* T-^'\V\\UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
xr!\ **A\N\ WASHINGTON, D.C. 20460
5 1330
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Dir. No. 9355.4-01
MEMORANDUM
SUBJECT: Guidance on Remedial Actions for Superfund Sites With
PCB Contamination
FROM:
TOS
Superfund Management Review: Rec
Henry L. Longest II, Director
Office of Emergency and Remedi
Bruce M. Diamond, Director-
Office of Waste Programs E
ndation 23
onse
cement
Waste Management Division Directors
Regions I, IV, V, VII, and VIII
Emergency and Remedial Response Division Director
Region II
-Hazardous Waste Management Division Directors
Region III, VI, and IX
Hazardous Waste Division Director
Region X
Purpose
The purpose of this memorandum is to transmit for your use
the Guidance on Remedial Actions for Superfund Sites With PCB
Contamination, the associated "Short Sheet", the joint guidance
on Superfund's approach to the Toxic Substances Control Act
(TSCA) anti-dilution provisions, and the guidance prepared by the
Office of Toxic Substances on options for disposing of PCBs at
Superfund sites.
Background
Approximately 12 to .17% of the sites on the National
Priorities .List—ifjvolve PCB contamination. Because this
represents a~~~substantial number of Superfund sites and because
PCB regulations are complicated, the Guidance on Remedial Actions
for Superfund Sites With PCB Contamination was prepared to assist
in streamlining efforts required to develop remedial alternatives
for these sites.
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An initial draft "working paper" was circulated for review
in October 1988 and a workgroup meeting was held with Regional
project managers and counsel in December 1988 in conjunction with
the annual PCB seninar sponsored by the Office of Toxic
Substances (OTS). Issues identified at this working session were
discussed and resolved in meetings held in early 1989 between
OERR and OTS. A draft version of the guidance was prepared and
distributed for review in September 1989. Several comments were
received and incorporated. A subsequent issue regarding the
application of the anti-dilution provisions of TSCA to Superfund
actions was identified and several meetings were held in early
1990 that resulted in agreement that these provisions apply to
Superfund decisions prospectively (PCB wastes at Superfund sites
cannot be further diluted in order to avoid the TSCA PCB disposal
requirements) but do not require cleanup levels and technologies
to be selected based on the form and concentration of the
original PCB material spilled or disposed of at the site prior to
EPA's involvement. This issue is discussed in a joint memorandum
from the OSWER and the Office of Pesticides and Toxic Substances
(OPTS) (attached). In conjunction with this joint memorandum the
OTS developed Interim Guidance on Non-Liquid PCB Disposal Methods
to Be Used as Alternatives to a 40 CFR -761.75 Chemical Waste
Landfill (attached).
Following development of guidance on the anti-dilution
issue, the attached Superfund guidance and "short sheet" were
finalized.
Objectives
The objectives of this guidance are to promote a consistent
approach to addressing PCB-contaminated Superfund sites by
highlighting key considerations for effective, efficient remedial
investigations and feasibility studies, outlining possible
approaches for addressing PCB contamination, and describing the
process for developing and evaluating response actions and
selecting a remedy. This document describes the recommended
approach for evaluating and remediating Superfund sites with PCB
contamination consistent with the program expectations as defined
in the NCP and the mandates of CERCLA as specified in the NCP.
This guidance fulfills part of Recommendation 23 of the
Superfund program management review.
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OSWER Directive No. 9355.4-01
August 1990
GUIDANCE ON REMEDIAL ACTIONS FOR SUPERFUND
SITES WITH PCB CONTAMINATION
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
Development of this document was funded by the United States
Environmental Protection Agency. It has been subjected to the
Agency's review process and approved for publication as an EPA
document.
The policies and procedures set out in this document are intended
solely for the guidance of response personnel. They are not
intended, nor can they be relied upon, to create any rights,
substantive or procedural, enforceable by any party in litigation
with the United States. EPA officials may decide to follow this
guidance, or to act at variance with these policies and
procedures based on an analysis of specific site circumstances,
and to change them at any time without public notice.
11
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FIGURES
Number Page
1-1 Decision Points in the Superfund Process 4
4-1 Key Steps in the Development of Remedial Alternatives
at Superfund Sites With PCB Contamination 41
4-2 Cover Designs — Example Scenario 51
C-l Example Scenario Cap Designs C-4
C-2 Evaluation Areas for VADOFT and AT123D C-8
IX
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Acknowledgements
We wish to acknowledge the following people who assisted in
preparing this document.
Jennifer Haley, OERR Johanna Miller, Region IX
Betsy Shaw, OERR Michael Jassinski, Region I
Bill Hanson, OERR Mark Fite, Region VI
Jim Orban, Region IV
Larry Kapustka, ORD/Corvallis
Steve Hwang, ORD/OHEA Barry Lester, Geotrans
Burt Bledsoe, ORD/RSKERL Rose Spikula, CH2M Hill
Ed Earth, ORD/RREL
Jacqueline Moya, ORD/OHEA
Bruce Means, OERR
Chris Zarba, OW
Larry Starfied, OGC
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5.2 Selection of Remedy 62
5.3 Documentation 63
6. References 65
Appendix A. Summary Report of FY82-FY89 Records of
Decision Addressing PCB Contaminated Media.. A-l
Appendix B. Direct Contact Risk Evaluation B-l
Appendix C. Determining Appropriate Long Term Management
Controls — Detailed Calculations for Case
Study C-l
Appendix D. Case Studies — Pepper Steel, FL; Wide Beach,
NY D-l
Appendix E. PCB Disposal Companies Commercially
Permitted E-l
Appendix F. Superfund Site Examples — Long Term
Management Controls F-l
VII
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TABLES
Number Page
2-1 Remediation Options for PCB Waste Under TSCA 12
2-2 TSCA Chemical Waste Landfill Requirements 17
3-1 Recommended Soil Clean-up Levels 27
3-2 Analytical Methods for PCBs 29
3-3 PCB Direct Contact Assumptions 31
3-4 Chemical and Physical Properties of PCBs 32.
3-5 PCB Sediment Quality Criteria 36
4-1 PCB Treatment Methods and Application Consequences.... 43
4-2 Selection of Long-Term Management Controls at PCB-
Contaminated Sites 48
4-3 Summary — Example Site Parameters 4$
4-4 Cover Design -- Summary Table 52
4-5 Example Scenario — Evaluation Results 53
4-6 Example PCB Compliance Scenarios for Contaminated Soil 57
C-l Cover Design Summary Table C-7
C-2 Example Scenario — Results C-ll
Vlll
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CONTENTS
Page
Executive Summary iii
Tables viii
Figures ix
Acknowledgements x
1. Introduction 1
1.1 Purpose 2
1. 2 Background 3
1.3 Focus of This Document With Respect to the
Remedial Process and Superfund Expectations. 3
1. 4 Organization of Document , 7
2. Regulations and "To-Be-Considered" Guidelines Pertinent
to PCB Contamination Sites 9
2 .1 National Contingency Plan 10
2.2 TSCA PCB Regulations 11
2.2.1 Liquid PCBs at Concentrations Greater
Than 500 ppm 13
2.2.2 Liquid PCBs at Concentrations Between
50 ppm and 500 ppm 13
2.2.3 Non-Liquid PCBs at Concentrations
Greater Than or Equal to 50 ppm 14
2.2.4 PCB Articles, Containers, Electrical
Equipment 15
2.2.5 TSCA Chemical Waste Landfill
Requirements 17
2.2.6 Storage Requirements 17
2.3 RCRA Regulations Addressing PCBs 19
2.3.1 Liquid Hazardous Waste With PCBs at
50 ppm or Greater 20
2.3.2 Hazardous Waste With HOCs at 1000 ppm
or Greater 20
2.4 Clean Water Act 20
2.5 Safe Drinking Water Act 21
2.6 PCB Spill Cleanup Policy Under TSCA 22
2.6.1 Low Concentration, Low Volume Spills
All Areas 22
2.6.2 Non-Restricted Access Areas 22
2.6.3 Industrial Areas 22
2.6.4 Outdoor Electrical Substations 23
2.6.5 Special Situations 23
2 . 7 Guidances 23
2.7.1 Draft Guidelines for Permit
Applications and Demonstrations —
Test Plans for PCB Disposal by Non-
Thermal Alternate Methods 24
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2.7.2 Verification of PCB Spill Cleanup by
Sampling and Analysis 24
2.7.3 Field Manual for Grid Sampling of PCB
Spill Sites to Verify Cleanup 24
2.7.4 Development of Advisory Levels for PCB
Cleanup 25
2.7.5 Risk Assessment Guidance for Superfund:
Human Health Evaluation 25
3. Cleanup Level Determination 26
3.1 Soils 27
3.1.1 Preliminary Remediation Goals for
Residential Areas 28
3.1.2 Preliminary Remediation Goals for
Industrial Areas 30
3.1.3 Assessing the Impact to Ground Water. 33
3 . 2 Ground Water 33
3 . 3 Sediment 34
3 .4 Ecological Considerations 36
4. Developing Remedial Alternatives 39
4.1 Identifying Principal Threats/Low-Threat
Areas 40
4 . 2 Treatment Methods 40
4.2.1 Incineration 42
4.2.2 Chemical Dechlorination (KPEG) 42
4.2.3 Biological Treatment 44
4.2.4 Solvent Washing/Extraction 45
4.2.5 Solidification/Stabilization 45
4.2.6 Vitrification 46
4.3 Determining Appropriate Management Controls
Areas Where Concentrations Are Above Action
Level s 46
4.3.1 Example Analysis — Long-Term
Management Controls 47
4 . 4 Dredged Material ". 54
4 . 5 RCRA Hazardous Waste 54
4.6 Example Options Analysis — Contaminated
Soil. 56
5. Analysis of Alternatives and Selection of Remedy. 58
5.1 Evaluating Remedial Alternatives 59
5.1.1 Overall Protection of Human Health and
the Environment 59
5.1.2 Compliance With ARARs 59
5.1.3 Long-Term Effectiveness and
Permanence " 60
5.1.4 Reduction of Toxicity, Mobility, or
Volume through Treatment 61
5.1.5 Short-Term Effectiveness 61
5.1.6 Implementability 62
5.1.7 Cost 62
vi
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Executive Summary
This document describes the recommended approach for evaluating
and remediating Superfund sites with PCB contamination. It
should be used as a guide in the investigation and remedy
selection process for PCB-contaminated Superfund sites. This
guidance provides preliminary remediation goals for various media
that may be contaminated and identifies other considerations
important to ensuring protection of human health and the
environment. In addition, potential applicable or relevant and
appropriate requirements (ARARs) and "to-be-considered" criteria
pertinent to Superfund sites with PCB contamination and their
integration into the RI/FS and remedy selection process are
summarized. This guidance also describes how to develop remedial
alternatives for PCB contaminated materials that are consistent
with Superfund program expectations and ARARs. The guidance
concludes with a discussion of considerations unique to PCBs that
should be considered in the nine criteria evaluation and
tradeoffs between options that are likely to occur.
Actions taken at Superfund sites must meet the mandates of the
Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) as provided for in the National Contingency Plan
(NCP). This requires that remedial actions protect human health
and the environment, comply with or waive applicable or relevant
and appropriate requirements, be cost-effective, and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
In addition, there is a preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as a
principal element. Although the basic Superfund approach to
addressing PCB-contaminated sites is consistent with other laws
and regulations, this consistency must be documented in the
feasibility study and ROD to demonstrate that ARARs have been
attained or waived. Primary Federal ARARs for PCBs derive from
the Toxic Substances Control Act (TSCA) and the Resource
Conservation and Recovery Act (RCRA).
To identify the areas for which a response action should be
considered, starting point concentrations (preliminary cleanup
goals) for each media are identified. These concentrations
represent the level above which unrestricted exposure may result
in risks exceeding protective levels. For soils, the preliminary
remediation goals should generally be 1 ppm for sites in or
expected to be in residential areas. Higher starting point
values (10 to 25 ppm) are suggested for sites, where non-
residential land use is anticipated. Remediation goals for
ground water that is potentially drinkable should be the proposed
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MCL of .5 ppb. Cleanup levels associated with surface
water should account for the potential use of the suface water as
drinking water, impacts to aquatic life, and impacts through the
food chain.
For contaminated material that is contained and managed in place
over the long term, appropriate engineering and institutional
controls should be used to ensure protection is maintained over
time. An initial framework for determining appropriate long-term
management measures is provided.
The Superfund program expectations should be considered in
developing appropriate response options for the
identified area over which some action must take place. In
particular; the expectation that principal threats at the site
should be treated, whenever practicable, and that consideration
should be given to containment of low-threat material, forms the
basis for assembling alternatives. Principal threats will
generally include material contaminated at concentrations
exceeding 100 ppm for sites in residential areas and
concentrations exceeding 500 ppm for sites in industrial areas
reflecting concentrations that are 1 to 2 orders of magnitude
higher than the preliminary remediation goals. Where
concentrations are below 100 ppm, treatment is less likely to be
practicable unless the volume of contaminated material is
relatively low.
t
The expectations support consideration of innovative treatment
methods where they offer potential for comparable or superior
treatment performance or implementability, fewer/lesser adverse
impacts, or lower costs. This emphasizes the need to develop a
range of treatment options. For PCBs, possible innovative
technologies meeting these criteria include solvent extraction,
potassium polyethylene glycol dechlorination (KPEG), biological
treatment, and in-situ vitrification.
Protective, ARAR-compliant alternatives will be compared relative
to the five balancing criteria: long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, and cost.
Primary tradeoffs are most likely to occur under the long-term
effectiveness and permanence, implementability, and cost
criteria.
Final decisions should document the PCB concentrations above
which material will be excavated, treatment processes that will
be used, action levels that define the area that will be
contained, long-term management controls that will be
implemented, treatment levels to which the selected remedy will
reduce PCB concentrations prior to disposal, and the time frame
for implementation.
iv
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options for remediating such sites, 2) identifying key
information necessary to fully evaluate those options, and
3) focussing on the major tradeoffs likely to emerge in the
comparative analysis upon which remedy selection is based.
Consideration of the factors outlined in this document
should lead to consistent alternatives development and
evaluation at sites involving PCB contamination.
1.2 Background
Approximately 12 percent of the Superfund sites for
which Records of Decision (RODs) have been signed (69 of 581
total RODs as of 9/89) address PCB contamination.
Preliminary assessment/site inspection data from all sites
on the National Priorities List indicates that approximately
17 percent of the sites for which RODs have not yet been
signed also involve PCBs. The RI/FS/remedy selection
process for PCB sites is complicated for a number of
reasons. From a regulatory point of view, there is an
unusually high number of potentially applicable or relevant
and appropriate requirements (ARARs) and pertinent "to-be-
considered" guidelines for actions involving PCB wastes.
PCBs are difficult to address technically due to their
persistence and high toxicity. Finally, a large number of
process options are potentially effective for addressing
PCBs and deserve consideration. The approach outlined in
this document attempts to address all three aspects of PCB
remediation.
1.3 Focus of This Document With Respect to the Remedial
Process and Superfund Expectations
The Superfund remedial process begins with the
identification of site problems during the preliminary
assessment/site inspection, which is conducted before a site
is listed on the National Priorities List. The process
continues through site characterization, risk assessment,
and treatability studies in the RI, the development,
screening, and detailed analysis of remedial alternatives in
the FS, and culminates in the selection, implementation, and
operation of a remedial action. Figure 1-1 shows the steps
comprising the Superfund RI/FS process. Arrows indicate key
decisions specifically addressed in this document.
The various components of the remedial investigation are
not specifically addressed in this document; however,
initial reference material including tables outlining
properties of PCBs, analytical methods available, and data
collection needs/considerations for technologies used to
address PCBs are provided. In addition, a general
discussion of the assessment of PCB impact on ground water
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REMEDIAL
INVESTIGATION
Draft
FS
Report/Proposed Plan
Figure 1-1 DECISION POINTS IN THE SUPERFUND PROCESS
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Chapter 1
Introduction
This document describes the recommended approach for
evaluating and remediating Superfund sites with PCB
contamination. It provides starting point cleanup levels
for various media that may become contaminated and
identifies other considerations important to ensuring
protection of human health and the environment that these
cleanup levels may not address. In addition, potential
applicable or relevant and appropriate requirements (ARARs)
and "to-be-considered" criteria pertinent to Superfund sites
with PCB contamination and their integration into the RI/FS
and remedy selection process are summarized.
The guidance also describes how to develop remedial
alternatives for PCB contaminated materials that are
consistent with Superfund program expectations and ARARs.
The guidance concludes with a discussion of considerations
unique to PCBs that should be considered in the nine
criteria evaluation and likely tradeoffs between options
that are likely to occur.
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1.1 Purpose
This guidance document outlines the RI/FS and selection
of remedy process as it specifically applies to the
development, evaluation, and selection of remedial actions
that address PCB contamination at Superfund sites. The
principal objectives of this guidance are to:
o Present the statutory basis and analytical framework for
formulating alternatives designed to address PCB
contamination, explaining in particular the regulatory
requirements and other criteria that can shape options for
remediation;
o Describe key considerations for developing remediation
goals for each contaminated media under various
scenarios;
o Outline options for achieving the remediation goals and
the associated ARARs;
o Summarize the key information that generally should be
considered in the detailed analysis of alternatives;
o Discuss key tradeoffs likely to occur in the remedy
selection process;
o Provide guidelines for documenting remedies for PCB
sites in a Proposed Plan and Record of Decision.
Although technical aspects of the investigation,
evaluation, and remediation are not discussed in detail,
pertinent references and, in some cases, summary
information, are provided.
This document is intended for use by EPA remedial
project managers (RPMs), State and other Federal Agency site
managers responsible for Superfund sites involving PCBs,
contractors responsible for conducting the field work and
alternatives evaluation at these sites, and others involved
in the oversight or implementation of response actions at
these sites.
Although each Superfund site may present a unique set of
environmental conditions and potential human health
problems, general guidelines can be established for sites
involving PCBs as the predominant chemical. Utilizing these
general principles, site managers can streamline the RI/FS
and remedy selection process by conducting a more efficient
and effective study. This can be accomplished by: 1)
specifying ARARs and other factors that shape the primary
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and evironmental considerations which may be pertinent in
the risk assessment is provided.
The focus of this guidance is primarily on the
feasibility study: development and screening of
alternatives, detailed analysis of alternatives, and the
consequent selection of remedy. This process is designed to
meet the overall Superfund goal to select remedial actions
that are protective of human health and the environment,
that maintain protection over time, and that minimize
untreated waste. In addition to the overall goal, Superfund
actions should consider the following program expectations:
o Treatment of principal threats wherever practicable,-
o Containment of waste that poses a low long-term threat
or where treatment is impracticable,
o Institutional controls to mitigate short-term impacts or
supplement engineering controls,
o Remedies that combine treatment of principal threats
with containment and institutional controls for
treatment residuals and untreated waste,
o Consideration of innovative technologies,
o Returning contaminated ground water to its beneficial
uses within a time frame that is reasonable, where
practicable.
The implications of these expectations for PCB contaminated
sites is described in appropriate sections of this document.
The development of alternatives involves completing the
following steps, considering the program expectations
described above:
1. Identify remedial action response objectives including
the preliminary remediation goals that define the
appropriate concentration of PCBs that could remain at
the site without management controls.
2. Identify general response actions such as excavation
and treatment, containment, or in-situ treatment.
Identify target areas for treatment and containment
consistent with Superfund program expectations and
consistent with ARARs and TBCs specific to PCB
contamination.
3, Identify process options for various response actions.
Treatment options for PCBs include incineration,
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solvent extraction, KPEG, or other removal/destruction
methods. Immobilization techniques may also be
considered. Long-term management controls appropriate
for the material remaining on site should be noted.
4. Evaluate/screen process options to determine which are
technically feasible for the site.
5. Combine feasible process options to formulate
alternative remedial actions for detailed analysis.
This document provides general guidance on two primary
aspects of the development of alternatives process that are
considered and revised throughout the completion of the
steps listed above:
o Determination of the appropriate concentration of PCBs
that can remain at a site (remediation goal) under
various site use assumptions. This is based on standard
exposure and fate assumptions for direct contact. A
qualitative consideration of potential migration to
ground water and environmental impacts is included for
site-specific assessment.
This concentration will reflect the level that will
achieve the program goal of protection and will be
achieved through removal and treatment to this level or
by restricting exposure to contamination remaining above
this level.
o Identification of options for addressing contaminated
material and the implications, in terms of long-term
management controls, associated with these options.
Remedial actions will fall into three general
categories: overall reduction of PCB concentrations at
the site (through removal or treatment) such that the
site can be used without restrictions, complete
containment of the PCBs present at the site with
appropriate long-term management controls and access
restrictions, and a combination of these options in
which high concentrations are reduced through removal or
treatment but the levels remaining still warrant some
management controls.
The determination of what combination of treatment and
containment is appropriate will be guided by the program
expectations to treat the principal threats and contain
and manage low-threat material. The determination of
what constitutes a principal threat will be site-
specific but will generally include material
contaminated at concentrations of PCBs that exceed 100
ppm (residential areas) or 500 ppm (industrial areas).
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The type of treatment selected will take into account
the program expectation to consider innovative
treatment. Treatment that is often comparable in
performance to but less costly than incineration may be
attained using solvent extraction or KPEG. In addition,
the potential for adverse affects from incineration can
be removed through use of one of these technologies, in-
situ vitrification, and in some cases, solidification.
For both evaluations, pertinent ARARs and TBCs are
identified.
Finally, this document will: 1) discuss some of the
unique factors associated with response actions at PCB-
contaminated sites that might be considered under the
detailed analysis of alternatives using the evaluation
criteria outlined in the proposed NCP, 2) indicate how these
factors might be evaluated in selecting the site remedy, and
3) outline the findings that should be documented for the
selected remedy.
1.4 Organization of Document
The remainder of this document is divided into four
chapters and six appendices, summarized below. At the
beginning of each chapter a brief summary highlighting the
main points of the section is provided.
Chapter 2 describes the potential ARARs and TBCs most
commonly identified for sites involving PCB contamination.
This discussion has been separated from the background
section because of the complexity of the regulatory
framework.
Chapter 3 provides general guidelines for determining
PCB concentrations appropriate to leave on site under
various scenarios. The primary factors affecting this
determination are the medium that is contaminated, the
exposure assumptions for the site, and the extent and level
of contamination that is to be addressed.
Chapter 4 outlines the remediation options for material
which warrants active response. Options include treatment
that destroys the PCBs and long-term management controls
that prevent exposure to PCBs. The regulatory implications
of each option are discussed.
Chapter 5 summarizes the primary considerations
associated with determining the appropriate response action
for a PCB contaminated Superfund site in terms of the nine
evaluation criteria used in the detailed analysis. Key
tradeoffs likey to occur among alternatives are noted.
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Finally, the findings specific to actions addressing PCBs
that should be documented in the Record of Decision are
presented.
Appendix A provides a summary of the Superfund sites
involving PCBs for which RODs have been signed, including
type of response action chosen and clean-up levels
specified.
Appendix B provides the detailed calculations supporting
the direct contact risk evaluation presented in Chapter 3.
Appendix C provides the backup calculations and
methodology for the example evaluation of long term
management controls presented in Chapter 4.
Appendix D includes two case studies of Superfund site
actions involving PCB contamination: Peppers Steel, FL
where the remedy involved solidification and Wide Beach, NY
where treatment using the KPEG process was selected.
Appendix E provides a list of the currently permitted
PCB disposal companies and their addresses and phone
numbers. It also includes a list of EPA's Regional PCB
disposal contacts in the TSCA program and their phone
numbers.
Appendix F provides examples of long-term management
controls implemented at several PCB Superfund sites where
varying concentrations of PCBs were left on site.
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Chapter 2
Potential ARARs and "To-Be-Considered" Guidelines
Pertinent to PCB Contamination Sites
Actions taken at Superfund sites must meet the mandates
of CERCLA as provided for in the NCP. This requires that
remedial actions protect human health and the environment,
comply with or waive applicable or relevant and appropriate
requirements/ be cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. In
addition, there is a preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as a
principal element. Although the basic Superfund approach to
addressing PCB-contaminated sites is consistent with other
laws and regulations, this consistency must be documented in
the feasability study and ROD to demonstrate that ARARs have
been attained or waived. Primary Federal ARARs 'for PCBs
derive from the Toxic Substances Control Act (TSCA) and the
Resource Conservation and Recovery Act (RCRA).
TSCA requires that material contaminated with PCBs at
concentrations of 50 ppm or greater be disposed of in an
incinerator or by an alternate method that achieves a level
of performance equivalent to incineration. Liquids at
concentrations above 50 ppm but less than 500 ppm and soils
contaminated above 50 ppm may also be disposed of in a
chemical waste landfill.
RCRA requirements apply to PCBs when liquid waste that
is hazardous under RCRA contains PCBs at concentrations
greater than 50 ppm or non-liquid hazardous waste contains
total HOCs at concentrations greater than 1000 ppm. The
land disposal restrictions require that prior to placing
this material on the land, it must be incinerated unless a
treatability variance is obtained.
Other requirements that derive from the Clean Water Act
(CWA) and Safe Drinking Water Act (SDWA) and their
implementing regulations may apply or be relevant and
appropriate when the site involves surface or ground water
contamination.
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2.1 National Contingency Plan (NCP) (U.S. EPA, I990a)
The primary regulation that governs actions at PCB-
contaminated Superfund sites is, of course, the National
Contingency Plan (NCP) , which defines the framework for
addressing the requirements of CERCLA. The provisions of
the NCP form the basis for the guidance provided in this
document and will not be discussed in detail here but will
be discussed in each section as they form the basic
structure for the approach. The NCP implements the
following CERCLA requirements:
o Protect human health and the environment (CERCLA Section
o Comply with the applicable or relevant and appropriate
requirements (ARARs) of Federal and State laws (CERCLA
Section 121 (d)(2)(A)) or justify a waiver (CERCLA
Section 121 (d) (4) )
o Be cost-effective, taking into consideration short- and
long-term costs (CERCLA Section 121(a))
o Utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable (CERCLA Section 121 (b) )
o Satisfy the preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as
a principal element or provide in the ROD an explanation
of why treatment was not chosen. (CERCLA Section 121 (b))
The nine evaluation criteria discussed in Section 5 are
designed to elicit the appropriate information that will
form the basis for demonstrating that these requirements
have been satisfied. Because remedies must attain the ARARs
of other Federal and State laws, some background and summary
material on the ARARs that address PCB contamination is
presented in this section.
ARARs for treating or managing PCB-contaminated material
derive primarily from two sets of regulations: the Toxic
Substances Control Act (TSCA) PCB regulations and the
Resource Conservation and Recovery Act (RCRA) land disposal
restrictions (LDRs) . Where PCBs affect ground or surface
water, the Safe Drinking Water Act (SDWA) and Clean Water
Act (CWA) may provide potential ARARs for establishing
remediation goals; i.e., Maximum Contaminant Levels (MCLs) ,
Maximum Contaminant Level Goals (MCLGs) , and Water Quality
Criteria (WQC) . In addition, the PCB Spill Policy, which is
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not an ARAR although it is published in the Code of Federal
Regulations, should be considered when determining cleanup
levels at a site. Other "to-be-considered" (TBC)
information is provided by guidances developed by the Office
of Toxic Substances to assist in implementing the PCB
regulations of TSCA.
2.2 TSCA PCB Regulations
The TSCA PCB regulations of importance to Superfund
actions are found in 40 CFR Section 761.60 - 761.79, Subpart
D: Storage and Disposal. They specify treatment, storage,
and disposal requirements for PCBs based on their form and
concentration. The disposal options for PCB-contaminated
material are summarized in Table 2-1 and discussed in the
following sections. A final section describes the storage
requirements.
TSCA requirements do not apply to PCBs at concentrations
less than 50 ppm; however, PCBs cannot be diluted to escape
TSCA requirements. Consequently, under TSCA PCBs that have
been deposited in the environment after the effective date
of the regulation, February 17, 1978, are treated, for the
purposes of determining disposal requirements, as if they
were at the concentration of the original material. For
example, if PCB transformers leaked oil containing PCBs at
greater than 500 ppm, the soil contaminated by the oil would
have to excavated and disposed of as if all of the PCB-
contaminated soil contained PCBs at greater than 500 ppm.
This reflects an interpretation of the anti-dilution
provisions in TSCA (40 CFR 761.l(b)) and was developed with
the intent of eliminating the incentive responsible parties
might have to dilute wastes in order to avoid regulation.
EPA has clarified that the TSCA anti-dilution provisions
are only applicable to CERCLA response actions that occur
once a remedial action is initiated (U.S. EPA, 1990a) . In
selecting response action strategies and cleanup levels
under CERCLA, EPA should evaluate the form and concentration
of the PCB contamination "as found" at the site, and dispose
of it in accordance with the requirements of 40 CFR
761.60(a)(2) - (5). Cleanup levels and technologies should
not be selected based on the form and concentration of the
original PCB material spilled or disposed of at the si,te
prior to EPA's involvement (i.e., the anti-dilution
provision of the PCB rules should not be applied). Because
EPA comes to a site under the CERCLA after the pollution has
already occurred, and is acting under statutory mandate to
select a proper cleanup level, EPA is not subject to the
anti-dilution provision at CERCLA sites when it selects a
remedy. However, the Agency may not further dilute the PCB
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Table 2-1
REMEDIATION OPTIONS FOR PCB WASTE UNDER TSCA
PCB waste
category
Liquid PCB
Liquids with
flash point > 60° C
Liquids with
flash point < 60° C
Other liquids thai are
also hazardous waste*
Other liquids thai are
also hazardous wastes
Nonliquids (soil.
rags, debris)
Dredged materials
and minicipal sewage
sludge
PCB transformers
(drained and flushed)
PCB capacitors6
PCB capacitors
PCB hydraulic machines
PCB contaminated
electrical equipment
(except capacitors)
Other PCB articles
Other PCB articles
PCB cor miners
PCB containers
All other PCBs
40 cm
Section
781 .00
761.75
761.75
268.42|a][1]
268.42la][1l
761.60[a][4]
761.60[a](5J
761.60[b|[1)
761.60[b][2]
761.60(b)[4J
761.60[b][3)
761.60[b][4)
761.60[b](5]
761.60[b)[5]
761.60[c]
761.60[c]
761.60(a]
Chemical High
PCS waste efficiency Alternative
concentration Incinerator landfill boiler method
(ppm) (J761.70) (8761.75) (6,761.80) <§761.60(e))
2500 X x
50-500 X X .X X
50-500 X XX
50-500 X XX
2500 ^ X X
250 'XX X
250 X X X
»>Ł* X X
2500 X
50-500 X X
250
2500* X X*
50-500
2500* X x"
<500
250 X X
Method Drain.
approved dispose as
by region solid waste Decontamination
X
xc'd
X*
X*
x"
x" x"
BNot specified.
"Exemptions for tome small capacitors.
°Must also be flushed If hydraulic fluid contain* >1.0OO ppm PCB« and flushing solvent disposed of in accordance wtlh §761.60(«).
d Drained liquid must be disposed of In accordance with }781.60(a).
"Must be drained of all tru floatnt liquid. The disposal ol the drained electrical equipment and other PCB article* is not regulated
by 40 CFR 761. All HqukJ* MUM »• dMprjsid of In accordance with paragraph (a)(2) or (3) of $761.60 [in an Incinerator (8761.70). chemical
waste landfill (761.75). Mgh ••atancy boiler, or by an alternative method (§76l.6O(e)l.
*
' Due to a typographical error. 40 CRt 7B1 (Jury 2. 1985. p. 163) erroneously stale* this value m SO ppm; refer to Federal Register, 44.
31514-31568 (May 3.1979) (U8G>A>.
"Drained of any free-flowing liquid and Iquld Indnermied In a $761.70 Incinerator.
"Decontaminated In compliance with {761.79.
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waste in order to avoid the TSCA PCB disposal requirements
as part of a CERLCA cleanup.
2.2.1 Liquid PCBs at Concentrations Greater Than 500 ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. High Eff. Alt.
761.70 Boiler Method
761.60 761.60fe)
Liquid PCB 761.60 X
268.42(a)(1) X
Other Liq.
also Haz.
Liquid PCBs at concentrations greater than 500 ppm must
be disposed of in an incinerator which complies with 40 CFR
761.70 or by an alternative disposal method that achieves a
level of performance equivalent to incineration as provided
under 76l.60(e). This has been interpreted to imply that
treatment residuals must contain less than 2 ppm PCBs.
2.2.2 Liquid PCBs at Concentrations Between 50 ppm and 500
ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. High Eff. Alt. Chem.
761.70 Boiler Method Waste
761.60 761.60(e)Landfl,
761.75
Liq. w/ 761.75 XX XX
flash pt > 60C
Liq. w/ 761.75 XX X
flash pt < 60C
Other liq.268.42(a)(a) X
also haz.
