-United bates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R03-88/051
June 1988
Superfund
Record of Decision
Southern Maryland Wood, MD
-------
REPORT DOCUMENTATION I-TCPOHT NO. 2.
PAGE EPA/ROD/R03-88/051
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Southern Maryland Wood, MD
First Remedial Action - Final
Authors)
9. Performing Organization Nam* and Address
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, s.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
06/29/88
6.
8. Performing Organization Rept. No.
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Southern Maryland Wood Treating (SMWT) site is located in Hollywood, St. Mary's
County, Maryland. The site is situated within a wetland area in a drainage divide such
that runoff from the site discharges into Brooks Run and Mclntosh Run tributaries, which
flow into the Potomac River.. The area surrounding the site is predominantly used for
agricultural and residential purposes. From 1965 to 1975, SMWT operated as a pressure
treatment facility for wood preservation. Currently, part of the site is being used as
a retail outlet for pretreated lumber and crab traps. The waste generated at the site
Deluded retort and cylinder sludges, process wastes, and material spillage. These
Pastes were in six onsite unlined lagoons. An onsite freshwater pond became
contaminated during the facilities active and inactive periods with VOCs, polynuclear
aromatics (PNAs), and base/neutral extractables due to contaminated ground water and
surface runoff, cleanup actions were initiated in 1982 following legal actions by the
Maryland Department of Health and Mental Hygiene. Liquids removed from the six lagoons
were spray irrigated onto the nearby woods. The six lagoons were excavated, backfilled,
and graded, and the freshwater pond was partially excavated. The excavated sludges were
mixed with composited sludge and topsoil, and spread in a level treatment area located
on the property. The primary contaminants of concern affecting the onsite ground water,
(See Attached Sheet)
17. Document Anajvsis. a. Descriptors
Record of Decision
Southern Maryland Wood, MD
First Remedial Action - Final
Contaminated Media: debris, gw, sediments, soil, sw
Key Contaminants: pNHs, VOCs
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
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EPA/ROD/R03-88/051
Southern Maryland Wood, MD
{first Remedial Action - Final
16. ABSTRACT (continued)
soil, surface water, sediments, and debris include: VOCs, PNA, and base/neutral acid
extractables.
The selected remedial action for this site includes: excavation/dredging of soils,
sediments, tank liquids, and cement, and treatment using onsite incineration with onsite
disposal of non-hazardous residual ash, backfilling, regrading, and revegetating, where
necessary; installation of a slurry wall; dewatering of the slurry wall area by a ground
water and surface water pumping system, and treatment using activated carbon adsorption
or hydrogen peroxide and irradiation with discharge to the onsite pond; installation of
a geotextile silt fence, sedimentation basins, and/or diversion; and ground water,
surface water, environmental, organic vapor, and dust monitoring.
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THE SOUTHERN MARYLAND WOOD TREATING
RECORD OF DECISION
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Record of Decision
Declaration
Site Name and Location
Southern Maryland Wood Treating Site
Hollywood, Maryland
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Southern Maryland Wood Treating (SMWT) Site developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986, ("CERCLA") and, to the greatest extent
practicable, is not inconsistent with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 400.
This decision is based upon the contents of the administrative
record for the SMWT Site.
The State of Maryland concurs with this remedy; however, their
concurrence is conditioned on the actual cost of the remedy (as
determined through the remedial design and bid selection process)
being substantially less than that estimated in the feasibility study.
The Maryland Department of the Environment (MCE) believes that
substantial reductions in actual costs will be experienced for several
of the major cost items identified in the feasibility study. MDE is
currently exploring the expected magnitude of those reductions and
suggests that EPA give close scrutiny to this issue throughout the
design phase of the project. In the event that the expected substan-
tial reductions are not evidenced at the conclusion of the design
and/or bid process, MDE has requested and EPA has agreed that the
remedy will be re-evaluated.
Description of the Remedy
Th» selected remedy consists of a final operable unit of on-site
thermal treatment of excavated soils, sediments, and other materials
at the site that exhibit concentrations of contaminants above the
risk-based levels established in the public health evaluation.
Soils remaining in the ground would be covered with clean fill
and possibly backfilled with non-hazardous ash from the incinerator
process. As needed, groundwater and surface water would be treated
and discharged on-site.
The function of the selected remedy is to eliminate contaminants
at the SMWT site as a source of groundwater and surface water contamin-
ation and to reduce or eliminate the risks associated with exposure
to contaminated surface water, soils, and sediments.
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[Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost effective.
The remedy satisfies the preference for treatment that reduces
toxicity, mobility, or volume as a principal element. Finally,
it is determined that this remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable. Since this remedy will not result in hazardous
substances remaining onsite above health based levels, the five
year facility review would not apply to this action.
Date -.-—^Tjarnes H. Se>?
x^Tfegional Administrator
-^ Region III
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The major components of this alternative involve the following
activities:
- Dredging of all contaminated sediments to the risk-based
cleanup level established for this site, and excavation of
contaminated soils at the site to risk-based cleanup levels,
and to cleanup levels established for subsurface soils.
Included are the following tasks:
- Installation of geotextile silt fences, sedimentation basins,
and/or diversion/surface management to control off-site soil
transport. •
- Installation of a slurry wall to cut off ground-water
migration through the process/pond excavation area.
- Dewatering of the area contained within a slurry wall by a
well pumping system and treatment of the groundwater/surface
water by activated carbon adsorption or hydrogen peroxide
(I^O^) and UV irradiation with discharge to the onsite pond.
- Excavation of surface and subsurface soils in the pond/process
and land treatment areas. Excavation of surface soils in the
upper site and northeast tank area. Dredging of sediments in
the pond"and west tributary.
- Organic vapor and dust monitoring.
- Dewatering of sediments and soils prior to treatment, as neces-
sary; further treatment of the generated waters by activated
carbon adsorption or f^O^ and UV irradiation; and discharge
on-site.
. On-site incineration of the contaminated materials such as the
excavated/dredged soils, and sediments, cement, and tank liquids
(would require air pollution controls), and on-sita disposal of
non-hazardous incinerator ash in previously excavated areas.
. Backfill/ regrade, and revegetate, where necessary.
. During and post-treatment groundwater/surface water monitoring
consisting of selected Hazardous Substance List (HSL) analyses.
. Environmental monitoring consisting of sediment and surface water
analysis, benthic and other biological monitoring needed to measure
the degree of cleanup achieved at the site.
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Sacori of Decision
ROD Decision Summary
I. Site :isne, Location, and Description
The Southern Mar/land Wood Treating (3'IWT) site is located off
toute 235 in Hollywood, St. Mary's County, Maryland. A regional
location map is shown in Figure 1. The site comprises approximately
25 acres in the northwest portion of a 96-acre property. About four
acres were previously devoted to a wood treatment operation. The
site is surrounded by residential and agricultural areas.
The 3M17T site is located within the Atlantic Coastal Plain
Physiographic province. Topographic relief across the site is about
35 feet, with elevation ranging between approximately 119 to 154 feet
above sea level. The 3I-IWT site lies on a drainage divide such chat
runoff from the site discharges to tributaries that straddle the site
to the east and west. Both of these tributaries discharge to the
Potomac River via Brooks Run and Mclntosh Run. Regionally, the site
is located close to the drainage divide between the Potomac and
Patuxent River Basins.
II. Site History
The SMWT facility was owned and operated by Southern Maryland
Wood Treating Co. from 1965 to 1978 as a pressure treatment facility for
wood preservation. A site sketch, indicating the locations of various
features, structures, and surface water bodies on the site, as well as
the property boundary, is shown in Figure 2.
Available information indicates that creosote and pentachlorophenol
(PCP) were used as wood preservatives at the facility. Wood treatment
activities are no longer being performed at the site. Presently, however,
a portion of the site is leased to Ridge Marine sales for use as a retail
outlet for pretreated lumber and crab traps.
The wastes generated at the SVvMT site included retort and cylinder
sludges, process wastes, and material spillage. Here wastes were disposed
of in six unlined lagoons on-site. An on-sita freshwater pond became
contaminated with volatile organic compounds (VDC's), polynuclear aromatics
(PNA's), and other base neutral extractables (BNAS) during the facility's
active and subsequent inactive periods from contaminated groundwater and
surface runoff.
Pursuant to legal actions taken by the Maryland Department of
Health and Mental Hygiene the Potentially Responsible Party (PRP),
L.A. Clarke and Sons, Inc., initiated clean-up actions at the site in
1982. Liquids from the lagoons were spray irrigated onto the nearby
woods. The six waste lagoons were excavated and the area was backfilled
and graded. The freshwater pond was partially excavated. Excavated
sludges were mixed with composted sludge, topsoil, and grass seed, then
spread in a level treatment area on the property.
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0 1O 20 30 40
Southern Maryland
Wood Trailing SJU
Fiquce 1.
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PRIMARY FEATURES AT THE SMWT SITE
Figure 2
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-9-
Synopsis of Previous Investigations
August 1982 - Field investigation conducted by EPA Region III.
Included Sampling of domestic wells, monitoring
wells, surface waters, soils, and sediments.
October 1984 - Site assessment performed by EPA Technical Assistance
Team. Sampling results, however, could not be validated.
Decemoer 1984 - Domestic '/Veil Sampling revealed no contamination in off-
site domestic wells.
January 1985 - Site assessment sampling. Tank, soil core, sediment,
surface water and monitor well samples were collected
for analyses. Sampling confirmed contamination from
PNA and PCP in surface water and sediments of the
freshwater pond and west tributary, on-site soils, and
an on-site monitoring well. Tank sludge samples were
contaminated with chlorinated dibenzodioxins.
Previous Removal Actions
March 1985 - A remedial removal action was begun with 350 samples
obtained and analyzed at the site. Data indicated a
widespread distribution of contaminants throughout the
site. Higher contaminant concentrations were detected
in saraples from the process area, former lagoon area,
land treatment and spray irrigation areas.
April 1985 - Straw filter fences were installed to control downstream
migration of sediments along the west tributary.
January 1986 - Approximately 1400 Y/D3 of soil were excavated from the
the northwestern bank of the freshwater pond and stored
on-site. The excavated soils were placed onto a synthetic
liner to the east of the former lagoon area and
capped with a synthetic cover.
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Site Characterization
The Remedial Investigation/Feasibility Study (RI/FS) for the
S'r,.T size was performed in a phased manner. The rssuits of each
phase were used to focus data requirements of successive phases and
provide support to the remedial alternative analysis. The objectives
of and scope of the three RI phases for this site are shown in
Taoies _1, 2, and 3_«
The results of sampling and analysis for the RI Phases are sum-
marized oelow:
I. Groundwater Quality
a) Residential Well tfater Quality
No contaminants of concern were detected in any resi-
dential well samples off-site from the SM17T facility.
b) On-Site Groundwatar Quality
On-site shallow groundwater contamination appears to be localized
in an area roughly bounded by monitor wells MW-03, MW-12, and MW-05,
as shown in Figure 3_, The shallow groundwater flow in the contaminated
area is directed towards the on-site pond. The pond, therefore,
represents a local discharge point for shallow groundwater and associated
contaminants. Seeps of black hydrocarbon-like liquid have been observed
along the eastern edge of the on-site pond.
Analytical results from the deep monitor well samples suggest that
there is no contamination of the deeper water-bearing strata directly
underlying the site. A clay and silt layer separates the shallow
groundwater in the upland deposits and the deeper water bearing zone.
The clay and silt layer has restricted the downward migration of
groundwater contaminants from the shallow zones to deeper zones.
