforcement review, holding
instead that the 107 reimbursement hearing
adequately protected the plaintiffs' rights
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In determining the process that is
constitutionally due in a particular case, a
court must balance three factors: (1) the private
interest at stake; (2) the risk of erroneous
deprivation of that interest through the
procedures used and-the probable value, if any,
of 'additional safeguards; and (3) the
government's interest, including the burdens that
additional procedural requirements would entail.
Matthews v. Eldridge. 424 U.S. 319, 335 (1976).
Applying these principles to the present case, we
conclude that the informal hearing envisioned in
SARA and implicitly endorsed in the Lone Pine
case is sufficient to satisfy the requirements of
due process.
First, we recognize the important financial
interest that potentially responsible parties
have in the selection of a response action,
particularly where the liability could amount to
millions of dollars. However, there is an
overwhelming countervailing public interest, as
evinced in CERCLA, in effecting the expeditious
clean-up of potentially health and life
threatening hazardous waste sites. The
imposition of long, drawn-out, and costly trial-
type procedures, either at the agency level or in
a de_ novo proceeding in district court, could
greatly hinder this effort. Moreover, we are
unconvinced that formal trial-type hearings would
advance the defendants' interests inaccuracy or
equity.
With respect to this final issue, it is important
to emphasize the nature of the agency decision-
making at issue here. The agency's determination
of an appropriate response action involves
inspections and testing aimed at discovering the
types of waste present at a site and the extent
of the hazard, and technical investigations to
develop an appropriate solution to the problem.
Congress vested a certain amount of discretion in
the U.S. EPA in its choice of a response action,
requiring only that the costs for which it seeks
reimbursement be not inconsistent with the NCP.
The ultimate selection of a response action
depends upon a balancing, by the agency, of a
number of factors, including cost, technology,
reliability, and public health, welfare and
environmental effects. See 40 C.F.R. 300.68.
Thus, the U.S. EPA's decision-making process at
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issue here need not involve a reconstruction of
past events through eyewitness testimony and
credibility judgments, as would be necessary
where, for example, a liability determination was
being made. Rather, the process involves the
evaluation of numerous expert reports and
technical data. As a result, the focus for
purposes of due process analysis should be on
whether interested parties have an opportunity to
participate in the development of such
informationand technical data before the agency.
Under these circumstances, where the parties are
allowed to comment on the agency's proposals and
to submit reports of their own experts, the
quality of the initial decision-making process
would not be greatly enhanced by the presentaf-on
of live testimony or the use of cross-
examination.
Moreover, we believe that an administrative
record built on such an exchange of opinions and
comments by experts and informed citizens and
containing an explanation by the agency of its
reasons for accepting or rejecting the various
proposals, provides an adequate basis for
subsequent judicial review. Under such
circumstances, the administrative record has not
"been created almost entirely by the U.S.
EPA....[with] virtually no evidence that might
exculpate" the defendants. Rather, it reflects
the contemporaneous analyses and criticisms of
all interested parties, and therefore provides a
comprehensive framework from which the court can
scrutinize the agency's action.
For all of these reasons, we conclude that
SARA's informal agency hearing procedures, and
deferential standard of judicial review satisfy
the requirements of due process. U.S. v. Rohm &
Haas Co., Inc., id. at 679-81.
This extensive quotation, which includes the language extracted from
its context in the PRP's cite at p. 20 of their comments, clearly
supports the process U.S. EPA has and will follow here. The PRPs are •
not entitled to, and will not be given, a trial-type proceeding at this
stage in the process. They are provided by SARA with an opportunity to
review the RI and FS, and the balance of U.S. EPA's record, and to make
comments on the remedy identified by U.S. EPA. They have now availed
themselves of that opportunity. Their comments will be considered and
responded to by U.S. EPA, and incorporated into the administrative
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record. Their comments may affect the remedial selection process which
culminates in U.S. EPA's Record of Decision. Should the U.S. EPA not be
able to negotiate a PRP performed cleanup, post-ROD, the PRPs will be at
liberty to raise issues by way of defense and request a review of U.S.
EPA's remedial decision in any action brought under Section 106 and 107
of SARA.
•
Technical Comments:
The following section provides responses to technical issues raised by
the PRPs and presented to the U.S. EPA in the Summit National PRP
Group Report dated March 11, 1988. Their detailed analysis of the
technical issues are presented primarily in Attachment E which is the
Conestoga-Rovers Associates (CRA) Report. U.S. EPA's response will be
focused on specific technical comments presented in Attachment E in an
attempt to avoid for repetition of comments. A comparison of comments
presented in the main report was made to insure all issues where
addressed in the CRA report.
Attachment E - Conestoga-Rover Associates (CRA) Report Comments and
Responses March 1988
The responses to the CRA report are grouped into several categories.
The Executive Summary is broken into comments concerning the RI and FS
reports and then presents the PRP group's proposed alternative. Each
of these sections will be addressed separately. Following responses
to the Executive Summary, a comment by comment discussion of issues
not already discussed will be performed.
Executive Summary
A. Remedial Investigation;
Comment (1):
The PRPs claim that U.S. EPA did not provide supporting documents and
data necessary for a complete and comprehensive review of the RI/FS.
U.S. EPA's Response (i):
All data collected during both phases of the RI is presented in the
final RI Report, both in Volumes I and II. These data are again
summarized in the FS. All supporting documentation is available in
the Administrative Record located at the Deerfield, Ohio Post Office
and U.S. EPA's regional office in Chicago. There are no existing data
missing that were used in the preparation of the RI or FS reports.
Comment (ii):
The PRPs claim that U.S. EPA did not perform its QA/QC data validation
procedures properly.
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U.S. EPA's Response (ii):
All analytical data collected during the RI were reviewed in
accordance with U.S. EPA quality assurance protocols in place at that
time. These guidelines are presented in Appendix B of the RI Report
Volume II. The valid data are presented in summary tables in Appendix
A of the R-I Report Volume II. The QA/QC assessment procedures are
discussed in Section 4.1 of the RI Report Volume I. A summary of the
analytical problems is presented in Tables 4.2 and 4.3. Based on
these problems, the data were either omitted from Summary Tables or
proper qualifiers were added. Therefore, following the above
guidelines, U.S. EPA has properly identified those contaminants that
are not attributable to the Summit National Site.
Comment (i i i);
According to the PRPs, improper well locations and depths resulted in
misleading hydraulic conductivity data.
U.S. EPA's Response (iii):
The selection and depth of well locations during Phase I of the RI was
based on available data at that time. The Phase II monitoring well
installation program and groundwater investigation activity were based
on data collected from Phase I. This provided more accurate
information on the hydrogeological characteristics of the site. A
pump test was considered. However, the yield of the wells did not
indicate that any reliable data could be obtained due to the low
pumping rate of less than 1 gal/min. that could be sustained. Many of
the monitoring wells were hand bailed dry while purging prior to
sample collection.
Comment (iv):
The PRPs claim that characterization of the intermediate aquifer was
performed incorrectly.
U.S. EPA's Response (iv):
Due to the complex geology at the site, the initial separation of
geologically similar units based on lithology led to the
identification of three primary units for the purpose of the RI
analysis. The intermediate unit was later separated into the upper
and lower units and a discussion of each was performed.
Comment (v):
The PRPs claim that the data for on-site and off-site soils was biased
and contamination levels were over-estimated.
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U.S. EPA's. Response (v):
Soil samples with the highest concentrations for volatile organic
analyzers (VOAs), and base neutral acids (BNAs) screening indicator
compounds were selected because the purpose of the RI investigation is
to define the nature and extent of contamination. Some uncontaminated
samples were sent to the Contract Lab Program (CLP) for analysis to
confirm the accuracy of the screening program. The objective of
selecting samples for analysis is to choose those that pose a concern
and warrant remediation. Uncontaminated samples are not a concern.
If the sampling was conducted in the manner proposed by the
commenters, the conclusions developed would ignore the existing
contamination problem. In addition, the RI sampling program used
covers the overall site and provides data to assess average risks as
well as area specific risks (See Appendix A of the FS Report).
Comment (vi):
According to the PRPs, the RI has failed to address the presence and
source of background soil contamination.
U.S. EPA's Response (vi):
The northern edge of the cement plant was impacted by the Summit
National Site during active site operations. This is based on the
fact that this portion received direct drainage from the site prior to
rerouting the southern ditch and is supported by the analytical data
gathered during the RI. The RI addressed the presence of contaminants
in background soils. An evaluation of background soil data was
performed to determine if certain compounds were site-related,
naturally occurring, or from other sources. This assessment of
background soils is presented in Section 4.4.3.1 of the RI Report.
The presence of contaminants due to other sources is considered, but
the positive identification of other sources is not part of the Summit
National Site investigation. Other potential sources mentioned in the
RI do not indicate that contamination associated with the Summit
National Site originated from other sources.
Comment (vii):
The PRPs state that the presentation of on-site soil data is
misleading.
U.S. EPA's Response (vii);
The presentation of on-site soil data may have confused the
commenters, but it is not misleading. Soil data were presented in
Chapter 4 of the RI Report, with the purpose of defining the nature
and extent of contamination in soils. Presentation of these data in
the form of mass of contaminants was considered but not used. The
presentation of data used in Chapter 4 is not for assessment of risk.
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Neither is mass of contamination necessarily indicative of health
risks. Remediation is based on risk reduction which is based on
health risks identified in the Public Health Evaluation (PHE).
Comment (viii):
According to the PRPs, the RI does not address the potential impact to
surface water in the southern ditch from off-site contaminants in the
cement plant yard.
U.S. EPA's Response (viii);
Surface water flow in these ditches occurs only in response to
precipitation or discharge from the east pond. Laboratory results
indicate the presence of contamination in surface water. The northern
edge of the cement plant property that contributed runoff to the
southern ditch was affected by previous site activities as discussed
previously. Therefore, the source of the contaminants in the southern
ditch can be connected to the site directly or indirectly due to the
site's effect on the cement plant soils. :
Comment (ix);
The PRPs claim that background sediment samples were not collected
during the RI.
U.S. EPA's Response (ix):
The furthest upstream sediments sampling location does not have the
highest level of contaminants as the commenter states (see RI Tables
4-45 through 4-47). Background sediment samples were obtained from an
upstream location not affected by site activity. In addition, the
sediment samples were also compared to background soil samples, since
these soils may have acted as a source for background sediment
characteristics. Both comparisons indicate site related contamination
levels above background soils and sediments for both on-site and
downstream sediments.
Comment (x):
The PRPs state that the investigation used to identify the location
and quantity of subsurface waste was inadequate.
U.S. EPA's Response (x):
All magnetic anomalies identified during the magnetometer survey were
investigated through test pit excavations. These test pit excavations
exposed the buried drums and allowed for visual estimates of numbers
and orientation of buried drums. In addition to subsurface
exploration through test pits, the 32 soil borings across the site did
not encounter any buried drums outside the magnetic anomalous areas. A
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drum investigation through parallel trenches is very extensive and
better suited for a remedial design data collection effort.
Comment (xi):
According to the PRPs, the RI fails to determine or estimate the
ultimate fete of groundwater contaminants.
U.S. EPA's Response (xi);
A delineation of the groundwater plume in the water table and upper
intermediate wells is presented in Figures 4-13 through 4-16, 4-18 and
4-19. The potential for groundwater contaminant migration is
presented on Tables 4-9 through 4-11 which predict concentrations at
points 100 ft., 1450 ft., and 4500 ft. down-gradient of the site.
Based on the above, both the plume and ultimate pale of groundwater
contamination has been defined.
Comment (xii):
The PRPs claim that the Public Health Evaluation (PHE) assumes a worst
case scenario which leads to a great overstatement of present and
future risk.
.U.S. EPA's Response (xii);
The PHE does assume the worst case exposure scenario based on the
maximum concentration. However, the PHE also evaluates the risk
associated with average concentration of contaminants. Both analyses
assume the no-action alternative as required by the PHE guidelines.
Comment (xi i i):
According to the PRPs, the PHE incorrectly quantifies carcinogenic
risk caused by polynuclear chlorinated hydrocarbons (PAHs) on the
basis of the total of all PAHs.
U.S. EPA's Response (xiii);
Carcinogenic risks associated with PAHs are based on only those PAHs
considered to be carcinogens.
Comment (xiv);
The PRPs claim that risks from background soils are not significantly
different and in some cases greater than risks posed by the site.
U.S. EPA's Response (xiv):
The total cancer risk associated with incidental ingestion of
background soils over a lifetime exceeds 10~6 for a plausible maximum
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exposure and is equal to 10"^ for the average exposure scenario. The
future residential scenario for exposure to on-site soils results in
average risks of 1 x 10~5 and plausible maximum risk of 5 x 10~3.
Both values are at least one order of magnitude higher for on-site
soils than background soils.
B. Feasibility Study:
Comments (i):
The PRPs believe that the extension of the site boundary is
unnecessary.
U.S. EPA's Response (i);
The extension of the site boundary is not based solely on soil
contamination, but also concerns regarding the off-site extent of
groundwater contamination and contaminated off-site sediments. The
slurry wall and the relocating of the southern drainage ditch must be
constructed beyond the area of contamination. In conclusion, adjacent
offsite properties are required for implementation of the remedial
action.
Comments (ii):
The PRPs propose that a permeable soil cover should be installed
instead of a RCRA cap.
U.S. EPA's Response (ii):
There are no available data to indicate that flushing of the
contaminated subsurface soils would lead to their cleanup.
Infiltration through the permeable soil cover proposed by the
commenters would be counter-productive to the groundwater extraction
and gradient control system as outlined in the recommended
alternative. In addition, the soil cover does not properly contain
hazardous materials from becoming exposed due to freeze and thaw
cycles which can cause cracking.
Comment (iii):
The PRPs believe that the FS has erred in its evaluation by
considering subsurface soils to be available for human contact and
incidental ingestion.
U.S. EPA's Response (iii):
The risk numbers estimated for subsurface soil blocks were used as a
mechanism to select soil blocks to be included in the "hot spot" soil
removal scenario, and not to define the risk of the site. The risk
associated with soils was based on surface soil blocks units. The
risks estimated for soil blocks at 2 ft. depth intervals from 2-8 ft.
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were not the only criteria vised to select "hot spot" soils. Past site
activities, disturbed versus undisturbed soils, and handling during
excavation were also considered. The delineation of "hot spot" soils
represent the most cost effective and practical removal scenario. The
risk numbers used in the PHE represent risk presented by the entire
site based on surface soils which are available for human contact and
incidental ingestion.
Comment f iv);
According to the ERPs, the FS is inconsistent and arbitrary in that
the need for surface control is not evaluated on the same basis as the
need for soil removal.
U.S. EPA's Response (iv);
Risks greater than 10~6 are spread throughout the site, therefore
warranting remedial action to protect against exposure to unacceptable
risks. Risks greater than 10~° are estimated for about 54% of the
cells that range between depths of 0 to 2 ft., and about 48% in cells
that range in depths between 6 to 8 ft. If we look at soil cells as
columns ranging from 0 to 8 ft., about 30% would exhibit risks greater
than 10""6 and this is spread throughout the site. Therefore, a
surface control across the entire site is needed to provide adequate
containment of unacceptable risks associated with soils. Surface
controls are not used only to prevent contact with contaminated soils,
but also to reduce infiltration. Reduction of infiltration through
the surface is an integral part of the groundwater gradient control
system. Any part of the site that is not properly covered would allow
greater infiltration and be counter-productive to the groundwater
treatment system.
Comment (v);
The PRPs believe that the groundwater extraction system proposed by
the U.S. EPA is extremely costly, complicated and unreliable.
U.S. EPA's Response (v): . -;
The primary goals of the groundwater extraction system are to provide
gradient control to stabilize flow from the water table into the upper
intermediate zone and to pump and treat the contaminated upper
intermediate unit and water table aquifer. The interceptor drains and
wet well system proposed by the PRPs, fail to control migration of the
contaminated water table downward, which could continue to contaminate
the upper intermediate unit indefinitely. U.S. EPA's proposed
alternative could allow for cleanup of the upper intermediate unit
within 5 to 10 years.
The commenter has provided no basis for statements regarding cost
while U.S. EPA has provided substantial details of cost estimation
that are within an acceptable FS range of +50 and -30 percent.
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Comment (vi):
According to the PRPs, the FS does not provide an estimate of the
chemical quality of the waste stream from extracted groundwater or
surface water that will require treatment.
U.S. EPA'sResponse (vi):
The chemical quality of the extracted groundwater or surface water to
be treated does not need to be "estimated" as the commenter suggests.
The data obtained and presented in the RI report already provide
current chemical characterization of all water to be treated. The
proposed groundwater treatment system is based on these results. The
current groundwater and surface water quality was evaluated by process
design engineers and no current contaminant characteristics presented
an unsolvable problem to designing a groundwater treatment system to
meet ARARs. A treatability study could be incorporated in the
remedial design phase. Once the system proves effective and is in
place, monitoring will be conducted to assure its efficiency.
Comment (vii):
The PRPs claim that the FS does not develop nor evaluate a sufficient
number of alternatives to rationally evaluate reduction of risk.
U.S. EPA's Response (vii):
In accordance with requirements under the Superfund Amendments and
Reauthorization Act (SARA), an FS should develop a range of treatment
alternatives which is delineated primarily by the degree to which each
alternative relies on long-term management of residuals or untreated
waste. A key consideration is the degree to which the alternative
reduces toxicity, mobility, and volume (TMV) of contaminants as its
principal component. In addition to a range of treatment
alternatives, a containment option involving little or no treatment
and a no action alternative should also be developed. The FS develops
a range of alternatives that beginVith no action, monitoring and a
range of treatment alternatives starting with partial treatment and
full treatment to the maximum extent practicable. This process allows
for a thorough analysis of alternatives and is consistent with the NCP
and SARA. Alternative 2 represents the minimum action alternative
with monitoring only while Alternative 3 represents cont-ainment with
minimal treatment. Alternative 4 provides a better containment
scenario with minimal treatment. Alternatives 5 through 7 provide a
full range of treatment alternatives that incrementally go from "hot
spot" soils treated to full treatment to the maximum extent possible.
Alternatives 8 and 9 provide an additional range of treatment
alternatives by considering an additional treatment technology.
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Oomment fviii);
According to the PRPs, the FS cost estimates are poorly developed and
suffer from several major defects.
i
U.S. EPA's Responses (viii) t
All costs are developed using the U.S EPA costing Tnanuai to provide a
+50 and -30 percent cost estimate. The costing procedures used by
U.S. EPA did apply proper contingency factors where appropriate
according to established costing guidelines. The total cost for a
specific alternative is the sum of the capital cost plus the present
worth of all operation and maintenance costs. An important point to
note is that the costing methodology is consistent for all
alternatives which allow direct comparison of each alternative based
solely on cost, regardless of how technically similar or dissimilar
the alternatives may be. The project cost estimate becomes more
refined as the design progresses from ROD to final design. A more
detailed cost analysis taking into account time completion schedules
will be done in the remedial design phase when the proper plans and
specifications are available.
C. PRP's Preferred Remedial Action Alternative;
This section provides a review and evaluation of the alternatives
proposed by the ERP group. It provides a general response rather than
a focused response on each specifically proposed element. Of the nine
components proposed by the PRPs, seven of them coincide with U.S.
EPA's proposed Alternative 5. The two components that are different
are still fundamentally the same in regard to remedial actions that
are required but different in the choice of technologies.
The groundwater extraction system consisting of an interceptor drain
and wet well system and the proposed permeable cover are the two areas
that differ. This proposal fails to stop groundwater contamination
from migrating downward and does not provide an effective extraction
system for contaminated groundwater. The PRP's proposal would require
intermediate unit groundwater treatment indefinitely.
