EPA/ROD/RO1-05/008
2005
EPA Superfund
Record of Decision:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
EPA ID: CTD009717604
OU 03
SOUTHINGTON, CT
09/30/2005
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EPA NEW ENGLAND
Stmerfund Records Center
SI I E: Sf<5M£
BREAK; 5 4-
111II1I1
SDMS DocID 238285
RECORD OF DECISION SUMMARY
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC (SRSNE) SITE
SOUTHtNGTON, CONNECTICUT
SEPTEMBER 2005
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Record of Decision
Table of Contents
PART 1: THE DECLARATION
A. SITE NAME AND LOCATION
B. STATEMENT OF BASIS AND PURPOSE
C. ASSESSMENT OF SITE
D. DESCRIPTION OF SELECTED REMEDY
E. STATUTORY DETERMINATIONS
F. SPECIAL FINDINGS
G. ROD DATA CERTIFICATION CHECKLIST
H. AUTHORIZING SIGNATURES
PART 2; THE DECISION SUMMARY
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1, History of Site Activities
2, History of Federal and State Investigations and Removal and Remedial Actions
3, History of CERCLA Enforcement Activities
C. COMMUNITY PARTICIPATION
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
E. SITE CHARACTERISTICS
1. Physical Setting
2. Conceptual Site Model
3. Nature and Extent of Contamination
4. Principal Threat Waste
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Southington, CT
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F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
1, Land Uses
2, Groundwater
3, Surface Water
G. SUMMARY OF SITE RISKS
1. Human Health Risks
2. Ecological Risks
3. Basis for Response Action
H. REMEDIATION OBJECTIVES
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
1. Statutory Requirements/Response Objectives
2. Technology and Alternative Development and Screening
J. DESCRIPTION OF ALTERNATIVES
1, Source Control Alternatives Analyzed
2. Management of Migration Alternatives Analyzed
K. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
L, THE SELECTED REMEDY
1. Rationale for Selected Remedy
2. Description of Remedial Components
3. Summary of Estimated Remedy Costs
4. Expected Outcomes
M. STATUTORY DETERMINATIONS
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
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Southington, CT
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Table of Contents
0. STATE ROLE
PART 3; THE RESPONSIVENESS SUMMARY
A. STAKEHOLDER ISSUES AND EPA RESPONSES
B. TECHNICAL AND LEGAL ISSUES
APPENDICES
Appendix A: Figures
Appendix B: Tables
Appendix C: Glossary of Terms and Acronyms
Appendix D; ARARs Tables
Appendix E: State DEP Letter of Concurrence
Appendix F: References
Appendix G; Administrative Record Index and Guidance Documents
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Southington, CT
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Part 1; The Declaration
DECLARATION FOR THE RECORD OF DECISION
A. SITE NAME AND LOCATION
Solvents Recovery Service of New England, Inc.
Lazy Lane, Town of Southington
Hartford County, Connecticut
CTD 009717604
B. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Solvents Recovery Service
of New England, Inc. Superfund Site (the Site or the SRSNE Site), in Southington, Connecticut,
which was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), 42 USC § 9601 et sea., as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300
et seq,. as amended. The Deputy Director of the Office of Site Remediation and Restoration
(OSRR) has been delegated the authority to approve this Record of Decision (ROD),
This decision was based on the Administrative Record, which has been developed in accordance
with Section 113 (k) of CERCLA, and which is available for review at the Southington Public
Library, 255 Main Street, Southington, and at the United States Environmental Protection
Agency (EPA or the Agency) New England OSRR Records Center in Boston, Massachusetts.
The Administrative Record Index (Appendix G to the ROD) identifies each of the items
comprising the Administrative Record upon which the Agency relied in making the selection of
this remedial action.
The State of Connecticut concurs with the principal components of the selected remedy.
However, Connecticut Department of Environmental Protection (CT DEP) has decided not to
concur on the component of the selected remedy that requires institutional controls to prevent
exposure to vapor emissions.
C. ASSESSMENT OF THE SITE
The response action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the environment.
D. DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the SRSNE Site, which requires the in-situ treatment
of subsurface source material (non-aqueous phase liquid or NAPL) in the overburden aquifer;
capping surface source material (contaminated soil and wetland soil); capturing groundwater that
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Southington, CT
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exceeds federal drinking water standards and other risk-based cleanup levels; institutional
controls; and monitored natural attenuation of NAPL in the deep subsurface (bedrock) and
contaminated groundwater throughout the plume including outside the capture zone, until
cleanup levels are achieved across the entire Site.
Within approximately one year of implementation of in-situ treatment, this technology is
expected to remove 95% - 99% of the NAPL mass located in the overburden where the greatest
concentration of NAPL is found at the Site. Federal drinking water standards are expected to be
achieved throughout the entire groundwater plume in an estimated 225 years.
The selected remedy is a comprehensive approach for the SRSNE Site that addresses all current
and potential future risks caused by soil, wetland soil, NAPL in the subsurface, and contaminated
groundwater. These remedial measures will prevent contaminant migration, and will allow for
the restoration of the Site to beneficial uses including eventual use of the aquifer underlying the
Site for drinking and other domestic uses.
The major components of this remedy are:
• In-situ thermal treatment of contaminants in the overburden NAPL area until site-
specific NAPL performance standards to be developed during Remedial Design are
achieved;
• Excavate, consolidate and cap soil and wetland soil that exceeds soil/wetland soil
cleanup levels;
• Capture and on-site treatment of contaminated groundwater in both the overburden and
bedrock aquifers, until federal safe drinking water standards and other risk-based levels
are achieved;
• Over time, modification of the configuration of the on-site groundwater extraction and
treatment system, as appropriate, based on expected reductions in contamination;
• Monitored natural attenuation of the groundwater plume, including: 1) groundwater
outside the capture zone of the groundwater extraction and treatment system until
groundwater cleanup levels are achieved, and 2) contaminants in the NAPL area of the
bedrock aquifer, until groundwater cleanup levels are achieved;
• Implement restrictions on uses of the site property in perpetuity to prevent human
exposure to contaminants in the subsurface soils and to prohibit activities that might
harm the cap. Implement institutional controls to prevent human exposure to
contaminated groundwater and NAPL areas until appropriate levels are met. These
restrictions will also prohibit construction above that portion of the groundwater plume
that exceeds the State's volatilization criteria, if remedial design studies confirm the
need for such restrictions.
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Southington. CT
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• Maintain the cap in the long terra; and
• Perform reviews at least every five years to ensure that the remedy remains protective of
human health and the environment.
Contingent component of this remedy;
• In the event that the Town of Southington decides to activate municipal production wells
located near the Site prior to attainment of federal drinking water standards and risk
based levels throughout the Site, this ROD includes a contingent action for additional
groundwater containment.
The principal threat waste identified at the SRSNE Site is NAPL in the overburden and bedrock
aquifers. The selected response action addresses principal threat waste at this Site by treating
NAPL in the overburden aquifer with an in-situ thermal technology and treating NAPL in the
bedrock aquifer with monitored natural attenuation. In addition, this response action contains
contaminated groundwater in the overburden and bedrock aquifers and addresses the threats
presented by soil/wetland soil by consolidation and capping.
E. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are applicable or relevant and appropriate to the remedial action, is
cost-effective, and utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable.
This remedy also satisfies the statutory preference for treatment as a principal element of the
remedy (i.e., reduce the toxicity, mobility, or volume of materials comprising principal threats
through treatment). Because this remedy will result in hazardous substances remaining on-site
above levels that allow for unlimited use and unrestricted exposure (and groundwater and land
use restrictions are necessary), a review will be conducted within five years after initiation of
remedial action, and every five years after that, to ensure that the remedy continues to provide
adequate protection of human health and the environment over time.
F. SPECIAL FINDINGS
This ROD includes specific determinations made by EPA.
Section 404 of the Clean Water Act and Executive Order Determinations
Under Section 404 of the Clean Water Act, Executive Order 11990 (Protection Wetlands) and
Executive Order 11988 (Floodplain Management), EPA finds that the selected remedy, which
involves excavating highly contaminated materials from a small area of wetlands and
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Southington, CT
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floodplains, is appropriate as there is no practicable alternative to conducting work in the
wetlands and floodplains. The remedial action minimizes potential harm and avoids adverse
effects, to the extent practicable. Best management practices will be used throughout the Site to
minimize adverse impacts on the wetlands, floodplains, wildlife and its habitat. Damage to
wetlands during excavation will be mitigated through erosion control measures. Wetlands
restoration with indigenous species will be conducted consistent with the requirements of Federal
and State wetlands protection laws. The floodplains will be returned to their natural levels so as
to prevent the loss of storage capacity,
TSCA Determination for Contingent Measures
Under the Toxic Substances Control Act (TSCA), the Regional Administrator finds that the
possible excavation and off-site disposal ofpolychlorinated biphenyl (PCB) contaminated soil set
out in this Record of Decision meets the standards of 40 CFR 761.50 for remediation, and will
not pose an unreasonable risk to human health or the environment pursuant to 40 CFR 761.61(c).
G. ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for this Site,
1. Chemicals of concern (COCs) and their respective concentrations;
2. Baseline risk represented by COCs;
3. Cleanup levels established for COCs and the basis for the levels;
4. How source materials constituting principal treats were addressed;
5. Current and future land and groundwater use assumptions used in the baseline risk
assessment and ROD;
6. Land and groundwater use that will be available at the Site as a result of the selected
remedy;
7. Estimated capital, operation and maintenance (O&M), and total present worth costs;
discount rate; and the number of years over which the remedy cost estimates are
projected; and
8. Decisive factor(s) that led to the selection of this remedy.
H. AUTHORIZING SIGNATURES
This ROD documents the selected remedy for soil, wetland soil, NAPL areas and groundwater at
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Southington. CT
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the SRSNE Site. This remedy was selected by EPA with concurrence of the Connecticut
Department of Environmental Protection on all components with the exception of the
institutional controls to prevent exposure to vapor emissions.
Approval of the TSCA findings only:
By:
Robert W. Vamey
Regional Administrator
EPA-New England
Approval of the Record of Decision:
Date: ^I^>0^
By:
Date:
tichanaCavagnero
Deputy Director
Office of Site Remediation and Restoration
EPA-New England
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Soulhington, CT
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Part 2: The Decision Summary
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
The Solvents Recovery Service of New England, Inc. Superfund Site (the Site or the SRSNE
Site) is located in the Town of Southington, Connecticut, in Hartford County, approximately 15
miles southwest of the City of Hartford. It is located on Lazy Lane, just off Route 10 (Queen
Street), and adjacent to the Quinnipiac River. The SRSNE Site, generally depicted on Figure 1
consists of the SRSNE Operations Area (4 acres), the Cianci property (10 acres), a railroad
easement (the Railroad Right-of-Way), and those areas where groundwater contamination has
come to be located, including Southington's Curtiss Street Well Field (the Town Well Field).
The Town Well Field is a 28-aere parcel of undeveloped land containing two municipal drinking
water wells (Production Wells No. 4 and No. 6). The wells were closed in 1979 when they were
found to be contaminated with volatile organic compounds (VOCs). The Site was listed on the
National Priorities List (NPL) in September 1983.
From 1955 to 1991, Solvents Recovery Service, that later became Solvents Recovery Service of
New England, Inc. (SRSNE), operated as a spent solvent processing and reclamation facility at
the Site. Millions of gallons of waste solvents and oils were handled, stored and processed in the
Operations Area. Spent solvents were processed in a distillation column. Contaminant-laden
distillation process water was channeled into a drainage ditch along the Railroad Right-of-Way
and into a buried culvert that discharged to the Quinnipiac River. Samples of solvents appear to
have been discarded in a leach field. The still bottoms and liquid waste by-products were first
disposed of in at least two unlined lagoons in the Operations Area, and later bumed in an open
pit. Overflow from the lagoons drained onto the neighboring Cianci property. Ash from the burn
pit was used as fill in the Operations Area. After 1976, the solvents were blended to create a fuel
product for use in rotary kilns. There are numerous documented instances of leaks and spills to
bare ground. None of the original facility structures remain.
Since 1994, investigations, studies and two interim groundwater response measures have been
implemented by a group of over 250 potentially responsible parties (PRPs or the PRP Group).
The first interim groundwater measure, constructed in 1995, captures contaminated groundwater
in the unconsolidated deposits of boulders cobbles, gravel, sand and silt that constitute the
overburden aquifer. The second interim groundwater measure, constructed in 1999, captures
contaminated groundwater in the bedrock aquifer.
A more complete description of the Site can be found in Section 1 of Remedial Investigation
Report, Vol 1 of 4 (Halliburton NUS, May 1994) and Section 2 of Remedial Investigation
Report, Vol 1 of 2 (Blasland, Bouck & Lee, June 1998).
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Southington, CT
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B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1. History of Site Activities
SRSNE began spent solvent recycling operations at the Site in 1955 (Figure 2). The
solvents and chemicals handled, stored and processed at the facility in the Operations Area
included chlorinated solvents, ketones, alcohols, aromatic compounds and waste oils.
Aerial photographs of the facility from 1965 and 1980 can be found in the May 2005
Feasibility Study (FS) as Figures 1-4 and 1-5, respectively
From 1955 to the 1980's, SRSNE processed the spent solvents in an on-site distillation
column, which separated the solvents from the impurities. The recovered solvents were
shipped back to the customer for reuse, or sold. Contaminant-laden distillation process
water was channeled into a drainage ditch along the eastern edge of the facility, and flowed
through a buried culvert to the Quinnipiac River. Also located along the eastern edge of the
facility was a leach field which appeared to have received samples of solvents that were
discarded by the small on-site laboratory where the solvents were checked for their
chemical and thermal properties.
The distillation process also resulted in the generation of sludges and still bottoms that
contained impurities and unrecoverable solvents. These distillation by-products were
disposed of in two unlined lagoons in the Operations Area. An estimated 1,000 to 2,000
gallons of waste per week were managed in the lagoons. Periodically, the lagoons would
be dredged and the sludge removed. Overflow from these lagoons drained from the
SRSNE facility onto the neighboring Cianci property. Use of the lagoons was discontinued
in 1967 when they were emptied of visible residues of paint and lacquer and filled with dirt.
After the lagoons were closed in 1967, the sludges and still bottoms were primarily either
disposed off site at several locations, including Old Southington Landfill or were burned,
along with other flammable liquid wastes, in an on-site open burn pit. As many as 1,000
gallons of waste material per day were burned in the open pit until it was decommissioned
in 1974. Ash from the bum pit was used as fill material in the Operations Area.
After 1976, operations at SRSNE focused on blending the sludge and still bottoms with
flammable liquid wastes for use as a waste-fuel product for rotary kilns. In 1988, the batch
stills used in the distillation process were removed, and fuel blending became the primary
enterprise of the facility until it closed in 1991.
Past operating practices, such as the use of lagoons and a leach field, contributed to
contamination on the SRSNE Operations Area and surrounding properties. Poor
housekeeping from a variety of practices, including the unloading and loading of tank
trucks, the transfer of spent solvents to storage tanks, as well as the improper handling and
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storage of drums, resulted in numerous leaks and spills to the bare ground and into the
underlying aquifer.
Facility records from pre-1967 were destroyed in a fire, but between 1967 and 1991, in
excess of 41 million gallons of waste solvents, fuels, paints and similar liquids were
handled by SRSNE.
A more detailed description of the Site history can be found in Section 2 of the Remedial
Investigation Report (Blasland, Bouck & Lee, Inc., June 1998), and, Sections 1 and 3 of the
of the Remedial Investigation Report (Halliburton NUS, May 1994).
2. History of Federal and State Investigations and Removal and Remedial Actions
The presence of volatile organic compounds (VOCs) in drinking water forced the closing of
the Town of Southington's Production Well No. 4 in 1976, and Production Well No. 6 in
1979 (see Figure 1). Subsequent environmental investigations revealed that SRSNE was a
major source of VOC contamination to the groundwater in this area. Significant
investigations and actions taken to date are summarized below. A more complete
description of these and other environmental studies can be found in Section 2.5 of the
Remedial Investigation Report (Blasland, Bouck & Lee, Inc., June 1998).
• In the late 1970's, EPA conducted field investigations to delineate the source(s) of
contamination in Production Wells No. 4 and No. 6. Groundwater was found to
contain a variety of organic solvents (chlorinated and aromatic). The SRSNE
facility was identified as a primary source of VOCs in groundwater, and as a result,
the wells were shutdown. (Warzyn Engineering, Inc. Hydrogeologic Investigation,
Southington, CT, 1980)
• In 1979, EPA filed suit against SRSNE under the Resource Conservation and
Recovery Act (RCRA) for contaminating Production Wells No. 4 and No. 6, and,
under the Clean Water Act for the unpermitted discharge of pollutants to the
Quinnipiae River. The Southington Board of Water Commissioners and the
Connecticut Fund for the Environment later joined EPA in that action. The suit was
amended in 1982 to include claims under CERCLA.
• Further EPA investigations of the Town Well Field during the early 1980's
determined that the unlined lagoons at SRSNE were a major historical source of
contamination that, under both pumping and non-pumping conditions, would
negatively impact the two municipal supply wells. (Ecology & Environment, Inc.
Update on Contamination of Curtiss Street Well Field, Southington, CT, 1982)
• In 1982, SRSNE commissioned a study to evaluate EPA's findings and to conduct
additional investigations. The study confirmed that under pumping conditions,
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South ingtori, CT
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contaminated groundwater from the SRSNE facility could reach Production Well
No, 6, The report identified other nearby VOC sources that also may have
contaminated the well field, (Wehran Engineering Corporation. Hydrogeologic
Assessment Report, 1982)
• In September 1983, EPA placed the SRSNE Site on the National Priorities List
making it eligible for federal assistance for clean up.
• In 1983, EPA's lawsuit against SRSNE (filed in 1979, and amended in 1982) was
settled. Under the settlement, embodied in a Consent Decree between SRNE, EPA
and others, SRSNE was required to make improvements to its solvents handling
procedures, construct a network of wells (the on-site interceptor system or OIS) at
the facility to reduce the migration of contaminated groundwater, construct a
cooling tower/air stripper to remove contaminants from the groundwater captured
by the OIS, and, to install an off-site interceptor system to capture contaminated
groundwater beyond the facility boundaries.