Overall, the Phase II and Phase III analytical results indicate that
the groundwater contamination at the site is confined to the saturated
deposits above the clay and silt layer in a relatively limited area as
shown in Figure _3«
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Overview of Phase I RI Activities
Objective
Scope Activities
Determine the location of
monitor wells and soil
sampling locations.
Determine groundwater
flow rate and direction
from existing on-site
wells.
Define analytical
requirements.
Develop a rapid-turn-
around field screening
method for PNAs.
Geophysical investigation
using ground penetrating
radar and terrain conduc-
tivity.
Conduct permeability tests
and measure water level
elevations.
Collection of two soil
samples and one sediment
sample from areas expected
to be highly contaminated.
Analysis of these samples
for Hazardous Substance
List (HSL) parameters.
Laboratory testing to
develop and validate the
extraction and analytical
techniques.
Table 1
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Overview of Phase II RI Activities
Objective
Scope Activities
• Characterize on-site and
local air quality.
Define the type, degree,
and extent of soil con-
tamination. Understand the
local stratigraphy.
Define the type, degree,
and extent of shallow
groundwater contamina-
tion. Define shallow
groundwater flow direc-
tion.
Investigate the impact of
the site on local residen-
tial walls.
Evaluate the role of
surface waters as a
contaminant migration
pathway.
Characterize the quanti-
ties and types of mate-
rials in on-site tanks.
One round of air sampling
with analysis Cor volatile
organic compounds, PNAs,
and pentachlprophenol.
Real-time air monitor-
ing for volatile organics
using HNu and/or OVA and
for respirable dust using
a mini-RAM.
Construction of soil borings
and test pits, and collect-
tion of soil samples.
Analysis of soil samples by
on-site PNA screening,
laboratory analytical
methods, and geotechnical
tests.
Installation
wells.
of monitor
Analysis of groundwater
samples by on-site PNA
screening and laboratory
analytical methods.
Sampling and analysis of
selected residential wells
Sampling of surface waters
and sediments from the east
and west tributaries, Brooks
Run, and Mclntosh Run.
Analysis of samples by PNA
screening and laboratory
analytical methods.
Sampling and analysis of
tanks and volumetric deter-
mination of tank contents.
Table 2
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Overview of Phase III RI Activities
Objective
Scope Activities
• Confirm groundwater flow
direction near the freshwater
pond.
• Further evaluate the type,
degree, and extent of shallow
groundwater contamination.
Evaluate the potential for
migration of contamination
to lower water-bearing zones
• Determine the level of con-
tamination of the on-site
buildings and sheds.
• Determine presence of
dioxins/furans in site ground-
water, subsurface soils, and
buildings.
• Evaluate the technical
feasibility of construc-
tion technologies proposed
in the remedial alternatives.
Install one shallow
well northwest of the
freshwater pond.
Sample the one newly-
installed shallow Phase
III well and resample the
12 existing wells.
Install and sample
three deep wells to the
first water-bearing
zone below the upper
aquifer.
Obtain surface samples
of on-site buildings
and sheds.
Analyze samples from
groundwater, subsurface
soils/ and buildings for
dioxins/furans.
Install four shallow
soil borings to obtain
split-spoon samples for
geologic logging and
Shelby tube samples for
geotechnical analysis.
Table 3
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— MW-07
~~MW-OS;
MW-17/:
MW-18 •
-;i m.
*v^
MW-tS^ MW-21
X
7"MW-13
/
# \
^~^\.
MW-03
• .^
>MW.Q2
*>
X
LEGEND
/
/
X^»
OF SHALLOW
WAT9 CONTAMNAT1ON
• SHALLOW QBOCK3 WATER MONITOR WELL
^ DEEP fl«OCK) WATER MONITOR WELL
Seal* in F««t
5ZS
250
500
SHALLOW GROUND WATER CONTAMINATION MAP
Figure 3
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-4-
The shallow-groundwater in the contaminated area contains volatile
and semi-volatile contaminants in the tens-to-nundreds of parts per
million range (Table 4_). The most commonl/ occurring volatile organics,
base neutral/acid extractable and PNA compounds found in the water samples
are listed in Table _5. Many of tnese compounds are at least partially
water soijole and ^ould be expected to migrate in the shallow groundwater.
The concentrations of acenapthene, fluorene, and phenanthene in ground-
water samples were in excess of the reported solubilities of these compounds
in water. Furtnermore, a dense, non-aqueous phase liquid was found at the
interface of the shallow aquifer and clay layer in wells MW-08 and MW-il.
Groundwater samples from selected shallow-monitoring wells were also
analyzed for chlorinated-dibenzodioxins and dibenzofurans. The
2,3,7,3-tetrachloro-dibenzodioxin (TCDD) toxicity equivalent factors (TEF)
reported for the groundwater samples were below 0.01 ug/L and are therefore
below the action level.
II Ambient Air Quality
Both real-time and time-weighted air monitoring samples taken both
on-site and around the site perimeter, showed no contaminants of concern in
concentrations that would need to be addressed in a remedial action at the site,
III Soils
a) Surface Soils
Analytical results for surface soil samples (0-2 foot depth interval)
are summarized by areas in Table 6_. (The areas described are shown in
Figure £). The most frequently identified organic compounds are listed
in Table !•, dioxin/furan results are shown in Table j3.
Hazardous Substances List (HSL) organic contamination in the surface
soils is widespread and does not follow any specific pattern. The analy-
tical results are consistent with the operating history and remedial
activities that have occurred at the site.
Surface soils in the land treatment area are the most contaminated
surface soils at the SMWT site, consistent with the land fanning of
lagoon sludges, in this area. The maximum total FNA concentrations in
the land treatment area was 4,120,000 ug/ka ppb).
Surface soils in the. excavated lagoons area also contain elevated
concentrations of PNA's. The northern part of the site, including the
northeast tank area and the upper site area, showed widely variable
contaminant concentrations. These results are consistent with the use
of this area to store finished products.
The surface soil samples from the vicinity of the freshwater pond
contained no detectable or low part-per-million levels of contaminants.
Soils in the process area contained up to 1290 ugA<3 of PNAS; no
organic contaminants were detected in surface soil samples from the
spray irrigation area.
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SUHHARY OF ANALYTICAL RESULTS FOR GROUND WATER SAHHLS
(All results in ug/L)
BTX
Phase Phase
II III
MU01 NO NO
NUOI Oup NO
HU02 NO NO
NU02 Oup NO
HU03 NO • NO
MU04 602 370
HU05 NO NO
NU06 NO NO
HU07 NO NO
HUOS 2840 1280
HUOa Oup
HU09 123 38
HU09 Dup 31
HUIO NO NO
NU11 460 440
MM12 300 160
HUI3 NO NO
HUM NO NO
HV15 NO NO
HUI6 1420 1360
HU16 Oup 336
HU17 NO NO
HU18 NO
HUI9 1
HU20 NO
HU21 1
TOTAL
PNAS
Phase Phase
II III
NO NO
NO
NO NO
NO
2 NO
5391 972
1647 NO
NO NO
NO NO
92290 20463
92 1083
1111
NO NO
9232 I37S2
280 2147
NO NO
NO NO
21 NO
90200 11599
58410
1 NO
NO
NO
NO
NO
PCP
Phase Phase
II III
NO NO
NO
NO NO
NO
NO NO
1300 3300
920 NO
NO NO
NO NO
5000 NO
i
NO NO
1300 670
500 NO
NO NO
NO NO
NO NO
1500 59
1100
NO NO
NO
NO
NO
NO
OTHER ACID
EX TRAC TABLES
Phase Phase
II III
4 2
NO
NO NO
NO
2 NO
8000 21700
1670 NO
NO 35
NO NO
46600 10900
886 33
40
NO NO
37600 15200
830 1300
NO 2
NO NO
NO NO
4930 890
3530
NO NO
NO
NO
NO
2
OllllR
BNAS
Phase Phase
II III
I
}
42 S
130 130
43 NO
NO NO
NO 2
7900 1300
19 106
105
NO NO
420 970
22 63
NO 11
NO NO
NO NO
4100 670
4900
NO 3
2
NO
NO
2
OIOXINS
ANO
FUHAHS (1)
Phase Phase
II III
0.111
o.oss
0 OU'J
0.184
0.000 00.' S
0.0)1
(2) 0.20J
0.03
O.t>4b
(I) OIOXIN/FURAN OATA IS TOXIC EQUIVALENT FACIOR (TEF) IN mj/l I OR PHASE II ANO iuj/l FOR I'HAM
(2) VAIUE COUIO NOT BE CA1CUIAIFD DUE TO SEVERE HAIRIX EFFECTS I OR TETRA/PENTA
CONGENERS. HEXACHlURlNAfEO DIBENZOOIOXINS ANO UIBINZOIUUAN^ ULkC OETECTEO IN IHIS SAHPl I .
T.»hlo 4
-------
Organic Compounds Most Frequently Identified
in Groundwater Samples
Volatile Organic
Compounds
Polynuclear
Aromatics
Hydrocarbons
Other Base/
Neutral/Acid
Extractables
Benzene
Toluene
Xylene
Ethylbenzene
Styrene
Anthracene
Acenaphthene
Chrysene
Pentachlorophenoi
Phenol
2-methylphenol
Benzo(a)anthrocene 4-methylphenol
Benzo(a)fluoranthene 2-4-dimethylphenol
Benzo(k)fluoranthene Dibenzofuran
Benzo(a)pyrene
Naphthalene
2-methylnaphthalene
Acenaphthylene
Fluorene
Phenanthene
Fluoranthene
Pyrene
Table 5
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\
soo
SITE SKETCH SHOWING DESIGNATED AfteAS
Figure 4
-------
SUMtl II IMIIIU «M»<« MUM
•Ml
KM «UHM fHll
UHMCI UMCI SOUUM Ml M
MIS (I) MIS ID (••*
ICI*
IMM «IMM OMMM (•*!* IMH IIM> •».«. tin
l«w»H
|.MI 4.M.4M l.ltl
W.MI 4.W.MI
• • • <».«** Mi.M* •».«»
U.M
i i 14 441? 1>M • • a I
II.IA
* li i II 4.(N • IM ft i
14.444
• n »u MM »u *otl
l».*4
U 4.) 4. Ill Mt4t 1 1 H :
I4.VM
li II ll.MI » t I
t) »44 H.M •)! ttuii
• )l •»» 4.4W » II IN On
l».M»
i: 24
%"
/ 141
.' • 14
^
t II
.' 41
tl «MMll
Table 6
-------
Organic Compounds Most Frequently Identified
in Surface Soil Samples
Volatile Organic
Compounds
Polynuclear
Aromatic
Hydrocarbons
Other Base/Neutral
Eztractables
Acetone
Toluene
Ethylbenzene
Styrene
Xylenes
Fluroanthene
Pyrene
Benzo(a)anthracene
Benzo(a)pyrene
Dibenzofuran
Table 7
-------
Summary of Dioxin/Furan Results
for Surface Soil Samples
Area
Upper Site
Northeast Tank
Freshwater Pond
Land Treatment
Process
Excavated Lagoons
Sample
Number
81-001
SS3-001
SS6-002
SS6-003
T10-002
T10-001
82-001
B3-001
B4-001
87-001
810-001
89-001
813-001
811-001
Total
TEF (ug/kg)
0 .000
0.000
0.000
0.000
0.017
0.036
0.000
0.426
0.438
0.006
0.024
0.765
0.079
0.161
Table 3
-------
-3-
The dioxin congeners found in surface soil samples were che nore
hi.jhly chlorinated, relatively less toxic forms, Although hepta-and-
octa-chlorinated dibenzodioxins were detected in all surface soil
samples, and hexa-chlorinated dibenzodioxims were found in seven of
13 surface soil samples, all of the compounds exist at levels well
oelow £?.Vs established action level for these compounds. :-to tetra-
jhlorinaced dioenzodioxin were detected in the surface soil samples.
o) Subsurface Soils
Subsurface soils are defined as those encountered oelow a depth
of two faec. The analytical results for subsurface soils area summar-
ized oy area in Table _9« Tne most frequently identified organic
compounds are listed in Table 10.