The permeable soil cover allows for increased potential of groundwater
contamination moving with the upper intermediate zone from the water
table zone and does not adequately contain soils with residual
contamination on site, thus resulting in inadequate protection from
exposure to human receptors and environment. The proposal, however,
appears to be fairly well in agreement with U.S. EPA's selected
alternative with respect to the remainder of components, as presented
in the POD "Selected Remedy."
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BY SECTION PP^SPONSE TO CRA
Only comments that were not specifically addressed in the Executive
Summary Response will be considered in the following response section.
Section 2.0 of the CRA report addresses the RI report and comments
were grouped into general topical categories or concerns for each
subsection and responded to accordingly.
SECTION 2.1 —
CunuiiSI it. ;
The PRPs claim that certain documents were not available to them.
U.S. EPA's Response;
All the documents referenced by the PRPs were available in the
Administrative Record located in the repository at the Deerfield U. S.
Post Office or at our regional office in Chicago. The Remedial Action
Master Plan (RAMP) is not a document that was used to assess site
conditions or evaluate alternatives in the FS process. Items i)
through ix) were developed to address site-specific conditions and
objectives. This is thoroughly discussed in the RI report. Work
plans and Quality Assurance and Project Plans (QAPPs) provide more
detailed information regarding the scope of work to be performed and
the methodology. These documents were final and available for review.
Phase I Work Plan and QAPP were finalized 7/27/84 and 5/29/84,
respectively. Phase II Work Plan and QAPP were finalized 11/5/85 and
10/24/85, respectively. These documents could have been requested any
time after they were finalized.
Comment;
According to the PRPs, the soil screening procedures were inadequate.
U.S. EPA's Response;
The Phase II screening procedure was designed to eliminate the need
for sending all samples to CLP analysis, thus resulting in significant
cost savings. After the screening of all the on-site soil samples was
complete, a plot of the results was evaluated so that the appropriate
samples could be sent to the CLP laboratories. The selection of
samples for CLP analysis was based on the following criteria: .
a. The concentration of contaminant levels;
b. The number of contaminants identified in a particular sample
or group of samples;
c. The location of the sample on the site;
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d. The depth of the sample from the surface; and
e. The proximity of the sample to a buried drum or visually
contaminated area.
Several ."clean" samples were selected for CLP analysis to verify the
accuracy of the screening program. Phase I sampling included a
composite of five sample portions per 100 sq. ft. across the whole
site for a total of 49 surface soil samples. Phase U collected 319
samples out of which 52 on-site samples, 19 background samples, and 25
off-site samples were sent for Hazardous Substance List (HSL)
analysis. These sample locations are representative of the whole
site, as demonstrated in the RI Report Figures 3-9 and 3-10. These
maps clearly show that the sampling program, including screening, are
not biased, but representative of the whole site.
Ouimitenti
According to the FRPs, the soil sample selection was inadequate.
U.S. EPA's Response:
The regrading of the site is discussed in Section 1.2.3 of the RI
report. The site surface regrading was done in conjunction with the
surface cleanup performed by the U.S. EPA in 1981-1982. The surface
cleanup included only incidental contaminated soil removal. Regrading
was performed to control site runon/runoff . This information was
known during the development of the sampling plans. As a result, the
Phase I surface soil sampling program was designed to characterize the
surface soils remaining on site since little contaminated soil was
removed. It is U.S. EPA's opinion that the minor soil removal and
regrading efforts did not redistribute surface soils enough that
composite samples from the 100 ft2 blocks would not be representative
of undisturbed soils. The Phase II sampling program was developed to
determine the vertical extent of contamination below contaminated
surface soils identified as Phase I.
The PRPs claim that the background comparison was inadequate.
U.S. EPA's Response;
The selection of background samples used for comparison to on-site
soils provided a cross section of soil types in the local area. These
included agricultural, residential and mine spoil. The average
background data, therefore, took into account any possible
contribution to chemical characteristics of local soils due to
naturally occurring materials. A comparison was also made to
residential soils alone which resulted in similar conclusions. In
both analyses the site did show contaminant levels several orders of
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magnitude above background, thereby not warranting further separate
.soil type comparison (see page 4-75 of the RI Report). In regard to
inorganics, an additional comparison was made to confirm inorganic
contamination present on site. Levels were compared to U.S. typical
concentrations which indicated that 11 out of 20 inorganics exceeded
background. An on-site soil was determined to be contaminated if its
mean and maximum values exceeded the upper 95% confidence limit for
background soils. If the mean concentration did not exceed the upper
95% confidence limit, but the maximum did, then an evaluation was made
based on frequency. Based on previous discussions, the PHE is
representative of site contaminants and is not typical of background
conditions.
SECTION 2.2 - ANALYTICAL DATA
Comment:
The PRPs state that the analytical data were reviewea-Improperly.
U.S. EPA's Response:
All the data obtained during the RI underwent Quality Assurance and
Quality Control (QA/QC) assessment according to procedures provided in
Appendix B of Volume 2 of the RI Report. These procedures were the
accepted protocol at that time. The "data were reviewed by U.S. EPA
Region V staff and appropriate qualifiers or invalidation was noted.
Tables 4-2 and 4-3 of the RI summarize data problems identified. In
addition to U.S. EPA review, the data were also assessed for Contract
Lab Program (CLP), and Central Regional Lab (CRL) data completion by
ICF/SRW and CH2M Hill staff. These quality assurance objectives and
QA/QC assessments were detailed in the approved Phase II QAPP dated
October 24, 1986 prior to initiating field activities.
Comment:
The PRPs claim that the data were qualified inadequately.
U.S. EPA's Response:
Data results attributable to laboratory contamination are represented
in Section 4 of the RI Report. Parameters such as methylene chloride,
acetone, and toluene with concentrations less than 10 times the
concentration detected in the blank are qualified as lab contaminants,
by both the CLP and the U.S. EPA QA/QC office. The valid data are
presented in summary tables in the RI Volume II and are designated
with the letter "B". Data analysis performed in Section 4 of the RI
report distinguishes those parameters attributable to laboratory
contamination and eliminates them as site-related contamination.
Those concentration levels reported within brackets are qualified as
concentrations below the laboratory detection, limits, which is not
considered a positive hit. Those parameters qualified with a "J" are
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an estimated value. If "J" is accompanied by brackets, it is an
estimated concentration below the contract laboratory detection limit.
SECTION 2.3 - HYDROGEOLOGICAL CONCERNS
Comment:
According to the PRPs, improper methods were used to define
hydrogeological properties.
U.S. EPA's Response;
As discussed previously, we agree that additional hydrogeological.
characterization is necessary. It was necessary to screen monitoring
wells across multiple strata for two reasons: 1) many of the strata
encountered were too thin to be isolated during well construction and,
2) the strata were, for the most part, very fine grained and
relatively unfractured, so it was necessary to install long gravel
packs to assure that the wells would yield sufficient water for
sampling. The cross sections and boring logs are very detailed, so
that many cf the strata identified are very similar to the units
immediately adjacent. Care was taken to avoid installing monitoring
zones across strata which appeared, on the basis of lithology or
fracture density, to be hydraulically dissimilar. Furthermore, if the
monitored zones crossed strata of dissimilar permeabilities, the
hydraulic conductivities measured would" not be "atypical", but would
rather be values most similar to the most conductive unit intercepted.
The commenter does not appear to believe the hydraulic conductivities
obtained for sandstone and coal. The sandstone was fine-grained,
silty, and well cemented. U.S. EPA believes that field data should
not be disregarded just because it does not fit a perceived or
textbook notion.
Comment:
The PRPs believe that there is a need to define regional hydrogeology.
U.S. EPA's Response:
Regional hydraulic information is not needed to remediate a'site.
Monitoring well MW-8 was omitted initially because of the change in.
stratigraphy between it and the remainder of the site as shown on the
cross section provided in both the RI and FS reports.
Comment:
The PRPs believe that hydraulic conductivities are uncertain.
U.S. EPA's Response:
The commenter is uncertain of the hydraulic conductivities because
normally a pump test is performed. Pump tests are not feasible in low
permeability strata. They were considered during Phase II field
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activities but due to low yield of most wells (less than 1 gpm) and
the ability of the wells to be bailed dry during purging they were not
performed.
The PRPs do not agree with U.S. EPA's well instrumentation employed
during the remedial investigation.
U.S. EPA's Response:
The use of PVC material for well construction seems to be a favorite.
topic of discussion. The specifications for well construction were
approved for both the Phase I and Phase H well installation
activities. All recent studies have indicated that FVC is a
reasonable well material, provided the well is purged before sampling.
All wells at the Summit National Site were purged prior to sampling.
The PRPs disagree with U.S. EPA's interpretation of . groundwater
conditions.
U.S. EPA's Response;
There are two aquifers identified at the site plus a series of
intermediate units, not three aquifers as the commenter states. The
intermediate units do not constitute aquifers. The calculations using
Darcy's law to quantify groundwater flow were order-of -magnitude
estimates only; they were never intended to be quantitative. It seems
that the commenter is looking for conclusions beyond the scope of the
PI report. The RI did not present water balance calculations as they
suggest. Again, it was clearly indicated that all flow calculations
were order-of -magnitude estimates.
Comment;
The PRPs have an alternative assessment of the flow system.
U.S. EPA's Response;
The commenter does not indicate the reason for believing that the
intermediate units constitute multiple hydrogeologic units. Although
the limestones indicated extremely low permeabilities, the remainder
of the strata in that zone also have low permeabilities. No high-
permeability strata were encountered, so there is no reason to divide
the series of low-permeability strata into multiple aquitards with no
intervening aquifers. The RI acknowledges that the intermediate units
constitute a highly heterogeneous aquitard, and as a result U.S EPA
does not believe that interpretation of the site is enhanced by
further dissection of this series of strata.
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The commenter's suggestion that the limestone is relatively continuous
and tight and thereby prevents interference between the two
intermediate zones is incorrect. The hydraulic test simply suggests
that we measured a very low permeability in one well. Given the
return of single well test, it is not prudent to evaluate the entire
site interpretation on a.single value.
•
•
The commenter's inclusion of the limestone unit into a subsurface
hydrogeologic water balance appears to constitute an over
interpretation of the data. The possibility that dense non-aqueous
phase liquid (DNAPL) could migrate vertically downward against the
groundwater flow that is up-gradient in the area of MW-22 and MW-23
does not alter any conclusions.
SECTION 2.4 - CONTAMINANT DISTRIBUTION
Soils Sampling Program;
These comments were similar to the general comments in Section 2.1.
The soil sampling program was developed to provide data on the
horizontal and vertical extent of soil contamination at the Summit
National Site. An important consideration in developing a
representative sampling plan is the implementation of a potential
remedial alternative. The 48 square blocks established by the site
grid and a. sampling plan for evaluating four consecutive 2 ft. thick
soil zones in each grid provided data for evaluation of 192 soil
"units" at the site. Each 100 ft. sq. by 2 ft. thick zone was
considered a workable unit of soil that could be isolated effectively
during remedial action implementation. Any further breakdown that
exceeded 192 soil units on an 11 acre site was deemed unnecessary.
Sample compositing is an acceptable scientific methodology used for
characterizing a particular area. It provides data that are
significantly more representative than one grab sample for the entire
area.
Field Screening:
These comments were similar to the general comments in Section 2.1.
The soil sampling procedures and protocols are presented in. Section
3.2 of the RI report. The intent of this, or any soil sampling
program, is to provide the nature and extent of contaminated soils.
This goal lends itself to the analysis of samples presumed to be
contaminated. Analysis of clean samples'will allow for a real
distribution of clean soils from which contaminated soils delineation
could be assumed. However, analysis of clean soils does not allow for
the determination of soil contaminant nature. As stated in the RI,
"clean" samples were also selected for CLP analysis to verify the
accuracy of the screening program.
Cement Plant Soils:
The cement plant soils were designated as background samples during
the preparation of the sampling plan. Background samples were chosen
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from areas that were assumed to be isolated from site-related
activities. However, during the course of the remedial investigation,
it was clear that the cement plant properly received direct drainage
from the site during its active operation prior to rerouting of the
southern ditch. The analytical data supported this conclusion. At
that time, it was decided that the cement plant soils should be
removed from consideration as background. The U.S. EPA has
successfully assessed off-site soil contamination that is site
related. The background soils were discussed separately in the PHE.
Analytical Results (Soils);
The intent of Section 4 of the RI report was to present the data
obtained and assess the nature and extent of site-related
contamination in various site media. The potential risks that these
site-related contaminants have on the public health and environment
are presented in Sections 5 and 6 of the RI report. The commenter
statement concerning presentation of volatile organic compounds
(VOCs), base/neutral/acids (BNAs), Pesticides/Polychlorinated
Biphenyls (PCBs) and inorganic data using total mass can only be
applied to the format for presentation and evaluation of data, not
assessment of risk. There is not a correlation of total mass of VOC
•to potential risk.- Consideration involving extent of soil removal is
more appropriately based on risk reduction rather than contaminant
mass reduction. Risk reduction technologies may either increase or
decrease contaminant mass but will result in reduction of toxicity and
in some cases mobility.
Analytical Results (Surface Water):
Based on water table flow data obtained during the RI investigation,
the water table may discharge to the drainage ditches only during
periods of high groundwater flow. Surface water flow was intermittent
during the RI investigation and, therefore, any component of
groundwater flow from the cement plant toward the southern ditch
probably had passed beneath the ditch and did not contribute directly
to surface water flow.
Analytical Results (Sediments):
U.S. EPA did collect upstream data for sediments from sample numbers
SD-011-001 and SD-032-001. These samples were obtained from the same
location that was upstream of any effects from the site and are
considered representative of background quality in the local drainage
system near the site. This was the primary comparison used to
indicate a downstream sediment contamination problem. Comparison of
sediments to background soils provided an additional analysis that
resulted in similar conclusions being made. This further analysis did
not rule out that the background soils may be an additional source of
off-site sediment contamination. The upstream sample in the south
ditch with the highest level of contamination was not the sample used
for background.
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Analytical Results (Buried Materials):
The further evaluation of the magnetometer data was not performed
using any data other than what were provided in the RI report. The
evaluation was mainly an ongoing development or reinterpretation of
the same magnetometer data. The results of the geophysical
investigations are presented as Appendix G of the RI Report Volume II.
A subsurface investigation consisting of parallel trenches across the
site would be an expensive and unnecessarily dangerous approach to
searching for buried drums, especially since magnetometer data has
identified areas most likely to contain buried drums. All drum.
estimates were made based on visual observation and counting of drums
in open this pits and were assumed to be representative of the entire
particular anomalous area. Each area that encountered drums was
excavated by two trenches that extend between all boundaries of the
anomalous area.
SECTION 2.5 CONTAMINANT TRANSPORT AND FATE;
The majority of this Section presents CRA concerns with the RI report.
A point of disagreement was concerning contamination in well MW-24 and
potential of trace contamination in MW-25. The commenter states that
if downward migration was occurring, contamination also would be
discovered in well MW-25 at or higher than levels in MW-24. The
commenter fails to consider the possibility that the contaminants
passed laterally beneath MW-25 or that contaminant transport was
affected by fracturing. The commenter makes the statement that in
order to minimize off-site migration of contaminants the water table
and upper intermediate zones should be the focus of remedial action
alternatives. This statement is contradictory to comment number 15 on
page 45 of the PRP Group report, when the commenter states that
groundwater extraction in the upper intermediate unit should not be
contained for detailed analysis in the FS. It is unclear as to what
the commenter's real preference is regarding this issue.
SECTION 3.0 PUBLIC HEALTH EVALUATION
General:
Concentrations of indicator chemicals present in groundwater
monitoring wells were compared to ARARs in Table 6-9 of the RI report,
and the intakes and risks associated with ingestion of groundwater by
workers are presented in Tables 6-27, 6-32 and 6-33. Similarly,
intakes and potential risks associated with ingestion by future site
residents are presented in Tables 6-30, 6-34, and 6-35.
Use of the maximum detected concentration of a chemical in evaluating
the plausible maximum exposure scenario is conservative in that it
assumes repeated exposure to the maximum concentration. However, the
possibility exists that additional sampling may result in
concentrations that are greater than the maximum detected during the
RI. This comment states that in evaluating the average risks only,
-------
-41-
presence of PAHs. This subset of chemicals is identified in Table 6-
2. Non-carcinogenic PAHs are not quantitatively evaluated in this
assessment. As indicated in Table 6-17 of the RI report, the average
and Tnaxiiraim concentrations of PCBs in soil near the eastern perimeter
of the site are 490 and 540 ug/kg, respectively. Under the exposure
scenarios evaluated, these concentrations correspond to cancer risks
of 9xlO~7' and SxlO"6 respectively.
Children Exposed to Sediment in Ditch;
While the exposure assumptions presented on page 6-39 of the RI
report, used to evaluate exposure of children to sediment are
conservative from a frequency standpoint, exposure is only evaluated
over a three year period, while actual exposure may possibly occur
less frequently over a longer tine period.
Exposed to S^'i'tcnt in
No issues raised by the PEPs. The iraximro risk is less than 1 x 10~6.
Exposure to Workers to Soils On-site:
Use of maximum concentrations in evaluating the plausible maximum
exposure scenarios has been discussed above. Also as discussed, only
carcinogenic PAHs were evaluated in the PHE.
Ingestion of Water bv Residents and Workers;
Risks from ingestion of groundwater from the water table, intermediate
unit and Upper Sharon unit were presented separately. If the
itaminated water table and intermediate unit are not cleaned up, the
r i nil s*m I
potential exists that the Upper Sharon could become contaminated.
Adequate controls saach as deed restrictions in the use of the site are
required to assure long term protectiveness of the selected
alternatives. The scenario of future risks to on-site residents
represents the worst case scenario and justifies a remedial action for
the Summit National Site. The risks associated with such an exposure
scenario address the main source of contamination. The remedial
alternative is designed to minimize threats at the source location and
affected areas (i.e. cement plant and eastern perimeter).
No issues raised by the PRPs.
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-42-
Residential Exposure to Soil:
Only carcinogenic polynuclear aromatic hydrocarbons (PAHs) were
included in evaluating the risks to off-site residents due to the
presence of PAHs. This subset of chemicals is identified in Table
6-2. Non-carcinogenic PAHs are not quantitatively evaluated in this
assessment;. As indicated in Table 6-17 of the RI report, the average
and maximum concentrations of PCBs in soil near the eastern perimeter
of the site are 490 and 540 ug/kg, respectively. Under the exposure
scenarios evaluated, these concentrations correspond to cancer risks
of 9xlO-7 and 5x10-° respectively.
Children Exposed to Sediment in Ditch;
While the exposure assumptions presented on page 6-39 of the RI
report, used to evaluate exposure of children to sediment are
conservative from a frequency standpoint, exposure is only evaluated
over a three year period, while actual exposure may possibly occur
less frequently over a longer time period.
Teenager Exposed to Sediment in Impoundments:
No issues .raised by the PRPs. The maximum risk is less than 1 x 10"^.
Exposure to Workers to Soils On-site:
Use of maximum concentrations in evaluating the plausible maximum
exposurs scenarios has been discussed above. Also as discussed, only
carcinogenic PAHs were evaluated in the PHE.
Ingestion of Water by Residents and Workers:
Risks from ingestion of groundwater from the water table, intermediate
unit and Upper Sharon unit were presented separately. If the
contaminated water table and intermediate unit are not cleaned up, the
potential exists that the Upper Sharon could become contaminated.
SECTION 4.0 FEASIBILITY STUDY REPORT
Section 4.1 General
Adequate controls such as deed restrictions in the use of the site are
required to assure long term protectiveness of the selected
alternatives. The scenario of future risks to on-site residents
represents the worst case scenario and justifies a remedial action for
the Summit National Site. The risks associated with such an exposure
scenario address the main source of contamination. The remedial
alternative is designed to minimize threats at the source location and
affected areas (i.e. cement plant and eastern perimeter).