X
Liquid PCBs at concentrations between 50 ppm and 500
ppm, can be disposed of in an incinerator or high efficiency
boiler as described above, or in a facility that provides an
alternative method of destroying PCBs that achieves a level
of performance equivalent to incineration (equivalent
method) approved under 40 CFR 761.60(e) (i.e., demonstrate
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achievement of less than 2 ppm PCBs in the treatment
residual).
Liquids at these concentrations with a flash point
greater than 60 degrees Centigrade (not considered
ignitable as defined in 761.75(b) (8) (iii) ) other than
mineral oil dielectric fluid, can also be disposed of in a
chemical waste landfill which complies with 40 CFR 761.75.
However, the following actions must be taken:
o Bulk liquids must be pretreated and/or stabilized (e.g.,
chemically fixed, evaporated, mixed with dry inert
absorbant) to reduce its liquid content or increase its
solid content so that a non-flowing consistency is
achieved;
o Containers of liquid PCBs must be surrounded by an
amount of inert sorbant material capable of absorbing
all of the liquid contents of the container.
2.2.3 Non-Liquid PCBs at Concentrations Greater Than or
Equal to 50 ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. Alt. Chem. Method
761.70 Treatmt. Waste Apprvd.
761.60(e)Landfl. by RA
761.75 761.60(a^ (5}
Non-liq. 761.60(a)(4) XXX
soil, rags,
debris
Dredged 761.60(a)(5) X X . X X
material, munic.
sewage sludge
Soils and municipal sludges contaminated with PCBs at
concentrations greater than or equal to 50 ppm can be
disposed of in an incinerator, treated by an equivalent
method, or disposed of in a chemical waste landfill.
Industrial sludges with PCB concentrations greater than 500
ppm may not be landfilled. The determination of whether
contaminated material should be considered a soil or an
industrial sludge should be made site specifically
consistent with the current process for classifying material
subject to the land disposal restrictions as either a pure
waste or a soil and debris contaminated with a waste.
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Waste Cat.
40CFR Sec. Incin.
761.70'
X
X
Dredged materials and municipal sewage treatment sludges
that contain PCBs at concentrations greater than or equal to
50 ppm can also be disposed of by methods other than those
noted above that are approved by the Regional Administrator.
It must be demonstrated that disposal in an incinerator or
chemical waste landfill is not reasonable and appropriate,
and that the alternate disposal method will provide adequate
protection to health and the environment.
2.2.4 PCB Articles, Containers, Electrical Equipment
Remediation Options for PCB Waste Under TSCA/RCRA
Alt. Chem. Drain Decon.
Treatmt. Waste Dispose
761.60(e)Landfl.as sol.
761.75 waste
PCB 761.60(b)(1) X X X
transformers
PCB 761.60(b)(2)
capacitors
(>= 500 ppm)
PCB 761.60(b)(4)
capacitors
(50 - 500 ppm)
PCB hyd. 761.60(b)(3)
machines
PCB elec.761.60(b)(4)
equip.
PCB 761.60(b)(5)
articles
(>=500 ppm)
PCB 761.60(b)(5)
articles
(50 - 500 ppm)
PCB 761.60(c)
containers
(>=500 ppm)
PCB 761.60(c)
containers
(<500 ppm)
X
X
PCB transformers and capacitors (by definition (40CFR
761.60) these contain 500 ppm PCB or greater as opposed to
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PCB-contaminated electrical equipment which contains less
than 500 ppm) must be disposed of in an incinerator, by an
alternate method which can achieve a level of performance
equal to incineration, or in a chemical waste landfill.
However, special procedures must be followed for disposing
of transformers in chemical waste landfills and a special .
showing indicating that incineration capacity does not
exist, that incineration of the capacitors will interfere
with the incineration of liquid PCBs, or other good cause,
must be made for disposing capacitors in landfills. These
are described in 40 CFR 761.60(b).
PCB-contaminated electrical equipment' (this includes
transformers and other equipment other than capacitors which
contain PCBs between 50 ppm and 500 ppm) must be drained of
all free flowing liquid. The liquid must be disposed of in
an incinerator, by an equivalent method, or in a chemical
waste landfill. The drained equipment is not covered under
TSCA regulations. PCB-contaminated capacitors must be
disposed of in an incinerator or a chemical waste landfill.
PCB articles and containers with PCB concentrations
greater than 500 ppm must be incinerated or disposed of in a
chemical waste landfill provided all free flowing liquid is
drained and incinerated. PCB articles and containers with
PCB concentrations between 50 ppm and 500 ppm must be
disposed of by draining all free flowing liquid and
appropriately disposing of the liquid. The drained articles
and containers can be disposed of as municipal solid waste.
2.2.5 TSCA Chemical Waste Landfill Requirements
The requirements for chemical waste landfills are
described in 40 CFR Section 761.75 and outlined in Table 2-
2. As indicated, the regulations do not require caps
because the regulations were designed for operating
landfills. Where Superfund remedial actions will leave PCBs
in place or where PCB-contaminated material is excavated,
treated, and re-disposed at concentrations that still pose a
threat, capping consistent with chemical waste landfill
requirements is generally appropriate. (Long-term
management controls for PCB-contaminated material generally
will also parallel RCRA closures.) However, some of the
requirements specified under TSCA may not always be
appropriate for existing waste disposal sites like those
addressed by Superfund. When this is the case, it may be
appropriate to waive certain requirements, such as liners,
under the TSCA waiver provisions, 761.75(c) (4) .
Requirements may be waived when it can be demonstrated that
operation of the landfill will not present an unreasonable
risk of injury to health or the environment. This
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Table 2-2
TSCA CHEMICAL WASTE LANDFILL REQUIREMENTS
(40 CFR SECTION 761.75)
1. Located in thick, relatively impermeable formation such as large area clay pans, or.
• On soil with high clay and silt content with the following parameters:
- in-place soil thickness of four feet or compacted soil liner thickness of three feet
- permeability equal to or less than 1 x 10"
- percent soil passing No. 200 Sieve, greater than 30
- liquid limit greater than 30
- plasticity index greater than 15.
• On a synthetic membrane liner (minimum thickness of 30 mils.) providing permeability equivalent to the soil
described above including adequate soil underlining and soil cover to prevent excessive stress on or rupture of
the liner.
2. A. Bottom of the landfill liner system or natural in-place soil barrier at least 50 feet from the historical high
.ground water table. Floodplains, shorelands, and ground water recharge areas shall be avoided and there shall
be no hydraulic connection between the site and standing or flowing surface water.
B. If the landfill is below the 100-year floodwater elevation, surface water diversion dikes should be constructed
around the perimeter with a minimum height equal to two feet above the 100-year floodwater elevation.
If the landfill is above the 100-year floodwater elevation, diversion structures capable of diverting all of the
surface water runoff from 24-hour, 25-year storm.
3. Located in an area of low to moderate relief to minimize erosion and to help prevent landslides or slumping.
4. Sampling of designated surface watercourses monthly during disposal activities and
once every six months after disposal is completed.
5. Ground water monitoring at a minimum of three points (equally spaced on a line through ths center of the
landfill), sampling frequency determined on a site specific basis (not specified in regulation) samples analyzed
for PCBs, pH, specific conductance, and chlorinated organics.
6. Leachate Collection System:
A. Gravity flow drainfield installed above the liner (recommended for use when semi-solid or leachable solid
wastes are placed in a lined pil excavated into a relatively unsaturated homogeneous layer of low permeable
soil) or
B. Gravity flow drainfield installed above the liner and above a secondary liner (recommended for use when
semi-liquid or leachable solid wastes are placed in a lined pit excavated into relatively permeable soil) or
C. Network of porous ceramic cups connected by hoses/tubing to a vacuum pump installed along the sides and
under the bottom of the waste disposal facility liner (recommended for relatively permeable unsaturated soil
immediately adjacent to the bottom and/or sides of the disposal facility).
7. Installation of a six foot woven mesh fence, wall, or similar device to prevent unauthorized persons and animals.
Note: Waiver Provision (761.75 (c)(4))- One or more of the above requirements may be waived as long as operation
of the landfill will not present an unreasonable risk of injury to health or the environment.
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demonstration may require column studies verifying that PCB
movement through the soil will not adversely affect ground
water. These waivers, are distinct from the six waivers from
ARARs provided under CERCLA Section 121(d)(2), which may
also be invoked under appropriate circumstances.
2.2.6 Storage Requirements
The requirements for storage of PCBs are described in
40 CFR Section 761.65. The regulations specify that PCBs at
concentrations of 50 ppm or greater must be disposed of
within one year after being placed in storage. The
regulations also include structural requirements for
facilities used for the storage of PCBs and requirements for
containers used to store PCBs.
PCBs stored as part of a Superfund action should be
placed in facilities that meet the following specifications:
o Provide an adequate roof and walls to prevent rain
water from reaching the stored PCBs,
o Provide an adequate floor which has continuous curbing
with a minimum six inch high curb,
o Contain no drain valves, floor drains, expansion
joints, sewer lines, or other openings that would
permit liquids to flow from the curbed area,
o Floors and curbing constructed of continuous smooth and
impervious materials, to minimize penetration of PCBs;
and '
o Not located at a site that is below the 100-year flood
water elevation.
PCBs subject to TSCA should not be stored longer than one
year. In some cases, PCB-contaminated material may be
generated during the RI/FS that will require storage that
may exceed the one-year limitation under TSCA. Where the
final disposition of the waste will be specified in the ROD,
the exceedence of the TSCA storage limitation may be
justified using a CERCLA waiver. An interim remedy waiver
under CERCLA could be invoked. Since the removal action is
interim in nature and the remedy determined in the ROD will
comply with ARARs for final disposition of the waste, a
waiver of the ARAR is justified. A memorandum supporting
the action should be prepared and placed in the
administrative record to document the finding.
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2.3 RCRA Regulations Addressing PCBs
Closure requirements described under RCRA are considered
potentially applicable or relevant and appropriate at
Superfund sites. A detailed discussion of these
requirements is not presented in this document since they
are not specific to PCBs. Instead, guidelines for long
term management controls consistent with RCRA closure
requirements that are warranted under various closure
scenarios are provided in section 4.3. (Further discussion
of the closure requirements under RCRA and their use at
Superfund sites can be found in the CERCLA Compliance With
Other Laws Manual (U.S. EPA, 1989b).)
PCBs are specifically addressed under RCRA in 40 CFR 268
which describes the prohibitions on land disposal of various
hazardous wastes. Note that RCRA regulations only apply to
waste that is considered hazardous under RCRA; i.e., listed
in 40 CFR 261.3 or characteristic as described in 40 CFR
261.2. PCBs alone are not a RCRA hazardous waste; however,
if the PCBs are mixed with a RCRA hazardous waste they may
be subject to land disposal restrictions as summarized
below.
PCBs are one of the constituents addressed by the land
disposal restrictions under the California List Wastes.
This subsection of wastes covers liquid hazardous wastes
containing PCBs at concentrations greater than or equal to
50 ppm and non-liquid hazardous wastes containing total
concentrations of Halogeriated Organic Compounds (HOCs) at
concentrations greater than 1000 ppm. PCBs are included in
the list of HOCs provided in the regulation (Appendix III
part 268).
2.3.1 Liquid Hazardous Waste With PCBs at 50 ppm or Greater
As described in 40 CFR 268.42(a)(1), liquid hazardous
(RCRA listed or characteristic) wastes containing PCBs at
concentrations greater than or equal to 500 ppm must be
incinerated in a facility meeting the requirements of 40 CFR
761.70. Liquid hazardous wastes containing PCBs at
concentrations greater than or equal to 50 ppm but less than
500 ppm must be incinerated or burned in a high efficiency
boiler meeting the requirements of 40 CFR 761.60.
A method of treatment equivalent to the required
treatment may also be used under a treatability variance
procedure if the alternate treatment can achieve a level of
performance equivalent to that achieved by the specified
method as described in 40. CFR 268.42(b).
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2.3.2 Hazardous Waste With HOCs at 1000 ppm or Greater
Liquid and non-liquid hazardous wastes containing HOCs
in total concentration greater than or equal to 1000 ppm
must be incinerated in accordance with the requirement of 40
CFR 264 Subpart O.
Again, a method of treatment equivalent to the required
treatment, under a treatability variance, may also be used.
Special considerations are pertinent for waste that
falls into the category of soil and debris from a CERCLA
remedial action or RCRA Corrective Action. The land
disposal restrictions for CERCLA soil and debris went into
effect November 8, 1988; however, no standards for disposal
were published at that time. Consequently soil and debris
contaminated with hazardous waste is banned from land
disposal unless it meets existing standards for the pure .
waste or qualifies for a treatability variance. The
preamble to the NCP, established a general presumption that
a treatability variance is warranted for CERCLA soil and
debris. Alternate treatment levels should be justified
based on the treatability variance guidance levels (U.S.
EPA, 1989h). For PCBs, residuals after treatment should
contain .1 to 10 ppm PCBs for initial concentrations up to
100 ppm and above 100 ppm, treatment should achieve 90 to
99% reduction in concentration to qualify for a treatability
variance.
Finally, hazardous wastes for which the treatment method
is incineration or the treatment standard was based on
incineration are subject to a 2-year capacity extension from
the time that the standard went into place. Wastes that
qualify for a capacity extension can be disposed without
meeting the treatment requirements; however, they must be
disposed of in a facility that is in compliance with the
minimum technology requirements established for landfills in
section 3004(o) of RCRA. The capacity extension for
California List wastes when they are present in CERCLA soil
and debris extends until November 8, 1990.
2.4 Clean Water Act
The Clean Water Act establishes requirements and
discharge limits for actions that affect surface water.
Water Quality Criteria (WQC) indicating concentrations of
concern for surface water based on human exposure through
drinking the water and ingesting fish as well as
concentrations of concern to aquatic life have been
developed for many compounds. For PCBs, the WQC for chronic
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exposure through drinking water and fish ingestion is
.000079 ppb based on an excess cancer risk of 10~6. This
assumes consumption of 6.5 grains of estuarine fish and
shellfish products and 2 liters of water per day over a 70
year lifetime. The level is the same if consumption of
water is excluded indicating a relative negligible impact
due to this source.
Acute toxicity to freshwater aquatic life is estimated
to occur only at concentrations above 2 ppb. Acute toxicity
to saltwater aquatic life is estimated to occur only at
concentrations above 10 ppb. The water quality criteria for
chronic effects are .014 ppb and .03 ppb for fresh and
saltwater aquatic life, respectively.
These values are used as guides in the development of
water quality standards for surface water that are enforced
at the State level. States may account for other factors in
establishing these standards including physical, chemical, '
biological, and economic factors. State standards and/or
WQC are ARAR for surface water discharges. More detailed
discussion of the CWA ARARs can be found in the CERCLA
Compliance Manual (U.S. EPA, 1989b).
2.5 Safe Drinking Water Act
Under the Safe Drinking Water Act (SDWA), Maximum
Contaminant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) are established. MCLs for carcinogens are
generally set at levels that reflect an excess cancer risk
due to drinking 2 liters of water per day over a 70 year
life of between 10'4 and 10"6. They are set as close as
practicable to the MCLG (which for carcinogens is zero)
accounting for the use of the best available technology,
cost, and analytical capabilities. MCLs must be attained by
public water supplies. MCLGs are goals set at levels that
would result in no known or anticipated adverse effects to
human health over a lifetime. At Superfund sites, MCLs and
non-zero MCLGs may be relevant and appropriate to
contaminated ground water that is or could be used as
drinking water.
An MCL of .5 ppb was proposed for PCBs in May 1989 (U.S.
EPA, 1989d). The MCLG is zero because PCBs are possible
carcinogens. As a proposed MCL, the .5 ppb level is a TBC
that EPA recommends be considered in determining the
appropriate cleanup level for potentially drinkable ground
water. (The MCL for PCBs is expected to be finalized by
September 1990.) More detailed discussion of the SDWA
ARARs can be found in the CERCLA Compliance Manual (U.S.
EPA, 1989b).
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2.6 PCB Spill Cleanup Policy Under TSCA
The PCB Spill Cleanup Policy was published in 40 CFR
761.120 - 761.139 on April 2, 1987 and describes the level
of cleanup required for PCB spills occurring after May 4,
1987 (the effective date). Because it is not a regulation
and only applies to recent spills (reported within 24 hours
of occurrence), the Spill Policy is not ARAR for Superfund
response actions; however, as a codified policy representing
substantial scientific and technical evaluation it has been
considered in developing the guidance cleanup levels
discussed in section 3. A summary of the policy follows.
2.6.1 Low Concentration, Low Volume Spills All Areas
For spills of low concentration PCBs (50 ppm to 500 ppm)
involving less than one pound of PCBs, cleanup in accordance
with procedural performance requirements is required. The
requirements consist of double wash rinse and cleanup of
indoor residential surfaces to 10 micrograms (ug) per 100
square centimeters (cm2) analyzed by a wipe test, and
excavation of all soils within the spill area plus a 1-foot
lateral boundary of soil and other ground media and
backfilling with clean (less than 1 ppm PCB) soil. No
confirmation sampling is required.
2.6.2 Non-Restricted Access Areas
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound PCBs by weight in
non-restricted access areas, materials such as household
furnishings and toys must be disposed of and soil and other
similar materials must be cleaned up to 10 ppm PCBs,
provided that the minimum depth of excavation is 10 inches.
In addition, a cap of at least 10 inches of clean materials
must be placed on top of the excavated area. Indoor and
outdoor surfaces must be cleaned to 10 ug/100 cm2, but low
contact outdoor surfaces may be cleaned to 100 ug/100 cm2
and encapsulated. Post clean-up sampling is required.
2.6.3 Industrial Areas
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound in industrial and
other restricted access areas, cleanup of soil, sand, and
gravel to 25 ppm PCBs is required. Indoor high contact and
outdoor high contact surfaces must be cleaned to 10 ug/100
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cm2. Indoor low contact surfaces may be cleaned to 10
ug/100 cm2 or to 100 ug/100 cm2 and encapsulated. Outdoor
low contact surfaces may be cleaned to 100 ug/100 cm2., Post
cleanup sampling is required.
2.6.4 Outdoor Electrical Substations
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound at an outdoor
electrical substation, cleanup of solid materials such as
soils to 25 ppm or to 50 ppm (with a sign posted) is
required. All surfaces must be cleaned to 100 ug/100 cm2.
Post cleanup sampling is required.
2.6.5 Special Situations
For particular situations, decontamination to site-
specific requirements established by EPA Regional Offices is
required. These situations are:
1. Spills that result in direct contamination of surface
waters;
2. Spills that result in direct contamination of sewers or
sewage treatment systems;
3. Spills that result in direct contamination of any
private or public drinking water sources;
4. Spills which migrate to and contaminate surface waters,
sewers, or drinking water supplies;
5. Spills that contaminate animal grazing land; and
6. Spills that contaminate vegetable gardens.
2.7 Guidances
Several documents have been produced that provide
background information and guidance on complying with the
regulations and policy described above. Pertinent
information provided by some of the more important documents
are described in this section. This material is "to-be-
considered" in developing remedies at Superfund sites.
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2.7.1 Draft Guidelines for Permit Applications and
Demonstrations — Test Plans for PCB Disposal by Non-
Thermal Alternate Methods (U.S. EPA, 1986c)
The most significant information in this document
affecting actions taking place at Superfund sites is the
discussion provided on evaluating the "equivalency" of
technologies to incineration. As described in section 2.2,
most PCB-contaminated material can be treated by an
alternate method provided that it can achieve a level of
performance equivalent to an incinerator or a high
efficiency boiler. The guidance manual indicates that an
equivalent level of performance for an alternate method of
treatment of PCB-contaminated material is demonstrated if it
reduces the level of PCBs to less than 2 ppm measured in the
treated residual. The residual can then be disposed of on-
site without further regulation. Otherwise, the material
must be treated as if it were contaminated at the original
level (i.e., disposed of in a chemical waste landfill or
incinerated).
This level was based on the practical limit of
quantification for PCBs in an organic matrix and
consequently does not apply to aqueous or air emissions
produced by the treatment process. For aqueous streams the
guidance provides that they must contain less than 3 ppb
PCBs. Releases to air roust be less than 10 ug of PCBs per
cubic meter. It should be noted that these levels apply to
treatment processes only and were not intended to be used as
cleanup standards for reentry or reuse.
2.7.2 Verification of PCB Spill Cleanup by Sampling and
Analysis (U.S. EPA, 1985b)
This document describes methods for sampling and
analyzing PCBs in various media. It also includes basic
sampling strategies, identification of sampling locations,
and guidance on interpreting sampling results. This manual
may be useful in developing sampling plans at Superfund
sites and in identifying appropriate methods for complicated
sampling, for instance sampling of structures.
2.7.3 Field Manual for Grid Sampling of PCB Spill Sites to
Verify Cleanup (U.S. EPA, 1986b)
This manual provides a step-by-step guidance for using
hexagonal grid sampling primarily for determining if cleanup
levels have been attained at the site. It discusses
preparation of the sample design, collection, handling and
preservation of the samples taken, maintenance of quality
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assurance and quality control, and documentation of sampling
procedures used. It is a companion to the guidance
described in section 2.7.2 that discusses in more detail the
rationale and techniques selected. The field manual
addresses field sampling only and does not provide
information on laboratory procedures. This guidance may be
useful in specifying the appropriate sampling after or
during remedial action to assess progress toward achieving
cleanup goals.
2.7.4 Development of Advisory Levels for PCB Cleanup (U.S.
•EPA 1986a)
This document provides the basis for the cleanup levels
developed in the PCB Spill Policy. It discusses the
assumptions made in addressing the dermal contact,
inhalation, and ingestion pathways and may provide useful
information for completing risk assessments at Superfund
sites. An update to the calculations made in this document
to account for recent policy on standard ingestion
assumptions and revised cancer potency factor for PCBs has
been provided in a memorandum (U.S. EPA, 1988d).
2.7.5 Risk Assessment Guidance for Superfund: Human Health
Evaluation (RAG) (U.S. EPA, 1989e)
This document describes the human health evaluation
process conducted as part of the risk assessment at
Superfund sites. It includes standard assumptions for
various exposure pathways that have been used to calculate
starting point action levels in section 3 of this document.
A second volume, Environmental Evaluation Manual,
addressing the environmental evaluation provides general
guidelines on considerations pertinent to evaluating the
impact of contamination on the environment.
25
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Chapter 3
Cleanup Level Determination
This section describes various scenarios and
considerations pertinent to determining the appropriate
level of PCBs that can be left in each media that is
contaminated to achieve protection of human health and the
environment. For soils, the starting point action level
(preliminary remediation goal) is 1 ppm for sites where
unlimited exposure under residential land use is assumed.
Higher starting point values (10 to 25 ppm) are suggested
for sites where the exposure scenario is industrial.
Remediation goals for ground water that is potentially
drinkable should be the proposed MCL of .5 ppb. Cleanup
levels associated with surface water should' account for the
potential use of the surface water as drinking water,
impacts to aquatic life, and impacts through the food chain.
Occasionally, stormwater runoff to nearby streams can
contribute significant environmental or health risks,
especially to those eating contaminated fish.
26
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3.1 Soils
The concentration of PCBs in the soil above which some
action should be considered (i.e., treatment or containment)
will depend primarily on the exposure estimated in the
baseline risk assessment based on current and potential
future land use. This section has correspondingly been
organized according to categories of alternatives
differentiated by the expected direct contact that will
occur. Other factors influencing the concentration to which
soils should be excavated or contained include the impact
the residual concentration will have on ground water and
potential environmental impacts. Since these pathways are
pertinent to all site categories, they are discussed in
separate sections. The guideline concentrations provided in
this section do not imply that action must be taken at a
Superfund site, rather they indicate the area over which
some action should be considered once it has been determined
that action is necessary to provide protection of human
health and the environment.
A summary of the guidelines discussed in this section is
presented in Table 3-1.
TABLE 3-1
Recommended Soil Action Levels — Analytical Starting
Points
(Considers ingestion, inhalation, and dermal contact only)
Land Use PCS Action Levels (ppm)
Residential 1 ppm
Industrial 10-25 ppm
These action levels and the assumptions discussed in the
following sections can be used to reduce the need for
detailed site-specific risk assessments; however, future
site uses should be well understood and final cleanup levels
must still reflect all relevant exposure pathways and be
defensible on a site-specific basis.
The analysis of PCBs is complicated by the fact that
there are 209 different PCB compounds1 (Alford-Stevens,
1986). Common analytical methods are listed in Table 3-2.
'Aracholors are groups of PCBs with different overall
percentages of chlorine. For example, Arochlor 1242 contains 42%
chlorine made up of tri- and tetra- chlorinated biphenyls. PCB
isomers are those compounds that have the same number of chlorine
atoms. Individual PCBs isomers, of which there are 209, are
called congeners.
27
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3.1.1 Preliminary Remediation Goals for Residential Areas
The concentration that defines the area over which some
action must be taken is the concentration of PCBs that can
protectively be left on site without management controls.
In areas where land use is residential, this concentration
will be based on standard assumptions for direct* contact —
dermal, ingestion, and inhalation — and should consider
potential impact to ground water, which is discussed in
section 3.1.4.
For Superfund sites, the risk remaining after
remediation should generally fall within the range of 10"4
to 10"6 individual excess cancer risk. Based on the
standard exposure assumptions associated with residential
land use (ingestion, inhalation, and dermal contact),
concentrations of . 1 ppm PCBs to 10 ppm PCBs will generally
fall within the protective range. A concentration of 1 ppm
PCBs equates to approximately a 10~5 excess cancer risk
assuming no soil cover or management controls. The 1 ppm
starting point for residential scenarios reflects a
protective, quantifiable concentration for soil. Lower
concentrations (e.g., reflecting a 10"6 risk level) are not
generally quantifiable and in many cases will be below
background concentrations. (Because of the persistence and
pervasiveness of PCBs, PCBs will be present in background
samples at many sites.) A concentration of 1 ppm PCBs
should therefore generally be the starting point for
analysis at PCB-contaminated Superfund sites where land use
is residential. Alternatives should reduce concentration to
this level or limit exposure to concentrations above this
level.
As part of the development of the cleanup levels in the
PCB Spill Cleanup Policy, a detailed analysis of the direct
contact pathways was performed by the EPA Office of Health
and Environmental Assessment (U.S. EPA, 1986a) . This
analysis was subsequently updated to account for the revised
cancer potency factor and ingestion assumptions (U.S. EPA,
1988d). This analysis estimates risk levels associated with
various concentrations of PCBs based on physical parameters
of PCB 1254. It is also estimated that a 10 inch cover of
clean soil will reduce risks by approximately one order of
magnitude. Using some of the basic assumptions associated
with PCBs (e.g., mobility, volatility, absorption) described
in this analysis and the standard exposure assumptions for
residential land use presented in the Risk Assessment
Guidance (U.S. EPA, 1989e), risk levels associated with
various concentrations of PCBs in soil were calculated (see
Appendix B). This analysis forms the basis for the
28
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Water
Table 3-2
ANALYTICAL METHODS FOR PCBs
Matrix
Oil
Soil/
Sediment
Method
Bellar and Lichtenberg
ASTM 04059
Method 680
3,5
Method 608
GC GC/MS
yes
yes .
yes
yes
Detection Limit
less than 2 ppm
less than 2 ppm
~ 100 ppb
0.1-0.5ppb
Quantification Limit
2 ppm
2 ppm
1 ppm
80 ppb
EPA Method 505
(Microextraction)
4
Method 508A
(Perchlorination)
yes
0.1 - 0.5 ppb not given
(based on the
arochlor present)
0.1 - 0.5 ppb (as not given
decachlorobiphenyl)
Air
Method 680
3,5
Method 608
N1OSH Method 5503
yes
yes
yes
~ 100 ppb
0.1 -0.5 ppb
1 ppm
0.5 ppb
Florosil sorbent,
hexane extraction,
GC/ECD
1 Detection limit indicates the concentration above which the presence of PCBs will be detected by
the analytical method.
2 Quantification limit indicates the concentration above which the quantity of PCBs present can be
determined.
3 U.S. EPA, 19S6d.
4 U.S. EPA, 1988a, Glaser, 1981.
5 Method 608 depends on the presence of an intact Arochlor. Analysts can estimate possible PCB
concentrations when intact Arochlors are not present. However, if this is done the presence of
PCBs should be confirmed using Method 680. Method 680 can identify PCB isomers.
29
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analytical starting point summarized here. The primary
assumptions and an example calculation for a PCB
concentration of 1 ppm are shown in Table 3-3. It should be
noted that some of these assumptions may be overly
conservative on a site-specific basis. For example, the
calculation for the inhalation pathway assumes that someone
is on the site 24 hours a day for 30 years and that the
concentration of PCBs in the air in a house on this site
will be the same as the concentration in the air outside.
In many cases, partial covering of the soil will limit the
level of PCBs that can volatilize. Another consideration is
that the calculation was based on the properties of Arachlor
1254 and properties may vary for different congeners as
shown in Table 3-4. Toxicities may also vary (McFarland,
1989; Kimbrough, 1987; Safe, 1985), though there is limited
information on this and the toxicity based on Arachlors 1254
or 1260 should generally be used.
As noted above, these calculations reflect direct
exposure assumptions only and may not be appropriate where
ground water or ecological habitats are potentially
threatened. These levels are consistent with the guidance
provided by the PCB Spill Cleanup Policy which recommends a
10 ppm cleanup level with a 10 inch cover for residential
areas.
3.1.2 Preliminary Remediation Goals for Industrial/Remote
Areas
In remote areas or areas where land use is industrial, a
more appropriate concentration at which to start analysis
may be 10 to 25 ppm, since direct exposure is less frequent
than for residential land use and higher concentrations will
be protective. (Under the PCB Spill Policy this category
includes sites that are more than .1 km from
residential/commercial areas or where access is limited by
either man-made or natural barriers (e.g., fences or
cliffs).) For example, at Superfund sites located in
industrial areas ingestion and inhalation exposures are more
limited than for a residential area. Even assuming exposure
equivalent to that in residential areas, these levels (10 to
25 ppm) ar% still within the acceptable risk range
(approxima1b>Ely 10"4) based on the direct contact exposure
pathways, *nd in fact will reflect a lower risk due to the
reduced frequency of exposure expected at the site. This is
consistent with the PCB Spill Cleanup Policy which
recommends a cleanup level of 25 to 50 ppm for sites in
30
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Table 3-3
PCB DIRECT CONTACT ASSUMPTIONS
(See Appendix B for detailed calculation)
INGESTION:
Soil ingestion (1 to 6 years) 0.2 g/day1
Soil ingestion (7 to 24 years) 0.1 g/day *
Body weight child 16 kg*
Body weight adult 70 kg*
Absorption of PCBs from
ingested soil 30%^
INHALATION
Adult inhalation rate 30 m
Lung absorption of inhaled PCBs 50%
DERMAL
Surface area (3-18 years) 0.4 m^/event*
Surface are (adult) 0.31 m^/eventl
Soil to skin adherence factor 2.77 mg/cm^/l
Exposure frequency (child) 132 events/year^
Exposure frequency (adult) 52 events/year
Adsorption fraction
To estimate exposure, the average concentration of PCBs in soil over the exposure period is
calculated. The concentration of PCBs will decrease with time due to volatilization.
EXAMPLE CALCULATION
At 1 ppm PCB initial soil concentration:
Average concentration over 10 inches over 6 years = 0.54 ppm
Average concentration over 10 inches over 30 years .= 0.28 ppm
Risk due to soil ingestion = 2 X 1(H>
Risk due to inhalation = 7 X 10*6
Risk due to dermal contact = 7 X 10~6
Total risk (all pathways) = 1.6 X 10'5
^U.S. EPA, 1989e
2U.S. EPA, 1986a
3U.S. EPA, 1986a
31
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Table 3-4
CHEMICAL AND PHYSICAL PROPERTIES OF PCBs
Molecular
PCB Weight KOW
PCB-1016
(Arochlor 1016) 257.9 24,000
PCB- 1221 200.7 12,000
PCB-1232 -232.2 35,000
PCB- 1242 266.5 380,000
PCB-1248 299.5 1,300,000
PCB-1254- 328.4 1,070,000
PCB-1260 377.5 14,000,000
PCB- 1262
PCB- 1268
PCB-1270
PCB-2565
PCB-4465
PCB-5442
PCB-5460
2,21,5,5'-Tetra-
chlorobiphenyl
2,2',3,4,5-Penta-
chlorobiphenyl
Specific
Gravity
1.182
1.266
1.380
1.445
1.538
1.620
1.646
1.810
1.947
1.727
1.712
1.434
1.740
Solubility a
in Water
(mg/l)
0.42
15.0
1.45
0.24
5.4 x 10"2
1.2x 10"2
2.7 x 10"3
4.6 x 10"2
2.2 x 10'2
Vapor
Pressure Henry's Law
(mm Hg) Constant
at 25°C (atm-nrVgmol)
4x 10-4
6.7 x ID"4
4.06 xlO'3
-4b
4.06 x 10 ^ 5.73 xlO"4
A 3b
4.94 x 10 "4 3.51 x 10 j
7.71 x 10 '5 8.37 xlO"3
4.05 x 10'5 7.l3x 10'3
aHutzinger et al., 1974, Monsanto Chemical Co., undated.
bMacKay andLeinonen, 1975.
c Hwang, 1982, and U.S. EPA, 1980b.
