oEPA Public Comment Period U.S. EPA will accept written comments on the Proposed Plan and Feasibility Study during a public comment period: Date: November 13 to December 13,1996 Public Meeting U.S. EPA will hold a public meeting to explain the Proposed Plan and all alternatives presented in the Feasibility Study. Oral and written comments will also be accepted at the meeting: Date: November 21, 1996 Time: 7:00 to 9:00 p.m. Place: Kent State-Ashtabula Campus Blue and Gold Room 3325 West 13th Street .Ashtabula, OH United States Environmental Protection Agency Office of Public Affairs Region 5 77 West Jackson Boulevard Chicago, Illinois 60604 Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin Proposed Plan for Remedial Action Fields Brook Superfund Site Floodplain/Wetland Area November 1996 Ashtabula, Ohio Introduction This Proposed Plan describes the con- sidered alternatives and the Recom- mended Alternative for proposed remediation of the Floodplain/Wetland Area (FWA) at the Fields Brook Superfund Site (Site) in Ashtabula, Ohio (Figure 1). The Proposed Plan summa- rizes the alternatives that have been considered for the Site by the U.S. Environmental Protection Agency (U.S. EPA). The remedial alternatives summarized in this Proposed Plan are more fully described in the Feasibility Study (FS) report. The FS report, as well as any other pertinent documents in the Ad- ministrative Record and Information Repository, should be consulted for in- depth details on the development and evaluation of the alternatives considered. Public comment on the remedial alter- natives and the information that sup- ports these alternatives is an important contribution to the cleanup remedy selection process. Based on new infor- mation or public comment, U.S. EPA may modify the recommended alterna- tive or select another alternative pre- sented in this plan and/orthe FS report. The public is encouraged to review and comment on all technologies and alter- natives considered for the Fields Brook FWA remediation. Site Location and Features Fields Brook is located in the city, township, and county of Ashtabula, in northeastern Ohio. A map showing the general location of the Fields Brook watershed is presented in Figure 1. Fields Brook drains a 6-squ are-mile area. The eastern portion of the water- shed drains Ashtabula Township, and the western portion drains the eastern portion of the city of Ashtabula, The main channel is 3-9 miles in length and begins at Cook Road, just south of the Penn Central Railroad tracks. From this point, Fields Brook flows northwest to Middle Road, then west to its confluence with the Ashtabula River. From Cook Road downstream to State Highway 11, Fields Brook flows through an industri- alized area. Downstream of State High- way 11 to near its confluence with the Ashtabula River, Fields Brook flows through a residential area within the city of Ashtabula. Fields Brook empties into the Ashtabula River, approximately 8,000 feet (ft) upstream from .Lake Erie, The city of Ashtabula, with a popula- tion of approximately 23,000, is the only urban area in the Fields Brook watershed. The industrial zone of Ashtabula is concentrated around Fields Brook and contains several chemical industries and waste disposal sites, Site Background and History The FWA soils are contaminated with PCB's, hexacMorobenzene (HCB), and other hazardous substances, both organic and inorganic, resulting from industrial discharges to Fields Brook. The Fields Brook Site was placed on the National Priorities List (NPL) of uncon- trolled hazardous waste sites under the 1 ------- Comprehensive Environmental Re- sponse, Compensation, and Liability Act (CERCLA) on September 8, 1983- U.S. EPA divided the Fields Brook Site into four areas of concern, three of which are considered "operable units" associated with the Fields Brook Superfund Site. Figure 1 shows the different study areas of the Site. The Sediment Operable Unit involves the cleanup of contaminated sediment in the Fields Brook channel and its tribu- taries. The Source Control Operable Unit will locate sources of contamina- tion to the Brook and identify ways to prevent future contamination. The FWA Operable Unit involves the cleanup of contaminated soils and sediments in floodplain areas surrounding Fields Brook, and is the focus of this Proposed Plan. To prevent recontamination of Fields Brook and the Ashtabula River, work on the Source Control Operable Unit will precede or coincide with work on the Sediment and Fioodplains Area Operable Units. The Ashtabula River Area of Concern is being addressed in part by the Ashtabula Public/Private Partnership and through separate Superfund investigations. In order to facilitate locating features and sampling points along Fields Brook and its tributaries, the stream and FWA have been divided into segments iden- tified by a numbering system involving stream reaches. Figure 2 depicts the watershed area and stream reach num- bers. The FWA areas along Fields Brook were divided by sections of the Brook into floodplain exposure units (EU), as indicated on Figure 2. Each of these EUs are approximately 2,000 feet in length along the Brook, and are located behind residential homes and industrial areas. The EUs correspond to areas where exposure to FWA soils would occur by distinct populations of people on a regular basis (e.g., resi- dents and industrial workers) on each side of the Brook. A remedial investigation (RI) was performed in 1985 by U.S. EPA on Fields Brook sediments and surface water. Detected compounds included chlorinated benzene compounds, poly- nuclear aromatic hydrocarbons (PAHs), hexachlorobutadiene and PCBs. These data indicated the types of hazardous substances which could be in the FWA. In late 1986, U.S. EPA began negotiat- ing with a number of companies thought to be responsible for contaminating Fields Brook to conduct response ac- tivities under the Source Control and Sediment Operable Units. It is U.S. EPA's policy to have these companies, known as potentially responsible parties (PRPs), pay for the cleanup rather than using funds from the Superfund program. The PRPs are com- prised