FISCAL YEAR 1990
RECORD OF DECISION
FORUM
REGION VIII
JUNE 5,1990
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
OFFICE OF WASTE PROGRAMS ENFORCEMENT
401 M STREET S.W.
WASHINGTON, D.C. 20460
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FY'90 RECORD OF DECISION
FORUM AGENDA
1.
INTRODUCTION
9:00- 9:15
2.
OVERVIEW OF FINAL NCP
9:15- 10:00
3.
FY'89 ROD ANALYSIS
10:00 - 10:30
Break
10:30 - 10:45
4.
FY'90 ROD TOOLS
10:45 - 10:50
5.
GROUND WATER ROD LANGUAGE
10:50 - 11:10
6.
ROLE OF BASELINE RISK ASSESSMENT
11:10 - 11:30
7.
LAND DISPOSAL RESTRICTIONS UPDATE
11:30 - 12:00
Lunch
12:00- 1:00
8.
REGIONAL MANAGEMENT DISCUSSIONS
1:00- 3:00
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TABLE OF CONTENTS
Tab 1. NATIONAL CONTINGENCY PLAN
a Overview of the NCP
h NCP Questions and Answers
c. NCP Outline (Region X)
Tab 2. FY'89 ROD ANALYSIS
a Overview of FY89 ROD Analysis Results
1. National and Regional Findings
Tab 3. FY90 ROD TOOLS
a Compendium of Examples From FY'89 RODs
1. Declaration
2. Site Description, Site History,
Community Relations
3. Scope and Role of Operable Unit
4. Summary of Site Characteristics
5. Summary of Site Risks
6. Description of Alternatives
7. Comparative Analysis
8. Selected Remedy
9. Statutoiy Determinations
10. Responsiveness Summary
11. State Letter of Concurrence
b. ROD Short Sheets
1. Record of Decision
2. Proposed Plan
3. Special RODs (Draft)
c. Selection of Remedy Short Sheet
d. ROD and Proposed Plan Checklists (Draft)
e. Overview of Ground Water Extraction Remedies
f. Ground Water Directive
g. Role of Baseline Risk Assessment
h. Exposure Assumptions
Tab 4. LAND DISPOSAL RESTRICTIONS
a LDR Update
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The 1990 National Contingency Plan
U.S. Environmental Protection Agency
Washington, D.C.
A
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The 1990 National Contingency Flan (NCR):
o Framework regulation for the Superfund program.
o Published in the Federal Register on March 8,1990 (55 FR 8666).
o Applies to responses to oil spills and hazardous waste releases conducted
by EPA, other federal agencies, states, and private parties.
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Contents of the NCP
Subpart A Introduction
Defines key terms and states the purpose, authority, applicability,
and scope of the NCP.
Subpart B Responsibility and Organization for Response
Describes the organization and responsibility of federal agencies
regarding response activities.
Subpart C Planning and Preparedness
Describes preparedness activities, federal and regional contin-
gency plans, and planning responsibilities of state and local agen-
cies (cross-references Title III planning requirements).
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Contents of the NCP (continued):
Subpart D Oil Removal
Sets forth the phases of response to discharges of oil.
Subpart E Hazardous Substance Response
Describes the sequence of activities site discovery through final
cleanup and deletion from the National Priorities List involved in
responding to releases of hazardous substances.
Subpart F State Involvement
Provides for the cooperation and coordination of federal and state
agencies during hazardous substance response.
Subpart G Trustees for Natural Resources
Designates the federal officials who shall act on behalf of the public
as trustees for natural resources.
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Contents of the NCP (continued):
Subpart H Participation by Other Persons
Describes the authorities that allow persons other than the federal
government to respond to releases and receive reimbursement of
response costs.
More flexible standard for determining "consistency with the
NCP:" whether cleanup, when evaluated as a whole, achieves
substantial compliance with potentially applicable NCP require-
ments and results in a "CERCLA-quality" cleanup.
Subpart I Administrative Record
Describes requirements for establishment and maintenance of
documents that form the basis for the selection of the response
action.
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Contents of the NCR (continued):
Subpart J
Use of Dispersants and Other Chemicals
Describes authorization requirements for use of dispersants, sur-
face collecting agents, biological additives, or miscellaneous oil spill
control agents in responding to oil spills in navigable waters.
Subpart K
Federal Facilities [Reserved]
This subpart will provide a "road map" for how NCP requirements
apply to federal facility cleanups.
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Effective date:
o The 1990 NCP is effective as of April 9,1990.
o The NCP requirements apply to on-going projects, except:
Administrative record requirements apply to remedial investigations
(Rl) started after the promulgation date (March 8, 1990).
Other response actions (i.e., RIs started before March 8) shall comply
with administrative record requirements to the extent practicable.
NCP section 300.800(d).
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Preambles to the proposed and final NCR
o Preamble to the proposed NCP (53 FR 51394-51474, December 21,1988)
and preamble to the final NCP (55 FR 8666-8813, March 8,1990) contain
important explanations, policies, and guidance. For example:
Preamble to proposed NCP explains community relations and
administrative record requirements for removal actions (53 FR 51450
and 51469). Preamble to final NCP also discusses administrative
record requirements (55 FR 8805).
Requirements under RCRA are described in preamble to proposed
NCP at 53 FR 51443 and preamble to final NCP at 55 FR 8758.
o Index to key terms in NCP is being developed.
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Removal actions
o NCP incorporates statutory limits of 12 months and $2 million.
NCP section 300.415(b)(5).
o Exemptions from limits may be obtained:
Emergency.
Continued response is otherwise appropriate and consistent with
the remedial action to be taken.
NCP section 300.415(b)(5)(i) and (ii) and 55 FR 8694.
o Removal actions will comply with ARARs to the extent practicable
considering the exigencies of the situation. NCP section 300.415(i).
o Public participation and administrative record requirements depend upon
type of removal action: emergency, time-critical, or non-time-critical.
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RI/FS and selection of remedy process
o PROGRAM GOAL is to select remedies that are protective of human health
and the environment, that maintain protection over time, and that minimize
untreated waste. NCP section 300.430(a)(1)(i) and 55 FR 8702.
o PROGRAM EXPECTATIONS are also included in the rule,
NCP section 300.430(a)(1)(iii) and 55 FR 8702.
Treatment will be used to address principal threats, wherever practi-
cable. Principal threats generally are highly toxic, highly mobile waste.
Engineering controls, such as containment, will be used for waste that
poses a relatively low long-term threat, or where treatment is
impracticable.
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o PROGRAM EXPECTATIONS (continued)
Combinations of treatment and engineering controls will be used at
most sites.
Institutional controls may be used during conduct of remedial action
and as a component of final remedy. Institutional controls shall not sub-
stitute for active measures unless active measures are determined not
to be practicable.
Use of innovative technologies is encouraged where comparable or
superior to demonstrated technologies.
Ground water will be restored to beneficial uses wherever practicable,
within a timeframe that is reasonable given the particular circumstances
of the site.
o PROGRAM GOAL and EXPECTATIONS can be used as a guide during
scoping and when developing a range of alternative approaches for
detailed analysis.
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RI/FS and selection of remedy process
O PROGRAM MANAGEMENT PRINCIPLES
Bias for action when necessary or appropriate to achieve
significant risk reduction quickly.
Streamlining to tailor investigation, analysis, and documentation
to size or complexity of the site problem to be addressed.
NCP section 300.430(a)(1)(ii) and 55 FR 8702.
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RI/FS and selection of remedy process
o SCOPING
Develop conceptual site model.
Identify management strategy, likely response scenarios, and
potentially applicable technologies and operable units.
Initiate ARARs identification.
Identify initial data quality objectives.
Prepare project plans.
NCP section 300.430(b) and 55 FR 8707.
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RI/FS and selection of remedy process
O REMEDIAL INVESTIGATION
Purpose is to characterize the site in order to develop and evaluate
effective remedial alternatives. NCP section 300.430(d) and 55 FR 8708.
The baseline risk assessment determines the extent to which the site poses
a current or potential risk to human health and the environment in the
absence of a remedial action. The baseline risk assessment will help
establish acceptable exposure levels.
o Exposure assessment.
o Toxicity assessment.
o NCP section 300.430(d)(4) and 55 FR 8709.
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RI/FS and selection of remedy process
O REMEDIAL INVESTIGATION/FEASIBILITY STUDY
Establish remedial action objectives (contaminants and media of concern,
potential exposure pathways, and preliminary remediation goals).
Preliminary remediation goals are desired endpoint concentrations or risk
levels and are modified as more information becomes available.
Final remediation goals are determined when remedy is selected.
NCP section 300.430(e)(2)(i) and 55 FR 8712.
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RI/FS and selection of remedy process
O RISK RANGE AND POINT OF DEPARTURE:
The 1990 NCP states that generally acceptable levels for carcinogens
fall within a range of 10"4 to 106. This means that an acceptable exposure
is when the excess risk to an individual of contracting cancer due to a
lifetime exposure to a certain concentration of a carcinogen falls be-
tween 104 to 106.
Risk range is used when ARARs are not available or when cumulative
risk due to multiple contaminants or pathways must be determined.
The point of departure when using the risk range is 10 6. The risk
level may be revised based on exposure, uncertainty, or technical
factors.
NCP section 300.430(e)(2)(i)(A)(2) and 55 FR 8715-19.
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RI/FS and selection of remedy process
o USE OF MCLGs AND MCLs
For cleanup of ground water that is or may be used for drinking,
maximum contaminant level goals (MCLGs) above zero generally
will be cleanup standards where relevant and appropriate.
When an MCLG equals zero (generally for carcinogens), the
corresponding maximum contaminant level (MCL) generally will
be used as the cleanup level where relevant and appropriate.
NCP section 300.430(e)(2)(i)(B) and 55 FR 8750.
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RI/FS and selection of remedy process
O FEASIBILITY STUDY
Range of source control options:
o Treatment option to eliminate, or minimize to extent feasible, the
need for long-term management.
o Treatment options which reduce the toxicity, mobility, or volume of
wastes as their principal element.
o One or more containment options utilizing little or no treatment.
o No-action alternative.
o NCP section 300.430(e)(3) and 55 FR 8714.
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RI/FS and selection of remedy process
O FEASIBILITY STUDY
Range of ground-water alternatives should be based on:
o Remediation level,
o Restoration time period,
o Methodologies/approach,
o NCP section 300.430(e)(4) and 55 FR 8732.
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RI/FS and selection of remedy process
O FEASIBILITY STUDY
Screening of alternatives:
o Effectiveness,
o Implementability.
o Cost.
o NCP section 300.430(e)(7) and 55 FR 8714.
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Rl/FS and selection of remedy process
o FEASIBILITY STUDY
Nine criteria used objectively to analyze advantages and disadvantages
of alternative approaches. NCP section 300.430(e)(9) and 55 FR 8719.
Functional categories for the nine criteria used when selecting
preferred approach. NCP section 300.430(f)(1)(i) and 55 FR 8723.
TCnir^toDdl
o Protection of human health and the environment.
o Compliance with applicable or relevant and appropriate
requirements (ARARs).
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RI/FS and selection of remedy process
Functional categories for the nine criteria (continued)
Ptrfte^trw
o Long-term effectiveness and permanence,
o Reduction of toxicity, mobility, or volume through treatment,
o Short-term effectiveness,
o Implementability.
o Cost.
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RI/FS and selection of remedy process
Functional categories for the nine criteria (continued)
o State acceptance,
o Community acceptance.
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RI/FS and selection of remedy process
O CONTENTS OF THE RECORD OF DECISION
Facts, analyses, and site-specific policy determinations.
How nine criteria were used to select remedy.
How CERCLA section 121 mandates are addressed by the remedy.
Remediation goals expected to be achieved.
Significant changes, if any, from proposed plan and response to
comments.
Whether five-year review is required.
NCP section 300.430(f)(5) and 55 FR 8731.
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RI/FS and selection of remedy process
O FIVE-YEAR REVIEW
Review at least every five years required when hazardous substances
will remain on-site above levels that allow for unlimited use and
unrestricted exposure. NCP section 300.430(f)(4)(ii).
Preamble states that generally it may not be appropriate to delete a site
before conducting at least one five-year review after completion of the
remedial action. 55 FR 8699.
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Applicable or relevant and appropriate requirements
O COMPLIANCE WITH LAND DISPOSAL RESTRICTIONS (LDm
"Placement" occurs when excavation of RCRA waste is followed
by treatment and replacement of residuals on land. Placement may
trigger LDR.
Preamble states that BDAT levels are presumed not to be appropriate for
contaminated soil and debris. Accordingly, when LDR is applicable to
soil and debris waste, a showing that BDAT is not appropriate is not
required to obtain a treatability variance.
Lead agency need only document in proposed plan and ROD that:
1. Wastes are soil or debris.
2. Compliance with LDRs will be achieved through treatability variance.
Alternative level selected should be based on the Superfund LDR
guide no. 6A.
55 FR 8758. -26-
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Applicable or relevant and appropriate requirements
O NEWLY PROMULGATED OR MODIFIED REQUIREMENTS:
"Freezing" ARARs at the ROD.
Requirements promulgated or modified after the ROD is signed
will be attained (or waived) only when determined to be ARAR
and necessary to ensure protectiveness.
NCP section 300.430(f)(1)(ii)(B)(7) and (2) and 55 FR 8757.
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Applicable or relevant and appropriate requirements
o SUBSTANTIVE VERSUS ADMINISTRATIVE REQUIREMENTS:
NCP requires compliance with cleanup standards, levels of control, and
other substantive environmental protection standards.
NCP specifically exempts compliance from administrative requirements,
including approval of, or consultation with, other programs, agencies,
or administrative bodies, issuance of permits, and reporting and
recordkeeping. EPA strongly encourages, however, coordination and
cooperation with the appropriate other programs or agencies.
55 FR 8756.
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Applicable or relevant and appropriate requirements
O COMPLIANCE WITH ARARs DURING IMPLEMENTATION:
NCP requires compliance during the remedial design and remedial
action steps, as well as its conclusion.
The requirements of other laws define how the activity can be
implemented in a manner that is protective of health and the
environment.
NCP section 300.435(a)(2) and 55 FR 8755.
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Applicable or relevant and appropriate requirements
O INFORMATION TO-BE-CONSIDERED (TBCs)
Criteria, advisories, or guidance that do not meet the definition of
ARARs but that may assist in determining what is necessary to be
protective or that are otherwise useful in developing Superfund
remedies are described as information to-be-considered (TBC).
Three general categories of TBCs are: (1) health effects information
with a high degree of creditability, e.g., reference doses;
(2) technical information on how to perform or evaluate site
investigations or response actions; and (3) policy, e.g., EPA's
ground-water policy.
NCP section 300.400(g)(3) and 55 FR 8744.
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Permit requirements
o Permits not required for activities conducted entirely on-site.
o On-site is defined as the areal extent of contamination and all
suitable areas in very close proximity to the contamination
necessary for implementation of the response action.
o NCP section 300.400(e) and 55 FR 8688.
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State involvement
O RESPONSIBILITIES WHEN EPA OR STATE IS LEAD AGENCY:
EPA retains ultimate authority to select remedies under CERCLA.
State may be lead agency for RI/FS and recommend a remedy to EPA.
A state may not issue a proposed plan that EPA has not approved.
EPA may assume the lead from the state if agreement cannot be
reached. If state disagrees with EPA-lead proposed plan, disagreement
must be noted in proposed plan.
Timeframes are the same for EPA and state review of each others'
documents.
NCP section 300.515 and 55 FR 8779.
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State involvement
O SUPERFUND MEMORANDUM OF AGREEMENT (SMOA^
SMOA describes general role and responsibilities of EPA and state
for all sites within a state, e.g., ARARs identification and documents
review. NCP section 300.505 and 55 FR 8776.
SMOA not required for state to be designated as lead agency at
Fund-financed site or to recommend a remedy to EPA.
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State involvement
O OPERATION AND MAINTENANCE
In general, state funds cost of operation and maintenance (O&M).
However, EPA will fund O&M for up to 10 years for treatment or
other measures to restore ground or surface water quality.
"Treatment or other measures" does not include:
o Source control maintenance measures (except if temporary or
interim measure, see 55 FR 8738-39), or
o Measures whose primary purpose is to provide drinking water.
NCP section 300.435(f) and 55 FR 8736.
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Public participation
o Public participation requirements are integrated into various phases of
removal and remedial activities, e.g., NCP sections 300.415(m), 300.430(c),
300.430(f)(3), 300.430(f)(6), and 300.435(c) and 55 FR 8766.
o Minimum 30-day public comment period can be extended an additional
30 days, upon timely request. NCP section 300.430(f)(3)(i)(C).
o At completion of remedial design, lead agency must issue fact sheet and
provide opportunity for public briefing. NCP section 300.435(c)(3).
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Administrative record
O LOCATION AND AVAILABILITY OF THE RECORD:
The record must be located at or near the site (in an information
repository) and at an office of the lead agency or another central
location. The record need not be available at or near the site, however,
for emergency removal actions that are concluded within 30 days of
initiation. NCP section 300.805 and 55 FR 8803.
Certain information need not be located at or near the site where it would
pose a substantial administrative burden, e.g., sampling and testing
data, guidance documents not generated specifically for the site, pub-
licly available technical literature. The index to the record, however,
shall indicate the availability of such items. NCP section 300.805
and 55 FR 8803.
The availability of the record must be announced in a major local
newspaper of general circulation. NCP sections 300.815 and 300.820
and 55 FR 8805.
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Administrative record
O ADDING DOCUMENTS AFTER THE ROD IS SIGNED:
Documents relating to remedy selection issues that the ROD reserves or
does not address, explanations of significant differences, and ROD
amendments. NCP section 300.825 and 55 FR 8807.
o RESPONDING TO COMMENTS RECEIVED BEFORE COMMENT PERIOD:
The lead agency is encouraged, but not required, to respond to signifi-
cant comments received before start of public comment period.
NCP sections 300.815 and 300.820 and 55 FR 8805.
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April 1990 EPA Region 10 - HW Policy Office
judi Schwarz (206) 442-2684 (FTS) 399-2684
THE REVISED FINAL NCP
INTRODUCTION
Previous final NCP - November 1985
Draft revised NCP published December 21, 1988
Final revised NCP published March 8, 1990 (40 CFR 300,
40 CFR 8666)
to reflect changes reguired by SARA
to reflect how EPA actually does business
The new NCP is very different from the 1985 NCP; not very
different from the 1988 draft or existing guidance or the way we
currently do business. This handout focuses on changes from the
1988 proposed NCP and/or positions that may affect the way we do
business.
Compliance with the NCP:
NCP Section 300.700(c)(i)
Reguires "substantial compliance" with the
reguirements.
Immaterial or insubstantial deviations are not
important.
Today's topics:
Page
Introduction and Organization of the NCP
Remedial Program Expectations and Goals
Early Actions
State Roles
Remedy Selection
ARAR Issues
RCRA ARARS
Risk Assessment and Remediation Goals
Groundwater and Surface Water Issues
Community Relations
Removals
Out-of-state Transfer of CERCLA Wastes
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4
6
7
11
14
15
17
19
20
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GENERAL ORGANIZATION OF THE NCP
Subpart A - Introduction
300.5 Definitions
Subpart B - Responsibility and Organization for
Response
Subpart C - Planning and Preparedness
Subpart D - Operational Response Phases for Oil Removal
Subpart E - Hazardous Substance Response**
Subpart F - State Involvement in Hazardous Substance
Response*
Subpart G - Trustees for Natural Resources
Subpart H - Participation by Other Persons*
Subpart I - Administrative Record for Selection of
Response Action*
Subpart J - Use of Dispersants and Other Chemicals
Subpart K - Federal Facilities (Reserved)
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REMEDIAL PROGRAM EXPECTATIONS AND GOALS
NCP Section 300.430(a)(1) - page 8846
Preamble - pages 8700 - 8703
Program Goal:
- Nothing much new - except that it's in the NCP proper
"The national goal of the remedy selection process is to
select remedies that are protective of human health and the
environment, that maintain protection over time, and that
minimize untreated wastes."
- The nine criteria determine the extent to which this goal
is satisfied.
Expectations:
- Now in the NCP proper.
- NOT binding requirements.
- Designed to guide the development of cleanup options.
There are 6 expectations:
a. Use treatment to address the principal threats wherever
practicable. Principal threats for which treatment is
most likely to be appropriate include:
liquids
areas contaminated with high concentrations of
toxic compounds
highly mobile materials
b. Use engineering controls, such as containment, for
waste that poses a relatively low long-term threat
(E.g. waste contaminated at low levels) or where
treatment is impracticable.
-Treatment is less likely to be practicable when
sites have large volumes of low concentration of
hazardous substances, or in wastes with widely
varying composition.
c. Combine methods as appropriate.
d. Institutional controls shall not substitute for active
response measures as the sole remedy unless such active
measures are determined not to be practicable. (See
the remedy selection section for a discussion of
"practicable.")
- Use institutional controls to supplement
engineering controls during the RI/FS and
implementation of the remedy, and where necessary,
as a component of the completed action.
e. Innovative technology will considered when:
-the technology offers the potential for
comparable or superior treatment performance or
implementability
-fewer or lesser adverse impact than the
alternatives
-or lower costs for similar level of performance
than demonstrated technologies
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f. Groundwater
-Usable groundwater will be returned to their
beneficial uses wherever practicable, within a
timeframe which is reasonable given the site.
-If restoration is not practicable, further
migration of the plume will be stopped, exposure
to the contaminated groundwater will be prevented
REMEMBER: THESE ARE EXPECTATIONS - NOT RULES. THE GOAL IS
FLEXIBLE, SITE-SPECIFIC DECISION-MAKING. THESE EXPECTATIONS DO
NOT SUBSTITUTE FOR SITE SPECIFIC ALTERNATIVES DEVELOPMENT AND
SCREENING - ONLY ASSIST IT.
HOW TO DO EARLY ACTIONS
Preamble: pages 8703 - 8706
Removals
We have been doing early actions at NPL sites under the
removal program since the beginning of the SF program. No
major changes.
Remedial Actions
Operable units - nothing much new.
- Use operable units to do early actions when necessary
or appropriate; to do phased analysis or response; to
deal with the size or complexity of the site; or to
speed the cleanup of the site.
- Operable units should not be inconsistent with the
expected final remedy
Let the paperwork fit the site and the action.
- All sections in the NCP describing the RI/FS include
the phrase "as appropriate."
- Focus on alternatives that show promise in achieving
the goals of the SF program.
A streamlined RI/FS may be particularly appropriate
when:
- site problems are straightforward with a limited
number of ways to address it.
- prompt action is needed
- ARARs limit the range of alternatives
- many alternatives are clearly impracticable
- no further action or only limited action is
required (esp. after a removal)
Act as soon as there is sufficient information
YOU DO NOT NEED TO FINISH AN RI/FS TO DO A REMEDIAL
ACTION - esp. an interim remedy.
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So what do you need (at a minimum) to do an interim action
as an operable unit under the remedial program?
- Extract data to support decision from the on-going
RI/FS or other source
- Develop few alternatives. (Sometimes only one
alternative need be developed.)
- Qualitative risk information to show that the
remedial action is necessary.
- Consider ARARs. (Waiver is available.)
- Involve the support agency.
- Involve the public.
- Involve the natural resource trustees.
- Document data and information in a focused
feasibility study, or, just in the proposed plan.
- Publish the Proposed plan and respond to public
comments.
- Prepare and sign the ROD.
You do NOT need:
- A baseline risk assessment
- A full RI/FS
- A definitive site characterization
For simple, straightforward interim actions, the total
documentation could be accomplished in just a few pages.
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STATE ROLES IN SUPERFUND
NCP Sections 300.500 - 300.525 - pages 8853-8857
Preamble - pages 8775 - 8786
Cooperation and coordination between agencies are encouraged.
States and Indian Tribes are encouraged to undertake all actions
that EPA is allowed to do under Section E.
Exceptions:
Emergencies and time-critical removals cannot be
state lead.
EPA must sign the ROD when Fund moneys are involved.
Superfund Memorandum of Agreement (SMOA):
Voluntary agreements.
Can establish review and comment periods between lead and
support agency. Such periods must be also documented in
site-specific cooperative agreements or Superfund state
contract.
SMOAs are no longer a prerequisite for any action.
Review and Response Periods when there is no SMOA:
- These NCP review periods apply to both the state and EPA
when they are operating as support agencies. (NCP. Section
300.515 (c) and (h))
NPL listing - 30 working days, to the extent feasible
ARAR identification - 30 working days
RI/FS, ROD, RD, ARAR/TBC determinations - 10 to 15
working days
Proposed plan - 5 to 10 working days
Institutional controls:
- State must provide assurances of institutional controls at
Fund-financed sites. (NCP section 300.510(c)(1), page 8854;
preamble page 8778.)
ROD preparation, concurrences, and selection of remedy:
(preamble 8782-8783)
- Agreements can provide for either agency to prepare the
proposed plan and ROD.
- Only EPA can sign the ROD/select the remedy, except when
the state is acting under state law instead of CERCLA.
- At Fund-financed sites, EPA can publish a proposed plan
without state concurrence; state cannot publish a proposed
plan without EPA concurrence.
- EPA approval requires written concurrence.
- At non-Fund financed state-lead sites:
- EPA is not bound by state action.
- EPA retains the right to act under its own CERCLA
authorities if needed.
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SELECTION OF REMEDY
"....A pragmatic and flexible valuation of potential
remedies at a site while still protecting human health and the
environment."
Development of alternatives
NCP Section 300.430(e) - pages 8848 - 8849
Preamble - pages 8714 - 8715
- Alternatives should be developed, as appropriate for the
particular situation at the site.
- Program expectations can help focus this development.
- If treatment is not practicable for all wastes at the
site, then complete treatment need not be included as
an alternative.
- If it is clear that treatment will be part of the
remedy, alternatives that rely solely on containment or
institutional controls and that do not include
treatment need not be considered.
- Innovative technologies - (p. 8714) See "Expectations"
section above. Eliminate from consideration only those
innovative technologies that have little potential for
performing well at specific sites.
Screening of Alternatives
NCP Section 300.4 30(e)(7), page 8849
Preamble pages 8714 - 8715
- To eliminate those alternatives that are not effective,
not implementable or whose costs are grossly excessive for
the effectiveness they provide.
- Cost is used in two ways to eliminate alternatives:
- When alternatives vary significantly in their
effectiveness, some alternatives are inordinately
costly for the effectiveness, e.g. total treatment of a
large municipal landfill.
- Where two or more alternatives provide similar levels
of effectiveness and implementability (using a similar
method of treatment or engineering control) but their
cost vary significantly.
Detailed Analysis of Alternatives
NCP Section 300.430(e)(9) - pages 8849-8850
Preamble - pages 8719 - 8723
- To present relevant information for the decision-making
step.
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Nine criteria
NEW - The three categories have been eliminated for
purposes of the detailed analysis.
Few changes to the nine criteria themselves:
1. Protection of human health and the environment -
draws on the assessments conducted under other
evaluation criteria, esp. long-term effectiveness and
permanence, short-term effectiveness, and compliance
with ARARs.
2. Compliance with ARARS - Either the PRP or a state
may perform the ARAR analysis and recommend the
applicability of ARAR waivers, but EPA determines
compliance with ARARs (and the applicability of ARAR
waivers) when it selects the remedial action, (p.8720)
3. Long-term effectiveness and permanence. Any
residual risk site after the response objectives have
been met.
- Permanence is judged along a continuum, with
remedies offering greater or lesser degrees of
long-term effectiveness and permanence.
4. Reduction of toxicity, mobility or volume through
treatment OR RECYCLING.
- EPA IS ESTABLISHING, AS A GUIDELINE, THAT
TREATMENT AS PART OF CERCLA REMEDIES SHOULD
GENERALLY ACHIEVE REDUCTIONS OF 90 TO 99 PERCENT
IN THE CONCENTRATION OR MOBILITY OF INDIVIDUAL
CONTAMINANTS OF CONCERN.
5. Short-term effectiveness
6. Implementability
7. Cost - Evaluates and compares the cost of the
alternatives. To include direct and indirect capital
and O&M costs, as well as certain replacement costs.
DOES NOT MAKE ANY CONCLUSION RE THE COST-EFFECTIVENESS
OF THE ALTERNATIVES. COST-EFFECTIVENESS IS DETERMINED
AT THE SELECTION OF REMEDY STAGE.
8. State acceptance
9. Community acceptance.
Procedure:
- Assess each alternative individually assessed against
the nine criteria.
- Comparative analysis to identify the key tradeoffs
(relative advantages and disadvantages) among the
alternatives with respect to the nine criteria.
Remedy Selection
NCP Section 300.430(f) - page 8851
Preamble - pages 8723 - 8731
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Flexibility: Each SF site presents a different set of
circumstances. Many different ways to fulfill each statutory
mandate.
Same nine criteria but used differently.
Threshold:
1. Protection of human health and the
environment
2. Compliance with ARARS
Primary Balancing:
Balancing is the key concept during the selection
of remedy.
3. MORE IMPORTANT: Long-term effectiveness and
permanence
4. MORE IMPORTANT: Reduction of toxicity,
mobility or volume through treatment or recycling.
5. Short-term effectiveness
6. Implementability
7. Cost (See below)
Modifying:
8. State acceptance
9. Community acceptance.
Modifying criteria: Generally considered in altering an
otherwise viable approach rather than in deciding between
very different approaches.
Statute, and now NCP, has a bias against off-site land
disposal of untreated waste. Neither has a bias for or
against off-site remedies involving treatment.
Statutory Determinations and The Role of Cost in Remedy Selection
Cost is considered in making two statutory determinations
required for selected remedies: (p. 8728 - 8731)
- That the remedy is cost-effective (i.e. the remedy
provides effectiveness proportional to its cost); and
- That the remedy utilizes permanent solutions and treatment
to the maximum extent practicable.
COST-EFFECTIVENESS:
- Are costs proportional to the effectiveness
achieved?
- Overall effectiveness includes long-term
effectiveness and permanence; reduction of
toxicity, mobility or volume through treatment;
and short-term effectiveness.
"Proportional" includes:
- the cost and effectiveness of each alternative
individually. (What is the relative magnitude of cost
to the effectiveness of the alternative?) and,
the cost and effectiveness of alternatives in
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relation to one another. (What is the incremental cost
difference in relation to the incremental differences
in effectiveness?)
Best professional judgement is used.
Strict mathematical proportionality is not
intended. Incremental differences is the key.
More than one alternative may be cost-effective.
COST AND PRACTICABILITY:
-Uses the same criteria as cost-effectiveness, plus
implementability of the remedy, and state and community
acceptance.
The two statutory determinations are separate findings that
result from balancing conducted during the remedy selection
process.
Chancres to the ROD after its adoption
NCP Section 300.435(c) - pages 8852
Preamble pages 8771- 8773
(Also, see section below on post-ROD ARAR changes.)
Three types of changes:
1. Non-significant changes -
- Examples:
- changes in the cost or type of materials,
equipment, etc.)
- Document in the post-ROD file.
2. Significant changes - incremental changes to a
component of a remedy that do not fundamentally alter the
overall remedial approach.
- Examples: -timing changes
- cost increases (more volume, cost up 50%)
- some technology changes ( carbon adsorption
instead of air stripping)
- Requires an explanation of significant differences to
be published. No formal public comment period
required, but comments that present substantial new
information must be considered.
3. Fundamental changes - the proposed action, with respect
to scope, performance, or cost, is no longer reflective of
the selected remedy in the ROD.
- Example: Innovative technology will not achieve
remediation goals, so a different technology will be
used.
- Requires a ROD amendment, including a proposed plan,
full public comment period, and response to comments.
ROD amendment public comment period can be concurrent
with public comment periods on consent decrees.
- ESDs and ROD amendments require consulting with support
agencies.
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ARAR ISSUES
NCP - Identification of ARARs; Factors to determine
relevant and appropriate: Section 300.400(g), page
8841
- Waivers and post-ROD ARAR changes: Section
300.430(f)(1), page 8850
Preamble - pages 8741 -8766
(Also see Groundwater Issues section below.)
General Points
No major changes:
- Federal, state, (and tribal) ARARs must be attained
for on-site actions.
- ARARs do not apply to off-site actions. All
applicable rules, including obtaining permits, apply to
off-site actions.
- ARARs apply to removals "to the extent practicable
considering the exigencies of the situation."
- A variance or exemption provision in a regulation can
be a potential ARARs as well as the basic standard,
(e.g. Treatability variances under LDR for soil and
debris.)
- ARARs must be attained during the implementation of
the remedial action, where the ARAR is pertinent to the
action itself, as well as at the completion of the
action.
- In general, state regulations under federally
authorized programs are considered federal
requirements.
- Need only meet ARARs within the scope of an interim
action.
Definition of on-site: the areal extent of contamination and
all suitable areas in very close proximity to the contamination
necessary for implementation of the response action. (Section
300.400(e), page 8841)
Relevant and Appropriate Determination:
(Preamble pages 8742 - 8744)
Eight factors are used. (No major changes.)
No single factor alone sufficient.
May find parts of a regulation to be relevant and
appropriate.
To be Considered (TBCs):
Identification of all possible TBCs is not longer
necessary.
TBCs to be identified and used "as appropriate."
TBC are meant to complement the use of ARARs, not
to be in competition with ARARS.
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Timely identification of ARARs:
(preamble page 8746-8747)
When there is a SMOA, the SMOA will identify the
deadlines for identifying ARARS.
When there is no SMOA, potential ARARs must be
sent to the lead agency within 3 0 WORKING
DAYS of the receipt of a request from the
lead agency.
ARARs are requested at two steps in the process.
Points of compliance:
Preamble - page 8713
- Air - The selected levels should be established for
the maximum exposed individual, considering reasonable
expected use of the site and surrounding area.
- Surface water - the selected levels should be
attained at the point or points where the release
enters the surface water.
- Groundwater - see below.
Soil - silent
Compliance with ARARs during RIs (and pre-remedial work);
NCP Section 300.410(i) - page 8843
Preamble - pages 8755 - 8756
- Studies are removal actions undertaken pursuant to
CERCLA section 104(b), but are not subject to the
statutory limits on removals.
- Like removals, ARARs need to be complied with during
RIs "to the extent practicable, considering the
exigencies of the situations."
Will involve the use of best professional judgement.
ARAR Waivers
NCP Section 300.430(f)(1)(ii)(C) - page 8850
Preamble - pages 8747 - 8750)
Nothing much new, except as noted.
- Interim measures. Interim measure are expected to be
followed by remedial actions which attain ARARs within
a "reasonable time." Reasonable time is not pre-set,
but is a site-specific decision. Factors to consider
include funding and priorities.
- Greater risk to health and the environment.
- Technical impracticability. From an engineering
perspective. Includes engineering feasibility and
reliability. Cost plays a subordinate role.
- Equivalent standard of performance. Not based on a
comparison of exposure risk, unless the original
standard is risk-based. Based on equivalent degree of
protection, level of performance and future
reliability.
- Inconsistent application of state requirements. A
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standard is presumed to have been consistently applied
unless these is evidence to the contrary.
- Fund balancing. New policy. EPA will routinely
consider, not necessarily invoke - the Fund-balancing
waiver at a threshold point. Threshold point - a
single action that would be four times the cost of an
average operable unit. Fund balancing could also occur
at a lower cost as well, if necessary.
ARARs identified after the ROD is signed:
NCP - Section 300.430(f)(ii), page 8850
Preamble - page 8747 and 8757 - 8758
ARARs are basically frozen when the ROD is signed.
Two exceptions:
1. If a component of a remedy is not identified
a the time of ROD signing, requirements in effect
when the component is later identified (e.g.
during remedial design) will be used to determine
ARARS.
2. Compliance is necessary to necessary to
maintain protectiveness. Primarily done as part
of the five year review.
Requirements applicable to off-site actions are
never frozen.
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RCRA ARARS
Preamble pages 8758 - 8764
Placement:
- The definition of "placement" has not changed.
- Treatment and placement is considered "placement."
CERCLA Area of Contamination (AOC):
- Can include widespread areas of generally dispersed
contamination.
- Not identical to a RCRA "unit," but generally-
analogous .
- Consolidation or movement of material within an AOC
not subject to any applicable RCRA regulation.
- Consolidation from different AOCs are subject to
applicable RCRA requirements.
LDR Treatability Waivers for soil and debris:
"EPA has determined that, until specific standards for soils
and debris are developed, current BDAT standards are generally
inappropriate or unachievable for soil and debris from CERCLA
response actions and RCRA corrective actions and closures.
Instead, EPA presumes that, because contaminated soil and debris
is significantly different from the wastes evaluated in
establishing the BDAT standards, it cannot be treated in
accordance with those standards and thus qualifies for a
treatability variance from those standards under 40 CFR 268.44."
(page 8760)
- No case-by-case demonstration of inappropriateness or
unachievability needed.
- Contaminated soil and debris should meet the
percentage reduction out-lined in Superfund LDR
Guidance #6A, "Obtaining a Soil and Debris Treatability
Variance for Remedial Actions. EPA OSWER Directive
9347.3-06FS, July 1989, to be revised shortly.
- Some exceptions, especially with soils with high
levels of combustible organics, and, maybe, soils and
debris with dioxin. In these cases, EPA may determine
that the existing BDAT standards are appropriate for
that particular site and would require such treatment
(e.g. combustion.)
NOTE: Even though we have guidance stating so, the NCP
never says that the LDR are never relevant and appropriate to
soil and debris.
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RISK ASSESSMENT AND REMEDIATION GOALS
NCP Section 300.430(e)(2)(i) - page 8848
Preamble - pages 8709 - 8711, 8713, 8715 - 8718
Risk Assessment - Two objectives:
1. Baseline risk - the risks that exist if no
remediation or institutional controls are applied to a
site.
ie. Is remediation necessary?
Which exposure pathways need to be remediated?
2. Help establish acceptable exposure levels
Exposure scenarios:
- Use "reasonable maximum exposure scenario".
- A "part of a lifetime" exposure duration can be used.
Remediation goals:
- A subset of remedial action objectives
- Medium-specific or operable unit specific protective
chemical concentrations
- Serve as goals for remedial action.
Preliminary remediation goals:
- Used to focus the development of, and to limit the
number of, alternatives, during the RI/FS.
- Developed based on readily available information
(e.g. environmental or health based ARARS like MCLs).
- modified, as necessary, during the RI/FS.
- Alternatives that attain other risk levels can be
developed.
Final remediation goals:
- Determined when the remedy is selected.
- Based on the balancing of criteria in the remedy
selection process.
Remediation goals: risk assessment vs. ARARs:
- EPA will use chemical-specific/health-based ARARs in
determining remediation goals for SF sites.
- Exceptions:
1) ARARs are not sufficiently protective:
multiple contaminants or pathways where attainment
of chemical-specific ARARs will result in
cumulative risk in excess of 10-4(p. 8718, p.
8848),
2) No ARARs are available.
In these exceptions, risk assessment will be used when
determining the cleanup level.
- 10-6 is the point of departure for establishing
preliminary remediation goals.
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- Acceptable exposure levels: 10-4 to 10-6 incremental
individual lifetime cancer risk, with a preference for
the more protective end of the range.
- Cleanups to levels more stringent than 10-6 allowed
in exceptional circumstances, (page 8716 and 8717)
- Cleanup level and remedy are selected by balancing
site-specific and remedy-specific factors, including:
- exposure factors
- assumptions and uncertainty factors
- technical factors
- the nine criteria.
Similar approaches are used for non-carcinogens and
ecological and environmental effects.
Non-carcinogens - exposures should present no
appreciable risk of significant adverse effects to
individuals.
Environmental evaluations may be necessary where
sensitive ecosystems and critical habitats of
threatened or endangered species exist.
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GROUNDWATER AND SURFACE WATER ISSUES
NCP Section 300.430(e)(2)(i) - page 8848 (MCLs vs.
MCLGs)
Preamble - pages 8732 - 8735
MCLs and MCLGs - pages 8750 - 8752
point of compliance - pages 8753 - 8755
Goal: return usable ground waters to their beneficial uses
within a timeframe that is reasonable given the particular
circumstances of the site.
Role of the draft EPA groundwater classification system:
- help set the remediation goal for groundwater restoration,
the timeframe for restoration, and most appropriate method
to achieve these goals.
- THESE GUIDELINES ARE NOT ARARS, BUT ARE ONLY USED TO HELP
DEFINE SITUATIONS FOR WHICH STANDARDS MAY BE APPLICABLE OR
RELEVANT AND APPROPRIATE AND HELP SET GOALS FOR GROUNDWATER
REMEDIATION.
- State or Indian tribe's classification may supersede.
Restoration timeframes:
-reasonable timeframes may range from very rapid (one to
five years) to relatively extended (perhaps several
decades.)
- Rapid restoration is preferred for Class I groundwaters or
current drinking water sources. If there are alternative
drinking water sources, the necessity for rapid restoration
of groundwater may be reduced.
- Rapid restoration may also be appropriate when
institutional controls are not reliable.
Remediation goals: MAJOR POLICY CHANGE FROM THE PROPOSED NCP.
For class I and II groundwaters:
- If MCLG is above zero, MCLG may be relevant and
appropriate. If MCLG is not relevant and appropriate
to the circumstances of the release, the corresponding
MCL may be relevant and appropriate.
- If MCLG is zero, EPA has determined that the MCLG is
not appropriate. The MCL may be relevant and
appropriate, considering the circumstances of the
release.
- MCLs are never applicable except at the tap.
For class III groundwaters:
-drinking water standards are not ARARs and are not
used to set preliminary remediation goals.
For surface water:
- MCLs and non-zero MCLGs will generally be the
relevant and appropriate standards for surface water
designated as a drinking water supply, unless the state
has promulgated water quality standards for the water
body that reflects the specific conditions of the water
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body.
-The Federal Water Quality Criteria should not be used
to substitute for MCLs and non-zero MCLGs, but may be
used when there are other uses of the water (e.g.
aquatic organism, fishing) or when there are no MCLs.
Alternate concentration limits (ACLs) under CERCLA:
- Use of ACLs is limited under CERCLA.
- In addition to the statutory limitations, the preamble
adds the demonstration that cleanup to MCLs or other
protective levels is not practicable.
- If a site situation qualifies for an ACL, an additional
ARAR waiver of MCLs or MCLGs is not necessary.
Point of Compliance for Groundwater:
- remediation levels should generally be attained
throughout the contaminated plume, or at and beyond the
edge of the waste management area when waste is left in
place.
- alternate points of compliance may be
acceptable/protective when:
- the plume of groundwater contamination is from
several distinct sources that are in close
geographic proximity. Can then address the
problem as a whole, but individual source control
actions still required.
- NEW - A remote site with little likelihood of
exposure. However, contaminated groundwater must
be controlled from further migration.
Natural attenuation:
Natural attenuation is recommended only when:
- active restoration is not practicable, cost-effective
or warranted because of site-specific conditions, or
- where natural attenuation is expected to reduce the
concentration of contaminants in the groundwater to the
remediation goals in a reasonable timeframe, or in a
timeframe comparable to that achieved through active
restoration.
- May also be important once pump and treat systems
have reached their limit. (E.G. as an alternative to
changing the remediation goals.)
- Institutional controls may be necessary.
Remember too the management expectation mentioned above:
when groundwater restoration is not practicable, remedial action
will focus on plume containment to prevent contaminant migration
and further contamination of the groundwater, prevention of
exposures, and evaluation of further risk reduction.
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At Fund-lead sites, who pays for operating the groundwater and
surface water facilities?
- Complex.
- State pays for O&M of source control measures.
- Fund pays 90% for up to 10 years of certain ground and
surface water restoration measures.
- Exception: Certain interim measures. EPA will consider
interim measures to be "remedial actions" if it is both
necessary and desirable in order to control or prevent the
further spread of contamination while the lead agency is
deciding upon a final remedy for the site. (preamble pages
8736 - 8740)
COMMUNITY RELATIONS
NCP Section 300.415(m) - CR in Removal Actions, page 8842
300.430(c) - CR during the RI/FS, page 8847
300.430(f)(2) and (3) - Proposed plans and
CR to support remedy selection, page 8851
300.430(f)(6) - CR when the ROD is signed, page
8852
300.435(c) - CR during RD, RA, and O&M, page
8852
300.700(c)(6) - CR during private party actions,
page 8858
Preamble pages 8766 - 8774
- No major changes in the way we do business.
Exception:
Comment periods on time-critical and non-time
critical removals are a minimum of 30 days. For
non-time critical removals, the lead agency will
extent the public comment period by a minimum of
15 days upon timely request.
Comment period on the proposed plan, etc, is a
minimum of 30 days, with an extension of the
public comment period by a minimum of 30
additional days upon timely request.
- Community relations starts at the pre-remedial stage and
continues throughout the remedy construction and operation.
Community relations does not stop at the ROD.
- Includes sections on PRP involvement, community
involvement in technical discussions with PRPs, equal
community and PRP access to information on the site.
If private party actions want to be "consistent with the
NCP" for cost-recovery purposes, they must also follow many
of these same community relations/public involvement
activities, (preamble page 8795)
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REMOVALS
NCP Section 300.415 (pages 8842 - 8844)
Preamble pages 8694 - 8698
Very few changes to the removal program in the NCP.
Main changes are:
- Clarifies community relations and administrative
record requirements
- ARARs apply to the extent practicable
- Codifies statutory increase of time and dollar limits
to 12 months and $2 million.
OUT-OF-STATE-TRANSFER OF CERCLA WASTE
Preamble page 8740
(Not in the NCP proper)
If SF waste is going to be shipped out-of-state, evg. to a
permitted waste management facility, the lead agency should
provide written notice to the receiving state prior to shipment
of the SF wastes. Notice should be provided for all remedial
actions and non-time critical removal actions, including Fund-
lead, state lead, federal facility and PRP responses.