SECTION 4.2 REMEDIAL TECHNOLOGY DEVELOPMENT
No issues raised by the PRPs.
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-43-
SECTION 4.3 SCREENING OF REMEDIAL TECHNOLOGIES
Soil Access Restrictions
Comment:
The PRPs state that the site extension is unnecessary.
U.S. EPA's Response:
The site extension is not based solely on soil remediation. The'
boundaries were also extended to contain the groundwater plume in the
water table aquifer and also to implement the other components of the
selected alternative such as the slurry wall, cap, and rerouting of
the lower eastern and southern ditches.
Containment
Comment:
According to the PRPs, a soil cover is more appropriate than a RCRA
cap.
U.S. EPA's Response;
The FS does evaluate surface controls in the context of containment of
contaminated soil/sediment/subsurface waste technologies..
Revegetation and soil cover were carried through Chapter 3, and
revegetation was carried through Chapter 4 and into the assembly of
alternatives. Surface sealing and soil stabilization were screened
out in Chapter 3 primarily since they are both temporary solutions and
do not meet the goals of the NCP. Leaching of contaminants is an
additional factor used to screen out soil stabilization. A soil cover
does not meet the criteria for protectiveness or long term
effectiveness based on the waste characteristics at the Summit
National Site. The requirements to repair topsoil and revegetate
every ten years is a common industry standard that is based on past
experience and used as a basis for estimating operating and
maintenance costs. Whether repair is the result of poor management or
other factors is not at issue.
Removal
Comment:
The PRPs claim that risk numbers and the scenario for subsurface soils
are illogical. Buried drum delineation needs to be defined
adequately.
U.S. EPA's Response:
Additional delineation and estimates of numbers of drums will be
performed during the pre-design investigation. The data gathered
during the remedial investigation represent the best estimate and
effort. The actual number of drums can only be determined through
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-44-
excavation and removal. This action is more appropriate during the
remedial action. Prior to remedial alternative implementation during
the design phase, the number of drums will be better estimated to
develop costing and design plans. The scenario of exposure to
subsurface soils through dermal contact and incidental ingestion is
appropriate to consider when defining the extent to which "hot spot"
soils require treatment.
Initially, the grid square (2-4) with a 1 x 10"4 risk was not included
in the "hot spot" soils removal scenario. However, after further
consideration of soil block units exceeding the cancer risk of 1 X
10~5, a more protective soil removal scenario has been developed. Soil
block units with a risk less than 10~5 risk are shallow (0-2 ft) and
will be covered by a cap to prevent direct contact and exposure
through ingestion. The concept of addressing "hot spot" soils is not
to provide complete treatment but to provide a cost effective
alternative that eliminates a substantial source of risk while being
cost-effective. The "hot spot" delineation is located primarily on
the southern half of the site where the buried drums were identified.
The delineation of "hot spot" soils for removal and the delineation of
the area to be capped are based on two different issues. Treatment of
"hot spots" to address reduction in mobility, toxicity, and volume is
based on a cost effective volume that reduces a majority of risk.
Placement of the cap is required over the entire site to contain
treated soils and reduce exposure to unacceptable soil contamination.
Comment;
According to the PRPs, the storage capacity is insufficient for
stockpiling soils.
U.S. EPA's Response;
The temporary staging of soils under the pole building should never
reach the capacity of the building. Soils will be stored temporarily
(several day§) until fed into the incinerator. This is an ongoing
practice and not intended to serve as long-term storage.
Comment:
The PRPs claim that the 85,000 c.y of soil was increased arbitrarily
to 105,000 c.y.
U.S. EPA's Response:
Soil blocks exceeding cancer risks of 1 x 10"6 are equivalent to
85,000 c.y. When considering cost sensitivity and technical
implementability, the location of certain contaminated soil blocks
result in the unavoidable removal of clean soil blocks. To work
around such blocks is impracticable and cumbersome resulting in
increased construction costs. The 105,000 c.y. of soils proposed for
-------
-45-
removal results in the most cost-effective and practicable method for
the contaminated vadose soil removal scenario.
Ouuunent;
•Die ERPs state that excavation of all unconsolidated material is
unrealistic.
U.S. EPA's Response;
The alternative to remove all unconsolidated material represents the
maximum extent of treatment possible at the site resulting in no
residual contamination that eliminates long-term management. This
alternative is extremely difficult to implement and is very costly.
Surface Water and Groundwater Treatment
Comment;
Ihe ERPs state that the influent is not chemically characterized.
U.S. EPA's Response;
The chemical characteristics of the influent are currently based on
surface water and groundwater analytical results from the remedial
investigation. A treatability study could be conducted prior to
installing the treatment process to assure it's removal efficiency.
rate. This treatability study will be conducted during the remedial
design phase. In waste water.treatment design, there are key
compounds that process design engineers look for, that if present at
certain concentrations, can create problems for treatment systems. No
such chemicals at restrictive concentrations have been detected at the
Summit National Site.
Groundwater Operable Unit Vertical Barrier;
Comment;
The ERPs believe that hydraulic containment at the site perimeter
would accomplish the same objective as the containment wall.
U.S. EPA's Response;
During the technology screening process leading to alternative
development the use of hydraulic containment through other process
options under vertical barriers was evaluated. The soil bentonite
slurry wall was the only option that passed through screening for its
ability to minimize lateral migration of contaminated groundwater. An
additional feature of the slurry wall is that it can prevent lateral
migration of groundwater from clean up-gradient sources into the
contaminated area beneath the site. The permeability of 10~7 cm/sec
that can be achieved by a soil bentonite slurry wall does not depend
on the permeability of natural soils used. The higher the
permeability of natural soils, the higher the portion of bentonite
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-46-
that will be used. The 10~6 permeabilities of surrounding soils
presents tiie lower range. The higher range of permeabilities was
estimated at 10~3.
Based on current available hydrogeologic data, drains (hydraulic
control) nay not be technically feasible due to the hydraulic
conductivity of on-site soils. An additional concern is that drains
would not be effective in dewatering the water table adequately to
prevent downward vertical migration of contaminants into the upper
intermediate unit.
Cover
Comment:
The PRPs claim that a low permeability soil cover is not necessary
since soil leachability is low and groundwater treatment is less
costly than constructing the cap.
U.S. EPA's Response
Using the current quality of the water table aquifer one can assume
that the contaminated soils or buried wastes leach sufficient
concentrations of chemicals to necessitate treatment. Those levels,
however, are not a problem for treatment.
By not using a low permeability cover, the collection and treatment of
contaminated groundwater will continue indefinitely. At some point in
time, this perpetual treatment would exceed eventually the cost of a
RCRA cap.
Groundwater Extraction/Collection
Comment;
According to the FRPs, the FS has arbitrarily included the low
permeability (RCRA) cap and containment wall with the groundwater
collection system.
U.S. EPA's Response;
The RCRA cap is an integral component of the groundwater extraction
and gradient stabilization system included with the proposed
alternative, not an arbitrary addition as the comments suggest.
Groundwater remediation and gradient control considerations are
presented in Appendix B and C of the FS.
Singular component technologies such as pipe or media drains, typical
extraction wells and radial collection wells passed Chapter 3
screening as being able to achieve the general response goal
established and suitable to site characteristics. Only radial
collection wells were eliminated in Chapter 4 of the FS, due to high
cost and unacceptable health and safety risk to workers.
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-47-
The groundwater extraction system designed to dewater the water table
aquifer was developed based on concepts presented in Appendices B and
C of the FS report. The point that the commenter makes where
reduction of the water table by greater than one foot would cause a
gradient reversal is only true in one area; that is the extreme
southern portion of the site. This is because the base of the water
table is sjightly lower and the piezometric surface on the Upper
Sharon unit is slightly higher. At other locations at the site much
more drawdown is necessary.
Perimeter drains were not considered for alternatives that included
partial removal of soils. They were screened out due to extensive
costs to include wall shoring, dewatering, and safety during
installation. Constructability of a drain system would also be very
difficult. Also perimeter drains alone are inadequate due to limited
radius of influence due to hydraulic conductivities at the site. In
Alternative 7 when all unconsolidated materials were removed, gravel
trench drains were used since they will be constructs: simultaneously
during the backfilling operation.
The groundwater extraction and gradient control system the U.S. EPA
has proposed for its recommended alternative is complex but is based
on the available data. More data needs to be collected during the
remedial design to refine the system. If additional hydrogeologic
data collected during the design phase shows a more permeable system
exists than some of the current data suggests, then the number of
wells could be reduced and costs would also be lowered. If fewer
drains were also required they may prove to be more economical. The
commenters statement that the costs for the proposed extraction system
are underestimated by a factor of three is an unsupported opinion.
Costs are based on published reference and industry contacts which
resulted in what U.S. EPA believes are adequate estimates to comply
with +50 and -30 reliability.
Again the commenter now says they do not believe that intermediate
zone groundwater extraction wells are warranted or advisable. This is
the third instance the commenter changes their technical opinion on
this issue.
i
In summary U.S. EPA has stated that more data are necessary to refine
the proposed groundwater extraction system. That data will be
collected during design and may or may not have significant changes on
cost or technologies of the currently proposed system.
4.4 ALTERNATIVES DEVELOPMENT
General Comment:
The PRPs claim that the Feasibility study fails, to evaluate the
reduction of risk associated with each alternative.
-------
-48-
U.S. EPA's Response;
Alternatives 3 through 9 eliminate risks associated with the site,
although, through different combinations of treatment, engineering, and
institutional controls. Since all exposure routes are eliminated, no
residual risks would occur providing there is no interference or
failure of the components of the remedial alternative.
She ERPs state that the residual risk in Alternative 5 is minute.
U.S. EPA's Response;
It is true that the exposure pathway to untreated soils is eliminated
by the installation of the multi-layer cap. The purpose of risk
numbers for each soil block is to define the "hot spot" soils and the
extent of residual contamination allowable at the site. The overall
risk associated with the remaining cells is 3 x 10~5, which is
acceptable for containment rather than treatment.
The ERPs prefer that the effectiveness of the alternatives be
evaluated in terms of contaminant mass:
U.S. EPA's Response
As previously discussed, contaminant mass is not indicative of health
risks. In addition, contaminant mass does not relate to clean-up
standards and therefore, this criteria would be inappropriate to
evaluate effectiveness.
Cujiuitent *
Ihe FRPs propose that intermediate alternatives between Alternative 2
and 3 need to be evaluated.
U.S. EPA's Response;
Alternative 2 represents the minimum action with no treatment or
containment options. Alternative 3 represents containment with
treatment of the major source of contamination which is drums for this
particular site. U.S. EPA considers the range between Alternatives 2
and 3 reasonable and appropriate.
Detailed Analysis of Assembled Alternatives
Effectiveness and Implementability
Comments made by the PRPs regarding reduction in risks, total mass of
contaminants, volume of 430,000 c.y. and cost effectiveness have been
previously discussed in this document.
-------
-49-
Comment;
The PRPs claim that a soil cover is less costly than a multi-layer
cap.
U.S. EPA's Response;
t
As previously discussed, a soil cover does not provide proper
containment due to its potential for cracking and leaking caused by
natural freeze/thaw cycles, and it also does not eliminate
infiltration which is an important function of the cap.
The initial screening of a viable alternative is primarily based on
its ability to be effective and implementable. Cost effectiveness is
a significant factor but it is not the primary decisive factor. If
two or more alternative provide similar results in effectiveness and
implementability, then cost effectiveness could be used as the
decisive factor. However, this is not the case for a soil cover
versus a multi-layer cap based on the waste characteristics at the
Summit National Site.
Cost Analysis
Comment;
According to the FRPs, the cost analysis fails to provide construction
and capital costs on a yearly basis to account for sequential
implementation of various cost items.
U.S. EPA's Response;
It is important that all costs are prepared using an equal and
comparable methodology to allow for direct comparison of alternatives
that contain different technologies and are implemented over different
periods of time. Cost estimates for the assembled alternatives were
prepared from cost information included in the U.S. EPA's "Compendium
of Costs of Remedial Technologies at Hazardous Waste Sites," the 1987
Means Site Work Cost Data guide, U.S. EPA's "Remedial Action at Waste
Disposal Sites Handbook," estimates for similar projects,-;and
estimates provided by equipment vendors.
All capital costs and operations and maintenance costs are carried to
a present worth based on 30 years at 10% interest rate. The order-of-
magnitude cost estimates presented have been prepared "from the
information available at the time of the estimate. Final costs of
assembled alternatives will depend on actual labor and material costs,
actual site conditions, productivity, competitive market conditions,
final project scope, final project schedule continuity of personnel,
engineering between the feasibility study and final design, and other
variable factors. As a result, the final alternative costs will vary
from the estimates presented in this report. Most of these factors
are not expected to affect the relative cost differences between
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-50-
alternatives. Factors that may substantially affect the relative cost
difference are discussed under "Cost Sensitivity Analysis". Because
of these factors funding needs must be carefully reviewed prior to
making specific financial decisions or establishing final budgets.
CON 5.0 - PRP'S PREFERRED KfcMEUlAL ACITC
t
U.S. EPA has already provided comments to the ERP's proposed
alternative in responding to the CRA's Report in the. Executive
Summary. The two differences between U.S. EPA's recommended
alternative and the FRP's, are the issues of the soil cover and the
groundwater extraction/gradient control system. The issue regarding
soil cover versus RCRA cap is fairly straight forward since a RCRA cap
is a regulatory requirement. U.S. EPA believes that some additional
discussion on the containment, collection, and extraction of
groundwater is warranted.
Based on current data available on site hydrogeologic conditions, the
system proposed by the PRPs would not dewater the water table
adequately to prevent vertical downward movement of contaminants into
the upper intermediate unit. For a system similar to that shown on
Figure 5.1, an up-gradient drain would probably need to be installed
to intercept water recharging the water table aquifer from north of
the site. Additionally, several more north-south oriented drains
would be required to adequately dewater the water table aquifer based
on current hydraulic conductivity data. The radius of influence of
drains proposed 'on Figure 5.1 is much larger than estimated based on
RE data. The proposed system may be feasible based on the refinement
of data during the Remedial Design phase, but current data indicates
it would not achieve groundwater remediation objectives.
RI/FS Comments Submitted by the Summit National PRP Group — March 11.
1988;
This document presents comments concerning legal and technical
matters. The legal comments presented in Section II have been
addressed previously in this document under the section entitled
"Legal Comments". The technical issues are generally based on the
report prepared by the PRP consultants, Conestoga-Rovers & Associates
(CRA).
The detailed technical issues raised by the PRP's consultants, CRA,
were presented in Attachment E. These comments have been responded to
by U.S. EPA in the previous section entitled "Technical Comments". In
reviewing the PRP document, there are some technical and procedural
comments that were not raised in the CRA document. The following
section includes responses to those comments.
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-51-
Section I - Introduction
Section I of the PRP Group report presents numerous comments that have
already been addressed during the discussion of the CRA report. The
issues already responded to include the interceptor and collector
drain system, excavation of offsite soils with low levels of
contamination, volume of "hot spot" soils, and the use of an
impermeable cover. The commenter later addresses excavation of
offsite soils that are "significantly contaminated" (page 6) which is
inconsistent with their previous comments about offsite soils with low
levels of contamination (page 4). It is not clear exactly what soils
the commenters are referring to. The PRP Group goes on to state that
they are basically in agreement with U.S. EPA's proposed alternative.
The two differences, grouridwater collection and soil cover, have been
previously addressed. The need for an exploratory trench program to
delineate buried drums and the removal of "hot spot" soils based on
mass instead of risk have also been addressed.
The commenters note that the Agency for Toxic Substance and Disease
Registry (ATSDR) has not presented a health assessment. ATSDR is
currently developing the health assessment for the Summit National
Site. The health assessment is based on the Remedial Investigation
and Feasibility Study report. The health assessment will be completed
by the time this Record of Decision is signed by the U.S. EPA.
Section II:
This section refers to legal matters which have been previously
addressed.
Section III:
This section presents specific comments on the RI report. All issues
presented in this section have been responded to during the review of
the CRA report. These include comments on "other potential
shortcomings" numbers 1-3 and 5-16. The PRP comment No. 4 concerning
adjacent subsurface soil samples needs further clarification. The two
foot vertical interval used for soil characterization represents a
common sample interval (split spoon samples). Also as previously
discussed, this will provide 192 2-ft. thick soil units for evaluation
at the site, which were deemed sufficient. The fact that certain
soils were loose such as fill, and a 3 or 4 ft. interval was required
to obtain sufficient sample volume is beyond control. The adjacent
split spoon samples were taken vertically and may in fact represent an
interval larger than 2 feet.
Section IV:
This section presents specific comments on the FS report. All issues
presented in this section have been responded to during the review of
the CRA report. These include comments or deficiencies numbered 1
through 23.
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-52-
General comments were made stating that the FS did not provide
applicable screening of technologies. The identification and initial
and detailed screening of technologies allows for a more thorough
evaluation of applicable remedial technologies. Chapter 3 of the FS
screens technologies on the basis of their compatibility with site
conditions and waste characteristics. Those applicable technologies
are then screened with respect to effectiveness, implementability, and
cost. This screening process is in accordance with the NCR and U.S.
EPA's FS guidance.
Comment:
The PRPs state that technologies such as polymerization,
bioreclamation, and critical fluid extraction were eliminated because
of their experimental and unproven nature, yet in-situ vitrification
was retained.
U.S. EPA's Response:
Certain technologies were not screened out not based solely on its
experimental and unproven nature but also the uncertainty of its
compatibility with waste characteristics. SARA Section 105 authorizes
the use of innovative technologies that are appropriate for
utilization in response actions. Vitrification applies to soil
remediation and appears promising in its application to hazardous
waste site remediation. However, for this particular site,
incineration was selected as the preferred treatment technology based
on feasibility and implementability.
Comment:
The commenters noted that the detailed analysis of alternatives does
not include the proper criteria by the NCR.
U.S. EPA's Response:
The FS for the Summit National Site is consistent with SARA and U.S.
EPA's Office of Solid Waste and Emergency Response (OSWER) directives
for evaluation of alternatives. The detailed analysis follows U.S.
EPA's evaluation criteria. Effectiveness includes an evaluation on
protectiveness, reliability, meeting ARARs, and reduction in toxicity,
mobility and volume. Implementability includes technical feasibility,
availability, and administrative feasibility. Finally a cost analysis
which includes capital, operations and maintenance costs. In
conclusion all alternatives were properly evaluated and is accordance
with the NCR.
Comment:
The PRPs state that the FS cannot be finalized without an evaluation
on community acceptance.
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-53-
U.S. EPA's Response;
The FS is entitled "The Public Comment Feasibility Study" and has
undergone public review. Based on public comments received by the
community there is no justifiable cause to reopen the FS.
Finally, Section 5 presents the PKP's proposed alternative which has
already been commented on in the CRA report review.
-------
Attachment 2 - Index to the Administrative Record
-------
Attachment 3 - Summary of Most
Representative Contaminants in each media
for the Summit National Site
-------
List of Tables
Table 3-1 'Summary List of Most Representative Parameters
identified in Shallow Groundwater
Table 3-2 Organic Contaminants Detected in MW-24
Table 3-3 Summary List of Contaminants in Background Soils
Table 3-4 Summary List of Contaminants in Onsite Surface Soils
Table 3-5 Summary List of Contaminants in Onsite Soils (2-4 ft.)
Table 3-6 Summary List of Contaminants in Onsite Soils (4-6 ft.)
Table 3-7 Surrmary List of Contaminants in Onsite Soils (6-8 ft.)
Table 3-8 Summary List of Contaminants in Cement Plant Surface Soils
Table 3-9 Summary List of Contaminants in Cement Plant Soils (2-6 ft.)
