PB96-963909
EPA/ROD/R03-96/226
September 1996
EPA Superfund
Record of Decision:
Limestone Road Superfund Site,
Operable Unit 2, Cumberland, MD
6/28/1996
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Limestone Road Superfund Site
Cumberland, Maryland
Record of Decision
Operable Unit 2 -
Prepared by
The U.S. Environmental Protection Agency
June 1996
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Record of Decision
Limestone Road Superfund Site
Table of Contents
Part 1 - Declaration
1.0 Site Name and Location 1
2.0 Statement of Basis and Purpose 1
3.0 Assessment of the Site 1
4.0 Description of the Selected Remedy 2
5.0 Statutory Determination 2
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Part 2 - Decision Summary
1.0 Site Name, Location and Description 3
2.0 Site History and Enforcement Activities 3
3.0 Scope and Role of Response Action 4
4.0 Highlights of Community Participation .5
5.0 Summary of Site Characteristics 5
5.1 Site Geology 5
5.2 Ground water, .. 6
5.3 Surface Water and Sediment 8
5.4 Fate and Transport 9
6.0 Summary of Site Risks 10
6.1 Data collection and evaluation 10
6.2 Exposure Assessment 10
6.3 Toxicity Assessment 12
6.5 Risk Characterization 16
7.0 Description of Alternatives 18
7.1 Alternatives Considered 18
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8.0 Summary of Comparative Analysis of Alternatives 21
8.1 Overall Protection of Human Health and the Environment 22
8.2 Compliance with ARARs 23
8.3 Long-term Effectiveness and Permanence 25
8.4 Reduction of Toxicity, Mobility or Volume through Treatment 26
8.5 Short-term Effectiveness 26
8.6 Implementability 27
8.7 Cost 27
8.8 State Acceptance 28
8.9 Community Acceptance 28
9.0 Selected Remedy and Performance Standards 28
10.0 Statutory Determinations ..' 29
10.1 Protection of Human Health and the Environment 29
10.2 Compliance with Applicable or Relevant and Appropriate RequirementsSO
10.3 Cost-Effectiveness 30
10.4 Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable 30
10.5 Preference for Treatment as a Principal Element 31
11.0 Documentation of Significant Changes 31
Part 3 - Responsivenes Summary
A. Overview 36
B. Comment Received During the Public Meeting 36
C. Written Comments Received During the Comment Period 41
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Record of Decision
Limestone Road Superfund Site
Part 1 - Declaration
1.0 Site Name and Location
Limestone Road Superfund Site
Operable Unit 2
Cumberland, Maryland
2.0 Statement of Basis and Purpose
This Record of Decision ("ROD") presents the final remedial action selected
for Operable Unit 2 ("OU2") of the Limestone Road Superfund Site ("Site"), located
in Cumberland, Allegany County, Maryland. This remedial action was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and "
Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. §§ 9601 et seq.. and the
National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40
C.F.R. Part 300. This decision document explains the factual and legal basis for
selecting the remedial action and is based on the Administrative Record for this Site.
An index of documents included in the Administrative Record may be found at
Appendix A of the ROD:
The Maryland Department of the Environment (MDE) was sent a draft of the
ROD on June 5, 1996, and by letter of June 12, 1996, indicated that it had no
comments on the ROD. A revised draft of the ROD was sent to MDE on June 20,
1996, along with a request for concurrence on the ROD. The State has verbally
indicated a willingness to concur, but wishes to see the final version before doing so in
writing.
3.0 Assessment of the Site
Pursuant to duly delegated authority, I hereby determine, pursuant to Section
106 of CERCLA, 42 U.S.C. § 9606, that actual or threatened releases of hazardous
substances from this Site, as discussed in Section 6.0 (Summary of Site Risks) of Part
2 of this ROD, if not addressed by implementing the remedial action selected in this
ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
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4.0 Description of the Selected Remedy
The selected remedy for the Site consists of the following major components:
> Installation of a waterline and ancillary equipment (a pumping station and fire
hydrants) to service residents in the vicinity of the Site. The waterline will be
of sufficient capacity to meet the needs of both current and reasonably
expected future development of the area; and
* Implementation of deed restrictions on the previously capped areas of the Site
to prevent use of such areas in such a manner as would cause disturbance of
the caps;
» Implementation of a ground water management program to prevent
installation of drinking water wells in the vicinity of the Site;
Continuation of the long term ground waterif.surface water, and sediment
monitoring plans currently being implemented pursuant to OU1;
» Abandonment of existing residential water supply wells.
5.0 Statutory Determination
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. The remedy utilizes
permanent solutions and alternative treatment technologies to the maximum extent
practicable for this Site. While EPA considered an alternative that employed
treatment as a principal element in order to reduce toxitity, mobility, or volume, this
alternative was not considered practicable and was not selected. A five year review
for OU2 will be included in the Site-wide five year review that has already been
triggered by the start of constuction of the OU1 remedy.
Thomas C. VoltafigioV / Date
Director
Hazardous Waste Management Division
Region 3
Environmental Protection Agency
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Record of Decision
Limestone Road Superfund Site
Part 2 - Decision Summary
1.0 Site Name. Location and Description
The Limestone Road Superfund Site is located in Allegany County, Maryland,
2 '/2 miles southeast of the city of Cumberland (see Figure 1). The Site includes
contamination found on two separate parcels of land: the Diggs Sanitation Company
(Diggs) property on the north side of Limestone Road (approximately 20 acres), and
the Cumberland Cement and Supply Company (CC&SC) property on the south side
of Limestone Road (approximately 190 acres). The Diggs property is bordered on the
southwest by several residences and to the northeast by the former Cumberland City
Dump (City Dump) and undeveloped land. The CC&SC property is partially
bordered on the north by the City Dump and Limestone Road, and undeveloped land
on the remaining perimeter of the property. Currently, 18 residences are within a - r
half mile of the Site, five are within 100 yards of the Site and one is located on the
Diggs property. These residences are serviced by individual water supply wells.
2.0 Site History and Enforcement Activities
Paul and George Boch reportedly operated a trash collection and burning
operation on the Diggs property during the 1960's. In the early 1970's, Diggs
Sanitation, Inc. (Diggs), a licensed waste hauler, bought the property and then
conducted refuse operations, primarily the landfilling of commercial, residential and
demolition waste, until the early 1980's.
The Cumberland Cement and Supply Company (CC&SC) property, which
had been the site of a commercial limestone quarrying operation, was purchased by
Charles Steiner in 1962 for the purpose of developing the quarry to the north and
east of the Site. The quarry, however, was never developed. Instead, ravine areas on
the Site were filled during the mid-1970's in order to make a level working area. The
fill reportedly consisted of a wide variety of clean construction and demolition debris
as well as household trash and commercial and industrial refuse. Activities such as
vehicle repair and oil recovery have also reportedly been conducted on the CC&SC
property.
In April of 1981, Diggs illegally dumped contaminated waste sludge containing
chromium, lead, and cadmium from Fairchild Republic Company (now Fairchild
Holding Corp., the successor to Fairchild Industries, Inc., which, in turn, is the
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successor to Fairchild Republic Company) of Hagerstown, Maryland. It was
estimated that 99 tons of that sludge was disposed of on the CC&SC property and 11
tons on the Diggs property. In June 1981, following an initial investigation by the
Maryland Department of Health and Mental Hygiene, Diggs Sanitation, Inc. and
CC&SC were ordered by the State to dean up their respective properties. The order
was challenged by Diggs and CC&SC and reversed; subsequently, new orders were
issued to both parties. This action was stayed when EPA became the lead agency for
the site. In 1984, a 20,000 gallon tank located in the area of the reported oil
recovery operation and the soil surrounding the tank were successfully removed under
the supervision of the Maryland Waste Management Administration and the
Allegany County Health Department.
In March 1982, EPA conducted a preliminary assessment of the Site which
resulted in the proposal for placement of the Site on the Superfund National
Priorities List (NPL). In September of 1983, EPA included the Site on the NPL.
In 1986, EPA concluded a Remedial Investigation (RJ) and Feasibility Study -
(FS) for Operable Unit 1 (OU1) at the Site. Based on the findings of these reports,
EPA issued an OU1 ROD on September 30,1986 to address the immediate threats
posed by the exposed waste at the Site. The ROD required capping of contaminated
soil on both properties and fencing the capped areas. The OU1 ROD also required a
Supplemental Remedial Investigation (SRI) and Feasibility Study (SFS) to evaluate
the local ground water system and adjacent streams. In February of 1990, EPA and
two potentially responsible parties entered into a Partial Consent Decree to conduct
the work described in the OU1 ROD. Construction of the fences and low
permeability caps for areas on both the Diggs and CC&SC properties began in June
1994 and was completed in November (1994. The supplemental studies were
completed in the fall of 1995.
Early findings of the SRI indicated that some local residential wells contained
elevated levels of metals, including lead, manganese, copper, and nickel. To address
this immediate threat to human health, several Potentially Responsible Parties (PRPs)
entered into an Administrative Order on Consent (AOC) in April of 1994 to conduct
regular monitoring of residential wells and to provide potable water to residents with
elevated levels of contaminants in their wells. At this time, several residents are still
receiving bottled water due to elevated levels of contaminants in their wells.
3.0 Scope and Role of Response Action
As with many Superfund sites, the problems at the Limestone Road Site are
complex. Thus, the Site has been divided into "Operable Units" (OUs) to simplify
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the process of addressing these problems. The first OU, OU1, focused on the
contaminant source areas. These areas were capped and fenced, as required by the
OU1 ROD, in 1994. Operable Unit 2 (OU2) addresses the ground water, surface
water, and sediment in the vicinity of the Site based on the SRI and SFS, which
studied the contamination in these areas and evaluated alternatives to address it.
This ROD addresses OU2 and is the final planned action at the Site.
4.0 Highlights of Community Participation
Pursuant to Section 113(k)(2)(B) of CERCLA, 42 U.S.C. §113(k)(2)(B), the
SRI and SFS reports, the Proposed Plan, and other documents relating to OU2 were
released to the public for comment on April 15, 19.96. These documents were made
available to the public in the Administrative Record located in the EPA Docket Room
in EPA's Region 3 office, and in the AUegany County Library located in Cumberland,
Maryland. The notice of availability of these documents was published in the
Cumberland Times-News on April 15. and April 24* 1996.
A public comment period on the documents was held from April 15 until May
14, 1996. EPA held a public meeting in Cumberland on April 24, 1996 during which
representatives from both EPA and the State of Maryland answered questions
regarding the Site and the Proposed Plan. Responses to the comments received
during the public comment period are included in the Responsiveness Summary of
this ROD.
5.0 Summary of Site Characteristics
5.1 Site Geology
The Site is located in the Valley and Ridge physiographic province of the
Appalachian Highlands. The area is dominated by steeply dipping slopes and ravines
and northeast/southwest trending ridges. Relief in the vicinity of the Site is
approximately 1,100 feet, ranging in elevation from 590 feet above sea level at the
North Branch of the Potomac River to 1,700 feet above sea level at the crest of Irons
Mountain. The Site itself is located on the western slope of Irons Mountain. The
elevations across the Site range from 660 feet above sea level to approximately 900
feet above sea level. The original topography of the Site has been altered by the
landfilling and subsequent capping of the Diggs and CC&SC properties.
During the course of the SRI, the extent of the fill materials requiring capping
on both properties was defined. In addition, the geologic and hydrogeologic units
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were studied. The fill unit consists of a highly variable mixture of brick, glass,
concrete, wood, paper, slag, plastic and fly ash in a silt, sand, gravel and clay matrix.
The thickness of the fill unit ranged from 0 to 26.4 feet on the CC&SC property and
from 0 to 17 feet at the Diggs property. The hydraulic conductivity of the fill
materials was measured and found to be approximately 1 x 10'7 cm/sec, much lower
than might be expected for fill material.
A 10-foot thick residuum/saprolite unit separates the fill unit from the
underlying bedrock. The very low vertical hydraulic conductivity of this unit (less
than 1 x 10"8 cm/sec) combined with its thickness, suggests that the unit acts as an
barrier that limits the movement of fill unit water into the unsaturated portion of the
bedrock. The bedrock unit beneath the Site consists of steeply dipping, fractured
shales and siltstones. The major structures within the bedrock which impact ground
water flow are horizontal or nearly horizontal fractures, bedding plane fractures, and
vertical joints oriented in the direction of the dip of the bedding planes. Short- and
long-term pumping tests have shown that the fractures are interconnected; however,
the degree of interconnectedness varies across the Site. The general direction of
ground water flow in the bedrock unit is in a west-northwest direction, with ground
water discharge occurring in Evitts Creek.
5.2 Ground water
Monitoring wells were installed into the fill units on both the Diggs and
CC&SC properties. Four volatile organic compounds (VOCs), acetone, benzene,
ethylbenzene, and trichloroethene, were detected at low concentrations (less than 15
parts per billion (ppb)) on the Diggs property; none were detected on the CC&SC
property. With the exception of nickel, total metals concentrations were generally
higher on the Diggs property. The maximum concentrations reported on either
property are 1.6 ppb for cadmium, 18.6 ppb for chromium, 20.2 ppb for lead (which
exceeds the health advisory level for this metal), 227 ppb for manganese, and 90.8
ppb for nickel.
Twenty-eight bedrock wells were installed and sampled during the SRI. No
VOCs were detected in the background monitoring wells or the background
residential well. Trichloroethene was detected in three bedrock monitoring wells at
concentrations ranging from 0.5 ppb to 1.2 ppb, levels which do not pose a threat to
human health. Other VOCs detected in either bedrock wells or residential wells were
acetone, chloromethane, 2-butanone, chloroform, ethylbenzene, tetrachloroethane,
toluene, and xylene. All were at concentrations below the appropriate Safe Drinking
Water Act Maximum Contaminant Level (MCL) or health advisory level.
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Metals were found in background, onsite, and residential wells. The maximum
concentrations of total metals found in background wells were 2.4 ppb cadmium,
57.2 ppb chromium, 443 ppb lead, 1700 ppb manganese, and 121 ppb nickel. The
levels of lead, manganese and nickel are all above MCLs or health advisory levels.
Concentrations of total metals exceeded background levels in numerous bedrock
monitoring wells; cadmium in three wells, manganese in seven wells, and nickel in five
wells. Total cadmium was found in one residential well at 137 ppb, total chromium
was found in 11 residential wells at levels ranging from 5 to 9.6 ppb, total lead was
found in 13 residential wells at levels ranging from 1.7 to 34.3 ppb, total manganese
was found in 20 residential wells at levels ranging from 6.7 to 2,510 ppb, and total
nickel was found in 8 residential wells at levels ranging from 12.3 to 100 ppb.
Concentrations of dissolved metals appear in ground water samples in the same
relative concentrations as they were detected in the bedrock core samples (manganese
is the highest, cadmium the lowest). There is no apparent spatial pattern in the
concentrations of the inorganics as a group; each constituent appears in its highest
concentration in a different monitoring well. Maximum concentrations of dissolved" -
cadmium, lead, and manganese found in the background wells were 5.3, 1.5, and 525
ppb respectively. Cadmium was not detected above background levels in any bedrock
monitoring well or residential well. Chromium was detected above background in
four wells, lead in four wells, manganese in 18 wells, and nickel in 13 wells. The
maximum concentrations of both total and dissolved metals and the appropriate
action levels are shown in Table 1.