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^eos%
' &% To UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
February 1990
QUESTIONS AND ANSWERS REGARDING THE 1990 NCP
INTRODUCTION
What is the National Contingency Plan (NCP)?
o The NCP is the major framework regulation for the federal
hazardous substance response program. The NCP includes
procedures and standards for how EPA, other federal
agencies, states, and private parties respond under the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) to releases of hazardous substances
and under the Clean Water Act to discharges of oil.
What is the purpose of the revisions to the NCP?
o CERCLA, originally enacted in 1980, was amended by the
Superfund Amendments and Reauthorization Act of 1986
(SARA), which mandates that the NCP be revised to implement
the requirements of SARA, particularly with regard to
procedures and standards for remedial actions.
o The revisions also clarify 1985 NCP language, reorganize the
1985 NCP to describe more accurately the sequence of
response actions, and incorporate changes based on program
experience since the 1985 revisions to the NCP.
What is the relationship between the revised NCP and the
Management Review of tne Superfund Program (the 90-day Study)?
o The 1990 (or final) NCP is consistent with, and embodies the
spirit of, the 1989 Management Review of the Superfund
Program. Both documents describe what the program
realistically can accomplish and emphasize the need for
taking action -- rather than prolonged investigation and
analysis at sites. The documents also recognize the
importance of increased state participation and public
involvement in the Superfund program. The documents differ
in that the Management Review focused on EFA's internal
management of the program and left certain national policy
decisions, e.g., the process of deciding on cleanups, to be
addressed in the NCP. EPA believes that together the 1990
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NCP and the Management Review provide a firm basis for
progress in cleaning up the nation's worst toxic waste
problems.
What are the major areas of change from the 1985 NCP to the 1990
NCP?
Note: More detail on each of these major changes is provided
below.
o Subpart E (Subpart F in the 1985 NCP) which addresses the
elements of hazardous substance response is significantly
revised. EPA's process implements the requirements of
CERCLA 121 and focuses on selection of treatment
technologies, uses nine specified criteria when evaluating
and selecting remedies, provides for conducting early
actions, and encourages streamlining of remedial activities.
o subpart-. F on state involvement is a new subpart added to
implement the 1986 statutory mandate to promulgate
regulations for substantial and meaningful state involvement
in CERCLA response actions. The major new concepts are
Superfund Memoranda of Agreement (SMOAs) between EPA regions
and states and EPA/state concurrence in remedy selection.
o -Snhpart-- T is a new subpart added to implement the 1986
statutory requirements for the establishment of an
administrative record. The record contains documents that
form the basis for the selection of a remedy at a CERCLA
site.
What sections from the 1985 NCP have generally remained unchanged?
o Subpart A. the introduction, defines key terms
and states the purpose, authority, applicability,
and scope of the NCP. Some definitions have been added,
e.g., "source control maintenance measures," and some
definitions have been revised, e.g. "CERCLIS" and
"cooperative agreement," but most definitions remain
unchanged.
o Subpart B describes the organization and responsibility of
federal agencies regarding response activities. For
example, roles and responsibilities of the National
Response Team (NRT) and the Regional Response Teams (RRT)
are described. The revised Subpart B combines the 1985
NCP's Subparts B and C without major revisions.
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o subpart c addresses preparedness activities,
federal and regional contingency plans, and planning
responsibilities of state and local agencies. The revised
Subpart C contains information from the 1985 NCP's Subpart D
and adds information on SARA Title III.
o Subpart D sets forth the phases of response to discharges
of oil and contains no major revisions from the 1985 NCP.
o Subpart G contains the designations of federal trustees to
act on behalf of the President in assessing damages to
natural resources from discharges of oil or releases of
hazardous substances. Subpart G also outlines in general
the responsibilities of trustees under the NCP.
o Subpart H is a new subpart that consolidates 1985 NCP
language on participation by other persons in response
activities and recovery of their costs. Persons conducting
a cleanup may recover their costs from a party liable under
CERCLA 107 if they substantially comply with requirements
of the NCP and conduct a "CERCLA-quality cleanup."
o Subpart J on use of dispersants for oil spills is similar to
the 1985 NCP's Subpart H; only minor clarifying revisions
have been made.
Why was the NCP on a court-ordered schedule?
o In the fall of 1988, the Natural Resources Defense
Council and several other national environmental groups
sued EPA for failure to meet the statutory deadline
(April 17, 1988) for revising the NCP. EPA's response
indicated that because of the magnitude of the project,
the number of interests involved, and the Agency's
efforts to achieve consensus among all parties, the
process was taking longer than anticipated to complete.
To resolve the litigation, the parties agreed to a
schedule for completion of revisions to the NCP that
would result in the delivery of the 1990 NCP to the
Federal Register by February 5, 1990.
How does the Hazard Ranking System (HRS) relate to the NCP?
o The HRS is Appendix A to the NCP (40 CFR Part 300). The
HRS is the mechanism used to evaluate whether releases
should be listed on the National Priorities List (NPL).
The NPL is a list of releases that appear to warrant
long-term evaluation and response. EPA proposed
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revisions to the HRS in a separate rulemaking on
December 23, 1988 (53 FR 51962).
What are some of the common abbreviations used in the NCP?
ARARs Applicable or relevant and appropriate
requirements.
FS Feasibility study.
HRS Hazard Ranking System.
NPL National Priorities List.
OSC On-scene coordinator.
O&M Operation and maintenance.
PRP Potentially responsible party.
RA Remedial action.
RD Remedial design.
RI Remedial investigation.
ROD Record of decision.
RPM Remedial project manager.
SMOA Superfund Memorandum of Agreement.
TBC -- Criteria, advisories or guidance to-be-considered.
REMOVAL PROGRAM
How is the removal program modified under the 1990 NCP?
o The NCP codifies the increase in the statutory time and
dollar limits for Fund-financed removal actions from 6
months and $1 million to 12 months and $2 million.
o The NCP also codifies a statutory exemption from these
limits: where continued response is otherwise appropriate
and consistent with the remedial action to be taken. EPA
expects to use the exemption primarily for proposed and
final NPL sites, and only rarely for non-NPL sites.
o The NCP confirms EPA's policy that removal actions will
comply to the extent practicable with applicable or
relevant and appropriate requirements under other federal or
state environmental laws
o Requirements relating to community relations and
administrative record are discussed in other sections
below.
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RETMF.nTAT, PROGRAM
What changes does the 1990 NCP make in the remedial response
program?
o The final rule implements the statutory requirements to
select remedies that:
Protect human health and the environment.
Comply with applicable or relevant and appropriate
requirements (ARARs) under federal environmental or
state environmental or facility siting laws (or invoke a
waiver).
Are cost-effective.
Use permanent solutions and treatment to the maximum
extent practicable.
Satisfy the preference for remedies in which treatment
that permanently reduces the toxicity, mobility, or
volume of hazardous substances, pollutants, or
contaminants is a principal element.
What are some of the features of the final remedy selection
process?
o In the remedy selection process, a range of alternatives
should be developed, representing distinct, viable
approaches to managing the site problem. For source control
response actions, a range of alternatives involving
treatment as a principal element should be included, as well
as containment and no-action alternatives, as appropriate.
For ground-water response actions, alternatives should be
developed that restore usable ground water to beneficial
uses within a timeframe that is reasonable given particular
site circumstances.
o When selecting the preferred approach, the following nine
criteria are used to compare relative advantages and
disadvantages of the alternatives under consideration:
Threshold
1. Overall protection of human health and the
environment.
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2. Compliance with applicable or relevant and
appropriate requirements (or invoke a waiver).
Balancing
3. Long-term effectiveness and permanence.
4. Reduction of toxicity, mobility, or volume through
treatment.
5. Short-term effectiveness (e.g., environmental impacts of
the cleanup itself).
6. Implementability (e.g., whether technology being
considered is available within the necessary timeframe).
7. Cost.
Modi fvina
8. State acceptance.
9. Community acceptance.
How does EPA intend that these categories of criteria be used?
o An alternative must meet the threshold criteria in order to
be selected; these requirements are taken directly from
CERCLA and cannot be compromised.
o The balancing and modifying criteria were developed to
encompass other CERCLA requirements. One requirement is to
use permanent solutions and treatment to the maximum extent
practicable. By including practicability, Congress appeared
to acknowledge that not all of the waste at a site may be
treated and that judgments would be required on whether or
to what extent permanent solutions and treatment would be
used (and the extent to which waste is left on-site). EPA
believes that these judgments are dependent upon site
conditions and technological, economic and implementation
constraints. By evaluating and comparing the alternatives
by means of the balancing and modifying criteria, the
decision-maker can make the site-specific judgments
necessary to select the most appropriate approach.
o State and community concerns, encompassed by the modifying
criteria, generally are considered in altering an otherwise
viable approach rather than in deciding between very
different approaches, e.g., treatment versus containment.
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How does this process differ from the process outlined in the
proposed NCP?
o The 1990 NCP process has been revised from what was
proposed in order to encourage selection of more treatment
remedies (and to comply with the CERCLA preference for
remedies that employ treatment as a principal element). The
two criteria of "long-term effectiveness and permanence" and
"reduction of toxicity, mobility or volume through
treatment" are given the most weight in the balancing
process.
o Also, the threshold, balancing, and modifying labels have
been removed from the discussion of the nine evaluation
criteria during the detailed analysis of alternatives.
During the detailed analysis, each alternative approach
should be evaluated using each of the nine criteria, without
assigning greater weight to any of the criteria. The
categories of criteria are now part of the remedy selection
step.
What is the meaning of a "bias for action" stated in the NCP?
o Bias for action means that actions should be taken, as
early as possible, when necessary or appropriate to achieve
significant risk reduction quickly, when phased analysis and
response is necessary or appropriate given the size or
complexity of the site, or to expedite the completion of
total site cleanup.
What is "streamlining?"
o Streamlining means tailoring site-specific data needs, the
evaluation of alternatives, and the documentation of the
selected remedy to reflect the scope and complexity of the
specific site problems being addressed. For example, a
streamlined RI/FS can be used when site problems are
straightforward such that it would be inappropriate to
develop a full range of alternatives.
To what extent does EPA intend to clean up ground water?
o The goal of EPA's Superfund ground-water approach is to
return usable ground waters to their beneficial uses within
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a timeframe that is reasonable, given the circumstances at
the site.
o EPA intends to restore contaminated ground water that is a
current or potential source of drinking water to levels that
are safe for drinking. EPA intends to attain such levels
throughout the contaminated plume, except directly below any
waste that is left in place.
What is a "risk range" and how does it relate to selection of
remedial actions?
o Contaminants that are considered carcinogenic are thought to
pose a risk at any level of exposure. This risk may be
small or large depending on the amount and duration of
exposure and the type of carcinogen involved. When
Superfund cannot entirely eliminate potential exposure to a
carcinogen, it determines that a remedy protects human
health when the amount of exposure is reduced so that the
risk is very small, i.e., at an acceptable level.
o The 1990 NCP states that generally acceptable levels fall
within a range of 10-4 to 10-6. This means that an
acceptable exposure is when the excess risk to an individual
of contracting cancer due to a lifetime exposure to a
certain concentration of a carcinogen falls between 10-4 to
10-6.
o The proposed revisions to the NCP had included a risk range
of 10-4 to 10-7. The risk range for Superfund cleanups
included in the final rule is consistent with the accepted
de minimis level used by other EPA programs and other
federal agencies. It also reflects currently available
analytical and detection techniques.
o The point of departure when using the risk range is 10~5.
The point of departure is the starting point for acceptable
exposure levels when analyzing various approaches to
cleaning up a site. This 10"^ risk level may be revised
based on exposure, uncertainty, or technical factors.
What actions are interpreted to fall under the 10-year provision
regarding the remediation of ground water?
o CERCLA section 104(c)(6) defines remedial action to include
the operation of measures to restore contaminated ground or
surface water for a period of up to 10 years after the
commencement of operation of such measures. The practical
effect is that federal funds will be used to pay 90 percent
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(or 50 percent for a publicly operated site) of the cost of
ground or surface water restoration for up to 10 years. The
state will pay the difference. This provision, however,
does not apply:
To source control maintenance measures initiated to
prevent contamination of ground or surface waters.
To ground or surface water measures initiated for the
primary purpose of providing a drinking water supply,
not for the purpose of restoring ground water.
How does EPA define "on-site" for purposes of the CERCLA section
121(e) exemption from obtaining federal, state, or local permits
for activities conducted entirely on-site?
o EPA defines "on-site" as the "areal extent of contamination
and all suitable areas in very close proximity to the
contamination necessary for implementation of the response
action." Flexibility in defining "on-site" is necessary in
order to provide expeditious response to site hazards.
What are the requirements for deleting sites from the NPL?
o Sites may be deleted from or recategorized on the NPL where
no further response is appropriate and any of the following
criteria has been met:
Responsible parties or other persons have implemented
all appropriate response actions required.
All appropriate Fund-financed response under CERCLA has
been implemented, and no further response action by
responsible parties is appropriate.
The remedial investigation has shown that the release
poses no significant threat to public health or the
environment and, therefore, taking of remedial measures
is not appropriate.
o EPA must obtain state concurrence in order to delete a site
from the NPL. Also, EPA must provide the opportunity for
public comment on a proposed deletion.
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What is the "Construction Completion" category.
o EPA has established a new "category" as part of the NPL,
the "Construction Completion" category. Sites may be
categorized as "construction complete" only after remedies
have been implemented and are operating properly. These may
be:
Sites awaiting deletion.
Sites awaiting five-year review and/or deletion (see
next question on five-year reviews).
Sites undergoing long-term remedial actions (LTRAs).
LTRAs are taken at sites where activities over a
relatively long duration are necessary in order to
attain cleanup levels identified in the ROD (e.g., pump
and treat of ground water for many years).
How does EPA ensure that sites remain safe after the remedial
action has been completed?
o The NCP requires a review of a site where waste is left
behind at least once every five ye",rs to ensure that the
site remains safe. No site will be deleted from the
National Priorities List (NPL) after completion of the
cleanup until at least one five-year review has been
conducted.
What contractor conflict of interest requirements are in the 1990
NCP?
o For Fund-financed remedial design/remedial action (RD/RA)
and operation and maintenance (O&M) activities, the NCP
requires the lead agency to include appropriate language in
solicitations requiring potential prime contractors to
submit information about their status, as well as the status
of their subcontractors, parent companies, and affiliates,
as potentially responsible parties at a site.
o Prior to contract award, the lead agency must evaluate the
information to determine if a conflict of interest exists
that could significantly impact the performance of the
contract or the liability of the prime contractors or
subcontractors.
o The purpose of this evaluation is to decide whether more
oversight of the performance of the contract is appropriate
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or whether a contractor has an unresolvable conflict of
interest such that it should be declared nonresponsible or
ineligible for contract award.
DEFERRAL POLICIES
The preamble to the proposed NCP solicited public comment on the
possible expansion of the Agency's policy for deferring the
listing of sites on the National Priorities List for response
under other authorities. What was EPA's decision on expanding the
policy?
o EPA decided not to establish an expanded deferral policy at
this time. EPA is still evaluating the complex issues
involved and believes that any changes in this policy are
best decided within the context of CERCLA reauthorization.
Current policies with regard to what sites are appropriate
for inclusion on the NPL will remain in effect.
APPLICABLE OR RFT.FTVANT and APPROPRIATE REQUIREMENTS (ARARs)
What are applicable requirements?
o Applicable requirements are cleanup standards, standards of
control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under
federal environmental or state environmental or facility
siting law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance found at a CERCLA site.
What are relevant and appropriate requirements?
o Relevant and appropriate requirements are cleanup
standards, etc. that, while not applicable, address
problems or situations sufficiently similar to those
encountered at a CERCLA site that their use is well-suited
to the particular site.
How does the 1990 NCP change the role of ARARs?
o Prior to the 1986 amendments, EPA required compliance with
all federal ARARs, but only consideration of state
requirements. The 1990 NCP incorporates the new statutory
requirement that remedies must comply not only with ARARs
under federal laws, but also with promulgated standards,
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requirements, criteria, or limitations under state
environmental or facility siting laws that are more
stringent than corresponding federal standards. The 1990
NCP defines "promulgated" state requirements as those laws
or regulations that are of general applicability and are
legally enforceable.
o The 1990 NCP provides that the lead and support agency
identify their respective federal and state ARARs in a
timely manner. "Timely manner" is defined in Subpart F as
sufficient time for the lead agency to consider and
incorporate ARARs into the remedy selection process without
inordinate delays and duplication of effort.
o The 1986 amendments establish six limited exceptions or
waivers to the general mandate that remedial actions attain
all ARARs. The NCP specifies the six waivers:
The alternative is an interim measure and will become
part of a total remedial action that will attain ARARs.
Compliance with ARARs will result in greater risk to
human health and the environment than other
alternatives.
Compliance with ARARs is technically impracticable from
an engineering perspective.
Another alternative that does not comply with the ARAR
will result in an equivalent standard of performance.
The state ARAR has not been consistently applied in
similar circumstances.
Attainment of ARARs will not provide a balance between
the need for protection of human health and environment
at the site and the availability of Fund monies to
respond to other sites. The preamble to the 1990 NCP
suggests a threshold for routine consideration of this
waiver at four times the average cost of an operable
unit.
Can non-promulgated criteria, such as advisory levels or guidance,
be considered when determining cleanup standards?
o Criteria, advisories, or guidance that do not meet the
definition of ARARs but that may assist in determining what
is necessary to be protective or that are otherwise useful
in developing Superfund remedies are described as
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information to-be-considered (TBC). Three general
categories of TBCs are: (1) health effects information with
a high degree of creditability, e.g., reference doses; (2)
technical information on how to perform or evaluate site
investigations or response actions; and (3) policy, e.g.,
EPA's ground-water policy.
o The proposed NCP's description of TBCs was revised in the
1990 NCP to emphasize that they should be used on an "as
appropriate" basis and that TBCs are intended to complement
use of ARARs, not to be in competition with ARARs.
When are MCLs or MCLGs considered relevant and appropriate in the
selection of ground-water restoration levels?
o Maximum contaminant levels (MCLs) are enforceable standards
under the Safe Drinking Water Act for specific contaminants
in public water supplies. Maximum contaminant level goals
(MCLGs) are non-enforceable goals on which MCLs are based.
o Consistent with CERCLA's direction to use maximum
contaminant level goals (MCLGs) as cleanup levels, the NCP
states that ground water that is or could be used for
drinking generally will be restored to MCLGs that are above
zero. When the MCLG equals zero (generally for
carcinogens), the corresponding maximum contaminant level
(MCLs) generally will be used as the cleanup level.
o The NCP explains that a cleanup level of zero is not
appropriate for Superfund because CERCLA does not require
the complete elimination of risk and because it is
impossible to detect whether "true" zero has actually been
attained.
o The proposed NCP had stated that MCLs generally will be used
as the cleanup level and stated that MCLGs would be used
only in cases where multiple contaminants or pathways posed
a risk in excess of 10-4.
Has the role of ARARs changed significantly in going from proposed
to final revisions?
o The role of ARARs in the 1990 NCP is essentially the same
as in the proposed rule. New language was added to the
rule, however, to clarify that requirements that are
promulgated or modified after the ROD is signed will be
attained only when determined to be ARAR and necessary to
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ensure that the remedy protects human health and the
environment.
o The preamble to the 1990 NCP also states that best
demonstrated available technology (BDAT) standards under the
RCRA land disposal restrictions (LDR) generally will not be
appropriate for contaminated soil and debris at a Superfund
site. This revised policy will allow Superfund sites to
attain alternative levels of cleanup to those required by
the BDAT standards.
COMMUNITY RF.T.ATTONS AND ADMINISTRATIVE RECORD
What community relations activities are specified in the 1990
NCP?
o In the 1985 NCP, all community relations requirements were
set forth in section 300.67. In the 1990 NCP, community
relations requirements are incorporated into each of the
sections relating to the different phases of response, i.e.,
removal actions, remedial investigation and feasibility
study (RI/FS) and selection of remedy, and remedial design
and remedial action (RD/RA). Further, in the 1990 NCP, new
community relations requirements are added to implement 1986
CERCLA requirements under sections 113 (administrative
record) and 117 (public participation).
1. Removal Actions
What are the administrative record and public participation
requirements for removal actions?
o These requirements depend upon the type of removal action
conducted. The three categories of removal actions are:
Emergency. which generally refers to a release or
threat of release that requires that removal activities
begin on site within hours of the lead agency's
determination that a removal action is appropriate.
Time-critical. where based on the site evaluation, the
lead agency determines that a remova. action is
appropriate and that there is a peric ^f less than six
months available before removal activ. ies must begin on
site.
Non-time-critical. where based on the site evaluation,
the lead agency determines that a removal action is
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appropriate and that there is a planning period of more
than six months before on-site removal activities must
begin.
What are the primary public participation requirements that apply
to all types of removal actions?
o The lead agency shall designate a spokesperson to provide
information and to respond to inquiries regarding the
action.
What are the primary administrative record and public
participation requirements that apply to: (1) emergency and (2)
time-critical removal actions? ("New" indicates a requirement not
stated in the 1985 NCP):
o (New) The administrative record shall be made available to
the public no later than 60 days after initiation of on-site
removal activities. The notice of availability shall be
published in a major local newspaper of general
circulation. The record shall be available at the office of
the lead agency or other central location and at or near the
site. The record for emergency cleanups lasting less than
30 days need only be available at the central location.
o (New) The lead agency shall, as appropriate, provide a 30-
day public comment period to begin at the time the
administrative record is made available to the public and
respond to comments received.
What are the primary administrative record and public
participation requirements that apply to: (1) all non-time-
critical actions and (2) time-critical actions where on-site
removal activities are expected to last longer than 120 calendar
days?
o (New) Conduct interviews with state and local officials,
residents, public interest groups, or other interested or
affected parties, as appropriate.
o Develop a community relations plan specifying the community
relations activities that the lead agency expects to
undertake.
o
(New) Establish at least one information repository at or
near the site to contain items made available for public
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inspection. The administrative record shall be available in
at least one of the repositories.
What additional administrative record and public participation
requirements apply to non-time-critical actions?
o (New) Publish a notice of availability and brief
description of the decision document, i.e., the engineering
evaluation/cost analysis (EE/CA).
o (New) At the same time, make the administrative record
available for public inspection.
o (New) Provide a public comment period on the EE/CA and the
administrative record of not less than 30 days after the
EE/CA is made available. Upon timely request, the lead
agency will extend the comment period by a minimum of 15
days.
o (New) Prepare a written response to significant comments.
2. Remedial Actions
What are the primary administrative record and public
participation requirements for remedial actions?
o (New) Conduct interviews with state and local officials,
residents, public interest groups, or other interested or
affected parties, as appropriate.
o Develop a community relations plan (CRP) specifying the
community relations activities that the lead agency expects
to undertake.
In a revision to the proposed NCP, the 1990 NCP more
clearly states that the purpose of developing the CRP
is to provide the public opportunities to participate in
decision-making at the site and to learn about the site.
o (New) Establish information repositories at a central
location and at or near the site and inform the public of
its availability.
o (New) Inform the community of the availability of technical
assistance grants.
o (New) Make the administrative record available for public
inspection when the remedial investigation (RI) starts
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(generally when the RI/FS workplan is available) and publish
a notice of availability.
o (New) Prepare a proposed plan that briefly describes the
remedial alternatives analyzed, proposes a preferred
remedial action alternative, and summarizes the information
relied upon to select the preferred alternative.
o (New) Publish a notice of availability of the proposed plan
and RI/FS in a newspaper of general circulation.
o (New) Make the proposed plan and supporting analyses and
information available in the administrative record.
o (New) Provide a comment period of not less than 30 days for
submission of written and oral comments (comment period in
the 1985 NCP is 21 days).
In a change from the proposed NCP, the 1990 NCP states
that, upon timely request, the comment period may be
extended a minimum of 30 days.
o Provide the opportunity for a public meeting during the
public comment period.
o (New) Keep a transcript of the public meeting.
o Prepare a response to comments, to be a part of the record
of decision (ROD).
o (New) Include in the ROD a discussion of any significant
changes from the proposed plan with respect to scope,
performance, or cost.
o (New) Solicit additional public comment on a revised
proposed plan if the significant changes from the proposed
plan could not have been reasonably anticipated based on
existing information.
o (New) Publish a notice of availability of the ROD and make
the ROD available for public inspection and copying.
o (New) Prior to remedial design, review the community
relations plan and, when appropriate, revise the community
relations plan to describe public involvement opportunities
during remedial design/remedial action.
o (New) If, after adoption of the ROD, the remedial action
differs significantly from the ROD with respect to scope,
performance, or cost, publish and make available an
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explanation of significant differences. If the changes
fundamentally alter the ROD, propose an amendment to the
ROD, issue a public notice, solicit public comment, and
comply with other community relations requirements, such as
public meetings, transcripts, comment response summaries,
etc.
o (New) Issue a final engineering design fact sheet and
provide, as appropriate, a public briefing prior to the
initiation of the remedial action.
How does a significant change to a remedy differ from a
fundamental change?
o Significant changes are generally incremental changes to a
component of a remedy that do not fundamentally alter the
overall remedial approach selected in the ROD (e.g.,
compliance with a newly promulgated requirement so that the
remedy remain protective but that does not change the
selected technology). A significant change requires an
explanation of significant differences. Fundamental changes
alter the ROD with respect to scope, performance, or cost in
such a manner that the proposed action, is no longer
reflective of the selected remedy in the ROD (e.g., a change
from an innovative technology to a more conventional one).
Fundamental changes require ROD amendments.
What changes were made in response to public comments on the
proposed NCP's community relations requirements?
o The purpose of developing the community relations plan is
to provide the public opportunities to participate in
decision-making at the site and to learn about the site.
o Upon timely request, the public comment period will be
extended a minimum of 30 days for remedial actions. For
non-time critical removal actions, the comment period will
be extended a minimum of 15 days, upon timely request.
o Prior to remedial design, the lead agency is required to
review the CRP to determine if it should be revised. The
proposed NCP provided for revision of the CRP in cases where
community concerns were not already addressed.
o Before initiation of remedial action, a fact sheet on the
final engineering design will be distributed and an
opportunity for a public briefing will be provided, as
appropriate.
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o The preamble to the 1990
participation activities
requirements that may be
NCP describes other public
in addition to the minimum
implemented at a site.
What is a technical assistance grant (TAG)?
o SARA section 117(e) provides that technical assistance
grants of up to $50,000 may be made available to community
groups that may be affected by a release or threatened
release at a site listed on the NPL. The grants must be
used to obtain assistance in interpreting technical material
related to site cleanups.
What changes were made in the 1990 NCP in response to public
comments about TAGS?
o The 1990 NCP requires the community to be informed of the
availability of TAGS and that information about the TAG
application process be placed in the information repository
located at or near the site.
ADMINISTRATIVE RECORD REQUIREMENTS
What is the purpose of the administrative record?
o The two primary purposes of the record are to:
Serve as the record for judicial review concerning the
adequacy of a response action.
Provide interested parties, including potentially
responsible parties (PRPs), an opportunity to
participate in selection of the response through review
of and comment on documents in the record.
What documents typically are included in the administrative
record?
o All documents which form the basis for the selection of a
response action. Such documents typically include: factual
information/data; analysis of factual information; policy
and guidance documents; public participation documents,
including public comments; decision documents and responses
to public comments; and some enforcement documents.
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Where must the administrative record be located and how will the
public be notified of its availability?
o The record must be located at or near the site (in an
information repository) and at an office of the lead agency
or another central location. The record need not be
available at or near the site, however, for emergency
removal actions that are concluded within 30 days of
initiation.
o Certain information need not be located at or near the site
where it would pose a substantial administrative burden,
e.g., sampling and testing data, guidance documents not
generated specifically for the site, publicly available
technical literature. The index to the record, however,
shall indicate the availability of such items.
o The availability of the record must be announced in a major
local newspaper of general circulation.
What documents may be added to the administrative record after the
ROD is signed?
o Documents relating to remedy selection issues that the ROD
reserves or does not address, explanations of significant
differences, and ROD amendments.
How does the administrative record differ from the information
repository?
o Information repositories include documents that relate to a
Superfund site and to the Superfund program in general, such
as documents on site activities, information about the site
location, and background program and policy guides. The
administrative record is the body of documents that forms
the basis of the Agency's selection of a particular response
at a site, such as site-specific data and public comments.
Documents in the administrative record may overlap with
those found in the information repository.
STATE INVOLVEMENT
Which NCP requirements apply to state-lead response actions?
o The NCP applies to federal agencies and states that take
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response actions pursuant to the authorities under CERCLA
and section 311 of the Clean Water Act.
How does the 1990 NCP implement the new CERCLA requirement to
provide for substantial and meaningful state involvement in
remedial planning and remedial actions?
o The 1990 NCP introduces the Superfund Memorandum of
Agreement (SMOA) and the process of EPA/state concurrence in
remedy selection. SMOAs are voluntary agreements that are
intended to ensure equitable relationships between EPA and
states and to reduce misunderstandings by clarifying the
expectations of both parties. The SMOA may be used to
establish the general framework for the EPA/state working
relationship, to define the roles and responsibilities of
the lead and support agencies, and to provide general
requirements for EPA oversight.
o The NCP provides that the state may be the lead agency for a
Fund-financed site. This allows the state to conduct the
investigation and analysis leading up to selecting the
remedy. The state may also conduct the remedial
design/remedial action phases of the response.
o The process of concurrence, which reflects the evolution of
the EPA/state partnership in recent years, enables a state
that demonstrates certain capabilities to prepare the
proposed plan and recommend the remedy for EPA adoption for
Fund-financed actions. EPA retains the authority to select
Fund-financed remedies and sign the record of decision
(ROD), with the state's concurrence.
Also under the concept of concurrence, a state will
select the remedy and may request EPA concurrence for
state enforcement actions not using the Superfund (i.e.,
non-Fund-financed actions).
One advantage to concurrence by EPA and a state on a
remedy is that it results in a unified position when
EPA and the state negotiate with PRPs.
o A state may recommend a remedy for EPA concurrence even
when no SMOA is established. EPA anticipates that the
concurrence process will increase EPA involvement in state
enforcement actions and provide for greater state
involvement in the selection of remedial actions at Fund-
financed sites.
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What happens if a SMOA is not established?
o The 1990 NCP sets forth minimum requirements in the absence
of a SMOA regarding annual EPA/state consultations, review
by the support agency of lead agency documents, and
identification of ARARs.
FEDERAL FACILITIES
Which NCP requirements apply to federal facility response actions?
o Requirements of the NCP apply to federal agency response
actions at NPL and non-NPL sites, except where specifically
noted that the requirements apply only to Fund-financed
activities. The requirement for joint selection of remedy
by a federal agency and EPA applies only at NPL sites.
o Subpart K of the 1990 NCP is specifically reserved for
federal facilities. EPA is currently drafting Subpart K,
which will provide a roadmap of the NCP requirements that
apply to federal facility response actions.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
FEB 5 1990
OFf ice
TME AOMtNiS
Honorable Frank Lautenberg
United States Senate
Washington, D.C. 20510
Dear Senator Lautenberg:
At your hearing last June on EPA's 90-Day Superfund
Management Review, you requested my personal attention to three
issues being addressed in revisions to the National Contingency
Plan (NCP): Your views on these issues were explained in detail
in the Lautenberg-Durenberger report, "Cleaning Up the Nation's
Cleanup Program." Now that the NCP is final and will be formally
announced tomorrow, I would like to report to you how I
considered your recommendations and resolved these issues, which
relate to cleanup standards for ground water, role of cost in
remedy selection, and cleanup selection criteria.
First, you asked me to reconsider EPA's policy on use of
Maximum Contaminant Levels (MCLs) instead of Maximum Contaminant
Level Goals (MCLGs) as cleanup standards for contaminated ground
water. Under the NCP as revised, the Agency expects that MCLGs
above zero will generally be used as the cleanup level for ground
water that is or may be used for drinking water; where the MCLG
is set at zero (as it is for carcinogens), the relevant MCL will
generally be used as the cleanup standard.
We believe this revised policy better reflects the statutory
intent of CERCLA section 121, while also recognizing the
practical difficulties inherent in attaining MCLGs set at zero.
The NCP explains that the use of zero is not appropriate in
setting actual cleanup levels to be attained under Superfund.
CERCLA requires the achievement of protective remedies, not the
complete elimination of risk? in fact, it is not scientifically
possible to determine whether a level of zero contamination has
been attained.
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The second issue you flagged for my personal attention
concerns the role of cost in selecting remedial actions under
CERCLA. You have argued that cleanup levels for a site should be
set first, and then a remedy should be selected to attain those
levels, without consideration of cost; cost comes into play only
in determining the most cost-effective method for implementing a
selected remedy.
We agree that this is the appropriate approach in those
situations where a specific applicable or relevant and
appropriate requirement (ARAR) defines the cleanup level that
must be achieved at the site (e.g., an MCLG above zero where
there is drinking water contamination). Where ARARs are not
available for the specific contaminants of concern, however, the
Agency defines protectiveness in terms of a risk range
(consistent with that used in other EPA programs), and several
alternative remedial technologies may be capable of achieving
protection within that range. Under such circumstances, cost may
be one factor to consider in choosing among the available
technologies.
It is important to note that the consideration of cost and
other factors may only distinguish among alternatives found to
protect hiaroan health and the environment. The NCP has been
revised to establish, as threshold criteria, that remedial
alternatives must be protective, and that they comply with
Federal and State ARARs (or justify a waiver)? cost cannot be
used to compromise these threshold requirements.
Rather, cost is one of the five criteria that are used to
weigh protective, ARAR-compliant remedial alternatives.
Moreover, even within that balancing, cost is not the primary
criterion. The final NCP provides that the factors of "long-term
effectiveness" and "reduction in mobility, toxicity, or volume"
should be emphasized in the evaluation, in accordance with the
statutory preference for permanence and treatment.
The final NCP has also been revised to narrow the
circumstances under which cost may be considered when screening
alternatives at the start of the evaluation process.
Specifically, the final rule provides that a given alternative
may be eliminated during screening if it is determined that the
cost of the alternative is "grossly excessive" compared to its
effectiveness. This provision will allow the Agency to avoid the
need to conduct resource-intensive analyses of extreme and
unrealistic options, while at the same time not allowing cost to
compromise consideration of viable options that may simply be
more expensive than other alternatives.
-------
-3-
I believe that the role given to cost, and the selection
process itself, are consistent with the mandates of CERCLA and
the guidelines in the Conference Report to SARA.
Finally, you also asked me to consider how to structure the
remedy selection process to ensure that remedies consistently
fulfill statutory mandates. I believe we have made some
significant improvements in finalizing the NCP to establish
clearer guidelines for selecting remedies.
The NCP explains in greater detail how each of the nine
evaluation criteria are to be used to meet the CERCLA
reguirements for remedy selection. As I mentioned above, the
reguirements that all remedies be protective and achieve
compliance with other laws are ensured by defining them as
"threshold" criteria, which every serious alternative must
fulfill. The statutory requirements that selected remedies
utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable, as well as be
cost-effective, are met based on a site-specific review of the
"balancing!.1 criteria set out in the rule. For example, the cost-
effectiveness mandate is fulfilled by examining the criteria of
long- and short-term effectiveness; reduction of mobility,
toxicity, or volume; and cost, and by ensuring that cost is in
proportion to the overall effectiveness afforded by the remedy.
The preference for permanence and treatment is implemented
by providing special emphasis in the rule on the factors of
"long-term effectiveness" and "reduction in mobility, toxicity or
volume." The modifying criteria of State and public acceptance
are also considered as part of the process.
For your information, the Superfund program is doing some
other things to improve the remedy selection process and promote
greater consistency in decision-making. For example, we are
training staff in EPA's regions on implementing the process; we
are working with our Regions to promote uniformity and
consistency to ensure that similar remedies are selected for
similar sites, to the extent possible; and we are analyzing
decisions to alert management to potential problems.
I hope that this information addresses some of the concerns
you expressed at the hearing and in the "Cleaning Up the Nation's
Cleanup Program" report. I want to assure you that we have given
extensive consideration to the appropriate role of cost in
-------
-4-
remedy selection; we have carefully weighed your views along with
the language of the Conference Report to SARA and the numerous
public comments to the proposal in arriving at our position. I
will continue to keep your positions in mind as we move toward
implementation of the NCP.
Please let me know if there is anything further you would
like to discuss about the final NCP.
Sincerely yours
William K. Reilly
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2
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FY'89 RECORD OF DECISION
ANALYSIS
Region VIII
Office of Emergency and Remedial Response
Office of Waste Programs Enforcement
March 1990
-------
FY189 ROD ANALYSIS
A. Overview of FY'89 ROD Analysis
B. National Findings
C. Regional vs. National Comparison
D. Major Recommendations for FY'90 RODs
-------
A.
OVERVIEW OF FY189 ROD ANALYSIS
PURPOSE
ฆ 1
Centerpiece of HQ QA/QC Program for RODs
ฎ Tool to gauge performance trends, identify strengths and areas for
improvement
-------
APPROACH
Total RODs Reviewed: 131
- Includes all RODs in CERCLIS minus 4 RODs not received
- RODs for multiple sites counted as one document
RODS divided into 5 categories; used separate evaluation form for each
category
- Final Source Control: 85
- Interim Source Control: 9
- Final Ground Water: 54
- Interim Ground Water: 10
- No Action: 12
-------
APPROACH
(Continued)
Review conducted January 29-31, 1990
FY'89 ROD Review team comprised of HSCD and OWPE
Regional Coordinators and Representatives from:
- Toxics Integration Branch, HSED
- Guidance and Oversight Branch, OWPE
- Technology Innovation Office, OSWER
- Office of General Counsel
- Region III
- State of New Jersey
Focus of Analysis
New - Consistency of remedies selected with program
expectations outlined in the NCP
FV88 and FY'89 - Quality of ROD Documentation
5
-------
B: NATIONAL FINDINGS:
PROGRAM EXPECTATIONS
Program Goal: select remedies that are protective of human health and the
environment, that maintain protection over time, and that minimize untreated waste
Summary of Program Expectations:
Treatment is most likely to be appropriate for materials that comprise the principal
threats posed by a site (i.e., highly toxic, highly mobile waste)
Engineering controls are most likely to be appropriate for materials that pose a
low-level threat, or where treatment is impracticable
Institutional controls are expected to be used to mitigate short-term impacts
and/or as a supplement to engineering controls to aid in long-term management
Innovative technologies are to be evaluated closely where there is a reasonable
belief that they may perform as well as or better than conventional technologies
Ground water is to be returned to its beneficial uses within a reasonable time
frame
-------
NATIONAL FINDINGS:
CONSISTENCY WITH PROGRAM EXPECTATIONS
Source Control (final actions only)
73% (69/95) of final source control RODs involve treatment*
54% (37/69) of treatment RODs selected innovative technologies*
Principal threats will be treated in all cases where principal threats were clearly
identified
Low-level waste will clearly be treated in 33% (24/72) of the cases involving low-level
threats; these RODs also are treating principal threats
Low-level waste will clearly be contained in 67% (48/72) of the cases involving
low-level threats
Institutional controls often used as a supplementary control (58% source control,
72% ground water)
Ground Water ffinal actions only)
97% (62/64) of ground water remedies intend to restore ground water to its beneficial
uses within a reasonable time frame*
8% (5/62) of pump and treat remedies used innovative technologies*
* Data summarized from the ROD Annual Report.
-------
FY-89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 1. Documentation of Threats at Final Source Control RODs
-------
NATIONAL FINDINGS:
ROD DOCUMENTATION
Defining Site Threats (see Exhibit 1)
Principal threats generally are defined clearly
Low-level threat material clearly defined less than half of the time
- Location and volume of contaminants often missing
-------
FY189 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 2. Documentation of Risks at Final Source and Final Ground Water RODs
Final Source
-------
NATIONAL FINDINGS:
ROD DOCUMENTATION (continued)
Documenting Site Risks (see Exhibit 2)
Priority area for improvement
In "Summary of Site Risks" section, pathway-specific and population risks or hazard
indices were provided about half the time
About 2/3 of the RODs clearly explained the relationship of the baseline risk to the
risk range
Environmental exposures addressed in 44% of final source control RODs and 56% of
final ground water RODs
"Imminent and Substantial Endangerment" language appeared in 53% of the
declarations and 27% of the texts
In "Description of Alternatives" section, 28% of the final source control RODs included
a description of initial risks for a pathway or population and 46% provided the risk
In "Overall Protection" discussion and "Protection of Human Health and the
Environment" determination, 75% of the RODs provided risk reduction
In "Selected Remedy" section, 44% of the final source control RODs provided risk
levels corresponding to remediation goals
reduction
9
-------
FY189 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 3. Documentation Findings at Final Source and Final Ground Water RODs
Record of Decision Documentation Sections
Final Ground
Record of Decision Documentation Sections
-------
NATIONAL FINDINGS:
ROD DOCUMENTATION (continued)
1
Alternatives Description and Analysis (see Exhibit 3)
Only 2/3 of final RODs provided a complete description of the alternatives;
management of residuals is often missing
Comparative analysis correctly used 9 evaluation criteria in 86% of final source
control RODs and 91% of final ground water RODs (an improvement over FY'88 in
which 80% of final RODs included an adequate comparative analysis)
-------
NATIONAL FINDINGS:
ROD DOCUMENTATION (continued)
ARARs (see Exhibit 3)
Incorporation of key ARARs into the description of alternatives has declined since last
year (70% in FY'88 vs. 52% in FY'89)
The presence of RCRA waste and LDRs as ARARs was addressed in only 1 /2 of final
source control RODs and 43% of final ground water RODs
RCRA closure requirements were identified as ARARs for close to half of remedies
involving containment
State ARARs were addressed in 86% and 83% of the final source control and final
ground water RODs, respectively
In the "Comparative Analysis" discussion, 73% and 78% of the final source control
and final ground water RODs, respectively, highlighted that each alternative meets
ARARs determination is almost always made as a statutory finding
31% of final RODs a did not list and describe ARARs to be attained by the selected
remedy
ARARs
li
-------
NATIONAL FINDINGS:
ROD DOCUMENTATION (continued)
Selected Remedy (see Exhibit 3)
Final remediation goals not provided in 1/3 of final source control RODs; points of
compliance missing in 2/3
87% of final ground water RODs provided remediation goals
Less than half of the final source control RODs documented the method for managing
residuals
Statutory Determinations/Rationale (see Exhibit 3)
Documentation of remedy selection rationale in final source control RODs has
improved over last year (50% in FY'88 vs. 71% in FY'89)
Rationale for remedy selection in terms of balancing of the five primary criteria was
provided in 37% of the final ground water RODs
-------
NATIONAL FINDINGS:
SUMMARY OF ROD DOCUMENTATION
Improvement over FY'89 in presentation of the 9 criteria analysis and
remedy selection rationale
Improvements need to be made in documenting:
- Site Threats
- Site Risks
- ARARs, particularly LDRs
- Points of compliance and remediation goals for the selected remedy
-------
C. REGIONAL VS. NATIONAL COMPARISON
1
ROD evaluation form responses were tallied for nearly every question
Tables that follow reflect statistics from ROD Analysis, which were compiled for each
Region based on final source control and final ground water RODs (interim action
and no action RODs were excluded)
-------
FT89 Record of Decision Analysis
Region Vm Comparison
Table 1. Definition of Principal and Low-level Threats in Final
Source Control RODs
Regional
(percent)
National
(percent)
Principal Threats
RODs clearly definina principal threats
60
80
RODs providina volumes of the contaminants
60
80
RODs Drovidina concentrations of the contaminants
80
89
Low-level Threats
RODs clearly definina low. but sianificant. lonq-term threat
50
49
RODs Drovidina volumes of the contaminants
25
29
RODs Drovidina concentrations of the contaminants
50
49
Table 2. Documentation of Site Risks in Final Source Control
RODs
ro
c
o
c
a>
o
S?
cc
4)
a
RODs identifying populations at risk
80
72
RODs identifvina current land use
100
91
RODs identifvina future land use
40
38
RODs providing carcinogenic risk or hazard indices for the pathway-specific
risk
40
54
RODs providing carcinogenic risk or hazard indices for the population
groups at risk
60
49
RODs identifvina reasonable exDosure pathways
100
89
RODs identifvina basic toxicity information
20
44
RODs documenting how the baseline risk relates to the risk range
60
66
RODs documentina environmental exposures
60
44
RODs providing statement on imminent and substantial endangerment in
summary of site risk section
0
27
RODs including description of the initial risks for a pathway or population in
description of alternatives section
60
28
RODs providing risk reduction for each alternative
40
46
RODs providing risk levels corresponding to cleanup goals in the description
of the selected remedy
80
44
jmber of Region VIII FV89 Final Source Control RODs = 5
i otal number of FY'89 Final Source Control RODs = 85
-------
FV89 Record of Decision Analysis
Region Vlll Comparison
Table 3. Alternatives Description and Comparative Analysis
in Final Source Control RODs
S =
o
p
8>
Q>
cc s
S c
C
Q.
RODs fully tracking all identified wastes, including residuals
80
66
RODs providing a comparative analysis that uses the nine criteria consistent
with NCP definitions
80
86
Table 4. ARARs Identification (LDR, RCRA Waste, Closure,
Endangered Species Act, State ARARs) in Final
Source Control RODs
m
C C
O ฎ
2 u
0>
IE S
2 c
C 0>
o o
(0
a)
a.
RODs documenting kev ARARs
40
52
RODs documenting whether the waste is RCRA waste
60
49
RODs providing a determination of LDR as an ARAR
60
51
RODs documenting RCRA closure requirements for actions that involve
cappina. excavation. ordiSDOsal
40
55
RODs identifying the Endangered Species Act as an ARAR at sites where
endanaered SDecies mav be encountered
0
25
RODs addressina State ARARs
80
86
RODs highlighting that each alternative meets ARARs in the comparative
analysis of alternatives
60
73
RODs documenting that the selected remedy complies with ARARs in the
statutory determinations.
