&EPA
United States
Environmental Protection
Agency
Summary of Technical Impracticability Waivers at
National Priorities List Sites
REPORT WITH GENERAL TECHNICAL IMPRACTICABILITY SITE
INFORMATION SHEETS
1.0 INTRODUCTION
The purpose of this report is to provide a summary of
Technical Impracticability (TI) waivers that have been
issued by U.S. Environmental Protection Agency
(EPA) Regions, and to distribute brief summaries of
the completed TI waiver decisions, including a
summary of the site conditions and the Regions'
rationale for adopting a TI waiver. TI waivers are one
of the means of waiving applicable or relevant and
appropriate requirements (ARARs), consistent with
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Section
121 (b) and by the National Contingency Plan (NCP)
(see Section 300.430(f)(l)(ii)(C)(3)). Through analysis
of site data and demonstration of the technical
impracticability of achieving those ARARs (for
example, maximum contaminant levels [MCLs] or
other federal or state standards), a waiver may be
appropriate. The compiled information in this report
may be useful in evaluating whether a TI waiver may
be part of a current site's remedial strategy. There have
been significant scientific advances and technological
innovations and improvements that may be relevant in
evaluating the appropriateness of new TI waivers. For
example, over time, innovative technologies such as in-
situ thermal treatment and in-situ flushing have been
found to effectively treat dense non-aqueous phase
liquids (DNAPLs). Progress has also been made in
locating the aqueous phase plume (dissolved) and in
delineating the entry locations where DNAPL was
released and likely is present in the subsurface.
The EPA has issued guidance on TI waivers, titled
"Guidelines for Evaluating the Technical
Impracticability of Ground Water Restoration."
OSWER Directive 9234.2-25, September 1993.
Although Headquarters is typically consulted, the TI
decision is generally made by the EPA Regional
Administrator. For additional information on
consultation procedures for Superfund response
decisions, see Appendix C of "A Guide to Preparing
Superfund Proposed Plans, Records of Decision, and
Other Remedy Selection Decision Documents"
OSWER Directive 9200.1-23.P, July 1999. Additional
information regarding the 1993 TI Guidance, especially
regarding communications, points of contact, and the
TI decision review process (including regional TI
review teams) can be found in "Consistent
Implementation of the FY1993 Guidance on Technical
Impracticability of Ground-Water Restoration at
Superfund Sites" OSWER Directive 9200.4-14,
January 19, 1995.
This report compiles historical information on 91 TI
waivers that have been approved for either
groundwater or surface water at 85 National Priorities
List (NPL) Sites (also called Superfund sites) between
1988 and 2011. Sources of this TI information include
Records of Decision (ROD); ROD Amendments; five-
year reviews; explanations of significant differences
(BSD); site summaries; TI evaluations as stand-alone
reports or as part of a feasibility study (FS) or focused
FS; petitions and requests for TI waivers; TI
demonstration reports; and TI determinations.
Information included in this report was verified by
contacting regional personnel.
A summary sheet for each TI waiver is included in
Appendix A to this report. These summary sheets are
intended to synthesize the site information contained in
a technical evaluation report or decision document.
They are not intended to be used as a substitute for the
complete evaluation report or decision document. For
additional information on each TI determination,
consult the evaluation report or decision document
referenced in each summary sheet.
This report provides only a summary of the numbers
and types of TI waivers that have been granted in the
past by regions. It does not provide an evaluation of the
basis of those decisions or recommendations as to how
those decisions would be made if the TI waiver were
being considered at the present time.
2.0 OVERVIEW OF TI WAIVERS ISSUED
Between 1988 and 2011, the EPA issued between one
and eleven TI waivers each year (except 2008 and 2010
when no waivers were issued). A total of 91 TI waivers
were issued at 85 sites. Figure 1 shows the number of
TI waivers issued in each year. Of the 85 sites with TI
waivers, eight are federal facilities. Nine often EPA
regions have issued waivers; Region 4 is the only
region that does not currently have any final TI
waivers. Figure 2 shows the number of TI waivers
issued by each region.
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5204P)
OSWER Directive 9230.2-24
August 2012
epa.gov/superfund/health/index.htm
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Summary of Technical Impracticability Waivers at National Priorities List Sites
Figure 1: EPA TI Waivers by Fiscal Year (FY 1988 - 2011)
Number of
TI Waivers
in
Q
n -
Total Number of TI Waivers = 91
n
4
4
5
4
3
2
5
3
6
7
8
4
4
3
2
5
2
11
3 3
2
0 0
Fiscal Year
Figure 2: TI Waivers per Region (FY 1988 - 2011)
zu -
1 1
Number of
TI Waivers
A
n
15
11
19
Total Number of TI Waivers = 91
0
1234
4
5
12
8
11
6 7 8 9 10
EPA Region
Of the 91 waivers, 81 have applied to groundwater
only, six have applied to surface water only, and four
have applied to both media. Most often, the ARAR
waived was the maximum contaminant level (MCL)
(55 waivers) or state drinking water standard (27
waivers) for at least one contaminant. Other ARARs
waived included other federal or state drinking water
standards and surface water quality standards.
TI waivers have been applied to only a shallow aquifer,
to only the deep aquifer, to all aquifers at the site, or to
multiple but not all aquifers. At one site, a TI waiver
was applied to underground mine workings.
August 2012
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Summary of Technical Impracticability Waivers at National Priorities List Sites
3.0 JUSTIFICATION FOR TI WAIVERS ISSUED
Based on the available information, a total of 23
different factors were cited as rationale for the 91 TI
waivers. Some common factors that have been used in
the past as justification for TI waivers are discussed
below. In most cases, more than one factor was cited as
the basis for a TI waiver.
Geology and hydrogeology - Complex geology was
cited as a contributing factor in the rationale for 54 of
the 85 groundwater TI waivers and included fractured
bedrock, karst terrain, and heterogeneous soils with
low permeability. Other factors were present or cited to
justify the TI waiver for the 54 that cited complex
geology. For additional information about
hydrogeologic characteristics, refer to Figure 1 of the
1993 TI Guidance.
Non-aqueous phase liquid (NAPL) and other
contaminants - NAPLs, because of their physical
properties, may occur as "free phase" or "residual"
contamination entrapped in difficult to remediate
locations and because of their low solubilities, may
serve as long-term continuous contaminant sources.
The presence of NAPL was cited as a contributing
factor in the rationale for 47 TI waivers. DNAPL was
included in 43 waivers, light non-aqueous phase liquid
(LNAPL) in nine TI waivers, and the type of NAPL
was not specified in three waivers. Eight waivers cited
both LNAPL and DNAPL.
In addition, 16 TI waivers cited certain other
complexities (e.g., low solubility, tendency to sorb to
organic soils, and relative immobility in the
subsurface) presented by contaminants such as metals,
polychlorinated biphenyls (PCBs), and polycyclic
aromatic hydrocarbons (PAHs), as contributing to the
rationale for the TI waiver.
There are 44 waivers where NAPL is not an issue, and
most of those sites have metals contamination. There
are two sites with a TI waiver, where even though
NAPL was present, the TI waiver applied to only
metals contamination. Of the ten TI waivers for surface
water, eight of them apply to metals contamination.
The most common types of contaminants waived in a
TI waiver are shown in Figure 3. Volatile organic
compounds (VOCs) (60 waivers), metals (45), and
semi-volatile organic compounds (SVOCs) and PAHs
(34) are the most common contaminant groups
addressed by a TI waiver.
Figure 3: Types of Contaminants Addressed by TI Waivers
Number of
TI Waivers
60
40
30
20
10
60
Total Number of Waivers with Contaminant Information = 90
45
34
12
VOCs Metals PAHs and PCBs
SVOCs
Pesticides
Dioxins
PAH - Polycyclic aromatic hydrocarbon
PCB - Polychlorinated biphenyl
SVOC - Semi-volatile organic compound
VOC - Volatile organic compound
Contaminant Type
August 2012
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Summary of Technical Impracticability Waivers at National Priorities List Sites
Site-specific conditions - Other factors that have been
considered when evaluating the ability to achieve
ARARs include: (1) a large source that could not be
removed (12 TI waivers); (2) the presence of upstream
sources (six TI waivers); and (3) too much volume to
treat prior to surface water discharge as a result of
storm events or mine drainage (three TI waivers).
Timeframe - With regard to considering the timeframe
associated with achieving ARARs, of the 91 waivers,
56 had information about the timeframe. Most of those
waivers (more than 90 percent) included timeframes of
greater than 100 years.
4.0 ATTAINING PROTECTIVENESS
Grounchvater remedial alternatives - The groundwater
remedy components implemented to ensure
protectiveness at sites with TI waivers for groundwater
ARARs are shown in Figure 4. Note that sites typically
have more than one groundwater remedy; therefore the
number of remedies exceeds the number of TI waivers
for groundwater. Remedial components identified in
waivers include treatment, containment, monitored
natural attenuation (MNA), institutional controls (ICs),
alternate water supplies (AWS) or well-head treatment,
and monitoring.
Source control measures - With regard to remediation
of contamination sources as a part of aquifer
restoration efforts, removal is the most common source
action, selected at 31 sites (36 percent). Source
containment and treatment were selected at 17 and 10
sites, respectively.
Figure 4: Groundwater Remedy Components Coupled with TI Waiver
to Ensure Protectiveness
Total Number of TI Waivers for Groundwater = 85
Number of
TI Waivers
f,C\ J
^n
JU
Af)
^H
JU
90
i n
1U
n -
18
?8
17
69
13
23
Treatment Containment MNA
ICs
AWS Monitoring
5.0 SUMMARY
In summary, TI waivers have been issued at sites in every
region except Region 4. The most common type of TI
waiver has been for groundwater restoration to ARARs
(75 percent). The most common contaminant groups
addressed by TI waivers have been VOCs (67 percent),
metals (50 percent), and SVOCs/PAHs (38 percent). The
most common reasons that have been used to justify TI
waivers for groundwater ARARs are complex geology
(64 percent) and the presence of NAPL (55 percent).
Where TI waivers have been issued for surface water, the
most common reasons that have been used to justify the
TI waivers are the presence of upstream sources (60
percent) and the presence of very large sources that
cannot be removed (50 percent). Nearly all TI waivers
included more than one reason for the waiver.
The Superfund program remains committed to restoring
groundwater to beneficial reuse consistent with CERCLA
and the NCP, and bringing human exposures under
control. TI waiver determinations are a recognized part of
the EPA's remedial strategy, and they may be appropriate
depending on site-specific conditions, as discussed in the
1993 TI Guidance.
In light of the continuing scientific advances in
groundwater remediation technologies which continue to
evolve, regions should not be limited by previously-
approved TI waivers described in this technical report as
justification for what may be appropriate when evaluating
and documenting current or future TI waivers.
August 2012
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Summary of Technical Impracticability Waivers at National Priorities List Sites
Sites with Technical Impracticability Waivers (Listed by Region)
REGION 1
Charles-George Reclamation Trust Landfill, MA (A-l)
Pinette's Salvage Yard, ME (A-2)
Sullivan's Ledge, MA (A-3)
Old Springfield Landfill, VT (A-4)
Pease Air Force Base, Site 32/36, NH (A-5)
Tansitor Electronics, Inc., VT (A-6)
South Municipal Water Supply Well, NH (A-7)
Hocomonco Pond, MA (A-8)
Loring Air Force Base, Entomology Shop (ES) and Jet
Engine Build-up Shop (JEBS), ME (A-9)
Loring Air Force Base, Quarry site, ME (A-10)
McKin Superfund Site, ME (A-ll)
O'Connor Superfund Site, ME (A-12)
Durham Meadows, CT (A-13)
West Site/Hows Corner, ME (A-14)
Elizabeth Mine Superfund Site, VT (A-15)
REGION 2
Caldwell Trucking Co., NJ (A-16)
GEMoreau,NY(A-17)
Niagara Mohawk Power Corp. (Saratoga Springs Plant),
NY (A-18)
Love Canal, NY (A-19)
Dupont/Necco Park, NY (A-20)
Federal Creosote, NJ (A-21)
Hudson River PCBs, NY (A-22)
Roebling Steel Company, NJ (A-23)
Atlantic Resources, NJ (A-24)
Horseshoe Road, NJ (A-25)
Chemical Insecticide, NJ (A-26)
REGION 3
Dorney Road Landfill, PA (A-27)
Heleva Landfill, PA (A-28)
Middletown Air Field, PA (A-29)
Whitmoyer Laboratories, PA (A-30)
Lindane Dump, PA (A-31)
Westinghouse Elevator Co, PA (A-32)
E.I. Dupont Nemours (Newport Landfill), DE (A-33)
Hunterstown Road, PA (A-3 4)
Aladdin Plating, PA (A-3 5)
Butler Mine Tunnel, PA (A-36)
Brodhead Creek, PA (A-37)
Revere Chemical Co, PA (A-3 8)
Aberdeen Proving Ground, Edgewood Area (OU2), MD
(A-39)
Aberdeen Proving Ground, Edgewood Area (OU8), MD
(A-40)
Rodale Manufacturing Co., Inc., PA (A-41)
Naval Air Development Center, PA (A-42)
Keystone Sanitation Landfill, PA (A-43)
Westinghouse Electric (Sharon Plant), PA (A-44)
UGI Columbia Gas Plant, PA (A-45)
REGION 5
Continental Steel Corp, IN (A-46)
Conrail Rail Yard (Elkhart), IN (A-47)
Lemon Lane Landfill, IN (A-48)
Neal's Landfill, IN (A-49)
REGION 6
Hardage/Criner, OK (A-50)
Crystal Chemical Co., TX (A-51)
Highway 71/72 Refinery, LA (A-52)
Popile Inc. Superfund Site, AR (A-53)
Garland Creosoting, TX (A-54)
Petro-Chemical Systems Inc. (Turtle Bayou), TX (A-55)
Hart Creosoting, TX (A-56)
Midland Products, AR (A-57)
Jasper Creosoting, TX (A-58)
Vertac, AR (A-59)
City of Perryton Well #2, TX (A-60)
North Cavalcade, TX (A-61)
REGION 7
Cherokee County, Baxter Springs and Treece Subsites,
KS (A-62)
Cherokee County, Galena Subsite, KS (A-63)
Aluminum Company of America-Davenport, IA (A-64)
Missouri Electric Works, MO (A-65)
Waterloo Coal Gasification Plant, IA (A-66)
Oronogo-Duenweg Mining Belt, MO (A-67)
Iowa City FMGP, IA (A-68)
Riverfront, MO (A-69)
REGION 8
East Helena, MT (A-70)
Whitewood Creek, SD (A-71)
Broderick Wood Products, CO (A-72)
Silver Bow Creek/Butte Area (OU3), MT (A-73)
Anaconda Co. Smelter, MT (A-74)
Summitville Mine, CO (A-75)
Milltown Reservoir Sediments, MT (A-76)
Silver Bow Creek/Butte Area (OU8), MT (A-77)
Libby Groundwater Contamination, MT (A-78)
California Gulch, CO (A-79)
Anaconda Co. Smelter, MT (A-80)
REGION 9
Westinghouse Electric Corp (Sunnyvale Plant), CA
(A-82)
Schofield Barracks, HI (A-83)
Tucson International Airport Area, AZ (A-84)
Del Norte Pesticide Storage, CA (A-85)
J.H. Baxter & Co., CA (A-86)
Del Amo, CA (A-87)
Koppers Co. Inc. (Oroville Plant), CA (A-88)
Montrose Chemical Corp., CA (A-89)
Edwards Air Force Base, CA (A-90)
REGION 10
Eielson Air Force Base (OU2), AK (A-91)
Eielson Air Force Base (OU4), AK (A-92)
August 2012
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Summary of Technical Impracticability Waivers at National Priorities List Sites
For Headquarters TI consultation, please contact Matthew Charsky (charsky.matthewtgiepa. gov or 703-603-8777) or
Dave Bartenfelder (bartenfelder.davidtgiepa.gov or 703-603-9047) of the EPA's Office of Superfund Remediation
and Technology Innovation, Assessment and Remediation Division, Science Policy Branch.
For additional information regarding the individual site summaries, please refer to the regional contacts below:
Region 1
Region 2
Region 3
Region 4
Region 5
Bill Brandon
Matthew Westgate
Kathy Davies
Bill Osteen
Luanne Vanderpool
Region 6
Region 7
Region 8
Region 9
Region 10
Greg Lyssy
Bill Pedicino
Fran Costanzi
Herb Levine
Jonathan Williams
6.0 REFERENCES
EPA. 1993. Guidelines for Evaluating the Technical Impracticability of Ground Water Restoration, OS WER Directive
9234.2-25, September, www.epa.gov/superfund/health/conmedia/gwdocs/techimp.htm.
EPA. 1995. Consistent Implementation of the FY1993 Guidance on Technical Impracticability of Ground-Water
Restoration at Superfund Sites, OSWER Directive 9200.4-14, January 19.
www.epa.gov/superfund/policv/remedv/pdfs/92-00414-s.pdf.
EPA. 1999.^4 Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection
Decision Documents, OSWER Directive 9200.1-23.P, July.
www.epa.gov/superfund/policv/remedv/rods/index.htm.
August 2012
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APPENDIX A:
Summary of Technical Impracticability Waivers at Superfund Sites
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Region 1: 14 sites (15 waivers)
Site Name: Charles-George
Reclamation Trust Landfill
State: MA;
OUs: 3&4
Decision Doc. (Type &Date):
ROD, 9/29/88
Stage: Pre- construction
Media: Groundwater
References: (1) ROD, OUs 3 and
4, 9/29/88,
www.epa. sov/superfund/sites/rods/
fulltext/r0188029.Ddf: (2) Five-
year review, 2010,
www.epa. sov/resionl/superfund/si
tes/charlesseorse/454642.pdf
TI Decision: ARARs to achieve MCLs for certain contaminants (specifically benzene, arsenic, and cadmium) in the "Eastern Deep Bedrock
Plume" area (groundwater deeper than 100 ft below ground surface) are waived because they are not likely to be attained.
Rationale: Contaminated deep bedrock groundwater will only be monitored (not remediated) for the following reasons : (1) given the
uncertainties regarding the spatial extent of the deep bedrock plume and the difficulties in predicting groundwater flow in bedrock, it is
considered infeasible to extract the entire deep bedrock plume. Heavy pumping for remedial purposes in the eastern deep aquifer could cause
further contaminant migration by drawing contamination from the shallow aquifers into the deeper one; (2) upon extension and connection of a
municipal water line from an alternate water supply source to nearby areas, the deep aquifer in the affected areas will not be used for drinking
water; (3) with landfill capping and overburden/shallow bedrock remediation, the landfill is not expected to contribute more contaminants to
the deep plume, and MCLs and acceptable risk levels should be attained through natural attenuation at an approximate distance of 1,000 feet
east of the landfill; and (4) this deep plume is not expected to discharge to nearby surface water bodies or move up into the overburden aquifer
in the Flint Pond area. As such, it will not pose environmental risks to these surface waters nor human health risks to users of the Flint Pond
aquifer. The Eastern Deep Bedrock Plume is inferred to discharge to the Merrimack River where groundwater monitoring will be implemented
in order to track contaminants on an ongoing basis. In the event of deteriorating conditions, the need for additional actions will be examined.
Conditions: NAPL (suspected or observed) - DNAPL has not been observed and, based on groundwater data, is not expected to be present
at the site. Eleven chlorinated VOCs are listed as COCs for the site, 9 of which are COCs because they are found in
concentrations in landfill gas vent emissions. In 1987, TCE was observed in landfill leachate (maximum of 24 ppb), and
1,1-DCA was found in leachate and in overburden groundwater (maximum of 83 ppb, and 16J ppb, respectively). The
presence of DNAPL was not identified as a reason for the TI waiver.
COCs (for the Eastern Deep Bedrock Plume) - Benzene, arsenic, and cadmium
Concentration - Maximum concentrations for COCs in the Eastern Deep Bedrock Plume area are benzene (69 ppb), arsenic (93
ppb), and cadmium (19 ppb). Site-wide COCs are listed in Table 1 of ROD.
Geology - Bedrock
TIZone - TI zone includes the deep bedrock aquifer (not the overburden or shallow bedrock aquifers); however the extent of
the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Not estimated
Remedial Action Alternatives - Contaminated overburden and shallow bedrock groundwater will be treated using P&T. The
Eastern Deep Bedrock Plume area, however, will only be monitored.
Current Status/Activities: P&T for overburden and shallow bedrock groundwater is currently in the LTRA phase. An alternate water supply
has also been provided to nearby residents. Sampling was conducted in 2006 and 2009. The 2010 5-year review recommended that (1)
additional monitoring be established to increase understanding of contaminant distributions and trends, and (2) ICs be established to prevent
use of contaminated groundwater and to prevent disturbance of the landfill cap.
August 2012
A-1
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Pinette's Salvage Yard
State: ME; OU: I
Decision Doc. (Type &Date):
ROD, 5/30/89
Stage: Pre- construction
Media: Ground water
References: (1) ROD, OU 1,
5/30/89,
www.epa. gov/superfund/sites/rods/
fulltext/r0189034.pdf: (2) Site
summarv.www.vosemite.epa.gov/r
l/npl_pad.nsf/701b6886fl89ceae8
5256bd20014e93d/0c97f4916d26d
bdd852569 If0063f6e9! OpenDocu
ment: (3) Five-year review, 2010,
www.epa. gov/regionl/superfund/si
tes/pinette/470820.pdf
TIDecision: ARARs to achieve state MEG (0.5 ppb) are waived for PCBs in groundwater beneath the property.
Rationale: PCBs are bound to aquifer soil particles and not easily removed from the subsurface. However, these PCBs can continue to
dissolve and enter groundwater at concentrations above drinking water standards. The 1989 ROD did not require restoration of groundwater to
drinking water quality, but rather explicitly recognized the technical impracticability, from an engineering perspective, of reducing PCBs to the
Maine MEG of 0.5 ppb. The objectives of the groundwater migration management component of the ROD were (1) to reduce the potential off-
site migration of PCBs by reducing concentrations of associated VOCs that facilitate transport of PCBs, and (2) to prevent ingestion of
contaminated water from the site. Thus, the selected P&T remedy objectives were set to reduce other organic COCs to the following cleanup
goals: benzene, 5 ppb; 1,4-dichlorobenzene, 27 ppb; chlorobenzene, 47 ppb; 1,2,4-trichlorobenzene, 680 ppb; and chloromethane, 10 ppb.
Conditions: NAPL (suspected or observed) - An estimated 1,000 gallons of dielectric fluids containing PCBs were spilled directly to the land
surface (from 3 obsolete electrical transformers brought to the site for salvage).
COCs - PCBs, VOCs, SVOCs, metals
Concentration - Maximum PCB concentrations in the shallow and bedrock groundwater were 23 and 7.4 ppb, respectively,
based on unfiltered samples reported in the 1989 ROD.
Geology - The site is underlain by two distinct aquifers separated by an intervening clay unit. The clay unit has a low
permeability relative to the overlying alluvium, acts as an aquitard limiting the downward movement of recharge waters and
contaminants. The clay unit also creates semi-confined conditions for the underlying till/fractured rock aquifer zone.
77 Zone - The extent of the TI zone is undefined in the 1989 ROD but includes the area where the salvage yard operations took
place on the Roger and Cynthia Pinette property. ICs (a restrictive covenant to the property, which applies to a 260-foot
circle) have been issued to limit groundwater use, and other activities, on a portion of this property until Maine DEP
determines that such restrictions are no longer necessary.
Evaluation: Remedial Timeframe Estimate (years) - The timeframe to restore groundwater was not estimated in the ROD, because the
removal of PCBs, sorbed to particulates, in groundwater was unlikely to be sufficient to meet Maine MEGs.
Remedial Action Alternatives - Excavation and removal of PCBs and other organic COC-contaminated soils. Following
excavation, collection and treatment of COC-contaminated groundwater in the alluvium using interceptor trenches. P&T
was selected to address other organic contamination present in the aquifer underlying the clay unit.
Current Status/Activities: The source control remedial action was completed in 1993, and VOC concentrations have decreased to below or
near target cleanup goals, as established in the 1989 ROD. Thus, additional extraction and treatment of groundwater is no longer warranted.
ICs, including a restrictive covenant, have been issued. The site was deleted from the NPL in 2002. As part of the 5-year review, groundwater
samples were collected in 2009 and sampling results indicate that PCB concentrations in groundwater (within the 1C area) remain above the
cleanup goal.
August 2012
A-2
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Sullivan's Ledge
State: MA; OU: I
Decision Doc. (Type &Date):
ROD, 6/29/89
Stage: Pre Construction
Media: Ground water
References: (1) ROD, OU 1,
6/29/89,
www.epa. gov/superfund/sites/rods/
fuHtext/r0188029.pdf; (2) Five-
year review, 2003,
www.epa. gov/superfund/sites/fivev
ear/f03-01009.pdf: (3) Five-year
review, 2008,
www.epa. gov/superfund/sites/fivev
ear/f2008010002480.pdf
TIDecision: ARARs to achieve MCLs, and state drinking water and groundwater quality standards are being waived for groundwater in the
bedrock due to geologic factors and the presence of DNAPL.
Rationale: EPA concluded that the former granite quarry pits and bedrock fractures contain DNAPL, as a result of dumping liquid wastes into
the pits at depths approaching 150 feet into the bedrock. The determination of technical impracticability is based on the nature of the wastes
and contaminants within the pits and along the bedrock fractures and the geology of the site. Bedrock fractures are irregular both in length and
orientation and, therefore, cannot be accurately located, especially at depths greater than 100 feet. In addition, pockets of highly contaminated
wastes located within the pits and along fractures cannot be cleaned up by conventional excavation and pumping methods as it is technically
not possible to locate and extract the contamination in all the pockets.
Conditions: NAPL (suspected or observed) - DNAPL suspected in deep bedrock. TCE concentrations were observed in one Westbay
multilevel sampling port (zone 5 of well ECJ-4 at more than 200 feet bgs at a location over 1,000 feet from the original
disposal area) to be 270,000 ppb (or approximately 25 percent of its solubility).
COCs - VOCs, SVOCs, PCBs, and metals
Concentration - Initial concentrations observed for total VOCs during the RI were as high as 8,200 ppb (overburden); up to
54,000 ppb (shallow bedrock) including benzene at 1,200 ppb, 1,2-DCE at 51,000 ppb, TCE at 4,000 ppb, vinyl chloride at
6,900 ppb, and up to 95,000 ppb (deep bedrock).
Geology - Fractured bedrock
77 Zone - TI waiver applies to the groundwater on site (former granite quarry pit area) and immediately off site); however the
extent of the TI zone is undefined in the references reviewed..
Evaluation: Remedial Timeframe Estimate (years) - Because achievement of ARARs for groundwater in bedrock was determined to be
impracticable, estimates of remedial timeframes were not provided in the ROD.
Remedial Action Alternatives - Install an impermeable cap over source area and a passive underdrain on top of bedrock to
collect groundwater contamination moving through the overburden. Implement active groundwater collection system using
deep bedrock extraction well in close proximity to disposal pits. The cleanup goal for the passive system is achievement of
AWQS for the designated uses of the receiving waters, and significant reduction in bedrock contamination for the active
collection system. Accomplishment of the active system goal will be determined by either an achievement of 1-10 ppm of
total VOCs, an asymptotic curve using groundwater monitoring data, or both, indicating that significant reductions are no
longer being achieved. A ROD Amendment to revise the active collection system performance goal is contemplated if
monitoring data indicate that increasing or decreasing the concentration goals is needed.
Current Status/Activities: The active groundwater collection system began operation in 1999 and continues to operate; draft ICs restricting
groundwater use and deed restrictions regulating land use are currently being reviewed as of the 2008 5-year review.
August 2012
A-3
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Old Springfield
Landfill
State: VT; OU: 2
Decision Doc. (Type & Date) :
ROD, 9/29/90
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
9/29/90,
www.epa. sov/superfund/sites/rods/
fulltext/rO 19003 3.pdf; (2) Five-
year review, 2003,
www.epa. sov/resionO 1/superfund/
sites/oldsprinsfield/48677.pdf; (3)
Five-year review, 2008,
www.epa. sov/resionl/superfund/si
tes/oldsprinsfield/295800.pdf
TI-Relevant Information
TI Decision: The ARAR to achieve the Vermont Groundwater Protection Act Enforcement Standard for PCE is being waived. Other
groundwater ARARs have not been waived.
Rationale: At this site, two state enforcement standards have been established that are more stringent than MCLs (for PCE and xylenes). EPA
is invoking a waiver of the enforcement standard for PCE, because EPA has determined that in this circumstance, it is technically
impracticable from an engineering perspective to establish a standard below a PQL. The PQL determined in accordance with SDWA methods
will be the cleanup level for PCE, which is equivalent to its MCL.
Conditions: NAPL (suspected or observed) - Maximum concentrations of chlorinated VOCs found in groundwater are less than 10 percent
of their respective solubility limits. However, the potential for entry of NAPLs into the subsurface cannot be dismissed with
certainty given the sources of waste materials and historic disposal practices at this landfill.
COCs - 15 VOCs, 4 SVOCs, naphthalene, 2 PCBs, 3 metals
Concentration - Groundwater concentrations are in Tables 1 and 2 of ROD.
Geology - Overburden materials include glacial till overlying a zone of permeable sand and gravel. These materials are
underlain by fractured bedrock.
77 Zone - The compliance boundary is the downgradient edge of the waste management unit; however, the extent of the TI zone
is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - At least 30 years
Remedial Action Alternatives Installation of an impermeable cap leachate collection using underground drains andP&T
using source control extraction wells
Current Status/Activities: P&T started in 1993 and operation continues. An alternate water supply (municipal water line) has been provided,
and ICs restricting groundwater use are in place. The Vermont standard for PCE was revised in 2005. The state standard (and ARAR) is now
equal to the MCL, thus rendering the original waiver moot. According to the 2008 5 -year review, operation of the P&T system, periodic cap
inspections, and maintenance are currently being conducted at the site.
August 2012
A-4
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Pease Air Force Base,
Site 32/36
State: NH; OU: 4
Decision Doc. (Type &Date):
ROD, 9/26/95
Stage: Pre- construction
Media: Ground water
References: (1) ROD, OU4,
9/26/95,
www.epa. gov/superfund/sites/rods/
fulltext/r0195109.pdf: (2) Revised
Site 32 TI Evaluation, March 1995;
(3) Five-year review, 2009,
www.epa. gov/superfund/sites/fivev
ear/f2009010003308.pdf
TI Decision: ARARs to achieve MCLs are being waived for TCE and its degradation products (1,2-DCE; 1,1-DCE; and vinyl chloride) due to
residual DNAPL and complex hydrogeology.
Rationale: Residual DNAPL is difficult to mobilize by P&T, which may result in extraction of excessive amounts of relatively
uncontaminated groundwater with relatively minimal removal of contaminant mass. In addition, complex hydrogeology is present at the site
and consists of four different overburden units, which are all hydraulically interconnected. Two of the four units (Lower Sand and Glacial Till
units) have a low yield, which makes groundwater extraction difficult. Geotechnical evaluations also found that groundwater extraction from
the shallow fractured bedrock may dewater and cause consolidation of the overlying Marine Clay and Silt unit, potentially resulting in
excessive settlement of nearby buildings. The shallow depth to groundwater, irregular depth to bedrock, and fractured nature of the bedrock
also would limit the potential success of soil vapor extraction, air sparging, and physical barriers (particularly horizontal barriers) to contain
source area contamination.
Conditions: NAPL (suspected or observed) - Free-phase DNAPL has not been observed or recovered but it is believed that residual DNAPL
exists based on TCE concentrations.
COCs - Chlorinated VOCs
Concentration - TCE: 940,000 ug/L maximum
Geology - 4 different units (clay and silt) underlain by fractured bedrock at shallow depths
77 Zone - The TI zone includes residual DNAPL and contaminated groundwater that does not meet ARARs and is restricted to
the source area and that portion of the dissolved-phase plume that can be hydraulically contained by the vertical barrier and
groundwater P&T. Vertically, the zone extends approximately 20 feet into the shallow bedrock.
Evaluation: Remedial Timeframe Estimate (years) - An estimate of 16,985 gallons of residual DNAPL and additional assumptions were
used to calculate the restoration timeframe of 175 years to reduce TCE to acceptable levels using P&T (assuming that all
residual TCE could be mobilized).
Remedial Action Alternatives - The selected remedy includes a vertical barrier coupled with groundwater P&T from two aquifer
units to achieve containment (not restoration) of contaminant plume.