Bioaccumulation factor: 31^00 L/kg, (U.S. EPA, 1986a)
Soil-water partition coefficient (U.S. EPA, 1980a): 22 - 1938 L/kg.
32
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industrial or other reduced access areas.2
3.1.3 Assessing the Impact to Ground Water
Generally, PCB soil cleanup levels based on direct
contact assumptions will provide sufficient protection of
ground water. However, if ground water is very shallow,
oily compounds are or were present, or the unsaturated zone
has a very low organic carbon content, an additional
evaluation of the residual concentration that will not
exceed levels found to be protective for ground water should
be made.
There are many factors such as soil permeability,
organic carbon content, and the presence of organic
colloids, which can influence PCB movement from soil .into
ground water. The situation is complicated by the low
solubility of PCBs and the prevalence of their occurrence as
solutes in oils. At this point the migration of PCBs to
ground water can only be described qualitatively. Table 3-4
lists factors affecting migration for several PCBs.
PCBs are very immobile under conditions where the PCB
concentration in the aqueous phase is controlled by the
aqueous solubility of PCBs and transport is governed by
partitioning between the water and soil. However, low
solubility compounds like PCBs may migrate through
facilitated transport on colloidal particles (Backhus, 1988)
or dissolved in more mobile substances such as oils if
present as a separate phase (U.S. EPA, 1989f). Measurements
of dissolved organic carbon (DOC) in leachate may help
assess this movement since PCBs will sorb to the organic
material. Concentrations of PCBs in water samples exceeding
PCB water solubility indicate that PCBs are being
solubilized by something other than water. PCBs in oils
will be mobile if the oil itself is present in volumes large
enough to move a significant distance from the source. If
immiscible fluid flow is significant, PCB transport
predictions must be based on immiscible fluid flow models.
3.2 Ground Water
If PCBs have contaminated potentially drinkable ground
water, ground water response actions should be considered.
2The difference between the Spill Cleanup Policy numbers and
the Superfund starting point concentrations is due to use of the
Superfund standard exposure assumptions and a revised cancer
potency factor for PCBs.
33
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As discussed above, PCBs generally have low mobility but can
be transported with oils in which they may be dissolved. A
problem that arises is that once the immiscible fluid has
been immobilized through capillary retention in the soil
pore space (termed the residual saturation), PCB transport
is governed by the rate at which the PCBs dissolve from the
oil into the water moving past the residually saturated oil.
This is a very slow process with the residual saturation
serving as a long-term source of contamination.
Emulsification of the residual oil, and PCB transport in
micelles may also occur.
PCBs have also been found to migrate within aquifers
sorbed to colloidal particles. This movement can be
assessed through analyzing both filtered and unfiltered
ground water samples for PCBs (U.S. EPA, 1989f and U.S. EPA,
1989g).
In both scenarios described above, PCBs can be found in
unfiltered ground water samples at levels that exceed health
based concentrations. The proposed MCL for PCBs is .5 ppb
reflecting a 10"A excess cancer risk. (Proposed MCLs are
considered TBC for ground water that is potentially
drinkable.) These situations are also very difficult to
address actively. In the first case, residual oil lodged in
pore spaces continues to be a source of PCBs and are very
difficult to remove through traditional pump and treat
methods. In the case of PCBs present on particulates, the
rate of removal through ground water extraction may be very
limited and substantial amounts of clean water will be
affected as it is pulled into the contaminated zone.
Because of the technical impracticability of reducing
concentrations to health-based levels, remedies designed to
prevent further migration of contaminants may be the only
viable option for portions of the contaminated ground water.
This may involve removing more soluble organics present
which increase the mobility of the PCBs present.
3.3 Sediment
The cleanup level established for PCB-contaminated
sediment may be based on direct contact threats using
exposure assumptions specific to the site if the surface
water is used for swimming. More often, the impact of PCBs
on aquatic life and consumers of aquatic life will drive the
cleanup level. Interim criteria for sediment based on
achieving and maintaining WQC in the surface water have been
developed for several chemicals (U.S. EPA, 1989a). The
approach used to estimate these values is called the
Equilibrium Partioning Approach (EP) which is based on two
interrelated assumptions. First, that the interstitial
34
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water concentration of the contaminant is controlled by
partitioning between the sediment and the water at
contaminant concentrations well below saturation in both
phases. Thus, the partitioning can be calculated from the
quantity of the sorbent on the sediment and the appropriate
sorption cqefficient. For nonpolar organic contaminants,
the primary sorbent is the organic carbon on the sediment;
therefore, the partition coefficient is called the organic
carbon normalized partition coefficient, Koc. Second, the
toxicity and the accumulation of the contaminant by benthic
organisms is correlated to the interstitial, or pore water
concentration and not directly to the total concentration of
the contaminant on the sediment.
When the EP approach is used to estimate sediment
quality criteria, chronic water quality criteria (WQC) (U.S.
EPA 1980c and U.S. EPA 1985a) are used to establish the "no-
effect" concentration in the interstitial water. The
interstitial water concentration (Cw) is then used with the
partition coefficients (Koc) and the following equation:
Csed = Koc * Cw
to calculate the concentration of the contaminant on the
sediment (Csed) that at equilibrium will result in this
interstitial water concentration. This concentration on the
sediment will be the numerical criteria value (SQC).
Interim sediment quality criteria for PCBs are shown in
Table 3-5. . These values were derived using the Koc value of
6.14 for PCBs which was estimated using the median of the
log mean Kow values for Arochlor 1242. Confidence limits
(95%) around this Koc value based on preliminary uncertainty
estimates range from 5.44 to 6.85. The WQC concentration of
.014 ug/L for freshwater aquatic life (U.S. EPA, 1980b) is
derived using the residue value of .64 ug/g from studies
with mink and the mean bioconcentration factor for salmonids
of 45,000. The WQC concentration of .03 ug/L PCBs for
saltwater was not used. Instead, a WQC concentration of
.024 ug/L for saltwater was calculated using the FDA Action
level of 2.0 ug/g, a mean BCF of 10,400 and a lipid value
for benthic species of 8.0 percent. Therefore, the SQC
concentrations in Table 3-5 are intended to protect wildlife
consumers of freshwater benthic species and the
marketability of saltwater benthic species.
To determine if the sediment concentration of a nonpolar
contaminant exceeds the sediment criteria values, the
concentration of the contaminant and the organic carbon
content of the sediment must both be known. Because the
sediment criteria values are presented as normalized to
organic carbon content (i.e., presented on a per organic
35
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carbon weight basis — ug/gC), the normalized sediment
concentrations of the contaminants must be calculated.
These normalized concentrations can then be directly
compared with the interim values shown in Table 3-5. SQC
concentrations do not apply to sediments containing less
than 0.5% organic carbon.
If concentrations of PCBs in sediments exceed these SQC
values, chemical monitoring of indigenous benthic and water
column species should be instituted to determine if prey
species of wildlife or marketable benthic or water column
species contain unacceptable concentrations of PCBs.
Monitoring of indigenous wildlife species will provide
insights into actual extent of exposure to PCBs from a
specific site relative to reference sites. This is
particularly important where the areal extent or the
heterogeneity of sediment contamination by' PCBs is great and
because biomagnification of PCBs in food chains is not
considered in deriving the aquatic life WQC concentrations.
If chemical monitoring of biota fails to indicate that uses
are impaired, the need for extensive remediation based on
exceedence of SQC values should be questioned.
TABLE 3-5
PCB Sediment Quality Criteria1
Sediment Quality Sediment
Criteria (ug/gC) Cone, "(ug/g)
WQC - Freshwater Mean 95% Confid.
Int. PC = 10% PC = 1%
.014 ug/L 19 3.8-99 1.9 .19
(.38 - 9.9) (.038 -.99)
WQC - Saltwater
.024 ug/L 33 6.6 - 170 3.3 .33
(.66 -17) (.066 - 1.7)
1 Based on Koc = 6.14 (5.44 - 6.85). If these SQC are
exceeded chemical monitoring of PCB concentrations in
indigenous biota is recommended prior to decisions on
ecological risks or remediation. These SQC apply to
sediments whose organic carbon (OC) concentrations are
greater than .5%.
3.4 Ecological Considerations
The occurrence of PCBs at Superfund sites often poses
significant threat to wildlife. Mobility of PCBs into
36
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ground water, into air, and through biological vectors can
result in adverse ecological impacts beyond the immediate
boundaries of the site. It is important to consider
interactive ecological processes relative to PCB
contamination as part of the remedial investigation. This
evaluation can provide insights into other avenues of human
exposure in addition to ensuring protection of wildlife.
Assessments of PCB sites by the Department of the
Interior have concluded that PCB concentrations of 1 - 2 ppm
will be protective of wildlife such as migratory birds and
that providing a soil cover over more highly contaminated
areas can further mitigate threats to acceptable levels.
However, the uncertainty regarding environmental impacts
described below may warrant more in-depth analysis at sites
where this pathway may be of particular significance; e.g.,
sensitive species, high agricultural use.
It may be important to note that, from a toxicological
and ecological perspective, not all PCB congeners will have
the same effects. Discrimination of congeners appears
operative at many physical, chemical, and biological levels:
primary source materials differ from environmental-samples;
toxicity values differ among congeners; persistence in the
environment varies; and bioaccumulation potential varies
among congeners and across trophic levels. Consequently, an
established environmental concentration based on total PCB
concentration (i.e., irrespective of the specific congeners)
may show little relationship to biological phenomena (e.g.,
food chain contamination, toxicity, etc.).
Metabolism of PCBs can occur in a diverse group of
organisms including bacteria, plants, and animals. (Fungi
almost certainly possess similar capabilities.) For the
most part the lesser chlorinated congeners are more readily
subject to metabolism, whereas the penta-, hexa-, and
heptachlorinated forms are quite recalcitrant. Metabolism
should not be equated with degradation, because certain
conversions are better thought of as modifications of the
parent compound; and in some cases the modified forms may
become more toxic, more water-soluble, more bioavailable.
To date the best evidence for degradation is demonstrated
for certain bacteria which are capable of dechlorinating the
lesser cholorinated congeners.
Toxicity symptoms are most clearly observed in animals
(Focardi, 1989 and Aulerich, 1986). Usually the symptoms
are sublethal. Chronic exposures lead to disrupted hormone
balances, reproductive failure, teratomas, or carcinomas.
37
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Plants do not appear to exhibit detectable toxicity
responses to PCBs (Fletcher, 1987a and Fletcher, 1987b).
Biological contamination may occur through a variety of
routes. Aquatic organisms may incorporate PCBs from water,
sediment, or food items. Subterranean animals, similarly
accumulate PCBs via dermal contact and ingestion
(Tarradellas, 1982). Exposure scenarios in above-ground
terrestrial populations additionally may occur via
volatilization. The least understood features of food web
contamination are those related to the uptake, fate and
transport of PCB congeners in plants.
38
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Chapter 4
Developing Remedial Alternatives
As described in Section 1, one of the Superfund
expectations is that principal threats at a site will be
treated wherever practicable and that low-threat material
will be contained and managed. Treatment and disposal
options for PCB contaminated material are governed by the
type of material that is contaminated and the concentration
of PCBs in the material that is to be disposed. Principal
threats will generally include material contaminated at
concentrations exceeding 100 ppm or 500 ppm depending on the
land use setting. Where concentrations are below 100 ppm
(less than 2 orders of magnitude above the starting point
action level), treatment is less likely to be practicable
unless the volume of contaminated material is relatively
low.
The treatment options for contaminated soils and sludges
mixed with soil are discussed in this chapter. (Consistent
with the Superfund expectations and TSCA requirements, PCB
liquids generally will be incinerated. Aqueous PCB streams
generally will be treated by traditional treatment systems
such as carbon adsorption.) There are three primary options
for non-liquid PCBs at concentrations of 50 ppm or greater
that are compliant with TSCA ARARs (there is no separate
consideration given to non-liquid PCBs at concentrations
greater than 500 ppm):
1. Incineration;
2. Treatment equivalent to incineration;
3. Disposal in a chemical waste landfill.
There are additional options for addressing PCB contaminated
dredged material. Superfund expectations indicate that
innovative treatment methods should be .considered where they
offer comparable or superior treatment performance/
fewer/lesser adverse impacts, or lower costs than more
demonstrated technologies. For PCBs, possible innovative
technologies meeting these criteria include solvent
extration, KPEG, biological treatment, and in-situ
vitrification.
For low-threat material that is contained and managed in
place over the long term, appropriate engineering and
institutional controls should be used to ensure protection
is maintained over time. An initial framework for
determining appropriate long-term management controls is
provided in Table 4-2. As indicated by this table,
institutional controls alone are not sufficient to provide
protection except in cases where the concentrations
remaining are low and the expected land use is industrial.
39
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4.1 Identifying Principal Threats/Low-Threat Areas
The process for developing alternatives at Superfund
sites with PCB contamination described below is outlined in
the flow chart in Figure 4-1.
Once the area over which some action must be taken to
reduce risks has been identified; i.e., areas contaminated
above 1 ppm PCBs (residential) or areas contaminated above
10 - 25 ppm PCBs (industrial), the wastes comprising the
principal threat at the site should be identified. These
wastes will include soil contaminated at 2 to 3 orders of
magnitude above the action level. For sites in residential
areas, principal threats will generally include soils
contaminated at concentrations greater than 100 ppm PCBs.
For sites in industrial areas, PCBs at concentrations of 500
ppm or greater will generally constitute a principal threat.
This is consistent with TSCA regulations.3 Consistent with
Superfund expectations, the principal threats at the site
should be treated. Treatment methods are described in
Section 4.2.
In some cases, it may be appropriate to treat material
contaminated at concentrations lower than what would
otherwise define the principal threats because it is cost
effective considering the cost of treatment verses the cost
of containment, because the site is located in a sensitive
area such as a wetland, or because the site is located in an
area where containment is unreliable such as a floodplain.
In other cases, it may be appropriate to contain the
principal threats as well as the low-threat material because
there are large volumes of contaminated material, because
the PCBs are mixed with other contaminants that make
treatment impracticable, or because the principal threats
are not accessible; e.g., sites where they are buried.
Material that is not treated but is above actions levels
should be contained to prevent access that would result in
exposures exceeding protective levels. A framework of long-
term management controls for various site scenarios is
provided in section 4.3.
4.2 Treatment Methods
Several methods have been used or are currently being
3TSCA regulations require that liquid PCBs at 500 ppro or
greater be incinerated or treated by an equivalent method.
40
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Figure 4-1 - Key Steps in the Development of Remedial Alternatives for PCB-Contaminated Superfund Sites*
What is the action area
assuming unlimited exposure?
10 - 25 ppm PCB
or greater
f J s ss ffff Jf '-,^Ł"3%'Ł-4,
•• r r r , tff t*A^ ."...*. ..f f.
'-'•? :'*,Ł,'+;&
Key
ft
A
XXX
O
Residential
Industrial
Containment
Action Area
Boundary
*, ~
What are principal threats \o be treated?
(PCBs at 5OO ppm or greater, or more than 2 orders of magnitude above the action level.)
Treat principal threats at least to levels that are to be contained (90% reduction)
100 ppm
or greater
\ Exceptions:
• Small volumes
• Sensitive exposures
How should material remaining at the site be contained?
Partially Treat
Contain residues and
remaining material
(See Table 3)
-'',';
X->V.
iff X* /J
* These numbers are guidance only and should not be treated as regulations.
41
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evaluated to reduce the toxicity, mobility, or volume of
PCB-contaminated material. Depending on the volume of
material to be treated, the other contaminants that may be
present, and the consistency of the contaminated material,
one or more of these methods should be considered as options
for addressing the principal threats.
In addition to incineration, there are several other
technologies that result in the destruction or removal of
PCBs in contaminated soil. These methods can be used with
no long-term management of treatment residuals if they can
be shown to achieve a level of performance equivalent to
incineration, as required in 40CFR761.60(e). As described
in guidance (U.S. EPA, 1986c), this determination can be
made by demonstrating that the solid treatment residuals
contain less than or equal to 2 ppm PCBs using a total waste
analysis. When a remedial action alternative for a
Superfund site involves use of a technology that can achieve
substantial reductions but residual concentrations will
still exceed 2 ppm, the alternative should include long-term
management controls as outlined later in Table 4-2. This
will not be considered equivalent treatment but will be
treated as closure of an existing hazardous waste unit
consistent with TSCA chemical waste landfill requirements
(RCRA closure - 40CFR 264.301 and TSCA chemical waste
landfill - 40CFR 761.75). As described in Table 4-2,
certain long term management controls may be waived using
the TSCA waiver provision, depending on the concentration of
PCBs remaining and other site-specific factors.
A brief discussion of some of the pertinent
considerations for several treatment technologies that
address PCBs follows. The evaluations described below
provide the substantive considerations pertinent to
treatment of PCBs on Superfund sites. .When material is
transported off-site for treatment, the treatment facility
must be permitted under TSCA. Table 4-1 summarizes
important considerations and consequences associated with
the use of the various technologies that should be accounted
for in developing and evaluating alternative remedial
actions.
4.2.1 Incineration
Incineration, covered in 40CFR761.70, should achieve the
equivalent of six 9's (99.9999%) destruction removal
efficiency. This is indicated by the requirement that mass
air emissions from the incinerator stack shall not be
greater than .001 g PCB/kg of PCB contaminated material fed
into the incinerator.
42
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Table 4-1
PCB TREATMENT METHODS AND APPLICATION CONSEQUENCES
Methods
Incineration
Biological Treatment
Solidification
Vitrification
KPEG (Potassium Polyethylene Glycolate)
Solvent Washing/Extraction
Granular Activated Carbon
Considerations/Consequences
• Cost
Residual disposal (ash, scrubber water)
Public resistance
• Efficiency
By-products
Treatment time
• Not proven effective for all
PCB congeners
Volatilization
• Leachability
• Physical strength
Life of composite's integrity
• . Cost
Volatilization
Leachability
Cost (varies with reagent recycleability)*
• Efficiency (varies with Arochlor type)
• Aqueous wastes must be dewatered either
as a pre-step or in a reactor
Volatilization of solvent
Solvent recovery
Inability of solvent to extract all PCBs
Several extraction steps
Solvent residual remains in extracted soil
Extracts require destruction via other
methods
Removal efficiency in soil has not been
established
Spent carbon requires treatment/disposal
43
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4.2.2 Chemical Dechlorination (KPEG)
Chemical reagents prepared from polyethylene glycols and
potassium hydroxide have been demonstrated to dechlorinate
PCBs through a nucleophilic substitution process. Studies
have shown that the products of the reaction are non-toxic,
non-mutagenic, and non-bioaccumulative (desRosiers, 1987).
Treatability studies in Guam and at the Wide Beach Superfund
Site in New York have shown that PCB concentrations can be
reduced to less than 2 ppm. However,-variable
concentrations in material to be treated will result in
varying efficiencies of the treatment system and systems
must be monitored carefully to ensure that'sufficient
reaction time is allowed.
This technology can achieve performance levels that are
considered equivalent to incineration; however, treatability
studies generally will be required to demonstrate that the
concentration reductions can be achieved on a consistent
basis for the material that is to be treated. In some
cases, cost-effective use of the KPEG process will result in
substantial reductions of PCB concentrations, but the
residual levels may still be. above 2 ppm, in which case
chemical waste landfill requirements will also need to be
met.
4.2.3 Biological Treatment
Some work has been done on the use of microbes to
degrade PCBs either through enhancing conditions for
existing microbes or mixing the contaminated material with
engineered microbes (Quensen, 1988; Bedard, 1986; Unterman,
1988; Abramowicz, 1989). The use of this process requires
detailed treatability studies to ensure that the specific
PCB congeners present will be degraded and that the
byproducts of the degradation process will not be toxic.
For in-situ application, it is possible that extensive
aeration and nutrient addition to the subsurface will
increase the mobility of PCBs through transport on
particulates. This phenomenon should be considered when
potential ground water contamination is a concern.
In-situ application does not trigger TSCA requirements
(unless disposal occurred after February 17, 1978) and the
primary consideration should be attainment of cleanup levels
established for the site based on the evaluation of factors
described in Chapter 3. Biological processes involving the
excavation of contaminated material for treatment in a
bioreactor that can be shown to achieve residual
concentrations of less than or equal to 2 ppm PCBs can be
44
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considered equivalent treatment. Treatment residuals can be
re-deposited on site without long-term management controls
as long as treatment byproducts do not present a threat to
human health and the environment.
4.2.4 Solvent Washing/Extraction
Solvent washing/extraction involves removing PCBs from
excavated contaminated soil and concentrating them in a
residual side stream that will require subsequent treatment,
generally incineration. Often the solvent can be recovered
by taking advantage of certain properties of the solvent
being used. Aliphatic amines (e.g., triethylamine [TEA]),
used in the Basic Extractive Sludge Treatment (B.E.S.T.),
exhibit inverse miscibility. Below 15 degrees C, TEA can
simultaneously solvate oils and water. Above this
temperature, water becomes immiscible and separates from the
oil and solvent. Consequently, a process can be designed to
remove water and organics at low temperatures, separate the
water from the organic phase at higher temperatures, and
recover most of the solvent through distillation. The high
concentration PCB stream is then typically incinerated.
A similar process, called critical fluid extraction,
involves taking advantage of increased solvent properties of
certain gases (e.g., propane) when they are heated and
compressed to their "critical point." Once the PCBs have
been extracted, the pressure can be reduced allowing the
solvent to vaporize. The solvent can be recovered and the
remaining PCBs sent to an incinerator.
Treatability tests run to date have indicated that there
is probably a limit to the percentage reduction (on the
order of 99.5%) achievable with these processes. Repeat
applications can increase the reductions obtained and
studies have shown that PCB concentrations in the extracted
soil of less than 2 ppm can be achieved. However, it may
not be cost-effective for sites where there are large
volumes of material at very high concentrations.
4.2.5 Solidification/Stabilization
The terms solidification and stabilization are sometimes
used interchangeably, however, subtle differences should be
recognized. Solidification implies hardening or
encapsulation to prevent leaching, whereas stabilization
implies a chemical reaction or bonding to prevent leaching.
Solidification of PCBs can be accomplished by use of
pozzolons such as cement or lime. Encapsulation, rather
than bonding, occurs to prevent leaching of the PCBs. There
45
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is some evidence in the literature that the excess
hydroxides are substituted on the biphenyl ring resulting in
a dechlorination reaction (U.S. EPA, 1988c). The
dechlorinated product would probably be less toxic than the
parent molecule. Stabilization may be accomplished using a
modified clay or other binder to bond to the PCB preventing
.leaching of the PCBs even under extreme environmental
conditions. This product will probably be stable over time
because of the binding, but no changes in the parent
molecules are expected.
To assess the reduction in mobility achieved through
solidification, leaching analysis, such as the Toxicity
Characteristic Leaching Procedure (TCLP), should be
performed before and after solidification. Since PCB
migration potential is reduced but the PCBs are still
present in the waste and the long term reliability of the
treatment process is uncertain, long-term management
controls as outlined in Table 4-2, based on the
concentration of PCBs stabilized or up to a factor of 10
lower (based on the results of the performance evaluation) ,
should be incorporated into the alternative.
4.2.6 Vitrification
Vitrification involves the use of high power electrical
current (approximately 4 MW) transmitted into the soil by
large electrodes which transform the treated material into a
pyrolyzed mass. Organic contaminants are destroyed and/or
volatilized, and inorganic contaminants are bound up in the
glass-like mass that is created. Volatilized organics must
be captured and treated. Since this process is often
performed in-situ without disturbing the contaminated
material, the requirements of TSCA would not be applicable
unless disposal occurred after February 17, 1978. Also, it
is often advantageous to consolidate contaminated material
into one area for purposes of applying the process in which
cases TSCA requirements would apply for PCBs at
concentrations greater than 50 ppm since this movement
constitutes disposal. Because the process results in
complete pyrolosis of the PCBs in the affected area it is
considered equivalent to incineration and no long-term
management would be warranted based on the PCBs. The
perimeter of the treated area should be tested using the
TCLP to determine if long term management controls are
warranted in areas where gradations in temperature resulted
in lower levels of PCB destruction.
4.3 Determining Appropriate Management Controls for Areas
Where Concentrations Are Above the Action Levels
46
-------
Consistent with the Superfund expectations low-threat
material should generally be contained on site. As
described above, this will generally include soil with PCBs
at concentration of less than 100 ppm (residential) or PCBs
at concentrations of less than 500 ppm (industrial). The
management controls that should be implemented for the
material that remains at these sites above the action level
will depend on the material that is to be contained and
hydrogeological and meteorological factors associated with
the site. Controls may include caps, liners, leachate
collection systems, ground water monitoring, surface water
controls, and site security. A general framework of
appropriate controls under various site scenarios is
provided in Table 4-2. If disposal of PCBs subject to TSCA
(concentrations greater than 50 ppm) occurred after 1978,
then the long-term management controls required for chemical
waste landfills must be addressed for material that is not
incinerated or treated by an equivalent method. As noted in
the Table, where low concentrations of PCBs will remain on
site and direct contact risks can be reduced sufficiently,
minimal long term management controls are warranted.
Controls should ensure that PCBs will not pose a threat to
the ground water or any nearby surface water. TSCA waivers
of particular chemical waste landfill requirements may be
justified. Where TSCA landfill requirements are not
applicable (post-78 disposal of >50 ppm PCB material
did/does not occur), they will not be relevant and
appropriate since RCRA closure requirements are generally
the relevant ant appropriate requirement; consequently, the
use of the TSCA waiver provision will not be necessary.
4.3.1 Example Analyses — Long-Term Management Controls
To illustrate the process of determining the appropriate
long-term management controls for low-threat PCB
contamination that will remain at a site, an example was
developed. A description of the models used in this
evaluation is provided in Appendix C. The parameters used
in this analysis are generally conservative. They are
summarized in Table 4-3. Four different source area PCB
concentrations were evaluated: 5 ppm, 20 ppm, 50 ppm, and
100 ppm.
The determination of the appropriate long term management
controls for this example site was based on preventing
access to concentrations of PCBs exceeding the action level
(residential, 1 ppm; industrial 10 - 25 ppm) and preventing
migration of PCBs to the ground water at concentrations that
exceed the proposed drinking water standard — .5 ppb. The
migration to ground water pathway was assessed by
47
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Table 4-2 - Selection of Long-Term Management Controls To Be Considered for PCB-Contamlnated Sites
LONG-TERM MANAGEMENT
CONTROLS RECCOMENDEO
CHEMICAL WASTE
LANDFILL REQUIREMENTS
POTENTIAL BASIS FOR TSCA WAIVER (761.75 (e) (4))
OF INDICATED CHEMCAL WASTE LANDRLL REQUIREMENTS)
< t
.> 1
1.1 A
1 IV
25-100
IftVC/Vl
1W-DW
>soo
AIDaoiht
Al Depths
AI Depths
* CA f »
J-30 rMI
KA C*^
> 90 rMI
3-50 Feel
>50FMI
* PDrwsinciM AOCMI
•DMdNotb*
.ItMMl
Fence
DMdNottoa
n^it frUjjjm
HMjnned Access
Dead Node*
•Deed Notice
Retfricted Access
Ftm»
Deed Notice
HMtnctM Aooni
Farw
DNdNotlc*
Hybrid Cbeor*
UndmCbsurt
iMrffflCbun
Undincbsura
1 ainiltMt^i-i^nia
Lrawciosurt
LandTiCbwre
MWmum
TarAaiil. •»!
icnnoiogy
Imdncbxm
MWmum
Tadvntogy
X
X
X
X
X
X
X
.
X
X
X
X
X
X
X
4
4
4
X
X
3
X
X
X
X
No waJwrs required; dean doaure
Low PCB oonoentftfton
Duty) end TOlMflnoft of t pfOtedVe cover systont
Evaluation at PCB migration to GW and SW
Design and tratalbtton o) a profcdlw cover system
Evaluation of PCB migration toGW and SW
RaWvfJjf tow PCB oonoantratton
Evaluation ol PCB migration to GW and SW
Design and Irsunaton ol a protective cover system
Evaluation ol PCB migration to GW and SW
DssKjn enfl numon or • pnacnM cover spwm
DamonstrM suffidefit depth to GW to prowa human health and
Evaluation ol PCB irigratoi to GW and SW
DamonstrM olhar bng-iann mmagemert oantrels wll provide
adet)uat0 pralactlon or GW
Damonstrato suffttenl daprh to GW and bng-term manaflanwnt controls
to prated human haaMi and the environment
knpkjmenMion of GW montorhg program
Evaluation ol PCB migration to GW and SW
GW. ground Mir; S
1 Cover jyj)OTrmyr«r^ from l^iol cap lor bwcone^raNom to iMrXRAt^ lor corx^
I Ths ne«d tof • torn tysttm till o^ptnd on tht kind UM (I.•.. rtsktentlal or Industrial).
40 CFR 76(.7S(bX3) rtqolnM that tandlis bt touted at toast 50 le«t abovt th» Ngh-tralar tabto.
4 In accoidmt «Hth 40 CFR 7(1.7S(b)(4) I thi ilto b localad batow tr« I OO^r llooo\Mlar t^
hBigria
-------
Table 4-3
SITE PARAMETERS
Source Area—5 Acres
Average Regional Flow 310 ft/year
Porosity of Soil-0.25
Bulk Density of Soil-1.97 g/inl
Time-Peak 70 years from 0-10,000 years
Contaminated zone organic content-5.0%
Clean unsaturated zone organic content-0.5%
Saturated zone organic content-0.1%
PCB half-life-50 years
Depth of Contamination-10 feet
Depth to Groundwater-20 feet
Thickness of Saturated Zone~5 feet
49
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determining the infiltration projected through four
different cap designs and then modeling the migration of
PCBs from the source area to and into the ground water.
The four caps evaluated in this analysis are:
1. Twelve-inch soil cap
2. Twelve-inch soil cap with 24-inch clay layer
3. 24-inch soil cap, flexible membrane liner, and 12-inch
cover soil, and
4. RCRA minimum technology cap including 24-inch soil cap,
12-inch sand drainage layer, flexible membrane liner,
24-inch clay layer, and 12-inch cover soil.
These caps are pictured in Figure 4-2. The infiltration
expected through each of these caps, presented in Table 4-4,
(given the site conditions presented in Table 4-3) was
estimated using the Hydrologic Evaluation of Landfill
Performance (HELP) model and the migration of PCBs to and
into the ground water was estimated using a combination of a
one-dimensional unsaturated zone finite-element flow and
transport module called VADOFT (U.S. EPA, 1989f) and an
analytical solute/heat transport module called AT123D (Yeh,
1981).
The results of this analysis are summarized in Table 4-
5. PCB concentrations in ground water were estimated for
each of the four cap designs and four different PCB source
concentrations. Based on this analysis, the following
recommendations for caps would be made:
5 ppm PCBs Source At this concentration the threat of PCB
migration to ground water at concentrations that would
exceed the proposed MCL of .5 ppb under the given site
conditions is unlikely. The maximum concentration averaged
over 70 years (occuring after 945 years) is .099 ppb with
only a soil cap. The soil cover would be recommended for
sites in residential areas to prevent contact with
concentrations above 1 ppm, the starting point action level.
20 ppm PCBs Source Again, the analysis indicates that the
threat to ground water is not significant. With only a soil
cap, the maximum concentration expected is .4 ppb. For
sites in residential areas, a cement cover and a deed notice
may be warranted to prevent contact with PCBs exceeding the
1 ppm starting point action level.
50 ppm PCBs Source At 50 ppm, PCB concentrations in the
ground water are projected to exceed the .5 ppb level
slightly — approximately 1 ppb. At this concentration, for
the site conditions presented, cap design 2 (Figure 4-2)
50
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DESIGN" 1
Figure 4-2
Cap Design Details
3-5%
Vegetation
12" .Soil Top Layer
Waste
DESIGN 2
• 3-5%
Vegetation
12" Sofl Top Layer
'cWsec
Waste
DESIGN 3
Vegetation
24" Sofl Top Layer
^xvox*>
vrivu-
•sY%l s»%• %^ s" ^^IS*1
I-K=lxlO~ cm/sec
Cover Soil- K=3.7x10^cm/sec
Waste
DESIGN 4
•3-5%
.2%
Vegetation
24" Soil Top Layer
12" Sand - K=lxlO"2 cm/sec
14
FML 20 mil--K=lxlO cm/sec
-7
24"Clay~K=lxlO cm/sec
12" Cover Soil- K^.TxlO^cm/sec
Landfill
Design i
(Minimum
Technology) |
I
12" Sand - K=lxlO*2cm/sec (Leaenate collection) '
FML 30 mil-K=lxlO"'on/sec (Liner) |
12" Clay -lxlO"7cm/sec (Liner) I
-2
12" Sand - K=lxlO on/sec (Leak detection) |
FML 30?nil-K=lxlO"1cin/kec (Liner) i
'36" Clay - K=lxlO" cm/cec (Liner) i
• Original Subgrade
• RCRA Minimum Teennology Landfill bottom liner design for remedial •ctioni requiring RCRA landfill construction.