Except in those areas with a long history of waste disposal, the
organic contaminants are confined to the upper 10 feet of soil. In the
process and excavated lagoon areas, the contaminants were encountered
down to the clay and silt layer. The organic compounds most commonly
identified in the subsurface soils include more mobile FNA's (napthalene,
2-methyl-napthalene) and acid extractables (phenol, 2-methylphenol,
2,4 - dimethylphenol). These parameters are also found in groundwater
samples, but not commonly found in surface soil samples.
Soil samples collected from the Phase III soil borings were analyzed
for chlorinated dibenzo-dioxins/furans. Like the background soils, the
hepta - and octa - chlorinated dibenzo - dioxin/furans (the relatively
less toxic forms) represent the highest percentage of cogeners found in
the subsurface samples.
IV Tanks and Retorts
Excluding a propane storage tank and the boiler treatment water make-
up tank, 14 tanks and two retorts were found on site. The locations of
these tanks and retorts are depicted in Figure _5. Table _11 summarizes
the analytical results for the tank samples.
A total of approximately 11,960 gallons of non-TCDD dioxin contami-
nated wastes are present in Tanks 3,4,5,9,10, and 12. Due to the simi-
larity of appearance to the material in Tanks 9 and 12, the waste in Tank
10 is also assumed to contain dioxins.
Additionally, a total of approximately 2,140 gallons of tank wastes
do not contain dioxins.Of these 2,140 gallons, all contain total volatile
organic compounds concentrations greater than 300 ppb, and 2,100 gallons
contain total FNA concentrations of 191,000 ppb.
V Surface Water and Sediments
The analytical results for surface water and sediment samples are
summarized in Table 12.
-------
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-------
Organic Compounds Most Frequently
Identified in Subsurface Soil Samples
Volatile
Organic
Compounds
Polynuclear
Aromatics
Hydrocarbons
Other Acid
Eztractables
Other
Base/Neutral
Extractables
Toluene
Ethylbenzene
Styrene
Xylenes
Naphthalene Phenol Dibenzofuran
2-methylnaphthalene 22,4-dimethylphenol
Acenaphthene
Fluorene
Phenanthrene
Fluoranthene
Pyrene
Pyrene(k)fluoranthene
Table 10
-------
^
\
./ Building 1
-Building 2
Tank to 7
Location of
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Tank /•
Location
*N .^-T13
Shad 3 f\f 1
iZ*ZZ^'~- T12y
L*g«nd
T* Tank
Seal* in P««t
=B—^
250 500
SITE STRUCTURES AND TANKS
Figure 5
-------
Table 11
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-------
Table 12
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-------
-ta-
in tne sadiment samples collected along the west tributary/
total ?NA concentrations in the cens of parts per million wera
encountered up to 1,900 feet downstream of the freshwater pond,
at the confluence of the east and west tributaries. Surface water
concentrations of organic contaminants ara in the" tans to hundreds
of parts per billion along this section of stream.
Along the east tributary, contaminant concentrations in sedi-
ments ranged from nondetectable to approximately two parts per million.
Surface water contaminants range from nondetectable to parts per billion,
At distances between 4/450 and 7,125 faet from (below the
confluence of East and West Tributaries) from the freshwater pond,
sediment contamination ranges from nondetectable to 41 ug/kg of PNAs,
while surface water contamination was not detected. Table _L3 provides
a summary of the most frequently identified organic contaminants in
surface water and sediments. The contaminants detected in the surface
water samples are similar to those compounds found in groundwater.
Sediment results are similar to results obtained for the surface soils.
This data supports two pathways of contaminant migration at the site.
The transport of contaminants from surface soils to stream sediments
through surface runoff/erosion is indicated by the data and the low
cohesive strength of the site soils. Additionally, the direct discharge
of contaminated groundwater into the freshwater pond is supported by the
similar contaminants in both media and visual observation of seeps along
the pond bank, and the presence of contaminants in surface water and
sediments.
Results of 0-to 6 inch and 6- to 12- inch sediment samples analyzed
by a UV screening method were compared. This comparison indicates that
samples from the 0-to 6- inch and 6- to 12- inch sample intervals typi-
cally contain KJA concentrations within the same order of magnitude.
This is consistent with the long-term deposition of sediments carrying
contaminants from upstream sources and does not indicate significant
changes in contaminant concentration over time.
Although dioxins and furans were detected in surface waters and
sediments, toxicity equivalent factors were at or below 0.010 ppb.
No tetra - or penta - chlorinated dibenzodioxins were detected in
surface water or sediment samples.
Comnunity Relation History
There has been ccranunity interest in the Southern Maryland Wood
Treating site since before the wood treating facility was built in
1965. Several individuals reported that nearby residents informally
protested the construction of an industrial facility on the property,
as the residents hoped the land would be used for residential develop-
ment .
After the Southern Maryland Wood Treating plant was built and
operations began, residents living nearby complained to county health
officials of strong creosote-like odors coming from the site. As a
follow-up to these complaints, the St. Mary's County Health Department
sampled air quality around the site, but the results of tests were
inconclusive.
-------
Table 13
Host Frequently Identified Organic Compounds
In Surface Water and Sediments
Volatile
Other
Other Acid Base Neutral
Organic Comoounds PNAs ' Extractables Extractables
Surface
Mater
Benzene
Toluene
Surface
Sediments Mater
Benzene Fluorene
Toluene Fluoran-
thene
Surface Surface
Sediments Mater Sediments Water Sediments
Fluorene Phenol -- Dibenzo- Oibenzo-
furan furan
Phenan- 2,4-di-
threne methyl -
phenol
Ethylbenzene
Ethylbenzene Fluoran-
thene
Styreue
Xylenes
Pyrene
Benzo(a)-
anthracene
Pyrene
Benzo(k)
fluorauthene
Benzo(a)-
pyrene
-------
ronnunity Relation History (Cont.)
Local officials and residents have expressed continuing interest
in EPA1 s progress ac the site. 3oth nave indicated that they want an
efreceive, permanent remedy and that they wish to be kept appraised
oif new Developments.
Local officials report that no formal community groups have formed
in response to the classification of the Southern Maryland Wood Treating
site as a hazardous waste site. However/ other established community
organizations, such as the Potomac River Association and the Patuxent
River Association, maintain an interest in site findings and develop-
ments. Both groups are concerned with the preservacion of the Potomac
and Patuxent rivers and keep a watcnful eye over conditions and activ-
ities that chreaten tne area's aquatic environment.
In addition, a class of science students attending Chopticon High
School in St. Mary's County has taken an interest in the site. Since
September 1985, the class has studied the Chesapeake Bay and cleanup
initiatives currently being undertaken to preserve the Say's environ-
ment. The teacher of the class believed it was important for students
to get a better sense of current events in their community and how those
events impact the ecosystem of the day. He therefore encouraged
students to follow media coverage of the Southern Maryland Wood Treating
site and research the contamination problems reported in site findings.
As part of that research, a group of students attended the November
public meeting conducted by EPA officials and asked a number of questions
about the extent and effects of contamination found at the site and the
cost of cleanup activities.
Media coverage of the Southern Maryland Wood Treating site has been
extensive in the local press. Recent coverage hs included stories on
public meetings conducted by EPA officials and the completion of removal
activities at the site. County officials report that , in general, the
local press is an important communications vehicle in St. Mary's County.
-------
Remedial Action Objective
Utilizing data generated during the RI, a Public Health Evaluation
(?HE) was conducted to evaluate the potential impacts on public health
and the environment that may result from the release of hazardous subs-
tances frora the Southern Mar/land '.vbod Treating site. A baseline
assessinent vas conducted evaluating tne site in the absence of remedi-
ation and then compared with various potential remedial alternatives
for this site.
For current use scenarios involving the exposure of trespassers
co contaminated soil and sediment, the noncarcinogenic chemicals in
the soil or sediments are not expected to pose a threat to human health
because the hazard indices for tnese exposures are less than one. The
risks associated with exposure to the carcinogenic chemicals under these
scenarios, however, exceed 10~° under the plausible maximum case.
For future use scenarios involving the exposure of construction
workers to contaminated soil, the presence of the noncarcinogenic chemicals
is not likely to pose a threat to human health because the hazard
indices for both the maximum case and the average case scenarios were
less than one. The excess risk of lifetime cancer associated with
exposure.to the carcinogenic chemicals under this scenario, however,
exceed 10~6 under the plausible maximum case.
For future exposure scenarios involving the exposure of residents
to contaminated surface soils, the noncarcinogenic chemicals in the
soil are not expected to pose a. threat to human health under the
maximum or average exposure conditions.
The risk associated with exposure to the carcinogenic chemicals for a
lifetime resident under this scenario, however, exceeds 10"^ under both
the average and the plausible maximum case. This suggests that exposures
to the carcinogenic PNAs may pose some threat to human health under the
conditions .of these assumptions for a potential resident residing at the
Southern rlaryland Site for a lifetime.
Remedial action objectives are long-term, permanent remedies that
eliminate unacceptable risk to human health and the environment. This
is accomolished to the maximum extent practicable through treatment
and/or destruction of contaminants at the site.
The objectives of the proposed remedial actions are to:
* Reduce or eliminate organic contamination in site sur-
face soils to cleanup levels established for contact and
incidental ingestion of carcinogenic polynuclear aromatic
hydrocarbons (PNAs) by future residents (2.2 ppm CPNAs based
on a maximum 1 x 10~^ lifetime cancer risk).
* Reduce or eliminate the organic contamination present in sedi-
ments, the pond, and on-site tributaries of Brooks Run to
cleanup levels established for on-site future residents
(2.2 ppm CPNAs based on 1 x 10"6 lifetime cancer risk)
and prevent off-site migration of contaminants via the
sediment migration pathway.
-------
-3-
* ?ad'jce or eliminate organic contamination in site subsurface
soils to the cleanup level established from the groundwater
infiltration model (1 ppro CPNA based on 1 :< 13~6 lifetime
cancer risk).
* pumping, collection, and treatment of contaminated liquids from
the onsite pond, the pond discharge, and the shallow
groundwater (inside the containment area). Treated water will
be discharged to the pond tributary after treatment to levels
to be established in accordance with appropriate ARARs.
* Reduce or eliminate the threat to the local environment
from existing contaminated storage/process tanks and process
equipment through demolition/remediation of these and any
associated organic contents.
The volume of surface soils, sediments, and subsurface
soils exceeding contaminant concentrations above the established risk
based cleanup levels were estimated for each acea of the site as follows:
. upper site - Volume was estimated assuming removal of top six inches
over 4.9 acres. Estimated volume is 4,000 cubic yards.
. Mortheast tank area - Volume was estimated assuming removal of top
six inches over four acres. Estimated volume is 3,200 cubic yards.