Current Status/Activities: Based on a 2009 5-year review, groundwater containment consisting of a vertical barrier and P&T system is
ongoing at Site 32/36 to protect a drinking water well. ICs (including groundwater and land use restrictions) and groundwater monitoring are
also ongoing.
August 2012
A-5
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Tansitor Electronics,
Inc.
State: VT; OU: 1
Decision Doc. (Type &Date):
ROD, 9/29/95
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/29/95,
www.epa. sov/superfund/sites/rods/
fulltext/r0195117.Ddf: (2) Final
Draft TI Evaluation Report, Feb
1995; (3) Five-year review, 2004,
www.epa. sov/superfund/sites/fivev
ear/f04-01019.pdf . (4) Five-year
review, 2009,
www.epa. sov/superfund/sites/fivev
ear/f2009010003145.rjdf
TI-Relevant Information
TI Decision: ARARs to achieve MCLs are being waived for 1,1,1-TCA; 1,1-DCE; TCE; PCE; and vinyl chloride.
Rationale: The restoration potential of the groundwater was evaluated with computer modeling, which took the following factors into
account: (1) low permeability of the overburden soils, (2) high concentrations of dissolved contaminants, (3) difficulty of extracting 1,1,1-
TCA and 1, 1-DCE, and (4) the assumption that DNAPLs are present. Modeling also was used to evaluate whether short term pumping would
significantly decrease the volume and/or shorten the time to achieve drinking water standards through natural attenuation. See Remedial
Timeframe Estimate below for modeling results.
Conditions: NAPL (suspected or observed) - DNAPLs have not been observed at the site, but high dissolved concentrations of 1 , 1 , 1 -TCA
(up to approximately 470,000 ppb) suggest that DNAPL is present.
COCs - Chlorinated VOCs
Concentration -Based on Table 1 inROD, maximum concentrations were as follows: 1,1,1-TCA-470,000 ppb; 1,1-DCE-
3 800 ppb' PCE 31 pbb' and vinyl chloride 4 pbb
Geology — Low permeability soils
TI Zone - The 9.6-acre TI zone is larger than the area of groundwater contamination. The TI zone was chosen to correspond to
the state's Class IV Aquifer zone (for water management purposes). Only a portion of the TI zone is currently contaminated.
The entire 44-acre site is within the Tansitor property boundary Vertically the TI zone extends to the bedrock surface
(approximately 180 ft bgs) and consists of ablation till and basal till.
Evaluation: Remedial Timeframe Estimate (years) - The timeframe required to meet drinking water standards by extraction/treatment ranged
from 160 years to more than 630 years (with 300 years being the most likely) and the time required to meet drinking water
standards by natural attenuation ranged from 220 years to more than 1 150 years (with 420 years being the most likely)
Based on the modeling results, EPA concluded that even after 50 years of pumping, it would still take approximately 300
more years for natural attenuation to restore groundwater.
Remedial Action Alternatives - Monitoring
Current Status/Activities: Monitoring is ongoing and ICs (deed and groundwater use restrictions) have been implemented. The site was
deleted from the NPL in 1999.
August 2012
A-6
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: South Municipal
Water Supply Well
State: NH; OU: I
Decision Doc. (Type &Date):
BSD, 2/3/97
Stage: Post-construction
Media: Ground water
References: (1) BSD, OU1,
2/3/97,
www.epa. gov/superfund/sites/rods/
fulltext/eO 197007.pdf: (2) Site
summary,
www.vosemite.epa.gov/rl/npl_pad
.nsf/701b6886fl89ceae85256bd20
014e93d/8a38a5b7fd3ee7d385256
9 If0063f6f8! OpenDocument
TIDecision: MCLs were waived for 1,1,1-TCA; 1,1-DCE; TCE;PCE; toluene; and vinyl chloride. The state cleanup level was waived for
1,1-DCA. The "major" COCs are 1,1,1-TCA; TCE; and PCE.
Rationale: When the ROD was issued (9/27/1989) EPA believed, based on the information available at that time, that groundwater ARARs
would be attained within an estimated 32 years. SVE, air sparging, and P&T systems were constructed and operated between 1994 and 1997.
In 1997, EPA determined that it was technically impracticable from an engineering perspective to restore contaminated groundwater within the
responsible party's property to drinking water quality in a reasonable time frame. This was based on reviewing quarterly groundwater
sampling data and considering changes in DNAPL understanding, which occurred since the ROD was issued in 1989. An BSD formalizing the
TI waiver was issued on 2/3/1997. The 1997 BSD and TI Evaluation changed pumping rates and extraction well configurations to
hydraulically contain, not extract and treat, the NHBB area plume within a defined TI Waiver Area.
Conditions: NAPL (suspected or observed) - DNAPLs have been observed in a portion of the site; other source areas are suspected based on
past disposal practices and groundwater quality data.
COCs - Chlorinated VOCs
Concentration - Groundwater data from February 1996 (reported in 1997 BSD Attachment) showed the highest levels of PCE at
21,000 ppb and TCE at 1,300 ppb.
Geology - Site is underlain by glacial/fluvial deposits approximately 20 to 90 ft in thickness. Deposits are predominantly sands
and gravels with silt layers interspersed throughout the subsurface.
TI Zone - The TI zone includes a portion of the site that is currently affected by DNAPLs, which is referred to as the "NHBB
area plume." This zone includes both the overburden and bedrock aquifers.
Evaluation: Remedial Timeframe Estimate (years) - EPA's reevaluation indicates that the ARARs may not be attainable for 108 years or
more (based on an estimated DNAPL mass of 20,400 ppm), and due to factors related to hydrogeology and contaminants
that limit the effectiveness of groundwater remediation at the site.
Remedial Action Alternatives - P&T will be continued to maintain hydraulic containment of the plume.
Current Status/Activities: In 2005, a long-term pumping test indicated the hydraulic containment system was not containing the plume within
the TI Waiver Area and in 2008 EPA concluded the remedy was not functioning as intended. A 2009 Focused Feasibility Study identified and
evaluated new remedial alternatives. An amendment to the 1989 ROD was prepared in 2010 to include in situ treatment for soil and
groundwater, including a PRB for groundwater because the P&T system failed to provide sufficient hydraulic control. ICs to restrict
groundwater use have been established.
August 2012
A-7
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Hocomonco Pond
State: MA; OU: I
Decision Doc. (Type &Date):
BSD, 9/21/99
Stage: Post-construction
Media: Ground water
References: (1) BSD, OU1,
9/21/99,
www.epa. gov/superfund/sites/rods/
fulltext/e0199116.pdf: (2) Site
summary,
www.vosemite.epa.gov/rl/npl_pad
.nsf/701b6886fl89ceae85256bd20
014e93d/ee9536bdef65eb8d85256
9 lfD063f6ce IQpenDocument; (3)
Five-year review, 2009,
www.epa. gov/regionl/superfund/si
tes/hocomonco/457922.pdf
TI Decision: ARARs to achieve cleanup levels for COCs in groundwater as established in the 1992 Supplemental Decision Document were
waived upon the approval of the TI waiver.
Rationale: In 1994 and 1995, a P&T system was constructed in an attempt to remove DNAPLs and treat associated groundwater; however,
investigations have revealed that DNAPL (creosote) is present at the site at depths greater than 120 ft bgs. The presence of DNAPLs results in
a limitation in achieving the groundwater cleanup goals. This determination is based on experience gained at other similar sites, which are
contaminated with creosote in sufficient quantities and concentrations to form DNAPLs. Most of the sites where EPA already has determined
that groundwater restoration is technically impracticable have been DNAPL sites. The contamination in the TI waiver area is believed to be
hydraulically contained; that is, its size (the area over which it is distributed) and its concentrations will not increase.
Conditions: NAPL (suspected or observed) - DNAPL is currently being recovered (as of 1999 BSD).
COCs - 8 PAHs, 4 SVOCs, 3 VOCs, 8 metals
Concentration - Concentration ranges listed in Tables 1 through 4 of 1985 ROD.
Geology - The site is underlain by stratified and unstratified glacial drift deposits of varying grain size (clay and silt to gravel
and larger) and thickness. These materials are in turn underlain by fractured bedrock. The topography of the upper surfaces of
finer-grained unconsolidated units and bedrock has influenced DNAPL distribution and transport.
TI Zone - The TI zone is undefined in the references reviewed; however it is described inFigures 3-1 and 3-2 of the TI
Demonstration report.
Evaluation: Remedial Timeframe Estimate (years) - unknown/indefinite. Both DNAPL and dissolved phase contamination will continue to
be present for a long period of time; therefore, groundwater clean-up goals will not be met in a reasonable time frame.
Remedial Action Alternatives - The 1999 BSD calls for continued recovery of DNAPL/creosote and long-term monitoring to
contain the plume and prevent the increase in contaminant levels and extent.
Current Status/Activities: DNAPL (creosote) recovery continues using gravity drainage to collector wells with periodic removal and shipment
to an offsite disposal facility. As of the 1999 BSD, DNAPL recovery had removed almost 63,000 gallons (about 50-100 gal/month) of pure
creosote. This system will continue until recovery is no longer practicable. COCs have been detected above clean-up levels in a well located
outside the TI zone. An investigation is underway to determine the extent of the exceedance and evaluate alternatives. The 2009 5-year review
recommends (1) that deed restrictions be finalized and recorded and (2) that the DNAPL recovery system currently in operation be evaluated
for optimization.
August 2012
A-8
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Loring Air Force Base,
Entomology Shop (ES) and Jet
Engine Build-up Shop (JEBS)
State: ME; OU: 12
Decision Doc. (Type &Date):
ROD, 9/19/99
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU12,
9/19/99,
www.epa. sov/superfund/sites/rods/
fulltext/r0199118.Ddf: (2) Five-
year review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f2010010003579.rjdf
TI-Relevant Information
TI Decision: ARARs (federal MCLs and state MEGs) are waived for TCE; cis-l,2-DCE; vinyl chloride; naphthalene; and benzene.
Rationale: Two large groundwater contaminant plumes (JEBS North and South Plumes) are present in the fractured bedrock aquifer. The
physical and chemical data, coupled with aquifer test analysis, 3-D fracture flow, and fate and transport modeling, indicate residual chlorinated
and fuel-related compounds are being retained within the primary and secondary porosity features of the bedrock aquifer matrix and will
continue to contribute contaminants to the groundwater.
Conditions: NAPL (suspected or observed) - DNAPL may be present as "ganglia" or "residual" product.
COCs - Chlorinated VOCs, naphthalene, benzene
Concentration - Maximum concentrations are as follows for the JEBS North Plume (in ppb) : TCE-1,556; cis-l,2-DCE-700;
vinyl chloride-71; and naphthalene-1,436. Maximum concentrations are as follows for the ES/JEBS South Plume (in ug/L):
TCE-2,800; cis-l,2-DCE-500; vinyl chloride-300; naphthalene- 100; andbenzene-370.
Geology - Fractured bedrock
77 Zone - TI zone encompasses an area of 2,000 feet by 1,000 feet, and vertically from the water table to 300 feet bgs.
Evaluation ' Remedial Timeframe Estimate (years) Although source areas have been excavated and treated using bioventing and S VE
P&T and in situ treatments were determined to be ineffective at achieving groundwater cleanup within a reasonable
timeframe (100 years)
Remedial Action Alternatives MNA is the selected remedy which is expected to achieve goals in 320 years based on
numerical, groundwater-contaminant fate and transport modeling.
Current Status/Activities: Based on a 2010 5-year review, bioventing and SVE are still being conducted to address potential leaching of
COCs from soils to groundwater in this area. The 2010 5-year review recommends that a new technologies review document be prepared per
TI waiver site requirements. The ROD selected implementing ICs (land use and well restrictions, which have been established) and providing
an alternate water supply to current and future areas/residents affected.
August 2012
A-9
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Loring Air Force Base,
Quarry site
State: ME; OU: 12
Decision Doc. (Type &Date):
ROD, 9/19/99
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU12,
9/19/99,
www.epa. gov/superfund/sites/rods/
fulltext/r0199118.pdf: (2) Five-
year review, 2005,
www.epa. gov/superfund/sites/fivev
ear/f05-01004.pdf: (3) Five-year
review, 2010,
www.epa. gov/superfund/sites/fivev
ear/f2008010002480.pdf
77Decision: ARARs (federal MCLs and state MEGs) are being waived for PCE; cis-l,2-DCE; 1,2-DCA; TCE; vinyl chloride; 1,1-DCE;
benzene; toluene; and naphthalene.
Rationale: It is believed that residual LNAPL and/or DNAPL contamination retained within the vadose zone of the fractured bedrock aquifer
is the current source of contamination in the groundwater. Source removal activities have been conducted. Given the large degree of
uncertainty regarding the amount of contaminant mass remaining and the hydraulic conditions at the site, it has been determined that no
currently available remedial technology can achieve cleanup of the groundwater within a reasonable timeframe (100 years), based on
calculations and computer modeling.
Conditions: NAPL (suspected or observed) - DNAPL is likely due to PCE concentration (38,000 ug/L). LNAPL also was observed in site
wells.
COCs - Chlorinated VOCs, BTEX, naphthalene
Concentration - Maximum concentrations were as follows (in ug/L): PCE-38,000; cis-l,2-DCE-5,500; 1,2-DCA-21; TCE-
8,100; vinyl chloride-500; 1,1-DCE-250; benzene-1,400; toluene-1,600; naphthalene-160. Investigations in 1998 found
previously unidentified VOCs at the following concentrations (in ug/L): 1,1,2-TCA-250; carbon tetrachloride-4,300;
chlorobenzene-200; and ethylbenzene-1,700.
Geology - Fractured bedrock
77 Zone - Based on the area where PCE and TCE exceed federal MCL and state MEG, the TI zone encompasses an area
approximately 1,700 feet by 600 feet, and vertically from the water table to 300 feet bgs.
Evaluation: Remedial Timeframe Estimate (years) - Based on an estimated contaminant release of 12 to 242 gallons of PCE, cleanup time
ranges from 168 to 1,152 years for the no action and MNA alternatives and from 87 to 308 years for in situ chemical
treatment.
Remedial Action Alternatives - Given the large degree of uncertainty associated with the amount of contaminant mass remaining
and the hydraulic conditions at the site, it has been determined that no currently available remedial technology can achieve
cleanup of the groundwater within a reasonable timeframe (100 years), based on calculations and computer modeling.
Current Status/Activities: Groundwater management zones and ICs (groundwater use restrictions) have been established. An alternate water
supply will be provided to future transferees of property within the groundwater use restriction boundaries. The 2010 5-year review indicates
that the Air Force is determining a reasonable method for assuring water is available. Long-term groundwater monitoring is currently being
conducted.
August 2012
A-10
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: McKin Superfund Site
State: ME; OU: 2
Decision Doc. (Type &Date):
ROD Amendment, 3/30/01
Stage: Post-construction
Media: Ground water
References: (1) ROD Amendment,
OU2, 3/30/01,
www.epa. gov/superfund/sites/rods/
fulltext/a0101015.pdf: (2) TI
Evaluation and Determination
Report, Jan 2001;
(3) Five-year review, 2008,
www.epa. gov/superfund/sites/fivev
ear/f2009010003306.pdf
TI Decision: ARARs to achieve MCLs and MEGs are waived for all COCs in groundwater: TCE; 1,1,1-TCA; cis-l,2-DCE; 1,1-DCE; PCE;
and vinyl chloride.
Rationale: Restoration of the bedrock aquifer is not practical for the following reasons: (1) there is a pathway from the McKin property to the
bedrock aquifer and residential wells; (2) data indicate that the potential DNAPL entry zone into the bedrock could extend for several hundred
feet north, making the identification of the actual pathway(s) difficult; (3) the presence of TCE in shallow bedrock wells suggest the lateral
extent of the bedrock contamination; (4) TCE concentrations suggest the presence of a nearby residual source; (5) the discovery of TCE in the
overburden east of Collyer Brook without an identified overburden plume connecting it to the McKin Site suggests bedrock transport; and (6)
contaminants remain in the bedrock and have not been flushed out by natural groundwater flow. Additional factors apply to restoration of the
surficial aquifer: (1) the saturated thickness varies from a few feet near the facility to over 100 feet in the southerly trending bedrock trough;
(2) drilling logs indicate a discontinuous glacial till unit above the bedrock, which can adsorb DNAPL and act as a source for the more
permeable units; and (3) it is likely that DNAPL in residual form is present in the bedrock and there are likely to be multiple areas where
seepage occurs from the bedrock into the overburden.
Conditions: NAPL (suspected or observed) - DNAPL may be present in the overburden and bedrock aquifers. Soil concentrations indicate
free-phase chlorinated VOCs were probably released and entered the overburden aquifer. Source control actions in the mid-
1980s treated the contaminated soils above the water table in the McKin property. Groundwater concentrations indicate that
residual DNAPL is also likely in the bedrock aquifer.
COCs - Chlorinated VOCs, primarily TCE
Concentration - Initial concentrations were 16,000 ppb for TCE and 170 ppb for 1,1,1-TCA in the surficial aquifer, while
bedrock aquifer concentrations were 29,000 ppb and 500 ppb, respectively.
Geology - Two aquifers: overburden and underlying fractured bedrock
77 Zone - The TI zone covers the same horizontal area as the ICs zone and vertically extends to the bedrock. The zone includes
the McKin property (7 acres) and extends primarily in the downgradient direction to and beyond the Royal River and
Collyer Brook. See Figure 2 in the 2001 ROD Amendment or Figure 6 of the Final TI Report.
Evaluation: Remedial Timeframe Estimate (years) - Extrapolation of monitoring data indicate that the concentrations will achieve drinking
water standards in the surficial and bedrock aquifers at the perimeter of the plume in about 20 years and about 50 years at
the center of the plume.
Remedial Action Alternatives - The remedial alternative includes long-term monitoring of groundwater, surface water, and
institutional controls.
Current Status/Activities: An alternate water supply was provided for this site (emergency water supplies followed by extension of the
municipal system). P&T operated from 1990 to 1995 when it was shut down to evaluate for TI. A 2001 ROD Amendment was issued to
replace P&T with ICs (town zoning ordinance and covenants to restrict groundwater use) and long-term monitoring. According to the 2008 5-
year review, all but one of the overlapping ICs have been implemented and the source control remedy, which involved the excavation,
treatment, and stabilization of VOC-impacted soil, is complete.
August 2012
A-11
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: O'Connor Superfund
Site
State: ME; OU: 2
Decision Doc. (Type &Date):
ROD Amendment, 9/26/02
Stage: Post-construction
Media: Groundwater
References: (1) ROD Amendment,
OU2, 9/26/02,
www.epa. gov/superfund/sites/rods/
fulltext/a0102023.pdf: (2) TI
Evaluation Report, June 2002; (3)
Site summary,
www.vosemite.epa.gov/rl/npl_pad
.nsf/701b6886fl89ceae85256bd20
014e93d/86cca6f85c3a63b385256
9 If0063f6e2! OpenDocument
TI Decision: ARARs to achieve MCLs and state MEGs are waived for all groundwater contaminants: benzene; 1,4-dichlorobenzene (DCB);
PCBs; chlorobenzene; 1,2-DCB; 1,3-DCB; 1,2,3-trichlorobenzene (TCB); 1,2,4-TCB; and 1,3,5-TCB.
Rationale: The continued presence of separate phase PCB-laden oil four years after the successful completion of the source control action
suggested that restoration of groundwater using extraction and treatment is not possible. Following the source removal action, post-ROD data
indicated the primary source of both oil and chlorobenzenes was the fractures in the clay. A VER system was selected rather than a traditional
P&T because it was capable of removing oil and groundwater without significantly lowering the water table, and thereby would limit the
mobility of the oil. VER operated actively between 1996 and 2002 and removed approximately 55 gallons of oil. Based on the observed trends
of decreasing VOC concentrations before the ROD Amendment, it was estimated that VOC concentrations would be below MCLs and MEGs
at wells outside the TWA II Area within the next 5 to 10 years. However, it could take hundreds of years to remove the residual oil and meet
drinking water standards for PCBs and VOCs within the TWA II Area. Even though the VER system has removed a moderate amount of
residual oil, and may continue to remove oil, the difficulty of inducing oil movement within the clay desiccation cracks and the bedrock
fractures makes it unlikely that the residual oil can be completely removed. Therefore, there will always be residual oil available to water
infiltrating into the TWA II Area.
Conditions: NAPL (suspected or observed) - DNAPL is not present but separate-phase PCB-laden oil is present
COCs - VOCs SVOCs, PCBs
Concentration - Maximum dissolved concentrations in 2001 were as follows in ug/L: benzene-8; 1,4-DCB-720; PCBs-44;
chlorobenzene-240; 1,2-DCB-210; 1,3-DCB-160; l,2,3-TCB-98; and 1,2,4-TCB-770
Geology - Fractured clay and fractured bedrock
TIZone - The TI Zone includes areas where VOCs and PCBs are present in groundwater at concentrations above ROD target
cleanup goals and current MCLs and MEGs. Laterally, the TI Zone covers approximately 3 acres and includes the TWA II
Area and the area associated with shallow groundwater flow to the south of the TWA II Area. Vertically, the TI Zone
extends into bedrock.
Evaluation: Remedial Timeframe Estimate (years) - Based on the observed trends of decreasing VOC concentrations, it is estimated that
VOC concentrations will be below MCLs and MEGs at wells outside the TWA II Area within the next 5 to 10 years.
However, it could take hundreds of years to remove the residual oil and meet drinking water standards for PCBs and VOCs
within the TWA II Area itself.
Remedial Action Alternatives - The remedial action alternative was annual active oil recovery using vacuum extraction in TWA
II wells, passive oil recovery throughout the year, monitoring, and ICs.
Current Status/Activities: According to site summary, source removal activities have been completed. Groundwater monitoring is ongoing.
Groundwater monitoring shows that performance standards for VOCs and PCBs beyond the TI Zone have been attained and maintained since
fall 2002 and spring 2006, respectively. ICs have been implemented for the entire site, including the groundwater.
August 2012
A-12
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Durham Meadows
State: CT; OU: 1
Decision Doc. (Type &Date):
ROD, 9/30/05
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/30/05,
www.epa. gov/superfund/sites/rods/
rulltext/rO 105007.pdf: (2) Draft TI
Evaluation Report, June 2005; (3)
Site summary,
www.vosemite.epa.gov/rl/npl_pad
.nsf/701b6886fl89ceae85256bd20
014e93d/9434a73086e515cl85256
90d00449688!OpenDocument: (4)
BSD, September 2011,
www.epa. gov/regionl/superfund/si
tes/durham/492341.pdf
TI Decision: ARARs to achieve cleanup levels (either MCLs, state standards, or health-based standards) are waived for all groundwater
contaminants (see Table 30 in ROD).
Rationale: EPA concluded that restoration of the overburden and bedrock aquifers is not practicable within a reasonable timeframe because
(1) there is widespread contamination in the fractured, sedimentary bedrock aquifer; (2) the depth of contamination in the bedrock aquifer is
not known and would require significant investigations to characterize the vertical extent of contamination; (3) operation of water supply wells
within, and near two DNAPL source areas have contributed to the spread of contamination, both vertically and horizontally, by borehole short-
circuiting and plume mobilization; (4) the overburden aquifer is a fractured, low permeability glacial till formation, which would limit
hydraulic accessibility and removal of DNAPL; and (5) it is likely that pooled or residual DNAPL may be present in the fractures and matrix
of overburden and bedrock units, and these would act as a continuing source for contamination to the dissolved plume. According to the ROD,
there is little benefit to attempting to remediate co-located compounds (chlorinated VOCs, PAHs, BTEX compounds, metals); therefore, the TI
waiver will apply to all dissolved contaminants found at the Site.
Conditions: NAPL (suspected or observed) - DNAPL is likely to be present based on a converging lines of evidence method of assessment
(see pg. 24 of ROD) of two source areas.
COCs- 14 VOCs; 8 PAHs; pentachlorophenol; 1,4-dioxane; 6 metals
Concentration - Maximum concentrations of groundwater contaminants are presented in Table 30 of ROD.
Geology - Two aquifers: overburden and bedrock
77 Zone - The TI Zone encompasses all areas in the overburden and bedrock aquifers that are currently or conceivably could be
impacted by groundwater contamination from the Merriam Manufacturing Company and the Durham Manufacturing
Company study areas; however the extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - The RI/FS determined that no remedial alternative was available to achieve cleanup of
the source zones within a reasonable timeframe.
Remedial Action Alternatives - All homes and businesses in the area use individual onsite bedrock supply wells. Overburden
materials in the area do not support a permanent water table nor provide a dependable source of water. Aggressive
remediation alternatives were deemed deleterious to current use of individual supply wells; therefore, the only alternatives
presented were for hydraulic containment (greater than 100 years) and for no action (see pg. 65 of ROD).
Current Status/Activities: Bottled water and residential treatment units are being provided as an alternate water supply, and water sampling is
being conducted on individual wells. ICs (land and groundwater use restrictions) and extension of the municipal water supply were selected in
the 2005 ROD. The 2011 BSD modifies the 2005 ROD 1C requirement that groundwater use for drinking water purposes be prohibited. Future
groundwater use for drinking water will be prevented unless the water supply is approved and meets Connecticut health code requirements.
The 2011 BSD also specifies that excavation or any other activity below the groundwater table is prohibited and activities within a 25-foot
radius around the groundwater monitoring wells are prohibited. Operation and maintenance environmental monitoring requirements for
groundwater are removed.
August 2012
A-13
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: West Site/Hows
Corner
State: ME; OU: I
Decision Doc. (Type &Date):
ROD, 9/28/06
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/28/06,
www.epa. sov/superfund/sites/rods/
Mltext/r2006010001236.pdf; (2)
TI Evaluation, 4/7/06
TI-Relevant Information
TI Decision: ARARs to achieve state MEGs for PCE; trans- 1,2-DCE; vinyl chloride; dieldrin; PCBs; and manganese, and MCLs for TCE;
1,1-DCE; cis-l,2-DCE; 1,2,4-TCB; and 1,1,1-TCA in groundwater are waived.
Rationale: EPA reached the conclusion that the source area groundwater could not be restored in a reasonable timeframe based on the
following factors: (1) contaminant concentrations suggest the presence of DNAPL in the fractured bedrock; (2) the source is entirely located
in fractured bedrock; (3) the bedrock has a complex, heterogeneous structure, making extraction difficult; (4) in situ chemical oxidation would
not be effective based on a pilot study; and (5) no other technology was identified that could restore the groundwater.
Conditions: NAPL (suspected or observed) - DNAPL is suspected based on concentrations of chlorinated VOCs
COCs - Chlorinated VOCs; dieldrin; PCBs; manganese; 1,2,4-trichlorobenzene
Concentration - Maximum concentrations are as follows (in ppb): PCE-32,000; trans-l,2-DCE-12; vinyl chloride-0.2;
dieldrin-0.24; PCBs-119; manganese-8,540; TCE-7,250; l,l-DCE-57; cis-l,2-DCE-l,000; 1,2,4-TCB-160; and 1,1,1-
TCA-1,000.
Geology - Fractured bedrock
TIZone - The TI waiver applies to source areas where VOC concentrations exceed 10,000 ppb and the probable DNAPL zone.
The lateral extent is approximately 10-12 acres (shown graphically in TI Evaluation Report, Figure 3-1) and extends
vertically to the deep bedrock.
Evaluation: Remedial Timeframe Estimate (years) - Source area groundwater is not expected to meet restoration goals for more than 100
years.
Remedial Action Alternatives - A P&T system will be installed to contain the source area groundwater and prevent it from
continuing to contaminate non-source area groundwater. Upon containment of the source area, the downgradient non-source
area groundwater is expected to be restored in 40-80 years (based on MNA estimates).
Current Status/Activities: The 2002 interim ROD selected P&T to contain the source area groundwater and institutional controls. The 2006
final ROD included a TI waiver for the source area groundwater, MNA for non-source area groundwater, and a requirement for vapor intrusion
investigation. ICs have been implemented. An alternate water supply has already been provided (through construction and operation of
municipal water supply system) and construction of the groundwater hydraulic containment system was completed in 201 1.
August 2012
A-14
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Elizabeth Mine
Superfund Site
State: VT; OU: I
Decision Doc. (Type &Date):
ROD, 9/28/06
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/28/06,
www.epa. gov/regionl/superfund/si
tes/elizmine/259306.pdf: (2) Site
summary,
www.vosemite.epa.gov/rl/npl_pad
.nsf/701b6886fl89ceae85256bd20
014e93d/22814871317824268525
69e400719bbe!OpenDocument
TI Decision: MCLs, MCLGs, and Vermont Primary Groundwater Quality Standards are being waived for all inorganic constituents
(cadmium, copper, manganese, mercury, and nickel) present in naturally occurring material.
Rationale: The primary basis for this waiver is that the source of contamination, wall rock and waste rock within the Underground Workings,
will generate conditions that cause the water to exceed the standards for hundreds, if not thousands, of years. The Underground Workings are
flooded in some areas and act as a large tunnel or drain having an infinite hydraulic conductivity. While it would be practicable to collect and
treat the discharge from the Underground Workings or to prevent the spread of the contamination from the Underground Workings into the
adjacent aquifer, EPA has determined that there are no practicable actions that would result in the water within the Underground Workings to
consistently meet groundwater standards. EPA retains the MCLs, MCLGs, and Vermont Primary Groundwater Quality Standards as
compliance criteria for the groundwater at the edge of the TI zone, which is the aquifer surrounding the Underground Workings. EPA has also
determined that contaminated water within the Underground Workings is not causing the adjacent bedrock aquifer to exceed federal or state
drinking water or groundwater standards.
Conditions: NAPL (suspected or observed) - NAPL is not an issue at this site.
COCs - Cadmium, copper, manganese, mercury, and nickel
Concentration - Maximum concentrations in the Underground Workings (in mg/L, from Table 58 of ROD): cadmium-88.3;
manganese-3,030; mercury-10.2; and zinc-16,200.
Geology - Two water-bearing zones present at the site are separated by a glacial basal till layer that has a thickness of up to 75
feet. The shallow water-bearing zone has a thickness of 2 to 3 feet and consists of sand, gravel, and debris. The deeper zone
is in the fractured bedrock layer.
77 Zone - Waiver applies to groundwater in the Underground Workings area and does not apply to adjacent bedrock aquifer;
however the extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - The continuing source of contamination will cause the water to exceed the standards
for hundreds, if not thousands, of years.
Remedial Action Alternatives - The selected remedy includes ICs (land use, well and groundwater use restrictions) and long-
term monitoring. The only other remedy evaluated for site-wide groundwater in the 2006 ROD was the No Action
alternative.
Current Status/Activities: A time-critical removal action was conducted from 2003 to 2005 to stabilize the Tailings Dam and improve surface
water drainage. A non-time-critical removal action began in 2006 and continues to control the release of acid mine drainage. Additional
containment and surface water controls were selected in the 2006 ROD, in addition to monitoring and ICs. According to the site summary
(November 2011), the cover system for 22 acres of the 45-acre tailing impoundment was completed in 2011. Remaining activities at the site
include the installation of the passive treatment system and the Remedial Design of the Lord Brook Source areas. Land use restrictions and the
long-term monitoring program will continue.
August 2012
A-15
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Caldwell Trucking Co.
State: NJ; OU: 1
Decision Doc. (Type &Date):
ROD, 9/28/89
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
9/28/89,
www.epa. sov/superfund/sites/rods/
fulltext/r0289096.Ddf: (2) Five-
year review, 2002;
www.epa. sov/superfund/sites/fivev
ear/f02-02004.Ddf: (3) Site
summary,
www.epa. sov/Resion2/superfund/
npl/0200340c.pdf; (4) Five-year
review, 2007,
www.epa. sov/superfund/sites/fivev
ear/f200702000 1676.pdf
TI-Relevant Information
Region 2: 11 sites
TI Decision: Federal and state MCLs are being waived for all contaminants, predominantly TCE.
Rationale: Due to the extent and concentration of the groundwater plume and the impact of other sources in the area, it would take more than
100 years to clean the aquifer to drinking water standards. Computer modeling indicated that after using P&T for 100 years, TCE
concentrations would range from 0.9 to 19 ug/L in the upper and lower aquifers, respectively.
Conditions: NAPL (suspected or observed) - NAPL is suspected because of reported extremely high concentrations of VOCs, particularly
TCE in the soil, with an unconfirmed reference to pure contaminant product during early remediation work. TCE
concentration in one groundwater monitoring well was 680,000 ug/L.
COCs - TCE
Concentration - In the 1989 ROD, TCE concentrations ranged from 1,004 to 3,637 ug/L in the water table aquifer and 556.2 to
5,250 ug/L in the lower bedrock aquifer.