100
93
RODs listing and describing the ARARs that will be attained
60
68
mber of Region Vlll FV89 Final Source Control RODs = 5
. otal number of FY'89 Final Source Control RODs = 85
-------
FV89 Record of Decision Analysis
Region Vm Comparison
Table 5. Description of Selected Remedy in Final Source Control RODs
g c
I 8
cc S
CO
c
o
CD
c
o
Q>
Q.
RODs documenting treatment of DrinciDal threats
100
100
RODs documenting use of engineering controls for low-level waste
50
67
RODs documenting use of engineering controls as the primary component
of the remedy
0
24
RODs including institutional controls in the remedy
40
58
RODs using institutional controls as the primary component of the remedy
0
0
RODs selecting a combination of treatment with engineering controls and
institutional controls
80
41
RODs selecting innovative treatment technologies*
75
54
mber of Region VIII FV89 Final Source Control RODs = 5
. otal number of FY'89 Final Source Control RODs = 85
* Total number of FY'89 Final Source Control Treatment RODs = 69; information obtained from FV89 Annual Report
-------
Fy89 Record of Decision Analysis
Region Vm Comparison
Table 1. Documentation of Site Risks in Final
Ground Water RODs
CO
c
-------
FV89 Record of Decision Analysis
Region VHI Comparison
Table 3. ARARs in Final Ground Water RODs
ซo p
C c
I s
DC 5
2 c
c a>
o o
si
RODs identifying State ARARs
100
83
RODs identifying whether the waste is a RCRA waste
100
41
RODs documenting a determination of LDR as an ARAR
100
44
RODs highlighting whether each alternative meets ARARs in the
comparative analysis
100
78
RODs documenting that the selected remedy complies with ARARs in the
statutory determinations
100
85
RODs listing and describing ARARs that will be attained
100
69
Table 4. Selected Remedy in Final Ground Water RODs
i 8
a S
to c
ฃ ฎ
o u
(0
0)
a
RODs providing the treatment level for the extracted ground water
100
100
RODs providing the remediation goal for the selected remedy
100
87
Tiber of Region VIII FY'89 Final Ground Water RODs = 2
. otal number of FV89 Final Ground Water RODs = 54
-------
FY'89 Record of Decision Analysis
Region vm Comparison
Table 5. Statutory Determinations in Final
Ground Water RODs
c =
I 8
IE S
(0
c
o
n
RODs stating the rationale for remedy selection in terms of the nine criteria 50
37
Table 6. Consistency With Program Expectations in
Final Ground Water RODs
CO
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a>
-.
c
a>
u
(0
c
o
c
0)
O
Q>
3
**
CO
z
-------
D. MAJOR RECOMMENDATIONS
FOR FV90 RODS
1. Keep up good work on 9 criteria analysis and remedy selection rationale
2. Clearly define site threats
3. Improve documentation of ARARs, particularly LDRs
4. Effectively summarize site risks
5. Provide remediation goals/cleanup levels and points of compliance for the selected
remedy
15
-------
FY'90 RECOMMENDATIONS
Clearly define site threats
In "Summary of Site Characteristics" Section: Identify locations, volumes and
concentrations for contaminants to delineate principal and low-level threats
In "Description of Alternatives," "Selected Remedy," and "Statutory Determinations"
Sections: Ensure that descriptions of remedies convey how a particular cleanup
option addresses principal vs. low-level threats
-------
FY90 RECOMMENDATIONS
(Continued)
Improve ARARs Documentation
Include listing of all ARARs for the selected remedy
Address presence/absence of RCRA waste and LDRs in all RODs
Use treatability variances for soil and debris contaminated with
RCRA restricted waste
-------
FY'90 RECOMMENDATIONS
(Continued)
Effectively Summarize Site Risks
Summarize in text or tables pertinent information from baseline risk assessment
Human Health
Contaminants of concern: contaminants, media, concentrations
Exposure: pathways, populations, current and future land uses, data, assumptions
Toxicity: cancer potency factors, reference doses, explanations
Risk Characterization:
- Carcinogenic risk of each contaminant: by medium, by pathway, total by population
- Noncarcinogenic effects: hazard index
- Explanation of measuring uncertainty, other conclusions
18
-------
BJflRCN BAEKEL AMD EFLM, NY
DESCRIPTION OP ALTERNATIVES
All of the drums and approximately 4 0 cubic yards of contaminated
surficial soil and debris have been removed from the site. The
levels of subsurface soil contamination on-site, with the possible
exception of inorganics located in Source Area 3, present risk
-------
17
levels which are within EPA's acceptable range. However,
contaminants remaining at the site have contaminated the underlying
groundwater, exceeding federal and state groundwater quality
standards. Specifically, Source Area 1 and Source Area 2 are
releasing organic contaminants into the groundwater through
infiltration of precipitation. The two plumes exceed ARARs and
pose a risk of off-site migration of contaminants to the nearby
Oak Orchard Creek. There does not appear to be a groundwater
contaminant plume emanating from Source Area 3. The alternatives
described below address the remaining subsurface soil contamina-
tion at the site and the contamination in the groundwater
underlying the site.
A total of eight alternatives were evaluated in detail for
remediating the site. Five remedial alternatives address the
contaminated subsurface soils that contribute to groundwater
contamination at the Byron Barrel and Drum site. In addition, six
alternatives address the contamination in the groundwater beneath
the site. These alternatives are as follows:
ALTERNATIVE 1 - NO ACTION WITH MONITORING
The Superfund program requires that the "no-action" alternative be
considered at every site. Under this alternative, EPA would take
no further action to control the source of contamination. However,
long-term monitoring of the site would be necessary to monitor
contaminant migration. Monitoring can be implemented by using
previously-installed monitoring wells and residential wells.
Because this alternative would result in contaminants remaining
on-site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions would be
implemented at that time to remove or treat the wastes.
The present worth cost of this alternative for a 20-year period is
approximately $2 65,000. The time to implement this alternative is
two months.
ALTERNATIVE 2 - DEED AND GROONDWATER-PBE RESTRICTIONS
This alternative would not require implementation of remedial
actions to address groundwater or subsurface soil contamination.
Deed restrictions would be imposed to prevent excavation in areas
of contamination. Groundwater-use restrictions would be imple-
mented in the affected area to prevent the use of contaminated
groundwater for drinking or irrigation purposes. These institu-
tional controls would also alert future property owners to poten-
tial site-related risks. A long-term monitoring program would also
be implemented. Deed and groundwater restrictions can be
implemented by state and local officials. Groundwater monitoring
can be performed using previously-installed monitoring wells and
residential wells.
-------
18
The present worth cost of this alternative, for a 20-year period,
is approximately $279,000. The time to implement this alterna-
tive would be 2 months.
ALTERNATIVE 3 - DEED RESTRICTIONS AND GROUNDWATER PUMPIKG.
TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative would not require implementation of remedial
actions to address subsurface soil contamination. Deed re-
strictions would be imposed to prevent excavation in areas of
subsurface soil contamination. Groundwater would be collected
using a series of extraction wells and pumped to an on-site
treatment system.
To treat the volatile organic contaminants (VOCs) in the extracted
groundwater, an air stripping column and activated carbon adsorber
would be constructed at the site. The air and VOC mixture exiting
the air stripper would be treated by a vapor phase carbon
adsorption unit. The clean air would be emitted to the atmosphere.
It is anticipated that a carbon adsorption unit would be necessary
for the removal of the MEK, since air stripping would not remove
this contaminant from the groundwater. In addition, inorganiq
contaminants in the groundwater would be removed by precipitation
prior to air stripping. Discharge piping would be installed to
pump the treated water to the drainage ditch located north of the
onion field or to Oak Orchard Creek. All air and surface water
discharges would comply with state and federal standards.
Environmental monitoring would be required during the life of the
treatment process. In addition, monitoring of the groundwater at
the site and its environs would continue for at least five years
after the completion of the remediation to ensure that the goals
of the remedial action have been met. Pre-construction,
construction and post-construction air monitoring would also be
performed.
The present worth cost of this alternative is approximately
$4,874,000. The time to reduce the groundwater contaminant
concentrations to levels based on ARARs is estimated to be 20
years.
ALTERNATIVE 4 - BOIL CAPPING AND GROUNDWATER PUMPING, TREATMENT.
AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternative 3, except that synthetic
membrane caps would be installed over the areas of soil
contamination.
Under this alternative, the oiintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Prior to capping, the areas would be graded to control surface
-------
19
water runoff and erosion. A protective soil cover would be placed
over the synthetic membrane, topsoil would be spread, and the
capped areas would be revegetated.
The groundwater pumping, treatment, and discharge scenario would
be the same as that discussed for Alternative 3. Monitoring would
be the same as in Alternative 3.
The present worth cost of this alternative is approximately
$5,14 3,000. Two months would be required to construct the cap.
The time to reduce the groundwater contaminant concentrations to
levels based on ARARs is estimated to be 20 years.
ALTERNATIVE 5 - BOIL EXCAVATION AND OFP-BITB DISPOSAL AND
GROUNDWATER PUMPING. TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3 and 4, except that
contaminated soil would be excavated and hauled to an off-site
Resource Conservation and Recovery Act (RCRA) landfill for
disposal.
Under this alternative, the maintenance building would be
dismantled and decontaminated if necessary, and disposed of off-',
site. Contaminated subsurface soil would be excavated, loaded into
trucks, and hauled to an approved off-site RCRA landfill for
disposal. (So as to comply with RCRA land disposal requirements,
treatment of the contaminated soil might be required prior to
disposal.) The excavations would be backfilled with clean fill
material from an off-site source. These areas would be covered
with a layer of topsoil and revegetated.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.
The present worth cost of this alternative is approximately
$7,929,000. Two months will be required to remove the contaminated
soil. The time to reduce groundwater contaminant concentrations
to levels based on ARARs is 20 years.
ALTERNATIVE 6 - SOIL EXCAVATION AND THERMAL DESORPTION AND
GROUNDWATER PUMPING. TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3, 4, and 5, except
that contaminated subsurface soil would be excavated and treated
on-site using low-temperature thermal desorption to remove volatile
organic contaminants.
Under this alternative, the maintenance building would be disman-
tled, and decontaminated if necessary, and disposed of off-site.
Contaminated soil would be excavated and hauled to a mobile thermal
desorption unit that would be set up at the site. Treated soil
-------
20
would be used to backfill the excavations. The areas would be
covered with a layer of topsoil and revegetated. Because of the
presence of inorganic constituents in the soil, which thermal
desorption would not remove, treatment of the residual by chemical
fixation might be necessary before backfilling to comply with RCRA
land disposal requirements.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
in Alternative 3.
The present worth cost of this alternative is approximately
$6,899,000. Two months would be required to complete soil
treatment. The time to reduce groundwater contaminant
concentrations to levels based on ARARs is estimated to be 2 0
years.
ALTERNATIVE 7 - IN-SITP SOIL VAPOR EXTRACTION AND GROUNDWATER
PUMPING. TREATMENT. AND DISCHARGE TO SURFACE WATER
This alternative is similar to Alternatives 3, 4, 5, and 6, except
that contaminated subsurface soil would be treated by in-situ vapor
extraction using air extraction and injection wells.
Under this alternative, the maintenance building would be disman-
tled and decontaminated if necessary, and disposed of off-site.
Vapor extraction wells would be installed at the centers of Source
Area 1 and 2. Air injection wells would be installed around the
perimeters of the Source Areas 1 and 2. A vacuum would be induced
and the air that would be collected would be treated using vapor-
phase carbon adsorption. A synthetic membrane would be used to
prevent air leakage from the soil surface between the air
extraction and injection wells.
The groundwater pumping, treatment, and discharge scenario would
be the same as for Alternative 3. Monitoring would be the same as
Alternative 3.
The present worth cost of this alternative is approximately
$5,2 00,000. Six months would be required to reduce soil
contaminants to levies that would achieve groundwater ARARs. The
time to reduce groundwater contaminant concentrations to levels
based on ARARs would be 20 years.
ALTERNATIVE fl - IN-SITU BOIL FLUSHING AND GROUNDWATER PUMPING.
TREATMENT. AND RECHARGE
This alternative is similar to Alternative 3, except that a portion
of the treated groundwater would be recharged to the aquifer in the
areas of subsurface soil contamination. This alternative would
attempt to restore groundwater quality and flush the residual
contaminants from the subsurface soil.
-------
21
The maintenance building would be dismantled, and decontaminated
if necessary, and disposed of off-site.
Monitoring would be the same as for Alternative 3.
The present worth cost of this alternative is approximately
$5,57 2,000. The time to reduce soil contaminant concentrations to
levels that would achieve groundwater ARARs is estimated to be in
10 years. The time to reduce groundwater contaminant concentra-
tions to levels based on ARARs is 20 vears.
-------
NOKlKilLE IANDFMli, WA.
DESCRIPTION' OF ALTERNATIVES
"he goal of the remedial actions is to prevent. reduce. or control t-.e
contaminants leaving the lanafill ana entering the groundwater.
Technically aoolicaDle technologies were identified in the "S for eacn of
the units. Most of the remedial actions that passed the screening process
for one of the landfill solid waste units (refuse, skimmings, old burn, or
sewage sludge) passed for all of the other three. The aquifer unit
includes different technologies that deal with the migration of the
contaminants in groundwater and not the material In the refuse. The
description of the treatment alternatives is divided Into those for the
landfill units and those for the aquifer unit.
Landfi11 Unlts
Remediation of the landfill units must control, as far as oossible,
the leaching of contaminants into the groundwater. This may be done by
either :
a) capping the landfill to eliminate leaching;
b) diverting stormwater so that it does not generate leachate; or
c) excavating "the landfill and removing the contaminated waste.
If it proves impracticable to control leachate, administrative restrictions
may be enacted to reduce exposure to contaminants. Another alternative
considered 1s to take no action.
a) Capping. The cap system would consist of multiple layers, Including
topsoi1, soil cover, drainage layers, and bedding/protection layers,
in conjunction with a low permeability, barrier layer to control
Infiltration. Around the perimeter of the cap, collection ditches
would be Installed to Intercept stormwater runoff and convey It to
appropriate points of discharge. Three different types of cap systems
were considered: synthetic membrane, synthetic membrane and clay, and
sol 1/bentonlte.
The cap would utilize proven technologies. Its main advantage is that
it restricts the amount of leachate that can enter the aquifer unit by
reducing the infiltration of precipitation Into the landfill.
Precipitation Is the principal source of leachate generation for the
landfill because It.Is located above the Identified groundwater
tables. Therefore, If precipitation, run-on, and any lateral flows
from the hillside can be kept from entering the waste, the health and
environmental hazards associated with leachate generation and
contamination of the aquifer unit would be significantly reduced.
Disadvantages of capping include the waste of concern remaining
onsite. the potential for the cap to leak and generate additional
leachate. and the magnitude of grading and covering 345 acres of
land. Leakage of the cap is a concern because of the potential for
future leachate generation. The design and Installation of the cap
would need to be carefully done, and a maintenance program would be
necessary to reduce the risk of leaks developing In the system over
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t: T.e E"v: rcnTie-ira i :Tca::s :** :~e :ao ; "is :a;: at; cn are :cns':?'-5:
rencorary because :~e exiifng 3urrace tcoograony would nor cnange
significantly and vegetation would te reestaolisneo.
Caooing, of course, oresucposes the closure of the landfill. Three of
tne unitsold burn, sewage sludge, and ski -nmi rigsare no longer in jse
and could be caoped at any time, but the refuse unit currently is
scheduled to -emain in use until December 31, 1991, wnen the
waste-to-energy treatment system becomes operational. Any refuse taken
to the Northside site after December 31, 1991, will be required to oe
placed into a new disposal unit which meets the state's Minimum
Functional Standards (MFS) requlrements.
ARARs
The closure and capping alternative include action-specific applicable or
relevant and appropriate requirements (ARARs). The primary ARAR is the
Washington State Minimum Functional Standards for Performance (MFS) (WAC
173-304-460). The MFS are applicable to landfills that Institute closure
after November 27, 1989. The Northside Landfill will be operating beyond
1989.
The MFS Include requirements for the final cover, groundwater monitoring,
landfill gas monitoring and control, runoff and leachate control, a
closure plan, and a closure cost estimate.
The wastes in the landfill are not currently classified as hazardous
wastes under RCRA because the only sources Identified are small quantity
generators. Since closure and capping do not include the placement of
RCRA hazardous wastes, those RCRA regulations would not apply.
There are no chemical-specific or location-specific ARARs identified for
this alternative.
b) Surface Water Diversion and Collection Systems. These systems are
designed to divert and collect stormwater runoff and keep it from
infiltrating the landfilled wastes, thereby reducing the potential for
leachate generation. The diversion and collection systems would consist
of ditches, culverts, and pipelines that collect runoff from flow
concentration areas and convey it to in appropriate point of discharge.
The ditches would be lined to ensure that infiltration would be minimized.
This alternative's chief advantages are that it would consistently help
reduce leachate-generatlng precipitation from entering the landfill, and
it is low In cost. The disadvantage is that It does not address
infiltration by precipitation that falls within the landfill boundaries.
In the final analysis of alternatives, surface water diversion is not
considered a separate alternative, but rather a component of capping, and
is included as part of that alternative.
c) Excavation and Offsite Disposal. One additional remedy passed screening
for the Skimmings Unit only. It was rejected for the refuse unit because
of high cost and EPA preference for onslte. remedies (the old burn and
sewage sludge units have low contaminant levels and disproportionately
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:~~&r costs; litsr-a:'.? total -ercvj' ;
>
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Thera *er9 io c n 0 m t :a i - 32e: i : zr ' cca:: cn-^ec ฆ * <: ;; -:-
tne excavation a Irs^na : i/es
For the excavation witn offsite aisccsa' alternative, tne RCSA nazaracus
waste regulations are not aDolicaole because the skimmings are not a RC3A
waste. However, offsite activities, such as disposal, will be regulated
by applicable laws and regulations, and are not suoject to ARAR
analysis. For example, the transportation and packaging of the skimmings
as a hazardous solid waste because of the PERC content is regulated by
the U.S. Oepartment of Transportation.
d> Administrative Restrictions. This would Involve restricting land use
with respect to future onsite excavation and construction.
The chief advantages of this alternative are its low cost and ease of
implementation. Public health would be protected by reducing exposure to
the contaminants at the site.
The primary disadvantage is that administrative restrictions would not oe
effective in eliminating or reducing public health concerns offsite.
Infiltration would not be reduced nor surface water or groundwater flow
controlled; thus the leachate would continue to be produced. The MFS,
which 1s an ARAR and requires landfill capping, would not be met.
e) Ho Action. The landfill would be left in its current condition without
any remedial action being taken. There would be no cost, but public
health would not be protected. ARARs would not be met.
Aquifer Unit
For this unit, the remedial objective 1s to reduce health risks from the
contaminants In the groundwater. Alternatives include:
a) extracting and treating the contaminated water;
b) monitoring;
c) administrative restrictions;
d) providing an alternate water supply; and
e) no action.
a> Collection Wells. Treatment, and Discharge. The purpose of the
extraction and treatment system is to reduce and control the release of
contamlnants-Into tfie aquifer downgradient from the landfill. The
aquifer unit alternative includes six variations using two extract'on
options for the contaminated groundwater and three treatment levels for
each extraction design.
The two extraction (pump) options are extracting the entire contaminated
plume (total plume capture) and extracting only a portion of the
contaminated plume (partial plume capture). The total plume capture,
system uses extraction wells across the entire width of the contaminated
plume and would be designed to extract groundwater with any amount of
contamination for treatment. This would Include pumping large volumes of
groundwater that is currently contaminated at levels below th# protective
requirements. The partial capture system would extract only that
groundwater that Is contaminated at concentrations greater than existing
30
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standards. "-1:3 *cul: rszj:? "e a-c." zf ซa:e- :-a: -
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TABI.E b
CHEMICAL-SPECIFIC ARABS AND TRCS FOR ORGANIC CONTAMINANTS
FOUND AT THE NORTH LANDFl (.1.
Clean Hater Act
u
K>
Safe Drinking Consumption of Referem t--
Water Act Acute Chronic Fisli and Fish Dose li.i:.cซl
Compound HCb HCLG Toxicity Tonicity w.ii or only Criteria
Chlorofona 100* - 28,900** 1,240** 0.19 15.7 350
1.1-Dichloroe thane - - - 0.94ฐ 24 3ฐ 4,500
1.2-(Trana)Dichloroethylene - - 11,600** - 0.33d 1.85d 350
ebb
Tetrachloroetliy lene - 0 5,280 450 O.fl H.05 10
1,I,l-Trichloroethane 200 - 18,400 1,030,000 1,000
Tr ichloroethylene 5 - 45,000** - 2.7 80.7 260
Vinyl Chloride 2 0 - - 2.0 525 (I /)
All units in ug/1
Criterion for total trihalomethanes (sum of chloroform, bromodichloromethane, dibromochloroiiuM,
And hroMofona).
''Lowest observed effect level.
CCrlterion For chlorinated ethanes based on toxicity of 1,2-diclilปroelliane.
^Criterion foe dichloroethylenes based on carcinogenicity of 1,1-dicliloroethylene.
"proposed October 1986.
^Longer tera Health Advisory for adult and 10 kg child is the 46 and 13 py/l, respectively. 1.ifซri inr
Health Advisory not calculated.
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^ i -: mem tr?a:~sn; ;f t~e ;-~u"wa:2r z~ : ;:~a':r ::
:ne Spokane Rwer must comc'y ซ;:n -moie'-: ^a:3r Qua'.':./ ~ r ฆ-1 a - ฆ a
(AwQCXsee Taole 5). "rs quality of :ne unt-eatsq groundwater u > r *c:
ae expected to satisfy tne AWQC ecr fresn *ater cue :o VCC
concentrations. An NPDES permit would nave to be cotained from icoicqy
prior to initiating the discharge. Oiscnarges to tne 'iver will oe
required to comply with the pnosphorus discharge limits established for
the Spokane River. The alternative would also have to be analyzed for
its effect on fish, wildlife, and habitat in and around the Spokane River
as required by the Fish and Wildlife Coordination Act. No other
location-specific natural resource ARARs were identified.
The extracted groundwater will be treated to meet drinking water
standards for metals and volatile organic compounds or meet NPDES and
AWQC requirements, whichever is more stringent, prior to discharge to the
Sookane River. There would be some level of contamination remaining in
the treated water discharged to the Spokane River.
The cost for the extraction and treatment alternatives would be moderate
to high, depending on the number of wells and the specific treatment
process selected.
b) Hon 1 torinq. The existing groundwater monitoring system would continue .to
be used until the long-term monitoring plan Is developed and approved by
EPA. This existing system consists of wells both on- and offsite which
were Installed at various depths to indicate the level of contamination.
Monitoring would be low In cost and easily Implemented, since It could
largely utilize an existing system which could be supplemented If the
existing wells are determined to be Inadequate. It would provide a means
for measuring the effectiveness of other response actions. However, it
would not in Itself protect public health.
Groundwater monitoring for the purpose of early detection of contaminants
beyond the existing plume area does not satisfy ARARs because the
existing groundwater contaminant levels would continue to exceed drinking
water MCls within the plume.
c) Administrative Restrictions. Under this alternative, the city would
prevent the installation of well; in the contaminated portion of the
aquifer. Though all affected residences are now connected to the city
water system, ther< are currently no regulations to make future
residences connect with this system or prevent existing contaminated
wells from being used.
This alternative would protect public health by limiting exposure to
contaminated groundwater; It would be low in cost to Implement. It would
not reduce contamination, and ensuring compliance could be difficult.
Administrative restrictions to prevent use of the contaminated
groundwater in the area of the plume do not satisfy ARARs because
groundwater contaminant levels would continue to exceed drinking water
MCLs for decades.
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1'> a're^-at:ve t?- Su::'/ ^: " s w raji^grraj ฆ n rne area : f
:on-aminat;en ซoula oe :cnnec:ป: *itn me .-nun i c i sa 1 water system, as
9ting residences already are It would oe techn 1 ca 1 1 y feaside i:~: =
:nere are nearoy water lines, tnougn some new service latera's might nave
to oe constructed. Public health would be Drotected and cost would oe
low, but the groundwater would remain contaminated. There were no
environmental receDtors of the contaminated grounqwater identified in tne
FS.
An alternate source of drinking water for residents located In the local
area of the contaminated plume does not satisfy ARARs. Groundwater
contaminant levels would continue to exceed drinking water MCLs until
natural recovery reduces the contaminants below the MCLs. This
alternative would help in the interim to protect public health, but
contamination would not be reduced to MCLs; therefore. It would not
sati sfy ARARs.
e) No Action. No remedial measures would be Implemented, beyond those
already in place (I.e., providing alternative water to existing
residences). There would Oe no cost, no change in the level of
protection of public health, and no reduction of contamination in the
aquifer. Water quality and Safe Drinking Hater Act ARARs would not be
met.
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7. COMPARASION OF ALTERNATIVES
This section summarizes the relative performance of the alternatives by
highlighting the key differences among the alternatives in relation to the nine
evaluation criteria. It is recommended that this be presented in a series of paragraphs
headed by each criterion. Under each criterion, the alternative that performs best in
that category may be discussed first, with other options discussed in sequence.
EXAMPLE: HEDBLUM INDUSTRIES, MI
This comparative Analysis Includes a helpful introductory sentence under each
criterion that identifies the purpose of that particular comparison. The discussions
under Compliance with ARARs, Short-term Effectiveness, Cost, and State Acceptance
are particularly good. This Comparative Analysis does not address the nine criteria in
the standard sequence established in the ROD guidance. The Overall Protection
discussion inappropriately refers to the different "degrees of protection" provided by the
alternatives. Since Overall Protection of Human Health and the Environment is a
threshold criterion, alternatives should be designated protective or not.
EXAMPLE: CROSS BROTHERS PAIL, IL
This example addresses the nine criteria in the appropriate sequence. The Long-
term Effectiveness and Permanence discussion is very good, appropriately conveying
the relative degrees of long-term effectiveness afforded by the options. This ROD also
identifies up front how remedies are comparable so the subsequent discussion is
focused only on significant differences between options. The alternatives are generally
discussed in order of best to worst under each criterion, which allows for a quick
understanding of results.
EXAMPLE: NORTHSIDE LANDFILL, WA
This example effectively summarizes State and Community Acceptance.
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HEDELLM INDUSTRIES, *1
CCKFfrRATIVg T ALTERATIVES
A detailed aralysis was performed on the six alternatives usi.~"5 v.e
nine evaluation criteria in order to select a site remedy. T^e
following is a aannaiy of the acrpariscn of ea
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Pฎ**ner*oe, 5) aost, 6) reduction of toxicity, natlity and sz'.jtg.
7) i^lsnerrtability, 8) State acceptance, and 9) aconjir/
araptance.
C**ปrปn Procacti^n erf Pitolic Haalth and tfre Brrw-Lnarmerfr
Evaluation of the overall protectiveness of eacti alterrative '-c w
cx> hew the alternative achieves protection ^er tin* and how the
risks are eliminated, reduced and acntrolled through traatserrt,
engineering controls oar institutional controlฎ. Alterrative 5,
which treats aontaaunation in the groundwater and soils would prov.2<
the highest degree of protection to the public health and the
environment. Raping and treating oantaoirated groundwater should
reduce the levels of TOC contamination in the aquifer to these
required Michigan Act 399 of 1976. Qaavating and treating
aontamirated soils on-site will reno/e this possible souroe of
groundwater ocntamination though exposure to this souroe was rot
positively identified as a potential haalth risk in the public healt
assessnent. Alternative 3 traats the ocntamirated groundwater as in
Alternative 5, to lwels required by >ct 399 of 1976 and is
protective of public haalth and the envirorment. Alternative 4
treats the aarrtamiratad on-site soils but since the residential well
directly east of the site do not show ele/atad levels voc and
indicate that the soils are not an cn-going source of contamination,
this alternative will have mmural protective effect an huran heal-
Alternative 2 will elisujv&te ingestion of and incidental oontact ซ
contaminated groundwater for these residents oaviwyjsd to the
main but it does not treat oontamiraticn in the envirorment and
therefore is not protective of future well users or the enviromer.t
Alternatives 1 and 6 are not protective of public health and the
environment because they do not treat acrrtaauraticn in the
environment.
Crrpl j apr* vjtft HVftg
Each alternative is evaluated for aarplianoe with ARAPs, including
ctienical-specific, action-specific and location specific AEARs.
These APARs are presented in Table 11 vith the alternatives to -hi:
they apply. All of the alteratives, exoept the no action
alternative, will meet their respective APAPs vith the foll3ป-mq
option: Alterratives 1, 2, and 4 do not aaqply with the Safe
Drlrtcing Water *=t of 1987 and Act 399 of 1976 which set prmar/
drinking water standards.
s^?rt^i>ara
This evaluation focuses on the effects on human health and the
envirorment wtucfi say occur wtvile the alternative is being
implemented and until the remedial objectives are met. U* fo*->ป
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37
'actors ware used to ป/aluate the short-tera effectiveness of eacr.
alternative: protection of the m iiimnicy ckaruxg < semens,
procect-ian of workers during remedial actions, errviramerrtal irpacis
frran isplenerrtatian of alternatives, and tis* until raaadial
objectives ax* arc.
With respect to protection of ths acmnjruty, Alternatives l through 5
will not pose riites to the local nmnmity, though there say be
Laiporary iraar/eniences. Alternatives 4 and 5 whi<3\ involve
excavation may result in increased dust generation bat this can be
axrtrolled throu^i conventional dust suppression techniques.
Risks to workers during ranedial action in Alteratives 1 through 5
can be controlled with safe working practiceฎ. Alternatives 4 and 5
may expose worker* to TCCs fran excavated soils but the levels should
be vithin applicable FELe and TLVs.
With respect to orwinxnental impacts, Alterratives 1, 2, 3, and 6
will have acntirued aigratian of contaminated groundwater at the site
and under the subdivision as they do not address groundwater
contamination. Altarratives 3, 4, and 5 will result in a tfinporary
<3wqe in groundwater flow from extraction and pit dewatermg and a
tarrporary increase in the flow rate in the bayou frcra the disci-^rged
groundwater. Alternatives 4 and 5 aould result in the release of low
levels of VOC to the air from the soils eacavati^.
Evaluation of the fiw until protection is achieved reveals the
following estimates: Alternative 2 should take a few -*aeXs to a fป
ronths, Alternative 4 should take 5- months, and Alternatives 3 and
5 should take 4-5 years. Alternatives 1 and 6 will not actueve
protection.
This evaluation fcruses on ths results of a rasdial action m terrs
of the risk rsaiiurq at the site after response objectives have oeer
net. Oie following factors are isej for aeA alternative:
Beatitude of rveiAing risk, adequacy and reliability of controls.
lbs prieery risk identified at ths site ths public
hsalth/anvai i inl risk assessment is frcn the ingestion of
aontaainated groundwater. Alternatives 3 and 5 offer tivt greatest
dsgroe of peraansnoa as they minimize the risks fraa ingestion cf and
incidental aorrtact with enrrtanarated groundwater by moving the
axrtamnants with traaowrt. Alternative 5 also treats subsurface
soils ansite. HcMver, the soils wert not found to pose an
unaaoeptabla rxaic. Alternative 2 alimirates the risks fran Lnqestisr
and incidental aorrtact with aantajrunatad groundwater by supplying
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-38
residents connected to the water main with a clean 9ouroe of pctafcle
<ซter. However, the aontaminated grcxmcVater would still persist
with this alternative. Alternative 4 nrtrw the risks fron aarrtact
with aibsurfaae soils but also docc not address the aarrtamiratian cf
the groundwater. Alterrativws 1 and 6 will not mitigate any of tte
ris*s presently associated with the site.
With respect to adequacy and reliability of controls, Alternatives 3
and 5 both use a reliable method to reduce and possibly eliminate
groundwater ccntaainatian. Total elimination of v*X aontanuratior.
will depend an it* distribution in the aquifer. If the system
canponents mechanically fail, they nay be replaced or repaired
without nucฑi iapact on the residences. Hie excavation and tnaatner.t
of on-site soils in Alternatives 4 and 5 should remove thos possible
source of grounciater aontaairatian. If the excavation or treatment
system mechanically fail, they may be replaced or repaired with no
exposure of the local aoBuunity to oantaminants. Alterrative 2
connections to the water main to eliminate risfcs from groundwater
which has a low potential for failure.
Oast
This evaluation examines the estirrated aosts for iflplsrenting the
resnedial alternatives. Capital and annual 06M aosts are used to
calculate estimated present wsrth aosts for each alternative.
Alternative 3, pumping and treating contaminated groundwater, has a
moderate capital cost and high annual cost trfiicti results in an
estimated present worth of SI,379,000. Alternative 4, excavating and
treating on-site soils has a high capital oast but since there is a
short implementation tine, annual costs are low. This results m an
esti-iatad present worth cost of $724,800. Alternative 5, which
acnbines A1 terratives 3 and 4, has the highest capital and annual
cost. Estimated present worth costs total SI,914,000 for Alternative
5. The remaining 3 alternatives which provide less overall
prutaction of public health and the environment cost less than the
already mentioned alternatives. Alterrative 6, no action, is
considered to have no associated aosts. Alternative 1, continued
monitoring at the site and subdivision, has low capital and annual
costs. The estimated present worth costs is $132,400. Alternative
2, connecting affected residents to the Oscoda water main and site
monitoring, also has low capital and annual trorth costs total
$170,250.
a-r+r-t\rp 1>wri7itY - Mobility and Voliae
This evaluatiji addresses the statutory preference for selecting
rated! al actions that er^>loy treatrwit technologies which perraner.tly
and significantly reduce toxicity, mobility, or volvsse of the
hazardous substances. This preference is satisfied when treatner.t is
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used to reduce the principal threats at a site through destruction of toxic
acrrtaainanfce, irreversible reduction in aarrtaamant nobility, or radv^rtior
of tot&l v^aluae of aorrtaoiratad oadia.
For Alternatives 3 and 5, the volvjne of axrtasnirants in the groundwater
wall be irreversibly reduced by extraction and treaUnert. T5ie ocntamrart
plane mobility will be affected Airing treataerrt but any remaining residua!
contamination wrll hove the same Debility once parting and treating has
stepped. Alternatives 4 and 5 vill eliminate the toxicity, volume, and
nobility of contaminants in the soil. ftanssver, the cn-site soil
oontamiraticn does not to be an or~racing cause of groundwater
contamination under the subdivision. of these three alternatives will
treat scxne groundwater, extraction fnan the aquifer in Alternatives 3 and 5
arri dewatering the excavation pit in Alternatives 4 and 5. The resulting
effluent water would Beet discharge criteria and vill be monitored to
verify this. The water treatment process vill generate spent carbon that
Tiay be considered hazardous waste and nust be handled accordingly (by the
carbon supplier and regenerator). The other three alternatives, 1, 2, and
6, provide no treatment, and thus, do nothing to affect toxicity, nobility
or volume.
Tny>1 1 j fy
This evaluation addresses the technical and administrative feasibility of
implementing the alternatives and the availability of the various services
and materials required during its implementation.
Technically, the placement of the extraction well system in Alternatives 2
and 5 is dependent cn the location of objects and structures in the
subdivision and the residents' willingness to have a well placed on their
property. Otherwise, the systen can be readily constructed or leased and
operated. The excavation in Alternatives 4 and 5 can be aacatplished with
conventional techniques but this may be difficult due to the close
proximity of the plant and the railroad tracks. The treattnent unit can be
easily constructed or leased and operated. For both the groundwater
extraction and the soil treaGnent, a pre-design study vill be needed to
verify systan performance. The connection to a water main in Alternative :
is a carron technology pi wen to be reliable. Alternative 1 only requires
installing a monitoring well and Alternative 6 has no actions.
Ai^-LTi-istrativftly, Alternative 2 will require tap-in fees to connect to the
Oscoda %ซtar main.
For all alternatives vfruch include sane type of action, all equipment,
services and specialists are available locally or fron national venders.
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7** Michigan DepaxtBMTt of Natural Resources fHENF) does not acrair
vith the U.S. EPfc's selection of Xlterr*t_iv% 3 as the preferred
remedial alterative for the Hedblum Industrieฎ site as presertad ir.
the next section. The MENR agrees vith the technology selected m
Alternative 3, but does vat agree vith the targeted cleanup level fcr
TCE. U* MKR wants a lower cleanup lr^%I for TCE, 1 ucyl, than that
indicated in the preferred ranedial alternative, 5 ug/1. Since the
groundwater vill be cleaned so as not to nireed an exness risk level
of 1 x 10"6 and the groundwater vill nest all oaxiflun aontaminant
limits (MCLs), this renedy has been determined to be protective of
human health and the envinxment (see Reduction of Site Risks belou-) .
mwrnmif-y Acaeptanoe
Comunity response to the alternatives is presented in the
responsiveness surmary *rtuch addresses aantnents received during the
public eminent period.
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GROSS HtTEHEKS PAEL, H.
13
"/Til. SUMMARY OP COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives developed during the Cress
3rot.ners Pail Recycling site FS were evaluated by U.S. I ? A
and H?A using the following 9 criteria. The advantages
and disadvantages of each alternative were then compared to
identify the alternative providing the best balance"among
these 9 criteria.
1. Overall Protection of Human Health and the Environment
addresses whether or not an alternative provides adequate
protection and describes how risks are eliminated, reduced
or controlled through treatment and engineering or
institutional controls.
2. Compliance with Applicable or Relevent and Appropriate
Requirements (ARARs) addresses whether or not an alternative
will meet all of the applicable or relevant and appropriate
requirements or provide grounds for invoking a waiver.
3. Long-term Effectiveness and Permanence refers to the
ability of an alternative to maintain reliable protection of
human health and the environment, over time, once cleanup
objectives have been met.
4. Reduction of Toxicity, Mobility or Volume is the
anticipated performance of the treatment technologies an
alternative may employ.
5. Short-term Effectiveness involves the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed during
the construction and implementation period until cleanup
objectives are achieved.
6. Implementability is the technical and administrative
feasibility off an alternative, including the availability of
goods and services needed to implement the solution.
7. Coste includes capital costs, as well as operation and
maintenance costs.
8. Agency Acceptance indicates whether, based on its
review off the HS/FS and Proposed Plan, U.S. EPA and IEPA
agree on the preferred alternative.
9. Community Acceptance indicates the public support of a
given alternative. This criteria is discussed in the
Responsiveness Summary.
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19
A matrix summarizing the comparative analysis of
alternatives on a criteria by criteria basis is presented i-
Table 10.
The following discussion expounds on the information
provided in Table 10.
A. pverall l?n lftnPปn Health and the Environment
All of the remedial alternatives considered for the Cross
Brothers Pail Recycling site, except for the no action
alternative, are protective of huaan health and the
environment by eliminating, reducing or controlling risks
through various combinations of treatment and engineering
controls and/or institutional controls. As the no action
alternative does not provide protection of human health and
the environment, it is not eligible for selection and shall
not be discussed further in this document.
All of the alternatives reduce the risks associated with
groundwater contamination by pumping and treating
contaminated groundwater. A groundwater monitoring program
will also be implemented to evaluate the effectiveness of
the groundwater remediation activities. In addition, all of
the alternatives utilize access restrictions (i.e. fence and
deed notification).
Alternative 3A does, however, include the removal of soil
contaminants through soil flushing. The treated groundwater
will be utilized as the flushing agent. In addition, a
6 inch vegetative cover will be placed over the non-flushed
areas to stablize the soils on-site. Alternative 2 includes
the same basic remedial components as Alternative 3A, less
the vegetative soil cover.
Alternative 3B does not include the soil flushing system.
Treated groundwater would be returned to the aquifer through
a series of re-injection wells. Alternative 3B also includes
a 6 inch vegetative cover over the entire site area. The use
of this cover type will result in passive flushing of the
soil* through natural infiltration.
Alternative 4A is very similar to Alternative 3B. The
treated groundwater will be re-injected into the aquifer.
Rather than a 6 inch vegetative cover. Alternative 4*
utilizes a small multi-layer cap over the most heavily
contaminated soil area to prevent the infiltration of
precipitation. Alternative 4B is identical to Alternative 4A
except the multi-layer cap will cover the entire site area.
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20
PCB Soil Removal - Option 1 requires removal of the
localized PCB-contaminated soil area and incineration a- a
TSCA approved incinerator. PCB Soil Removal - Option 2
requires removal of the localized PCB-contaminated soil ar=a
and landfilling of the soils at a TSCA approved landfill.
B. ARARs Compliance
SARA requires that remedial actions meet legally applicable
or relevant and appropriate requirements (ARARs) of*other
environmental laws. These laws may include: the Toxic
Substances Control Act, the Safe Drinking Water Act, the
Clean Air Act, the Clean Water Act, the Resource
Conservation and Recovery Act, and any state law which has
stricter requirements than the corresponding federal law.
A "legally applicable" requirement is one which would
legally apply to the response action if that action were r.ct
taken pursuant to Sections 104, 106 or 122 of CERCLA. A
"relevant and appropriate" requirement is one that, while
not "applicable", is designed to apply to problems
sufficiently similar that their application is appropriate.
All of the alternatives proposed for the Cross Brothers Pail
Recycling site meet or exceed ARARs.
C. Long-term Effectiveness and Permanence
The alternatives considered for the Cross Brothers Pail
Recycling site vary in their ability to provide long-term
effectiveness and permanence.
Each of the alternatives considered includes a groundwater
pump and treat component. By eliminating the contaminants
present in groundwater each of the alternatives achieves a
certain degree of long-term effectiveness and permanence.
The difference between the alternatives with regard to
long-term effectiveness and permanence is directly related
to how each alternative addresses soil contamination at the
sitซ.
Alternative 3A provides the greatest degree of permanence.
Til# heavily contaminated soil area is flushed, removing any
leachable materials from the soil. A 6 inch vegetative
cover is placed over the site's non-flushed area stabilizing
the soils on-site. Alternative 2 follows Alternative 3A in
degree of permanence. Alternative 2 does not include the
6 inch vegetative cover. As such, soils in the non-flushed
areas will be subject to wind and water erosion.
Alternative 3B, which includes pump and treat with re-
injection of the treated groundwater, provides the least
amount of long-term effectiveness and permanence.
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Alternative 33 dees not actively address tr.e
in tile soil. The presence of only a 5 inch vegetative cover
will allow passive flushing of the soil contaminants. Thus
recontamination of the groundwater due to leaching of the
.contaminated soils is lixely. Alternatives 4A and A3, while
not removing the contaminants present in the soil, do offer
greater long-term effectiveness than Alternative 33 by
containing the contaminants. Both of these alternatives
include a multi-layer cap that will limit the infiltration
of precipitation through the soils and preclude the leaching
of contaminants into the groundwater.
The long-term effectiveness and permanence differ greatly
with respect to the PCB Soil Removal Options. Option 1,
removal and incineration, provides far greater permanence
than Option 2 - removal and landfilling. Under Option 1, the
PCBs present in the soils will be permanently destroyed.
Option 2, however, only displaces the contamination to a new
location.
Reduction of Toxicity. Mobility or Volume through Treatment
All of the alternatives include a component which reduces
the toxicity, mobility and volume of the contaminants
present in the groundwater at the site through treatment.
The difference between alternatives is most noted with
regard to the contaminants present in the soils at the site.
Alternatives 2 and 3A provide for the greatest reduction in
the toxicity, mobility and volume of the contaminated soils.
Both of these alternatives require the soils to be
continually flushed during the groundwater remediation
activities. Upon completion of the groundwater remediation
activities (estimated 15 years), any leachable contaminants
will be removed from the soils. Alternatives 4A and 4B
reduce only the mobility of the soil contaminants through
the use of a multi-layer cap. The multi-layer cap will
limit the infiltration of precipitation, and preclude the
leaching of soil contaminants into the groundwater.
Alternative 3B does not actively address the contaminated
soils at the site. Therefore, Alternative 3B does not
provide a significant reduction in the toxicity, mobility or
volume of the soil contaminants.
PCB Soil Removal - Option 1 significantly reduces the
toxicity, mobility and volume of the PCB contaminated soils
by thermally destroying the PCBs. Option 2, however, only
reduces the mobility of the PCBs by landfilling the soil in
a TSCA landfill.
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22
Z. Short-tera ggfectivenpss
All of the alternatives considered have similar impacts on
sr.ort-tera effectiveness resulting from a groundwater
treatment system being utilized. The alternatives differ
however, with respect to the other remedial ccmponents~used
as well as the length of time required to remediate the
site. These factors present varying potential short-tera
risks across all the alternatives. It is not obvious
however, that any one alternative presents lower overall
short-tera risks than the others.
The use of the soil flushing under Alternatives 2 and 3A
presents a potential short-tera risk to the environment by
temporarily increasing the mobility of the contaminants
within the soils. This increased risk, however, will be
controlled through the proper placement of the groundwater
pumping system. In addition, the groundwater monitoring
program will assess any changes in aquifer conditions. The
use of soil flushing in these alternatives lengthens the
estimated period required to meet the site's cleanup
objectives. The remedial action time estimated for
Alternatives 2 and 3A is 15 years, compared with the 11
years estimated for Alternative 3B and the 10 years
estimated for Alternatives 4A and 4B.
Alternatives 3A, 3B, 4A and 4B which utilize a vegetative
cover or a multi-layer cap will involve the grading of
surface soils which may create a temporary dust problem.
Conventional dust control measures will be employed
however, to limit any fugitive dust emissions that may occur
during grading activities.
The PCB Soil Removal Options are similar in the area of
short-term effectiveness. Both options require the
excavation and off-site transport of the contaminated sub-
soils. Short-tera exposure risks to workers and the
community may result. One potential difference between the
options is tile length of time necessary to complete the
remedial action if a larger quantity of soil needs to be
removed*,. Option 1 will take longer than Option 2 due to
capacity restraints of the licensed TSCA incinerators. The
projected volume of soil to be excavated under either
option, however, is expected to be small enough that no
problems would a*-ise with either incineration or
landfilling.