. Land Treatment Area - volume was estimated assuming removal of top
three feet over 2.9 acres. Estimated volume is 1,400 cubic yards.
-------
Subsurface Soils/Contained Area - volume vas estimated assuming
ranoval down to the clay and silt layer over an area of 3.3 acres.
Estimated volume is 90,300 cubic yards.
. process Area - volume was estimated assuming removal of the top
six inches of soil over 2.7 acres. Estimated volume is 2/000
cubic yards.
. West Tributary - Volume was estimated assuming stream excavation
one-foot deep by five-feet wide to 1900 feet downstream of the
on-site pond, volume is estimated to be 1,000 cubic yards; however,
this is most likely a maximum volume and may be less to minimize
disturbance to wetlands.
The total volume of contaminated soils and sediments at the Southern
Maryland Wood Treating site is estimated to be 102,000 cubic yards.
Alternatives Evaluation
The RI/FS for the SMWT site screened a large number of alternatives
which could potentially achieve the remedial objectives at this site,
i.e., reduction of contaminant levels in on-site soils, sediments, and
ground water to levels which eliminate unacceptable risk to human health
or the environment.
A. Preliminary Screening
During the preliminary screening process certain alternatives were
eliminated from further consideration for applicability at this site.
Each eliminated alternative and the reason for its elimination are
listed below:
Alternative Reason for Elimination from Detailed Analysisly.
Soil &±nixtures Cap Less Costly, equally effective materials are
available for capping.
In-situ absorption Insufficient technology; suitable only for
tanporary remediation. Technical problems
with clogging and saturation of treatment
beds.
Supercritical extraction Insufficient information available for
preliminary assessment.
-------
?/rolysis
Wet Air Oxidation
Macroencapsulation
Ion Exchange
Membrane Separation
Insufficient data available. For this teen-
technology. Cannot accept si edge-type material
Mo data available for dioxin wastes.
Limited information for hazardous waste appli-
cation. Limited to pumpable aqueous wastes.
Not recommended for halogenated organic
aromatics.
Potential Leaching Problems.
disposal in RCRA Landfill.
May require
Restrictions on solids and organisms contents
of wastes, problems with clogging and regen-
eration of resin material. High Costs
Limited to treatment of aqueous streams with
low organic concentrations. Membrane clogging
problems. Concentrated waste stream need
disposal.
B. Development and Description of Remedial Action Alternatives
Remedial action alternatives were formulated to address the
environmental issues and contaminant pathways related to the Southern
Maryland Wood Treating site. Alternatives were developed by applying
technologies to the site singly or in combination, based on previously
developed remedial objectives.
With respect to the SMWT Site, most of the remedial action technol-
ogies that remain after screening are under the Source Control Classi-
fication (versus migration management). This is because the site
contamination and contaminant pathways can best be addressed on-site.
Management of migration at the SMWT site applies to the contamination
that has migrated off-site via sediment transport mechanisms.
Eight remedial alternatives have been retained for detailed
evaluation. A description of each alternative follows, including an
estimate of the present worth cost of remediation and the present
worth cost of operation and maintenance of each.
I. Alternative 1; No Action
Present worth cost of Remediation: $114,000
present worth costs of 0 & M: $107,000
-------
-12-
The no action alternative is a baseline remedial alternative against
which other alternatives may be compared. Under the no action alternative
no additional measures will be used to remediate contaminant sources or
their potential migration pathways. The two major components of. this
alternative are:
* Upgrac - 'f site security including the installation of fencing
arounc .e west tributary to restrict public access.
* Implementation of a long-term quarterly groundwater/surface
water monitoring program.
Implementation of only the above remedial activities at the site
allows the existing contaminant sources and migration pathways to remain
in place. Current environmental conditions will remain unchanged.
Infiltration of precipitation through the surface soils, the flow of
groundwater through subsurface soils, and the surface water transport of
sediments will continue to result in the migration of contamination to off-
site locations.
II. Alternative 2; On-Site Thermal Treatment
Present worth costs of Remediation: $38,163,00
Present worth costs of 0 & M: $44,000
This alternative consists of on-site thermal treatment of excavated
soils, sediments, and other materials at the site that exhibit concen-
trations of contaminants above the risk based levels established for this
site. Soils remaining in the ground would be covered with clean fill and
possibly backfilled with non-hazardous ash from the incineration process.
Groundwater and surface water would be treated and discharged on-site.
The major components of this alternative include:
* Dredging of all contaminated sediments surface and subsur-
face soils to cleanup levels established for this site.
* Control of off-site soil transport.
* Installation of a slurry wall (or other means of containment)
for control of groundwater migration through the pond/process
area.
* Dewatering of the contained area by pumping and treating
contaminated ground and surface water.
* Excavation of surface and subsurface soils in the pond/
process and land treatment areas; surface soils in the
upper site and northeast tank area; and dredging of
sediments in the pond and west tributary.
* Cn-site incineration of contaminated materials and on-site
disposal of incinerator ash in previously excavated areas.
-------
3ac
-------
Laboratory and pilot-scale testing to determine the opti-jr washir.:
soLation, field operating parameters, etc., would be needed oefore
implementing this alternative.
IV. Alternative 4; In Situ Soil Flushing/Bioreclamation
present worth of Remediation costs: $30,991,000
Present worth of 0 &-M Costs: $25,000
This alternative consists of in situ treatment of the contaminated
materials (associated with the area bounded by the process area, the
freshwater pond, and the are just east of the excavated lagoons) by soil
flushing, followed by in-situ bioreclamation. Included in this altern-
ative is the on-site landfarming of surface soils from the upper site
and northeast tank area, and sediments from the west tributary and the
pond/process area. The land fanning of these soils would occur in the
existing land treatment section of the site. Other major components
of this alternative include:
* Recovery of the product layer located just above the clay in
the excavated lagoon and eastern pond areas.
* Treatment of groundwater/surface water from product recovery
and dredging operations and discharge on-site.
* Installation of slurry wall to prevent groundwater migration.
* in situ soil flushing within containment area.
- injection/recovery wells
- Biodegradable surfactant
- Treatment system to remove contaminants from
washing solution
- Disposal of treated wastewater
* In situ biodegradation in the containment area following the
in-situ flushing.
* Groundwater monitoring.
* On-site land treatment of excavated soils from various site areas.
* On-site incineration of tank contents and onsite disposal of
ash residue.
Treatability studies would be required to determine the effectiveness
of this alternative.
-------
7. Alternative 5; In Situ vitrification
Present worth of Remediation costs: 351,345,000
present worth of 0 & M costs: $43,000
This alternative consists of in situ vitrification of contaminated
soils at the SMWT site. Groundwater and surface water would be treated
and discharged on-site. The major components of this alternative
include:
* Establishment of vitrification zones and the placing
of excavated/dredged contaminated surface and subsurface
soils and sediments in these treatment zones.
* Control of off-site soil transport
* vitrification of the soils and sediments
* Treatment and discharge of sediment, surface, and groundwater
recovered during the excavation process.
* Groundwater monitoring.
* On-site incineration of tank-contents and onsite disposal of
ash residue.
In situ vitrification is a thermal treatment process that converts
contaminated soil into a chemically inert, stable glass and crystalline
product. The in situ vitrification process has not been extensively
tested for organic contaminants, especially low boiling - point organics,
treatability studies would be required for this alternative.
VI. Alternative 6; Containment
Present worth of Remediation costs: $10,589,000
Present worth of 0 & M costs: $585,000
This alternative consists of establishing a containment system that
encompasses the process area, the freshwater pond, and the area just east
of the excavated lagoons. Contaminated materials excavated from outside
this area will be deposited therein. These contaminated materials will
be stabilized and then placed under a cover system. The major components
of this alternative include:
* Recovery of the product layer located just above the clay in
the excavated lagoon and eastern pond area.
* Treatment of groundwater/surface water from product recovery
and dredging operations with on-site discharge.
* Diversion of surface water and groundwater around the proposed
containment area using surface management techniques and a
slurry wall as a subsurface groundwater barrier.
* Excavation of surface and subsurface soils and sediments and
transfer to containment area.
-------
* Construction of a surface cap.
* On-site incineration of tank contents and onsite disposal
of ash residue.
VII. Alternative 7; Removal/Off-Site Option
Present Worth of remediation costs: $73,490,000
present Worth of 0 & M costs: $53,000
This alternative consists of removal by excavation of the sources
of contamination at the SMWT site and disposal/treatment of these
materials at an EPA-approved off-site facility. The treatment option
would be incineration, and the disposal option would be a RCRA-approved
landfill. This removal/ off-site option applies to the contaminated soils
and sediments at the site that exceed risk-based cleanup levels. Soils
remaining in the ground may be covered with clean fill. As needed,
groundwater and surface water would be treated and discharged on-site.
The major components of this alternative include:
* Dredging of contaminat..-- sediments and excavation of contaminated
surface and sub-surface soils to appropriate risk-based levels.
* Backfilling, regrading and revegetation of excavated areas.
* Off-site disposal/treatment as either:
-Off-site thermal treatment
-Off-site disposal at a RCRA Approved Landfill
* On-site incineration of tank contents and onsite disposal
of ash residue.
VIII. Alternative 8; RCRA Containment
present worth of remediation costs: $22,799,000
present Worth of 0 & M costs: $970,000
This alternative consists of establishing a RCRA - type
landfill to contain contaminated materials excavated from the
upper site, northeast tank area, land treatment area, excavated
lagoons, process and pond areas, and sediments from the west tri-
butary. These contaminated materials will be dewatered prior to
placement under a cover system. The excavated areas will be back-
filled with clean soil. The major components of this alternative
include:
-------
* Removal of the contaminated surface soils from the proposed =>C?A
landfill location with temporary storage in the northeast tank area
pending final disposition in the landfill.
* Construction of a RCRA type landfill, which satisfies the
applicable requirements of RCRA.
* Recovery and disposal of the product layer located above the
silty clay layer.
* Treatment of groundwater/surface water from product recovery and
dredging operation and onsite discharge of treated water.
* Diversion of surface water and groundwater around the proposed
excavation in the pond/process area utilizing surface management
techniques and a slurry wall as a subsurface groundwater barrier.
* Excavation of surface and subsurface soils and dredging of sedi-
ments to established levels. Transfer of excavated soils and sedi-
ments to the landfill area.
* Backfilling of excavations with clean fill.
* Construction of a surface cap over the landfill area.
* On-site incineration of tank contents and onsite disposal of
ash residue.
* Groundwater monitoring.
The RCRA containment alternative does not reduce the toxicity
nor volume of the hazardous substances on-site. Additionally, because
there is a relatively shallow water table across the site, an above
ground landfill is required.
C. Evaluation of Alternatives
Each alternative described in the preceding section will be
evaluated against specific criteria as follows:
1. Overall Protection of Human Health and the Environment
The No-Action alternative would not be protective of human health
or the environment since contaminant levels in soils, groundwater and
surface water would continue to present an unacceptable risk.
The remaining alternatives are protective of the shallow aquifer,
public health and aquatic life by either treating soils to target
clean-up levels, removing soils to prevent migration, or containing
removing soils to prevent migration. Direct contact Pathways are prevented
by placement of a soil cover over the site.
-------
-13-
2. Compliance with Applicable or Relevant and Appropriate P.equirer.ents
All alternatives except alternative 1 would be subject to land
disposal regulations as EPA experts that the residual ash from this
process will qualify for hazardous waste delisting prior to
backfilling at the site.