Table 3-10 Summary List of Contaminants in Eastern Perimeter Soils
Table 3-11 Summary List of Contaminants in Onsite Surface Water
Table 3-12 Summary List of Contaminants in Offsite Surface Water
Table 3-13 Summary List of Contaminants in West Pond Sediments
Table 3-14 Summary List of Contaminants in East Pond Sediments
Table 3-15 Summary List of Contaminants in Offsite Sediments
Table 3-16 Summary List of Contaminants in Buried Drums
Table 3-17 Summary List of Contaminants Tank A
Table 3-18 Summary List of Contaminants Tank B Incinerator
Table 3-19 Organic Contaminants Detected in Air Samples
-------
VOIAtllES
TABLE 3-1
HOST REPRESENTATIVE ORGANIC CONTAMINANTS IDENTIFIED
IN THE SHALLOU CROUNOUAIER SVSIEH
SLHNIT NATIONAL SUE
Cootamirmnt
Arei Affected
Maxims
Cone. (iB/ll
Background
Ccnc. (ug/l)
Carmen ts
Methylene Chloride
Acetone
1,1-Dlchloroethsne
1,2 Dlchlorotthtne
2-Butinone
1.1.1-Trlchloroethane
Irlchlorocthene
4-Ncthyl-2-Pentanone
Toluene
Ethytbeniene
Southwestern qjadrsnt
Southern half of alt*
Southern half of sits
Southern helf of alte
Southern helf of ille
Southern helf of alte
Southern helf of elte
Southwestern quadrant
Southueetern quadrant
Southern half
24.000
1.300.000
12.000
IIS. 000*
650.000
SI. 000
2T.OOO
62.000
18.000*
11.000
2"
*•*
HO
ND
H**
NO
16
ND
16"
MO
Tenda to occur at higher concentratlona In shallower wells
Tenda to occur at higher concentratlona
Tenda to occur at higher concentratlona
Tends to occur at higher concentrations
Tends to occur at higher concentrations
Tends to occur at higher concentrations
In shallower well Is
in shallower wel.Is
In shsllower wells
In deeper wells • •'
In shallower wells
SfM|-VOI.AT|tES
4-He thy I phenol
2.4-DI Methyl phenol
Phenol
(•ophorona
Naphthslene
2-Mtthylnaphlhilerx
Southwest quadrant
Southwest quadrant
Southwest quadrant
Southern half of alta
Southwest quadrant
Southwest quadrant
Bis(2-ethylhejiyl)Phthalate Southern half of the site
Mote:
510
130*
7.000
2.600
620
370
7.250*
MU-7 used for background concentration
• Average of 2 delicate*, duplicates not averaged had one value of 0
•• Concentration level can be attributed to lab contamination
ND
ND
ND
ND
ND
ND
5
Tenda to occur at higher concentrations In deeper wells
Tends to occur at higher concentrstIons In shallower wells
Tends to occur st higher concentrations In shallower wells
Tends to occur at higher concentrations In deeper wells
-------
TABLE 3-2
IDENTIFIED ORGANIC CONTAMINANTS DETECTED IN HU-24
SUMMIT NATIONAL SITE
Concentration
Concentration
Concentration
Maximum Concentration in
Contaminant
Methyl ene Chloride
Acetone
1, 1-Dichloroethane
l,2-.Dichloroethane
2-Butanone
1,1,1 -Tr ichl oroethane
Trichloroethene
4-Methyl-2-Pentanone
Toluene
Ethyl benzene
4-Methylphenol
Isophorone
2, 4 -Dimethyl phenol
Naphthalene
2-Hethylnaphthalene
in MH-24
180 ug/1
2,700
820
5,800
1,800
360
55
250
3,200
590
140
41
16
11
5
in MW-25
3 uy/1
13
5
100
15
3
NO
ND
9
ND
ND
ND
ND
ND
ND
in MW-22
1 ug/1
9
ND
ND
15
ND
ND
ND
ND
4 ND
ND
ND
NO
3
3
Water-Table Aquifer
24,000 ug/1
1,300,000
12,000
115,000
650,000
53,000
18,000
62,000
27,000
11,000
510
2,600
140
620
370
ND - Not Detected
-------
TABLE 3-3
SUMMARY LIST Of ORGANIC PARAMETERS IDENTIFIED
IN BACKGROUND (1) SOILS
SUMMIT NATIONAL SITE
Volatile Paramctfrj
Toluene
lotal Xylenes
DMA Parameter!
Hinfcer of lines
Detected (?)
U
2
Beniolc Acid 3
Naphthalene 10
2-Hethylnaphthalene 11
Acenaphthylene 2
Dibeniofuren fl
Huorene 2
Hexachlorobeniene 1
Pentachloroptierol 1
Phenanthrene 15
Anthracene 3
Di-N-Butylpnthalat* 6
fluoranthene 16
Pyrene 16
Benio(a)Anthracene 14
flls<2-ethylheiiyl)Phthal«te 8
Chrysene 15
Benzo(b)fluoranlhene 14
Benio(k)fluoranthena U
Beruo( a) Pyrene 11
lndeno(t,2,3-cd)Pyrene 4
Dibent(a,h)Anthraceno 2
Bento(a,h,l)Pery(ene 4
Pestlcldes/PCB's
Range of Detected
Concentrations (3)
4J - 31
6 • 7
160J
110J
55J •
B3J •
230J
65J •
3JOJ
87J
42J •
67J -
49J •
69J •
54J •
59J -
40J •
47J -
49J •
49J •
65 J •
B2J •
97J •
150J
• 11004
• 3500
3700
150J
• 810
94J
2400
2BOJ
270J
2100
1500
1000
120
1100
1900
1900
1100
550
120J
• 470
Mean
Concent rat|on(3)(4)
9
1
126
859
972
14
212
9
19
5
725
30
45
353
331
222
32
268
351
351
161
68
13
65
None
Notes!
(1) • Includes residential, firm and nine coll sanptes
(2) • Out of total 17 sanples
(3) • Units - gg/kg
(4) • Mean calculated using lero for samples where parameters not detected
J • Estimated Value
B • Found in laboratory blank
Standard
Oeviatjpns(3)
a
2
331
1124
1196
40
265
27
80
21
712
76
79
470
352
241
39
302
480
480
271
158
36
136
Upper 95X
Confidence Limit (3)
13
2
297
1438
1587
35
349
23
61
16
1091
69
86
594
512
346
52
423
598
598
301
150
31
135
-------
TABLE 3-3
(con't)
SLHMART LIST OF INORGANIC PARAMETERS IDENTIFIED
IN BACKGROUND SOUS (1)
SIHHIT NATIONAL SITE
Pafmneter
Hunter of Tines Range of Detected Mean Standard Upper 95X
Deleted (?) Concentrations (31 Concentration (}J(41 Dey|atjons(3) Confidence Limit (3)
Alunlnun
Ant 1 iron/
Anenlc
Bar ILID
Beryll Inn
Caitnlun
Calcium
Chromiui
Cobolt
Copper
Iron
Lead
Cyanide
Magnet lin
Manganese
Mercury
Nickel
Potassium
Silver
Sod Inn
Vanadiun
Zinc
17
1
16
\r
IS
11
u
17
17
17
17
17
a
17
17
3
17
17
10
1
17
17
4070 • 18100
(20) R
IS. 8) • 26
(281 - CU5J
(0.321 • (1.31
(2.31 • 4.1
(201) • 5510
12 • 24
(5.9) - 21
(161 • 51
16600 • 39400
17 • 391
.69 • 4.2
(1720) • 5340
10SJ.R • 1580J.R
I.095J • .38
(11) • 38
(905) • (3100)
(2.5JJ.R • 16J.R
(7791
(14) • (36)
50 • 227
9661
1
16
85
0.54
2
3253
17
11
25
25694
66
0.65
2356
729
0.043
16
1832
3
46
24
87
3964
5
6
29
0.538
2
7903
3
4
9
7543
98
1.045
829
531
0.108
6
639
4
189
6
49
11699
4
19
100
0.726
3
7316
IB
13
29
29572
117
1.186
2782
1003
0.098
19
2161
5
143
26
113
(1) Includes residential, farm, and nine soil samples
(2) Out of total 17 samples
(3) Units • ing/kg dry weight
(4) Mean calculated using tero for samples where parameters not detected
(I • Positive value (ess than contract required detection limit
R • Spike sanple recovery not within contract limits
J • Estimated value
-------
TABLE 3-4
SUWARY LIST OF INORGANIC PARAMETERS IDENTIFIED
IN ONSIIE SURFACE SOUS THAT EXCEED BACKGROUND
NATIONAL SITE
Hunter of Tine* Range of Detected Mean
Detected (1) Concentrations (2) Concentrations (2)(3)
Inorganic Parameters Onjlte Onslte Ons Ite
Antimony
Arsenic
Barium
Beryl llun
Cadmium
Calclua
Chromium
Cobalt
Copper
Cyanide
Iron
Magnet Ion
Manganese
Mercury
Nickel
Selenlin
Sodium
Tin
Van ad Inn
2lnc
11
SI
At
36
1J
61
61
48
61
37
61
60
61
36
50
2
34
7
61
61
(16IR-S45R
7.3S-(3S1R
(391-343
10.321 -11.91
[2.41-112
(8641-30029
a.7-102
14. 6) -(281
C71-175
0.31*-43.6
11489-95300
(3261-6120
29-2620
(0.0841-0.81
(5.31-56
3R-8.2R
(1061 -(1280)
(131R-106
(141-62
24-803
17
17
103
0.59
3
8982
27
It
37
4
39531
2827
365
0.167
26
0
164
3
28
168
Standard Upper 95X
Deviation (2) Confidence Limit In
Onslte Background Sample* (2)
71
9
58
0.56
14
9281
18
8
27
11
18264
1344
34.6
0.198
12
1
229
14
12
149
4
19
100
0.726
3
7316
18
13
29
1.186
29572
2782
1001
0.098
19
NO
143
NO
26
113
Upper 95X
Confidence Limit In
Residential Soil Sanples (2)
NO
24
133
1.074
3
4289
23
18
43
2.895
30494
4142
1362
0.289
30
NO
NO
NO
32
197
(1) Out of total 61 samples
(2) Units tig/kg dry weight
(3) Mean calculated using tero for samples Uiere parameter* not detected
R Spike recovery not within control limits
( I Positive values less than the contract required detection limit*
S Value determined by standard addition
-------
TABLE 3-4
(con1t)
SUMMARY LIST OF VOLATILE PARAMETERS IDENTIFIED
IM ONSIIE SURFACE SOILS THAT EXCEED BACKGROUND
SUMMIT NATIONAL SITE '
Nuitoer of Tlacs Range of Detected Mean
Detected (1) Concentration* (2) Concentrations (2)(3)
Volatile Parameters Onilte Oralte Ons Ite
Methylene Chloride
Acetone
Carbon DUulfide
1, 1-Oichloroethene
1, 1-Dichloroe thane
Trans- 1, 2-0 ichloroethene
Chloroform
1.2-Dlchloroethane
2-Butanone
1.1,1-TrUhloroetharte
Irichloroelhene
1,1,2-Trlchloroethane
Beniene
Hexanone
4- Methyl -2-Pentanone
Tetrachloroethena
Toluene
Chlorobeniene
Ethylbeniene
Total Xylenes
22
25
3
2
5
7
10
9
15
31
38
2
30
5
2
12
40
9
in
27
3.B-1BOOOB
6J-520000B
5-10
3.2-33
7-15
2.4-381
2J-4300J,"
44-80000"
5J-38000B,"
3J-51000"
2J- 160000"
14-48
1J-24
19-4400"
78-45000"
1J-4600J,"
2.2-260000**
4J-3600**
3.7-180000**
7. 3- 730000"
406
9484
0
1
1
9
72
3177
1682
2216
6017
1
3
146
739
97
7002
62
4882
20440
Standard Upper 9SX Upper 95X
Deviation (2) Confidence Limit In Confidence Limit In
Ons Ite Backgromd Sanplea (2) Residential Soil Samples (2)
2375
66152
2
4
3
49
546
14120
6901
9022
30691
6
5
7d3
5714
604
34207
457
24924
101649
NO
NO
NO
NO
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
13
ND
ND
2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
NO
ND
11
ND
ND
ND
(1) Out of total 61 canples
(2) Units ug/kg dry weight
(3) Mean calculated using lero for samples uhere parameters not detected
J Estimated value
B Found In laboratory blank, Indicates possible/probable contamination
•• Analyied at medium concentration
ND Not detected
-------
TAHI.K 3-
(con1t)
SUMMARY LIST OF BNA AND PESIICIOE/PCB PARAMETERS IDENTIFIED
IN ONSIIE SURFACE SOILS THAT EXCEED BACKGROUND
SUMMIT NATIONAL SUE
Ninlwr of Tlnwu Range of Detected Mean
Detected (1) Concentrations (2) Concentrations (2)(3)
BMA Parameters Onsile On.stte Onsite
Phenol
1 , 3 -D ichl orobeniene
1 . 4 -D IchlorobenierM
1,2-0 ichl orobeniene
2-Melhylphenol
4-Helhylphenol
Isophorone
2,4-Dimethylphenol
Bentoic Acid
1. 2. 4 -Trichl orobeniene
Naphthalene
2- Net hy (naphthalene
Hexachl orocyc 1 opcnt adl ene
Acenaphthene
Dielhylphthalate
Fluorene
N -N i t rosodlphenyl arnlne
Hexachlorobenicne
Phenanlhrene
Anthracene
Di-N-Butylphthalate
Butyl bentylph thai ate
Bis(2-ethylhexyt)Phthalate
Dl-N-Octyl Phthalate
Pesticide Parameters
Heptachlor Epoxlde
PCB'i (4)
a
2
4
9
6
I
4
5
6
6
30
30
3
7
a
10
s
2t
28
2
23
11
47
30
2
19
290J -44000"
3JOJ
76J-18000J,**
52J-UOOOO"
310J-4BOO
4SJ-B30
63J-3000
BOO J- 7000
1.600J-BOOOJ
3JOJ-UOM
260 J- 41000"
370-14000
53000**-2800000«*
48J-1600J
330J-1600J
6SJ-UOOJ
BOOJ-1600J
48 J- 25 0000"
270J-13000J."
1600J-1JOOOJ,**
140J.B-12000J."
330-12000J,**
5508-3300000"
48J- 170000"
19.8J-20J
40J-590000C,"
1304
11
304
3811
16S
29
111
211
370
293
1965
1856
84475
69
95
81
79
aaii
1095
239
1538
592
103511
7925
•
1
17058
Standard Upper 9SX
Deviation (2) Confidence Limit In
Onsite Background Samples (2)
6368
59
2285
19627
689
136
531
966
1299
1786
5883
3410
456241
252
283
256
279
38049
2231
1660
3107
2052
453957
28180
4
83969
NO
NO
NO
ND
HO
ND
W>
NO
297
ND
1438
1587
NO
35
NO
23
ND
61
1091
69
86
ND
52
NO
ND
ND
Upper 95X
Confidence Limit in
Residential Soil Samples (2)
ND
NO
ND
ND
ND
NO
NO
NO
885
NO
1214
1726
NO
106
ND
71
ND
196
1122
199
213
NO
107
ND
NO
NO
(1) Out of total 61
(2) Units ug/kg dry ueiyht
(3) Mean calculated using lero for samples where parameters not detected
(4) Arochlor 1232, 1242, 1248, 1254
J Estimated value
•• Analyied at medium concentration
B Found in laboratory blank, possible/probable contamination
MD Not delected
C lUcntification confirmed by CC/MS
-------
TABLE 3-5
SIHMARY LIST OF VOLATILE PARAMETERS IDENTIFIED
IN OMSITE SOILS (2-4 FT.) THAT EXCEED BACKGROUND
NATIONAL SITE
Volatile Parameter*
Nethylene Chloride
Acetone
Carbon Dlsulflde
1.1-Dlchtoroethene
1,1-Dfchloroethane
Trans -1,2-Dfchl or oethene
1,2-Oichloroethane
2-Butanone
1.1.1-Trlchloroethane
Irlchloroethene
1,1.2-Trichloroethan*
Beniene
4 -Methyl • 2-Pent anone
Tetrachloroethene
Toluene
Chlorobeniene
Ethylbeniene
Total Xylene*
Nuitwr of Times Range of Detected Neon
Detected (1) Concentrations (2) Concent rat lona (2H3)
1
3
4
i
2
2
2
2
5
s
1
6
J
3
a
4
7
a
470J.B
120B-17000B."
3J-20
430J
H-*30J
UOOJ-7700**
B1-3200J
4SOOOB.J-49000B.**
10-43000**
5-UOOOO**
510J
1J-110
U-15000J
JJ-MOOJ."
17-4AOOOJ
11-670J
7-3BOOJ
11- 30000 J
59
2263
6
S«
56
1150
410
11750
B391
21502
64
26
2577
476
6990
98 '
916
6083
Standard Upper 95X Confidence Limit
Deviation (2) In Backaromd Sanples (2)
155
5579
7
142
142
2522
1055
20376
15255
45996
169
34
5040
1256
15027
217
1553
10771
NO
ND
ND
NO
NO
NO
ND
ND
ND
ND
ND
ND
ND
ND
13
ND
NO
2
(1) Out of total 8 sample*
(2) Units ug/kg dry weight
(3) Mean calculated using tero for samples where parameters not detected
J Estimated value
B Found in laboratory blank, Indicates possible/probable contamination
•• Analyied at medlui concentration
NO Not detected
-------
TABLE 3-5
(con1t)
SUMMARY LIST OF BHA AND PESTICIDE/PCB PARAMETERS IDENTIFIED
IN ONSITE SOILS (2 • 4 FT.) THAT EXCEED BACKGROUND
SUMMIT NATIONAL SITE
Muifcer of Time*, Jang* of Detected
Semi-Volatile Parnmetert Detected (1) Concentrations (2)
Phenol
1,4-Dlchlorobeniene
1.2-Dichlorobeniene
4-Me(hylphenot
2,4-Oimethylphenol
Benioic Acid
1,2,4-Trichlorobeniene
Naphthalene
2-MethylnapMhalene
Dibenxofuran
Fluorene
Hexachlorobeniene
Phenaruhrene
Oi-N-ButylpMhalate
f luoranthene
Pyrene
BulylbeniylprithalatA
Benro(a)anlhracene
Bis(2-ethylhexyl)Phthalate
Chrytene
Oi-N-Octyt Phlhalate
1 ndeno( 1 , 2, 3 • cd )Pyrcno
B«iio(fl,h, I IPeryl ene
2
2
1
1
1
1
1
7
7
6
5
1
6
5
6
0
1
4
6
5
1
J
4
52J-3300
76J-1500J
8JOO
68J
190J
9300
«200
200 J- 27000* •
310J-UOOQ"
I20J-6300J,**
59J-2BOOJ.**
5800
290 j- 16000**
150J.B-1800B
59J-2200J.**
160J-3600J.**
2200
78J-3000J,**
58 J- 130000
76J-2700J,**
13000
6AJ-UOOJ
73J-1200J
Mean
Concentrations (?)(3)
419
197
1030
9
24
1163
525
5197
B030
146B
527
725
3S06
. 675
760
903
275
580
16622
522
1625
194
207
Standard Upper 95X Confidence limit
Deviation (2) in Background Sanples (2)
1089
493
2745
22
63
3076
1389
8493
13854
2062
916
1918
5113
670
840
1159
728
984
42857
840
4299
457
384
NO
NO
NO
NO
NO
297
NO
1438
1587
349
23
61
1091
86
594
512
NO
346
52
423
NO
150
135
Pesticides
Heptachlor Epoxlde
PCB'i (4)
Ml rex
550"
6400C
9000"
69
800
1125
(1) Out of total 8 simples
(2) Units ug/kg dry weight
(3) Mean calculated using xero for sanplei where parameters not detected
(4) Arochlor 1232. 1242, 1248, 1254
J Estimated value
B Found in laboratory blank, possible/probable contamination
C Identification confirmed by CC/MS
•• Arulyied at medium concentrations
182
2117
2976
NO
HO
NO
-------
TABLE 3-5
(con't)
SUmARV LIST OF INORGANIC PARAMETERS IDENTIFIED
IN ONSITE SOILS (2 • 4 FT.). THAT EXCEED BACKGROUND
Sum IT NATIONAL SITE
Parnmeters
Arsenic
Bar Inn
Beryl 1 lun
Cadii Ion
Chromiun
Copper
Mercury
Nickel
Seleniun
Ihalliun
Tin
Nuifcer of Tloci Ranga of Detected
Detected (1) Concentrations (2)
14-61J
(611-245
(0.49) -[0.931
12.7) -15
9-732
22-43
4 (0.0741-0.32
0 (8.61-27
1 5. IS
1 15.91
2 (151 -(201
Mean
Concentrations (2)(3)
24
130
0.61
4
102
34
0.12
20
1
1
4
Standard
Deviation (2)
15
62
0.37
5
238
6
0.14
7
2
2
8
Upper 9SX Confidence
In Background
19
100
0.726
3
18
29
0.098
19
NO
NO
NO
Limit
(2)
(1) Out of total 8 saoples
(2) Unlti mg/kg dry weight
(3) Mean calculated using rero for samples Uiere parameters not detected
( 1 Positive values less than the contract required detection limit
J Estimated value
-------
TABLE 3-6
SIMHART LIST OF BKA AND PESTICIDE/PC8 PARAMETERS IDENTIFIED
IN ONSITE SOILS (4 • 6 FT.) THAT EXCEED BACKGROUND
SIHHIT NATIONAL SITE
BNA and PCS Parameter!