of the companies who are con- sidered the owners and operators of the chemical industries and waste dis- posal sites surrounding Fields Brook. The PRPs also include the companies who, by contract, agreement, or other means, either accepted, or arranged for transport, disposal or treatment of, haz- ardous substances within the Fields Brook Site. In 1989, the PRPs agreed to design the Fields Brook remedy, iden- tify the contamination sources, and develop potential remedial alternatives for those sources. In August 1994, the PRPs agreed to voluntarily evaluate the FWA portion of the Fields Brook Site, and conducted and submitted a Feasibility Study report and Integrated Human and Ecological Baseline Risk Assessment report for the FWA. Additional reports, including a Remedial Investigation report, and Ecological Assessment and Human Risk Assessment reports on the FWA, were completed by the U.S. EPA in fall 1996. These FWA documents present find- ings of data collected from the FWA, assess human and ecological risks in these areas and discuss remedial cleanup alternatives to address the risks found, and form the basis for this proposed remediation plan for the FWA. These reports have been sent to the informa- tion repositories noted on this fact sheet, and can be found in the Site's Administrative Record. Floodplain Area Field Studies and Sampling A total of 211 soil samples were taken from the FWA, with generally 40 samples collected within each of the five EUs which were investigated in this study: EU2, EU3, EU4, EU6 and EUS. The sampling locations were spread fairly evenly along each length of the FWA, with an equal number of samples (twenty) on the north and south sides of the main channel of Fields Brook within each EU. EUs 2 and 3 are considered residential based upon the presence of homes on the property (see Figures 3, 4 and 5). The industrial EUs are upstream of the residential EUs. EU4, EU6 and EUS are considered to have industrial usage for the following reasons: a) the area east of Route 11 currently does not have residential development; b) the prop- erties that fall within EU4 and EU6 primarily belong to industry or the City of Ashtabula, and do not belong to private land owners; and c) the proper- ties would be permanently restricted from residential development through deed restrictions (see Figures 6, 7 and 8). The other five EUs were eliminated from further consideration within the U.S. EPA risk assessment. EUs 1, 5 and 7 do not have a floodplain area (i.e., the Brook, during a 100 year storm, stays within the brook channel and does not overflow the banks in these EUs). In EUs 9 and 10, sampling results indi- cated no exceedances in the FWA above Cleanup Goals. Soil samples were analyzed for ap- proximately 130 different chemicals and selected chemicals of concern. Soil sam- pling showed 95 hazardous substances which were detected in some or all portions of the FWA. As would be expected based on the Site's history, volatile and semi-volatile organic chemi- cals, pesticides, PCBs, and inorganic chemicals were detected in the FWA soils. The chemicals of concern concentra- tions vary from background and non- detect to several hundred parts per 2 ------- &EPA Public Comment Period U.S. EPA will accept written comments on the Proposed Plan and Feasibility Study during a public comment period: Date: November 13 to December 13,1996 Public Meeting U.S. EPA will hold a public meeting to explain the Proposed Plan and all alternatives presented in the Feasibility Study. Oral and written comments will also be accepted at the meeting: Date: November 21, 1996 Time: 7:00 to 9:00 p.m. Place: Kent State-Ashtabula Campus Blue and Gold Room 3325 West 13th Street Ashtabula, OH United States Office of Public Affairs Illinois, Indiana, Environmental Region 5 Michigan, Minnesota, Protection Agency 77 West Jackson Boulevard Ohio, Wisconsin Chicago, Illinois 60604 Proposed Plan Summary Fields Brook Superfund Site Floodplain/Wetland Area November 1996 Ashtabula, Ohio Introduction This Proposed Plan summary de- scribes the alternatives considered and the Proposed Plan for Superfund remediation of the Floodplain/Wet- land Area of the Fields Brook Superfund site in Ashtabula, Ohio. The Proposed Plan is described in detail in the attached fact sheet. Site Background The Fields Brook Superfund site is located in Ashtabula, in northeast Ohio. Fields Brook flows through an industrialized area of Ashtabula that includes several chemical companies and waste disposal sites. The floodplain adjacent to Fields Brook has become contaminated with PCBs, hexachlorobenzene (HCB) and other hazardous substances resulting from discharges to Fields Brook (see Glossary at end of the attached fact sheet for a definition of these sub- stances). The site was placed on the U.S. EPA's National Priorities List in 1983 and in 1985 the U.S. EPA began a detailed investigation of contamination at the site. The Fields Brook site was di- vided into three areas for investiga- tion and subsequent cleanup: the source of the contaminants (industrial uses near Fields Brook); Fields Brook itself; and the floodplain and wetland adjacent to Fields Brook. The Ashtabula River sediments, Ashtabula Harbor, and City of Ashtabula water intake were also in- vestigated. This Proposed Plan deals only with cleanup of the floodplain and wetland adjacent to Fields Brook. Results of Feasibility Study The U.S. EPA and the parties believed responsible for contaminating Fields Brook completed their reports on the floodplain and wetland areas investi- gation in fall 1996. The primary re- ports include a Remedial Investiga- tion Report, Human Risk Assessment, Ecological Risk Assessment, and a Feasibility Study. The Remedial In- vestigation Report presents the re- sults of sampling conducted in the floodplain and wetland areas. The Risk Assessments describe the poten- tial risk to human health and the environment posed by the contami- nants in the Fields Brook floodplain and wetland areas. The Feasibility Study (FS) evaluates the alternatives for cleaning up the floodplains and wetlands. Eight alternatives were evaluated in the