United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-93/201
September 1993
c/EPA Superfund
Record of Decision:
Reynolds Metals, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-93/201
3. Recipient's Accession No.
THIe and Subtitle
SUPERFUND RECORD OF DECISION
Reynolds Metals, NY
First Remedial Action - Final
5. Roped Date
09/27/93
6.
7. Authors)
8. Performing Organization Rapt. No.
9. Performing Organization Nam* and Address
10 Projaet Task/Work Unit No.
11. Contract(C) or Qrant(G) No.
(C)
12. Sponsoring Organization Nanw and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Typa of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-963826
16. Abstract (Limit: 200 words)
The 1,600-acre Reynolds Metals site is an active aluminum production plant located in
Massena, St. Lawrence County, New York. Land use in the area is predominantly
residential and industrial. The site is bordered to the north by the Grasse and St.
Lawrence Rivers, to the east by the New York Central Railroad, to the west by
Haverstock Road, and to the south by the Raquette River. The St. Regis Mohawk Indian
Reservation, with approximately 3,500 residents, is located 0.5 miles from the site.
In 1985, the Reynolds Metals Company (RMC) plant was constructed for the production of
aluminum from alumina. The main components of the plant include the reduction plant .
and supporting structures and facilities (approximately 20.5 acres), the solid waste
landfill (11.5 acres), and the Black Mud Pond (approximately 6 acres). The
contamination detected in the waste, ground water, leachate, and surface water is
characterized by elevated concentrations of cyanides (up to 300 ppm), fluorides (up to
8,500 ppm), sulfates (up to 13,000 ppm), aluminum (up to 87,000 ppm), and polyaromatic
hydrocarbons (PAHs) (up to 2,200 ppm). PCBs also are detected in both areas at
concentrations as high as 690 ppm. Ground water from these areas drains to wetlands
RR-6, south of the landfill area. A leachate collection system on the landfill
intercepts some, but not all, of the contaminated ground water from the landfill to the
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Reynolds Metals, NY
First Remedial Action - Final
Contaminated Medium: sediment
Key Contaminants: organics (PAHs, PCBs), metals (lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None •
21. No. of Pages
74
22. Price
(See ANSI-Z39.18)
SM Instructions en R»vane
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-93/201
Reynolds Metals, NY
First Remedial Action - Final
Abstract (Continued)
wetlands. Remediation of this wetland is being overseen by the State. As a result of
production activities and years of continuous operations and expansion, various types of
industrial and hazardous waste were generated, disposed of, and spread throughout the
facility. RMC also discharged contaminants into the St. Lawrence River through four
outfalls, known as Outfalls 001, 002, 003, and 004; three of which are still in use. In
1987, the State required RMC to investigate the contamination at the facility not
including the river system surrounding the facility. In 1989, RMC completed an initial
study of sediment contamination in the St. Lawrence River adjacent to its plant. This ROD
provides a first and final remedy for the site and addresses the principal threat posed by
contaminated sediment, as OU1. The primary contaminants of concern affecting the sediment
are organics, including PAHs and PCBs; and metals, including lead.
The selected remedial action for this site includes dredging and/or excavating 51,500 yd^
of contaminated sediment with PCBs greater than 1 mg/kg, PAHs greater than 10 mg/kg, and
TDBF greater than 1 mg/kg; treating approximately 14,500 yd3 of the sediment, with PCS
levels greater than 25 mg/kg, using thermal desorption controlling the emissions for the
thermal desorption system using venturi scrubbers; transporting condensed contaminants
recovered during thermal desorption offsite for incineration; treating water removed from
the sediment onsite using flocculation and activated carbon adsorption, with discharge of
all water removed from the sediment or generated during the treatment process onsite to
the St. Lawrence River; pretreating dredged sediment to remove water; disposing of the
untreated sediment and treated residuals onsite in the Black Mud Pond; and capping the
Black Mud Pond area. The estimated present worth cost for this remedial action is
$35,100,000, which includes an estimated annual O&M cost of $250,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific sediment cleanup goals are risk-based and include Aroclor 1016 1 mg/kg;
Aroclor 1221 1 mg/kg; Aroclor 1248 1 mg/kg; Aroclor 1254 I mg/kg; Aroclor 1260 1 mg/kg;
and dibenzofurans 1 ug/kg.
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TABLE OF CONTENTS
I. Site Name, Location, and Description 1
II. Site History and Enforcement Activities 2
III. Highlights of Community Participation 4
IV. Scope and Role of Operable Unit or Response Action Within
Site Strategy 5
V. Summary of Site Characteristics 5
VI. Summary of Site Risks 6
VII. Description of Alternatives 11
VIII. Summary of Comparative Analysis of Alternatives .... 20
IX. Selected Remedy .... 1 27
X. Statutory Determinations 29
XI. Documentation of Significant Changes 30
Attachments
APPENDIX 1 - FIGURES
APPENDIX 2 - TABLES
APPENDIX 3 - STATE LETTER OF CONCURRENCE
APPENDIX 4 - ADMINISTRATIVE RECORD INDEX
APPENDIX 5 - RESPONSIVENESS SUMMARY
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ROD FACT SHEET
SITE
Name : Reynolds Metals Company Study Area Site
Location/State : Massena, New York
EPA Region : II
HRS Score (date): Not Applicable
ROD
Date Signed: 9/27/93
Remedy/ies: Dredging and/or excavation of sediments from
contaminated areas in the St. Lawrence River and
from the associated riverbank; treatment of
dredged material with PCB concentrations above 25
ppm by thermal desorption. Untreated sediments
(with PCB concentrations between 1 ppm and 25 ppm)
and treatment residuals (which are expected to be
non-hazardous and to have PCB concentrations below
10 ppm) will be disposed on-site, in the Black Mud
Pond, and covered. Contaminants condensed in the
thermal desorption process will be transported
off-site and burned at a commercial incinerator.
Operable Unit Number: OU-1
Capital cost: $ 34.8 million (in 1993 dollars)
Construction Completion: 9/98
O & M in 1993: none (in 1993 dollars)
1994: none
1995: $ 28,000
1996: $ 28,000
Present worth: $ 35.1 million (at an assumed 5% discount rate for
an assumed O&M period of 30 years)
LEAD
EPA Enforcement-lead
Primary contact: Lisa P. Carson (212) 264-6857
Secondary contact: Bernice Gorman, Esq. (212) 264-4472
Main PRP(s): Reynolds Metals Company
PRP Contact: (315) 764-6200
WASTE
Type: PCB, total dibenzofurans (TDBFs), PAHs
Medium: sediment
Origin: Contamination of river sediments through plant outfalls
Est. quantity: 51,500 cu.yd. of sediments with PCB concentrations
above 1 ppm, PAH concentrations above 10 ppm, and
TDBF concentrations above 1 ppb
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Declaration for the Decision Document
Site Name and Location
Reynolds Metals Company Site Study Area
Massena, St. Lawrence County, New York
Statement of Basis and Purpose
This decision document presents the selected remedial action
for the Reynolds Metals Company Site Study Area, in Massena, New
York, which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision document explains the factual and legal basis
for selecting the remedy for this Site.
The New York State Department of Environmental Conservation
(NYSDEC) strongly suppports the proposed dredging of contaminated
sediments from the river, agrees with EPA's cleanup levels for the
Site, and agrees with and supports the concept of using the Black
Mud Pond for the disposal of untreated sediments and treatment
residuals. However, while the NYSDEC agrees with the cleanup
numbers for the Site, they do not agree with the process by which
they were obtained. In addition, the NYSDEC would encourage the use
of lower treatment levels if it could be demonstrated that doing so
would not add unreasonable costs to the project. Their letter is
attached as Appendix 3.
The information supporting this remedial action decision is
contained in the administrative record for this Site, the index of
which is also attached to this document as Appendix 4.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Decision Document, may present an imminent and substantial
threat to public health, welfare, or the environment.
Description of the Selected Remedy
This action or "operable unit" is the first and only operable
unit planned by the D. S. Environmental Protection Agency for the
Reynolds Metals Company Site Study Area and addresses the principal
threat posed by contaminated sediments in this Area by utilizing a
mixed treatment/containment remedy for these contaminated sediments.
The major components of the selected remedy include the
following:
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Dredging and/or excavation of approximately 51,500 cubic
yards of sediments with polychlorinated biphenyl (PCB)
concentrations above 1 part per million (ppm), total
polyaromatic hydrocarbon (PAH) concentrations above 10
ppm, and total dibenzofuran (TDBF) concentrations above 1
part per billion (ppb) from contaminated areas in the St.
Lawrence River and from the associated riverbank;
Treatment of approximately 14,500 cubic yards of
dredged/excavated material with PCB concentrations above
25 ppm by thermal desorption. Untreated sediments (with
PCB concentrations between 1 ppm and 25 ppm) and treatment
residuals (which are expected to be non-hazardous and to
have PCB concentrations below 10 ppm) will be disposed on-
site, in the Black Hud Pond, and covered. The Black Mud
Pond will be capped in conformance with the requirements
of the January 22, 1992 New York State Record of Decision
for the state lead Reynolds Metals Site, which encompasses
the entire Reynolds facility. Contaminants condensed in
the thermal desorption process will be transported off-
site and burned at a commercial incinerator.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and it satisfies the
statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances
remaining on site above health-based levels, a review will be
conducted within five years, and every five years thereafter, after
commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
William J^iuszynski";>*7E. Date
Acting Re
U. S. Environmental Protection Agency
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DECISION SUMMARY
REYNOLDS METALS COMPANY SITE STUDY AREA
MASSENA, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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Decision Summary for the Decision Document
Site Name. Location, and Description
The Reynolds Metals Company (BMC) facility is an active aluminum
production plant located on 1600 acres in the town of Massena in St.
Lawrence County, New York. The RMC facility is bordered on the
north by the Grasse and St. Lawrence Rivers, on the east by the New
York Central Railroad, on the west by Haverstock Road (South Grasse
River Road), and on the south by the Raguette River. The plant is
located off Route 37 near the Massena-Cornwall International Bridge,
directly upriver of the General Motors - Powertrain Division Plant
(see Figure 1).
The Reynolds Metals Company Study Area Site ("the Site") includes
that portion of the St. Lawrence, Grasse, and Raguette Rivers, any
tributaries of those rivers and any wetlands which are between the
International Bridge and the confluence of the Grasse and St.
Lawrence Rivers and that portion of the Raguette River which is
south of the confluence of the Grasse and St. Lawrence Rivers and
south of the International Bridge. The Reynolds Study Area Site is
depicted in Figure 1. In general, the Reynolds Study Area Site
encompasses those surface waters, sediments, and wetlands which are
adjacent to the Reynolds Metals Company facility in Massena, New
York. The Reynolds Study Area is part of the St. Lawrence/Grasse
River Site (site code 6-45-15) which was added to the New York State
Registry of Inactive Hazardous Waste Sites on April 14, 1987. This
Site was listed as a result of environmental impacts which occurred
to the river system at and in the vicinity of the Aluminum Company
of America (ALCOA), Reynolds Metals, and General Motors facilities.
Land use in the area surrounding the Site consists of mixed
residential and industrial uses. The St. Regis Mohawk Indian
Reservation, Akwesasne, is located within 0.5 miles of the RMC
facility. Approximately 3,500 individuals live on the St. Regis
Indian Reservation. The downtown area of Massena is located
approximately eight miles west and upriver of the RMC facility. The
1980 population estimate for Massena was 14,856. In addition, the
St. Lawrence River forms the border between the U.S. and Canada in
this area.
Due to past contamination of the General Motors facility and in the
surrounding river system, the General Motors-Powertrain Division
plant has been designated as a federal Superfund Site. EPA is
overseeing cleanup of the General Motors facility and surrounding
river system. EPA is also overseeing the cleanup of the river
system surrounding the ALCOA facility, which is approximately eight
miles upriver from the RMC site.
Major areas of contamination on the RMC facility include an unlined
pit used for the disposal of carbon solids known as the Black Mud
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Pond, a landfill, and the plant's North Yard. The New York State
Department of Environmental Conservation (NYSDEC) is overseeing the
cleanup of contamination on the RMC and ALCOA facilities.
The St. Lawrence River flows are partially controlled by the Moses-
Saunders Power Dam, located approximately four miles upstream of the
Site on the St. Lawrence River. In the vicinity of the Site, the
St. Lawrence River is greater than 0.5 miles in width with depths
exceeding 30 feet in some portions of the River. The section of the
St. Lawrence River adjacent to the RMC facility is part of the St.
Lawrence Seaway. In general, the Reynolds Study Area is comprised
of a shallow shelf containing slow currents, fine-grained sediments,
and dense beds of submergent aquatic vegetation. The shallow shelf
was created in the late 1950s by dredge spoil from the south
Cornwall Navigation Channel that is located 300 to 800 feet offshore
from the RMC facility. No dredge spoil has been deposited in this
section of the river since the initial dredging.
Local water bodies are used recreationally for swimming, wading,
fishing, boating, camping, and picnicking. Two general groups, the
Mohawk native population and recreational fisherman, fish in the
vicinity of the Reynolds Study Area. However, direct land access to
the Reynolds Study Area is limited by the steep nature of the
shoreline.
A tract of regulated water wetlands (identified as No. RR-6 by
NYSDEC) occur on the Reynolds' property. The wetland is
approximately 170 acres in size and is a Class 2 wetland. It is one
of the three largest wetlands in the town of Massena. NYSDEC is
also overseeing the cleanup of contamination in these wetlands.
II. Site History and Enforcement Activities
The RMC plant was constructed in 1958 for the production of aluminum
from alumina (aluminum oxide). The main components of the plant
include the reduction plant and supporting structures and facilities
encompassing about 20.5 acres, the solid waste landfill (11.5
acres), and the Black Mud Pond (approximately 6 acres).