1,2-Dichlorobemene
Fiuorene
Oi -n-Butylphthalate
Butylbeniylphthalate
Bls(2-ethythexyl)phthalate
Di-N-Octyl Phthalate
Nurbcr of Times
Pflscied (1)
1
2
3
1
5
1
Range of Detected
Concentration* (2)
54J
57J-69J
3806-10958
59J
47J-4500
1300
Mean
Concentrations (2)(1)
11
25
435
12
1787
260
Standard
Deviation (2)
22
31
421
24
1BM
520
Upper 9SX Confidence LI nit
In Baekgroind Sanples (2)
NO
23
86
NO
52
MO
Pesticides
Heptachlor Epoxide
Hirei
12000**
136
2400
(1) Out of total 5 •ample*
(2) Units ug/kg dry weight
(3) Mean calculated using icro for samples where parameters not detected
J Estimated value
B Focnd In laboratory blank, possible/probable contamination
NO Not detected
•• Analyzed at medlun concentrations
272
4800
NO
NO
-------
TABLE 3-6
(con't)
SIHMARY LIST OF INORGANIC PARAMETERS IDENTIFIED
IN OMSITE SOILS <4 • 6 FT.) THAT EXCEED BACKGROUND
StHHIT NATIONAL SITE
Inorganic Parameters
Antimony
Chromiim
Copper
Iron
MagnesUm
Hercury
Nickel
Sodium
line
Nurber of Tines
Detected (1)
1
5
5
5
5
2
5
1
5
Range of Detected
Concentrations (2)
(161J.II
11-115
29-43
24700-50800
(12601-6020
0.19-0.25
1151-40
(660)
SI -359
Mean
Concentrations (2){3)
3
35
34
34060
2954
0.088
25
136
129
Standard Upper 95X Confidence Limit
Deviation (2)
6
40
5
8933
1636
0.109
9
272
116
in Background (2)
4
IB
29
29572
2782
0.098
19
143
113
(1) Out of total 5 samples
(2) Units mo/kg dry weight
(3) Mean calculated ualng icro for samples where parameters not detected
R Spike recovery not within control Units
( 1 Positive values less than the contract required detection Halt
J Estlmtaed value
-------
TABLE 3-6
(con't)
SUMMARY LIST Of VOLATILE PARAMETERS IDENTIFIED
IN ONSME SOILS (4 • 6 FT.) THAT EXCEED BACKGROUND
NATIONAL SITE
Volatile Parameters
Methylene Chloride
Acetone
1, 2-0 Ichtoroe thane
2 -But an one
1,1, 1 •Trlchloroethane
Trichloroethene
Beniene
Toluene
Chlorobeniene
Ethyl beniene
Total Xylenes
Nuitoer of Tines
Detected {1)
1
3
1
1
2
2
4
5
1
5 «
5
Range of Detected Mean
Concentrations (?) Concentrations (2)(3)
I7DOJ.B
1 008-4800 08, J
B900J
190000B.J
5-2BOOJ
4J-1100J
4J-31
36- 26000 J
-------
TABLE 3-7
SWMARY LIST OF VOLATILE PARAMETERS IDENTIFIED
IN OMSITE SOILS (6-8 FT.) THAT EXCEED BACKGROUND
NATIONAL SITE
Volatile Parameters
Methylene Chloride
Acetone
Carbon Disulflde
l.rolchloroethene
1,1-Dlchloroe thane
Trans-1.2-Dlchloroeihene
l.2-0lch(oroethane
2-Butanone
1,1.1-Trlchloroethane
Trlchloroethene
Beniene
4 -Methyl -2-Pentanooe
Tetrachloroetheno
Toluene
Chlorobemene
Ethyl bent ene
lotal Xylenes
Nurber of Tlnet Range of Detected Mean
Detected (1) Concentrations (2) Concentrations (2)(3)
B
10
10
5
10
5
9
7
15
20
19
B
6
26
5
24
26
190J."-6000B.J."
1308-42000B."
JJ-10
3J-7600J,"
3J-41000"
3J-7100
14-68000"
1BOJ,B,"-40000B,**
4J-2JOOOO"
4J-430000**
4J-110
4J-6400J,"
3J-2500J."
17- 140000"
5-5200"
3J-76000J/*
9-270000"
814
5272
2
293
2104
482
5887
5368
10252
21525
19
354
193
9818
203
9789
39927
Standard
Deviation (2)
1766
11024
3
1461
8169
1682
17558
11033
44102
83962
23
1301
639
28420
999
20794
84355
Upper 95X Confidence Level
in Background Samples(2)
ND
NO
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
13
ND
ND
2
(1) Out of total 26 aamplea
(2) Units ug/kg dry weight
(!) Mean calculated using icro for tanplei Uiere parameters not detected
J Estimated value
B Found In laboratory blank. Indicates possible/probable contamination
•• Anatyted at nedlun concentration
NO Not detected
-------
TABLE 3-7
(con1t)
SUMMARY UST Of BNA AND PESTICIOE/PCB PARAMETERS IDEMIIflED
IN ONSITE SOILS <6 • 8 FT.) THAT EXCEED BACKGROUND
SUMMIT NAIIOMAL SITE
Nutor of Time* Range of Detected Mean
BHA and PCS Parnnetert Dettcfed "> Concentrations (2) Concentrations (2)(3)
Phenol
1 , 4 • 0 1 ch I orobemene
1,2-Dlchlorobeniene
1 sophorone
1.2,4 -Irichlorobeniene
Naphthalene
2-Methylnupthalene
f luorene
Hexachlorobeniene
Phenanthrene
Di-N-Butylphthalate
But ylbentylph thai ate
Bis(2-ethy(hexyl)Ph thai ate
Oi-N-Octyl Phthalate
lndeno(1,2,3-cd)pvrene
Dibctu(a,h)Anthracene
Benzo(g,h. i )Peryl eoe
2
2
^
2
2
24
25
11
3
25
16
4
26
12
5
3
14
87J-740
240J-2300V
49 J- 17000"
44 J -720
100J-210J
7»J-7flOO"
130J-6800"
61J-380
960-34000**
110J-4700J,"
100J.B-2400J,**
450J-4900J,"
71J-370000**
44J-22000"
54J-2900J,**
66J-2700J.**
53J-4500J**
32
9
74B
29
12
1802
1639
83
144S
1122
357
383
28086
1307
134
122
255
Standard
Deviation (2)
143
46
3266
138
44
2101
1604
125
6532
1214
586
1133
76468
4272
558
522
855
upper 95X Confidence Limit
in Background Samples (2)
NO
NO
ND
ND
ND
1438
1587
23
61
1091
86
NO
52
ND
150
31
135
Pesticides
4.4'-DOT
PC8'i(4)
27-36
990-37000**
2
2230
a
7245
ND
NO
(1) Out of total 26 •ample*
(2) Units ug/kg dry weight
<3) Mean calculated using lero for samples Uiere parameters not detected
<4) Arochlor 1232, 1242, 1248, 1254
J Estimated value
•• Anatyied at nedlun concentration
B Found In laboratory blank, possible/probable contamination
NO Not delected
-------
TABLE 3-7
(con't)
SUMMARY LIST OF INORGANIC PARAMETERS IDENTIFIED
IN ONSITE SOILS (6 • 8 FT.) THAT EXCEED BACKGROUND
SUMMIT NATIONAL SITE
Inorganic Parameter*
Arsenic
Barlun
Beryl 1 km
Chromium
Cobalt
Copper
Iron
Magnesium
Nickel
Potass lun
Zinc
Nurtwr of Time*
Detected (1)
26
26
26
26
26
26
26
26
26
26
26
Range of Detected
Concent ration! (2)
9.3J-29J
[351 -251
[0.451 -(1. 8)
8.8-29
m-si
19-66
20800 -48900
(13401-5140
11*1-47
(12201-3450
41-195
Mean
Concentrations (2){?)
19
81
0.54
17
15
30
32462
3233
29
1730
90
Standard
Deviation (2)
5
50
0.35
I
8
9
7310
1060
9
494
35
Upper 95X Confidence Limit
In Background {2)
19
100
0.726
18
13
29
29572
2782
19
2161
113
(1) Out of total 26 samples
(2) Unite mg/kg dry weight
(3) Mean calculated using tero for sample* where parameters not detected
R Spike recovery not within control Units
( ] Positive values less than the contract required detection limit
S Value determined by standard addition
J Estimated value
-------
Parameter*
Nuifcer of
Time* Detected (1)
TABLE 3-8
SUMMARY OF ORGANIC PARAMETERS IDENTIFIED IN
CEMENT PLANT SURFACE SOILS THAT EXCEED BACKGROUND
SLUMIT NATIONAL SITE
Range of Detected
Concentrations (?)
• Mean
Concentration (?)(3)
Standard
Deviation (?)
Upper 95X
Confidence Limit
in Onsite Soil
Upper KX
Confidence Limit
in Background
Soil
Volatllea
Methylene Chloride
1,2-Dichloroethane
BHA and PC8
Naphthalene
?• Methyl naphthal erte
Dibeniofuran
Mourene
Phenanthrene
Anthracene
Di-N-Butylphthalate
Fluoranthene
Pyrene
Benio(a)Anthracene
Bis(2-ethylhexyl)Phthalate
Chrysene
Benio(b)f(uoranthene
Benio(k)fIuoranthene
Benio(a)pyrene
Indent) (1,2.3-cd)Pyrene
Bcnio(g,h,i iPcrylene
PCB'S
7
It
4
1
7
2
10
5
5
4
2
5
4
4
4
1
1
2J-18
4J-16
239 J-36000"
90J-55000"
57J-1?000"
100J
I36J-30000*•
?500J/«-5500J,**
fi?J-1677B
1JOJ-?0000«*
130 J-20000"
190J-16000"
330J-469J
7?J-16000"
?50J-?1000"
?50J-?1000"
150J-10000*•
5200J,"
3900 J,"
398-3100
3628
S3S3
1069
a
3338
615
42S
2689
245S
1787
61
1999
2511
2511
1258
400
300
887
9476
14471
3174
27
8029
1559
469
6217
5837
4468
147
471S
6078
6078
2981
1386
1039
1234
1007
6750
3453
2719
96
146
1660
659
2324
300
280
187
218378
227
160
82
116
32
ITS
38305
NO
NO
1438
1587
349
23
1091
69
86
594
512
346
52
423
598
598
301
150
115
NO
(1) Out of • total of 13 samples
(2) ug/kg dry weight
(3) Mean calculated using zero for samples where parameters not detected
J Estimated value
B Found in laboratory blank
" Analyzed at median concentration.
-------
TABLE 3-8
(con't)
SUMMARY OF INORGANIC PARAMETERS IDENTIFIED IN
CEMENT KANT SURFACE SOUS THAT EXCEED BACKGROUND
SUMMIT NATIONAL SITE
Parameters
Arsenic
Bariun
Calcium
Copper
Iron
Mercury
Nickel
iodiun
Nuitocr of Range of Detected
Times Defected (1) Concentrations (?)
12
1]
11
11
1]
6
12
5
8.7-78
[51J-578
[9821 -1UOO
(171-119
6620-51700
0.1-0.52
(141-36
* (7661 -15090)
Mean
Concentration (2)(3)
21
166
19867
36
12186
0.13 .
25
676
Upper 95X Upper 95X
Standard Confidence Unit Confidence Limit
Deviation (2) In Or.site Soil (2) In Background Soil (2)
19
154
29892
25
12702
0.16
10
1343
19
118
11331
44
44152
0.217
29
222
19
100
7316
29
29572
0.098
19
143
(1) Cut of • total of 13 cample*
(2) ma/kg dry weight
(1) Mean calculated using lero for a ample* where parameter* not detected
(] Positive values less than the contract required detection limit
J Estimated value
E Eft(mated due to interference
R Spike recovery not within control Units
-------
TABLE 3-9
SUMMARY OF ORGANIC PARAMETERS IDENTIFIED IN
CEMENT PLANT SUBSURFACE SOILS (2 • 6 FEET) THAT EXCEED BACKGROUND
SUMMIT NATIONAL SITE » '
Parameters
Nunfcer of
Detected (1>
Range of Detected
Concentrations (?)
Mean
Standard
Deviation (2)
Upper 95X
Confidence Limit
In Onsite Soil (?)
Upper 9SX
Confidence Limit
In Backgromd Sol I (2)
VQ!at lies
Methylene Chloride
BHA 1 PCB
Isophorooe
Di-N-Butylphthalate
ButylbemylpMhalate
8is(2-ethylhexyl)phthalate
PCB
21-97
US
30JJ.B-13138
60J
S9J
170-1240
20
90
743
U
12
628
(1) Out of a total of 5 sanples
(2) ug/kg dry weight
(1) He on calculated using lero for samples Uiere parameters not detected
J Estimated value
B Foind in laboratory blank
179
349
27
24
4B3
907
246
2324
1111
2I6M78
38305
NO
NO
66
NO
52
ND
-------
TABLE 3-9
(con't).
SUMMARY OF INORGANIC PARAMETERS IDENTIFIED IN
CEMENT PLANT SUBSURFACE SOILS (2 • 6 FEET) THAT EXCEED BACKGROUND
SIMHIT NATIONAL SITE
Parameters
Cobalt
Copp«r
Maynesiun
Nickel
Nintoer of
Times Detected (1)
5
5
S
5
Range of Detected
Concentrations (?)
[141-1231
26-30
125201-4890
(221-40
Mean
Concentration (2){3)
tr
28
3o08
32
Standard
Deviation (2)
3
1
852
6
Upper 9SX
Upper 95X
Confidence Limit Confidence Limit
inOnsite Soil
13
44
3168
29
(2) in Background Sol I (2)
11
29
2782
19
(1) Out of a total of 5 tanplet
(2) ma/kg dry weight
(3) Mean calculated using tero for iample Utere parameters not detected
( 1 Positive values less than the contract required detection limit
E Estimated due to interference
-------
TABLE 3-10
SUMMARY LIST OF ORGANIC PARAMETERS IDENTIFIED IH
EASTERN PERIMEIER SOILS THAT EXCEED BACKGROUND (2)
SUMHIT NATIONAL SITE '
Parameters
Volatile!
Toluene
BNA Parameters
Bentolc Acid
Naphthalene
2 -Me thy I naphthalene
Acenapthene
Dibemofuran
Fluorene
Phenanthene
Anthracene
Di-n-butylphthalate
Huoranthene
Pyrene
Butylbeniylphthalate
Benio(a)Anthracene
BU<2-ethylheicyl)Phthatate
Chrysene
Benio( b) F luoranthene
Benio(k)Fluoranthene
8enio(a)Pyrene
lndeno(1,2,3-cd)Pyrene
Dibeni(a,h)Anthracene
Benio(g,h, 1 )Perylene
PCB's
Notes:
Cittern Perimeter Sold
No. of Times Range of Detected
Detected (1) Concentration
7
1
7
7
1
5
1
7
1
7
5
6
1
4
4
4
4
4
1
)
2
4
2
4J-28
SOOJ
125J-2000
125J-3200
240J
120J-B70
460
204J-6SOO
910
60J- 10868
B6J-7100
1 JO J- 4700
67J
88J-3000
4SJ-206J
BJ J -2400
1 20 J- J200
1 20 J- 3200
4IJ-1700
41J-1700
89J-410
I20J-1200
450-5AO
Mean
Concent rat ion(3-)
11
•
56
B72
1J29
27
260
SI
1314
101
279
947
685
7
429
54
315
462
462
23B
238
55
194
110
Standard
Deviation
9
157
766
1187
75
310
1S1
1924
286
364
2192
1434
21
931
72
741
992
992
531
531
128
368
207
Upper 95X
Confidence Limit
in Ons! te
Surface Soils
15658
699
3453
2719
133
96
146
1660
659
2324
300
280
1111
187
218378
227
160
82
116
32
ND
175
38305
Upper 9SX
Confidence
Limit in
Background Soils
13
297
1438
1587
35
349
23
1091
69
86
594
512
NO
346
52
423
598
598
301
150
31
135
NO
(1) Out of • total of 9 camples
(2) ug/kg dry weight
(3) Mean calculated using tero for those samples where parameters were not detected
J Est invited value
B found in laboratory blank
-------
TABLE 3-10
(con1t)
SIMHARY LISr Of INORGANIC PARAMETERS IDENTIFIED IN
EASIERH PERIMETER SOILS THAT EXCEED BACKGROUND (2)
SIMMII NA1IONAL SITE
Parameter!
AluninLfn
Arsenic
Bar HID
Beryl 1 fun
Caotniim
Colclim
Chromiun
Cobalt
Cojper
Iron
lead
Magnesium
Manganese
Mercury
Nickel
Potasshn
Selenium
Silver
Sodiun
Tin
Vanadium
Zinc
Upper 95X
Eaitern Perimeter Soils Confidence Limit
Ho. of Time* Range of Detected Mean • Standard in Ons ite
Detected (1) Concentration Concentration^) Deviation Surface Soils
9
9
9
7
I
9
9
9
9
9
9
9
9
S
9
9
1
4
6
2
9
9
2300-12700
9.9-20
1511-295
1.521-1. J
12.81 -4.2
(4021-19700
15-22
151-115)
29-56
26100-40600
17-241
(5151-4700
54J-1350J
.2-1.1
(181-30
(1190)- (2230)
3.3
I2.71J,R-(4.5U,R
(6741-111501
(161 -(221
(161 -(251
36-300
8169
13
114
.529
2
4706
IB
It
36
30211
99
2742
512
.272
24
1826
0
2
581
4
20
155
2627
3
73
.166
2
5883
3
3
7
4452
85
1126
394
.347
5
323
(
2
438
a
3
114
9640
19
118
0.729
6
11331
32
13
44
44152
49
3168
452
0.217
29
1923
0
1
222
7
31
205
Upper 95X
Confidence
Limit in
Background Soils
11699
19
100
0.726
3
7316
18
13
29
29572
117
2782
1003
0.098
19
2161
NO
5
143
NO
26
113
Motes;
(1) Out of a total of 9 sample*
(2) nQ/kg dry weight
(3) Mean calculated using tero for sample* where parameters not detected
( ) Positive values less than the contract required detection limit
R Spike recovery not within control limits
S Value determined by standard addition
J Estimated value
-------
TABLE 3-11
SUNiAIV US! Of ORGANIC PARAMETERS IDENTIHtO IN ONSIIE SURFACE UAIER
SHOUT NATIONAL SHE
No. of Tlges Range of Detected Mean £ Standard Upper 95X
Parvneters Deiecie
-------
TABLE 3-11
(con't)
SIMMARV LIST or INORGANIC AND SAS PARAMETERS IDENTIFIED IN OHSIIE SURFACE WATER
SUMMIT NATIONAL SITE
Parameter!