• Between 1983 and its closing in 1991, SRSNE implemented some of the
improvements required under the Consent Decree, It installed 25 interceptor wells
for the OIS in 1985, and began operating the OIS and the cooling tower/air stripper
in 1986. SRSNE also installed the off-site interceptor system, though this system
never became operational because SRSNE was never issued a state discharge
permit. SRSNE also paved the Operations Area with asphalt, installed berms to
contain spills, improved fire protection and suppression measures by extending the
public water line to the facility, and improved general housekeeping measures to
some degree. Despite these efforts, numerous deficiencies remained.
• From 1983 through 1988, the federal and state governments took steps to ensure
SRSNE's full compliance with the 1983 Consent Decree. In 1986, EPA issued
SRSNE a permit under the Hazardous and Solid Waste Amendments to RCRA
(HSWA permit) which required the submittal of a plan to clean up the contaminated
soils around the facility. Despite several submissions of such a plan, none were
approved by EPA due to deficiencies. CT DEP issued a RCRA operating permit to
SRSNE in 1986 with provisions requiring major improvements in the way
hazardous waste was handled, and, establishing emergency procedures and financial
responsibility requirements. SRSNE failed to come into full compliance with these
requirements.
• In the spring of 1988, EPA and CT DEP established a schedule for SRSNE's
implementation of short-term operations improvements, safety improvements, and
long-term activities. Due to insufficient progress by SRSNE, the Agencies
terminated further negotiations with SRSNE in August 1988, and EPA obligated
Superfund monies to conduct its own work on the Site.
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South ington, CT
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• In 1990, EPA filed suit against SRSNE seeking injunctive relief and civil penalties
for violations of the 1983 Consent Decree and SRSNE's RCRA and HWSA
permits. The suit also included claims against SRSNE, its president, and its parent
company, for recovery of response costs and the issuance of a declaratory judgment
under CERCLA.
• In a separate action in January of 1991, the State of Connecticut sought a temporary
injunction against SRSNE for its failure to meet the terms of the existing RCRA
permit. When a temporary injunction was granted, SRSNE was required to meet
specific legal requirements within a specified period of time, or face permanent
closure. One of these requirements was that SRSNE obtain adequate liability
insurance for sudden accidental occurrences by May 28,1991. On May 29,1991,
the Attorney General for the State of Connecticut confirmed that SRSNE had not
obtained the necessary insurance, and the facility was closed permanently.
• EPA initiated a Remedial Investigation/Feasibility Study (RI/FS) in 1990. Between
1990 and 1992, EPA funded three phases of remedial investigations at the SRSNE
Site to determine the nature and extent of contamination at the Site, and to assess
human-health and ecological risks. Sampling results obtained during these
investigations revealed that the soils at the Site contain extensive VOCs
(chlorinated hydrocarbons, ketones, alcohols, and aromatics), semi-volatile organic
compounds (SVOCs), polychlorinated biphenyls (PCBs), dioxins and metals. High
concentrations of VOCs (exceeding federal maximum contaminant levels or MCLs)
were also detected in both overburden and bedrock groundwater underlying the
Operations Area and the Cianci property. Highly-contaminated groundwater was
also found to extend southward from the Cianci property into the Town Well Field,
and eastward beyond the Quinnipiac River. (Halliburton NUS Environmental
Corporation. Final Remedial Investigation Report; Remedial
Investigation/Feasibility Study. SRSNE Site, Southington, Connecticut, May 1994)
• Several rounds of residential well sampling were conducted during the 1990's by
both EPA and CT DEP. Only one location, immediately north and adjacent to the
SRSNE facility, has been found to have elevated levels of VOCs (the chlorinated
solvent trichloroethene) associated with operations at SRSNE. CT DEP supplied
bottled water to this location, until it was connected to the municipal water supply
by the PRP Group.
• In 1990, the Connecticut Department of Public Health (CT DPH) initiated a public
health assessment for the SRSNE Site under a cooperative agreement with the
Agency for Toxic Substances and Disease Registry (ATSDR). CT DPH concluded
that people living within one mile of the contaminated municipal wells had a
slightly higher rate of bladder cancer. This effort culminated in a 1997 study of
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Southington, CT
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cancer incidence in Southington, in response to the observations of a local resident
who believed that there was a higher than usual occurrence of cancer in the area,
CT DPH reported that while Southington as a whole had lower rates of cancers
studied1 in comparison to Connecticut statewide rates, those areas that were likely
exposed to air emissions from SRSNE had slightly higher rates of all cancers
studied in comparison to the areas of Southington that were not exposed. The
results from the study also suggested that female non-Hodgkin's lymphoma may be
associated with exposure to air pollution. The report concluded that environmental
exposures caused by SRSNE had stopped and there is currently no risk to public
health.
• After the SRSNE facility closed in 1991, CT DEP took over the operation of the
On-Site Interceptor System installed by SRSNE in 1985. In July 1992, CT DEP
modified the OIS to include an ultra-violet/oxidation system to treat air emissions.
CT DEP operated the modified OIS until 1995.
• During August and September of 1992, EPA conducted a time-critical removal
action to address potential health threats associated with PCB contamination in soil
and sediment in the drainage ditch on the eastern edge of the Operations Area.
During that effort, approximately 19 drums of contaminated material containing up
to 100 parts per million (ppm) total VOCs and 350 parts per million (ppm) PCBs
were removed.
• Also in 1992, EPA initiated an Engineering Evaluation/Cost Analysis (EE/CA) to
evaluate alternatives that could be implemented as a non-time critical removal
action ("NTCRA 1"). After a public comment period, EPA issued a First Action
Memorandum for Non-Time Critical Removal Action (NTCRA 1) at the Site on
April 1,1993, which required (a) the implementation of a groundwater containment
and treatment system to prevent the migration of contaminated groundwater in the
overburden aquifer; and (b) the performance of certain soil studies to provide EPA
with information for its use in planning and directing future responses at the Site.
This work was performed by the SRSNE PRP Group pursuant to a 1994
Administrative Order on Consent (CERCLA Docket No. 1-94-1045). (ENSR
Consulting and Engineering. Groundwater Technical Memorandum, Soils Study
Report, and Additional Studies Report for the SRSNE Superfund Site. June 1994;
Blasland, Bouck & Lee, Inc. Non-Time-Critical Removal Action, 100%
Groundwater Containment and Treatment System Design Report. December 1994)
• In January 1994, EPA conducted a second time-critical removal action to remove
and dispose of laboratory chemicals and asbestos that SRSNE had abandoned at the
Site.
1 Southington residents who were diagnosed with bladder, kidney, liver, testicular cancer; Hodgkin's
disease, leukemia, or non-Hodgkin's lymphoma between 1968 to 1991 were included in the study.
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Southington. CT
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• Also in 1994, EPA initiated a second EE/CA to evaluate further alternatives that
could be implemented as a non-time critical removal action (NTCRA 2). After a
public comment period, EPA issued a second Action Memorandum for Non-Time
Critical Removal Action at the Site on June 1, 1995, which required among other
things, the implementation of a groundwater containment and treatment system to
minimize the migration of contaminated groundwater in the bedrock aquifer. This
work was performed by the SRSNE PRP Group pursuant to a 1997 Administrative
Order on Consent (CERCLA Docket No. 1-97-1000). Under the 1997
Administrative Order on Consent, the PRP Group also agreed to perform of the
remainder of the RI/FS for the Site. {Blasland, Bouck & Lee, Inc. Non-Time-
Critical Removal Action 2, 100% Groundwater System Design Report. November
1999; Blasland, Bouck & Lee, Inc. Remedial Investigation Report. June 1998;
Draft Feasibility Study. May 2005)
• In 1994, after several years of litigation, the United States reached a cash settlement
of its 1990 lawsuit against SRSNE, its president, and its parent company.
• In 1994 and 1995, the SRSNE PPR Group conducted additional groundwater
monitoring. Their results were consistent with studies performed by EPA in 1990
through 1992, with one notable exception. Concentrations in the bedrock
underlying the Operations Area appeared to have declined by three orders of
magnitude from tens to hundreds of ppm, to tens to hundreds of parts per billion
(ppb). (ENSR Consulting and Engineering. Memorandum to Mr. Bruce Thompson
(de maximis, inc.), Subject: Results of Comprehensive Groundwater Sampling
SRSNE, Southington, CT, March-April 1995. June 19, 1995)
• In 1995, the SRSNE PRP Group implemented a private well monitoring program to
assess the potential impact to private wells as the result of operating NTCRA 1
groundwater extraction system. The results indicated that the NTCRA 1 system had
little or no hydraulic impact on the residential supply wells. (Blasland, Bouck &
Lee, Inc. Private Well Monitoring Report. October 1995)
• In 1996, the SRSNE PRP Group constructed an oxbow-shaped wetland in the
northeast corner of the Cianci property, in the floodplain of the Quinnipiac River, to
mitigate potential impacts to small, isolated wetlands within and adjacent to the
NTCRA 1 containment area.
• In 1998, the SRSNE PRP Group concluded a Remedial Investigation (RI) to
supplement the RI conducted by EPA in 1994. The 1998 RI report presents the
results of calculations regarding the mass of VOCs at the Site and presents an
overview of the appropriateness of a technical impracticability waiver for the Site.