Geology - Two aquifers: upper water table and lower bedrock. The upper and lower aquifers are divided into four zones. The
"A Zone" is shallow surface aquifer, which is separated from the deeper bedrock aquifer zone by a clay layer. The deeper
bedrock groundwater is divided into three zones: the "B Zone," the "C Zone," and the "D Zone" based on structure of the
material comprising the zone.
77 Zone - The TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Due to the extent and concentration of the groundwater plume and the impact of other
sources in the area it would take more than 100 years to clean the aquifer to drinking water standards
Remedial Action Alternatives - The selected remedy includes P&T to reduce contaminant levels, ICs, and alternate water supply.
In 1993 an ESD was issued that implemented the contingent remedy which includes P&T to intercept the most
contaminated portions of the plume (lower water table aquifer and upper bedrock aquifer)
Current Status/Activities: According to the 2007 5 -year review and site summary (August 201 1), P&T has been installed, an alternate water
supply has been provided, in situ bioremediation and PRB pilot studies have been conducted, and the area downgradient of the Site has been
placed into the State's Classification Exception Area. The groundwater recovery wells have been installed, but additional work needs to be
completed to ensure that containment of the source groundwater is achieved. Information obtained since the 1989 ROD has confirmed that
MCLs cannot be achieved within a reasonable timeframe.
August 2012
A-16
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: GEMoreau
State: NY; OU: I
Decision Doc. (Type &Date):
BSD, 10/6/94
Stage: Pre-construction
Media: Ground water
References: (1) BSD, 10/6/94; (2)
Five-year review, 1998,
www.epa. gov/superfund/sites/fivev
ear/f98-02004.pdf: (3) Site
summary,
www.epa. gov/region02/superfund/
npl/0201858c.pdf: (4) Five-year
review, 2008,
www.epa. gov/superfund/sites/fivev
ear/f2008020002572.pdf
TIDecision: Federal MCLs waived: TCE-5 ug/L; vinyl chloride-2 ug/L; l,l-DCE-7 ug/L; total trihalomethanes-100 ug/L; and state
ambient water quality criteria waived: trans-1,2-DCE-50 ug/L; methylene chloride-50 ug/L.
Rationale: The original remedy selected in the 1987 ROD included groundwater restoration using natural gradient flushing to the nearby
brook, where groundwater would be treated along with surface water via air stripping. Alternate water supply and ICs were also selected.
Following the ROD, additional evaluation was conducted and it was determined that either remedy (natural gradient flushing with treatment or
P&T) would take 200 years or more to achieve restoration (based on modeling). This is due to (1) heterogeneity of the aquifer (such as
variations in hydraulic conductivity and geologic stratigraphy); (2) contaminant-related constraints (such as the nature and extent of release
[large volume over long time], chemical and physical properties); and (3) contaminant phases (dissolved, gaseous, sorbed, and DNAPLs). In
addition, in 1985, a containment system (cap and VEB) was installed to isolate DNAPL contamination. Dewatering was conducted (1994-1996
and 2003-2004) to ensure an inward gradient and limit outward migration.
Conditions: NAPL (suspected or observed) - NAPL is present. TCE was disposed in DNAPL form and is encapsulated behind the slurry
wall and cap.
COCs - Chlorinated VOCs, total trihalomethanes
Concentration - TCE concentrations averaged from 10,000 to 20,000 ug/L in the upper zone, with a maximum concentration of
81,000 ug/L. The maximum TCE concentration was 1,800 ug/L in the lower zone.
Geology - The surrounding aquifer is primarily sand and gravel from glacial outwash.
77 Zone - ARARs waived for entire groundwater plume area (4,800 feet long by 2,000 wide and an average thickness of 60
feet).
Evaluation: Remedial Timeframe Estimate (years) - Following the 1987 ROD, additional evaluation was conducted and it was determined
that either remedy (natural gradient flushing with treatment or P&T would take 200 years or more to achieve restoration
(based on modeling).
Remedial Action Alternatives - In 1985, a containment system (cap and VEB) was installed to isolate DNAPL contamination.
Dewatering was conducted (1994-1996 and 2003-2004) to ensure an inward gradient and limit outward migration.
Current Status/Activities: Based on the site summary (February 2011), an air stripper continues to operate at the brook to treat both
groundwater and surface water. In addition, an alternate water supply has been provided and ICs are in place. The 2008 5-year review
documented dewatering activities of the containment system in 2003 and 2004. Reportedly, more than 1 million gallons of contaminated
groundwater were removed, treated, and disposed of on-site.
August 2012
A-17
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Niagara Mohawk
Power Corp. (Saratoga Springs
Plant)
State: NY; OU: 00
Decision Doc. (Type &Date):
ROD, 9/29/95
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, 9/29/95,
www.epa. sov/resion02/superfund/
nrjl/0202182c.rjdf: (2) Five-vear
review, 2006,
www.epa. sov/resion02/superfund/
nrjl/0202182c.rjdf: (3) Five-vear
review, 2011,
www.epa. sov/superfund/sites/fivev
ear/f20 11020004031.pdf
TI-Relevant Information
TI Decision: Federal and state drinking water standards and state groundwater quality standards for the shallow groundwater contained within
a containment system on the Niagara Mohawk property are being waived for a variety of VOCs, P AHs, and inorganics . This waiver does not
apply to other contaminated areas at the site.
Rationale: ARARs are being waived on the shallow aquifer contained within a cap and VEB only under the Niagara Mohawk property based
on two technical limitations: (1) approximately 7 acres of contaminated aquifer materials residing above a thick subsurface clay layer (which
begin at 20 feet bgs) would require excavation and off-site disposal to remove all the DNAPL from the Niagara Mohawk property area; and (2)
all operating facilities on the Niagara Mohawk property area would need to be demolished to allow access to the contaminated area
underneath. It is technically impracticable to excavate an area this large; as a result, DNAPL and PAHs will remain contained within the cap
and VEB system after the selected remedy is implemented.
Conditions: NAPL (suspected or observed) - DNAPL is present.
COCs - VOCs, PAHs, inorganics
Concentration - Maximum concentrations in the shallow aquifer (in ppb): benzene-14,000; ethylbenzene-3,500; toluene-
5,700; xylene-3,700; and naphthalene-6,400. Additional concentrations provided in Table 2 of ROD.
Geology - In descending order: fill, upper glaciolucustrine clay (thickness ranging from 27 to 53 feet), and till.
77 Zone - TI applies to the shallow aquifer contained within a cap and VEB system on the Niagara Mohawk property; however,
the extent of the TI zone is undefined in the references reviewed. This waiver does not apply to other contaminated areas at
the site.
Evaluation: Remedial Timeframe Estimate (years) — No time frame was estimated
Remedial A ction A Iternatives - The selected remedy is to establish hydraulic control of the Niagara Mohawk property
contaminated groundwater, specifically to prevent groundwater and DNAPL from flowing off site by using a containment
system (VEB and cap) and P&T, soil and sediment removals, ICs, and monitoring.
Current Status/Activities: Based on a 201 1 5-year review, source and sediment removal activities have been conducted, a VEB has been
installed and is being used with P&T for containment, post-remedy monitoring is being conducted, and ICs (deed restrictions) are in place.
August 2012
A-18
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Love Canal
State: NY; OU: 9
Decision Doc. (Type &Date):
ROD, 5/15/91
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU9,
5/15/91,
www.epa. sov/superfund/sites/rods/
fulltext/r0291 165.pdf; (2) Five-
year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f03-02018.rjdf: (3) Site
summary,
www.epa. sov/Resion2/superfund/
npl/020 1290c.pdf; (4) Five-year
review, 2008,
www.epa. sov/superfund/sites/fivev
ear/f2008020002577.rjdf
TI-Relevant Information
TI Decision: ARARs are waived for all contaminants, including iron and others (list not provided in ROD).
Rationale: ARARs are being waived based on the following considerations: (1) groundwater is not used and is not planned to be used for
drinking purposes; (2) there is no route of exposure for groundwater to the population; (3) regional groundwater quality compares to
groundwater quality in the Niagara Falls area; (4) treatment of groundwater may not be practicable, due to low contamination levels; and (5)
all contaminated soils are being excavated and disposed off-site.
Conditions: NAPL (suspected or observed) - NAPL is being recovered in the barrier drain system.
COCs - Iron and others (list not provided in ROD)
Concentration - Table 3 of ROD not provided in online version.
Geology - Overburden bedrock varies from 25 to 27 feet thick and consists of glacial till covered by layers of clay, silt, fine
sand, and fill.
77 Zone - TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Assessment not done.
Remedial Action Alternatives — No remedy for groundwater was selected in this ROD' excavation and off-site disposal was the
selected remedy for this OU.
Current Status/Activities: The 2008 5-year review mentions that ICs in the form of zoning restrictions, deed restrictions, and land use
restrictions are in place The only groundwater remedies found were a shallow interceptor trench (barrier drain system) installed in 1978 to
August 2012
A-19
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Dupont/Necco Park
State: NY; OU: I
Decision Doc. (Type &Date):
ROD, 9/18/98
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU1,
9/18/98,
www.epa. sov/superfund/sites/rods/
Mltext/r0298 144.pdf
TI-Relevant Information
TI Decision: Federal and state drinking water standards and state groundwater quality standards for the groundwater are being waived.
Rationale: Groundwater remediation in the source area is impracticable because (1) removal of all the DNAPL would require excavation of
more than 1 million cubic yards of landfill materials and (2) DNAPL has migrated into the fractured bedrock, the on-site landfill, and nearby
waste cells, and no technologies are currently available to completely remove DNAPLs from the fractured bedrock.
Conditions: NAPL (suspected or observed) - DNAPL is present
COCs - Chlorinated VOCs and SVOCs (hexachlorobutadiene; hexachlorobenzene; carbon tetrachloride; chloroform; PCE;
TCE; 1,1,2,2-PCA)
Concentration - DNAPL at 330,000 ug/L
Geology - Fractured bedrock
TI Zone TI applies to source area (24-acre landfill)' however the vertical extent of the TI zone is undefined in the references
reviewed
Evaluation: Remedial Timeframe Estimate (years) - EPA expects MCLs will never be achieved within the source area.
Remedial Action Alternatives - The selected remedy for the source area includes hydraulic containment via P&T, VEB, or both;
DNAPL recovery; and ICs. It is expected that groundwater outside of the source area (known as far-field) would naturally
attenuate to groundwater standards; however, a degree of uncertainty exists and additional information will be required to
fully evaluate the potential for achievement of MCLs in the far-field area.
Current Status/Activities: This site is not on the NPL and additional information is not available online.
August 2012
A-20
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Federal Creosote
State: NJ; OU: 3
Decision Doc. (Type &Date):
ROD, 9/30/02
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU3,
9/30/02,
www.epa. sov/superfund/sites/rods/
Mltext/r2002020001368.pdf; (2)
Draft Final FS, 6/28/02; (3) Site
summary,
www.epa. sov/resion02/superfund/
npl/0204097c.pdf; (4) Five-vear
review, 2007,
www.epa. sov/superfund/sites/fivev
ear/f200702000 1680.pdf
TI-Relevant Information
TI Decision: The following Federal or state standards are being waived (or the PQL was waived for standards that were less than the PQL) :
benzo(a)pyrene-5 ppb; dibenzo(a,h)anthracene-5 ppb; benzo(a)anthracene-5 ppb; chrysene-5 ppb; benzo(b)fluoranthene-5 ppb;
benzo(k)fluoranthene-5 ppb; indeno(l,2,3-cd)pyrene-5 ppb; benzene-1 ppb; and naphthalene-300 ppb.
Rationale: The determination of a TI waiver is based on three factors : ( 1 ) the persistence of DN APL contaminants and their presence in
fractured bedrock are expected to result in the inability to meet ARARs for the foreseeable future; (2) limited options are available to
successfully treat DNAPL in fractured bedrock; and (3) alternatives would cause short-term and/or long-term disruptions in a residential and
commercial community. While several alternatives offered some prospect of success at treating at least a portion of the DNAPL contamination,
this benefit was weighed against the significant community disruptions and other implementability concerns. The selected remedy includes soil
excavation and ICs for both soil and groundwater.
Conditions: NAPL (suspected or observed) - DNAPL has been detected at depths of 120 feet bgs.
COCs - PAHs, benzene
Concentration - Maximum concentrations in OU3 groundwater: benzo(a)pyrene-l 1 ppm; dibenzo(a,h)anthracene-ND;
benzo(a)anthracene-21 ppm; chrysene-14 ppm; benzo(b)fluoranthene-9 ppm; benzo(k)fluoranthene-13 ppm; indeno(l,2,3-
cd)pyrene-l ppm; benzene-68 ppm; naphthalene- 13, 000 ppb.
Geology - Fractured bedrock
77 Zone - TI Zone covers 119 acres and both the overburden and bedrock aquifers.
Evaluation: Remedial Timeframe Estimate (years) — No timeframe estimate was provided in the RI
Remedial Action Alternatives - The selected remedy includes soil excavation and ICs for both soil and groundwater.
Current Status/Activities: ICs are partially in place and some residents have been relocated. NJDEP has applied deed notices to 5 residential
properties and EPA is in the process of placing deed notices on 13 other residential properties. NJDEP plans to have three residential and one
commercial property owner apply deed notices to their properties. NJDEP plans to institute a Classification Exception Area for groundwater
(that is, an area, projected out five years, of no groundwater use). According to the 2007 5 -year review, the first round of long-term
groundwater monitoring was conducted in 2005 and the Classification Exception Area was anticipated to be in place by 2008. According to the
Site Summary (February 201 1), source removal and remediation activities have been completed.
August 2012
A-21
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Hudson River PCBs
State: NY; OU: 2
Decision Doc. (Type &Date):
ROD, 2/1/02
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU2,
2/1/02,
www.epa. sov/hudson/RecordofDe
cision-textpdf; (2) Site summary.
www.epa. sov/hudson/pdf/hudson
riverfactsheet 2011.pdf; (3) Fact
Sheet, January 20 12,
www.epa.sov/hudson/Phase2 Dre
dsins.pdf
TI-Relevant Information
TI Decision: Three of seven standards are being waived for total PCBs in surface water: federal water quality criteria-1 ng/L; state standard
for protection of wildlife-0. 12 mg/L; and state standard for protection of human consumers of fish-0.00 1 ng/L.
Rationale: Due to upstream sources of PCBs, EPA has determined that it is technically impracticable to meet 3 of 7 ARARs for the Hudson
River for the 70 -year forecast period.
Conditions: NAPL (suspected or observed) - No
COCs-PCBs
Concentration - Total PCB concentrations averaged 90 ng/L from 1996 to 2000.
Geology - The river is underlain by glacial Lake Albany clays and shale formations.
77 Zone - The TI applies to the Hudson River; however the extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Four of 7 ARARs can be met within 70-year forecast period
Remedial Action Alternatives — The selected remedy includes dredging river sediments MNA for PCB contamination remaining
in the river following excavation, and ICs. Additional actions are associated with nearby sites and other RODs for this site.
Current Status/Activities ' The site summary (November 20 11) does not indicate if ICs have yet been implemented The second and final
phase of the cleanup project commenced in 201 1 and sediment dredging is currently underway.
August 2012
A-22
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Roebling Steel
Company
State: NJ; OU: 5
Decision Doc. (Type &Date):
ROD, 9/30/03
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU5,
9/30/03,
www.epa. gov/superfund/sites/rods/
fuHtext/r2003020003518.pdf; (2)
Five-year review, 2009,
www.epa. gov/superfund/sites/fivev
ear/f2009020002824.pdf
77Decision: NJ GWQS are being waived for arsenic, beryllium, and lead.
Rationale: COCs at this site are arsenic, beryllium, and lead, which are all virtually immobile in the aquifer. A site-specific conceptual model
and a contaminant transport model (using USGS MODPATH 96 and MT3DMS) were used to develop the following conclusions: (1)
extraction of organics would be extremely difficult due to the high partition coefficient values of arsenic, beryllium, and lead; and if no source
removal was conducted, the metal contaminant plumes would double in concentration but will not expand; (2) if source removal was
implemented, MNA would achieve goals in 90,000 years; P&T would take 35,000 years and require treatment of 1.7 trillion gallons of water;
and (3) if source removal is not conducted, the aquifer would never be remediated (with or without P&T).
Conditions: NAPL (suspected or observed) - Oil areas of contamination (LNAPL) in soils have been observed and remediated. Groundwater
investigation of these areas is planned to take place as part of the Part 2 Pre-design Investigation.
COCs - Metals
Concentration - Concentrations in 1996 were 8.1 ug/L for arsenic and 67 ug/L for lead.
Geology - The site is underlain by a sequence of fill materials, sands, clays, silts, and gravels. These soils, excluding the fill
material, appear to correlate to the Raritan or Magothy Formations, which outcrop along the eastern bank of the Delaware
River throughout much of southern New Jersey. These two formations are major aquifers of the Atlantic Coastal Plain in
New Jersey.
77 Zone - TI Zone is undefined in the references reviewed, but contaminated area is 200 acres (size of site).
Evaluation: Remedial Timeframe Estimate (years) - If source removal was implemented, MNA would achieve goals in 90,000 years, and
P&T would take 35,000 years and require treatment of 1.7 trillion gallons of water; and if source removal is not conducted,
the aquifer would never be remediated (with or without P&T).
Remedial Action Alternatives - The selected remedy includes (1) implementing a long-term groundwater sampling and analysis
program to monitor the contaminant concentrations in the groundwater at the site, to assess the migration and attenuation of
these contaminants in the groundwater over time, and (2) establishing ICs to restrict the installation of wells and the use of
contaminated groundwater in the vicinity of the site.
Current Status/Activities: Capping of site soils and ICs (groundwater well and use restrictions) were selected in the 2003 ROD. Remediation
of soil areas of concern associated with OU 4 is being conducted. According to the 2009 5-year review, additional ICs (deed restrictions) are
needed and remedial activities at the site have not been fully implemented. Soil capping was conducted for 5 acres under OU 5 in 2005 and a
pre-design investigation is underway to develop a groundwater baseline for assessing potential groundwater impacts to surface water and
identity future monitoring needs.
August 2012
A-23
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Atlantic Resources
State: NJ; OU: 2
Decision Doc. (Type &Date):
ROD, 9/30/04
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
9/30/04; (2) Site summary, 2007,
www.epa. sov/resion02/superfund/
npl/atlanticresources/
TI-Relevant Information
TI Decision: Cleanup goals being waived for VOCs, SVOCs, and metals are state standards and background levels. See Table 9 of ROD for
complete list.
Rationale: A TI waiver is being issued based on the following factors: (1) the ineffectiveness of active remedies in the low permeable soils
found at the site; (2) the expected removal of substantial quantities of contaminants during source removal activities; (3) the expected limited
mobility of residual groundwater contamination; and (4) the absence of current and potential receptors. Groundwater contamination was
observed no deeper than 30 feet bgs, which is a zone of very low permeability. Pumping tests have shown that five of six wells could not
maintain a pumping rate of 0.5 gallons per minute, and limited plume migration is expected in this zone.
Conditions: NAPL (suspected or observed) - NAPLs were suspected because of high concentrations in groundwater; however, there was no
direct evidence.
COCs- 15 VOCs, 5 SVOCs, and 11 metals
Concentration - Concentrations provided in Table 1 of ROD.
Geology - Low permeability soils (clay with some silt/sand lenses)
TI Zone - TI Zone includes a 17-acre area; however the vertical extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - About 2,000 years
Remedial Action Alternatives - The selected remedy includes ICs (land and groundwater use restrictions), groundwater
monitoring, and source excavation/disposal.
Current Status/Activities: ICs selected for OU2 include deed notice, covenant, and a groundwater use/well drilling regulation; however, their
status is not provided in the documents reviewed. This TI waiver applies at two sites (Horseshoe Road and Atlantic Resources).
August 2012
A-24
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Horseshoe Road
State: NJ; OU: 2
Decision Doc. (Type &Date):
ROD, 9/30/04
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
9/30/04,
www.epa. sov/superfund/sites/rods/
Mltext/r2004020001405.pdf; (2)
Site summary,
http://www.epa.gov/Region2/super
fund/npl/0200781c.pdf
TI-Relevant Information
TI Decision: The cleanup goals being waived for VOCs, SVOCs, and metals are state standards and background levels. See Table 9 of ROD
for complete list.
Rationale: A TI waiver is being issued based on the following factors: (1) the ineffectiveness of active remedies in the low permeable soils
found at the site; (2) the expected removal of substantial quantities of contaminants during source removal activities; (3) the expected limited
mobility of residual groundwater contamination; and (4) the absence of current and potential receptors. Groundwater contamination was
observed no deeper than 30 feet bgs, which is a zone of very low permeability. Pumping tests have shown that five of six wells could not
maintain a pumping rate of 0.5 gallons per minute, and limited plume migration is expected in this zone.
Conditions: NAPL (suspected or observed) - NAPLs were suspected because of high concentrations in groundwater; however, there was no
direct evidence.
COCs- 15 VOCs, 5 SVOCs, and 11 metals
Concentration - Concentrations provided in Table 1 of ROD.
Geology - Low permeability soils (clay with some silt/sand lenses)
TI Zone - TI Zone includes a 17-acre area; however the vertical extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - About 2,000 years
Remedial Action Alternatives - The selected remedy includes ICs (land and groundwater use restrictions), groundwater
monitoring, and source excavation and disposal.
Current Status/Activities: ICs selected for OU2 include deed notice, covenant, and a groundwater use/well drilling regulation; however, their
status is not provided in the documents reviewed. This TI waiver applies at two sites (Horseshoe Road and Atlantic Resources).
August 2012
A-25
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Chemical Insecticide
State: NJ OU: 4
Decision Doc. (Type &Date):
ROD, 12/22/03
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU4,
12/22/03,
www.epa. sov/superfund/sites/rods/
fulltext/r2004020001416.Ddf: (2)
Site summary,
www.epa. sov/Resion2/superfund/
nDl/0200517c.Ddf: (3) Five-vear
review, 2009,
www.epa. sov/superfund/sites/fivev
ear/f2009020002903 .pdf
TI-Relevant Information
TI Decision: Federal and state drinking water standards are being waived, which include but are not limited to arsenic (8 ppb), dinoseb (7
ppb), TCE (1 ppb), and PCE (1 ppb).
Rationale: The overburden and bedrock aquifers at the site are highly contaminated. It was concluded that based on the nature of
contaminants and aquifer characteristics, an active pumping remedy was unlikely to be successful in restoring the site groundwater. Although
reducing contaminant mass was considered, it was not selected as the final remedy when weighed against other factors.
Conditions: NAPL (suspected or observed) - NAPL was never observed
COCs - Arsenic, dinoseb, and chlorinated VOCs
Concentration - Maximum concentrations were as follows: arsenic-17,400 ppb; dinoseb-1,400 ppb; TCE-1,800 ppb off-site
and 28 ppb on-site; and PCE-51 ppb off-site and 41 ppb on-site.
Geology - Fill material, fluvio -glacial deposits, red clay and silt, and consolidated bedrock. The area has two water-bearing units
separated by a leaky confining unit. The overburden and bedrock groundwater on site are highly contaminated.
77 Zone - TI applies to a 50-acre area, which corresponds to a majority of the site with limited off-site migration; however the
vertical extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Tirnefrarne Estimate (years) — At least several hundred years for groundwater restoration
Remedial Action Alternatives - The selected remedy includes ICs and groundwater monitoring. It is anticipated that work on ICs
will begin in the beginning of FY 2009 with final implementation later that year.
Current Status/Activities ' Data have been collected from the existing network of groundwater monitoring wells since 2005 Based on this
data, it is apparent that the OU 2 remedy, which consisted of removing contaminated soil and source materials, has shown a decrease in the
concentration of contaminants. TCE was determined to be an off-site contaminant, as specified in the ROD. As stated in the 2009 5-year
review, overall, concentrations of arsenic and alpha-BHC are decreasing. VOCs and herbicides have gradually stabilized, and low-level
detections of these constituents are attributed to stable plume conditions. A Classification Exception Area, which will include groundwater use
restrictions, is currently being prepared.
August 2012
A-26
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Dorney Road Landfill
State: PA; OU: 1
Decision Doc. (Type &Date):
ROD, 9/30/91
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
9/30/91,
www.epa. sov/res3 hwmd/npl/P AD
980538763.htm; (2) TI Waiver,
undated; (3) Site summary,
www.epa. sov/res3 hwmd/npl/P AD
980508832.htm; (4) Five-vear
review, 2008,
www.epa. sov/superfund/sites/fivev
ear/f2008030002622.rjdf
TI-Relevant Information
Region 3: 18 sites (19 waivers)
TI Decision: Requirements being waived are the state regulation to remediate on-site groundwater to background levels and off-site
groundwater to MCLs (for metals and VOCs).
Rationale: ARARs are being waived for the following reasons: (1) lack of discharge areas with the necessary capacity within a reasonable
distance (less than 1 mile) from the site, and (2) lack of confidence in the reliability of reinjection of treated water within the vicinity due to
highly fractured bedrock.
Conditions: NAPL (suspected or observed) - No
COCs - Metals, VOCs
Concentration - Tables not included in online version of ROD.
Geology - Fractured bedrock
77 Zone - TI Zone applies to on-site and off-site groundwater, however the extent of the TI zone is undefined in references
reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Not applicable
Remedial Action Alternatives No action will be taken to actively remediate the groundwater' data indicate that groundwater
appears to be naturally attenuating The selected remedy is well-head treatment for affected residences
Current Status/Activities: Based on the site summary (January 2012), monitoring showed no wells above standards; therefore, no well-head
conducted for 1,4-dioxane.
August 2012
A-27
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Heleva Landfill
State: PA; OU: 1
Decision Doc. (Type &Date):
ROD Amendment, 9/30/91
Stage: Pre-construction
Media: Groundwater
References: (1) ROD Amendment,
OU1, 9/30/91,
www.epa. sov/superfund/sites/rods/
fulltext/a0391124.Ddf: (2) Site
summary,
www.epa. sov/res3 hwmd/npl/P AD
980537716.htm
TI-Relevant Information
TI Decision: Requirements being waived are the state ARAR to remediate on-site groundwater to background levels and the federal ARARs
of MCLs and non-zero MCLGs for VOCs.
Rationale: The original remedy called for reduction of concentrations of VOCs in groundwater under the landfill. However, during design, it
was determined that this was not feasible due to the presence of DNAPLs. The ROD states that there are no technologies presently in existence
capable of locating or remediating all the DNAPL present because of the heterogeneous distribution (both horizontally and vertically) of
fractures within the bedrock.
Conditions: NAPL (suspected or observed) - Free-phase DNAPLs have not been observed but are likely present.
COCs - VOCs (TCE, acetone, and vinyl chloride are listed in ROD - Tables 1 and 3 not provided in online version)
Concentration - Maximum concentrations: TCE-930,000 ug/L; acetone-1,900,000 ug/L; and vinyl chloride-19,000 ug/L.
Geology - Heterogeneous layers and bedrock
77 Zone - TI waiver applies to "neargradient" groundwater (the area in which DNAPLs are present); however the extent of the
TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Very long time (indefinite)
Remedial Action Alternatives — The amended remedy includes P&T to contain the neargradient portion of the plume associated
with DNAPLs and P&T to restore downgradient groundwater to background levels . If implementation of the amended
remedy demonstrates that is it technically impracticable to remediate to background levels, an amendment or BSD may be
issued with a TI waiver for the downgradient area.
Current Status/Activities: The site summary (January 2012) indicates an alternate water supply (bottled water followed by extension of
municipal water line in 1986), has been provided and P&T is operational.
August 2012
A-28
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Middletown Air Field
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 12/17/90
Stage: Post-construction
Media: Ground water
References: (1) ROD, OU1,
12/17/90,
www.epa. sov/superfund/sites/rods/
fulltext/r0391107.Ddf: (2) ROD.
OU3, 9/19/96,
www.epa. sov/superfund/sites/rods/
fulltext/r0396237.Ddf: (3) Site
summary,
www.epa. sov/res3 hwmd/npl/P AD
980538763.htm
TI-Relevant Information
TI Decision: State background levels being waived as ARARs. MCLs will be achieved.
Rationale: State requirement to achieve background levels is being waived because (1) VOCs are being treated using air stripping, the current
BAT, but cannot achieve background levels, which are zero upgradient of the site; (2) background concentrations for inorganics would require
treating to zero or below detection limits and for some contaminants, the BATs are not capable of achieving those levels; (3) a number of the
chemicals do not have sufficient associated risk to either human health or the environment to warrant their treatment; and (4) since the edge of
the waste management unit is the Susquehanna River, any treatment at this area would be treating river water, making it impractical to achieve
background levels due to the large volume of water requiring treatment.
Conditions: NAPL (suspected or observed) - Suspected
COCs - 4 chlorinated VOCs, 6 inorganics (metals)
Concentration - Chlorinated VOCs and inorganics are present at elevated levels, with TCE being the primary COC. TCE
concentrations ranged from 6 to 1,000 ppb.
Geology - Fractured rock
77 Zone - The TI zone is undefined in references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Indefinite
Remedial Action Alternatives - The selected remedy included continued operation of the existing drinking water supply
treatment system and ICs (groundwater use restrictions).
remedy in place at the North Base Landfill portion is protective and no additional investigation is necessary. The Susquehanna Area Regional
Airport Authority will require monitoring and a VI study because it was not assessed previously. The VI study will be evaluated in the 2012
FYR. This site was deleted from the NPL in 1997.
August 2012
A-29
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Whitmoyer
Laboratories
State: PA; OU: 3 (since changed
to OU 6)
Decision Doc. (Type &Date):
ROD, 12/31/90
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU3,
12/31/90,
www.epa. sov/superfund/sites/rods/
Mltext/r0391 109.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-03032.rjdf: (3)
Five-year review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f20 10030003458.pdf
TI-Relevant Information
TI Decision: ARARs being waived in the selected remedy are background levels. The contingent remedy would waive MCLs. Health-based
cleanup goals were selected for arsenic at 50 ug/L and aniline at 10 ug/L.
Rationale: The extent of groundwater contamination was defined by the arsenic and aniline plume. Based on health-based cleanup levels, the
quantity of groundwater was estimated to be 350 million gallons for the dissolved portion of contaminants. Substantial amounts of the
contaminants may also be adsorbed onto clays found within the bedrock fractures, and VOCs may be present in NAPL form.
Conditions: NAPL (suspected or observed) - NAPL could be present.
COCs - arsenic, aniline, PCE
Concentration - Average concentrations were 17 mg/L for arsenic, 6.4 mg/L for aniline, and 0.25 mg/L for PCE.
Geology - Clay and fractured bedrock
77 Zone - The contaminated area totals 215 acres to an estimated depth of 500 feet bgs.
Evaluation: Remedial Timeframe Estimate (years) - Indefinite
Remedial Action Alternatives — The selected remedy consists of P&T remediation to health-based standards and waives
remediation to background levels due to the extent of contamination and presence of fractured bedrock Phase II of P&T is
the same as Phase I. No changes were made in Phase I of P&T based on remedy performance.
Current Status/Activities' The 2010 5-year review states full-scale P&T began in 1998 and is maintaining hydraulic control It is unclear if the
contingent remedy (P&T for containment and a TI waiver for NICLs) has been implemented An evaluation is necessary to see if the current
remedy can meet the more stringent cleanup standard of arsenic (changed from 50 ug/L to 10 ug/L). ICs (groundwater well restriction) have
been established and groundwater monitoring will continue
August 2012
A-30
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Lindane Dump
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 3/31/92
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
3/31/92,
www.epa. sov/superfund/sites/rods/
fulltext/r0392147.Ddf: (2) FS.
Appendix A; (3) Site summary,
www.epa. sov/res3 hwmd/npl/P AD
980712798.htm; (4) Five-vear
review, 2008,
www.epa. sov/superfund/sites/fivev
ear/f2008030003189.rjdf
TI-Relevant Information
TI Decision: ARARs being waived are background levels for pesticides, VOCs, and metals. Cleanup goals will be MCLs for lindane (0.2
ug/L) and benzene (5 ug/L).
Rationale: The ARAR for remediation to background levels is being waived for the shallow aquifer because of the following: (1) based on
the industrial land use and the fact that no wells exist downgradient, it is unlikely that groundwater would be considered for use as a drinking
water source; (2) past site activities (coal mining) have rendered the groundwater a poor source of drinking water; (3) existing
leachate/groundwater collection is effectively capturing shallow groundwater; and (4) it is technically impracticable to extract all shallow
groundwater at the site due to complex hydrogeological conditions, possibility of subsidence, and site damage due to extensive pumping.