The ground water analyses conducted during the SRI have confirmed that
trichloroethylene (TCE) and methylene chloride are not contaminants of concern
(COCs) at the Site. TCE was detected in only eight of the 52 wells sampled, all at
levels below the MCL. Methylene chloride was detected in two residential wells;
however, in both cases, it was also detected in blank samples as well, which indicates
the chemical was present as a result of the analytical procedure, not actual onsite
contamination.
The only inorganics which exceeded MCLs in onsite monitoring wells were
cadmium and nickel. The MCL for nickel (in the dissolved samples) was exceeded in
four wells. Exceedance of the MCL for cadmium occurred only in a background
monitoring well. Although an MCL has not been established for manganese, the high
concentrations of this inorganic pose a potential human health risk. Concentrations
of manganese appear to be higher in the immediate vicinity of the two landfilled
areas. The presence of organic chemical compounds onsite could cause elevated levels
of manganese in the ground water. The distribution of dissolved manganese in
ground water shows no obvious pattern, most likely because of the fractured bedrock
medium. While a traditional plume-like distribution is expected in a fractured
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medium, the actual distribution is dependent upon the fracture network and the
degree to which the rock behaves as a porous medium. Sources of contamination
other than the Site may be contributing to the elevated levels of manganese in some
residential wells since numerous wells with much lower concentrations are located
between the Site and those wells. However, no other specific sources have been
identified.
Evaluation of temporal trends shows that the concentrations of all indicators,
with the exception of manganese, are generally decreasing or remaining stable. The
concentrations of manganese in all wells, including background wells, have shown an
increase over time.
5.3 Surface Water and Sediment
The Site is in the drainage basin of the North Branch of the Potomac River
(North Branch). Surface water drains from the Site to unnamed tributary streams
that flow to the North Branch and.Evitts Creek. A-spring discharging from the base -
of the CC&SC property drains to a tributary that flows south/southwest to the North
Branch. A spring also discharges from the base of the City Dump and drains to a
stream which receives runoff from the City Dump and the Diggs Property and flows
into the unnamed tributary above the confluence of Evitts Creek with the North
Branch. The capping of the contaminated areas of the Diggs and CC&SC properties
has eliminated the contaminated surface runoff; however, the streams still receive
groundwater discharge from the bedrock aquifers beneath the Site. In addition, the
stream that receives runoff from the Diggs property still receives runoff from the City
Dump. While some of the waste on that site has been capped, it is currently being
used for salvage operations by the property owner.
Sediment in the two streams which receive surface runoff from the Site have
been impacted by Site activities. The sediment in the stream on the CC&SC
property exhibits a slightly elevated concentration of chromium at a sampling location
near the edge of the Site cap. At the Diggs property, all sampling locations may have
been affected by Site conditions. It is difficult, if not impossible, to determine to
what degree the contaminants originate from the Diggs and City Dump properties,
respectively. Site-related metals found in the stream include chromium, lead, and
manganese, all contaminants of concern. These metals have also been found on the
City Dump property, which has only been partially capped and which is still used as a
salvage yard. Ground water at the City Dump has not been studied and may or may
not be contaminated. If it is contaminated, discharge of this water to the creek would
be an additional source of contamination to the stream.
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In order to assess the impact of the Site on surface water the data from the
analyses of the total'and dissolved constituents must be reviewed in conjunction with
the sediment data. Near the CC&SC property manganese was detected above
background in the dissolved analyses at all locations. Manganese was not present
above background in the sediment analyses at th£se locations, however. This suggests
that the source of manganese in surface water is ground water rather than surface
runoff. (Were the source surface runoff, sediment levels would likely be above
background levels as well.) Cadmium and chromium, on the other hand, were
reported in total concentrations but were not detected in any dissolved analyses,
indicating that surface runoff was the source. Lead and zinc were both reported
above background in total and dissolved analyses in the sample taken nearest the
Site. However, these samples were collected prior to the capping of this property.
The quality of surface water in the vicinity of the Diggs property is very
similar. Near the Diggs property manganese was present above background in the
total and dissolved analyses of surface water and in the stream sediments in all
locations. Manganese is also present at elevated concentrations in ground water in -.
this area of the Site. Springs occur at two sampling locations, and the presence of
manganese in the surface water samples in this area most likely reflects ground water
contribution. Zinc, cadmium, and lead were present above background in total
analyses of surface water and in sediment analyses near the Diggs property.
Cadmium was also present in dissolved analyses of surface water at one location, and
zinc at two locations. Again, these samples were collected prior to the capping of this
property. Table 2 shows the maximum and average concentrations of metals found in
the surface water and sediment as compared to the Biological and Technical
Assistance Group (BTAG) screening levels. (These are threshold levels below which
adverse impacts to biota are not expected to occur.)
5.4 Fate and Transport
The construction of the caps has effectively eliminated the potential for
migration of Site-related contamination via surface water runoff and by air through
either volatilization or by entrainment of chemicals absorbed onto paniculate matter.
The caps have also eliminated the infiltration of precipitation into the fill units. This
will reduce the amount of leachate produced over time. Fill unit water leaking
vertically through the residuum saprolite unit and into the bedrock aquifer would mix
with the ground water and migrate in the general direction of ground water flow
(west^northwest). Local residents are currently relying on ground water as a potable
water source.
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6.0 Summary of Site Risks
The Baseline Risk Assessment (BRA) was prepared as a part of the SRI prior to
the start of the OU1 remedial action (i.e., the capping of the landfilled areas) and
thus did not consider the impact of these actions on the fate and transport of Site
contaminants. Construction of the caps has effectively eliminated the potential for
future contamination of the surface water and sediment via runoff; thus, these
pathways will not be discussed here.
6.1 Data collection and evaluation
Data from analysis of ground water, surface water and sediments reported in
the 1986 RI and the more recent SRI reports were thoroughly examined to evaluate
the chemicals present, their distribution and concentrations at the Site. Based upon
this review, the data did not demonstrate any dear trends. This is exemplified by the
sporadic nature and variability oif positive detections for volatiles and inorganics in
ground water. Therefore, only the SRI analyses of groundwater, surface water and *
sediments were used in this BRA as this data is more representative of current site
conditions.
Data validation qualifiers were treated according to EPA guidance. Rejected
samples ("R" qualifiers) were not included in the database for the risk assessment.
Non-detect results ("U" qualifiers) were included only if other results for a given
chemical in a particular medium/area indicated the chemical was present. In these
instances, half the reported quantitation limit was used. Estimate^ results, usually
indicated by a "J" qualifier, were included in the evaluation. Duplicate samples were
averaged and considered as one sample.
' Based on Region 3 policy, the exposure point concentrations used in the BRA
were calculated based on dissolved inorganics data in monitoring wells and on total
inorganics in residential wells.
6.2 Exposure Assessment
There are three basic steps involved in an exposure assessment: 1) identifying
the potentially exposed populations, both current and future; 2) determining the
pathways by which these populations could be exposed; and 3) quantifying the
exposure.
The current and probable future land uses of the Site are critical in identifying
current and future potentially exposed populations. Based upon current land use,
current zoning and planning, local populations, and future land use plans, residential
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development is the actual or potential land use for property in the vicinity of the Site.
The Site itself is expected to remain undeveloped.
The Site is zoned as a general urban district. Property to the southwest below
(downhill of) the Site is zoned for residential use. Due to erosion problems, the
steeply sloping wooded land above (uphill of) the Site is a restricted conservation area
where no further development will be permitted. Property to the west of the Site
slopes steeply down to Evitts Creek. This area is less accessible and would be difficult
to develop as residential lots and is likely to remain undeveloped.
For residents living at or near the Site, the primary pathway for exposure to
Site-related contaminants is through use of ground water. Homes in the vicinity of
the Site obtain drinking water from the local groundwater aquifer through private
wells. Due to the rural nature of the area, any.new residences would be expected to
use this ground water as well. Ground water can release and transport contaminants.
Infiltration of precipitation- through the soil can potentially leach Site-related
contaminants to ground water, although at this Site, the caps should greatly reduce ~ r
the amount of precipitation reaching the fill material. There is a current and future
potential exposure to Site-related contaminants in drinking water wells on and
downgradient from the Site. Exposure could occur by consumption of groundwater,
dermal contact from household use (i.e. dishwashing, washing cars, laundry,
bathingtehowering) and inhalation of volatiles while bathingfehowering.
Another group of individuals who could be potentially exposed to Site-related
contaminants are hikers, hunters and others using the area in the immediate vicinity
of the Site for recreational purposes. Evitts Creek is classified as a FV-P surface water
which is defined as "recreational trout waters and public water supply". This use
designation includes a) holding and supporting adult trout for put-and-take fishing;
b) special fishery by periodic stocking and seasonal catching; and c) use as a public
water supply. The main stem of the North Branch Potomac River is classified as a I-P
surface water which is defined as "water contact recreation, protection of aquatic life
and public water supply". This use designation includes a) water contact sports; b)
play and leisure time activities where individuals may come in direct contact with
surface water; c) fishing; d) the growth and propagation of fish; e) agricultural water
supply; f) industrial water supply; and g) public water supply.
The unnamed tributaries of Evitts Creek and the North Branch of the Potomac
River receive runoff from the Site as well as the City Dump. Since the construction
of the Site caps was completed, contaminated surface runoff was eliminated; however,
the streams still receive ground water discharging from beneath the Site. Potential
exposure to any contaminants found in surface water could occur during recreational
activities by hunters and hikers in unnamed tributaries of Evitts Creek and the North
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Branch of the Potomac River. Because of the location of the stream and the nature of
the surrounding terrain, it is highly unlikely that unattended small children would
play in the area or that adults would bring small children to the area to play.
Exposure routes associated with these pathways include incidental ingestion and
dermal contact with surface water by adults and small children hiking or hunting in
the area. The physical conditions of the unnamed tributaries of Evitts Creek and the
North Branch of Potomac River are such that they will not provide a suitable habitat
to support a population of sizable game fish. Therefore, ingestion of fish from these
streams is not evaluated.
In order to quantify the potential exposure associated with each exposure
pathway discussed above, assumptions were made with respect to the various factors
used in the calculations. Table 3 summarizes the values used in the BRA.
6.3 Toxirity Assessment
The purpose of the toxicity assessment is to weigh available evidence regarding -
the potential for particular contaminants to cause adverse effects in exposed
individuals. Where possible, the assessment provides a quantitative estimate of the
relationship between the extent of exposure to a contaminant and the increased
likelihood and/or severity of adverse effects.
A toxicity assessment for contaminants found at a Superfund site is generally
accomplished in two steps: 1) hazard identification; and 2) dose-response
assessment. Hazard identification is the process of determining whether exposure to
a contaminant can cause an increase in the incidence of a particular adverse health
effect (e.g., cancer or birth defects) and whether the adverse health effect is likely to
occur in humans. It involves characterizing the nature and strength of the evidence
of causation.
Dose-response evaluation is the process of quantitatively evaluating the toxicity
information and characterizing the relationship between the dose of the contaminant
administered or received and the incidence of adverse health effects in the
administered population. From this quantitative dose-response relationship, toxicity
values (e.g., reference doses and slope factors) are derived that can be used to
estimate the incidence of or potential for adverse effects as a function of human
exposure to the contaminant. These toxicity values are used in the risk
characterization step to estimate the likelihood of adverse effects occurring in humans
at different exposure levels. For the purpose of the BRA, contaminants were classified
into two groups: potential carcinogens and noncartinogens. The risks posed by these
two types of compounds are assessed differently because noncarcinogens generally
exhibit a threshold dose below which no adverse effects occur, while no such
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threshold has been proven to exist for most carcinogens. As used here, the term
carcinogen means any chemical for which there is sufficient evidence that exposure
may result in continuing uncontrolled cell division (cancer) in humans and/or
animals. Conversely, the term noncarcinogen means any chemical for which the
carcinogenic evidence is negative or insufficient.
Slope factors have been developed by EPA's Carcinogenic Assessment Group
for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic contaminants of concern. Slope factors, which are expressed in units of
(mj^kg-day)"1, are multiplied by the estimated intake of a potential carcinogen, in
mgflcg-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 slope factor. Use of this
approach makes underestimation of the actual cancer risk highly unlikely. 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 (e.g., to account for the use of animal data to predict effects on * -
humans). Slope factors used in the BRA for contaminants found at the Site are
presented in Table 4.
Reference doses (RfDs) have been developed by EPA to indicate the potential
for adverse health effects from exposure to contaminants of concern exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of m^kg-day, are
estimates of lifetime daily exposure levels for humans, including sensitive individuals.
Estimated intakes of contaminants of concern from human epidemiological studies or
animal studies to which uncertainty factors have been applied account for the use of
animal data to predict effects on humans. Reference doses used in the BRA for
contaminants of concern are presented in Table 4.
6.4 Human Health Effects
The contaminants of concern for this Site were determined to be arsenic,
cadmium, copper, manganese, nickel, and zinc. The following discussion of the
human health effects of each of these contaminants is summarized from the BRA
Arsenic
Arsenic is a naturally occurring element that can be present in a number of
different valence states and as a constituent of both inorganic and organic
compounds. It occurs most often as a sulfide in a variety of complex minerals
containing copper, lead, iron, nickel, cobalt, and other metals. Most of the arsenical
compounds are used in the production of agricultural chemicals such as insecticides,
13
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herbicides, algitides, and growth stimulants for plants and animals. In certain areas,
concentrations in soil may be elevated because of naturally high levels in mineral
deposits in the area.
The fate of arsenic in water depends upon the chemical form of the arsenic and
on interactions with other materials present. Soluble forms move with water, and
may be carried long distances through rivers. However, arsenic may be adsorbed from
water onto sediments, especially days, iron oxides, aluminum hydroxides, manganese
compounds and organic material. Bioconcentration of arsenic occurs in aquatic
organisms, primarily in algae and lower invertebrates. Biomagnification in aquatic
food chains does not appear to be significant. There is no evidence that photolysis
and volatilization are important removal mechanisms of arsenic in the aquatic
environment. Although arsenic minerals and compounds are readily soluble,
migration of arsenic through soil is greatly limited due to the strong sorption by days,
hydroxides, and organic matter.
Acute oral poisoning in humans may result in gastrointestinal disturbances
(nausea, vomiting and diarrhea), hemolysis and encephalopathy following very high
doses. In most cases, effects are seen only after chronic low-dose exposures, whether
environmental or occupational. These disorders have been linked to exposure to
drinking water containing greater than 50 grams of Arsenic per liter of water. Higher
exposures to inorganic arsenic related to arsenical poisoning or industrial exposures
can also cause characteristic skin lesions, dark and light patches, and small corns on
heavily comified skin such as palms and soles of feet.
Arsenic has been dassified by EPA as a Group A - Human Carcinogen. This is
based on reports of increased cancer inddence from inhalation and drinking water
exposures.
Cadmium
Cadmium is present generally throughout the environment and in many
materials. Elevated concentrations are generally related to non-ferrous mining and
refining. It is used in steel manufacturing and in pigments for plastics. Cadmium
concentrations in soil are increased by the application of sewage sludge and
phosphate fertilizers. Long-term exposure to excessive cadmium causes adverse
kidney effects and effects on calcium metabolism. An assodation has been shown
between occupational exposure and an increased inddence of lung and prostate
cancer in workers. Teratogenic effects have been observed in test animals after very
high doses.