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23
Tjplaaentability
while all of the alternatives considered are ispieaer.tab le,
scae alternatives are technically easier to implement t.-.an
ct.-.ers, based an their design and complexity.
Alternative 33 is the easiest alternative to implement as
the remaining alternatives involve modifying this design.
Next in iaplementability would be Alternative 2, which
involves installing flushing equipment at the site.
Alternative 3A is next and is similar to Alternative 2 with
the addition of the 6 inch vegetative cover.
Alternatives 4A and 4B would be next, respectively, due to
the complexities in designing and installing a multi-layered
cap. Alternative 4A would be easier to implement than
Alternaitve 4B as it involves a smaller multi-layer cap
than Alternative 4B.
Excavation of the localized PCB-contaminated soil area is
easily implemented under either PCB Soil Removal Option.
Option 1 has some implementability problems due to the
finite availability of incinerators that are licensed to
handle PCS contaminated soil. This could potentially lead
to delays in transporting the materials to be incinerated if
a large volume of soils is removed.
G. Cost
The estimated present worth value of each alternative and
option is as follows:
Groundwater and Soil Remediation Alternatives
Alternative 2
Alternative 3A
Alternative 3B
Alternative 4A
Alternative 4B
$ 1,729,400
$ 1,956,700
$ 1,872,800
$ 2,285,000
$ 2,997,000
Localized PCB Soil Removal Options
Option 1 $ 17,700
Option 2 $ 8,600
H. Agency Acceptance
U.S. EPA and IEPA agree on the preferred alternative. Both
Agencies have been involved in the technical review of this
state-lead fund financed HS/FS, and the development of the
Proposed Plan and ROD.
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2-4
I. Community Acceptance
Community acceptance is assessed in the attached
Responsiveness Susaary. The Responsiveness Suamar/ provides
a thorough review cf the puslie ccaaents received on the
HS/T5 and Proposed Plan, and U.S. EPA's and IZPA's responses
to the comments received.
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fCRIHSIEE LANEFTLJL, WA
Modifying Criteria
The modifying criteria are used In the final evaluation of reme31ai
alternatives. The two modifying criteria are state ana community accept
For both of these elements, the factors considered in the evaluation are
elements of the alternative which are supported, the elements of tne
alternative which are not supported, and the elements of the alternative *^a-
have strong opposition.
8. State Acceptance
Washington State Department of Ecology (Ecology) has been closely
involved with the development and review of the Remedial Investigation ana
reasibi1ity Study arocssses Ecology comnerted on tie RI-'FS a^: ?
recommendation in tne Feasipility Study. The state strongly favors oumo ana
t-eatment of the contaminated groundwater plume as an intsnm neasure >jnf'
contamination coming from tne landfill is reduced to acceptable leva's
Aitnough EPA has been *or
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8. SELECTED REMEDY
This section of the ROD should identify the selected remedy and remediation
goals , state the carcinogenic risk level to be attained and the rationale for it, and the
specific points of compliance for each media addressed.
EXAMPLE: VOGEL PAINT AND WAX, LA
This example provides a good, detailed technical description of the selected
remedy. The strong points are the inclusion of a figure that depicts the selected
treatment process in general terms, and cost tables for both the source control and
ground water components. One flaw in this discussion is that a specific vendor is
named for the low temperature thermal treatment system that may be used. Vendors
should never be named in a ROD. Also, although technical parameters are well
established, remediation goals and points of compliance are not distinctly addressed.
A summary of the important features of this ROD's contingency remedy and the
criteria for its implementation are described in an appropriate level of detail.
EXAMPLE: MARATHON BATTERY, NY
This second example provides a good, succinct description of the selected remedy
and explicitly addressed remediation goals and their basis. Points of compliance are,
however, not outlined specifically.
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\*XZL FAD/T & WAX, IA
2.8 Selected Kemeav
The selected remedy is Alternative S-3 involving on-site
bioremediation of soils coupled with Alternative GW-1 involving
pumping and air stripping of groundwater.
The selected remedy will include the following ancillary
activities:
o Continued listing and restrictions associated with the State
Abandoned or Uncontrolled Sites Registry until no further
threat remains.
o Continued floating hydrocarbon removal until no appreciable
amounts can be recovered.
o Removal of the uncontaminated cover soil and temporary storage
of the material in a protected area.
o Removal of solid waste material, other than contaminated soil
(e.g., drums, paint cans, wooden pallets, paint solids,
general trash), from the disposal trenches and temporary
storage in a protected area.
o Ultimate disposal of the solid waste material in a municipal
l&sidfall if the material is non-hazardous or can be made non-
hazardous through decontamination. Ultimate disposal in a
hazardous waste landfill or off-site incineration of this
aatarial may be warranted if the material is hazardous and
cannot be made non-hazardous.
o Removal of free solvent liquids from the excavation and
temporary storage in tanks, and off-site recycling of the
solvent, if possible, or off-site incineration.
18
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o For "clean closure" soils aust pass the E? Toxicity test for
leachable metals (40 CF3 251.24), the TCLP test for leachable
organics (40 CFR 253.41) and shall not contain aore than 100
mg/kg of Total Organic Hydrocarbons prior to final placement.
o A-n air monitoring program approved by the DffR will be
implemented during all site vork.
o Dust control will be provided during excavation.
Bioreoediation of soils will involve a fully contained surface
impoundment system complying with minimum technology standards
using conventional soil management practices (e.g., nutrient
addition and soil aeration) to enhance microbial degradation and
volatilization of organic contaminants. The system vill be
designed to contain and treat soil leachate and volatilized
contaminants.
A system consists of a double lined treatment bed, a sand/gravel
layer to serve as a leachate collection system with perforated
drainage pipe and a sump, and groundwater monitoring, if volatile
contaminants must be contained, the entire treatment bed will be
covered by a modified plastic film greenhouse. An overhead spray
irrigation system will be installed to control moisture and used
as a means of distributing nutrients (see Figure 9).
The leachate will be recycled back to the treatment area via the
spray irrigation system. Leachate in excess of acceptable limits
will be treated on-site or collected for off-site treatment.
Vapors will be treated (i.e. carbon adsorption) and released. The
spent carbon would be regenerated if possible, or sent to an
approved landfill facility. Approximately one-acre of land will
be needed for treatment of 3000 cubic yards of soil.
High concentrations of heavy metals may prohibit use of this
process. Additional soil sampling and testing and a treatability
study are necessary prior to implementation. If small quantities
of soils are identified as containing high levels of heavy metals
which are incompatible with bioremediation, these soils vill be
isolated and treated on-site using a stabilization process (e.g.
lime, Portland cement or bentonite). Treated soil vill be
redeposited in the excavation and covered vith clean soil.
If high concentrations of heavy metals pose excessive restrictions
on the use of bioremediation, thermal treatment of soils vould be
implemented in its place; in which case, ancillary activities vould
remain the same and the soil vould then be treated using lov
temperature thermal treatment to drive off the volatile organic
compounds. The organic compounds in the off-gas vould be destroyed
using an afterburner if ARARs for air emissions cannot be met. The
mobile lov temperature thermal treatment system developed by WESTON
is designed to handle 15,000 lb/hr of contaminated soil based on
19
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Contaminated Soil
Excavation
Soil
Solid Phosซ
Source: Evoca Corp.
(revised)
SOLID PHASE BI0DECEADA7I0K
FIGURE 9
19a
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20% soil moisture and 1% (10,000 ppa) VOCs. The system is
comprised of three trailers that are a total of 120 feet long ar.d
3 feet wide. The total height of the trailers, with the equipment
assembled, is under 13.5 feet. As with bioremediation, thermal
treatment will not remove metals and residual soil will be
stabilized, if necessary, prior to redeposition.
Contaminated groundwater would be removed by pumping from one or
more recovery wells. A pumping test will be conducted during the
remedial design to determine aquifer characteristics. This
information will be used to design the pumping system; i.e., number
and location of wells, pumping rates, and gradient controls. The
well (or wells) would be located and sized to draw water from the
entire contaminant plume thereby preventing any off-site migration
of groundwater contaminants. The pumped water would be treated by
air stripping to remove greater than 95 percent of the volatile
organic contaminants. Carbon adsorption would be used to remove
contaminants in the air discharged from an air stripper, if
necessary. Treated water from the air stripper would be discharged
to the adjacent stream. Activated carbon used for air stripping
off-gas and water polishing prior to discharge would be regenerated
or disposed of in an approved landfill facility. Pumping and
treatment will be continued until groundwater ARARs are met. A
groundwater monitoring program, approved by the DNR, will be
implemented and criteria for ceasing remedial action based on
monitoring results will be developed.
Air modeling will be done to ensure that air emissions pose no
acute or chronic health risks with risks from carcinogens less than
10"6 and 1/100 threshold limit value (TLV) for non-carcinogens. Air
emissions will be evaluated during pilot studies and an air
monitoring program acceptable to the DNR will be developed for
normal operation.
Some changes may be made to the selected remedy as a result of the
remedial design and construction processes.
Estimated costs for the selected remedy are shown in Tables 4 and
5.
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TX3LB 4
BSTIXATED COST 0? SOIL RZX2DIATI0N
:rec~ Cast Itess Basis
1. Reacval of clean soil & staging $4/cy x 9,000 cy $ 36,000
2. Excavation of solid waste, staging
and disposal $150/cy x 3,200 cy 480,000
3. Free product removal, trans-
portation and incineration $0.50/gal x 5,000 gal 2,500
4. Air monitoring 2,000
5. Excavation & staging of
contaminated soil $5/cy x 3,000 cy 15,000
6. Sampling & analysis of staged
soil 20,000
7. Land & site development 10,000
8. Construction of staging areas &
physical facilities for bioremediation 99,000
(Thermal Treatment) (40,000)
9. Biological Treatment including
leachate disposal) $33/cy x 3,000 cy 100,000
(Thermal Treatment) ($265/cy x 3,000 cy) (795,000)
10. On-site stabilization $60/cy x 3,000 cy 180,000
11. Backfill $4.5/cy x 3,200 cy 14,400
12. Clay Cap 515/cy x 6,450 cy 96,750
13. Revegetation $l,250/ac x 2 ac 2.500
TOTAL DIRECT $1,053,150
($1,694,150)
.-.direct Cost I tens
Engineering, design and treatability study $150,000(100,000)
Contingency S160.000(250.oooi
TOTAL INDIRECT $310,000(350,000)
TOTAL CAPITAL COST $1,368,150(2,045,000)
SM Ccst Items $l,000/year for 30 years
TOTAL PRESENT WORTH COST $1,385,000(2,060,000)
Discount Rate ซ 5.00%
NOTE: Cost for Thermal treatment same as bioremediation except as shown in
parenthaats*
21
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TXflI*8 5
ESTIMATED C08T 07 GROUNDWATER REMEDIATION
Direct Crst Iteas cist
1. Czr.szruction of recovery wells 5 40,000
2. Installation of pumps 10,000
3. Construction of air stripper 110,000
4. Activated carbon disposal (air treatment) 3,000
5. Air monitoring 2,000
6. Monitoring well installation S 20.000
TOTAL DIRECT $ 18 5,000
Indirect cast Items
1. Engineering and Design (incl.
treatability study) $ 80,000
2. Aquifer pump test 25,000
3. Contingency 30.000
TOTAL INDIRECT $ 135,000
TOTAL CAPITAL COST $ 3 20,000
O&M Cost Items
1. Power, operation and maintenance $50,000/year for 3 years
2. Groundwater monitoring $ 1,200/year for 3 years
3. Lab analyses $ 2,400/year for 3 years
TOTAL PRE8EMT WORTH C08T $ 4 66,000
Discount Rate - 5.00%
22
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The combination of Alternative 5-3 for soils and GW-i for
groundwater, would provide a substantial risk reduction througn
treatment of contaminated soils and removal and air stripping of
contaminated groundwater. The selected remedy ranks high witn
respect to the nine evaluation criteria except for implementability
cf the soil remediation. If implementability of on-site
cioremediation of soils proves impractical, then Alternative s-2
(on-site thermal treatment) will be utilised as the method for
soils remediation. Alternatives S-2 and 5-3 are similar with
regard to the evaluation criteria except for costs and
implementability.
Since no immediate risk has been identified, the risks (i.e., time
and development costs) of attempting to implement Alternative S-
3 are justified. If Alternative S-3 proves impractical,
Alternative S-2 will provide a well-proven technology as a
substitute.
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MARAUCN BArilKY, NY
TEX SELECTED REXZDY
The results of the RI/FS have shown that elevated levels of cadmium
above backround are present in Area III sediments.
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, both
EPA and NYSDEC have selected Alternative EFC-3, dredging of the
contaminated sediments from East Foundry Cove to a depth of one
foot, chemical fixation and off-site disposal of those sediments,
and restoration of the original contours, as necessary; Alternative
WFC-1, continued monitoring, for West Foundry Cove; and
Alternative CSP-3, sampling and analysis adjacent to and under Cold
Spring pier with dredging of any contaminated sediments determined
to be a threat to the environment, followed by chemical fixation,
off-site disposal, and restoration of the original contours, as
necessary.
The data compiled for East Foundry Cove indicate that over 951 of
the cadmium contamination is located in the upper layer (1 foot)
of the sediments. Due to the nature of the dredging process,
dredging to a specific action level (e.g., 10, 100, or 250 mg/kg
of cadmium) would be technically difficult, since these
concentrations vary in the sediments by only a few inches of depth.
Therefore, expectations are that by dredging the upper layer of
contaminated sediments, 95% of the cadmium contamination will be
removed. Following remediation, it is anticipated that cadmium
concentrations would not exceed 10 mg/kg in most of the dredged
areas.
A no-action alternative was chosen for West Foundry Cove. It was
assumed that West Foundry Cove receives cadmium-contaminated
sediments from East Foundry Cove and East Foundry Cove Marsh and
the Cold Spring Pier Area. Once these sources are remediated,
cadmium-free sediments would then be deposited in West Foundry
Cove. Tidal action would cause the existing sediments to mix with
the newly deposited sediments thereby causing the average cadmium
29
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concentration in the sediae.nts to decrease gradually below its
current average concentration of 43.9 ag/kg. x hydrologic analysis
of Area III will be conducted in order to evaluate sedi-er.t
transport routes.
Sediaent samples at and beneath the Cold Spring pier will be
collected, analyzed, and evaluated to ascertain whether this area
is a source of cadmium contamination. If, based upon this
analysis, these sediments are determined to be a source, these
sediments will be dredged to a depth of one foot.
During the dredging operation, silt curtains will be utilized to
contain resuspended sediments and minimize short-term environmental
impacts.
The dredged sediments will be thickened on-site. The dredge water,
resulting from the thickening process, will be clarified and tested
to make sure that it meets EPA and New York State water quality
standards before it is discharged into the Cove. The solids
resulting from the clarification process will be added to the
contaminated sediments awaiting fixation. Fixation of the
thickened sediments will take place at an on-site facility. Bench
scale tests were performed for the Area I ROD and indicate that
fixation of the contaminated sediments is a viable remedy.
Following treatment, the fixated material will be transported to
an off-site sanitary landfill. For costing purposes, it was
assumed that the more costly rail transport would be used to remove
the fixated sediments from the site.
Following dredging, the dredged areas will be resampled to
determine the levels of cadmium remaining in the sediment; this
information will be used as a baseline study for the monitoring
program. The dredged areas will be restored as necessary, pending
the outcome of the previously stated studies to preserve the
estuary structure and function and to provide an added level of
protection to the environment. Monitoring will be conducted to
assure the success of the restoration. The capital cost for the
remedy in East Foundry Cove is $17,000,000. The operation and
maintenance cost is estimated to be $19,770,160. The estimated
capital cost for the remedy for the Pier Area is $8.5 million. The
operation and maintenance cost is estimated to be $1.5 million.
The selected remedy for treating the contaminated sediments from
Area I and- Area IZ is chemical fixation. It vas assumed that
sediment*- from Area III could be treated at the facility con-
structed on-site for Areas I and II, and a savings in capital cost
could be realized. This cost saving vas not reflected in the cost
estimates stated in the ROD.
30
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RgKgT3IAT:3H OPALS
The risk assessaent has concluded that with
cor.taairation presently remaining in East Foundry cSv. ?rd
Area, a threat^ to human health and the environment ~lv *er
Existing conditions at the site have been d8tln 1 tQ nnf5'
threat predominantly froa ingestion of contaminated 1
h'-Laan and animal DODu1*f
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9. STATUTORY DETERMINATIONS
The remedy selected must satisfy the requirements of Section 121 of CERCLA to:
protect human health and the environment
comply with ARARs or justify a waiver
be cost effective
utilize permanent solutions and alternative technologies
or resource recovery technologies to the maximum extent practical
satisfy the preference for treatment as a principal element to justify
not meeting the preference
Documentation of each finding Is important but perhaps most crucial is the
rationale for the selection decision (in terms of the nine criteria), which should be made
under the Utilization of Permanent Solutions (to the maximum extent practicable)
determination.
EXAMPLE: WAUSAU WATER SUPPLY, WT
Highlights worth noting in this example are that the discussion under
Protection of Human Health and the Environment describes how the selected remedy
addresses the specific risks identified in the baseline risk assessment. This discussion
also explicitly states that the remedy will not pose any unacceptable short-term risks,
cross-media impacts, or environmental risks. These items should be addressed in
every ROD.
The rationale for ARARs determination are provided as necessary and the land
disposal restrictions are discussed ,as they should be in every ROD, in order to
document clearly whether or not they are ARAR. The discussion under Utilization of
Permanent Solutions and Alternative Treatment Technologies to the maximum extent
practicablel provides a logical rationale for the selection that highlights choices made
on the basis of differences between the options related the the five balancing criteria.
EXAMPLE: SOLED STATE CIRCUITS, MO
The second example is well written overall and shares many of the same
strengths as the previous example. In addition, the ARARs have been organized into
chemical, action, and location-specific and pertinent 'To Be Considered" is also
included.
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WAU5ALJ WATVR SUPPLY, WI
1. Protection of Human Health and the Environment
Based on the rislc assessment developed for the site, long-term
exposure to low levels of VOCs In drinking water, potential
exposure through the use of private wells, and exposure to air
ealsslons froa existing VOC treatment systems are the identified
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33
ris*s associated with the site. Implementation of S'<~Z syste-3 it
the source areas and treatment of off-gases, as called f:r ..-de:
Alternative 5, provides protection to human health and the
environment through volatilization of VOCs from ccntaair.ated
soils, and expedited removal of contaminants from groundwater cy
increased pumpage of municipal wells.
Volatilization of VOC-contaminated soils will eliminate the
source of continued loading of VOCs to tile aquifer; thus reducing
the time during which residents are exposed to trace levels of
VOCs. Implementation of Alternative 5 will not pose any
unacceptable short-term risks or cross-media impacts to the site,
the workers, or the community. No environmental impacts have
been identified for the site. This is largely due to the fact
that impacts from the site have been to groundwater, and soils m
industrial areas.
2. Attainment of Applicable or Relevant and Appropriate
Requirements of Environmental Laws
Alternative 5 will bซ designed to meet all applicable or relevant
and appropriate requirements (ARARs) of Federal and more
stringent State environmental laws. Tables 7-n list the ARARs
that apply to each of the action alternatives and the following
discussion provides the details of the ARARs that will be set by
Alternative 5. The Land Ban requirements of RCRA do not apply to
this remedial action.
a. Fiscal; Safe Drinking Water Act (SDWA) / State:
Chapter >TR 109 Wisconsin Administrative Code fWACl
The SDWA and corresponding State standards specifies maximum
contaminant levels (MCLs) for drinking water at public water
supplies. Since TCS is regulated under the SDWA MCLs,
requirements for achieving MCLs are relevant and appropriate for
this remedial action. PCE is under consideration for a proposed
MCL of 5 ug/1 in the near future. Therefore, the likely proposed
MCL for PCE is a TBC (to bซ considered) for this remedial action.
b. State; Chapter 14 0 WAC
Wisconsin groundwater protection Administrative Rule, Chapter ^
140 WAC, regulates public health groundwater quality standards
for the State of Wisconsin. The enforceable groundwater quality
standard for TCE is 1.8 ug/L. Groundwater quality standards as
found in NR 140 WAC are ARARs for this remedial action.
c. Federal: Clean air act (CPA)
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34
The CAA identifies and regulates ".a release of pollutants to
air. Section 109 of the CAA identifies those pollutants for
which Aabient Air Quality Standards (AAQS) have been established.
Section 112 outlines criteria for pollutants for which there are
no applicable AAQS. Eaissions from existing and proposed
treatment systeas are not expected to exceed the AAQSs for any cf
the compounds present in groundwater.
d. State: Chapter >fR 445 WAC
Wisconsin Chapter NR 445 establishes hourly or annual emission
rate limits for specific contaminants. Eaissions rates on the
order of 1 lb/day for individual systems are estimated and would
be expected to meet the liaits.
3. Cost-effectiveness
Alternative 5 affords a high degree of effectiveness by providing
protection from chronic low level exposure of TCE for production
wells CW3 and CW6, providing protection from potential exposure
to future private well users, and preventing further discharge of
VOC emissions. Alternative 5 is the least costly alternative
that is protective of huaan health and the environment.
Therefore, Alternative 5 is considered to be the most cost-
effective alternative that is protective.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maxuun
Extent Practicable
U.S. EPA and the State of Wisconsin believe the selected remedy
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective
manner for the final remedy at the Wausau site. Of the
alternatives that are protective of huaan health and the
environaent and comply with ARARs, U.S. CPA and the State have
determined that the selected remedy provides the best balance of
tradeoffs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility or volume achieved through
treatment, short-term effectiveness, implementability, cost, also
considering the statutory preference for treatment as a principal
element and considering State and community acceptance.
Although all of the alternatives that are protective and comply
with ARARs will achieve reduction of risks, there are significant
differences in the time required to achieve this goal.
Alternatives 2, 3, and 4 are groundwater remediation alternatives
that do not address source areas. This results in contamination
from source area soils loading to the aquifer for several
additional years. In addition, none of these alternatives
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35
provide any reduction in ::sa to remediate the deep TCI pl-tes
originating from the former landfill source area. This also
results in a significant time period to achieve reduction of
risks. Alternative 5 requires the shortest time period for
remediation of the site because it eliminates the continued
loading of contaminants to the groundwater, and it provides for
reduction in time to purge the deep TCS plumes by removing the
source and increasing removal rates of contaminants at the
Municipal supply wells.
The selection of a treatment technology for remediation of
contaminated soils is consistent with the Superfund program
policy that the highly toxic and mobile wastes are a priority for
treatment and to ensure permanence and long-term effectiveness zz
the remedy. Under the selected remedy, treatment of groundwater
will not provide a reduction of toxicity, mobility, or volume
(TMV). However, it will reduce contaminant levels in groundwater
and thus reduce the risks associated with ingestion of
groundwater, which has been determined to be a greater risk
than inhalation of air emissions. While other alternatives
evaluated provided treatment to achieve TMV reductions in
groundwater, these alternatives had other difficulties.
Alternative 2 required almost twice as long to purge
contaminants. Alternatives 3 and 4 propose a technology that has
not been shown to work on contaminants present in groundwater at
the site and thus would require extensive testing that would
delay full scale operation of the system for an estimated two
years. Based on these factors, it vas determined that
Alternative 5 would provide the shortest time period during
which receptors would be exposed to contaminants in drinking
water. In addition, based on air modeling, release of emissions
from the municipal air strippers do not contribute a greater than
1 x 10"6 risk level to receptors.
Since treatment of groundvater vill not achieve a reduction in
toxicity, mobility or volume, the major trade-offs that provide
the basis for this selection decision are long-term
effectiveness, short-term effectiveness, implementability, and
cost. The selected remedy can be implemented and completed more
quickly with less difficulty and at less cost than groundwater
treatment alternatives, thus reducing the exposure time for
pathway* oฃ concern. Alternative 5 is therefore considered to be
the moat appropriate solution to contamination at the site
because it provides the best trade-offs with respect to the nine
criteria and represents the maximum extent to which permanent
solutions and treatment are practicable.
5. Preference for Treatment as a Principal Element
By treating the VOC-contaminated soils using SVE with carbon
-------
26
absorption of off-gases wich regeneration of the carbon, t.-.e
selected remedy satisfies the statutory preference for remedies
that employ treatment of the principal threat which permanently
and significantly reduces toxicity, mobility, or volume of
hazardous substances as a principal element. Treatment of
groundwater to reduce toxicity, mobility, or volume would also
seem to be desirable to satisfy the statutory preference.
However, treatment of groundwater to permanently and
significantly reduce toxicity, mobility, or volume of
contaminants was not found to be practicable or cost-effective
for remediation of the site.
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SOLID STATE CIRCUITS, (O
SECTION 10.0 STATJTCPV -T-r?ซ'ปjA-::N5
V-der its legal au:hcr:::es, EPA' s primary rsspc-s:::'.::.
S-cerr-nd s itas is 'o ur.iertaks rerr.edisi 3C" : :r.s ~ - at a o r. i e . ฆ=
j:er-2".2 ::ctact::n ;f r.--an r.eal:.". and :r.e er.v::;--o--. :-
additi;-. section 121 of CIP.CL.A estao 11 sr.es several, ctrar
3t2"-:::y requirements and preferences. These scecif/ ::j: --
complete, the selected remedial action for tr.is site -.3: " -;
wit.-. applicable :r releva.-.t and appropriate anv;r:r.?srtal
standards established under Federal and State er.vir:r.rerti. -i
-n.less a statutory waiver is justified. The selected rereoy 1
-ust be cost effective and utilize permanent solutions ano a. t
native treatment technologies or resource recovery tecr.r.o1 og 1 ฆ=
to the maximum extent practicable. Finally, tne statute inc.-
a preference for remedies that employ treatment that pem.ane-t
and significantly reduce the volume, toxicity, or mobility c:
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
10.1 Protect ion 21 Human Health and the Environment
The selected remedy protects human health and the e.nviror
-en.t through extraction and treatment of the VOC contaminate::
ground water. The contaminants will be permanently removed :
t.-.e ground water by air stripping. The volatile dissolved
-ill be transferred to the air stream for release to the
atmosphere.
Extraction of the VOC contaminated ground water also w1_
eliminate the threat of exposure to the most mobile contamma
from direct contact or from ingestion of contaminated ground
water. The future carcinogenic risks associated with these
exposure pathways are as high as 1.1 x 10 , or one person in
tan, for TCE. By extracting the contaminated ground water an
treating it bv air stripping, the cancer risks will be reduce
accut 1 x 10 and an Hazard Indices (HI) ratio of less than
A numerical computer model was utilized to predict the highes
airborne concentrations emitted from the air strippers. The
location with the highest concentrations was used to evaluate
potential health risks. The highest cancer risk is 5.5 x 13-
and the highest HI ratio is 0.3997. These levels are within
range of acceptable exposure levels of between 10~4 and 10~
an HI ratio of less than 1 There are no short-term threats
associated with the selected remedy that cannot be readily
controlled. In addition, no adverse cross-media impacts are
expected from the remedy.
61
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The selected remedy o: extraction, :r,s::a :."V3;cal, oner:
zr eatr.er.t, and discharge ~f the traatad affluent zz t.-.e ?CT'-'
"rely 'ซ i th all applicaole :r relevant and appropriate cr.s-::
arti;.-., and Location specific req^-ire-er.ts ' AJRAP.s) . The A?Jk.:
a 3 3*"950r.-S- 3 0 1 C V
\zz i;r.~5p0Cir - - s :
:.'at::r.al Primary a.-,i Secondary Ar_oisnt Air .ual.t/
Standards (40 CFR Part 50)
State air quality De Minimis Emission Levels
;10 CSR 6.060(7)(A);;
State water quality standards for aquatic life
protection (10 CSR 20-7.03 1) incorporated into tne
NPDES permit for the POTW discharge to Dry Branch;
National Pretreatment Standards, 40 CFR Part 4 0 3;
and,
Pretreatr-.ent standards of 200 ug/1 and 200 gpn
established by the City of Repub lie for the
discharge of treated SSC effluent to the POTW.
Chemical-specific ARARs:
Federal Maximum Contaminant Levels for inorganic an:
volatile organics in drinking water supplies
(40 CFR Part 141) ?
State Maximum Inorganic Chemical Contaminant Levels
(10 CSR 60-4.030) for public water systems;
State Maximum Volatile Organic Chemical Contaminant
Levels for public water systems (1C CSR 60-4.100);
ar.d,
State water quality standards for inorganic and
volatile organics in ground water (10 CSR 20-7.03l)
Lccation-spซcific ARARs:
None
Other Criteria, Advisories or Guidance To Be Considered for
Remedial Action (TBCs) :
62
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- Z.PA 3rd tr.e State o f M i s s e u r i ~.ava i^rssd to
ir.eo rperate a local :r dirar.ce :o eror.ieit ::-.3:r.:-
11 0 r. or rev va 0 a r sue z 1 / ซ e 1 - 3 _ r. or r.jir - - a ;:~-
t a m 1 r. a r, - u s s r. 111 - "*ฆ r5;2'l. 311 0 n 3 0 0 r. c . a t a .
This v 1. 1 c r a v a r. t d ; ract ;cr.t jc* sr. d or _-"23t.or of
con~a.Tiir.aoad grcur.d water.
1 - :;5:-"f :;c: - v a - a s ?;
T~e sa-aetad remedy : 3 rest-e f f set ive eecausa it -.as oaa~
oatamr.ed to provide overall e f f ect ivar.ess p:cporo:or.al to :ts
ocsts, tr.e .".at present vcrth value being 3 ฆ; , 6 29 , ฆ; C 0 . Tr.e se.aot-
ed reredy is tr.e least costly of tr.e Alternatives II, III I'.',
-.men ara equally protective of human health ar.d tr.e ar.v 1 ro r ~ar t.
13.4 1111 z a 11 e r. 0 i Permanent Solutions and A11 e r r. a 11 v e Treat-a--_
Tech-elegies ' e r Resource Recove rv Techno leg les ) t e tr.e
'*a:< 1 ~urt Zxter.t Practicable
The State of Missouri and EPA have determined tnat the
selectad remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized m a cost-
effective manner for the Solid State Circuits Site. Of those
alternatives that are protective of human health and the
environment and comply with ARARs, the State of Missouri ar.d IPA
r.ave determined that this selected remedy provides the eest
ealar.ee of tradeoffs in terms of long-term effectiveness ar.d
permanence, reduction m toxicity, mobility, or volume achieved
tr.reugn treatment, short-term effectiveness, implementaDiliv. .
eest, also considering the statutory preference for treatment 23
a principal element and considering State and community input.
Alternative II reduces the toxicity, mobility, and volume of
tr.e contaminants m the ground water; complies with ARARs; pro-
vides snort-term effectiveness; and protects human health ar.d tr.e
environment equally as well a Alternatives III and IV. In terms
ef long-term effectiveness, Alternative II is more reliable
eac^up to the stripper units and because it does not generate any
residuals. Alternative II will be easier to implement techni-
cally because it requires less construction and administratively
eecause it will require less coordination with relevant agencies.
Finally, and importantly, Alternative II costs the least of tr.e
equally protective alternatives. The major tradeoffs that pro-
vide the basis for this selection decision are long-term effec-
tiveness, implementability, and cost. The selected remedy is
-ere reliable and can be implemented more quickly, with less
difficulty and at less cost than the other treatment alternatives
ar.d is therefore determined to be the most appropriate solution
for the contaminated ground waters at the SSC site.
63
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The State Missaur: is 'ซ 11i~e
remedy. A^tncugn pus lie c"".ar."s ซers racsivad :cr.carr. .r^ tr. e
capacity of t.-.e ccr^iur.ity1 3 PC7W, tr.ose ::".er.ts are fully
addressed in the Responsiveness Summary.
The Proposed Plan for e 33C sita was released for ;usL.:
::--sr: on August 14, 1939. The Proposed Plan identified"
i.:ar"3:ive II as tr.e preferred a 1 te ma t ive . I? A reviewed a'.,
written and verbal comments submitted during tr.e cue lie
period. Vpcn review of these ccr~.er.ts, it ซas determined tr.at ~c
significant cnanges to the remedy, as it was originally
identified in the Proposed Plan, was necessary.
12.5 ?re ferencs for Treatment as a Principal ZIgmer.t
3y treating the VQC-contammated ground waters m two
existing ensita air strippers and discharging the treated
effluent to the POTW for secondary treatment, the selected rerecy
addresses tne principal threat of future direct contact/ingest icr.
of contaminated ground waters posed by the site tnrough the use
of treatment technologies. Therefore, the statutory preference
for remedies that employ treatment as a principal element is
satisf ied.
64
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10. RESPONSIVENESS SUMMARY
The final component of the ROD is the Responsiveness Summary which serves
two purposes. First, it provides lead agency decision makers with information about
community preferences regarding both the remedial alternatives and general concerns
about the site. Second, it demonstrates to members of the public how their comments
were taken into account as an integral part of the decision making process.
EXAMPLE: CHEMICAL INSECTICIDE, NJ
The sample Responsiveness Summary is very thorough and easy to follow. It
provides an overview of the activities required by Section 121 for public notification
and comment and outlines the various sections of the remainder of the Summary.
There is a brief history of the community relations activities for the community, and a
summary of major questions and responses received during the comment period. The
questions found here are excellent examples and typical of concerns often posed by the
public. The responses are logical and informative. A citizens' petition and the specific
response to it are also reproduced. For general information and a reference source the
proposed plan, attendance sheets from the public meeting, list of information
repositories and labs used (in response to a specific question) are attached as
appendices.
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(jfflf) UNITEDST
<3,i" _ r ' .1 1H0Q
-Jo 1989
V W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RฃGON I
jaco6 *ฆ Mvrrs fedctal buudino
NEW VOซK. Nfiw YOซK 10278
Sec Address List
Re: Your August 28, 1989 Letter Concerning the
Cheaical Insecticide Corporation Site in Edison, New Jersey
Thank you for the August 28, 1989 letter which you and other
concerned citizens vrote to express your questions and comments
concerning the Environmental Protection Agency's Proposed Plan
for an intaria remedial action at the Cheaical Insecticide
Corporation Sit*. The concerns expressed in your letter have
been reviewed by appropriate Environaental Protection Agency
staff, by Ebasco Services personnel who worked on the Reaedial -
Investigation and Feasibility Study for the site, and also by an
Agency for Toxic Substances and Disease Registry representative
assigned to tho EPA Region II office. A response to the
questions and coaaents expressed in your letter has been
prepared, incorporating information obtained froa the reviewers
mentioned above. A copy of this response is enclosed and is
being bซ sent to each of the signers of tha August 21 letter.
Copies of both the August 21 letter and EPA'a response will also
be placed in the inforaation repositories for the Site.
EPA will keep you informed of our progress regarding the Cheaical
Insecticide Corporation Site, including the decision regarding
the selection of an interia remedial action. Z appreciate your
interest and participation in tha Suparfund program.
umm
Dear
Cheaical Sngineer
New Jeroay Compliance Branch
Emergency and Reaedial Response Division
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RZSPOHSrVQTESS SUMMARY
CHBCICAL INSECTICIDE CORPORATION SITS
ED I SOW, KKM JERSEY
I. RJSSPONSIVBfESS SUMMARY OVERVIEW
The U.S. Environaental Protection Agency (EPA) held a public
conusant period froa August 3, 1989 through Septeaber 8, 1989 for
interested parties to cosunent on the Focused Reaedial
Investigation/Feasibility Study (RI/FS) report for Surface Water
Run-off Control and the Proposed Reaedial Action Plan (PRAP) for
the Cheaical Insecticide Corporation (CIC) Site in Edison, New
Jersey.
The PRAP, which has baen provided as Appendix A of this docuaent,
provides a suaaary of the background information leading up to
the public coaaent pariod. Specifically, the PRAP include*
information pertaining to the history of the CIC Site, the scops
of the proposed cleanup action and its role in tha overall Site
cleanup, the risks presented by tha Site, the descriptions of the
reaedial alternatives evaluated by EPA, the identification of
EPA's preferred alternative, the rationale for EPA's preferred
alternative, and the coaaunity's role in the reaedy selection
process.
EPA held a public aeeting at 7:00 p.a. on August 10, 1989 at the
Edison Municipal Coaplex in Edison, New Jersey to outline the
interia reaedial alternatives describซd in the focused RI/FS and
to present EPA's proposed reaedial alternative for controlling
the surface water run-off froa the CIC Site.
The responsiveness suaaary, required by the Supซrfund Lav,
provides a suaaary of citizens' coaaents and concerns identified
and received during the public coaaant pariod, and EPA's
responses to thosa coaaents and concams. All coaaents received
by EPA during tha public coaaent pariod will ba considered in
EPA's final decision for selecting tha roaedial alternative for
addressing surfaca water run-off froa tha CIC Site.
This responsiveness suaaary is organized into sections and
appendica* as described below:
Z. RlSPOMSIvnnsS SUMMARY OVERVIEW. This section outlines
tha purposas of tha Public Coanant pariod and tha
Rasponsivanass Suaaary. Zt aloo referancas tha
appandad background information laading up to tha
Public Coaaant pariod.
1
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS. This
section provides a brief history of coasunity concerns
and interests regarding the Cheaical Insecticide
Corporation Site.
III. SUHXXRY OP MAJOR QUESTIONS AND COMXBfTS BKTTVP) DURING
THE PUBLIC COMMENT PERIOD AMD EPA RESPONSES TO THESE
COKKSfTS. This section suamarizss the oral comments
received by EPA at the August 10, 1989 public meeting,
and provides EPA's responses to thsse comments.
IV. WRITTHi COMMENTS RECEIVED DURING THE PUBLIC COKKENT
PERIOD AND EPA RESPONSES TO THESE COHXZSTS. This
section contains the one letter received by EPA
containing written conents, as veil as EPA's written
response to that letter.
Appendix A: The Proposed Reaedial Action Plan (PRAP)
which was distributed to the public during the public
nesting on August 10, 1989.
Appendix B: Sign-in sheets from the Public
Meeting held on August 10, 1989 in The Edison Municipal
Complex, Edison, New Jersey.
Appendix C: Naaes, addresses and phone numbers of the
information repositories designated for the CIC Site.
Appendix Di A list of the laboratories used to
analyze samples from the CXC Site.
2
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II. BACKGROUND OH CQMKUKITY INVOLVEMENT AND CONCERNS
Township records show that community concern regarding the CIC
Site, existed aa early as 1966, when residents living near the
Site complained of odors emanating from the CIC Sit*. The Edison
Township Departaent of Health and Human Resources and the New
Jersey Departaent of Health (NJDOH) continued to receive
complaints from residents and business operators about odors and
air pollution froa 1966 through 1970.
Comaunity interest increased in June 1983 when the Hew Jersey
Departaent of Environmental Protection (HJDEP) and EPA began
collecting soil samples for a State-wide dioxin-screening
program. Residents were concerned about the potential for off-
site migration of dioxin into surrounding residential areas. EPA
held a public meeting on June 20, 1983 to address community
concerns. Several hundred residents attended the meeting and
extensive media coverage continued for weeks.
Residents, local officials and business owners were interviewed
in 1987 during the developaent of the Community Relations Plan
for the Site. Their concerns are summarized below:
ฆ Residents would like to be better informed of all EPA
activities at the CIC Site.
a Residents were concerned about the potential exposure to
dioxin during EPA activities.
ฆ Local officials and residents were concerned that local
property values could be adversely affected by the EPA
activities at the CIC Site.
Residents and businsss owners wero concerned regarding
the extent and potential of contamination at the Site and
of the surrounding business and residential properties.
As part of EPA's responsibility and coaaitaent to ths Superfund
Program, the community has been kept inforaed of ongoing
activities conducted at the CIC Site. EPA has established
information repositories where relevant sits docuaents may be
reviewed. Docuaents stored at the repositories include:
ฆ Ths focused RX/FS Report for surface run-off
control.
Ths Proposed Reaedial Action Plan (PRAP).
ฆ Pact sheets, sumaarixing the technical studies
conducted at ths Sits.
ฆ Public Mssting Transcript.
3
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"^PA' a selection of f. remedy to control surface water run-off at
the Sit* will bซ presented in a document known as a Record of
Decision (ROD). The ROD and the documents containing inforaation
that EPA used in making its decision (axcapt for documents that
are published and generally available) will alao bซ placad in the
information repositories, as will this responsiveness summary.
ITT. SUMMARY OF MAJOR QUESTIONS AMD COWCDTTS RECEIVED DURING THE
PL4LXC COMMENT ?ERIOO AND EPA RESPONSES TO THESE COMMENTS
Oral comments raised during the public comment pซriod for the CXC
Site interia reaediation have been summarized below together with
EPA's response to thee* eoaaents.
COMMENT: One resident wanted to know why it was necassary to
select an interia reaediation alternative if a final remedy would
b* the aost protective of human health and tha environaent.
RESPONSE: A final reaedy which would, among other things, clean
up tha contaainated soil at tha Sita, cannot ba selected at the
present tiae. EPA has determined that treatability atudies are
needed to find tha aost effective technology or combination of
technologies for treating tha Sit* soils. The particular mixture
of pollutants in the Site soils (arsanic and pซaticldซs, in
particular) is potentially difficult to tr*at. This is bซcausซ
th* aost proven technology for organic pesticides, thermal
treatment (e.g. incineration), may not ba effective in treating
araenic. In fact, tha arsanic emissions from an incinerator
treating Site soils alght praaent an air pollution hazard, unless
treatability studies can show that air pollution controls are
capable of reducing arsanic emissions to safe levels. Therefore,
EPA is currently planning to teat thermal treatment and other
technologiaa such aa soil attraction and soil fixation on soil
samplea from tha Sita.
Depending on tha final remedy *v*ntually selected, it could take
up to eight years to parform treatability studies, select the
remedy, design tha reaedy and implamant tha remedy. Unless an
interia ramady is impleaented first, tha surfaca water run-off
from tha Sita would praaant continued risks until tha remedy for
Sita aoils has bean implemented.
EPA baliavm* that tha surfaca water run-off problem should ba
addressad first, sinca EPA la now in a position to address the
hazards prasantad by tha surfaca watar run-off from tha Sita.
While tha intaria ramady is proceeding, EPA would not slacken its
efforts to achiava a final ramady. onca tha final ramady for
aita aoil has baan implemanted, surfaca run-off from tha Sita
would no longer ba contaminated by contact with Sita aoila.
Therefore, tha surfaca watar ramady is considarad to b* an
Intaria aeaaure which would no longer ba naedad onca tha Site
soils hava baan claanad up.
4
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COMMHfT: One resident asked what type off capping ซyfe.eป would bซ
used and hov effective would it bซ.
RESPONSE: If an impermeable surficial capping syst&a was
implemented, it would probably consist of a multi-layer cap with
a synthetic membrane or a sprayed-on lining, together with
protective layers, such as textile "abrics. Standard landfill
caps are intended to bซ effective f->r thirty years or more.
However, the capping system recommended by EPA for ths CIC site
would only bs needed for ths duration of the interia remedy
(probably less than eight ysars). This capping systea would have
fewer layers than the standard landfill caps. Therefore, the
capping systsa would allow easier access to collect any soil
samples required for a treatability study, and would bซ easier to
remove once the final reaediation plan was implemented.
COMMENT: A resident inquired whether capping systeas have bซen
used on other sites and, if so, hov effectivs they were.
RESPONSE: Surficial caps have bซen employed at a nuaber of sites
such as hazardous waste landfills and municipal landfills. This
technology has proven quite effective over tias psriods similar
to that conteaplated for this interia action in preventing the
migration of contaaination in ths past.
COMMENT: One resident noted that there would bซ a large quantity
of run-off if a surficial cap were installed on CXC's six acre
lot. Ths resident wanted to know what type of storage capacity
EPA has planned to accoaaodats ths large volume of accuaulated
run-off.
RESPONSE: A detention structure would bs constructed in the
northeast corner of ths Sits to regulate the flow of discharge so
that ths reaedy would not causs any advsrss flooding iapact. As
part of ths rsmsdial design for Altsmativs 2, a drainage
analysis would be performed. Ths sizs of ths dstsntion structure
and ths details of any othsr asasures nssdsd to avoid flooding
iapact (s.g., iaprovsaents in area stoni drains), would be bassd
on that drainags analysis. Ths dstsntion structurs for
Alternative 2 would not nsesssarily be designed to dstain ths
precipitation froa a ones in twenty-five ysar stora svsnt.
COXXDlTf A rssidsnt asksd if Altsrnativs 2 was sslsctsd, whsn
would EPA sxpsct ths surficial cap to be installed.
RESPONSE: Work could begin on capping tha Sits approxiaatsly six
months following finalization of ths ROD for this interim action.
Ths reaedial design would be psrforasd during those six aonths.
5
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ZPA RESPONSE TO THE AUGUST 28, 1989 WRITTEN COMMENTS REGARDING
THE CHEMICAL INSECTICIDE CORPORATION SITE IN EDISON, NEW JERSEY
TJie August 28, 1989 written comments regarding the Chemical
Insecticide Corporation Site have been summarized below, together
with and EPA's responses to these comments.
COMMENT: How much and what types of contaminants were on-site
and have spread off-site?
RESPONSE: The types of contaminants linked to the Site were
discussed at the August 10, 1989 public meeting and summaries of
the analytical data were presented. Unfortunately, the slides
that were projected were not very clear. The chief contaminants
are arsenic, pesticides (DDT, lindane, chlordane, dieldrin,
etc.), herbicides (e.g., 2,4,5-T, 2,4-D and dinoseb) and dioxin.
Summaries of this data, which provide concentration values for
the measured contaminants in the different media sampled, can be
found in Exhibits 1-12 through 1-24 of the rocused RI/FS Report.