Conditions: NAPL (suspected or observed) - No
COCs - 5 pesticides, 4 VOCs, 3 metals, and phenol
Concentration - Concentrations are included in Tables 13-18 in the ROD (not included in online version).
Geology - Two aquifers (shallow and deep bedrock)
77 Zone - TI Zone includes shallow aquifer; however the lateral extent of the TI zone is undefined in the references reviewed.
Groundwater in the deep bedrock aquifer already meets MCLs.
Evaluation: Remedial Timeframe Estimate (years) — Indefinite
Remedial Action Alternatives - The selected remedy includes upgrading the existing leachate/groundwater collection treatment
system and ICs (deed and access restrictions).
sampling and groundwater monitoring are being conducted at the Site. An 1C in the form of a restrictive covenant that encompasses the 47.5
acres of the Lower Project Area was established in 2000.
August 2012
A-31
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Westinghouse Elevator
Co
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 6/30/92
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU1,
6/30/92,
www.epa. sov/superfund/sites/rods/
Mltext/r0392148.pdf; (2) Five-
year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f200603000 1084.pdf; (3) Site
summary
www.epa. sov/res3 hwmd/npl/P AD
043882281.htm
TI-Relevant Information
TI Decision: ARARs being waived are background levels for VOCs: TCE; 1,1,1-TCA; 1,1-DCE; 1,1-DCA; 1,2-DCE; and 1,2-DCA. Goals
will be non-zero MCLGs or MCLs.
Rationale: Based on the complex hydrogeology and likely presence of DNAPL, hydrogeologists recommended that the entire plume not be
remediated because wells in the more dilute portion of the plume could draw water from the center of the plume and spread the contamination.
The ARAR to remediate to background levels is being waived because (1) it is technically impracticable from an engineering perspective and
(2) it will result in greater risk to human health and the environment.
Conditions: NAPL (suspected or observed) - DNAPL is likely present due to high VOC concentrations.
COCs - Chlorinated VOCs
Concentration - Total VOCs were as high as 200,000 ppm, with TCE at more than 81,000 ppb.
Geology - Complex. The geology beneath the site consists of red and gray siltstones and shale bedrock. The shallow
groundwater flow direction mostly follows the topography toward nearby Rock Creek and there also appears to be some
structural influence (that is, bedding). The deeper flow is strongly influenced by the bedding and is anisotropic.
77 Zone - TI Zone includes on-plant and off-plant groundwater; however the extent of the TI zone is undefined in the references
reviewed.
Evaluation: Remedial Tirnefrarne Estimate (years) — Very long time
Remedial Action Alternatives - The selected remedy includes P&T to contain the plume and achieve non-zero MCLGs or
MCLs.
Current Status/Activities' The 2006 5-year review states that P&T was installed in 1997 ICs are in place to restrict groundwater use and an
alternate water supply would be provided if requested. The site summary (January 20 12) states that monitoring is in place and the
protectiveness of the remedy will be determined after a VI study is conducted.
August 2012
A-32
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: E.I. Dupont Nemours
(Newport Landfill)
State: DE; OU: I
Decision Doc. (Type &Date):
ROD, 9/29/93
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU1,
9/29/93;
www.epa. sov/superfund/sites/rods/
fulltext/r0393 170.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f201 1090004165.pdf; (3) Five-
year review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f2010030003634.rjdf
TI-Relevant Information
TI Decision: State and federal surface water quality standards are being waived for lead, copper, zinc, cadmium, aluminum, iron, chromium,
mercury, dichlorobenzenes, and PCE.
Rationale: Upstream sources of zinc and possible background sources of iron and aluminum make it technically impracticable to achieve
surface water standards for the north wetlands and Christiana River. The containment remedy prevents discharge to the river.
Conditions: NAPL (suspected or observed) - No formal DNAPL investigation was performed, but contaminant levels are indicative of
DNAPL.
COCs - Metals, dichlorobenzenes, and PCE
Concentration - Concentrations not provided.
Geology - Coastal plain (unconsolidated sands, silts, and clays), Columbia and Potomac formations
77 Zone - TI Zone applies to the Christiana River and the north wetlands; however the extent of the TI zone is undefined in the
references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Groundwater has no evaluation of timeframe because TI is based on greater risk to
human health and the environment waiver. Ambient water quality controls for surface water waived using TI waiver.
Remedial Action Alternatives — The selected remedy includes dredging of the river actions to limit contaminant migration in the
northern area, alternate water supply, and ICs for groundwater.
Current Status/Activities: The 2005 5-year review indicated that alternate water supply and ICs (groundwater well restrictions) have been
southern perimeter of the Site was also recommended.
August 2012
A-33
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Hunterstown Road
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 8/2/93
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
8/2/93,
www.epa. sov/superfund/sites/rods/
fulltext/r0393176.Ddf: (2) BSD.
8/25/98,
www.epa. sov/superfund/sites/rods/
fulltext/e0398045.rjdf: (3) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-03023.pdf ; (4) Five-year
review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f2010030003541.rjdf
TI-Relevant Information
TI Decision: ARARs waived include background levels, MCLs, and MCLGs for VOCs.
Rationale: The TI waiver was issued based on probable DNAPLs in fractured bedrock at extreme depths (RI indicated that DNAPLs may
have migrated deeper than 2,000 feet). The ROD selected waiving background levels, MCLs, and MCLGs for groundwater at depths greater
than 800 feet bgs and indicated that groundwater above 800 feet bgs will be remediated to background levels (defined as "no detection of
VOCs"). The ROD also stated that after the remedy (P&T) was operational for several years, it may be determined that background levels
cannot be achieved at depths less than 800 feet bgs and may be waived due to TI. A 1998 BSD stated that it may be possible to make a
determination as to the engineering feasibility and practicability of remediating the aquifer above 800 feet bgs during the remedial design
phase. However, documentation reviewed for this summary does not clearly indicate if this waiver above 800 feet has been issued.
Conditions: NAPL (suspected or observed) - DNAPLs are likely present based on past site activities and concentrations.
COCs - Primarily TCE, DCE, vinyl chloride, TCA, and DCA
Concentration - Total VOCs were detected above 2,000 ppb at 500 feet bgs.
Geology - Fractured bedrock
77 Zone - Standards waived for groundwater at depths greater than 800 feet bgs, but may be expanded to all groundwater depths,
at the Lagoon Area and Drum Burial Areas.
Evaluation: Remedial Timeframe Estimate (years) - Very long time
Remedial Action Alternatives - P&T for the upper 800 feet of the aquifer, and ICs
Groundwater Monitoring Plan. All ICs to restrict groundwater use and protect the constructed remedy have been implemented at the site. VI
August 2012
A-34
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Aladdin Plating
State: PA; OU: 2
Decision Doc. (Type &Date):
ROD, 12/30/93
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
12/30/93,
www.epa. sov/superfund/sites/rods/
fulltext/r0394179.pdf; (2) Five-
year review, 2004,
www.epa. sov/superfund/sites/fivev
ear/f04-03015.rjdf: (3) Five-vear
review, 2009,
www.epa. sov/superfund/sites/fivev
ear/f2009030003038.pdf
TI-Relevant Information
TI Decision: The ARAR being waived is for background levels of chromium (25 PA Code Sections 264.90-100).
Rationale: A TI waiver has been issued because (1) migration is very limited (chromium contamination in the shallow aquifer is not expected
to migrate to a drinking water aquifer for at least 2,000 years due to the tightly bound site soils) and (2) there are no technically practicable
alternatives for achieving background quality in the shallow and intermediate water-bearing zones. MCLs and federal standards will continue
to be attained where relevant and appropriate (bedrock aquifer for MCLs and in nearby creeks for surface water standards).
Conditions: NAPL (suspected or observed) - No
COCs - Chromium
Concentration - Maximum total dissolved chromium in shallow groundwater was 188,000 ppb.
Geology - Shallow and intermediate water-bearing zones with low permeability soils, deeper bedrock aquifer
77 Zone — TI Zone includes shallow and intermediate groundwater zones' however the lateral extent of the TI zone is undefined
in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Indefinite
Remedial Action Alternatives The selected remedy includes ICs and monitoring Currently no pumping is ongoing The source
has been removed and the contamination has been isolated
Current Status/Activities: Based on the 2009 5-year review, ICs preventing disturbances to the shallow contaminated groundwater have been
August 2012
A-35
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Butler Mine Tunnel
State: PA; OU: 1
Decision Doc. (Type &Date):
ROD, 7/15/96
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU1,
7/15/96,
www.epa. sov/superfund/sites/rods/
fulltext/r0396224.rjdf: (2) Site
summary,
www.epa. sov/res3 hwmd/npl/P AD
980508451.htm; (3) Five-vear
review, 2009,
www.epa. sov/superfund/sites/fivev
ear/f2009030002935.pdf
TI-Relevant Information
TI Decision: ARARs being waived are state water quality criteria and NPDES standards for VOCs, SVOCs, naphthalene (PAH), and cyanide
(see Table 4 of ROD).
Rationale: This remedy addresses the possible future releases of hazardous substances from the Butler Tunnel to the Susquehanna River. It is
estimated that 50,000 to 90,000 gallons of oil could still be contained in the mine workings. Releases from the mine would allow significant
contamination to discharge to the river, and as a result, state water quality criteria would be exceeded because no technologies are currently
available to prevent the flow of contaminants to the river. In addition, if a release creates a point source discharge of pollutants to surface
waters, NPDES criteria would be applicable. However, because of the potential volume of tunnel flushout, compliance with NPDES
requirements are technically impracticable from an engineering perspective.
Conditions: NAPL (suspected or observed) - Oily wastes are in the mine and may discharge to the river
COCs - 8 VOCs, 6 SVOCs, PAH, and cyanide
Concentration - Concentrations provided in Table 2 of the ROD.
Geology - The tunnel is a subsurface mine drainage system that was constructed prior to 1930 to drain interconnected mine
shafts above an elevation of 595 feet above mean sea level into the Susquehanna River. Releases occur when the waste oils
that exist in the mine network get flushed out during rain events that raise the water elevation to the Butler Mine tunnel
interconnected drainage system.
77 Zone - TI waiver applies to the Susquehanna River; however the extent of the TI zone is undefined in the references
reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Very long time
Remedial Action Alternatives - The selected remedy includes ICs (deed restrictions) and preparation for responding to a release.
Current Status/Activities: According to the 2009 5 -year review, ICs (deed restrictions) are currently being negotiated. Site summary (June
201 1) indicates the remedial action (as set forth in the ROD) has been performed.
August 2012
A-36
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Brodhead Creek
State: PA; OU: 2
Decision Doc. (Type &Date):
ROD, 6/30/95
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
6/30/95,
www.epa. gov/superfund/sites/rods/
fulltext/r03 95211.pdf: (2) FS,
Appendix C, 3/14/95; (3) Site
summary,
www.epa.gov/reg3hwmd/npl/PAD
980691760.htm; (4) Five-year
review, 2009,
www.epa. gov/superfund/sites/fivev
ear/f2009030002934.pdf
TI Decision: MCLs are being waived for benzene, pentachlorophenol, benz(a)anthracene, chrysene, BEHP, benzo(b)fluoranthene,
benzo(k)fluoranthene, benzo(a)pyrene, indeno(l,2,3-cd)pyrene, dibenz(a,h)anthracene, arsenic, and cyanide. The requirement of the PA DER
Groundwater Protection Strategy, which requires groundwater to be restored to background levels, is also being waived.
Rationale: Two free coal tar accumulations are immobilized and confined in the upper surface of the silty sand unit, and coal tar at residual
levels is also present in the site soils. However, there are no existing or potential exposures to either the shallow or deep groundwater at any
on- or off-site supply wells. In addition, although the groundwater discharging to Brodhead Creek is the principal potential route of migration
for coal tar-related constituents in the dissolved phase, no site-related impacts on the stream are expected to occur. Previous actions have
included installation of a slurry wall, recovery of 8,000 gallons of coal tar using extraction wells, and removal of 1,500 gallons of coal tar
using CROW, which have reduced most coal tar (except the 2 accumulations) to residual levels. Given that there is no technically viable
method for remediating subsurface soils containing residual levels of coal tar (either by complete removal or in situ treatment), the restoration
timeframe for groundwater in the shallow aquifer is indefinite, as these soils will continue to be a source of continuing releases of coal tar-
related constituents to the groundwater in the stream gravel unit.
Conditions: NAPL (suspected or observed) - Free coal tar (a DNAPL) has been detected at 2 separate areas. Additional areas contain coal tar
at residual levels.
COCs - Benzene, pentachlorophenol, 7 PAHs, bis(2-ethylhexyl)phthalate, arsenic, and cyanide
Concentration - Concentrations not provided in FS, Appendix C (TI Demonstration)
Geology - Two water-bearing zones (silty sand unit, stream gravel unit)
77 Zone - The horizontal area (2.7 acres) includes the area containing free and residual coal tar from the slurry wall to the west
of the site. The vertical extent includes the stream gravel unit between the fill and silty sand units. This TI Zone has a
volume of approximately 26,000 cubic yards.
Evaluation: Remedial Timeframe Estimate (years) - The restoration timeframe for groundwater in the shallow aquifer is indefinite because
soils will be a continual source of contamination.
Remedial Action Alternatives - No further action was selected for this OU.
Current Status/Activities: According to site summary (January 2012), ICs as land use and groundwater restrictions are in place. The site was
deleted from the NPL in 2001. In August 2007, two coal tar seeps were discovered in McMichael Creek and a stormwater runoff channel. The
PRP undertook immediate action to contain the seeps. The 2009 5-year review states that investigations conducted in 2008 to determine the
probable cause of the seeps concluded that the seeps were likely the result of northward erosion of McMichael Creek and heating of coal tar in
the subsurface in the summer months resulting from a lack of vegetation. Excavation of coal tar impacted soils was conducted in 2008 and
disposed offsite. No coal tar seeps have since been identified.
August 2012
A-37
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Revere Chemical Co
State: PA; OU: 2
Decision Doc. (Type &Date):
ROD, 6/20/96
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
6/20/96,
www.epa. sov/superfund/sites/rods/
fulltext/r0396220.pdf; (2) Five-
year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f0603025.mlf: . (3) Five-vear
review, 2011,
www.epa. sov/superfund/sites/fivev
ear/f2011030004092.rjdf
TI-Relevant Information
TI Decision: MCLs are being waived for VOCs (TCE, TCA, PCE, and toluene) and SVOCs (1,2,4-TCB, BEHP, and 1,2-DCB).
Rationale: The use of P&T for groundwater restoration is not practicable because of the limited capacity of the shallow groundwater to
recharge the wells and produce sufficient water quantities. The contaminated zone has not been expanding and does not extend beyond the area
to be capped. The cap is expected to have a direct influence on improving the quality of the shallow groundwater unit at this site.
Conditions: NAPL (suspected or observed) - No
COCs- VOCs, SVOCs
Concentration - Maximum TCE concentration was 200 ppb. Concentration ranges were as follows (in ppb): 1,2,4-TCB-41-
150; l,2-DCB-3-5; and BEHP-3-42.
Geology - Very tight Triassic shale
TI Zone - TI zone includes the shallow groundwater; however the lateral extent of the TI zone is undefined in the references
reviewed.
Evaluation: Remedial Timeframe Estimate (years) - less than 30 years (Note: Groundwater contamination was marginally above the MCLs
and limited in area The shale aquifer is very tight and wells tend to purge dry and take days to recover)
Remedial Action Alternatives - The selected remedy for groundwater includes ICs and monitoring.
Current Status/Activities: Based on the 201 1 5-year review, groundwater restrictions are in place at the site and groundwater migration is
under control \Vith the recording of a revised covenant in 20 10 the ICs are complete Remedial actions were implemented pursuant to the
ROFK fnrbnth Oils anH thp sitp is mnsiHprprl nrntprtivp nf human health anH thp ptrvirnnmpnt
August 2012
A-38
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Aberdeen Proving
Ground, Edgewood Area
State: MD; OU: 2
Decision Doc. (Type &Date):
ROD, 9/24/97
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
9/24/97,
www.epa. sov/superfund/sites/rods/
fulltext/r0397090.Ddf: (2) FFS.
Appendix J, June 1996; (3) Five-
year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f04-03028.pdf ; (4) Five-year
review, 12/16/08,
www.epa. sov/superfund/sites/fivev
ear/f2009030002827.pdf
TI-Relevant Information
TI Decision: Federal and state standards are being waived for organics and inorganics.
Rationale: An evaluation determined that the DNAPL zone could neither be contained nor removed, and that the aqueous -phase plume could
not be restored. A TI waiver was justified because of the folio wing: (1) difficulty to locate all DNAPL as a high degree of stratigraphic and
hydrogeologic discontinuities have been identified; (2) human health and ecological risk assessments have show no unacceptable levels of risk;
(3) groundwater discharges into Bush River and appears to result in surface water concentrations that are nondetectable or at non-toxic levels;
and (4) upward migration is not likely due to the hydraulic disconnection between this area with the mainland surficial aquifer and its low
production yield. In addition, the presence of UXO and the ability to clear such ordnance makes containment and removal efforts infeasible.
Although DNAPL is the main reason for the TI waiver, inorganics are also included in the waiver because (1) there is no benefit from
attempting to remediate these compounds alone, (2) inorganic compounds do not suggest a continuous plume, and (3) several contaminants
were found to be within natural background concentration ranges.
Conditions' MAfL (suspected or observed) DNAPLs are likely residual and pooled (112 2-PCA and TCE)
COCs 15 organics (VOCs) 20 inorganics
Concentration - Maximum concentrations: antimony-0.312 mg/L; beryllium-0.005 mg/L; cadmium-0.028 mg/L; lead-0.015
mg/L; nickel-0.443 mg/L; vinyl chloride-1 ug/L; 1,2-DCE-340 ug/L; chloroform-10 ug/L; TCE-2400 ug/L; 1,1,2-TCA-
150 ug/L' PCE 120 ug/L and 112 2-PCA 22 000 ug/L
Geology High degree of stratigraphic and hydrogeologic discontinuities in unconsolidated coastal plain sediments
TIZone - TI Zone includes all portions of the groundwater where cleanup levels are not met and extends to the base of the
aquifer (75 feet bgsV however the lateral extent of the TI zone is undefined in the references provided
Remedial Action Alternatives - The selected remedy includes ICs (groundwater use restrictions).
Current Status/Activities: According to the 2008 5-year review, many activities are being conducted at the site. ICs (groundwater use
restrictions) are in place and the annual status was reported in a formal certificate from Aberdeen Proving Ground.
August 2012
A-39
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Aberdeen Proving
Ground, Edgewood Area
State: MD; OU: 8
Decision Doc. (Type &Date):
ROD, 9/28/01
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU8,
9/28/01,
www.epa. sov/superfund/sites/rods/
fuHtext/r0301025.pdf; (2) TI
Evaluation, October 2001; (3)
Five-year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f04-03028.pdf ; (4) Five-year
review, 12/16/08,
www.epa. sov/superfund/sites/fivev
ear/f2009030002827.rjdf
TI-Relevant Information
TI Decision: MCLs and MCLGs are being waived for VOCs, primarily chlorinated ethanes and ethenes, as well as inorganic constituents
(metals).
Rationale: Groundwater contamination (mainly VOCs) is present throughout the surficial aquifer but mostly in the upper 20 feet. DNAPL has
been observed in a free-phase form and is likely also present in residual form. The low permeability and heterogeneity of the aquifer materials,
the presence of UXO, and the large size of the contaminated area complicate removal, treatment, or containment actions for NAPL. Metals
contamination is co-located with the VOC contaminants, and MCLs for metals will also be waived because the inability to clean up VOCs
precludes the use of the aquifer.
Conditions: NAPL (suspected or observed) - Free-phase DNAPL has been observed and residual DNAPL is likely present.
COCs - 15 organics (mostly chlorinated ethanes and ethenes), 21 inorganics (metals)
Concentration - Maximum concentrations in 1999 (in mg/L): 1,1,2,2-PCA-390; DCE-1 10; TCE-93; PCE-1 1; TCA-7. 1; and
vinyl chloride-4.2. See Tables 4-11 and 4-13 of TI Evaluation Report for additional concentrations.
Geology - Low permeability and heterogeneous
TIZone - TI Zone encompasses all portions of the J-Field Surficial Aquifer that do not meet MCLs and extends to the confining
layer (approximately 40 feet bgs).
Evaluation: Remedial Timeframe Estimate (years) — Indefinite
Remedial Action Alternatives — The selected remedy includes DNAPL recovery phytoremediation, and ICs (land and
groundwater use restrictions).
IISP restriction^ havR hppn imnlpmpntprl
August 2012
A-40
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Rodale Manufacturing
Co., Inc.
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 9/30/99
Stage: Post-construction
Media: Ground water
References: (1) ROD, OU1,
9/30/99,
www.epa. sov/superfund/sites/rods/
fulltext/r0399086.pdf; (2) TI
Evaluation, 9/99; (3) Site
summary,
www.epa. sov/res3 hwmd/npl/P AD
981033285.htm
TI-Relevant Information
TI Decision: MCL at 5 ug/L is being waived for TCE.
Rationale: An overburden and fractured bedrock aquifer are present at the site. Both units are highly heterogeneous and complex at a small
scale. The bedrock matrix porosity represents a significant storage capacity for VOCs that diffuse into the matrix from the fractures, as
confirmed by bedrock matrix VOC analysis; this diffusion will significantly hinder efforts to restore bedrock groundwater quality. P&T began
in 1 996 and after 2 years of operation, approximately 2 1 million gallons of groundwater had been pumped while groundwater concentrations
of influent are showing asymptotic levels approximately 3 orders of magnitude above regulatory criteria. At these mass-removal rates, it has
been estimated that the DNAPL mass will dissolve in 592 to 2,370 years. VOC mass calculations indicate the estimated total subsurface VOC
mass may range up to 647,000 mg/kg, with up to 592,000 mg/kg in the form of DNAPLs and the remainder in the dissolved, sorbed, or vapor
phase. Currently, no technology is capable of restoring groundwater; technologies are capable of removing some mass but they pose
unacceptable risks, such as mobilizing DNAPL or drilling through DNAPL to install wells.
Conditions: NAPL (suspected or observed) - DNAPL is likely present based on TCE concentrations.
COCs TCE
Concentration - Maximum TCE concentration was 570,000 ug/L.
Geology - Overburden and fractured bedrock aquifers (both units are highly heterogeneous and complex at a small scale)
77 Zone - The TI Zone coincides with the probable DNAPL zone, which has been identified by wells that indicate the likely
presence of proximal DNAPL based on groundwater VOC concentrations exceeding 1 percent of the solubility of TCE in
groundwater (source area is approximately 350 feet long, 200 feet wide, and extends an average of 320 feet bgs).
Evaluation: Remedial Timeframe Estimate (years) - It has been estimated that DNAPL mass will dissolve in 592 to 2,370 years.
Remedial Action Alternatives - According to site documents, an appropriate remedial action objective is to minimize the risk of
DNAPL mobilization; this will be achieved by hydraulic containment, ICs, and MNA.
Current Status/Activities: In 1990, municipal well-head treatment (air strippers) was implemented at three wells. Based on the site summary
(January 2012), P&T is being conducted to limit migration and MNA is ongoing. ICs (land use and groundwater use restrictions) have been
selected but it is not clear if they have been implemented. A VI study was conducted in 2010 with additional sampling planned for February
2012.
August 2012
A-41
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Naval Air
Development Center
State: PA; OU: 12A
Decision Doc. (Type &Date):
ROD, 9/27/00
Stage: Post-construction
Media: Ground water
References: (1) ROD, OU12A,
9/27/00,
www.epa. sov/superfund/sites/rods/
fulltext/r03000 14.pdf; (2) RI/FS.
Appendix E, June 2000; (3) Five-
year review, 2002,
www.epa. sov/superfund/sites/fivev
ear/f02-03024.rjdf : (4) Five-vear
review, 8/14/07,
www.epa. sov/superfund/sites/fivev
ear/f2007030001712.rjdf
TI-Relevant Information
TI Decision: The TI waiver is for federal and state drinking water standards for chemicals present in DNAPL form. The waiver is for TCE (5
ug/L) and potentially for standards for carbon tetrachloride, PCE, or both, if present.
Rationale: Chlorinated VOCs are present in the fractured bedrock aquifer below the site (and TCE has been observed as a DNAPL) . P&T
began at OU1 as an interim remedy in 1999 (selected in 1993) until additional evaluations could be conducted and a final remedy selected. On-
site concentrations have remained relatively constant but P&T has decreased concentrations downgradient of the system and is controlling
migration. The evaluation concluded that extraction processes may be effective in restricting the migration of the plume in the immediate
vicinity of DNAPL; however, extraction wells likely would not capture and remove all DNAPL, and collection trenches are not a viable option
because DNAPL is present at depths of 70 feet bgs. Little destructive biological degradation activity was noted at this site. Soil removal
actions have been conducted and an alternate water supply was provided.
Conditions: NAPL (suspected or observed) - TCE was confirmed in DNAPL form. Carbon tetrachloride, PCE, or both may also potentially
exist as DNAPL.
COCs TCE, carbon tetrachloride, PCE
Concentration - The maximum TCE concentration measured during extraction well installation was 1,219 mg/L in 1999.
Geology - Fractured bedrock
77 Zone - The TI Zone is approximately 80 feet in diameter and a depth from the water table to 75 feet bgs.
Evaluation: Remedial Timeframe Estimate (years) — Based on an estimated TCE release of 75 to 374 gallons the estimated time to dissolve
DNAPL is 199 years. After DNAPL is dissolved, cleanup to the MCL should proceed relatively quickly (5 to 1 1 years).
Since TCE is the most prominent contaminant it is expected that other contaminants will achieve goals in an equal or lesser
timeframe
Remedial Action Alternatives - P&T will continue to limit DNAPL migration. ICs were also selected as part of the remedy.
Current Status/Activities: Based on 2007 5-year review, ICs prohibiting groundwater usage have been implemented and P&T is ongoing.
August 2012
A-42
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Keystone Sanitation
Landfill
State: PA
OUs: 01
Decision Doc. (Type &Date):
Amd, 6/1999
Stage: Pre-construction
Media: Ground water
References: (1) Amd, OU 1,
6/1999,
www.epa. gov/superfund/sites/rods/
fulltext/a0399505.pdf: (2) Five-
year review report, 9/2010,
www.epa. gov/superfund/sites/fivev
ear/f2010030003542.pdf: (3) Site
summary,
www.epa.gov/reg3hwmd/npl/PAD
054142781.htm: (4) Institutional
Controls for Keystone Sanitation
Landfill, July 2008,
www.epa. gov/ictssw07/public/exp
ort/03/PAD054142781/PAD05414
2781 report.HTM
TIDecision: ARARs waiver of state secondary MCLs for iron and manganese in both on-site and off-site groundwater (Class IIA aquifer).
Rationale: Since the secondary MCL (SMCL) for both iron and manganese is less than the upper range of naturally-occurring iron and
manganese, EPA has determined it is technically impracticable from an engineering perspective to clean up these contaminants to the state
SMCL levels. Groundwater extraction will capture and remediate the manganese associated with releases from the Site but would not reduce
ambient levels. The risk-based cleanup standards for iron and manganese are sufficiently health-protective.
Conditions: NAPL (suspected or observed) - NAPL is not an issue
COCs - Metals and VOCs
Concentration - Not provided
Geology - Fractured bedrock
77 Zone - On-site and off-site groundwater.
Evaluation: Remedial Timeframe Estimate (years) - Not provided
Remedial Action Alternatives - Groundwater P&T was selected as the original remedy for on-site groundwater. This
amendment adds off-site groundwater to the remedy. When the amendment was signed, the P&T system was under
construction. Point-of-use treatment units were also selected for affected residents.
Current Status/Activities: P&T has been operational since 2000 and treatment units have been installed on 34 residences. The landfill cap has
been upgraded and the landfill gas extraction system is also operational. ICs are in place for soil and groundwater to prohibit any activity that
may disturb the integrity of engineering controls at the site.
August 2012
A-43
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Westinghouse Electric
(Sharon Plant)
State: PA; OU: 2
Decision Doc. (Type &Date):
ROD, 2/20/03
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
2/20/03,
www.epa. sov/superfund/sites/rods/
fulltext/r0303067.pdf; (2) TI
Evaluation Report, 3/22/02; (3)
Five-year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f2006030001101.pdf ; (4) Five-
year review, 9/22/1 1,
www.epa. sov/superfund/sites/fivev
ear/f2011030004096.rjdf
TI-Relevant Information
TI Decision: The TI waiver is for MCLs and non-zero MCLGs for PCBs, VOCs and metals, and chlorinated benzenes (the demonstrated
DNAPL constituents). Additional contaminants are present at this site but are not included in the TI waiver.
Rationale: The release of DNAPL at this site is classified as "a large-volume, long duration, continual release to a heterogeneous, low to
moderate permeability medium." The estimated DNAPL mass present in the alluvial aquifer is approximately 3,000 to 7,300 tons; and the
estimated volume of LNAPL is 60,000 gallons. LNAPL recovery is being conducted and after 6.5 years of operation (as of 2002) had
recovered a total of 648 gallons of LNAPL, which is about 1 percent of the total estimated volume. The NAPLs have remained relatively
immobile and there is concern that in situ treatment may increase NAPL mobilization by creating preferential pathways or by increasing
solubility of the contaminants. "Based on the mass of COPCs in NAPLs within the source area at the site and the stable and hydrophobic
nature of PCBs, there is no reasonable basis to expect that these NAPL zones can be remediated to ARAR -based criteria in a time frame less
than hundreds of years." Physical containment of NAPL source areas is not feasible because of anthropologic conditions (2 active industrial
plants and an active railroad line). There are no receptors of impacted groundwater in the site vicinity, no threats posed to human health, and
no threats posed to the environment from groundwater discharge to a nearby river. Contamination in the bedrock aquifer is limited.
Conditions: NAPL (suspected or observed) - Both LNAPL and DNAPL are present.
COCs - PCBs, 5 chlorinated benzenes
Concentration - In 201 1, the following concentrations were observed in the alluvial aquifer: 1,2,4-TCB 6,300 ug/L; total
dichlorobenzene up to 1,000+ ug/L; chlorobenzene 2,000 ug/L; TCE 70 ug/L; and PCBs up to 7,300 ug/L.
Geology - Two aquifers (alluvial and bedrock aquifers)
77 Zone — TI Zone fully encompasses the alluvial aquifer where LNAPL and DNAPL exist and downgradient areas where MCLs
and non-zero MCLGs might be exceeded in the foreseeable future. The extent of the TI zone is approximately 100 acres.
Evaluation: Remedial Timeframe Estimate (years) - According to site documents reviewed, it is not possible to extrapolate remedial time
frame estimates at this site because there are no mass-removal rates available for innovative or emerging DNAPL treatment
technologies. Based on the mass of contamination within the source area, there is no reasonable basis to expect that
remediation can occur in less than 100 years.
Remedial Action Alternatives - Monitoring is the only action to be taken for groundwater.
Current Status/Activities: Based on a 201 1 5-year review, soil removal actions have been conducted, site-wide ICs (groundwater well
restrictions and deed restrictions) are in place, and groundwater monitoring is ongoing.
August 2012
A-44
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: UGI Columbia Gas
Plant
State: PA; OU: I
Decision Doc. (Type &Date):
ROD, 9/24/07
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/24/07,
www.losserhead.epa.sov/arweb/p
ublic/rjdf/2084262.rjdf: (2) TI
Evaluation Report, October 2003;
(3) Site summary,
www.epa. sov/res3 hwmd/npl/P AD
980539126.htm
TI-Relevant Information
TI Decision: The TI waiver is for MCLs and risk-based concentration ARARs for 27 contaminants within and above the DNAPL (TI) zone.
Rationale: Currently, no technologies are capable of restoring groundwater to ARARs in the area of the DNAPL under present site conditio ns.
A large amount of viscous DNAPL is present in the fractured bedrock. The more soluble and mobile source fractions of the original DNAPL
have likely been removed through naturally occurring attenuation processes, leaving behind the more intractable fractions (residual DNAPL).
This residual DNAPL will likely continue to slowly dissolve for centuries (or longer). Any technology capable of removing the DNAPL in
such an environment would first have to mobilize the DNAPL and then extract the mobilized DNAPL. No known technologies are capable of
extracting DNAPL from such a complicated fractured bedrock geologic system. Moreover, any attempt to remobilize the DNAPL may cause
ecological and human health risks, which do not currently exist in the vicinity of the site and Susquehanna River.