Aluminum is produced in individual pots lined with "potliner," which
is composed of a mixture of carbon compounds and which acts as the
cathode of the electrolytic cell. Potliner is fabricated in the
carbon plant section of the plant where coal tar pitch, coke and
other materials are blended and shaped to fit the pots. A heat
transfer medium (HTM) system is used to maintain the pitch in a
flowable and pumpable form. The HTM system no longer uses a
polychlorinated biphenyl (PCB) oil.
As a result of production activities and years of continuous
operations and expansion, various types of industrial waste,
including hazardous waste, were generated, disposed of, and spread
throughout the facility. Contaminated areas on the facility
property are being investigated and remediated by RMC under the
authority of Consent Orders with NYSDEC. Several areas on the
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facility serve as potential sources of contamination to the Reynolds
Study Area. These areas are described briefly below and are
depicted in Figure 2.
^Wastes from the plant's pot liner recovery system were disposed of in
the Black Mud Pond. The Black Mud Pond contains waste primarily
composed of alumina (30-40%) and carbon (35-45%) with fluoride at 2-
5%, cyanide at 61 parts per million (ppm),' and PCBs at 3.4-8.1 ppm.
These contaminants have been detected in groundwater near the pond.
However, groundwater contamination appears to confined to a limited
area downgradient of the pond. Shallow contaminated groundwater may
be discharging to surface water pathways to the south and east of
the pond.
The plant's Solid Waste Landfill and former Potliner Storage Area
can be characterized as one contaminant source area, based on their
proximity and similarity of contaminants and receptor zone of
contaminants migrating from the area. The contamination detected in
the waste, groundwater, leachate and surface water is characterized
by elevated concentrations of cyanides (up to 300 ppm), fluorides
(up to 8500 ppm), sulfates (up to 13,000 ppm), aluminum (up to
87,000 ppm) and polyaromatic hydrocarbons (PAHs) (up to 2,200 ppm).
PCBs are also detected in both areas at concentrations as high as
690 ppm. Groundwater from these areas drains to wetlands RR-6,
south of the Landfill area. A leachate collection system on the
Landfill intercepts some, but not all, of the contaminated
groundwater from the Landfill to the wetlands. Remediation of this
wetland is being overseen by NYSDEC.
PCBs, polychlorinated dibenzofurans (PCDFs), and polychlorinated
dibenzo-p-dioxins (PCDDs) are distributed in North Yard surficial
soils. PCBs have been found in this area at concentrations as high
as 89,000 ppm. PCODs and PCDFs have been detected at levels of 9.92
parts per billion (ppb) and 9.35 ppb, respectively. PCBs, PCDFs,
and PCDDs originate from the plant HTM system. North Yard
groundwater contamination is characterized by local areas of
elevated concentrations of aluminum, arsenic, cyanide, PCBs, and
fluoride.
In addition to contamination throughout the facility, RMC also
discharged contaminants to the St. Lawrence River through four
outfalls - known as Outfalls 001, 002, 003, and 004. Three of these
outfalls - Outfalls 001 and a combined Outfall 002 and 003 - are
still in use. These outfalls are depicted in Figure 3 and served as
the primary sources of contamination to the Site.
Discharges from Outfall 001 include water from the facility's waste
water treatment system. Outfall 002 discharges contact cooling
water and stormwater runoff from the facility. It carries the
highest volume of water (averaging 2.5 million gallons per day) of
all four of the outfalls. Prior to November 1989, the discharge
from Outfall 002 traveled down an open ditch on the RMC property to
enter the St. Lawrence River. After November 1989, this discharge
was combined with that of Outfall 003. Outfall 003 carries treated
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discharge from the facility sanitary treatment plant. Outfall 003
discharges to the St. Lawrence River through a submerged pipe
located approximately 100 feet from the shore. Prior to June 1988,
Outfall 004 carried intermittent runoff from northern areas of the
plant. The runoff formerly discharged at Outfall 004 is now treated
and used in plant operations.
The RMC facility and upland areas are listed on the NYSDEC Registry
of Inactive Hazardous Waste Sites. In September 1987, RMC and
NYSDEC signed a Consent Order, pursuant to which RMC agreed to
investigate contamination at the RMC facility. However, this Order
did not include an investigation of contamination in the river
system surrounding the facility. In January 1992, NYSDEC issued a
Record of Decision (ROD) which outlined its selected remedy for the
RMC facility, excluding the river system. NYSDEC's selected remedy
included a combination of excavation and treatment of areas highly
contaminated with PCBs and other contaminants and consolidation and
containment of other contaminated areas on the facility. In March,
1993, RMC and NYSDEC signed a Consent Order which required RMC to
implement the remedy in the January 1992 ROD.
In January 1989, RMC completed an initial study of sediment
contamination in the St. Lawrence River adjacent to its plant. In
September 1989, EPA issued a Unilateral Administrative Order (EPA
Index No. II CERCLA-90230), requiring that RMC investigate and clean
up contamination in the river system surrounding the RMC facility.
The river system has been termed the "Reynolds Study Area." In
August 1991, RMC submitted a revised Additional River Sampling (ARS)
Report which further characterized the nature and extent of
contamination in the Reynolds Study Area. In March 1992, RMC
submitted a draft Analysis of Alternatives (AA) Report which
evaluated options for remediating contaminated sediments at the
Site. In January 1993, RMC submitted a revised draft AA Report for
the Reynolds Study Area.
III. Highlights of Community Participation
The ARS and AA Reports and the Proposed Plan for the Reynolds Study
Area Site were released to the public for comment on February 19,
1993. These documents were made available to the public in both the
administrative record and in information repositories maintained at
the EPA Docket Room in Region II, at the St. Regis Mohawk Tribal
Offices, and at the Massena Public Library. The notice of
availability for these two documents was published in the Massena
Courier-Observer on February 19, 1993, in the People's Voice on
February 22, 1993, and in the Indian Times on February 19, 1993. A
public comment period on the documents was held from February 19,
1993 through April 21, 1993. The public comment period was extended
once upon the request of officials from Environment Canada.
EPA held a public meeting regarding the Reynolds Study Area Site on
March 9, 1993 at the Massena Town Hall. At this meeting,
representatives from EPA answered questions about problems at the
Site and the remedial alternatives under consideration. A response
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to the comments received during this period is included in the
Responsiveness Summary, which is part of this Decision Document.
The Responsiveness Summary and Decision Document, along with the
administrative record for the Reynolds Study Area Site, are
available at the information repositories referenced above.
IV. Scope and Role of Operable Unit or Response Action Within Site
Strategy
This Decision Document addresses the first and only planned remedial
action for the Reynolds Study Area Site. This action is intended to
address the principal threats to human health and the environment
posed by the contaminated sediments in the Reynolds Study Area.
Remediation of the contaminated upland areas on the RMC facility is
being overseen by NYSDEC.
V. Summary of Site Characteristics
Hydrodynamic Conditions
Prior to completion of the ARS, RMC conducted a study of flow
conditions in the St. Lawrence River adjacent to its facility. The
flow study, conducted in November 1989, supplemented previous flow
studies done by RMC and its consultants. The flow study yielded the
following general conclusions about the Reynolds Study Area Site
which are depicted graphically in Figure 3. The main river current
which enters the area adjacent to the RMC facility from Polly's Gut
has velocities of 8 feet per second or greater. This flow is
deflected to the east by training dikes which protect the Seaway
channel. There are a series of clockwise and counterclockwise
eddies as the main current exits the training dikes. These eddies
are characterized by low velocity flow and migrate toward the shore
in both upstream and downstream directions. There is an area in the
vicinity of Outfalls 001 and 004 which exhibits some flow separation
with predominantly upstream flow to the west of the outfalls and
predominantly downstream flow to the east of the outfalls.
The overall result of these flow patterns is that water generally
stagnates along the shoreline in the vicinity of Outfall 001.
Because of this stagnation, sediments and particulate materials
discharged into the River through the four outfalls generally remain
close to shore. This pattern would be enhanced in summer months by
extensive vegetation growth that would act to further slow currents
in the shallow water near the shore.
Contaminant Characteristics
As part of the ARS, sediment samples were collected from 47
locations in the St. Lawrence River and 17 locations in the Raguette
River adjacent to the RMC facility. A total of 127 sediment samples
were collected, 20 in the Raguette River and 107 in the St. Lawrence
River. The results of the ARS sampling were generally consistent
with the results from 67 sediment samples taken in 1988 by RMC
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although the levels of contamination detected during the ARS were
higher than those found in the 1988 study.
Based on sampling and analyses conducted during the ARS, there are
several contaminants in Reynolds Study Area sediments including
PCBs, PAHs, total dibenzofurans (TOBFs), fluoride, and cyanide.
PCBs are the primary contaminant found in sediment samples in the
Reynolds Study Area. Contaminants other than PCBs are generally
found in a pattern similar to that of PCBs and will be remediated
along with PCBs.
PCBs were found in 72 of the sediment samples taken from the St.
Lawrence River. However no PCBs were found in background samples or
in sediment samples from the Raquette River. Figures 4-6 show an
approximation of the general distribution of PCBs at various depths
in the Reynolds Study Area. Figures 7-10 show the distribution of
PAHs, cyanides, fluorides, and TDBFs in the Reynolds Study Area.
EPA estimates that there are approximately 51,500 cubic yards of
sediment with PCB concentrations above 1 ppm, PAH concentrations
above 10 ppm, and TDBF concentrations above 1 ppb.
The highest concentration of PCBs detected in sediments in the
Reynolds Study Area was 1300 parts per million (ppm). All samples
with PCB concentrations above 100 ppm are located within 500 feet of
the RMC outfalls. Concentrations decrease away from the shoreline.
PCBs were detected in some samples at a depth of 24 inches into the
sediments and may extend below that depth at some locations.
Sediment depths range from one foot to over 5 feet. PCBs were not
detected in water samples taken by RMC from the St. Lawrence River.
However, NYSDEC, using a more sensitive analytical technique than
the one used by RMC, detected PCBs in surface water at levels up to
54 parts per trillion (ppt).
PCBs and other contaminants which are present in Reynolds Study Area
sediments may migrate downstream or dissolve slowly into the River.
In addition, PCBs in contaminated sediments can serve as a source of
contamination for aquatic organisms and begin to bioaccumulate
within the food chain. Therefore, one potential pathway of human
exposure is human consumption of PCBs in the fatty tissue of fish
and wildlife, as explained below.
VI. Summary of Site Risks
Human Health Risks
Contaminant Identification and Exposure Assessment
EPA conducted a baseline risk assessment to evaluate the potential
risks to human health and the environment associated with the Site
in its current state. The baseline risk assessment focused on the
chemicals in Reynolds Study Area sediments which are likely to pose
the most significant risks to human health and the environment.
These "contaminants of concern" for the Reynolds Metals Company
Study Area Site are listed in Table 1.
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EPA's Baseline Risk Assessment identified several potential exposure
pathways by which the public may be exposed to contaminant releases.
The potential exposure routes which were identified in the baseline
risk assessment for St. Lawrence River and Raquette River sediments
include:
• dermal contact with contaminated sediments;
• ingestion of contaminated sediments;
• ingestion of fish caught from the St. Lawrence River;
• ingestion of surface water from the St. Lawrence River;
• inhalation of contaminants volatilized from surface water;
and
• dermal contact with surface water during swimming.
Of these potential pathways of exposure, ingestion of surface water,
inhalation of volatilized contaminants, and dermal contact with
surface water were not evaluated quantitatively in the baseline risk
assessment because available data indicated that the risks
associated with these exposure pathways would be relatively minor
compared to the other routes of exposure considered.
The baseline risk assessment evaluated both present and possible
future exposures for recreational users and for subsistence
fishermen. Potentially exposed populations include area residents
and residents of the St. Regis Mohawk Reservation and Canadians who
are downriver of the Site. Risks were calculated for small children
and for adults. Exposure assumptions were based on reasonable
maximum exposure scenarios. Tables 2-4 present the exposure
assumptions used by EPA in its Baseline Risk Assessment.
Toxicity Assessment
Under current EPA guidelines, the likelihood of carcinogenic (cancer
causing) and noncarcinogenic effects due to exposure to Site
chemicals are considered separately. It was assumed that the toxic
effects of the site-related chemicals would be additive. Thus,
carcinogenic and noncarcinogenic risks associated with exposures to
individual contaminants were summed separately to indicate the
potential risks associated with mixtures of potential carcinogens
and noncarcinogens, respectively.
Potential carcinogenic risks were evaluated using the cancer slope
factors developed by EPA for the contaminants of concern. Cancer
slope factors (SFs) have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor (CRAVE) for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. SFs, which are expressed in units of
(mg/kg-day)\ are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, -to provide an upper-bound estimate of the
excess lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate of
the risks calculated from the SF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Cancer
*>
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slope factors are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human
extrapolation and uncertainty factors have been applied. SF values
for Reynolds Study Area contaminants of concern are given in Table
5.
Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes and
safe levels of intake (Reference Doses). Reference doses (RfDs)
have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic
effects. RfDs, which are expressed in units of milligrams/kilogram-
day (mg/kg-day), are estimates of daily exposure levels for humans
which are thought to be safe over a lifetime (including sensitive
individuals). Estimated intakes of chemicals from environmental
media (e.g.. the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from
human epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g.. to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur. RfDs for Reynolds Study
Area contaminants of concern are given in Table 5.
Human Health Risk Characterization
Excess lifetime cancer risks for the Reynolds Study Area were
determined by multiplying the intake levels with the SF (see Table
5) for each contaminant of concern. These risks are probabilities
that are expressed in scientific notation (e.g.. i x 10"*). An
excess lifetime cancer risk of 1 x 1CT6 indicates that as a plausible
upper bound, an individual has an additional one in one million
chance of developing cancer as a result of site-related exposure to
contaminants over a 70-year lifetime under the specific exposure
conditions presented in the Reynolds Study Area. Table 6 presents
a summary of the carcinogenic risks posed by each exposure pathway
developed for the Reynolds Study Area. The greatest carcinogenic
risk values calculated for the Site are associated with the
ingestion of fish caught in the St. Lawrence River. The only
contaminants contributing to this value were PCBs.