The results for on-site and off-site samples have been summarized
separately in these exhibits. The complete set of sampling data,
together with maps showing the sampling locations, can be found
in the two-volume document containing the "Remedial Investigation
Field Data: Validated Laboratory Results" (Ebasco, July 1989).
These documents are available in the information repositories for
the Site. Because of the volume of this information, it is not
practicable to present it here.
COMMENT: What effects did these contaminants have on the workers
of the factory, the community and the surrounding land and
animals?
RESPONSE: There is little information currently available to EPA
indicating any effects of the contaminants on the CIC employees,
the area residents and animals. In the 1960's several cattle
were alleged to have died as a result of drinking arsenic
contaminated water downstream of the factory. However, the
levels of arsenic found at the downstream sampling locations
during the Remedial Investigation are much less than those
associated with sudh acute effects. In all likelihood, the
arsenic concentrations were much higher during the period when
the Chmical Insecticide Corporation was operating and the cattle
deaths occurred.
As noted at the public meeting, sampling results from the
Remedial Investigation and other studies indicates that
contamination of the land around the CIC property by arsenic,
pesticides and herbicides is chiefly limited to the easement area
immediately east of the CIC property. In addition, sail
concentrations of dioxin off of the CIC property have all been
1
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11. LETTER FROM SUPPORT AGENCY
It is recommended that a letter stating the position of the support agency be
attached as an appendix to the ROD to demonstrate their concurrence. State
concurrence may also be demonstrated by the State Director's signature, however, that
seems to be more rare than a copy of the State letter. If the State has withheld an
opinion or given concurrence verbally, the ROD should state this in the Declaration and
in the Summary of Comparative Analysis of Alternatives section of the Decision
Summary.
EXAMPLE: MW MANUFACTURING, PA
A copy of two State letters are attached. These letters are brief and recount what
documents were reviewed, the major components of the remedial action with which the
State concurs, and lists any conditions to that concurrence such as continued
consultation during RD/RA, reserving the right to take independent enforcement action
and to be party to any negotiations with the PRPs.
EXAMPLE: WAUSAU WATER SUPPLY, WI
The second letter reviews costs and recognizes that the State may be required to
contribute 10% of the cost of the remedy should the PRPs refuse or be unable to fund the
action. It also outlines the role the State expects to play during the RD/RA.
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PENNSYLVANIA
Deouty Secretary for
Environmental Protection
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Bo* 2063
Harnsburg, Parmay'varna 17120
March 30 , 1989
(717) 797-5023
Mr. Stephen R. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut 3uilding
Philadelphia, PA 19107
Re: Letter of Concurrence
M. w. Manufacturing Superfund Site, Record of Decision (ROD)
Dear Mr. Wassersug:
The Record of Decision for the initial ooerable unit which addresses
the main source of the contamination by remediation of the carbon waste pile at
the M. w. Manufacturing site has been reviewed by the Department.
The major components of the selected source control remedy include:
* Excavation of approximately 875 cubic yards of contaminated waste
and contaminated underlying soils and incineration in an off-site
RCRA approved Incinerator.
* Oisposal of incinerator ash in a RCRA permitted hazardous waste
1andfi11.
I hereby concur with the EPA's proposed remedy with the following
conditions:
* Tht Ofpartment will be given the opportunity to concur with
decisions related to the overall Remedial Investigation and
Feasibility Study to identify the extent of, and future potential
for, groundwater contamination and remaining sources of that
-contamination, and evaluate appropriate remedial alternatives to
assure compliance with DER cleanup ARARs and design specific
ARARs.
* EPA will assure that the Department is provided an opportunity to
fully participate 1n any negotiations with responsible parties.
* The Department will reserve our right and responsibility to take
independent enforcement actions pursuant to state law.
-------
Mr. Steonen Wasser>.jg
* This concurrence with the selected retned'al action ^ not
'Htenaed to orovide .-y assurances oursuant to SARA
Section 104(c) (3).
Thank you for the oooortunity to concur with this ฃฐA 3aC;rj ;f ;ecs;:n.
If you have questions regarding this matter, olease do not hesitate to contact
Sincerely,
Mar* m. McClellan
Deputy Secretary
Environmental Protection
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5ซrซ:sa.:3 <*sr=. rz- ssss^s 29. ises ^
State Of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
GirroM 0. Btuiny, Sซc.-t:,ry
841 ?92t
Utdlton, Wltconln :j7i7
TZLE/AX NO. ซOI-Jซ7 0S7)
TOO MO, i04-247-ซaj7
Sซptซaber 28, 1989 IN reply R2?ฃR TO:
Nr. Valdus Adaokus, Regional Administrator
U.S. Environaental Protection Agency, Region V
230 South Dearborn Street
Chicago, IL 60604
SUBJECT: Selected Superfund Remedy
Vausau Groundwater Contaaination Sice
Vausau, Wisconsin
Doer Mr. Adaakus:
Your stiff has requested this leeter to doeuaent our position on the final
reaedy for the Vausau Groundwater Contamination Site. The proposed final
reaedy, identified as Alternative No. 5, is discussed fully in the Racord of
Decision and includes:
Installation of Soil Vapor Extraction (SVE) systaas to reaove volatile
organie compounds (VOCs) in soils at each of the three identified source
area*
Treataent of off*gases froa the SVE operation using vapor phase carbon
units which will be regenerated at a off-site RCRA-approved facility; and
0 Groundwater reaediation utilizing specified puapage rates of the
aunicipal supply veils In order to expedite reaoval of the groundwater
contaainant pluaes effecting Cheee wells.
The costs of the selected reaedy are estimated to be
Capital coses - $252,000
Operation eose* $222,000
An eighteen aoaeti operating period was assuaed and the eoeta were not
discounted.
Based upon our reviev of the public consent Feasibility Study reeelvod on
August 14, 1989, end the draft Record of Decision received on
Sepeeaber 8, 1989, our Agency concurs with the selection of this reaedy.
Se understand thet your staff end contractors, or the potentially responsible
parties will develop the aajor design eleaents of the soil vapor extraction
systeas, the off*gas treataent systea and the groundwater reaediation syttea
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ฃr ;33_:3 'jaST to: 5535^=5
ar. Vp.ldus Adar=' 29, :=ซ =;-i3ar =.3g
In eloae consultation with oy staff during the predesign and design p'r.asr: of
the project. Ve alio ,understand that if the potentially responsible parties
do not agree to fund the remedy, the State of Wisconsin will contribute 10* of
the reaedial action costs, In addition to cost sharing on the remedy we
acknowledge our responsibility for operation and naintenance of this systea
once the reaedy ia constructed.
As always, thank you for your support and cooperation in addressing the
contamination problea at this ait*. If you have any questions regarding this
natter, please contact Kr. Paul Didier, Director of tha Bureau of Solid &
Hazardous Vases Management'at(608) 266-1327.
" /
COB:Sป:ab33
d:\8910\aw9wsclt.sxb
cc: Lyman Vtble AD/5
Paul Didier SV/3
Hark Giesfeldt SV/3
Gary Kulibert HCD
Ran* Sanford FN/1
Nora Niedergang - EPA Region V
Margaret Cuerriero EPA Region V
Sincerely,
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Compendium Of Examples
from
FY'89 Records of Decision
1. Declaration
2. Site Description, Site History, Community Relations
3. Scope and Role of Operable Unit
4. Summary of Site Characteristics
5. Summary of Site Risks
6. Description of Alternatives
7. Comparative Analysis
8. Selected Remedy
9. Statutory Determinations
10. Responsiveness Summary
11. State Letter of Concurrence
Office of Emergency and Remedial Response
Office of Waste Programs Enforcement
May 1990
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INTRODUCTION
Sections 113 and 121 of CERCLA require that the Agency issue a final remedial action
plan, known as the Record of Decision (ROD). It may include the basis and purpose for the
selected remedy and certain public notification and involvement activities which must occur
to provide opportunity for the public discussion of the information.
The ROD documents the remedial action plan for a site or operable unit. It is prepared
by the lead agency in consultation with the support agency(ies). It has three purposes:
legally certifies that the remedy selection process was carried out in
accordance with the requirements of CERCLA and, to the extent practicable, the
NCP
outlines the engineering components and remediation goals of the selected
remedy
provides the public with a consolidated source of information about the site ,
the cleanup alternatives considered and the rationale for the one selected.
The ROD has three major components: the Declaration, the Decision Summary and the
Responsiveness Summary. Good examples of each section will be presented in this portion of
the handbook. They can serve as illustrative models for remedial Project Managers
responsible for preparing RODs in FY90.
The primary criteria used to compile these examples were:
1) Whether the sections followed the format and contained the appropriate
contents suggested by the "Guidance in Preparing Superfund Decision
Documents (ROD Guidance)" OSWER Directive 9355.0.
2) Whether the sections were clearly written and effectively presented.
3) Whether the sections appropriately reflect current Superfund program policy.
This compendium of examples reflects the fact that there is often more than one way to
present similar information, and the level of detail may appropriately vary from ROD to ROD.
However, some approaches are more effective than others and contain essential information
which should always be included in the ROD.
There were many good examples available for some sections of the ROD which
necessitated selecting a subset that would most effectively convey key concepts. For other
sections of the ROD, ideal examples were not available. It is important to read the comments
that introduce each set of examples to understand what each example is intended to
demonstrate.
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1. DECLARATION
The Declaration Is a formal statement signed by the Regional Administrator
that identifies the selected remedy and indicates that the selection was carried out in
accordance with the statutory and regulatory requirements of the Superfund program.
EXAMPLE: CROSS BROTHERS PAIL, IL
This sample Declaration follows the guidance exactly by using the standard
language for each section. Under the statement of Basis and Purpose, the Declaration
includes the appropriate references to CERCLA as amended by SARA, and the NCP
which is to be met "to the extent practicable".
Also, the administrative record is referenced as the basis of the decision but the
index is not attached. (It is no longer a requirement for the administrative record index
to be attached to the ROD.)
The Assessment of the Site section contains the necessary standard language
reflecting that the site may pose an endangerment. This standard language is
important to include because it provides the necessary basis for Section 106
enforcement actions. Some RODs used alternative language which may or may not
accomplish the same legal purpose. Other RODs did not contain this section at all.
The selected remedy is effectively presented in a bullet fashion, explaining all
major treatment and containment components as well as institutional controls.
The Statutory Determination section contains the appropriate language that
indicates that the remedy will satisfy the statutory preference for treatment of a
principal treatment and that the five year review will be conducted because material
will remain on site above the health-based levels.
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CROSS BROTHERS PAIL, ZL
DECLARATION FOR THE RECORD OP DECISION
SITE HAKE AND LOCATION
Cross Brothers Pail Recycling
Pembroke Township, Illinois
STATEMENT OP BASIS AND PURPOSE
This decision document represents the selected remedial action
for the Cross Brothers Pail Recycling site developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative
record for the Cross Brothers Pail Recycling site.
The United States Environmental Protection Agency and the
State of Illinois agree on the selected remedy.
ASSESSMENT OP THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present a current
or potential threat to public health, welfare, or the
environment.
DESCRIPTION OP REMEDY
This final remedy addresses remediation of groundwater and soil
contamination by eliminating or reducing the risks posed by the
site, through treatment and engineering and institutional
controls.
The major components of the selected remedy include:
ฐ Resampling of the localized PCB soil area to identify
thซ existence of a PCB source.
ฐ If identified, remove the localized PCB-contaminated
soil area and incinerate the soils at a TSCA approved
incinerator.
ฐ Install and maintain a groundwater collection system
capable of capturing the groundwater contaminant plume.
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o
Install and maintain an on-site groundwater treatment
facility to remove contaminants from the collected
groundwater.
ฐ Install and maintain a soil flushing system for the
3.5 acres of contaminated soil within the disposal
area.
ฐ Install and maintain a 6 inch vegetative cover over
that portion of the disposal area not subject to the
soil flushing operation.
ฐ Monitor the groundwater collection/treatment system and
the groundwater contaminant plume during groundwater
remediation activities.
ฐ Install and maintain a 6 inch vegetative cover over
the 3.5 acre area subject to soil flushing upon
terminating the soil flushing operation.
ฐ Install and maintain a fence around the site during
remedial activities.
o Initiate a deed notification identifying U.S. EPA and
IEPA concerns regarding the conductance of intrusive
activities at the site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element. As this remedy will initially result in
hazardous substances remaining on-site above health-based levels,
a review will be conducted within five years after commencement
of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Regional Administrator
U.S. EPA - Region V
Date
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2. SITE DESCRIPTION, SITE HISTORY AND SUMMARY OF
ENFORCEMENT AND COMMUNITY RELATIONS
These sections of the ROD provide essential background information on the site
so the physical, enforcement and public participation context of the site can be properly
understood.
EXAMPLE: PREFERRED PLATING, NY
The sample illustrates how the necessary information can be provided clearly
and succinctly.
In the Site Location and Description sections note the reference to the fact that
no endangered species or critical habitats have been identified and the proximity of
wetlands to the site. These items should be included in all RODs to reflect that
appropriate assessments have been made.
The Site History and Enforcement Activities section effectively summarizes the
activities that caused the problem, the site investigations conducted to date, and
pertinent enforcement information.
The Community Relations Activities section provides a brief overview of key
public participation activities undertaken to fulfill the requirements of CERCLA
Section 113 and 117.
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PREFERRED PLAITNG, NY
.SIT? LOCATION AND DESCRIPTION
The Preferred Plating Corporation Site (the "Site") is located at 32
Allen Boulevard in Farmingdale, Town of Babylon, Suffolk County, New
York. This 0.5-scre Site is situated in a light industrial area
approximately 1 mile west of the Nassau-Suffolk County border. Route
110 passes just west of the Site (see Figure 1).
The land to the east and west of the Site is occupied by commercial
or light industrial properties. Immediately north of the Site is a
large wooded area followed by various industrial facilities further
north of that. To the south are a residential community and a U.S.
Army facility.
The 1980 census records a population of greater than 10,000 within a
3 mile radius of the Site. The population density in the area is
estimated to be 3,000 to 6,000 persons per square mile. All homes
and businesses, in the area surrounding the Site, are supplied by two
public water companies. Ground water is the source of water supplies
for the entire population of both Nassau and Suffolk Counties. All
public water supply wells in the Site area draw water from the deeper
aquifer, the Magothy Aquifer. The nearest public water supply well
fields are located approximately 1 mile east and 1 mile south of the
Site.
The nearest body of surface water is an unnamed intermittent
tributary of Massapequa Creek which is approximately 6000 feet west
of the Site. There is no designated New York State Significant
Habitat, agricultural land, nor historic, or landmark site directly or
potentially affected. There are no endangered species or critical
habitats within close proximity of the Site. The Site is located
more than 2 miles from a 5-acre coastal wetland and more than 1 mile
from a 5-acre fresh-water wetland.
The Site is situated in the south-central glacial outvash plain of
Long Island, which constitutes the Upper Glacial Aquifer, estimated
to be 90 feet in thickness under the Site. The naturally occurring
surface soil is a sandy loam which promotes- rapid infiltration to the
ground water. On the Site proper and throughout much of the region,
soils have been classified as urban. This is primarily due to the
development and pavement which promote greater run-off of
precipitation. The Upper Glacial Aquifer overlies the Magothy
Aquifer and the two may act as distinct aquifers, or as one,
depending upon the degree of hydraulic connection between the two.
In the Site area, it is believed that the two are not hydraulically
connected.
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-2-
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Preferred Plating Corporation (PPC) conducted operations
beginning in September 1951 through June 1976. The primary
activities at the site were to chemically treat metal parts to
increase their corrosion resistance and provide a cohesive base for
painting. The plating processes included degreasing, cleaning, and
surface finishing of the metal parts. These processes involved the
use of various chemicals which resulted in the generation, storage,
and disposal of hazardous waste. Untreated waste water was
discharged to four concrete leaching pits directly behind the
original building.
Ground water contaminated with heavy metals was detected in the Site
area by the Suffolk County Department of Health Services (SCDHS) as
early as June 1953. SCDHS indicated that the leaching pits on the
Site were severely cracked and leaking. Samples taken from the pits
showed the major contaminants to be heavy metals. From 1953 to 1976,
SCDHS instituted numerous legal actions against PPC in an effort to
stop illegal dumping of wastes and to install or upgrade the on-site
treatment facility. PPC prepared an engineering report in May 1974
in order to apply for a State Pollutant Discharge Elimination System
(SPDES) permit which was issued in June 1975. PPC chemically treated
the waste water in the pits and, allegedly, then had the treated
waste water removed. Whether the treated ground water was ever
removed has not been confirmed by EPA. The facility was never in
full compliance with the terms and conditions outlined in the permit.
In 1976, PPC declared bankruptcy. Since then, several firms have
occupied the Site, none conducting similar operations to PPC. In
1982, the original building was extended, by 200 feet, thereby burying
t.ie concrete leaching pits. Nearly the entire Site is covered either
by the one existing building or paved driveways and parking areas.
In September 1984, Woodward-Clyde Consultants, Inc. performed a Phase
I-Preliminary Investigation of the Preferred Plating Site for NYSDEC
for the purpose of computing a Hazard Ranking System (HRS) score
needed to evaluat*.whether to place.the Site on the National
Priorities List (MPL). In the Phase I report, an HRS score of 3 3.76
was documented, thereby enabling the Site to be included on the NPL.
On October 15, 1984, (49 FR 1984), the Site was proposed for the NPL
and was added with a ranking of 500 on June 10, 1986, (51 FR 21054).
At EPA's direction, a remedial investigation (Rl) was initiated in
1987. The RI consisted of a field sampling and analysis program
followed by validation and evaluation of the data collected. The
field work was initiated in June 1988 and completed in February 1989.
The work was conducted by EPA's REM III contractor, Ebasco Services,
Inc. The soil sampling program*involved- the determination of lateral
and vertical extents of contamination by obtaining samples from six
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-3-
on-site monitoring wells, two off-site monitoring well locations, six
surface soil locations, and seven angle borings which extended
underneath the on-site building overlying the former leaching pits.
The groundwater sampling program involved the installation of nine
on-site and two off-site monitoring wells. In addition, two storm
water run-off samples and two sediment samples were collected from
on-site storm sewers.
The potentially responsible parties (PRP's) were notified in writing
on February 12, 1988 via a special notice letter and given the
opportunity to conduct the RI/FS under EPA supervision. However,
none elected to undertake these activities.
In July 1989, Ebasco's remedial investigation (RI) and feasibility
study (FS) reports were released to the public along with the
Proposed Remedial Action Plan (PRAP) developed by EPA. A 28-day
public comment period was provided, ending on August 18, 1989.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Preferred Plating Site was
finalized in March 1988. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination of
irtinent information. Subsequently, a fact sheet outlining the RI
sampling program was distributed in June 1988. The RI/FS and the
Proposed Plan were released to the public in July 1989. All of these
documents were made available in both the administrative record and
two information repositories, maintained at the Babylon Town Hall and
the West Babylon Library. A public comment period was held from July
19, 1989 to August 18, 1989., In addition, a public meeting was hei-i
on August 3, 1989 to present the results of the RI/FS and the
preferred alternative as presented in the Proposed Plan for the Site.
All comments which were rec<^ved by EPA prior to the end of the
public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary which is
attached, as Appendix V, to this Record of Decision.
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3. SCOPE AND ROLE OF OPERABLE UNIT
This section should describe the role of the remedial action within the overall
site cleanup strategy and summarize the scope of the problems to be addressed b y the
remedial action selected. It should identify whether the action will address s any of the
principal threats posed by the site.
EXAMPLE: CHEMICAL INSECTICIDE. NJ
This sample thoroughly describes past response actions, how they provided
protection and the remaining threat and pathways. It also explains how this interim
action ROD will provide additional controls, why EPA chose to address the site in
operable units, and describes the principal threat addressed, (this provides the basis for
the statutory determination made later in the ROD as to whether the remedy satisfies
the preference for treatment of a principal threat.) Future response actions are briefly
described as to their scope, the media they will address, and how they will mesh with
this ROD. It also characterizes when a final remedy may be expected.
EXAMPLE: WAUSAU WATER SUPPLY, WI
This example illustrates how this section might work for a final action ROD and
also does a good job of explaining how the principal threats are being addressed.
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The CIC site, as characterized by the RI field investigations, is
extremely complex, due to the number and variety of contaminants
present, the concentrations of contaminants documented, and the
physical and geological characteristics of the site. The specific
combination of chemical contaainants at the CZC site (herbicidos,
pesticides and metals) will require performance of treatability
tests prior to identification of alternatives to reaedy the entire
site. Preparation of an FS report which addresses all aspects of
tho CIC site requires performance of the proposed treatability
tests and assessaent of the results. Such treatability tests are
in the planning otage.
EPA has already taken two Halted response actions related to the
surface water run-off problea at the site. The first action in
February of 1988 was to install a fence to prevent access to the
contaainated liquid* and sediaents in the drainage ditch east of
the CIC property. The second action in March of 1989 was to clean
up the overflow froa the drainage ditch to the Metroplex parking
lot and to iaprove the ditch to reduce the likelihood of future
overflows. The surface water run-off during this overflow incident
had a yellow color that is characteristic of standing water at the
southern end of the CZC property. This yellow color is attributed
to dinoseb, an herbicide which has been found in saaples of
standing water froa the southern end of the site end in water
saaples froa the drainage ditch and parking lot during ti^e overflow
incident. Dinooeb is known to produce e yellow color when
dissolved in water.
These liaited response actions have only partially addressed the
surface water run-off problem in that the eurface water run-off
would continue to migrate to downstream waterways (i.e. the unnamed
tributary, Mill Brook and the Raritan River), with potential for
harm to the environment and for huaan exposure.
In this ROD, EPA is selecting an interia remedial action to control
contaminated surface water run-off from the CIC site until the time
that the FS addreosing all aspects of the CIC site is finalised and
the resulting ROD is lapleaented. This action will be the first
operable unit (i.e., the first cleanup phase) of the reaediation
of the entire site. EPA has elected to address the surface water
run-off problea as the first operable unit because of the threat
posed by the surface water run-off (see Section 2, above) and
because oufficient information is available to select an
appropriate remedy for this problea. This action will focus on one
of the principal threats presented by the site, that of the
contaainated surface water run-off.
One or aore future RODS will address tho reaaining probleas
presented by the site, including the contaaination of soil and
groundwater. It should be noted that onee the contaainated toil
at the sito has been effectively reaediated, the surface water run-
off froa the site would no longer becoae contaainated by eontact
with the soil. As e result, the reaedy selected in this ROD would
no longer be needed after the contaainated soil is cleaned up.
Therefore, the reaedy selected in this ROD is considered to be an
interia reaedy which can be discontinued once a reaedy for the soil
contaaination has been lapleaented. SPA expects to be in a
position to select a reaedy for the soil contaaination after
treatability studies for the eontaaineted soils are conducted and
after the results of the studies have been analyzed and
Incorporated in a PS.
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VWJSMJ WAITER SUPPLY, WI
IV. SCOPE AND ROLE OF RESPONSE ACTION
The scop* of this response action is to address the remaining
concerns (principal threats) at the site. As discussed, a
previous operable unit action at the site addresses the
contaminant plume originating from the former landfill/Marathon
Electric source area which affects CW6.
During development of the final PS, it was determined that the
deep plume which originates from the former city landfill area
and migrates under the River to CW3 would best be addressed by
purging groundwater at the same location as the interim remedy
extraction system. Therefore, it was determined that an increase
in the minimum pumping rates called for in the extraction system
and modifications to the monitoring plan would provide the most
effective remediation for this contaminant plume. Zt was also
assumed that the City would continue to use CW3 as a supply well
and thus continue to remove contaminants from the most eastern
portion of the plume.
The selected alternative for the final phase of the Wausau
project, in conjunction with the operable unit, will address all
concerns at the site. Remaining concerns include three source
areas and the shallow east side groundwater contaminant plume
originating from the Wausau Chemical source area. The identified
source areas.include? former City landfill/Karathon Electric
property, Wausau Chemical property, and Wausau Energy property.
The final remedy for the sits is intended to address the entire
site with regards to the principal threats to human health and
the environment posed by the site as indicated in the risk
assessment for the site. The findings of the risk assessment are
included in the RX Report and are summarized in a later section
of this document.
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4. SUMMARY OF SITE CHARACTERISTICS
This section should highlight all known or suspected sources of contamination,
affected media and the characteristics of the contamination such as the mobility,
toxicity, the volumes and concentrations, and location at the site. Also, it should
identify potential routes of migration and potentially exposed populations.
EXAMPLE: BYRON BARREL AND DRUM, NY
The first example demonstrates how site characteristics can be summarized in a
narrative format. Although this summary does not explicitly delineate material
comprising principal versus low-level threats, it does a good job of identifying the
location of different contaminants and their associated concentrations and volumes.
This helps establish a clear basis for the types of remedial alternatives developed.
EXAMPLE: NORTHWEST TRANSFORMERS, WA
The second example provides a good model ft/' explaining the characteristics of
PCBs, the primary contaminant at this site, and the potential migration pathways.
EXAMPLE: WAUSAU WATER SUPPLY, WI
The third example illustrates how a table can provide an efficient vehicle for
conveying great amounts of information. This particular table includes contaminated
media, contaminants found, concentrations (high, low, geometric mean), and the
number of samples.
The first example states the concentrations, volumes, depths of contaminants
in each media, potential migration pathways, and some characteristics of the
contaminants. The contaminants of concern and sampling locations are also laid out
well in two tables.
This section should also clearly state the characteristics (whether they are toxic,
mobile, carcinogens, etc.), potential populations affected, and exposure pathways. Not
all the RODs included had volumes, pathways, and areas affected.
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BKKCN BARREL AND CRM, NY
BUMMARY OF SITE CHARACTERISTICS
Approximately 200 55-gallon steel barrels that were filled with
hazardous waste were abandoned at the Byron Barrel and Drum site
from 1978 to 1980, when the site was used as a salvage yard for
heavy construction equipment. Leakage and spillage from these
drums appears to have been the primary source of contamination of
the site. The drums and their contents were removed from the site
by EPA in 1984. In addition, approximately 40 cubic yards of
visibly-contaminated surface soil and debris were removed from the
site during the same period.
Analyses of soil, groundwater, sediment, and surface water from
the site and adjacent areas indicate that the environmental
contamination at the Byron Barrel and Drum site consists primarily
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6
of subsurface soil and groundwater contamination. Based on the
absence of substantial soil contamination, it appears that the EPA
removal action was effective in reducing contaminant releases.
Chlorinated aliphatic hydrocarbons such as 1,1,1-trichloroethane,
1,1-dichloroethane, trichloroethene, and 1,1-dichloroethene are the
primary contaminants. Various monocyclic aromatics such as toluene
and xylenes were also detected, although groundwater contamination
with these substances is minimal when compared to the contamination
with chlorinated species.
SURFACE SOIL
A total of 25 surface soil samples were collected during the field
investigation at the locations shown in Figure 3. The locations
were selected based on the results of the soil-gas investigation
and historical information. Of the 25 samples, 21 were collected
on-site, and 4 were collected off-site to provide background
information. Surface soil samples were collected to provide the
necessary data to assess the risks posed by dermal contact, as well
as to provide information on potential contamination migration via
surface-water erosion of soil.
Surface soils at the Byron Barrel and Drum site contain only low
levels of volatile organics (less than 50 parts per billion (ppb))'f
phthalate esters (less than 600 ppb), polynuclear aromatic
hydrocarbons (less than 300 ppb), and benzoic acid (less than
500 ppb). By contrast, much higher concentrations of various
pesticides, such as 4,4'-DDT, 4,4'-DDE, endrin, and dieldrin, were
encountered. The highest concentrations of the pesticides were
detected in surface soil samples which were collected from the
adjacent farmland. On-site samples containing pesticides were
obtained in proximity to the agricultural land and are believed to
be present as a result of atmospheric transport of pesticides
during their application to crops. Figure 3 summarizes the
volatile organics detected in surface soil samples.
Although chromium and lead were detected in site surface soils
above background, contamination with these substances is not
pronounced. Figure 4 presents the analytical results for surface
soil samples containing chromium and lead above background levels.
As is evident from the Figure 4, chromium and lead contamination
is greatest in Source Area 3.
Based on the results of a surface soil sampling program in Source
Area 3, it is estimated that there are 1,100 cubic yards of
contaminated soil in this area.
SUBSURFACE SOIL
As shown in Figure 5, test pits and trenches were dug at 46
locations, from which a total of 130 subsurface samples were
-------
7
collected for analysis. No drums were detected in any of these
test pits.
As shown in Figure 6, volatile organics were detected in subsurface
soil samples at concentrations ranging from 5 ppb to 2,669 ppb.
The most pronounced contaminants based on the mobile laboratory
results are toluene, 1,1,1-trichloroethane, and trichloroethane.
Concentrations of these ranged as high as 865 ppb, 551 ppb, and
2,669 ppb, respectively.
Twenty subsurface soil samples were also obtained. As can be seen
by the analytical results summarized in Table 1, volatile organics
are the primary contaminants detected, and toluene and
trichloroethene were detected at relatively high concentrations
(2,700 ppb and 2,800 ppb, respectively). In addition, several
other volatile organics, notably xylenes and tetrachloroethene
(PCE), were detected at high concentrations. Xylene concentra-
tions ranged as high as 1,700 ppb, while PCE concentrations ranged
as high as 4,400 ppb. All of these samples were collected from the
southwestern portion of Source Area 1. In addition, phthalate
esters were detected in several samples at concentrations ranging
as high as 2,000 ppb (di-n-butylphthalate) . Arochlor 1254 was
detected in one test pit sample at a depth of 4 feet. PCBs werฃ
detected in drum samples collected by the NYSDEC prior to the
removal action. The detection of PCB Arochlor 12 54 at a
concentration of 690 milligrams per kilogram (mg/kg) indicates that
some release of PCBs occurred at the site. However, only one
sample from Source Area 1 contained a PCB compound, and the
available data indicate that PCB contamination is not extensive.
PCBs were not identified in any of the other matrices sampled at
the site (i.e., surface soil, sediment, groundwater, or surface
water).
Based upon the sampling results in Source Area 1, it is estimated
that there are 1,100 cubic yards of contaminated soil in this area.
The analytical results for subsurface soil samples obtained in
Source Area 2 are depicted in Figure 7. Subsurface soil samples
contained several chlorinated aliphatic hydrocarbons, including
l,l,l-trichloroethane,1,1,2-trichloroethane, trichloroethene, 1,1-
di.chloroethene, and methylene chloride. TCA concentrations ranged
as high as 410 ppb in these samples.
Based on the results of the subsurface soil sampling and analysis
program in Source Area 2, it is estimated that approximately 3,000
cubic yards of contaminated unsaturated zone soil exists in this
area.
Figure 8 depicts detections of chromium and lead above background
soil concentrations. From this figure, it is apparent that
subsurface contamination with these contaminants is not extensive
in any of the source areas.
-------
8
GROUNDWATER
The primary contaminant transport mechanism at the Byron Barrel
and Drum site is associated with groundwater advection of dis-
solved contaminants. Two contaminant plumes originating in the
vicinity of Source Areas 1 and 2 were noted to be migrating in the
downgradient direction to the northwest. No evidence of
contaminant migration toward residential wells to the southwest
was observed during the RI. Based on the analytical results for
monitoring well samples, it is apparent that these contaminant
plumes are confined to the immediate proximity of the source areas.
It is estimated that the contaminant plumes have migrated no
further than 400 and 300 feet from the Source Areas 1 and 2,
respectively. This phenomenon is a manifestation of the shallow
hydraulic gradient and the relatively recent time frame of disposal
activities (as late as 1982).
Four distinct rounds of groundwater sampling were conducted at the
Byron Barrel and Drum site. The first two rounds were conducted
during the course of the monitoring well installation
program. The second complete sampling round included analysis for
volatile organics. The analytical results for groundwater sampling
rounds 3 and 4 are summarized in Tables 2 and 3, respectively.
As shown in Tables 2 and 3, a number of volatile organic chemicals
were detected in site groundwater samples during the third and
fourth sampling rounds. Volatile organics detected frequently
and/or at high concentrations include 1,1,1-trichloroethane, 1,1-
dichloroethane, tetrachloroethene, trichloroethene, 1,1-
dichloroethene, and 1,2-dichloroethene. Concentrations of these
compounds ranged as high as 4,400 ppb, 290 ppb, 82 ppb, 3,300 ppb,
41 ppb, and 110 ppb, respectively. Of these compounds, all but
1,2-dichloroethene are considered major site contaminants. Only
one sample was found to contain 1,2-dichloroethene at a
concentration above 1 ppb, which is the sample mentioned above.
Methylene chloride was detected in one of three samples at a
concentration of 2.8 ppb.
Figures 9 and 10 summarize the results for the predominant site
groundwater contaminants for the third and fourth sampling rounds,
respectively.
In addition to the organic contaminants detected in site
groundwater samples, a number of inorganic constituents were
detected above background levels. Table 4 provides a summary of
the inorganic sample results for the upgradient monitoring well
(MW-4A) versus the site monitoring well samples. Chemicals
detected at concentrations significantly above background include
aluminum, arsenic, barium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, nickel, potassium, sodium,
vanadium, and zinc. It should be noted that groundwater samples
-------
9
were not filtered prior to acidification. Hence, these results are
indicative of total inorganics in the water samples, including
those present in suspended solids. -The average concentrations
presented in Table 4 indicate that there is little difference
between the overall site concentrations and background levels,
with the exception of sodium, mercury, and zinc, the average
background concentrations exceed the site average values. Figure
11 displays the results for chromium and lead detected above
background (upgradient) levels. Based on these results, it appears
that lead contamination exists in all source areas.
The analytical results for groundwater samples collected during
the supplemental activities are summarized in Figure 12.
Groundwater contamination consists of chlorinated aliphatics and
ketones. Organic contamination with 1,1,1-trichloroethane and MEK
is most pronounced. Concentrations of TCA ranged as high as 2,500
ppb while concentrations of MEK ranged as high as 3,000 ppb.
The estimated extent of the contaminant plumes originating from
Source Areas 1 and 2 is depicted in Figure 13. There is not a
contaminant plume originating from Source Area 3.
SURFACE WATER AND SEDIMENT
Surface water and sediment samples obtained from a drainage ditch
adjacent to the site property contained relatively low levels of
organic chemicals. There is no evidence of any downstream impact
on Oak Orchard Creek, the primary receiving surface water body.
Several sediment samples from another drainage ditch that runs east
to west, just north of the site, contained relatively high levels
of toluene, acetone, and MEK. However, based upon surface drainage
patterns and the absence of potential discharge of contaminated
groundwater to this drainage channel, it is not believed that this
contamination is site related.
-------
NCRMffiST TSANSTCWMEKS, WA
Site Characteristics
Contaminant Characteristics
The contaminant of concern at the NHT site is PCS, primarily Arochlor
1260. It 1s unlikely that free-flowing PCB-bearing fluids (I.e.,
transformer dielectrics) are still present at thฎ site. PCS is read-iy
adsorbed onto soil particles and does not easily leach from soil.
Adsorption of PCB by soil is related to the organic content of a
particular soil type, and PCB recovered from soil is found to concentrate
in the organic fraction of the soil media. The low water solubility ana
low volatility of PCB also suggest that It Is partitioned most heavily
into the organic fraction of soil. The rate of PCB movement In saturated
soil has been found to be between one-tenth and one-hundredth the r&te of
groundwater movement.
Affected Matrices Characteristics
For site management, stabilization, and cleanup purposes, the NHT site
can be divided Into specific affected matrices.
The following discussion summarizes the characteristics and volumes of
each matrix that are relevant to the identification, screening, anc
selection of remedial technologies and strategies.
S-11
The contaminant of concern in the soil is PCB. The
tri-tetrachlorobenzenes were not included in analyses because these
more volatile compounos were not expected to oe persistent m
surface soils, especially considering the length of time between the
EPA IRM and the RI sampling effort. The distribution of PCB
contamination in tne surface soil Is shown in Figure 2 (p.7). PCB
12
-------
contamination has seen shown to exist at levels e*cee:i^g rr.e
April 1985 IRM cleanup level of 10 com (mg/kg) in two areas. :*e
area south of the oam and 2) the former seepage di t a^ea
(Figure 2). 8CB concentrations between 1 an<3 10 ppm (mg/k;) e*ij:
in surface soil tnrougnout trie site.
During the July 1987 RI. shallow subsurface samples were taken from
2.5 and 5.0 feet beiow ground surface at selected locations. The
pr1ncioaI contaminant of c:ncern in these samoles was ?CB. The
tri-tetrachlorooenzenes were not detected in the samples Results
indicated that PCS contamination generally decreased with septn and
that the PCB levels were at or oelow 1 ppm (mg/kg) below the deon
of five feet. The PC3 analytical aata show concentrations at or
above 10 ppm (mg/kg) m the area just south of tne barn. Analytical
data indicate that below 2.5 feet some PCB concentrations are
between 1 ppm (mg/kg) and 5 ppm (mg/kg). PCB concentrations in tne
suosurface soil in tne seeoage/septic tank area range between l to
10 apm (mg/kg) at a depth of 19 feet.
The volumes of soil within the ranges of PCB contamination reported
n the FS are shown in Table 1.
The surface area of the site 1s approximately 70,000 square feet
(7,778 square yaros) or approximately 1.6 acres.
Groundwater
There are two current primary PCB sources relative to groundwater
contamination beneath the NWT site and vicinity. First, historical
dumping of potentially high but undocumented concentrations of PCB
1n the seepage pit may have resulted 1n significant PCB migration
Into groundwater In the past. This high level contamination could
act as a future source of groundwater contamination by PCB. The
current low level PCB soil contamination can be considered a second
source. The soil PCB contamination could act as a constant low
level source of groundwater contamination until the site is
remediated.
8ased on the results of this RI and previous investigations, PCB
contamination In groundwater has not been adequately characterized
to assess thซ lifetime Incremental cancer risk through ingestion of
contaminated water, nor have the groundwater flow patterns been
fully determined.
On-Slte Structure (Barn)
During the IRM. a significant amount of washing, rinsing, and
sandblasting of the surface of wooden structural members inside tie
barn was conducted, however, there is uncertainty as to the
effectiveness of tne decontamination of the deeper wood matrix of
the barn. Core samples of the wood must be analyzed for PCB before
all remediation alternatives, including the no action alternative,
can be evaluated for tne barn.
13
-------
TABLE 1 NORTHWEST TRANSFORMER: ESTIMATED VOLUMES
ASSOCIATED WITH SURFACE SOIL CLEANUP LEVELS
RESIDUAL PCB
CONCENTRATION
(PPM)
EXCAVATION
DEPTH IN
10 PPM AREA
VOLUME OF
SOIL FROM
10 PPM AREA
(su.rd-Hl)
VOLUME OF
SOIL FROM
AREA BETWEEN
10 ANO 1 PPM
(cu.vd.Hn
TOTAL
VOLUME OF
SOIL
(CU ฆ Yti )
40
32
24
16
10
8
5
1
0.0
o.s
1.0
1.5
1.9
2.0
2.2
2.5
0
313
625
938
1,172
1,250
1,367
1,563
0
0
0
0
0
171
468
964
0
313
625
938
1,172
1,421
1,836
2,526
(1) See Figure 2 for Isoconcentration contours.
(2) Assume that concentration decreases from surface (avg 40 ppm) to 2.5
ft. depth (1 ppm) in a linear manner.
14
-------
Migration Pathways
The transport of tne cnionnated contaminants in tne environment >s
control lea oy their jnysica) properties. Three potential patnซays
of migration exist, grcunawater."a 1r , and surface ซater.
The ccrertial for ai^torie migration of PC3 from the site 'S
min:ma; The contaminants, especially tne more chlorinated isome-s.
are not highly volatile. Also, the high equilibrium binding
constant for ?C3 in so') 'ndlcates that contaminants bind tigntly to
the soils. Heavy vegetation on tne site virtually eliminates any
migration of contaminants on particulates generated from wind
erosion. If surface vegetation is removed, the resulting wind
dispersion of easting contaminated surface soils is not expected to
result in off-site PCB contamination greater than one mg/*g based on
results of background soi's and on-site surface soils obtained in
July 1987.
Likewise, the potential for transport of PCB frooi the site via
surface *ater is minimal. Due to the very high permeability of the
soils at the site and relatively flat topography, surface water
runoff from tne site 1s minimal.
It is for these reasons that the major potential pathway of
contaminant migration identified for this site 1s the regional
groundwater system. PCB is readily absorbed from water by solid
particles and only slowly leaches from soils. PCB has poor mobility
through saturated soil. Downward movement of contaminants would se
effected very slowly by water infiltration from precipitation
coupled with sorption/desorptlon mtchanlsms based on contaminant
solubility. Rapid downward movement and horizontal migration would
only be suspected if large quantities of oil-soluble solvents were
allowed to percolate through the soil.
The highest potential for the downward migration appears to be in
the seepage pit area, where the excavated and caved area tends to
funnel precipitation. Rtv1eป of previous Investigations indicates
that unknown amounts of liquids were disposed of in this area of the
site by dumping Into the seepage pit. The construction of this pit
was such that liquids would seep out to the surrounding formations.
Sources of the liquids are not Known but are suspected to include
son* portions of tht liquids generated on site. Unless large
quantities of solvents were dumped into the excavated area,
migration of PCB would not be expected to be significant.
-------
VWBAU WATER SUPPLY, WI
ium
SURFACE SOILS
SURFACE WATER
Sos Creek
Ccnc;r*.
'at"or
Sam:'?:
Chemical
Geometr:c
.
M' n .hu.ti
"aximum
Mean
Totil * -
Metal/C1*
uc/'.
uc/L
uc/L
3
I r on
95?
5300
2110
Manganese
1610
2920
2110
Volst"1e
Lie / Vc
uq/Vq
uqAq
S
Methylene chlonce
t *
ISO
110
1,1,1-Tncn loroetflane
Tetrachloroetnene
Xylenes (total)
Sem vol at i 1 e
Phenol
4-Hethy1pheno1
Benzoic acid
Naphthalene
2-Hethylnaphthalene
Acenapnthy1ene
Acenaohthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Flouranthene
Pyrene
Butylbenzylphthalite
Benzo(a)a'ntnracene
81i(2-ethy Ihexy 1)pnthai ate
Chrysene
Di-n-octylphthalate
Benzo(b)fluoranthene
Benzouj f luoranthene
8enzo(a)pyrene
Indeno(l,2.3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
Pesticide/PCB
Not Analyzed
Hetal/CN
Not Analyzed
Volati1e
1,2 OKhlorwthene (total)
Trichloroetnene
Tetrachloroethene
ic/kc
ucAa
uqAc
89
93
90
--
200
..
--
150
37
720
192
,32
770
264
2
110
22
51
69
59
38
180
82
100
120
109
200
2500
651
32
480
155
200
6600
1300
150
2900
910
59
390
150
HO
2400
749
150
1600
489
390
3200
861
380
250
5400
1380
1600
100
2700
604
210
1200
614
390
22C
1400
655
uq/L uo/l
1 1
1 110
1 3
uq/L
1
41
2
12
Sewivolatile
Not analyzed
Pesticide/PCB
Not Analyzed
Hctal/CH
Not Analyzed
-------
Table 2
(Continued)
ftc' iffl Ci^eni cal
9en:o(blfluorantnene
Ber.zoi'kjflueranthene
8en:o(a)pvrene
Indeno(1.2.3-cd)pyrene
Dibenz(a,h)anthracene
Ben:o(g,h,i)perylene
Pes 11ct de/aC3
Not Analyzed
Metal/CN
Copper
LANDFILL REFUSE
Vc . at i1e
Methylene chloride
Acetone
1,2-0ichloroethene (total)
Trichloroethene
Toluene
Ethyl benzene
Xylenes (total)
Seimvolat'i 1e
Phenol
2-Chloroohenol
1,2-Dich lorobenzer.e
2-Hethy1 phenol
4-Methylpnenol
Isophorone
1.2,4-Tnchlorobenzene
Naphthalene
4-Chloro-3-methyl phenol
2-Methylnaphthaiene
2-Chloronaohthalene
Acenaphthy lene
Acenaphthene
Oibenzcfuran
Fluorene
Pentachlorophenol .
Phenanthrene
Anthracene
Fluoranthene
tyrene
Butylbenzylphthalate
8enzo(a)antnracene
Bis(2-ethylhexy1)phthalate
Chrysene
Benzo(b)fluoranthene
Sen zo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2.3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h, i)perylene
Pesticide/PCB
Arochlor 1260
C^enica' Concft
.-at :r
Gesme*. - ฆ c
Minimum
Maximum
Mปป~
110
680
22C
100
760
210
120
750
250
130
680
22C
74
120
800
270
mq/kq
mc/kj
mq/kg
--
107
--
uq/kq
uq/ka
uq/kq
, 9
1900
70
71
160
100
21
220
67
36
160000
680
3
750
60
2
4
2
4
24
13
uq/kq
uq/kq
uq/kq
..
2200
2200
--
210
75
830
-
130
--
1200
49
1300
150
--
2300
--
65
890
150
170
130
45
730
180
19
330
63
82
500
186
820
320C0
2900
170
15000
1100
19
2200
250
60
45000
1600
63
49000
1700
130
2300
500
420
24000
1400
110
54000
860
54
25000
970
410
25000
1700
430
25000
1400
480
25000
1200
640
31000
940
280
1200
450
560
14000
1600
uq/kq
uc/kq
uq/kq
850
2300
1400
-------
5. SUMMARY OF SITE RISKS
The baseline risk assessment should be summarized in this section. It should
include both human health risks and environmental risks. This provides the rationale
for the lead agency's either undertaking a response action or taking no action
EXAMPLE: NORTHSIDE LANDFILL, WA
The example of the human health Site Risk section includes well defined
sections which discuss contaminants of concern; exposure assessment including
exposure points and calculation of dose; toxicity assessment with separate discussions
of carcinogenic and noncarcinogenic criteria; characterization of carcinogenic and
noncarcinogenic risks; uncertainties and conclusions. The narrative is supported by
several tables on exposures, doses and cancer risk, and hazard index. The introduction
to each section states the parameters to be discussed such as population at risk, and
exposures. Terms such as Reference Dose, Chronic Daily Intake, No Observed Adverse
Effect Levels, and classes of carcinogens are defined. The basic methodology used to
arrive at the basic calculations are briefly explained. There is a great deal of
information provided but it is presented logically, systematically, and is fairly
readable. The result is a basic understanding of the actual and potential exposures,
populations, pathways and risk.