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• During 1998, a full-scale phyioremediation2 pilot was implemented at the Site to
evaluate the potential for that technology to supplement NTCRA 1. The SRSNE
PRP Group planted approximately 1000 young trees within the NTCRA 1 Area of
Containment, The trees have since matured and the study is on-going,
{Phytokinetics, Inc. Phyioremediation Pilot Study at the Solvents Recovery Service
of New England Superfund Site. November 1998)
• In 1999, the SRSNE PRP Group decontaminated, demolished and removed all
remaining original structures within the Operations Area including a modular office,
process building, tank farm, drum storage area, processing area, tank car and trailer
parking area, and two fuel blending tanks.
• In November 2003, the SRSNE PRP Group conducted a field-based investigation to
delineate the occurrence of non-aqueous phase liquid (NAPL) in the overburden
aquifer at the SRSNE Site. The results of this study were used to define an area that
is being targeted for source reduction with this Record of Decision. {Blasland,
Bouck & Lee, Inc. NAPL Delineation Pilot Study. December 2003)
• In May 2005, the SRSNE PRP Group completed the Feasibility Study.
• The SRSNE PRP Group has been operating the NTCRA 1 (overburden) and
NTCRA 2 (bedrock) groundwater containment and treatment system (hereafter,
where appropriate, jointly referred to as the NTCRA 1 and NTCRA 2 Groundwater
Extraction and Treatment System or the NTCRA 1/2 Groundwater System)
continuously since July 1995 and June 1999, respectively. The combined system
has extracted over 85,000,000 gallons of contaminated groundwater to date, and
removed an estimated 12,500 pounds of VOCs.
3. History of CERCLA Enforcement Activities
The SRSNE Site was an EPA fund-lead site until the SRSNE PRP Group agreed to perform
the remainder of the RI/FS, and implement the NTCRA 1 and NTCRA 2 Groundwater
Extraction and Treatment System, pursuant to two Administrative Orders on Consent. A
brief summary of the CERCLA enforcement actions taken to date is provided below.
• A description of EPA's enforcement actions against the owner/operators of the Site
is provided in the previous section of this ROD (History of Federal and State
Investigations and Removal and Remedial Actions).
• Since June 1992, EPA has notified approximately 1700 parties who either owned or
operated the facility, generated wastes that were shipped to the facility, arranged for
2 Pliytoremediation is the biological remediation of contamination using plants.
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the disposal of wastes at the facility, or transported wastes to the facility of their
potential liability with respect to the Site,
• In October 1993, EPA invited all PRPs to perform or finance a non-time critical
removal action, as set forth in the April 1993 Action Memorandum (NTCRA 1).
Negotiations culminated in an Administrative Order on Consent (AOC) with over
250 PRPs, which became effective on October 4, 1994,
• In April 1994, EPA offered an early de minimis settlement offer to 1250 PRPs that
shipped no more than 10,000 gallons of hazardous substances to the SRSNE
facility. Of those 1250 parties, approximately 882 joined the de minimis settlement.
• Due to a variety of circumstances, a number of the PRPs who were otherwise
eligible to participate in the original de minimis settlement did not participate. On
May 31, 1995, EPA offered a supplemental de minimis settlement offer to 58 PRPs,
On September 18, 2005,43 additional de minimis PRPs joined a supplemental de
minimis settlement that contained terms identical to the original de minimis
settlement.
• On June 16,1995, EPA notified all of the PRPs that had not settled their liability in
the prior de minimis settlements of their continuing liability at the SRSNE Site, and
invited them to perform or finance an RI/FS and a second non-time critical removal
action, as set forth in the June 1995 Action Memorandum (NTCRA 2).
Negotiations culminated in a second AOC with over 250 PRPs, which became
effective on February 11,1997.
• The PRPs that are performing response work under the 1994 and 1997 AOCs have
been active in the remedy selection process for this Site. They offered verbal
comments at the public hearing on June 30, 2005, and submitted written comments
during the 60-day comment period. The PRPs' comments are included in the
Administrative Record.
C. COMMUNITY PARTICIPATION
Prior to the PRP Group undertaking actions under the direction of EPA and CT DEP to contain
and treat contaminated groundwater, community concern and involvement was high. As
successful response actions have been taken over the years to address soil and groundwater at the
Site, the level of interest in the community has decreased. At this time, community participation
can be characterized as moderate to low. EPA, CT DEP and the SRSNE PRP Group have kept
the community and other interested parties apprised of Site activities through informational
meetings, fact sheets, press releases, open houses, and public meetings. Below is a brief
chronology of Superfund public outreach efforts since the Site was listed on the National
Priorities List.
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• On July 26,1990, EPA held an informational meeting at Southington High School to
describe the field activities set to begin for the Remedial Investigation (RI).
• On August 23, 1990, EPA announced it had received a letter of intent from the
Southington Association for the Environment (SAFE) to apply for a Technical Assistance
Grant (TAG). EPA invited all citizens' groups interested in applying for a TAG for the
SRSNE Site to consolidate with SAFE and to file a joint application because under
CERCLA, only one TAG at a time can be awarded for a site.
• In June 1991, EPA released a community relations plan that outlined a program to
address community concerns and keep citizens informed about and involved in remedial
activities at the SRSNE site.
• On July 3, 1991, SAFE was awarded a TAG in the amount of $49,600. On September
28,1998, that grant was extended, and SAFE received an additional $25,000.
• On July 18, 1991, EPA held a public informational meeting at the DePaolo Junior High
School to present the findings of the first phase of the RI.
• On May 12, 1992, EPA held an informational meeting at the DePaolo Junior High School
to present the results of the second phase of the RI, and to describe plans for additional RI
work and the Feasibility Study (FS).
• In the early 1990s, EPA made an administrative record file for the SRSNE Site available
for public review at EPA's offices in Boston and at the Southington Public Library, 255
Main Street, Southington, CT.
• On December 16,1992, EPA held a public meeting to announce its intent to take an
interim action (a non-time critical removal action) to minimize the migration of
contaminated groundwater and to reduce soils contamination at the SRSNE site. The
public was invited to comment on this proposal during a 45-day comment ending
February 1, 1993. EPA adjusted its planned action following consideration of public
comments, and issued a First Action Memorandum for Non-Time Critical Removal
Action for the Site (NTCRA 1) along with a Responsiveness Summary on April 3, 1993.
• Throughout 1994 and 1995, EPA held a series of meetings with SAFE and other
members of the public to discuss the results of remedial investigations, and plans for
future actions at the site.
• In 1994, the Unites States held a public comment period concerning its proposed Consent
Decree with SRSNE, its president and its parent corporation.
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• In 1994, the United States held a public comment period concerning its proposed Consent
Decree with approximately 882 de minimis PRPs,
• On December 6, 1994, EPA held a public meeting in Southington at the Red Carpet Inn
to seek comments on a second interim cleanup action (a non-time critical removal action)
proposed for the SRSNE Site. A 30-day comment period was held from December 7,
1994 to January 21,1995. EPA conducted a public hearing to accept written and oral
comments on the recommended alternative on January 5, 1995 at the DePaolo Junior
High School. EPA issued a Second Action Memorandum for Non-Time Critical
Removal Action for the Site (NTCRA 2) on June 1, 1995.
• On June 12, 1995, local residents were invited to walk through the on-site NTCRA 1
treatment facility prior to its coming on line. EPA, CT DEP and the PRP Group
commemorated the startup of the system with a ribbon-cutting ceremony on August 23,
1995.
• In the fall of 1995, the United States held a public comment period concerning its
proposed Consent Decree with 42 de minimis PRPs. The terms of this Consent Decree
were identical to the terms contained in the earlier Consent Decree reached with 882 de
minimis PRPs.
• On July 18,1996, representatives of EPA, CT DEP and the PRP Group held an
informational meeting in Southington at the Comfort Inn to discuss plans for additional
field work.
• On March 18, 1998, the CT DPH held a public meeting at the Southington Public Library
to describe the findings of their recently completed cancer incidence study.
• On June 23, 1998, EPA and the PRP Group held an informational meeting in Southington
at the Holiday Inn to provide an update on the on-going field investigations.
Representatives of the CT DEP and CT DPH also attended.
• On August 14,1999, the PRP Group held an "open house" at the SRSNE Site. The
public was invited to tour the groundwater treatment plant, the mitigation wetlands, the
phytoremediation study area, and the Operations Area. EPA and CT DEP also attended.
• In October 1999, EPA distributed a neighborhood notice advising local residents and
town officials of work at the SRSNE Site.
• In September 2003, EPA completed a preliminary reuse assessment of the Site. EPA
solicited input from town officials and the community on the reasonably-anticipated
future land use and groundwater uses for the reuse assessment.
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• In May 2005, EPA mailed the Proposed Plan to 271 residents, local media and town and
elected officials on EPA's Site mailing list. The Proposed Plan was also mailed to 454
individuals associated with the SRSNE PRP Group,
• On June 10, 2005, EPA published a notice of the Proposed Plan in the Southington
Citizen and announced dates of the comment period and public hearing to accept verbal
comments,
• On June 8,2005, EPA held an informational meeting at the Southington Public Library to
present the Agency's Proposed Plan. At this meeting, representatives from EPA, CT
DEP and the SRSNE PRP Group answered questions from the public.