For known or suspected carcinogens, EPA considers excess upper bound
individual lifetime cancer risks of between icr4 to 1CT* to be
acceptable. This level indicates that an individual has not greater
than a one in ten thousand to one in a million chance of developing
cancer as a result of site-related exposure to a carcinogen over a
70-year period under specific exposure conditions at the Site. As
illustrated in Table 6,v the risks associated with all exposure
pathways associated with the St. Lawrence River are outside the
range considered acceptable by EPA. The risks associated with
ingestion of fish from the Raguette River were calculated and were
found to be unacceptable. However, these calculations were based on
fish caught near the mouth of the Raguette River, not in the
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immediate vicinity of the Reynolds facility. These risks are
assumed to be attributable to sources other than the Reynolds Study
Area Site due to the low levels of contaminants detected in Raquette
River sediments (< 1 ppm PCBs) and surface water (< 65 ppt PCBs) in
the vicinity of the Reynolds facility.
The potential risks of noncarcinogenic effects of contaminants in a
single medium are expressed as the hazard index (or the ratio of the
intake level for a given medium to the RfD), given in Table 5, for
each contaminant of concern. Table 7 presents a summary of the His
posed by each exposure pathway. Again, the noncarcinogenic effects
associated with ingestion of fish are generally greater than those
associated with other exposure pathways.
A hazard index greater than 1 indicates that potential exists for
noncarcinogenic health effects to occur as a result of site-related
exposures. The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a
single medium or across media. As illustrated in Table 7, the
noncarcinogenic effects associated with all exposure .pathways
associated with the St. Lawrence River are above 1. The
noncarcinogenic effects associated with Raquette River pathways were
below 1 due to the low levels of contaminants detected in Raguette
River sediments and surface water.
It can be seen from Table 7 that the HI for noncarcinogenic effects
from ingestion of fish from the St. Lawrence and Raquette Rivers is
70. Therefore, noncarcinogenic effects may occur from the exposure
routes evaluated in the Risk Assessment. The noncarcinogenic risk
was attributable to PCBs.
Uncertainties
The procedures and inputs used to assess risks in this evaluation,
as in all such assessments, are subject to a wide variety of
uncertainties. In general, the main sources of uncertainty include:
environmental chemistry sampling and analysis;
environmental parameter measurement;
fate and transport modeling;
exposure parameter estimation; and
toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry analysis error can stem
from several sources including the errors inherent in the analytical
methods and characteristics of the matrix being sampled. Uncer-
tainty in the exposure assessment is related to the presence of
potentially sensitive populations (fishermen and residents) in very
close proximity to the Site. Additional uncertainties arise from
estimates of how often an individual would actually come in contact
with the chemicals of concern, the period of time over which such
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exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from
animals to humans and from high to low doses of exposure, as well as
from the difficulties in assessing the toxicity of a mixture of
chemicals. These uncertainties are addressed by making conservative
assumptions concerning risk and exposure parameters throughout the
assessment. As a result, the baseline risk assessment provides
upper bound estimates of the risks to populations near the site.
Potential site-specific sources of uncertainty for the Reynolds
Study Area Site include the inherent variability associated with
environmental sampling of biota, especially fish. For example, fish
contaminant concentrations may vary depending on species, mobility,
fat content, age, and feeding habits. The significant total number
of samples in the Reynolds Study Area serves to reduce this source
of uncertainty.
Environmental Risks
An ecological risk assessment was performed to determine the actual
and/or potential effects of contaminants of concern on fish and
other primarily aquatic wildlife in the Reynolds Study Area. A
four-step process was utilized for assessing site-related ecological
risks for a reasonable maximum exposure scenario: Problem
Formulation and Hazard Identification - development of information
characterizing habitats and potentially exposed species found in the
Reynolds Study Area and identification of contaminants of concern
and exposure pathways and receptors; Exposure Assessment - involves
the estimation of actual and potential exposure point concentrations
for selected indicator species; Ecological Effects Assessment -
literature reviews, field studies, and toxicity tests linking
contaminant concentrations to effects on indicator species; and Risk
Characterization - measurement or estimation of both current and
future adverse effects from exposure to contaminants in the Reynolds
Study Area.
i
EPA identified several contaminants which were of concern from an
ecological risk perspective and their respective animal receptors
including PCBs, PAHs, aluminum, fluoride, and cyanide in aquatic
macroinvertebrates, yellow perch, white sucker, least bittern,
belted kingfisher, little brown bat, and mink. PCBs have been shown
to have adverse effects on these receptors including reproductive
impairment in certain birds and reproductive failure in mink.
Aquatic macroinvertebrates may take up contaminants from water which
has contacted contaminated sediments. Aquatic macroinvertebrates
are then consumed by fish', birds, and small mammals. Because PCBs
remain in the fat cells of these animals, the concentrations of PCBs
in these small animals increase over time. These small animals with
increasingly higher PCB concentrations may then be eaten by larger-
animals .
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The results of the ecological risk assessment indicate that the
contaminated sediment and water in the St. Lawrence River in the
Reynolds Study Area pose unacceptable risks to several species.
These risks include reproductive effects to animals which
bioaccumulate PCBs in their tissues. In addition, the
concentrations of several contaminants, including aluminum and PAHs,
are several times higher than federal and State ambient water
quality criteria and federal sediment quality criteria and National
Oceanic and Atmospheric Administration sediment guidelines which are
based on protection of wildlife.
Risk Summary
Actual or threatened releases of hazardous substances from the Site,
if not addressed by the preferred alternative or one of the other
active measures considered, may present an imminent and substantial
threat to public health, welfare or the environment.
VII. Description of Alternatives
Sediment Cleanup Levels
Based on the results of its risk assessment, EPA established cleanup
levels for contaminated sediment in the Reynolds Study Area which
are protective of human health and the environment. The cleanup
levels are: PCBs - 1 ppm; PAHs - 10 ppm; TDBF - 1 ppb. Cleanup
levels are the concentration of contaminants in sediment above which
some remedial action will be taken (i.e.. treatment or containment).
These cleanup levels were based on ingestion of fish by local
residents and represent sediment contaminant concentrations which
would be associated with carcinogenic risks on the order of 10"*.
Cleanup to these levels will also remove the threat from other
contaminants such as fluoride and cyanide. The 1 ppm PCB cleanup
level is identical to that selected by EPA for contaminated sediment
associated with the General Motors Site which is immediately
downstream of the RMC facility. For the G.M. Site, EPA estimated
that a 1 ppm PCB cleanup level in sediments is associated with a 10"*
(1 in 10,000) excess cancer risk to humans. For the RMC Study Area
Site, EPA estimates that a 1 ppm PCB cleanup level in sediments is
associated with an excess cancer risk to humans on the order of 10"4
(1 in 10,000). There is a variation in estimated residual cancer
risks between the G.M. and RMC Study Area Sites due to uncertainties
associated with estimating the effect of varying sediment PCB
concentrations on area fish.
A rough approximation of the area which must be addressed to meet
Site cleanup levels is given in Figure 11. There are approximately
51,500 cubic yards of sediment over a 27- acre area with PCB
concentrations above 1 ppm, PAHs above 10 ppm, and TDBFs above 1
ppb. EPA considers such sediments to pose a principal threat to
human health and the environment.
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It should be noted that federal and New York State sediment quality
criteria guidance indicate that PCB cleanup levels well below l ppm
are required to achieve protection of the environment since PCBs
pose a significant ecological risk. While EPA would prefer a lower
cleanup level which would be associated with a 10 •" cancer risk, EPA
has significant concerns as to the technical practicability of
achieving a PCB cleanup level below l ppm in this area of the St.
Lawrence River. In selecting the 1 ppm cleanup goal, EPA has
balanced its desire for a very low cleanup level which will minimize
residual risk with the constraints posed by the limitations of
dredging as a means of removing sediment with the further intent of
selecting treatment as a principal element over containment. EPA
believes that a 1 ppm cleanup goal in the St. Lawrence River
provides an acceptable measure of protection of human health.
Description of Alternatives
The AA Report evaluated in detail several alternatives for
addressing the contamination in the St. Lawrence River in the
Reynolds Study Area. These alternatives are described below.
Construction times given include the time necessary to construct and
implement the remedy but do not include the time required for design
or contract award.
The remedial alternatives developed for the Site are consistent with
EPA's 1990 "Guidance for Remedial Actions for Superfund Sites with
PCB Contamination" (also referred to as the "PCB Guidance"). For
instance, according to this guidance, soils with PCB concentrations
in the 10 - 25 ppm range may be disposed on an industrial facility
with minimal long-term management controls. Accordingly, EPA has
evaluated an alternative for the RMC Site which includes disposal of
sediments with PCB concentrations between 10 and 25 ppm in the Black
Mud Pond, rather than in an engineered landfill (see Alternative G
below). The PCB Guidance also recommends that soils with higher
concentrations of PCBs be disposed on an industrial facility in an
engineered containment system which may include a cover and liner
system. Accordingly, EPA has evaluated alternatives which include
disposal of untreated sediments (see Alternative D below) or treated
sediments with PCB concentrations between 50 and 500 ppm in an
engineered landfill (see Alternative I below). In addition, several
of the other alternatives evaluated below (including Alternatives E,
F, and J) include options for disposal in the Black Mud Pond or in
an engineered landfill depending on whether the material is a
hazardous waste. The alternatives are described in detail below.
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Alternative A: No Action
Capital Cost: $ 0
O&M Cost: $ 0/year
Present Worth Cost: $ 0
Construction Tine: None
The Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA) requires that the "no action" alternative be
considered as a baseline for comparison with other alternatives.
This action consists of allowing the 51,500 cubic yards of
contaminated sediments with concentrations above the cleanup levels
to remain in their present state. No actions would be taken to
remove or contain contaminated sediments which currently pose a
threat to human health and the environment.
Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the
review, remedial actions may be implemented to remove or treat the
wastes.
Alternative B; In-Situ Capping of Sediments
Capital Cost: $ 13.3 million
O&M Cost: $ 190,000/year
Present Worth Cost: $ 16.6 million
Construction Time: 3 years
This alternative involves leaving the 51,500 cubic yards of
contaminated sediments in place and placing a multilayer cap
consisting of fine-grained clean sand and a woven geotextile fabric
over the sediments. The portion of the Site adjacent to the
shoreline would then be armored to minimize erosion (see Figure 12).
This alternative is designed to isolate and limit the transport of
river sediments and is based on methods commonly used to reduce
shoreline erosion.
Prior to construction, the Reynolds Study Area bathymetry would be
refined and remapped. In addition, areas of dense vegetation and
any areas containing boulders or debris would be identified and
mapped. The geotextile fabric would be pieced together from
sections delivered to the shoreline and each geofabric piece
transported on a barge out to each area defined for sediment
capping. Once lowered from the barge, the geotextile would be
anchored with sand bags. The placement of the geotextile would be
carefully controlled to minimize mudwaves and turbidity. Clean sand
would then be spread in an approximate 1.5 foot layer over the
geotextile using a diffuser.
Armoring material would then be placed in the shallow area adjacent
to the shoreline which is exposed to wave action and boat wakes.
The armoring system would be concrete revetment which consists of a
water permeable fabric casing, which has been woven from high-
>
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strength synthetic fibers and which would be laid by laborers and
then filled with concrete. The total area of the cap would extend
10 to 20 percent beyond the contaminated area to maximize isolation
of the contaminated sediment from the aquatic environment.
Inspections and monitoring including depth sounding and water
quality monitoring would be conducted during construction. After
construction, a long-term physical, chemical, and biological
performance monitoring program would be instituted to determine the
cover's effectiveness in containing contaminated sediments. This
alternative also provides for periodic maintenance of the cover and
posting warning signs and restricting access from both on and
offshore.
Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the
review, remedial actions may be implemented to remove or treat the
wastes.
Alternative D; Sediment Removal./Landfill ing
Capital Cost: $ 33.4 million
O&M Cost: $ 28,000/year
Present Worth Cost: $ 33.9 million
Construction Time: 4 years
This alternative involves dredging sediment which is above Reynolds
Study Area cleanup levels (approximately 51,500 cubic yards) from
the St. Lawrence River adjacent to the RMC facility. The dredged
sediment would then be pretreated and placed in an engineered
landfill on the RMC facility.
Prior to dredging, silt curtains would be installed to minimize
transport of contaminated sediment which may be suspended during the
dredging process. Hydraulic dredges would be used to remove
sediments. Oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted and dewatered
and placed, along with the previously screened oversized debris,
into an on-site engineered landfill. Water removed from the
sediments would be treated using methods including flocculation and
chemical precipitation to remove solids, and sand bed filtration and
activated carbon adsorption. All water that is removed from
sediments would be discharged to the St. Lawrence River in
compliance with the substantive requirements of the New York State
Pollutant Discharge Elimination System (SPDES) which regulates
surface water discharges in New York State.
Following completion of sediment placement in the landfill, the on-
site landfill would be closed. Leachate from the landfill would be
collected, treated, and discharged to the St. Lawrence River.
Groundwater downgradient of the landfill would be monitored.
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The major ARARs associated with this alternative include the
applicable federal Toxic Substances Control Act (TSCA) and the
relevant and appropriate federal and State Resource Conservation and
Recovery Act (RCRA) regulations which govern the construction,
closure, and monitoring of the on-site landfill. In addition, all
discharges to the St. Lawrence River would be subject to applicable
substantive SPDES requirements and all operations would be subject
to New York State air quality standards.
Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the five
year review, remedial actions may be implemented to remove or treat
the wastes.
Alternative E: Sediment Removal/Xncineration/On-site Disposal in the
Black Mud Pond or Landfilling
Capital Cost: $ 52.8 million (with Black Mud Pond disposal)
$ 55.3 million (with landfill construction)
O&M Cost: $ 28,000/year
Present Worth Cost: $ 53.3 million (with Black Mud Pond disposal)
$ 55.8 million (with landfill construction)
Construction Time: 4 years
This alternative involves dredging sediments which are above
Reynolds Study Area cleanup levels (approximately 51,500 cubic
yards) from the St. Lawrence River adjacent to the RMC facility.