EXAMPLE: FAA TECHNICAL CENTER, NJ
The summary of Site Risk section in this ROD provides good tables that
concisely present appropriate risk information. Table 1 highlights contaminants of
concern, maximum and average concentrations and their frequency of detection in the
environmental media. Table 2 provides a good summary of the toxicity information
for these contaminants. The exposure assumptions are reported in an easy-to-read
manner in Table 3. Tables 4 and 5 should be abbreviated to report only those chemicals
with risks that are above or near the 10"ฎ level or with hazard indices near or above
one. We also recommend that the noncarcinogenic chemicals of concern not be
included on the table of carcinogenic risks.
EXAMPLE: MARATHON BATTERY. NY
The summary of Site Risks should discuss environmental risks, summarizing
the affects of contaminants on critical habitats and any endangered species.
This ROD also provides a discussion of bioassays conducted to determine
concentrations of contaminants which may affect aquatic organisms. It describes
sampling, levels of contaminants which would be protective of the environment, other
factors which will impact achievement of those levels. The State believes that there
may be an adverse ecological impact. Endangered species are identified and a
conclusion drawn about potential impact of the contamination on that species.
-------
NCREBSHE LANDFILL, WA
SL'MMaRV of site risks
3ersons who may use contaminated grcuncwater Cr~cm tie area of the
Nortnsiae Landfill as tneir only source of water *erป :aentified as cne
oooulation at ris< of adverse nealtn effects. The primary routes of exposure
to contaminants in groundwater are ingestion, innalation of volatile
constituents, and dermal absorption. Tetracnloroethylene, (PERC),
trichloroethylene (TCE), and 1,1,1-trichloroethane (TCA) detected In
groundwater from offsite wells are the contaminants of concern. The maximum
cancer risk from exposure to groundwater from the most contaminated private
well is one in ten thousand (1 x 10~4). Non-carcinogenic health effects are
not expected from exposure to PERC and TCA at the present detected level of
contamination in onsite and offsite wells.
Identification of Contaminants of Concern
The Remedial Investigation/Feasibility Study (RI/FS) identified
groundwater as the exposure medium of greatest concern. Exposure via other
media including soil and surface water was not considered to be significant.
Thus, groundwater is the only exposure medium considered here.
The RI/FS Identified PERC, TCE, and TCA as the contaminants of concern.
These were the only organic comoounds regularly detected in the offsite
wells. Groundwater monitoring data from Appendix 0 of the Supplemental RI
Addendum were used to calculate exposure point concentrations for the exposure
scenarios described below.
Three hypothetical exposure scenarios were evaluated: (1) average
exposure due to use of an offsite well, (2) exposure due to use of one of the
most contaminated offsite wells, and (3) exposure due to use of one of the
most contaminated onsite wells. The exposure point concentrations used to
calculate risk estimates are described in the following paragraphs and are
also 11sted in Tables 2-4.
For average exoosure due to use of an offsite well, it was assumed that
persons would be exposed to groundwater contaminants at a level equal to the
mean of all the observations over time for all of the offsite wells. For
PERC. TCE, and TCA. these concentrations are 3. 1. and 1 ug/1, respectively.
For exposure due to use of the one of the most contaminated offsite
wells, the Pellow and Voftman Wells were identified as the two most
contaminated wells: Two concentration levels of contaminants were considered
at each of these wells: the average concentration at the wells and the
highest concentration observed at the wells. At the Pellow Well, the average
concentrations of PERC. TCE, and TCA are 28, 5, and 4 ug/1, respectively. The
highest concentrations of PERC, TCE, and TCA observed at this well are 38. 8.
and 10 ug/1, respectively. At the Volkman Well, the average concentrations of
TCE and TCA are 1 and 7, respectively. The highest concentrations of TCE and
TCA observed at this well are 7 and 15 ug/1, respectively. PERC was not
detected in this well and therefore 0.5 ug/1 (half the detection limit) was
used as the average and maximum value.
In order to evaluate exposure due to use of one of the most contaminated
onsite wells, the same approach was used as for offsite wells. The most
16
-------
FftA TECHNICAL CUTTER, NJ
volume of contaminated groundwater is estimated to be 13.3
million gallons.
SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for Area D and is
presented in a document entitled, Baseline Risk Assessment, Site
D Jet Fuel Farm (TRC, June 1939). The risk assessment consisted
of hazard identification, a dose-response evaluation, exposure
assessment and risk characterization.
Selection of Contaminants of Concern
The hazard identification involved the selection of
contaminants of concern (COCs), detected contaminants which have
inherent toxic/carcinogenic effects that are likely to pose the
greatest concern with respect to the protection of public health
and the environment. Selected contaminants of concern at Area D
induced:
Volatile Organic Contaminants
* Benzene
* Toluene
* Ethylbenzene
* Xylene
Base/Neutral and Acid Extractable Compounds
* Naphthalene
* Phenol
* 2-Ch1oropheno 1
Metals
* Chromium
* Nickel
* Lead
The media in which these contaminants were detected and
associated concentrations are summarized in Table 1.
-------
5
Dose-Response Evaluation
The dose-response evaluation presented available human
health and environmental criteria for the contaminants of
concern, and related the chemical exposure (dose) to expected
adverse health effects (response). Included in this assessment
are the pertinent standards, criteria, advisories and guidelines
developed for the protection of human health and the environment.
An explanation of how these values were derived and how they
should be applied is presented below.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg/day),
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg/day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfO. RfDs are derived from hum^n
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects of humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The Office of Research and Development (ORD) has developed
Health Effects Assessments (HEAs) for 58 hazardous substances.
The intent of these assessments is to suggest an acceptable
exposure level whenever sufficient data are available. These
values reflect the relative degree of hazard associated with
exposure to the chemical addressed.
When possible, two categories of maximum dose tolerated
(MDT) have been estimated for systemic toxicants. The first, the
"Acceptable Intake Subchronic" (AIS), is an estimate of an
exposure level that would not be expected to cause adverse
effects under subchronic exposure. Limited information is
available on subhcronic exposure because efforts have been
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10
directed primarily to lifetime exposures. Subchronic human data
are rarely available. Reported exposures are usually from
chronic, occupational exposure situations, or from reports of
acute accidental exposure. If data are available to estimate a
cnronic exposure, the subchronic exposure is also based on this
data, v11h an uncertainty factor applied.
The "Acceptable Intake Chronic" (AIC) is similar to the
concept of the Reference Dose (RfD) previously discussed. It is
an estimate of an exposure level which would not be expected to
cause adverse effects when exposure occurs for a significant
portion of the life-span. As with the RfD, the AIC does not
reflect the carcinogenic properties of the contaminant since it
is assumed, correctly or incorrectly, that there is no acceptable
intake level for carcinogens. The AIC is also considered to be
route specific, thus it estimates the acceptable exposure for a
given route with the implicit assumption that exposure via other
routes is insignificant.
AIC and AIS values are generally derived from animal studies
to which uncertainty factors have been applied. AIC and AIS
values are expressed both in terms of human intake (mg/kg/day)
and ambient concentration (e.g., mg/1 for drinking water).
Dose-response parameters used in the assessment of
none arcinogenic and carcinogenic risks at Area D are presented in
Table 2.
Excosure Assessment
The exposure assessment identified potential pathways and
routes for contaminants of concern to reach the receptors and the
estimated contaminant concentration at the points of exposure.
Contaminant release mechanisms from environmental media, based on
relevant hydrologic and hydrogeo1ogic information (fate and
transport, and other pertinent site-specific information, such as
local land and water use or demographic information), were also
presented. At Area D, the current receptor population was
identified as basically limited to government employees due to
the size and security of the FAA facility. In addition, only a
small percent of the Government employees (<2%) who work at the
Technical Center are authorized access to the Fuel Farm.
Potential exposure pathways evaluated include the ingestion of
groundwater, ingestion of or direct contact with surface soils,
and ingestion of or direct contact with subsurface soils.
Inhalation of airborne contaminants or fugitive dust was not
identified as a significant exposure pathway. For each
potentially significant exposure pathway, exposure assumptions
were made for realistic worst-case and most probable exposure
scenarios.
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1 1
Assumptions used to characterize exposure point
concentrations were all based on a 70-kg adult. Specific
assumptions for each exposure pathway and scenario are summarized
in Tac 1 e 3.
Risk Characterization
The risk characterization quantifies present and/cr
potential future threats to human health that result from
exposure to the contaminants of concern at Area D. The site-
specific risk values are estimated by incorporating information
from the hazard identification, dose-response evaluation, and
exposure assessment.
When sufficient data are available, a quantitative
evaluation is made of either the incremental risk to the
individual, resulting from exposure to a carcinogen or, for
noncarcinogens, a numerical index or ratio of the exposure dose
level to an acceptable dose level is calculated.
Risks which were assessed in the Area D feasibility study
include noncarcinogenic and carcinogenic risks resulting from
exposure to individual COCs.
For noncarcinogenic compounds, various regulatory agencies
have developed standards, guidelines and criteria which provide
"acceptable" contaminant levels considered to protect human
populations from the possible adverse effects resulting from
chemical exposures. A ratio of the estimated body dose level to
the RfD or AIC/AIS provides a numerical index to show the
transition between acceptable and unacceptable exposure. This
ratio is referred to as the chronic hazard index. For
noncarcinogenic risks, the term "significant" is used when the
chronic hazard index is greater than one. When Federal standards
do not exist, a comparison was made to the most applicable
criteria or guideline.
Calculated body dose levels, as described previously, were
compared to the body dose level associated with the most
applicable standard or guideline. The estimated chronic body
dose level in ug/kg/day is estimated using the exposure
assessment assumptions and actual site data as summarized in
Table 3. The body dose level is then compared to the AIC to
determine if chronic exposure to the contaminated soil presents a
risk. Because certain standards are derived for protection
against acute (e.g., 1-day HA), subchronic (e.g., AIS), and
chronic (e.g., AIC) exposures, body dose levels for
noncarcinogens are developed for both acute and chronic exposures
and the associated risks assessed.
For carcinogens or suspected carcinogens, a quantitative
risk assessment involves calculating risk levels considered to
represent the probability or range of probabilities of developing
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12
additional incidences cf cancer under the prescribed exposure
conditions. Carcinogenic risk estimates, expressed as additional
incidences of cancer, are determined by multiplying the
carcinogenic potency factor, as described earlier, by the
projected exposure dose level. It is the carcinogenic potency
factor, expressed in (mg/kg/day)~-, which converts the estimated
exposure dose level, expressed in (mg/kg/day), to incremental
risk. These risks are probabilities that are generally expressed
in scientific notation (e.g., 1^x 10~6or 1E-6). An excess
lifetime cancer risk of 1 x 1 0 indicates that, as a plausible
upper bound, an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure
conditions at a site. To put the calculated risk estimates into
perspective, they should be evalu a_ted against a baseline risk
level. Risk levels of 10~4 to 10_/ can be used to determine the
"environmental significance" of the risk incurred and are used as
a target range for remedial purposes (U.S. EPA, 1986). Using
this range as a baseline, a risk level greater than 10 ~4 is
considered to present a "significant" risk with regard to hu m an
health in an environmental context, and levels less tfian 10 are
considered "insignificant". A risk level between 10~4 and 10-/
is classified as "potentially significant". The use of the terms
"significant", "potentially significant", and "insignificant" ai-e
not meant to imply acceptability; however, they help to put
numerical risk estimates developed in risk assessment into
perspective.
The noncarcinogenic risk characterization for Area D
concluded that under realistic worst-case and most probable
exposure scenarios the acute and chronic noncarcinogenic risks
associated with future exposures (ingestion or dermal contact) to
surface and subsurface soils appear to be "insignificant".
Likewise, acute or chronic ingestion of contaminated groundwater
under realistic worst-case and most probable exposure scenarios
does not appear to result in "significant" noncarcinogenic risk.
A summary of noncarcinogenic chronic hazard indices is presented
in Table 4.
The carcinogenic risk characterization concluded that the
carcinogenic risks associated with future incidental ingestion cf
surface or subsurface soils under realistic worst-case and most
probaDle exposure scenarios are considered "insignificant".
Direct dermal contact with surface or subsurface soils under
future realistic worst-case and most probable exposure scenarios
also appears to be "insicrificant". Future scenarios which
evaluate the carcinogenic. ~azard associated with groundwater
ingestion predict the car mogenic risk to.be "sionificant"
(i.e., exceeds the EPA target range of 10 to 10 ) for the
realistic worst-case and "potentially significant" for the most
probable exposure scenarios. A summary of carcinogenic risks at
Area D is presented in Table 5.
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13
Environmental risks associated with the presence of
contamination at Area D are expected to be minimal. Based cn the
investigation results, surfisial contamination is limited to tne
presence of petroleum hydrocarbons in relatively small c eas of
jet f-jel spills. The majority of the threats posed by Area D are
associated with the presence of the floating hydrocarbon plume
and subsurface soil contamination. Therefore, risks to flora and
fauna at the surface are limited.
Regardless of the type of risk estimate developed, it should
be emphasized that all estimates of risk are based upon numerous
assumptions and uncertainties. In addition to limitations
associated with site-specific chemical data, other assumptions
and uncertainties that affect the accuracy of the site-specific
risk characterizations result from the extrapolation of potential
adverse human health effects from animal studies, the
extrapolation of effects observed at high dose to lose dose
effects, the modeling of dose response effects, and route-to-
route extrapolation.
The use of acceptable levels (established standards,
criteria and guidelines) and unit cancer risk values which are
derived from animal studies introduces uncertainty into the ris.k
estimates. In addition, the exposure coefficients used in
estimating body dose levels are often surrounded by
uncertainties. As such, these estimates should not siand alone
from the various assumptions and uncertainties upon which they
are based. In developing numerical indices of risk, an attempt
is made to evaluate the effect of the assumptions and limitations
cn the numerical estimates. When the assumptions and
uncertainties outweigh the meaningfulness of a risk assessment, a
qualitative assessment of the risk is performed.
The uncertainty factors which are incorporated into the risk
estimates are believed to be conservative. As such, when they
are considered collectively, exposure, and subsequently risk, may
be overestimated.
In conclusion, based on the results of the risk assessment,
actual or threatened releases of hazardous substances from Area
D, if not addressed by implementing the response action selected
in this ROD, may present an endangerment to public health,
welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Eight remedial alternatives were developed for analysis in
the Area D FS. Each of these alternatives is described in detail
below. Because a number of the alternatives involve common
remedial elements, these are described separately, where
applicable, and then are referenced in the individual alternative
descriptions.
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TABLE 1
CONTAMINANTS OF CONCERN - AREA D
MONITORING WELLS
Concent, rat: ion
Average
Max lmuin
Detected
Frequency
SURFACE SOIL
Concentrat ion
Detected
EPA
Carcinogenic
Classification
VOLATILE ORGANICS
Benzene
To! viene
Ethylbenzene
Xylene (total)
(ppb)
4,000
3.100
530
4,700
390.18
325.41
67.53
404.00
5/17
4/17
6/17
5/17
160
150
160
560
A(>>
D^)
D<2>
SEMI-VOI.ATILE (DNAs)
Naphtha 1 ene
Pheno1
2-Chlorophenol
(ppb)
1,000
303
79.82
33.79
6/17
9/16
600
570
INORGANICS (ppb)
Chromium, Total
Nieke 1, Tota1
Lead, Total
192 <3 >
3441 3 >
68< 3>
29. 73
36.51
12.94
8/17
6/17
9/17
7.700
4,000
D
d('ป
B2 ( 1 >
EI'A Carcinogen Classification: A = Known Human Carcinogen
132 - Probable Human Carcinogen (based on animal studies -
Inadequate evidence in humans)
D = Not Classified
Reference-Memorandum from S. Lee (Toxics Integration Branch). Updated Reference Dose and
Cancer Potency Numbers for use in risk assessment (November 16, 1987)
'2) Drinking Water Regulations and Health Advisories, U.S. EPA Office of Drinking Water (December 1908).
Inorganic concentrations are based on the analysis of unfiltered ground water samples.
-------
tRIDCPFJ
TABLE 2 DOSE-RESPONSE PARAMETERS USED IN I HE ASSESSMENT OF NONCARCI NOC.EN IC AND CARCINOGENIC RISK - AREA D
(4) (5)
Health Advisories (ppb) Carcinogenic
(I) (2) (3) Potency
Contaminant of AIS AIC RfD 1-Day Long-lerm Factor -1
Concern (fng/kg/day) (*g/kg/day) (mg/kg/day) (Adultl (AcKjl 11 (mg/kg/day)
Benzene
200
--
2
Ethylbeniene
9.70E-01
1.00E-01
1.00E-01
30000
3000
--
Toluene
4.30E-01
3.00E-01
3.00E-01
20000
10000
--
Xylene
4.00Eป00
2.00E+00
2.00E+00
40000
10000
--
Naphthalene
4.10E-01
4.10E-01
4.00E-01
--
--
--
Phenol
4.00E-02
4.00E-02
6.00E-01
--
--
--
2-Chlorophenol
5.70E-03
5.70E-OJ
5.00E-03 (6)
--
--
--
Chromiui
2.50E-02
5.00E-03
5.00E-03 (6)
1000
800
--
Nickel
1.40E-02
1.00E-02
2.00E-02
1000
600
--
Lead
--
1.40E-03
1.40E-03 (7)
--
--
--
(1) Subchronlc Acceptable Intake - Memorandum from S lee (EPA, Toxics Integration Branch), Updated Reference Dose and Cancer
Potency Ninfcers for use In risk assessment (Novenfcer 16, 1987)
(2) Chronic Acceptable Intake - Memorandum from S Lee (EPA, Toxics Integration Branch), Updated Reference Dose and Cancer
Potency Nurbera for use In risk assessment (November 16, 1987)
Source RfD for lead
(3) Reference Doses (RfDs) of Oral Exposure- EPA Office of Research and Development, Health Effects Assessment Simmary Tables,
First Quarter F*B9, January 1989
(4) Health Advisories * Drinking Water Regulations and Health Advisories, U.S. EPA Office of Drinking Uater (December, 1988)
(3) Carcinogenic Potency Factor (Oral) - EPA Office of Research and Development, Health Effects Assessment Sunmary Tablet,
Flrat Quarter FY89, January 1989
(6) Reference Dose (RfD) of Oral Exposure - Drinking Uater Regulations and Health Advisories, U.S. EPA Office of Drinking Uater
(Decenfcer, 1988)
(7) Reference Dose (RfD) - Superfund Public Health Evaluation Manual, October, 1986
EPA Is currently reviewing lead as a carcinogen and may calculate a cancer potency factor (CPF) in the future. The RfD
value listed in this table has been revoked. Slrvce a CPF does not exist at present, the old RiD is being retained so
that the noncarcInogenic potential of lead can be evaluated.
-------
TABLE 2
ESTIMATED DOSES AND INCREMENTAL CANCER RISKS FROM
AVERAGE EXPOSURE DUE TO USE OF AN OFFSITE WELL
TCE
Concentration (ug/1)
Risk.
Oral
3 x 10~7
Inhalation
1
3 x lO"7
Derma
1
1 x 10-9
PERC
Concentration (ug/1)
R1 sk.
Total Excess Risk
4 x 10-6
1 x 10-5
4 x 10~6
2 x 10"3
(Sum of risks due to three
exposure routes and both
chemlcals)
17
-------
lABir j
ฃSI IMAllO DOSES AND INCRIHLNIAI CANCIR RISKS t ROM
CXPOSUKC UUi 10 USฃ Of IMC MUSI COHIAHINAICD OK SI 11 WEILS
Pet low He! 1
01 dl
Averse Ca>ซ
inhalation
derwd I
Upper-buundLaig
OUl inlidldl ion ieriUll
ICC
Concentration (ug/1)
Risk
2 x 10
-6
10"
I ซ 10
-S
3 ซ 10"
b ซ 10
-b
10"
PCRC
Concentration (ug/l) 28
Risk 4 x I0"5
lot31 [>cess Risk 8 ซ 10
-S
28
4 x ป0~5
28
2 ป I0";
(Sua of risks due to three
routes and both cheaicdls)
38
b m 10 s
2 x 10'"
18
10"
18
2 ซ 10"
(Sun of risks due to three
routes and both chemcaU)
VflHtun Mel 1
ttud
Ca^e
InlmUt ion Pcfdl
Unit c cJifliunLCiiii
Qldl Inlidldt IQII Uenidl
ICC
Concentration (ug/l)
Risk
1 10
-7
1 ซ 10
-7
I
I ซ 10
-9
2 k I0"6 4 ซ I0"6 8 . I0"li
PC HI
Concentration (ug/l) .5
Risk 7 . 10
-7
7 x 10
.5
3 ซ I0"9
.5
7 a IQ";
.5
I x I0"6
.5
3 x IO-y
Total Excess Risk
2 x 10"
(Sum ul risks due la three
routes and both cheaicdls)
I x 10
-b
(Sum of risks due to llute
routes
-------
IABII 4
rSIIHAiril noseS AND INCRtHtNIAl CANCIR RISKS iroh
IXHOSURt out 10 USl 01 Iht HOSI CONIAMINAIIO ONSIIE WILLS
Mfcli-MJl
lllhd ldliOfl ltฃฃiui
ami
UMBcr-tiuuniiJ^g
LutuldllUil dCKUil
ICE
Concentration (ug/1) 13
Risk 4 ซ 10
-6
13
4 ซ 10
-6
13
2 ซ 10'
22
7 x I0"6
22
I ซ
10"
22
3 >
10-
PCRC
Concentration (ug/l) 14* 14 14
Risk 2 * IQ~5 2 ซ I0~5 8 * 10"ฎ
lotal luces* Risk
b ป 10
26
4 x 10
-5
^ ( Sum o( risks due to three 1 * 10 4
routes and both chemicals)
2b
H * 10"^
2b
I x
10
-1
(Sum ol risks due to three
routes and both chemicals)
Well HH I
Qlil
Aveia^e Case
lnhdl^t ton Ikced!
Qui
-bound Case
liiludiilifli) Btrwitl
ICC
Concentration (ug/l)
Risk
I ซ 10"
4
I * I0"6
0"
I ซ 10
-6
i x 10"
10
-9
PCRC
Concentration (ug/l)
Risk
Jl
b x t0_i
3i
5 * IQ~5
33
2 x I0~7
(3
5 * 10 s
II
I x 10"
33
2 x 10
-/
lotal Excess Risk
I * I0"4 (Sunt of risks due to three I x ID ^
routes and both chemicals)
(Sua ol risks due to thiee
routes anil both chemcals)
-------
c c n * 3 n' ฆ d t- :ns-:5 ซe' ' i ซe'? 'rent ""a: as Tc-'tc-'ng .ซe!:s a-:
At fe ' i . tie average :;-:?":'a:-;r$ zf PUZ, ~Ci. a-: a-? 'i. :
ana 5 ug/1. respectively "he ngnest :cncen tra t1 on s of ?E3C, ~ZZ. a*:
ccservea at this wei1 ars 26. 22. anc 15 ug/1, rescect:ve1/. vw-T ซฉ;i as
samoied only once in June 1988. The concentrations of PERC, TCE, ana TCA
detected in this well are 33, 4, and 13 ug/1, respectively.
Four other organic compounds~chloroform, 1,2-transdichloroetny1ene ,
1,1-dichloroethane. and vinyl chloridewere detected on a few occasions in
less than 301 of the offsite wells. Vinyl chloride, for example, was analyzed
on only one occasion and was detected only In the Pel low. MH-M, and mw-T WeHs
at 1 ug/1. Chloroform was sampled for regularly in each well, but was
detected in only 3 wells, on one occasion In each well (maximum concentration
- 5 ug/l detected in the Costello Well, October 1987). These chemicals were
therefore not evaluated in the risk assessment, because they were detected so
infrequently and at very low concentrations relative to their toxicity (often
near the detection limit of i ug/1). However, because of the weight of
evidence and cancer potency of vinyl chloride and chloroform, the maximum
likely additional cancer risks due to exposure to these chemicals are
discussed in the uncertainty section.
Iron was the only Inorganic c-mpound detected in offsite wells that
exceeded drinking water standards. The ambient water quality criterion for
iron (0.3 mg/1) Is based on taste, odor, and staining properties. This
compound was not considered a contaminant of concern because there are no
known health effects from ingestion of iron at the concentrations measured.
Exposure Assessment
The population at greatest risk of adverse health effects are those
people who potentially use the groundwater In the area of the NorthsIde
Landfill as their only source of drinking water. The primary routes of
exposure to contaminants In groundwater are ingestion, Inhalation of volatile
constituents, and dermal absorption.
A. Exposure Point Concentrations
As mentioned above, groundwater monitoring data from Appendix 0 of the
Supplemental RI Addendum were used to derive exposure point concentrations.
Appendix D contains organic chemical concentration data for samples taken
during the period of September 1983 through June 1988 for onsite and offsite
wells. Most wells were .sampled periodically auring this period ana so a time
series of data i* available for these wells. Some wells were sampled only
once or very Infrequently during this period.
A great number of analytical results are reported as below a detection
limit of 1 microgram per liter or as below an unspecified detection limit.
When calculating exposure point concentrations for PERC. TCE and TCA, these
"non-detectable" results were treated In the following manner. If a result
was reported as less than 1 microgram per liter, then it was assumed that the
concentration equals one-half of the detection limit. I.e., 0.5 ug/1. If a
result was reported as less than an unspecified detection limit, it was
assumed that the detection limit Is 1 microgram per liter, and that the
concentration equals 0.5 ug/1.
20
-------
lr. cms scenario, it *as assume: t~at oerscns ^cu'd be 9
-------
"-,3 ifij MW-T i ? 'Z?~~ ' z- j; -,-= "ICS"
:znti:Tn,,dt3a weilj. 3is :~e ecci^ra r; gre^'Oi:?'
ecntamt nants from ootn t"sse 1 is are eva'. jatea assuming :-o i e v e i 3 :f
axoosure. The firs: level is tne average concentration at :ne *eiis T-ese
concentrations are given in tne paragracns aoove.
The second level considered is the hignest concentration ooserved at the
wells. At tne mw-m well, the highest ooserved concentrations of PESC. TCE,
and TCA are 26. 22, and 15 ug/1, respectively. At the MW-T Hell, tne only
ooserved concentrations of PERC. TCE. and TCA are 33, 4. and 18 ug/1.
respectively.
8. Calculation of Dose
For each chemical of concern, an average daily dose was calculated for
two routes of exposure. Ingestion and dermal contact. A dose from inhalation
of volatile organic compounds, such as the chemicals of concern, was not
calculated directly, as the various models for estimating risks from
inhalation exposure have not been critically reviewed by the EPA. Region 10.
Therefore, In this risk assessment it was assumed that the inhalation risks
are equal to (average case) or two times (upper-bound case) the risks from
Ingestion of 2 liters of water per day. according to current EPA, Region 10
guidelines (USEPA. 1989a).
The average daily dose (mg/kg/day) via ingestion was calculated as
follows:
dose - concentration of contaminant (mg/l> x intake rate <1/day) / 70 kg
body weight
For all exposure scenarios, a person was assumed to Ingest 2 liters of
contaminated water every day for a lifetime. Absorption was assumed to be
100X for all chemicals.
The average daily dose from dermal absorption of contaminants while
bathing was calculated as follows:
dose - C x CF x Kp x SA xEF / 70 kg body weight
where,
C - concentration of contaminant (mg/1)
CF ฆ conversion factor (10'3 i/cm3)
Kp dermal permeability constant (cm/hr)
SA body surface area contacted (cm^)
EF - frequency (hr/day)
For all the volatile contaminants, a dermal permeability constant of 8.4
x 10"4 cm/hr was used in the above equation (USEPA, 1989c). The body
surface area exposed to water while bathing was assumed to be 18.000 cm2 for
the average adult (USEPA, 1989b). For each exposure scenario, a person was
assumed to bathe for a duration and frequency equivalent to one-naif hour
every day for a lifetime.
22
-------
~ ~ i' - ฆ " v ^ s19 S i r "
Under current E?A gui :e i'ฆ nes. t"e : ">
-------
A; iocad c"5v' cus i i. -1 r<; s-cm ;nra'at-:r. 5<;csjr? -c: zi
c: rec11 y. but assumed to o? ecjal to (a^e-age case) or :ซo -;res
case) ne risks from ingestion of 2 liters of *ater oer aay accorc; ~o
guide!mes (USEPA, 1989a).
3 Criteria for Carcinogenic Effects
The EPA uses a weight-of-evidence system to convey how likely a chemical
is to be a human carcinogen, Based on epidemiological studies, animal studies,
and other supportive data. The classification system of the EPA for
characterization of the overall weight of evidence for carcinogenicity
Includes: Group A- Human Carcinogen; Group B- Probable Human Carcinogen;
Group C- Possible Human Carcinogen; Group D- Not Classifiable as to Human
Carcinogenicity; and Group E- Evidence of Non-Carcinogenicity for Humans.
Group 8 is subdivided into two groups: Group 81- limited human evidence for
carcinogenicity; ana Grouo 82- sufficient data in animals, but Inadeauate or
no evidence in humans.
TCA is currently in Group 0, not classifiable as to human
carcinogenicity, and therefore was not evaluated for carcinogenic risks. PERC
and TCE are currently classified as probable human carcinogens by the EPA,
Group 82. However, the status of these compounds and their respective cancer
potency factors Is now under review.
For PERC, the review concerns whether this chemical is most approDriately
classified In Group B2 or C. Evidence of liver tumors (in both sexes of mice
by two routes of administration), leukemia in rats, and renal carcinomas in
male rats, along with supportive metabolic considerations, provide a basis for
classifying PERC in Group 82. However, mutagenicity data have In general been
negative or Inconclusive. Furthermore, the relevance of mouse liver tumors to
human cancer risk Is still In question. PERC would therefore be classified as
Group C, possible human carcinogen, If one accepts the weighting of the animal
evidence to be 1imi ted.
For chemicals with carcinogenic effects, EPA calculates the cancer risk
associated with a given dose by multiplying the dose from a given route of
exposure by a cancer potency factor or potency slope. The EPA derives potency
factors from the upper 951 confidence 11m1t of the slope of the extrapolated
dose-response curve, which shows the relationship between a given dose and the
associated tumor Incidence. As a result, the predicted cancer risk 1s an
upper-Dound estimate of the potential risk associated with exposure.
*
The present oral cancer potency factors for PERC and TCE are 5.1 x 10-2
and 1.1 x 10"', respectively (USEPA, 1988). There are no cancer potency
factors for dermal absorption. However, for volatile organic compounds, such
as the chemicals of concern, current EPA policy Is to use the oral potency
slope in calculating cancer risk from dermal exposure.
R1sk Cha-icterlzation
A. Carcinogenic Risks
Estimates of carcinogenic risks for the three exposure scenarios
considered are presented in Tables 2, 3, and 4. These risks are the estimated
lifetime Incremental upper-bound risks of developing cancer as a result of
24
-------
Cr'ig eocsaa 5ฃPC a-: "31 j-ce- :~e ass-.Tec t-:rs '-= -'s^s
ai icc i area ฆ i t h e * c c s j r ? :; 5 a: - e c a ' /'a . ฆ .ฆ*, n a ' 1: ; r , a r : ; s' - a
e*cosures routes are gi;?i Also. tctai excess risk / a > ue s are snc*n rer-
ead scenario, 'oral excess ns< values are calculated by aacing tne ris*$
aue to exposure ro botn cnemicals oy all three exposure routes.
Table 2 snows tne estimated cancer risks based on an average exposure
to PERC and TCE due to use of an offsite well. The total excess risk, is 9
x 10"ฎ for this scenario. This number represents an increased risk of
contracting cancer of nine chances in one million for a person exposed for
70 years.
Estimated cancer risks based on exposure to PERC and TCE due to use of
the most contaminated offsite wells (the Pellow and Volkman Wells) is snown
in Table 3. For each of these wells, exposure to the average and maximum
concentrations of each chemical observed at the well was considered
(average and upper-bound cases, respectively). For the Pel low Well, total
excess risks are estimated to be 8 x 10~5 and 2 x 10-4 assuming
exposure to average and maximum concentrations. respectively. For the
Volkman Hell, total excess risks are estimated to be 2 x 10-6 and 9 x
10-6 assuming exposure to average and maximum concentrations,
respectively.
Table 4 shows the estimated cancer risks based on exposure to PERC and
TCE due to use of the most contaminated onsite wells (the mw-m and mw-t
Wells). For Well mw-m, the same two levels of exposure were considered as
for the offsite wells. Total excess risks are estimated to be 5 x 10-5
and 1 * 10"4 assuming exposure to average and maximum concentrations,
respectively. For the MW-T Well, the total excess risk Is 1 x 10"4 for
both the average and upper-bound exposure calculations, based on the single
available observation.
B. Non-Carcinogenic Risks
Non-carcinogenic risks are presented as a hazard index which Is the
ratio between the route-specific calculated dose and the RfD. Ratios
exceeding unity (one) Indicate doses that exceed the acceptable level;
ratios less than one are not expected to cause adverse health effects.
Based on the highest observed concentrations of PERC and TCA. the
Pellow and MW-T wells were the offsite and onsite wells, respectively,
found to pose the greatest risk of non-carclnogenic effects. The estimated
doses of each chemical, based on the maximum observed concentration, and
the corresponding hazard Index are presented below for the Pellow and mw-T
wel is.
Pellow Well PERC TCA
(mg/kg/day) (mg/kg/day)
Oral Dose 1.1 x 10" 3 2.9 x 10-4
Inhalation Dose 2.2 x 10"3 5.7 x 10"4
Dermal Dose 4.1 x 10"ฎ 1.1 x.10"ฎ
Total Dose (A) 3.3 x 10"3 8.6 x 10-4
RfD (B) 1.0 x 10"2 9.0 x 10-2
Hazard Index (A/B) 0.30 0.01
25
-------
Cra: Dose
Inhalation Dose
Der-nai Dose
Total Dose (A)
RfD (3)
Hazard Inde* (A/B)
9 4 x 10"4
1.9 x 10"3
3.6 x lO"6
2.8 x 10-3
1.0 x lO"2
0.30
5.1 x !0-4
1.0 x lO"3
1.9 x 10"6
1.5 x 10"3
9.0 x 10"2
0.02
The hazard indices for both chemicals may be totaled as PERC and TCA
have similar toxic endpolnts. The total hazard indices for the Pellow and
mn-T well are 0.34 and 0.30, respectively. As these hazard indices are
below unity, non-carcinogenic health effects are not expected from exposure
to PESC and TCA in these two wells. The risk, from exposure to PERC and TCA
in other wells would be less, as the Pellow and mw-T Wells have the highest
concentrations of these contaminants. Thus no non-carcinogenic effects ar?
expected due to exposure to these chemicals in any well.
C. Uncertainty
The accuracy of the risk, characterization depends In large part on the
quality and representativeness of the available sampling, exposure, and
toxicologlcal data.
One major area of uncertainty that may have underestimated health
risks Is that cancer risks from exposure to chloroform and vinyl chloride
were not evaluated In this study. These chemicals were detected very
Infrequently and the RI/FS determined there was insufficient data to
evaluate them. However, vinyl chloride is classified as a human
carcinogen, Group A, and chloroform 1s classified in Group 82. probable
human carcinogen. 8ecause of their Inherent toxicity, likely maximum
additional increases in cancer risk from exposure to vinyl chloride and
chloroform were therefore calculated. Using the highest single
concentration detected for vinyl chloride (1 ug/1) and an oral cancer
potency slope of 2.3 (USEPA, 1989d>, the upper-bound estimate of additional
cancer risk 1s 2 x 10-4. For chloroform, the upper-bound estimate of
additional cancer risk Is 3 x 10"ฎ, based on the highest observed
concentration (6 ug/1) and an oral cancer potency slope of 0.0061
(USEPA. 1988). Because these chemicals are degradation products of the
other chlorinated organfcs, vinyl chloride and chloroform levels could rise
and pose risks greater than the above estimates.
D. Conclusions
In conclusion, the total Incremental Increase in cancer risk for the
average exposure scenario is 9 x 10~6. For exposure to one of the
offslte wells with the highest average concentration of carcinogens, cancer
risks range from 2 x 10"ฎ to 1 x 10-*. Estimated cancer risks from
exposure to groundwater from the most contaminated onslte wells range from
5 x 10-5 to 1 x 10"4. These scenarios are based on the assumotlon that
the population at risk Is using groundwater near the Northslde Landfill as
the only source of drinking water over an entire 11fe11m (70 years).
Non-carcinogenic health effects are not expected from exposure to PERC and
TCA at the present level of contamination in onslte and offslte wells.
-------
raRAHCN BATHRY, NY
gyvTROMxrsTAL risks
Sediment bioassays vere conducted on four freshwater estuarine
spซcies reariodiphp^a dubla. Sซlanซltruป eaprlcomutuB.
Crangpg fip and Plwphales promalesl to determine the concentra-
tions of cadmium, nickel, end cobalt in sediment which edveraely
affect aquatic organisms. Thirteen sediaent samples were collected
from Foundry Cove and the Pier Area and one fro* Wappingers Pallฎ
(reference location) and used in the bioassay tests. Staples vera
recovered froa the top 6 inches of sediaent. Based on the results
of ~;:se tests, it was concluded that a level between 10 ar.d 25 5
ag/fcg of cadmium in the sediaent would protect the environment.
Research performed for EPA (JRB, 1984) established sediaent
criteria for cadmium based upon limiting concentrations in water
to levels below EPA Ambient Water Quality Criteria. Preliminary
results have shown that sediaent cadmium toxicity decreases with
increasing organic content. Therefore, for a total organic carbon
(TOC) concentration of 5%, the chronic eediment cadmium criterion
vas found to be 38.5 ag/lcg, and at a TOC of 10%, the chronic level
was found to be 77 ag/kg. Ebasco's field results shoving an
average TOC value of 9.4% for this area vould iaply that a cadmium
concentration soaevhere in the range of 73 ag/)cg vould bซ required
to prevent chronic expoeure. The proportion of cadmium found in
the .sediment to that in aqueous solution in the marsh, however,
will depend not only on TOC, but on other site-specific factors,
including water chemistry, pH, oxidation/reduction potential, and
temperature. Therefore, the aodel for partitioning based upon
simplifying assumptions will only approxiaate site-specific cadmium
criteria (ERT, 1986) . KYSDEC feels that even at 10 ag/kg of
cadmium in sediaents there aay be adverse ecological iapacts.
The shortnosed sturgeon tAclpenser brevirostrun). an endangered
species since 1967, occurs in the Hudson River froa Troy to
Pieraont, a range of 125 ailes which includes the site. Because
it is a bottom feeder, and benthic organisms aceuaulate cadmium,
exposure to site contamination is possible. However, sinco
critical life stages (e.g., juveniles and larvae) end over-
vintering individuals do not congregate in the Foundry Cove area,
it is expected that the site contamination aay not have a
significant effect on these fish.
-------
6. DESCRIPTION OF ALTERNATIVES
The objective of this section is to provide an understanding of the remedial
alternatives developed for the site and their specific components. Each alternative
should be described to provide a clear understanding of how all of the wastes (including
any residuals) will be addressed through treatment, containment, and/or institutional
controls.
An excellent description of alternatives includes discussion of chemical-,
action- and location-specific ARARs, why they are ARARs, assumptions, limitations
and uncertainties, risk reduction, volumes, and the degree of hazard of waste left on site
or disposed off site. Capitol, O&M, and present worth costs should be provided as well as
implementation requirements and time frames.
EXAMPLE: BYRON BARREL AND DRUM, NY
This example contains a helpful introductory section that provides an
overview of the number of alternatives presented and the respective problems they are
intended to address. Although brief, the descriptions provide essential information to
convey how all of the waste is being addressed through treatment, containment, or
institutional controls. In addition, each description addressed volumes of material,
implementation requirements and time frames, monitoring, and the need for a five
year review, as well as present worth costs. Additional information that would be
useful to include are capitol and O&M costs, a bit more detail on the major ARARs each
alternative will trigger (particularly the land ban), and the ground water classification
and area of attainment for the ground water alternatives.
EXAMPLE: NORTHSEDE LANDFILL. WA
Example two is included because it provides a good summary of other malor
ARARs associated with each alternative. The ROD also describes the objectives of the
alternative well, although the discussion of advantages and disadvantages is
unnecessary in this section. It would be better placed in the Comparative Analysis
section. Costs, volumes, and other information is missing, although the ROD did
address implementation time frames and the need for treatability studies in a table
that was not included.
-------
United States A 1 Office of Superfund Publication.
Environmental Wniww^S Sllid Waste and 9335.3-02FS-3
Agency Emergency Response May 1990
4'uPA Guide to Developing Superfund
No Action, Interim Action, and
Contingency Remedy RODs
Office of Emergency and Remedial Response
Hazardous Site Control Division Quick Reference Fact Sheet
This guide provides Remedial Project Managers (RPMs) with a quick reference to the essential
components of Records of Decision (RODs) prepared to document the following three special types of
remedial action decisions: (1) no action; (2) interim actions; and (3) contingency remedies. The first type
of special ROD, the no action ROD, documents that no response action is necessary to ensure adequate
protection of human health and the environment or is not possible either technologically or under CERCLA
authority. The second type of special ROD, the interim action ROD, documents that the response action
selected will be of limited scope and will be followed by a later, final response action for that operable unit.
For interim action RODs, the documentation provided should be tailored to the limited scope and purpose
of the interim action (as opposed to a limited final action, where the ROD may be streamlined within the
standard ROD format). Finally, the contingency remedy ROD provides a fall-back remedy in the event that
the primary, selected remedy does not achieve its expected performance. In preparing all three types of
special RODs, RPMs should modify, as outlined in this guide, the format of the standard ROD for final
response actions (see Highlight 1). Sections that have been crossed out should not appear in a special ROD.
Sections that appear in bold should be supplemented according to the directions provided in this fact sheet.
Finally, sections of the standard ROD that are not modified in the outlines below should be included in the
special ROD at the same level of detail as if they were standard ROD discussions. More detail on preparing
the three types of special RODs is provided in Chapter 9 of the Interim Final Guidance on Preparing
Superfund Decision Documents (the "ROD Guidance")(December 1989, EPA/624/1-87/001).
I. DOCUMENTING NO ACTION DECISIONS
EPA may determine that no action is warranted
for a site or operable unit within a site under the
following three general sets of circumstances:
When the site or operable unit poses no current
or potential threat to human health or the
environment (i.e., the site or operable unit is
already in a protective state);
When the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization
Act (SARA) of 1986, does not provide the
authority to take remedial action; or
When no effective action can be taken, given
currently available technology and the site or
contaminant characteristics.
Highlight 2 provides specific examples of
potential sites requiring no action decisions for
each of the reasons cited above. The remainder
of this section presents an outline of the ROD
format to use in each of these situations.
Highlight 1
OUTLINE FCR THE STANDARD ROD
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy
Statutory Determinations
Signature and Support Agency Acceptance
of the Remedy
2. Decision Surnnarv
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit
Site Characteristics
Stannary of Site Risks
Description of Alternatives
Summary of Comparative Analysis of
Alternatives
Selected Remedy
Statutory Determinations
Documentation of Significant Differences
3.
ResDonsiveness Sunmarv
Community Preferences
Integration of Comments
-------
DRAFT
Highlight 2
POTENTIAL SITES REQUIRING
NO ACTION DECISIONS
Where a previous removal action
mitigated the threat;
Where a natural environmental
process, such as the attenuation of a
ground-water contaminant plume,
eliminated the threat;
WTiere the baseline risk assessment
concluded that the conditions posed
no threat;
Where a remedy includes no
treatment, engineering, or institutional
controls; and
Where a release involved only
petroleum wastes, making the
contaminants exempt from remedial
action under CERCLA section 101.
NO ACTION SITUATION #1:
ACTION NOT NECESSARY FOR PROTECTION
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
Statutoiy Determinations
Declaration Statement: None of the Section
121 statutory determinations are necessary in
this section. Instead, the lead agency should
state briefly that no remedial action is
necessary to ensure protection of human health
and the environment This section should also
note whether five-year review is required. (A
five-year review is necessary under a no action
ROD when previous removal or remedial
actions at the site resulted in the
implementation of engineering controls to
prevent unacceptable exposures and when these
controls will remain in place over the long
term.)
Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit or Response
Action
Site Characteristics
Summary of Site Risks: The information in
this section provides the primary basis for the
no action decision. The discussion shoufd
support the determination that no remedial
action is necessary to ensure protection of
human health and the environment. The lead
agency should explain how the baseline risk
assessment conducted during the remedial
investigation (RI) indicates that unacceptable
exposures will not occur. Any engineering
controls implemented as part of previous
actions that contribute to protection of human
health and the environment should be
discussed.
ซ Description of Alternatives
ป Summary of Comparative Analysis of
Alternatives
Selected Remedy
Statutory Deteiwmatious
Description of the No Action Alternative: The
lead agency should identify the no action
alternative in this section of the ROD. If
alternatives were developed in the feasibility
study (FS), the lead agency should reference
the RI/FS Report.