FS, including a "no-action" alter- native. The seven "action" alterna- tives involve several common mea- sures including site preparation, insti- tutional controls such as fencing and deed restrictions to prevent residen- 1 ------- &EPA What's Next The U.S. EPA will consider all com- ments received during the public com- ment period before selecting a final cleanup remedy, A public hearing will be held on November 21st at the Kent State-Ashtabula Campus to receive com- ments on the recommended alterna- tive. A pre-addressed comment form is included in the attached fact sheet if you wish to send your comments to the U.S. EPA. All written comments must be postmarked by December 13. Following selection of the final cleanup remedy, the cleanup remedy will be designed and implemented. Additional Information Anyone interested in learning more about the investigation of the Fields Brook Superfund site and the Pro- posed Plan for controlling contamina- tion at the Fields Brook floodplain and wetland areas is encouraged to review copies of the FS, Risk Assessments, Proposed Plan, and other materials related to the site. These documents may be reviewed at the information repositories for the site. See the at- tached fact sheet for addresses of the information repositories. For further information you may contact Ginny Narsete at (312) 886-4359 or Ed Hanlon at (312) 353-9228. tial development within the flood- plain, erosion control, and revegeta- tion of excavation or cover areas. Inspection and chemical sampling as part of long-term monitoring would also be included under the seven action alternatives. Wetland mitiga- tion would also be considered under the seven alternatives. The eight al- ternatives are summarized as follows; Alternative 1No Action. Cost: $0 Alternative 2Placement of a 6- to 12-inch soil cover over areas of contamination. Cost: $4.6 million. Alternative 3APlacement of a 6- to 12-inch soil cover over some areas of contamination. Excava- tion and off-site disposal of contaminated soil in other areas. Cost; $8.9 million. Alternative 3BPlacement of a 6- to 12-inch soil cover over areas of contamination in some areas. Excavation and off-site disposal of contaminated soil in other areas. Similar to Alt. 3A except excavation would be required near residential areas. Cost: $9.5 million. Alternative 4Placement of a 6- to 12-inch soil cover over areas of contamination. Similar to Alt. 2 except that the soil cover in the industrial area would be more extensive under Alt. 4. Cost: $5-8 million. Alternative 5Excavation and off-site disposal of contaminated soil. Excavated areas would be backfilled with clean soil. Cost: $19 million. Alternative 6Excavation and off-site thermal treatment of soil contaminated above a certain level. Excavated areas would be backfilled with clean soil. Cost: $21.3 million. Alternative 7 Placement of a 6- to 12-inch soil cover over areas of low-level contamination in resi- dential areas. Excavation and on- site disposal of contaminated soil in other areas. Cost: $6.9 million. Proposed Remedial Alternative The U.S. EPA used nine criteria (de- scribed in the attached fact sheet) to evaluate all the alternatives. Based on this evaluation, the U.S. EPA recom- mends Alternative 7. Alternative 7 would provide the most protective- ness and long-term effectiveness at the lowest overall cost. The attached fact sheet describes Alternative 7 in detail. 2 ------- FWA Soil Sampling Results Average Concentration mg/kg Maximum Concentration mg/kg Exposure Unit PCB HCB PCB HCB EU-2 24.1 17.9 360 9" EU-3 38.6 10.9 530 99 EU-4 68.1 36.0 560 300 EU-6 87.1 45.6 610 540 EU-8 38.0 14.9 270 480 million (ppm or mg/kg). Maximum concentrations for some of the semivolatile organics were; 610 mg/kg for total PCBs (EU 6), 480 mg/kg for HCB (EU 8). 170 mg/kg for hexachior©butadiene (EU 4); for some of the volatile organics were: 56 rng/kg for trichloroethene (EU 6), 89 mg/kg for tetrachloroethene (EU 6), and 8.5 mg/kg for vinyl chloride (EU 6); for some of the trace metals were: 43 mg/ kg for arsenic (EU 8) and 57.7 mg/kg for mercury and for total PCBs: 610 mg/kg in EU6. Average concentrations for two widespread chemicals (HCB and PCBs) in soil are summarized in the table above. Tissue samples were also collected from mice, shrews, earthworms, voles, in- sects, and vegetation and analyzed for the 130 parameters. PCBs were ob- served in the FWA biota. A maximum concentration of 11 ppm total PCBs was detected in a single shrew compos- ite sample, however, most concentra- tions were well below this level ranging from 0.029 to 4.8 ppm in other samples. Arsenic, cadmium, chromium, lead, and hexachlorobenzene were observed in all tissue matrices throughout the flood- plain/wetland area. Barium, vanadium, and hexachlorobutadiene were ob- served in several but not all matrices. Various chemicals of concern, includ- ing several trace metals (lead, cad- mium, chromium, vanadium, and barium), were considered in the eco- logical risk assessment. PCBs, hexachlorobenzene, and hexa- chlorobutadiene were the organics that were fully assessed in the ecological risk assessment; others were eliminated because their levels were not high enough in the FWA to be of concern to organisms. Summary of Site Risks An Integrated Baseline Risk Assess- ment for the FWA was conducted by the PRPs. which considered both a human health risk assessment and an ecologi- cal risk assessment. U.S. EPA has also prepared a risk assessment. The poten- tial risks to people exposed to the FWA include risks from ingestion of soils in the FWA, inhalation of dusts from the area, dermal exposure to the soils, and gardening in the FWA. The greatest potential risks to people are from inges- tion of soils in the FWA. EPA's review of these risks indicate that if risks from ingestion of soil are addressed, the other risks to humans and potentially to the environment would also be ad- dressed. Copies of these risk assess- ments are available for review in the Information Repositories. Exposure assessments were conducted as part of the human health and eco- logical risk assessments. The U.S. EPA considered a variety of