The dredged sediment would then be pretreated to remove water,
incinerated to destroy organic contaminants, and disposed of on-site
in the Black Mud Pond.
Prior to dredging, silt curtains would be installed to minimize
transport of contaminated sediment which may be resuspended during
the dredging process. Hydraulic dredges would be used to remove
sediments. Oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted, dewatered, and
incinerated on-site. The incinerator ash would have PCB levels at
or below 2 ppm.
The ash would be. tested using the RCRA Toxicity Characteristic
Leaching Procedure (TCLP) test to determine if it is a RCRA
hazardous waste. EPA has tested the sediments and does not expect
that the ash from the incinerator would be a RCRA hazardous waste.
If the ash was not a RCRA hazardous waste, it would be disposed of
on-site in the Black Mud Pond along with the previously screened
debris. If the ash was found to be a RCRA hazardous waste, it would
either be treated to rvender it non-hazardous or it would be
disposed, along with the previously screened oversized debris, in an
engineered on-site landfill. Therefore, the costs of this
alternative may vary, depending on whether construction of an
engineered landfill is necessary.
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Water removed from the sediments would be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process would be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
The major ARARs associated with this alternative include the
applicable federal TSCA and the relevant and appropriate federal and
State RCRA regulations which govern the operation and monitoring of
the on-site incinerator and the construction, closure, and
monitoring of the on-site landfill. In addition, air emissions from
the incinerator would be monitored to ensure compliance with federal
Clean Air Act regulations and New York State air quality standards
and air emissions regulations. Discharges to the St. Lawrence River
would be subject to applicable substantive SPDES requirements.
Alternative F: Sediment Removal/Thermal Desorption/On-site Disposal
in the Black Mud Pond or Landfilling
Capital Cost: $ 43.7 million (with Black Mud Pond disposal)
$ 46.2 million (with landfill construction)
O&M Cost: $ 28,000/year
Present Worth Cost: $ 44.2 million (with Black Mud Pond disposal)
$ 46.7 million (with landfill construction)
Construction Time: 4 years
This alternative involves dredging sediments which are above
Reynolds Study Area cleanup levels (approximately 51,500 cubic
yards) from the St. Lawrence River adjacent to the RMC facility.
The dredged sediment would then be pretreated to remove water,
treated by thermal desorption to remove organic contaminants, and
disposed of on-site.
Prior to dredging, silt curtains would be installed to minimize
transport of contaminated sediment which may be suspended during the
dredging process. Hydraulic dredges would be used to remove
sediments. Oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted, dewatered, and
treated on-site. The sediment treatment process would consist of
thermal desorption, an innovative technology which thermally
extracts organic contaminants and subsequently condenses and
recovers the distilled contaminants. The recovered contaminants
would then be sent to an off-site location for incineration at a
permitted commercial incinerator.
Based on the results of treatability testing, treated sediments
would have PCB concentrations below 10 ppm. The treated sediments
would be tested using the RCRA TCLP test to determine if they are a
RCRA hazardous waste. EPA has tested the sediments and does not
expect that the treated sediments would be a RCRA hazardous waste.
If the treated sediments were not a RCRA hazardous waste, they would
be disposed of on-site in the Black Mud Pond along with the
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previously screened debris. If the treated sediments were found to
be a RCRA hazardous waste, they would either be treated to render
them non-hazardous or they would be disposed, along with the
previously screened oversized debris, in an engineered on-site
landfill. Therefore, the costs of this alternative may vary,
depending on whether construction of an engineered landfill is
necessary.
Water removed from the sediments would be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process would be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
The major ARARs associated with this alternative include the
applicable federal TSCA and the relevant and appropriate federal and
State RCRA regulations which govern the construction, closure, and
monitoring of the on-site landfill. In addition, air emissions from
the thermal desorption process would be monitored to ensure
compliance with federal Clean Air Act regulations and New York State
air quality standards and air emissions regulations. Discharges to
the St. Lawrence River would be subject to applicable substantive
SPDES requirements.
Alternative 6: Sediment Removal /Partial Thermal Desorption/Disposal
in the Black Mud Pond
Alternative G(A) - 25 ppm treatment level
Capital Cost: $ 34.8 million
O&M Cost: $ 28,000/year
Present Worth Cost: $ 35.1 million
Construction Time: 4 years
Alternative G(B) - 10 ppm treatment level
Capital Cost: $ 36.4 million
O&M Cost: $ 28,000/year
Present Worth Cost: $ 36.7 million
Construction Time: 4 years
This alternative is very similar to Alternative F above. However,
under this alternative, only those more highly contaminated
sediments would be treated by thermal desorption. As in
Alternatives D - F, this alternative involves dredging sediments
which are above Reynolds Study Area cleanup levels (approximately
51,500 cubic yards) from the St. Lawrence River adjacent to the RMC
facility. The dredged sediment would then be pretreated to remove
water. Sediment with PCB concentrations above the treatment level
would be treated by thermal desorption to remove organic
contaminants. Treated sediment and untreated sediment would then be
disposed of on-site in the Black Hud Pond.
Under this alternative, EPA has evaluated two different treatment
levels. Under Alternative G(A), only those sediments with PCB
l-
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concentrations above 25 ppm (approximately 14,500 cubic yards) would
be treated by thermal desorption. The remaining 37,000 cubic yards
of sediment with PCB concentrations at or below 25 ppm would be
disposed of on-site without prior treatment. Under Alternative
G(B), only those sediments with PCB concentrations above 10 ppm
(approximately 19,700 cubic yards) would be treated by thermal
desorption. The remaining 31,800 cubic yards of sediment would be
disposed of on-site without prior treatment. The 10 ppm and 25 ppm
PCB treatment levels evaluated represent levels which EPA generally
considers acceptable for on-site disposal in an industrial area (see
discussion on page 12). Per the EPA PCB Guidance, material with PCB
concentrations in the 10 - 25 ppm range may generally be disposed of
on an industrial facility with minimal long-term management.
Prior to dredging, silt curtains would be installed to minimize
transport of contaminated sediment which may be suspended during the
dredging process. Hydraulic dredges would be used to remove
sediments. Oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted, dewatered, and,
for those sediments with PCB concentrations above the treatment
level, treated on-site by thermal desorption. Condensed
contaminants recovered during treatment would then be sent to an
off-site location for incineration at a permitted commercial
incinerator.
Based on the results of treatability testing, treated sediments
would have PCB concentrations below 10 ppm. Treated and untreated
sediments would be tested to ensure that they cannot be classified
as a RCRA hazardous waste using the RCRA TCLP test. Treated
sediments, along with untreated dewatered sediments, would be
disposed of on-site in the Black Mud Pond and capped in conformance
with the requirements of the January 22, 1992 New York State Record
of Decision for the state lead Reynolds Metals Site.
Water removed from the sediments would be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process would be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
The major ARARs associated with this alternative include the
applicable federal TSCA and the relevant and appropriate federal and
State RCRA regulations which govern the disposal and monitoring of
the sediments. In addition, air emissions from the thermal
desorption process would be monitored to ensure compliance with
federal Clean Air Act regulations and New York State air quality
standards and air emissions regulations. Discharges to the St.
Lawrence River would be subject to applicable substantive SPDES
regulations.
Because this alternative would result in contaminants remaining on-
site above. health-based levels, CERCLA requires that the Site be
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reviewed at least once every five years. If justified by the five
year review, remedial actions may be implemented to remove or treat
the wastes.
Alternative I: Sediment Removal/Partial Thermal
Desorption/Landfilling
Alternative I(A) - 500 ppm treatment level
Capital Cost: $ 35.3 million
O&H Cost: $ 28,000/year
Present Worth Cost: $ 35.8 million
Construction Time: 4 years
Alternative I(B) - 50 ppm treatment level
Capital Cost: $ 37.4 million
O&H Cost: $ 28,000/year
Present Worth Cost: $ 37.9 million
Construction Time: 4 years
This alternative is very similar to Alternative G above. However,
under this alternative, only the most highly contaminated sediments
would be treated by thermal desorption. As in Alternatives F and G,
this alternative involves dredging sediments which are above
Reynolds Study Area cleanup levels (approximately 51,500 cubic
yards) from the St. Lawrence River adjacent to the RMC facility.
The dredged sediment would then be pretreated to remove water and
sediment with PCS concentrations above the treatment level would be
treated by thermal desorption to remove organic contaminants.
Treated sediment and untreated sediment would then be disposed of
on-site.
Under this alternative, EPA has evaluated two different treatment
levels. Under Alternative I(A), only those sediments with PCB
concentrations above 500 ppm (approximately 2,300 cubic yards) would
be treated by thermal desorption. The remaining 49,200 cubic yards
of sediment with PCB concentrations below 500 ppm would be disposed
of in an on-site landfill without prior treatment. Under
Alternative I (B), only those sediments with PCB concentrations above
50 ppm (approximately 11,300 cubic yards) would be treated by
thermal desorption. The remaining 39,700 cubic yards of sediment
would be disposed of on-site without prior treatment. The 500 ppm
and 50 ppm PCB treatment levels evaluated represent levels which EPA
generally considers acceptable for on-site disposal in an industrial
area (see discussion on page 12). Per the EPA PCB Guidance,
material with PCB concentrations in the 50 - 500 ppm range may
generally be disposed of on an industrial facility in an engineered
containment system.
Prior to dredging, silt 'curtains would be installed to minimize
transport of contaminated sediment which may be suspended during the
dredging process. Hydraulic dredges would be used to remove
sediments. Oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted, dewatered, and,
•
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for those sediments with PCB concentrations above the treatment
level, treated on-site by thermal desorption. Condensed
contaminants recovered during treatment would then be sent to an
off-site location for incineration at a permitted commercial
incinerator.
Based on the results of treatability testing, treated sediments
would have PCB concentrations below 10 ppm. Treated and untreated
sediments would be placed, along with the previously screened
oversized debris and untreated sediments, into an on-site landfill.
Water removed from the sediments would be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process would be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
The major ARARs associated with this alternative include the
applicable federal TSCA and the relevant and appropriate federal and
State RCRA regulations which govern the construction, closure, and
monitoring of the on-site landfill. In addition, air emissions from
the thermal desorption process would be monitored to ensure
compliance with federal Clean Air Act regulations and New York State
air quality standards and air emissions regulations. Discharges to
the St. Lawrence River would be subject to applicable substantive
SPDES regulations.
Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the five
year review, remedial actions may be implemented to remove or treat
the wastes.
Alternative J: Partial Sediment Removal/Thermal Desorption/On-site
Disposal in the Black Mud Pond or Landfilling/In-Situ Capping
Capital Cost: $ 17.1 million (with Black Mud Pond disposal)
$ 19.6 million (with landfill construction)
O&M Cost: $ 28,000/year
Present Worth Cost: $ 17.6 million (with Black Mud Pond disposal)
$ 23.2 million (with landfill construction)
Construction Time: 3 years
This alternative includes dredging approximately 2,300 cubic yards
of contaminated sediment with PCB concentrations above 500 ppm from
the St. Lawrence River adjacent to the RMC facility. The dredged
sediment would then be pretreated to remove water and treated by
thermal desorption to remove organic contaminants. Treated sediment
would then be disposed of on-site. The remaining 49,200 cubic yards
of contaminated sediment would be left in place and covered in the
river with a multilayer cap.
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Prior to dredging, silt curtains would be installed to minimize
transport of contaminated sediment which may be resuspended during
the dredging process. Hydraulic dredges would be used to remove
sediments, oversized materials would be screened from the dredged
sediments as the sediments are offloaded into scows and transported
to the shoreline. Sediments would then be decanted, dewatered, and
treated on-site by thermal desorption. Condensed contaminants
recovered during treatment would then be sent to an off-site
location for incineration at a permitted commercial incinerator.
Water removed from the sediments would be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process would be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
Based on the results of treatability testing, treated sediments
would have PCB concentrations below 10 ppm. The treated sediments
would be tested using the RCRA TCLP test to determine if they are a
RCRA hazardous waste. EPA has tested the sediments and does not
expect that the treated sediments will be a RCRA hazardous waste.
If the treated sediments are not a RCRA hazardous waste, they will
be disposed of on-site in the Black Mud Pond along with the
previously screened debris. If the treated sediments are found to
be a RCRA hazardous waste, they will either be treated to render
them non-hazardous or they will be disposed, along with the
previously screened oversized debris, in an engineered on-site
landfill. Therefore, the costs of this alternative may vary,
depending on whether construction of an engineered landfill is
necessary.
As in Alternative B, the remaining 49,200 cubic yards of sediment
would be left in place and a multilayer cap consisting of fine-
grained clean sand and a woven geotextile fabric would be placed
over the sediments. The capping system design, construction, and
monitoring would be identical to that described in Alternative B.
This alternative also provides for periodic maintenance of the cover
and posting warning signs and restricting access from both on and
offshore.
The major ARARs associated with this alternative include the
applicable federal TSCA and the relevant and appropriate federal and
State RCRA regulations which govern the construction, closure, and
monitoring of the on-site landfill. In addition, air emissions from
the thermal desorption process would be monitored to ensure
compliance with federal Clean Air Act regulations and New York State
air quality standards and air emissions regulations. Discharges to
the St. Lawrence River would be subject to applicable substantive
SPDES regulations.
Because this alternative would result in contaminants remaining on-
site above health-based levels, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the five
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year review, remedial actions may be implemented to remove or treat
the wastes.
VIII. Summary of Comparative Analysis of Alternatives
In accordance with the National Contingency Plan (NCP), a detailed
analysis of each alternative was performed. The purpose of the
detailed analysis was to objectively assess the alternatives with
respect to nine evaluation criteria that encompass statutory
requirements and include other gauges of the overall feasibility and
acceptability of remedial alternatives. The analysis was comprised
of an individual assessment of the alternatives against each
criterion and a comparative analysis designed to determine the
relative performance of the alternatives and identify major trade-
offs, that is, relative advantages and disadvantages, among them.