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Cadmium is classed as a Bl carcinogen (some evidence in humans and
adequate evidence in animal studies) only by inhalation.
Copper
Copper occurs naturally as sulfides, oxides and carbonates. Sulfide ores
constitute 75 percent of the total copper production. Approximately half of all
copper production is used in electrical equipment. Another common use for copper is
in plumbing and heating equipment. Copper salts also function as pesticides for
fungi or algae and as herbicides.
Copper is an essential element and forms part of several enzymes. The daily
requirement is about 2 mg for adult humans. The daily intake of copper ranges from
2 to 5 mg/day and comes from common food stuff which contain up to 10 mg/kg.
By inhalation, copper is a respiratory irritant. Occupational exposure to copper
dust via inhalation has resulted in mucosal irritation of the mouth, eyes, and nose; -.
anorexia; nausea; and occasional diarrhea by factory workers. Accidental exposure to
large amounts of copper can cause gastrointestinal disturbances including vomiting,
diarrhea, nausea, abdominal pain and metallic taste in the mouth. Copper fumes can
cause irritation of the respiratory tract otherwise known as metal fume fever, a
reversible flu-like response. The drinking water limits (secondary MCL of 1 mg/L and
MCL of 1.3 mg/L) are based on adverse tastes and potential health risks, respectively.
Manganese
Manganese is widely distributed and found naturally as oxides, carbonates and
silicates. It is used in metallurgy, chemical manufacture, tanning, textile bleaching
and welding rods. It is added as a trace element in fertilizers for certain crops.
Manganese is an essential,trace element in the diet, but deficiencies have not been
reported. Manganese is neurotoxic at adequate dose levels; neurological disorders are
well-documented via the inhalation route by workers.
The general public is primarily exposed to manganese by ingestion of foods and
water or inadvertent ingestion of soil. Very little information is available concerning
manganese poisoning by the oral route. Dermal exposure has not been noted as a
concern except in the case of potassium permanganate which may cause severe
irritation or is corrosive when it contacts skin or mucous membrane.
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Nickel
Agricultural soils, world-wide, contain from 3 to 1000 mg/kg nickel. Nickel is
found in many foods and the average daily intake in the U.S A is reported to be from
300 to 500 mg. Less than 10 percent of the ingested inorganic nickel is adsorbed
from the digestive tract. Nickel has been shown to be an essential element in the diet
of some animal species but this has not been proven for the human species. Large
oral doses are tolerated by animals and systemic effects from oral ingestion are
unlikely. Nickel can cause pulmonary inflammation and dermal contact has caused
dermatitis in nickel workers.
Nickel is classified as a known human,carcinogen via inhalation (Group A) by
USEPA and the oral RfD for soluble salts is 0.02 mg^k^day.
Zinc
Zinc concentration in soils varies from 10 to^SOO mgfcg. Zinc is found in
foods, particularly those high in protein. Zinc is an essential element, necessary for
the function of various enzymes. Fifteen mg^day has been recommended as the daily
requirement for adults by the National Academy of Scientists Food and Nutrition
Board. Chronic poisoning from zinc ingestion has not been described in humans.
Zinc is not a suspected carcinogen.
6.5 Risk Characterization
The risk characterization process integrates the toxirity and exposure
assessments into a quantitative expression of risk. For carcinogens, the exposure
point concentrations and exposure factors discussed earlier are mathematically
combined to generate a chronic daily intake value that is averaged over a lifetime (i.e.,
70 years). This intake value is then multiplied by the toxirity value for the
contaminant (i.e., the slope factor) to generate the incremental probability of an
individual developing cancer over a lifetime as a result of exposure to the
contaminant. These probabilities are generally expressed in scientific notation (e.g.,
1.0 x 10"6, otherwise expressed as 1E-6). An excess lifetime cancer risk of 1.0 x 10"6
indicates that, as a reasonable maximum estimate, an individual has a 1 in 1,000,000
chance of developing cancer as a result of site-related exposure to a carcinogen over a
70-year lifetime under specific exposure conditions at a site. The generally acceptable
excess cancer risk range, as defined by Section 300.430 (e)(2)(I)(A)(2) of the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40
C.F.R. § 300.430 (e)(2)(I)(A)(2), is between 1.0 x lO"4 and 1.0 x lO"6.
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The potential for noncarcinogenic effects is evaluated by comparing an
exposure level over a specified time period (i.e., the chronic daily intake) with the
toxicity of the contaminant for a similar time period (i.e., the reference dose). The
ratio of exposure to toxicity is called a hazard quotient. A Hazard Index (HI) is
generated by adding the appropriate hazard quotients for contaminants to which a
given population may reasonably be exposed. Any media with an HI greater than 1.0
has the potential to adversely affect health.
Under a current residential use scenario it was found that the Site did not pose
an unacceptable carcinogenic risk. The carcinogenic risk was between 1 x 10"4 and I x
10"6 in all but one monitoring well, where it exceeded 1 x 10"4. The carcinogenic risk
is driven primarily by arsenic; however, the levels of arsenic are below the MCL even
in the well that exceeded the acceptable risk level. Furthermore, it is not dear that
the arsenic is Site-related. Under this same scenario, it was found that the Hazard
Index exceeded 1 for many residential and onsite wells. The elevated Hazard Index
values were primarily driven by manganese. The risk posed by the Site indicates that
remedial action is warranted to address the ground water contaminated by manganese-
and to prevent future exposure. Table 5 shows the maximum calculated cancer risks
and hazard indices for both onsite and offsite wells, using both the average
concentrations detected and the maximum concentrations detected.
Elevated levels of lead found in the drinking water of several residences has
also been of concern. Several exceedances of EPA's action level for lead (15 ppb) have
been detected. The source(s) of the lead have not been determined. Potential
sources of lead are both contamination from the Site and residential plumbing.
No unacceptable levels of risk were associated with the recreational use of the
area in the vicinity of the Site.
The ecological risk assessment showed that there are elevated levels of
contaminants in adjacent streams. Prior to the construction of the Site caps, the
streams received runoff from the fill areas. These past discharges may have left areas
of contamination in the stream sediment that could be a continuing source of
contaminants to the environment. Also, ground water currently flowing beneath the
Site still reaches the streams and is a potential continued source of contamination.
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the
environment.
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7.0 Description of Alternatives
The SFS Report discusses the alternatives evaluated for the Site and provides
supporting information relating to the alternatives presented in this ROD.
7.1 Alternatives Considered
\
The alternatives considered for the OU2 are as follows:
1. No Action
2. Home Treatment Units, Monitoring, and Institutional Controls
3. Waterline, Monitoring, and Institutional Controls
4. Pump and Treat, Waterline, Monitoring, and Institutional Controls
Alternative 1: No Action
Estimated Capital Costs: $0
Estimated Annual O&M Costs: $0
Estimated Present-Worth Costs: $0
The NCP requires that EPA consider a no action alternative for every site to
establish a baseline for comparison to alternatives that do require action. This
alternative assumes that the measures currently being undertaken as a part of the
OU1 Interim Remedial Action called for in the September, 1986 ROD would
continue, but no additional actions would be taken. These measures include periodic
inspection of the landfill caps, ground water monitoring, and surface water
monitoring. There would be no additional costs associated with the No Action
alternative.
Common Elements of Alternatives 2 through 4
The three additional alternatives analyzed contain several common elements.
These common elements are necessary to monitor and/or prevent unacceptable risks
posed to human health and the environment. These elements include:
institutional controls;
ground water monitoring; and
ecological monitoring.
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Description and Purpose of each Common Element
» Institutional controls: The length of time necessary to return the ground water to
natural conditions (if this is possible) cannot be determined. Therefore,
institutional controls will be used to prevent the use of contaminated ground
water and installation of additional wells into the contaminated aquifer. These
controls will take the form of deed restrictions and the use of a ground water
management zone in the vicinity of the Site. The deed restrictions will also
prevent future use of the land in such a way as to potentially expose the fill
material.
+ Ground water monitoring: The ground water monitoring program currently being
implemented at the Site pursuant to the OU1 ROD will continue. This
monitoring program currently consists of the collection of samples from onsite
and offsite monitoring wells on a quarterly basis and will be modified as
necessary and appropriate based on yearly reviews of the monitoring data.
* Ecological monitoring: The surface water and sediment monitoring program
currently being implemented at the Site pursuant to the OU1 ROD will
continue. This monitoring program currently consists of the collection of
samples from streams receiving ground water discharge and surface water
runoff from both the Diggs and CC&SC properties on a quarterly basis. This
program, like the ground water monitoring program, will be modified as
necessary and appropriate based on yearly reviews of the data.
Alternative 2 - Home Treatment Units plus Common Elements
Estimated Capital Costs: $268,000
Estimated Annual O&M Costs: $34,000
Estimated Present-Worth^Costs: $608,000
Time to Implement: Less than one year
In-home treatment of residential well water would be provided through the use
of individual units such as ion exchange systems. These home treatment units would
be installed on the water supply line from the well to treat water to be used for
domestic purposes. Any expended resin cartridges would require either onsite
regeneration or disposal. In addition to the ground water monitoring program
described under "Common Elements," quarterly monitoring of residential wells would
also be required.
The cost estimate for this alternative assumes that 19 residences would need
home treatment units. This is a conservative assumption; results from recent home
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well monitoring suggest that fewer than half of the residences would in fact need
units.
With the completion of the Site caps required under OU1, it is expected that
levels of contaminants will slowly dissipate to background levels and that ground
water could eventually be available for beneficial use. Monitoring of onsite and
off site wells, including residential wells, will track ground water contaminant levels for
up to 30 years to ensure that contaminant levels do not increase.
Alternative 3 -Waterline plus Common Elements
Estimated Capital Costs: $683,000
Estimated Annual O&M Costs: $19,000
Estimated Present-Worth Costs: $873,000
Time to implement: Approximately one year
A waterline would be installed to provide an alternative water supply to the 19
residents along Limestone Road. Specific remedial activities include the installation
of approximately 2,800 feet of 6-inch diameter watermain, one booster pumping
station, five fire hydrants, and 19 house connections, as well as the abandonment of
19 residential wells. The proposed alignment of the watermain is shown on Figure 2.
With the completion of the Site caps required under OU1, it is expected that
levels of contaminants will slowly dissipate to background levels and that ground
water could eventually be available for beneficial use. Monitoring of onsite and
offsite wells will track ground water contaminant levels for up to 30 years to ensure
that contaminant levels do not increase.
Alternative 4 - Pump and Treat, Waterline, plus Common Elements
Estimated Capital Costs: $1,766,500
Estimated Annual O&M Costs: $300,000
Estimated Present-Worth Costs: $4,766,500
Time to Implement: One to two years
This alternative includes all of the elements of Alternative 3, plus the
installation of five to ten groundwater extraction wells around the downgradient
perimeter of the Site, performance of limited pumping tests on each extraction well,
construction of a pump station above each extraction well location, installation of
buried forcemains to convey extracted ground water to a central on-Site treatment
facility, construction of a ground water treatment facility, construction of a gravity
main to convey treated ground water from the treatment facility to the drainage swale
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oh the Diggs property and any drainage improvements required to convey the treated
water to Evitts Creek, and long-term discharge monitoring. Ground water treatment
would continue until the aquifer has been restored to beneficial use. For cost
estimation purposes, operation and maintenance of the system was assumed to
continue for thirty years.
Home treatment units were ruled out as a part of a pump and treat option
because it is likely that the ground water extraction would dry up or severely limit the
production of residential wells.
8.0 Summary of Comparative Analysis of Alternatives
The remedial action alternatives described above were evaluated using the following
criteria, as required under Section 300.430(e)(9)(iii) of the NCP, 40 C.F.R. §
300.430(e)(9)(iii):
:*'
Threshold Criteria: Statutory requirements that each alternative must satisfy in
order to be eligible for selection.
1. Overall Protection of Human Health and the Environment - Evaluation of the ability
of each alternative to provide adequate protection of human health and the
environment in the long and short-term and of how risks posed through each
exposure pathway are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) -
Evaluation of the ability of each alternative to attain applicable or relevant and
appropriate requirements under federal environmental laws and state
environmental or facility siting laws or provide grounds for invoking a waiver
established under CERCIA
Primary Balancing Criteria: Technical criteria upon which the detailed analysis of
the alternatives is primarily based.
3. Long-Term Effectiveness and Permanence - Evaluation of expected residual risk and
the ability of each alternative to maintain reliable protection of human health
and the environment over time after cleanup requirements have been met.
4. Reduction of Toxicity, Mobility, or Volume through Treatment - Evaluation of the
degree to which an alternative employs treatment methods to reduce the
toxicity, mobility or volume of hazardous substances at the Site.
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5. Short-Term Effectiveness Evaluation of the period of time needed for each
alternative to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period.
6. Implementability - Evaluation of the technical and administrative feasibility of
each alternative, including the availability of materials and services.
7. Cost - Section 121 of CERCLA, 42 U.S.C. § 9621, requires selection of a cost-
effective remedy that protects human health and the environment and meets
the other requirements of the statute. Alternatives are compared using present
worth cost, which includes all capital costs and the operation and maintenance
costs incurred over the life of the project. Capital costs include expenditures
necessary to implement a remedial action (e.g., construction costs). All costs
presented are estimates calculated for comparison purposes only.
Modifying Criteria: Criteria considered throughout the development of the
preferred remedial alternative and formally assessed after the public comment period,
which may modify the preferred alternative.
8. State Acceptance - Assessment of technical and administrative issues and
concerns that the State may have regarding each alternative.
9. Community Acceptance - Assessment of issues and concerns the public may have
regarding each alternative based on a review of public comments received on
the Administrative Record and the Proposed Plan.
8.1 Overall Protection of Human Health and the Environment
Alternative 1 (No Action) contains no provisions for preventing exposure to
contamination and is not protective of human health and the environment. Because
Alternative 1 does not meet this threshold criteria, it will not be evaluated further.
The common elements in Alternatives 2, 3, and 4 include monitoring and
institutional controls to ensure that the alternatives are protective of human health
and the environment. Institutional controls will restrict the potential for use of
contaminated ground water. Ground water monitoring will track ground water
contaminant levels and monitor the effectiveness of the Site clean-up. The ecological
monitoring will ensure that Site-related contamination does not pose unacceptable
environmental risks.
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In Alternatives 2,3, and 4, either a waterline or home treatment units will
remove the potential current and future exposure of local residents to Site-related
contaminants. Therefore, Alternatives 2, 3, and 4 are considered equally protective of
human health. The pump and treat system considered under Alternative 4 would
reduce the amount of Site-related contamination reaching both the ground water and
the stream, decreasing the threats to both.
8.2 Compliance with ARARs
The Federal and State requirements or criteria that a Superfund remedy must
comply with are called Applicable or Relevant and Appropriate Requirements
(ARARs). In this section of the ROD, EPA has identified certain ARARs which the
alternatives must meet. The ARAR for Alternative 2. follows:
40 C.F.R. Part 141
Safe Drinking Water
Act '
Establishes Maximum Contaminant
Levels (MCLs) and non-zero
Maximum Contaminant Level Goals
(MCLGs)that would be allowed to
remain in ground water used for
drinking water; applies to water that
has been treated by the home
treatment units.