information to determine what would be the appro- priate length of floodplain along each side of the Brook which would ad- equately represent the geographic area to which a person would be exposed. These lengths formed the basis and size of the FWA exposure units. The infor- mation reviewed as part of this effort included review of survey data, discus- sions with local citizens, inspection of all floodplain areas, investigations of plants and animals along the FWA, and evidence of use along the floodplain. The exposure unit lengths also consid- ered potential exposures by plants and animals in the floodplain area. U.S. EPA has reviewed these lengths and con- cluded that if, after cleanup activities occurred, contamination levels were on average at or below the Cleanup Goals (CUGs) for each exposure unit, the remedy would be protective of human health and the environment. The FWA sampling confirmed prior results and was the basis of the U.S. EPA CUG calculation performed in October of 1994. These CUGs indicate the con- centration for each contaminant found within the FWA at which exposure by people, plants and animals would be protective. Copies of U.S. EPA's 10/20/ 94 letter which includes these CUGs, and copies of U.S. EPA's 1/31/94 letter which indicates Radionuclide Contami- nation CUGs, are included in separate reports which have been sent to the information repositories. U.S. EPA's October 1996 Fields Brook FWA human health and ecological risk assessments focused on 11 chemicals of concern (COC) that were found in the Sediment Operable Unit; these COC's included arsenic, benzo(a)- pyrene, beryllium, hexachlorobenzene, hexachlorobutadiene, PCBs, 1,1,2,2,- 3 ------- tetrachloroethane, tetrachloroethene, trichloro-ethene, hexachloroethane, and vinyl chloride, Hexachloroethane and vinyl chloride were screened out as COCs in the U.S. EPA 1996 FWA human health risk assessment. U.S. EPA's evaluation of risks and the chemical sampling data indicates that PCBs and HCB were the two com- pounds causing the majority of human health risk, and that if the cleanup activities removed the elevated areas of PCB and HCB soil contamination, then the cleanup would also remove other COCs in the floodplain area. This is because the other COCs exist where elevated levels of PCBs and HCB exist. Radionuclide detections were also indi- cated on the EMI Extrusion property floodplain area within tine Fields Brook floodplain area. U.S. EPA reviewed all of the radionuclide data taken on the RMI Extrusion facility and floodplain area. 74 FWA samples were taken within floodplain areas behind RMl-Extrusion for U-234, U-235, and Technetium-99; 132 FWA samples were taken behind RMI-Extrusion for U-238. Of the 74 U- 234, U-235, and Technetium-99 FWA samples, there were no U-234 and Technetium-99 radionuclide cleanup goal (RCUG) exceedences, and there were 2 U-235 RCUG exceedences (these two U-235 ¦ RCUG exceedences were within the fenced-in areas behind RMI). Of the 132 U-238 FWA samples behind the RMI-Extrusion facility, there were 10 U-238 RCUG exceedences, with seven exceedences within the previously existing fenced-in area be- hind RMI, and three RCUG exceedences outside of the previously existing fenced-in areas. U.S. EPA's review of the data indicate that radionuclides, and in particular Uranium, are not considered a chemi- cal of concern within the floodplain areas of the Fields Brook Site because the levels of U-235 and U-238 indicated in the FWA area were relatively low. These levels are below the RCUGs established for U-235 and U-238 by the Nuclear Regulatory Commission and the U.S. EPA (i.e., the soil levels within the FWA are below the IxlO*5 risk levels) on average within each flood- plain area residential and industrial EU, including EU6 which includes the RMI Extrusion facility. Also, to be protective, RMI-Extrusion has recently fenced in all areas of RCUG exceedences on the property, installed silt fences in the downgradient areas of the detected radionuclides to catch sus- pended silt which may run off the property during rainstorms, and is also planning to excavate/remove the con- taminated soils in their backyard, in- cluding the RCUG exceedance FWA soil areas, and ship the soil to an approved storage facility in either Utah or Nevada. The excavation activities are planned to occur in 1998, and will be conducted in coordination with the ongoing facility decontamination and decommissioning actions being con- ducted under supervision of the U.S. Department of Energy. The excavation actions will also include delineation sampling in 1997 prior to the beginning of excavation to ensure that the RCUG exceedance areas have been defined. Based on a review of the data, U.S. EPA has found that if a remedial cleanup to certain concentrations of HCB and PCB within each exposure unit occurs, the low levels of contamination remaining in the FWA after cleanup is completed would be protective of human health and the environment for each exposure unit. The following is a summary of remedial response actions which would need to occur in each exposure unit to achieve such a protective cleanup: 1) excavate or cover all soil areas with PCB con- tamination above 6 ppm and HCB above 80 ppm in the residential area (leaving a residual PCB concentration of 1 ppm on average in each residential exposure unit); and 2) excavate all soil areas above 50 ppm PCBs and over 200 ppm HCBs in the industrial area (leav- ing a residual PCB concentration of between 6 to 8 ppm on average in each industrial exposure unit). The areas of the floodplain where remedial response actions would occur, for the above described excavation and cover activ- ity, are termed "Response Areas" in the alternatives described below. These ar- eas are indicated for Alternative 7 in Figures 3 through 8 provided within this Proposed Plan. Response actions which meet the above criteria would be protective because remaining levels of each contaminant would be. on average, at or below the CUGs (i.e., would be at IxlO"6 risk) in floodplain areas on each side of the Brook in each residential exposure unit, and within the acceptable risk range