The containment altenatives would not actually reduce soil and
sediment contaminants to cleanup levels. Rather, soils and sediments
exceeding contaminated levels protective of the shallow aquifer would
be contained to prevent their migration into the aquifer.
The location,action, and chemical specific ARARs for each
alternative are shown in Tables 14 and 15.
3. Long Term Effectiveness and Permanance
The Soil Biodegradation and Cn-site Thermal treatment alternatives
provide solutions that offer a high degree of permanence over the long
term, although the biodegradation alternative may not be as effective
as thermal treatment because of dioxin contaminated soils. In each
case there are few, if any, toxic residuals generated during the treat-
ment of waste and the contaminants of concern are permanently destroyed.
The Soil Washing and Soil Flushing Alternatives will generate large
quantities of residuals which will need to be disposed of, most likely
by incineration on-site, since these residuals are non-biodegradable.
The Containment Alternative provides a lesser degree of permanance
and will require considerable operation and maintenance, possibly
significant repairs, and some measure of security. Since compounds of
concern are not permanently destroyed, leachate exceeding risk based
levels could be released into the ground and/or the aquifer should a
leak occur. The RCRA landfill alternative, while more secure and
permanent than the containment option, has many of the same inherent
risks.
Off-site disposal provides a long term solution for the SMWT
site; however, because of future land disposal restrictions, this
alternative may not be feasible to implement. Mditionally, the
Superfund Snendments and Reauthorization Act (SARA) specifies that
landfilling without treatment is the least preferred remedial option.
in-situ vitrification technologies have not been sufficiently
developed to determine their long term effectiveness or permanence.
-------
-13-
P.eductions of Toxicity, Mobility, or Volume
The Soil Flushing/Biodegradation and thermal treatment altern-
atives both permanently destroy the compounds of concern, thus reducing
the toxicity and volume of the waste to levels which do not present an
unacceptable risk to the public or the environment.
The Soil Washing alternative does not reduce the toxicity of the
compounds of concern; rather, the contaminants are removed from the
soil/sediment and the residuals disposed of separately.
The offsite Removal and Vitrification alternatives may reduce the
mobility of the contaminants of concern; however, neither the volume nor
the toxicity of contaminants would be permanently reduced.
The Containment and RCRA landfill alternatives would reduce neither
the toxicity nor the volume of the contaminants. The mobility of the
waste would be reduced by these options; however, due to the possibility
of leachate migration due to potential leaks from there alternatives,
the permanence of this option is dependent upon the expected life of
the landfill.
5. Short-Term Effectiveness
Current conditions at the site do present current risks for the
environment. The thermal treatment, off-site disposal, containment and
RCRA landfill alternatives would have shorter design and implementation
periods than the other alternatives and would therefore be expected to
produce positive results in a shorter timeframe.
The Soil Washing/Soil Flushing and Vitrification alternatives would
require both longer times for implementation and pilot/bench scale
studies during the design phase.
The transportation of contaminated materials under the off-site
disposal alternative presents a short-term risk which does not occur
with the other alternatives.
Any short term impacts to public health or the environment result-
ing from implementation of the remedial action will be prevented by
ARARs, addressing discharge to air, groundwater, surface water, and
wetlands. The ARARs of concern are identified in Tables 14 and 15.
To assure the prevention of short term impacts, monitoring of air and water
shall be conducted both during and after the implementation of the selected
remedy.
-------
-20-
6. Implemen tab i 1 i ty
The L-nplementability of the on-site Thermal Treatment alternative
could be hampered somewhat by the low heating value of the material
and the need to conduct test burns; however, no other obstacles to
implementability are forseen.
Soil Washing and Soil Flushing/Biodegradation would need fairly
extensive design/treatability studies before implementation could
begin. Similar studies would also be needed for the on-site vitrifi-
cation option. These alternatives have a higher risk of remedy failure
than thermal treatment.
The containment and RCRA landfill alternatives require long-
term maintenance and monitoring after implementation. Maintenance
of the Cap in the Contaircnent alternative and the liner/leachate
System in the RCRA alternative is necessary for compliance with
RCRA requirments.
Potential problems exist with both off-site options. With respect
to off-site thermal treatment, obtaining sufficient capacity at a
commercial facility may be a limiting factor. Off-site disposal, on
the other hand,"will be impacted by the enforcement of the proposed
land disposal ban of untreated wastes. The land ban would render
this alternative unacceptable.
7. Community Acceptance
A public meeting on the selected remedy was held on June 15, 1988.
Although not heavily attended, the general feeling of those present
seemed to be that a plan to remediate the Southern Maryland Site and
eliminate the public health and environmental threats was acceptable.
A responsiveness summary has been prepared for this site and is
attached to, and made part of, this ROD.
-------
8. State Acceptance
The Maryland Department of the Environment (MDE),
had concurred with this remedy as conditioned in the
Record of Decision Declaration.
9. Costs
The costs of each Alternative are as follows:
Present Worth
Implementation
Present Worth
0 & M
Alternative
Alternative
Alternative
Alternative
Alternative
Alternative
Alternative
1-No Action
2-On-site Thermal Treatment
3-Extraction/Soil Washing
4-ln-Situ Soil Flushing/
Biodegradation
5-in-Situ Soil vitrification
6-Contairment
7-Off-site Disposal
a) Documentation
b) Landfill
$114,000
$38. 1M
$25. 1M
$30. 9M
$107,000
$ 44,000
$ 48,000
$ 25,000
$51. 0M
$10. 5M
$84. 7M
$66. 9M
$ 48,000
$585,000
$ 53,000
$ 53,000
Alternative 8-RCRA Landfill
$22.7M
$970,000
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Summary of Comparative Analysis
Alternative 1, No-Action, is not protective of human health
and the environment. Therefore, it should be eliminated from
further consideration.
Among the remaining alternatives, all are expected to be pro-
tective of human health and the environment; however, Alternative 6,
Containment, and Alternative 7, Off-Site Disposal, are not expected
to meet SCRA ARARs. These alternatives would probably not be
acceptable to the community because they would not eliminate either
the toxicity or volume of the contaminants.
Alternatives 3,4,5, and the incineration option of alternative
7 rate highly in long term effectiveness and permanence. The disp-
osal option of alternative 7 removes contaminants from the site but
does not provide a permanent treatment method for those contaminants.
'The containment option, alternative 6, neither destroys nor
removes contaminants from the site, although their mobility is reduced
considerably. Alternative 8, the RCRA landfill alternative, provides
a higher degree of permanence than simple containment but, again,
provides for no reduction in toxicity or volume.
Each alternative has some short-term impacts to public health
and the environment associated with it; however, these effects would
be mitigated to the greatest extent possible through careful design
and close monitoring of activities during remediation.
All alternatives, with the exception of the disposal option of
alternative 7, should be impleroentable after the completion of test
burns and/or treatability studies. The incineration option of altern-
ative alternative 7 may be difficult to implement due to limited
off-site incinerator capacity.
All alternatives except alternative 1, would be subject to land
disposal restrictions. With alternative 2, however, EPA expects
that the residual ash from the incineration process will qualify for
hazardous waste delisting prior to back filling at the site.
-------
Alternative 2, On-Site thermal treatment is the selected altern-
ative for the SMWT site. This alternative utilizes incineration tech-
niques to permanently destroy contaminants in soil/sediment which
present a threat to human health and the environment, in addition,
contaminated groundwater at the site will be treated to remove con-
taminants and the contents of tanks and reactors on site will also
be incinerated. This alternative achieves a long-term, permanent
solution and is relatively, implementable.
As required by Section 121 of CERCLA, Alternative 2 is protective
of human health and the environment, reduces the volume and toxicity
of contamination, will attain ARARs, and utilizes permanent solutions
and alternate treatment technologies to the maximum extent practicable.
The selected remedy also satisfies the statutory preference for
employing treatment which significantly reduces the mobility, toxicity
and/or volume of hazardous substances as a principal element. This
alternative is the most cost effective remedy in that it achieves the
Remedial Action Objectives and offers the best balance among the nine
criteria in comparison with the other alternatives. The remedy
provides effective and long term remediation by destroying or removing
contaminants of concern at the site, is readily implementable, and
provides for achievement of the remediation objectives over a 3 to 4
year period. The requirements of 40 CFR 265.193(a)(2) (Tank
Storage) will be met to the extent practicable.
The selected alternative will effectively remove the source
of contaminants at the SMWT site, remediate the contaminated ground-
water, and prevent further threats to public health and the environ-
ment by eliminating contaminant migration from the site. Addition-
ally, this remedy will be protective by reducing direct contact
soil/sediment concentrations to levels protective of the shallow
aquifer below the site and protective of those persons potentially
or actually coming into direct contact with the contaminated soils/
sediments, and surface waters. These levels are also protective of
aquatic life in downgradient surface waters. The design of the
remedy and monitoring before, during and after remedy implementation
will control contaminant releases during remedial action. Functional
controls that are necessary to maintain the site during and after
remedial action shall be developed.
All Federal, State, and local ARARs will be met by the selected
remedy. The ARARs of concern are identified in the ARAR Compliance
Matrix. The ash residue from incineration of contaminated soils,
sediment, and tank contents is expected to meet Best Demonstrated
Available Technology (BOAT) for this remediation. EPA also expects
to delist the ash residue pursuant to 40 CFR 261.22 prior to
backfilling of th eash onsite.
-------
Statement of Findings Regarding Wetlands
The RI/FS for the SMWT site has determined that site wetlands
contain site-related contaminants at levels which constitute an
unacceptable risk to public health and the environment. Excavation
and/or treatment of the sediments of concern will be required to
eliminate this unacceptable risk. All remedial alternatives, except
No Action, will require excavatic of these sediments.
The excavation and fill activities of concern shall be conducted
in a manner consistent with provisions of Appendix A of 40 CFR Part 6.
The subject regulations have been entitled " statement of procedures
on Floodplain Management and Wetland protection." These procedures
constitute policy and guidance for carrying out provisions of Executive
order 11990. This order addresses Protection of Wetlands.
The Remedial Design of the Remedial Action shall be developed in
a manner consistent with Appendix A of 40 CFR part 6 to assure that
potential harm and adverse effects to the wetlands is minimized.
The Remedial Design has not yet been initiated at this time. There-
fore, specific steps to-minimize impacts have not yet been identified.
In addition, the effect of the Remedial Action on the wetlands cannot
accurately be assessed at this time.
While all remedial measures shall be designed to minimize harm
to wetlands, it is possible that some adverse effects may be unavoid-
able. Should remedial activity be expected to create such effects,
restorative and/or mitigative measures shall be developed during the
Remedial Design and reviewed by EPA and the State, should anticipated
adverse effects occur, these measures shall be implemented as part
of the Remedial Action.
Surface water, sediment, and benthic sampling to be conducted
during the ranediation and 0 & M process will provide data on nature
and extent of any mitigative/restorative measures needed.
-------
Evaluation of AlteCTWfcives
Table 15
Alternative
Present Worth
Implementation
Present Worth Total
O & M present Worth
Protective of Lon<) Term
Human Health Compliance Effective-
& Environment with ARARs ness
(1)
(2)
(3)
(4)
(5)
(6)
No-Action $114,000 $107,000
On-Site
Thermal $38.111 $44,000
Extraction/
Soil Washing $25. IN $48,000
In-Situ
Flushing
Biodegradation $30. 9M $25,000
In-Situ
Vitrification $51M $48,000
Containment $10. 5M $585,000
$221,000 No.
$38,144,000 Yes- Soils,
sed iment ,
g.w. treated
to clean-up
levels.