40 C.F.R. Parts
260-270;
COMAR26.13
Standards for
Generation,
Treatment, Storage or
Disposal of Hazardous
Waste
Establishes standards for the
handling of hazardous waste; applies
to wastes which may be generated
by the home treatment units.
In addition, 40 C.F,.R. Part 268 may be applicable if residues generated by the
home treatment units are land disposal restricted wastes.
The ARARs for Alternative 3 are as follows:
40 C.F.R. Part 141
Safe Drinking
Water Act
Establishes Maximum Contaminant
Levels (MCLs) and non-zero Maximum
Contaminant Level Goals (MCLGs)that
would be allowed to remain in ground
water used for drinking water; applies to
water delivered by the public water supply
line.
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Code of Maryland
Regulations
(COMAR)
26.04.04
Well
Construction
Includes requirements for construction
and abandonment of wells.
The ARARs for Alternative 4 include those which are pertinent to Alternative
3, plus the following:
16U.S.C661-
667e
Fish and Wildlife
Coordination Act
Coordinates Federal, State, public,
and private organizations in
protecting fish, wildlife, and their
habitats.
40 C.F.R. Part
261
COMAR
26.13.02
Identification and
Listing of Hazardous
Waste
Establishes the criteria for
determining if a solid waste exhibits
the characteristics of toxicity,
igniiability, corrosivity, or reactivity
or is a listed waste; applies to waste
generated during the ground water
treatment process.
40 C.F.R. Part
262
COMAR
26.13.03
Standards Applicable
to Generators of
Hazardous Waste
Establishes requirements for a
generator who treats, stores or
disposes of hazardous waste onsite;
applies to waste generated during the
ground water treatment process.
40 C.F.R. Part
263
COMAR
26.13.04
Standards Applicable
to Transporters of
Hazardous Waste
Establishes standards which apply to
persons transporting hazardous waste
within the State if the transportation
requires a manifest under COMAR
26.13.03; applies to offsite transport
of waste generated during the ground
water treatment process.
40 C.F.R. Part
264
COMAR
26.13.05
Standards for Owners
and Operators of
Hazardous Waste
Treatment, Storage
and Disposal Facilities
Establishes minimum State standards
which define the acceptable
management of hazardous waste;
applies to operation of the ground
water treatment plant.
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40 C.F.R. Pan
268
Land Disposal
Restrictions
Restrictions on land disposal and
certain storage of land disposal
restricted wastes which may be
generated by the treatment of
contaminated ground water.
COMAR
26.08.01
Maryland Water
Pollution Control
Regulations
Establishes Best Practicable Control
Technology Currently Available as
the requirement for water pollution
control; applies to treatment of
ground water.
COMAR
26.08.02
Maryland Water
Quality Regulations
Establishes designated uses of the
waters of the State and sets water
quality criteria based on protection
of these uses; applies to discharge of
treated ground water.
COMAR
26.08.03
Maryland Discharge
Regulations
Establishes discharge limitations for
point source discharges to surface
water; applies to discharge of treated
ground water.
33 U.S.CA
§1342
COMAR
26.08.04
Clean Water Act
Maryland Discharge
Permits
Establishes requirements for issuance
of permits for water discharge;
substantive (but not administrative)
requirements apply to discharge of
treated ground water.
8.3 Long-term Effectiveness and Permanence
The Site caps are expected to reduce the impacts of Site contamination to the
ground water, surface water and sediment. The monitoring provisions of the common
elements will track any changes in ground water quality over time. The land use
restrictions will prevent any disturbance of the caps that could reduce their
effectiveness or cause a release of the contaminated fill material beneath them.
Alternative 2 (Home Treatment Units) provides an immediate supply of safe
drinking water to those residences that are impacted by the Site. The reliability and
effectiveness of the home treatment units will depend on consistent ground water
monitoring and adequate maintenance of the units. This option would require a
greater degree of regular monitoring and maintenance than the other alternatives to
ensure the continued protection of human health.
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Alternative 3 (Waterline) provides a permanent, safe and reliable water supply
to all currently impacted residences, as well as those that may be impacted in the
future. This alternative would not require the regular monitoring of residential wells
or maintenance of the treatment units as would Alternative 2, and thus is a more
reliable source of safe drinking water.
Alternative 4 (Pump and Treat, Waterline) would result in the removal and
treatment of Site-related contaminated groundwater from beneath the Site, and
therefore, may provide greater overall effectiveness than either a waterline or home
treatment units. Furthermore, pumping and treating the ground water would reduce
the amount of contamination leaving the Site and impacting the stream.
8.4 Reduction of Toxicity, Mobility or Volume through Treatment
. Alternative 4 is the only alternative that has the potential to reduce the volume
of contaminated ground water at the Site, as it is the only alternative that includes
active treatment to reduce the contaminant levels at the source area. However,
because of the fractured bedrock, it would be difficult to implement a program that
would effectively capture and treat the contaminated ground water. In addition, the
caps installed over the contaminated areas during the OU1 Interim Remedial Action
are expected to reduce the levels of contaminated ground water leaving the Site over
time.
8.5 Short-term Effectiveness
Because the monitoring provisions of the common elements are a continuation
of actions already being taken pursuant to the OU1 ROD, no additional construction
or start up period would be necessary. The deed restrictions could be implemented in
less than one year.
Installation of home treatment units (Alternative 2) would be easier and
quicker than the construction of a waterline or a pump and treat system. While the
design of a waterline could take some time, the actual construction of the waterline
(Alternatives 3 and 4) would only require a few months. In the interim, the PRPs are
required, under the terms of the April 1994 AOC, to provide residences with
excessive levels of Site contaminants in their well water with bottled drinking water
until the selected remedial action has been fully implemented. Thus, the impacted
residences would not be at risk during the time required to construct any of the
alternatives.
The design and construction of the pump and treat system included in
Alternative 4 would likely take up to one year longer than the design and
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construction of the water line. Because this construction work would take place
onsite, the only additional risk to the community would be posed by the increased
traffic in the vicinity of the Site. The risk to workers would occur primarily during
the installation of the extraction wells through potential contact with contaminated
ground water. The workers could be protected from any potential hazards through a
properly implemented and enforced health and safety plan.
8.6 Implementability
Because the monitoring provisions of the common elements are a continuation
of actions already being taken pursuant to the OU1 ROD, implementability is not an
issue. Because the Site owners are PRPs, it is expected that they will agree to
implement deed restrictions on the Site properties.
Under Alternative 2, the use of home-treatment units is technically feasible, as
the equipment is readily available. Long-term maintenance of the systems would be
required in order to ensure that the units remain effective. This type of maintenance.
may be difficult to implement over the assumed 30-year O&M period. Any expended
resin cartridges (or other waste products) from each unit would require regeneration
or disposal, possibly as a hazardous waste.
There are no foreseeable implementability concerns for Alternative 3. This
alternative employs standard construction techniques and demonstrated and reliable
technologies.
Implementation of the ground water pump and treat portion of Alternative 4
may not be feasible for a number of reasons. Because there is no clearly discernable
contaminant plume, it would be difficult to properly locate the extraction wells. It is
questionable whether an extraction system could be designed which would effectively
contain or capture Site-related contaminants since their distribution is not clear. In
addition, the pumping of water at the Site could mobilize contaminants from other
sources, including the City Dump, which is located adjacent to the Site. Also, metal
sludge generated during the treatment process would require temporary onsite storage
in compliance with 40 C.F.R. Parts 264 and 268 and eventual offsite disposal.
8.7 Cost
The estimated present worth cost of Alternative 2 (home treatment units) is
$608,000. Based on verbal quotations received from vendors, the capital cost
(equipment and installation) would be approximately $268,000 for 19 units. It was
assumed that over the next 30 years, one replacement unit would be required at each
location. O&M costs would be approximately $34,000 annually.
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The estimated present worth cost of Alternative 3 (waterline) is $873,400.
This includes a capital cost $683,000, and O&M costs of approximately $19,000
annually.
The estimated present worth cost for Alternative 4 (pump and treat and
waterline) is $4,766,500. The capital cost of $1,766,500 includes the waterline, the
pump and treat system, a water treatment plant, and a discharge line. The annual
O&M costs will be approximately $300,000.
8.8 State Acceptance
The Maryland Department of the Environment (MDE) was sent a draft of the
ROD on June 5, 1996, and by letter of June 12, 1996, indicated that it had no
comments on the ROD. A revised draft of the ROD was sent to MDE on June 20,
1996, along with a request for concurrence on the ROD. The State has verbally
indicated a willingness to concur, but wishes to see the final version before doing so in
writing. '
8.9 Community Acceptance
A public comment period on the Proposed Plan was held from April 15 to May
14, 1996 and a public meeting was held to discuss the plan and the SRI and SRS on
April 24, 1996, as described in Section 3 of this ROD. As shown in the
Responsiveness Summary section, the comments received during the meeting were
supportive of EPA's preferred remedy. Letters received from local officials during the
public comment period were also supportive of the remedy.
9.0 Selected Remedy and Performance Standards
After consideration'of the requirements of GERCLA, the detailed analysis of
the alternatives using the nine criteria, and public comments, EPA has determined
that Alternative 3, Waterline plus Common Elements, is the most appropriate remedy
for the Limestone Road Superfund Site. This alternative meets the threshold criteria
of overall protection of human health and the environment and compliance with
ARARs, and provides the best balance of long-term effectiveness and permanence,
reduction of toxicity, mobility or volume of contaminants through treatment, short-
term effectiveness, implementability, and cost.
The selected remedy consists of the following major components:
28
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» Installation of a waterline and ancillary equipment (a pumping station and fire
hydrants) to service residents in the vicinity of the Site. The waterline will be
of sufficient capacity to meet the needs of both current and reasonably
expected future development of the area; and
* Implementation of deed restrictions on the previously capped areas of the Site
to prevent use of such areas in such a manner as would cause disturbance of
the caps;
* Implementation of a ground water management program to prevent
installation of drinking water wells in the vicinity of the Site;
Continuation of the long term ground water, surface water, and sediment
monitoring plans currently being implemented pursuant to the ROD for OU1;
* Abandonment of existing residential water supply wells.
The proposed alignment of the waterline is shown in Figure 2.
10.0 Statutory Determinations
EPA's primary responsibility at Superfund sites is to select remedial actions
that are protective of human health and the environment. In addition, Section 121
of CERCLA, 42 U.S.C. § 9621, establishes several other statutory requirements and
preferences. These requirements and preferences specify that, when complete, the
selected remedial action for a site must comply with applicable or relevant and
appropriate requirements established under Federal and State environmental laws,
unless a statutory waiver is justified. The selected remedy must also be cost-effective
and utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. The statute also expresses
a preference for remedies that employ treatment as a principal element.
10.1 Protection of Human Health and the Environment
The selected remedy for the Site will provide adequate protection of human
health and the environment as follows: the institutional controls will prevent the
future use of the landfilled areas such that the integrity of the caps would be
compromised, thus preventing direct contact with the fill material, and would prevent
the installation of a drinking water well into the fill area; the ground water, surface
water and sediment monitoring will track what are expected to be decreasing levels of
contaminants in these media (due to the site caps); and the waterline will provide safe
29
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drinking water for area residents, eliminating their reliance on ground water for a
drinking water supply.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
Under Section 121(d) of CERCLA, 42 U.S.C. § 962 l(d) and EPA guidance,
remedial actions at Superfund sites must attain legally applicable or relevant and
appropriate Federal and State environmental standards, requirements, criteria, and
limitations (collectively referred to as ARARs). Applicable requirements are those
substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that specifically address hazardous material
found at the site, the remedial action to be implemented at the site, the location of
the site, or other circumstances at the site. Relevant and appropriate requirements
are those which, while not directly applicable to the site, nevertheless address
problems or situations sufficiently similar to those encountered at the site that their
use is well suited to that site.
f
The selected remedy will comply with all applicable or relevant and appropriate
requirements. These ARARs are presented in Section 8.2 (Compliance with ARARs).
10.3 Cost-Effectiveness
Section 300.430(f)(l)(ii)(D) of the NCP, 40 C.F.R § 300.430(f)(l)(ii)(D),
requires EPA to evaluate cost-effectiveness by first determining if the alternative
satisfies the threshold criteria: protection of human health and the environment and
compliance with ARARs. The effectiveness of the alternative is then determined by
evaluating the following three of the five balancing criteria: long-term effectiveness
and permanence, reduction of toxitity, mobility, or volume through treatment, and
short-term effectiveness. EPA has determined that the selected remedy will satisfy
the threshold criteria and jnost effectively address the threats presented by
contaminated ground water at the Site. The estimated present worth costs are
$873,000. The selected remedy is cost effective because the cost is proportional to
the overall effectiveness as compared to the other alternatives that were considered.
10.4 Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent
to which permanent solutions and alternative treatment technologies can be utilized
in a cost-effective manner at the Site. The waterline will provide a permanent source
of safe drinking water to the residents living in the vicinity of the Site. While
pumping arid treatment of the contaminated ground water was considered, this
30
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alternative was not selected because the effectiveness of such a system is highly
questionable due to the nature of the impacted aquifer (fractured bedrock). Also, the
system could possibly exacerbate the problem by pulling contaminants from another
local source (the City Dump). Finally, the caps installed during the OU1 Interim
Remedial Action are expected to reduce impact of the Site on the ground water and
surface water over time.
10.5 Preference for Treatment as a Principal Element
There are no treatment technologies in the selected remedy. As discussed in
Section 10.4, treatment was not considered practicable at this Site due to the nature
of the contaminated media and the expectation that the caps will reduce the Site
impacts to ground water and surface water over time. These impacts will continue to
be monitored as a part of this selected remedy.
11.0 Documentation of Significant Changes
EPA issued the Proposed Remedial Action Plan for OU2 of this Site for public
review and comment on April 15, 1996, and held a public meeting to discuss the plan
on April 24, 1996. The local community, including the local public officials, were
supportive of the then proposed (now selected) remedy identified by EPA
EPA received three letters containing comments during the comment period.
Two were from local officials and were again supportive of EPA's plan. The third
letter was from Conestoga-Rovers &. Associates (CRA), a firm that has served as the
prime contractor for the PRPs during the SRI and the interim remedial action. EPA
agreed with many of the comments in the letter, which are addressed in the
Responsiveness Summary section of this ROD.
Among other things, CRA commented on the monitoring provisions of the
proposed plan. Specifically, EPA's proposed plan called for quarterly monitoring of
ground water, surface water and sediment for both organic and inorganic
contaminants, as well as bioassays. CRA suggested that the extant interim
monitoring plan, which currently includes quarterly monitoring of these same media
for inorganics, was adequate to meet the needs of the project since the contaminants
of concern, as identified in the SRI and presented in the ROD, are inorganics. EPA
agrees, and has modified the selected remedy accordingly.
31
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Figure 1
- SITE LOCATION MAP
LIMESTONE ROAD SITE SRI
Cumberland, Maryland
-------
,.'--1
/O JOO 40QII
\ \
\^ V
CUMBERLAND \ \
CITY DUMP x- \
\
\
---- PROPER I Y LINE
RESIDENTIAL WELL LOCATION
EXISTING WATER MAIN
PROPOSED 6'* MAIN
PROPOSED DOMESTIC SERVICE
ALTERNATIVE WATER SUPPLY
SUPPLEMENTAL FEASIBILITY STUDY
LIMESTONE ROAD SITE
Cumbertand. Maryland
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Table 1
Concentrations of Total and Dissolved Metals in Site Monitoring Wells Compared to
MCLs and Risk-Based Concentrations (RBCs)
values in ug/\
Metal
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Thallium
Vanadium
Zinc
Range, dissolved
n.d.-1080
n.d.-31.6
10.6-441
n.d.-0.31
n.d. - 3.3
2870 - 394,000
n.d. - 27.9
n.d. - 40
n.d. - 7.3
n.d. - 45,000
n.d. - 10.1
n.d.- 186,000
17.5-3050
n.d.-0.15
n.d.-180.