for PCBs (i.e., would be at or below 3xl04 risk), for each CUG com- pound in floodplain areas on each side of the Brook within each industrial exposure unit. EPA believes these response actions would also protect the various popula- tions of plants and animals which exist or may exist within the floodplain area for this site. These response actions would reduce the short- and long-term risks to these ecological populations and would provide for their future health and viability by reducing these population's potential uptake of con- tamination via soil and food to accept- able levels of exposure. Summary of Alternatives The FS identified and evaluated alter- natives that addressed threats and po- tential threats to human health and the environment posed by the chemicals of concern in the FWA. These remedial alternatives have several common com- ponents including site preparation, in- stitutional controls such as fencing and deed restrictions to prevent residential development within the floodplain, and surface controls such as soil erosion control and revegetation of excavation and cover areas and areas of disturbance. All of the following remedial alterna- tives except the no action alternative would involve excavation or cover of each exposure unit's soil areas which are at or greater than the concentra- 4 ------- tions noted in the previous section of this Proposed Plan, Alternatives 5, 6 and 7 involve a greater degree of exca- vation and removal of floodplain soils than the other alternatives. Over the long term, these alternatives would be more protective, effective and perma- nent, Also, to help demonstrate that the response areas are properly defined, all of the following remedial alternatives except no action would have delinea- tion sampling conducted in each FWA exposure unit prior to the beginning of construction to ensure that PCB (and HCB where necessary) soil sampling data have been provided for every fifty foot increment along north-south and east-west directions of the floodplain. The alternatives evaluated in the FS are presented below; Alternative 1 - No Action * Estimated Present Worth Cost: $0 * Estimated Construction Time: Immediate The inclusion of the no action alterna- tive is required by law and gives U.S. EPA a basis for comparison. This alter- native will not reduce any potential public health or environmental risks currently associated with the Site. This alternative does not include any institu- tional controls over the use of ground water or surface water. Alternative 2 - Containment- Hydric-Compatible Soil Cover Estimated Present Worth Cost: $4,600,000 Estimated Construction Time: 12 months This alternative consists of site prepara- tion, institutional controls, revegeta- tion, and the placement of a hydric- compatible soil cover and erosion mat over the Response Areas, The soil cover thickness would vary from 6 to 12 inches. Physical inspections and chemi- cal sampling would be part of long- term monitoring. Wetlands mitigation at off-Site locations is also considered. Alternative 3A - Hydric-Compatible Soil Cover, Excavation, Backfill and Off-Site Disposal Estimated Present Worth Cost: $8,900,000 » Estimated Construction Time: 12 months This alternative consists of site prepara- tion, institutional controls, revegeta- tion, and the placement of a hydric- compatible soil cover and erosion mat over the Response Areas. Excavation would be limited to 12 inches. Exca- vated soil would be disposed of at an off-Site landfill. Physical inspections and chemical sampling would be part of long-term monitoring. Wetlands miti- gation at off-Site locations is also con- sidered. Approximately 8,000 cubic yards will be excavated and removed from the FWA under this alternative, and brought to an off-site disposal facility. Alternative 3B- Hydric-Compatible Soil Cover, Excavation, Backfill and Off-Site Disposal Estimated Present Worth Cost: $9,500,000 Estimated Construction Time: 12 months This alternative is similar to Alternative 3A except the Response Areas were adjusted to require excavation near residential areas. Excavation would be limited to 12 inches. Excavated soil would be disposed of at an off-Site landfill. Physical inspections and chemi- cal sampling would be part of long- term monitoring. Wetlands mitigation at off-Site locations is also considered. Approximately 9,300 cubic yards will be excavated and removed from the FWA under this alternative, and brought to an off-site disposal facility. Alternative 4 - Hydric-Compatible Soil Cover Estimated Present Worth Cost: $5,800,000 Estimated Construction Time: 12 months This alternative is similar to Alternative 2, except the soil cover and erosion pro- tection mat would be placed over a larger Response Area than Alternative 2. Physical inspections and chemical sam- pling would be part of long-term moni- toring. Wetlands mitigation at off-Site locations is also considered. Alternative 5 - Excavation, Backfill, and Off-Site Disposal Estimated Present Worth Cost: $19,000,000 Estimated Constriction Time: 12 months This alternative consists of site prepara- tion, institutional controls, re vegeta- tion, excavating, and backfilling with hydric-compatible soils over Response Areas. Excavation would be limited to 12 inches. Physical inspection and chemical sampling would be part of long-term monitoring. Wetlands miti- gation at off-Site locations is also con- sidered. Approximately 28,500 cubic yards will be excavated and removed from the FWA under this alternative, and brought to an off-site disposal facility. Alternative 6 - Excavation, Backfill, Thermal Treatment of PCB-Contaminated Soil, and Off-Site Disposal Estimated Present Worth Cost: $21,300,000 Estimated Construction Time: 12 months This alternative is similar to Alternative 5, except that, in lieu of off-Site landfilling, excavated material exceeding 500 mg/ kg PCBs would be transported off-Site for thermal treatment. Physical inspec- tions and chemical sampling would be part of long-term monitoring. Wetlands mitigation at off-Site locations is also considered. Approximately 28,500 cubic yards will be excavated and removed from the FWA under this alter- native, and brought to an off-site disposal facility. 