51
-------
Cover
Site Area
Table 4-4
COVER DESIGN SUMMARY TABLE (ANNUAL VALUES)
I I Infiltration
I e.-*- - Precip. Runoff Evapotrans. (Co. Ft.)/
(Cn.Ft) I (Co. Ft) I (Cu.Ft)
258,877 3,349 113,134
285,877 78,164 114,628
258,877 127,318 131,170
_285,877
52
-------
T>k 1*4-5
(Ml CwimMnllMi S ffm
Ml CoMtnlrallMi 10 fftx
S^l ('•ncrnlraflMi M fpm
S*0 (^
IM too rtt*
U)
.099
.029
0.0
0.0
..196
Dnfcn
1
.116
0.0
00
Dnlpi
I
.990
.290
00
0.0
1.98
.5X0
Dnkn
.1
0.0
00
Dnfca
I
943
1645
Driilyn
J
-------
would be recommended. The combination of a low-permeability
cover soil and the soil cap will prevent PCBs from migrating
to the ground water at levels that exceed .5 ppb. With the
reduced infiltration the maximum PCB concentration projected
for the ground water (occurring after 1645 years) is .3 ppb.
Again, a deed notice would be warranted to prevent direct
contact with the soil in the future.
100 ppm PCBs Source At 100 ppm, PCB concentrations in the
ground water are projected to exceed the .5 ppb level
slightly — approximately .6 ppb, even with the addition of
a low-permeability cover soil. At this concentration, for
the site conditions presented, the cap design 3 (Figure 4-2)
would be recommended. The addition of a flexible membrane
liner reduces infiltration sufficiently to prevent migration
of PCBs to the ground water. Consistent with Table 4-2, a
deed notice, fence, and periodic ground water monitoring
would also be recommended.
4.4 Dredged Material
A special allowance is made under TSCA for dredged
material and municipal sewage treatment sludges in section
761.60(a)(5)(iii). If, based on technical, environmental,
and economic considerations, it can be shown that disposal
in an incinerator or chemical waste landfill is not
reasonable or appropriate and that an alternative disposal
method will provide adequate protection to health and the
environment, this alternate disposal method will meet the
substantive requirements of TSCA. Since these showings are
integral components of any remedy selected at a Superfund
site, Superfund actions involving PCB-contaminated dredged
material generally will be consistent with TSCA.
4.5 RCRA Hazardous Waste
As noted in section 2.3.2, special consideration must be
given to PCB-contaminated soil that also contains material
considered hazardous under RCRA. Soil containing
constituents that make it hazardous under RCRA that is
excavated for the purpose of treatment or disposal must be
treated consistent with the land disposal restrictions prior
to placement and residuals managed in accordance with
Subtitle C closure requirements. This means that a specific
treatment method must be applied, or specified concentration
levels must be attained for the waste contained in the soil,
or a treatability variance must be obtained to establish
alternate treatment standards. For soil and debris from
CERCLA sites the need for a treatability variance is
presumed (preamble to NCP, 55 Federal Register 8760-61,
54
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March 8, 1990). Treatment guidelines for constituents found
in RCRA hazardous waste have been developed for use in
treatability variances and should be used as a guide in
determining the reductions in contaminant levels that should
be attained by alternative treatment methods.
PCBs alone are not considered hazardous under RCRA since
they are addressed under the TSCA regulations; however, land
disposal restrictions do address PCBs under the California
List Waste provisions for cases where PCBs are mixed with a
waste that is considered hazardous under RCRA. If the waste
is hazardous under RCRA, and the concentration of
halogenated organic compounds exceeds 1000 ppm, the land
disposal restrictions associated with California List Waste
become applicable. A list of compounds regulated under the
category of halogenated organic compounds is provided in 40
CFR part 268 Appendix III. PCBs are included on this list.
Soil with HOCs exceeding 1000 ppm that is also considered
hazardous under RCRA, must be incinerated or treated under a
treatability variance. Under a treatability variance,
treatment should achieve residual HOC concentrations
consistent with the levels specified for a treatabi-lity
variance for Superfund soil and debris. PCB concentrations
must be reduced to .1 - 10 ppm for concentrations up to 100
ppm, and percent reductions of 90 - 99.9% must be achieved
for higher concentrations (U.S. EPA, 1989h). If
solidification is used, the levels specified under
treatability variance guidelines apply to leachate obtained
from application of the Toxicity Characteristic Leaching
Procedure (TCLP).
The implications of the land disposal restrictions vary
somewhat depending on whether the waste present is a listed
hazardous waste or is hazardous by characteristic. If the
soil contains a listed hazardous waste, once treatment
consistent with the land disposal restrictions (i.e.,
specified treatment or concentration reductions consistent
with the levels provided in the treatability variance
guidelines for soil and debris) is employed, the residual
after treatment must be disposed of in a landfill that meets
the requirements of a RCRA Subtitle C Landfill. It may be
possible to delist the residuals to demonstrate that it is
no longer hazardous; this may be done for wastes on-site as
part of the ROD; for wastes to be sent off-site, EPA
Headquarters should be consulted regarding de-listing. If
the concentration of PCBs remaining still exceeds 2 ppm, the
landfill should also be consistent with a chemical waste
landfill described under TSCA. As discussed in Section 4.3,
fulfillment of RCRA Subtitle C Landfill Closure requirements
will also guarantee fulfillment of TSCA chemical waste
landfill requirements.
55
-------
If the soil contains material that makes it hazardous
because of a characteristic; e.g., leachate concentrations
exceed levels specified in 40 CFR 261.24, the soil should be
treated to established BOAT levels, if any; if BOAT
concentrations are not specified, the soil should be treated
such that it no longer exhibits the characteristic. Once
the BDAT level is achieved (if any) or the characteristic
has been removed, it may be possible to land dispose the
waste and Subtitle C landfill requirements would not be
applicable but rather, the waste would be considered a solid
waste and governed by Subtitle D. However, when PCBs are
present in the waste, long term management controls
consistent with the guidelines given in Section 4.2 should
be employed.
4.6 Example Options Analysis — Contaminated Soil
Table 4-6 outlines the ARARs that may have to be addressed
for wastes with different constituents including those that
will make the waste hazardous because either a listed waste
is present or the material exhibits a hazardous
characteristic. These restrictions apply only when PCB-
contaminated waste is disposed. They do not require
excavation of PCBs that were disposed prior to Superfund
response.
56
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Table 4-6
EXAMPLE PCB COMPLIANCE SCENARIOS FOR CONTAMINATED SOIL
Waste Type and
Concentration
Restriction(s)
in Effect
•Compliance Options to
Meet Restrictions *
PCBs > 50 ppm
TSCA
Dispose of in chemical waste landfill;
Incinerate; oi
Use equivalent treatment to 2 ppm (solid residue) or
3 ppb (aqueous phase)
PCBs > 50 ppm,
RCRA listed waste, and
HOCs< l.OOOppm
[in this case PCBs
not covered by RCRA]
TSCA
RCRALDRs
• Must also be consistent with chemical waste
landfill if final PCB concentration exceeds 2
ppm (solid residue)
• Treat to LDR treatment standard for listed
waste; &[
• Obtain an equivalent treatment method
petition; QI
• Obtain a treatability variance (soil and
debris concentration levels as TBC); and
• Dispose of according to Subtitle C restrictions
PCBs > 50 ppm,
RCRA listed waste,
and HOCs > 1,000 mg/kg
TSCA
RCRALDRs
Dispose of in chemical waste landfill if final
PCB concentration exceeds 2 ppm (solid residue)
Treat to LDR PCB (i.e., incinerate) and
listed waste treatment standard; oi
Obtain an equivalent treatment method
petition; or
Treat to treatability variance levels for
Superfund soil and debris; and
Dispose of according to Subtitle C restrictions
PCBs > 50 ppm,
RCRA characteristic
metal waste, and
HOCs< 1,000 mg/kg
TSCA
RCRALDRs
Dispose of in chemical waste landfill if final
PCB concentration exceeds 2 ppm (solid residue)
Treat to BDAT or Treatability Variance levels and dispose
according to Subtitle C restrictions
, *
Solidify to remove characteristic (based on TCLP) and
dispose according to Subtitle D restrictions
' PCBs > 50 ppm.
RCRA characteristic
metal waste, and
HOCs> 1,000 ppm
TSCA
RCRALDRs
57
Dispose of in chemical waste landfill if PCB
concentration exceeds 2 ppm (solid residue)
Incinerate to LDR treatment standard for
HOCs, solidify ash; or
Treat by equivalent method, solidify; pi
Treat to treatability variance levels for PCBs
in soil and debris
Treat residuals to meet BDAT/Treatabiltry Variance
and dispose according to Subtitle C or remove
characteristic and dispose according to Subtitle D
restrictions
-------
Chapter 5
Analysis of Alternatives and Selection of Remedy
Consistent with program expectations, it will generally
be appropriate to develop a range of alternatives for sites
with PCB contamination, including alternatives that involve
treatment of the principal threats using methods described
in chapter 4 or more innovative methods in combination with
long-term management of low-threat wastes consistent with
the framework provided. As described in the Guidance on
Conducting Remedial Investigations/ Feasibility Studies
Under CERCLA, alternatives are initially screened on the
basis of effectiveness, implementability, and cost (order of
magnitude). Those alternatives that are retained are
analyzed in detail against the nine evaluation criteria.
58
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5.1 Evaluating Remedial Alternatives
The overall response options at any site range from
cleaning up the site to levels that would allow it to be
used without restrictions to closing the site with full
containment of the wastes. Alternatives retained for
detailed analysis are evaluated on the basis of the
following criteria:
o Overall protection of human health and the environment
o Compliance with ARARs
o Long-term effectiveness and permanence
o Reduction of toxicity, mobility, or volume through
treatment
o Short-term effectiveness
o Implementability
o Cost
o State acceptance
o Community acceptance
The sections that follow will discuss in turn the first
seven of these criteria and the special considerations that
may be appropriate when PCB contamination is to be
addressed. State and community acceptance are important
criteria but are generally handled no differently for PCB
sites than they are for other contaminated sites.
5.1.1 Overall Protection of Human Health and the Environment
Overall protection of human health and the environment
is achieved by eliminating, reducing, or controlling site
risks posed through each pathway. As covered in section 3,
this includes direct contact.risks, potential migration to
ground water, and potential risks to ecosystems. Often
alternatives will involve a combination of methods (e.g.,
treatment and containment) to achieve protection. In
general, remedies for PCB sites will involve reducing high
concentrations of PCBs through treatment and long-term
managment of materials remaining. The methods of protection
used to control exposure through each pathway should be
described under this criterion.
5.1.2 Compliance With ARARs
As outlined in section 2, the primary ARARs for
alternatives addressing PCB contamination derive from the
TSCA and the RCRA, and for actions involving PCB
contaminated ground water and/or surface water, the SDWA and
the CWA.
59
-------
Since RCRA closure requirements are generally relevant
and appropriate at Superfund sites even when a hazardous
waste is not involved, a discussion of the measures taken at
the site for the alternative being considered that are
consistent with the RCRA requirements is warranted.
TSCA is applicable where disposal occurred after
February 17, 1978 including any alternatives involving
movement of material with 50 ppm or greater PCBs and
compliance with the substantive requirements must be
addressed. For alternatives that do not achieve the
standards specified for treatment of PCBs under TSCA,
consistency with long-term management controls associated
with a chemical waste landfill must be demonstrated.
Consistency may be achieved by complying with the specified
landfill requirements or meeting the substantive findings to
support a waiver as provided in the TSCA regulations (40 CFR
761.75).
Although the PCB Spill Policy is not ARAR, it is an
important TBC. A statement indicating the relationship
between the cleanup levels selected and the cleanup levels
in the Spill Policy for alternatives involving no or minimal
long term management controls is usually warranted.
Because PCBs adhere strongly to soil, it may be
impracticable to reduce concentrations in the ground water
to the proposed MCL level of .5 ppb throughout the entire
plume, for sites where PCBs have migrated to the saturated
zone. PCBs adsorbed to particulates can be removed in
extraction wells; however, they will be drawn through the
aquifer very slowly. A waiver from State standards or the
MCL once it becomes final may be warranted for sites where
ground water restoration time frames are estimated to be
very long or where cleanup cannot be achieved throughout the
entire area of attainment. Interim remedies (extraction for
a specified period of time such as 5 years) to assess the
practicability of extraction or other techniques may be
worthwhile to determine the feasibility of achieving
drinking water levels or at a minimum, reducing risks to the
extent practicable.
5.1.3 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses how well
a remedy maintains protection of human health and the
environment after remedial action objectives have been met.
Alternatives that involve the removal or destruction of PCBs
to the extent that no access restrictions are necessary
for protection of human health and the environment provide
the greatest long-term effectiveness and permanence. The
60
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uncertainty associated with achieving remediation goals for
the treatment methods considered may distinguish
alternatives with respect to this criterion. Alternatives
that limit the mobility of PCBs through treatment such as
solidification/stabilization afford less long-term
effectiveness and permanence than alternatives that
permanently destroy the PCBs, although solidification in
combination with management controls can be very reliable
based on the site-specific circumstances involved.
Generally, alternatives relying solely on long-term
management controls such as caps, liners, and leachate
collection systems to provide protection have the lowest
long-term effectiveness and permanence; however, this may be
appropriate where low-concentration material is to be
contained or where excavation is not practicable. Many
alternatives will involve combinations of treatment and
containment and will consequently fall at various points
along the permanence continuum depending on the volume and
concentration of residuals remaining on site.
5.1.4 Reduction of Toxicity, Mobility, or Volume Through
Treatment
The anticipated performance of treatment technologies
used in the alternatives is evaluated under this criterion.
Alternatives that do not involve treatment achieve no
reduction of toxicity, mobility, or volume through treatment
and should not be described as doing so under this criterion
(e.g., placing a cap over contaminated soil does not reduce
mobility of PCBs through treatment). Alternatives that use
treatment methods that have a high certainty of achieving
substantial reductions (at least 90%) of PCBs have the
greatest reduction of toxicity. Alternatives that treat the
majority of the contaminated material through these
processes achieve the greatest reduction in volume.
Alternatives that utilize methods to encapsulate or
chemically stabilize PCBs achieve reduction of mobility;
however, most of these processes also increase the volume of
contaminated material and this must be considered.
5.1.5 Short-Term Effectiveness
The effectiveness of alternatives in protecting human
health and the environment during construction and
implementation is assessed under short-term effectiveness.
This criterion encompassess concerns about short-term
impacts as well as the length of time required to implement
the alternatives. Factors such as cross-media impacts, the
need to transport contaminated material through populated
areas, and potential disruption of ecosystems may be
61
-------
pertinent. Because PCBs do volatilize, remedies involving
excavation will create short-term risks through the
inhalation pathway. For actions involving large volumes of
highly contaminated material this risk may be substantial;
however, it can be controlled.
5.1.6 Implementability
The technical and administrative feasibility of
alternatives as well as the availability of needed goods and
services are evaluated to assess the alternative's
implementability. Many of the treatment methods for PCBs
require construction of the treatment system on-site since
commercial systems for such techniques as KPEG and solvent
washing may not be readily available. Other methods, such
as bioremediation, require extensive study before their
effectiveness can be fully assessed. This reduces the
implementability of the alternative. Offsite treatment and
disposal facilities must be permitted under TSCA and usually
under RCRA as well if other contaminants are present. This
may affect the implementability of alternatives that require
PCB material be taken offsite due to treatment and disposal
facility capacity problems and the need to transport
contaminated material. Finally, the implementability of
alternatives involving long-term management and limitations
on site access to provide protection may be limited by the
site location; e.g., flood plain, residential area.
5.1.7 Cost
Capital and operation and maintenance costs are
evaluated for each alternative. These costs include design
and construction costs, remedial action operating costs,
other capital and short-term costs, costs associated with
maintenance, and costs of performance evaluations, including
monitoring. All costs are calculated on a present worth
basis.
5.2 Selection of Remedy
The remedy selected for the site should provide the best
balance of tradeoffs among alternatives with respect to the
nine evaluation criteria. First, it should be confirmed
that all alternatives provide adequate protection of human
health and the environment and either attain or exceed all
of their ARARs or provide grounds for invoking a CERCLA
waiver of an ARAR. Some of the key tradeoffs for sites with
62
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PCB contamination include:
o Alternatives that offer a high degree of long-term
effectiveness and permanence and reduction of toxicity,
mobility, or volume through treatment, such as
incineration, generally involve high costs. Short-term
effectiveness for such alternatives may be low since
risks may increase during implementation due to the
need to excavate and possibly transport contaminated
material, resulting in cross-media impacts.
o Alternatives that utilize innovative methods, often
less costly than incineration, to reduce toxicity,
mobility, or volume are often more difficult to
implement due to the need for treatability studies and
to construct treatment facilities onsite. In addition,
the treatment levels achievable and the long term
effectiveness and permanence may be less certain.
o Alternatives that involve stabilization to reduce the
mobility of PCBs and limit cross-media impacts that may
result from incineration (particularly important when
other contaminants such as volatile metals are present)
at a lower cost than other treatment methods, have
higher uncertainty over the long term but may provide
advantages in long-term effectiveness over alternatives
that simply contain the waste in place.
o Alternatives that simply contain PCBs do not utilize
treatment to reduce toxicity, mobility, or volume of
the waste, have lower long-term effectiveness and
permanence than alternatives involving treatment, but
are generally less costly, easy to implement, and pose
minimal short-term impacts.
The relative trade-offs based on these considerations will
vary depending on site specific considerations discussed in
earlier sections; i.e., concentration and volume of PCBs,
site location, and presence of other contaminants.
5.3 Documentation
Typically, a ROD for a PCB-contaminated site should
include the following unique components in addition to the
standard site characterization and FS summary information
described in the Guidance on Preparing Superfund Decision
Documents:
o Remediation goals defined in the FS. For the selected
63
-------
remedy, the ROD should describe:
- Cleanup levels above which PCB-contaminated material
will be excavated. A comparison of the levels
selected to PCB Spill Policy levels and explanation
of why they differ may be warranted.
- Treatment levels to which the selected remedy will
reduce PCB concentrations prior to re-depositing
residuals onsite or in a landfill. The consistency
of these levels with the TSCA requirements (i.e.,
the requirement to demonstrate achievement of 2 ppm
or less in solid treatment residue for material that
will remain on site with no controls) , and RCRA LDR
requirements for hazardous wastes, should be noted.
o A description of technical aspects of the remedy, such
as the following (should be included in alternative
descriptions):
- Treatment process, including the disposition of all
effluent streams and residuals.
- Time frame for completing the remedy and controls
that will be implemented during this time to ensure
protection of human health and the environment.
- Long term management actions or site controls that
will be implemented to contain or limit access to
PCBs remaining on site. The consistency with RCRA
closure and TSCA chemical waste landfill measures,
and necessary TSCA waivers, should be indicated.
64
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Chapter 6
References
Alford-Stevens, Ann L. , Analyzing PCBs, Environmental Science and
Technology, Vol 20, No. 12, 1986.
Aulerich et al, Assessment of Primary and Secondary Toxicity of
Arochlor 1254 to Mink, Arch. Environmental Contaminant
Toxicology 15: 393-399, 1986.
Backhus, Debera A. and Gschwend, Philip M., Fluorescent Polycyclic
Aromatic Hydrocarbons as Probes for Studying the Impacts of
Colloids on Pollutant Transport in Ground Water, R.M. Parsons
Laboratory for Water Resources and Hydrodynamics, Department
of Civil Engineering, Massachusettes Institute of Technology,
August 8, 1988.
Bedard, Donna L; Unterman, Ronald; Bopp, Lawrence H.; Brennan,
Michael J; Haberl, Marie L.; Johnson, Carl, Rabid Assay for
Screening and Characterizing Microorganisms for the Ability
to Degrade Polychlorinated Biphenyls, Applied and
Environmental Microbiology, pp 761-768, April 1986.
Brown, John F.; Wagner, Robert F.; Feng, Helen; Bedard, Donna L.;
Brennan, Michael J.; Carnahan, James C.; May, Ralph J.,
Environmental Dechlorination of PCBs, Environmental
Toxicology and Chem., Vol. 6, pp 579-593, 1987.
des Rosiers, Paul E., Chemical Detoxification of Dioxin-
Contaminated Wastes Using Potassium Polyethylene Glycolate,
Dioxin '87, 7th International Symposium on Dioxins and
Related .Compounds, Las Vegas, NV, October 1987.
Fetter, C.W. Jr., Applied hydrogeology, Bell and Howard Co., pp
64, 1980.
Fletcher et al., Metabolism of 2-Chlorobiphenyl by Suspension
Cultures of Paul's Scarlet Rose, Bulletin on Environmental
Contaminant Toxicology 39:960-965, 1987a.
Fletcher et al., Polychlorobiphenyl (PCB) Metabolism by Plant
Cells, Biotechnology Letters 9:817-820, 1987b.
Focardi et al, Variations in Polychlorinated Biphenyl Congener
Composition in Eggs of Mediterranean Water Birds in Relation
to Their Position in the Food Chain, Environmental Pollution
52: 243-255, 1988.
Glaser et al., Trace Analyses for Water Waters, Environmental
Science and Technology, Vol 15, pp 1426, 1981.
65
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U.S. EPA, "PCB Contamination at Superfund Sites — Relationship
of TSCA Anti-Dilution Provisions to S"uperfund Response
Actions," Memorandum from Don Clay and Linda Fisher, July
1990b.
U.S. EPA, Risk Assessment Guidance for Superfund, Volume 1, Human
Health Evaluation Manual (Part A) (Interim Final), EPA/540/1-
89/002, Office of Emergency and Remedial Response, December
1989f.
U.S. EPA, Risk of Unsaturated Transport and Transformation of
Chemical Concentrations (RUSTIC), EPA/600/3-89/048a,b, July
1989g.
U.S. EPA, Stabilization of PCB Contaminated Soil, Memorandum from
Edwin Earth to Jennifer Haley, September 26, 1988c.
U.S. EPA, Superfund Ground Water Issue — Facilitated Transport,
EPA/540/4-89/003, Office of Research and Development, August
1989h.
U.S. EPA, Superfund Ground Water Issue — Ground Water Sampling
for Metals Analysis, EPA/540/4-89/001, Office of Research and
Development, March 1989i.
U.S. EPA, Superfund Land Disposal Restrictions Guide #6A —
Obtaining a Soil and Debris Treatability Variance for
Remedial Actions, Office of Solid Waste and Emergency
Response, Directive No. 9347.3-06FS, July 1989j.
U.S. EPA, "Update PCB Cleanup-Level Document," Memorandum from
Michael Callahan to Henry Longest, December 6, 1988d.
U.S. EPA, Verification of PCB Spill Cleanup by Sampling and
Analysis, EPA-560/5-85-026, Office of Toxic Substances,
August 1985b.
U.S. EPA, Water Quality Criteria Document for PCBs, Federal
Register 45 pp 79332, Office of Water, 1980C.
Unterman, Ronald; Brennan, Michael J., Brooks, Ronald E; Mondello,
Frank J.; Mobley, David P; McDermott, John B.; Dietrich, David
K; Wagner, Robert E., Bioremediation of PCBs in Soil; Research
and Development Program for the Destruction pf PCBs, GE
Research and Development Center, Schenectedy, N.Y., June 1988.
Yeh, G.T., AT123D, Analytical Transient One-, Two-, and Three-
Dimensional Simulation of Waste Water Transport in the
Aquifer System, ORNL-5601, 1981.
68
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APPENDIX A
SUMMARY REPORT
FY82 - FY89 RECORDS OF DECISION ADDRESSING PCB-CONTAMINATED MEDIA
-------
06/25/90
SUMMARY REPOR1 OrFY82 THROUGH
RF.CORDS OF DECISION THAI ADDRESS POIYCIIIORINAHO BIPIIENYI.S
.AS A CONIAMINANI OF CONCERN
SITE NAME. STATE (ROD SIGN DATE] [LEAD]
COMPONENTS OF ,ME SELECTED REMEDY
COSTS
RD/RA COMPLETION
DA1ES
AROCHLORS
PRE-TREA1MENI
CONCENIRA1ION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SflECTEO
"' REGION 01
* Cannon Engineerirg/tMymouth. MA [03/31/88]
Decontamination of all structures and
debris with offsite disposal; excavation
> of contaminated soils with onsite thermal
>-* aeration; excavation of PCB contaminated
soils and offsite incineration and
disposal; restrict ground water use;
ground water monitoring.
[F ]
$2.700.000
Capital Cost
RO: (SCAP): 89/4 Not Not
RA: (SCAP): 91/4 Stated Stated
Not
Stated
Not
Stated
Incineration selected.
Norwood PCBs. MA (09/29/89] [F ]
Excavation and onsite treatment of
PCB-contaminated soils and sediments
using solvent extraction; area specific
soil target cleanup levels established
based on area risk assessment exposure
scenarios; offsite incineration of oil
extract from solvent extraction process;
soil cover over treated soils;
decontamination cf machinery using
solvents; extraction and treatment of
PCB-contaminated ground water using
carbon adsorption with offsite disposal
of spent carbon; ground water use
controls; and wetlands restoration.
$16,100.000
Present Worth
RD: 91/3
RA: 92/4
1016
1254
1260
2.060 ppm
sediment
1-25 ppm 31,550 Incineration was selected for
cubic yards oil extract Irom solvent
extract ion process.
Incineration was chosen only
as a contingency n.-inedy tor
soil anrt sediment ilur to
higher cost .
-------
SUMMARY REPORT Or FY82 THROUGH FY89
RECORDS OF DECISION THAI ADDRESS POLYCHLORINAIFD RIPHENYLS
AS A CONTAMINANT OF CONCIRN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREA1MENT
CONCENTRAIION
EXCAVATION
UVEIS
ESTIMATED
VOLUME.
RATIONALE WHY INCINERATION
WAS HOI SUECTEO
' O'Connor, ME [09/27/89] [RP]
Excavation and onsite treatment of
approximately 23.500 cubic yards of soil
and sediments containing PCBs using
solvent extraction; solvent extract will
> be incinerated offsite; treated soils
to containing lead levels >248ppm will
undergo solidification/stabilization
treatment and offsite disposal;
backfilling using clean and treated
soils; pumping and offsite treatment of
approximately 19f>,000 gallons of surface
water containing ?CBs; and extraction and
onsite treatment of PC8 (Arochlor 1260)
contaminated ground water using
filtration/carbon adsorption.
$13.590.000
Present Worth
RD: 91/4
RA: 94/1
1260 200.000 ppm max Not 23,500 Incineration was not selected
Stated cubic yards as primary treatment due to
its short-term air quality
impacts on local community and
onsi te workers.
Ottati & Goss. NH [01/16/87] [S ]
Excavation of PCB contaminated soil and
sediment and treatment using incineration
following test bu<-n; RCRA delisting
evaluation to be conducted for ash
residuals; aeration of other contaminated
soils, including I'LB soil with
$6.055.000
Present Worth
RD: (SCAP): 89/2. Not
subsequent RO start Stated
pending trial
RA: (SCAP): 91/1
143 ppm
1 ppm 14,000 EPA feels th.it thi; recommended
(sediment). cubic yards health-based BKOiv.it ion
20 ppm criterion o! '/Q ppm ' •;
(soil) appropr ial ir lor tins site and
is consistent with II'A di.ift
' IJIJHlillll (' ( Devi'I (l|,nil-Ill of
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAIED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGH DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
concentrations less than 20 ppm; pilot
study to be conducted to demonstrate the
aerat ion process.
COSTS .
RO/RA COMPLFTION
DAirs
AROCHLORS
PRE-TR[AIM[NI
CONCENIRAMON
FXCAVATION
IEVELS
ESTIMATED
VOt UMf
RATIONALE WHY INCINERA1ION
WAS NOJ SHFCHO
Advisory Levels for PCB
Cleanup). Soil aeration will
be consistent with RCRA
requirements achieving 1 ppm
for sediments with less than
20 ppm PCBs.
Ptnette's Salvage Yard. ME [05/30/89]
Excavation and offsite Incineration of
PCB-contaminated soil with offsite
disposal of ash; excavation and onsite
solvent extraction of 5-50 ppm PCB
contaminated soil with collection of
treatment waters in onsite storage tanks
and treatment by carbon adsorption and
disposal (unspecified) of carbon filters
and water, offsita incineration and
disposal of PCB oil by-products, and
onsite backfilling of treated soils;
consolidation of 500 cubic yards of 1-5
ppm PCB soil into excavated areas and
cover with < I ppm PCB soil; extraction
and onsite treatment of contaminated
ground water using filtration and carbon
adsorption with reinjection of treated
water and disposal of carbon residuals
(unspecified); offsite disposal of debris
affecting remediation activities; O&M.
[F]
$3.420,000 RD: (SCAP): 90/4 Not
Capital Cost RA: (SCAP): 91/4 Stated
92 ppm
1 ppm
2.200 Incineration for I'CB
cubic yards concentrations above 50 ppm.
Solvent extraction for PCB
concentrations between 5 ppm
and 50 ppm. Rep dice and cover
for PCBs below S |i|xn.
-------
SUMMARY REPORT OF FY8e THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAFED BIPHENYLS
AS A CONTAMINANT OF CONCERN
* SITE NAME. STATE fROO SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLEFION
DATES
AROCHLORS
PRE-IREATMfNI
CONCENIRATION
EXCAVATION
LEVELS
ESTIMATFO
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SFLICIED
Re-Solve. MA [07/01/83] [F ]
Excavation of oi' leachate soils and four
unlined lagoons with offslte disposal at
a RCRA hazardous waste facility; capping,
regrading, and reveyetating of the six
acre site.
$3.050,000 RD: (SCAP): 83/4 Not Not
Capital Cost RA: (SCAP): 87/4 Stated Stated
Not 3,900 cy Incineration HAS not
Stated (soil), considered as a remedial
3,100 cy alternative in this Record of
(lagoon) Decision.
Re-Solve. MA [09/24/87] (F ]
Dechlorination of RGB-contaminated soils
using potassium polyethylene glycol
(KPEG) with onstte disposal of treated
soils.
$17,038.000
Present Worth
RD: (SCAP): 90/4 Not
RA: (SCAP): 93/1 Stated
3,000 ppm
1 ppm ?2,500 Incineration not '.elected due
(sediment), cubic yards to limited facilities
25 ppm (availability) anil length of
(soil) implementation timp
Rose Disposal Pit. MA [09/23/88] [RP]
Excavation of soil and sediment with
onsite incineration and disposal;
recovery of subsurface free product with
offsite thermal destruction and disposal;
extraction of ground water and treatment
using air stripping and carbon adsorption
with discharge to the aquifer.
$6,450.000 RD: (SCAP): 90/3 Not Not
Present Worth RA: (SCAP): 91/3 Stated Stated
13 ppm
15,000
cubic yards
Incinerat ion sHi-i
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STAH [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENfRAMON
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOJ SELEC1ED
South Municipal Water Supply Well. NH [09/27/89] [F ]
Excavation and/or dredging of 1,170 cubic $3.394,519
yards of wetlands sediments containing Present Worth
PCB levels >lppm followed by offsite
incineration and disposal of residuals;
In-sttu treatment of 7,500 cubic yards of
sol) contaminated by volatile organic
compounds using carbon adsorption for air
emissions; ground water treatment using
air stripping; and ground water
restrictions.
RO: 91/3
RA: 92/4
Not
Stated
Not
Stated
1 ppra
1.170
cubic yards
Incineration selected.
Sullivan's Ledge, MA [06/29/69] [F ]
Excavation of contamianted soil and
sediment with dewatering and onsite
solidification and disposal; excavation,
clearing, and onsite and offsite disposal
of debris; capping of eleven of the
twelve acre site; extraction and onsite
treatment of contaminated ground water
with onsite discharge of treated water to
surface water or to a secondary treatment
plant; diversion ind lining of surface
water; ground wat^r institutional
$10,000,000
Present Worth
RD: (SCAP): 91/1 Not
RA: (SCAP): 92/4 Stated
?.400 ppm
10 ppm 24.200 cy Selected remedy is
(soils), (soil), cost-effective considering
1 ppm 1.900 cy long-term effectIVPMCSS and
(sediment) (seds) the significant reduction of
mobility equivalent to other
treatment alternatIVRS (i.e.,
incinerat ion)
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATFD RIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAOj
COMPONENTS OF THE SELECTED REMEDY
controls; O&M.