$25,148,000 Same as
Alt. 2
Same as
$30,925,000 Alt. 2
Same as
$51,048,000 Alt. 2
$11,085,000 Yes
NO.
Yes-Al 1
ARARs are
expected
to be
met.
Same as
Alt. 2
Same as
Alt. 2
Same as
Alt. 2
No.
None
Permanent
Remody
Contaminants
Dest toyed/
treated.
Contaminants
Extracted/
Residuals
Destroyed.
Contaminants
Treated.
Contaminants
Immobi lized.
Contaminants
contained
needs signi-
ficant main-
tenance.
(7) Off-Site Dis-
posal
a) incineration
b) Landfill
a)$84.7M
b)$66.9M
$53,000
$53,000
$84,753,000
$66,953,000
Yes-Soils,
sediments
exceeding a) Yes
clean-up b) No
levels
removed from the site.
a) Contaminants
Destroyed.
b) Land Ban
Restrictions.
(8) RCRA
Landfill
$22.7M
$970,000
$23,670,000
Yes
Yes
Signi ficant
Maintenance
-------
Alternative
(1) No Action
(2) On-Site
Thermal
(3) Extraction/
Soil Washing
(4) In-Situ
Flushing/
B iodegrada t ion
Reduction &
Mobility, Toxicity,
or Volume
None
Complete elimina-
tion of on-site
contaminants.
Contaminants elim-
inated on-site and
removed for off-
site disposal.
Contaminants
eliminated on site,
Short-Term
Effectiveness
None
Short term
risks will be
mitigated thru
design and
monitoring.
Same as
Alt. 2
Same as
Alt. 2
Community
Implementabi1i ty Acceptance
Readily Not Accup-
Implementable table
Readily Implemantablu No sijni-
needs test burns. ficant
Remediation over a comments.
four year period.
Need Treatability Same as
Studies. Reined i- 2
ation over in a
four year period.
Treatability Studies
needed. Remediation
over a 10 year period.
State
Acceptance;
Accept-
able
Concur subject
to condit i ui is
stated in
declaration .
Deferred until
State accep-
tance of
alternative '1
Same as 3
(5) In-Situ
Vitrification
(6) Containment
(7) Off-Site Dis-
posal
a) Incineration
b) Landfill
Eliminates Mobility Same as
and Tbxicity. Alt. 2
Reduces Mobility
Contaminants
removed off-site.
Same as
Alt. 2
Same as
Alt. 2
Treatability Studies
requir.-d. Remedi-
ation over a three
year period.
Maintenance Required-
Long Term.
Incinerator Capacity
questionable. Land
Ban restrictions may
apply.
Same as
2
Same as 3
Same as Same as 3
2
Same as Same as 3
2
(8) RCRA Landfill Reduces Mobility
Same as
Alt. 2
Long Term Maintenance Same as
and monitoring 2
required.
Same as
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DRAFT RESPONSIVENESS SUMMARY
FOR THE
SOUTHERN MARYLAND WOOD TREATING SITE
ST. MART'S' COUNTY, MARYLAND
From May'|27, 1988 through June 24, 1988, ch« U.S. Environmental
Protection Agency (EPA) held a public coamenc period on the Proposed Plan and
the Remedial Investigation/Feasibility Study (RI/FS) for the Southern Maryland
Wood Treating |$uperfund site in St.^Mary's County, Maryland. The Rl/FS and
other information utilized by EPA to select a preferred remedial alternative
is included in the Administrative Record which has been available to the
public since the beginning of the public comment period. In addition, copies
of the Proposed Plan vere distributed at the public meeting held on June 15,
1988 in Hollywood, MD. This responsiveness summary summarizes consents on
these documents as expressed by residents, local officials, and other
interested parties during the publid comment period and provides EPA'a
responses to the comments. Public comments were submitted verbally during the
public meeting',. j
SUMMARY OF MAJOR COMMENTS AND SPA RESPONSES
1 • !
The public meeting was held at the Hollywood Fire House on June IS, 1988
at 7:30 p.m. Those attending the meeting included representatives from EPA,
the Maryland Department of the Environment (MDE), area news reporters, and
approximately 12 community residents'. The EPA representatives included Mr.
Ray Cermann, Mr. Tony Dappolone, and Mr. Thomas Volcaggio. The MDE
representative wag Mr. Mike Kilpatrijik. Prior to the public meeting, EPA and
State official]
meetings, EPA t
also met with St. Mary's County officials. During these
taff presented an overview of the events that have occurrsd at
the site, described how the Superfund cleanup program works, described the
proposed remedial alternatives, and explained why EPA recommends Alternative 2
(on-site thermal sreataent) as the preferred alternative. The MDE
representative^described MDE's past experience with the site and the State's
desire to work Vlth the public and EPA in selecting a cleanup remedy.
Following these
officials about
presentations, EPA answered questions from citizens and county
the proposed remedy and cleanup of the site. In addition,
citizens vere given the opportunity to ask questions of the Maryland
Department of tie Environment representative.
Questions ind comments received during these meetings and throughout che
comment period ire summarized below and are categorized into the following
topics: 1) Incineration; 2) Previous Site Studies; 3) Hunan Health and Safety;
4) Nature and Extent of Contamination; 5) Other Remedies; 6) Cost of Cleanup;
7) ^Slte Sampling; and 8) Status of th'e Land After Cleanup. Each comment is
followed by EPAfs or MDE's response. The questions and responses summarized
here are also contained In the official transcript of the meeting. Copies of
the transcript are available at the s't. Mary's County Memorial Library and
Health Department in Leonardtown, MD.
-------
A County official at the EPA/County aeeting and later, at the
public meeting, a local resident, Mr. Robert Larrabee. asked what would be th<
chemical composition of the ash resulting from incineration of the hazardous
was te .
Response: SPA will conduct a test burn to analyze che chemical content of th
ash. Before the technology is implemented at the site, the test results ausc
indicate that the ash is non- hazardous. Studies of incineration have shown
chat this process renders hazardous material non-hazardous .
Question: Mr. Larrabee asked if incineration would: 1) volatize the
contaminants and cause an air quality problem; 2) if the a
-------
Mr,
! 3/
t
Larrabee asked if dioxins' have been treated by incineration.
Response: Mr. Kilpatrick responded that Incineracion has been used
successfully ac a. Missouri. Superfun
-------
HDMAN HEALTH AKD SAFETY
Question;. A County official asked whac were the hazards to workers from the
original work 'done at the sits.
'• i !
Response i Although the EPA staff attending the meeting did not know, they
could get an opinion from the Agency for Toxic Substances and Disease Registry
of the National Centers for Disease Control. Normally, the type of
contaminants found at this site are chronic in nature and would pose a health
risk only if the workers were exposed over a long period of time.
A County official noted that the County had arranged for site workers to be
screened at a local facility but only two workers chose to bear the expense.
There were no findings and no subsequent follow-up with those workers.
j I
Question: A County official asked if the materials in the West Tributary
immediately hazardous to human health.
* '
are
Responses The | contaminants include creosote, pentachlorophenol , and dioxins.
Although these ! contaminants are toxic to humans, they are in the streambad
sediments of the Vest Tributary and 'are mostly toxic to aquatic life. They
would pose a problem to human health! if an individual were to have direct
contact with th'e streaznbed sediments.
1 i
Qua at ion: Mr. .Peter Gamble, an area resident, asked why someone still works
at the site when it is contaminated.!
Response: The individual is noe worlting in a highly contaminated part of the
site. The EPA does not regulate worker safety and does not own the property.
NATURE AND EXIEBT OF COMIMUHATIOH
I > i
Question: l How far downstream of the'West Tributary has the contamination
reached? '
ResponseL i Contaminants have migrated 1900 feet down the West Tributary, the
migration of contamination has slowed^ because the Removal Action removed che
concentrated soiree of contamination.!
How :iany year* would it take for the contaminants to break down
naturally?
decompose
I
OTHER REMEDIES
TlM Contaminants are persistent in the environment and do not
readi
i
.y when in high concentrations.
I
Question: j Has the State used biodegradation before ac the site?
Response; : Biodegradation was attempted at the site, although not by the
State, but this method was unsuccessful. This process required careful
-------
maintenance and was acre of a chemical process than a simple solution
involving earth tilling. • j
Question:' Mr. Combs suggested building a concrete vault to store the
contaminated materials at the site. !
! ' i !
ResponseL Alternative 8 in the Proposed Plan does suggest on-site
containment, i i
1 i i
COST OF CLEANUP i
i «
Question: A County official asked how much the incinerator will cost and who
is going to pay. i
I ; I !
Response: The cost estimates for the alternatives in the Proposed Plan
include the cost for the equipment and treatment. Much of the treatment cost
for Alternative 2 is in the excavation of the soils because excavation
involves moving large volumes of hazardous waste contaminated media. The cost
of the equipment will vary depending^ on the vendor hired and the incinerator
type selected. \
' i
The federal Superfund program will cover 90 percent of the cost and the State
will cover 10 percent of the cost. Funding is available to implement the
cleanup as soon as a remedy is selected.
SITE SAMPLING
Question: Ms. Jloy Buddenbohn, an area resident, asked when the last sampling
was done at the site and how far downstream samples were collected from ch«
West Tributary. 1
Response: ' Sampling was last conducted between 18 to 24 months ago. The
samples were taken from the stream aijd strcambed sediments as far as 7000 feet
downstream. The data indicate that the contamination is not moving v«ry
quickly.
STATUS OF LAHD AFTER CLKAHUP
Question: j A County official asked what the land's status would be once the
four year cleanup period Is over.
Futu:
I* A:
any, on future '
Response.;
selected.
e use of the site depends upon the cleanup alternative
tentative 2 is selected, there vill be little limitation, if
and use. i
In 'addition, thr Federal government will sue to recover the cost of the
cleanup, and this may affect future ownership of the land.
-------
Alt. 1
Action/ARAR No Action
Discharge of
dredge/fill
material into
navigatable
waters.
N/A
Action - Specific and Location Specific ARARs Matrix
3
Table 14
Alt. 2 - On-
site Thermal
Treatment
Alt.
Soil Washing
/Extraction
Alt. 4 - In-s i tu
Soi1 Flushing/
Bioreclamation
Same as Alt. 2
A11. 'i
In-si tu
V i t r i I i c a l i <»
Same as Alt.
Dredging of Same as
contaminated Alt. 2
sediments in
pond and west
tributary
(and of same)
backfilling
may constitute
such a dis-
charge and,
if so, must be performed in accordance with substantive requirements
of clean Water Act {404; 40 C.F.R. (230.10; 33 CFR {{320.330.
Discharge of
treated ground
water and sur-
face water into
pond.
N/A
Direct discharge of Same as
treated groundwater Alt. 2
and surface water into
pond, a "water of the
United States", must
satisfy substantive
standards of Clean Water
Act {402 (a)(l). Clean Water Act
Act {302 water quality standards;
125 and 136.
Same as Alt
Same as Alt
{304 Water Quality Criteria; Clean Walor
implementing regulations at 40 Cb'R {[122,
On-site incine- N/A
rator for treat-
ment of soils
and/or tank
contents (hazard-
ous wastes).
Must be performed in
accordance with appli-
cable construction and
operation requirements
of 40 C.F.R. {264.1-.178
and subpart 0.