5 ------- Evaluation Table Evaluation Criteria Alt 1. Alt 2. Alt. 3A Alt. 3B Alt 4 Alt. 5 Ait. 6 Alt. 7 Overall Protection of Health and Environment O 1 1 » 1 Compliance with ARARs NA I 1 1 1 Long-term Effectiveness and Permanence O 1 1 1 I m Reduction of Toxicity, Mobility, or Volume through Treatment 3 O O O O O o O Short-term Effectiveness Q » i » Implementability NA - Present Worth Cost (millions) 0 4.6 8.9 9.5 5.8 19,0 21.3 6.9 State Agency Acceptance Community Acceptance Community acceptance of the recommended alternative will be evaluated after the public comment period. # Fully meets criteria 1 Partially meets criteria O Does not meet criteria NA Not applicable Alternative 7 - Hydric-Compatible Soil Cover, Excavation, Backfill, and On-Site Disposal Estimated Present Worth Cost: $6,900,000 Estimated Construction Time: 12 months This alternative consists of site prepara- tion, institutional controls, revegeta- tion, excavation and backfill, and the placement of a hydric-compatible soil cover and erosion mat over Response Areas, Excavation would be limited to 12 inches. Excavated soil would be disposed of at an on-Site consolidation area located at a selected industrial facility within the Fields Brook Site. Wetlands mitigation at off-Site locations is also considered. In addition to exca- vation and backfill activities, a 6-inch soil cover would be placed over all soil areas with PCB contamination of 6 ppm to 30 ppm in EU2 and EU3. Physical inspections and chemical sampling will be conducted as a part of long-term monitoring to help ensure that the cleanup activities in both of these areas remain protective of human health and the environment. Approximately 15,300 cubic yards will be excavated and re- moved from the FWA under this alter- native, and brought to an on-site con- solidation area. Evaluation of Alternatives U.S. EPA used nine criteria described below to evaluate all of the alternatives. An evaluation table comparing each alternative against these criteria is pro- vided, The evaluation criteria are sum- marized below. Overall Protection of Human Health and the Environment addresses whether a remedy provides adequate protection and describes how risks posed through each pathway are eliminated, reduced, or controlled through treatment, engi- neering controls, or institutional controls. Compliance with Applicable or Rel- evant and Appropriate Requirements (ARARs) addresses whether a remedy will meet all other Federal and State environmental statutes and/or provide grounds for issuing a waiver. Long-Term Effectiveness and Perma- nence refers to the amount of risk to maintain reliable protection of human health and the environment over time once cleanup goals have been met. Reduction of Toxicity. Mobility, or Vol- ume through Treatment is the antici- pated performance of treatment tech- nologies that may be employed in a remedy. Short-Term Effectiveness refers to the speed with which the remedy achieves protection, as well as the remedy's potential to create adverse impacts on human health and the environment during the construction and implemen- tation period. Implementabilitv is the technical and administrative feasibility of a remedy, including the availability of materials and sen-ices needed to implement the chosen solution. Cost addresses the estimated capital and operation and maintenance costs. 6 ------- Legend ~ Sediment Operable Unit and Floodplain/Wetlands Area Operable Unit Source Control Operable Unit Ashtabula River Investigation figure 1 Location Map ------- Legend 1 Exposure Unit Number l Reach Number Woodward-Clyde Consultants Feet The different patterns shown are Intended to show the approximate area of the Exposure Unit. No other delineation is assigned to these patterns. 2000 4000 Figure 2 Exposure Units Floodplain-Wetlands Area Proposed Remedial Response Area ------- E 2465QOO MATCH LINE - SEE FEU2B, FIGURES Figure 3 Exposure Unit #2A Remedial Response Areas Alternative VII Floodplain-Wetlands Area Proposed Remedial Response Area ------- . r,.-.-r:,:,,.,., ... " " .. ... " . _____ i_ i ¦ ' ¦ ' ¦ ¦ ¦ : *" """ ** " i . ' " ' '¦ ' , ' ' ¦ I | J I § \ \ \ V _____ ___, v_ --r \ \ \ V n n, m \ \ \ . . " ! \ ' ' ' - . . ° *> «> *f> »»° scAli 11 1 to \ - ¦ ¦ ¦»" 1 ¦; » ' - ------- Figure 5 Exposure Unit #3 Remedial Response Areas Alternative ₯! Floodplain-Wetlarids Area Proposed Remedial Response Area ------- . ¦ . . 2SL___ " \\ .¦ . ' , y Cv/>»\«TlftlLl iktSCA t^linVAilwiT ' _____ . / - ' ' / - / * ¦ " * -- . L s , - - - - . . ¦ . . : ; ' ' » n - . : ¦ - - . . x. - ,, __ X- X-X -X- 1 ... '' ' . ¦ I ; - kp. ^ ¦ i - *¦ * »¦ 1 11 " ¦"»" ' . . - -g'-" - ------- K 21£22ffli_ F 2470000 Figure 7 Floodplain Exposure Unit #6 Remedial Response Areas Alternative VI! Floodplain-Weliands Area Proposed Remedial Response Area ------- : ; : __ ' ' ' ' . - "E 24? J OOS - ' . . ! V... - ¦ - , ' ' ' MJ . f\ x ' i 1_ . ^ . . ' iifi i-m n-iiiTiiiriir . ' . ¦ _______ ' .. . ' ------- evaluated as the present worth cost. Present worth is the present value of the capital and future O&M costs of an alternative based on the time value of money. Support Agency Acceptance indicates whether, based on its review of the FS and the Proposed Plan, the support agency (in this case, the Ohio EPA) concurs with, opposes, or has no com- ment on the recommended alternative. Community Acceptance will be assessed in the Record of Decision (ROD) (the document that outlines the selected cleanup plan) following a review of the public comments received on die FS report and the Proposed Plan. The Evaluation Table above shows that the recommended alternative is Alternative 7. It would provide the most long-term effectiveness and perma- nence at the lowest overall costs. Recommended Alternative The recommended alternative is Alter- native 7hydric-compatible soil cover, excavation, backfill, and on-Site dis- posal Specific requirements of this Recommended Alternative are provided below. The Evaluation Table indicates that Alternative 7 provides the overall best tradeoffs with respect to the nine evalu- ation