COSTS.
RD/RA COMPLETION
DATES
AROCHLORS
P'RE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED RATIONALE WHY INCINERATION
VOIUME WAS NOI SEICCTED
O\
Wells G&H, MA [09/14/89] [F J
Excavation of PCR-contamlnated soils with
onsite incineration and backfilling of
excavated areas; in-situ volatilization
of 7.600 cubic yards of soils
contaminated with volatile organic
compounds using carbon adsorption for
emissions; and extraction of ground water
and treatment using air stripping and
carbon adsorption.
S68.400.000
Present Worth
RD: 91/3
RA: 93/2
Not
Stated
Not
Stated
I.04 ppm
3.100
cubic yards
Incineration selected.
*• Subtotal **
11
REGION 02
Bridgeport Rental i Oil. NJ [12/31/84] [F ]
Excavation and onsfte incineration of $35.050.000
oily waste, sediment and sludge using a Present Worth
pyrotech mobile incinerator.
RD: (SCAP): 88/2 Not
RA: (SCAP): 92/4 Stated
>500 ppm
Not
Stated
60,000
cubic yards
Incineration snln leil.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAFEO BIPHENYLS
AS A CON1AMINAN1 OF CONCFRN
SITE NAME. STA;E [ROD SIGN DATE] [LEAD]
COMPONENTS OF 1HE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DAIES
AROCHLORS
PRE-TRF.ATMCNI
CONCENTRAHON
EXCAVAIION
LEVELS
LSTIMATFO
VOLUME
RATIONALE WHY INCINERATION
WAS NOf Ml ECHO
Burnt Fly Bog. NJ [11/16/83] [S ]
Excavation and offsite disposal of
liquids, sludges, asphalt pines, drums.
and contaminated soils from lagoons and
wetlands; restoration of site contours
and revegetatton ground water
monitoring.
$7.310.000 RD: (SCAP): 86/3 Not
Capital Cost RA: (SCAP): 89/4 Stated
245 ppm
8.5 ppm Not There are no mobile
Stated incinerators presently
available which can reliably
incinerate PCB waste. In
addition, the process would
generate ash residual,
wastewater, and air emmissions
which would require treatment
or secure disposal
Burnt Fly Bog. NJ [09/29/88] [S ]
Excavation of contaminated materials and
offsite disposal; containment of
contaminated soil In westerly wetlands;
construction of a security fence and
access road; treatability studies will
determine the most appropriate remedy for
the westerly wetlands.
$6,100,000
Present Worth
RO: (SCAP): 90/e Not
RA: (SCAP): 91/2 Stated
232 ppm
5 ppm 62,000 cy Contamination found in the
(soils) (soil) downstream area, while
1,400 cy significant enough to pose a
(seds) threat in the stri'.im, is at
sufficiently low concentration
that treatment is not
warranted. At this low
concentration, [PA li;els that
containment in a HI PA or ISCA
permitteil facility would lie
protective.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POIYCHI iii:INAlŁ0 BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STA1E [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF IHE SELECTED REMEDY
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NQl SFIECUO
Chemical Control. NJ [09/23/87] [F ]
In-sltu fixation of contaminated soil
(drill large diameter soil borings,
inject chemical fixating material and mix
with soil); treatability studies will be
conducted during remedial design.
$7.280.000
Capital Cost
RD: (SCAP): 91/2 1242
RA: (SCAP): 93/1 1254
1260
6 ppm
Not 18.000 Incineration is more expensive
Stated cubic yards than the selected alternative
and does little to further
reduce risk at the site.
Clothier Disposal. NY [12/28/88] [S ]
Cover contaminated soil containing less
than 1 ppm PCBs with one foot of clean
soil; installation of rip rap to prevent
soil erosion; long-term ground water,
surface water, air and sediment
monitoring; institutional controls
including land use and deed restrictions.
$500.000
Present Worth
RD: (SCAP): 89/3
RA: (SCAP): 90/4
1242
2.7 ppm
1 ppm 2.500 EPA determined that the risk
cubic yards levels associated with the
residua) contamitMtion was
minimal and within the range
considered acceptable for
Superfund remedies. Ihe
selected remedy provides
additional protection by
reducing the thre.il of contact
and ingpstinn through capping.
GE Moreau. NY [07/13/87] [RP]
Excavation of 8.600 cubic yards of soil
with onsite disposal within existing
slurry wall containment area; cap
disposal area; extent ion of public water
$4.664.000
Capital Cost
RD: (SCAP): 87/4 Not
RA: (SCAP): 89/3 Stated
3,000 ppm
Not 8.600 Inr.iMiMat ion mi1, ill- in ollsite
Slated cubic yards lor some H.I.(1(1 uil.n y.inK of
material would lie
prohllil t i vtrl y i'«pi'n . I ve
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAfED BIPHENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
supply to approximately 100 homes;
Institutional controls.
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
FXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS N01 SELECTED
compared to the other two
remedial alternatives
described. Incineration was
therefore eliminated from
future consideration.
Hooker/Hyde Park. NY [11/26/85] [FE]
Extraction and orsite phase separation of $17,000.000
non-aqueous phase liquids (NAPL) from Total Cost
ground water followed by thermal
destruction.
RD: (SCAP): 86/4
RA: (SCAP): 92/1
1248
3.000 ppm
Not
Stated
Not
Stated
Incineration selected.
Hudson River PCB. NY [09/25/84] [F ]
In-situ contalnme.it of remnant shoreline
deposits; covering of affected areas with
soil, regrading, jnd seeding;
stabilization of river bank, if
necessary.
$2.950.000 RD: (SCAP): 89/4 Not
Capital Cost RA: (SCAP): 92/1 Staled
1,000 ppm Not Not The capital costs associated
Applicable Applicable with const inc. ting A
multi-incinerator system that
would have the capacity to
handle the massive amounts of
PCB sediment (at Iho site)
would approach 25(1 million
dollars.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAI ADDRESS POLYCHLORINATED BIPHCNYIS
AS A CONTAMINANT OF CONCERN
SHE NAME, STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RD/RA COMPLETION
DAIES
AROCHLORS
PRE-TREATMENI
CONCENTRATION
EXCAVATION
I[VCIS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOJ SI.IICTED
Kln-Buc Landfill, NJ [09/30/88] [RP]
Extraction of ground Mater and aqueous
phase leachate and onsite treatment using
carbon adsorption and aerobic/anaerobic
biodegradrtion treatment with onsite
residual discharge to surface water;
collection and offslte incineration of
oily phase leachate; installation of a
slurry wall and cip with periodic
monitoring; 0!>M.
$16.635.000
Present Worth
RD: (SCAP): 90/2 Not
RA: (SCAP): 93/1 Slated
ppm Not 3.000,000 It would be difficult for a
Stated gallons single incinerator facility to
r (leachate) dedicate itself to handling
such a large volume of
ha/ardous waste. Even if an
incinerator dedicated itself
to disposing Kin-Hue wastes,
it is estimated that it would
take 35 years to complete
incinerat ion.
Krysowaty Farm. NJ [06/20/84] [F ]
Excavation and offsite disposal of
contaminated soils and wastes at an
approved PCB facility; monitoring of
onsite wells; provide alternate water
supply to affected residents;
post-closure environmental monitoring.
$2,164,014
Capital Cost
RD: (SCAP): 85/1 1221
RA: (SCAP): 86/2 1260
300 ppm
Not 4,000 PCB contamination at the site
Stated cubic yards did not exceed 500 ppm;
therefore, disposal of
contaminated soils will occur
in a ISCA approved landfill.
If soils arc encountered with
PCB levels above 500 ppm,
these soi Is will In-
incinerated |i(;r I SI A
i on111 rcmnnt s
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOJ MIECTED
Ludlow Sand & Gravel. NY [09/30/88] [FE]
Excavation of contaminated soil and $3.727.000-
sediment and onsite consolidation, $14.548,900
disposal, and capping; collection of Present Worth
leachate using either a passive drain
system or an active extraction well
system and dewaterlng of contaminated
leachate and ground water with onsite
discharge of effluent to surface water or
offsite discharge; multimedia monitoring.
RD: (SCAP): 91/1 Not
RA: (SCAP): 93/2 Stated
482 ppm
10 ppm 10.000 Thermal treatment
cubic yards (incineration) was not
expected to offer significant
increases in protectiveness to
public health and the
environment, or short- or
long-term effectiveness for
the increased cost
Renora, NJ [09/29/87] [FE]
Excavation and offsite landfill ing of
PCB-contaminated soils; excavation and
onsite biodegradation of PAH-contaminated
soils; backfilling; grading; and
revegetation.
$1.344,000
Capital Cost
RD: (SCAP): 88/4
RA: (SCAP): 90/4
1260 37,000 ppm 5 ppm 1.100 Excavation and of(site
cubic yards disposal also may include
offsite incineration as a
component of the selected
remedy.
Swope Oil & Chemical, NJ [09/27/85] [F
Excavation and offsite incineration of
PCB "hot spots"; removal of tanks,
buildings, and debris with offsite
incineration; extraction and offsite
incineration of aqueous tank contents;
$3.134.683
total Cost
RO: (SCAP): 88/4
RA: (SCAP): 90/4
1242
1248
1254
1200
500 ppm
• 5 ppm
145 cy
> 50 ppm
8.650 cy
•• ')0 p|)in
Total site cont.iiniii.it ion not
me inrralpc) ilni," In i ir;t
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATTD BIPHFNYI.S
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRAIION
FXCAVAT10N
LEVELS
ESTIMATED
VOLUME
offsite disposal of non-aqueous tank
contents: excavation of PCB contaminated
soil and buried sludge area with offsite
disposal.
RATIONALE WHY INCINERATION
WAS KOI SFIECTEO
' Wide Beach Development. NY [09/30/85] [S ]
> Conduct pilot study on KPEG (potassium $9.295.000
•-• polyethylene glycol) treatment to Present Worth
determine effectiveness in neutralizing
the PCB contaminated soil.
RO: (SCAP): 89/2
RA: (SCAP): 91/1
1254
1.026 ppm
10 ppm 22.300 Incineration not retained as a
cubic yards viable alternative through
preliminary screening. No
rationale was provided in the
ROD.
York Oil. NY [02/09/88] [F ]
Excavation and dewatering of PCB
contaminated soil and sediments with
solidification in a mobile onslte unit,
the stabilized material will be tested to
verify its non-Teachability and then
disposed onsite: extraction of ground
water with onsite treatment using an oil
skimmer and oi)/»ater separator with
discharge into a nodular water treatment
unit; offsite tre.'tment (to be selected
following (reliability studies) of
PCB-i.ontaimiioted tank oils; demolition
$6.500.000
Capital Cost
RO: (SCAP): 91/1
RA: (SCAP): 93/2
1248
1254
1260
210 ppm
10 ppm
(soil)
1 ppb
(ground
water)
30.000
cubic yards
25.000
gal Ions
Incineration was riot selected
because further treatment of
the residual ash following
thermal destructinn may be
needed to fuse llic high
concentration of metals fcmml
onsite into the re*, i HIM I ash
in a non -h.w.n ilnir. limn
-------
SUMMARY REPORT OF FY82 THROUGH FYB9
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATEO BIPHENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
and decontamination of the empty storage
tanks.
** Subtotal
IS
COSTS
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NQT SELECTED
**
REGION 03
Delaware Sand ft Gravel. DE [04/22/68]
Excavation of PCB-contaminated soil at
Drum Disposal Area iind Ridge Area;
temporary onsite storage followed by
onsite mobile incineration of excavated
soil and waste; ireatability studies;
residual ash wll DC analyzed and
disposed onsite.
[Ft]
$18.250.000
Total Cost
RD: (SCAP): 90/2 Not
RA: (SCAP): 93/4 Stated
49 ppm
Not
Stated
29,722
cubic yards
Incineration selected.
Oouglassville Disposal. PA [06/24/88]
Removal, transportation, and offsite
Incineration of liquid and sludge tank
waste; decontamination of tanks, piping,
processing equipment, and building
materials designated for salvage or reuse
to a level not to exceed 100 ug/100
square centimeters PCBs on the surface;
offsite disposal of building rubble,
[S]
$4,050.000
Capital Cost
RD: (SCAP): 89/3
RA: (SCAP): 91/1
1260
6,400 ppm
Not
Stated
200.000
gal Ions
Incineration selected.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION IHAT ADDRESS POLYCHLORINAIEO BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE (ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
concrete, asphalt, and other materials
that cannot be decontaminated to less
than 50 ppm PCBs and treatment
(dewatering or incineration) of generated
decontamination fluids.
RD/RA COMPLETION
OAIES
AROCHLORS
PRE-TREA1MENT
CONCENIRAIION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS Nfrl SI I ECHO
Oouglassvilie Disposal. PA [06/30/89] [S ]
Excavation and onslte thermal treatment
of contaminated soils, sludges and
sediments with solidification and onsite
disposal of ash residuals; installation
of soil covers in lesser contaminated
source areas; deed restrictions.
$39.280.670-
$53.619.000
Capital Cost
RD: (SCAP): 90/3 Not •
RA: (SCAP): 91/4 Stated
1,889 ppm
Not
Stated
48.400
cubic yards
Incineration selected.
Fike Chemical, WV [09/29/88] [F ]
Excavation and removal of tanks and drums
with offsite incineration and disposal;
drainage and onslte treatment of lagoon
sludge using ion exchange or chemical
oxydation; wastewater treatment using
granulated activated carbon with offsite
residual discharge to surface water.
$13.130,000 RD: (SCAP): 89/2 Not Not
Present Worth RA: (SCAP): 90/1 Stated Stated
Not
Stated
Not
Stated
Incineration
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAIEO RIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RO/RA COMPLETION
OA1ES
AROCHLORS
PRE-TREAIMENT
CONCENIRA1ION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SflECIED
* Lehigh Electric. PA [02/11/83] [F ]
Excavation and offsite disposal of soils
greater than 50 ppm; additional removal
of soil where cost-effective; demolition
.. of buildings onsite; grading and
^ revegetation; O&M.
$6.401.000 RO: (SCAP): 84/1 Not
Capital Cost RA: (SCAP): 84/4 Stated
110,000 ppm 50 ppm 18.800 Ihnre are no mobi It-
cubic yards incinerators permitted to
operate in Pennsylvania.
Operating costs also would be
excessive, making this option
not cost-effoctivi?
M.U. Manufacturing, PA [03/31/89] [F ]
Excavation of cor laminated waste and soil
followed by offsite incineration at a
RCRA permitted facility; incinerator ash
will be disposed offsite at a RCRA
landfill.
$7.061.000 RD: (SCAP): 89/4 Not
Capital Cost RA: (SCAP): 90/1 Stated
54 ppm
Not
Stated
Incineration selo> I ml.
cubic yards
Ordinance Works D.sposal. UV [03/31/88]
Onsite mobile Incineration and
containment of excavated soils and
sediments; onsite disposal of non-EP
toxic ash residuals In an inactive
landfill; offsite Disposal of EP toxic
[ft]
$6.718,000
Present Worth
RO: (SCAP): 91/2 1016
RA: (SCAP): 93/4 1260
229 ppm
5 ppm
Not
Incinerat ion seln Icil.
-------
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
ash at an approved RCRA facility; close
inactive landfill using multi-layer cap.
" Subtotal "*
7
** REGION 04
SUMMARY REPORT OF FY83 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAIED BIPHENYLS
AS A CONTAMINANT OF CONCERN
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED RATIONALf WHY INCINERA1ION
VOLUME VAS NOT SIIECTED
Afrco Carbide. KY [06/24/88] [RP]
Excavation and consolidation of
contaminated sediments and surface soils
In former Burn Pit Area and cap;
extraction of grennet water and onsite
treatment using
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RO/RA COMPLETION
DA1ES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED RATIONALE WHY INCINERATION
VOLUME WAS N04 SELECTED
solidification/stabilization of thermally
treated soil following treatability
studies.
Goodrich. 8.F. Chemical Group. KY [06/24/88] [RP]
Extraction of grc.und water and treatment
using air stripping, carbon adsorption,
and oil/water separation with discharge
of treated water to surface water; deed
restrictions; excavation and placement of
the contaminated surface soils in former
burn pit area and cap; construction of an
organic vapor recovery system;
construction of a flood protection dike;
installation of a leachate extraction
system and upgrade existing landfill clay
cap.
$6.090,000
Present Worth
RD: (SCAP): 89/3 Not 4 ppm
RA: (SCAP): 91/4 Stated (seds)
Not 5,000 Incineration not retained as a
Stated cubic yards viable alternative through
preliminary screening. No
rationale was provided in the
ROD.
Mowbray Engineering, AL [09/25/86] [F ]
Excavation of contaminated soils and 1750,000
either on- or offsite incineration or Capital Cost
unsite stabilization/solidification of
these soils.
RO: No RD date; 1260
removal act ion wi11
be conducted to
implement ROD;
solidification was
chosen as the
1,500 ppm 25 ppm 4,800 Incineration prelcin-rJ in ROD.
cubic yards however, Reqion.il I imrdirMtor
stated thjt sol idi I u:
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BII'HENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STA1F [ROD SIGN DATE] [LEAD]
COMPONENTS OF IHE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DAIES
selected action.
RA: (SCAP): 87/4
AROCHLORS
PRE-TREATMFNT
CONCENIRATION
EXCAVATION
IEVELS
ESIIMATEf)
VOLUME
RATIONALE WHY INCINERATION
WAS NQ.1 SILECUD
Newport Dump. KY [03/27/88] [FE]
Restoration and extention of leachate
collection system; resoration, regrading,
and revegetatlon of clay cap; monitoring
of ground water and soil; O&M.
$516,000
Capital Cost
RD: (SCAP): 88/1 1242
RA: (SCAP): 88/1 1260
1,020 ppm Not Not Incineration was not
Applicable Applicable considered as a remedial
alternative in this Record of
Decision.
Newsom Brothers Old Reichold. MS [09/18/89] [F ]
Excavation of PCB-contaminated sediments $14,180.249
and soils with offsite disposal; Present Worth
excavation of non-PCB contaminated black
tar-like waste material with offsite
treatment using incineration and offsite
disposal of ash at a RCRA landfill
RD: 90/4
RA: 92/2
1254
10 ppm
sediment
0.12 ppm 48,370 Incineration for soils and
cubic yards sediments wris not selected due
to uncertainty over volume of
material to he Inwted and
lack of acceptance hy State
and coinnunity. llHjhor cost
was consideicd a minor
influence in
Pepper's Steel & Alloy. FL [03/12/86] [FE]
Solidification of PCB contaminated soils $5.212.000
with a cement typ-i mixture and onsite Present Worth
RD: (SCAP): 87/1 Not
HA: (SCAP): 89/3 Stated
2.700 ppm
ppm
4H.OOO lnciner.it ion w.is nnl '.elected
cubic yards iluc to serious cnv 11 on
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POIYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
placement of residuals; residual analysis
of solidified soils prior to disposal.
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED RATIONALE WHY INCINERATIOM
VOLUME WAS Nftl SllfClEO
disadvantages (2-16% of lead
escapes into the aquifer).
inavallability of
incinerators, complexity of
waste matrix, time intensive
remedy, costly, and requires
additional waste handling.
Smith's Farm Brooks. ICY [09/29/89] [F ]
Excavation of PCB contaminated soil.
waste material and sediments from site
Area B with onsfte incineration followed
by solidification/fixation of treatment
residuals; cappirj of sods in Area A;
construction of 1;arhate collection
system; access restrictions; and ground
water monitoring.
$26,900,000
Present Worth
RO: 91/1
HA: 93/3
1248
1254
1260
6.100-13.lOOppm 2 ppm
26,200
cubic yards
Incineration selected.
Subtotal
REGION OS
AiF Materials/Greenup. IL [06/14/85] [FE]
Excavation and offsite disposal of soil $824,000
contaminated above recommended action Capital Cost
RO: (SCAP): 84/3 Not Not
RA: (SCAP): 85/4 Stated Stated
1 ppm
1.332
cuhic yards
lncinet.it inn w.is mil
considc.'icd .r. .1 ifnu'
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STA E [ROD SIGN DATE] [LEAD]
COMPONENTS OF IHE SELECTED REMEDY
COSTS
levels; decontamination and removal of
onslte equipment and buildings; ground
water monitoring; O&H.
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SLIECTEO
alternative in this Record of
Dec i s i on.
>
J
Alsco Anaconda. (H [09/08/89] [RP]
Excavation of SO cubic yards of sludge
with PCB levels >500ppm followed by
offslte incineration and disposal;
excavation of reclining 3,250 cubic yards
of sludge and soils (PCB concentrations
<500ppm) with offsite disposal in
compliance with all RCRA and TSCA
regulations; backfilling excavated areas;
and deed restrictions.
$4.161,066
Capital Cost
RO: 91/3
RA: 93/4
Not
Stated
3,000 ppm max
sludge
Not
Stated
3,300 Incineration selected for PCB
cubic yards concentrations >M)Oppra.
Belvldere Municipal Landfill l\. IL [06/30/88] (S ]
Soils in the drum disposal area will be
resampled and those containing greater
than SO ppm PCBs will either be excavated
and incinerated offsite or left in place
and capped with a soil cover; soils
contaminated with less than 50 ppm PCBs
will be consolidated with the landfill
material prior to capping.
$5.617.000
Present Worth
RD: (SCAP): 90/1
RA: (SCAP): 92/3
1254
1260
51.000 ppm 50 ppm Not Incineration selected for
Stated soils containing <|ieater than
50 ppm PCBs.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYI.S
AS A CONTAMINANT OF CONCERN
' SITE NAME. STAIE [HOD SIGN DATE] [LEAD]
COMPONENTS OF !HE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMAIED
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SFIECTED
Bowers Landfill. OH [03/31/89] [RP]
Capping; management of surface debrts;
erosion control and monitoring of ground
water; O&H.
$4.267,500
Present Worth
RD: (SCAP): 90/4 1242
RA: (SCAP): 92/1 1248
1254
36 ppm
Not Not Incineration was not
Stated Stated considered as a alternative
remedy, and no rationale was
provided in the ROD
Cross Brothers Pail. IL [09/28/89] [S ]
Resampling of localized PCB soil area to
identify existence of PCB source; if
Identified the source area Mill be
excavated and incinerated offsite at a
TSCA Incinerator; installation of a
passive ground water collection and soil
flushing system; ground water monitoring;
and deed and access restrictions.
$2.076.500
Present Worth
RD: 91/2
RA: 92/4
1242
1248
1254
1260
42.900-
112,000 pp
10 ppm
Incineration selected.
cubic yards
Fields Brook. OH [09/30/86] [F ]
Excavation of contaminated sediment with $12,260.000
temporary storage, dewatering, test burns Capital Cost
and onsite thermal treatment followed by
onsite disposal of ash in a RCRA/TSCA
RO: (SCAP): 91/3 Not
RA: (SCAP): 94/1 Stated
518 ppm
SO ppm
16.000
cubic yards
I IK: inrr.il ion M-II'I.I r
-------
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS Of DECISION THAI ADDRESS POIYCHLORINAIFO fllPHENYIS
AS A CONIAMINANT OF CONCERN
RD/RA COMPLETION AROCHLORS PRE-TREATMENT • EXCAVATION
DATES CONCENIRAIION LEVELS
ESTIMAIED
VOLUME
RATIONALE WHY INCINERAIIO!
WAS NOI SELECTED
landfill, unless determined to be
non-hazardous.
Fort Wayne Reduction. IN [08/26/88] [F
Excavation of the western portion of the
site for removal of 4.600 buried intact
j> drums and incineration of the drum
K) contents onsite or offsite;
reconsolidation of excavated soils and
wastes onsite followed by hybrid closure
consisting of a compacted, continuous
soil cover.
$10.020.000
Present Worth
RD: (SCAP): 91/3 Not
RA: (SCAP): 91/4 Stated
14.2 ppm
10 ppm ' 230.000 Incineration selected for drum
gallons contents; incineration not
selected for contaminated soil
due to high cost:;
LaSalle Electrica' Utilities. IL [08/29/86] [F ]
Excavation and incineration of
contaminated soil and clean fill
excavated areas; decontamination of
onsite structures.
$26.400.000
Present Worth
RD: (SCAP): 87/4 1248
RA: (SCAP): 90/1 1254
5,800 ppm
5 ppm
25.530
cubic yards
Incineration selected.
LaSalle Electrical Utilities. II [03/30/88] (F ]
Excavation and mobile onsite incineration $34,495.180
of PCB contaminated soils and stream Present Worth
RD: (SCAP): 89/2 1248
RA: (SCAP): 93/2 1254
17.000 ppm
5 ppm
(r,nr face)
23.500 .
CiiliiC y,)r
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONIAMINANI OF CONCERN
* SITE NAME, STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
sediments with subsequent ash analysis to
determine final disposal location; high
pressure flushing and mechanical cleaning
of sewer lines, and collection and
treatment (to be detailed during design.
but will include phase separation,
filtration, and air stripping) of ground
water containing PCBs at concentrations
above I ppb.
RD/RA COMPLETION
DATFS
AROCHLORS
PRE-TREAIMINI
CONCFN1RAIION
FXCAVATION
ItVELS
10 ppm
(subsoiIs)
ESTIMATED
VOLUME
RATIONAU. WHY 1NCINERAIION
WAS NOJ Ml ECTED
I.askln/Poplar Oil. OH [08/09/84] [F ]
Excavation and ofsite incineration of $1,043,000
PCB contaminated waste water and oils. Total Cost
RO: (SCAP): 86/2 Not
RA: (SCAP): 92/4 Stated
500 ppm
Not
Stated
250.000
gal Ions
Incineration selected.
Laskln/Poplar Oil. OH [09/30/87] [F ]
Excavation and incineration of oils,
sludges and highly contaminated soils and
offslte disposal of ash residuals.
"
$4.377,500
Present Worth
RD: (SCAP): 89/3
RA: (SCAP): 92/?
1221
1242
1254
1260
144 ppm
6 [>pm
71,100
cubic yards
Incinerat ion so lot li'il.
Laskin/Poplar Oil. OH (06/29/89) [S
thermal destruction of contaminated
$11.000.000
RD." (SCAP): 91/2
Not
Not
Not
j.OOO
IMC Mini .il ion
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAHO BIPHENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF iHE SELECTED REMEDY
soils, ash and djbrls with onslte
disposal of ash if delisted or offsite
disposal at a RC3A hazardous waste
landfill; demolition and thermal
destruction or decontamination of dioxin
contaminated structures, if these
structures cannot be decontaminated then
contain in a concrete vault onsite and
cap for temporary storage; drain
> retention and freshwater ponds with
-> discharge to surface water and treatment
as necessary; construct a multi-layer cap
over soils exceeding performance levels;
dewater site by natural ground water flow
to surface water; ground and surface
water monitoring and land use
restrictions.
RO/RA COMPLETION AROCHLORS PR[-TREAIM[NT EXCAVATION ESTIMATED
OAIES CONCENTRATION LEVELS VOLUME
RATIONALE WHY INCINERATION
WAS NOT SrifCTEO
Capital Cost
RA: (SCAP): 92/4 Stated Stated
Stated
cubic yards
Liquid Disposal. HI [09/30/87] [S ]
Excavation and onslte disposal of debris
with jo'lidifIcation/fIxatlon of soil and
waste; extraction of ground water onsite
and treatment using air strippers or ion
exchange with discharge to surface water;
construction of a slurry wall and cap.
$21.743,100 RD: (SCAP): 90/2 Not Not
Capital Cost RA: (SCAP): 92/4 Slated Stated
Not 136,6SO the level of treatment
Stated cubic yards afforded by incineration,
while desirable. p,n t icularly
(or PCBs. is not
cost -nf (pel ive loi Hie 11)1
Si le tout ami n.int •.,
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAIED BIPIIENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE (ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
•PRE-TREAlMfN!
CONCENIRAIION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOT SI IfCTED
Mia,ni County Incinerator. OH [06/30/89]
Excavation and consolidation of ash
wastes and contaminated soils with
disposal In north or south landfill and
capping vapor extraction and treatment of
exhaust; extraction and treatment
(unspecified) of ground water with
discharge to POTW; pretreatment of ground
water (unspecified) If necessary;
alternate water supply.
[F ]
$1.700,000-
$3.500.000
Present Worth
RO: (SCAP): 93/1 Not Not
RA: (SCAP): 92/2 Stated Stated
Background ?2.000 Incineration would cost six to
Levels cubic yards seven times as much as the
selected remedy (vapor
extraction) without providing
a proportionate benefit.
Incineration would leave a
residue which would need to be
disposed of onsite or taken to
an appropriate latitld 11
offsi te.
Mldco I. IN [06/30/89] [RP]
Excavation and onsite treatment of I?.400
cubic yards of contaminated soil and
waste and 1,200 cubic yards of
contaminated sedi-nenta by a combination
of /apor extraction and
solidification/stabilization followed by
onsite disposal; Installation and
opeiation of a ground water pumping
system to intercept contaminated ground
water followed by reinjection into a deep
well; installation of RCRA cap.
$9.094,000
Capital Cost
RD: (SCAP): 91/1 1242
RA: (SCAP): 93/1 1254
1248
44 ppm
Not 12,400 cy Incineration is moie expensive
Stated (soil) than the selected alternative
1,200 cy and does little to further
(seds) reduce risk .it the site.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RD/RA COMPLETION
DATES
AROCIILORS
PRE-TREATMENT
CONCCN1RAIION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOI siiir.iro
Hideo II, IN [06/30/89] [RPJ
Excavation and onslte treatment of 35,000
cubic yards of contaminated sot) and
waste, and 500 cubic yards of sediments
by solidification/stabilization followed
by onslte disposal of the solidified
waste; installation and operation of a
pumping system tc intercept contaminated
ground water followed by discharge to a
deep injection wc-ll; Installation of RCRA
cap.
$11,755,400 RD: (SCAP): 91/1 Not
Capital Cost RA: (SCAP): 93/4 Stated
< bO ppm
.Not 35,000 cy Incineration is mote expensive
Stated (soil) than the selected alternative
500 cy and does little to lurttier
(seds) reduce risk at the site.
New Brighton/Arden Hills (TCAAP), HN [08/11/89]
The (08/11/89) ROD amends the (06/30/86)
ROD by revoking the decision to construct
the new municipal well 113.
[PR]
RD: 90/4
RA: 91/2
Ninth Avenue Dump, IN [09/20/88] [I ] •
Containment of the oil layer by
constructing a soi1-bentonite slurry wall
extending into the clay layer 30 feet
$1,960.000
Capital Cost
RO: (SCAP): 90/3
RA: (SCAP): 92/1
1248
1254
1260
I.500 ppm
Not 250,000- lncuier.il ion not srli'i.lnl
Staled /OO.UOO because thf;i>il l.iyi-i i:.
(Jill Ions t(inl.i:niiHt(:il wilh i him in.ilcd
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAI ADDRESS POLYCHI.OR1NATED BIPHENYIS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
below the surface; extraction of oil and
ground water within the containment area
with treatment of ground water using
oil/water separator and discharge into a
ground water recnarge system; temporary
onsite storage of contaminated oil in a
secondary contai iment structure meeting
RCRA and TSCA tank storage requirements.
RD/RA COMPLETION
DAIES
AROCHLORS
PRE-TREATMENT
CONCCNIRAIION
EXCAVATION
IEVFLS
FSTIHATED
VOLUME
RATIONALE WHY INCINERATION
UAS NQI MI.ICIED
dibenzo-dioxins ai well as
PCBs and it may IIP difficult
to find a comnercial
incinerator will ing to accept
dioxin contaminated waste, and
a mobile incinerator may not
be cost-ef(net ivn
Ninth Avenue Dump. IN [06/30/89] [F ]
Excavation of oil contaminated waste,
fill, debris, and sediments from on- and
offsite surface water followed by onsite
thermal destruction in a mobile
incinerator; extraction, treatment
(unspecified) and reinjection of
contaminated ground water inside slurry
wall to promote soil flushing; discharge
of a small quantity of ground water
outside slurry wall to compensate for
Infiltration; capping.
'
$?2,209.000 RD: (SCAP): 91/3 Not Not
Present Worth RA: (SCAP): 93/4 Stated Stated
Not
Stated
36.000
cubic yards
Incinerat ion soln:ted.
Outboard Mjrine/Johnson, IL [05/15/84] [F )
Dredge, dewater and fixate the four $13.890.000
contaminated "hot spots" containing PCB Capital Cost
RD: (SCAP): 85/3 Not
RA: (SCAP): 91/4 Stated
155.000 ppm 50 p|>m ???,<100 hind IM I annum ir-iM In w.nve
ciilnc y.inls .i|i|)l i call 111 l-iw. |m mcr.it mil
-------
SUMMARY REPORT OF FY8Z THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLOR1NAIED BIPHENYIS
AS A CONTAMINAN1 OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DAIES
AROCHLORS
PRE-TREATHENT
CONCENIRA1ION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
contaminated soil and sediments with
offsitfi disposal. Total amount of PCBs
is estimated to be 771,200 pounds.