• From June 9 to July 8, 2005, EPA held a 30-day comment period to accept public
comment on the alternatives presented in the Feasibility Study and the Proposed Plan and
on any other documents previously released to the public. An extension to the public
comment period was requested and on June 29, 2005, EPA issued a press release to
announce that the comment period had been extended to August 8, 2005.
• On June 30, 2005, EPA held a public hearing at the Southington Town Hall to accept
verbal comments on the Proposed Plan, A transcript of this meeting and all written
comments received during the comment period are in the Administrative Record. EPA's
responses to the comments received during the comment period are included in the
Responsiveness Summary, which is Part 3 of this Record of Decision.
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining components of different source control and
management of migration alternatives to obtain a comprehensive approach for Site remediation.
In summary, the final remedy for the SRSNE Site will:
• Treat waste oil and solvents (NAPL) located in the subsurface in the overburden aquifer
by heating them in place. The approximatelyl .5-acre NAPL treatment zone is primarily
in the Operations Area, but extends across the Railroad Right-of-Way and into the Cianci
property near the western (upgradient) end of the culvert (see Figure 5).
• After the subsurface has been treated, the Operations Area/Railroad soil will be capped.
Prior to capping, soil on the Cianci property that exceeds CT remediation standards, and,
wetland soil that exceeds CT remediation standards and poses an ecological risk will be
excavated and moved into the Operations Area/Railroad area to also be capped.
• Capture and treat on site the contaminated groundwater in both the overburden and
bedrock aquifers that exceeds federal drinking water standards and risk-based levels.
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• Monitored natural attenuation of the groundwater plume outside the capture zone that
exceeds cleanup levels.
• Monitor natural degradation of contaminants in the NAPL area of the bedrock aquifer.
• Over time, modification of the configuration of the on-site groundwater extraction and
treatment system, as appropriate, based on expected reductions in contamination,
• Implement restrictions on uses of the site property in perpetuity to prevent human
exposure to contaminants in the subsurface soils and to prohibit activities that might harm
the cap. Implement institutional controls to prevent human exposure to contaminated
groundwater and NAPL areas until federal drinking water standards, risk-based levels,
and CT Groundwater Criteria (Appendix C of the RSRs) are met. These restrictions will
also prohibit construction above groundwater plume that exceeds the State's
volatilization criteria, if remedial design studies confirm the need for such restrictions.
• Monitor groundwater and maintain the cap in the long term. Monitor land use and
groundwater use restrictions to ensure compliance. Perform reviews at least every five
years to ensure that the remedy remains protective of human health and the environment.
The selected remedy also includes the following contingency:
• In the event that the Town of Southington decides to activate municipal production wells
located near the Site prior to attainment of federal drinking water standards and other risk-
based levels throughout the Site, the selected remedy includes a contingent action for
additional groundwater containment.
Principal threat wastes are those source materials considered to be highly toxic or highly mobile
which generally cannot be contained in a reliable manner or would present a significant risk to
human health or the environment should exposure occur. Wastes generally considered to be
principal threats are liquid, mobile and/or highly-toxic source material. The principal threats at
the SRSNE Site that are addressed with this ROD are summarized in the following table:
Medium
Principal Threats
Contaminant(s)
Remedial Action
NAPL in
Overburden Aquifer
Highly mobile
V Source material that will
result in highly toxic
groundwater
Separate-phase VOCs
and other organic
compounds dissolved
in NAPL (e.g., PCBs)
Treat in place ("in-
situ") with thermal
technology.
NAPL in Bedrock
Aquifer
"V Highly mobile
V Source material that will
result in highly toxic
groundwater
Separate-phase VOCs
and other organic
compounds dissolved
in NAPL (e.g., PCBs)
Monitor natural
degradation
processes.
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Southington, CT
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Although groundwater is not considered a "principal threat" as this term is defined in EPA's
guidance (EPA, November 1991), the selected remedy also addresses the contamination in
groundwater because it poses a human-health hazard that exceeds EPA's acceptable risk range.
E. SITE CHARACTERISTICS
This section presents an overview of the Site. A remedial investigation of the Site was done in
three phases. The findings of the first phase that was conducted by EPA are documented in
Remedial Investigation Report, Volumes 1-4, Halliburton NUS, May 1994 ("1994 RI"). The
findings of the second phase, which was conducted by the PRP Group, can be found in Remedial
Investigation Report, Volumes 1-2, Blasland, Bouck & Lee, June 1998 ("1998 RI"). A third
phase was limited to sampling soil on the Cianci property and sediment in the Quinnipiac River.
The results of this additional sampling are summarized in Appendix x of the Feasibility Study,
Volumes 1-4, May 2005, Groundwater at the SRSNE Site has been monitored extensively.
Groundwater was sampled for the 1994 RI, 1998 RI, design and construction of the NTCRA 1
and NTCRA 2 Groundwater Extraction and Treatment System, and twice a year since 1998 as
part of the PRPs obligations under the NTCRA 2 AOC.
The information summarized below can be found in sections 3-5 in the 1994 RI, and Section 3 in
the 1998 RI. Refer also to CT DEP's Groundwater Use and Value Determination (May 2005) for
a more detailed discussion of groundwater use.
1. Physical Setting
Site Geology
The SRSNE Site is located within the Connecticut Valley Lowland section of the New
England physiographic province. The Connecticut Valley Lowland occupies a regional,
structural rift basin, which is characterized by block-faulted and tilted bedrock strata. The
geology of the region, in general, consists of the Upper Triassic New Haven Arkose,
overlain by Wisconsin-age unconsolidated deposits formed when glaciers eroded and
smoothed the bedrock hills.
Directly beneath the SRSNE Site, depth to bedrock varies, from approximately 15 to 40
feet below grade at the Operations Area, to approximately 25 to 45 feet below grade on the
Cianci property, to approximately 80 to 100 feet below grade at the Town Well Field. Core
samples and drilling observations indicate that the upper five feet of the bedrock in the
Operations Area and Cianci property is severely weathered and partially decomposed. The
degree of weathering generally decreases with depth. In the interval between five and 30
feet below the top of bedrock, the bedrock is less weathered but is still highly fractured and
permeable. The fracture spacing generally increases with depth, At depths of 30 feet or
more the rock is characterized by relatively few fractures and may exhibit slightly lower
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hydraulic conductivity. The deep bedrock can transmit groundwater flow, however, and is
the primary zone tapped by private water supply wells north and east of the Site.
The overburden geology beneath the Operations Area and Cianci property consists of two
main unconsolidated layers. The shallow, upper layer, called outwash, extends from
ground surface to approximately 10 to 25 feet below grade and consists of reddish-brown
silty sand and gravel deposits, interbedded with discontinuous layers of silt and relatively
well-sorted sand and gravel. The lower layer consists of glacial till, a generally unstratified
unit consisting of reddish-brown clay, silt, sand, gravel, cobbles and boulders, but also
including isolated, discontinuous sandy seams. Fill materials are present above the outwash
in portions of the Operations Area and Cianci property, where grading operations have
reworked the upper few feet of soil and filled low areas. Fill materials are also observed
along the Railroad Right-of-Way which separates the Operations Area from the Cianci
property. The overburden in the Town Well Field grades to a coarser overall grain size
distribution, lacking fines.
Site Hydro ecology
Depth to the water table ranges from 0 to 10 feet throughout the Site. Groundwater in the
unconfmed overburden aquifer flows east and southeast from the Operations Area toward
the Quinnipiac River. Groundwater in the semi-confined bedrock aquifer is primarily
transmitted in the upper fractured zone, but may also travel in deeper portions of the rock.
Flow in the bedrock is also east and southeast towards the Quinnipiac River.
The overburden aquifer is primarily recharged by precipitation. Recharge to the bedrock
aquifer is also primarily by precipitation. Immediately west and upgradient of the
Operations Area the water table lies within the bedrock. However, some flow between the
aquifers occurs in portions of the Site where the till is especially thin or absent. The
direction of flow and the rate of recharge vary in response to seasonal fluctuations.
Groundwater Classification and Use
Groundwater within the Site is currently classified by CT DEP as GA, GA-Degraded or
GAA (see Figure 3).
Much of the Site is Class GA. Per the CT DEP Groundwater Quality Standards (CT DEP,
April 1996), Class GA is:
"Groundwater within the area of existing private water supply wells or in an area with
the potential to provide water to public or private water supply wells. The Department
presumes that groundwater in [a Class GA] area is, at a minimum, suitable for drinking
or other domestic uses without treatment."