InorgnnU Paranx
Alumirtn
Anl inmny
Arsenic
Barium
Beryl Ilin
Cncfrnlin
Calclui
Chromium
Cobalt
Center
I run
Haflnesiui
Manganese
Nickel
Potassium
Selenium
Sodiun
Zinc
SAS Parameters
No. of Tlgtes Range of Detected
Detected^ Concentrations
t*rt
5 200-39800
2 62-121
•
25-27
9.9-25 .
5-7.9
9-35
139000- 297000E
4.2-28
13-123
11-122
3010-68500
32500-120000
3740-8100
20-322
3670- 12400
16
14700-72100
202-1660
Anrnonla as N (ng/l) 2 4.5-4.6
Chloride (ng/l)
Suspended Sol Ids
Dlisolved Solid*
Sulfate (ni/D
Acidity (w/l)
field Parameter*
47-12)
(mg/1) 7-41
(•a/1) 1320-2210
850 -1 310
43-320
Mean
Concentration
9932
31
9
to
2
11
216283
9
37
41
2)132
77647
6180
112
8155
• •
44833
749
3
85
18
1873
1160
137
•
Standard Upper 95X
Deviation Confidence Halt
14746
46
12
11
3
13
63373
It
45
51
26386
34t40
1681
114
3108
• -
23674
610
2
31
16
394
220
130
25409
TV
22
21
5
25
282800
21
84
94
51026
113480
8145
232
11627
..
69682
1411
a
162
58
2853
1705
459
pH (standard units) 6 3.4-6.5
Specific Conductance (urfios/cn) 6 1050-2000
1463
398
2163
Area 4
USGS (1981)
HA
HA
NA
NA
HA
HA
NA
NA
NA
HA
0-27000
HA
0-4900
HA
NA
NA
HA
HA
NA
HA
HA
HA
1.0-2500
HA
3.1-9.2
30-14500
Notes;
£ Alt values eipressed In parti per billion (ppb) unless otherwise noted
e Based on total of sin samples except for SAS parameters which were analyzed In three sanples
Mean Is calculated using »ero for samples where parameters not detected
E Value is estimated die to interference
NA Not available
•• Not applicable
-------
TABLE 3-12
Parameters
SUttlARY LIST OF ORGANIC PARAMETERS IDENTIFIED
IN OfFSIIE SURFACE UATER THAI EXCEED BACKGROUND (1) (2)
SUMMIT NATIONAL SUE
Concentration Concentration Concentration
In South in Sooth In lower East
Dltch-Upatrea* Dluh-DonuUream* Drainage Ditch
Concentration Concentration Concentration
In East in First in Second
Drainege Dltch(l) lnf>oundnent(3) Inpoundment
Range of Concentration
Detected in
Onslie Surface Water
Volatiles
Vinyl Chloride NO
Hethylene Chloride 1J.B
Acetone 17B
1.1-Dfchloroethane NO
Trans- 1.2-dichloroethene NO
1.2-Dichlorocthane NO
2-Bulanone 198
1.1.1-Frichloroethane NO
Irichloroelhcfte NO
t-Hclhyl -2-penlanone MD
loluene NO
Chlorotwniene NO
7J
W
78
HO
NO
NO
NO
3100
NO
s
soo
158
NO
NO
58
NO
NO
HO
IS
11
NO
HO
NO
NO
NO
NO
HO
NO
NO
HO
NO
HO
HO
HO
16
NO
HO
HO
NO
NO
NO
NO
2J.B
188
NO
HO
11
188
NO
NO
HO
13
NO
ND
2B,J-S1 •
300.J-4000
5J •'
NO •
VJ-860-
St6eV
NO..
U:120
50*
BMAl
Aniline
Isoptiorone
Benioic Add
Bi»(2-ethylhe«yl)
Phthtltt*
Notes;
NO
NO
NO
NO
AJ.B
107
NO
NO
MO
12B.J
7J
28)
H
J1J
UB.J
HO
NO
NO
NO
25B
NO
HO
HO
HO
138
NO
NO
NO
HO
108
(1) Kaxiiun concentration In particular area
(2) Unite In ppb
(I) 19M (Mple only • dry In 1986
8 Analyt. Not detected
— All values show laboratory contamination and statistically treated as lero
Only one sample
BJ-12
227-211
12-11
47J*
-------
TABLE 3-12
(con1t)
SIMMARV LIST OF INORGANIC AND SAS PARAMETERS IDENTIFIED
IN OFFSIIE SURFACE UAIER THAT EXCEED BACKCROUNO (1) (2)
SUMMIT NAIIOHAL SHE
Concentration Concentration Concentration Concentration
Inorganic In South In South In Lower East In East
Parameters 01 tch-Up*trem Ditch- Dour* treaid* Drainage Ditch Drainage Ditch(J)
Aluninin
Aminony
Arsenic
Uuriim
Caitnium
Calciin
Chromium
Cobalt
Cojiper
Iron
Magnesium
Marvjanetie
Nickel
Polassiun
Sodium
Vanadium
2inC
SAS Parameters
Total Alkalinity (CaCO.)
Amiunia at N (rg/l)
Chloride (i«/l)
Suspended Solids (mo/1)
Dissolved Solids (nQ/l)
Sullate <»g/l)
Field Parameters
pH (standard units)
Sp. Cond. (unfcos/CB)
343HO
ND
NO
I76|
NO
306000E
It
ia.n
(16)
17200
112000
5170
19.91
2
-------
TABLE 3-13
SUMMARY LIST OF VOLATILE PARAMETERS IDENTIFIED
IN UEST POND SEDIHENT THAT EXCEEDED BACKGROUND SOILS
SUtfIT NATIONAL SITE
Upper 95X Upper 95X
Confidence Limit Confidence Limit Maxima
Mintwr of Tinea Range of Detected Neon Standard in Onsite in Background Concent rat Inn In
Defected) Concentrations^) Concentrat|ons(2)(1) Deviation Surface So|l«(?) Soil Sanples(2) Upstream Sed(mtnt(2)
A
2
3
1
1
a
i
7
3
4
4
6
5
50-41000"
300A-2600"
13-16
86
9A
3J-B900"
12000"- 18000"
50A-2SOOA."
10-500"
12A- 174000"
8 J- 1000"
16A-2BOOO"
4J-WOQO**
6263
322
S
10
1
2426
5000
670
SB
23)35
1B3
B037
29023
12574
811
7
27
3
340B
7211
747
156
5)791
345
1M17
39332
1007
26222
2
2
22
6750
3429
4499
157B2
15658
177
11 189
44161
NO
NO
NO
NO
NO
NO
NO
NO
NO
13
NO
NO
2
230
NO
MD
NO
NO
NO
SOBJ
ND
NO
ND
ND
NO
NO
Volatile Parameter!
Hethylerte Chloride
Acetone
1,1-Dlchloroethene
1,1-Dichloroethane
Trans-1.2-0ich(oroethene
1.2-Dichloroclharte
2-Butftnone
1.1,1-IrUM oroet hane
Trichloroethene
Toluene
Chlorobeniene
Ethylbeniene
Total Xylene*
(1) Out of total 9 aonplci
(2) Unit* ug/kg dry weight
(!) Mean calculated ming icro for aaoplei Uiere parameters not detected
J EttiMted value
B Found In laboratory blank. Indicates possible/probable contamination
•• Analyied at medium concentration
NO Not detected
A Delected below quant I tat Ion limit
-------
TABLE 3-13
(con't)
SUN4ARY LIST Of BNA AND PCB PARAMETERS IDENTIFIED
IN iCSI POND SEDIMENT THAT EXCEEDED BACKGROUND SOILS
SLUM11 NATIONAL SITE
Ninfcer of Tine* Range of Detected Mean
Conctntritlont(Z) Concentmtlon9(?)(3)
2
2 ;
9
)
5
B262J-1W6J
. 2400-2700A
5 1 20 J- 87000
2100-9400
MOOA-J5000C
2201
567
J6/07
1913
6022
4190
10&2
263/6
3206
10597
149
15438
2I8J7B
1SOS6
M105
NO
61
52
NO
NO
409J
518J
197J
NO
NO
BMA and PCB Parameter!
N-NitrosodipnenyI anlne
Hexach I oroberu eoe
Bis(2-ethylhe«yl)Phthalate
Oi-n-Octyl PhthaUte
PC Us (4)
(1) Out of total 9 samples
(2) Units ug/kg dry weight
(}) Mean calculated uaing icro for sarrples where parameters not detected
(4) Arochlor 1232. 1242. 1248. 1254
J Estimated value
A Detected below quantltatlon limit
NO Not detected
C Pettlclde parameter confirmed by CC/MS
Upper 95X Upper 95X
Confidence limit Confidence Unit Naxlsui
Standard In OnsHe In Background Concentration In
Pevlatloo Surface So|ls(?) Soil SanplesfZ) Upstream Sedlmentt?)
-------
TABLE 3-13
(con't)
SIMHARV LIST Of INORGANIC PA«AMETE*S IDENTIFIED
IN UEST POND SEDIMENTS THAI EKCEEDEO BACKGROUND SOUS
SUMMIT NATIONAL SITE
•far of Tlaws
Detectedtll
1
9
9
9
4
4
9
4
9
9
Range of Detected
Concentration^?)
14BR
15R-55R
18R-57
34154-72667
2. 18-258
.16-. 3
1151 -37A
(791) -(1310]
(14)-(35)R
71R.E-915R.E
Mean
Concentrat|ons(2)(3)
16
32
37
47789
4
.094
23
482
24
263
Standard
Deviation
47
14
13
11250
a
.111
6
556
7
259
Upper 95X
Confidence Limit
In Ons Ite
Surface Sol|s(?)
35
32
44
44152
7
0.217
29
222
31
205
Upper 95X
Confidence Linlt NIK (nun
In Background Concentration in
Soil S«
-------
TABLE 3-1A
SUMMARY LIST OF VOLATILE PARAMETERS IDENTIFIED
IN EAST PONO SEDIMENT THAT.EXCEEDED BACKGROUND SOILS
SUMMIT NATIONAL SITE
Upper 95X Upper 95X
Confidence Limit Confidence Ll«it HaKlnun
Nuntoer of TlMi
Dctretcdd)
6
5
3
2
4
2
2
4
1
2
Range of Detected
Concentration^?)
8J .1-8708
46B-510A
69 2261
13115-16608
30.SA-787
10-20
10J-25
20A-329
24A-146
41-67
Mean
Concent rat lons{?)(3)
3U
ISO
534
4246
241
4
5
95
J5
16
Standard
Deviation
310
199
854
6778
343
7
9
117
32
26
In Onalte
Surface So|ls(2)
1007
26222
2
6750
4499
15782
4
177
11189
46161
In Background
Soil Sanple*(2)
MO
NO
NO
NO
NO
NO .
NO
NO
NO
2
Concentration In
Upstream Sedlment(2)
230
NO
NO
NO
soaj
NO
NO
NO .:
NO
NO
Volatile Parameter!
Methylene Chloride
Acetone
1.1-Oichloro*thane
1.2-DUMorocthane
1.1,1-Trlchloroeihaoe
Trichloroethene
Benicne
Chlorobeniene
Ethylbeniene
Total Xylenea
(1) Out of total 7 tanple*
(2) Unit* ug/kg dry weight
(5) Mean calculated using icro for aanpl* Uiere parametera not identified
J Estlnted value
B Found in laboratory blank. Indicate* posilble/probable contamination
NO Not detected
A Detected below quantltatlon lleilt
-------
TABLE 3-14
(con't)
SLHHARY LIST OF 6MA AND PCS PARAMETERS IDENTIFIED
IN EAST POND SEDIMENT THAT EXCEEDED BACKGROUND SOILS
SUMMIT NATIONAL SHE
Scral -Volatile Parameter!
PCBs
Upper 95X Upper 9SX
Confidence Limit Confidence Halt Msilnn
Ninfcer of Tine* Range of Detected Mean Standard In On*lie In Background Concentration in
Pctycted())_ Concentrations^) Concentrations(?)(3) Deviation Surface Soils(2) Soil SaffplcaC?) Upatream
N-Nltrosodlphenylmlne
Hexachl orotoeniene
Di-rvbutylphthilate
Bi*(2-ethylhe»yl )Phlhilale
Dl-n-Octyl Phlhalate
PCBs (4)
1
2
2
7
5
I
<90J-229S1J
S1BJ-10BOA
2521B-67UB
9244-291608
JJ9J-55J7BJ
8171-21000
3505
22fl
1)19
70076
11111
474fl
7948
391
2168
95172
18792
7236
149
164W
2324
218378
15056
38305
NO
61
84
52
NO
NO
409J
51BJ
2348B
197J
NO
NO
(1) Out of total 7 sanple*
(2) Units ug/kg dry weight
(J) Mean calculated ualna icro for sanplea Uiere parameters not detected
(4) Arochlor 1232. 1242, 1248. 1254
J Estimated value
B Found In laboratory blank. Indicates possible/probable contamination
NO Not detected
A Detected below c^antItatlon Unit
B Found in laboratory blank. Indicates possible/probable contamination
-------
TABLE 3-14
(con't)
SUMMARY LIST OF INORGANIC PARAMETERS IDENTIFIED
IN EAST POND SEOINEMT THAT EXCEEDED BACKGROUND SOILS
SUHHIT NATIONAL SITE
Upper 95X Upper 95X
Confidence limit Confidence Llnlt Man I nun
Inorganic Parameters
Antimony •
Barium
Chromium
Iron
Cyanide
Mercury
Nickel
Sodium
Zinc
Number of Tlsws Range of Detected
Detectedd) Concentrations^)
2
7
7
7
2
4
6
2
7
68- IBS) R
(82IR-I1511
12R-73
30728-118000
3R-74R
.17-. 29
I211II- (Ml
C1B701- 119601
100R.E-1S70
Mean Standard In Onsite
Coneentratlons(2)<3) Deviation Surface Soi(»{2)
22
106
44
57806
11
0.13
24
547
471
35
25
18
38168
26
.119
11
865
470
35
118
32
44152
7
0.217
29
222
205
In Background Concentration In
Soil San>lefi(2) Upatream Sediment (2)
4
100
18
29572
1.186
0.098
19
143
111
ND
(1281
10
25682
NO
ND
30R
ND
85R.E
(1) Out of total 7 simple*
(2) Units mg/kfl dry weight
(1) Mean calculated utlng icro for sanplea where parameters not detected
R Spike recovery not within control Unit*
( | Poeitlve value* lets than the contract required detection limit
E Value 11 ei tinted due to the presence of Interference
-------
TABLE 3-15
SUWARY LIST Of VOLATILE PARAMETERS IDENTIFIED
IN OffSITE SEOIHEMTS THAT EXCEED BACKGItaiMD (1) (2)
SIKH IT NAT I OH AL SITE
Volatile
Pnriuneters
Hethylene Chloride
Acetone
trans- 1,2-Dichloro-
ethene
1,2-Dichloroe thane
1. 1. 1-lrichloro-
ethane
Irichloroethene
Beniene
Toluene
Concentration
In South
Pltch-tlpatreaq
340
229
HO
MO
663J
HO
NO
97
Concentration
In South
Dltch-DoHratream
400
NO
290
ND
NO
110A
3JA
ND
Concentration
In tower East
Prajnage pitch
2788
ND
NO
240
ND
NO
NO
NO
Concentration
in East
Drainage Ditch
670
64B
ND
NO
NO
ND
ND
NO
Concentration
in f-lrst
linpounriment
• *
uoo
ND
ND
27
NO
NO
ND
Concentration
In Second
Ifflpomdnent
B m
15J
HO
NO
423
NO
NO
NO
Nail Bin
Concentre! Ion
in upstream
Sediment (2)
230
NO
NO
NO
SOflJ
NO
ND
ND
Upper 95X
Confidence Limit
In Background
Soil Sanples (2)
NO
NO
NO
NO
.
NO
NO
NO
13
Total Volatlles(3) 1229
780
175
670
1600
160
(1) Mailflin concentrations In particular area
(2) Units u9/kg dry weight
(3) Based on highest single sample In particular area
J Estimated value
A Detected below quant I tat Ion limit
B found In laboratory blank. Indicates possible/probable contamination
MO Not detected
NA Not applicable
•• Detected below background
5U
NA
-------
TABLE 3-15
(con1t)
SUMMARY LIST Of SNA AMD PESTICIDE/PCB PARAMETERS IDENTIFIED
IN OFfSITE SEDIMENTS THAT EXCEED BACKGROUND (1) (2)
SUMMIT NATIONAL SITE
Concentration Concentration
Somi- Volatile in South In South
Parameters Oilrh ll|K>U*vn 01 If h -Downstream
Phenol
1 , 2 • 0 i ch 1 orobeni ene
4 Methyl phenol
Mu|ftlhalene
2-Huihylnapthalene
Accnuplhyl er»e
Acii>u(Jthene
Ditivniofuran
Fliorene
N-Ni trosodtprierryla-
mine
He » at hi orobeni ene
Phcnanthene
Oi N-Butylphthalate
Muoranlhene
Pyrene
Uen;o( a) Anthracene
8is(2-ethylhe»yl)
Phthalale
Chrysene
Uenio(b)Fluorinthene
Uenio(k)Huoranthern
Ucnto( a) Pyrene
lrKicno(1,2.3-cd)
Pyrene
Oibeni(a.h)Anthracene
Bcnio(0,h. l)Pcryleite
Pest icldes
Heptachtor Epoxide
PCBs (4)
55BJ
HO
99 7 J
1600
610A
11 00 A
1100A
2 100 A
3100
609 J
HO
6400
5I21J
24000
16000
9000
704 J
16000
13000
413J
7300
5200
5400
6900
UD
ND
ND
680A
ND
&OOA
1200A
NO
NO
18JJ
NO
ND
ND
710A
ND
ND
ND
ND
15000
5 90 A
ND
NO
ND
ND
ND
ND
ND
4200A
Concentration
in lower East
Drainage Ditch
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
7336B
ND
ND
ND
26000
ND
ND
ND
ND
ND
ND
ND
ND
ND
Concentration Concentration
in East ' . in Hrst
Drainage Ditch InMttfvtnent
ND
ND
ND
ND
4 30 A
NO
ND
ND
ND
NO
ND
ND
••
670
640A
NO
NO
NO
640A
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2100
2400A
NO
ND
370A
ND
1727J
ND
1700A
86368
309J
359J
ND
5909J
NO
ND
ND
ND
ND
ND
NO
8.1
ND
Max 1 BUB Upper 95X
Concentration Concentration Confidence Limit
in Second in Upstream in Background
Impotntnent Sediment Soil Samples (2)
ND
ND
ND
4 70 A
5BOA
ND
ND
ND
NO
809J
2800
4 70 A
4313B
NO
ND
NO
997B.J
NO
ND
ND
NO
4
NO
ND
ND
NO
ND
NO
UD
NO
ND
NO
ND
NO
NO
NO
409J
518J
ND
23488
NO
ND
ND
197J
NO
NO
ND
ND
NO
ND
ND
NO
NO
ND
ND
ND
1438
1587
ND
35
349
23
ND
61
1091
80 :
594
512
546
52
423
598
598
301
150
31
135
NO
NO
Total BNAs (3):
124530
15480
26000
2340
20517
(1) Mninuti concentrations in particular area
(?) Units "9/kg dry weight
(!) B«»ed on highett tingle sanple in particular area
(4) Arothlor 12)2. 1242. 1248. 1254
1 fkiifluied v
-------
TABLE 3-15
(con't)
SUMMARY LIST OF INORGANIC PARAMETERS IDENTIFIED
IN OffSIIE SEOIHEMIS 1HAT EXCEED BACKGROUND (1) (2)
SIKH II NATIONAL SITE
Inorganic
Parameters
Aluninun
Ant inufiy
Arsenic
Bariun
Cuclniun
Calcium
Chrumiun
CoUilt
Cp|fxr
lru>
lejd
Cyanide
HinjMakiun
Haivjaoese
Mercury
Nickel
Poiasslm
Sod i in
Vanadium
line
Concentration
in South
Oi ich-lifwirean
11600
NO
19
145
4.6
11600
24
1211
48
49000
1)1
NO
1 1980)
8S5
NO
(16|
(IttO)
NO
124)
215
Concentration Concentration
In South in lower East
Oltch-Downatrean Drainage Ditch
17600
NO
43
165
14
17236
41
1)2]
89
112000
71
2.4
(50001
2810
0.15
SI
(24501
(1780)
(161(1
355
16700
14)
38
• •
19
110500]
55
(20)
74
92589
35
NO
••
1500
NO
(49)
(2090)
(6720)
1281
1254
Concentration
in East
Drainage Ditch
10556
52
28
••
18
t
26 •
• •
66 .