N/A
N/A
N/A
Disposal of ash
from incineration
of soils and/or
tank contents
on-si
N/A
See Action *7 and #20
Same
Alt.
as
12
Same as
Alt. #2
Same
Alt.
a.-;
-------
Table 14 Alt. #6 Alt. |7 Alt. #8
Removal RCuA
Action/ARAR - Cont1 Containment Off-site Containment
1. Discharge of Same as Altern- Same as Altern- Same as Altern-
dtedge/fill ative #2 ative *2 ative #2
material into
navigatable
waters.
Discharge of Same as Altern- Same as Altern- Same as Altern-
treated ground- ative 12 ative |2 ative |2
water and
surface water
into pond.
On-site incince- N/A N/A N/A
neration for treat-
ment of soils and/
or tank contents
(hazardous wastes).
Disposal of ash Same as Same as Same as Altern-
from incineration Alt. |5 Alt. |5 ative #5
of soils and/or
tank contents
on site.
-------
Construction &
operation of
Alt. #1
No Action
Alternative #2
on-site
Thermal Treatment
Alternative #3
soil
Washing/Extraction
Alternative |4
in-situ soil
Flushing
Backfilling,
regrading,
vegetation of
dredged/exca-
vated areas with
treated soil and/
or clean fill.
N/A See Action |1_ for
backfilling with
cleanfill See
Action #;? and |20
for backfilling
with treated soils.
Same as Alt.#2
Same as Alt. #2
Release of air
emissions from
soil movement
and incineration
soils and/or tank
contents.
N/A Any air emissions Same as Alt. #2
generated by the
remedial Alterna-
tive must be in
compliance with
Maryland's State Implementation Plan.
Same as Alt. #2
Land Disposal of
hazardous waste.
N/A placement of ash
from incinceration
of contaminated
tents constitutes
"land disposal" of
wastes. Must be
conducted in accord-
ance with RCRA Sec-
tions 3004 (e), (g)
(h) and 40 C.F.R.
Part 268.
Placement of excavated
site soils and lagoon
sludges treated by
soil washing const-
itues "land disposal,"
placement of ash from
incineration of tank
contents constitutes
"land disposal" of
listed hazardous
wastes. All such land
disposals must be con-
ducted in accordance
with RCRA {3004 (e),
(g) and (h) and
40 C.F.R. {268.
placement of soils from
upper sites, in the NE
tank area, west tributary
and pond/process area
into former land
treatment area
(a "new hazardous
waste management
facility" subject to
regulations under RCRA)
constitutes "land disposal" of
listed hazardous wastes.
Backfilling of other site areas
with soil treated in former land
treatment area constitutes land
disposal of the same listed as
hazardous wastes. Placement oi
ash from incineration of tank
contents and recovered product
layer constitutes land disixjs.d
of listed hazardous wastes
All such land disposal
condijcted in accordance
KCKA '{3004" (e)., (.)) ,,and
m^^ i
W1
-------
Construction &
Operation
of
5.
6.
Backfilling,
regrading,
vegetation of
dredged/exca-
vated areas
with treated soil
and/or clean fill
Release of air
emissions from
Alt. t5 Alt. #6 Alt. | 7
In-Situ Contain- Removal
Vitrification ment Off-site
Clean fill Same as Same as
only. Alt. |5 Alt. #5
(See Action
11)
•
Same as Same as Same as
Alt. |2 Alt. #2 Alt. #2
Alt. #8
RCRA
Containment
Same as
Alt. #5
Same as
Alt. #2
soil movement
and incineration of soils and/or tank contents.
7. Land disposal
Placement of dredged
sediments & excavated
soils from other site
areas into former
waste lagoon areas
and former land
treatment areas
constitutes "land
disposal" of listed
hazardous wastes.
placement of ash
from incineration
of tank contents
constitutes "land
disposal" of list-
ed hazardous waste.
All such land
disposal must be
conducted in accord-
ance with RCRA
{3004 (e), (g) and
(h), and 40 C.F.R.
{268.
Placement of soils
from former land
treatment area
constitutes
"land disposal"
of listed hazard-
ous wastes, place-
ment of ash from
incineration of
tank contents
constitutes "land
disposal" of
listed hazardous
wastes. All such
land disposals
must be conducted
in accordance with
RCRA Section 3004
(e) , (g) and (h) ,
and 40 C.F.R.
(268.
Off-site thermal
incineration of
soils and tank
contents consti-
tutes "land
disposal" of
listed hazardous
wastes.
Off-site Disposal-
placement of soils
from sites in off-
site landfills
constitutes" land
disposal" of listed
hazardous wastes.
placement of ash
from incineration
of tank contents
constitutes" land
disposal" of listed hazardous wastes. All
such land disposal must l>e conducted in
accordance with RCKA Section HW4 (e) , (
-------
Alt. fl
NO-
Action
Alt. #2
On-site Ther-
mal Treatment
Alt. #3 Soil
Washing/
Extraction
Alt. #4 In-situ
soil Flushing/
Bioreclamation
8. Construction of or/
operation of a new
hazardous waste
management unit.
N/A
Incinerator, treat-
ment tanks for ground-
water, surface water
(and process waste-
waters) and landfill
area for ash back-
filling are RCRA regu-
lated units which must
be constructed, .and
operated in accordance
with 40 C.F.R. {264.1-
.178 and subparts 0, J
and N/ respectively.
Incinerator, soil
washing tanks(s)
for groundwater,
surface water and
process water,
landfill(s) for
backfilling of
washed soil and
ash, are RCRA-
regulated units
which must be
constricted and
operated in
accordance with
40 C.F.R. { 264.1-
.178 and Subparts
O,J, and N, re-
spectively.
Incinerator, treat-
ment tank(s) for ijround-
water, surface water and
process wastewatec,
landfill for backfilling
of ash and treated
soils, land treatment:
areas for biorclcuu.i-
tion of treated
soils are RCRA-regulated
units which must be
constricted and operated
in accordance with 4W
C.F.R. { 264.1-.178
and Subparts O,.7,M >nd
M, respectively.
9. Closure of
hazardous
waste manage-
ment unit
Former waste lagoons,
former product tanks
and former land treat-
ment area are RCRA-re-
gulated units which
must be closed in
accordance with 40
C.F.R. { 264.110-
.116 and 40 C.F.R.
{ 264.228, and .19.280,
respectively.
Same as Alternative
fl. In addition,
incinerator, treat-
ment tank(s) for
groundwater, surface
water [and process
wastewaters] and
landfill area for ash
backfilling are RCRA-
regulated units which
must be closed in
accordance with 40
C.F.R. { 264.351,
.197 and .310, re-
spectively.
Same as Alternative
|1. In addition,
incinerator, soil
washing tank and
tank(s) for treat-
ment of groundwater,
surface water [and
process wastewaters]
and landfill(s) for
backfilling of ash
and washed soil are
RCRA-regulated units
which must be closed
in accordance with
40 C.F.R. {264.U0-
.116 and 40 C.F.R.
{264.351, .197 and
.310, respectively.
Same as Alternative fl.
In addition, incinertor,
treatment tank(s' i
groundwater, suriaee
water (and process waste
water), land treatment
areas (to the extent
they differ from tormer
land treatment area) and
landfill for backl. i 1 I in.)
of ash and any treated
soil, are RCRA - regu-
lated units which musi
be closed in accordant-. •
with 40 C.F.R (264.IIU
.116 and 40 C.F.K.
{254.351, .197, .2HU .md
.310, respeetively
-------
Alter natiQ #5
in-Situ
Vitrification
Alternative #6
Containment
jrnatwe #7
Removal
Off-Site
Alternative #8
KCRA
Containment
Incinerator treatment
tank for ground water,
surface water (and pro-
cess wastewater) ,
landfill areas for
vitrification and
backfilling of inciner-
ator ash are RCRA
regulated units which
must be constructed
and operated in accord-
ance with 40 C.F.R.
{264.1 - .178 and
supports 0, J and N,
respectively.
Incinerator, treatment
tank(s) for ground water
surface water (and process
waters), landfill area for
excavated soils, sediments
and ash are RCRA regulated
units which must be con-
structed and operated in
accordance with 40 C.F.R.
(264.1 - .178 and Subparts
O, J and N, respectively.
Incinerator, treatment
tank(s) for ground water,
surface water (and process
water), (landfill for back-
filling of ash?) are RCRA
regulated units which must
be constructed and operated
in accordance with 40 C.F.R.
{264.1 - .178 and Subparts
0, J (and N?), respectively.
Incinerator, treatment tc«i>k(:i)
for ground water, surface w.jter
(and process water?), new
landfills are RCRA-regulate.I
units which must be constructed
and operated in accordance with
40 C.F.R. {264.1 -.178 and
Subparts O, J and N,
respectively.
Same as Alternative |1.
In addition, incinerator,
treatment tank(s) for
ground water, surface
watr (and process waste-
waters) , landfill areas
for vitrification and
backfilling of ash are
RCRA-regulated units
which must be closed
in accordance with
40 C.F.R. {264.110 -
.116 and 40 C.F.R.
{264.351, .197 and
.310.
Same as Alternative #1.
In addition, incinerator,
treatment tank(s) for
ground water, surface water
(and process wastewater),
and landfill (containment)
area for soils and ash back-
filling are RCRA regulated
units which must be closed
in accordance with 40 C.F.R.
{264.110 - .178 and
40 C.F.R. {264.351, .197
and .310, respectively
Same as Alternative #1.
In Addition, incinerator,
treatment tank(s) for
ground water, surface
water (and process waste-
water) , (and landfill
for backfilling of ash)
are RCRA-regulated units
which must be closed in
accordance with 40 C.F.R.
{264.110 - .116 and
40 C.F.R. {264.351,
.197 (and .310) .
Same as Alternative #1.
In addition, incinerator,
treatment tank(s) for .jroi
water, surface water (and
process wastewaters), and
new landfill are RCHA-reijul.it>> 1
units which muste te construeto
and operated in accordance
with 40 C.F.R. {264.1 - . 17«
and 40 C.F.R. {264.351, .197
and .310.
-------
Alternative |1
No Action
Alternative #2
On-Site
Thermal Treatment
Alternative #3
Soil washing/
Extraction
Alternative #4
In-Situ Soil
Flush in
-------
Alterative #6
Containment
Alternative # 7
Removal Off-Site
Alternative #8
RCRA
Containemnt
10. Closure of
contaminated
areas which
are not hazard-
ous waste
management units
Same as Alter-
native | 1
Same as Alter-
native # 1
Same as Alternative
#1
11. post-closure
care of a
hazardous
waste manage-
ment unit.
Same as Alter-
native fl. in
addition, units
described in
Action |9r
Alternative |6,
must comply with
any applicable
post-closure
care requirements
of 40 C.F.R. f
264.351, .197 and
.310, respectively
Same as Alter-
native #1. in
addition, units
described in Action
#9, Alternative | 7,
must comply with
any applicable post-
closure care re-
quirements of 40
C.F.R. | 264.351,
.197 [and .310],
respectively.
Same as Alternative # 1.
In addition, units
described in Action #9,
Alternative #8, must
comply with any appli-
cable post-closure
care requirements of
40 C.F.R. | 264.351,
.197 and .310, respectively.
-------
Alternative I
No Action
Alternative f 2
On-Site
Thermal Treatment
Alternative It 3
Soil
Washing/Extraction
Action
Alternative # 4
In-Situ Soil
Flush irvj/Bio-
reclamaation
12. post-closure
care for con-
taminated areas
which are not
RCRA-regulated
hazardous waste
management units
The post-closure
care requirements
of 40 C.F.R. \
264.117-.120 and
1264.310 are "re-
levant and appro-
priate" for non-
RCRA regulated
areas of the site.