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The GA classification means that the state's goal is to maintain or restore groundwater to
its natural quality. The GA-Degraded classification applies to the Operations Area, Cianci
property and the northern portion of the Town Well Field, Groundwater quality in these
areas is not currently suitable for drinking, but the state's goal is to restore the groundwater
to its natural quality (CT DEP, August 1997),
A small area surrounding municipal Production Well No, 4 and No. 6 is Class GAA. Class
GAA groundwater is . .used or which may be used for public supplies of water suitable
for drinking without treatment; groundwater within the area that contributes to a public
water supply well; and groundwater in areas that have been designated as a future water
supply in an individual utility supply plan." CT DEP notes, however, in its Preliminary
Groundwater Use and Value Determination that the portion of the GAA area near Curtiss
Street does not currently meet Class GA/GAA Groundwater Protection Criteria (CT DEP,
October 1997),
Based on a review of the 1990 CT DEP private well sampling results, the majority of
private wells near the Site are drilled, open-bedrock wells ranging from 90 to more than
200 feet deep. The only known current domestic use of groundwater near the Site occurs in
homes along Lazy Lane to the west of and hydraulically upgradient of the Operations Area.
The private wells historically situated nearest the Site were at the Maiellaro (Mickey's
Garage) property, located approximately 400 feet north of the Operations Area, and the
former Onofrio residence (now the location of the Southington Police Department
building), located across Lazy Lane from the Cianci property. The Onofrio and Maiellaro
wells have been abandoned and the properties have been connected to the municipal water
supply. State public health code prohibits the drilling of new private water supply wells on
properties that are within 200 feet of a municipal water supply line (CT DPH Public Health
Code 2000,19-13-B 51m). Municipal water supply lines run along both Lazy Lane and
Route 10,
Surface Features
Much of the Operations Area (the 4-acre parcel where spent solvents and waste oil were
stored, managed and processed), is paved with asphalt and/or concrete and is completely
enclosed with security fencing. All the original above-ground structures - buildings,
processing equipment, storage tanks and drums - have been removed. All underground
features - septic tanks, storage tanks, utilities - have also been excavated and removed
from the Site. The Operations Area is located approximately 600 feet west of the
Quinnipiac River,
The Cianci property, is a 10-acre parcel immediately east of the Operations Area across the
Railroad Right-of-Way. It is bordered on the eastern edge by the Quinnipiac River, and
fenced on the other three sides. Prior to NTCRA 1, this property did not contain any
permanent features. A gravel access road and the NTCRA 1 groundwater containment
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system (including a 700 foot x 30 foot sheet-pile wall installed into bedrock) and treatment
building were constructed on the Cianci property (Figure 2).
The Town Well Field is 28 acres of undeveloped land directly south of the Cianci property.
A Connecticut Light and Power (CL&P) electrical transmission line easement cuts across
the northern portion of the well field.
A network of monitoring and recovery wells is distributed across the Site.
The terrain at the SRSNE Site is generally flat with a gentle downslope toward the
Quinnipiac River. The Site comprises riverine, wetland and upland habitats. The majority
of the wetland communities are associated along the eastern border of the Site along the
floodplain of the Quinnipiac River. A constructed wetland was built in the northeastern
corner of the Cianci property as mitigation for any losses to wetlands associated with
NTCRA 1 activities. The vegetation along the river is dominated by mature deciduous
trees with a fairly dense understory of deciduous shrubs. The river banks have moderate to
dense vegetation of saplings and shrubs. Wetland types include forested-scrub/shrub and
scrub/shrub emergent palustrine wetlands. Upland habitat types consist of old fields and
small deciduous woodlots, including a stand of trees associated with the phytoremediation
pilot. The powerline right-of-way is characterized by low shrubs and grasses.
There are no areas of architectural or historical importance.
2, Conceptual Site Model
The sources of contamination, release mechanisms, and exposure pathways to receptors for
the soil, wetland soil, groundwater, surface water, sediment and air, as well as other site-
specific factors, are considered while developing a Conceptual Site Model (CSM). The
CSM is a three-dimensional "picture" of site conditions that identifies contaminant sources,
release mechanisms, exposure pathways, migration routes, and potential human and
ecological receptors. It documents current and potential future site conditions and shows
what is known about human and environmental exposure through contaminant release and
migration to potential receptors. The risk assessment and response action for all
environmental media at the SRSNE Site are based on this CSM.
The mechanisms governing fate and transport of contaminants from the source areas to
other parts of the Site are numerous and complex. The chemical and physical properties of
the various contaminants present and the complicated geologic and hydrogeologic
conditions at the Site influence the migration of contaminants within and between the soils,
groundwater, and surface water. The CSM identified several pathways for contaminant
transport from the point of release to environmental media throughout the study area.
These are summarized below. A more complete discussion of contaminant fate and
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transport at the SRSNE Site can be found in Section 5 of the 1994 RI (Halliburton NUS)
and Section 4.4 of the 1998 RI (BBL).
Waste oils, solvents and other liquids containing contaminants seeped into the soils in the
Operations Area through the unlined lagoons and leaks and spills onto bare ground, and
migrated downward under the influence of gravity. Some of the contaminants adsorbed to
the soils or partitioned into the soil pore spaces while others continued downward to the
water table. Contaminants remaining in the soil could later be mobilized through contact
with precipitation or rising groundwater. The highly contaminated soils in the Operations
Area, therefore, act as continuing sources of contamination to the overburden and bedrock
aquifers, and to down gradient soils.
Contaminants that migrate into the overburden aquifer have several available migration
pathways. Contaminants may migrate vertically downward into the bedrock aquifer or
horizontally through the unconsolidated overburden units. The vertical transport of
contaminants can also be reversed as upward hydraulic gradients can move contaminated
groundwater from the bedrock to the overburden in areas where there are till windows. The
lateral migration of contaminants in both the overburden and bedrock aquifers is
predominantly east and southeast, toward and beneath the Quinnipiac River. East of the
Quinnipiac River, in the vicinity of Route 10, contaminated overburden and bedrock
groundwater converge with groundwater traveling westward; the converged flow then
travels to the south and southwest. Groundwater in the upper portion of the overburden
aquifer flows into the Quinnipiac River. Groundwater in the lower portion of the
overburden aquifer and in the bedrock aquifer flows under the Quinnipiac River. The
current extent of the groundwater plumes can be found in Figures 4 and 5.
Prior to 1980, direct discharge pathways for contaminated transport to surface water,
sediment, and soil included overflow from the SRSNE facility lagoons, runoff of spilled
contaminants and the discharge of the partially treated effluent from the SRSNE cooling
tower/air stripper to the drainage ditch and ultimately onto the surface of the Cianci
property. After 1980, the flow was channeled from the drainage ditch, through the
underground culvert beneath the Cianci property, and into a wetland adjoining the
Quinnipiac River. Today, cracks in that culvert allow contaminated groundwater to flow
directly into the wetland and eventually the river itself.
3. Nature and Extent of Contamination
As stated in the introduction to Section E, the remedial investigation was conducted in
three phases. The information provided below is a compilation of data from all three.
Overview of Chemical Compounds Detected
* Volatile Organic Compounds (VOCs). The VOCs identified in soil and
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groundwater at the SRSNE Site, as shown in Table E-l, can be separated into three
major groups: chlorinated hydrocarbons, aromatic hydrocarbons, and ketones.
• Semi-Volatile Organic Compounds (SVOCs). The SVOCs identified in soil and
groundwater at the SRSNE Site, as shown in Table E-l, can also be separated into
three major groups: polynuelear aromatic hydrocarbons (PAHs), phthalates, and
phenolic compounds. Other SVOCs constitute only a few compounds.
• Pesticides and Polychlorinated Biphenyls (PCBs).
• Metals. The analytes of interest are heavy metals that may have potential health
effects or may affect environmental receptors. These metals include arsenic,
cadmium, chromium, cobalt, lead, nickel and zinc.
Although VOCs are not the only contaminants of concern at the Site, they present a major
long-term threat to the quality of groundwater in both the dissolved phase and undissolved
(i.e., NAPL) phase. The total mass of VOCs at the Site is thought to be distributed
approximately as follows:
Soil and Wetland Soil: < 1%
NAPL in Overburden Aquifer: 84%
NAPL in Bedrock Aquifer: present, but extent not defined
Dissolved in Overburden Groundwater: 2%
Dissolved in Bedrock Groundwater: 13%
Soil and Wetland Soil
During the 1994 RI, soil samples were taken from the Operations Area, Cianci property, the
drainage ditch between the Operations Area and Cianci property, the Quinnipiac River
floodplain and associated wetlands, the Town Well Field and upgradient (background)
locations. Abroad range of VOCs, SVOCs, metals, pesticides and PCBs were found in soil
across the Site. Some of the more frequently detected compounds are listed below, with
their maximum concentrations.
• 2-butanonc (38,000 ppb)
• 1,2-dichloroetetrachloroethene (440,000 ppb)
• 1,1,1 -trichloroethane (690,000 ppb)
• trichlorothene (800,000 ppb)
• toluene (1,700,000 ppb)
• total xylenes (760,000 ppb)
• benzo(a)anthraccne (490 ppb)
• benzo(b)fluoranthene (1,800 ppb)
• benzo(k)fluoranthene (1,800 ppb
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Southiriflton, CT
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• bis(2-ethylhexyl)phthaiate (120,000 ppb)
• chrysene (600 ppb)
• fluoranthene (1,100 ppb)
• phenanthrene (1,500 ppb)
• benzo(a)pyrene (740 ppb)
• pyrene (800 ppb)
• aroclors (13,000 ppb)
• 4,4'-DDE (27 ppb)
• 4,4'-DDT (28 ppb)
• Arsenic (9.7 ppm)
• Cadmium (389 ppm)
• Chromium (183 ppm)
• Cobalt (13.7 ppm)
• Lead (1,750 ppm)
• Nickel (67.8 ppm)
• Zinc (204 ppm)
Surficial soils (0 to 6 inches) at the Site were essentially free of VOC contamination, PAHs
were the predominant SVOCs detected in surficial Site soils and they were found in the
drainage ditch, on the Cianci property and in areas adjacent to the Quinnipiae River.