543 - 35,200
n.d. - 5.5
17,100-1,800,000
n.d.-1.3
n.d. -2.5
n.d. - 332
Range, total
n.d. - 4760
n.d. - 230
n.d. - 934
n.d.-1.7
n.d. - 10.0
3610 - 420,000
n.d. - 144
n.d.'- 152
n.d. - 287
n.d. - 191,000
n.d. - 504
n.d.-165,000
6.8-37,000
n.d. - 0.4
n.d. - 328
n.d. - 32,900
n.d. - 6.9
12,000 - 2,390,000
n.d.
n.d. -54
n.d. - 1520
RBC
11,000
. 0.045
2600
0.02
18
-
180
2200
1500
-
'
-
800
37
730
-
18
-
2.9
260
11000
MCL
-
50
2,000
4
5
-
100
-
1300
-
15
-
-
2
100
-
50
-
2
-
. -
n.d. = not detected
32
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Table 2
Concentrations of Metals in Site Surface water and Sediment compared to BTAG screening
levels (Flora/Fauna)
Metal
Aluminum
Arsenic.
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
HexCr.
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Surface Water
Range, dissolved
n.d. - 20.200
n.d. 4.4
n.d. - 330
n.d.-31
n.d. - 44
26300-351.000
n.d. - 58
n.d.- 151
n.d. - 50
n.d. - 0.05
n.d. - 39.000
n.d. - 86
4350-177,000
n.d. - 86.200
n.d. - 40
n.d. - 4000
n.d. - 224.000
n.d. - 5.2
n.d. -18,000
n.d.- 1.000.000
n.A-70
n.d.
n.d. - 15300
Surface water
Range, total
n.a.
n.d.
n.d.- 197
n.a.
n.d.-1.3
39.900 - 294,000
n.d.
n.a.
n.d.-9.1
n.a.
n.d.-l!2
n.d. - 2.9
4790-118.000
n.d. - 103
n.a.
n.d. - 15.7
1900-207.000
n.d
n.a.
1960-516.000
n.a.
n.a.
n.d. - 982
BTAG Screening
Level
460/200
-/874
-yi o.ooo
100.000/5.3
1.1/0.15
/
-/210
--/-
-/6.5
2/1
-/320
-/I
/-
-/-
-/0.012
-/14.77
-/-
522/3
1.9/0.0001
-/-
/40
-/<10.0
110/110
Sediment
Range
1600-33,000
n.d. - 38
84 - 626
n.d.-3.8
n.d. - 80
n.d. - 63,000
n.d. - 90
n.d. -160
n.d. - 136
n.d. - 0.08
5750 - 66300
13.4-220
n.d. - 10,000
n.d. - 178,000
n.d.-0.21
n.d. - 729
n.d. - 5000
n.d.- 1.4
n.d. - 4.9
n.d. - 10300
n.d.
n.d. - 50
24-31.900
BTAG
Screening Level
-/-
- /8.200
-/
-/
676/-
-/
5/260,000
- --/-
-/34.000
/<8 1.000
-/-
-/46.700
-/-
-/-
-/150
-/20.900
-/-
-/-
-/733
-/-
-/-
-/-
-/1 50,00
n.d.
n.a.
not detected
not analyzed
33
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Table 3 - Exposure Assumptions
Ground water ingestion scenario
Average and Maximum expected exposures
Variable
Chemical Concentration
Ingestion rate (liters/day)
Body weight (kilograms)
Exposure frequency (days/year)
Exposure duration - carcinogen
(years)
Exposure duration - noncarcinogert
(years)
Averaging time - carcinogen (years
x days)*
Averaging time - noncarcinogen
(years x days)*
Value, Child
Average
mean
1
15
350
10
1*
25550
365
Maximum
maximum
1
15
350
30*
1*
25550
365
Value, Adult
Average
mean
2
70
350
10
1*
25550
365
Maximum
maximum
2
70
350
30
1*
25550
365
*These values are non-standard for EPA-approved risk assessments; however, they do not
change the net result of the risk assessment.
Table 4 - Cancer Potency Slopes and Reference Doses (RfDs) for
Contaminants of Concern (COCs) .
coc
Arsenic
Cadmium
Copper
Manganese
Nickel
Zinc
Cancer Potency Slope
- (mg/kg/dayV1
1.5
n.c.
n.c.
n.c.
n.c.
n.c.
RfD
(mg/kg-day)
3.00 x 10-4
5.00 xlO"4
3.70 x 10'2
2.40 xlO'2
2.00 xlO'2
3.00 x 10''
n.c. = non-carcinogen
34
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Table 5 Maximum Cancer Risk and Hazard Indices
Onsite wells - average concentration
Onsite wells - maximum concentration
Offsite wells - average concentration
Offsite wells - maximum concentration
Cancer Risk
3-llxlO-4
7.94X10-4
2. 34x1 0'5
9.04xlO'5
Hazard Index
8.06
8.48
7.39
19.2
Cancer risk is, in all cases, driven by arsenic, which does not exceed the Maximum
Contaminant Level (MCL).
Except for the "offsite wells - maximum concentration," hazard indices are driven by
manganese; in this case, it is driven by cadmium, which exceeds the MCL.
35
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Record of Decision
Limestone Road Superfund Site
Part 3 Responsiveness Summary
This Responsiveness Summary documents public comments expressed to EPA on the
Proposed Remedial Action Plan for OU2 of the Limestone Road Superfund Site and EPA's
responses to those comments. The information is organized as follows:
A Overview
B. Comments Received During the Public Meeting
C. Written Comments Received During the Comment Period
A. Overview
EPA held a public comment- period from April 15 through May 14, 1996, to receive
comments from the public on the Supplemental Remedial Investigation and Supplemental
Feasibility Study (SRI and SFS) reports and the Proposed Remedial Action Plan ("Proposed
Plan") for OU2 of the Limestone Road Superfund Site. EPA held a public meeting on April
24,1996 at 7:00 at the District 16 Fire Hall in Cumberland, Maryland. The public meeting
was attended by EPA and Maryland Department of the Environment (MDE) staff, local
residents, public officials, and representatives and consultants of the Potentially Responsible
Parties (PRPs). The transcript from the public meeting is in the Administrative Record for
the Site.
The purpose of the meeting was to present and discuss the findings of the SRI/SFS
and to apprise the meeting participants of EPA's preferred remedial alternative for OU2.
Comments received during the meeting and written comments received throughout the public
comment period are presented below, along with EPA's response.
B. Comment RecehredUDuring the Public Meeting
1. A community member asked how EPA would select the final alternative to address the
ground water.
EPA RESPONSE: EPA relies on public input during the clean-up process so that the remedy
for each Superfund site meets the needs and concerns of the local community. EPA has, in
the past, reviewed public input and recommendations on a proposed clean-up remedy and
changed that remedy to address the community's concerns. EPA will review all of the
comments received from the community during the public meeting and those submitted in
writing during the public comment period. After reviewing these comments, EPA will select a
final alternative and announce this selection in a document called a Record of Decision. In
addition, EPA will place a public notice in the Cumberland Times News to inform the
36
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community of the Record of Decision. EPA may also produce a brief fact sheet highlighting
the selected remedy and send the fact sheet to each person on the Site mailing list.
2. A community member asked who will pay for the cost of constructing the proposed
waterline or any of the proposed remedies.
EPA RESPONSE: Once EPA selects its final alternative, EPA will negotiate with the PRPs to
pay for the costs of the remedy including the construction, maintenance, and initial hook-up
to the existing residences. If EPA is unsuccessful in coming to an agreement with the PRPs,
then money from the Superfund trust fund may be used to pay for the selected remedy. If
money is used from the trust fund, EPA will continue to pursue the PRPs to recover the
money spent on implementing the selected remedy.
3. A community member asked EPA to identify the PRPs at the Site.
EPA RESPONSE: EPA has identified Joseph and Patricia Diggs, Fairchild Industries,
Cumberland Cement and Supply Company, and Kelly Springfield Tire Company as the PRPs
at the Limestone Road Site. These parties, with the exception of Joseph and Patricia Diggs,
have entered into agreements with EPA to perform work'at the Site, including capping and
fencing the landfilled areas, supplying bottled water to local residents, and conducting the
supplemental groundwater and stream studies.
4. A community member asked why parties responsible for Site contamination are
identified by EPA as only potentially responsible.
EPA RESPONSE: The CERCLA statute provides the definition of a PRP. They are
considered to be "potentially responsible" until such time as their liability is established by a
court of law.
5. A community member asked how EPA identifies parties responsible for contamination
and how they are involved in the cleanup.
EPA RESPONSE: CERCLAJ107 identifies four categories of individuals or organizations
that are responsible parties: current site owners or operators; owners or operators of the site
at the time hazardous substances were disposed of at the site; certain persons who arranged
for treatment or disposal of hazardous substances at the site; and certain persons who
transported hazardous substances to the site. EPA attempts to compel these parties to
perform or pay the costs associated with the cleanup at a site. However, some parties are
financially unable to provide support to the cleanup, so EPA will use money from the
Superfund trust fund, which is established through a tax on the chemical and petroleum
industries, to pay for the costs associated with the cleanup.
6. A community member asked if EPA's final decision on a selected remedy depends on
the willingness of the PRPs to pay for implementing the remedy.
37
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EPA RESPONSE: EPA's final decision on a selected remedy does not depend on the
willingness of the PRPs to pay for implementing the remedy. However, the NCP requires
EPA to consider the cost effectiveness of a proposed remedy. If the PRPs choose not pay for
the remedy, EPA may pay for the remedy using Superfund trust monies and pursue the PRPs
through court action to recover the costs for the remedy. EPA may also issue an order to the
PRPs requiring them to implement the remedy.
7. A community member asked where the proposed waterline would be placed, what size
it would be, and how far it would extend.
EPA RESPONSE: The proposed waterline is in the conceptual stages and has yet to be
designed. If EPA selects the waterline alternative, the location, size, and length will be
addressed during the design stage. Currently, there is an existing water main located on
Route 51 that could be used to connect a waterline to provide service for the residents in the
Site area.
8. A community member asked how long it would take to install the proposed waterline
if Alternative 3 is selected as the remedy.
EPA RESPONSE: Once EPA selects a final remedy, the Agency will attempt to negotiate
with the PRPs to conduct the work needed to implement the selected remedy. This work will
include preparing the designs and specifications and constructing and implementing the
selected remedy. EPA estimates that construction will be completed in approximately two
years.
9. A community member asked if local residents will be responsible for any of the costs
associated with installing the proposed waterline.
EPA RESPONSE: Local residents and community members will not be responsible for any
of the costs associated with constructing or installing the proposed waterline. EPA will
negotiate the costs with the PRPs or utilize the Superfund trust monies to cover the costs of
constructing and installing the proposed waterline. However, residents will be responsible for
paying future bills for water service.
10. A community member asked if installing a sewage system is included as part of the
waterline alternatives in the Proposed Plan..
EPA RESPONSE: A sewage system is not included in EPA's proposed waterline alternatives
at the Site. Any information on installing a sewage system would be handled by local
government and not EPA
11. A community member asked about the projected costs for installing the proposed
waterline.
EPA RESPONSE: The current projected cost of the proposed waterline work, including
constructing, installing, and monitoring, is $875,000.00.
38
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12. A community member asked if the proposed waterline will be large enough to service
more than the 19 houses listed in the Proposed Plan.
EPA RESPONSE: The size of the proposed waterline will be addressed and determined
during the design stage of the project. Areas that are currently impacted by the Site or may
be impacted in the future will be included in the area to be serviced.
13. A community member asked if the American Legion property (baseball field) would be
included in the hook-up to the proposed waterline.
EPA RESPONSE: The proposed waterline will be designed to have a capacity to provide
service to the entire Site area, including this property.
%
14. A community member asked EPA to explain the deed restrictions on the landfill
properties that are listed under Alternative 3 in the Proposed Plan.
EPA RESPONSE: The deed restrictions that are listed under Alternative 3 are designed to
prevent someone from installing a well through the landfill caps, building a structure on top _
of the landfill caps, or using ground water affected by contamination at the Site.
15. A community member asked if the residential wells will be capped in EPA's
recommended alternative and if well water can be used to water lawns and wash cars.
EPA RESPONSE: In order to prevent future exposure to contaminated ground water, EPA's
selected remedy includes capping the residential wells once the water line is in place.
Therefore, once the remedy is installed, residents would not have access to the well water for
use on their lawns or cars.
16. A community member asked what contaminants are currently in the ground water and
whether EPA found contamination in Evitts Creek or the Potomac River.
EPA RESPONSE: Sampling results revealed elevated levels of nickel, manganese, and
cadmium in the ground watet. In addition, slightly elevated levels of lead were detected;
however, it is not known if the lead is present as a result of the Site or residential plumbing.
Sampling results from Evitts Creek revealed elevated levels of nickel, manganese, lead,
chromium, cadmium, and zinc. Because of the size of the Potomac River, any contamination
migrating from the Site to the Potomac River would not be detectable because of dilution.
Therefore, EPA did not sample the water in the Potomac River.
17. A community member commented on the inconsistency of contamination showing up
in their wells and asked if EPA will continue to sample and monitor the residential
wells for contamination until the selected remedy is implemented.
EPA RESPONSE: The PRPs, under the direction of EPA, continue to test a number of
residential wells in an effort to monitor the type and amount of contamination in the Site
area. The sampling will continue if necessary until the waterline is in place.
39
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18. A community member commented that a local resident was taken off of bottled water
because sampling showed that contaminants, which were once present in the resident's
well, were no longer detected. The community member asked what criteria EPA uses
to determine whether residences can be taken off the bottled water supply.
EPA RESPONSE: EPA identified certain criteria and health-based levels for contamination
in the 1994 Administrative Order on Consent with the PRPs. Residential wells were sampled
for one year, and if the data indicated that the wells were not, in fact, contaminated, the
resident was taken off bottled water.
19. A community member asked if there are any potential risks associated with currently
using contaminated well water to water lawns or wash cars.
EPA RESPONSE: The risk posed by the contaminants in the ground water is through
direct, long-term ingestion. In addition, the contaminants remain in the water and do not
dissipate into the air. Therefore, the contaminated ground water does not pose any short-
term risks when used to water lawns or wash cars.
20. A community member commented that a house is currently under construction near
the Site. The community member asked if EPA would provide bottled water to that
residence once it is completed or would the homeowner need to have a well installed
and sampled to determine if that well is contaminated.
EPA RESPONSE: EPA can not determine if the ground water in that area is contaminated
without installing a well. However, if a well is installed at this property and sampling
indicates that the water is contaminated, bottled water would be provided to that residence
pursuant to the AOC.
21. A community member asked about the type of waste dumped at the Site and if the
waste posed an immediate danger to the community.