The nine evaluation criteria against which the alternatives were
evaluated are as follows:
Threshold Criteria - The first two criteria must be satisfied in
order for an alternative to be eligible for selection.
1. overall Protection of Human Health and the Environment
addresses whether a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with Applicable, or Relevant and Appropriate
Requirements (ARARs) is used to determine whether each
alternative will meet all of its federal and state ARARs.
When an ARAR is not met, the detailed analysis should
discuss whether one of the six statutory waivers is
appropriate.
Primary Balancing Criteria - The next five "primary balancing
criteria" are to be used to weigh major trade-offs among the
different hazardous waste management strategies.
3. Long-term Effectiveness and Permanence focuses on any
residual risk remaining at the Site after the completion
of the remedial action. This analysis includes
consideration of the degree of threat posed by the
hazardous substances remaining at the Site and the
adequacy of any controls (for example, engineering and
institutional) used to manage the hazardous substances
remaining at the Site.
4. Reduction of Toxicity, Mobility, or Volume Through
Treatment is the anticipated performance of the treatment
technologies a. particular remedy may employ.
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5. Short-term Effectiveness addresses the effects of the
alternative during the construction and implementation
phase until the remedial response objectives are met.
6. Implementability addresses the technical and
administrative feasibility of implementing an alternative
and the availability of various services and materials
required during its implementation.
7. Cost includes estimated capital, and operation and
maintenance costs, both translated to a present worth
basis. The detailed analysis evaluates and compares the
cost of the respective alternatives, but draws no
conclusions as to the cost effectiveness of the
alternatives. Cost effectiveness is determined in the
remedy selection phase, when cost is considered along with
the other balancing criteria.
Modifying Criteria - The final two criteria are regarded as
"modifying criteria," and are to be taken into account .after the
above criteria have been evaluated. They are generally to be
focused upon after public comment is received.
8. State Acceptance reflects the statutory requirement to
provide for substantial and meaningful State and Tribal
involvement.
9. Community Acceptance refers to the St. Regis Mohawk
Tribe's and the community's comments on the remedial
alternatives under consideration, along with the Proposed
Plan. Comments received during the public comment period,
and the EPA's responses to those comments, are summarized
in the Responsiveness Summary which is attached to this
ROD.
The following is a summary of the comparison of each alternative's
strengths and weaknesses with respect to the nine evaluation
criteria.
Overall Protection of Human Health and the Environment
With the exception of Alternative A, no action, each of the
alternatives, if properly implemented, operated, and maintained,
protects human health and the environment. Although the
alternatives differ in the degree of protection they afford, all
reduce excess carcinogenic health risks to humans to levels within
the acceptable EPA range of 1(T* to 10"*. Each of the alternatives
also differs in how they provide protection, either through
treatment of contaminated"sediments, containment of sediments, or a
combination of both.
Since Alternative A, the no action alternative, is not protective,
it will not be considered in the remainder of this analysis.
i
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Compliance with ARARs
All action alternatives comply with ARARs. As noted in the section
above, the major federal and State ARARs include portions of TSCA
and RCRA and State solid and hazardous waste disposal regulations.
In addition, State SPDES provisions and federal Clean Air Act
regulations are also ARARs for several of the alternatives. There
are no chemical-specific ARARs for sediments.
Any thermal desorber will involve the release of an air stream from
which PCBs have been removed. Such an air stream must represent an
acceptable risk for PCBs and products of incomplete combustion, if
any combustion occurs in the thermal desorption process. Evaluation
of risk and of the TSCA requirements for a 99.9999% mass emissions
factor will be included in determining the operation of the thermal
desorber. In addition, emissions from the desorber must meet
federal and State ARARs.
Lonq-Term Effectiveness and Permanence
In general, the containment and capping alternatives (Alternatives
B and D) provide a lesser degree of permanence in remediating
contamination than treatment alternatives (Alternatives E, F, G, I,
and J) which destroy contamination. Alternative B which allows
contamination to remain in the river system is less permanent than
Alternative D. Alternatives E and F, which include treatment of all
contaminated sediment, best meet this criterion. The mixed
treatment/containment alternatives (Alternatives G, I, and J)
provide a higher degree of permanence than the containment
alternatives (Alternatives B and D) through permanent destruction of
contaminants in highly contaminated sediments.
Of the alternatives which include treatment of contaminated
sediments (Alternatives E, F, G, I, and J), long-term effectiveness
varies depending on the extent to which contaminants are permanently
destroyed. Accordingly, Alternatives E and F which include
treatment and destruction of contaminants in all dredged sediments
are more effective than Alternatives G, I, and J which include
partial treatment of contaminants in dredged sediments. Similarly,
Alternative G which includes treatment of sediments with PCB
concentrations above 25 ppm (Alternative G(A)) or 10 ppm
(Alternative G (B)) is more effective than Alternatives I and J which
include treatment of sediments with PCB concentrations above 500 ppm
(Alternative I (A) and Alternative J) or 50 ppm (Alternative I (B)).
The proper implementation of all alternatives would result in
acceptable residual cancer risks and noncarcinogenic effects, i.e..
cancer risks between 10"4 and 104, and hazard indices below 1.
However, the effectiveness of certain alternatives is dependent on
specific technical constraints. For example, the long-term
effectiveness of Alternative B (in-situ capping) depends on the
success of efforts to accurately place the sediment cap and to
repair or replace the cap if monitoring indicates that it is failing
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to adequately isolate the sediments. Similarly, the effectiveness
of Alternatives D,- E, F, G, and I will depend on whether it is
technically possible to dredge contaminated sediments completely
such that all sediment cleanup levels are met.
Alternatives B and J, which include in-situ capping, would require
the greatest degree of long-term monitoring and operation and
maintenance. This is because, contrary to the other alternatives
where contaminated sediments are removed from the river system, the
contaminated sediments would be left in-place in the river system
under Alternatives B and J. Monitoring and maintenance of contained
underwater sediments is technically more difficult than monitoring
treated or untreated sediments which are placed in an upland
landfill. Because the sediments are submerged, the contained
underwater sediments would require periodic inspections by divers.
In addition, several rounds of sampling might be required to detect
underwater containment cell leakage, since any leaking contamination
would be diluted. Further, if underwater monitoring revealed that
cap repairs were necessary, such repairs could likely only be
undertaken in late spring or in summer.
In addition, the operation and maintenance requirements for
Alternatives B and J pose the greatest uncertainties and technical
difficulties. For example, the risk to human health and the
environment is greatest if Alternatives B and J fail since
contaminated sediments would reenter the river system and be
available to contaminate fish and wildlife. Sediments contained in
a landfill are more secure since a leak in the landfill cap or liner
does not automatically result in sediments reentering the river
system and contaminating fish and wildlife.
Reduction of Toxicity. Mobility, or Volume through Treatment
In general, all of the alternatives which include dredging and
treatment best meet this criterion. Alternatives E and F, which
include treatment of all 51,500 cubic yards of contaminated
sediments with PCB concentrations above 1 ppro, would result in the
greatest reduction of toxicity, mobility, and volume of all the
alternatives. Alternative G which includes treatment of sediments
with PCB concentrations above 25 ppm (Alternative G(A)) or 10 ppm
(Alternative G(B)) is more effective in reducing contaminant
toxicity, mobility, and volume than Alternatives I and J which
includes treatment of sediments with PCB concentrations above 500
ppm (Alternative I (A) and Alternative J) or 50 ppm (Alternative
KB)).
Although capping and containment alternatives (Alternatives B and D)
would reduce the mobility of contaminated material in sediment, no
treatment would be performed. Incineration or thermal desorption of
sediments (as in Alternatives E, F, G, I, and J) would reduce the
mobility, toxicity, and volume of the contaminated material.
Incineration produces an ash which must be disposed. Thermal
desorption would produce a toxic extract which would be shipped off-
site for incineration. Both thermal desorption and incineration
V
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would result in the production of treated sediment residuals or ash
which EPA does not anticipate will be hazardous.
Short-Term Effectiveness
In general, effective alternatives which can be implemented quickly
with little risk to human health and the environment are favored
under this criterion. Of the action alternatives evaluated,
Alternative B (in-situ capping) would have the fewest short-term
effects because sediment suspension would be minimized. Sediment
suspension is a concern because any suspended contaminated sediment
could redeposit in downstream areas. Alternatives which involve
sediment dredging (Alternatives D, E, F, G, I, and J) include the
use of extensive controls such as silt curtains to minimize sediment
suspension and deposition in the River.
Sediment treatment alternatives (Alternatives E, F, G, I, and J)
would reduce the potential for direct contact with contaminated
sediment by permanently removing the source of contamination.
Community and worker exposure would be minimized by the use of
construction methods that minimize air emissions from treatment
processes; also, protective equipment that minimizes workers'
contact with the contaminated materials would be utilized. Air
quality would be monitored during remediation.
Completion of remedial design for any selected remedy would take up
to two years. The time required to implement each alternative is:
3 years for Alternative B; 4 years for Alternatives D, E, F, G, and
I; and 3 years for Alternative J.
Impleroentability
All of the alternatives are implementable from an engineering
standpoint. However, there are some inherent difficulties which
make some alternatives more difficult to implement than others.
While the technology associated with Alternatives B and J (in-situ
capping) has been generally used in lakes and harbors, the technical
feasibility of ensuring the integrity of the cap, given the currents
in the area adjacent to the RMC facility, remains questionable. If
the integrity of the cap cannot be maintained in the future,
additional cleanup activities, such as sediment dredging, would be
required. In addition, because sediments would remain underwater,
it may be technically difficult to monitor the effectiveness of the
cap. If a cap failure went undetected, fish and wildlife would
again be exposed to PCBs and other contaminants.
The greatest potential technical difficulty associated with the
sediment removal alternatives (Alternatives D, E, F, G, I, and J) is
the technical feasibility of dredging sediments sufficiently to
achieve the cleanup goals for the Site. With the exception of the
G.M. Site, to date, no environmental dredging program has had as its
goal the removal of sediments to levels of 1 ppm PCBs. If dredging
cannot achieve the 1 ppm PCB level, additional cleanup activities,
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which could include sediment containment, would be required. For
example, Alternative J includes a combination of dredging to remove
some highly contaminated sediment and containment of the remaining
sediment which is not dredged.
Incineration, a component of Alternative E, is the most proven and
widely available technology for treating many contaminants.
However, test burns would be required prior to implementation of
incineration. Thermal desorption processes, included in
Alternatives F, G, I, and J, while not as widely applied as
incineration, have been used in full-scale sediment remediation.
Landfilling is also a widely used, easily implementable, relatively
easily monitored technology. Coordination with several agencies,
including the St. Lawrence Seaway Development Corporation and the
U.S. Corps of Engineers would be required prior to implementation of
any alternative.
Cost
The costs associated with each alternative are presented in the
descriptions of the alternatives given above. These costs are
estimates and may change as a result of modifications made during
design and/or construction.
The least expensive action alternative is Alternative B with a
present worth cost of $ 16.6 million. Alternative J is the next
least expensive with present worth costs ranging from $ 17.6 million
to $ 23.2 million. Alternatives D, G and I have present worth costs
which range from $ 33.9 million to $ 37.9 million. Alternative F
has present worth costs which range from $ 44.2 million to $ 46.7
million. Alternative E is the most expensive alternative with
present worth costs ranging from $ 53.3 million to $ 55.8 million.
State Acceptance
The NYSDEC strongly suppports the proposed dredging of contaminated
sediments from the river, agrees with EPA's cleanup levels for the
Site, and agrees with and supports the concept of using the Black
Mud Pond for the disposal of untreated sediments and treatment
residuals. However, while the NYSDEC agrees with the cleanup
numbers for the Site, they do not agree with the process by. which
they were obtained. In addition, the NYSDEC would encourage the use
of lower treatment levels if it could be demonstrated that doing so
would not add unreasonable costs to the project.
Community Acceptance
Comments from the community submitted during the public comment
period indicate that the -community has varying opinions regarding
remediation of the Reynolds Study Area. The St. Regis Mohawk Tribe
expressed a desire for a cleanup plan which takes the contaminants
out of the river system and permanently disposes of them. They
prefer a 0.1 ppm PCS cleanup level for contaminated sediments and
called for additional sampling in the Baguette River.
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Comments received from the general public indicated that a majority
supported Alternative G(B) with one modification: that sediments and
treated residuals be disposed in an engineered landfill, rather than
disposed of on-site with a soil cover. Comments from the Canadian
government indicated that they believed a pilot-scale dredging study
was essential prior to full-scale remedy implementation and
requested that EPA consider additional containment measures other
than a soil cover for sediments. However, comments received from
area industries, including Reynolds, General Motors, and ALCOA, and
from the Massena Industrial Development Corporation supported the
increased use of in-place containment of sediments as part of EPA's
selected remedy and questioned whether a 1 ppm PCS cleanup level is
technically achievable. Comments are responded to in detail in the
Responsiveness Summary which is an appendix to this document.
IX. Selected Remedy
Based upon an evaluation of the various alternatives and comments
received from the public, EPA has selected Alternative G(A),
Sediment Removal/Partial Thermal Desorption/Disposal in the Black
Mud Pond for remediation of the Reynolds Study Area site. The major
components of the selected remedy include:
Dredging/Excavation of Contaminated Sediments
Sediments in the St. Lawrence River with PCB levels above 1 ppm, PAH
levels above 10 ppm, and TDBF levels above l ppb will be dredged
and/or excavated. The approximate area to be dredged is shown in
Figure 11. EPA estimates that approximately 51,500 cubic yards of
sediment will be removed from the Reynolds Study Area though the
actual volume of sediment which exceeds the above criteria may prove
to exceed or be less than that amount. All contaminated sediments
in the area to be dredged will be removed given the technological
limitations associated with dredging. In selecting the 1 ppm
cleanup goal, EPA has balanced its desire for a very low cleanup
level which will minimize residual risk with the constraints posed
by dredging as a means of removing sediment from a riverine
environment.