Phthalates were also detected in significant numbers and concentrations in the drainage
ditch and in wetland soils near the culvert outfall to the Quinnipiae River. Relatively low
concentrations of a few other SVOCs were detected in samples from the Cianci property
and the Town Well Field. Pesticides were found in surficial soil throughout the Site with
no apparent distribution of type or concentration, PCBs were detected at the culvert outfall
location. Elevated concentrations of metals were detected primarily in the drainage ditch
and wetlands at the culvert outfall, Metals present at elevated concentrations include
barium, cadmium, chromium, lead and silver. Metal concentrations from surficial soils
from the western side of the Cianci property and the Town Well Field were generally
comparable in variety and concentration to those detected in upgradient samples. The
samples taken in the Operations Area are primarily subsurface samples, as the majority of
the area is paved.
Elevated levels of numerous VOCs were detected in subsurface soils throughout the
Operations Area, the southern half of the Cianci property, and the northern portion of the
Town Well Field. In general, the highest VOC concentrations and greatest number of VOC
compounds were detected in subsurface soils in the Operations Area. Chlorinated and
aromatic hydrocarbons comprised the majority of the VOC contamination in the subsurface
soils in the Operations Area. Fewer VOCs and generally lower concentrations were
detected in the Cianci property and the Town Well Field. Ketones were the predominant
VOCs detected in these two areas, and tended to be greater in deeper soils (>16 feet) than in
shallow soils, SVOCs and PCBs in subsurface soils seem to be fairly limited to the
Operations Area. The SVOCs consist of primarily several PAHs and phthalates; a few
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Southing ton, CT
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phenolic compounds and other SVOCs were also detected. Subsurface soils appear to be
generally free of pesticide contamination.
Elevated concentrations of metals in subsurface soils were detected primarily in the
Operations Area, near the locations of the former SRSNE facility lagoons and open-pit
incinerator. Cadmium was detected at elevated concentrations at greater frequency and
over a wider area than any other metal and was found in subsurface soils in the Operations
Area, Cianci property and the Town Well Field.
Subsurface soil from eight locations in the Operations Area was collected for dioxin/furan
analysis. Relatively low concentrations (0.002 - 0.30 ppb) were detected in four samples.
A supplemental round of soil sampling was conducted on the Cianci property in 1999 to
provide additional data for the risk assessment and to obtain leaching-based inorganics
analytical data to compare to CT DEP's pollutant mobility criteria (PMC). The data
collected was consistent with earlier rounds.
Non-aqueous Phase Liquid fNAPL)
Dense non-aqueous phase liquid (DNAPL) has been found in the subsurface at the SRSNE
Site. Light NAPL (LNAPL) has also been detected but in relatively minor amounts,
DNAPL is by far the more significant source of continued degradation of groundwater.
The 1998 RI Report (BBL, section 4.2.1) delineated two levels of relative NAPL likelihood
for both the overburden and bedrock aquifers for purposes of a Technical Impracticability
evaluation:
* Probable NAPL zone is that region of the subsurface where NAPL is either
confirmed to be present, or very likely to be present. This delineation was based on
site history, direct observation, presence of alcohols, and a greater than 10%
effective solubility of chemicals in groundwater (or calculated pore-water
concentrations in saturated soil samples >100%).
• Potential NAPL zone is that region of the subsurface where NAPL may be present,
but site data do not yield conclusive evidence that it is present. This delineation
was based on effective solubility greater than 1% but less than 10% in groundwater
(or calculated pore-water concentrations in saturates soil samples between 10% and
100%), the presence of VOCs in hydraulically anomalous locations, and areas
where an abrupt change in contaminant chemistry was observed.
Figure 6a shows the lateral extent of these two NAPL zones in the bedrock. The
probable bedrock NAPL zone covers an area of approximately 260,000 square feet (~ 6
acres) and the potential bedrock NAPL zone extends 618,000 square feet (~ 14 acres).
The depth of NAPL in the bedrock was not delineated during the RI.
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SoutHington, CT
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Additional field work was performed to further refine the presence and distribution of
pooled and residual NAPL in the overburden, based on visual observations of NAPL in
soil borings as well as field screening techniques (PID, Oil Red O dye, etc). The
purpose of this work was to delineate an area and volume of greatest NAPL
concentration in the overburden for evaluating source control technologies in the FS.
The end result was the area called the Overburden NAPL Area that is approximately 1.5
acres and 47,000 cubic yards and is shown in Figure 6b.
The physical properties and chemical composition of DNAPL were quantified based on
samples obtained from groundwater monitoring wells during the RI and a June 2003
compliance monitoring event. The density of the DNAPL in those samples is relatively
close to that of water (ranging from 1,068 to 1.23 g/cm3) which suggests that DNAPL at
those locations would be relatively easy to mobilize, where present in pools. Total
VOC concentrations ranged from 899,000 ppm to 99,800 ppm.
Groundwater
The data summarized below comes largely from the 1994 RI, which reflects conditions at
the Site prior to implementation of groundwater pumping as part of the NTCRA 1 and
NTCRA 2 Groundwater Extraction and Treatment System. Groundwater from the
overburden and bedrock aquifers was sampled, from locations in the Operations Area,
Cianci property, and the Town Well Field, as well as upgradient and cross-gradient
locations. A broad range of VOCs, SVOCs, metals, pesticides and PCBs were found in
groundwater across the Site. Some of the more frequently detected compounds are listed
below, with their maximum concentrations from the 1994 RI.
• Benzene (610 ppb)
• Carbon tetrachloride (9,100 ppb)
• Chlorobenzene (39 ppb)
• Chloroethane (1,100 ppb)
• 1,2-dichloroethane (940 ppb)
• 1,1-dichloroethene (15,000 ppb)
• cis-1,2-dichloroethene (110,000 ppb)
• trans-1,2-dichloroethene (3,700 ppb)
• ethylben/ene (60,000 ppb)
• 4-methyl-2-pentanone (22,000 ppb)
• Styrene (49,000 ppb)
• Tetrachloroethene (6,400 ppb)
• Toluene (150,000 ppb)
• total xylenes (6,800 ppb)
• trichloroethene (41,000 ppb)
• 1,1,1 -trichloroethane (320,000 ppb)
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• Vinyl chloride (7,300 ppb)
• bis(2-ethylhexyl)phthalate (11,100 ppb)
• di-n-butylphthalate (52 ppb)
• 2,4-dimethylphenol (66 ppb)
• 2-methylphenol (92 ppb)
• Phenol (4,200 ppb)
• 4-methylphenol (760 ppb)
• Naphthalene (47 ppb)
• Aroelors (85 ppb)
• Arsenic (49 ppb)
• Barium (20,400 ppb)
• Cadmium (76.9 ppb)
• Chromium (764 ppb)
• Cobalt (390 ppb)
• Copper (1570 ppb)
• Manganese (43,330 ppb)
• Nickel (792 ppb)
• Vanadium (1,260 ppb)
• Zinc (11,700 ppb)
Overburden Groundwater. The highest VOC and SVQC concentrations found in the
overburden aquifer during the 1994 RI were in the Operations Area, particularly in the area
of the SRSNE facility lagoons. The plume of elevated VOCs extends from the Operations
Area, through the southern portion of the Cianci property and into the northern portion of
the Town Well Field. In the southern portion of the Town Well Field, VOCs are detected
at low concentrations which are below federal drinking water standards. The plume of
elevated SVOCs also extends from the Operations Area into the southern Cianci property
but only trace amounts of SVOCs are detected in the northern Town Well Field.
Groundwater in the northern portion of the Cianci property - upgradient of the Operations
Area - appears to be free of VOCs and SVOCs.
All metals in the upgradient well were also present in samples taken from the overburden
aquifer in the Operations Area. Several metals that were detected at higher concentrations
in the area of the lagoons include arsenic, barium, calcium, cadmium, cobalt, lead,
manganese, potassium, and sodium. PCBs were found at one location in the Operations
Area, again near the lagoons, and no pesticides were detected. As was the case with the
VOCs and SVOCs, elevated levels of metals were found on the Cianci property directly
downgradient of the Operations Area and in the Town Well Field. The metals and their
concentrations were similar to those found on the Operations Area. No pesticides or PCBs
were detected in the overburden aquifer on the Cianci property or the Town Well Field.
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Soulhinglon, CT
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September 2005
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The data from the 1994 RI suggest that in the overburden aquifer, contamination migrated
away from the Operations Area to the east and southeast across the southern portion of the
Cianci property, into the Town Well Field, towards the Quinnipiac River. During the 1998
RI, elevated levels of some VOCs and SVOCs similar to those found in the plume
extending from the Operations Area to the Cianci property were detected in the middle
stratum of the overburden aquifer east of the Quinnipiac River. This suggests that some
contaminants are migrating under the Quinnipiac River. VOCs have also historically been
detected in the deep overburden aquifer and shallow bedrock aquifer northeast of the Site
near the comer of Lazy Lane and Queen Street.