EPA RESPONSE: A majority of the waste at the Site is residential and industrial debris and
trash. However, some hazardous wastes, including chromium, lead, and cadmium, were
disposed on both properties of the Site. These contaminants pose a risk to human health and
the environment through long-term direct contact or direct exposure (ingestion). The cap
and fencing previously installed will prevent direct contact with the contaminants and the
alternate water supply will prevent direct exposure to the contaminants.
22. A community member asked if the contaminants at the Site could get into the air and
endanger the local residents who live immediately near the Site.
EPA RESPONSE: The exposed wastes at the Site have been capped, thereby preventing the
possibility of the contaminants becoming airborne.
40
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23. A community member asked EPA to explain how they capped the exposed waste and
asked how long the caps will last.
EPA RESPONSE: The cap consists of four layers. The first layer above the landfill is a soil
base; the second layer is a synthetic liner; the third layer is a drainage layer, and the final
layer is a two-foot layer of soil. The cap prevents water from coming in contact with the
waste and reduces the spreading of contamination off-site. In addition, fences were erected
around the capped areas. The cap will be evaluated on a regular basis to ensure that it
maintains its effectiveness. Currently, the PRPs are maintaining the cap, sampling the
ground water every three months, and performing inspections of the cap to ensure that there
is no significant erosion. The PRFs activities are closely monitored by EPA and the State of
Maryland.
C Written Comments Received During the Comment Period
EPA received three letters of comment during the public comment period for the
Proposed Plan; two were from local officials, and the third was from Conestoga-Rovers and
Associates (CRA), prime contractor to the PRPs.
1. The first letter received was from the Allegany County Health Department. In
addition to supporting the selected remedy, the Department also requested that three
comments become a part of the Site record:
1.) Connection to a newly constructed public water supply must be mandated
by regulation or local code home rule ordinance; and
2.) After connection to the public water supply, all domestic groundwater
supplies (e.g., wells) formerly serving these residents must be abandoned and
sealed in conformance with Code of Maryland Regulations 26.04.04 - Well
Construction; and
3.) All tap connections to the public supply must be inspected by the
appropriate County authority. Similarly, severance of connections from former
groundwater supplies must be inspected to eliminate any possibilities of cross-
contamination.
EPA Response: All written comments are included in the Administrative Record for the Site
2. The second letter received was from the Allegany County Department of Public
Works. In addition to supporting the proposed remedy, the County asked that EPA consider
a currently planned water supply project "as the solution to the Limestone Road Site rather
than proceeding to have the PRPs provide the water system."
EPA Response: EPA will keep the County's willingness and proven ability to provide public
water service in mind when planning the implementation of the selected remedy.
41
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3. The final letter received was from CRA. They, too "agree that USEPA's proposed
remedial action ... is the most appropriate remedial action of those [presented in the
Proposed Plan] in light of the conditions at the Site." Additional comments are summarized
below:
A. CRA discusses the change in Reference Dose (RfD) for manganese between the time
the SRI and risk assessment were completed and the time the Proposed Plan was
prepared, and recommends the new RfD be used in the preparation of the ROD.
EPA Response: The hazard index values presented in the Proposed Plan do reflect the new
RfD; it was used in preparation of the ROD, as well.
B. CRA suggests the Proposed Plan was misleading in that it didn't mention that the
streams near the Site "also would receive runoff from other properties which are likely
to contribute contaminants (e.g., the City Dump)."
EPA Response: The City Dump is not a part of the Superfund Site and thus was not
discussed in detail in either the Proposed Plan or this ROD. EPA agrees that the City Dump
has contributed and may still contribute contaminants te the tributary to Evitts Greek, which'
also flows by the Diggs Property.
C. CRA suggests that the Proposed Plan was misleading regarding the presence of lead in
residential wells, stating that currently, only one residential well has shown an
exceedance of the EPA Action Level.
EPA Response: While CRA's statement is correct regarding recent sampling, data from the
OU1 RI/FS show lead in residential wells at levels of up to 134 ppb.
D. CRA discusses in detail the differences between the monitoring requirements of the
various alternatives and the associated differences in cost associated with the
requirements and suggests these differences are not taken into account in the Propose
Plan. For example, Alternative 2 would require substantially more residential well
monitoring than Alternatives 3 or 4 because under those alternatives, residential wells
would be abandoned, thus, the monitoring costs associated with Alternative 2 would
be higher than those associated with Alternatives 3 and 4.
EPA Response: These differences were, in fact, taken into account in the cost estimates
presented in both the Proposed Plan and this ROD.
E. CRA suggests that the groundwater "monitoring program for the remedial action
. should build upon the existing [Interim Monitoring Program], and not commence
with up to five years of quarterly sampling as proposed in the Proposed Plan." They
further maintain that there is no need for surface water and sediment monitoring at
the Site because the caps have eliminated the potential for contaminants to migrate to
the streams via surface runoff.
42
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EPA Response: Upon further consideration, EPA agrees that it is appropriate for the
monitoring provisions of this ROD to mirror those currently required under the Interim
Monitoring Program and has altered the provisions of the Proposed Plan accordingly. The
issue of continued monitoring of the stream will be revisited when the current years'
monitoring data are reviewed.
F. CRA states that Alternative 3 "could be implemented in the shortest time frame,'' and
further suggests that because "(t)he design and installation ofywaterlines are standard
civil engineering practices .. .Detailed review of this component of the remedial
action by the USEPA, the Army Corps of Engineers, or USEPA's oversight contractor
would not be necessary."
EPA Response: EPA does not agree that Alternative 3 could be implemented in the shortest
time frame; it would be more expeditious to provide home treatment units to local residents
(as provided for under Alternative 2). However, the estimated time difference for
implementation between those twd alternatives is months and residents with elevated levels
of contaminants in their wells would continue receiving .battled water during this period.
EPA does agree, however, that the design and installation of a waterline is a standard civil
engineering practice and will take a streamlined approach to the oversight of this work,
should the PRPs agree to undertake it.
G. CRA and the Settlors suggested that EPA include in the ROD language to the effect
that under the pump and treat scheme proposed under Alternative 4, "capture of
contaminants by pumping from the aquifer would be difficult due to the fractured
nature of the bedrock aquifer. Therefore, Alternative 4 may not be reliable over the
long term."
EPA Response: EPA generally agrees with this statement. See Section 8.6 of the Decision
Summary.
43
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LIMESTONE ROAD OU2
.ADMINISTRATIVE RECORD FILE * **'
INDEX OF DOCUMENTS
II. REMEDIAL ENFORCEMENT PLANNING '
1. Complaint, In the United States District Court for the
: District of Maryland, United States of America,.
Plaintiff, v. Fairchild Industries, Ij^c. and Cumberland
Cement and Supply Co., Defendant, (undated).
P. 200001-200011.
2. Partial Consent Decree, In the United States District
Court for the District of Maryland; Civil Action No.
R.-88-2933; United States of America,,et al.,
Plaintiffs; v. Fairchild Industries, Inc. and
Cumberland Cement and Supply Co., Defendants,
(undated) . P. 200012-2000.71.
3. Letter to Mr. Tracy Getz, Winston & Strawn, from Ms.
Cynthia Nadol'ski, U.S. EPA, re: Interpretation ,-of the"-
language in the Partial Consent Decree describing the
procedures EPA uses to approve or disapprove of plans,
reports, or. proposals, 1/23/92. P. 200072-200073.
4. Letter to Mr. Danald [sic] Rose from Mr. S. Andrew
Sochanski, U.S. EPA, re: Consent for Access or Right,
of Entry to Mr. Rose's property, 1/31/92.. P. 200074-
200074. . '
5. Letter to Mrs. Viola Piper from Mr. S. Andrew
Sochanski, U.S. EPA, re: Consent for Access- or Right
of Entry to Ms. Piper's property, 1/31/92. P. 200075-
' 200075.. ..->-.
* -
6. Letter to Mr. Ray Brabson from Mr.-S. Andrew Sochanski,
U.S. EPA, re: Consent for Access or Right of Entry to
Mr. Brabson's property, 1/31/92, P. 200076-200076.
7. Letter to Ms. Viola Piper from Mr. S: Andrew Sochanski,
U.S. EPA, re: The .signed Consent for Access or Right
. of Entry to Ms. Piper's property, 1/31/92. P. 200.077-
200079. The Consent for"Access is attached.
* 'Administrative Record File available 3/11/91, updated
3/27/92, 2/2/93, 10/18/93, and 4/11/96.
.*'* . Further information pertaining Limestone Road OU2 can be
found in the Administrative Record File for Limestone Road
OU1.
-------
8. Letter to Mr. and Mrs. Ray. Brabson from Mr. S. Andrew
Sochanski, U.S. "EPA, re: The signed Consent for Access
or Right of Entry to the Brabson's property, 1/31/92.
P. 200080-200082. The Consent for Access is attached.
9. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Philip M. Andrews, Kramon & Graham, re: Clarification
of requirements in the Consent Decree not being
fulfilled, 2/18/92. P. 200083-200085.
/
10. Consent for Access to Property, signed by Mr. Donald R.
Rose, 3/18/92. P. 200086-200088. A site map is
attached.
11. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Philip M. Andrews, Kramon & Graham, re: Notice of
violation letter sent to Cumberland Cement and Supply
and Fairchild Industries, Inc., 4/2/92. P. 200089-
200090. '
12. Letter to Mr. Philip M. Andrews, Kramon & Graham, from.
Mr. S. Andrew Sochanski, U.S.'EPA, re: Non-compliance
with the Consent Decree, 4/24/92. P. 200091-200092.
13. Letter to Mr. Philip M. Andrews, Kramon & Graham, from
Mr. S. Andrew Sochanski, U.S. EPA, re: Non-compliance
with the Consent Decree, 5/5/92. P. 200093-200094.
14. Letter to Ms. Cynthia Nadolski, U.S. EPA, from Mr. B.
Michael Hodge, The Fairchild Corporation, re:
Replacement of Mr. Tracy Getz of Winston & Strawn as
counsel for Fairchild Industries, Inc., 10/1/92.
P. 200095-200095. .
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III. REMEDIAL RESPONSE PLANNING
1. Report: Work Plan for the Supplemental Remedial
Investigation/Feasibility Study (SRI/FS) and Remedial
Design/Remedial Action (RD/RA) at the Limestone Road
Site, Cumberland. Maryland..prepared by Geraghty and
Miller, Inc., 5/88. P. 300001-300076.
2. National Priorities List (NPL) Site Certification,
Limestone Road Site, Cumberland, Allegheny Co.,
Maryland, 4/21 to 22/90. P. 300077-300077.
3. Letter to Mr. Robert Davis, U.S. EPA, from Mr. John P.
Wolflin, U.S. Department of the Interior (DOI), re:
Site biological characterization, 7/13/90. P. 300078-
300080. A map showing additional sampling locations is
attached. .
4. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
John P. Wolflin, U.S. DOI, re: Presence of endangered
species at the 'site, 10/4/90. :: P. 3.00081-300082.
' ' *ff'
5. Letter to Mr. S. Andrew'Sochanski, U.S. EPA, from Mr.
James Burtis, Jr., Maryland Department of Natural
Resources, re: Presence of Federal or state threatened
or endangered plant or wildlife species at the site,
10/12/90. P. 300083-300083.
6. Memorandum to Mr. Andrew Sochansky [sic], U.S. EPA,
from Biological Technical Assistance Group (STAG), re:
Recommendations for Potentially Responsible Parties
(PRPs) to carry out sampling and analys is suggest ions,
12/20/90. " P-. 300084-300085. A letter regarding the
U.S. DOI's review of the revised Field Sampling Plan is
attached.
7. Report: Field Sampling Plan for the SRI/FS at the
Limestone Road Site. Cumberland. Maryland. Draft
Report. prepared by Geraghty & Miller, Inc., 6/90.
P. 300086-300241. A cover letter is' attached.
8. Report: Quality Assurance Project Plan for the SRI/FS
. at the Limestone Road Site. Cumberland. Maryland. Draft
Report. prepared by Geraghty & Miller, Inc., 6/90.
P. .300242-300552. (Pages 300251-300258 and 300452-
300468 have been removed because they contain
. confidential information.)
-------
9. Letter to Mr. Scott Phillips, Geiraghty & Miller, Inc.,
from Mr. S. Andrew Sochanski, U.S. EPA, re: Initial
review of the draft Field Sampling Plan (DFSP) and the
draft Quality Assurance Project Plan (DQAPP) for the
SRI/FS, 7/23/90. P. 300553-300584. The following are
attached:
a) Figure 3.1, Locations of Sampling Sites for
the Supplemental Remedial Investigation;
>
b) comments on the draft Field Sampling Plan;
c) comments on the draft Quality Assurance
Project Plan;
d) comments on the Quality Assurance Project
Plan Review.
10. Report: Field.Sampling Plan for the SRI/FS at the
Limestone Road .Site. Cumberland. Maryland. Revised
Draft Report, prepared by GeEaghty-& Miller, Inc.,
8/90. P. 300585-3Q0830. A cover letter and responses
to EPA's review of the' Field Sampling Plan are
attached.
11. Report: Revised Draft Quality Assurance Project Plan,
Limestone Road SRI/FS. Cumberland. Maryland, prepared
by Geraghty & Miller, Inc., 8/90. P. 300831-301059.
A cover letter and a summary of responses to the draft
Quality Assurance Project Plan are attached. (Pages
300862-300869 and 300932-300969 have been removed
because they contain confidential information.)
12. Report: Appendix B. Laboratory Quality Assurance Plan,
Limestone Road RI/FS. prepared by Geraghty & Miller,
Inc., 8/28/90. P. 301060-301177. (Pages 301138-301148
and 301153-301158 have been removed because they ,
contain confidential information.)
13. Letter to Mr. Scott Phillips, Geraghty & Miller, Inc.,
from Mr. S. Andrew Sochanski, U.S. EPA, re: Second
review of the draft Field Sampling Plan and draft
Quality Assurance Project Plan, 10/18/90. P. 301178-
301197. EPA's responses to Geraghty & Miller's
comments and an agenda for review of significant
comments to the second draft of the Field Sampling Plan
are attached. "
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14. Report: Revised Field Sampling Plan for the SRI/FS at
the Limestone Road Site, Cumberland. Maryland. Draft
Report. prepared by Geraghty & Miller, Inc., n/90.
P. 301198-301453. A cover letter and responses to
EPA's October 1990 comments on the review of the Field
Sampling Plan and the Quality Assurance Project Plan
are attached..
15 . Report: Revised Draft Quality Assurance Pro-ject Plan.
Limestone Road SRI/FS. Cumberland.' Maryland, prepared
by Geraghty & Miller, Inc., 11/90. P. 301454-301783.
(Pages 301471-301478, 301541-301575, 301655-301665, and
301670-301675 have been removed because they contain
confidential information.)
16. Report: Field Sampling Plan for the SRI/FS at the
Limestone Road Site. Cumberland. Maryland, prepared by
Geraghty & Miller, Inc., 7/91. P. 301784-302067.. Six
letters and a non-potable water chemistry proficiency
test report are attached..
17. Report: Quality Assurance Project Plan.' Limestone Road-
SRI/FS. Cumberland. Maryland, prepared by'Geraghty &
Miller, Inc., 7/91. P. 30206.8-302395. (Pages 302085-
302092, 302157-302190, and 302270-302277 have been
removed because they contain 'confidential information.)