Prior to dredging, additional sediment and surface water sampling
will be conducted to better delineate the extent of the area to be
dredged and to serve as baseline monitoring data. The area to be
sampled will include the upriver portion of the Reynolds Study Area
and the area near the mouth of the Grasse River. Bathymetry in the
Reynolds Study Area will be refined and remapped. In addition,
areas of dense vegetation and any areas containing boulders or
debris will be identified and mapped. The initial dredging program
will be conducted in a manner which will identify site-specific
information and operating parameters such as dredging rates and
depths, sediment removal efficiencies, silt curtains and sheet
piling effectiveness, sediment dewatering methods, and sediment
suspension and settling characteristics. This information will be
evaluated and used as appropriate in modifying operating procedures
to improve the effectiveness of the removal program.
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Silt curtains and, if deemed necessary during design, sheet piling
will be installed on the river side of the areas to be dredged to
provide a stilling basin for dredging operations and to minimize
transport of contaminated sediment which may be resuspended during
the dredging process. Sediments will generally be removed using
hydraulic dredges but mechanical dredges may also be used when
appropriate. Sediments near the shoreline may also be excavated
using conventional excavation equipment. During dredging, sediments
and surface water will be monitored to ensure that downstream
transport of contaminated sediment is minimized. A contingency plan
will be developed which describes measures to control and/or
minimize the impacts of dredging. Measures to control the impacts
of dredging could include, if approved by EPA, modification and/or
suspension of dredging activities. Oversized materials will be
screened from the dredged sediments as the sediments are transported
to the shoreline. Dredged /excavated areas will be restored to their
original grade either through the use of fill or, if determined to
be appropriate by EPA during design, through natural sediment
deposition.
Partial Thermal Desorption of Sediments
Removed sediments will then be decanted and dewatered. Those
sediments with PCB concentrations above 25 ppm (approximately 14,500
cubic yards) will then be treated on-site by thermal desorption.
Based on the results of treatability testing, treated sediments will
have PCB concentrations below 10 ppm. Condensed contaminants
recovered during thermal desorption will be sent to an off-site
location for incineration at a permitted commercial incinerator.
Water removed from the sediments will be treated using methods
including flocculation and chemical precipitation to remove solids,
and sand bed filtration and activated carbon adsorption. All water
that is removed from sediments or generated during the treatment
process will be discharged to the St. Lawrence River in compliance
with substantive SPDES requirements.
Emissions from the thermal desorption system will be controlled
using venturi scrubbers and scrubber towers. Emissions will be
monitored to ensure compliance with federal and State air quality
and emissions requirements.
• Sediment On-site Disposal in the Black Mud Pond
Sediments will be tested using the RCRA TCLP to ensure that they
cannot be classified as RCRA hazardous waste. If they are RCRA
hazardous waste, additional treatment, such as solidification, may
be required to render them non-hazardous. Treated sediments, along
with approximately 37,000 cubic yards of untreated dewatered
sediments with PCB concentrations between 1 and 25 ppm, a,nd rinsed
oversized material will be disposed of on-site in the Black Mud
Pond. The Black Mud Pond will be capped, in compliance with the
requirements of the New York State-Reynolds Consent Order, with a
multilayer cap and monitored and maintained to ensure the integrity
of the cap.
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Prior to remediation, a floodplains assessment will be performed and
a determination will be made as to the consistency of the remedial
action with the New York State Coastal Zone Management Program.
Some changes may be made to the remedy as a result of the remedial
design and construction processes. If the changes are significant,
for purposes of Section 300.435(c)(2) of the National Contingency
Plan, then EPA will follow the appropriate procedures set forth in
that regulatory provision. Monitoring of the St. Lawrence River
sediments, water, and biota will be performed prior to, during, and
after dredging operations.
The capital cost of the selected remedy is $ 34.8 million. Annual
operation and maintenance costs are $ 28,000/year. The total
present worth cost of the selected remedy is $ 35.1 million. A more
detailed breakdown of estimated costs associated with the selected
remedy is presented in Table 8.
X. Statutory Determinations
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through the removal of contaminated sediments from the river system
and the subsequent permanent treatment of highly contaminated
sediments. Treated sediments and untreated sediments with low level
contamination will be disposed of on-site. Cleaned oversized items
which cannot be treated will also be disposed of on-site. Following
implementation of the selected remedy, the excess cancer risk to
adults will be on the order of 1CT4, within the range considered
acceptable by EPA. In addition, following implementation, hazard
indices for non-carcinogens will be less than one.
Compliance with Applicable or Relevant and Appropriate
Requirements
A list of ARARs for the selected remedy is presented in Table 9.
The selected remedy complies with these ARARs.
TSCA is the primary federal law which regulates the disposal of
PCBs. A special allowance is made under 40 CFR §761.60(a)(5)(iii)
of the TSCA regulations for dredged material disposal. For the
reasons described in this document (see the discussions in Part VIII
entitled "Long-term Effectiveness and Permanence", "Reduction of
Toxicity, Mobility, or Volume through Treatment", and "Cost" and the
discussion in the following section), EPA believes that the remedy
selected herein is consistent with the TSCA requirements at 40 CFR
$761.60(a)'(5) (iii).
Cost-Effect ivenes s
The selected remedy is cost-effective because it has been
demonstrated to provide overall effectiveness proportional to its
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costs. The present worth cost of the selected alternative,
Alternative G(A), which includes a 25 ppm treatment threshold, is
$ 35.1 million. The present worth cost of Alternative G(B), which
includes a 10 ppm treatment threshold, is $ 36.7 million. The
present worth cost of Alternative I (A), which incorporates a 500 ppm
treatment threshold, is $ 35.8 million. The present worth cost of
Alternative I(B), which incorporates a 50 ppm treatment threshold,
is $ 37.9 million. Thus, EPA has selected the least expensive
alternative which provides for permanent removal and treatment of
the majority of the principal threat posed by contaminated
sediments. In addition, a comparison of the costs of Alternatives
G(A), I (A), and I(B) demonstrates that it is more expensive to
construct a landfill for disposal of sediments with PCB
concentrations between 25 and 500 ppm than it is to treat such
sediments. Therefore, Alternative G(A) is more cost-effective than
Alternative I.
The use of thermal desorption, rather than incineration, minimizes
the cost of treatment. The 25 ppm treatment threshold results in
permanent treatment of the majority of the PCB mass within the
contaminated sediments and is consistent with EPA guidance and the
State's cleanup plans for the upland portion of the Reynolds
facility, while at the same time being less expensive than
Alternative G(B), which includes a treatment level of 10 ppm. EPA's
preference for use of the Black Mud Pond for disposal is also cost-
effective since it will minimize the amount of fill needed in this
area and it will consolidate material in one management area.
Utilization of Permanent Solutions and Alternative Treatment
for resource recovery) Technologies to the Maximum Extent
Practicable fMEPl
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable. The selected remedy
represents the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility, or
volume through treatment, short-term effectiveness,
implementability, and cost while also considering the statutory
preference for treatment as a principal element and considering
State, Tribe, and community acceptance.
The selected remedy offers a higher degree of permanence than in-
situ containment alternatives. Because PCBs, PAHs, and TDBFs are
highly persistent in the environment, removal and treatment provide
the most effective way of assuring long-term protection. In
addition, the treatment of the most highly contaminated sediments
combined with on-site containment of untreated sediments and
treatment residuals significantly reduces the total concentration of
PCBs in the material which must be managed over the long-term. The
use of thermal desorption combined with incineration of the
condensed extract from the thermal desorption process will reduce
the toxicity and mobility of contaminants. Although there are
short-term impacts associated with the selected remedy, these will
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be mitigated through the use of controls such as silt curtains and,
if necessary, sheet piles.
EPA realizes that the implementability of the selected remedy has
not been fully established. Therefore, the initial dredging program
will be conducted in a manner which will identify site-specific
information and operating parameters such as dredging rates and
depths, sediment removal efficiencies, silt curtains and sheet
piling effectiveness, sediment dewatering methods, and sediment
suspension and settling characteristics. This information will be
evaluated and used as appropriate in modifying operating procedures
to improve the effectiveness of the removal program. Among the
alternatives considered for the Site, the major tradeoffs that
provided the basis for EPA's remedy selection were the fact that the
selected remedy provides long-term effectiveness and permanence and
reduces the toxicity of the principal threat material at the lowest
cost while being consistent with the State's selected remedy for the
upland portion of the Reynolds facility.
Preference for Treatment as a Principal Element
By removing and treating the contaminated sediments with PCB
concentrations above 25 ppm, the selected remedy satisfies the
statutory preference for remedies that employ treatment as a
principal element. The selected remedy is consistent with Superfund
program expectations that indicate that highly toxic, persistent
wastes are a priority for treatment.
XI. Documentation of Significant Changes
After reviewing comments received from the New York State Department
of Environmental Conservation, EPA has determined that the Black Mud
Pond would be a suitable location for disposal of treatment
residuals and untreated sediment. Utilization of the Black Mud Pond
as a disposal area would consolidate contaminants in one management
unit while realizing cost savings due to eliminating construction,
maintenance, and monitoring of a new disposal cell and substantially
reducing the volume of fill needed for the Black Mud Pond before
capping.
Originally, EPA, in its Proposed Plan, preferred Alternative G(B),
sediment removal/partial thermal desorption/disposal with soil cover
which incorporated a 10 ppm PCB treatment level. However, EPA has
determined that a 25 ppm PCB treatment level is consistent with New
York State's plans for remediating on-site contamination and that
this change will lower remedial costs. However, although the
treatment level is consistent, the process by which the number was
obtained is not consistent with the State's process by which they
obtained their cleanup >and treatment numbers for the on-site
contamination. This treatment level is consistent with EPA guidance
which recommends a 10 — 25 ppm soil cleanup level for industrial
sites as generally protective of human health and the environment.
-32-
-------
In addition, material with PCB concentrations below 25 ppro could be
placed in the Black Mud Pond since it would not contain
concentrations significantly above material currently found in the
Black Mud Pond. Accordingly, EPA has selected Alternative G(A),
which incorporates a 25 ppm PCB treatment level and disposal in the
Black Mud Pond, for remediation of the Reynolds Study Area
sediments.
-33-
-------
APPENDIX 1
FIGURES
-34-
-------
CORNWALL
ISLAND
(CANADA)
GENERAL
MOTORS
CORPORATION
LEGEND:
> now tmccnoH
I UPSTREAM AREA OF THE RMC PLANT
I CRASSE RIVER
I SLR AREA NORTH OT CRASSE RIVER TO RMC PUMP HOUSE
WAN PART Or SHALLOW SHELF; OUTFALL AREA
AREA DOWNSTREAM OF OUTFALL AREA TO INTERNATIONAL BRIDGE
i DOWNSTREAM OF INTERNATIONAL BRIDGE
> RAOUETTE RIVER
RMC STUDY AREA
ST. LAWRENCE AND RAOUETTE RIVERS
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
H».T MCISiy-1
0>nn *f IT
Ool« OI/W/IM1
FIQUnEI
-------
LEGEND:
ST. LAW&iCE «*R DRAINAGE
RAOUETC RTCR DRAINAGE
STIE ORAWAOE AREAS
ST. LAWRENCE REDUCTION PLANT
REYNOLDS METALS COMPANY
MASSEHA, NEW YORK
-------
SNELL LOCK
GRASSE RIVER
SEAWAY
INTERNATIONAL
BRIDGE
T4
rT6
i AUXILIARY
PUMP
HOUSE
T5
LEGEND;
IflBB STUDY
0 OUTFALL LOCATION
WATER DEPTH. 6 FEET
—— WATER DEPTH. 12 FEET
WATER DEPTH. 18 FEET
<$> MAIN RIVER FLOW-CORE CURRENT
<£> ZONE OF TURBULENCE
<$> REVERSE FLOW-COUNTER CURRENT
<$> ZONE OF LOW-VELOCITY TURBULENCE
CURRENT METER AND DROGUE TRANSECTS
1089 DIVING TRANSECTS
SKETCH OF MAJOR FLOW ZONES
AND CIRCULATION PATTERNS
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
HIS
0«l« 01/M/IM1
FiounE 3
-------
mo BOOY
LEGEND
1988 SAMPUNO
• •
•
0
NO
Wv^MM
com SAMPLES
GRAB SAMPLES
OUTFALL
NOT OtltCIW
-BOUNDARY OF ,
STUDY AREAS
1990 SAMPLING
D « SEDIMENT SAMPUNO
T 1 LOCATIONS
TT SEDIMENT SAMPLES TO
•y~r WCLUOE auTRATE
TESTMO
(1) SURVEYED SHORE
LOCATION MARKER
X WATER SAMPUNO
LOCATIONS
CHANNEL MARGIN
S. CORNWALL CHANNEL r-STrtAWRENCE RIVER
I 7000.-
200
SCALE IN fTET
SNtU 10
OREDi BUOY
CHANNa MARGIN
ANT WATER
INTAKEs
B20 >'
• NO
,014 »J
•se
LC8
•.-'HOUSE'
.
^SURFACE. •
DISCHARGE'
:••.:••.•>:••. -:• v. '•.
•10 V.-\OUTFALL
004
•' 001 ^
t4-4-f-
' WTFALt
002
O
o
REYNOLDS METALS
COMPANY
ST. LAWRENCE RIVER SEDIMENT
SAMPLING PROGRAM DETAIL AREA
TOTAL PCBs (0-8 Inches, mg/kg)
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
IWootfmnf-Ctpto
ConuHhg Ci>ghMr« CMlogKtl end Cf»»onm §5131213
>own by •>.<:.