RATIONALE WHY INCINERATION
WAS N0.1 SIIECIED
not retained as A viable
alternative Ihromjh
preliminary screening.
Outboard Marine/Johnson. Ml [03/31/89]
Amendment: Construction of three
containment cells to hold contaminated
soil and sediment; excavation of
PCB-contaminated sediment and soil with
onsite thermal or chemical extraction.
(or an effective alternative treatment)
with offsite disposal of extracted PCBs;
placement of treated sediment and soil in
lined and capped containment cells;
treatment of dredge water by sand
filtration and carbon adsorption with
discharge to either an offsite sanitary
sewer or onsite.
[r ]
$19,000,000
Present Worth
RD: (SCAP): 90/2 Not
RA: (SCAP): 91/4 Stated
710,000 ppm > SOO ppm Not Ihere are no PCB extraction or
(sediment) Stated soil treatment technologies
> 10,000 ppm specified in this ROD. There
(Soil) is no rationale documented in
the ROD concerning which
treatment technolnqy will be
selected.
Rose Township Dump. Ml (09/30/87) [S ]
Excavation of contaminated soil with
ensile incineration and onsite or offsite
residual ash disposal; extraction and
treatment of contaminated ground water
using chemical cc.iqulat ion. air
J32.547.000 RD: (SCAP): 90/3 Not
Capital Cost HA: (SCAP): 9?/3 Staled
980 ppm
10 ppm
sn.oon
culnc yards
i\r. inor.ll inn -."'I IM I cil
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME, STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
stripping, and activated carbon
adsorption with onsite discharge of
treated water; O&M.
COSTS
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENIRA1ION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOJ SfLlClEO
Schmalz.Dutnp. V! [08/13/85] [F ]
Excavation and offsite disposal or
offslte incineration and offsite residual
ash disposal of contaminated building
debris.
$2.088,300 RD: (SCAP): 8//4 Not
Capital Cost RA: (SCAP): 89/1 Stated
3,100 ppm Not 3,500 Incineration is an option lor
Stated cubic yards PCB-contaminated debris
removed from the site.
Suroilt National liquid Disposal. OH [06/30/88] [F ]
Excavation and onsite mobile Incineration $25,000,000
of PCB contaminated soil, sediment, and Present Worth
debris, Including tank contents with
disposal of incinerated residual In an
onsite RCRA landfill; pre-burn tests will
be required to demonstrate the type of
thermal /destruction to be employed at the
site/'
RD: (SCAP): 90/2 Not Not
RA: (SCAP): 95/3 Stated Stated
Not
Stated
32,000
cubic yards
88.000
gal Ions
Incineration selected.
Ved;eb, IN [06/30/89] [F ]
Flushing and decontamination of sewer
$24,500
Rl): .(SCAP): 91/2
Not
3/0 ppm
10
Not
Inn I nerat ion lor I'l II
-------
SUMMARY REPORT Of FY82 THROUGH FY89
RECORDS or DECISION THAT ADDRESS POLYCHI.ORINATED BIPHENYLS
AS A CONTAMINANT Of CONCERN
OJ
O
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
lines; filtration of sewer water to
retnove PCB contaminated sediments;
monitoring of the water and refilterlng,
If necessary with discharge to a POTW;
analyze two barrels of sediment and 20
barrels of RI generated waste; > 50 ppm
PCB levels will ^e treated by offsite
Incineration and levels < 50 ppm PCB will
be disposed offsite at a EPA approved
site.
Present Worth
RD/RA COMPLETION
DATES
RA: (SCAP): 93/3
AROCHLORS
PRE-TREATMCNT
CONCEN1RA110N
EXCAVATION
UVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERATION
WAS NOI Sfl.CCIED
Slated
(seds)
Stated
concentrations above 50 ppm,
offsite TSCA land disposal for
concentrations below SO ppm.
'**• Subtotal **
24
'* REGION 06
French Limited, TX [03/24/88] [F )
In-sltu blodegradatfon of sludges and
contaminated soils using indigenous
bacteria with aeration of the lagoon
waste to enhance the degradation process;
residues from the treatment process will
be stabilized and disposed onslte.
$47.000,000
Present Worth
RO: (SCAP): 90/1 Not
RA: (SCAP): 95/2 Stated
616 ppm
23 ppm 149,000 Incineration is more expensive
cubic yards than the selected alternative
and does I it tin to further
reduce risk at tlip site.
Geneva Industries. IX [09/18/86] [S ]
Offsite disposal of surface structures to
Jl 4.992.000
RD: (SCAP): H8/I
Not
I,750 ppm
100 ppm
I IIP spirited rciiii'ily oiler:, the
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATEO BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATEJ [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
hazardous waste landfill; excavation of
soils with > 100 ppro PCBs and drums with
offslte disposal to an EPA-approved
facility; construction of a multi-layer
clay cap and slurry wall; extraction and
treatment of ground water using carbon
adsorption with discharge to adjacent
flood control channel.
Capital Cost
RD/RA COMPLETION
DAIES
RA: (SCAP): 91/3
AROCHLORS
PRE-TREATMfNT
CONCENTRATION
EXCAVATION
UVELS
Stated
ESTIMATED
VOLUME
cubic yards
RATIONALE WHY INCINERATION
WAS NOT SlILCIED
same level of prelection for
public health and the
environment. Since onsite
incineration was found to
generally cost more than
offsite remedies, offsite
disposal has been selected as
the remedy for this site.
Gurley Pit, AR [10/06/86] [FE]
Construction of an onsite pond water
treatment unit with discharge to Bayou;
removal of contaminated solids from pond
water and dispose with pit sludge;
removal of oil from pond water using
oU/water separator with treatment using
PCB-approved incinerator; extraction and
stabilization of ?it sludge with pond
solids with onsit.2 disposal; excavation
of soil and sediments with onsite
disposal with stabllized material; cap
stabilized wastes; O&M.
$5.780.000 RD: (SCAP): 88/4 Not
Capital Cost RA: (SCAP): 91/2 Stated
20 ppm
Not 17 cy The large increase in cost for
Stated (oil), incineration (or a small gain
15.984 cy in containment weighted
(sludge) against incineration of sludge
waste. In'addition, a large
quantity of waste would have
to be transported to an
incinerator. Ihis would
increase the dangpr of
exposure of the public through
accidental spills. Offsite
incineration was r.i-lected for
the smal I qu.int i t y of
PCB-contamitMti'd oil removed
from thr pomlcd w.ili-i .
-------
SUMMARY REPORT OF FY82 THROUGH FY89
R[CORDS OF DECISION THAT ADDRESS POLYCHLORINA1EO BIPHENYLS
AS A CON1AMINAN1 OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED RATIONALE WHY INCINERATION
VOLUME WAS NOT SflECTED
Hardage/Criner, OK [11/14/86] [FE]
Extraction of surface and ground water
with separation of NAPL followed by
offslte Incineration of organic liquids
with offsite disrosal of ash residuals.
or onsite Incineration with onsite
disposal of solid ash residuals, and
either recycle or treat (unspecified)
residual liquids followed by offslte
discharge; onsite treatment of soils and
debris by one or more of the following:
chemical neutralization, solidification,
dewaterlng, chemical oxidation/reduction,
air stripping; totory-klln Incineration
bench-scale test to be conducted for
moisture content and reactions of
soil/fluid combinations and if
successful, conduct pilot study and
emissions testing.
$68.000.000
Present Worth
RO: currently
negot iating wi th
PRP. (SCAP): 89/1;
RA: (SCAP):
assuming RP
judgement 92/4
1260
50 ppm
Not 175.000 Determine soil treatment
Stated cubic yards remedy during remedial design.
MOTCO. TX [03/15/85] [F ]
Excavation and offsite incineration of $42,300.000
PCS liquid organics at a permitted 1SCA Capital Cost
facility; excovalion and offsite disposal
RD: (SCAP): 86/4 Not
RA: (SCAP): 94/1 Stated
100 ppm
Not
Stated
18.000
cul) 16 yards
I nc I norflt MIII
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYI.S
AS A CON1AMINANI OF CONCfRN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF 1HE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENIRAIION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
of PCB-contaminated tars and sludges at a
RCRA landfill; extraction of pit water
and treatment at an industrial waste
water treatment plant.
RATIONALE WHY INCINERATION
WAS NW SUEC1ED
Sheridan Disposal Services. TX [12/29/88] [RP]
Excavation and onslte blotreatment of all $28,346,000
sludges, debris, floating oil and
emulsion, and soilr containing > 25 ppm
of PCBs; residuals, reduced to < 50 ppm
PCBs, will be stabilized onsite. returned
to the pond and capped; if the residuals
are > 50 ppm PCBs, the pond will be a
RCRA compl lant landfill; decontamination
and disposal of all onslte tanks and
processing equipment with onslte
treatment (unspecified) or offsite
disposal depending on contents; treatment
of storm and waste water streams to
remove solids, metaJ and organlcs with
discharge to surface water; Institutional
controls.
Capital Cost
RO: (SCAP): 91/1 Not
RA: (SC.'P): Not Stated
Avallable
223 ppm
25 ppm 44,000 Bioremediation significantly
cubic yards reduces mobility, loxicity and
volume and essentially
eliminates the source of
contamination to the ground
water. Incineration is
mechanically complex, using
highly specialized costly
equipment and operators and
would have required approved
offsite disposal ol ash.
Sol Lynn/Industrial Transformers, TX [03/25/88] [F ]
t'xcavation and treatment of contaminated J?,200,000
RO: (SCAP): 90/4 Not
350 ppm
25
2,400
Inc. iiipral inn mil ••<• Irrtril
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION JHAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONIAMINANI OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
soil with an alkai: metal polyethylene
glycolate (APEG) reagent In a batch
reactor; pretreatment. If necessary, and
discharge o* liquid by-products of
treatment to a POTW; APEG feasibility
testing will be conducted during the
design phase.
Present Worth
RD/RA COMPLETION
DAIfS
RA :(SCAP): 93/2
AROCHLORS PRE-TREATMENI EXCAVATION ESTIMATED
CONCENIRAIION IEV[LS VOlUMr
Stated
cubic yards
RATIONALE WHY INCINERATION
WAS NQT SflfCIED
because it is not
cost-effective and no
additional protection would be
provided by this treatment.
Subtotal '*
'REGION 07
Ooepke Disposal Hoi 1(day. KS [09/21/89]
Removal and offsite treatment of
contaminated liquids ponded under former
turface impoundments; construction of an
impermeable multi-layer cap over majority
of waste area, including soils
contaminated with PCBs; deed and access
restrictions; and ground water
moni toring.
'
[RP]
$5,970,000
Present Worth
RD: 91/1
RA: 93/3
1218
1254
1260
.07-.393 pom
Not
Stated
Not Due to the magnitude of waste
Stated and low PCS concentrations
further studies will be
performed to ful ly
characterise soiIs.
Incineration not considered as
alternative for tliii operable
uni t.
Subtotal "
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINAIEO BIPHENYLS
AS A CONIAMINAN1 OF CONCERN
SUE NAME. STATE [ROD SIGN DATE] [LEAD]
COHPONENIS OF THE SELECTED REMEDY
COS IS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-IREAIMENT
CONCENIRAIION
EXCAVATION
LLVELS
ESTIMATED
VOLUME
RATIONALE WHY INC1NERATIQM
WAS HOT SI I EC HO
REGION 09
Lorentz Barrel & Drum, CA [09/28/88]
Extraction of PCB contaminated ground
water and onslte treatment using a
packaged ozone-UV system with discharge
of treated effluent onsite to a storm
sewer.
[FE]
$3.238.000
Present Worth
RO: (SCAP): 90/1
RA: (SCAP): 91/4
1221
6.4 ppm
1254
1260
0.065 ppb Not Incineration was not discussed
Stated as a treatment alternative in
the ROD.
MGM Brakes. CA [09/29/88] [FE]
Excavation of PCB-contamlnated soil with
offsite disposal of soil; extraction and
treatment of wastewater from dewaterlng
process in a mobile treatment system
(unspecified) and discharge of treated
water either onslte or to a POTW; soil
containing > 50 ppm PCBs will be
transported to a Class I TSCA-pennitted
disposal facility; soil containing 10-50
ppm PCBs will be transported to a Class
II tA DOHS-permllted facility: de«nolition
of processing building, crushing of the
concrete slab and excavation of the
underlying soil contaminated with > 10
ppm PCBs followed by transportation and
offsite disposal of the contaminated
concrete In an appropriate disposal
$5,369.300
Present Worth
RO: (SCAP): 90/4 Not
RA: (SCAP): 91/4 Stated
4,500 ppm
10 ppm 13.510 Incineration was not selected
cubic yards because of'community
opposition and limited
availability of incinerators.
-------
SUMMARY REPORT OF FY8? 1HROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME. STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
COSTS
RD/RA COMPLETION
DATES
AROCHLORS
PRE-IRCAIHfNT
CONCENIRA1ION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
facility.
Subtotal
REGION 10
RATIONALE WHY INCINERA110
WAS NOI SELECTED
OJ
a\
Commencement Bay-Near Shore/Tide Flats. WA
Source remediation involving control of
effluent sources; PCB-conlaminated
sediment remedial ion includes natural
attenuation and utilization, as
appropriate, of t'c'ir alternatives
including in-situ capping, confined
aquatic disposal, confined nearshore
disposal, and removal and upland disposal
onshore; site use restrictions; and
sediment monitoring.
[09/30/89]
J3?.300,000
Total Cost
[RP]
RD: 93/4
RA: 94/4
Not
Stated
Not
Stated
1.500 ppm 1,181,000 Most problem areas are
sediment cubic yards characterized by significant
metals contamination, which is
not mitigated by incineration.
Additionally, marine sediments
were found to havi: very low
BIU content. making
incineration extremely energy
intensive and less cost
effective considering the
volume of contaminated
material.
Commencement Bay/NTF, WA [1Z/30/87]
Excavation and stabilization of PCB
contaminated soils; extraction and
stabilization of ponded water and
sediments with onsite disposal of
$3.400.000
Present Worth
RD: (SCAP): 91/1 Not
RA: (SCAP): 9?/l Stated
?04 ppm
I ppm
(soil)
? ppb
(ponded
4S.OOO Incineration mil M-lri.lc'd ,ir,
cubic yards vialili; al tor n.it i vi- Ihinucjh H
preliminary IIMT. iln 1 1 y study
due In hiqh cost
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POLYCHLORINATED BIPHENYLS
AS A CONTAMINANT OF CONCERN
SITE NAME, STATE [ROD SIGN DATE] [LEAD]
COMPONENTS OF THE SELECTED REMEDY
treatment residu.ils and asphalt capping
of the entire stibilized matrix.
COSTS
RD/RA COMPLETION
DAKS
AROCHLORS
PRE-TREAFMENT
CONCENTRATION
EXCAVATION
LEVELS
ESTIMATED
VOLUME
water)
RATIONALE WHY INCINERATION
WAS NOT SELEC1ED
Northwest Transformer. WA [09/15/89] (F ]
Excavation, consolidation and treatment $771,000
of soils with PCB concentrations >IOppm Total Cost
using in-situ vitrification; well
abandonment; construction of soil cover;
and ground water monitoring.
RD: 91/4
RA: 93/2
1260
I -10 ppm
10 ppm 1,200 Ihe best thermal destruction
cubic yards process for this site was
determined to be vitrification
based on ease of mobilisation,
lower cost, lack of residuals
management and local
acceptance of treatment
process.
Pacific Hide & Fur Recycling. ID [06/28/88] [RP]
Excavation of contaminated soil with
solidification of soils; installation of
soil cover over solidified soils with
either on- or offslte disposal; onslte
containment of contaminated soils if
solidification found to be not viable
through a pilot study; decontamination of
debris with either on- or offsite
disposal.
Jl,890.000
Present Worth
RD: (SCAP): 89/4 Not Not
RA: (SCAP): 91/4 Stated Stated
25 ppm
(restricted)
10 ppm
(non-
restricted)
8,200 Incineration not selected as a
cubic yards viable alternative through
preliminary screening due to
difficulty of im|ilrmentat ion.
-------
SUMMARY REPORT OF FY82 THROUGH FY89
RECORDS OF DECISION THAT ADDRESS POIYCHLORINAIEO 8IPIIFNYLS
AS A CONTAMINANT OF CONCERN
SITE NAHE. STATE [ROD SIGN DATE] [LEAD] COSTS
COMPONENTS OF THE SELECTED REMEDY
RO/RA COMPLETION
DATES
AROCHLORS
PRE-TREATMENT
CONCENTRAMON
EXCAVATION
LEVELS
ESTIMATED
VOLUME
RATIONALE WHY INCINERA1I
WAS NOT SELECTED
Queen City Farms, WA [10/24/85] [FE]
Phase separation of sludge with
solidification and liquid stabilization.
Offslte disposal of contaminated soil.
U)
oo
$3.439,000
Total Cost
RD: (SCAP): 8//1
"RA: (SCAP): 87/1
1?60
l?5 ppm
Not 5,200 Incineration not selected due
Stated cubic yards to cost, limited incinerator
capacity and difficulty in
transportat ion.
Western Processing/Phase II, WA [09/25/85] [F ]
Conduct bench-scale tests using in-situ $18.100,000
solidification/stabilization; if Present Worth
successful, conduct pilot studies.
RO: (SCAP): 88/4 Not
RA: (SCAP): 89/2 Stated
1.128 ppm
? ppm*
(Offsite)
50 ppm
(Onsite)
10,650 Incineration not retained as <
cubic yards viable alternative through
preliminary screening.
*' Subtotal "
6
Total
81
Tpt'i
* * *
-------
APPENDIX B
DIRECT CONTACT RISK CALCULATION
-------
Risk Calculations for an Individual Contacting PCB Contaminated
Soil
Risk are calculated below for an individual in contact with PCB
contaminated soil at three concentrations, 0.1 ppm, 1 ppm, and 10
ppm. The pathways considered are soil ingestion, dermal contact
and inhalation of volatilized PCBs .
Soil Ingestion Scenario
Some of the PCB in the soil is going to volatilize throughout the
years. Therefore, if a more in-depth assessment is required, the
volatilization of PCB needs to be accounted for. The equations
used to account for the volatilization of PCBs from the soil over
certain period of time are derived in Appendix A of the EPA
document titled Development of Advisory Levels for Polychlorinated
Biphenyls (PCBs) Cleanup (U.S. EPA, 1986a) .
Assumptions
Exposure Factor Value Reference or Comment
Child Ingestion
rate (mg/day) 200 U.S. EPA, 1989f
Adult Ingestion
rate (mg/day) 100 U.S. EPA, 1989f
Exposure Duration
for a child (yrs) 6 U.S. EPA, 1989f
Exposure Duration
for an aduld (yrs) 24 (30 - 6)
Exposure Frequency
(days/yr) 365 U.S. EPA, 1989f
Body weight
child (kg) 16 U.S. EPA, 1989f
Body weight
adult (fcgt 70 U.S. EPA, 1989f
Absorption fraction 30% U.S. EPA 1986a
Exposure = C x IR x EF x ED
BW x AT
-------
where,
C = concentration of PCB in so.il
IR = intake rate
ED = exposure duration
EF = exposure frequency
BW = body weight
AT = averaging time (70 yrs for a carcinogen)
To estimate exposure, the average concentration of PCBs in soil
over the exposure period is calculated. The concentration of PCBs
will decrease with time due to volatilization. This concentration
is estimated using the equation A-35 from the 1986 PCB cleanup
guidance for an uncovered surface.
C = C 1_ erf _z dz
S S0 z 2 t
where,
C = average concentration of PCB in soil (ppm)
S
C__ = initial concentration of PCB in soil (ppm)
SO
z = depth of contamination (cm)
= constant defined by D . x E
[E + Ps x (1 - E) x Kd/H]
t = exposure time divided by 4 (sec)
De^ = effective diffusivity (cm /s) = D^ x E '
D^ = molecular diffusivity (cm /s)
E = pore porosity (unitless)
P = bulk density of soil (g/cm )
K^ = soil/water partition coefficient (mg/g soil)/(mg/cm water)
H = Henry's Law Constant (atm-m /gmol)
-------
Example calculation for the following set of assumptions:
Cso = 1 ppm
= 25.4 cm (10 inches)
=0.05 cm2/s
E =
Ps =
Kd =
H
t
c« = _
0.35
2 . 65 g/cm3
1000 (mg/g soil)/(mg/cm water)
8.37 x 10"3 (atm-m3/gmol)
6 yrs/4 = 1.89 x 108 sec/4 = 4.73 x 107 sec
1 erf z dz
25.4 21.53
This equation is solved by assuming different values of z and
evaluating the error function using the table attached. Then the
integral is evaluated numerically using the Trapezoidal Rule.
z (cm) _ erf (x)
0 0
5 0.2550
10 0.4847
15 0.6778
20 0.8116
25 0.9103
Using the Trapezoidal Rule:
C_ =f25.4 - 0) [0 + 2(. 02550) + 2(0.4847) + 2(0.6778) + 2(0.8116)
(25.4)(2)(5)
+ 0.9103]
Cg = 0.54 ppm
The same procedure is used to determine the average concentration
for a period of 30 yrs which yields a concentration of 0.28 ppm
for the adult exposure.
-------
Example calculation for soil ingestion by a child at an initial
concentration of 1.o ppm
Exposure = 0.54 mq x 200 ma x 365 days x 6 vrs x 1 x 1
kg day yr 16 kg 70 yrs
vr
10~6 kg
365 days mg
= 5.8 x 10~7 mg/kg-day
Similarly, the adult exposure is estimated.
Exposure = 0.28 ma x 100 ma x 365 days x 24 yrs x 1 x 1
kg day yr 70 kg 70 yrs
vr
10"6 kg
365 days
mg
-7
= 1.4 x 10 mg/kg-day
The total exposure is calculated by adding the child and the adult
exposure.
Total exposure = 7.2 x 10~ mg/kg-day
Cancer risk is then calculated using a cancer potency factor for
PCBs of 7.7 (mg/kg-day) and multiplying by an absorption factor
of 30%. The table below summarizes the total exposure and risk
from soil ingestion (child + adult) for the three concentration
values.
Soil Concentration
Total Exposure
(mg/kg-day)
Risk
0.1
1.0
10
Dermal Contact. Scenario
x 10
x 10
7.2
7.2
7.2 X 10
-8
-7
-6
2
2
2
10
10
10
-7
-6
-5
[B2]
[B2]
[B2]
As in the »oil ingestion scenario, the concentration of PCB in the
soil is needs to be averaged over the period of exposure to account
for the volatilization of PCBs. Exposure is estimated for both a
child and an adult. A child ages 3-18 years old wearing shorts
and short sleeve shirt is assumed to be exposed 3 times/week during
the spring and fall and 5 times/week during the summer months. The
adult is assumed to be wearing long pants and short sleeve shirt
while gardening 1 day/wk during spring, fall and summer.
-------
Exposure Factor
Surface area
arms, hands and legs
(average 3 -18 yrs)
(m /event)
Surface area
arms and hands
(adult) m2
Soil to skin
adherence factor
(mg/cm2)
Exposure frequency
(child) (events/yr)
Exposure frequency
(adult), (events/yr)
Exposure duration
(child) (yr)
Exposure duration
(adult) (yr)
Body weight (child) (.kg)
Body weight (adult) (kg)
Absorption fraction
Assumptions
Value
0.40
0.31
2.77
132
52
15
12
38
70
10%
Reference
U.S. EPA, 1989f
U.S. EPA, 1989f
U.S. EPA, 1989f
U.S. EPA, 1989f
judgement
(18 - 3)
(30 - 18)
U.S. EPA 1989c
U.S. EPA 1989C
U.S. EPA 1988a
Exposure = C x SA x AF x EF x ED
BW x AT
where,
SA = surface area (cm /event)
AF = soil - skin adherence factor
The absorption fraction is based on a study the was conducted by
Versar/Mobil to measure the dermal bioavailability of dioxin (TCDD)
and trichlorobiphenyl (TCB) sorbed to soil. Results of this study
will be incorporated into a draft report titled Dermal Absorption
of Dioxins and PCBs from Soil (U.S. EPA, 1988a) which is being
revised by Versar for the Office of Toxic Substances. In vitro
dermal absorption through human skin resulted in 8% absorption for
TCB in low organic content soil (0.77% organic matter) and 10% in
high organic content soil (19.35%). It is important to understand
-------
the uncertainties associated with these values. These are based
on only one experiment and the TCB content, in the soil was 1000
ppro.
To estimate the exposure through the dermal route, the average
concentration of PCBs in the soil needs to be estimated and
volatilization of PCBs accounted for using the same procedure
described in the soil ingestion scenario. The average
concentration of PCB in the soil after a period of 15 yrs is 0.38
ppm which is used for the child scenario and 0.28 after 30 yrs
which is used for the adult scenario.
Dermal exposure is estimated for a child exposed to soil with an
initial concentration of 1 ppra of PCBs.
2
Exposure = 0.38 ma x .40 m x 132 events x 2.77 ma x 15 yrs
X
kg
1
x
event
1
x
yr
vr x
10
-6
en
kq
X
104
cm2
38 kg 70 yrs 365 days mg m
= 8.6 x 10~6 mg/kg-day
In this case, as in the adult calculation event = day. The
exposure for an adult is estimated below.
Exposure = 0.28 mg x 0.31 m x 2.77 mcr x 52 events
kg event cm^ yr
x 12 vrs x 1 x 1 x yr 10 kg x 104 cm
70 yrs 70 kg 365 day mg m
= 8.4 x 10 mg/kg-day
Then risk is estimated by multiplying the total exposure (child +
adult) times the cancer potency factor for PCB and multiplying by
the absorption factor of 10%. The table below summarizes exposure
and risk for the three soil concentrations.
Soil Concentration Total Exposure Risk
(ppm) (mg/kg-day)
0.1 9.4 x 10~7 7 x 10~7 [B2]
1.0 9.4 X 10"^ 7 x 10~J? [B2]
10 9.4 X 10~4 7 x 10~5 [B2]
Vapor Inhalation Scenario
Exposure to volatilized PCB is estimated for an individual standing
on site. If risk estimates exceed the cleanup value range of
' 10 - 10 , then off-site air concentrations need to be estimated
using dispersion models. In order to use dispersion models, site
-------
specific data such as meteorological data are necessary. On site
air concentrations are estimated by using a "box model" described
in the 1986 PCB guidance document (U.S. EPA," 1986a) .
C =
Ls X V X H
where,
Q = flux rate (g/sec) Q = Emission rate x Area
Ls = width dimension of contaminated area (m)
V = average wind speed at mixing height (m/s)
H = mixing height (m)
At the mixing height the V = 0.5 x wind speed. A wind speed of 10
mph (4.5 m/s) which is the average in the United states is used.
The flux rate is estimated using the model described in the 1986
PCB guidance document (U.S. EPA, 1986a). It is assumed that the
contaminated soil is uncovered and the depth of contamination is
25 cm.
Emission rates are tabulated below.
Soil Concentration (ppm)
0.1
1.0
10
Emission rates (g/cm -s)
9.9 x 10
9.9 X 10
9.9 X 10
-15
-14
-13
To estimate the concentration in air, a mixing height of 2 m and
a width Ls of 45 m are assumed. These are the values assumed in
the 1986 PCb guidance document (U.S. EPA, 1986a) . Air
concentrations are tabulated below.
Soil Concentration (ppm)
0.1
1.0
10
Air Concentration (g/m )
9.9 X 10
9.9 X 10
9.9 X 10
-10
-9
-8
Inhalation exposure is estimated for an adult using the assumptions
listed below.
Exposure Factor
Adult Inhalation
rate (m /day)
Exposure Duration
(yrs)
Assumptions
Value Reference
30
30
U.S. EPA, 1989f
U.S. EPA, 1989f
Body weight
-------
adult (kg) 70 U.S. EPA, 1989f
Absorption fraction 50% . U.S. EPA 1986a
Exposure = 9.9 x 10"10 g x 30 ro3 x 30 vrs x 1 x
nr day 70 kg 70 yrs
x 10 mq
= 1.8 x 10~7 rog/kg-day
Exposure and risks are tabulated below for the three concentration
values.
i
Soil Concentration (ppm) Exposure . Risk
(mg/kg-day)
0.1 1.7 X 10~J 7 x 10"^ [B2]
1.0 1.7 X 10'^ 7 X 10"^ [B2]
10 1.7 X 10~5 7 X 10~5 [B2]
8
-------
Uncertainties
Sources of uncertainty include measured values that may not
be accurate or representative, use of mathematical models which
may not reflect the physical or chemical process actually occurring
and assumptions on the selection of parameters in the models.
The analysis conducted used the physical and chemical
properties of Aroclor 1254 to estimate air emission rates because
this will yield the most conservative estimate. On the other hand,
the Agency derived a Cancer Potency Factor for Aroclor 1260, which
is the most toxic of the Aroclor, and uses it to be representative
of other PCB mixtures. However, emission rate results may not be
affected significantly since these two Aroclors have similar
physical and chemical properties.
Human behavior patterns can strongly affect exposure results.
Based on the limitations of our knowledge, the values for the
exposure duration and frequency for the pathways considered are
intended to be best reasonable upperbound estimates. For example,
the vapor inhalation scenario assumes that a person will be
breathing at a 30 m /day rate 24 hours/day for a period of 3O
years. It also assumes that the concentration indoors will be the
same as the concentration outdoors. These assumptions are
considered reasonable since it is possible to observe certain
subpopulations (i.e., housewife) spending the majority of their
time at their residence without air conditioning.
In the soil ingestion scenario, the exposure values obtained
do not account for children with pica behavior. Exposure estimates
that will reflect this type of behavior will be considerably
higher.
The rate of air emission through volatilization was calculated
using the model developed in the 1986 PCB guidance (U.S. EPA,
1986a). The model is based on theoretical mass-balance equations
to account for fundamental physical/chemical transport processes.
No empirical data are available to validate the model. Values of
the parameters that are input into the model are based on soil
characteristics such as E and Ps, physical laws such as D-, or
determined empirically such as K.. The latter is one of the major
sources of uncertainty. The Kd depends not only on the chemical
but also in the soil characteristics (i.e., organic carbon
content) . ' A Kg based on highly adsorbable soil was used which will
result in a higher emission rate than if a less adsorbable soil
such as sandy soils is used.
There are also uncertainties with the values used for
absorption factors. For example, the absorbtion factor of 10% used
in the dermal exposure scenario is based on very limited data.
This assumption was based on one study which used a concentration
of tetrachlorobiphenyl of 1000 ppm in the soil. It is likely that
the absolute dermal absorption at lower concentrations in the soil
will tend to be less.
-------
APPENDIX C
DETERMINING APPROPRIATE LONG-TERM MANAGEMENT CONTROLS
DETAILED CALCULATIONS FOR CASE STUDY
-------
Introduction
To illustrate the process of determining the appropriate
long-term management controls for low-threat PCB contamination
that will remain at a site, an example analysis is provided.
Several source concentrations are evaluated.
The evaluation presented in this Appendix concentrates on
ensuring that PCBs remaining will not adversely affect the quality
of the ground water. Where concentrations remaining on site are
higher than levels determined to be safe for direct contact,
measures to prevent or limit access to the contaminated areas
should be instituted. For concentrations within an order of
magnitude of the health-based level, a soil or cement cover with a
deed notice may be sufficient. Higher concentrations will require
fencing and management of the cover over time.
The process used in this assessment involved two primary
steps:
1. Evaluation of potential cap designs and their impact
on infiltration through the contaminated zone.
2. Evaluation of the migration of PCBs to and into the
ground water.
Once this was completed the concentrations of PCBs in the ground
water was compared to the drinking water standard, .5 ppb, to
identify the cap which prevented infiltration to the extent
necessary to prevent degradation of the ground water.
This first section of this appendix provides a description of
the site including the values of parameters necessary for the
evaluation of PCB migration. Next the cap designs considered are
presented with the description of the analysis of the infiltration
expected. Finally, the model which estimates PCB migration to
ground water is described and the resulting ground water
concentrations for the various scenarios considered is presented.
Description of Site and Variations
The description of the site focusses on the factors that
would affect the migration of PCBs and consequently indicate a
need for a different level of control. These include:
o Size of PCB source area — area and depth
o Concentration of PCBs
o PCB biodegradation rate
-------
o Depth to ground water and thickness of saturated zone of
interest
o Flow of ground water
o Rate of infiltration through the contaminated zone
o Soil porosity
o Organic carbon content of soil
o Bulk density of soil
The values of these factors used in the scenario evaluated in this
example are discussed below.
Size of Site The site evaluated in this analysis covers 5 acres
and the contamination is assumed to extend 10 feet vertically.