Explanation of Significant Changes
3. Responsiveness Summary.
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DRAFT
NO ACTION SITUATION #2:
NO CERCLA AUTHORITY TO TAKE ACTION
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy: The lead
agency should state that it has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
ซStatutory Determinations
o Declaration Statement: No Section 121
statutory determinations are necessary in this
section. This section should explain that EPA
does not have authority under CERCLA Section
104 to address the site or operable unit The
statement that the no action decision does not
constitute a finding by EPA that adequate
protection has been achieved at the site.
Rather, the statement should identify the
statutory or regulatory authority that does have,
or potentially could have, jurisdiction over the
problem. If the problem has been referred to
other authorities, this should be explained.
Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit or Response
Action
Site Characteristics
Summary of Site Risks
Description of Alternatives
ซ SummaryofComparativeAnalysisof
Alternatives
Selected Remedy
Statutory Authority Finding: The concluding
statement of the absence of CERCLA authority
to address the problem should be the same as
in the Declaration.
Explanation of Significant Changes
3. Responsiveness Summary.
NO ACTION SITUATION #3:
NO EFFECTIVE ACTION POSSIBLE
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy. The lead
agency should state that is has selected no
action as the remedy for the site or operable
unit, although it may authorize monitoring to
verify that no unacceptable exposures to risks
posed by conditions at the site occur in the
future.
Statutory Determinations
Declaration Statement: This Declaration should
state that it has been determined that no
effective remedial action is possible at the site.
The Declaration should also explain that the no
action decision does not constitute a finding
that the remedy ensures adequate protection of
human health and the environment. A
statement that a five-year review will be
conducted should be included.
Signature and Support Agency Acceptance of the
Remedy
2. Decision Summary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit or Response
Action
Site Characteristics
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DRAFT
Summary of Site Risks
-Description of Alternatives
Summary of Comparative Analysis of
Alternatives
Selected Remedy
*Statutory Determinations
Summary of Basis for No Action Decision: The
rationale for the no action decision should be
provided. The remedial alternatives that were
considered, and the impact associated with them
or their feasibility, should be summarized in
this discussion. A detailed comparative analysis
using the nine evaluation criteria need not be
included. A statement should also be included
to the effect that this no action decision does
not constitute a finding that adequate protection
of human health and the environment has been
achieved at the site.
Explanation of Significant Changes
3. Responsiveness Summary
II. DOCUMENTING INTERIM ACTION
DECISIONS
During scoping, or at other points in the RI/FS,
the lead agency may determine that an interim
action should be taken either to respond to an
immediate site threat or to take advantage quickly
of an opportunity to reduce risk at a site. Interim
actions are limited in scope and are followed by
other operable units that complete the steps to
provide definitive protection of human health and
the environment for the long term. Highlight 3
Highlight 3
EXAMPLES OF INTERIM
ACTION DECISIONS
Constructing a fence to restrict access to
the site;
Pumping a ground-water aquifer to
restrict migration of a contaminant
plume;
Providing an alternative source of
drinking water; and
Constructing a temporary cap.
provides specific examples of types cT interim
action decisions.
Interim actions should not be confused with
final actions that are limited in scope. A limited
final action is the last action to be taken at or on
a limited portion of the site to ensure that
protection of human health and the environment
has been achieved. The ROD used for these
actions should be a streamlined version of the
standard ROD format shown in Highlight 1. An
interim action is an action that must be followed
by a subsequent action (and ROD) to achieve
definite protection of human health and the
environment at a portion of a site. In an Interim
Action ROD, an outline of which follows this
discussion, the "Summary of Site Risks" discussion
may be very brief, providing information to support
the need to take action but usually not specifying
final acceptable exposure levels for the site. The
findings of the baseline risk assessment should be
included in the decision documents for future, final
operable units. The number of alternatives
considered for interim actions should generally be
limited to three or fewer, and the nine-criteria
evaluation should be limited to addressing factors
pertinent to the scope and purpose of the interim
action.
INTERIM ACTION ROD FORMAT
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of Selected Remedy
Statutory Determinations: The declaration
statement should read as follows:
This interim action is protective of human health
and the environment, complies with Federal and
State applicable or relevant and appropriate
requirements directly associated with this action,
and is cost-effective. This action utilizes
permanent solutions and alternative treatment (or
resource recovery) technologies, to the maximum
extent practicable, given the limited scope of the
action. Because this action does not constitute
the final remedy for the [site/operable unit], the
statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume
as a principal element [will not be satisfied by
this interim action (or) will be addressed by the
-------
DRAFT
final response action]. Subsequent actions are
planned to address fully the principal threats
posed by the conditions at this /site/operable
unit].
Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
Site Name, Location, and Description
ฎ Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit: This section
provides the rationale for taking the limited
action. To the extent that information is
available, the section should detail how the
response action fits into the overall site
strategy. This section should state that the
interim action will be consistent with any
planned future actions, to the extent possible.
Site Characteristics: This section should focus
on the description of those site characteristics
to be addressed by the interim remedy.
Summary of Site Risks: This section should
focus on risks addressed by the interim action
and should provide the rationale for the limited
action. This could be supported by facts that
indicate that action is necessary to stabilize the
site, prevent further degradation, or achieve
significant risk reduction quickly. Qualitative
risk information may be presented if
quantitative risk information is not yet
available, which will often be the case.
Description of Alternatives: This section should
describe only the limited alternatives that were
considered for the interim action. Applicable
or relevant and appropriate requirements
(ARARs) associated with the limited action
should be incorporated into the description of
alternatives.
Summary of Comparative Analysis of
Alternatives: The comparative analysis should
be presented in light of the limited scope of the
action. Criteria not relevant to the evaluation
of interim actions need not be addressed in
detail. Rather, their irrelevance to the decision
should be noted briefly.
Selected Remedy
Statutory Determinations: The interim action
should protect human health and the
environment from the exposure pathway or
threat it is addressing, any releases generated,
or the waste material that is managed. The
ARARs discussion should focus only on those
ARARs specific to the interim action - those
related to any final disposition of waste, off-site
treatment or disposal, or released caused during
implementation. An interim remedy waiver may
be necessary in some situations. However, if an
interim waiver is needed, the final remedy must
comply with this requirement The discussion
under "utilization of permanent solutions and
treatment to the maximum extent practicable"
should indicate that the selected remedy
represents the best balance of tradeoffs among
alternatives with respect to pertinent criteria,
given the limited scope of the action. The
discussion under the preference for treatment
section should note that the preference will be
addressed in the final decision document for the
site or operable unit
Explanation of Significant Changes
3. Responsiveness Summary
III. DOCUMENTING CONTINGENCY
REMEDIES
In some limited cases, the lead agency may
determine that to ensure implementation of the
most appropriate remedy, a ROD will be prepared
with a selected remedy that is accompanied by a
contingency remedy. The contingency remedy may
be appropriate to use in the following cases:
(1) when an innovative treatment technology
appears to be the most appropriate remedy for the
site, although further testing is needed during
remedial design to verify its potential effectiveness;
and (2) when two different technologies appear to
offer comparable performance on the basis of the
five primary balancing criteria, and neither one
offers the better balance of tradeoffs. Highlight 4
provides specific examples of contingency remedies,
which typically involve treatment categories, rather
than specific technology process options.
In general, the lead agency identifies a preferred
alternative in the Proposed Plan and selects a
single remedy in the ROD. When selecting a
treatment technology to address the source of
contamination, this typically involves selection of a
treatment class or family, (i.e.,thermal destruction),
rather than a specific technology process option
(i.e., rotary kiln). Selection of a treatment class
affords the lead agency flexibility during the remedy
-------
DRAFT
Highlight 4
CIRCUMSTANCES WHERE CONTINGENCY
REMEDIES MAY BE APPROPRIATE
An innovative treatment technology may
appear to be the most appropriate
remedy for a site or operable unit
during the RI/FS, but more testing is
needed during remedial design to verify
the technology's expected performance
potential. If there are uncertainties
about an innovative treatment
technology, then the lead agency, in
consultation with the support agency,
may elect to include a proven technology
as a contingency remedy in the ROD.
Where two different technologies under
consideration appear to offer comparable
performance on the basis of the five
primary balancing criteria, such that both
could be argued to provide the "best
balance of tradeoffs." Under such
circumstances, the ROD may identify
one as the selected remedy and the
other as a contingency remedy and
specify the criteria whereby the
contingency remedy would be
implemented.
remedy design to procure the most cost-effective
process through competitive bidding. There are
limited situations, however, where additional
flexibility may be required to implement the most
appropriate treatment remedy for a site. In such
situations, the lead agency may determine a ROD
with a selected remedy and a contingency remedy
is appropriate.
CONTINGENCY REMEDY ROD FORMAT
1. Declaration
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Selected Remedy: Both the
selected remedy and the contingency remedies
should be described in bullet form.
Statutory Determinations: The Declaration
should be modified to indicate that both the
selected remedy and the contingency remedy will
meet the statutory findings.
Signature and Support Agency Acceptance of
the Remedy
2. Decision Summary
Site Name, Location, and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit or Response
Action
Site Characteristics
Summary of Site Risks
Description of Alternatives: This section should
identify any uncertainties about the use of the
technologies being considered, and the extent
additional testing is needed. The selected
remedy and the contingency remedy must be
fully described.
Summary of Comparative Analysis: The
selected remedy and any contingency alternative
should be evaluated fully against the nine
criteria. The uncertainties should be noted, as
well as performance expectations. Id the
discussion of community (and support agency)
acceptance of an innovative technology, the
support of the interested parties should be
discussed in light of the CERCLA provisions in
Section 121(b)(2). Where alternatives are
chosen because they are comparable, the
analysis should provide support for the finding.
Selected Remedy: The selected and contingency
remedy should be identified. If an innovative
technology is identified as the preferred
alternative, this section should describe what
will happen if further testing determines that
the preferred alternative is not effective or
implementable. If comparable alternatives are
selected, each should be described in detail.
Statutory Determinations: The statutory
determination discussion should show that both
remedies fulfill CERCLA Section 121
requirements.
Explanation of Significant Changes
3. Responsiveness Summary
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive: 9355.0-27FS
April 1990
& EPA A Guide to Selecting
Superfund Remedial Actions
Office of Emergency and Remedial Response
Hazardous Site Control Division OS-220
INTRODUCTION
The Superfund program's rem-
edy selection process is the decision-
making bridge between the analy-
sis of remedial alternatives for clean-
ingup a site conducted in a remedial
investigation/feasibility study (RI7
FS) and the explanation of the se-
lected remedy that is documented
in a Record of Decision (ROD). This
fact sheet describes statutory re-
quirements for CERCLA remedies
and the process EPAhas established
in the 1990 revised National Con-
ingency Plan (55 FR ฃฃฃฃ (3/8/90))
or meeting these requirements.
This process is a general framework
for reaching a judgment as to the
most appropriate method of achiev-
EXHIBIT 1: PROGRAM EXPECTATIONS
ing protection of human health and
the environment at a particular site.
This framework can be streamlined
as appropriate to the site.
STATUTORYREQUIREMENTS
Section 121 of CERCLA man-
dates that the remedial action must:
1. Protect human health and the
environment;
2. Comply with applicable or rele-
vant and appropriate require-
ments (ARARs) unless a waiver
is justified;
3. Be cost-effective;
Quick Reference Fact Sheet
4. Utilize permanent solutions and
alternative treatment technolo-
gies or resource recovery tech-
nologies to the maximum ex-
tent practicable;
5. Satisfy the preference for treat-
ment as a principal element, ar
provide an explanation in the
ROD why the preference was
not met.
EPAhas established a national
goal and expectations reflecting
these requirements in the 1990 NCP
(Sec. 300.430(a)(l)(i) and (iii). The
NCP also defines nine criteria that
are to be used to compare remedial
alternatives, to establish the basis
for the selection decision, and to
>ฆ Containment will be considered for wastes that pose a relatively
lowlong-term threat or where treatment is impracticable. Those
include wastes that are near health-based levels, are substan-
tially immobile, or otherwise can be reliably contained over long
periods of time; wastes that are technically difficult to treat or
for which treatment is infeasible or unavailable; situations
where treatment-based remedies would result in greater over-
all risk to the human health or the environment during implem-
entation due to potential explosiveness, volatilization, or other
materials handling problems; or sites that are extraordinarily
large where the scope of the problem may make treatment of all
wastes impracticable, such as municipal landfills or mining
sites.
> Institutional controls are most useful as a supplement to engi-
neering controls for short- and long-term management. Institu -
tional controls (e.g. deed restrictions, prohibitions of well con-
struction) are important in controlling exposures during reme-
dial action implementation and as a supplement to long-term
engineering controls. Institutional controls alone should not
substitute for more active measures (treatment or containment)
unless such active measures are found to be impracticable.
>ฆ Innovative technologies should be considered if they offer the
potential for comparable or superior treatment performance,
fewer I lesser adverse impacts, or lower costs for similar levels of
performance than demonstrated technologies.
> Ground waters will be returned to their beneficial uses within
reasonable periods of time wherever practicable.
Protection of human health and the environment can be achieved
through a variety of methods: treatment to destroy or reduce the
inherent hazards posed by hazardous substances, engineering con-
trols (such as containment), and institutional controls to prevent ex-
posure to hazardous substances. The NCP sets out the types of
remedies that are expected to result from the remedy selection
process (Sec. 300.430(aXlXiii)).
>ฆ Treat principal threats, wherever practicable. Principal threats
for which treatment is most likely to be appropriate are
characterized as:
- Areas contaminated with high concentrations of toxic com-
pounds;
- Liquids and other highly mobile materials;
- Contaminated media (e.g., contaminated ground water,
sediment, soil) that pose significant risk of exposure; or
- Media containing contaminants several orders of magni-
tude above health-based levels.
>- Appropriate remedies often will combine treatment and con-
tainment. For a specific site, treatment of the principal
threat(s) may be combined with containment of treatment
residuals and low-level contaminated material.
April 1990 - 1
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Exhibit 2
Key Steps in the Development of Remedial Alternatives
Develop Preliminary Remediation Goals
Health-based remediation goals (eg . 10 * excess cancer rak e
point of departure, ARARs resulting in X ppm
Based on unlimited exposure for relevant land use
Define Action Area
>X ppm
Determine areas of contamination
that require remediaJ action
Identity Princpal Threats that are Candidates for Treatment
Treat liquids, highly toxic materials, highly mobile matenals
Exceptions include large municpal
landfills, areas where contaminants
are inaccessible, or other situations
where treatment is not impkementable
Identify Low-level Threats that are Candidates for Containment
I
Contain Treatment
Residuals and
Remaining Material
Exceptions
Small volumes
Sensitive exposure
Containment unreliable
Partially Treat
Fully Treat
Identify Remedial
Treat to levels that can
Treat to levels for
Alternatives lor
be reliably contained
which access
Detailed Analyses
restrictions are not
and Remedy
necessary
Selection
i
demonstrate that statutory require-
ments have been satisfied (Sec.
300.430(0(1)). Each of these as-
pects of EPA's remedy selection
approach are described below.
GOAL AND EXPECTATIONS
OF THE REMEDY SELECTION
PROCESS
The national goal of the remedy
selection process is "to select reme-
dies that are protective of human
health and the environment, that
maintain protection over time, and
that minimize untreated waste"
(NCP Sec. 300.430(a)(lXi)).
While protection of human
health and the environment can be
achieved through a variety of meth-
ods, this goal reflects CERCLA's em-
phasis on achieving protection
through the aggressive, but realis-
tic use of treatment. The 1990 NCP
presents EPA's expectations regard-
ing circumstances under which
treatment, as well as engineering
and institutional controls, are most
likely to be appropriate (Sec.
300.430(aXl)(iii), see Exhibit 1).
These expectations are intended pri-
marily to assist in focusing the de-
velopment of alternatives in the FS
(see The Feasibility Study: Devel-
opment and Screening of Alterna-
tives, OSWER Directive 9355.3-
01FS). These expectations do not
substitute for site-specific balanc-
ing of the nine criteria to determine
the maximum extent to which treat-
ment can be practicably used in a
cost-effective manner for a operable
unit.
Exhibit 2 illustrates the alter-
natives development process, as
shaped by the expectations. The
process begins with the identifica-
tion of preliminary remediation
goals, which provide initial esti-
mates of the contaminant concen-
trations/risk levels of concern. Based
on ARARs, readily available toxic-
ity information, and current and fu-
ture land use, preliminary remedia-
tion goals are initial health-based
levels and are used to define site ar-
eas that may require remedial ac-
tion (i.e., action areas). Areas on-
site with contaminant concentra-
tions several orders of magnitude
(e.g., 2) above these preliminary re-
mediation goals are candidate ar-
eas for treatment. Areas onsite with
contaminant concentrations within
several orders of magnitude of these
preliminary remediation goal levels
are candidate areasfor containment.
The remediation goals, action ar-
eas, and target treatment/contain-
ment areas are refined throughout
the RI/FS process as additional in-
formation becomes available. The
final determination of remediation
goals, action areas, and the appro-
priate degree of treatment and con-
tainment are made as part of the
remedy selection.
THE REMEDY SELECTION
PROCESS
Overview
The remedy selection process
begins with the identification of a
preferred alternative from among
those evaluated in detail in the FS
by the lead agency, in consultation
with the support agency. The pre-
ferred alternative is presented to
the public in a Proposed Plan that is
2 - OSWER Directive 9355.0-27FS
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EXHIBIT 3: NINE EVALUATION
CRITERIA
EPA has developed nine criteria to
be used to evaluate remedial alterna-
tives to ensure all important considera-
tions arc factored into remedy selection
decisions. These criteria are derived
from the statutory requirements of
Section 121, particularly the long-term
effectiveness and related considerations
specified in Section 121(bXl), as well as
other additional technical and policy
considerations that have proven to be
important for selecting among remedial
alternatives.
Threshold Criteria
The two most important criteria
are statutory requirements that must
be satisfied by any alternative in order
for it to be eligible for selection.
1. Overall protection of human health
and the environment addresses
whether or not a remedy provides
adequate protection and describes
how risks posed through each
exposure pathway(assuminga rea-
sonable maximum exposure) are
eliminated, reduced, or controlled
through treatment, engineering
controls, or institutional controls.
2. Compliance with applicable or rele-
vant and appropriate requirements
(ARARs) addresses whether a rem-
edy will meet all of the applicable
or relevant and appropriate require-
ments of other Federal and State
environmental laws or whether a
waiver can be justified.
Primary Balancing Criteria
Five primary balancing criteria are
used to identify major trade-ofTs between
remedial alternatives. These trade-ofTs
are ultimately balanced to identify the
preferred alternative and to select the final
remedy.
1. Long-term effectiveness and
permanence refers to the ability of a
remedy to maintain reliable protec-
tion of human health and the envi-
ronment over ti me, once cleanu p goals
have been met.
2. Reduction of toxicity, mobility, or
volume through treatment is the an-
ticipated performance of the treat-
ment technologies a remedy may
employ.
3. Short-term effectiveness addresses the
period of time needed to achieve pro-
tection and any adverse impacts on
human health and the environment
that may be posed during the con-
struction and implementation period,
until cleanup goals are achieved.
4. lmplementability is the technical and
administrative feasibility of a rem-
edy, including the availability of ma-
terials and services needed to imple-
ment a particular option.
5. Cost includes estimated capital and
operation and maintenance costs, and
net present worth costs.
Modifying Criteria
These criteria may not be considered
fully until after the formal publiccomment
period on the Proposed Plan and RI/FS
report is complete, although EPA works
with the State and community throughout
the project.
1. State acceptance addresses the sup-
port agency's comments. Where the
State or other Federal agency is the
lead agency, EPA's acceptance of the
selected remedy should be addressed
under this criterion. State views on
compliance with State ARARs are
especially important.
2. Community acceptance refers to the
public's general response to the alter-
natives described in the Pro posed Plan
and the RI/FS report.
The 1990 NCP at 55 FR 8719-23
describes how the detailed analysis of al-
ternatives is to be performed using these
criteria. The detailed analysis is the infor-
mation base upon which the remedy selec-
tion decision is made. Chapter 7 of the
"Interim Final Guidance for Conducting
Remedial Investigations and Feasibility
Studies Under CERCLA" (October 1988)
provides further detail on the process.
issued for comment along with the
RI/FS. Upon receipt of public com-
ments on the Proposed Plan, the
lead agency consults with the sup-
port agency to determine if the pre-
ferred alternative remains the most
appropriate remedial action for the
site or operable unit. The final
remedy is selected and documented
in a Record of Decision.
Considering the Nine Criteria
The identification of a preferred
alternative and final selection of a
remedy is derived from considera-
tion of nine evaluation criteria in
three major steps, as described in
the 1990 NCP (Sec.
300.430(f)(l)(ii)(E)). The nine crite-
ria are presented in Exhibit 3. The
steps in which the criteria are con-
sidered are depicted in Exhibit 4
and discussed below.
Threshold Criteria
The first step of remedy selec-
tion is to identify those alternatives
that satisfy the threshold criteria.
Only those alternatives that pro-
vide adequate protection of human
health and the environment and
comply with ARARs (or justify a
waiver) are eligible for selection.
Alternatives that do not satisfy the
threshold criteria should not be
evaluated further.
Primary Balancing Criteria
The second step involves the
balancing of tradeoff's among pro-
tective and ARAR-compliant alter-
natives with respect to the five pri-
mary balancing criteria (and modi-
fying criteria, if known). In this
step, alternatives are compared with
each other based on their long-term
effectiveness and permanence, re-
duction in toxicity, mobility, or vol-
ume achieved through treatment,
implementability, short-term effec-
tiveness, and cost. The sequence in
which the criteria are generally con-
sidered, and pertinent considera-
tions related to each, are noted be-
low.
1. Long-term effectiveness and
permanence is a major theme of
CERCLA Section 121, and,
therefore, is one of the two most
important criteria used during
remedy selection to determine
the maximum extent to which
permanence and treatment are
practicable. This factor will
often be decisive where alterna-
tives vary significantly in the
types of residuals that will
remain onsite and/or their re-
spective long-term management
controls.
April 1990 - 3
-------
Exhibit 4
THRESHOLD
CRITERIA
BALANCING
CRITERIA
MODIFYING
CRITERIA
Yes
Yesj
Evaluate:
Long-term Effectiveness
Reduction of T.M.V.
Short-term Effectiveness
Implementability
Cost
T
Choose Preferred Alternative:
Balancing across Criteria
ฆ Emphasize Long-Term
Effectiveness and Reduction of
T.M.V.
2. Reduction in the toxicity, mobil-
ity, or volume of contaminants
achieved through the applica-
tion of treatment technologies
is the other criterion that will
be emphasized during remedy
selection in determining the
maximum extent to which per-
manent solutions and treatment
are practicable. Remedies that
use treatment to address mate-
rials comprising the principal
threats posed by a site are pre-
ferred over those that do not.
Treatment as part of CERCLA
remedies should generally
achieve reductions of 90 to 99
percent in the concentrations or
mobility of individual contami-
nants of concern. There will,
however, be situations where
reductions outside the 90 to 99
percent range will be appropri-
ate to achieve site-specific re-
mediation goals.
3. The short-term effectiveness of
an alternative includes consid-
eration of the time required for
each alternative to achieve pro-
tection, as well as adverse short-
term impacts that may be posed
by their implementation. Many
potential adverse impacts can
be avoided by incorporating
mitigative steps into the alter-
native. Poor short-term effec-
tiveness can weigh significantly
against an option and can, in
fact, result in an alternative
being rejected as unprotecti ve if
adverse impacts cannot be ade-
quately mitigated.
4. Implementability is particularly
important for evaluating reme-
dies at sites with highly hetero-
geneous wastes or media that
make the performance of cer-
tain technologies highly uncer-
tain. Implementability is also
significant when evaluating
technologies that are less proven
and remedies that are depend-
ent on a limited supply of facili-
ties (e.g. ,TSCA - permitted land
disposal facility), equipment
(e..g., in-situ vitrification units),
or experts.
5. Cost may play a significant role
in selectingbetween options that
appear comparable with respect
to the other criteria, particu-
larly long-term effectiveness and
permanence, or when choosing
among treatment options that
provide similar performance.
Cost generally will not be used
to determine whether or not
principal threats will be treated,
except under special circum-
stances that make treatment
impracticable (see expecta-
tions). Costcanneverbeusedto
pick a remedy that is not protec-
tive.
Modifying Criteria
If known at the completion of
the RI/FS, state (support agency)
and community acceptance of the
alternatives should be considered
with the results of the balancing
criteria evaluation to identify the
preferred alternative. After the
public comment period, state and
community acceptance are again
considered, along with any new in-
formation, and may prompt modifi-
cation of the preferred alternative.
4 - OSWER Directive 9355.0-27FS
-------
Exhibit 5
Relationship of the Nine Criteria to the Statutory Findings
^NjNECR^Ri^| STATUTORY FINDINGS |
PROTECTION OF HUMAN HEALTH
AND THE ENVIRONMENT
COMPLIANCE WITH ARARs
ฆ>- PROTECTION OF HUMAN HEALTH
AND THE ENVIRONMENT
ฆ>- COMPLIANCE WITH ARARs OR
JUSTIFICATION OF A WAIVER
COST-EFFECTIVENESS
UTILIZATION OF PERMANENT
SOLUTIONS AND TREATMENT OR
RECOVERY TO THE MAXIMUM
EXTENT PRACTICABLE ("MEP")
PREFERENCE FOR TREATMENT
AS A PRINCIPAL ELEMENT OR
EXPLANATION AS TO WHY
PREFERENCE NOT SATISFIED
Identification of a Preferred
Alternative
Once the relative performance
of the protective and ARAR-compli-
ant alternatives under each crite-
rion has been established, prelimi-
nary determinations of which op-
tions are cost-effective and which
alternatives utilize permanent so-
lutions and treatment technologies
to the maximum extent practicable
are made to identify the preferred
alternative. Exhibit 5 illustrates
the relationship between the nine
criteria and the statutory require-
ments for remedy selection.
Cost-effectiveness is determined
by comparing the costs of all alter-
natives being considered with their
iverall effectiveness to determine
hether the costs are proportional
lo the effectiveness achieved. Over-
all effectiveness for the purpose of
this determination includes long-
term effectiveness and permanence;
reduction of toxicity, mobility, and
volume through treatment; and
short-term effectiveness. More than
one alternative can be cost-effec-
tive.
The determination of which cost-
effective alternative utilizes perma-
nent solutions and treatment to the
maximum extent practicable is a
risk management judgment made
by the decisionmaker who balances
the tradeoffs among the alterna-
tives with respect to the balancing
criteria (and modifying criteria to
the extent they are known). As a
general rule, those criteria that dis-
tinguish the alternatives the most
will be the most decisive factors in
the balancing. See Exhibit 6 for a
summary of criteria likely to be im-
portant in certain site situations.
The alternative determined to pro-
vide the best balance of trade-offs,
as considered in light of the statu-
tory mandates and preferences, as
well as the NCP goal and expecta-
tions, is identified as the preferred
alternative and presented to the
public for comment in a Proposed
Plan.
Final Selection of Remedy
Upon receipt of public com-
ments, the preferred alternative is
reevaluated in light of any new in-
formation that has become avail-
able, including State and commu-
nity acceptance, if previously un-
known. This new information should
be considered to determine whether
an option other than the preferred
alternative better fulfills the statu-
tory requirements. The decision-
maker's final judgment is docu-
mented in a Record of Decision.
April 1990 - 5
-------
Exhibit 6
EXAMPLES OF PROMINENT CRITERIA AND EXPECTATIONS
FOR SELECTED SITE SITUATIONS
SITUATION
Small area of high levels of toxic contaminants
(e.g., lagoon, hot spots)
Highly mobi Ie contaminants (e.g., liquids, vola-
tiles, metals)
PROMINENT CRITERIA
Long-term effectiveness,
Reduction oftoxicity, mobility, or vol-
ume through treatment
Long-term effectiveness,
Reduction of mobility through treat-
ment
F.yPF.HTF.n RESUI.T OF REMEDY
SELECTION*
Treatment is preferred when highly toxic mate-
rial is a principal threat at a site
Treatment is preferred when highly mobile
material is a principal threat at a site
Very large volume of material contaminated
marginally above health-based levels (e.g., mine
tailings one order of magnitude above health-
based levels in soil)
Complex mixture of heterogeneous waste
without discrete hot spots (e.g., heterogeneous
municipal landfill waste)
Soils contaminated with high concentrations
ofVOCs
Contaminated ground water
Implementability,
Cost
Implementability,
Short-term effectiveness,
Cost
Long-term effectiveness,
Short-term effectiveness
Long-term effectiveness,
Short-term effectiveness
Containment may afford high level of long-term
effectiveness; treatment may be difficult to im-
plement because of insufficient treatment ca-
pacity for large volume of material, and cost of
treatment may be prohibitive due to large scope
of site
Treatment of heterogeneous waste often diffi-
cult or infeasible, reducing implementability;
containment avoids short-term impacts and un-
certainties associated with excavation; cost of
treatment may be prohibitive
In-situ treatment may be preferred over excava-
tion because of negative short-term impacts and
high cost of excavation
Ground waters should be returned to beneficial
use as soon as is practicable
* These are only examples and have been highly simplified for illustration purposes. They are not intended to prescribe certain remedies
for certain situations.
NOTICE: The policies set out in this memorandum are intended solely for the guidance of Government personnel They are not intended, nor can they be relied
upon, to create any rights enforceable by any party in litigation with the United States. EPA officials may decide to follow the guidance provided in this
memorandum, or to act at variance with the guidance, based on an analysis of specific site circumstances Remedy selection decisions are made and justified on
a case-specific basis. The Agency also reserves the right to change this guidance at any time without public notice
6 - OSWER Directive 9355.0-27FS
-------
ฐ^P7"
CHECKLIST FOR RECORDS OF DECISIONS
I. The Declaration
o Site Name and Location
Does the ROD contain the name of the site as it
appears on the National Priorities List (NPL)?
Does the ROD contain the name of the town or county
and the State in which the site is located?
o Statement of Basis and Purpose
Does the ROD contain the following standard language?
"This decision document presents the selected remedial
action for the (site name). in (location). which was
chosen in accordance with CERCLA, as amended by SARA,
and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the administrative record for
this site."
"The State/Commonwealth of concurs with the
selected remedy."
o Assessment of the Site
Does the ROD contain the following standard language?
"Actual or threatened releases of hazardous substances
from this site, if not addressed by implementing the
response action selected in this Record of Decision
(ROD), may present an imminent and substantial
endangerment to public health, welfare, or the
environment.11
o Description of the Selected Remedy
Does the ROD include a description of the role of this
operable unit within the overall site strategy?
Does the description indicate whether the operable unit
addresses the principal threats posed by the
conditions at the site?
Does the ROD include a description of the major
components of the selected remedy in bullet fashion?
-------
Statutory Determinations
If the selected remedy satisfies the statutory
preference for treatment as a principal element (by
addressing the principal threats at the site with
treatment), does it contain the following standard
language?
"The selected remedy is protective of human health and
the environment, complies with Federal and State
requirements that are legally applicable or relevant
and appropriate to the remedial action [or "a waiver
can be justified for whatever Federal and State
applicable or relevant and appropriate requirement that
will not be met"], and is cost-effective. This remedy
utilizes permanent solutions and alternative treatment
(or resource recovery) technologies, to the maximum
extent practicable, and satisfies the statutory
preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal
element."
If the remedy does not satisfy the preference for
treatment as a principal element, does it contain the
following standard language?
(Repeat standard psrt) "However, because treatment of
the principal threats of the site was not found to be
practicable, this remedy does not satisfy the
statutory preference for treatment that as a principal
element."
If hazardous substances will remain on-site above
health-based levels, does the ROD contain the
following standard language?
"Because this remedy will result in hazardous
substances remaining on-site above health-based
levels, a review will be conducted within five years
after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of
human health and the environment."
If hazardous substances will not remain on-site above
health-based levels, does the ROD contain the
following standard language?
"Because this remedy will not result in hazardous
substances on-site above health-based levels, the
five-year review will not apply to this action."
x
-------
II. The Decision SinrnnaTy
o Site Name, Location, and Description
Does the ROD include a description of the site in
terms of the following factors?
name, location, and address of the site;
area and topography of the site (especially if the
site is located within a floodplain or wetlands);
adjacent land uses;
natural resource uses;
general surface-water and ground-water resources;
location of and distance to nearby populations; and
surface and subsurface features (e.g., number and
volume of tanks, lagoons, drums, or other
structures).
Does the ROD include maps, a site plan, or other
graphic descriptions?
o Site History and Enforcement Activities
Does the ROD include a history of the site activities
that led to current problems?
Does the ROD include a history of Federal and State
site investigations, removal actions, and remedial
actions conducted under the CERCLA or other statutory
authorities?
Does the ROD include a history of CERCLA enforcement
activities at the site, including:
the results of searches for PRPs?
whether special notices have been issued?
o Highlights of Community Participation
Does the ROD summarize how the public participation
requirements of CERCLA sections 113(k)(2)(B)(i-v) and
117 were met in the remedy selection process?
o Scope and Role of Operable Unit [(or Response Action)]
Within Site Strategy
Does the ROD include a description of the role of this
remedial action within the overall site clean-up
strategy?
Does the ROD summarize the scope of the problems
addressed by the remedial action selected?
-------
Does the ROD describe whether or not the action will
address any of the principal threats posed by
conditions at the site?
Summary of Site Characteristics
Does the ROD indicate all known or suspected sources
of contamination at the site?
Does the ROD include a description of the following
information related to the contamination and affected
media?
types and characteristics (e.g., toxicity,
mobility, carcinogenicity) of contaminants?
volume of contaminated material?
concentrations of contaminants?
Does the ROD include a description of the location of
contamination and known or potential routes of
migration, including the following factors?
population and environmental areas that could be
affected, if exposed?
lateral and vertical extent of contamination?
potential surface and subsurface pathways of
migration?
Does the ROD include maps, charts, tables, or other
graphic descriptions of contaminants and affected
media?
Summary of Site Risks
Does the ROD summarize the results of the baseline risk
assessment conducted for the site?
Does the ROD include a description of the following
factors related to human health risks?
concentrations of the contaminants chemicals) of
concern in each medium of exposure?
results of the exposure assessment?
results of the toxicity assessment of contaminants
of concern?
results of the risk characterization for each
population by each pathway and the total risk for
the site?
potential or actual carcinogenic risks
non carcinogenic risks
explanation of key risks times
//
-------
Does the ROD include, where appropriate, a description
of the following factors related to environmental
risks?
effects of the contamination on critical
habitats?
effects of the contamination on any endangered
species?
Description of Alternatives
Does the ROD include a description of the treatment
components of each remedial alternative, including the
following?
treatment technologies that will be used?
type and volume of waste to be treated?
process sizing?
primary treatment levels (e.g., best demonstrated
available technology [BDAT], percentage or order
of magnitude of concentration reductions
expected?
Does the ROD include a description of the containment
or storage components of each remedial alternative,
including the following:
type of storage (e.g., landfill, tank, surface
impoundment)?
type of closure that will be implemented (e.g.,
RCRA Subtitle C clean closure, landfill closure,
Subtitle D solid waste closure)?
type and quantity of waste to be stored?
quantity of untreated waste and treatment residuals
to be disposed of off-site or managed on-site in a
containment system (e.g., cap, minimum-technology
unit) and the degree of hazard remaining in such
waste)?
Does the ROD include a description of the ground-water
components of each remedial alternative (if
appropriate), including the following?
ground-water classification (e.g., Class I, II, or
III)?
remediation goals (e.g., maximum contaminant
levels [MCLs] to be achieved)?
estimated restoration timeframe?
area of attainment?
-------
Does the ROD include a description of the general
components of each remedial alternative, including the
following?
quantities of contaminated media addressed (and
physical location at the site)?
expected risk reduction to be achieved?
whether treatability testing has been or will be
conducted?
implementation requirements
use of institutional controls?
residual levels (e.g., delisting, BDAT)?
implementation requirements?
whether treatability testing has been or will be
conducted?
estimated implementation timeframe?
estimated capital, operation and maintenance
(O&M), and present-worth costs?
assumptions and uncertainties?
Does the ROD include a description of the major
applicable or relevant and appropriate requirements
(ARARs) and other standards "to be considered" (TBCs)
being met/utilized for the specific components of the
waste management process of each remedial alternative,
including the following?
how the specific components of each will or will
not comply with the major ARARs?
why the standard is applicable or relevant and
appropriate for each alternative?
whether RCRA Land Disposal Restrictions are
ARARs?
Summary of Comparative Analysis of Alternatives
Does the ROD highlight the key differences among the
alternatives in relation to the nine criteria?
Overall protection of human health and the
environment: addresses whether a remedy provides
adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or
controlled through treatment, engineering
controls, or institutional controls;
Compliance with ARARs: addresses whether a
remedy will meet all of the ARARs of other
Federal and State environmental laws and/or
justifies use of a waiver.
Long-term effectiveness and permanence:
addresses the expected residual risk and the
ability of a remedy to maintain reliable
-------
protection of human health and the environment
over time, once clean-up goals have been met;
Reduction of toxicity, mobility, or volume
through treatment: addresses the anticipated
performance of the treatment technologies the
remedy may employ;
Short-term effectiveness; addresses the period of
time needed to achieve protection and any adverse
impacts on human health and the environment that
may be posed during the construction and
implementation period (i.e., until clean-up goals
are achieved);
Implementabilitv: addresses the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option; and
Cost: addresses the estimated capital and O&M
costs, as well as a present-worth.
State/support agency acceptance: addresses the
support agency's comments and concerns. (Where the
State or Federal agency is the lead agency for the
ROD, EPA's acceptance of the selected remedy
should be addressed under this criterion);
Community acceptance: addresses the public's
comments on and concerns about the Proposed Plan
and RI/FS report. (The specific responses to
public comments should be addressed in the
Responsiveness Summary section of the ROD).
The Selected Remedy
Does the ROD identify the selected remedy
Does the ROD identify remediation goals for the
selected remedy?
Does the ROD describe the carcinogenic risk level that
the selected remedy will attain and the rationale for
selecting that level?
Does the ROD identify the specific points of
compliance, as appropriate, for the media addressed by
the selected remedy (e.g., "MCLs will be met at the
edge of the waste-management area")?
-------
Statutory Determinations
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
protect human health and the environment, as follows?
A description of how the selected remedy will
eliminate, reduce, or control risks posed through
each pathway to each population through treatment,
engineering controls, or institutional controls,
to ensure adequate protection of human health and
the environment (including that the site risk will
be reduced to within the 10~4 to 10~6 risk range
for carcinogens, and that the Hazard Indices for
non-carcinogens will be less than one?
An indication that no unacceptable short-term
risks or cross-media impacts will be caused by
implementation of the remedy?
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
comply with ARARs, as follows?
A statement of whether the selected remedy will
comply with ARARs. When appropriate, the ROD
should state that a waiver that is being invoked
and justify the waiver. The ARARs should be
organized as chemical-specific, location-specific,
and action-specific?
A list and description of the Federal and State
ARARs that the selected remedy will attain,
distinguishing applicable from relevant and
appropriate requirements, as necessary?
A listing and the rationale for using any TBCs?
Does the ROD describe how the selected remedy provides
overall effectiveness proportionate to its costs, such
that it represents a reasonable value for the money to
be spent (i.e., is cost-effective).
Does the ROD document how the selected remedy
satisfies the requirement of CERCLA section 121 to
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable, as follows?
A description of the rationale for the remedy
selection, including a statement that the remedy
selected provides the best balance of tradeoffs
among the alternatives with respect to the
evaluation criteria, especially the five balancing
criteria?
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_ A discussion of those criteria that were most
critical in the selection decision (i.e., those
criteria that distinguish the alternatives most)?
_ Emphasis on the tradeoffs among the alternatives
with respect to the five balancing criteria?
_ A description of the role of the State and
community acceptance considerations (i.e.,
modifying criteria)in the decision-making
process?
_ A general statement that the selected remedy meets
the statutory requirement to utilize permanent
solutions and treatment technologies to the
maximum extent practicable?
Does the ROD document how the selected remedy
satisfies the preference of CERCLA section 121 for
treatment as a principal element, as follows?
If the remedy uses treatment to address the
principal threat(s) posed by conditions at the
site, a description of how the preference for
treatment is satisfied? or
If treatment is not used to address the principal
threats, an explanation of why the preference is
not satisfied. This explanation will refer back
to the explanation under the "maximum extent
practicable" finding of why treatment of the
principal threats was found to be either
impracticable or not within the limited scope of
the response action.
o Documentation of Significant Changes
Does the ROD identify the preferred alternative
originally presented in the Proposed Plan?
Does the ROD describe any significant changes and
explain the reasons for them, as required by CERCLA
section 117(b)?
III. The Responsiveness SnmmarY
Does the ROD contain information about (1) community
preferences regarding the remedial alternatives; and
(2) general public concerns about the site?
Does the ROD contain the comments of the public,
including PRPs, on key Agency documents related to the
site cleanup, as well as the Agency response to those
comments?
1
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CHECKLIST FOR PROPOSED PLANS
I. INTRODUCTION
Does the introduction state the site name and location,
identify the lead and support agencies, and state that
the Proposed Plan:
fulfills requirements of CERCLA section 117(a)?
describes remedial alternatives analyzed?
identifies preferred alternative and explains
rationale for preference?
highlights key information in the RI/FS and
administrative record?
solicits community involvement in the selection of
remedy?
invites public comment on all alternatives?
II. SITE BACKGROUND
Does the Proposed Plan provide a brief description of the
site, including:
history of site activities leading to current
problems?
site area or media to be addressed by the selected
remedy?
III. SCOPE/ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Are the principal threats posed by conditions at the
site identified?
Is the scope of the problems addressed by the preferred
alternative and its role within the overall site clean-up
strategy discussed?
IV. SUMMARY OF SITE RISKS
Is a brief overview of results of the baseline risk
assessment presented?
Are current risks compared against remediation goals?
Are environmental risks addressed?
-------
V. SUMMARY OF ALTERNATIVES
Is each alternative adequately described by highlighting
the following:
treatment/engineering components and quantities of
waste related to each component
institutional controls
implementation time/requirements
estimated construction and O&M costs (including
present worth)
major ARARs
VI. EVALUATION OF ALTERNATIVES & THE PREFERRED ALTERNATIVE
Is the preferred alternative identified and is it
emphasized that selection of this alternative is
preliminary and could change as a result of public
comments or new information?
Are the nine criteria used to evaluate alternatives
described?
Is the expected performance of the preferred alternative
(in terms of the nine criteria) discussed, explaining how
the preferred alternative compares to the other
alternatives?