Dale 0«/I»/II
ncuRE .4
-------
CHANNEL MARGIN
S. CORNWALL CHANNEL r
CHANNEL MARGIN
PLANT WATER
INTAKE
'• .IT ••'•'. 12'. • T OU.tf ALL \ •'' 004
• FORMER
' OUTFALL
002
SURfACt.
DISCHARGE
ST. LAWRENCE RIVER SEDIMENT
SAMPLING PROGRAM DETAIL AREA
TOTAL PCBs (8-16 Inches, mg/kg)
REYNOLDS METALS COMPANY
MASSENA, NEW YORK
REYNOLDS METALS
COMPANY
Woodw«tf-CM* Cm
COTHlltaf Cngtonri. Gwloglltl OK) Cmkonnxtd Mindtta
-------
CHANNEL MARGIN
S. CORNWALL CHANNEL -
CHANNEL MARON
PtAMT WATER
INTAKE
e
At
10 \.-\ OUTFALL
004
•FORME?
' PU.TFAU
002
% SURF ACE
WSCHAKct
REYNOLDS METALS COMPANY
MASSENA, NEW YORK
noODWARD-CLYDE CONSULTANTS
CoifullMf Cnghwni CMlogWi ontf Cn«kentn«nld SctonlWt
ST. LAWRENCE RIVER
SEDIMENT SAMPLING PROGRAM
DETAIL AREA
TOTAL PCBs (>16 Inches.
REYNOLDS METALS
COMPANY
-------
mo BUOY
CHANNEL MARGIN .
LEGEND
1988 SAM PUNO
•
•
o
NO
•«M^r-
cone SAMPLES
GRAB SAMPLES
OUTFAU.
NOT mlLCICO
-BOUNDARY GT ,
StUDY AREAS
1MO SAMPUNO
a o SEDIMENT SAMPLING •
f > IOCATIONS
TT SEDIMENT SAMPLES TO
-TT" NCUJOE aUTRIATE
1ESTMO
A SUR^dO SHORE
LOCATION MARKER
w WATER SAMPUNO
* LOCATIONS
SNELL LO
GREEN BUOY
A9J
iA8
PLANT WATER j
INTAKEs
D*
S. CORNWALL CHANNEL --STrTAWRENCE RIVER
CHANNEL MARGIN
XWB-3
B21
o??
• '.'9'.
^SURFACE. •
DISCHARGE'
I ?«?•—-
0 200 400
I I I
SCAU IN FEET
- JT2 »,\ _,„
js?or~ 18M.
C2
ISLAND °l.37
Vt.4(
.10-
NO.
• '.'. F^ME^\ °°2 * ^.\ . ~i^%t V
' OUTFALL^ \ •-.••.••.• .2 ..
002
000^
'
o
REYNOLDS METALS
COMPANY
Tn>«
ST. LAWRENCE RIVER SEDIMENT
SAMPLING PROGRAM DETAIL AREA
SUM OF PAHs (mg/lcg) AT ALL DEPTHS
REYNOLDS METALS COMPANY
MASSENA, NEW YORK
IWoodmrtf-Cfyd* Camitftanto
ConuHkg CnghMm CMloglili or.J Cn«»onm«ntd Sdinthto
Jab Ho.: B9C231X>-> Ornkig No. «5I3121<
Oolr. M/20/M
FIGURE 7
-------
S. CORNWALL CHANNEL -^.STr LAWRENCE RIVER
SHELL LOCK—-—T"~~"^
^gASa-ftnlR \
CHANNEL MARGIN
PLANT WATER
INTAKE
FORMER
10-V.-1 OUTFALL
OU.TF'ALL.A-'1 004
•001 L
• FORMER
OUTFALL
002
ST. LAWRENCE RIVER SEDIMENT
SAMPLING PROGRAM DETAIL AREA
TOTAL CYANIDE (mg/hq)
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
Woodmrtf-dyd* ConMJtMta
Conrfthg CngtiMr^ CMlogMt otd [mkonmtnld SdxIWt
-------
CHANNEL MARGIN
S. CORNWALL CHANNEL^-STrtAWRENCE RIVER
CHANNEL MARGIN
3B
PLANT WATER
INTAKE
C4,. -. '"/oCT
- o 1.3 ^—^^ ^ .
FORMER
' PliTFALL
002
•'. •'. • -rt' •'. • • 1.2 •'.
,' • .'9 .
SURFACC
DISCHARGE
ST. LAWRENCE RIVER SEDIMENT
SAMPLING PROGRAM DETAIL AREA
TOTAL aUORIDE (mg/kg)
REYNOLDS METALS COMPANY
MASSENA, NEW YORK
REYNOLDS METALS
COMPANY
Co-irfltig CnqhMr*. CMlogtoli mtf CnAontwilol ScMnlMl
-------
CHANNEL MARGIN
S. CORNWALL CHANNEL --STv tAY/RENCE RIVER
CHANNEL MARGIN
SNELL LOCK -
GRASS RTVER
OIEEN BUOY
A^,.-.
PLANT WATER
INTAKE
FORMER
OUTFALL
FORMER
OUTFALL
AUXILIARY
PUMP HOUSE
SURfACE
DISCHARGE
ST. LAWRENCE RIVER
SEDIMENT SAMPLING PROGRAM
TOTAL FURANS (ng/g)
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
REYNOLDS METALS
COMPANY
Wootfwwtf-Cfyd* CoTMrfUnt*
Cauullhg CnghMTK C^jlo^UH «id Cnv»oiim«ntd 3dintMl
-------
USA
SEAWAY
INTERNATIONAL
- BRIDGE
REYNOLDS
METALS
COMPANY
UCCMK
AKA CF H» StOMCMT
CONTAMMAIMM
1-1 H*>
(OUIIft
(mines
FAtto
t-B«wi
>3p»m
wvtd now nmciKM
MXVCUAL JAUPIC lOCAIKMS.
CONCtMtRAIKMS M ppm.
J-EStMATIO CONCtHIRAtKM
OUffML IOCA1NW
ST. LAWRENCE RIVER
DISTRIBUTION OF PCB SEDIMENT CONCENTRATIONS
REYNOLDS METALS COMPANY
MASSCNA. NEW YORK
Weodwurtf-Oyd* ConwMnto
m* b»»«nnMnM
otm*i« NO. tsisnio
O«l« OI/lt/IMJ
FKJORE 11
-------
Ammmra (« TO • M.)
CONTAMINATED
SEDIMENT
BOUNDARY or
CONTAMINATED SEDIMENT
BOUNDARY or GCOTtxme
BOUNDARY Or
OJEAN SAND CAP
(IB IN.-UIN.)
2 rr.-MM. CLEAN
TRANSITION ZONE
PLAN YEW
ARMORINO TO
4.5 rT. DEPTH
1.5 FT. TRANSITION ZONE
TUX ot Bullion
OEAM SEDIMENT
LEGEND:
BOUNDARY OT CONTAMINATED SEDIMENT
TYPICAL EXISTING BATHYMETRY CONTOURS
GEOTEXTlie
CLEAN SAND CAP
ARMOWNO (REVETMENT MAT)
IN-SITU CAP SCHEMATIC
REYNOLDS METALS COMPANY
MASSENA. NEW YORK
©Wootfwvtf-Ctytf* ConwTUnto
Ccnwltkig CnglnMrt^ CMloqtttl and CnAemntnlal SctantM*
•Mi No.: B9C23I5T-I Orawhf No. OSI5SMO
Oro«n b)r otO
NOT TO SCAU
-------
APPENDIX 2
TABLES
-35-
-------
TABLE * 1. REYNOLDS METAL STUDY AREA: CONTAMINANTS OF CONCERN
SEMIVOLATILES
Acenaphthene
Acenaphttiylene
Anthracene
Beuolateothncene
Benzo(»>pyrene
BenzoTb)fluonnthene
Benzoftitflooruthene
BenzoCf .hJ Iperylene
Chiysene
Di benzol aJ> tamhncene
Dibenzafunns
Fluaraatheoe
Fluarene
Phenaslhrene
Pyrene
CDDf/CDFs
METALS
Aluminum
Fluoride
Lead
Cyanide
Mercury
PESTldDEVPCBf
Aroclor 1016
Aroclor 121
Aroclor 1248
Aroclor 1254
Aroclor 1260
Dieldrin
DDE
Sediments
St Lawrence Raqoette
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
t
X
X
X
X
X
Fbh
St Lawrence Raqnette
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
•Risk Assessment evaluates total PCBs.
-------
TABLE 2
EXPOSURE PATHWAY: INGEST1ON OF FISH BY MOHAWK NATION RESIDENTS FOR
PRESENT AND FUTURE SCENARIOS
Variable
Receptor Population
Body Weight (kg)
Resident
Duration of Exposure (Years)
Resident
Exposure Frequency (Days/Year)
Ingenion Kate (g/Day)
Resident
Averaging Time (Days)
noncarcinogenic
carcinogenic
Range Midpoint Value Rationale
J Used
< , Mohawk Nation
' ' - Residents
f - 70 Per EPA guidance
s
1-70 35 K' -70 , Based on known
;. ' :' , residence time of
i; .- . Mohawk Nation
N members
1-365 183 ;^350 Value used is specified
in supplemental EPA
v " guidance
", 132 Per EPA guidance
, - Range, midpoint and
365 - 25550 12775 -' 25550 value used are based on
exposure duration for
:";: - noncarcinogens and
lifetime for carcinogens
Reference
EPA. 1989d
EPA. 1989a
Jock, 1991
EPA, 1991a
EPA, 1989a
EPA. 1989a
EPA. 1989a. Risk Assessment Guidance for Superfund, Volume I, EPA 540/1-89/002. Office of Emergency and Remedial
Response. December 1989.
EPA, 1989d. Exposure Factors Handbook, EPA 600/8/-89/043. Exposure Assessment Group, Office of Health and
Environmental Assessment 1989.
EPA, 199la Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors". OSWER
Directive 9285.6-03. March 25, 1991.
Jock. 1991. St. Regis Mohawk Tribe Environmental Program, Personal communication with Naida Gavrelis, TRC
Environmental Corporation.
-------
TABLE .3
EXPOSURE PATHWAY: DERMAL CONTACT WITH RIVER SEDIMENTS BY LOCAL
RESIDENTS AND FISHERMEN FOR PRESENT AND FUTURE SCENARIOS
Variable
Receptor Population
Body Weight (Kg)
Small Child (Age 1-6)
Adult
Duration of Exposure (Years)
Small Child
Adult/Fisherman
Exposure Frequency (Days/year)
Small Child
Adult
Fisherman
Skin Surface Area Contacted
(sq.cm)
Small Child
Arms
Hands
Legs
Feet
Total Area of These Limbs
Adult/Fisherman
Anns
Hands
Total Area of These Limbs
Soil Skin Adherence Factor
(mg/sq. cm)
Range Midpoint , Value
5 Used
-
. |,, ^ .-
-' 15 ""
!' 70 '
x ..
1-6 3 r *
1-70 35 i "*4 -
: •
1 - 365 183 ^ 143
*
°.
,
1 - 365 183 78
-
''
1-365 183 * 350
>,
/
, * .,
f- «6Q
\ =400
\: 1800
? ,-520
r 3680
;
; •, >-\'
"< " ""- ' "
Lasoo
f "520
f 3120 , '
& ^, %
02-1.0 0.6 |f-^\>
r% "*-
Rationale
Local Residents
As specified in supplemental
guidance
Based on known residence time
Of Mohawk Nation members
Assume child spends 5 d/wk
outdoors during summer and 3
d/wk during spring and fall (39
weeks total)
Assume adult spends 2 d/wk
outdoors during spring,
summer, and fall (39 weeks
total)
Assumes fishing occurs daily
year round.
50th percemile values; assume
ave. is represented by values
for ages 3-4
Values used are presented in
RAGS, except for feet GZFH)
Value used is midpoint of
range
Reference
EPA, 1991a
Jock, 1991
Jock, 1992
EPA, 1991a
EPA, 1989a
EPA, 1989d
EPA, 1989a
EPA, 1989d
EPA, 1992b
-------
TABLE 3
EXPOSURE PATHWAY: DERMAL CONTACT WITH RIVER SEDIMENTS BY LOCAL
RESIDENTS AND FISHERMEN FOR PRESENT AND FUTURE SCENARIOS (continued)
Variable
Absorption Factor (Percent)
PCBs (Aroclor 1254)
CDD/CDFs
Averaging Time (Da\s)
Small Cbild
noncarcinogenic
carcinogenic
Adult/Fisherman
noncarcinogens
carcinogens
Range
0.006 - 0.06
0.001 - 0.03
365 - 2190
365 - 25550
Midpoint
0.03
0.02
1095
12775
'? Value
' Used
•^0.03 * '
i 0.02
I- "'
1 1190
j',3SS30
Is '
^23360
'25550
Rationale
Value used is midpoint of
range given by EPA
Range, midpoint, and value
used are based on exposure
duration for noncarcinogens
and lifetime for carcinogens
Reference
EPA, 1992b
EPA, 1989a
EPA, 1989a. Risk Assessment Guidance for Superfund, Volume I, EPA 540/1-89/002. Office of Emergency and Remedial
Response. December 1989.
EPA, 1989d. Exposure Factors Handbook, EPA 600/8-89/043. Exposure Assessment Group, Office of Health and
Environmental Assessment 1989.
EPA, 199la Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors". OSWER
Directive 9285.6-03. March 25, 1991.
EPA, 1992b. Dermal Exposure Assessment: Principles and Applications. Interim Report, EPA/600/8-91/01 IB. Office of
Research and Development. January 1992.
Jock, 1991 and 1992. St. Regis Mobawk Tribe Environmental Programs. Personal communication with Naida Gavrelis and
Scott Heim, TRC Environmental Corporation.