166000
134
NO
•-
248
NO
• •
(15741
(1520]
IJ41R
134
Concentration
in First
Impoureknent
15431
NO
39
170
B.I
8X400
20
:'iui
42 ;
41600
42
' . NO
' 18897 ::
2014
NO
140}
(6410)'
13260)
(37)
279
Max Inn Upper 95X
Concentration Concentration Confidence Limit
in Second in Upstream In Background
Inpoiinrtnent Sediment Soil Saoples (2)
22.300
NO
54
•-
17 .
(5,4201 ,
36
(25)
35
. 113877
49
NO '.'.
(8.240) V
542
0.24
139)
(3,180)
(1,830)
(41)
200
9560
NO
NO
(128)
NO
(2855)
10
dam
1171R
25682
20
NO
3247
44 7R
NO
30R
(863)
NO
(24) R
85R.E
11699
4
19
100
3
7316
IB
13
29
29572
117
1.186 :
2782
1003
0.098
19
2161
143
26
113
(1) Nailnui concentration In particular area
(2) Units no/kg dry weight
R Spike recovery not within control limits
I ) Positive values less than the contract required detection limit
E estimated due to presence of Interference
•• Detected beluw background
ND Not detected
-------
TABLE 3-16
SUMMARY LIST OF PARAMETERS IDENTIFIED IN BURIED DRUMS
SUMMIT NATIONAL SITE
Parameter
Volatiles
Chloromethane
Methylene Chloride
Acetone
Trans-1,2-Dichloro-
ethene
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-Trichloroethane
Trichloroethene
Benzene
Toluene
Chlorobenzene
Ethylbenzene
Styrene
Total Xylenes
Base/Neutrals and Acids
Phenol
Naphthalene
Di-n-Butylphthalate
Pyrene
Bis(2-ethylhexyl)
Phthalate
Di-n-Octyl Phthalate
4
Pesticides/PCB's
None Detected
Inorganics
Aluminum
Cadmium
Calcium
Chromium
Copper
Range
20,000
5,700B,**-1,800,OOOB,J
l,600B,**-4,800,0008
370J,**-72,000
620B,J-770B,**
3,100**
5,400B,**-84,OOOB,J
1,500J-19,OOOJ
1,400J-140/000
1,200J
2,OOOJ-340/000
15,OOOJ-110,000
570J-190,000
370,000
650J,**-840/000
85,OOOJ
5,700J,**-28/OOOJ
2,900J,**
21,000**
43,000**-100/000**
>
No. of
Drums
Detected In
1
8
7
2
3
1
6
4
4
1
8
2
5
1
6
1
1
2
I
1
1
2,790-16,500
88R-139R
2,700-6,240
68
69.7-527
3
2
6
1
2
-------
TABLE 3-16
(con't)
No. of
Drums
Parameter Range Detected In
Iron 226-25,700? 6
Cyanide 768-1,330F 2
Magnesium 809-2,340 4
Manganese 60.6-982 3
Nickel 55-241 8
Silicon 897-49,700E 5
Titanium . 602-979 2
Zinc 111-198,000 4
Notas:
Organic results expressed in ug/kg; inorganic results
expressed in mg/kg dry weight
B Analyte found in laboratory blank; indicates
possible/probable laboratory contamination
E Value is estimated due to the presence of interference
F Sample concentration is greater than four times the
spike value
** Sample analyzed at medium concentration
-------
TABLE-3-17
SUMMARY LIST OF PARAMETERS IDENTIFIED IN TANK A
SUMMIT NATIONAL SITE
parameter Range
Volatiles
Methylene Chloride
Acetone
2-Butanone
Benzene
Toluene
Ethylbenzene
Total Xylenes
Base/Neutrals and Acids
6,300B-1,200,OOOB,J
36,0008-9,500,0008
72,0008
43,000-13,000,000
64,000-54,000,000
6,000-10,000,000
32,000-55,000,000
Naphthalene
2-Methylnaphthalene
Acenaphthene
Fluorene
Pentachlorophenol
Plienanthrene
Anthracene
Di-n-butylphthalate
Pyrene
Benzo(a)Anthracene
Chrysene
Benzo(b)Fluoranthene
Benzo(k)Fluoranthene
Pesticides/PCB's
None Detected
Inorcanics
Aluninun
Calciun
Copper
Iron
Lead
Magnesiun
Manganese
Silicon
12,OOOJ,**-360,000**
11,OOOJ,**-470,000**
28,OOOJ,**
4,200J,**
34,OOOJ,**
34,000**
4,OOOJ,**
28,OOOJ,**
4,700J,**
2,OOOJ,**
2,800J,**
2,300J,**
1,600J,**
6,210
1,680-2,680
120
162,OOOF
460
871
331
2,160-21,900E
Phases
Detected
T,M,S
M,S
M
T,M,S
T,M,S
T,M,S
T,M,S
T,M
T,M
T
T
S
S
S
T
S
S
S
S
S
T
T,M
T
T
T
T
T
T,M
-------
TABLE 3-18
SUMMARY OF PARAMETERS IDENTIFIED IN TANK BY INCINERATOR
SUMMIT NATIONAL SITE
Parameter
Volatiles
Methylene Chloride
1,1-Dichloroethene
2-Butanone
1,1,1-Trichloroethane
Toluene
Ethylbenzene
Total Xylenes
Base/Neutrals and Acids
Phenol
4-Methylphenol
2,4-Dimethylphenol
Naphthalene
Phenanthrene
Anthracene
Di-n-butylphthalate
Bis(2-ethylhexyl)
Phthalate
Pest icides/PCB's
Delta-BHC
Aldrin
Endosulfan I
4,4'-DDE
Inorganics
Aluminum
Barium
Cadmium
Chromium
Copper
Iron
Lead
Ranee
110,OOOB
50,OOOJ
50,OOOJ
250,000-270,000
3,120,000-3,550,
240,000-260,000
140,000-160,000
250,000
•664,000
•109,000
•24,OOOJ
•28,OOOJ
•112,000
67,OOOJ
525,000-
101,000-
23,OOOJ-
25,OOOJ
25,000,7-
16,OOOJ-
281,000-298,000
6,250**
4,750**
1,700**
1,800**
699-803
88-89
2.4-7.9
189R-202R
28
2050
168-195
No. of
Samples
Detected
2
1
2
2
2
2
1
1
2
2
2
1
2
2
1
1
1
1
2
2
2
2
2
2
2
-------
TABLE 3-18
(con't)
NO. Of
Samples
Parameter Range Detected
Manganese 14-17 2
Sodium 4,760-4,800 2
Thallium [2.3] 1
Tin 18R 1
Zinc - 67-71 2
Notes:
Based on duplicate samples TK001001 and TK301002 from
11/14/84
Organic results expressed in ug/kg; inorganic results
expressed in mg/kg dry weight.
B Analyte found in laboratory blank; indicates
possible/probable laboratory contamination
J An estimated value
R Spike sample recovery is not within control limits
** Sample analyzed at medium concentration
[] Positive values less than the contract required
detection limit
-------
. TABLE 3-19
ORGANIC CONTAMINANTS DETECTED IN AIR SAMPLES
SUMMIT NATIONAL SITE
Sample No.
Location
Date Sampled
SOI
Downwind
9/12/84
S02
Midrange
9/12/84
S03
Upwind
9/12/84
S04
Downwind
9/13/84
SOS
Midrange
9/13/84
S06
Upwind
9/13/84
Tetrachloroethcne
Toluene
Notes:
Front Back Front Back Front Back
-- <0.001 <0.001 <0.001
-- <0.001 -- <0.001 --
All concentrations reported In parts per million (ppm)
-- Not detected
Front - Front section of charcoal tube
Oack - Back section of charcoal tube
Front Back Front Back Front Back
-------
Attachment 4 - Detailed Cost Analysis Summary
-------
Attachment 4
List of Tables
Table 4-1 Cost Estimate Summary Alternative 2
Table 4-2 Cost Estimate Summary Alternative 3
Table 4-3 Cost Estimate Summary Alternative 4
Table 4-4 Coat Estimate Summary Alternative 5
Table 4-5 Cost Estimate Summary Alternative 6
Table 4-6 Cost Estimate Summary Alternative 7
Table 4-7 Cost Estimate Summary Alternative 8
Table 4-7 Cost Estimate Summary Alternative 9
-------
TABLE 4-1
Cost Estimate Suaury
Alternative 2
Resident Relocation with Monitoring
. He.
I. HRTSON RELOCATION
Move Watson Residence
Extend Site Boundary
Extend Site Fence
II. MONITORING
Runoff Monitoring
Groundtiatrr Monitoring
CONSTRUCTION SUBTOTAL
Health and Safety (10*)
Bid Contigency (15%)
Scope Contingency (201)
CONSTRUCTION TOTflL
Peraittira 1 Legal (5*5
Services Curing Construction (8X>
TOTAL IMPLEHSfffiTION COST
Engineering t Design (10*)
TOTflL CAPITAL COSTS
Capital Annual
Cost QIN
121,000
120,000
120,000 si, 000
116,000
$32,000 $54,000
$93,000
«,000
IU.OOO
1120,000
16,000
110,000
(140,000
* 14,000
Present Worth 30 Years
OtM/ReplaceMKnt
3* » 10*
$20,000 $15,000 $9,000
$310,000 $250,000 $150,000
$1,100,000 $830,000 $310,000
$1,400,000 $1,100,000 $670,000
1150,000
PRESENT WORTH
$1,SOO,000 $1,300,000 $820,000
-------
TABLE 4-2
Cost Estimate Summary
Alternative 3.
Capping with Drum and Tank Incineration
Ite.
I. GENERAL SITE PREPARATION
Decontamination Facility
Move Watson Residence
Extend Site Boundary
Extend Site Fence
Reroute S. Drainage Ditch
Diversion Berm
Demolition of Site Structures
Removal t Incineration of Drums 1 Tanks
tegrading
II. HJLTH.AYER CAP
Clay Layer
HOPE Liner
Drainage Layer
Vegetative Soil Layer
Revegetacion
III. 6ROUKDUATE3
Slurry Wall
Wells in Water Table Aquifer
Oil Skimmers
Wells in Upoer Intermediate Unit
5 Year Pumo Replacement
IV. WATER TREATMENT
Total System 50 6PM
V. MONITORIN6
Mobile Laboratory
Runoff Monitoring
Sroundnater Monitoring
CONSTRUCTION SUBTOTAL
Health and Safety (101)
Bid Contigency (15*)
Scooe Contingency (201)
CONSTRUCTION TOTAL
Permitting t Legal (SI)
Services During Construction (81)
TOTAL IXPLDeXTATICN COST
Engineering I Design (101)
TDTa CSPITflL COSTS
Capital Annual
Cost 0 t H
410,000
421,000
420,000
420,000 41,000
475,000
430,000
$54,000
41.300,000
4240,000
$670,000
4310,000 45,000
$220,000
$580,000
$20,000 $1,000
$690,000
41,200,000 4180,000
$90,000
$82,000 $15,000
*
$250,000 $87,000
$97,000
$16,000
$32,000 $54,000
$6,000,000
$600,000
$900,000
$1,200,000
$8,700,000
$440,000
$700,000
$10,000,000
$1,000,000
$11,000,000
Preset
! (
3X
420,000
498,000
$250,000
$55,000
$3,500,000
$290,000
$810,000
$1,700,000
$310,000
$1,100,000
$8,100,000
it Worth 2
Jtt/Replacew
a
415,000
477,000
4180,000
$40,000
$2,800,000
$230,000
$610,000
$1,300,000
$250,000
$830,000
$6,300,000
*
» Years
tent
101
49,000
447,000
$86,000 *
$21,000 *
$1,700,000
$140,000
$340,000
$820,000
$150,000
$510,000
$3,800,000
•
415,000,000 $17,000,000 $15,000,000-
« Present wrth calculated assuming replacement of 301 topsoil, regrading, and revegetating every 10 yrs.
-------
TABLE 4-4
Cost Estimate Suuarv
Alternative 5
Incineration of Hotspot Soil
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
Itei
6ENERAL SITE PREPARATION
Decontamination Facility
Hove Watson Residence
Extend Site Boundary
Extend Site Fence
Reroute S. Drainage Ditch
Diversion Sera
Demolition of Site Structures
Buildings for Incinerator
Soil Storage Building
INCINERATION
Capital
Maintenance
Operation
EICAVATICN 1 LOADIN5 OF
CONTAMINATED MATERIAL
Drum Excavation/Classification
Soil Excavation
Soil Handling and Loading
Backfill Ash and Coapact
DOUBLE LINER SYSTEM
Clay Layer
Drainage Systea
HDPE Liner
Geotextile
MULTI-LAYER CA?
Clav Layer
HDPE Liner
Drainace Layer
Vegetative Soil Layer
Revegetation
6ROUNDMATER
Slurrv Wall
Nells in Water Table Aquifer
Oil Skiaoers
Nells in Upper Interaediate Unit
5 Year Puap Replaceae.it
WATER TREATMENT
Total Systea 50 6PM
MONITCRIN5
Onsite Laboratory
Runoff Monitorina
Srcundwater Monitoring
CONSTRUCTION SUBTOTAL
Health and safety MOZi .
Bid Ccntiger.cy (151!
Scspe Contingency (201)
CONSTRUCTION TOTAL
Pereittir.a 6 Legal (51)
Services Dunns Csnstructior. (8Z)
TOTAL IMPLEMENTATION COST
Engineering & Design (101)
TOTAL CAPITAL COSTS
PRESENT WORTH
Capital Annual
Cost 0 6 N
$14,000 $4,500
$21,000
$20,000
$20,000 $1,000
$75,000
$30,000 $5,000
$54,000
$120,000
$44,000
$1,300,000
$50,000
$1,800,000
$580,000
$180,000
$200,000
$170,000
$170,000
$67,000
$130,000 $3,000
$46,000
$670,000
. $310,000 $5.000
$220,000
$580,000
$20,000 $1,000
$690.000
$1,200,000 $180,000
$90,000
$82,000 $15,000
•
$250,000 $87,000
$400,000 $110,000
$16,000
' $32,000 $54,000
Present Worth 30 Years
O&H/Replaceaeaent
31 51 10Z
$24,000
$20,000
$27,000
$270,000
$9,800,000
$59,000
$98,000
$250,000
$55,000
$3,500,000
$290,000
$810,000
$1,700,000
$600,000
$310,000
$1,100,000
$7.800,000 $19.000,000
$780,000
$1,200,000
$1,600,000
$11,000,000
$530.000.
$900,000
$12,000,000
$1,100,000 til
$13,000,000
$32,000,000
$23,000
$15,000
$25,000
$250,000
$9,100,000
$46,000
$77,000
$180,000
$40,000
$2,800,000
$230,000
$610,000
$1,300,000
$560.000
$250,000
$830,000
$16,000,000
$29,000,000
$20,000 t
$9,400
$22,000 t
$220.000 1
$7,800,000 t
$28,000
$47,000
$86,000 It
$21,000 tt
$1,700,000
$140.000
$340,000
$820,000
$480.000 t
$150,000
$510,000
$12,000,000
$25,000,000
t Present »c.-'.h caicjiaiss ov?r
tt Frs=s.-,t «r;h : = i:jii:ed issus
tit •r.ginssnr.c ;:.: :=5i:r. ccsts :'
vr. trsataent pericd.
g reciacesent of 301 tcpsoii. rsgradir.g, arid revegetaiina every 10 vrs.
r.ct include pre-encineered ir.cir.sration unit.
-------
TABLE A-5
Cost Estieate Suimary
alternative 6
Incineration of Vaoose Soil
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
Item
GENERAL SITE PREPARATION
Decontamination Facility
Move Watson Residence
Extend Site Boundary-
Extend Site Fence
Reroute S. Drainage Ditch
Diversion Berm
Demolition of Site Structures
Buildings for Incinerator
Soil Storage Building
INCINERATION
Caoital
Maintenance
Operation
EXCAVATION t LOADING OF
CONTAMINATED MATERIAL
Drum Excavation/Classification
Soil Excavation
Soil Handling and Loading
Backfill Ash and Compact
DOUBLE LINER SYSTEM
Clay Layer
Drainage System
HJPE Liner
Geotextile
MULTI-LAYES CAP
Clay Layer
KDPE Liner
Drainage Layer
Vegetative Soil Layer
Revegetation
6ROUNDWATES
Slurry Wall
Wells in Water Table Aquifer
Oil Skimmers
Wells in Upper Intermediate Unit
5 Year Pump Replacement
UflTES TREATMENT
Total System 50 BPH
MONITORING •
Onsite Laooratory
Runoff Monitoring
SrouniMter Monitoring
OBSTRUCT ICN SLSTOTflL
Health and Safety (10%)
Bid Contigency (15%)
Scope Contingency (20%)
CONSTRUCTION TOTAL
Permitting I Legal (5J)
Services Cur ir.g'Ccrwt ruction (8%)
TOTAL IKPLDtXTATIGN COST
Engineering 1 Design (10%)
TOTAL KPI73. CCSTS
Pfi£E£?fT iCRTH
* ?""er' 3crt:i C3ic'J'i:?d ~'er 3
Capital
Cost
$14,000
$21,000
$20,000
$20,000
$75,000
$30,000
$54,000
$120,000
$44,000
$2,600,000
$580,000
$580,000
$920,000
$760,000
$670,000
$260,000
$520,000
$180,000
$670,000
$310,000
$220,000
$530,000
$20,000
$690,000
$1,200,000
$90,000
$82,000
$250,000
$400,000
$32,000
$12,000,000
$1,200,000
$1,800,000
$2,400,000
$17,000,000
$850,000
$1,400,000
$19,000,000
$1,500,000
$21,000,000
Annual
0 SM
$4,500
$1,000
$5,000
$100,000
$3,500,000
$5,000
$5,000
$1,000
$180,000
$15,000
$87,000
$110,000
$16,000
$54,000
Present Worth 30 Years
QM/Replacesesent
& 5X 10%
$35,000
$20,000
$39,000
$800,000
$27,000,000
$98,000
$98,000
$250,000
$55,000
$3,500,000
$290,000
$810,000
$1,700,000
$860,000
$310,000
$1,100,000
$37,000,000
Ht
558,000,000
$32,000
$15,000
$36,000
$700,000
$25,000,000
$77,000
$77,000
$180,000
$40,000
$2,800,000
$230,000
$610,000
$1,300,000
$780,000
$250,000
$830,000
$33,000,000
$:*,ooo,oco
yr. tr?it>?r.c ;°ricd.