Same as Alternative
f 1
Same as
Alternative f 1
Same as Alternative
13. Off-site ship-
ment of
hazardous waste
(For incinera-
tion or land
disposal)
N/A
N/A
N/A
N/A
-------
Alternative # 5
In-Situ
Vitrification
Alternative # 6
Containment
Alternative
Ranoval
Off-Site
# 7
Alternative #
UCRA
Containment
12.
Same aa Alter-
native | 1
Same as
Alternative # 1
Same as
Alternative
Same as
Alternative # 1
13.
N/A
N/A
Contaminated Soils,
sediments {and ashj
containing listed
hazardous wastes
F021, U051, U242 and
K001 must be trans-
ported off-site in
accordance with
substantive re-
quirements of 40 C.F.R.
| 264.262 and 263. In
addition, such wastes
must be handled in
accordance with CERCLA
f
N/A
-------
Alternative I
NO Action
Alternative | 2
On-Site
Thermal Treatment
Alternative I 3
Soil
Washing/Bioreclamation
Alternative ft 4
In-Soi1 Flushing/
Bioreclamation
14. Actions at
Site which
would require
the facility
to obtain a
RCRA operating
or post-closure
permit absent
a CERCLA clean-
up
Closure of the
former waste
lagoon area in
a manner other
than in accord-
ance with "clean
closure" re-
quirements of
40 C.F.R. { 264.
228. (a)(1)
will require
a post-closure
permit for such
unit. Closure
of the former
land treatment
area in a manner
other than in
accordance with
the requirements
of 40 C.F.R. {
264.280 (d) will
require a post-
closure permit
for such unit.
post-closure
care requirements
of 40 C.F.R. {
264. 310 are
"relevant and
appropriate"
for closure of
nonRCRA-regulated
of the site.
Accordingly, the
corrective action
requirements of
RCRA (3004(u),
42 U.S.C. {
6924(u) and imple-
menting regulations
are both applicable
and relevant 'antl
Same as Alternative
# 1. In addition,
constriction and
operation of new
RCRA units described
in Action 8, this
Alternative, will
require a RCRA
operating permit.
Accordingly, the
corrective action
requirements of
RCRA (3004(u) , 42
U.S.C. {6924(u),
and implementing
regulations are
both applicable
and relevant and
appropriate.
Same as
Alternative ft 2
Same As
Alternative # 2
-------
Alternative | 5 Alternative # 6 Alternative # 7 Alternative # 8
In-Situ Containment Ranoval RCUA
Vitrification Off-Site Containment
Same As Same as Same as Same a:i
Alternative | 2 Alternative # 2 Alternative # 2 Alternative # 2
-------
Alternative | 1
No Action
Alternative | 2
On-Site
Thermal Treatment
Alternative g 3
Soil Washing/
Extraction
Alternative # 4
In-Situ Soil
Flushin«j/Bioreclamat ion
15. Excavation/
dredging of
contaminated
soiIs/sediments
N/A
Excavation/dredging
of contaminated
soiIs/sed iments
constitutes
"generation" of
hazardous waste.
Sec. 40 C.F.R. f
264. .
Generator must
comply with sub-
stantive require-
ments of 40 C.F.R.
J264.263.
Same as
Alternative | 2
Same as Alternative # l
16. Soil Washing
N/A
N/A
Soil Washing
constitutes
treatment of
hazardous wastes
in a tank. Tank
must be constructed
and operated in
accordance with
40 C.F.R. f 264.1-
.178 and subpart
3, closed in
accordance with 40
C.F.R. f 264.110-
.116 and .197 and
given post-closure
care in accordance
with 40 C.F.R. t
264.197.
N/A
-------
Alternative | 5
In-Situ
Vitrification
Alternative g 6
Containment
Alternative
Removal
Off-Site
Alternative # 8
RCRA
Containment
15.
Same as
Alternative f 2
Same as
Alterntive # 2
Same as
Alternative # 2
Same as
Alternative # 2
16.
N/A
N/A
N/A
N/A
-------
Alternative
No Action
Alternative # 2
On-Site
Thermal Treatment
Alternative | 3
Soil washing/
Extraction
Alternative # 4
In-Situ Soil Flushing/
Bioreclamation
17. In-Situ
Soil Flushing
N/A
N/A
N/A
NO ARARs
identified.
18. Bioreclamation
N/A
N/A
N/A
Bioreclamation
of contaminated
soils, sediments
constitutes "land
treatment" of
hazardous wastes.
Land treatment
unit(s) must be
constructed and
operated in
accordance wi th
40 C.F.R. { 264. L-
.178 and subpart
N, closed in
accordance with
40 C.F.R. { 264.
110-.116 and
.280 and provided
with post-closure
care under 40
C.F.R. { 264.117-
.120 and .280.
-------
Alternative | 5 Alternative # 6 Alternative # 7 Alternative # 8
In-Situ Containment Removal RCUA
Vitrification Off-Site Containment
17. N/A N/A N/A N/A
18. N/A N/A N/A N/A
-------
Alternative f I
NO Action
Alternative # 2
On-Site
Thermal Treatment
Alternative # 3
Soil Washing/
Extraction
Alternative # 4
In-Situ SoiI
Flushincj/Bioreclamat ion
19. On-Site
incineration
of contaminated
soils, sediments
and/or tank
contents
N/A
Incineration of
contents must be
conducted in
accordance with
the applicable
requirements of
40 C.F.R. f 264.1-
.178 and Subpart 0.
Same as
Alternative # 2
Sa-ne as
Alternative # 2
20. On-Site
containment
(landfilling)
of contaminated
soils and sedi-
ments
N/A
Backfilling of ash
from incinerator
of contaminated
soils, sediments
and tank contents
constitutes land-
filling of hazardous
waste. Landfilling
must be constricted,
operated, closed and
given post-closure
care in accordance
with applicable re-
quirements of 40
C.F.R. f 264.1-
.178 and subpart M.
Backfilling of
washed soils and
sediments and ash
from incineration
of tank contents
constitutes land-
filling of hazardous
wastes. Landfill
must be constructed,
operated, closed and
given post-closure
care in accordance
with applicable
requirements of
40 C.F.R. f 264.1-
.178 and subpart M.
Any backfilling
of land-treated
soils and sediments
and/or ash from
incineration of
tank contents con-
stitutes landfillirvj
of hazardous wastes.
Landfill must be
constructed, operated,
closed and given posi.-
closure care in
accordance with
applicable require-
ments of 40 C.F.tt.
f 264.1 - .178 and
Subpart M.
-------
Alter. ive ft 5
In-Situ
Vitrification
Alternative ft 6
Containment
Alternative ft
Removal
Off-Site
Alternative ft 8
RCUA
Containment
19.
Same as
Alternative ft 2
Same as
Alternative ft 2
Same as
Alternative ft
Same as
Alternative ft 2
20.
Backfilling of
ash from in-
cineration of
tank contents
constitutes
landfilling of
hazardous wastes.
Landfill must
be constricted,
operated, closed
and given post-
closure care in
accordance with
the applicable
requirements of
C.F.R. 1264.1-
.178 and Subpart M.
placement of
contaminated
soils and
sediments and
ash from in-
cineration of
tank contents
in containment
area and con-
st itutes land-
filling of hazardous
wastes. Landfill
must be constricted,
operated, closed
and given post-
closure care in
accordance with
the applicable
requirements of
40 C.F.R. I 264.1-
.178 and Subpart M.
N/A
Placement of
Same as
Alternative ft 6
-------
Alternative |
NO Action
Alternative | 2
On-Site
Thermal Treatment
Alternative f 3
Soil Washing/
Extraction
Alternative # 4
In-Situ Soil
Flushing/Bioreclaroat ion
21. Vitrification
N/A
N/A
N/A
N/A
-------
Alternative tf 5
In Situ
Vitrification
Alternative # 6
Containment
Alternative
Removal
Off-Site
Alternative # 8
RCRA
Containment
21.
Disposal of
contaminated
soils and
sediments on-
site after
vitrification,
and backfilling
of ash from
incinerator of
task contents
constitutes
landfilling of
hazardous wastes.
Landfill must be
constricted,
operated, closed
and given post-
closure care in
accordance with
the applicable
requirements of
40 C.F.R. | 264.1 -
.178 and Subpart M.
N/A
N/A
N/A
-------
Alternative # 1
No Action
Alternative # 2
On-Site
Thermal Treatment
Alternative # 3
Soil Washing/
Extraction
Alternative # 4
In-Situ
Flushing/fiioreclamat ion
22. On-Site N/A
treatment of
contaminated
ground water
surface water
and/or process
wastewaters in
a tank(s)
Unless exempt Same as Same as
under 40 C.F.R. Alternative | 2 Alternative ft 2
jt 264. as a
"wastewater
treatment unit",
tank(s) must be
constricted,
operated, closed .
and given post-
closure care in
accordance with
the applicable
requirements of
40 C.F.R. | 264.1-
.178 and Subpart J.
23. Recovery of
product layer
N/A
N/A
N/A
No ARARs
identified
-------
Alternative I 5 Alternative # 6 Alternative # 7 Alternative # 8
in-Situ Containment Removal RCRA
Vitrification Off-Site Containment
22. Same as Same as Same as Same as
Alternative I 2 Alternative # 2 Alternative # 2 Alternative # 2
23. N/A No ARARs N/A N/A
identified
-------
Alternative f 1
No Action
Alternative # 2
On-Site
Thermal Treatment
Alternative # 3
Soil Washing/
Extraction
24. underground
injection of
fluids
N/A
N/A
N/A
Alternative ft 4
in-Situ Soil
.ng/Bioreclamat
The underground
injection of
soil washing
fluids must
meet applicable
standards of 40
C.P.R. Part 144
(Class V well)
25. Activity within
a floodplain
Executive Order
11988, Protection
of floodplains,
40 C.F.R. Part 6,
App. A. Action
must be taken to
avoid adverse
effects, minimize
potential harm,
restore and preserve
national and bene-
ficial values.
Same as
Alternative | 1
Same as
ALternative #
Same as
Alternative # 1
-------
Alternative f 5
In-Situ
Vitrification
Alternative f 6
Containment
Alternative # 7
Removal
Off-Site
Alternative # 8
RCRA
Containment
24.
N/A
N/A
N/A
N/A
25.
Same as
Alternative I
Same as
Alternative
Same as
Alternative
Same as
Alternative #
-------
Alternative f
No Action
Alternative # 2
On-Site
Thermal Treatment
Alternative # 3
Soil Washing/
Extraction
of Wetlands, 40
C.F.R. pact 6,
App A. Action must
be taken to Minimize
the destriction,
loss or degradation
of wetlands.
Alternative ft 4
in-Situ Soil
Flushirxj/Bioreclamation
26. Activity within
a wetlands
Executive Order
11990, Protection
Same as
Alternative | 1
Same as
Alternative # 1
Same as
Alternative # 1
-------
Alternative I 5 Alternative # 6 Alternative # 7 Alternative # 8
In-Situ Containment Removal RCRA
Vitrification Off-Site Containment
26. Same as Same as Same as Same as
Alternative I 1 Alternative | L Alternative | 1 Alternative | 1
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TABLE 15
Chemical Specific ARARs
Safe Drinking Water
Act Contaminant Level
a/1
Clean Water Act
Smtaient Water
Quality Criteria
u/1
Chemical/Containant
Benzene
Pentachlorophenol
phend
Toluene
0.67
0.001
0.0035
0.015
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