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

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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

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&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-

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&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 1—No Action. Cost: $0

•	Alternative 2—Placement of a 6-
to 12-inch soil cover over areas of
contamination. Cost: $4.6 million.

•	Alternative 3A—Placement 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 3B—Placement 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 4—Placement 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 5—Excavation and
off-site disposal of contaminated
soil. Excavated areas would be
backfilled with clean soil. Cost:
$19 million.

•	Alternative 6—Excavation 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.

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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,-

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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


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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


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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


-------


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Floodplain-Wetlarids Area Proposed Remedial Response Area


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Floodplain-Weliands Area Proposed Remedial Response Area


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-------
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 7—hydric-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.


-------
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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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