— .-?oiicc-->=r.: ;r 2C- tcssoil, reorsdir.tv and revecetat:
$26,000
$9,400
$29,000
$580,000
$20,000,000
$47,000
$47,000
$86,000
$21,000
$1,700,000
$140,000
$340,000
$820,000
$630,000
$150,000
$510,000
$25,000,000
$*6,eco,ooo
r.r averv 10
t
t
t
*
«
t*
»
n.
-------
TABLE 4-6
Cost Estimate Sunary
Alternative 7
Incineration of All Uneonsolidated Material
.1.
II.
III.
IV.
V.
VI.
VII.
VIII.
Item
GQCRAL SITE PREPARATION
Decontamination Facility
Move Uatscn Residence
Extend Site Boundary
Extend Site Fence
Reroute S. Drainage Ditch
Diversion Ben •
Demolition of Site Structures
Soil Storage Building
DCnVflTICh i BACKFILLING
OF ALL UNC2NSO.IDATED MATERIAL
Drum Excavation/Classification
Soil Excavation
Debater ing Excavation
Soil Handling and Loading
Backfill Clean Material and Coaoact
Backfill Treated Soil and Comoact
INCIf€SATION
Capital
Maintenance
Operation
DOUBLE LINES SYSTEM
Clay Layer
Drainage System
HOPE Liner
Geotextile .
MU.TI-LAYE3 CAP
Clay Layer
HDPE Liner
Drainage Laverr
Vegetative Soil Layer
Revegetation
6ROUNDUATER
Slurry Hall
Drains in Water Table Aquifer
Uells in Upper Intermediate Unit
MATES TREflTHEXT
Total System 50 EPM
MONITDRIW
ftooile Laboratory
Runoff Honitorinq
Monitoring Uells*
CDGTRLCnON SLBTUTH.
Health and Safety (105)
Bid Conticerry (15*)
Scop* Contingency <20X)
KnSTSUCTION TOTflL
Permitting I Legal (5*>
Services Curing Construction (fit)
TOT«. IKPLDGiTflTICN CCST
Engineering t Dwign (105)
TOTSi. KPITft. CCS75
PRESENT UGflTH
« %S£ S l^m :^'
Capital
Cost
$14,000
$21,000
$20,000
$20,000
$75,000
$30,000
$54,000
$44,000
$580,000
$4,30^000
$3,800,000
$2,600,000
$3,100,000
$4,000,000
$670,000
$260,000
$520,000
$180,000
$670,000
$310,000
$220,000
$580,000
$20,000
$690,000
$240,000
$82,000
$250,000
$400,000
$32,000
$24,000,000
$2,400,000
$3,600,000
$4,800,000
$35,000,000
$1,800,000
$2,600,000
$40,000,000
$3,300,000
$43,000,000
'Annual
0 tM
$4,500
$1,000
$5,000
$1,000
$200,000
$11,680,000
$5,000
$5,000
$1,000
$2,500
$15,000
$87,000
$110,000
$16,000
$54,000
Present Uorth 30 Years
OiM/Replaceneoent
3X 5* 10*
$45,000
$20,000
$50,000
$10,000
$2,000,000
$120,000,000
$98,000
$98,000
$250,000
$55,000
' $49,000
$254,000
$1,700,000
$1.100,000
$310,000
$1,100,000
$127,000,000
m
$170,000,000
$40,000
$15,000
$44,000
$9,000
$1,800,000
$100,000,000
$77,000
$77,000
$180,000
$40,000
$38,000
$231,000
$1,300,000
$1,000,000
$250,000
$830,000
$106,000,000
$149,000,000
r. tr^ataen: oericd.
i~2c!ic?Ter.: :r 202 tcnoil. re^raoing, and revegetat
$31,000
$9,000
$34,000
$7,000
$1,400,000
$80,000,000
$47,000
$47,000
$86,000
$21,000
$24,000
$141,000
$820,000
$750,000
$150,000
$510,000
$84,000,000
$127,000,000
•3 aver/ '.0
t
t
'
*
*
«
«
t
{f
-------
TABLE 4-7
Cost Estiiite Suatary
Alternative B
In Situ Vitrification of Hotspot Soil
I.
II.
III.
IV.
VI.
VII.
Itet
6ENERAL SITE PREPARATION
Decontaai nation Facility
Move Hatson Residenfe
Extend Site Boundary
Extend Site Fence
Reroute S. Drainage Ditch
Diversion Bert
Deaolition of Site Structures
Reioval & Incineration of Druis &
IN SITU VITRIFICATION
Capital
Operation and Maintenance
BACKFILL AND CAP ENTIRE SITE
Backfill Subsided Areas with Clean
Clav Layer
HDPE Liner
Drainage Layer
Vec.eta.ive Soil Layer
Revegetation
6ROUNOHATER
Slurrv Mail
Hells in Hater Table Aquifer .
Oi! Skianers
Hells in Upper Interesdiate Unit
5 Year Puap Replacement
HATES TREATMENT
Total Systai* 50 EPfl
MONITORINS
Mobile Laboratory
Runoff Monitoring
Capital Annual
Cost 0 t H
$14
$21
9
9
• $20,
• $20
$75
$30
$54
Tanks $1,300
$2,200
Fill $100
?
•
v
9
»
)
<
$670,
$310
$220
$580
$20
$690
$i,200
$90
$82
$250
$400
9
1
9
J
9
1
I
«
1
f
000 $4
000
000
000 $1
000
000 $5
000
000
000
$5,500
000
000
000 $5
000
000
000 $1
000
000 $180
000
000 $15
000 $87
000 $110
$16
Monitoring Hells' $32,000 $54
CONSTRUCTION SUBTOTAL $8,000,000
Health and Safety (101:
Bid Ccntise.icy (15X)
Scape Contingency (201)
CONSTRUCTION TOTAL
Psraittino & Legal (5J)
Services During Construction i£I)
$800
$1,200
$1,600
$12,000
$600
$1,000
1
1
«
4
<
)
000
000
000
000
000
000
,500
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
Present Horth 30 Years
OtH/Replaceaetent
31 51
$9
$20
$10
$10,500
$98
$250
$55
$3,500
,000
,000
,000
,000
,000
.000
,000
,000
$290,000
$810
$1,700
$210
$310
$1,100
$19.000
,000
,000
,000
,000
,000
,000
$8,000
$15,000
$9,000
$10,200,000
$77,000
$180,000
$40,000
$2.800,000
$230,000
$610,000
$1,300,000
$200,000
$250,000
$830,000
$17,000,000
. S
$8
$9
$9
$9,500
$47
$86
$21
101
,000
,000
,000
. -
,000
,000
,000
,000
t
t
t
tt
tt
$1,700,000
$140
$340
$820
$190
$150
$510
$14,000
,000
,000
,000
,000
,000
,000
,000
t
S""TSr = Z~S3SCZCS"ZTZZZr";ZSSr~S=SS'Z2~ST"~Z3T-SSS
TOTAL IMPLEMENTATION COST
Engineering & Design (101!
srsssrz— S2ss=r~z-izrs;r~;rzszrszrr
TOTAL CAPITAL COSTS
PRESENT iiOST.H
$14,000
f
000
$1,400,000
* ==z-£±-=« ~z~=srszs;r^srrr"~ -Z--S— ssssisssTissssssssszsszis^sssssszss
$15.000.000
$34,000
,000
$32.000,000
$29,000
,000
t Present *cr:h calcuiatsd ever 2 yr. treatsent period.
tl Present north calculate: asiusino replacsaar.t of 30i tap-soil, regrading. an
d reveijststing every 10 yrs.
-------
TABLE 4-8
Cost Estisats Suasary
Hiiarr.ative 9
In situ Vitrification sf Vadcss Scs:
Its:
I. =E»1EHAI 5I7E rF.E=AnA7ISN
iscir.tisisatisn Facility
Xcve satsca Residence
Ertc.id Sits Ssuncary
Ertsnd Sits Fenca
Hercute 3. iJraiaasa Hitch
Divsrsisn Sera
• 3c3c::ii:n or Sits Structurss
Fc^r. :.-=:a Sits Friar to ISV
F.sscvsl i Incinsratica BT uruss &
C'"ra*i~s sid ?*»ifi^a"s.";ca
ill. SC-IL C2VE?. AXD HEVEC-E'ATE
Csvsr ni4i! Tscscil
IV. SfiiS-jSSafl'E?.
Siurrv sail
Scii; in itatsr Tab: a Sauifar
Oil Sxissar?
s'siis is :j::sr intsricdiats Unit
5 :sar ?-jso risuiacsaer.i
VI. »A7E= 7SEA7KENT
7::a; Systaa 50 £?M
„.. M,...T u.
Ssiii? Laanraicrv
SunatT fionitcrisa
R:nit:-r:r.g iiells
cc-ss-saCTiss SUET:-AL
Hsaitft and isrstv (10IJ
si: C::!ti""cv (151;
=;:;3 ic.iv.ncsr.cy ;20:!
•:S:-iS7.vJ-:T ---K TCTAL
Ss..jt*j., i : ...: ;5T)
5srv::ss Juris: "C:r.stru:tisn i£IJ
* ' i * *
114.030
521.000
520,000
520.000
575,. »0
530.000
554.000
514.000
7anzs 51,300.000
«-r if.ii .-.,•..3
i".* "*..\
520,000
5690,000
51,200,000
590.000
$62.000
$250,000
5400,000
532.000
17,000,000
5700,000
51.JOv.000
$1.400,000
510,000,000
«ev:'« 000
5SOO.OOO
Annual
•3 * .1
54.500
51.000
55.000
tc -.-.r, fM
51,000
5 ISO. 000
515.000
537.000
5110,000
515.099
554.000
rrsssnt
jit
524,000
52Q.C-C-0
527,000
***C 'i.-.A 1AA «*
$20,000
53.500.000 $
5250.900
5210,000
$1,700,000 5
$£00,000
531 0,099
51,100.000
53i,000,OvO $3;
$9. MO
5230, OvO
SalO.OvO
55£0.vOO
5250,009
J330.0vO
f
5140,000
5340,000
5S20.000
J4SO.OOO I
5150.000
$5iO.Cw
KL lrLSiE
511,000,000
51,100.000
512.000,000
54s.OvO.OvO !45.vvO,000 S3r,000,000
F"-*.-.i .cr:.1! :£;:u:ai== :v»r £ yr. t.-jjt:s.-t rsrisd.
-------
Briefing on the
Record of Decision for
the Summit National Site
Deerfield, Ohio
I. Site History
The Summit National site was a former solvent recycling and disposal
facility .located in Deerfield, Ohio. Solvents, paint sludges, phenols,
cyanide, arsenic, and other liquid wastes were stored, incinerated, and
buried or dumped during 1973 through 1978. In 1983, Sumnit National site
was added to the National Priorities List (NPL). In February 1988, U.S.
EPA concluded in a Remedial Investigation (RI) report that toxic waste had
contaminated all onsite medium and presented an unacceptable risk to human
health and the environment. Offsite areas have also been affected by site
operations. Contamination includes a variety of organic and inorganic
compounds. The RI conclusions and Feasibility Study justify the need for
remedial action at the Summit National site.
II.Site Characterization
The remedial investigation detected contamination onsite in all medium.
Over 65 hazardous substances exceeding background concentrations were
detected in onsite soils, 43 in onsite surface water, 29 in onsite
sediments, and over 25 in the shallow groundwater system beneath the site.
Contamination includes organic and inorganic compounds. The major
contaminants that represent the most significant risks to human health are
as follows:
Major Organic Compounds Major Inorganic Compounds
Bis (2-ethylhexyl)Phthalate Antimony
1,2 Dichloroethane Barium
1,1 Dichloroethene Cadi urn
Trichloroethene Chromium
Hexaclorobenzene Cyanide
PAHs Zinc
PCBs
These contaminants occur in high concentrations and frequency onsite in the
groundwater system, soils, sediments and surface water. The RI also
identified the existence of about 900-1600 buried drums and 4 buried tanks
containing hazardous substances. Offsite areas have also been affected
with similar compounds by site operations to the south and eastern
perimeter. The extent of contamination is depicted in Figure 1. There are
nine residential wells within 1000 feet of the site. These wells have not
been affected by the site.
The Deerfield Township is about 76% undeveloped or agriculture. The
remaining areas have been developed for residential, industrial,
commercial, and recreational purposes. The area immediately surrounding
the site has few rural residences, two landfills, a cement plant, a roller
skating rink, and a used tire storage lot. (See Figure 1).
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SKATING
MINK
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U.S. ROUTE 234
OITCM
STREAM IEO
TO If BUN
RESERVOIR
tat MIL! '
LEGEND
%#&) ABANDONED STRUCTURES
Y/7,\ Buried Drums Location
Contaminated Groundwater
w / / Contaminated "Hot Spot" Soils
200
NOTE- ALL LOCATIONS OF STRUCTURES
AND PHYSICAL FEATURES APPROXIMATE.
SOURCE-' MODIFIED FROM USEPA
FIGURE I
SITE MAP
SUMMIT NATIONAL Rl
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-3-
The potential receptors are residents and workers near the site. The
potential exposure pathways are groundwater consumption, and soil ingestion
and dermal absorption. The highest risk and worst case scenario associated
with each medium are as follows:
Current Conditions
i .
Soils 3 X 10~5 Onsite trespassers
Sediments 6 X 10~6 Children in offsite ditches
Future Conditions
Soils 5 X 10~3 Onsite residents
Groundwater 3 X 10"! Onsite residents using the
watertable as a drinking water source
III.Description of Alternatives
The Feasibility Study presented nine alternatives ranging from no action to
the maximum action practicable. The alternatives and costs are as follows:
Alternative Cost
1. No Action
2. Resident Relocation with Monitoring $ 820,000
3. Capping with Offsite Drum
and Tank Incineration $ 15,000,000
4. RCRA Landfill for Vadose Soil $ 22,000,000
5. Onsite Incineration of "Hot Spot" Soils
(32,000 c.y.) $ 25,000,000
6. Onsite Incineration of Contaminated
Vadose Soils (105,000 c.y.) $ 46,000,000
7. Onsite Incineration of All Unconsolidated
Materials (430,000 c.y.) $127,000,000
8.'In-situ Vitrification of "Hot Spot" Soils
(32,000 c.y.) $ 29,000,000
9. In-situ Vitrification of Contaminated
Vadose Soils (105,000 c.y.) $ 39,000,000
IV.Nine Criteria Analysis
The alternatives were evaluated based on the nine criteria. All
alternatives satisfy the evaluation criteria, with the exception of
Alternatives 1 and 2. The alternatives differ in the extent to which each
criteria is satisfied. The attached matrix summarizes how each alternative
is evaluated. (See Figure 2)
The alternative that best satisfies the evaluation criteria is Alternative
5 - Onsite Incineration of "Hot Spot" Soils.
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V.Cost Effectiveness Analysis
•
The alternatives that provide overall effectiveness, protect!veness,
and implementability at a reasonable cost are as follows:
Alternative Cost
Capping wfth Offsite Drum and Tank Incineration $15,000,000
Onsite Incineration of "Hot Spot" Soils $25,000,000
In-situ Vitrification of "Hot Spot" Soils $29,000,000
Alternative 3 did not include treatment of contaminated soils which
represented a concern with leaching and allowing groundwater conditions to
worsen. In addition, offsite treatment and transportation is least
favorable due to the limited RCRA capacity, and implications and
availability of transportation services. The Ohio EPA would not accept
this alternative and would not waive a State ARAR which would require U.S.
EPA to provide an alternate drinking water supply to residents within a
1000 foot radius.
Alternative 8 proposed In-situ Vitrification, which is an innovative
technology that has not been tried and proven at hazardous waste sites with
multi-contaminants similar to the Summit National Site. Based on its
uncertain reliability, performance, and availability, it was less favorable
than Alternative 5. Therefore, Alternative 5 Onsite Incineration of "Hot
Spot" Soils is the preferred alternative.
VI.Preferred Alternative
The major components of the preferred alternative are as follows:
* Excavation and Onsite Incineration of the following waste;
(Activity to be completed within a 5 year time frame.)
Contaminated "Hot Spot" Soils 32,000 c.y.
Contaminated Offsite Sediments 1,500 c.y.
Contents of Buried Drums 900 - 1600
* Groundwater treatment of the Intermediate aquifer to be
completed within a 5 to 10 year time frame.
* Dewatering of the water table to be completed within a 2 to 10
year time frame.
* Construction of a Double Synthetic Liner to contain the
incinerated waste material.
* Construction of a Multi-layer Cap across the entire site
(16 acres).
* Removal of Onsite Structures.
* Installation of a Slurry Wall around site perimeter to a depth of
40 feet.
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SUMMIT NATIOMA1 5ITI
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-6-
* Elimination of Onsite Surface Water.
* Site Extension (4 acres) and Relocation on One Home Owner
(No Occupants).
* Access and Deed Restrictions
* Groundwater and Surface Water Monitoring Programs
* Total Cost $25,000,000
A detailed site plan and cross section are presented in Figures 3 and 4
respectively.
The preferred alternative provides the best balance among the nine
criteria. The strongest benefit is that the remedy will permanently reduce
contamination to non-hazardous levels leaving behind an acceptable residual
risk of 2 X 10'5 in soils. In addition, the alternative eliminates all
exposure pathways, thus eliminating risk. This alternative can be readily
implemented at a reasonable cost and utilizes permanent solutions and
treatment technologies to the maximum extent practicable.
VII.Enforcement Status
In November, 1987, the U.S. EPA, State of Ohio, DOJ, .OAG, and PRPs started
the legal Remedial Design/Remedial Action Consent Decree negotiations. The
negotiations are currently on-going between all parties. Once the ROD is
finalized, the components of the Consent Decree negotiations will commence
under Section 122 (c) CERCLA.
VIII. Issues
State:
The major issue raised by Ohio EPA is the definition and volume of "hot
spot" soils. After further review and discussion, it was agreed by both
parties to redefine the removal scenario which resulted in an incremental
volume from 27,000 c.y. to 32,000 c.y. at an additional cost of
approximately $1,000,000. This additional soil volume increased the
preferred remedial alternative from $24,000,000 to $25,000,000. Based on
the latest meeting (May 26, 1988), the Ohio EPA, has verbally approved the
preferred remedial alternative. Ohio EPA will provide us with a letter of
concurrence by June 17, 1988.
PRP:
The PRPs have commented on the preferred alternative and have three major
differences of opinion. They propose trenches across the site rather than
extraction wells, a soil cover rather than a multi-layer cap, and a smaller
volume of "hot spot" soils 3000 c.y. versus the 32,000 c.y. Without
further information, it is our technical and legal opinion that the PRP's
proposal is not acceptable. However, it appears that the PRPs are in
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favor of the remaining components. Although, negotiations appear
favorable, to date the PRP group has not made a commitment that can
guarantee their willingness to conduct the remedial design/remedial action.
Region V
The relocation of a resident has been a concern since such action has not
been conducted within the region. The justification for relocating and
purchasing 4 acres of property is based on unacceptable short and long term
risks, and implementability of the remedial alternative. U.S. EPA
headquarters was consulted and does not pose an objection. The agency in
charge of managing negotiations is the Federal Emergency Management Agency
(FEMA). Once the ROD is signed, an Interagency Agreement between U.S. EPA
and FEMA can be developed to initiate the planning, terms, and costs of the
relocation and acquisition. U.S. EPA's legal staff, office of public
affairs, and project manager would assist as necessary during the process.
FEMA will work closely with the State of Ohio since the State must concur
and obtain title of the property.
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