Does discussion present the lead agency's preliminary
determination that the preferred alternative provides the
best balance of tradeoffs with respect to the nine
criteria, and that it is anticipated to meet the
following statutory requirements:
protect human health and the environment
comply with ARARs (or justify a waiver)
be cost-effective
utilize permanent solutions and alternative treatment
or resource recovery technologies, to the maximum
extent practicable
satisfy the statutory preference for treatment as a
principal element, or justify not meeting the
preference
VII. COMMUNITY PARTICIPATION
Does the plan provide information that helps public
understand how they can be involved, including:
notice of the dates of the public comment period
date, time, and location of public meeting(s) planned
names, numbers, and addresses of lead and support
agency contacts to whom comments should be sent
whether a special notice has been issued to PRPs
location of the administrative record and other
information repositories
-------
RECORD OF DECISION (ROD) GUIDANCE FOR
SELECTING AND DOCUMENTING GROUND WATER
EXTRACTION REMEDIES
$
\
ml
PRO"^ฐ
T)
w
U
Office of Emergency and Remedial Response
Directive No. 9355.4-03
October 1989
-------
OVERVIEW OF GROUND WATER
EVALUATION
A. Study Findings
B. Study Recommendations
C. Recommended Language for Ground Water Records of Decision
(RODs)
-------
A. STUDY FINDINGS
1. Extraction systems are generally effective in containing contaminant
plumes
2. Extraction systems can achieve significant mass removal of
contaminants
3. Concentrations of contaminants generally decrease significantly after
extraction is initiated, but tend to level off after a period of time. This
leveling off usually occurs at concentrations above the cleanup goals or
concentrations expected at that point in time
4. Data collection was insufficient to fully assess contaminant movement
and system response to pumping
-------
STUDY FINDINGS
(continued)
Factors which limit the effectiveness of extraction systems include:
1. Hydrogeological factors, such as subsurface heterogeneities
2. Contaminant-related factors, such as soil sorption/desorption
processes, presence of non-aqueous phase liquids (NAPLs)
3. Continued leaching from source areas, such as contaminated
soils
4. System design parameters, such as pumping rate, placement of
wells and well screens
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B. STUDY RECOMMENDATIONS
1. Initiate early response measures to contain the ground water plume and prevent
further migration of contaminants. This can be achieved through:
a. Early Action Record of Decision; or
b. Interim Action Record of Decision
5
-------
STUDY RECOMMENDATIONS
(continued)
2. Indicate the degree of uncertainty associated with the selected remedy
Provide enough flexibility in the remedy to allow modifications to the system in
response to new information obtained during its operation
a. Final Action Record of Decision (low uncertainty)
b. Contingency Record of Decision (moderate to high uncertainty) and
Explanation of Significant Difference
i Change in Selected Remedy
ii. Change in Remedial Goals (ARARs waiver)
c. Interim Record of Decision (high uncertainty)
i. Phased system design
ii. Review remedy and goals at specified intervals
-------
STUDY RECOMMENDATIONS
(continued)
3. Collect data that will allow evaluation of contaminant behavior, and assessment
of extraction effectiveness, such as information on:
a. Detailed vertical variations in stratigraphy
b. Contaminant-soil interactions (sorption/desorption) in the unsaturated
and saturated zones
7
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C. RECOMMENDED LANGUAGE FOR
GROUND WATER RODS
Study findings indicate that it is often difficult to predict the ultimate concentrations
to which contaminants in ground water may be reduced until an extraction system
has been operating for some period of time
RODs should indicate the amount of uncertainty believed to be associated with
achieving health-based remediation goals in ground water at a particular site
-------
RECOMMENDED LANGUAGE FOR
GROUND WATER RODS
(continued)
Final Action RODs
Contingency measures and goals
Interim Action RODs
Early Action RODs
-------
FINAL ACTION RODS (low uncertainty)
A final remedy may be specified in the ROD if there is little uncertainty that the
remedy will be able to achieve health-based levels of contaminants throughout the
area of attainment
The "Selected Remedy" section for a Final Action ROD should include language that:
1. Recognizes the potential technical impracticability of the selected extraction and
treatment system; and
2. Describes recommended modifications to that system which may improve its
performance, such as:
i. discontinuing operation in certain areas
ii. alternating pumping
iii. pulse-pumping
10
-------
CONTINGENCY MEASURES AND GOALS
(high to moderate uncertainty)
J
Information may emerge from the operation of the extraction system
that strongly suggests that it is technically impracticable to achieve
health-based levels throughout the area of attainment
If this is considered likely, the ROD should provide for contingency
measures, which may involve changing both the remedy and the
remedial goals
11
-------
CONTINGENCY MEASURES AND GOALS
(high to moderate uncertainty)
(continued)
The "Selected Remedy" section of a Contingency ROD should include language that:
1. Recognizes the potential technical impracticability of the selected extraction and
treatment system; and
2. Describes recommended modifications to that system which may improve its
performance if the selected remedy cannot meet remedial goals
3. Describes the criteria for implementing contingency measures
a. hydrogeological or contaminant-specific data that call into question the
ability of the primary remedy to achieve health-based goals
b. an observed "leveling-off of contaminant concentrations before health-based
goals have been reached
-------
4. Describes the actual contingency measures which will modify the existing
system if portions of the aquifer cannot be restored to its beneficial use after a
reasonable period of time
a. institutional controls to restrict access to contaminated ground water
b. an ARARs waiver for those portions of the aquifer that remain
contaminated
c. low-level pumping to restrict plume migration
Any contingency remedy or measures discussed in the "Selected Remedy" section of
the ROD must be accompanied by supporting language in the "Comparative Analysis
of Alternatives" and "Statutory Determinations" sections
13
-------
INTERIM ACTION ROD (high uncertainty)
An Interim Action ROD should be specified when there is substantial uncertainty
regarding the ability of a remedy to restore contaminant concentrations in ground
water to health-based levels
The purpose of the remedy is to restrict plume migration and initiate ground water
restoration
An Interim Remedy is not a final action for the ground water
14
-------
INTERIM ACTION ROD (high uncertainty)
(continued)
An Interim Action ROD should include language that:
1. Recognizes the potential technical impracticability of the
selected extraction and treatment system
2. States the interim goals of the remedy
3. Specifies the period of time before system performance is
reviewed and a Final Action ROD is prepared
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EARLY ACTION ROD
(Subset of Interim Action ROD)
At some point during the project scoping or RI/FS, it may be determined that an
operable unit should be implemented immediately to prevent further migration of a
contaminant plume. An Interim Action ROD should be prepared specifically to
implement early containment measures, and should include language that:
1. Describes the limited goals (i.e., containment) of the action
2. Describes the anticipated time period covered by the action
3. States that MCLs/MCLGs are not ARARs for this action
16
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I UNITED STATES ENVIRONMENTAL PROTECTION AGtNCY
v WASHINGTON, D.C 20460
f*L PHO^
OCT I 8 1989 Directive No. 9355.4-03
OFF'CE OF
SOLID WASTE AND EMERGENC" P ESP ON
MEMORANDUM
SUBJECT:
FROM:
TO:
Considerations in Ground Water Remediation at Superfund
Sites /
Pi ah ^2,
istant Administrator
Jonatfiah'"Z
Acting Ass
. uannon
Waste Management Division Directors
Regions I, IV, V, VI, VII, VIII
Emergency and Remedial Response Division Director
Region II
Hazardous Waste Management Division Directors
Region III, IX
Hazardous Waste Division Director
Region X
Purpose
The purpose of this memorandum is to transmit our findings
from a recently completed study of several sites where ground
water extraction is being conducted to contain or reduce levels of
contaminants in the ground water. In addition, this memorandum
presents several recommendations for modifying the Superfund
approach to ground water remediation.
Background
The most common method for restoring contaminated ground
water is extraction and treatment of contaminated ground water.
Recent research has suggested that in many cases, it may be more
difficult than is often estimated to achieve cleanup concentration
goals in ground water. In response to these findings, the Office of
Emergency and Remedial Response (OERR) initiated a project to
assess the effectiveness of ground water extraction systems in
achieving specified goals. Nineteen case studies were developed
from among Superfund and State-lead sites, RCRA and Federal
facilities. These sites were selected primarily on the basis that
the ground water extraction systems had been operating for a period
of time sufficiently long to allow for an evaluation of the system.
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2
Obi ective
The objective of this memorandum is to describe the findings
of this study and to recommend the consideration of certain
factors and approaches in developing and implementing ground water
response actions at Superfund sites.
Findings of Study
Several trends were identified from the case studies:
o The extraction systems are generally effective in
containing contaminant plumes, thus preventing further
migration of contaminants.
o Significant mass removal of contaminants (up to 130,000
pounds over three years) is being achieved.
o Concentrations of contaminants have generally decreased
significantly after initiation of extraction but have_
tended to level off after a period of time. At the sites
examined, this leveling off usually began to occur at
concentrations above the cleanup goal concentrations
expected to have been attained at that particular point
in time.
o Data collection was usually not sufficient to fully
assess contaminant movement and system response to
extraction.
Several factors appear to be limiting the effectiveness of
the extraction systems examined, including:
o Hydrogeological factors, such as the heterogeneity of the
subsurface, the presence of low permeability layers, and
the presence of fractures;
o Contaminant-related factors, such as sorption to the
soil, and presence of non-aqueous phase liquids
(dissolution from a separate non-aqueous phase or
partitioning of contaminants from the residual non-
aqueous phase);
o Continued leaching from source areas?
o System design parameters, such as pumping rate, screened
interval, and location of extraction wells.
The report summarizing the study and findings, entitled
Evaluation of Ground Water Extraction Remedies is attached.
Additional copies of the report are available through the Public
Information Center ((202) 382-2080) or the Center for
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3
Environmental Research Information (FTS 684-7391 or (513) 569-
7391).
Recommendations
The findings of the study substantiate previous research and
confirm that ground water remediation is a very new, complex
field. Based on this study, I am recommending consideration of
certain factors and approaches in developing and implementing
ground water response actions. The major recommendation is to
orient our thinking so that we initiate early action on a small
scale, while gathering more detailed data prior to committing to
full-scale restoration. These recommendations are consistent
with the Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites and do not alter Superfund's primary
goal of returning ground water to its beneficial uses in a time
frame that is reasonable given the particular site circumstances.
The recommendations do, however, encourage the collection of data
to allow for the design of an efficient cleanup approach that
more accurately estimates the time frames required for
remediation and the practicability of achieving cleanup goals..
While standard procedures for the more refined data
collection techniques suggested below are being developed, it
will be beneficial at most sites to implement the ground water
remedy in stages. This might consist of operating an extraction
system on a small scale that can be supplemented incrementally as
information on aquifer response is obtained.
These recommendations are described further below. The
attached flow chart illustrates how the recommendations fit into
the Superfund ground water response process.
Recommendation 1: Initiate Response Action Early.
The bias for action should be considered early in the site
management process. Response measures may be implemented to
prevent further migration of contaminants if they will prevent
the situation from getting worse, initiate risk reduction, and/or
the operation of such a system would provide information useful
to the design of the final remedy. Because the data needed to
design a ground water containment system are often more limited
than that needed to implement full remediation, it will in a
number of cases be possible and valuable to prevent the
contaminant plume from spreading while the investigation to
select the remediation system progresses. The determination of
whether to implement a containment system should be based on
existing information, data defining the approximate plume
boundaries, hydrologic data, contaminants present, and
approximate concentrations, and best professional judgment.
Examples of situations where this type of action will probably be
warranted include sites where ground water plumes are migrating
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4
rapidly (e.g., highly permeable aquifers, mobile contaminants,
potential migration thorough fractures) and sites near drinking
water wells that are potentially affected by the plume.
A Record of Decision (ROD) for an interim remedy may be
prepared with a limited evaluation of alternatives that compares
the advantages of taking an early action to the possible
ramifications of waiting until the investigation has been
completed. The evaluation of this action should be included as
part of the scoping phase for the site and if determined to be
appropriate, implemented while the overall RI/FS is underway.
The RI/FS for the final action at the site should continue and
incorporate information gained from this early action. If a
containment action is implemented, the ground water flow should
be monitored frequently, immediately before, during, and
immediately after initiation of the action to obtain information
on system response.
It is also advisable to implement ground water remediation
systems in a staged process at sites where data collected during
the remedial investigation did not clearly define the parameters
necessary to optimize system design. This might consist of
installing an extraction system in a highly contaminated area and
observing the response of the aquifer and contaminant plume
during implementation of the remedy. Based on the data gathered
during this initial operation, the system could be modified and
expanded as part of the remedial action phase to address the
entire plume in the most efficient manner.
Recommendation 2: Provide Flexibility in the Selected Remedy to
Modify the System Based on Information Gained During Its
Operation.
In many cases it may not be possible to determine the
ultimate concentration reductions achievable in the ground water
until the ground water extraction system has been implemented and
monitored for some period of time. Records of Decision should
indicate the uncertainty associated with achieving cleanup goals
in the ground water.
In general, RODs should indicate that the goal of the action
is to return the ground water to its beneficial uses; i.e.,
health-based levels should be achieved for ground water that is
potentially drinkable. In some cases, the uncertainty in the
ability of the remedy to achieve this goal will be low enough
that the final remedy can be specified without a contingency.
However, in many cases, it may not be practicable to attain that
goal, and thus it may be appropriate to provide in the ROD for a
contingent remedy, or for the possibility that this may only be
an interim ROD. Specifically, the ROD should discuss the
possibility that information gained during the implementation of
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5
the remedy may reveal that it is technically impracticable to
achieve health-based concentrations throughout the area of
attainment, and that another remedy or a contingent remedy may be
needed.
Where sufficient information is available to specify an
alternative or contingent remedy at the time of remedy selection,
the ROD should discuss the contingency in equal detail to the
primary remedial option, and should provide substantive criteria
by which the Agency will decide whether or not to implement the
contingency. See Interim Final Guidance on Preparing Superfund
Decision Documents, OSWER Directive 9355.3-02 (May 1989), at page
9-17.1 The ROD may also discuss the possibility that an ARARs
waiver will be invoked when MCLs or other Federal or State
standards cannot practicably be attained in the ground water; a
written waiver finding should be issued at the time the
contingency is invoked, or in limited circumstances, in the ROD
itself.2
The public should be informed of the decision to invoke the
contingency (and, perhaps, the waiver) through issuance of an
Explanation of Significant Differences (ESD) which involves a
public notice. A formal public comment period is not required
when a decision is made to invoke a contingency specified in the
ROD; however, the Region may decide to hold additional public
comment periods pursuant to NCP section 300.825(b) (proposed)
(Dec. 21, 1988, 53FR at 51516). In any event, the public may
submit comments after ROD signature on any significant new
information which "substantially support[s] the need to
significantly alter the response action" NCP Section 300.825(c)
(proposed).
There may also be situations where the Region finds that it
is impracticable to achieve the levels set out in the ROD, but no
contingency had been previously specified in the ROD. In such
cases, a ROD amendment would be necessary to document fundamental
changes that are made in the remedy based on the information
gained during implementation; an ESD would be necessary to
1 For instance, the ROD may provide that a contingent
remedy will be implemented if there is a levelling-off of
contaminant concentrations despite continued ground water
extraction over a stated period of time.
2 It may be possible to invoke a waiver at the time of ROD
signature (a "contingent waiver") where, for example, the ROD is
detailed and establishes an objective level or situation at which
the waiver would be triggered. However, the use of contingent
waivers should only be considered on a case-by-case basis after
discussion with 0ERR\0WPE.
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6
document significant but non-fundamental changes in the remedy
based on the additional information.
For sites where there is substantial uncertainty regarding
the ability of the remedy to return the ground water to its
beneficial uses (e.g., dense non-aqueous phase liquids in
fractured bedrock) it is appropriate to indicate that the initial
action is interim with an ultimate remedy to be determined at
some specified future date. The action should be designed to
achieve the basic goal and carefully monitored over time to
determine the feasibility of achieving this goal. In many of
these cases, this can only be determined after several years of
operation. The five year review may be the most appropriate time
to make this evaluation. When sufficient data have been
collected to specify the ultimate goal achievable at the site
(e.g., first or second five year review), a final ROD for ground
water would be prepared specifying the ultimate goal, including
anticipated time frame, of the remedial action.
Although overall system parameters must be specified in the
ROD, it is usually appropriate to design and implement the groi^nd
water response action as a phased process. An iterative process
of system operation, evaluation, and modification during the
construction phase can result in the optimum system design.
Extraction wells might be installed incrementally and observed
for one to three months to determine their effectiveness. This
will help to identify appropriate locations for additional wells
and can assure proper sizing of the treatment systems as the
range of contaminant concentrations in extracted ground water is
confirmed.
If it is determined that some portion of the ground water
within the area of attainment cannot be returned to its
beneficial uses, an evaluation of an alternate goal for the
ground water should be made. Experience to date on this phase of
ground water remediation is extremely limited and more definitive
guidance on when to terminate ground water extraction will be
provided later. When the point at which contaminant
concentrations in ground water level off, however, this should be
viewed as a signal that some re-evaluation of the remedy is
warranted. In many cases, operation of the extraction system on
an intermittent basis will provide the most efficient mass
removal. This allows contaminants to desorb from the soil in the
saturated zone before ground water is extracted providing for
maximum removal of contaminant mass per volume of ground water
removed.
Ground water monitoring should continue for two to three
years after active remediation measures have been completed to
ensure that contaminant levels do not recover. For cases where
contaminants remain above health-based levels, reviews to ensure
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7
that protection is being maintained at the site will take place
at least every five years.
Recommendation 3: Collect Data to Better Assess Contaminant
Movement and Likely Response of Ground Water to Extraction.
In addition to the traditional plume characterization data
normally collected, the following data is of particular
importance to the design and evaluation of ground water remedies
and should be considered in scoping ground water RI/FSs.
Assessments of contaminant movement and extraction effectiveness
can be greatly enhanced by collecting more detailed information
on vertical variations in stratigraphy and correlating this to
contaminant concentrations in the soil during the remedial
investigation. More frequent coring during construction of
monitoring wells and the use of field techniques to assess
relative contaminant concentrations in the cores are methods that
may be used to gain this information. More detailed analysis of
contaminant sorption to soil in the saturated zone can also
provide the basis for estimating the time frame for reducing
contaminant concentrations to established levels and identifying
the presence of non-aqueous phase liquids. Cores taken from
depths where relatively high concentrations of contaminants were
identified might be analyzed to assess contaminant partitioning
between the solid and aqueous phases. This might involve
measuring the organic carbon content and/or the concentration of
the contaminants themselves.
The long-term goal is to collect this information during the
RI so that more definitive decisions can be made at the ROD
stage. Standardized sampling and analytical methods to support
these analyses are currently being evaluated.
For further information, please consult the appropriate
Regional Ground Water Forum member, Jennifer Haley at
FTS 475-6705 or Caroline Roe at FTS 475-9754 in OERR's Hazardous
Site Control Division, or Dick Scalf at the Robert S. Kerr
Environmental Research Laboratory (FTS 74 3-2308)
Attachment: Flow Chart
Summary Report
cc: Superfund Branch Chiefs, Regions I - X
Superfund Section Chiefs, Regions I - X wo/summary report
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GRGi/ND WATER REMEDIATION PROCESS
Phase:
Scoping of
the RI/FS
Site
Characterization
Treatability
Investigation
Early
Action
HE
Development/
Screening of
Alternatives
I Detailed Analysis
I of Alternatives
First or Second
5 Year Review
Very Hiqh^
Interim
Final Acbon
1 (A) >
Action
.Moderate^
Final Action with
' (B) *
Contingency
Implement
No
Contingency
1 Low
Final Action
(C)
Actions:
Identify data collection
needs
Identify possible
containment action
Install gradient control wells
in phased process
Monitor aquifer response
Design and implement ground
water extraction system in
phased process
Monitor aquifer response
Evaluate data from system
operabon
Determine practicable goals
Identity any areas where
long term institutional
controls will be necessary
Administrative Considerations:
ROD (Early Action)
A). ROD (Interim Remedy)
B). ROD (Contingency)
C). ROD (Final)
A). ROD (Final)
B). ESD or ROD
amendment
Enforcement Considerations:
Negotiate RVFS Scope:
Negotiate Consent Decree
A).
Negotiate Consent Decree
Data collection
B)
Possible stipulation or
Earty action
amendment to Consent
Decree
-------
CLARIFYING THE ROLE OF
BASELINE RISK ASSESSMENT
IN REMEDY SELECTION
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
May 1990
-------
IDENTIFYING RISKS TO HUMAN HEALTH
AND THE ENVIRONMENT
Where the baseline risk assessment of the current
and future land use indicates that a cumulative
risk from a site exceeds the 10"4 lifetime excess
cancer risk level or the hazard index exceeds one,
a site poses an unacceptable risk to human
health.
A d
Sites with risks between 10 and 10" also may be
determined to pose an unacceptable risk,
depending on site-specific conditions.
2
-------
IDENTIFYING RISKS TO HUMAN HEALTH
AND THE ENVIRONMENT
(continued)
Interim action RODs do not require completion of a
quantitative baseline risk assessment. A qualitative
description of risk should be included in the ROD
for interim actions.
If the baseline risk assessment indicates that a site
presents no risk, then no remedial action is required
and ARARs are not triggered. If Section 104 criteria
are not met, 121 and ARARs are not triggered.
Baseline risk assessment is used to demonstrate
endangerment under Section 106.
3
-------
CONSISTENT RISK ASSESSMENT
METHODOLOGY
Risk assessment should address all chemicals likely to
be associated with significant risk, which are identified
as chemicals of concern.
Standardized exposure assumptions [found in Risk
Assessment Guidance( RAGS): Human Health Exposure
Manual (HHEM) and others, as developed] should be
used wherever possible. Use of different assumptions
should be justified.
Institutional controls (e.g., fences) should not be
considered in the baseline assessment.
4
-------
DEVELOPMENT OF ALTERNATIVES
l
Baseline risk assessment helps identify areas of
the site requiring remedial action and principal
threats that are candidates for treatment.
-------
DOCUMENTATION IN THE ROD
All RODs (except no-action RODs) should include in the ROD
"Declaration" and "Summary Risks" section of the ROD
"Decision Summary" standard language indicating that the
site may present an imminent and substantial endangerment.
"Summary of Site Risks" section should include a discussion
of current and future risk.
ROD should include how remedial alternatives will reduce
risks and the level of residual risk remaining at the site after
remediation, if quantifiable.
-------
Page 6-35
EXHIBIT 6-11
RESIDENTIAL EXPOSURE: INGESTION OF
CHEMICALS IN DRINKING WATER
(AND BEVERAGES MADE USING DRINKING WATER)
Equation:
Intake (mg/kg-day) = CW x IR x EF x ED
BWx AT
Where:
CW = Chemical Concentration in Water (mg/liter)
IR = Ingestion Rate (liters/day)
EF = Exposure Frequency (days/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CW: Site-specific measured or modeled value
IR: 2 liters/day (adult, 90th percentile; EPA 1989d)
1.4 liters/day (adult, average; EPA 1989d)
Age-specific values (EPA 1989d)
EF: Pathway-specific value (for residents, usually daily 365 days/year)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile)
at one residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic
effects (i.e., 70 years x 365 days/year).
a
See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
and exposure frequency and duration variables.
-------
Page 6-36
EXHIBIT 6-12
RESIDENTIAL EXPOSURE:
INGESTION OF CHEMICALS IN SURFACE WATER
WHILE SWIMMING0
Equation:
Intake (mg/kg-day) = CW x CR x ET x EF x ED
BWx AT
Where:
CW = Chemical Concentration in Water (mg/liter)
CR = Contact Rate (liters/hour)
ET = Exposure Time (hours/event)
EF = Exposure Frequency (events/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CW: Site-specific measured or modeled value
CR: 50 ml/hour (EPA 1989d)
ET: Pathway-specific value
EF: Pathway-specific value (should consider local climatic conditions
[e. g., number of days above a given temperature] and age of
potentially exposed population)
7 days/year (national average for swimming; USDOl in
EPA 1988b, EPA 1989d)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one
residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic
effects (i.e., 70 years x 365 days/year).
" See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rate
and exposure frequer and duration variables.
-------
Page 6-37
EXHIBIT 6-13
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN WATER0
Equation:
Absorbed Dose (mg/kg-day) = CW x SA x PC x ET x EF x ED x CF
BWx AT
Where:
CW = Chemical Concentration in Water (mg/liter)
SA = Skin Surface Area Available for Contact (cm2)
PC = Chemical-specific Dermal Permeability Constant (cm/hr)
ET = Exposure Time (hours/day)
EF = Exposure Frequency (days/year)
ED = Exposure Duration (years)
CF = Volumetric Conversion Factor for Water (1 liter/1000 cm3)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CW: Site-specific measured or modeled value
SA:
SOth Percentile Total Body Surface Area (m2) (EPA 1989d. 1985a)
AGE (YRS)
MAI/E
FEMALE
3 < 6
0.728
0.711
6 < 9
0.931
0.919
9 < 12
1.16
1.16
12 < 15
1.49
1.48
15 < 18
1.75
1.60
Adult
1.94
1.69
SOth Percentile Body Part-specific Surface Areas for Males (m2) (EPA 1989d. 1985a)
AGE (YRS) ARMS HANDS LEGS
3 < 4 0.096 0.040 0.18
6 < 7 0.11 0.041 0.24
9 < 10 0.13 0.057 0.31
Adult 0.23 0.082 0.55
" See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rale and
exposure frequency and duration variables. Use SOth percentile values for ฃ4; see text for rationale.
(continued)
-------
Page 6-38
EXHIBIT 6-13 (continued)
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN WATER"
NOTE: Values for children were calculated using age-specific body surface areas and the average
percentage of total body surface area represented by particular body parts in children,
presented in EPA 1985a. Values for adults presented in EPA 1989d or calculated from
information presented in EPA 1985a. Information on surface area ofother body parts (e.g.,
head, feet) and for female children and adults also is presented in EPA 1985a, I989d.
Differences in body part surface areas between sexes is negligible.
PC:
Consult open literature for values [Note that use of PC values results in
an estimate of absorbed dose.]
ET:
Pathway-specific value (consider local activity patterns if information
is available)
2.6 hrs/day (national average for swimming; US DO I in
EPA 1988b, EPA 1989d)
EF:
Pathway-specific value (should consider local climatic conditions
[e. g., number of days above a given temperature] and age of potentially
exposed population)
7 days/year (national average for swimming; USDOl in EPA 1988b,
EPA 1989d)
ED:
70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
CF:
1 liter/1000 cm3
BW:
70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT:
Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
a See Section 6.4.1 and 6.6.1 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, combine 95th or 90th percentile values for
contact rate and exposure frequency and duration variables.
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Page 6-40
EXHIBIT 6-14
RESIDENTIAL EXPOSURE:
INGESTION OF CHEMICALS IN SOIL*
Equation:
Intake (mg/kg-day) = CS x IR x CF x FT x EF x ED
BWxAT
Where:
CS = Chemical Concentration in Soil (nig/kg)
IR = Ingestion Rate (mg soil/day)
CF = Conversion Factor (10- kg/mg)
FI = Fraction Ingested from Contaminated Source (unitless)
EF = Exposure Frequency (days/years)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CS: Site-specific measured value
IR: 200 mg/day (children, 1 through 6 years old; ErA 1989g)
100 mg/day (age groups greater than 6 years old; EPA 1989g)
NOTE: IR values are default values and could change based
on site-specific or other information. Research is currently ongoing
to better define ingestion rates. IR values do not apply to individuals
with abnormally high soil ingestion rates (i.e., pica).
CF: 10 "6 kg/mg
FI: Pathway-specific value (should consider contaminant location and
population activity patterns)
EF: 365 days/year
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one
residence; EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
16 kg (children 1 through 6 years old, 50th percentile; EPA 1985a)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED \ 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
aSee Section 6.4. / and 6.6.2 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, use 95th or 90th percentile values for contact rate
and exposure frequency and duration variables.
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Page 6-41
EXHIBIT 6-15
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN SOIL0
Equation:
Absorbed Dose (mg/kg-day) = CS x CF x SA x AF x ABS x EF x ED
BWx AT
Where:
CS
=
Chemical Concentration in Soil (mg/kg)
CF
=
Conversion Factor (10 " kg/mg)
SA
=
Skin Surface Area Available for Contact (em'/event)
AF
=
Soil to Skin Adherence Factor (mg/cm2)
ABS
=
Absorption Factor (unitless)
EF
=
Exposure Frequency (events/year)
ED
=
Exposure Duration (years)
BW
=
Body Weight (kg)
AT
=
Averaging Time (period over which exposure is averaged days)
Variable Values:
CS: Based on site-specific measured value
CF: 10'* kg/mg
SA:
50th Percentile Total Body Surface Area (m*) (EPA 1989d. 1985a)
ACfv (YRS)
MAI#E
FEMAfF,
3 < 6
0.728
0.711
6 < 9
0.931
0.919
9 < 12
1.16
1.16
12 < 15
1.49
1.48
15 < 18
1.75
1.60
Adult
1.94
1.69
SOth Percentile Body Part-specific Surface Areas for Males (m;) (EPA 1989d. 1985a)
AfiE (YRS) ARMS HANDS LEGS
3 < 4 0.096 0.040 0.18
6 < 7 0.11 0.041 0.24
9 < 10 0.13 0.057 0.31
Adult 0.23 0.082 0.55
NOTE: Values for children were calculated using age-specific body surface areas and the average percentage
of total body surface area represented by particular body parts in children, presented in EPA 1985a.
Values for adults presented in EPA 19S9d or calculated from information presented in EPA 1985a.
a See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the reason-
able maximum exposure. In general, combine 95th or 90th percentile values for contact rate and exposure
frequency variab' Use 50th percentile values for SA; see text for rationale.
(continued)
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Page 6-42
EXHIBIT 6-15 (continued)
RESIDENTIAL EXPOSURE:
DERMAL CONTACT WITH CHEMICALS IN SOIL"
NOTE (continued): Information on surface area ofother body parts (e.g., head, feet) andfor female
children and adults also is presented in EPA 1985a, 1989d. Differences in body part surface
areas between sexes is negligible.
AF: 1.45 mg/cm* commercial potting soil (for hands; EPA 1989d, EPA
1988b)
2.77_mg/cm2 kaolin clay (for hands; EPA 1989d, EPA 1988b)
ABS: Chemical-specific value (this value accounts for desorption of
chemical from the soil matrix and absorption of chemical across
the skin; generally, information to support a determination of ABS is
limited see text)
EF: Pathway-specific value (should consider local weather conditions
[e.g.,number of rain, snow and frost-free days] and age of potentially
exposed population)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
" See Section 6.4.1 and 6.6.2 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, combine 95th or 90th percentile values for contact rale
and exposure frequency and duration variables.
-------
Pace 6-44
EXHIBIT 6-16
RESIDENTIAL EXPOSURE:
INHALATION OF AIRBORNE (VAPOR PHASE) CHEMICALS0 b
Equation:
Intake (mg/kg-day) = CA x IR x ET x EF x ED
BWx AT
Where:
CA = Contaminant Concentration in Air (mg/m3)
IR = Inhalation Rate (m3/hour)
ET = Exposure Time (hours/day)
EF = Exposure Frequency (days/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CA: Site-specific measured or modeled value
IR: 30 m3/day (adult, suggested upper bound value; EPA 1989d)
20 m3/day (adult, average; EPA 1989d)
Hourly rates (EPA 1989d)
Age-specific values (EPA 1985a)
Age, sex, and activity based values (EPA 1985a)
0.6 m3/hr showering (all age groups; EPA 1989d)
ET: Pathway-specific values (dependent on duration of exposure-related
activities)
12 minutes showering (90th percentile; EPA 1989d)
7 minutes showering (50th percentile; EPA 1989d)
EF: Pathway-specific value (dependent on frequency of showering or other
exposure-related activities)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EI'A 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
" See Section 6.4.1 and 6.6.3 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, use 9Sth or 90th percentile values for contact rate and
exposure frequency and duration variables.
' The equation and variable values for vapor phase exposure can be used with modification to calculate
particulate exposure. See text.
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Page 6-45
EXHIBIT 6-17
RESIDENTIAL EXPOSURE: FOOD PATHWAY
INGESTION OF CONTAMINATED FISH AND SHELLFISH"
Equation:
Intake (mg/kg-day) = CF x IR x FI x EF x ED
BWx AT
Where:
CF = Contaminant Concentration in Fish (mg/kg)
IR = Ingestion Rate (kg/meal)
FI = Fraction Ingested from Contaminated Source (unitless)
EF = Exposure Frequency (meals/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CF: Site-specific measured or modeled value
IR: 0.284 kg/meal (95th percentile for fin fish; Pao etai. 1982)
0.113 kg/meal (50th percentile for Tin fish; Pao et al. 1982)
132 g/day (95th percentile daily intakes averaged over three days
for consumers of fin fish; Pao el al. 1982)
38 &/day (50th percentile daily intake, averaged over three days
for consumers of fin fish; Pao et al. 1982)
6.5 g/day (daily intake averaged over a year; EPA 1989d.
NOTE: Daily intake values should be used in conjunction with
an exposure frequency of 365 days/year.)
Specific values for age, sex, race, region and fish species are
available (EPA 1989d, 1989h)
FI: Pathway-specific value (should consider local usage patterns)
EF: Pathway-specific value (should consider local population patterns
if information is available)
48 days/year (average per capita for fish and shellfish; EPA Tolerance
Assessment System in EPA 1989h)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
a See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, use 95th or 90th percentile values for intake rate and
exposure frequency and duration variables.
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Page 6-46
EXHIBIT 6-18
RESIDENTIAL EXPOSURE: FOOD PATHWAY
INGESTION OF CONTAMINATED FRUITS AND VEGETABLES ฐ
Equation:
Intake (mg/kg-day) = CF x IR x FI x EF x ED
BWx AT
Where:
CF = Contaminant Concentration in Food (mg/kg)
1R = Ingestion Rate (kg/meal)
FI = Fraction Ingested from Contaminated Source (unitless)
EF = Exposure Frequency (meals/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CF: Site-specific measured value or modeled value based on soil
concentration and plant:soil accumulation factor or deposition factors
IR: Specific values for a wide variety of fruits and vegetables are available
Ir&oetal. 1982)
FI: Pathway-specific value (should consider location and size of
contaminated area relative to that of residential areas, as well as
anticipated usage patterns)
EF: Pathway-specific value (should consider anticipated usage patterns)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA 1989d)
BW: 70 kg (adult, average; EPA I989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
"See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate the
reasonable maximum exposure. In general, use 95th or 90th percentile values for contact rale and
exposure frequency and duration variables.
-------
Page 6-48
EXHIBIT 6-19
RESIDENTIAL EXPOSURE: FOOD PATHWAY
INGESTION OF CONTAMINATED MEAT, EGGS,
AND DAIRY PRODUCTS a
Equation:
Intake (mg/kg-day) = CF x IR x FI x EF x ED
BWx AT
Where:
CF = Contaminant Concentration in Food (mg/kg)
IR = Ingestion Rate (kg/meal)
Fl = Fraction Ingested from Contaminated Source (unitless)
EF = Exposure Frequency (meals/year)
ED = Exposure Duration (years)
BW = Body Weight (kg)
AT = Averaging Time (period over which exposure is averaged days)
Variable Values:
CF: Site-specific measured or modeled value. Based on soil
concentrations, plant (feed) accumulation factors, and feed-to-meat
or feed-to-dairy product transfer coefficients
IR: 0.28 kg/meal beef (95th percentile; Pao el al. 1982)
0.112 kg/meal beef (50th percentile; Pao et al. 1982)
Specific values for other meats are available (Pao et al. 1982)
0.150 kg/meal eggs (95th percentile; Pao el al. 1982)
0.064 kg/meal eggs (50th percentile; Pao et al. 1982)
Specific values for milk, cheese and other dairy products are available
(Pao et al. 1982)
FI: Pathway-specific value (should consider location and size of contaminated
area relative to that of residential areas, as well as anticipated usage
patterns)
EF: Pathway-specific value (should consider anticipated usage patterns)
ED: 70 years (lifetime; by convention)
30 years (national upper-bound time (90th percentile) at one residence;
EPA 1989d)
9 years (national median time (50th percentile) at one residence;
EPA1989d)
BW: 70 kg (adult, average; EPA 1989d)
Age-specific values (EPA 1985a, 1989d)
AT: Pathway-specific period of exposure for noncarcinogenic effects
(i.e., ED x 365 days/year), and 70 year lifetime for carcinogenic effects
(i.e., 70 years x 365 days/year).
"See Section 6.4.1 and 6.6.4 for a discussion of which variable values should be used to calculate
the reasonable maximum exposure. In general, use 95th or 90th percentile values for contact rate
and exposure frequency and duration.
-------
4
-------
BRIEFING ON LDRs FOR ROD FORUM
-------
Page 1
OVERVIEW OF SUPERFUND APPROACH FOR COMPLYING
WITH RCRA LAND DISPOSAL RESTRICTIONS
ON-SITE OFF-SITE
Relevant and
Appropriate AppNcaMe
Industrial
Process
Waste
Sod and Debris
(Make case-by-
case determination
lor sludges)
MaatBDAT a
Obtain TraataMtty
Variance
- DaiMwaati
. Obtain Ho liQiiion
PoMon
Meat BOAT -99 percent reduction
Ih concentration or
mobility of waate
Meat BOAT ซ
- Obtain Treatability Variance
- (MM wane
- Obtain No-Migration Petition and
Comply wilti admtntetritiw requirements
- - _ _ At .
- nowewon
* ovMciton
Obttin TrtatabiNty Variano* flod
comply witi cdffllniilFilivv
fiQuiwninli
ฆ notification
* carfcficaiJon
e Major factors in evaluating compliance are:
Type of waste (industrial process vs. soil and debris)
Does action occur on- or off-site
Whether LDRs are applicable or relevant and appropriate
e Presumption is to comply with the LDRs for soil and debris through a Treatability Variance
-------
Page 2
ARAR DETERMINATION
APPLICABLE (Superfund LDR Guide #5)
PLACEMENT
RCRA WASTE
RESTRICTED AT TIME OF PLACEMENT
RELEVANT AND APPROPRIATE (Superfund LDk Guide #7)
CERCLA OBJECTIVES vs. LDR OBJECTIVES
SIMILARITY OF WASTE
CONSTITUENTS
MATRIX
MEDIUM OF OCCURRENCE
-------
Page 3
LDRs IN TrtE RI/FS PROCESS
>, V -.1 .
* "hi:-'
Evaluate
nature and
hImiI of ad*
Develop waste
management
tHamidwi lor
the alia
Evaluate attematfvea; determine If
they win result In significant
reductions ol toxicity, mobility, or
volume of primary contamlnanta
Salact
ramady
In ROD
CO^twroi
i&H-
raatrlctad RCRA
hazardous
wastas ara
praaarrt
Compara Superhmd
Evaluate
Identify alternative
Treatability
contamlnanta of
whether reme-
treatment level*
Variance
concern ซW) BDAT
dlal altarnatlva
that mutt be met
granted when
conatltuanta lequhlinj
Involve*
under Treatability
ROD U algned
control
,-i 'Y-.
"ptacetnenT
. v' -
Variance
-------
Page 4
INFORMATION TO BE INCLUDED IN AN RI/FS TO DOCUMENT THE INTENT
TO COMPLY WITH THE LDRs THROUGH A TREATABILITY VARIANCE FOR
ON-SITE AND OFF-SITE CERCLA RESPONSE ACTIONS INVOLVING THE
PLACEMENT OF SOIL AND DEBRIS CONTAMINATED WITH RESTRICTED RCRA WASTES
ON-SITE
Description of the soil or debris waste and the source of the contamination;
o Description of the Proposed Action (e.g., "excavation, treatment, and off-site disposal");
Intent to comply with the LDRs through a Treatability Variance;
For each alternative using a Treatability Variance to comply, the specific treatment level range
to be achieved.
OFF-SITE
For off-site Treatability Variances, the information above should be extracted from the RI/FS report and
combined with the following information in a separate document:*
ซ i>ฃtitioner5s.name and aririrfKK. and identification, of an authorized coniactpeison .(if.different);
Statement of petitioner's interest in obtaining a Treatability Variance; and
* This document may be prepared after the ROD is signed (and Treatability Variance granted) but will
need to be compiled prior to the first shipment of wastes (or treatment residuals) to the receiving
treatment or disposal facility.
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Page 5
SAMPLE LANGUAGE FOR A RECORD OF DECISION
DESCRIPTION OF ALTERNATIVES SECTION:
This alternative will comply with the LDRs through a Treatability Variance for the contaminated
soil and debris. The treatment level range established through a Treatability Variance that [Enter
technology] will attain for each constituent as determined by the indicated analyses are: [Example
shown below]
Barium 0.1 - 40 ppm (TCLP)
Mercury 0.0002 - 0.008 ppm (TCLP)
Vanadium 0.2 - 22 ppm (TCLP)
TCE 95-99.9% reduction (TWA)
Cresols 90-99.9% reduction (TWA)
Treatability Variance is effective when ROD is signed by Regional Administrator.
In the Comparative Analysis section, indicate which alternatives will comply with the LDRs through a Treatability Variance.
In circumstances where the need for a Treatability Variance is discovered after ROD is signed (e.g., because site was found to contain RCRA
wastes), will need an ESD or ROD amendment.
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Page 7
WASTES REGULATED UNDER 3RD THIRDS
CHARACTERISTIC WASTES
MULTI-SOURCE LEACHATE
LAB PACKS
MIXED RADIOACTIVE WASTE
Characteristic wastes
EPA set concentration-based treatment standards for most characteristics
LDR treatment standard level established at level that defines waste as hazardous
Some characteristic standards set as a method of treatment
Establishing new subcategories for certain wastes
Multi-source leachate
F039 waste code, with treatment standards for 200 constituents in wastewaters and nonwastewaters
Lab packs
Segregate lab packs with special LDR treatment standards set for organometallics and certain organics
Lab packs with matures of wastes must meet standards for each waste in lab pack
Mixed radioactive waste
Treatment standards for three categories of characteristic mixed wastes
National capacity extension for all First, Second, and Third Third mixed wastes
Storage of these wastes allowed (does not violate storage prohibition)
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SUBCATEGORIES FOR CHARACTERISTIC WASTES
The following are RCRA characteristic wastes for which EPA established more than the two standard
treatability groups (i.e., wastewaters and nonwastewaters):
ฆ D001 Igni tables
Ignitable liquids
-- organic liquids
-- aqueous liquids
- wastewaters
Ignitable reactives
Oxidizers
Ignitable compressed gases
ฆ D002 Corrosives
Acids
Alkalines
Other corrosives
ฆ D003 Reactives
Reactive cyanides
Explosives
Water reactives
Reactive sulfides
Other reactives
ฆ D006 Cadmium
Wastewaters
Nonwastewaters
Cadmium Batteries
ฆ D007 Chromium
Wastewaters
Nonwastewaters
Chromium Bricks
Chromium Batteries
ฆ D008 Lead
Wastewaters
Nonwastewaters
Lead-Acid Batteries
Note: Those characteristic wastes not included were divided only into wastewater and nonwastewater
forms.
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COMPLIANCE DATES
EFFECTIVE DATE DELAY
ฎ NATIONAL CAPACITY EXTENSIONS
Effective date delay
Third Third rule goes into effect August 8, 1990 for all wastes.
National capacity variances, however, were not granted a delay. They will extend from May 8, 1990 until May 8, 1992.
National capacity extensions
Granted for several surface-disposed wastes, as well as soil and debris for which LDR treatment standards were based on
combustion, vitrification, wet-air oxidation, mercniry retorting, and chromium reduction.
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SURFACE-DISPOSED WASTES RECEIVING NATIONAL CAPACITY VARIANCES IN THE THIRD THIRD RULE
Technology Waste Codeฎ
Vitrification D004
K031
K084
K101
K102
P010
P011
P012
P036
P038
U136
Chromium Recovery D007b
Combustion of Sludge/Solids FTB^
Mercury Retorting D009
K106
P065
P092
U151
Secondary Smelting D008^
Thermal Recovery P015
P073
P087
Combustion, vitrification, wet-air Soil and
oxidation, mercury retorting, and Debris
chromium reduction
a Variances are granted only to the nonwastewater forms.
b D007 refractory bricks.
c Multi-source leachate.
d D008 lead-acid batteries.
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THIRD THIRDS/CALIFORNIA LIST OVERLAP
MORE SPECIFIC STANDARDS APPLY
CERTAIN CIRCUMSTANCES - CA-LIST RESTRICTIONS STILL APPLY
More specific standards apply
California list wastes are defined as RCRA wastes that also meet other conditions (e.g., contain HOCs greater than 1,000 ppm)
All RCRA wastes are now restricted; therefore, ih most cases, California list wastes standards will not apply because the RCRA
standards are more specific
Certain circumstances - California list restrictions apply when:
Liquid hazardous wastes contain over 50 ppm PCfes, where the PCBs are not regulated by the treatment standard;
HOC-containing wastes are identified as hazardous by a characteristic property that does not involve HOCs, such as an ignitable
waste that also contains greater than 1,000 ppm HOCs;
Liquid hazardous wastes contain a total concentration of more than 134 mg/1 of nickel and/or 130 mg/1 of thallium (because
these two constituents are not regulated under the characteristic of toxicity);
Wastes granted a 2-year national capacity variance are also Calif, list wastes, until the treatment standards become effective.
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DILUTION
AFFIRMED DILUTION PERMISSIBLE IF:
LEGITIMATE TYPE OF TREATMEP^T
OCCURS DURING ONE OF SPECIFIED CIRCUMSTANCES
Remove the characteristic property from all D001 through D017 wastewaters when managed on-site; and
Remove the characteristic property from non-toxic D001, D002, D003 nonwastewaters. except when the following toxic nonwastewaters
are in the following subcategories: high TOC ignitable nonwastewaters (D001), reactive cyanide wastes (D003), and reactive sulfide
wastes (D003).
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CONSTITUENTS AND REGULATORY LEVELS
ESTABLISHED UNDER THE TOXICITY CHARACTERISTIC RULE
Old EP Toxicity Characteristics New TC Constituents
(also regulated under TC)
Waste
Code
Regulated
Constituent
Reg. Level
(me/1)
Waste
Code
Regulated Reg. Level
Constituent (me/1)
D004
Arsenic
5.0
D018
Benzene
0.5
D005
Barium
100.0
D019
Carbon Tetrachloride
0.5
D006
Cadmium
1.0
D020
Chlordane
0.0
D007
Chromium
5.0
D021
Chlorobenzene
100.0
D008
Lead
5.0
D022
Chloroform
6.0
D009
Mercury
0.2
D023
o-Cresol
200.0'
D010
Selenium
1.0
D024
m-Cresol
200.0'
D011
Silver
5.0
D025
p-Cresol
200.0'
EX) 12
Endrin
0.0
D026
1,4-Dichlorobenzene
7.5
D013
Lindane
0.4
D027
1,2-Dichloroe thane
0.5
D014
Methoxyclor
10.0
D028
1,1 -Dichloroethylene
0.7
D015
Toxaphene
0.5
D029
2,4-Dinitrotoluene
0.1
D016
2,4-D
10.0
D030
Heptachlor
0.0
D017
2,4,5-TP (silvex)
1.0
D031
Hexachlorobenzene
0.1
D032
Hexachloro-13-butadiene
0.5
D033
Hexachloroe thane
3.0
D034
Methyl ethyl ketone
200.0
D035
Nitrobenzene
10
D036
Pentachlorophenol
100.0
D037
Pyridine
5.0
D038
Tetrachloroethylene
0.7
D039
Trichloroethylene
0.5
D040
23^-Trichlorophenol
400.0
D041
2,4,6-Trichlorophenol
10
D042
Vinyl chloride
0.2
* If o-, m-, and p-Cresol cannot be differentiated, total cresol concentration of 200.0 mg/1 is used as a
regulatory level.
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CHARACTERIZATION & LDR COMPLIANCE OF
RCRA CHARACTERISTIC WASTE: EP vs. TCLP
t- 1
Use EP to test for
characteristic
| : j
Use EP or TCLP to teat
for characteristic
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IMPLEMENTATION RECOMMENDATIONS FOR ALTERNATIVES
INVOLVING PLACEMENT/DISPOSAL
AS OF MARCH 29, 1990, THE TCLP SHOULD BE USED TO DETERMINE WHETHER A WASTE IS
HAZARDOUS IN CHARACTERISTIC
IF RI/FS COMPLETED, PLAN TO PERFORM TCLP ANALYSIS DURING RD/RA
INCLUDE COMPLIANCE LANGUAGE IN ROD OR ACTUAL MANAGEMENT CONTINGENCIES IF
THEY CAN BE ANTICIPATED
IF TCLP IS RUN AND POSITIVE RESULTS OBTAINED AFTER ROD IS SIGNED, ASSESS NEED
FOR REMEDY MODIFICATIONS AND ISSUANCE OF ESD OR ROD AMENDMENT
ROD COMPLIANCE LANGUAGE
"Should waste or waste residuals be found to be TC characteristic, they will be managed in accordance with specified RCRA
requirements."
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