A dissolved phase plume presumably discharges to the Susquehanna River; however, discharge points/discharge area into the River was not
detected, nor was contamination from the DNAPL found in the River. The Susquehanna River eliminates the potential for further expansion of
the groundwater plume; however, the Lancaster Water Authority cooling water wells had pulled a small lobe of the dissolved plume into the
pre-treated public water supply. These wells stopped pumping in 2007. Reducing the plume size would be extremely expensive and will not
provide further risk reduction for human health; ecological risks could not be quantified because the discharge points/area into the River could
not be identified. Additionally, the site vicinity is supplied with public water and no risks are associated with the current use of groundwater.
Conditions: NAPL (suspected or observed) - DNAPL present
COCs - VOCs (7), SVOCs (14) and inorganics (6)
Concentration - Maximum concentrations provided in Table 3-1 of TI Evaluation Report.
Geology - Fill and alluvium underlain by fractured bedrock
77 Zone - TI zone applies to areas within and above the DNAPL zone, including the overburden, shallow bedrock, and deep
bedrock aquifers. Zone covers approximately 6 acres and includes the site, area south of the site to the Susquehanna River,
and area west of the site.
Evaluation: Remedial Timeframe Estimate (years) - DNAPL description above states that DNAPL will continue to dissolve for centuries (or
longer).
Remedial Action Alternatives - Monitored natural gradient flushing and ICs.
Current Status/Activities: Former gas holders were emptied and stabilized, on-site soils were capped, and sediments were removed. In 2007,
no further action was selected for site soils. ICs such as groundwater use and well restrictions are in place, and additional ICs, including land
use restrictions, are planned. Long-term groundwater monitoring is currently being performed.
August 2012
A-45
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Continental Steel Corp
State: IN; OU: I
Decision Doc. (Type &Date):
ROD, 9/30/98
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, 9/30/98,
www.epa. sov/superfund/sites/rods/
fulltext/r0598091.pdf; (2) Five-
year review, 2002,
www.epa. sov/superfund/sites/fivev
ear/f02-05013.rjdf
TI-Relevant Information
Region 4: 0 sites
Region 5: 4 sites
TI Decision: Cleanup standards are being waived for all contaminants; the most prominent contaminants in site groundwater are PCE; TCE;
1,2-DCE; and vinyl chloride.
Rationale: It was estimated that with or without treatment, groundwater would take more than 200 years to be restored.
Conditions: NAPL (suspected or observed) - DNAPL is present in all three water-bearing zones.
COCs - Chlorinated VOCs
Concentration - Ranges of concentrations in intermediate water-bearing zone (in ug/L): 1,2-DCE-2,000; PCE-76-99; TCE-1-
5,100; and vinyl chloride-1-150. Ranges of concentrations in lower water-bearing zone (in ug/L): PCE-130; TCE-1-160;
and vinyl chloride- 1-3 30.
Geology Three water-bearing units (deepest is fractured bedrock)
77 Zone - TI Zone includes the intermediate and lower water-bearing zones (fractured bedrock) for the entire site.
Evaluation: Remedial Timeframe Estimate (years) - More than 200 years
Remedial Action Alternatives The selected remedy included use of a nearby P&T system to contain the plume in the lower
water-bearing zones and restore the shallow zone NINA for plume remediation of lower 2 zones and ICs
Current Status/Activities: Remedial actions for OUs 3, 4, 5 and 6 have been completed. Remedial action for OU1 (SVE and groundwater
extraction) and OU2 (the Lagoon Area) are ongoing. SVE is expected to be completed in September 2012.
August 2012
A-46
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Conrail Rail Yard
(Elkhart)
State: IN; OU: 2
Decision Doc. (Type &Date):
ROD Amendment, 9/27/00
Stage: Pre-construction
Media: Groundwater
References: (1) ROD Amendment,
OU2, 9/27/00,
www.epa. sov/superfund/sites/rods/
fulltext/aOSOO 160.pdf; (2) Petition
for TI Waiver; (3) Five-year
review, 2004,
www.epa. sov/superfund/sites/fivev
ear/f04-05031.Ddf : (4) Five-vear
review, 6/15/09,
www.epa. sov/superfund/sites/fivev
ear/f2009050002956.pdf
TI-Relevant Information
TI Decision: MCLs are waived for the folio wing compounds: carbon tetrachloride; 1,1-DCE;TCE; 1,2-DCE; PCE; chloroform; and vinyl
chloride.
Rationale: The 2000 ROD Amendment changes the remedy from P&T for restoration to hydraulic containment of DNAPL source areas
(where DNAPL was likely present but not observed or recovered). In addition, subsurface geology is heterogeneous both vertically and
horizontally, and contamination ranges as deep as 60 to 80 feet bgs. Active railyard operations also present a formidable restriction on the
engineering practicability of available alternatives. Based on these factors, it was determined that groundwater contaminant concentrations
may be lowered, but they could not be lowered enough to restore the groundwater.
Conditions: NAPL (suspected or observed) - DNAPL is likely but not observed or recovered
COCs - Chlorinated VOCs
Concentration - Historical maximum concentrations have been detected at 15,000 ug/L for TCE and 1 10,000 ug/L for
tetrachloride. More recent sampling indicated TCE concentrations from ND-2, 800 ug/L and tetrachloride from 1 10-7,200
ug/L.
Geology - Heterogeneous, both vertically and horizontally
77 Zone - TI waiver applies to 2 DNAPL source areas (Track 65/66 and Track 69); however the vertical extent of the TI zone is
undefined in the references reviewed.
Evaluation: Remedial Tirnefrarne Estimate (years) — Very long timeframe (no quantitative evaluation of the restoration)
Remedial Action Alternatives - P&T for hydraulic containment of DNAPL source areas.
Current Status/Activities' An alternate water supply was provided at this site (bottled water followed by residential treatment units then
extension of municipal supply) as well as SVE systems in some homes P&T was constructed to limit migration and continues to operate and
MNA is being monitored; however ICs (deed restrictions to protect the P&T system) are not fully implemented. A third 5-year review was
completed by EPA in 2009, which concluded that the groundwater remedy is not operating as intended and that some groundwater
contamination is escaping the capture system. The PRPs initiated an investigation in 2009 to address the issues raised in the 5-year review.
EPA is currently evaluating the results of the investigation for potential modifications to the groundwater remedies in both the rail yard and
drag strip areas.
August 2012
A-47
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Lemon Lane Landfill
State: IN; OUs: 2&3
Decision Doc. (Type &Date):
ROD Amendment, OUs 2 and 3,
9/29/06
Stage: Post-construction
Media: Ground water
References: (1) ROD Amendment,
OUs 2 and 3, 9/29/06; (2) Site
summary,
www.epa.gov/region5superfund/np
l/indiana/IND980794341.htm: (3)
Five-year review, 5/24/10,
www.epa. gov/superfund/sites/fivev
ear/f2010050003424.pdf
TIDecision: The TI waiver is for the NPDES substantive requirements for stormwater flow greater than 1,000 gpm, which bypasses the water
treatment plant. The following ARARs are waived: 327 IAC 2-1-6 Table 1; 327 IAC 5-2-8 (10), (11), (12), (13) (14); 327 IAC 5-2-11 (a)(l),
(2), (3), (4), (5)(c), (d), (e), (f), (g), (h); 327 IAC 5-2-11.1 (a), (b), (d), (f), (g), (h).
Rationale: The Illinois Central Spring (ICS) is a discharge point for an approximately 300-acre groundwater basin, of which Lemon Lane
Landfill is 11 acres. Hydrologic tests since 1998 have not successfully demonstrated that PCBs in karst bedrock can be effectively contained,
removed, or treated by remedial action focused at the landfill and there is no location between the landfill and ICS where groundwater drainage
can be captured and treated for PCBs. Instead, groundwater must be treated as it emerges from the groundwater system, which includes water
from the entire 300-acre basin. The ICS has a mean hourly flow rate of 300 gpm, and peak rates are approximately 4,500 gpm. Due to the
infrequent and episodic nature of the PCB releases at ICS, the large quantities of DNAPL deep in the rock near the landfill, and the volume of
water requiring treatment, the EPA is granting a TI waiver of NPDES substantive requirements for spring water which is not treated within the
existing 1,000-gpm treatment plant. The State of Indiana typically sets an effluent limit of 0.3 ug/L for PCBs discharged by treatment plants
into waters other than the Great Lakes System. As result of this TI waiver, no discharge criteria will be given to spring water that is not treated
by the 1,000-gpm treatment plant. The remedial action objective of reducing the amount of PCBs released into Clear Creek will continue to be
achieved.
Conditions: NAPL (suspected or observed) - DNAPL present in bedrock
COCs-PCBs
Concentration - PCBs generally range from 5 to 20 ug/L under low flow conditions in ICS and can exceed 500 ug/L during
storm events.
Geology - Karst terrain, 5 to 20 feet of soil above limestone layers (70 to 80 feet thick each). Four springs located near the
landfill.
77 Zone - TI waiver applies to groundwater flow greater than 500 gpm during storm events; however the extent of the TI zone is
undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Not applicable
Remedial Action Alternatives - This TI waiver is common to all remedial alternatives. The selected remedy includes a storage
overflow tank system, which will treat 5,000 gpm and when combined with the existing 1,000-gpm treatment plant, can
address a 25-year, 6-hour storm event. This alternative treats nearly 100 percent of the ICS flow and addresses 99 percent of
the PCB mass released from ICS.
Current Status/Activities: Source removal, on-site consolidation, and capping for OU1 have been conducted. OU2 and OU3 (sediments and
groundwater) are approximately 99% construction completed. Groundwater is being treated at the existing treatment plant, which has been
expanded. ICs have not been finalized.
August 2012
A-48
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Neal's Landfill
State: IN; OU: 2
Decision Doc. (Type &Date):
ROD, 9/25/07
Stage: Post-construction
Media: Groundwater
References: (1) ROD, OUs 2 and
3, 9/25/07
TI Decision: The TI waiver is for the NPDES substantive requirements for stormwater flow greater than 500 gpm, which bypasses the water
treatment plant. The following ARARs are waived: 327 IAC 2-1-6 Table 1; 327 IAC 5-2-8 (10), (11), (12), (13) (14); 327 IAC 5-2-11 (a)(l),
(2), (3), (4), (5)(c), (d), (e), (f), (g), (h); and 327 IAC 5-2-11.1 (a), (b), (d), (f), (g), (h).
Rationale: The State of Indiana typically sets an effluent limit of 0.3 ug/L for PCBs discharged by treatment plants into waters other than the
Great Lakes System. Spring water up to 500 gpm from the Northwest Spring System will be captured, treated, and subject to the 0.3 ug/L
discharge criterion. Based on the fate and transport model, it is not necessary to capture and treat more water because the additional water does
not pose an unacceptable risk to human health and the environment. Due to the large volume of stormwater produced from the karst geology
and the inability to store and eventually treat all the stormwater, it is technically impracticable from an engineering standpoint. Average spring
flows are approximately 400 gpm, but flows as high as 11,000 gpm have been observed during storm events. During one event that lasted 21
days beginning on December 29, 2004, 61.4 million gallons of water (or 188-acre feet) bypassed the existing 500-gpm water treatment plant.
Storing this large amount of water for eventual treatment would require over 100 storage tanks able to contain 600,000 gallons each, or a 47-
acre storage lagoon 4 feet in depth.
Conditions: NAPL (suspected or observed) - NAPL not mentioned in ROD
COCs-PCBs
Concentration - Non-storm concentrations of PCBs range from 0.34 to 2.6 ug/L. Peak concentrations during storm events have
been observed as high as 30 ug/L (in 2000).
Geology - Unconsolidated overburden consists of residual clay and silts and is separated from the karst limestone bedrock by a
clay layer. The Northwest Spring System, consisting of two springs and five overflow stormwater springs, is the discharge
point for a 350 to 400-acre groundwater drainage basin.
77 Zone - TI waiver applies to groundwater flow greater than 500 gpm during storm events; however the extent of the TI zone is
undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Not applicable
Remedial Action Alternatives - Storage and treatment of maximum stormwater flow would require more than 100 storage tanks
able to contain 600,000 gallons each, or a 47-acre storage lagoon with a depth of 4 feet. The selected remedy continues the
treatment of groundwater up to 500 gpm and includes ICs to prevent groundwater use at the site.
Current Status/Activities: The 2007 ROD amendment selected continued operation of the current water treatment plant (with improvement of
the water collection system) and sediment cleanup. The 2007 ROD amendment is the final action for groundwater at this site. Remedy
construction (sediment/floodplain PCB cleanup and improvements in the water treatment plant) is nearly complete.
August 2012
A-49
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Region 6: 12 sites
Site Name: Hardage/Criner
State: OK; OU: 1
Decision Doc. (Type &Date):
ROD, 11/22/89
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
11/22/89,
www.epa. sov/superfund/sites/rods/
Mltext/r0690054.pdf; (2) Five-
year review, 2002,
www.epa. sov/superfund/sites/fivev
ear/f02-06006.pdf; (3) Five-year
review, 2007,
www.epa. sov/superfund/sites/fivev
ear/f2007060001812.rjdf
TI Decision: Contaminants not specified for bedrock aquifer.
Rationale: Restoration of the bedrock aquifer is technically impracticable because DNAPL is present in the aquifer, and some contaminants
have diffused into the dead-end cracks and fine-grained pores of the rock matrix. Cleanup goals could not be met within a reasonable time
(noted as a few decades in the ROD). The ROD does not specifically state that "ARARs are being waived."
Conditions: NAPL (suspected or observed) - DNAPL is present.
COCs - Contaminants not specified for bedrock aquifer.
Concentration - Concentrations not provided for bedrock contaminants.
Geology - Two aquifers (shallow and bedrock).
77 Zone - TI waiver applies to the bedrock aquifer; however the extent of the TI zone is undefined in the references reviewed.
trenches and wells, followed by treatment, along with MNA in other areas, leading to restoration of the alluvial aquifer.
Source removal with on-site containment, treatment using SVE, ICs, and alternate water supplies were also selected.
Current Status/Activities: Based on the 2007 5-year review, ICs (site access and use [land and groundwater] restrictions) and an alternate
water supply (extension of a municipal water line) have been implemented. Trenches have been installed and are containing groundwater (in
most areas). Monitoring and maintenance of the trenches will continue.
August 2012
A-50
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Crystal Chemical Co.
State: TX; OU: I
Decision Doc. (Type &Date):
BSD, 3/19/97
Stage: Pre-construction
Media: Ground water
References: (1) BSD, OU1,
3/19/97,
www.epa. sov/superfund/sites/rods/
fulltext/e0697153.Ddf: (2)
Assessment of the TI of
Groundwater Remediation, 2/96;
(3) Five-year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f0506011.Ddf:f4)Site
summary,
www.epa.sov/earthlr6/6sf/pdffiles
/O603555.rjdf
TI-Relevant Information
TI Decision: TI waives the MCL for arsenic (50 ug/L).
Rationale: Geologic, hydrogeologic, and geochemical conditions at the site make it technically impracticable to achieve the cleanup goal for
arsenic. The site is geologically more complex than hypothesized at the time of the ROD (1990) with off -channel deposits, which are fine-
grained sediments and represent lacustrine (lake deposits), overbank, relic channel, and flood plain deposits. This geology will inhibit
migration of arsenic to extraction wells and limit the ability of P&T to remove arsenic from this area. In addition, arsenic adsorbs onto these
sediments. The current estimate for the areal extent of groundwater exceeding 50 ug/L is 420,000 square feet (5 times more than the ROD
estimated) and the volume of groundwater exceeding 50 ug/L is between 6 and 8 million gallons (more than 2 times greater than the ROD
estimated).
Conditions: NAPL (suspected or observed) - No
COCs - Arsenic
Concentration - Concentration of arsenic not provided.
Geology - The site is geologically more complex than hypothesized at the time of the ROD (1990) with off -channel deposits,
overbank, relic channel, and flood plain deposits.
TIZone - The areal extent of the TI Zone is that portion of the site north of the southern boundary of the Crystal Chemical
property where arsenic concentrations are above 50 ug/L in the shallow aquifer.
Evaluation: Remedial Timeframe Estimate (years) — Based on modeling P&T will require a minimum time of 650 years to reach a
concentration of 50 ug/L for the entire site, if it can be achieved at all.
Remedial Action Alternatives A slurry wall will be constructed to isolate the TI Zone and a limited pumping system will be
installed south of the property boundary
Current Status/Activities: According to the site summary (March 2012), VEB and P&T were used for groundwater containment. The system
was shut down in 2010 for a pilot study of phytoremediation, which is ongoing. ICs are not yet in place.
August 2012
A-51
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Highway 7 1/72
Refinery
State: LA;OU: 00
Decision Doc. (Type &Date):
ROD, 9/28/00
Stage: Pre-construction
Media: Ground water
References: (1) ROD, 9/28/00,
www.epa. sov/superfund/sites/rods/
fulltext/r0600098.Ddf: (2) Site
summary,
www.epa. sov/resion6/6sf/pdffiles/
0600641.pdf
TI-Relevant Information
TI Decision: The TI waiver applies to all groundwater COCs (including benzene).
Rationale: Groundwater restoration is not feasible from an engineering standpoint. The TI waiver was based on (1) the presence of a
potentially large source area that will remain at the site, (2) the nature and extent of contaminated groundwater plume, and (3) community
requests. First, there are several LNAPL plumes floating on top of groundwater (approximately 325,000 gallons). This layer fluctuates as much
as 1 5 feet and has created a " smear zone. " Second, more than half of the site is covered with pavement or buildings, and the community wanted
a remedy that didn't disturb the site and its development. Without extensive soil and source removal, it is impossible to address the source of
groundwater contamination. Third, the contaminant plume appears to have stabilized beneath the site likely due to natural degradation
processes and the reversal of groundwater flow. The groundwater is not currently being used and likely will not in the future due to high TDS
levels and because all residents are on city water.
Conditions: NAPL (suspected or observed) - LNAPL is present. Several plumes are floating on groundwater.
COCs - all groundwater COCs (including benzene)
Concentration - Concentrations ranged from ND to 49 ppm for VOCs, ND to 4.2 ppm for SVOCs, ND to 0. 154 ppm for lead,
and ND to 0.24 for chromium.
Geology - Alluvial aquifer is composed of sands and clayey /silty sands.
TI Zone - The TI Zone includes the entire shallow aquifer (10-60 feet bgs) at the site (215 acres).
Evaluation: Remedial Timeframe Estimate (years) - Exceeds reasonable timeframe estimate for site conditions.
Remedial Action Alternatives - Enhanced LNAPL recovery by dual phase extraction, and ICs for groundwater use restrictions.
Current Status/Activities: The site summary (April 2012) indicates that a pilot test of dual-phase extraction was operating properly in July
2010 with system optimization ongoing, and that ICs (groundwater use restrictions) were selected in the ROD. Soil contamination reached
remedial action completion in September 201 1.
August 2012
A-52
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Popile Inc. Superfund
Site
State: AR; OU: I
Decision Doc. (Type &Date):
ROD, 9/28/01
Stage:
Pre-construction
Media: Groundwater
References: (1) ROD, OU1,
9/28/01,
www.epa. sov/superfund/sites/rods/
fulltext/a0601549.rjdf: (2) TI
Determination, 9/01; (3) Site
summary,
www.epa. sov/resion6/6sf/pdffiles/
0603790.pdf
TI-Relevant Information
TI Decision: MCLs are being waived for PAH compounds expressed as benzo(a)pyrene at 0.2 ppb and PCP at 1 ppb.
Rationale: The extent of the NAPLs is approximately 4 acres (horizontally) and 30 feet (vertically) in site soils and groundwater. An in situ
pilot study for bioremediation of soils was unsuccessful, and other in situ treatments of the soils are unlikely to succeed due to low
permeability. Based on available site data, the contaminant concentrations have already achieved static levels indicating steady-state conditions
between the NAPL and the surrounding dissolved phase plume. These conditions are further demonstrated by the lack of plume growth with
little or no predicted changes based on modeling (the plume has changed little in the past 43 years and is predicted to remain static for the next
48 years). P&T would have a limited impact in achieving restoration due to characteristics of the aquifer and physical properties of the
creosote and PCP. Pumping to maintain gradient control is unnecessary since the dissolved plume has demonstrated little or no migration from
the source area due to physical adsorption and biodegradation within the aquifer.
Conditions: NAPL (suspected or observed) - Waste generated from past wood preserving operations occurs as DNAPL and LNAPL.
Contamination exists as both residual and free-phase NAPL.
COCs 7 PAHs and PCP
Concentration The solubilities of the PAHs identified range from relatively insoluble to 3 1 mg/L
Geology - Low permeability soils
77 Zone - The TI Zone includes groundwater beneath the current site boundary eastward to the Ouachita Railroad; this
horizontal extent is based on presence of residual contamination and NAPL The vertical extent is to the base of the
Cockfield aquifer (approximately 55 feet bgs)
Evaluation: Remedial Timeframe Estimate (years) - Exceeds reasonable timeframe estimate for site conditions.
Remedial Action Alternatives - The long-term management solutions for the groundwater contamination includes the use of ICs
to prevent exposure and the use of a TI waiver for the previously established remedial goals (chemical -specific ARARs).
Current Status/Activities: According to the site summary (February 2012), groundwater is not migrating off-site and EPA concluded that no
further remedial action is necessary because natural attenuation is occurring. Groundwater monitoring is still ongoing and ICs have been
maintained since 200 1 (fencing and signage preventing excavation and drilling into the aquifer), but EPA is in the process of ensuring deed
restrictions are implemented.
August 2012
A-53
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Garland Creosoting
State: TX; OU: I
Decision Doc. (Type &Date):
ROD, 9/15/06
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/15/06,
www.epa. sov/superfund/sites/rods/
Mltext/r2006060001492.pdf; (2)
Final FS, Evaluation of TI,
6/20/06, (3) Site summary
www.epa.sov/earthlr6/6sf/pdffiles
/060 1644.pdf
TI-Relevant Information
TI Decision: ARARs waived are MCLs for PCP and benzo(a)pyrene.
Rationale: Based on monitoring data, DNAPL was found from 2 to 15 inches in thickness over 1 acre. However, assuming the DNAPL is 6
inches thick and the aquifer has an effective porosity of 25 percent, more than 35,700 gallons of DNAPL are present. DNAPL may not be
adequately delineated and its movement in the subsurface is difficult to predict. Previous non-time critical removal actions included soil
removal and interceptor trenches that collect and treat water and NAPL before it migrates off-site; these trenches continue to operate. It is
believed the trenches will be required to operate indefinitely to contain the groundwater contamination.
Conditions: NAPL (suspected or observed) - DNAPL is present.
COCs - PCP and benzo(a)pyrene
Concentration - Maximum concentrations in 2002 were 16.4 ug/L for pentachlorophenol and 10.8 ug/L for benzo(a)pyrene.
Geology - Silt and fine-grained sand unit overlain and underlain by clay unit.
TI Zone - The TI Zone encompasses the entire site and areas that are captured by the existing trenches. Vertically, the zone
extends through the shallow water-bearing zone down to the clay layer.
Evaluation: Remedial Timeframe Estimate (years) - Exceeds reasonable timeframe estimate for site conditions.
Remedial Action Alternatives — Selected remedy consists of continued operation of the interceptor trench, installation of
additional groundwater recovery wells, MNA, and ICs to restrict future use of the groundwater.
Current Status/Activities: According to the site summary (March 2012), the Site achieved construction complete status in August 2010. The
long term action consists of collecting leachate from two trenches and treating it on-site for 10 years. ICs were selected in the ROD (deed
restrictions and land use restrictions) but their status is not reported.
August 2012
A-54
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Petro-Chemical
Systems Inc. (Turtle Bayou)
State: TX; OU: 2
Decision Doc. (Type &Date):
ROD Amendment, 9/22/06
Stage: Post-construction
Media: Ground water
References: (1) ROD Amendment,
OU2, 9/22/06,
www.epa. gov/superfund/sites/rods/
fulltext/a2006060001486.pdf: (2)
TI Demonstration, 3/06; (3) Five-
year review, 2006,
www.epa. gov/superfund/sites/fivev
ear/f2006060001401 .pdf: (4) Five-
year review, 2011
www.epa.gov/earthlr6/6sf/pdffiles
/0601644.pdf
TI Decision: MCLs are being waived for all contaminants (PAHs and VOCs).
Rationale: Previous actions include excavation at this area; SVE, in situ thermal treatment, P&T, and in situ bioremediation for other areas at
the site. However, these actions have not been effective at restoring the shallow aquifer. Complex hydrogeology is present at this site, which
consists of a complex and heterogeneous stratigraphy of interbedded silts and clays and some sand, low hydraulic conductivity, a downward
vertical gradient, and high temporal variation in the water levels. Two saturated zones are affected and form the basis of the TI waiver: S1
zone (clayey soils from 18-24 feet bgs) and S2 (sand from 30-80 feet bgs). P&T and in situ treatment would be limited because of (1) the low
hydraulic conductivity of the S1 layer and (2) the distribution of constituents in the clay layer between the S1 and S2 units because the
clays/silty clays will serve as an ongoing diffusion-limited source of constituents. Based on mass calculations, over 99 percent of the total COC
mass is contained within the low permeability soils, which will act as a continuing source, and less than 1 percent of the mass is present as
dissolved COCs. It is estimated that an extraction or injection technology would remove less than 10 percent of the mass in these zones based
on empirical data for similar site conditions.
Conditions: NAPL (suspected or observed) - No recoverable NAPL was encountered during site investigations but are likely present.
COCs - PAHs and VOCs
Concentration - No concentrations provided in TI Demonstration Report.
Geology - Complex hydrogeology is present at this site, which consists of a complex and heterogeneous stratigraphy of
interbedded silts and clays and some sand, low hydraulic conductivity, a downward vertical gradient, and high temporal
variation in the water levels. Two saturated zones are affected and the basis of the TI waiver: SI zone (clayey soils from
18-24 feet bgs) and S2 (sand from 30-80 feet bgs).
TIZone - The TI Zones include the affected areas of the SI (3 acres) and S2 (5 acres) units. The boundary was drawn, as
requested by the State of Texas, through the peripheral well sample points with groundwater concentrations below MCLs.
The SI and S2 units extend 18-24 and 30-80 feet bgs, respectively.
Evaluation: Remedial Timeframe Estimate (years) - Calculations determined that restoration of the site would require over 100 years
because mass removal will be diffusion-limited regardless of which technology (active versus MNA) is implemented.
Remedial Action Alternatives - The selected remedy consists of (1) excavation and in situ chemical treatment for soils, (2) in
situ chemical injection to destroy about 80 percent of COCs in the groundwater, and (3) ICs (deed notices, signage, and
restrictions on use of land and groundwater). Although this remedy will not achieve groundwater restoration, it is
technically practicable, protective of human health and the environment, and results in partial remediation of the source area
and groundwater.
Current Status/Activities: Based on the 2011 5-year review, in situ treatments were used at several areas of the site for soil and groundwater
through 2005. ICs have been developed for a portion of the site and are being developed for the remaining area. The remedy is protective of
human health and the environment in the short term in most areas, but site monitoring is ongoing. The possibility of VI pathways will be
assessed and final O&M plans are needed.
August 2012
A-55
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General Site Information
Site Name: Hart Creosoting
State: TX; OU: I
Decision Doc. (Type &Date):
ROD, OU1, 9/21/06
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/21/06,
www.epa. sov/superfund/sites/rods/
Mltext/r2006060001481.pdf; (2)
Site Summary,
www.epa.sov/earthlr6/6sf/pdffiles
/060 1975.pdf
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
TI-Relevant Information
TI Decision: MCLs are being waived for all contaminants; the prominent one is naphthalene (MCL-100 ug/L). Groundwater PRGs will also
not be achieved. See Table 3 of the 2006 ROD for all PRGs.
Rationale: A TI waiver is necessary because the presence of PAHs in the dissolved phase groundwater plume and free -phase and residual
DNAPL in multi-lithology zones make it technically impracticable to restore groundwater within a reasonable timeframe.
Conditions: NAPL (suspected or observed) - Free-phase and residual DNAPL has been observed.
COCs - 12 PAHs, 4 SVOCs, and benzene
Concentration - Naphthalene was detected between 0.11 and 15.2 mg/L in 1986.
Geology - Multi-lithology zones
TIZone - TI Zone includes all portions of on-site groundwater where naphthalene exceeds the PRO and extends from 10 to 200
feet bgs (groundwater zones P-2 and P-4); however the lateral extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Exceeds reasonable timeframe estimate for site conditions
Remedial Action Alternatives - The selected remedy includes a NAPL recovery system, treatment of surface water, excavation
and on-site landfilling for site soils and sediments, a TI waiver, MNA, and ICs (land and groundwater use restrictions).
Current Status/Activities' The site summary (March 2012) indicates the site is in the long-term remedial action phase and construction
completion was achieved in September 2008. The remedy included a NAPL recovery system and soil excavation with on-site disposal.
August 2012
A-56
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Midland Products
State: AR; OU: I
Decision Doc. (Type &Date):
ROD Amendment, 6/9/06
Stage: Post-construction
Media: Groundwater
References: (1) ROD Amendment,
OU1, 6/9/06,
www.epa.sov/earthlr6/6sf/pdffiles
/old midland amended rod.pdf;
(2) Site summary,
www.epa.sov/earthlr6/6sf/pdffiles
/06002 16.pdf
TI-Relevant Information
TI Decision: MCLs are being waived for 2 contaminants: PCP (1 ug/L) and benzo(a)pyrene (0.2 ug/L).
Rationale: The ROD Amendment changes the remedy from P&T to MNA with a TI waiver and ICs. P&T has treated more than 12 million
gallons of groundwater, which is more than 20 times greater than the contaminated plume volume of 450,000 gallons estimated in the 1988
ROD; however, high contaminant levels remain in the aquifer. LNAPL and DNAPL are still present in several wells.
Conditions: NAPL (suspected or observed) - LNAPL and DNAPL have been observed.
COCs - PCP, PAHs
Concentration - Maximum concentrations in 2005 were 910 ug/L for PCP and 9.2 ug/L benzo(a)pyrene.
Geology - Fractured bedrock
77 Zone - TI Zone consists of the DNAPL source area and the area enclosed by downgradient monitoring wells. Vertically, the
zone extends to 40 feet bgs.
Evaluation • Remedial Timeframe Estimate (years) Exceeds reasonable timeframe estimate for site conditions
Remedial Action Alternatives - Amendment changes remedy from P&T to MNA with a TI waiver and ICs (groundwater use
restrictions)
Current Status/Activities' Based on the site summary (January 2012) the sroundwater remedy included a P&T system that has treated 12
million gallons of groundwater. The groundwater plume is currently stable and not expanding. The site is protective of human health and the
environment, and is ready for non-residential use.
August 2012
A-57
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Jasper Creosoting
State: TX; OU: I
Decision Doc. (Type &Date):
ROD, 9/20/06
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU1,
9/20/06,
www.epa. sov/superfund/sites/rods/
Mltext/r2006060001482.rjdf: (2)
Site summary,
www.epa.sov/earthlr6/6sf/pdffiles
/O601735.pdf
TI-Relevant Information
TI Decision: MCLs are being waived for all contaminants; the prominent one is naphthalene (MCL- 100 ug/L). Groundwater PRGs will also
not be achieved. See Table 3 of 2006 ROD for all PRGs.
Rationale: A TI waiver is necessary because the presence of PAHs in the dissolved phase groundwater plume and free -phase and residual
DNAPL in multi-lithology zones make it technically impracticable to restore groundwater within a reasonable timeframe.
Conditions: NAPL (suspected or observed) - Free-phase and residual DNAPL has been observed.
COCs-PAHs
Concentration - Maximum concentrations were 307,000 ug/L for total PAH and 105,000 ug/L for naphthalene in 2004.
Geology - Multi-lithology zones
TIZone - TI Zone covers 12 acres and includes all portions of on-site and off-site groundwater where site COCs are above
PRGs. Vertically, the zone includes groundwater zones PI and P3 and extends to 150 feet bgs on-site and to 130 feet off
site.
Evaluation: Remedial Timeframe Estimate (years) - Exceeds reasonable timeframe estimate for site conditions.
Remedial Action Alternatives — The selected remedy includes a NAPL recovery system, excavation and on-site landfilling for
site soils MNA for sediments and groundwater a TI waiver ICs and P&T for containment (if necessary)
Current Status/Activities: The site summary (March 2012) does not include any new information (since the ROD was issued).