criteria. Alternative 7 is the most cost effective alternative which reduces exposure to contaminants by removing the soil with the most elevated concen- trations of contaminants from the FWA environment via excavation and on- Site consolidation, and by covering areas of relatively low level contamina- tion. This alternative provides for in- creased protectiveness. long-term ef- fectiveness. and permanence over the alternatives which primarily consider use of cover (Alternatives 2, 3-A, 3-B, and 4) because it includes the removal of soil from areas of highest contamina- tion concentration in the FWA. A) Excavation, Cover, and Disposal Requirements: 1) excavate all soil in residential areas with PCB contamination above 30 ppm and HCB above 80 ppm, and excavate all soil in industrial areas above 50 ppm PCBs and over 200 ppm HCBs; 2) cover all soil in residential areas with between 6-30 ppm PCBs with 6 inches of hydric-compatible soil, and reveg- etate using erosion mats and native vegetation 3) transport excavated soils, construc- tion debris, and roadways to a contain- ment cell (landfill) to be built on one of the industrial properties located within the Fields Brook watershed; 4) removal of all trees in excavation areas, and all trees below 12-inch diam- eter in cover areas; and 5) backfill all excavation areas with hydric-compatible soils and re vegetate using erosion mats and native vegetation. B) Landfill Requirements The on-Site landfill to be constructed would be located on one of the indus- trial properties. It would have a bottom liner and would be covered with a plastic liner, clean soil and vegetation. It would be surrounded by a fence, and would have future monitoring and sam- pling to ensure it remains protective. To assure long- term effectiveness and protectiveness, the landfill would be constructed to meet the following mini- mum requirements: 1) Bottom Liner (from bottom to top): choose area where underlying clay is expected to be continuous, sand lenses not known to exist, and ground water not known to be contaminated if possible; grade to level: 5 feet above ground water 6-inch thick compacted in-situ clay 60-mil flexible synthetic membrane liner (FML) which has a permeability equivalent or less than lxlO"11 cm/sec 6-inch thick sand/gravel with leachate detection system 60-mil FML liner 6-inch thick sand/gravel with leachate collection system dewatered contaminated soils/sedi- ment (no rocks/sharp materials near bottom) 2) Cover (from bottom to top): grade 12-inch thick clean soil/gravel (con- sider need for soil gas collection or vents) 40-mil FML liner, keyed in 1/4-inch thick geonet liner 24-inch thick topsoil revegetate downgradient wells, one upgradient minimum, for monitoring purposes C) Post-Cleanup Sampling Requirements Post-remediation sampling would be initiated in the FWA to evaluate the remedial action in both the residential and industrial EUs. The sampling program would involve the following components: 1) Residential EUs (EUs 2 and 3): samples are planned to be taken each year analyze for PCBs year 1 through 4 analyze for nine chemicals of concern in year 5 (i.e., arsenic, benzo(a)pyrene, beryllium, hexachlorobenzene, hexachloro- butadiene, PCBs, 1,1,2,2,- tetrachloroethane, tetrachloroethene, and trichloroethene) review results each year, evaluate data to assess the need for further sampling and potential changes in sampling locations, and evaluate the need for remedy repairs, in accor- dance with the Superfund Program's National Contingency Plan regula- tion (40 CFR Section 300) 2) Industrial EUs (EUs 4, 6, and 8): samples are planned to be taken each year analyze for PCBs in year 1 through 4 analyze for nine chemicals of concern in year 5 (i.e., arsenic, benzo(a)pyrene, beryllium, hexachlorobenzene, hexachloro- butadiene, PCBs, 1,1,2,2,- tetrachloroethane, tetrachloroethene, and trichloroethene) review results each year, evaluate data to assess the need for further ------- sampling and potential changes in sampling locations, and evaluate the need for remedy repairs, in accordance with the Superfund Program's National Contingency Plan regulation D) Remedial Activity Locations Figures 3, 4, 5, 6, 7, and 3 indicate the proposed floodplain areas in the resi- dential areas (EU2 and EU3) located between East 16th Street and Route 11, and in the industrial areas (EU4, EU6, and EU8) located between Route 11 and about 2,000 feet east of State Road, where remedial activities would take place under Alternative 7. To construct this FWA remedy, delinea- tion sampling would be conducted in each FWA exposure unit prior to the beginning of construction to ensure that PCB '(and HCB where necessary) soil sampling data have been collected every fifty feet on the floodplain, A temporary access road would be installed along most of the floodplain area. This temporary road would be made of crushed stone and would have periodic access points to existing road- ways. It would be removed after con- struction and disposed of properly. The Next Step Public Involvement The U.S. EPA encourages the public to comment on all the alternatives dis- cussed as potential remedies for the Fields Brook Site. If an individual is interested in the exact locations of work to be performed in the FWA under the recommended alternative, those individuals may contact the EPA individuals noted below in this Fact Sheet. These comments will be ad- dressed and evaluated in the selection process of the remedy. Enclosed is a comment sheet for your convenience. A summary of all comments received and U.S. EPA's responses will be con- tained in the Responsiveness Summary, which will be attached to the ROD (which is a document outlining the final choice for a remedy). Comments may be presented orally or in writing at the public meeting (see page 1 of this fact sheet for date, time, and place). Comments may also be mailed to: Ginny Narsete, P-19J U.S. Environmental Protection Agency 77 West Jackson Blvd. Chicago, IL 60604 Mailed comments must be postmarked by December 13. 