18. Letter to Mr. Bob Byer, Geraghty & Miller, Inc., from
Mr. S. Andrew Sochanski, U.S. EPA, re: Fourth review
of the revised Field Sampling Plan and-Quality
Assurance Project Plan, 9/16/91. P. 302396-302400.
19. Letter to Mir. S. Andrew Sochanski, U.S. EPA/ from Mr.
Robert M. Byer, Jr., Mr. .John E. Claypool,, and Mr.
.Jeffrey P. Sgambat,. Geraghty & Miller, Inc., re:
Revised-pages of the Field Sampling Plan and Quality
Assurance Project Plan, 9/30/91. P. 302401-302452.
Responses to EPA's September 1991 comments on the
review of the .Field Sampling Plan and Quality Assurance
Project Plan and the revised pages of the plans are
attached. (Pages 302436-302448 have been removed
because they contain confidential information.)
20. Letter to Mr. S. Andrew Sochanski, Ms. Cynthia
Nadoiski, and Mr. David Healy, U.S. ,.EPA, -from Mr.
Jeffrey P.- Sgambat, Geraghty & Miller, Inc., re:
Revised pages of the Field Sampling Plan and-Quality
Assurance Project Plan, 12/19/91. P. 302453-302492.
The following are attached:
a) a facsimile cover letter;
-------
b) Attachment 1, Responses to EPA's November 20,
1991 Comments on the Review of the Field
Sampling Plan and Quality Assurance Project
Plan; .
c) 'the revised pages of the Field Sampling Plan;
d) the revised pages of the Quality Assurance
Project Plan.
. ' ' J
21. Report: Health and Safety Plan for the SRI/FS at the
Limestone Road Site. Cumberland. Maryland, prepared by
Geraghty & Miller, Inc., 9/90. P. 302493-302690.
22. Report: Field Sampling Plan for .the SRI/FS at the
Limestone Road Site. Cumberland. Maryland, prepared by
Geraghty & Miller, Inc., 12/91. P. 302691-302925.
23. Letter to Mr. Jeffery P. Sgambat, Geraghty & Miller,
Inc., from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review of the draft Field Sampling-Plan and the Quality.
Assurance Project Plan, 1/17/92. P. 302926-302929.
The review comments are attached.
24. Report: Revised Quality Assurance Project Plan.
Limestone Road SRI/FS. Cumberland. Maryland, prepared
by Geraghty & Miller, Inc., 2/92. P. 302930-303238.
25. Letter to Mr. Tracy M. Getz, Winston & Strawn, and Mr.
Philip M. Andrews, Kramon & Graham, from Mr. S. Andrew
Sochanski, U.S. EPA, re: Review and acceptance of the
proposed substitute Prime Contractor for site work,
3/11/92. P. 303239-303240.
26. Letter to Ms. Cynthia Nadolski, U.S. EPA, from Mr.
Philip M, Andrews, Kramon & Graham, re: Proposed sigh
locations, 3/17/92. P. 303241-303244. Two site maps
showing approximate locations for signs are attached.
.27. Report: Geophysical Investigation at the Limestone
Road Site near Cumberland. Maryland, (no author cited),
4/92 to 6/92. P. 303245-303426.
28. Letter to Mr. -David Kargbo, U.S. EPA^ from Mr. Robert
f. Pyle, Conestoga-Rovers & Associates, re: Site
: inspection to review alternate borehole and monitoring
well locations, 4/2/92. P. 303427-303429. A site map
and a facsimile transmittal sheet are attached.
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29. Report: Summary Report of Short Term Aquifer Testing
Program and Long Term Aquifer Testing Proposal.
Limestone Road Site. Cumberland. Maryland, prepared by
Conestoga-Rovers & Associates,- 5/92. P. 303430-303581.
30. Report: Geotechnical Testing Report, Limestone Road
Site. Cumberland. Maryland, prepared by Empire Soils
Investigations, Inc., 6/92. P. 303582-303643.
31. Letter to Mr. Robert T. Pyle, -Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski,. U.S. EPA, re:
Review comments on the Summary Report of Short Term
Aquifer Testing Program arid Long Term Aquifer Testing
Proposal, 6/8/92. P. 303644-303648. The comments are
attached.
32. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr'.
Robert T. Pyle, Conestoga-Rovers & Associates, re:
Responses to EPA's comments on the Summary Report of
Short Term Aquifer Testing Program and Long Term
Aquifer Testing Proposal, 6/8/92. .P. 303649-303661.
The responses are attached. .: ..
33. Memorandum to Ms. Carol Dunnigan from Ms. Doreen
Garden, re: Analytical Data Quality Assessment and
Validation of the surface soil cap area and soil
borings investigation, 8/4/92. P. 30662-30703. The
following are attached:
a) Table i, Analytical Results, Fill Sample
Program;
b) Table 2,' Analytical Results, Soil Fill
Boreholes; " .
c) Table 3, Summary, of Sample Collection and
Analytical Programs;\
.d) Table 4, Qualification of Data due to
Outlying Internal Standard Area Counts; .
e) Table 5, Qualified Sample Data due to Field
Duplicated Discrepancies, Soil Borings;
f) Table 6, Qualification of Data.vdue to
Outlying Matrix Spike Recoveries;
' ' - "
g) ' fable. 7, Qualified Sample Data due to Field
Duplicated Discrepancies, Soil Fill.
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34. Letter to Mr. Robert T. Pyle, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Summary of EPA's and Maryland Department of the
Environment's position on the RI/FS work tasks, 8/6/92.
P. 303704-303706.
35. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers & Associates, re:
Response to clarify Conestoga-Rovers' understanding of
the progress of site work, 8/12/92. Py. 30370-6-303709.
36. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers & Associates, re:.
Clarification of issues concerning the Long Term
Aquifer Testing Program, 9/4/92. P. 303710-303712.
37. Letter to Mr. Robert T. Pyle, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review comments on the Geotechnical Testing Report, the
Geophysical Investigation Report, and the Analytical
Data Quality Assessment and Validation, 9/11/92.
P. 303713-303716. The comments are attached.
38. Letter to Mr. Andrew Sochanski, U.S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers & Associates, re:
Proposed changes to the Long Term Aquifer Testing
Program, 9/22/92. P. 303717-303725. Three graphs are
attached.
39. Letter to Mr. S.A. Sochanski, U.S. EPA, from'Ms. Carol
F. Dunnigan, Conestoga-RoVers & Associates, re:
Clarification of sampling results, 10/15/92.
P. 303726-303730. A table of Surface Fill Soil Samples
and a site map are attached.
40.. Letter to Mr. Robert T. Pyle, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
The Long Term Aquifer Testing Program, 10/24/92.
P.,303731-303735.
41. Letter to Mr. S. Andrew Sochanski, U.S. EPA> from Mr.
Robert T.. Pyle, Conestoga-Rovers & Associates, re:
Installation of additional monitoring wells and
scheduling of field activities for the Supplemental
Remedial Investigation, 11/13/92. P. 303736-303740.
Two revised RI/FS schedules are attached.
»
42. Letter to Mr. Robert. T. Pyle, Conestoga-Rovers &
Associates, from Mr. S.. Andrew Sochanski, U.S. EPA, re:
Review comments on the Analytical Quality Assessment
and.Validation, 11/16/92. P. 303741-303743. The
comments are attached.
8
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43. Letter to Mr. Jeffery P. Sgambat, Geraghty & Miller,
Inc., from Mr. S. Andrew Sochanski, U.S. EPA, re:
Discovery of bullet holes in monitoring well casings
7/3/91. P. 303744-303745.
44. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Philip M. Andrews, Kramon & Graham, re: Response to
the letter concerning bullet holes found in monitoring
well casings, 7/22/91. P. 303746-303747.
45. Letter to Mr. Phil Andrews, Kramon & Graham, from Ms.
Cynthia Nadolski, .U.S. EPA, re: Signs to be posted at
the site to deter unrestricted access, 9/24/91.
P. 303748-303749.
46. Report: Remedial Investigation Risk Assessment Work
Plan. Limestone Road Site. Cumberland. Maryland.
prepared by Dynamac Corporation, 3/31/92. P. 303750-
303787. A cover letter is attached.
47. Report: Analytical Data Quality Assessment and
Validation. Limestone Road SRI/FS. prepared by,
Conestoga-Rovers & Associates, 7/8/92: P. 303788-
303866.
48. Letter to Mr. S. Andrew Sochanski, U..S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers & Associates, re:
Results of fill material sampling, 8/12/92. P. 303867-
303868. :
49. Letter to Mr. Robert T. Pyle, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Acceptance of the schedule for additional monitoring
well installation, 12/14/92. P. 303869-303870.
50. Report: Supplemental Remedial Investicration. Long-Term
Pumping Test Results and Additional Monitoring Well.
Proposal. Limestone Road Site. Cumberland. Maryland.
prepared by Conestoga-Royers & Associates, 1/29/93.
P. 303871-304193. A cover letter is attached.
51. Report: Attachment.1. Supplemental Remedial
Investigation. Long-Term Pumping Test Results and-
Additional Monitoring Well Proposal. Limestone Road
Site. Cumberland. Maryland, prepared by Conestoga-
Rovers & Associates, 1/29/93. P. 304194-304392.
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52. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers & Associates, re:
Request for a meeting to resolve differences concerning
. the expansion of activities beyond site limits, 2./1/93.
P. 304393-304401. A letter dated January 21, 1993
regarding the third round surface soil sampling and six
site maps are attached.
53. Report: Residential Well Sampling Proposal. Limestone
Road Site. Cumberland, Maryland, prepared by Conestoga-
Rovers & Associates, 2/5/93. P. 304402-304432. A
cover letter is attached.
54. Letter to Mr. Camille Gosta, Dynamac'. Corporation, from
Mr. S. Andrew Sochanski, U.S. EPA, re: Review of the
revised Ecological Risk Assessment Work Plan, 2/8/93.
P. 304433-304433. '
55. Letter to Director of Public Works, City of Cumberland,
from Ms. Carol ;F. Dunnigan, Conestoga-Rovers &
Associates, re: Request for permission to discharge to
the city wastewater treatment facility, 2/9/93.
. P. 304434-304458. A table of stored ground water
sampling results and an analytical report of sampling
results are attached.
56. Letter to Mr. Robert T. Pyle, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review comments on the Long Term Pumping Test Results
and Additional Monitoring Well Proposal and the
Geophysical Survey Report, 2/16/93. P: 304459-304474.
The comments are attached.
57. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Robert T. Pyle, Conestoga-Rovers &. Associates, re:
Results of the reanalysis of archived fill samples and
a change to be made to the analysis method for cadmium,
2/18/93. P. 304475-304493. The following are
attached:
a) Figure i, Perimeter Fill Material Analytical
Data Summary;
b) a table of Surface Fill Soil Samples;
\
c) a memorandum regarding the assessment and
validation of analytical results, dated
February 9, 1993; . ..
d) Table 1, Analytical Data, Cadmium Reanalysis;
10
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e) Table 2, Qualified Data due to Outlying
Matrix Spike Recoveries, Cadmium Reanalysis;
f) Table 3, Qualified Sample Data due to
Outlying MSA Correlation Coefficients,
Cadmium Reanalysis;
g) Table 4,'Field Duplicate Results and
Qualified-Sample Data, Cadmium Reanalysis;
h) Table 5, Sample Data Discrepancies, Cadmium
Reanalysis.
58. " Report: Analytical Data Quality Assessment and
Validation. Limestone Road SRI/FS. Soil Samples (13).
prepared by Conestoga-Rovers & Associates, 3/4/93.
P. 304494-304515.
59. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Ms.
Carol F. Dunnigan, Conestoga-Rovers & Associates, re:
Notification of- a change in Project. Coordinator for
Conestoga-Royers & Associates* 3/4/93/ P. 304516-
304525. The resume of Mr. Jack J.A. Michels is
attached.
60. Letter to Mr. Robert T. Pyle^ Conestoga-Rovers t
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review comments on the Residential Well Sampling
.Proposal, 3/4/93. P. 304526-304533: The comments are
attached.
61. Letter to Mr. S. Andrew Sochanski, U.S.. EPA, from Mr.
Andrew P. Kisiel, Conestoga-Rovers & Associates, re:
Specifications for well construction details, 3/5/93.
P. 304534-304535. '
62. Letter'to Mr. S. Andrew Sochanski, U.S..EPA> from Mr.
Michael G. Mateyk, Cones toga-Rovers & Associates, re:
Response to EPA's and Maryland Department of the
Environment's comments on the Additional Monitoring
Well Proposal, 3/9/93. P. 304536-304554. The
responses are attached.
63. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack J.A. Michels, Conestoga-Rovers & Associates, re:
Request for an extension to submit the Remedial Design
Plan, 3/12/93. P. 304555-304555.
64. Memorandum to Mr. Frederick Dreisch from Behrooz
Khoshikhoo, Lockheed Environmental Systems &
Technologies Co., re: Total hexavalent .chromium
determinations, 3/22/93. P. 304556-304559.
11
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65. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Michael G. Mateyk, Conestoga-Rovers & Associates, re:
Response to EPA's and Maryland Department of the
Environment's comments on the Residential Well Sampling
Proposal, 3/24/93. P. 304560-304572. The responses
are attached.
66. Memorandum to Mr. Frederick Dreisch from Ms. Linda D.
Vaughan, Lockheed Environmental Systems & Technologies
Co., re: Determination of pH in soil ^samples, 3/26/93.
P. 304573-304574.
67. Letter to Mr. Jack J.A. Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Acceptance of the request for an extension to submit
the Remedial Design Work Plan., 3/31/93. P. 304575-
' 304576. .
68. Letter to Mr. Jack J.A. Michels, Conestoga-Rovers &
Associates, form Mr. S. Andrew Sochanski, U.S. EPA, re:
Acceptance of Mr. Michels as .jthe new Project
Coordinator for Conestoga-Rovers & Associates, 3/31/93.
P. 304577-304578.
69. Report: Analytical Data Quality Assessment and
Validation, Limestone Road SRI/FS. Soil Fill Samples,
(10). prepared by Conestoga-Rovers & Associates, 4/93.
P. 304579-304597.
70. Letter to Mr. Jack J.A. Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review of the Residential Well Sampling Proposal and
the Long Term Pumping Test Results and Additional
Monitoring Well Proposal, 4/7/93. P. 304598-304600.
71. Letter to Mr. Jack J.A. Michels, Conestoga-Rovers &
Associates, from Mr.; S. Andrew Sochanski, U.S. EPA, re:
Design specifications, 4/8/93. P. 304601-304603. A
Remedial Design Specifications and Plans Distribution
List is attached. .
72. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Response to EPA's comments on the Residential Well
Sampling Proposal, 4/13/93. P. 304604-304606. A table
of residential wells.sampled is attached.
m
73. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Ms.
Carol F. Dunnigan, Conestoga-Rovers & Associates, re:
Request for a sample key, 4/15/93. . P. 304607-304607.
12
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74. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Residential well sampling efforts, 4/15/93. P. 304608-
304611. Two lists of residential wells to be sampled
are attached.