August 2012
A-58
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Vertac
State: AR; OU: 3
Decision Doc. (Type &Date):
ROD, 9/17/96
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU3,
9/17/96,
www.epa. sov/superfund/sites/rods/
fulltext/r0696 103.pdf; (2) Request
for TI Waiver, OU3, 9/96; (3)
Five-year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f04-06002.Ddf: (4) Site
summary,
www.epa.sov/earthlr6/6sf/pdffiles
/O600023.rjdf
TI-Relevant Information
TI Decision: Groundwater constituents include chloride; 2-chlorophenol; 4-chlorophenol; 2,4-dichlorophenol; 2,6-dichlorophenol; 2,4,5-
trichlorophenol; 2,4,6-trichlorophenol; toluene; tetrachlorobenzene; 2,6-D; 2,4-D; 2,4,6-T; 2,4,5-T; 2,4,5-TP; and 2,3,7,8-TCDD. MCLs were
only listed for chloride; toluene; 2-4D; 2,4,5-TP; and 2,3,7,8-TCDD.
Rationale: The OU3 FS concluded that restoration of groundwater under much of the central process area to concentrations below MCLs is
technically impracticable due to the presence of NAPLs and the hydrologic characteristics of the weathered and fresh bedrock. Free-phase
NAPL has been observed at 3 locations; it may be possible to recover these localized NAPLs. Throughout the northern part of the central
process area, residual NAPLs are present in limited quantities or are trapped interstitially such that direct recovery is not possible. According to
the Request for TI Waiver, there are no available remediation technologies that could effectively remove the residual product in the fractured
bedrock. In these locations, the NAPL and residual product will continue to contribute to dissolved-phase concentrations as long as pure
product remains in contact with the groundwater. In addition, some of the contaminants, particularly 2,3,7,8-TCDD, have relatively low
solubilities and will biodegrade slowly, persisting in the soil and rock matrices for many decades.
Conditions: NAPL (suspected or observed) - Free-phase NAPLs were observed (greater than 1-inch thickness) in 3 locations. Other locations
have NAPL as residual product.
COCs - Chloride; chlorinated SVOCs; toluene; pesticides
Concentration - Concentrations not provided in Request for TI Waiver.
Geology - weathered and fractured bedrock
77 Zone — The TI Zone includes groundwater located beneath the north part of the central process area the North Landfill and
the Reasor Hill Landfill' this zone includes areas north and west of the known and suspected NAPL areas in order to
account for potential DNAPL migration. The vertical extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Exceeds reasonable timeframe estimate for site conditions.
Remedial Action Alternatives - Hydraulic containment system composed of extraction wells and a French drain system plus ICs
to prevent the installation of water supply wells.
Current Status/Activities: Based on the site summary (March 2012), source control activities are complete and P&T for hydraulic control will
continue. Almost half of the site will be available for beneficial use.
August 2012
A-59
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: City of Perryton Well
#2
State: TX;OUs: I
Decision Doc. (Type &Date):
ROD Amendment, 9/29/11
Stage: Post-construction
Media: Ground water
References: (1) Site Summary,
January 20 12,
www.epa.sov/earthlr6/6sf/pdffiles
/06050 15.pdf;
(2) Five-year review, 9/9/08,
www.epa. sov/superfund/sites/fivev
ear/f2008060002676.pdf
TI-Relevant Information
TI Decision: ARARs to achieve MCLs for carbon tetrachloride (5 ng/L) and nitrate (10 mg/L) in the Upper Zone and Lower Unit 2 of the
Ogallala aquifer.
Rationale: The original remedy was a groundwater P&T system composed of two extraction wells and an air stripper treatment plant to
remove the carbon tetrachloride from the extracted groundwater. EPA temporarily shut down the groundwater P&T system in late September
2007 to evaluate potential contaminant rebound in the extraction wells after the July 2007 sample results confirmed that groundwater in the
lower zone had been cleaned up. The first rebound sampling event occurred on October 29, 2007 and the second event was completed on
November 28, 2007. The October 29th sample results indicated no change in contaminant concentration in extraction well MW-17EX, but
carbon tetrachloride concentrations in Well #2 rebounded to 27.9 ug/L in Upper Unit 2 and Unit 3 (similar to pre-cleanup conditions).
Following the November 28th sampling, Well #2 was re-started to ensure that the lower zone did not become contaminated again. The results
for Well #2 indicated that contamination from the upper zone of the aquifer was migrating downward along the gravel packed annulus of Well
#2 and contaminating the lower zone. The P&T system was restarted in November 2007 because continued operation of Well #2 was
necessary to prevent recontamination of the lower zone. The two extraction wells were sampled again during the week of January 7, 2008, and
well MW-17EX contained 1 ug/L of carbon tetrachloride and Well #2 contained 3.6 ug/L of carbon tetrachloride.
The cleanup goal has been achieved for the lower zone in the Ogallala aquifer. The upper flow zone still has contamination above the cleanup
goal but behaves as a perched zone and not a part of the primary water production zone in the Ogallala. Site data collected since October 2002
demonstrates that the existing P&T system, which pumps groundwater from aquifer Unit 3, has had little or no effect on the contamination
present in these perched zones. EPA plugged and abandoned Well #2 in January 201 1, which will allow unrestricted use of the aquifer, the
source of drinking water for the City of Perryton. A site-wide groundwater sampling event was completed in August 20 1 1, and no changes
were detected in the carbon tetrachloride concentrations since the last site-wide sampling events in April 2008 and July 2007.
According to the 5-year review (2008), the ROD did not include the use of ICs to protect the remedy effectiveness because the remedy was
anticipated to achieve the cleanup goals throughout the Ogallala aquifer. However, since groundwater standards will likely not be achieved in
the Upper Zone and Lower Unit 2, the use of ICs may be necessary to prevent the installation of a private well that would create a migration
pathway between the contaminated Upper Zone and the remediated Lower Unit 3. The ROD Amendment (2011) was not available for review
to determine if ICs were indeed selected along with the TI waiver.
Conditions: NAPL (suspected or observed) - NAPL not mentioned in Site Summary.
COCs - Carbon tetrachloride, nitrate
Concentration -Concentrations for carbon tetrachloride in Upper Unit 2 and Unit 3 ranged from 40 ug/L in 1990 to 27.9 ug/L
in October 2007 to 3.6 ug/L in April 2008. Monitoring data are provided in Attachment 6 of the 2008 5-year review.
Geology - The aquifer at the site is composed of interbedded sand, silt, and clay layers, and is divided into an Upper and Lower
Zone (which are separated by low permeability silt and clay layers). The Upper Zone consists of Unit 1 and Upper Unit 2,
and the Lower Zone is composed of Lower Unit 2, Unit 3, and Unit 4.
77 Zone - TI zone includes the Upper Zone and Lower Unit 2 of the Ogallala aquifer and covers approximately 20 acres (based
on estimates obtained from figures in Site Summary).
Evaluation: Remedial Timeframe Estimate (years) - Not provided in Site Summary
Remedial Action Alternatives - Well #2 was abandoned and sealed in January 201 1 to prevent contaminant migration. The P&T
system continues to be shutdown. The current status of ICs is not available in the documentation reviewed.
Current Status/Activities: The P&T system was shutdown in 2007 to allow for rebound sampling and plans are for it to be decommissioned.
Well #2 was restarted in 2007 and continued pumping until it was plugged in 201 1. The remaining city water supply wells are not threatened
by the contaminant plume and are routinely monitored as part of the requirements of the Federal Safe Drinking Water Act.
August 2012
A-60
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: North Cavalcade
State: TX; OU: 3
Decision Doc. (Type &Date):
ROD Amendment, 8/26/11
Stage: Post-construction
Media: Ground water
References: (1) Five-year Review,
9/29/08,
www.epa. gov/superfund/sites/fivev
ear/f2008060002683.pdf:
(2) Site summary, January 2012,
www.epa.gov/earthlr6/6sf/pdffiles
/O602956.pdf:
(3) TI Technical Memorandum,
7/6/11,
www.epa. gov/earthlr6/6sf/texas/n
orth cavalcade/tx ncavalcade ncr
a tm-ti 2011-0706 draftfinal.pdf
TI Decision: ARARs waived are MCLs for benzene (5 ug/L) and benzo(a)pyrene (0.2 ng/L), and a state promulgated standard for
naphthalene (1,500 ng/L onsite and 490 ug/L offsite) in the shallow sand and interbedded units.
Rationale: Dissolved phase contamination exceeding these cleanup levels is limited to within 2 blocks west of the site despite wood treating
operations ceasing at the site over 50 years ago. P&T was conducted for the shallow aquifer and removed an estimated 8,000 pounds of
creosote from the shallow sand. Later investigation verified that contamination was also present in the underlying interbedded unit, a much
sillier zone that was not conducive to the P&T remedy.
TI of groundwater restoration is supported by the following: (1) the remaining residual and free-phase DNAPL, although limited in extent,
will continue to act as a source for site-related contaminants in groundwater, essentially outpacing the natural degradation of these
contaminants in the areas where DNAPL appears. In this case, natural attenuation serves as a process for plume stability and containment,
rather than restoration; (2) the heterogeneity and lithologic complexity of the interbedded unit limits the effectiveness of treatment
technologies for source material and contaminated groundwater. While the predominant clay and silt limit migration of contamination, material
bound in the matrix will continue to serve as an active source of contamination through dissolution. However, it cannot be removed or treated
effectively or sufficiently to eventually achieve cleanup levels throughout the contaminated area; (3) the occurrence of DNAPL accumulation
is limited to 4 wells out of the 65-well network associated with the source areas. DNAPL accumulation will continue to be measured and
recovered when observed; and (4) source treatment has already been implemented using P&T and in situ source stabilization (ISS). P&T was
found to be ineffective for the interbedded unit where the majority of contamination is observed, and expansion of the implemented ISS
remedy or application of other remedies is limited by site features (active commercial businesses onsite, active rail lines, and future above-
ground construction extending a highway).
Conditions: NAPL (suspected or observed) - Free-phase and residual DNAPL are present.
COCs - Benzene, benzo(a)pyrene and naphthalene
Concentration - Maximum concentrations in 2010 exceed 10,000 ug/L for naphthalene and 500 ug/L for benzene. Plume maps
are provided in the Technical Memorandum.
Geology - The site is underlain by two water-bearing zones (shallow sand and interbedded unit) located above a thick regional
clay layer (approximately 100 feet thick), which serves as a barrier to downward groundwater flow. The shallow sand is
mostly poorly graded sand or silt sand. The interbedded unit is comprised of various clays, silts, and sands.
TIZone -The TI zone applies to both the shallow sand and interbedded units. The TI zone covers approximately 16 acres and is
defined by the extent of the naphthalene plume in the interbedded unit.
Evaluation: Remedial Timeframe Estimate (years) - Not provided in documents reviewed.
Remedial Action Alternatives - The 2011 ROD Amendment selected containment of the shallow sand and interbedded unit
dissolved phase plumes, as restoration throughout the impacted groundwater would not be achievable in the presence of DNAPL. The decision
established a 16-acre TI Zone, wherein cleanup levels would be waived for benzene, benzo(a)pyrene, and naphthalene. ICs will be established
to restrict the installation of groundwater wells within this zone to prevent exposure to contaminants.
Current Status/Activities: GW P&T was suspended in 2003 to investigate additional (deeper) contamination. Source control activities
including on-site consolidation (24,500 cy) and ISS (12,000 cy) were completed in 2011. The current remedy includes containment of
groundwater via natural processes and site conditions. The 2011 ROD Amendment selects ICs to restrict use of or access to groundwater with
contaminant concentrations above drinking water standards; their status is not provided in documents reviewed. Drinking water is provided by
the City of Houston's public water supply in this area.
August 2012
A-61
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Cherokee County,
Baxter Springs and Treece Subsites
State: KS; OUs: 3&4
Decision Doc. (Type & Date):
ROD, 8/20/97
Stage: Pre-construction
Media: Groundwater and surface
water
References: (1) ROD, OUs 3 & 4,
8/20/97,
www.epa. sov/superfund/sites/rods/
fulltext/r0797073.Ddf: (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-07004.pdf; (3) Five-vear
review, 2010,
www.epa.sov/earthlr6/6sf/pdffiles
/O601735.rjdf
TI-Relevant Information
Region 7: 7 sites (8 waivers)
TI Decision: ARARs to be waived include MCLs (cadmium-5 ppb) and state standards (lead- 15 ppb) for groundwater. Clean Water Act
standards (dissolved cadmium-3 ppb, dissolved lead-1 1 ppb, and total recoverable zinc-412 ppb) are also being waived for nearby creeks.
Rationale: There are several factors present that warrant the TI waiver at the Baxter Springs and Treece subsites. First, site conditions, such as
karst-like topography, mine voids, and mining wastes at this site and neighboring sites cover 1,400 acres and total 7.5 million cubic yards. No
alternatives evaluated were capable of achieving MCLs or Clean Water Act standards under these conditions. Secondly, nearby residents are
supplied municipal water, and the shallow aquifer is not used for consumption. The deeper aquifer is not contaminated and is used for water
supply to the area. Additionally, this site is contained within the Tri-State Mining District, which also includes Tar Creek in Oklahoma and
Jasper County in Missouri.
Conditions: NAPL (suspected or observed) - NAPL is not an issue at this site.
COCs - Metals
Concentration - Concentrations for groundwater not included in ROD.
Geology — Karst-like topography and mine voids two aquifers
77 Zone — TI Zone applies to the shallow aquifer and nearby creeks' however the extent of the TI zone is undefined in the
references reviewed.
Evaluation' Remedial Timeframe Estimate (years) not calculated (Note' There are no active groundwater remedies to remediate or clean
up the groundwater EPA is relying on ICs and the provision of clean drinking water via rural water districts and pipeline
expansions - providing a safe source to consume but not remediating the groundwater.)
Remedial Action Alternatives — Excavation and/or consolidation of mining wastes followed by capping and revegetation For
groundwater ICs and the provision of clean drinking water via rural water districts and pipeline expansions
Current Status/Activities: According to the 2010 5-year review, not all county -wide ICs (land use restrictions and restrictions on use of mine
wastes) have been implemented. An alternate water supply (extension of municipal water supply) was provided to affected residences. Many
remedial activities have been conducted to address sources at this site. No groundwater actions were conducted at this OU.
August 2012
A-62
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Cherokee County,
Galena Subsite
State: KS; OU: I
Decision Doc. (Type &Date):
ROD, 9/18/89
Stage: Pre-construction
Media: Groundwater and surface
water
References: (1) ROD, OU1,
9/18/89,
www.epa. sov/superfund/sites/rods/
fulltext/r0789030.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-07004.pdf; (3) Five-year
review, 2010,
www.epa.sov/earthlr6/6sf/pdffiles
/O601735.rjdf
TI-Relevant Information
TI Decision: ARARs to be waived include MCLs, state standards, and Clean Water Act standards for arsenic, barium, cadmium, chromium
(VI), copper, iron, lead, manganese, mercury, nickel, selenium, silver, and zinc.
Rationale: The continued presence of waste materials on site, off site, and upgradient of the site make it technically impracticable to achieve
MCLs in groundwater and water quality criteria in surface water. The only approach identified that could possibly remediate the site to achieve
ARARs is to (1) treat all surface mine wastes and (2) strip mine the remaining mineralization at the Galena subsite. This alternative has several
implications, such as destruction of an endangered species habitat, removal of all surface soils, and permanent relocation of the town of
Galena. Inordinate costs would be associated with such an action.
Conditions: NAPL (suspected or observed) - NAPL is not an issue at this site.
COCs - Metals
Concentration - Maximum concentrations observed in private wells (in ug/L): barium-390; cadmium-180; chromium-120;
copper-140; lead-230; manganese-3,400; mercury-0.44; nickel-270; selenium-24; silver-11; zinc-15,000
Geology - Karst-like topography and mine voids, two aquifers
77 Zone -TI Zone applies to the area groundwater and Short Creek; however the extent of the TI zone is undefined in the
references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Not calculated (Note' There are no active groundwater remedies to remediate or clean
up the groundwater EPA is relying on ICs and the provision of clean drinking water via rural water districts and pipeline
expansions - providing a safe source to consume but not remediating the groundwater.)
Remedial Action Alternatives Alternate water supply included the construction of new public water supply wells and
associated pipelines A rural water district was created and serves as a permanent water supply to affected residents Using
ICs to control risk.
Current Status/Activities: According to the 2010 5-year review, not all county -wide ICs (land use restrictions and restrictions on use of mine
wastes) have been implemented. An alternate water supply (extension of municipal water supply) was provided to affected residences. Many
remedial activities have been conducted to address sources at this site. No groundwater actions were conducted at this OU.
August 2012
A-63
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Aluminum Company
of America-Davenport
State: IA; OU: I
Decision Doc. (Type &Date):
ROD, 9/28/04
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU1,
9/28/04,
www.epa. gov/superfund/sites/rods/
fulltext/r2004070003144.pdf: (2)
Feasibility Study and Appendix A
(TI Evaluation Report, September
2004), 5/2004; (3) BSD, 7/5/07,
www.epa. gov/superfund/sites/rods/
fulltext/e2007070003101.pdf
TI Decision: ARARs to be waived include MCLs for a variety of VOCs, PAHs, SVOCs, and PCBs. The TI Determination also indicated that
PRGs for a variety of VOCs, PAHs, SVOCs, and PCBs will not be achieved. See Table 5-1 in Appendix A of the FS for a complete list.
Rationale: The multiple sources of NAPL, which cannot be delineated with a high degree of certainty, have resulted in a large volume of
contaminated groundwater that extends to great depths (400 feet bgs) and will likely persist for a very long time due to the migration of low
solubility DNAPL and LNAPL. In addition to the substantial depths of contamination, the poor connectivity of fractures common to fractured
carbonate bedrock formations limits the ability to fully delineate the extent of DNAPL contamination areas. Given the properties of the
contamination and the subsurface media, it is not possible to develop a meaningful estimate of the contaminant mass; therefore, the restoration
timeframe cannot be estimated precisely but is known to be considerable (longer than 100 years). The TI waiver applies to the constituents in
both the dissolved and NAPL phase within the TI Zone. The remedy selected in the 2004 ROD is groundwater containment, which includes
groundwater P&T, source area remediation, groundwater monitoring, and ICs. The existing P&T system is containing the groundwater plume,
and concentrations outside the containment area exhibit either background groundwater quality or are below ARAR thresholds. The 2007 BSD
clarifies the compounds and chemical-specific ARARs that will be used as groundwater performance standards and monitoring levels for areas
outside the TI Zone in the subsequent implementation of the groundwater monitoring program.
Conditions: NAPL (suspected or observed) - Both DNAPL and LNAPL are present.
COCs - 30 VOCs, 13 PAHs, 2 SVOCs, 3 PCBs
Concentration - Tables L-3-1, L-3-2, and N-4 of the 2004 ROD show maximum groundwater concentrations for select VOCs
within certain areas of the aquifer. A more comprehensive set of groundwater concentration data is included in Table A-l of
Appendix A to the Feasibility Study.
Geology - Fractured limestone/dolomite bedrock formations to approximately 400 feet bgs
77 Zone - The TI Zone includes locations where NAPL sources were identified based on direct observations or detections with a
NAPL/water interface probe and the interpretation of groundwater concentrations. The vertical extent of the TI Zone
consists of all saturated zones, which include the unconsolidated groundwater and underlying bedrock aquifer (both shallow
and intermediate/deep bedrock zones).
Evaluation: Remedial Timeframe Estimate (years) - More than 100 years
Remedial Action Alternatives - The selected remedy included continuing P&T for hydraulic control, groundwater monitoring,
and ICs (land and groundwater use restrictions).
Current Status/Activities: According to the 2004 ROD and 2007 BSD, ICs restricting groundwater and land use are in place, and additional
ICs will be implemented. The P&T system was implemented in 1989 and continues operating for plume containment. No additional
information was available.
August 2012
A-64
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Missouri Electric
Works
State: MO; OU: 2
Decision Doc. (Type &Date):
ROD, 9/28/05
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
9/28/05,
www.epa. sov/superfund/sites/rods/
fulltext/r0705052.rjdf: (2)
Fractured Bedrock TI Evaluation
Report, 7/5/05; (3) Site summary,
www.epa. sov/resion07/cleanup/np
1 files/mod980965982.pdf
TI-Relevant Information
TI Decision: The ROD is waiving MCLs and non-zero MCLGs for 1,1,1-TCA; TCE; PCE; 1,1-DCA; 1,1-DCE; 1,2-DCE; benzene;
chlorobenzene; 1,2,4-TCB; 1,2-DCB; 1,3-DCB; 1,4-DCB; and PCBs within the TI Zone of the fractured bedrock.
Rationale: In 1990, P&T was selected to address groundwater contamination. However, after the ROD was issued, new hydrogeologic
information indicated contamination at depths greater than 300 feet bgs. The selected remedy in the 2005 ROD includes ICs, well-head
treatment, monitoring, and a TI waiver for the bedrock aquifer. Enhanced bioremediation and MNA are being evaluated for the alluvium
aquifer. Due to the fractured bedrock present at the site, it is difficult to accurately and completely predict the location and migration of COCs.
The fracture network includes a complex set of vertical fractures and near-horizontal bedding plane fractures. The following limitations were
identified: (1) identifying fractures, (2) locating COCs, (3) installing angled wells to intercept key fracture and karst features, and (4)
adequately monitoring COCs within the aquifer. In addition, pumping or in situ injection may exacerbate contaminant migration. Based on
these factors, the amount of time required to reach ARARs cannot be reliably determined; however, this period is expected to be greater than
30 years and may be more than 100 years. The TI Zone includes the areas of measured COC concentration above cleanup levels from
approximately 80 feet upgradient of the known source areas to the downgradient area where groundwater discharges at depth from the
fractures to the alluvium. A "buffer zone" is also provided in this zone to allow for the variability of the fractured bedrock system.
Conditions: NAPL (suspected or observed) - NAPL has not been observed and is not expected to be present.
COCs - Chlorinated VOCs and SVOCs; pesticides; PAHs, nitrobenzene; benzene; PCBs
Concentration - Maximum concentrations reported in the ROD (ug/L): l,2,4-TCB-62; 1,3-DCB-lOO; 1,4-DCB-120; 2-
chlorophenol-9; aroclor-1260-110; benzene-83; bis(2-chloroethyl)ether-6; BEHP-120; chlorobenzene-3,200; chloroform-
13; naphthalene-8.7; n-nitrosodi-n-propylamine-8.1; PCE-8.6; and TCE-13.
Geology - Fractures, karst, bedrock.
TI Zone - The TI Zone includes an area of the bedrock aquifer that measures approximately 1,150 feet by 1,000 feet. No vertical
(depth) limitations are included for the TI Zone.
Evaluation: Remedial Timeframe Estimate (years) - At least 30 years but possibly more than 100 years
Remedial Action Alternatives - Well-head treatment and ICs (including notices, land use restrictions, and groundwater use and
well installation restrictions) were also selected for this aquifer.
Current Status/Activities: The site summary (March 2012) indicates that thermal desorption for contaminated soils was completed in 2002. A
Consent Decree is currently being negotiated for OUs 2 and 3.
August 2012
A-65
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Waterloo Coal
Gasification Plant
State: IA; OU: I
Decision Doc. (Type &Date):
BSD, 8/11/06
Stage: Pre-construction
Media: Ground water
References: (1) BSD, OU1,
8/11/06,
www.epa. gov/superfund/sites/rods/
fulltext/e0706002.pdf: (2) TI
Evaluation Report, 8/2/06; (3)
ROD, 9/24/04,
www.epa. gov/superfund/sites/rods/
fulltext/r0704653.pdf: (4) Site
summary,
www.epa. gov/region07/cleanup/np
1 files/iad984566356.pdf
TI Decision: According to the TI Evaluation Report, the following ARARs are being waived: MCLs for antimony, arsenic, cadmium,
chromium, lead, cyanide, benzene, ethylbenzene, and benzo(a)pyrene. The TI Evaluation Report also determined that PQLs for
benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenzo(a,h)anthracene, and indeno(l,2,3-cd)pyrene and Risk-Based
Cleanup Levels for iron, manganese, nickel, 2-methylnaphthalene, chrysene, and naphthalene could not be met.
Rationale: The following issues make it technically impracticable to achieve restoration of the alluvial aquifer within a reasonable timeframe:
(1) approximately 99 percent of the estimated 85,900 pounds of organic contaminant mass remaining at the site consists of PAHs; (2) the
alluvial aquifer is impacted by residual and free-phase NAPL, which will remain as a long-term source of contamination; (3) the complex
stratigraphy of the alluvial aquifer presents intrinsic difficulties to remediation due to low permeability zones intermixed with higher
permeability zones; and (4) the proximity of the Cedar River, which is hydraulically connected to the alluvial aquifer, would reduce
contaminant mass removal rates of P&T due to infiltration of river water. Even with the most promising technologies, cleanup would require
more than 35,000 years to achieve aquifer restoration for recalcitrant PAHs (specifically benzo(a)pyrene) based on SourceDK Remediation
Timeframe Decision Support System estimates.
Conditions: NAPL (suspected or observed) - NAPL is currently suspected at the site. During source removal activities, NAPL was removed
from the site.
COCs - 8 metals, cyanide, BTEX, 9 PAHs
Concentration - Groundwater concentrations included in Tables of 3.9 and 3.10 of 2004 ROD.
Geology - Alluvial aquifer consists of alluvial and glacial outwash units consisting of finer-grained layers and coarser-grained
layers.
77 Zone - Horizontally, the TI Zone encompasses the estimated area of residual soil contamination and suspected NAPL based
on soil descriptions and groundwater concentrations exceeding 1 percent contaminant aqueous solubilities. Vertically, the TI
Zone encompasses the alluvial aquifer, which extends from the water table (approximately 15 feet bgs) to the top of bedrock
(varies between 40 and 65 feet bgs across the site). The bedrock aquifer is not included in the TI Zone.
Evaluation: Remedial Timeframe Estimate (years) - More than 35,000 years based on SourceDK Remediation Timeframe Decision Support
System estimates
Remedial Action Alternatives - The selected remedy includes MNA, groundwater monitoring for COCs and MNA parameters, a
TI waiver, and ICs, which will achieve remedial action objectives because (1) potential exposure will be controlled by ICs
(prohibiting installation of groundwater wells, restrictions on future land use, and engineering future structures to address
vapor intrusion unless sufficient testing demonstrates that vapor intrusion pathway will not present health risk); (2) previous
source removal actions have removed coal tar and coal tar-impacted materials and soils to a depth of 15 feet bgs to limit
further groundwater contamination and DNAPL migration; (3) the geologic/hydrogeologic setting minimizes the potential
for further contaminant migration; and (4) natural attenuation processes have stabilized the plume and are controlling its
migration.
Current Status/Activities: The original remedy selected in the 2004 ROD indicated ACLs would be established for this site. The 2006 BSD
selects a TI waiver in place of the ACLs. According to the site summary (June 2011), a restrictive covenant is in place that (1) prohibits the
installation of groundwater wells and residential use and (2) addresses potential for VI. Groundwater monitoring for COCs and MNA
parameters is ongoing (additional wells were installed in 2008).
August 2012
A-66
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Oronogo-Duenweg
Mining Belt
State: MO; OU: 4
Decision Doc. (Type &Date):
ROD, 7/29/98
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU4,
7/29/98,
www.epa. gov/superfund/sites/rods/
fulltext/r0798026.pdf: (2) Site
summary,
www.epa. gov/region7/cleanup/npl
files/mod980686281 .pdf
TIDecision: The following ARARs are being waived: cadmium and nickel (MCLs); manganese (secondary drinking water standard); and
lead (action level under SDWA).
Rationale: Groundwater flow in the shallow aquifer occurs primarily in the fractured breccia zones and secondary openings created by both
the dissolutioning of the bedrock formations and underground mining. Sampling and analysis conducted during site investigations have shown
that distribution of metals in the shallow groundwater is extremely sporadic. Action level exceedance of metals in individual wells is
dependent on the interception of fracture zones connected to contaminant sources; residual mineral deposits left in the mine openings are now
in contact with oxygenated groundwater which contributes to metals leaching and further contamination of the groundwater. This condition
prohibits effective cleanup by conventional groundwater P&T systems to restore the aquifer for safe drinking water use. EPA has determined
that design of a groundwater recovery system and placement of pumping wells to intercept all fractures and openings conducting contaminated
groundwater would be nearly impossible. The TI determination is based on the technical difficulty, as well as, the inordinate cost to attain the
ARARs for the protection of human health. However, limited groundwater remediation may be conducted as part of a subsequent ROD to
address ecological risks created by groundwater contributions to surface water. After consideration of all the facts in combination with the size
and volume (nine million cubic yards) of mining wastes at the site, EPA considers remediation of site groundwater to be technically
impracticable based on inordinate costs from an engineering perspective.
Conditions: NAPL (suspected or observed) - DNAPL is not an issue at this site.
COCs - Metals
Concentration - Maximum concentrations in the shallow aquifer as of 1995 are as follows (in mg/L): cadmium-0.22; nickel-
0.13; manganese-6.88; and lead-0.29.
Geology - Shallow aquifer occurs primarily in the fractured breccia zones and secondary openings created by both the
dissolutioning of the bedrock formations and underground mining.
77 Zone - TI Zone is expected to cover the entire watershed within Jasper County (approximately 270 square miles). The TI
Zone includes only the shallow aquifer, which ranges in thickness from 300 to 400 feet.
Evaluation: Remedial Timeframe Estimate (years) - Not calculated (Note: There are no active groundwater remedies to remediate or clean
up the groundwater. EPA is relying on ICs and the provision of clean drinking water via rural water districts and pipeline
expansions - providing a safe source to consume but not remediating the groundwater.)
Remedial Action Alternatives - Alternate water supply included the expansion of an existing water supply system, which serves
as a permanent water source to affected residents. Using ICs to control risk.
Current Status/Activities: Based on the site summary (February 2010), the installation of public water supplies is complete. Residential
properties with soil contamination have been cleaned, and the remedial action for mining wastes is underway. ICs (county building ordinance
and state well restriction) are already in place.
August 2012
A-67
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Iowa City FMGP
State: IA; OU: I
Decision Doc. (Type &Date):
ROD, 9/26/06
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, 9/26/06,
www.epa. gov/superfund/sites/rods/
fulltext/r2006070002463.pdf: (21
FS Report, Appendix A - TI
Evaluation Report, 6/1/06, 8/2/06;
(3) Site summary,
www.epa. gov/region7/cleanup/npl
files/iad984591172.pdf
TI Decision: According to the TI Evaluation Report, the following ARARs are being waived: MCLs for cyanide, benzene, ethylbenzene,
toluene, xylenes, and benzo(a)pyrene. The TI Evaluation Report also determined that PQLs for benzo(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, dibenzo(a,h)anthracene, and indeno(l,2,3-cd)pyrene and Risk-Based Cleanup Levels for 2-methylnaphthalene,
acenaphthene, acenaphthylene, chrysene, fluorene, naphthalene, and phenanthrene could not be met.
Rationale: The following issues make it technically impracticable to achieve restoration through the Devonian and Silurian aquifers within a
reasonable timeframe: (1) approximately 92 percent of the estimated 40,200 pounds of contaminant mass remaining at the site consists of
PAHs; (2) approximately 93 percent of contaminant mass is present as NAPL, which will remain as a long-term source of contamination of
PAH and BTEX; (3) the complex fracture network present in the carbonate aquifer; and (4) further remediation in the source area is physically
limited by the presence of an apartment building on the property. Even with the most promising technologies, cleanup would require more than
21,900 years to achieve aquifer restoration for recalcitrant PAHs (specifically benzo(a)pyrene) based on SourceDK Remediation Timeframe
Decision Support System estimates.
Conditions: NAPL (suspected or observed) - DNAPL and LNAPL have been observed in multiple wells at the site. During source removal
activities, LNAPL was removed from the site.
COCs - 13 PAHs, cyanide, and BTEX
Concentration - Groundwater concentrations included in Table 7-3.6 ROD.
Geology - Alluvial aquifer consists of loess, alluvial and glacial outwash units consisting of finer-grained layers and coarser-
grained layers. The shallower Devonian bedrock is fractured dolomite. In the deeper bedrock zones, the bedrock is generally
vuggy and exhibits karst and paleokarst features including the identification of two large solution cavities.
77 Zone - Horizontally, the TI Zone encompasses the estimated area of residual soil contamination and suspected NAPL based
on soil descriptions, confirmed presence of NAPL, and groundwater concentrations exceeding 1 percent contaminant
aqueous solubilities. Vertically, the TI Zone encompasses the alluvial aquifer, which extends from the water table
(approximately 15 feet bgs) to the Devonian and Silurian bedrock aquifers.