1996. U.S. EPA will consider public com- ments received during the public com- ment period before choosing a final action for the FWA. The final action will be described in the ROD. After a final action is chosen, U.S. EPA will meet with the PRPs believed re- sponsible for the Site contamination and request that they conduct Site cleanup activities. Following negotia- tions, the final action will be designed and implemented. If these PRPs are unable to negotiate an agreement with U.S. EPA or unwilling to conduct the cleanup activities, the PRPs may be ordered to conduct the cleanup, or Superfund monies may be used to pay for the final action, U.S. EPA will try to recover those costs from the PRPs in federal court in the event Superfund is used to pay for the cleanup. The Superfund Process Superfund was enacted by Congress in 1980 to investigate and clean up actual and potential releases of hazardous chemicals and other substances at sits throughout the United States, The Superfund process involves sev- eral steps after a site is initially identi- fied. After a preliminary inspection of the site is conducted by the U.S. EPA or a state agency such as the Ohio EPA, the site is evaluated for its impact on hu- man health and the environment. If the site poses a serious enough threat to the community, it is placed on the National Priorities List (NPL), a roster of the nation's worst hazardous waste sites. After the site is placed on the NPL, the U.S. EPA plans and conducts a remedial investigation and feasibility study (RI/ FS). The RI is a long-term study to identify the nature and extent of con- tamination at the site. The FS evaluates alternatives for cleaning up the site. The people or businesses that may have contaminated the site are referred to as potentially responsible parties (PRPs). If PRPs can be identified and are willing to cooperate with the U.S. EPA, one or more of the PRPs may conduct the RI/ FS. All work conducted by the PRPs is closely monitored by state and federal agencies. After the FS is completed, the U.S. EPA summarizes the cleanup alternatives in the Proposed Plan. The Proposed Plan also explains which alternative the U.S. EPA thinks is the best cleanup remedy. The U.S. EPA then provides the public an opportunity to comment on the alternatives presented in the Proposed Plan. After the public comment period, the U.S. EPA chooses the most appropri- ate alternative as a final remedy to clean up the site. The chosen remedy is then designed and implemented. At any time during this process, the U.S. EPA may conduct an emergency response action if the site becomes an immediate threat to public health or the environment. 8 ------- ------- Public Comment Period- The public-comment period run? You may send written comments to; Community-Involvement Coordinator Office of Public Affairs (P-19J) ' U.S. EPA 77 W, Jackson Blvd. * - Chicago, IL.60604 ' ' ' - fro - ' AC ₯ Fold on Ashed linfes, tape, stamp, and mail - Address _____ City__ .State. Zip . Gtnny Jfarsete- . ' Community 'involvement Coordinator Office of'Public Affairs (P-19J) ' . : ' U.S. EPA, . 77 W. Jackson Blvd. ' Chicago, IL 60604. ------- Glossary Hexachlorobenzene (HCB): A chlorinated organic compound commonly used as a fungicide and wood preservative. Hydric-compatible soils: Contain seeds, organics and other properties necessary for regrowth in the wet environment. Pofyehk»rinated Biphcnyb (PCBs): A family of compounds commonly used in electric transformers as insulators and coolants, in lubri- cants, adhesives, and caulking compounds. PCBs are extremely persistent in the environment because they do not readily break down into less harmful chemicals. Poly nuclear Aromatic Hydrocarbons (PAHs): A group of organic compounds related by their basic chemical structure. These compounds are normally associated with petro- leum products, and some are suspected to cause cancer. PAHs are commonly components of petroleum products such as tars and oils that are generated during incom- plete combustion of petroleum and coal fuel. Potentially Responsible Party (PRP): The PRPs are comprised of the companies who are considered the owners and operators of the chemical industries and waste disposal sites surrounding Fields Brook. The PRPs also include the companies who, by contract, agreement, or other means, either accepted, or arranged for transport, disposal or treatment of, hazardous substances within the Fields Brook Site. Record of Decision (ROD): A legal document signed by the U.S. EPA that describes the final cleanup remedy for a Superfund site, why the remedial actions were chosen, how much they will cost, and how the public responded. Remedial Investigation/Feasibility Study (RI/FS): A two-part study that is completed before any remedial cleanup can begin. The first part is the Remedial Investigation, which studies the nature and extent of the problem. The second part is the Feasibility Study, which evaluates different methods of dealing with the problem and selects a method that will effectively protect public health and the environment. Risk Assessment: The part of the remedial investiga- tion report that discusses the potential for human and ecological exposure to site contaminants. Volitaie Organic Compounds (V'OCs) Compounds of primarily carbon, oxygen, and hydrogen character- ized by their tendency to evaporate easily and quickly. Examples of VOCs include trichloroethene, tetra-chloroethene, and vinyl chloride which may be chemicals within such liquids as dry cleaning fluid, lighter fluid, paint thinners, and components of gasoline. ------- I- ¦ l nil mini iiihiin mi .run uniir film nim-.ii J ¦ - ¦ , , , , , ¦ ¦ ¦ ¦ ii . i ii i ; , ¦ related to the Site. The 1) Ashtabula County District library 335 West 44th Street Ashta Repositories are located at the following - 2) ~ " . Records ¦ ¦ ¦ Ginny Narsete U.S. EPA Region 5 Community Involvement Coordinator (312) 886-4359 ' ' U.S. EPA Region 5 / / west jacKson jDOUicvaxci Chicago, IL 6Q6Q4' Toll Free; 1-800-621-8431 ' (10 a.m. - 5:30 p.m.. Eastern Time) EPA Region 5 KCiTicQ iai i roicct M2iMScr (312). 353-9228 ' Regan S. Williams, Projtect Manager Ohio EPA . Northeast District Office 2110 E. Aurora Avenue . 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