-------
TABLE 4
EXPOSURE PATHWAY: DIGESTION OF SEDIMENTS FROM THE RIVER BANKS BY
LOCAL RESIDENTS AND FISHERMEN FOR PRESENT AND FUTURE SCENARIOS
Variable
Receptor Population
Body Weight (kg)
Small Child (Age 1-6)
Adult
Duration of Exposure
(Years)
Small Child
Adult/Fisherman
Exposure Frequency
(Days/Year)
Small Child
Adult
Fisherman
Ingestion Rate (mg/Da\)
Child
Adult
Fraction Ingested from
Contaminated Source
(Unitless)
Averaging Time (Davs)
Child
noncarcinogens
carcinogens
Adult/Fisherman
noncarcinogens
carcinogens
Range Midpoint ° Value
1 Used
-
£ IS
* 70 .
1-6 3 I' -** -
1-70 35 I 64 , ;
\ •.*
1-365 183 •; J43
1-365 183 :' 7*" V
1 - 365 183 \- 350 "
; 300
; 100 -
- I--V.
365-2190 1095 * 2190
1 "25550 -
365-25550 12775 £23360*
1^25550"
Rationale
Local Residents
As specified in supplemental
guidance
Total duration equals 70 year
residence time
Assumes 5 d/wk outdoors during
summer and 3 d/wk during
spring and fall (39 weeks total)
Assume 2 d/wk outdoors during
spring, summer, and fall (39
weeks total)
Assumes fishing occurs daily
year round
Value used is specified in RAGS
Assume that all soil contacted is
contaminated
Range, midpoint, and value used
are based on exposure duration
for noncarcinogens and lifetime
for carcinogens
Reference
EPA, 1991a
EPA. 1991a
Jock, 1992
EPA, 199 la
EPA, 1989a
EPA, 1989a
EPA, 1989a
EPA. 1989a. Risk Assessment Guidance for Superfund, Volume L EPA 540/1-89/002. Office of Emergency and Remedial
Response. December 1989.
EPA, 199la. Human Health Evaluation Manual. Supplemental Guidance: "Standard Default Exposure Factors". OSWER
Directive 9285.6-03. March 25. 1991.
Jock. 1992. St. Regis Mohawk Tribe Environmental Programs. Personal Communication with Scon Heim. TRC Environmental
Corporation.
-------
TABLE 5 TOXICITY VALUES FOR THE REYNOLDS SITE CONTAMINANTS
Chemical
Acenapbtbene
Acenapbtbylene
Anthracene
Benzo(a)antbracene
Benzo(a)pyrene
Benzo(b)fluorantbene
Benzo(g,b.i)perylene
BenzoftOfluorantbene
Chrysene
Dibenzofuran
Dibenz(aj))anthracene
Fluoranibene
Fluorene
2,3,7,8-Heptachlorodibenzodioxin
23,7,8'Heptachlorodibenzofuran
23,7,8-HexacbJorodibenzodioxin
2,3.7,8-Hexacnlorodibenzofuran
Octochlorodibenzodioxin
Octocblorodibenzofuran
23,7.8-Pentachlorodibenzodioxin
1 .2,3,7,8-PemachlonxJibenzofuian
2J,4,7,8-Pentachlorodibenzofuran
Pbenantbrene
Pyrene
23,7,8-Tetrachlorodibenzodioxin
2,3.7.8-Tetrachlorodibenzofunc
CARCINOGENIC
Weight
of Evidence
Classification
~
D
D
B2
62
62
D
B2
B2
D
B2
D
D
62
62
B2
62
62
62
62
62
62
D
D
62
62
a
a
a
a
a
a
a
a
a
a
a
a
a
b
b
b
b
b
b
b
b
b
a
a
b
b
Oral Slope
Factor
(mg/kg/day)-l
7.30E-01
7.30E400
730E-01
7.30E-01
730E-02
730E400
1.60E+03
1.60E403
1.60E404
1.60E-KM
1.60E+02
1.60E+02
8.00E404
8.00E403
8.00E-M34
1.60E405
1.60E404
d
a
d
d
d
d
e
e
e
e
t
t
t
t
t
b
e
CHRONIC
Chronic
Oral RID
(mg/kg/day)
6-OOE-02
3.00E-01
4.00E-03
4.00E-02
4.00E-02
3.00E-02
a
a
c
a
a
a
-------
TABLE -.5 (CONTINUED)
Chemical
Aroclor - 1260
Aroclor - 1016
AlunuDinn
Cyanide
Fluoride
Lead
Mercury
CARCINOGENIC
Weight
of Evidence
Classification
B2
D
D
—
B2
D
a
d
a
a
a
a
Oral Slope
Factor
( ing/kg/day)-!
7.70E400
a
CHRONIC
Chronic
OralRfD
(mg/kg/day)
7.00E - 05
l.OOE+00
2.00E-02
6.00E-02
3.00E-04
c
c
a
a
b
a. U.S. EPA, Integrated Risk Information System (IRIS), September 1, 1992.
b. U.S. EPA. Health Effects Assessment Summary Tables (HEAST). FY 1992.
c. Interim value from ECAO (see text for specific references).
d. Oral slope factor for B(a)P used for PAHs classified as B2 carcinogens with the following TEFs applied:
Benzo(a)anthracene 0.1
Benzo(a)fluaranthene 0.1
Benzo(k)fluoranihene 0.1
Chrysene 0.01
Dibenz(aji)amhracene 1.0
e. Oral slope factor for Z3.7.8-TCDD was used for other chlorinated dioxins/dibenzofurans with the
following TEFs (EPA, 1989e) applied:
Z3.7,8-PeCDDs 0.5
23,7,8-HxCDDs O.I
2.3.7.8-HpCDDs 0.01
OCDDs 0.001
2J.7,8-TCDFs 0.1
2,3,7,8-PeCDFs 0.5
1^3.7^-PeCDFs 0.05
2J,7.8-HxCDFs 0.1
2J,7,8-HpCDFs 0.01
OCDFs 0.001
-------
TABLE . 6.. SUMMARY OF CARCINOGENIC RISK ESTIMATED FOR THE
REYNOLDS SITE
Scenario
FISH INGESTION
St. Lawrence River at RMC
SL Lawrence River - RMC Vicinity
Raquette River
SEDIMENT
Ingestion - SL Lawrence River
Dermal Contact - St. Lawrence River
Ingestion - Raquette River
Ingestion - SL Lawrence River
Dermal Contact - SL Lawrence River
Ingestion - Raquette River
Receptor
Resident
Resident
Resident
Fisherman
Fisherman
Fisherman
Resident
Resident
Resident
Present/Future
P/F
P/F
P/F
P/F
P/F
P/F
P/F
P/F
P/F
Total Risk
4xlO"2*
6xlO'2*
4xlO'2*
6x10-'*
3x1 0'?*
N/A
3x1 0'?*
1x1 0'?*
N/A
•Exceeds 10" risk
N/A - Not applicable, no carcinogens detected
-------
TABLE . 7 SUMMARY OF NONCARCINOGENIC HAZARD INDICES (HI)
ESTIMATED FOR THE REYNOLDS SITE
Scenario
V
FISH INGESTION
St. Lawrence River at RMC
St Lawrence River - RMC Vicinity
Raquette River
SEDIMENT
Ingestion - St. Lawrence River
Dermal Contact - St. Lawrence River
Ingestion • Raquette River
Ingestion - St. Lawrence River
Dermal Contact - St. Lawrence River
Ingestion - Raquette River
Receptor
Resident
Resident
Resident
Fisherman
Fisherman
Fisherman
Resident
Resident
Resident
Present/Future
P/F
P/F
P/F
P/F
P/F
P/F
P/F
P/F
P/F
Total Risk
7x10*'*
IxlO*2*
7xlO*1*
5x10°*
3x10°*
2xlO"2
2x10*'*
9x10°*
9xlO'2
•HI exceeds one (1)
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TABLES
SUMMARY OF COSTS OF SELECTED REMEDY
Component of Selected Remedy
Cost
Sampling
Mobfltzation/Demobaization
Site Preparation
Dredging/Dewatering/On-shore Loading
ATP Treatment
DIRECT COSTS
INDIRECT COSTS (30% of direct costs)
SUBTOTAL
CONTINGENCY (20% of subtotal)
TOTAL CAPITAL COSTS OF REMEDY
OAM COSTS*
O&M 30 YEAR PRESENT WORTH**
TOTAL PRESENT WORTH COSTS OF REMEDY
$200,000
$1,200,000
$ 2,100,000
$ 15,900,000
$ 2,900,000
$ 22,300,000
$ 6.700,000
$ 29,000,000
$ 5,800.000
$ 34.8 million
$ 28,000/year
$250,000
$ 35.1 million
O&M begins after completion of construction.
I on an assumed discount rate of 5%.
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TABLES
MAJOR APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS,
AMONG OTHERS, ASSOCIATED WITH THE SELECTED REMEDY
Chemical-Specific ARARs
• Clean Air Act
National Primary and Secondary Ambient Air Quality Standards at 40 CFRPartSO
• New York State Requirements
Air quality standards at 6 NYCRR Part 257
Air emission refutations at 6 NYCRR Part 211
Water quality regulations for surface waters and groundwaters at 6 NYCRR Parts 700 - 705
Action-Specific ARARs
• Toxic Substances Control Act
PCS disposal requirements for disposal of dredged material generally found at 40 CFR
761.60(a)(5)
• Resource Conservation and Recovery Act
Capping and monitoring requirements generally found at 40 CFR 264.303 and 264.310
Groundwater monttoring requirements at 40 CFR 264 Subpart F
Generator requirements at 40 CFR 262
Transporter requirements at 40 CFR 263
• dean Water Act
Best available technology and monitoring requirements at 40 CFR 122.44
Best management practices program at 40 CFR 125.100, 40 CFR 125.104, 40 CFR 136.1-
136.4
• River and Harbors Act
Dredging requirements at 33 CFR 320-330
-40-
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TABLE 9 (cont.)
MAJOR APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS,
AMONG OTHERS, ASSOCIATED WITH THE SELECTED REMEDY
• New York State Requirements
Solid waste management facflity regulations at 6 NYCRR Part 360
Final status standards for hazardous waste facilities at 6 NYCRR Part 373, Including standards
for incinerators at 373-3.15 and standards for thermal treatment at 373-3.16
Implementation of National Permit Discharge Elimination System at 6 NYCRR 750-757
Process exhaust and/or ventilation system requirements at 6 NYCRR Part 212
Location-Specific ARARa
• Executive Orders 11988 and 11990
Roodplalns management and protection of wetlands at 40 CFR 6.302 and 40 CFR 6.
Appendix A
• Fish and WBdlife Coordination Act
Protection of endangered species and wfldlife at 33 CFR Parts 320-330 and 40 CFR 6.302
• National WBdlife Historical Preservation Act
Preservation of historic properties at 36 CFR 65 and 36 CFR 800
• Endangered Species Act
Protection of endangered species at 50 CFR 200,50 CFR 402
• Clean Water Act
Section 404 requirements for dredge spoD discharge at 40 CFR 230 and 33 CFR Parts 320-
330
• WDd and Scenic Act
Protection of recreational river at 40 CFR 6.302(e)
• Coastal Zone Management Act k
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TABLE 9 (cont)
MAJOR APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS,
AMONG OTHERS, ASSOCIATED WITH THE SELECTED REMEDY
• New York State Requirements
Endangered species requirements at 6 NYCRR 182
Coastal zone management policies at 1 NYCRR Part 600
"To Be Considered" Requirements
• St Regis Mohawk Tribe Requirements
0.1 ppm PCB sediment level
Sng/m'PCBairlevel
• Clean Water Act interim sediment quality criteria
• New York State sediment quality criteria
• Acceptable ambient levels of volatile organics In emissions from ail sources in NYS Air Guide I
-42-
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APPENDIX 3
STATE LETTER OF CONCURRENCE
-36-
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Now York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
-7010
« « JA*. Thom»$ C. Jorilng
* 7 1993 CommlMhMttr
Ms. Kathleen C. Callahan
Acting Deputy Regional Administrator
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, Hew York 10278
Dear Me. Callahan:
The New York State Department of Environmental Conservation
has reviewed the United states Environmental Protection Agency
(USEPA) Draft Record of Decision (ROD) for the Reynolds Study
Area for which Reynolds Metals is responsible for investigating
and remediating, pursuant to the September 1989 USEPA Unilateral
Administrative Order.
We strongly support the proposed dredging of contaminated
sediments from the river and can agree with USEPA's cleanup
levels for this site. He also agree with and support the concept
of using the Black Mud Pond for the disposal of untreated
sediments and treatment residuals
Regarding the document's reference to the on-site PCB
treatment levels required by the New York State ROD, we believe
that it is inappropriate to state that the 25 parts per million
(ppm) level being considered by USEPA is consistent with that
level required by New York State. While the numbers are the
same, the processes followed to arrive at those values are not.
The 25 ppm PCB soil treatment level selected by New York State
was based on a cost analysis which compared projected remedial
costs to the mass of PCBs which would be treated through the use
of different treatment levels. USEPA does not appear to have
conducted an analysis similar to the above. Therefore, the ROD
language should be duly modified. As the Department has
previously indicated, we do not accept USEPA's PCB Guidance
Document since it is inconsistent with our approach to PCB
remediation and, as indicated in the document, the guidance is
optional for USEPA to follow. In accordance with the State's
approach, we recommend that USEPA require Reynolds Metals to
evaluate remedial design sampling results to determine the
feasibility of treating sediments with PCB concentrations below
25 ppm. Based on the results of the evaluation, we would
encourage the use of lower treatment levels if it could be
demonstrated that doing so vould not add unreasonable costs to
the project.
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Us. Kathleen C. Callahan Page 2
While the Department can agree with US EPA 's cleanup levels
for this site, we strongly encourage Reynolds Metals to eliminate
as much of the contamination as possible, while it is in the
process of remediating the environs of this site and to pursue
the lowest possible cleanup level that is feasible under existing
conditions.
The USEPA should ensure that pilot testing of the thermal
desorption unit is performed during remedial design to verify
that the emissions from the treatment unit are acceptable.
Thank you for the opportunity to review this document.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
TOTftL P.03
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