Evaluation: Remedial Timeframe Estimate (years) - More than 21,000 years based on SourceDK Remediation Timeframe Decision Support
System estimates
Remedial Action Alternatives - In addition to the implementation of the TI waiver, the selected remedy included: (1)
implementation of ICs in the form of environmental covenants, county and city ordinances and state laws; (2) MNA of
groundwater; (3) sediment monitoring of the adjacent creek; (4) indoor air monitoring of the apartment building; and (5)
recovery of LNAPL in the unconsolidated aquifer.
Current Status/Activities: Site summary (November 2010) indicates the remedial action for the site, including LNAPL recovery, MNA,
establishing ICs (environmental covenant) and monitoring, are currently ongoing. A preliminary close-out report was completed in 2010.
August 2012
A-68
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Riverfront
State: MO
OUs: 4
Decision Doc. (Type &Date):
ROD, 3/26/09
Stage: Pre-construction
Media: Ground water
References: (1) ROD, 3/26/09,
www.epa. sov/superfund/sites/rods/
fulltext/r2009070002848.pdf; (2)
Site summary,
www.epa. sov/resion07/cleanup/np
1 files/mod98 1720246.pdf ; (3)
ROD, 5/13/11,
www.epa. sov/superfund/sites/rods/
fulltext/r201 1070003850.rjdf
TI-Relevant Information
TI Decision: ARARs waived are MCLs for PCE and TCE and non-zero MCLGs for cis-l,2-DCE and trans-l,2-DCE in the bedrock aquifer.
Rationale: A TI waiver is warranted because of the folio wing: (1) depth of contamination may extend more than 400 ftbgs; (2) detailed
fracture diameter, spacing, orientation, vertical extent, and connectivity within and between formations are unknown and cannot be accurately
determined because of the plume's size and depth, surface topography and residential area above the plume; (3) dissolved PCE may be present
in fractures and/or as DNAPL; and (4) the area above the plume is steep/rugged and a heavily developed residential area making it difficult to
find suitable locations for treatment and/or extraction wells. With the remediation of the contaminant source area, the contaminant levels in the
groundwater are expected to decrease over time to a level that is protective of human health.
Conditions: NAPL (suspected or observed) - Possible that PCE is present as DNAPL.
COCs - PCE; TCE; cis-l,2-DCE; trans-l,2-DCE
Concentration (maximum) PCE-9,100 ug/L; TCE-lOOug/L; cis-l,2-DCE-210ug/L; trans-l,2-DCE-30ug/L
Geology - Two aquifers are present at the site: Ozark aquifer (fractured bedrock) and Missouri River aquifer (alluvial).
77 Zone - TI zone is comprised of a block of fractured bedrock that is approximately 5,000 feet in length, between 2,000 and
4,500 feet wide, and between 20 and 450 feet deep. The zone includes the area of the PCE plume with concentrations above
its MCL (5 ug/L).
Evaluation: Remedial Timeframe Estimate (years) - 100 years
Remedial Action Alternatives — The 2009 ROD selects in situ chemical oxidation monitoring and ICs to address residual PCE
soil contamination at the site and ICs (well drilling restrictions) and monitoring for groundwater The source action will
minimize contaminants migrating into the groundwater. Highly contaminated soils were removed in 2007.
Current Status/Activities: According to the site summary (October 20 1 1), well drilling restrictions are already in place. The remedial design
has been proved for the remedy selected in the May 201 1 ROD. OU 6 includes limited residential drinking water contamination and continues
to be treated with whole house filtration systems.
August 2012
A-69
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: East Helena
State: MT; OU: 1
Decision Doc. (Type &Date):
ROD, 11/22/89
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU1,
11/22/89,
www.epa. sov/superfund/sites/rods/
fulltext/r0890027.pdf; (2) Five-
year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f2006080001359.rjdf: (3) Five-
year review, 2011,
ftp://ftp.epa.sov/r8/temp/EHelena
3FYR 092711.Ddf
TI-Relevant Information
Region 8: 9 sites (11 waivers)
TI Decision: State water quality standards are being waived for arsenic (0.0022 ug/L), cadmium (0.001 1 mg/L) and lead (0.0032 mg/L).
Standards for copper and zinc can be achieved.
Rationale: Lower Lake collected and stored process water from the plant and runoff from the site, resulting in metals contamination in the
lake and sediments. The selected remedy in 1989 included replacing the lake with storage tanks, constructing a lined pond for stormwater
runoff, treating the lake using in situ chemical treatment, and removing sediments. In 1993, an BSD implemented the contingent remedy of
P&T for Lower Lake and treatment continues. Arsenic, cadmium, and lead standards were waived because they could not be attained and/or
measured with available treatment and monitoring technologies; the selected standards were either equal to or lower than MCLs or other
standards.
Conditions: NAPL (suspected or observed) - NAPL not an issue.
COCs - Metals
Concentration — Concentrations from 1984-1987 (in ug/L)' arsenic— 19 900' lead— 5 110' and cadmium— 1 050
Geology - Lower Lake lies within the ancestral floodplain of Prickly Pear Creek. The channel and excavation into the alluvium
are composed of highly porous tertiary cobbles gravels and sediments The overbank areas of the floodplain are composed
of sands clays fine sediments and organic -rich deposits
77 Zone - 77 waiver applies to Lower Lake; however the extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Very long time
Remedial Action Alternatives - Continue P&T and excavate sediments
Current Status/Activities: Based on the 20 1 1 5-year review, completion of RCRA investigations and implementation of appropriate corrective
actions are needed to ensure protectiveness. State standards for arsenic and copper have been changed since the ROD, but no change to the
prescribed standards was recommended in the 5 -year review.
August 2012
A-70
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Whitewood Creek
State: SD; OU: I
Decision Doc. (Type &Date):
ROD, 3/30/90
Stage: Pre-construction
Media: Groundwater and surface
water
References: (1) ROD, OU1,
3/30/90,
www.epa. sov/superfund/sites/rods/
fulltext/r0890028.pdf; (2) Site
summary,
www.epa. sov/resion8/superfund/s
d/whitewood/index. html
TI-Relevant Information
TI Decision: The TI waives standards for arsenic in groundwater and surface water.
Rationale: Whitewood Creek would not achieve compliance with water quality criteria for the protection of human health from the
consumption of fish because upstream surface water exceeds this criterion. In addition, groundwater discharge and surface erosion and runoff
contribute additional arsenic to the creek. Due to the continued presence of mine tailings acting as a source of contamination, it will be
technically impracticable to restore groundwater at the site.
Conditions: NAPL (suspected or observed) - NAPL not an issue.
COCs - Arsenic
Concentration - Maximum concentrations of arsenic were 0.780 mg/L in groundwater and 0.20 mg/L in surface water.
Geology - The headwaters of Whitewood Creek originate in predominantly Precambrian granite and schist, which is the host
rock for gold ore. The bedrock lithology changes to thick-bedded limestone of Paleozoic age. Whitewood Creek passes over
limestone beds and across Mesozoic sedimentary rocks containing shale and gypsum, with some thin sandstone and
limestone beds.
77 Zone - TI waiver applies to alluvial groundwater and Whitewood Creek; however the extent of the TI zone is undefined in the
references reviewed.
Evaluation: Remedial Tirnefrarne Estimate (years) — Very long time
Remedial Action Alternatives - ICs with (1) covering of surface soils, (2) fencing of tailings, (3) partial soil cover of tailings, and
(4) removal of surface soils and tailings.
Current Status/Activities: The site summary (October 201 1) indicates ICs (zoning regulations and groundwater well restrictions) have been
implemented. This site was deleted from the NPL in 1996. The third 5-year review will be completed before August 2012.
August 2012
A-71
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Broderick Wood
Products
State: CO; OU: 2
Decision Doc. (Type &Date):
ROD, 3/24/92
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
3/24/92,
www.epa. sov/superfund/sites/rods/
fulltext/r0892057.Ddf: (2) Five-
year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f2006080001 189.pdf; (3) Five-
year review, 2011,
www.epa. sov/superfund/sites/fivev
ear/f201 1080004141.pdf
TI-Relevant Information
TI Decision: ARARs waived as part of the 1992 ROD include MCLs (lead-0.05 mg/L) and state standards for groundwater (cadmium-
0.01 mg/L; chromium-0.05 mg/L; benzene-1 ug/L).
Rationale: The Denver aquifer is made up of small lenses of permeable sandstones interbedded with near-impermeable claystone, which
significantly limits the ability of the P&T system. Due to these lenses, contaminated groundwater is confined to an area onsite.
Conditions: NAPL (suspected or observed) - Both LNAPL and DNAPL are present.
COCs - VOCs, SVOCs, metals, PAHs, dioxins, and furans (Table IB not available in online version of ROD)
Concentration - See Table 1 1 of 2006 5-year review for contaminant concentrations (text is unclear).
Geology - Small lenses of permeable sandstones interbedded with near-impermeable claystone.
77 Zone - TI waiver applies to the Denver aquifer; however the extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Very long time
Remedial Action Alternatives — ICs and monitoring are required for the Denver aquifer The surficial aquifer will be restored
using P&T and the lowest aquifer (Arapahoe aquifer) will be monitored and action taken if necessary
Current Status/Activities: Based on the 201 1 5-year review, P&T continues on a sporadic basis and monitoring has been discontinued because
of financial issues The P&T system should be operational full time for the site to be protective of human health and the environment The ICs
are currently in place (restricting soil activities the use of groundwater and installation of wells)' the environmental covenant was recorded in
February 2007.
August 2012
A-72
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Silver Bow
Creek/Butte Area
State: MT;
OU: 3 (Butte Mine Flooding)
Decision Doc. (Type &Date):
ROD, 9/29/94
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU3,
9/29/94,
www.epa. sov/superfund/sites/rods/
fulltext/r0894 102.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-08005.pdf; (3) Five-vear
review, 2011,
www.epa. sov/superfund/sites/fivev
ear/f2011080004074.rjdf
TI-Relevant Information
TI Decision: ARARs are waived for arsenic, cadmium, lead, copper, and sulfate (if a primary MCL is established for sulfate); these are the
only site-related groundwater contaminants that exceed ARARs.
Rationale: A TI is required because (1) the extremely large horizontal and vertical extent of the contamination problem — the sheer size of the
source, calculated to be 27 billion cubic yards — would leave an open pit about 62 times larger than the current Berkeley Pit, would eliminate
the historic city of Butte, and would have untold environmental consequences; (2) the potentially applicable remediation technologies are not
proven in conditions similar to this site, the volume of contaminated groundwater contained within the bedrock aquifer of the TI area is
approximately 125 billion gallons, implementation of P&T would cause a progressive deterioration of groundwater quality and reverse the
currently observable trends of improving bedrock groundwater quality by exposing more source material to oxygen, and injection of either
grout or acid neutralizing fluids is very uncertain due to the large extent of underground workings and the improbability of reaching all mine
workings; and (3) even if one of the potentially applicable technologies were used, the cost of remediation would be inordinately high ranging
from $9 billion to $462 billion, with the exception of inundation which will range between $27 and $213 million.
Conditions: NAPL (suspected or observed) — NAPL does not seem to be an issue
COCs Metals sulfate
Concentration - The maximum concentrations in 1991 were as follows (in ug/L): arsenic-726; cadmium-3.7; copper-129;
lead 7. 3; and sulfate 980,000.
Geology - Bedrock
TIZone - The TI Zone (which covers 6.75 square miles) includes the potential contaminated bedrock aquifer and encompasses
the area of underground mine workings The vertical extent of the TI Zone is defined by the elevation of the lowest
underground mine workings, which has been determined to be approximately 1,500 feet above mean sea level.
Evaluation: Remedial Timeframe Estimate (years) - Very long time (indefinite)
Remedial Action Alternatives - The selected remedy includes inundation, but ARARs will not be met.
Current Status/Activities: Based on the 201 1 5-year review, the treatment plant where mine discharge is treated and then recycled for mine
operations is operational; however, there have been several issues: the pH level of the effluent standard has not been met and the
supersaturation of gypsum can cause the TSS discharge to be above standards, which may lead to cadmium above standards. These problems
will all be addressed in the next 5 -year review period, as well as a more practical approach to analyzing radionuclides for compliance with
beta-photon emitter discharge criteria. Monitoring is ongoing and ICs have been implemented including land use access controls and
restriction of groundwater use.
August 2012
A-73
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Anaconda Co. Smelter
State: MT; OU: 4
Decision Doc. (Type &Date):
ROD, 9/29/98
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU4,
9/29/98,
www.epa. sov/superfund/sites/rods/
fulltext/r0898096.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-08003.pdf; (3) Five-year
review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f20 100800036 lO.odf
TI-Relevant Information
TI Decision: The TI waiver is for Montana Water Quality Standard for arsenic (18 ug/L).
Rationale: Groundwater contamination in the bedrock aquifers has likely occurred as a result of transport of arsenic via infiltration and deep
percolation of precipitation through contaminated soil. Due to this source and complex geology (fractured bedrock) it was determined that
groundwater quality could not be restored in the bedrock aquifers at this site.
Conditions: NAPL (suspected or observed) - NAPL is not an issue at this site
COCs - Arsenic
Concentration - Dissolved arsenic concentrations ranged from 2.7-1,990 ug/L in the Smelter Hill TI Zone and from 17.4-414
ug/L in the Mt. Haggin zone. Concentrations were greater than 100 ug/L in some areas of Stucky Ridge.
Geology - Fractured bedrock
77 Zone — Area includes 3 TI Zones for more than 28 600 acres total' Stucky Ridge (4 77 1 acres) Smelter Hill (5 872 acres)
and Mount Haggin (17,956 acres). TI Zone is for the bedrock aquifers with a maximum depth of 250 ft bgs.
Evaluation: Remedial Timeframe Estimate (years) - Very long time
Remedial Action Alternatives Removal capping reclamation andMNA
Current Status/Activities: Based on the 20 10 5-year review, the development of a final vegetation cover design for Milltown sediments, the
removal of all Yellow Ditch material and resolution of the Georgetown railroad grade must be completed. Natural attenuation was selected for
groundwater (at Regional Water, Waste, and Soils OU), but is being re-evaluated because of a new arsenic standard. ICs were selected but a
final plan is not yet complete. A ROD modification was issued in September 201 1 that expanded the TI zone and added surface water
(according to the NPL fact sheet). A separate TI waiver summary has been prepared for the 20 1 1 ROD Amendment and is included below on
page 76.
August 2012
A-74
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Summitville Mine
State: CO; OU: 5
Decision Doc. (Type &Date):
ROD, 9/28/01
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU5,
9/28/01,
www.epa. sov/superfund/sites/rods/
fulltext/r0801538.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/fivev
ear/f05-08006.pdf; , (3) Five-year
review, 2010,
www.epa. sov/superfund/sites/fivev
ear/f2010080003754.rjdf
TI-Relevant Information
TI Decision: Use classifications will be waived for two segments of the Alamosa River (agricultural use in Segment 6 and Class I - Cold
Water in Segment 3B). Associated standards being waived are 200 ug/L for manganese in Segment 6 and 750 ug/L for aluminum and 12,000
ug/L for iron in Segment 3B.
Rationale: Certain state standards and use classifications for Alamosa River Segments 3B and 6 are being waived because of technical
impracticability. Metals upstream of these two segments are naturally occurring and not a result of mining related activities in the area.
Conditions: NAPL (suspected or observed) - NAPL is not an issue.
COCs - Metals
Concentration - Concentrations were estimated to be as high as 1,330 ug/L for aluminum in Segment 6. Maximum
concentrations upgradient of Segment 3B were 8,070 ug/L for aluminum and 180,030 ug/L for iron.
Geology - Wide-spread naturally -occurring mineralized zones within headwater basins of Alamosa River.
77 Zone - TI waiver applies to Segments 6 and 3B of the Alamosa River; however the extent of the TI zone is undefined in the
references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Very long time
Remedial Action Alternatives — The selected remedy for this OU was to contain and treat acid mine drainage prior to discharge'
ICs were not associated with this remedy.
Current Status/Activities' Based on the 2010 5-year review treatment is being conducted at OU5 but the water treatment plant is not large
drainage and a mine pool management system.
August 2012
A-75
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Milltown Reservoir
Sediments
State: MT; OU: 3
Decision Doc. (Type &Date):
ROD, 4/29/04
Stage: Pre-construction
Media: Surface water
References: (1) ROD, OU3,
4/29/04,
www.epa. sov/resion8/superfund/m
t/milltown/mrsrod.html; (2) ROD
fact sheet,
www.epa. sov/resion8/superfund/m
t/milltown/pdf/mrsRODfs.pdf; (3)
Site summary,
www.epa. sov/resion8/superfund/m
Itown/
TI-Relevant Information
TI Decision: The state water quality standard for copper is being waived and replaced with the federal water quality criteria.
Rationale: Current modeling projections indicate that none of the alternatives proposed, including total removal of all exposed and buried
tailings, would achieve complete compliance with the state standard. Additionally, violations of the copper standard occur upstream due to
other non site-related mining activities.
Conditions: NAPL (suspected or observed) - NAPL not an issue.
COCs - Copper
Concentration - From 1991 to 1997, dissolved copper concentrations ranged from 2 to 20 ug/L.
Geology - River valley alluvium with vertical and lateral sand, gravel, boulders, and some clay lenses. Anoxic conditions
beneath reservoir sediments.
77 Zone - TI waiver applies to the Clark Fork River; however the extent of the TI zone is undefined in the references reviewed.
Evaluation ' Remedial Time frame Estimate (years) Very long time
Remedial Action Alternatives The selected remedy in the 2004 ROD includes temporary ICs until the aquifer is restored using
MNA for groundwater, which is expected to take 4 to 10 years after dam and sediment removal. ICs include zoning
regulations, deed restrictions, and limitations on groundwater use.
Current Status/Activities: An alternate water supply (including replacement or retrofitting of domestic wells) has been provided as necessary.
The site summary (October 201 1) indicates OU3 will be addressed in a 5-year review planned for 2015. In 2010, the Clark Fork River was
diverted to a new channel through the site. No additional updates were available in the information sources reviewed.
August 2012
A-76
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Silver Bow
Creek/Butte Area
State: MT
OUs: 08
Decision Doc. (Type &Date):
ROD, 9/2006
Stage: Post-construction
Media: Ground water
References: (1) ROD, OU 8,
9/2006; (2) Final Technical
Memorandum. TI Evaluation for
Alluvial Groundwater, 2/2006; (3)
Five-year review, 201 1,
www.epa. sov/resion8/superfund/m
t/milltown/
TI-Relevant Information
TI Decision: ARARs waiver of MCLs for COCs include arsenic, cadmium, copper, lead, mercury, and zinc in groundwater for the alluvial
aquifer underlying the identified TI zone within the BPSOU.
Rationale: Based on conclusions presented in the TI evaluation, EPA has determined that the water quality in the BPSOU alluvial aquifer
cannot be improved by remedial action within a reasonable time frame even assuming implementation of the most extensive and costly mine
waste removal alternatives. The most aggressive alternative included complete removal of the source area with an estimated cost of $189
million, but many diffuse sources would remain. Even with complete source removal and groundwater capture, the TI evaluation concluded
that the groundwater would not attain ARARs within a reasonable time due to slow desorption kinetics in the aquifer.
Conditions: NAPL (suspected or observed) - NAPL does not seem to be an issue
COCs - Metals
Concentration - Copper: 2,100 mg/L; Cadmium 3.5 mg/L, Zinc: 2,275 mg/L; Lead 1.3 mg/L
Geology - Alluvial
77 Zone - The TI zone generally extends from the Parrot tailings area to the groundwater capture system at Lower Area One
within the area where groundwater exceeds ARARs for metals. The area is approximately 871 acres. The depth of the TI
zone is the full thickness of the alluvial aquifer which is highly variable but extends to 268 feet below ground surface in one
well.
years and likely greater than 300 years even with extensive source removal. This is due to slow kinetics of desorption of
metals from contaminated aquifer materials.
Remedial Action Alternatives - Groundwater capture and treatment has been operational since 1998 at the downgradient edge of
the plume and since 2005 in the middle of the plume and will be continued in perpetuity.
Current Status/Activities: Based on the 201 1 5 -year review, a groundwater monitoring plan (with additional monitoring wells) is being
prepared to ensure groundwater is not leaving the TI zone. ICs are being established to prevent residential use of groundwater, but are not yet
in place. Groundwater collection and treatment has been operational since 1998 and refinement of the system is ongoing.
August 2012
A-77
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Libby Groundwater
Contamination
State: MT; OUs: 2
Decision Doc. (Type &Date):
BSD, 9/14/93
Stage: Pre-construction
Media: Groundwater
References: (1) BSD, OU 2,
9/14/93,
www.epa. gov/superfund/sites/rods/
fulltext/e0893 500.pdf: (2) 5-year
review, 3/30/00,
www.epa. gov/superfund/sites/fivev
ear/fOO-08006.pdf: (3) Five-year
review, 2010,
www.epa. gov/superfund/sites/fivev
ear/f2010080003364.pdf
TIDecision: The following ARAR requirements are waived in the Lower Aquifer: (1) reduction of PCP, chrysene, and benzo(a)anthracene
concentrations below their primary MCLs of 1 ug/L, 0.2 ug/L, and 0.1 ug/L, respectively and (2) reduction of naphthalene concentrations
below EPA's lifetime health advisory limit of 20 ug/L.
Rationale: The initial remedy for the Lower Aquifer selected in the 1988 ROD consisted of feasibility testing of biorestoration remedial
technologies, both alone and in conjunction with oil recovery and oil dispersion techniques. Bench-scale studies and additional investigations
were conducted, and it was determined that remediation of DNAPL contamination using P&T or in situ bioremediation was technically
impracticable in a cost-effective and timely manner. In addition, use of oil dispersion techniques (such as surfactants) could potentially result
in greater risk to human health and the environment than currently exists or would exist in the future. The following additional conclusions
were also noted: (1) the dissolved contaminant plumes have apparently stabilized, consequently there is no need for migration control of the
dissolved phase plumes in the Lower Aquifer; (2) a small potential for cross-contamination of the Upper Aquifer could exist in an area of the
Lower Aquifer plume where a natural upward gradient appears to occur; however, the estimated upward flux does not result in contaminant
concentrations that exceed MCLs for drinking water; (3) potential for either the dissolved contaminant plumes or DNAPL to reach the
Kootenai River is low; (4) although direct ingestion and dermal contact with dissolved contaminants would result in an unacceptable excess
cancer risk, institutional controls are in place, eliminating the only potential pathway of concern.
Conditions: NAPL (suspected or observed) - NAPL is present in the Lower Aquifer.
COCs - COCs for the Lower Aquifer include PAHs and PCP. Tables are provided in the ROD but not included in the online
version.
Concentration - Tables are provided in the ROD but not included in the online version.
Geology - The Lower Aquifer ranges in depth from 100 to 160 feet bgs and is separated from the Upper Aquifer by a relatively
low permeability layer (35 feet thick) that may not be laterally continuous across the entire site.
77 Zone - TI zone includes the Lower Aquifer; however the lateral extent of the TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - Due to the presence of NAPL in the Lower Aquifer, it is unlikely that ARARs could be
met within a reasonable timeframe.
Remedial Action Alternatives - The remedy for the Lower Aquifer consists of institutional controls prohibiting installation of
new water supply wells and groundwater monitoring.
Current Status/Activities: An alternate water supply has been provided to residents whose domestic wells were influenced or potentially
influenced by off-site migration of the contaminant plumes in the Upper Aquifer. According to the 2010 5-year review, as a result of drought
conditions, some residents have installed new wells or are using sealed wells. ICs that prohibit the installation of new water supply wells are in
place, but some of the affected area is not within the City of Libby, and is not subject to the well drilling restriction. A P&T system consisting
of an oil/water separator, biological treatment and an oxygen injection system have been used to address contamination in the Upper Aquifer;
however the oxygen injection system was discontinued in 2003. An additional investigation continues to evaluate the effectiveness of the
remedial strategy in the Upper Aquifer and to better define the extent of the Controlled Groundwater Area because it appears groundwater
P&T with biological treatment may not be remediating the source zone and PCP plume. Land treatment units were used to address
contaminated soil at the site. Both the soil and groundwater cleanup levels have become more stringent, which has led to doubts in the
performance of both media's selected remedy. The VI pathway and presence of 1,4-dioxane in groundwater warrant additional data collection.
August 2012
A-78
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: California Gulch
State: CO
OUs: 12
Decision Doc. (Type &Date):
ROD, 9/22/09
Stage: Pre-construction
Media: Ground water
References: (1) ROD, 9/22/09,
www.epa. sov/superfund/sites/rods/
fulltext/r2009080003087.pdf; (2)
Site summary,
www.epa. sov/resion8/superfund/c
o/calsulch/index. html
TI-Relevant Information
TI Decision: ARARs waived are MCLs for cadmium and lead in the shallow aquifer. There are no current exceedances of the arsenic MCL.
Rationale: TI waiver for lead and cadmium in the shallow aquifer is necessary because of (1) the amount of waste remaining in place at the
site, (2) the free exchange of metal-impacted surface water and alluvial groundwater, and (3) the presence of widespread disturbed and
saturated alluvium in Lower California Gulch (and elsewhere in the Site) acting as a low-grade reservoir of metals with the potential to desorb
or otherwise be mobilized into alluvial groundwater.
Conditions: NAPL (suspected or observed) - NAPL is not an issue.
COCs - Metals (cadmium, lead, arsenic)
Concentration - Table 6-1 is not provided in copy of ROD.
Geology - The 1994 CD restricts OU12 to the shallow alluvial aquifer not to exceed a depth of 250 feet or contact with
bedrock, whichever is the lesser depth below the ground surface. The alluvial aquifer is largely contiguous and primarily
under unconfined conditions although perched groundwater can occur locally. Depth to groundwater varies from less than
one foot to approximately 250 feet, and saturated thickness ranges from 0 to over 500 feet in the alluvial aquifer above the
bedrock contact. Throughout much of the Site, bedrock is overlain by unconsolidated glacial deposits up to 1,000 feet thick
derived from various types of lithologies in the Mosquito Range including porphyry, rhyolite, granite, quartzite, dolomite,
limestone and sandstone. Sediments are poorly sorted, loose and porous and were transported and deposited by glacial and
fluvial processes.
TIZone - TI zone applies to the shallow alluvium of Stray Horse, California, and Oregon gulches, as well as a portion of the
Arkansas Valley floodplain. [please confirm - obtain TI Evaluation report]
Evaluation: Remedial Timeframe Estimate (years) - Not provided
Remedial Action Alternatives - The selected remedy includes ICs to restrict the use of alluvial groundwater for human
consumption and groundwater monitoring to provide protectiveness.
Current Status/Activities: According to the site summary (September 20 1 1), EPA has conducted partial deletions for OUs 2, 8, 9, and 10 . ICs
are either in development or have been implemented at multiple OUs on site.
August 2012
A-79
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Anaconda Co. Smelter
State: MT; OU: 4
Decision Doc. (Type &Date):
ROD Amendment, 9/29/11
Stage: Post-Construction
Media: Groundwater and surface
water
References: (1) ROD Amendment,
OU 4, 9/29/11,
www.epa. gov/regionS/superfund/m
t/anaconda/Anaconda OU4RODA
mendment0911.pdf: (2) Site
Summary, November 2011,
www.epa. gov/region8/superfund/m
t/anaconda/index.html: (3) Five-
year review, 9/30/10,
www.epa. gov/superfund/sites/fivev
ear/f2010080003610.pdf
TIDecision: Human health standard (10 ng/L) is being waived for arsenic in groundwater and surface waters, which has resulted in new and
expanded TI zones for this site.
Rationale: In addition to the expansion of the bedrock aquifer TI zone boundaries, a waiver of the arsenic human health standard have been
identified for alluvial aquifers in the North Opportunity and South Opportunity areas.
Although this ROD Amendment requires more source control measures (e.g., removal of miscellaneous wastes and reclamation of
contaminated soils) than the 1998 Selected Remedy, TI evaluations have concluded that the human health arsenic standard will not be achieved
within a reasonable period of time within the areas. A domestic well monitoring and replacement plan has been developed to ensure that
domestic well users within or adjacent to these TI zones will have drinking water that, at a minimum, meets human health standards. The
arsenic human health standard for surface water is waived to the chronic and acute aquatic life federal and state standards of 150 and 340 ug/L,
respectively, within the surface water TI zone. These surface waters have been impacted by groundwater discharges from the bedrock TI zone.
North Opportunity Area - The arsenic standard is waived for the uppermost portion of the shallow unconfined alluvial aquifer within the
North Opportunity Ground Water/Surface Water Area of Concern, where shallow groundwater interacts with arsenic-contaminated soils. The
source of arsenic contamination in groundwater is the combination of contaminated soil and saturated conditions. The restrictions on RAs due
to its wetland characteristics limit any actions that will significantly disturb the soil or hydrologic conditions. Additionally, the geochemical
conditions necessary for natural attenuation are not present. Since no actions are available which will remove the source or disrupt the
transport pathway, any groundwater within or entering the North Opportunity AOC will remain or become contaminated with arsenic. Even if
groundwater is withdrawn for treatment, the recharge water will become contaminated.
The North Opportunity TI Zone extends from the edge of the valley bottom along the north side of Lost Creek to Warm Springs Creek on the
south and from the 5000 foot elevation contour on the west to the OU 4 boundary on the east. The downgradient/downstream limits of the TI
Zone extend to the OU boundary where the surface and groundwater flow into the Clark Fork River OU. The TI Zone applies to all surface
water within the TI Zone. The TI zone also applies to groundwater within 10 feet of the water table. On this basis, the North Opportunity TI
Analysis concludes that it is technically impracticable from an engineering perspective to reduce arsenic concentrations below 10 ug/L in
groundwater within the North Opportunity AOC. The TI zone generally extends from the Anaconda Airport to the Clark Fork River OU
boundary and from Warm Springs Creek to Lost Creek.
South Opportunity Area - The arsenic human health standard is waived for certain surface water and groundwater within the South
Opportunity Area of Concern. None of the alternatives evaluated is capable of achieving the human health standard for arsenic with certainty.
The source of arsenic contamination in groundwater is the combination of contaminated soil and saturated conditions. The previous RAs of
reducing irrigation and allowing natural attenuation to work for eleven years has not resulted in significant progress toward meeting the
groundwater ARAR. Additional RAs which would control the source through removal action or changing the hydrologic conditions are
difficult to implement because much of the area of concern is a jurisdictional wetland. Additionally, the geochemical conditions necessary for
natural attenuation are not present. Since no actions are available which will entirely remove the source or disrupt the transport pathway, any
groundwater within or entering the South Opportunity Area of Concern will remain or become contaminated with arsenic. Even if groundwater
is withdrawn for treatment, the recharge water will become contaminated. Because the contaminated South Opportunity TI zone groundwater
discharges to surface water (Willow Creek), movement of the plume is hydraulically controlled. The source of arsenic in surface water is gains
from groundwater via small tributaries and drain tiles, and upstream source within the bedrock TI zone. It has been determined to be
technically impracticable to remediate the groundwater to the arsenic human health standard throughout the South Opportunity Area of
Concern, and a previous determination has concluded that it is technically impracticable to remediate the upstream source.
The TI zone generally includes the valley bottom land located within an area bounded by Mill Creek or Highway 1 to the north, the Streamside
August 2012
A-80
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Tailings OU to the east, the Silver Bow County line to the south, and uplands associated with the Mount Haggin WMA (also the bedrock TI
zone) to the west. Downgradient movement of the plume is hydraulically controlled by discharge into surface water either along Willow Creek
or drain tiles. Because of the connection between the extent of wetlands and groundwater contamination, wetlands on the north side of
Highway 1 are included in the TI zone. The surface water TI zone includes all surface water within the groundwater TI zone plus all surface
water exiting the bedrock TI zone to the confluence of Mill Creek and Willow Creek.
Bedrock Aquifer - Additional data collected for the bedrock aquifer have resulted in an expansion of its TI zone. The primary changes to all
three previous TI Zones include:
-The bedrock aquifer beneath the alluvial aquifer in the valleys has been added to the bedrock TI zone resulting in merging of the previous
three TI zones into a single bedrock TI zone;
-The California Creek area has been added based on new spring and surface water data;
-The area from Lost Creek to Modesty Creek has been added based on surface water data and limited spring data;
-The western boundary near Anaconda has been expanded slightly based on data collected from domestic wells; and
-Boundaries with waste management areas are adjusted based on changes to the WMA boundaries
The bedrock TI zone now includes 63,515 acres or 99 square miles, approximately double the area delineated in the ROD. The depth of the
bedrock TI zone remains unchanged at 250 feet below ground surface.