Concentration of PCBs PCB concentrations are assumed to be the
same throughout the contaminated zone. Concentrations of 5, 20,
50 and 100 ppm were evaluated to provide examples where long term
management controls short of the minimum technology requirements
under RCRA and the chemical waste landfill requirements under TSCA
can usually be justified. (As shown in Table 3-4, in the unusual
case where PCBs at concentrations exceeding 500 ppm are left on
site, minimum technology requirements are generally warranted.)
PCB Biodegradation Rate Since the model evaluates PCB migration
over very long time frames (up to 10,000 years) it seemed
appropriate to incorporate some estimate of PCB biodegradation.
Several studies have documented highly variable PCB biodegradation
rates (Quensen, 1988; Bedard, 1986; Brown, 1987). A half life of
50 years was assumed in this analysis.
Depth to Ground Water/Thickness of Saturated Zone The ground
water table is encountered at 20 feet below the surface. A
saturated thickness of 5 feet was assumed since this represents a
conservative minimum screened interval for a well.
Flow of Ground Water The ground water is flowing at 310 feet per
year. This is a typical flow for a sand and gravel aquifer and
would be sufficient to provide 150 gallons per day with a 60-foot
wide capture zone from a well screened over the first five feet.
This is the minimum amount of water assumed to be used by a family
of four. This reflects a very conservative scenario since few
wells are screened through a thickness of only 5 feet. In most
cases, wider intervals would be screend and greater dilution of
PCBs would occur.
Rate of Infiltration Through the Saturated Zone The infiltration
values used in this analysis were developed using the Hydrologic
-------
Evaluation of Landfill Performance (HELP); version II, computer
program (U.S. EPA, 1984). This program was used to estimate
runoff, evapotranspiration, and infiltration rates through the four
cap designs considered. Climatic conditions of the City of
Seattle, Washington, were used to model rainfall, temperature, and
other daily climatological data. Seattle was picked after
preliminary estimates showed that the combination of climatic
conditions in that city was one of the most extreme of all U.S.
climates and would therefore represent a conservative scenario. A
more detailed description of the use of the HELP model is presented
below.
Soil Porosity The porosity of the soil was assumed to be 25%
which corresponds to a mixed sand"and gravel (Fetter, 1980).
Organic Carbon Content of Soil The first 10 feet of soil was
assumed to have an organic content of 5%. The 10 feet below that
was assumed to have an organic content of .5%. The organic
content of the soil in the saturated zone was assumed to be .1%.
This is. a farely typical range.
Bulk Density of Soil A bulk density of 1.97 g/ml was used based
on the porosity of .25 and the density of quartz, 2.63 g/ml.
Cap Designs/Infiltration Evaluation
Four different cover systems were considered. These are
shown in Figure C-l. As indicated cover system 1 is simply a 12
inch soil cap, cover system 4 reflects the RCRA cover design
guidance (U.S. EPA, 1989d), and cover systems 2 and 3 reflect
intermediate cover systems. Given the fact that climatological
conditions are the same for all alternatives and that soil
properties do not change, the only variables are the number of
layers, their type, and their thicknesses. Brief descriptions of
the physical properties of each layer used in the design models
are presented below:
Vegetative soil layer This layer consists of sandy loam. The
permeability of this soil is approximately 1 X 10~^ cm/sec. This
permeability is considered moderate-to-high when compared to other
soils.
Sand drainage layer This layer consists of clean, coarse sand.
The permeability of this sand is approximately 1 X 10~2 cm/sec.
This sand is considered a highly permeable soil.
Synthetic drainage layer (geonet) This layer is typically made of
two high density polyethylene (HOPE) strands bonded together in a
crossing pattern. Geonets are called geocomposites when they are
sandwiched between two layers of geotextile fabric. Geonets and
geocomposites are typically characterized by their
transmissivities. The transmissivity of a layer equals the
-------
xxxxxxxxx
DESIGN 1
Figure C-1
Cap Design Details
3-5%
VXXXXXXXX
Vegetation
. 12" Soil Top Layer
Waste
-3-5%
DESIGN 2
, Vegetation
12"SoflTopLayer
24"ClaySoil--K=8.SxlO l2m/scc
Waste
'XXXXXXXX/
.3-5*
DESIGN 3
„— Vegetauon
24" Sofl Top Layer
"FML20mil1- K=lx 10" cm/sec
^t rivLu^umu — fv.=ixiu cm/sec
^Y&Yffi 12" Cover Soil- K=3.7xlO"*cm/sec
/•//x/xxxx
•3-5% -xxxxxxxxx
DESIGN 4
Vegetation
24" Soil Top Layer
12" Sand - K=lxlO"2 cm/sec
FML 20 mfl1-K=lxlOMcm/sec
24" Clay -- K=lxlO"7 cm/sec
12" Cover Soil-- K=3.7xlO'4crr7scc
Design I
(Minimum
Technology) I
12" Sand - K>= 1x10 cm/sec (Lc»fh«ie collection)
•~-FML302mil - K=lxlO' 'cm/sec (Liner)
- 12" Clay -lxlO~7cm/*ec (Uner)
12" Sand - K=lxlO cm/sec (Leak doeoion)
^FML SO^mil - K=lxlO" 'cm/tec (Liner)
-36" Clay •- K«=lxlO"7cm/«ec (Liner)
' OriginaJ Subgrade
* RCRA Minimum Technology Landfill bottom liner de«gn for remedial actioni reqoiring RCRA landfill comtruoion.
C-4
-------
permeability of that layer multiplied by its thickness.
Therefore, the permeability of a geonet can be calculated by
dividing its transmissivity by its thickness. A transmissivity of
5 X 10~* m^/sec is assumed for a 1/4-inch-thick geonet,
corresponding to a permeability of 7.8 cm/sec. This permeability
is considered extremely high when compared to permeabilities of
soil classes.
Compacted clay barrier layer This layer consists of mechanically
compacted clay. The permeability of this layer is approximately 1
X 10~7 cm/sec. This clay is considered a highly impermeable soil.
Synthetic barrier layer This layer consists of a flexible
synthetic membrane (FML). Typically, FMLs are considered
impermeable. Thus, their effectiveness is measured by estimating
the number and size of holes or defects that would be expected
from manufacturing or installation operations. It is believed,
for the. purposes of comparison, that the permeability of this
layer is approximately equivalent to 1 X 10~^-4 cm/sec. This
permeability is considerably lower than the permeabilities of soil
classes. However, in the HELP-II model this layer is considered
impermeable and a leakage fraction, corresponding to the number, and
sizes of holes, is used to estimate the inflow rate through this
layer.
Cover soil layer This layer consists of firm sandy clay loam.
Its permeability is approximately 1 X 10~4 cm/sec. This
permeability is considered moderate, when compared to
permeabilities of other soils.
The Hydrologic Evaluation of Landfill Performance (HELP);
version II, computer program (U.S. EPA, 1984) is a quasi-two-
dimensional hydrologic model of water movement that was developed
by the U.S. Army Corps of Engineers Waterways Experiment Station
in Vicksburg, Mississippi, for the EPA Hazardous Waste Engineering
Research Laboratory, Cincinnati, Ohio. Help-II models water
movement across, into, through, and out of landfills. It uses
climatological, soil, and landfill design data. The model accounts
for the effects of runoff, surface storage, evapotranspiration,
soil moisture storage, lateral drainage, hydraulic head on barrier
layers, infiltration through covers, and percolation from liners.
The model does not account for lateral inflow of ground water or
surface water runon, nor does it account for surface slopes of the
cover fof runoff. The program reports peak daily, average monthly,
and average annuual water budgets. The HELP-II model, which is
currently being recommended by EPA for estimating infiltration
through cover systems, has readily available climatological data
for 102 U.S. cities, including Seattle, Washington. The
climatological data consists of daily precipitation values from
1974 through 1978. Other daily climatological data are
stochastically generated using a model developed by the
Agricultural Research Service
-------
(Richardson, 1984) .
« The soil and cover design data are entered either manually or
by selecting default soil characteristics, Each landfill was
assumed to have the following design characteristics:
1. SCS RCN, 69 7 this value corresponds to a runoff curve
number, under average antecedent moisture conditions, for
a fairly grassed soil that has a moderate infiltration
rate.
2. Drainage media slope, 2 percent; this value represents the
minimum cover slope allowed by RCRA minimum technology
guidance; it has very little effect on the HELP model when
under 20 percent.
3. Drainage length (spacing between collectors), 500 feet;
this value was selected because RCRA does not require
collection pipes in the cover system and therefore, it is
unlikely to find any collectors on the cover.
Table C-l summarizes the pertinent values for the four cap designs
considered in this analysis. The infiltration value indicated 'is
the value used for the infiltration entering the contaminated zone
in the calculation of PCB migration to the water table.
PCB Migration To Ground Water
The PCB attenuation analysis was performed using EPA's one-
dimensional unsaturated zone finite-element flow and transport:
module, VADOFT (U.S. EPA, 1989g) , coupled to the analytical
solute/heat transport AT123D (Yeh, 1981) . The finite-element
module was used to evaluate vertical PCB transport in the
unsaturated zone and to generate time varying mass flux rates at
the water table which were used as input to AT123D which was used
to simulate mass transport in the saturated zone (Figure C-2) .
AT123D was used to determine a time series of depth averaged
concentrations beneath the PCB source. The results were then time
averaged over the seventy-year period representing the years of
peak concentrations occurring within a 10,000-year period.
VADOFT is a one-dimensional, non-linear, finite-element code
used to evaluate variably saturated groundwater flow and solute
transport. Solute transport in the unsaturated zone is described
by the following governing equation:
CVSWRV (dC/dt) = Dv(d2C/dZ2) - Vv(dC/dZ) - vOvSwRvC (1)
where: o^ = the effective porosity
Sw = the saturation
Vv = the vertical Darcy velocity
v = the decay coefficient
-------
Table C-l
COVER DESIGN SUMMARY TABLE (ANNUAL VALUES)
Cover
Design
1
2
3
4
Site Area
(Acres)
2
2
2
2
Precip.
(Cu.Ft.)
258,877
285,877
258,877
285,877
Runoff
(Cu. FL)
3,349
78,164
127,318
94,262
Evapotrans.
(Cu. Ft.)
113,134
114,628
131,170
118,162
Infiltration
(Cu. Ft.)/
Acre
71,467
33,529
226
1
C-7
-------
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i 111 Jliiiii Jim
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o
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CD
Original
Contaminated Zone
I
1
II
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.
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idbavXi
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*.*•'•'
y>>^i|j
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li,.
^^5^^^
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8ill^^WB88iS%
'•''.*•'•."**•.'•*•.'•''.'•*•.'•,'•.'•,'*.'•''.'•''.'-."'.'•'".'•'•.'•'•.'•*'.'•'•.*• '•.'•'*.*•*•.**'•.'•'','•**.*''•.'•''.*•*•.'•"'.'• v
#®#^
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FIGURE C-2 EVALUATION AREAS FOR VADOFT AND AT123D
v//
-------
and
Rv = 1 -f ( (Kdpb)/ (ovSw) = the retardation coefficient
= the adsorption coefficient
(2)
= the bulk density of the soil
For transport simulations using a steady-state flow field and.
where there is no decay, or the decay rate is not a function of
the saturation, the nonlinear flow analysis may be avoided for
highly adsorptive chemicals. For chemicals with large adsorption
coefficients (e.g., greater than 10) such as PCB's:
RV (KdPb)/(°vsw) (3)
and the saturation terms in Equations (1) and (2) cancel and can
be disregarded. This circumvents the need for the nonlinear flow
analysis and allows the transport analysis to be performed using a
default Darcy velocity equal to the infiltration rate. Transient
finite-element solute transport analyses were performed for the
period of interest to generate time series of mass flux rates that
were used. as a boundary condition for AT123D.
AT123D, an analytical method based on Green's function
techniques, simulates three-dimensional advective/dispersive
transport in porous media. The three-dimensional solute transport
equation on which AT123D is based can be written as:
Dx(d2C/dx2)
Dy(d2C/dy2) + Dz(d2C/dz2) - Vs(dC/dx) =
where
Rs(dC/dt)
x, y, z
Rs SC
((qC)/(Bos)) + M/o
(4)
x,
R
B
M
= spatial coordinates in the longitudinal,
lateral and vertical directions, respectively
= dissolved concentration of chemical
Dy, D2 = dispersion coefficients in the x, y, and z
directions, respectively
= one-dimensional, uniform seepage velocity in
the x direction
= retardation factor in the saturated zone
= elapsed time
= effective first-order decay coefficient in the
saturated zone
. = net recharge outside the facility percolating
directly into and diluting the contaminant
plume
= the thickness of the saturated zone
= the constant or time dependent mass flux rate
By taking the products of various directionally independent
spatially integrated Greens functions the model allows for the
application of linear, planar and volumetric mass flux sources to
a porous medium which is of infinite extent in the flow direction
and can be considered to be of either infinite or finite extent in
-------
the directions perpendicular to flow. Temporally, the Greens
functions represent instantaneous sources which are numerically
integrated with respect to time to allow for a constant mass flux
or a time variant mass flux source condition. The general
solution can be written as follows:
C(s,y,z,t) = (M/(osRs))Fijk(x,y,z,t; )d (5)
where: t = time of interest
= variable of integration
The term F^-j^ is the product of the three-directionally-
independent Greens functions (Yeh, 1981) . Since the source term
is a mass flux rate, a decay term accounting for dilution due to
infiltration of water was utilized. This dilution factor.is shown
in the second to last term of Equation (4) . For these simulations
the source was approximated as a fully penetrating rectangular
prismatic source with a surface area equal to the source area. The
fully penetrating source was used to circumvent the need to depth
average values of the concentrations.
RESULTS
The results of the analysis described above are summarized in
table C-2. PCB concentrations in ground water were estimated for
each of the four cap designs and four different PCB source
concentrations. Based on this analysis, the following
recommendations for caps could be made:
5 ppm PCBs Source At this concentration the threat of PCB
migration to ground water at concentrations that would exceed the
proposed MCL of .5 ppb under the given site conditions is
unlikely. The maximum concentration averaged over 70 years
(occuring after 945 years) is .099 ppb with only a soil cap. The
soil cover would be recommended for sites in residential areas to
prevent contact with concentrations above 1 ppm, the starting
point action level.
20 ppm PCBs Source Again, the analysis indicates that the threat
to ground water is not significant. With only a soil cap, the
maximum concentration expected is .4 ppb. For sites in
residential areas, a cement cover and a deed notice may be
warranted to prevent contact with PCBs exceeding the 1 ppm
starting point action level.
50 ppm PCBs Source At 50 ppm, PCB concentrations in the ground
water are projected to exceed the .5 ppb level slightly —
approximately 1 ppb. At this concentration, for the site
conditions presented, the second cap illustrated in Figure C-l
would be recommended. The combination of a low-permeability cover
10
-------
T.hk C-l
SATURATED TXWF. DEFTI! AND TIME AVERAGED CONCENTRATIONS HENKATII TIIF. SOIIRCF. (ff«) AND TIME OF TEAK CONCENTRATION (YEARS)
Sort r*nr«NlratWn 5 ft in
c.f
IVnVin
1
.099
Of
Dwfcn
i
.029
c.f
Dnlfn
)
0.0
Of
D«l*n
4
0.0
S«4I C««*e*n
.116
C-r
Dn%n
.<
p.o
C.p
O».lim
4
0.0
Soil ConrvntnHtow 50 p^m
CM
Dnlpi
1
.990
CM
IW^IKII
2
.DO
C.f
Dnlxn
J
0.0
C.f
DMlpi
4
0.0
Soil CiMmntralWfl 100 ffn>
c.r
Dnlpi
1.98
or
IVilfn
2
.580
<^f
Dnlitn
J
0.0
Cf
Dnl(n
4
0.0
Tre.k <*••">
Of
Dtdp,
1
945
Op
Drtlftn
2
1645
Of
IVtttn
)
('•r
l>nl|tn
4
SITF. fARAMFTF.RS
Sour« Are«-'5 Acret
«l Bnw 310 (l/yrnr
Hulk IX-mliy i<( S.»l -1.97 |/ml
TimC"Peiik 70 ycjin trnm 0-10.000 yean
Cnnitminilnl i.mt or(«nlc cmieni-S.0%
CVin urauilurvird zone orgink cnfilenl--0.5%
Sjtonln) nme <»(«nk ctwlcni -0.1%
PCB hull lifc--50 ye.n
l)qxh r( CnnlnmlnXlon-IO Feel
I)ep4h In (tniundwAter--2n (crl
IliictocM 14 Stiuntn) 7jnnt--l tctt
-------
soil and '-the soil cap will prevent PCBs from migrating to the
ground water at levels that exceed .5 ppb. With the reduce
infiltration t*e maximum PCB concentration- projected for the
ground water (occurring after 1645 years) is .3 ppb. Again, a
deed notice would be warranted to prevent direct contact with the
soil in the future. Consistent with Table 4-2, a fence and some
ground water monitoring (annual) would be recommended.
100 ppm PCBs Source At 100 ppm, PCB concentrations in the ground
water are projected to exceed the .5 ppb level slightly —
approximately .6 ppb, even with the addition of a low-
permeability cover soil. At this concentration, for the site
conditions presented, the third cap illustrated in Figure C-l
would be recommended. The addition of a flexible membrane liner
reduces infiltration sufficiently to prevent migration of PCBs to
the ground water. Consistent with Table 4-2, a deed notice,
fence, and periodic ground water monitoring would also be
recommended.
12
-------
APPENDIX D
CASE STUDIES
PEPPER STEEL, FL AND WIDE BEACH, NY
-------
SITE NAME: Peppers Steel and Alloys, Florida.
SITE DESCRIPTION: Xbe cite r^mni^c ^O-acres in Medley, Florida, approximately 10 miles
northwest of Miami overlying the Biscayne Aquifer. This aquifer is used as a sole source drinking
water supply for a large population. This location has been the site of a variery of businesses
including the manufacture of batteries and fiberglass boats, repair of trucks and heavy equipment
and an automobile scrap operation. Batteries, underground storage tanks, transformers, discarded
oil tanks and other miscellaneous debris have accumulated as a result of disposal from past and
present operations at the site. Contaminants have been identified within the soil, sediments and
ground water.
WASTE DESCRIPTION: The contaminants of concern are polychlorinated biphenyls (PCBs),
organic compounds and metals such as lead, arsenic, cadmium, chromium, copper, manganese,
mercury, zinc and antimony. The quantities and concentrations of the primary contaminants are:
PCBs - 48,000 cubic yards of soil at 1.4 ppm to 760 ppm,
12,000 gallons of free oils with concentrations up to 2,700 ppm;
Lead - 2 1 ,500 cubic yards of soil at 1,100 ppm to 98,000 ppm;
Arsenic - 9,000 cubic yards of soil at concentrations greater than 5 ppm.
PATHWA YS OF CONCERN: Of significant concern is ground water transport of PCBs and lead'
to private wells and lead intake due to ingestion from direct contact with local soils. Air paniculate
matter containing PCBs provides a possible inhalation exposure pathway to onsite workers and
offsite to neighboring residents.
TREATMENT TECHNOLOGY SELECTED: The recommended remedial alternative involves the
excavation of PCB contaminated soils > 1 ppm and solidifying with a cement-based material
followed by onsite placement. Soils contaminated with > 100 ppm lead or > 5 ppm arsenic will be
excavated and chemically fixed (stabilized), thus reducing dissolution and diffusion rates. Free
oils contaminated with PCBs will be treated offsite at a Toxics Substances Control Act (TSCA)
approved incinerator. The offsite disposal of the free oil is cost-effective, implementable and
satisfied the disposal requirements of TSCA Pan 761.60(a). The solidified mass will be replaced
onsite approximately 4-5 feet above ground water level.
EQUIVALENT TREATMENT: TSCA regulation 761.60(a)(4) requires that soils containing
PCBs at concentrations greater than 50 ppm be destroyed by incineration or disposed in a chemical
waste landfill. TSCA 761.60(e) provides for the approval of alternative methods of disposal
which achieve a level of performance equivalent to incineration and protective of human health and
the environment. The TSCA Spill Cleanup Policy (Pan 761.120) covers spills which occurred
since May 4, 1987. Spills which occurred before that date are to be decontaminated to
requirements csablished at the discretion of EPA, usually through its regional offices. TSCA
regulation 761.123 defines the relationship of the PCB Spill Cleanup Policy to other statutes. The
Policy does not affect cleanup standards or requirements for the reporting of spills imposed, or to
be imposed under other Federal statutory authorities including CERCLA. Where more than one
requirement applies, the stricter standard must be met. PCB spills at Pepper's Steel took place
during a period between 1960 through the early 1980's, therefore the PCB Spill Cleanup Policy is
not applicable to this situation.
D-l
-------
Incineration was deerned unacceptable due to high metal content in the contaminated soils. The
volatilization of the metals would result in significant air discharges even with the implementation
of air control mechanisaas on the incinerator. Depending on the ?.'.r.f-nnrro\ method used, sm-bber
waters or bag house .filters contaminated with metals, 1 ppm will be solidified, the action is consistent with the TSCA PCB Spill
Cleanup Policy (761.125) which recommends a 10 ppm cleanup level fora site with nonresrxicted
access.
Of chief concern with the fixation method is the long term integrity of the fixed mass related to near
surface ground water or infiltrating rainwater which may contribute to migration of the
contaminants. To assess risk of injury to health or the environment, the EPA performed rreatability
studies on the solid mix to define performance standards. The tests performed to verify the
integrity of the solidified matrix were Toxic Charac.terist.ic Leaching Procedure (TCLP), Extraction
Procedure (EP) Toxicity, ANS 16-1 and a modified MCC-11. Fate and modeling (method not
provided) were used to establish ground water action levels to monitor for failure of the
technology. This remedial action warrants the submission of a waiver under 40 CFR 761.75(a)(4),
for chemical waste landfills. Under this regulation the EPA Administrator may waive certain
landfill requirements if it is determined that the landfill does not present an unreasonable risk of
injury or adverse effects to health or the environment. This alternative satisfactorily addresses
specific concerns in TSCA chemical waste landfill requirements by providing leachate collection,
monitoring wells and a liner or fill to maintain the solidified mass above the ground water table.
Parameters for the treatability studies were set using the Water Quality Criteria Standard of 0.079
ng/1 PCBs in water for PCBs at the property line several hundred feet from the solidified mass.
Using ground water modeling, a level of 7 ppb PCB in leachate from the solidified mass was
established as the maximum allowable concentration which would yield an acceptable risk at the
receptor. Results from the treatability studies all indicated concentrations of PCBs in leachate of
less than the detectable limit of 1 ppb.
This remedial action can be viewed to be consistent with two areas of TSCA PCB disposal
policies. The solidification of the waste and leachate monitoring provide additional protective
measures than are required in the chemical waste landfill regulations. The action also achieves a
level of performance equivalent to incineration. Analysis of leachate from the solidified mass
shows no PCBs at a detection limit of Ippb, which supports the conclusion that the mobility of
PCBs into the surrounding environment is essentially destroyed.
D-2
-------
SITE NAN-IE: WJde Beach, NT
SITF. DESCRIPTION: The Wide Beach Development site is located in a small lakerids c-Trrr1.'".^-
in Brant, New York, approximately 48 km south of Buffalo. The Development coven, 22
hectares, 16 of which are developed for residential use. The site is bordered on the west by Lake
Erie, on the south by wetlands and on the east and north by residential and agricultural property. -
Between 1968 and 1987, 155 cubic meters (approximately 744 barrels) of waste oil, some
containing polychlorinated biphenyls (PCBs), was applied to roadways for dust control by the
Wide Beach Homeowners Association. In 1980, the installation of a sewer line resulted in
excavation of highly contaminated soils and surplus soil was then used to fill in several yards and a
nearby grove of trees.
The Erie County Department of Environmental Planning investigated a complaint in 1981 of odors
coming from nearby woods. They discovered 19 drums in the woods and two contained PCB-
contaminated waste oil. Alerted to a potential problem subsequent investigatory sampling revealed
the presence of PCBs in dust, soil, vacuum cleaner dust, and water samples from private wells.
In 1985 the EPA performed an action to protect the public from the immediate concern until
implementation of a long-term measure. The action involved the paving of roadways and drainage
ditches, decontamination of homes by rug shampooing, vacuuming, and replacement of air
conditioner and furnace filters and protection of individual private wells by installation of
paniculate filters.
WASTE DESCRIPTION: The primary containment at the Wide Beach site is PCBs, found over
the majority of the site in all environmental media. The most significant contaminations were
found in the sewer trench wells, soils adjacent to the roadways and wetlands sediments.
Maximum PCB concentrations from the following areas were:
drainage ditch samples - 1,026 ppm;
yards and open lot samples - 600 ppm;
unpaved driveway samples - 390 ppm;
roadway samples - 226 ppm;
sediment samples from marsh area - 126 ppm
The concentration of PCBs in one catch basin sample was 5,300 ppm. Investigations revealed that
one of eight monitoring wells, and all six sewer trench wells were contaminated with PCBs.
Drinking water sampling studies discovered PCB contamination in 21 of 60 residential wells,
however, the level of contamination was low ranging from 0.06 us/I to 4.56 ug/1.
PATHWAYS OF CONCERN: The primary pathway of concern is through the ingestion of PCB
contaminated soils. Additional potential concerns involve the environmental impact of
contamination on the surrounding marshlands.
TREATMENT TECHNOLOGY SELECTED: The recommended remedial alternative involves the
excavation of contaminated soils > 10 ppm PCBs, onsite chemical treatment to destroy PCBs and
soil residual replacement. The recommended treatment will involve removing 5,600 cubic meters
of soil from the roadway, 8,500 cubic meters from drainage ditches, 1,500 cubic meters from
unpaved driveways and 13,000 cubic meters from back and front yards. The chemical treatment
for the 28,600 cubic yards of contaminated soil consists of a two step procedure. First, PCB
molecules are extracted from the soils using solvents. The solvents are then treated with Potassium
Polyethylene Glycol (KPEG), to remove chlorine atoms from the PCB molecule. This slurry is
then pumped to a jacketed, internally agitated, batch reactor where the mixture is maintained at a
soil moisture content of 2-3 percent for two hours at a temperature of 140 degrees Celsius while
D-3
-------
the dechlorination reaction takes place. This stage is followed by several water washes, and solids
separation. The soils will be replaced onsite after the PCB contaminated matrix is treated to 2 ppm.
EOUrVALFNT TREATMENT: TSCA regulation 76l.60(a)(4) requires that soils containing
PCBs at concentrations greater than 50 ppm be destroyed by incineration or disposed in a chemical
waste landfill. TSCA 761.60(e) provides for the approval of alternative methods of disposal
which achieve a level of performance equivalent to incineration and are protective of human health
and the environment. Incineration was rejected as a remedial alternative option during the remedial
investigation and was not documented in the Record of Decision. Offsite landfilling of the PCB
soils was rejected due to concerns of excessive cost, dust release during excavation and possible
exposure risks during transport. .
Primary concerns with this treatment technology include the ability to attain the 10 ppm level for
soil decontamination, and the potential formation of toxic end products through use of the reaction
vessel. To address these concerns pilot plant treatabiliry studies were performed to assess the
effectiveness of potassium polyethylene glycol in dechlorinating the PCBs, and to determine
important design parameters for the reaction vessel such as physical dimensions, operation
temperatures and detention time. The results from one run revealed a reduction from 260 ppm in
soil to under 2 ppm in the treated residual. Runs were performed on soil at 80 ppm PCBs which is
the average concentration at the site. The results indicated that the 10 ppm PCB levels could be
achieved consistently. Lab tests in the bench scale treatability study revealed no mutagenic effects
with the soil, indicating that the residuals are non-toxic. The results of both KPEG bench scale
and pilot plant treatabiliry studies showed that PCB concentrations or 10 ppm or lower can be
achieved successfully without hazardous end products, which eliminates the primary concerns with
this treatment.
The 2 ppm cleanup level was derived by Best Demonstrated Available Technology (BDAT) values.
TSCA policy, and health-based criteria identified in the risk assessment. The TSCA policy for
evaluating whether treatment is equivalent to incineration (TSCA 761.60(e)) defines successful
equivalent treatment by the level of PCBs in the treatment residual. A concentration of 2 ppm is
considered to indicate the treatment has achieved a level of performance equivalent to incineration.
The selected treatment destroys PCBs in contaminated soils therefore eliminating the potential risk
identified in the risk assessment (i.e., direct contact threats). KPEG also provides protection
through permanent and significant reduction of toxicity, mobility and volume of the waste, and
complies with all relevant and appropriate requirements set forth in TSCA. Since this method has
achieved a level of performance equivalent to incineration through pilot studies and it has been
shown to be protective of human health and the environment, it is an acceptable alternative to
incineration. '
D-4
-------
APPENDIX E
PCB DISPOSAL COMPANIES, COMMERCIALLY PERMITTED
-------
NOV 29 1989
PCB DISPOSAL COMPANIES
PERMITED
* Permitted to operate
COMPANY
INCINERATOR
ENSCO
ENSCO
General Electric
Pyrochem/Aptus
Rollins
SCA Chemical
Services
U.S. Department
of Energy/
Martin Marietta
Energy Systems
WESTON
in all ten EPA Regions
ADDRESS
P.O. Box 1957
El Dorado, AR 71730
P.O. Box 8513
Little Rock, AR 72215-8513
100 Woodlawn Ave.
Pittsfield, MA 01201
P.O. Box 907
Coffeyville, KS
P.O. Box 609
Deer Park, TX 77536
11700 South Stony Island Ave,
Chicago, IL 60617
Federal Office Building
Room G-108
P.O. Box E
Oak Ridge, TN 37830
One Weston Way
West Chester, PA 19380
PHONE NO.
501-223-4160
501-223-4100 *
413-494-3729
316-251-6380
713-479-6001
312-646-5700
615-576-0973
215-692-3030 *
Ecova Corporation
Ogden Environmental
Services, Inc.
(formerly GA
Technologies, Inc.)
J.M. Huber
Corporation
O.H. Materials
Corporation
12790 Merit Drive
Suite 220, Lock Box 145
Dallas, Texas 75251
P.O. Box 85178
San Diego, CA 92138-5178
P.O. Box 2831
Borger, TX 79007
16406 U.S. Route 224 East
P.O. Box 551
Findlay, Ohio 45839-0551
214-404-7540 *
800-876-4336 *
or
619-455-3045
806-274-6331
800-537-9540 *
-------
CHEMICAL
American Mobile Oil
Purification Co.
Chemical Waste
Management
Exceltech, inc.
General Electric
General Electric
National Oil
Processing/Aptus
Niagara Mohawk Power
Corporation
PPM, Inc.
ENSR Operations
(formerly Sunohio)
T & R Electric Supply
Company, Inc.
Transformer
Consultants
Trinity Chemical Co.
Inc.
233 Broadway, 17th Floor
New York, NY 10279
1550 Balmer Road
Model City, NY 14107
41638 Christy Street
Fremont, CA 94538
One River Road
Schenectady, NY 12345
One River Road
Schenectady, NY 12345
P.O. Box 1062
Coffeyville, KS 67337
300 Erie Boulevard West
Syracuse, NY 13202
1875 Forge Street
Tucker, GA 30084
1700 Gateway Blvd. S.E.
Canton, OH 44707
Box 180
Colman, SD 57017
P.O. Box 4724
Akron, OH 44310
6405 Metcalf, Cloverleaf 3
Suite 313
Shawnee Mission, KS 66202
212-267-7073 *
716-754-8231
415-659-0404
518-385-3134
518-385-3134 *
800-345-6573
315-474-1511
404-934-0902 *
216-452-0837
800-843-7994
800-321-9580 *
913-831-2290
PHYSICAL SEPARATION
ENSCO
National Electric/
Apt us
Quadrex HPS, Inc.
Unison Transformer
Services, Inc.
1015 Louisiana Street
Little Rock, AR 72202
P.O. Box 935
Coffeyville, KS 67337
1940 N.W. 67th Place
Gainesville, FL 32606
P.O. Box 1076
Henderson, KY 42420
501-223-4100 *
800-345-6573
904-373-6066 *
800-544-0030
-------
PHYSICAL SEPARATION continued
General Electric
One River Road
Schenectady, NY 12345
PCS TRANSFORMER DECOMMISSIONING
G&L Recovery
Systems, Inc.
1302 West 38th Street
Ashtabula, Ohio 44004
518-385-3134 *
216-992-8665
BIOLOGICAL
Detox Industries,
Inc.
12919 Dairy Ashford
Sugar Land, TX 77478
713-240-0892
RMOA
Texas Eastern Gas
Pipeline Company
P.O. Box 2521
Houston, Texas 77252-2521
713-759-5167 *
CHEMICAL WASTE L.