75. Report: Trip Report for Enforcement Sampling at the
Limestone Road Site, Cumberland. Maryland, prepared by
Dynamac Corporation, 4/16/93. P. 304612-304662. A
cover letter is attached.. ^
76. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Request for permission to discharge ground water,
4/22/93. P. 304663-304669. A stored ground water
analysis table and ground water sampling results are
attached.- . . . -
77. Letter to Mr. Jack Michels, Conestoga-Rovers &
Associates, .from Mr. S. Andrew Sochanski, U.S. EPA, re:
Request for a meeting to discuss the .Long Term
Monitoring Well Proposal, the*.-Additional Monitoring -.
Well Installation, and the Residential Well Sampling
Proposal, 4/26/93. P. . 304.670-304671.
77. Letter to Mr. Burly Cunningham from Mr. S. Andrew
Sochanski, U.S. EPA, re: .Request for vehicles.and
other salvage material to be removed from the Diggs
property, 4/27/93. P. 304672-304673.
79. Letter to Mr. Jack Michels,. ConestogarRovers &
Associates, from Mr. S. Andrew Sochanski,. U.S. EPA, re:
EPA'a contesting of a dispute resolution claim and
information oil the residential well sampling, 4/27/93.
P. 304674-304675.
80. Report: Limestone Road. Superfund Enforcement Account
No. TGB03N663. REO 9300067. prepared by U.S. EPA,
4/28/93. P. 304676-304697.
81. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Results of the filtered and unfiltered ground and
surface water sampling, 4/30/93. P, 304698-304699.
... »*.
82. Letter to Mr. Jack Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Denial of a request to dispose of ground water on-site,
5/4/93. P. 304700-304700.
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83. Report: Analytical Report. Project Number 4550.
prepared by Enesco-Wadsworth/Alert Laboratories,
5/12/93. P. 304701-304738.
84. Report: Remedial Design Plan, Limestone Road.
Cumberland. Maryland, prepared by Conestoga-Rovers &
Associates, 5/12/93. P. 304739-304990.
85. Report: Health and Safety Plan. Interim Remedial
Action. Limestone Road Site. Cumberland. Maryland.
prepared by Conestoga-Rovers & Associates, 5/12/93.
P. 304991-305083. '
86. Report.: Operation and Maintenance Plan. Limestone Road
Site. Cumberland. Maryland, prepared by Conestoga-
Rovers & Associates, 5/12/93. P. 305084-305101.
87. Report: Interim Remedial Program Project
Specifications. Limestone Road Site. Cumberland,
Maryland, prepared by Conestoga-Rovers & Associates,
5/12/93. P. 305102-305231. ':. .
88. Report:. Construction Quality Assurance: Project Plan.
Limestone Road Site. Cumberland. Maryland, prepared by
Conestoga-Rovers & Associates, 5/12/93. P. 305232-
305261.
89. Report: Evaluation of Total Versus Dissolved
Constituent Concentrations. Supplemental Remedial
Investigation/Feasibility Study. Limestone Road Site.
Cumberland. Maryland, prepared by Conestoga-Rovers &
Associates, 5/12/93. P. 305262-305382. A cover letter
is attached.
90. Report: Trip Report for Enforcement Sampling at the
Limestone Road Site. Cumberland. Maryland, prepared by
Dynamac Corporation, 5/17/93. P. 305383-305406. A
cover letter is attached.
91. Report: Evaluation of Total Versus Dissolved
Constituent Concentrations. Supplemental Remedial
Investigation/Feasibility Study. Limestone Road Site,
Cumberland. Maryland, prepared by Conestoga-Rovers &
Associates, 5/28/93. P. 305407-305466. A cover letter
is attached.
92. Letter to Mr. Jack Michels, Conestoga-Rovers, &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Need for collection of additional geophysical data,
6/1/93. P. 305467-305468.
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93. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Notice that Fairchild Industries will .not perform
additional geophysical, data collection, 6/7/93.
P. 305469-305469. .
94. Letter to Mr. Jack Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review of the Total Versus Dissolved Metals Residential
Well Sampling, 6/7/93. P. 305470-3054/71.
95. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Additional residential well sampling, 6/10/93.
P. 305472-305474. The sampling results are attached.
96. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates, re:
Revision of the capping boundaries, 6/11/93.
P. 304575-3.0548.1. Surface fill sampling results are
attached. ','
'jr. - '
97. Letter to Mr. Jack Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review comments oh the Remedial Design.Plan, the
Project Specifications, the Construction Quality
Assurance Project Plan, the Operation and Maintenance
Plan, and the Health and Safety Plan, 6/16/93.
P. 305482-305528. The comments are attached.
98. Letter to Mr. Jack Michels, Conestoga-Rovers &
Associates, from Mr. S. Andrew Sochanski, U.S. EPA, re:
Review comments on the Operation and Maintenance Plan,
6/17/93. P. 305529-305530. The comments are attached.
99. Report: Trip Report for Enforcement Sampling at the
Limestone Road Site. Cumberland. Maryland, prepared by
Dynamac Corporation, 6/17/93. P. 305531-305558. A
cover letter is attached.
100. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Philip M. Andrews, Kramon & Graham, re: Notice that
Cumberland Cement and Supply Company will not perform
additional work, 6/17/93. P. 305559-305559.
101. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Andrew P. Kisiel, Conestoga-Rovers & Associates, re:
A field audit conducted on May 20, 1993 to verify that
sampling was being performed according to the Work
Plan, 6/17/93. P. 305560-305568. A memorandum dated
June 14, 1993 regarding the field audit and a field
audit summary form are attached.
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102. Memorandum to Mr. Gregg Crystal!, U.S. EPA, from Ms.
Marian Murphy, Roy F. Weston, Inc., re: Analytical
review of five water samples, 6/22/93. P. 305569-
305584.
103. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Steven C. Day, Conestoga-Rovers & Associates, re: A
laboratory audit conducted on May 27, 1993 to verify
that analyses were being performed according to the
Work Plan, 6/24/93. P. 305585-305664./ A memorandum
dated June 23, 1993 regarding the laboratory audit, the
Audit Checklist, and Performance Evaluation Results are
attached.
104. Special Bulletin A to Regional Response Center, Region
III, U.S. EPA, from Mr. George English, U.S. EPA, re:
Notification of a $50,000 activation, 7/1/93.
P. 305665-305667.
105. Letter to Mr. S'. Andrew Sochanski and Ms. Cynthia.
Nadolski, U.S. EPA, and Mr. David Healy, Maryland
Department of the Environment, from Ms. Carol F.
Dunnigan, Conestoga-Rovers & Associates, re: The April
1993 Analytical Data Quality Assessment and Validation
report, 7/7/93. P. 305668-305687. The report is
attached.
106. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Wayne H. Sonntag, U.S. DOI, re: The U.S. Geological
Survey Work Plan for povision of technical support,
7/7/93. P. 305688-305735. The Work Plan and the Scope
of Work for Borehole Geophysical Logging and
Interpretation are attached.
107. Memorandum to Mr. Andy Sochanski, U.S. EPA, from Ms.
Cynthia E..Caporale, U.S. EPA, re: Organic Data
Validation*for Case 20107/7571HQ, 7/14/93. P. 305736-
305745. The Organic Data Validation for Case
20107/7571HQ; Appendix A,' Glossary of Data Qualifiers;
and Appendix B, Data Summary Forms, are attached.
108. Report: Limestone Road. Superfund Enforcement Account
No. 3TGB03N663. REO 9306. prepared by U.S. EPA,
7/21/93. P. 305746-305752.
109. Letter to Mr. S. Andrew Sochanski, U.S. EPA, from Mr.
Jack Michels, Conestoga-Rovers & Associates,-re:
Response to comments on the Remedial Design Plan,
7/21/93. P. 305753-305808. The response is. attached.
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110. Facsimile transmittal sheet to Mr. Andrew Sochanski,
U.S. EPA, from J. Kozel, Dynamac Corporation, re:
Summary tables for residential well sampling, 7/28/93.
P. 305809-305812. The tables are attached..
111. Report: Analytical Data Quality Assessment and
Validation. Limestone Road SRI/FS, Groundwater
Investigation Round I. Surface Water/Sediment
Investigation.Round I. Residential Well Sampling Round
I_, prepared by Conestoga-Rovers & Associates, 7/28/93.
P. 305813-305880. A cover letter is attached.
112. Report: Analytical Data Quality Assessment and
Validation. Limestone Road SRI/FS. Groundwater.
Investigation Round II. Surface Water/Sediment
Investigation Round II. Residential Well Sampling Round
II. prepared by Conestoga-Rovers & Associates, 7/28/93.
P. 305881-305946.
113. Memorandum to Mr. Andy Sochanski, U.S. .EPA, from Ms.
Cynthia E. Caporale, U.S. EPA,; re: . Inorganic Data
Validation for Case SAS 78650^03, 8/2/93: P. 305947- r
305965. The following are attached:
a) the Inorganic Data Validation for Case SAS
7865C-03; .
b) Table 1, Data Summary Form;
c) Table 2, Glossary of Data Qualifier Codes;
d) four Special Analytical Service Packing List/
Chain of Custody forms;
e) three EPA Sample Shipping Logs.
114. Memorandum to Mr. Andy Sochanski, "U.S. EPA, from Ms.
Cynthia E. Caporale, U.S. EPA, re: Inorganic Data
Validation for Case SAS 7908C-02, 8/10/93. P. 305966-
3059.81. The.following are attached:
a) the Inorganic Data Validation for Case SAS
7908C-02;
b) Table 1A, Summary of Qualif iers;>on Data
Summary After Data Validation;
»
c) Table IB, Codes Used in Comments Column;
d) Table 2, Glossary of Data Qualifier Codes;
17
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e) Table 3, Summary of Sample Locations and
Associated EPA Sample Numbers;
f) Appendix A, Results Reported by Laboratory
Form Inorganics (Is);
g) two Special Analytical Service Packing List/
Chain of Custody forms;
e) two EPA Sample Shipping Logs/
115. Report: Phase .1 Ecological Assessment Supplemental
Remedial Investigation, prepared by Conestoga-Rovers &
Associates, 9/94. P. 305982-306102.
116. Letter to Mr. Gerald Hoover, U.S. EPA, from Mr. Jack
Michels, Conestoga-Rovers & Associates, re:
Supplemental information for the ecological risk
assessment for the site, 1/13/95. P. 306103-306111.
117. Letter to Mr. Gerald Hoover, IKS. E.PA, from Mr. Jack
Michels, Conestoga-Rovers & Associates,, re:
Supplemental information concerning the ecological risk
assessment, 1/16/95. P. 306112-306116. A list of
flora and fauna at the site is attached.
118. Letter to Mr. Gerald Hoover, U.S. EPA, from Mr.
Christopher Bozzini, CH2M Hill, re: Comments
concerning the supplemental ecological risk assessment
information submitted by Conestoga-Rovers & Associates,
2/6/95. P. 306117-306119. '
119. Memorandum to Mr. Gerald Hoover, U.S. EPA, from Mr.
Robert S. Davis, U.S. EPA, re: Biological Technical
Assistance Group's (BTAG) comments concerning the
supplemental ecological risk assessment information
submitted by Conestoga-Rovers & Associates, 2/6/95.
P. 306120-306122.
120. Memorandum to Mr. Gerald Hoover, U.S. EPA, from Mr.
Robert S. Davis, U.S. EPA, re: Comments concerning the
supplemental ecological risk assessment information
submitted by Conestoga-Rovers & Associates, 2/10/95.
P. 306123-306125.
121. Report: Final Remedial Investigation Report. Volume I
Text and Appendices, prepared by Conestoga-Rovers &
Associates, 3/95. P. 306126-307152. A transmittal
letter is attached.
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122. Report: Final Supplemental Feasibility Study.
prepared by Conestoga-Rovers & Associates, 4/95.
P. 307153-307359.
123. U.S. EPA Summary of Environmental Risk Assessment,
Limestone Road Superfund Site, 4/10/95. P. 307360-
307367. A facsimile transmittal is attached.
124. Memorandum to Mr. Gerald Hoover, U.S. EPA, from Mr.. .
Robert S. Davis, U.S. EPA, re: Comments concerning the
ecological risk assessment, 4/26/95. P. 307368-307369.
125. Letter to Mr. Glen S. Lapsley, U.S. EPA, from Mr. Jack
Michels, Conestoga-Rovers & Associates, re: Summary of
the results of the residential well monitoring program
and proposed changes in the program, 11/17/95.
P. 307370-307422. A letter providing EPA's conditional
approval to changes in the residential well monitoring
program, a summary of the statistical methodology used
by Conestoga-Rovers & Associates, and the analytical
results and comparison statistics for the monitoring
program are attached. <; , '
'126. Report: Interim Remedial Action Operation and
Maintenance and Interim Monitoring Program, prepared by
Conestoga-Rovers & Associates, 1/96. P., 307423-307587.
127. Letter to Mr. Jagk Michels, Conestoga-Rovers &
Associates, from Ms. Lesley Brunker, U.S. EPA, re:
Conditional approval of the final supplemental
feasibility study for the site, 2/14/96. P. 307588-
307589..
128. Letter to Ms. Lesley Brunker, U.S. EPA, from Mr. Rick
Grills, Maryland Department of the Environment (MDE),
re: Approval of the draft proposed plan for the site
and notification that the state has no comments
concerning this document, 2/29/96. P. 307590-307590.
129. Memorandum to Ms. Lesley Brunker, U.S. EPA, from Mr.
Robert S. Davis, U.S. EPA, re: STAG'S comments
concerning the draft proposed plan, 3/6/96. P. 307591-
307592.
130. Memorandum to Ms. Lesley Brunker, U.S. EPA, from Mr.
Roy Smith, U.S. EPA, re: Comments concerning the
proposed.plan, 3/11/96. P. 307593-307593. '
131. Memorandum to the site file, from Mr. Lesley Brunker,
re: Revised risk calculations based on changes in the
reference dose for manganese, 3/20/96. P. 307594-
307594.
19.
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132. Proposed Plan, Limestone Road OU2 Site, 4/96.
P. 307595-307611.
133. Letter to Ms. Lesley Brunker, U.S. EPA, from Dr. Jane
A. Fiscus, Allegheny County Health Department, re:
Notification of the Allegheny County Health
Department's support of EPA Alternative 3 for the
Limestone Road Site, 4/26/96. P.
134. Letter to Ms. Lesley Brunker, U.S. EPAy from Mr. Ronald
K. Snyder, Allegheny County Department of Public Works,
re: Recommendation that Allegheny County, rather than
the PRPs, provide a water supply to the Limestone Road
Site, 5/10/96. P. .
135. Letter to Ms. Lesley Brunker, U.S. EPA, from Mr. Jack
Michels, -Constega-Rovers & Associates, re: Transmittal
of comments regarding EPA's Propsed Plan for the
Limestone Road OU2 Site on behalf of the PRPs, 5/13/96.
P. ' .
«
136. Letter to Ms. Lesley Brunker, U.S. EPA, from Mr. Rick
Grills, Maryland Department of the Environment (MDE),
re: Notification that MDE has no comments regarding
the draft Record of Decision (ROD) for the Limestone
Road OU2 Site, 6/12/96. P.
20
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V. COMMUNITY RELATIONS/CONGRESSIONAL CORRESPONDENCE/IMAGERY
137. U.S. EPA Fact Sheet, Limestone Road Site, 4/93.
P. 500001-500004.
138. Minutes of a public meeting held on April 24, 1996, .in
the District 16 Fire Hall, 12100 North Branch Road,
Cumberland, Maryland, to discuss the proposed plan for
the Limestone Road Site, 4/24/96.' P.
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