Spring-fed Tributaries - The Montana surface water human health standard and federal MCL for arsenic are waived in the spring-fed
tributaries. These spring-fed tributaries are discharges of bedrock groundwater, which has already been addressed under the bedrock TI
evaluation. Since the groundwater source will not be mitigated, surface water in spring-fed tributaries will remain impacted by arsenic within
the reaches affected by gaining groundwater. It was determined to be technically impracticable from an engineering perspective to reduce
arsenic concentration in spring-fed tributaries of Willow, Mill, California, and Modesty Creeks as well as intermittent flow tributaries below
10 ug/L in surface water within the bedrock TI zone. The TI waiver addresses all surface water bodies with the Bedrock Aquifer TI Zones and
extends to the mouths of these surface water bodies or the downstream end of the OU.
Conditions: NAPL (suspected or observed) - NAPL is not an issue at this site.
COCs -Arsenic
Concentration - In Willow Creek (South Opportunity area), arsenic concentrations ranged from 11 to 164 ug/L in the
mainstream and from 28 to 307 ug/L in small tributaries. Arsenic concentrations at the top of the aquifer approach 150 ug/L
over a large area of South Opportunity. Additional recent data was not available in the documents reviewed.
Geology - Fractured bedrock
77 Zone - TI waiver applies to the shallow groundwater at the North and South Opportunity areas (from the water table to 10
feet below the water table), expands upon the existing TI zone in the bedrock aquifer, and includes surface waters within the
TI zones.
Evaluation: Remedial Timeframe Estimate (years) - Not provided in the ROD Amendment.
Remedial Action Alternatives - ICs were selected to minimize exposure to groundwater and surface waters located within the TI
zones. A domestic well monitoring and replacement program will be implemented to ensure that nearby residents are
provided appropriate drinking water. Long-term monitoring was also selected. Additional source removal was also selected
for the South Opportunity area.
Current Status/Activities: According to the 2010 5-year review, site-wide activities such as ICs, monitoring and maintenance, and
groundwater and surface water remedies are ongoing. Construction is also ongoing at 3 areas (OU 4, 7, and 16).
August 2012
A-81
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Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Region 9: 9 sites
Site Name: Westinghouse Electric
Corp (Sunnyvale Plant)
State: CA;OU: 1
Decision Doc. (Type &Date):
ROD, 10/16/91
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU1,
10/16/91,
www.epa. sov/superfund/sites/rods/
fulltext/r0992079.pdf; (2) Five-
year review, 2006,
www.epa. sov/superfund/sites/fivev
ear/f2006090001097.Ddf: (3) Five-
year review, 9/29/1 1,
www.epa. sov/superfund/sites/fivev
ear/f201 1090004165.pdf
TI Decision: MCLs are being waived for PCBs.
Rationale: A TI waiver is justified based on the following: (1) the presence of spatially discontinuous DNAPL PCB in significant amounts;
(2) the heterogeneity of the subsurface combined with low permeabilities; and (3) the characteristics of PCBs, including low solubility, high
tendency to partition onto organic materials, and high viscosity.
Conditions: NAPL (suspected or observed) - DNAPL has been observed in the A and B aquifers and
COCs-PCBs
Concentration - Concentration of PCBs in the A aquifer was not available.
Geology - Low permeability soils
77 Zone - TI Zone includes aquifer A in the source area.
Evaluation: Remedial Timeframe Estimate (years) - An assessment was not done.
PCBs in the source area, ICs, and monitoring. Source removal and incineration were
Current Status/Activities: According to the 201 1 5-year review, P&T continues and ICs have not been
at the A/B aquitard.
r contaminants and for containment of
also selected.
implemented yet.
August 2012
A-82
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Schofield Barracks
State: HI; OU: 2
Decision Doc. (Type & Date):
ROD, 2/7/97
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU2,
2/7/97,
www.epa. sov/superfund/sites/rods/
fulltext/r0997032.Ddf: (2)
Justification for TI Waiver, 2/7/97;
(3) Five-year review, 2002,
www.epa. sov/superfund/sites/fivev
ear/f02-09007.rjdf: (4) Site
summary,
www.vosemite.epa.gov/r9/sfund/r9sf
docw.nsf/3dec8ba325236842882574
260074373 3/1 8 1 8fba24 1 43 1 Odc882
57007005e9452!OpenDocument
TI-Relevant Information
TI Decision: MCLs are waived for carbon tetrachloride and TCE.
Rationale: The Justification for TI Waiver states "Remediating the aquifer to MCLs is not feasible because of the depth (500 to 700 feet),
thickness (greater than 2,000 feet), and fractured lava characteristics of the aquifer, and the large size and age of the plume. The plume is
contained through a combination of P&T of 4 mgd at supply wells, geologic barriers, and natural attenuation. Treatment at the source is not
possible because of the geology of the site and the nature of DNAPLs. The geology at the site is complex fractured basalt and there is extreme
heterogeneity. Additionally, the high transmissivity (about 900,000 feet/day) and the associated high volume of water flowing through the
system would require tremendous P&T capacity to contain the plume estimated at 150 mgd (based on FEMWATER modeling). A P&T system
of this capacity would cost about $350 million. The plume migrating off -base has concentrations less than 15 ppb, which poses a risk of IxlO"5
to 10"6; therefore, removal of residual DNAPL would not provide a significant reduction in risk. Risk is controlled through wellhead treatment
(air stripping) for VOCs at all affected water supply wells.
Conditions: NAPL (suspected or observed) - Residual DNAPL is likely present.
COCs - Carbon tetrachloride and TCE
Concentration - Influent concentrations at the production wells were observed at 8.2 ug/L for carbon tetrachloride and 25 ug/L
for TCE.
Geology - The geology at the site is complex fractured basalt and there is extreme heterogeneity with a high transmissivity
(about 900,000 ft/day).
77 Zone - The entire plume above MCLs; however the extent of the TI zone is undefined in the references reviewed.
remediate and there is not enough power on the island to operate the required number of pumps.
Current Status/Activities: Based on the site summary and the 2002 5 -year review report, well-head treatment was added to nearby production
wells, and ICs (land and groundwater use restrictions) are in place at OU4 (ICs were not mentioned for OU2) .
August 2012
A-83
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Tucson International
Airport Area
State: AZ;OU: 2
Decision Doc. (Type & Date):
ROD, 9/30/97
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU2,
9/30/97,
www.epa. sov/superfund/sites/rods/
fulltext/r0997137.Ddf: (2) Final FS.
Appendix B, June 1997; (3) Site
summary,
www.vosemite.epa.sov/r9/sfund/r9
sfdocw.nsf/3dec8ba325236842882
5742600743733/edd9fbcl53 Ia93b
788257007005e9467 lOpenDocum
ent
TI-Relevant Information
TI Decision: MCLs are being waived for contaminants in the TI Zone, including TCE; PCE; 1,1-DCE; benzene; chloroform; 1,2-DCP; and
methylene chloride.
Rationale: A TI waiver is justified for the Airport Property area of the site because the VOCs are present in low permeability clays and there
are significant heterogeneous conditions within the vadose and shallow groundwater zones, making contaminant removal difficult. In addition,
there are no remedial technologies available to remove all trapped DNAPL. There is indirect evidence of DNAPL at depths greater than 1 10
feet bgs in the gravel unit. Complete restoration of the TI Zone is unlikely because remedial technologies can only reduce the DNAPL mass,
not eliminate it.
Conditions: NAPL (suspected or observed) - DNAPL is likely present as TCE, which has been detected at concentrations almost 10 times
greater than its solubility limit.
COCs - 8 VOCs, 2 metals, nitrate, and di(2-ethylhexyl)phthalate
Concentration - Maximum TCE concentration was 74,000 ug/L in the shallow groundwater.
Geology - Clays, gravel
77 Zone - The TI Zone covers 2 acres and includes the shallow groundwater zone extending to 180 feet bgs (5 feet below the
Unit 4 gravel subunit). The Regional Aquifer is not included.
Evaluation: Remedial Timeframe Estimate (years) — Assessment not done
Remedial Action Alternatives — The selected remedy includes P&T to restore groundwater outside the TI Zone and to contain
contamination within the TI Zone and ICs (groundwater use restrictions) SVE removal and on-site containment were
selected for site soils
Current Status/Activities: Based on the site summary, P&T construction at this area began in early 2007.
August 2012
A-84
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Del Norte Pesticide
Storage
State: CA; OU: I
Decision Doc. (Type & Date):
ROD Amendment, 8/29/00
Stage: Post-construction
Media: Ground water
References: (1) ROD Amendment,
OU1, 8/29/00,
www.epa. sov/superfund/sites/rods/
fulltext/a0900113.Ddf: (2) Site
summary,
vosemite.epa. sov/r9/sfund/r9sfdoc
w.nsf/3dec8ba3252368428825742
600743733/17e2c218855f66ce882
57007005e9406!OpenDocument
TI-Relevant Information
TI Decision: The MCL for 1,2-DCP (5 ug/L) is being waived due to TI. This Amendment changed the cleanup goal from 10 ug/L to 5 ug/L
for 1,2-DCP and then waived the newly identified cleanup goal.
Rationale: Following source removal actions in 1987 and P&T operation from 1990 to 1994, 1,2-DCP concentrations decreased (from 2,000
ug/L) to asymptotic levels (15-40 ug/L). The P&T system has been shut off since 1997 and concentrations continue to decline very slowly (at
the same rate as when the system was operating prior to shut down). Air sparging was added in 1994 but no discernable changes to
concentrations were observed. It was determined that the cleanup levels of 1,2-DCP cannot be reached through engineering means or natural
attenuation. It is not known if the source of the 1,2-DCP is a NAPL or not.
Conditions: NAPL (suspected or observed) - NAPL - residual 1,2-DCP is acting as a NAPL.
COCs- 1,2-DCP
Concentration - 1,2-DCP concentrations decreased from approximately 2,000 to 600 ug/L following the source removal action.
Geology - Low permeability soils, sea terrace, fluctuating water table.
77 Zone - Area of TI Zone applies to the current area! and vertical extent of the contaminant plume with concentrations above 5
ug/L (approx. 5,000 square feet) and to the depth of the uppermost aquifer (30 feet bgs).
Evaluation: Remedial Timeframe Estimate (years) — Assessment not done
Remedial Action Alternatives - Evaluated removal, P&T, and air sparging.
Current Status/Activities' Based on the site summary P&T is shutdown The site was deleted from the NPL in 2002 EPA continues to
approaching the 5 ug/L level.
August 2012
A-85
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: J.H. Baxter & Co.
State: CA; OU: I
Decision Doc. (Type & Date):
ROD Amendment, 3/27/98
Stage: Pre-construction
Media: Ground water
References: (1) ROD Amendment,
OU1, 3/27/98,
www.epa. sov/superfund/sites/rods/
fulltext/a0998033.Ddf: (2) Final
Focused FS and Evaluation of TI,
May 1997; (3) Five-year review,
2005,
www.epa. sov/superfund/sites/fivev
ear/f05-090 17.pdf ; (4) Five-year
review, 9/30/10,
www.epa. sov/superfund/sites/fivev
ear/f2010090003624.rjdf
TI-Relevant Information
TI Decision: Cleanup standards that are being waived include (in ug/L): arsenic-5; chromium-8; copper-1 1; zinc-90; benzene-1;
pentachlorophenol-1; tetrachlorophenol-1,100; carcinogenic PAHs-5; non-carcinogenic PAHs-5; and dioxins-0. 000025.
Rationale: A number of alternatives were evaluated; however, even if only 5 percent of the DNAPL -contaminated soil remains after complete
excavation or in situ treatments, achievement of cleanup goals for non-chlorinated PAHs would take at least 3,000 and 400 years, respectively
(and achievement of cleanup goals for chlorinated PAHs would take even longer). The lower aquifer is not currently impacted by DNAPL and
it is likely that the aquitard separating the two aquifers will continue to protect the lower aquifer. No groundwater remediation will be
conducted for the DNAPL zone, because although it is technically feasible to address the non-PAH contaminants in the upper aquifer, the
PAHs remaining in the aquifer would still result in an unacceptable risk.
Conditions: NAPL (suspected or observed) - Free-phase and residual DNAPL have been observed.
COCs - 4 metals; benzene; 2 organic pesticides; carcinogenic PAHs; non-carcinogenic PAHs; dioxins
Concentration — Maximum concentrations prior to the ROD (1990) in ppb' arsenic— 1 740' chromium— 122' copper— 37 100'
zinc-23,000; pentachlorophenol-210; carcinogenic PAHs-6,000; non-carcinogenic PAHs-251,800; benzene-170; dioxins-
13.
Geology - Two aquifers separated by an aquitard.
77 Zone - TI Zone includes the area interpreted to contain DNAPLs with a vertical extent from the water table of the upper
aquifer down to the aquitard. The lower aquifer is not included.
Evaluation: Remedial Timeframe Estimate (years) - At least 3,000 years
Remedial Action Alternatives The amended remedy includes a slurry wall for groundwater containment (along with pumping
inside the wall to create an inward gradient) source containment and treatment and ICs Groundwater contamination
outside of the DNAPL zone will be addressed by P&T.
Current Status/Activities: According to the 2010 5-year review, the slurry wall and associated extraction system were installed in 1999 and
continue to function. ICs (restrictive covenants) have been filed with the country recorder to limit site access, restrict land and groundwater
use, provide notices, and prohibit activities that could cause potential threat to human health or the environment.
August 2012
A-86
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Del Amo
State: CA; OU: 3
Decision Doc. (Type & Date):
ROD, 3/30/99
Stage: Pre-construction
Media: Groundwater
References: (1) ROD, OU3,
3/30/99,
www.epa. sov/superfund/sites/rods/
Mltext/r099903 5.pdf; (2) Five-
year review, 2005,
www.epa. sov/superfund/sites/rods/
fulltext/r099903 5.pdf
TI-Relevant Information
TI Decision: In situ groundwater standards, the lower of either Federal or state MCLs, are being waived for all contaminants within the TI
Zone; primary COCs in this area include TCE (5 ppb), chlorobenzene (70 ppb) and benzene (1 ppb).
Rationale: Due to the presence of LNAPL and DNAPL, it would be technically impracticable to restore groundwater at the source because
there are no remedial technologies that can remove all of the contamination. These areas will be contained by pumping, injection, and MNA,
and ICs will prevent exposure. DNAPL is present at depths potentially exceeding 130 feet bgs and occurs in discontinuous thin layers that
reside atop the heterogeneously distributed fine-grained sediments. The majority of DNAPL is below the water table. LNAPL is smeared in the
aquifer due to the rise and fall of the water table. The dissolved contamination in the TI Zones is not being restored but will only be contained
because (1) NAPL removal is not technically practicable, (2) restoration could never be complete due to the continuing migration of benzene
from the LNAPL, (3) extraction wells in the fine-grained units would have extremely small radii of influence, and (4) extraction may cause
adverse migration of contaminants.
Conditions: NAPL (suspected or observed) - DNAPL and LNAPL are present.
COCs - all contaminants within the TI zone, mainly TCE, chlorobenzene, and benzene
Concentration - Maximum concentrations: benzene exceeded 100,000 ug/L; TCE at 9,400 ug/L, and chlorobenzene up to
38,000 ug/L.
Geology - Heterogeneously distributed fine-grained sediments.
77 Zone - TI Zones were determined based on contaminant plumes. The chlorobenzene (DNAPL) plume vertically includes the
Bellflower Aquitard and Gage Aquifer and horizontally, the zone is larger than the plume to allow for a buffer between the
plume and extraction well. The TCE and benzene plumes (LNAPL) are commingled in the UBF and MBFB units and are
vertically delineated by the current benzene plume (greater than 1 ppb). The TI Zone for benzene and TCE in the MBFC
sand unit is based on the benzene plume in the unit above (the MBFB sand) because there is little separation between the
two layers.
Evaluation: Remedial Timeframe Estimate (years) - Indefinite
Remedial Action Alternatives - According to the ROD, NAPL areas will be contained by pumping, injection, and MNA, and ICs
will prevent exposure. The areas of dissolved contamination outside the TI Zones will be restored by P&T.
Current Status/Activities: The 2005 5-year review was for OU2 (not groundwater) and it is unclear if groundwater ICs have been
implemented. This TI waiver applies at two sites (Del Amo and Montrose Chemical).
August 2012
A-87
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Koppers Co. Inc.
(Oroville Plant)
State: LA; uu: I
Decision Doc. (Type & Date):
ROD Amendment, 9/23/99
Stage: Post-construction
Media: Groundwater
References: (1) ROD Amendment,
OU1, 9/23/99,
www.epa. gov/superfund/sites/rods/
fulltext/a0999094.pdf; (2) Site
summary,
www.vosemite.epa.sov/r9/sfund/r9
sfdocw.nsf/3dec8ba325236842882
5742600743733/028690d5578028
H8889^7nmnn^pQAi HiOnpnnrir'ii
ment
TI-Relevant Information
TI Decision: Remedial standards for dioxin (5.3xlO~7ppb) and total cPAHs (0.007 ppb) and the federal MCL for PCP (1 ppb) are being
waived in the TI Zone.
Rationale: The nature and extent of DNAPL at the site has become better defined than at the time of the RI, and technical issues regarding
DNAPL are better understood than during the FS and original ROD (1989). The ROD Amendment changes the goal for groundwater from
within the 4-acre TI Zone from restoration to containment. A TI waiver is justified based on the following: (1) surface and near surface soil
contamination have been remediated and the DNAPL has been contained; (2) it is not technically feasible to meet the cleanup standards within
the TI Zone; (3) deed restrictions can provide adequate protection; (4) contaminants will be monitored inside the TI zone; and (5) operation of
P&T will be resumed as a contingent remedy if contaminants migrate outside the TI Zone. Groundwater is approximately 30 feet bgs with an
estimated volume of 67 million gallons in the TI Zone. The DNAPL likely resides on three clay layers separating the different aquifers, and
based on RI data, more than 1 million gallons of free creosote may be present at these layers.
f~1 J *-/_? ~\T A TtT / J- 1 J 1\ T~\~\ T A TYT ' -t -tJ-t i'111 ' il 1*1 1 1 i il ' J 1 -t ' i '
Conditions: NAPL (suspected or observed} — DJN APL is not expected to still be in the mobile phase but rather as residual contamination on
each of the 3 clay layers.
COCs - Dioxin, total cPAHs, PCP
Concentration — In 1998, total cPAH concentrations ranged from ND to 6,980 ppb in the TI zone.
Geology — Clay layers separate each of the aquifers.
77 Zone — TI Zone covers 4 acres of 200-acre site and includes all aquifers.
Evaluation: Remedial Timeframe Estimate (years) - Indefinite
Remedial Action Alternatives - The amended remedy includes continued operation of the existing P&T system to restore
groundwater outside the TI Zone, coupled with enhanced in situ bioremediation to address PCP. MNA is designated as a
contingent remedy outside the TI Zone. Source removal activities were conducted followed by on-site
consolidation/landfilling.
Current Status/Activities: The site summary indicates ICs (land and groundwater use restrictions) have been implemented, and on-site P&T
and monitoring (on-site and off-site) continue.
August 2012
A-88
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Montrose Chemical
Corp.
State: CA; OU: 3
Decision Doc. (Type & Date):
ROD, 3/30/99
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OU3,
3/30/99,
www.epa. sov/superfund/sites/rods/
fulltext/r099903 5.pdf; (2) Five-
year review, 2005
TI-Relevant Information
TI Decision: In situ groundwater standards, the lower of either Federal or state MCLs, are being waived for all contaminants within the TI
Zone, mainly TCE (5 ppb), chlorobenzene (70 ppb) and benzene (1 ppb).
Rationale: Due to the presence of LNAPL and DNAPL, it was determined that it would be technically impracticable to restore groundwater at
the source zones because at the time the ROD was written there were no remedial technologies that could remove all of the contamination.
These areas will be contained by pumping and MNA, and ICs will prevent exposure. DNAPL is present at depths potentially exceeding 130
feet bgs and occurs in discontinuous thin layers that reside atop the heterogeneously distributed fine-grained sediments. The majority of
DNAPL is below the water table. LNAPL is smeared in the aquifer due to the rise and fall of the water table. The dissolved contamination in
the TI Zones is not being restored but will only be contained because (1) NAPL removal is not technically practicable; (2) restoration could
never be complete due to the continuing migration of benzene from the LNAPL; (3) extraction wells in the fine-grained units would have
extremely small radii of influence; and (4) extraction may cause adverse migration of contaminants.
Conditions: NAPL (suspected or observed) - DNAPL and LNAPL are present.
COCs - TCE, chlorobenzene, and benzene
Concentration - Maximum concentrations: benzene exceeded 100,000 ug/L; TCE at 9,400 ug/L, and chlorobenzene up to
38,000 ug/L.
Geology - Heterogeneously distributed fine-grained sediments.
77 Zone - TI Zones were determined based on contaminant plumes. The chlorobenzene (DNAPL) plume vertically includes the
Bellflower Aquitard and Gage Aquifer and horizontally, the zone is larger than the plume to allow for a buffer between the
plume and extraction well. The TCE and benzene plumes (LNAPL) are commingled in the UBF and MBFB units and are
vertically delineated by the current benzene plume (greater than 1 ppb). The TI Zone for benzene and TCE in the MBFC
sand unit is based on the benzene plume in the unit above (the MBFB sand) because there is little separation between the
two layers.
Evaluation: Remedial Timeframe Estimate (years) - Indefinite
Remedial Action Alternatives - NAPL areas will be contained by pumping and MNA, and ICs will prevent exposure. The areas
of dissolved contamination outside the TI zones will be restored by P&T.
Current Status/Activities: 2005 5-year review was for OU2 (not groundwater) and it is unclear if groundwater ICs have been implemented
yet. This TI waiver applies at two sites (Del Amo and Montrose Chemical).
August 2012
A-89
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
TI-Relevant Information
Site Name: Edwards Air Force
Base
State: CA; OUs: 4 & 9 (Sites 37,
120, 133, and 321)
Decision Doc. (Type &Date):
ROD, 9/24/07
Stage: Pre-construction
Media: Ground water
References: (1) ROD, OUs 4 & 9,
9/24/07,
www.vosemite.epa.gov/r9/sfund/r9
Sfdocw.nsf/cadf7f8d48234c988825
74260073d787/23b33b4a7b9ed482
8825740a00621d8b!OpenDocume
nt; (2) Site summary,
www.vosemite.epa.gov/r9/sfund/r9
sfdocw.nsf/3dec8ba325236842882
5742600743733/130468772dfd94f
f88257007005e9413!QpenDocume
nt
TI Decision: ARARs are being waived for contaminants that have primary MCLs, see Table 2.5-1 of ROD. The TI waiver applies only to
COCs with a chemical-specific ARAR (primary MCL).
Rationale: A TI waiver is being invoked due to the technical impracticability, from an engineering perspective, of achieving groundwater
restoration and removing DNAPL solvents that are suspected in crystalline, fractured granitic bedrock impacted by dissolved-phase VOCs and
other chemicals. Remediation of groundwater is limited at this site due to the following factors: (1) groundwater occurs in a complex system
of isolated and heterogeneous fractures within the crystalline granitic bedrock. As a result, aquifer permeability is very low, hindering both
groundwater extraction for above ground treatment and the delivery of materials for in situ treatment; (2) chlorinated solvents such as PCE and
TCE are recalcitrant contaminants when present as DNAPL and have proven difficult (if not impossible) to remove or remediate on a large
scale. PCE and TCE are likely present as DNAPL at Site 37 and 133 based on groundwater sampling coupled with known historical
contaminant releases; and (3) groundwater at depths in excess of 250 feet bgs (Site 37) and 350 feet bgs (Site 133) is impacted based on
analysis of samples from deep wells. Extraction of groundwater for treatment, or distribution of injected materials (e.g. chemicals and/or
bacteria) for in situ treatment becomes increasingly difficult at greater depths because the fractures become smaller, tighter, and less frequent,
further reducing the permeability of the water-bearing intervals. Moreover, installation of deep monitoring wells is challenging and expensive,
especially if care is taken not to carry contamination further downward.
Conditions: NAPL (suspected or observed) - DNAPL is suspected in the fractured bedrock
COCs- 9 chlorinated VOCs, benzene, naphthalene, trichlorofluoroethane (CFC 113), methylene chloride, MTBE, nitrate
Concentration - Maximum concentrations are provided in Table 2.5-1 of ROD.
Geology - The crystalline granitic bedrock is overlain in some areas by a thin veneer of unconsolidated material. Multiple
aquifers are present.
TIZone - TI zone covers 16.4 square miles and corresponds to township, range, and section boundaries as convenient. The zone
extends to a depth of 500 ft bgs, which is 175 ft below the maximum depth of contamination.
Evaluation: Remedial Timeframe Estimate (years) - Combined PCE and TCE plumes would advance for 300 years before the western lobe
would reach equilibrium and 800 years until the eastern lobe would. Estimates for P&T range from 210 to 1,200 years
assuming that the entire DNAPL source could be removed (See table 2.5-5 of ROD for additional information).
Remedial Action Alternatives —The selected remedy includes institutional controls restricting groundwater use and long-term
groundwater monitoring with a contingency (if contaminants are found to be migrating), along with no action for soil, and
institutional and engineering controls for soil vapor. Additional groundwater remedies evaluated in the ROD included P&T
for containment and blast fracturing.
Current Status/Activities: Long-term groundwater monitoring required by the ROD continues to be used for documenting the slowly
migrating plumes and the related compliance boundary for vapor intrusion pathway land use controls (VIP LUCs). Occasional vapor sampling
in or near buildings is conducted per the VIP LUC requirements. The first 5-year review report is due in September 2012.
August 2012
A-90
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Eielson Air Force Base
State: AK; OU: 1
Decision Doc. (Type & Date):
ROD Amendment, 9/28/98
Stage: Pre-construction
Media: Groundwater
References: (1) ROD Amendment,
OUs 2, 3, 4, 5; 9/28/98,
www.epa. sov/superfund/sites/rods/
fulltext/al098185.Ddf: (2) Five-
year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f03-10002.rjdf
TI-Relevant Information
Region 10: 1 site (2 waivers)
TI Decision: EPA's established action level for lead in drinking water (15 ug/L) is being waived.
Rationale: P&T was selected in 1994 to address lead contamination. However, subsequent evaluation has concluded that lead is largely
immobile in the subsurface, that the plume is stable and not expanding, and that removal of lead contamination is technically infeasible. Any
remaining source of more mobile organic lead will be degraded to the immobile inorganic lead through treatment and removal of petroleum
products.
Conditions: NAPL (suspected or observed) - NAPL has been detected as free product in some areas of this OU.
COCs-Lead
Concentration - Concentration range for lead at OU2 was 1.3 to 795 ug/L.
Geology - Glacial outwash plain/thick deposits of mostly high-energy fluvial deposits (sand and gravel with thin discontinuous
lenses of silt).
77 Zone - TI Zone includes a portion of the site and extends from the water table to 30 feet bgs; however the lateral extent of the
TI zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) — Air Force estimated over 100 years if a standard P&T system was to be used EPA
believes this is an optimistic estimate because the immobile form of lead is described as unlikely to be leached from the
formation and transported to production wells by a conventional P&T system within a reasonable timeframe.
Remedial Action Alternatives - The 1998 ROD Amendment selected monitoring and ICs (use restrictions) for groundwater.
Bioventing and SVE have been conducted for site soils and passive skimming has removed floating fuel.
Current Status/Activities: Based on the 2003 5 -year review, ICs have been implemented at OU2.
August 2012
A-91
-------
Summary of Technical Impracticability Waivers at Superfund Sites
(91 waivers at 85 sites through FY 2011, as of April 2012)
General Site Information
Site Name: Eielson Air Force
Base, ST58
State: AK; OU: 4
Decision Doc. (Type & Date):
ROD Amendment, 9/28/98
Stage: Pre-construction
Media: Ground water
References: (1) ROD Amendment,
OUs 2, 3, 4, 5; 9/28/98,
www.epa. sov/superfund/sites/rods/
fulltext/al098186.Ddf: (2) Five-
year review, 2003,
www.epa. sov/superfund/sites/fivev
ear/f03-10002.pdf
TI-Relevant Information
TI Decision: EPA's established action level for lead in drinking water (15 ug/L) is being waived.
Rationale: The original remedy was monitoring and ICs for groundwater (and bioventing for soils and fuels). Subsequent investigations have
shown that bioventing is no longer necessary because contamination has been reduced in soils as a result of removal actions. In addition, it has
been determined that (1) the organic lead originally contained in the fuel has degraded to an immobile, stable inorganic lead; (2) any remaining
organic fuel will be converted to its immobile phase; and (3) lead is also not migrating. Modeling estimated restoration in about 100 years.
Conditions: NAPL (suspected or observed) - No floating product has been observed at ST58.
COCs - Lead
Concentration - Concentration range for lead at ST58 was 35 to 180 ug/L.
Geology - Glacial outwash plain/thick deposits of mostly high-energy fluvial deposits (sand and gravel with thin discontinuous
lenses of silt).
77 Zone - TI Zone includes a portion of the site and extends from water table to 30 feet bgs; however the lateral extent of the TI
zone is undefined in the references reviewed.
Evaluation: Remedial Timeframe Estimate (years) - 100 years
Remedial Action Alternatives — The Air Force considered a standard P&T system and excavation of the soil/aquifer matrix
which serves as the source area for slow leaching of lead into groundwater. Both are described as technically impracticable.
Current Status/Activities: Based on the 2003 5-year review, ICs (groundwater use restrictions) have been implemented at ST58.
August 2012
A-92
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APPENDIX B:
List of Acronyms
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ACL - Alternative concentration limit
ARAR - Applicable or relevant and appropriate requirements
AWQS - Ambient water quality standard
BAT - Best available technology
bgs - Below ground surface
BEHP - Bis(2-ethylhexyl)phthalate
BTEX - Benzene, toluene, ethylbenzene, xylenes
CFC - Chlorofluorocarbon
COC - Contaminant of concern
COPC - Contaminant of potential concern
CROW - Contained recovery of oil waste
DCA - Dichloroethane
DCB - Dichlorobenzene
DCE - Dichloroethene
DCP - Dichloropropane
DNAPL - Dense non-aqueous phase liquid
EPA - Environmental Protection Agency
ES - Entomology Shop
BSD - Explanation of Significant Differences
FEMWATER - Finite Element Model for
Groundwater
FS - Feasibility study
ft - Foot/feet
gpm - Gallon per minute
GWQS - Groundwater quality standard
IAC - Indiana Administrative Code
1C - Institutional control
ICS - Illinois Central Spring
JEBS - Jet Engine Build-Up Shop
LNAPL - Light non-aqueous phase liquid
LTRA - Long-term response action
MBFB - Middle Bellflower "B" Sand
MBFC - Middle Bellflower "C" Sand
MCL - Maximum contaminant level
MCLG - Maximum contaminant level goal
MEG - Maximum exposure guideline
mg/kg - Milligram per kilogram
mg/L - Milligram per liter
mgd - Million gallons per day
MNA - Monitored natural attenuation
MTBE - Methyl tertiary butyl ether
NAPL - Non-aqueous phase liquid
ND - Not detected
ng/L - Nanogram per liter
NHBB - New Hampshire Ball Bearings, Inc.
NJDEP - New Jersey Department of Environmental
Protection
NPDES - National Pollutant Discharge Elimination
System
NPL - National Priorities List
OU - Operable unit
P&T - Pump and treat
PADEP - Pennsylvania Department of Environmental
Protection
PAH - Polyaromatic hydrocarbon
PCA - Tetrachloroethane
PCB - Fob/chlorinated biphenyl
PCE - Tetrachloroethene
PCP - Pentachlorophenol
ppb - Part per billion
ppm - Part per million
PQL - Practical quantitation limit
PRB - Permeable reactive barrier
PRO - Preliminary remedial goal
RI - Remedial Investigation
ROD - Record of Decision
SDWA - Safe Drinking Water Act
SVE - Soil vapor extraction
SVOC - Semivolatile organic compound
TCA - Trichloroethane
TCB - Trichlorobenzene
TCDD - Tetrachlorodibenzodioxin
TCE - Trichloroethene
TDS - Total dissolved solids
TI - Technical Impracticability
TP - Trichlorophenol
TWA - Transformer work area
UBF - Upper Bellflower
ug/L - Microgram per liter
USGS -U.S. Geological Survey
UXO - Unexploded ordnance
VEB - Vertical engineered barrier
VER - Vacuum enhanced recovery
VI - Vapor intrusion
VOC - Volatile organic compound
August 2012
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