Casmalia Resources
CECOS International
CECOS International
Chemical Waste
Management
Chemical Waste
Management
Chem-Security Systems
Incorporated
Envirosafe Services
Inc. of Idaho
SCA Chemical Services
559 San Ysidro Road
P.O. Box 5275
Santa Barbara, CA 93150
56th St. & Niagara Falls
Boulevard
Niagara Falls,. NY 14302
5092 Aber Road
Williamsburg, OH 45176
Alabama Inc. Box 55
Emelle, AL 35459
BOX 471
Kettleman City, CA 93239
Star Route
Arlington, OR 98712
P.O. Box 417
Boise, ID 83701
BOX 200
Model City, NY 14107
805-937-8449
716-282-2676
513-720-6114
205-652-9721
209-386-9711
503-454-2777
208-384-1500
716-754-8231
-------
CHEMICAL WASTE LANDFILLS continued
U.S. Ecology, Inc. Box 578 . 702-553-2203
Beatty, NV 89003
U.S. Pollution Grayback Mountain 405-528-8371
Control, Inc. Knolls, UT 84074
-------
APPENDIX F
LONG TERM MANAGEMENT CONTROLS AT PCB-CONTAMINATED SITES
SUPERFUND EXAMPLES
-------
CHEMICAL WASTT LANDFILL C
•OTtirriAL ARAKS:
BCKA: 40 CFR Part 264.310 or 265.301 provide* five criteria for the design and construct la,
minimization of liquid*; (2) function with m1ti1t»«n maintenance; (3) proaot* drainage
and (5) th« pr*«Mabilltv of the cap «o*C b« !••• than or «qual to tha pcnMAblilty ci
TSCA: None.
V«««tici»t TOP Corir
Mlddl*
S.—pfpf Ve««tarlon
HA: •inl*«a« Hlnlalzt
chnology Guidance eroalon
•malla Rctourcat
nta aarbara. CA
COS Inctrnatlonal Regional
c.. Sp«ci«»
agara Falli. NY
COS International tegloaal
;., Speclea
lllaniburg, OH
ralcal Vaact Regional
*11«, AL
•nical Waatc
cclatun City. CA
viroaafe Scrvicta, Regional
c. Sp«ciei
Idaho
Ut. ID
ra'Stcurlty
CM>. Inc.
llngton. OR
nugMMDC (SCA) Specie*
xi»l City. KT
S. Ecology
•«tty, KV
S. Pollution
introl. Inc.
ioll«. UT
Sell
Top Soil Soil PerMabllitr Ceoteztil* Drainage
TOD Slocx rtmckPI" rfciCtatll (n/lft) Filter Haterlal
At leaat 31 Total Tblckaeaa 1/4 Tea (dealgn Sand or
but no greater 24* to prevent equivalent
than SI cloulmg) geoavntbetic
«' "/A Ceoayntbetlc
«' 30- P/A Ceoar»tb«tic
18* ** "/A H/A rTt HTLF
2»*
f 19° •/* Tea Ceoerntbetlc
«* J*' I/A Tea Ceoevvtheclc
-
*" 36* I/A Sand
12- a,
.1*
Equi»
Co 12
AJUU.1
ce i;
-------
SJ
S«p»rf«rx) Kilt (RO[> r»lr)
10 KrriKh l.imilrd
rrmhy. 1 X
(\nt/M)
1 1 . Commence mr nl
Il»y/Nc«t Shore
TariKn». WA
(I2/VI/N7)
12. Ptciftc Hide ind l:ur
P.ic.tfllo. II)
(6/2JMW)
l\' Pinntiri S»tv«gc Y»rd
Wmhhurn. Ml-;
(.VW»)
H h SullrvirTi lr.*h DouftlKUvlllC Uilptnal
Silt
lltrkA Cntmly, PA
l)r»ll (W)
I7."1* Town of Norwood
Norfolk Courtly. MA
Drull (I/RV)
SIIPK.IWINI) KXAMPl.KS.-mNC.TKRM MANACKMKNT CONTRCII5
Inlllil Sonrrr A Pn*Wm
• 7..\ ^crf Ugrxin
• Vinp y«rd
• Tmniformtn, cufwciiori
• Strap y«nj
• Srfvp yird
• Tnrnformcr dlcrcclric
fluid ipill
• Qutrry
• PrcvMtus dl.^pnMl
• IrKJuithiil divhArf^
• Oil retyrlinjt
• F.rrclriail rquipmtnl
nunufnciurrr
• I'revkMH di^piruil
DKpralllon
• In *ilu binli»f;ic4l irr.ilmrnl
• Sl.ihili/c
• l;ju:avflle
• StMlMl identified HI «h
ullcrnntivc
• [:JC*V»»C
• Slubiltrc
. c:.P
• l-jtirflct Nnd trcm ^rnundwutcr
• RoltKC wetlands
• Secure *ilc
• Knlrict use
• l-ong Icrm moniloring
* (jtnfrtnjt idcniin«J AS »n
alicrnalive
• (*J*pf>in|t idcntifinJ n\ an
fllicrnjiive
• Cippinft WcniifleO AS an
Alternative
InMlal rt'll
('orxrn Ira lion
Rahjtt (ppm)
N.I). 61 A
0 2fM
7.4 .VW
2,400 (soil)
500-400
(Mtlimcnl)
NO -30.000
(v.iU)
IQ./A.OOO
(w>ih)
Fln.l PCR
(!oncr ntrallon
(ppm)
2*
\
10-25
10-50
( i fn|o(lc/l Ij^rofrnlof k
Conditions
• (irnundwflirr: Irw than 50
feet bel'Ttv surfffrt
• (icitloj-y: to|nnil; flsy
• (iniund-wNtrr: 8 12 frvl
htlrr>un(Jwiier 0 20 feet
he low turface
• deotofy; wnd and gravel;
cUy tnd silly ct»y; ularinl
fill; heitnKk
• (imufxJ*ater. 100 fert
bekw turfdce
• Geology: qujirriw loaned
in fruclurcd hrdmck
• fimund>»ter
ctmlimlnalron due In
diffusion from «diment
• (irrHindwaler leu thin 5
feet in .11 (eel to surface
• Oeotofy: fill; nuiuml »TVTT-
burden bedrock
• OeotofT r'"; Mnd In(1
(travel; glxcial fill; bed trek
Covrr Drftlicn
N.me
2 Inrhe* *e*letj
it^phjill
Ijtpw permciiNliiy or
KCKAr«p
4 Incho Hpn*lt; 12
Inches Hone; tingle
synthetic lityen ''"
2 feel cliy; IB inrho
buffer toil; 12 inches
undv toil: 2 feet
vegtiiitvc »oil;
vc get it ton
^ feel undMU;
tynthelk" layer
Sjmlhetk tiner,
proleclive toil;
turmoil; vejrldikx*
3 Inches mphilt 2*
»»rrgAllfin ^)'*lffTl
p,.,,,^
N
Sltiti v ***M
1 in>imd*Airr welti
may tie planned (or
ptmip .iml lic.iime nl
Nonr
(iriiiindwkiet
b^itici
Noite
?i'»ppin|y1»nd dispoMl MicnIifkO «i nn «tltrti«lrvr. ''Propiwrd Plan.
-------
SIIPKRFIIND F.XAMH.FS.-l,ONi;.TF.RM MANAfJF.MF.NT CONTROLS
Stperflmrf Slk (ROD D.l»)
1. Olllli and GOM,
Kingston, Nl 1(1/16/87)
2. Re -Solve. MA
North Dartmouth, MA
(7/Z4/87)
.1. Chemical Control
liliianeih. NJ
(W/R7)
4. Wide IUach
Rnnl. NY
(9/WRS)
.V Yort Oil
Moire. NY
(2/>/W>)
6 Mowhray Engineering
. AI.
(»/i Variety of w»ile In
drumt
• Wmic oM jptc»d on din
rtwtdt
• 3 acn twimp
• TrtRtfttrmer rcpjilr plant
• X) ictrt u«h
. . landfill
• Drum Dbprwal
• Dumping urea
• Recycling plant
Dfcfmltton
• Fjicavale
• Off-xite Incineration
. C.p
• Aerniiofl
* I:jtlr»cl tnd Irttl grrnindwiiter
• I'jtCAviiie
• C»p
• On site trctlmcnl (dcch tori nut ton)
* WctUnd rt*t
• Chemicul ircjitmcnl
• pjicwite
• .Slahillu
* Oft-iilc Incincnlkxi
* I:jtr»ct inU irrtl ^rourxtwiiicr
• (^kwc tcvrrr
• I ;jt civile
» SliNHu
• Fjctvitc
* SmNlUe
• OR-titr Incineration
. Cip
• l-xlracl and treat fmundwater
• l:jicfvile
• Oil *iie incineration
• Ijndlilt
. Cap
• l-JilncI ind treat (rroundwiiler
• Secure tile
• Kxcavate
• On-niic Inclnerntion
• Op
• Contaminant wall
• l:j|r»ct and Iretl (mundwater
• Secure Aite
Initial rCB
Concrnlnilloa
ntnft (pfm)
14.1 (loll)
15 52.000
On
O.OVI02^
.1-210
N.D.-A2 (uiil)
1.5-760 («oil)
9-51.000
O..U H.2
Fln.l rT»
Canctnlralloii
(«"">
20 (soil)
2.5 (»iil)
0-6
10
25
1
50
10
Cn>lofk/1lygy: oulwa^h land*
and gntvek; bke ctxyi.
Hill*, and fine*
Cevtr Ofalfpl
v Inches lop loll
Regraded and graued
1 ..1 fool gravel layer
None (not feailbte, a
mktenllil
community)
None (ilabilltallon
prxKUA ICHVQ trolled
toib tmpcrmciMc)
2 fed orxnp*cled city,
2 t«1 vt|el*i!ve
Uycr, 2 feel und.
tjmiheik liner
12 Inches rnnhcd
limes lone
RCRA cover
2 feel tliy end 6
Inchct vegeinitve Uycr
Beltofn Unen
• None
None
None
• Nitunl
ifnpernicAuM ciffys
• Nttnt
None
» Ntluret
Impermeihk cliyi
• None
* None
• None
• None
l**cH.iU
('otta-ltniVR+mov*!
•nrf Ixkk IVVfllon
(iniuniN»Mtrr wrlh
pUnnrtl (itf pttnip
und iifMlmcni
(irtHinihtrntrr well*
ptjtnnH for pump
Nn
-------
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
Directive: 9355.4-01 FS
August 1990
&EPA
A Guide on Remedial
Actions at Superfund Sites
With PCB Contamination
Office of Emergency and Remedial Response
Hazardous Site Control Division (OS-220)
Quick Reference Fact Sheet
GOALS
: This fact sheet summarizes pertinent considerations in the development, evaluation, and selection of remedial actions at Superfund
sites with PCB contamination^ It provides a general framework for determining cleanup levels, identifying treatment options, and
assessing necessary managementcontrols for residuals. It is not a strict "recipe" for taking action at PCB-contaminated sites.but
it should be used as a guide for developing remedial actions for PCBs. Site-specific conditions may warrant departures from this
basic framework. A more detailed discussion of these issues can be found in the Guidance on Remedial Actions for Superfund Sites
. with PCB Contamination, OSWER Directive No. 9355.4 - 01.
SUPERFUND GOAL AND EXPECTATIONS
The Superfund program goal and expec-
tations for remedial actions (40CFR
300.430 (a)(l)(i) and (iii)(1990)) should
be considered during the process of
developing remedial alternatives. EPA's
goal is to select remedies that are protec-
tive of human health and the environ-
ment, thatmaintain protection overtime,
and that minimize untreated waste. The
Agency expects to develop appropriate
remedial alternatives that:
• Use treatment to address the principal
threats at a site, wherever practicable
• Useengineeringcontrols.suchascon-
tainment, for waste that poses a rela-
tively low long-term threat or where
treatment is impracticable
• Use a combination of treatment and
containment to achieve protection of
human health and the environment as
appropriate
•• Use institutional controls to supple-
ment engineering controls for long-term
management and to mitigate short-term
impacts
• Consider the use of innovative tech-
nology when such technology offers the
potential for comparable or superior treat-
ment performance or implementability.
fewer or lesser adverse impacts than other
available approaches, or lower costs for
similar levels of perfomance than more
demonstrated technologies
• Return usable ground waters to their
beneficial uses wherever practicable,
within a timeframe that is reasonable,
given the particular circumstances of the
site
The following sections are organized to
follow the Superfund decision process
from scoping through preparation of the
ROD
DETERMINE DATA NEEDS - Consider Special Characteristics of PCBs
Considerations to note during scoping
and when developing potential remedial
.alternatives for PCBs, include the fol-
lowing:
• Apph'cable or relevant and appropri-
ate requirements (ARARs) for PCBs are
relatively complex because PCBs are
addressed by both TSCA and RCRA
(and in some cases, state regulations).
Figure 1 illustrates primary regulatory
requirements that address PCBs.
• PCBs encompass a class of chlorin-
ated compounds that includes up to 209
variations or congeners with different
physical and chemical characteristics.
PCBs were commonly used as mixtures
called Aroclors. The most common
Aroclors are Aroclor-1254, Aroclor-1260,
and Ajoclor-1242.
• PCBs alone are not usually very mo-
bile. However, they are often found with
oils, •which may carry the PCBs in a
separate phase. PCB s may also be carried
with soil particuiates to which they are
sorbed.
• Although most PCBs are not very vola-
tile, they are very toxic in the vapor phase.
Consequently, air sampling and analyti-
cal methodologies should be selected
that will allow for detection of low levels
of PCBs.
• Certain remedial technologies will
require specific evaluations and/or treata-
bility studies. If biotreatment is consid-
ered, the mobility and toxicity of pos-
sibie by-products should be assessed. If
stabilization is considered, the volatili-
zation of PCBs during and after the pro-
cess should be evaluated. Also, the long-
term effectiveness of stabilization should
be evaluated carefully. If incineration is
considered, the presence of volatile met-
als should be addressed.
-------
Figure 1 - Primary Regulatory Requlromants/Pollctes
Addressing PCBs
RCRA
Outlines closure requirements for hazardous
waste landfills (40 CFR 264.310)
Establishes land disposal restrictions for liquid
hazardous waste that contains PCBs at 50 pom
or greater or nonliquid hazardous waste that
contains total HOCs (including PCBs) at concen-
trations greater than 1,000 ppm (40 CFR 268.32)
Provides for a treatability variance (40 CFR
268.44) that may be used for PCBs in CERCLA
soil and debris. (Under Superfund treatability
variance guidance, PCB concentrations should
be reduced to .1 -10 ppm for initial concentra-
tions up to 100 ppm; abovelOO ppm, treatment
should achieve 90-99% reduction of PCBs, con-
sistent with Superfund expectations for treatment.)
TSCA
Regulates PCBs at concentrations of 50 ppm or
greater (40 CFR 761)*
— PCB management options include: incineration
(40 CFR 761.70), high- temperature boiler (40
CFR 761.60), alternative technology that
achieves a level of performance equivalent to
incineration (40 CFR 761.60), and chemical
waste landfill (40 CFR 761.75)
Note: Liquid PCBs at concentrations of 500 ppm
or greater can only be incinerated or treated by
using an alternative technology equivalent to in-
cineration (40 CFR 761.60). Dredged material
rr\ay also be disposed of by a method approved
by the RA (40 CFR 761.60 (a)(5)).
Establishes a PCB spill policy (40 CFR 761.120)
that defines the level of cleanup for recent small-
,volume spills. The Superfund approach is
consistent with this policy.
i
CERCLA/NCP
Remedial Actions Must:
• Protect human health and the environment (121[b][1])
• Comply with applicable or relevant and appropriate
requirements (ARARs) (121[d][2))
• Be cost-effective (40 CFR 300.430) (121[b][1])
• Utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable (40 CFR 300.430) (121[b][1])
x-:w>»:*:wXv:w>>>:
-------
Table 1
Recommended Soil Action Levels-
Analytical Starting Point
Land Use ; Concentration (ppm)
Residential
Industrial
1
10-25
The 1 ppm starting point for sites in
residential areas reflects a protective
quantifiable concentration. (Also, be-
cause of the persistence and pervasive-
ness of PCBs, PCBs will be present in
background samples at many sites.) For
sites in industrial areas, action levels
generally should be established within
the range of 10 to 25 ppm. The appropri-
ate concentration within the range will
depend on site-specific factors that af-
fect the exposure assumptions. For ex-
ample, at sites where exposures will be
very limited or where soil is already
covered with concrete, PCB concentra-
tions near the high end of the lO-to-25
ppm range may be protective of human
health and the environment.
Ground Water
If ground water that is, or may be, used
for ^drinking water has been contami-
nalŁd by PCBs, response actions that
return the ground water to drinkable levels
should be considered. Non-zero maxi-
mum contaminant level goals (MCLG)
or maximum contaminant levels (MCL)
should be attained in ground water where
relevant and appropriate. State drinking
water standards may also be potential
ARARs. Proposed non-zero MCLGs
und proposed MCLs may be considered
for contaminated ground water. The pro-
posed MCL for PCBs is .5 ppb. Since
PCB s are relatively im mobile, their pres-
ence in the ground water may have been
facilitated by solvents (e.g., oils) or by
movement on colloidal particles. Thus,
the effectiveness of PCB removal from
ground water, i.e., ground-water extrac-
tion, may be limited. In some cases, an
ARAR waiver for the ground water may
be supported based on the technical im-
practicability of reducing PCB concen-
trations to health-based levels in the
ground water. Access restrictions to
prevent the use of contaminated ground
water and containment measures to pre-
vent con lamination of clean ground water
should be considered in these cases.
Sediment
The cleanup level established for PCB-
contaminated sediment may be based on
direct-contact threats (if the surface water
is used for swimming) or on exposure as-
sumptions specific to the site (e.g., drink-
ing water supplies). More often, the
impact of PCBs on aquatic life and con-
sumers of aquatic life will determine the
Table 2 - Sediment Cleanup Levels
cleanup level. Interim sediment quality
criteria (SQC) have been developed for
several non-ionic organic chemicals, in-
cluding PCBs and may be considered in
establishing remediation goals for PCB-
contaminated sediments. The method
used to estimate these values is called the
equilibrium partitioning approach. It is
based on the assumptions that: (1) the
biologically available dissolved concen-
tration of a chemical in interstitial water
is controlled by partitioning between
sediment and water phases that can be
estimated based on organic carbon parti-
tion coefficients; (2) the toxicity of a
chemical to, and bioaccumulation by,
benthic organisms is correlated with the
bioavailable concentration of the chemi-
cal in pore water, and (3) the ambient
aquatic life water quality criteria (WQC)
concentrations are appropriate for the
protection of benthic communities and
their uses. Table 2 presents the sediment
quality criteria and derived PCB sedi-
ment concentrations based on the SQC
for freshwater and saltwater environments
and two organic carbon (OC) concentra-
tions. These criteria are to be considered
in establishing remediation goals for con-
taminated sediments.
;Aquatlc Environment
Freshwater Saltwater
Sediment Quality Criteria (SQC) 19
(Concentrations expressed as ug/g of sediment)
OC = 10% 1.90
OC = 1% 0.19
33
3.30
0.33
DEVELOP REMEDIAL ALTERNATIVES
The potential response options at any site
range from cleaning up the site to levels
that would allow it to be used without
restrictions to closing the site with full
containment of the wastes. Figure 2 il-
lustrates the process for developing al-
ternatives for a PCB-contaminated site.
Primary Alternatives
It is the expectation of the Superfund
program that the primary alternatives for
a site will involve treatment of the prin-
cipal threats and containment of the re-
maining low level material. For residen-
tial sites, principal threats will generally
include soils contaminated at concentra-
tions greater than 100 ppm PCBs. For in-
dustrial sites, principal threats will in-
clude soils contaminated at concentra-
tions greater than or equal to 500 ppm
PCBs.
Treatment Options
Liquid and highly concentrated PCBs
constituting the principal threats at the
site should be addressed through treat-
ment. Treatment options that are cur-
rently available or are being tested in-
clude incineration, solvent washing,
KPEG (chemical dechlorination), bio-
logical treatment, and solidification.
Compliance with TSCA ARARs re-
quires that PCB s, at greater than 50ppm,
be incinerated, treated by an equivalent
method, or disposed of in a chemical
waste landfill. Equivalence to incinera-
tion is demonstrated when treatment
residues contain <2 ppm PCB. If treat-
ment is not equivalent to incineration,
compliance with TSCA ARARs must be
achieved by implementing long-term
management controls consistent with the
chemical waste landfill requirements.
(Liquid PCBs at concentrations greater
than 500 ppm cannot be landfilled under
TSCA.)
Containment of Low-Threat Material
Long-term management controls should
generally be implemented for treatment
residuals and other low level contami-
nated materials remaining at the site
Example scenarios for the use of long-
term management controls appropriate
for particular PCB concentrations an
shown in Table 3. The substantive re
quirements of a chemical waste landfil
specified^ TSCA regulations (761.7!
-------
(b)) are indicated, along with the justifi-
cation that should be provided when a
specific requirement is waived under
TSCA (761.75 (cX4)) (Under CERCLA
on-site actions must meet substantive,
but not procedural, requirements of other
laws.) TSCA requires that PCBs that are
not incinerated or treated by an equiva-
lent method be disposed of in a chemical
waste landfill; it may be appropriate to
waive certain landfill requirements,
where treatment has reduced the threat
posed by the material remaining at the
site, as is indicated in Table 3.
Exceptions
Treatment of low-threat material may be
warranted at sites involving:
• Relatively small volumes of contamin-
ated material
• Sensitive environments (e.g., wet-
lands)
• Floodplains or other conditions that
make containment unreliable.
In these cases, long-term management
controls may be reduced, as shown in
Table 3, since the concentrations are
lower.
.ontainment of principal threats may be
arranted at sites involving:
Large volumes of contaminated mate-
rial for which treatment may not
be practicable
PCBs mixed with other contaminants
that make treatment impracticable
Highly concentrated PCBs that are
difficult to treat because of their
inaccessibility (i.e.,buriedinalandfill)
Figure 2 - Key Steps In the Development of Remedial Alternatives for PCB-Contamlnated Superfund Sites*
What is the action area
assuming unlimited exposure?
Key
Residential
III
Industrial
XXX Containment
o
Action Area
Boundary
What are principal threats to be treated?
(PCBs at 500 ppm or greater, or more than 2 orders of magnitude above the action level.)
Treat principal threats at least to levels that are to be contained (90-99% Reduction)
1 -100 ppm
100 ppm
or greater
1-100 ppm
Exceptions:
I • Large municipal landfills
I • Inaccessible contamination
How should material remaining at the site be contained?
Exceptions: '
• Small volumes '
• Sensitive exposures ^
• Unreliable containment I
Contain residues and
remaining material
(See Table 3)
| Partially Treat |
••I Treat to levels requiring fewer [
i long-term management controls f
I (See Table 3) |
J j
Fully Treat
Treat to levels for which no j?
long-term management controls [5
(including access restrictions) are p
necessary j?;
.1
• These numbers are guidance only and should not b* treated as regulations.
-------
SELECTION OF REMEDY
Criteria and Balancing Threshold Criteria
The analysis of remedial alternatives foe
PCB-contaminated Superfund sites is
developed on the basis of the following
nine evaluation criteria provid-
ed in the NCP (300.430[e][a][iii];
300.430[f][i][i]). Considerations unique
to PCBs are noted.
• Overall protection of human health
and tht environment. Are all pertinent
exposure pathways being addressed? Are
highly concentrated PCBsbeing treated?
Are remaining PCBs and treatment re-
siduals being properly contained, as out-
lined in Table 3?
• Compliance with ARARs. Does the
action involve disposal of PCBs at con-
centrations greater than or equal to SO
ppm? IstheactionconsistentwithTSCA
treatment requirements? Is the action
consistent with chemical waste landfill
requirements, with appropriate TSCA
waivers specified for landfilling of
material that does not meet treatment re-
quirements? Is a RCR A hazardous waste
present? Do California List land dis-
Table 3 - Selection of Long-Term Management Controls To Be Considered for PCB-Contamlnated Sites
-------
Table 3 - Selection of Long-Term Management Control* To Be Considered for PCB-Contamlnated Sites
LONG-TERM MANAGEMENT
CONTROLS RECCOMENDED
CHEMICAL WASTE
LANDFILL REQUIREMENTS
POTENTIAL BASIS FOR TSCA WAIVER (761.75 (c) (4))
OF INDICATED CHEMCAL WASTE LANDFILL REQUIREMENT(S)
S1
MO
10-25
25-100
100-500
>500
Al Depths
Al Depths
Al Depths
Al Depths
3-50 Fee*
>50Feet
3-50 Feel
> 50 Feel
• Nomestricled Access
• Nonroslricted Access
• Limited Access
• Dood Notice
• Restricted Access
• Fence
• Deed Notice
• Rastrided Access
• Fence
• Deed Notice
• Restricted Access
• Fefice
• Deed Notice
• Restricted Access
• Fence
• Deed Notice
• Restricted Access
• Fence
< Deed Notice
Clean Closure
Hybrid Closure
Hybrid Closure
Landfill Closure
Landfill Closure
Landfill Closure
Landfill Closure
Minimum
Technology
Landfill Closure
Minimum
Technology
2
X
X
X
X
X
X
X
X
X
X
X
X
X
5
X
X
X
X
X
X
4
4
4
4
4
X
X
X
X
X
1
J
X
X
X
X
X
X
X
X
X
X
X
X
No waivers required; clean closure
Low PCB concentration
Design and Installation ot a protective cover system
Evaluation ol PCB migration to GW and SW
Low PCB concentration
Design and Installation ot a protect** cover system
Evaluation ol PCB migration to GW and SW
Relatively low PCS concentration
Implementation of a GW monitoring program
Evaluation ol PCB migration to GW and SW
Design and installation of a protective cover system
Implementation of GW monitoring program
Design and Installs bo ol a protectto cover system
Evaluation ol PCS migration to GW and SW
Design and Installation ol a protective cover system
Demonstrate sufficient depth to GW lo protect human health tnd
the environment
Evaluation ol PCB migration to GW and SW
Demonstrate other long-lerm management controb to provide
adequate protection ol GW
Demonstrate sufficient depth lo GW and long-term management controls
lo protect human health and the environment
Implementation of GW monitoring program
Evaluation ol PCB migration lo GW and SW
GW . ground waler; SW - surface water
1 Cover system may range from 12" soil cap lor low concentrations to a full RCRA cap lor concentrations exceeding 500 ppm.
J The need lor a cover system wil depend on the land use (i.e., residential or industrial).
40 CFR 761.7S(b)(3) requires lhat landlih be located at least 50 feet above the high-water table.
4 In accordance with 40 CFR 761.7S(b)(4) if the site is located below the 100-year lloodwater elevation, diversion dikes shall be constructed around the perimeter ol the landfill site with a minimum
equal lo 2 feet above the 100-year lloodwater elevation. Flood protection lor landfills above the 100-yearIbj^ier elevation is not applicable lo closed land!ill units.
j * ste » located in a permeable lormation, incorporation of this long-term management control should b8
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posal restrictions (LDRs) apply? Is the
action consistent with LDRs or treatabil-
ity variance levels where appropriate? Is
contaminated ground water that is poten-
tially drinkable being returned to drink-
able levels or is support for a technical
impracticability waiver provided?
Balancing Criteria
• Long-term effectiveness and perma-
nence. Are highly concentrated PCBs
being treated? Are low-concentration
PCBs being properly contained, as out-
lined in Table 3? Is the site in a location
that geographically limits the long-term
reliabilityof con tainment(e.g.,high water
table, floodplain)?
• Reduction of toxichy, mobility, or
volume through treatment. Is there a
high degree of certainty that the treat-
ment methods selected will achieve at
least a 90 percent reduction of PCBs?
Does treatment increase the volume of
PCB-contaminated material that must be
addressed either directly (e.g., solidifi-
cation) or through the creation of addi-
tional waste streams (e.g., solvent wash-
ing)?.
• Short-term effectiveness. Is the short-
term inhalation risk resulting from vola-
tilization of PCBs properly addressed?
What is the relative timing of the differ-
ent remedial alternatives?
• ImpIementability.Doesthetreatment
selected require construction of a system
onsite (e.g., KPEG, solvent washing)?
Does the action require extensive study
to determine effectiveness (e.g., biore-
mediation)? Are permitted facilities
available for alternatives involving off-
site treatment or disposal?
• Cost.
Modifying Criteria
• State acceptance
• Community acceptance
Likely Tradeoffs Among Alternatives
Primary tradeoffs for PCB-contaminated
sites will derive from the type of treat-
ment selected for the principal threats
and the determination of what material
can be reliably contained. Alternatives
that require minimal long-term manage-
ment will often provide less short-term
effectiveness and implementability be-
cause large volumes of contaminated
material must be excavated and treated.
They will generally be more costly but
will provide high long-term effective-
ness and permanence and achieve sig-
nificant reductions in toxicity and vol-
ume through treatment. Alternatives that
involve containment of large portions of
the contaminated site will generally have
lower long-term effectiveness and per-
manence and achieve less toxicity or
volume reduction through treatment.
However, they will generally be less
costly, more easily implemented, and
have higher short-term effectiveness.
DOCUMENTATION
A ROD for a PCB-contaminated Super-
fund site should include the following
components under the Description of
Alternatives section:
• Remediation goals defined in the FS
for each alternative, i.e., concentrations
Sabove which PCB-contaminated mate-
rnal will be addressed arid concentrations
•above which material will be treated::
« Treatment levels to which the selected
-action will reduce PCBs before redepos-
iting residuals. The consistency of these
levels with TSC A requirements and other
ARARs should be indicated.
• Long-term management controls that
will be implemented to contain or limit
access to PCBs remaining onsite. The
consistency with RCRA closure and
TSC A chemical waste landfill require-
ments (and justification for appropriate
TSCA waivers) should be indicated.
NOTICE
Development of this document was funded by the United States Environmental Protection
Agency. It has been subjected to the Agency's review process and approved for publication
as an EPA document.
The policies and procedures set out in this document are intended solely for the guidance
of response personnel. They are not intended nor can they be relied upon, to create any
rights, substantive or procedural, enforceable by any party in litigation with the United
States. EPA officials may decide to follow this guidance, or to act at variance with these
policies and procedures based on an analysis of specific site circumstances, and to change
them at any time without public notice. "<
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U.S. EPA REGIONAL DISPOSAL CONTACTS
• Tzr.r.ec t i cu- , :-:a i r.e , Xa ss ac r.us e - -.3 .
Rhode Island, Vermont:)
Tony Paierr.o
Air Management Division
Environmental Protection Agency, Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
(-617) 565-3279, FTS 835-3279
Region II
(New Jersey, New York, Puerto Rico, Virgin Islands)
John Brogard Dan Kraft
Air and Waste Management Division FTS 340-6669
Environmental Protection Agency, Region II
26 Federal Plaza
New York, New York 10278
(212) 264-8682, FTS 264-8682
Region III
(Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia)
Edward Cohen (3HW40)
Hazardous Waste Management Division
Environmental Protection Agency, Region III
841 Chestnut Street
Philadelphia, Pennsylvania 19107
(215) 597-7668, FTS 597-7668
Region IV
(Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee)
Robert StryJcer, PCB Coordinator
Pesticides and Toxic Substances Branch
Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-3864, FTS 257-3864
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?es-:r:r = s =r.i Toxic Substances Branch < 5S-?7S3-7:>
Er.vi r "j-er.ial Protection Agency, Region V
230 South Dearborn Street
Chicaco, Illinois 60604
(312)"353-1428, FTS 886-6087
Region VI
(Arkansas, Louisiana, New Mexico, Oklahoma, Texas)
Jim Sales ' Donna Mull ins
Hazardous Waste Management Division FTS 255-7244
Environmental Protection Agency, Region VI
Allied Bank Tower
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 655-6719, FTS 255-6785
Region VII
(Iowa, Kansas, Missouri, Nebraska)
Leo Alderman, PCB Coordinator
Doug Elders
Toxic and Pesticides Branch
Environmental Protection Agency, Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
(913) 236-2835, FTS 757-2835
Region VIII
(Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming)
Dan Bench (303) 293-1732, FTS 330-1732
Tom Pauling (303) 293-1747, FTS 330-1747
Paul Grinun (303) 293-1443, FTS 330-1443 - 7,^ V " ^ ^> 7
Toxic Substances Branch
Environmental Protection Agency, Region VIII
One Denv»r Place
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
(303) 293-1442, FTS 564-1442
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'3 r -r :: .' z a ; -co vs .< ; • . - 5 -1 ; .
Pesticides a.r.d Toxics Brar.cr.
Envi rorir.er.t ai Protection Agency, Region IX
215 Fremont Street
San Francisco, California 94105
(415) 974-7295, FTS 454-7295
Region X
(Alaska, Idaho, Oregon, Washington)
Cathy Massimino (HW-114) Bill Hedgebeth
Hazardous Waste Management Branch FTS 399-7369
Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
(206) 442-4153, FTS 399-4153
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