Bedrock Groundwater, Unlike in the overburden aquifer, data from the 1994 RI showed
significant differences in VOC concentrations at individual locations in the bedrock
aquifer. This condition may be the result of the nature of the bedrock fractures in
combination with how contaminants are transferred into the bedrock aquifer. The
individual bedrock fractures are likely to have higher hydraulic conductivities than the
overlying stratified soils, and would allow faster passage of groundwater and contaminants
than in the overburden aquifer. Till windows in the unconsolidated unit provide a
preferential pathway for the migration of contaminants between the overburden and
bedrock aquifers. Contaminant concentrations are less likely to experience reductions since
there is less dilution from mixing with cleaner groundwater and less adsorption to soil.
Generally speaking, the data collected during the 1994 RI suggest that highly chlorinated
(tri- or tetra-) VOCs have migrated farther in the bedrock aquifer than in the overburden
aquifer. The highest VOC concentrations found in the bedrock aquifer were in the central
portion of the Operations Area, downgradient of the former tank farm and near the location
of the former lagoons. Around the periphery of the Operations Area, significantly lower
VOCs were detected. Contaminants likely entered the bedrock aquifer directly through a
till window in the Operations Area, Two major components of flow influenced the
migration of VOCs in bedrock. First, contamination migrated from the Operations Area
east and southeast across the southern Cianci towards the Quinnipiac River. Second, a
gradient with a strong southerly component resulted in a narrow plume of elevated VOCs
extending from the Cianci property deep into the Town Well Field. Unlike the overburden,
VOCs in low concentrations were detected in bedrock wells in the northern Cianci property
as well. It is thought that a deep pumping well on the Cianci property near Lazy Lane
influenced the migration of the plume in bedrock. VOC concentrations in the bedrock in
the Operations Area and Cianci property are higher than in the overburden; shallow
portions of the bedrock aquifer are generally more contaminated than deeper portions. Low
concentrations of VOCs are present throughout the shallow bedrock aquifer in the Town
Well Field. The only area of significant SVOC contamination is the southern Cianci
property; here, concentrations are comparable or higher to those found in the overburden
aquifer, and, the shallow bedrock is generally more contaminated than the deeper bedrock.
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Soufhington, CT
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As with SVOCs, the Cianci property bedrock has significant concentrations of PCBs and
pesticides, whereas the rest of the Site is relatively free of these contaminants. The PCBs
were found in the bedrock aquifer in one location, likely due to high VOC solvents and
possibly surfactants causing PCBs to be soluble in groundwater.
Metals concentrations in the bedrock aquifer are elevated in the Operations Area, Cianci
property and northern Town Well Field, In general, more metals and in higher
concentrations were detected in the Operations Area bedrock wells than in upgradient and
cross-gradient wells, and these were in the area of the lagoons and open pit incinerator.
Metals in the Operations Area bedrock tended "to be at comparable or lower concentrations
to metals found in Operations Area overburden groundwater. In the southern portion of the
Cianci property, immediately downgradient of the Operations Area, fewer metals at
comparable or lower concentrations were detected, however, closer to the river, metals
were at comparable or higher concentrations to those found in the bedrock in the
Operations Area. More metals at higher concentrations were detected in the northeast
portion of the Town Well Field than in upgradient wells, and were comparable or a bit
higher in concentration than the Operations Area bedrock.
Mercury and cadmium were not detected in the background wells but were in the
Operations Area. Other metals detected in background locations include arsenic, barium,
calcium, chromium, copper, manganese, nickel, potassium, sodium, vanadium and zinc
were also detected in the Operations Area and locations downgradient from the SRSNE
facility. Lead was found in both Site wells and background wells though in higher
concentrations in Site wells.
NTCRA 1 and NTCRA 2 Groundwater Extraction and Treatment System. As discussed
earlier, groundwater in both the overburden and bedrock aquifers is currently being
contained by the NTCRA 1 and NTCRA 2 Groundwater Extraction and Treatment System.
Figure 4 shows the extent of the groundwater plume in the overburden aquifer. Figure 5
shows the extent of the groundwater plume in the bedrock aquifer.
Since 1995, the NTCRA 1/2 Groundwater System has extracted over 85,000,000 gallons of
contaminated groundwater, and removed an estimated 12,500 pounds of VOCs. Influent
concentrations average 16.1 ppm (range <1 to 77.9 ppm) of total combined VOCs,
including primarily 1,2-DCE, toluene, 1,1,1-TCA, ethylbenzene, xylenes and vinyl
chloride. Alcohols, ketones and tetrahydrofuran have also been detected in the influent
during operation of only the NTCRA 1 wells. Since the NTCRA 2 wells have come on
line, these compounds are typically below detectable levels
Surface Water and Sediment
During the 1994 RI, surface water samples were collected from the eastern drainage ditch
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Southington, CT
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September 2005
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along the Railroad Right-of-Way between the Operations Area and Cianci property, at the
culvert outfall, the Quinnipiac River, and wetlands adjacent to the Site. Samples in the
river were taken from locations both upstream and downstream of the Site. Sediment
samples were also taken from the Quinnipiac River.
Surface water in the Quinnipiac River does not seem to have been impacted significantly by
activities at the SRSNE Site. No VOCs were detected either upstream or downstream of
the Site. Bis(2-ethylhexyl)phthalate was detected at the upstream and one downstream
sampling location; no other SVOCs were detected. Neither pesticides nor PCBs were
detected downstream of the Site, Metals detected in downstream locations were similar to
those found in the upstream sampling location and generally were in the same range of
analyte concentrations. Sediment collected from the Quinnipiac River does not appear to
be significantly impacted by activities on the Site. The riverine sediments have low
concentrations of a few VOCs; and the concentration and distribution of SVOCs,
pesticides, PCBs and metals were similar among upstream and downstream sampling
locations.
Surface water collected from the drainage ditch and the culvert outfall does appear to have
been impacted significantly by activities on the Site. The greatest number of VOCs in
surface water was detected in the drainage ditch, as were the highest concentrations of
metals. Also present in surface water at the drainage ditch and the culvert outfall were
pesticides, PCBs, and low concentrations of SVOCs.
Since 1998, three surface water points along the Quinnipiac River, adjacent to the Site have
been sampled twice a year by the PRP Group. The data is consistent with that collected for
the 1994 RI. The PRP Group also conducted supplemental sediment investigations in the
Quinnipiac River to support the interpretation of the 1994 ecological risk assessment. That
data too supported earlier conclusions regarding the minimal impacts of the Site on riverine
sediments.
Soil Gas
A soil gas survey was conducted as part of the 1994 RI. The results indicated that VOCs of
varying types and concentrations were detected throughout the Site. The highest
concentrations were detected along the eastern perimeter of the Operations Area.
Relatively high concentrations of VOCs were present in soil gas in the northern portion of
the Town Well Field and throughout the southern half of the Cianci property. Low
concentrations of VOCs were detected in the northern portion of the Cianci property and
throughout the remainder of the well field. Among the VOCs detected were trans-1,2
dichlorocthcne; 1,1,!-trichloroethane; 1,1,2,2,-tetrachloroethane; tetrachloroethene;
toluene; and ethylbenzene. The presence of specific VOCs in soil gas correlated with
VOCs detected in groundwater and soil samples from the same geographic locations.
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Southington, CT
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September 2005
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4. Principal Threat Waste
Principal threat wastes are those source materials considered to be highly toxic or highly
mobile which generally cannot be contained in a reliable manner or would present a
significant risk to human health or the environment should exposure occur. The manner in
which principal threats are addressed generally will determine whether the statutory
preference for treatment as a principal element is satisfied. Wastes generally considered to
be principal threats are liquid, mobile and/or highly-toxic source material. Source material
is defined as material that includes or contains hazardous substances, pollutants or
contaminants that act as a reservoir for migration of contamination to groundwater, surface
water, air or acts as a source for direct exposure.
The principal threat waste at the SRSNE Site is:
• Overburden and Bedrock NAPL. Waste oil and solvents in the form of non-aqueous
phase liquid (NAPL) in the unconsolidated deposits in the overburden aquifer and
in the fractured arkosic sandstone in the bedrock aquifer are principal threats due to
toxicity and mobility. The NAPL presents a potential human-health hazard through
direct contact. The NAPL also presents a significant on-going source of
contamination to groundwater, a potential future source of drinking water.
Although groundwater is not considered a "principal threat" as this term is defined in EPA
guidance (EPA, November 1991), the selected remedy also addresses the contamination in
groundwater because it poses a human-health hazard that exceeds EPA's acceptable risk
range.
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
The current and anticipated future uses of the Site form the basis for the exposure assumptions
that are used for the risk assessment; are considered in the development of remedial objectives
and remedial alternatives; and are considered in the selection of the appropriate remedial action.
The future land use assumptions are based on interviews EPA conducted with stakeholders,
including local residents and town officials, as well as review of Town of Southington Zoning
Regulations, the Enterprise Zone designation, and current deed restrictions for a preliminary
reuse assessment (EPA, September 2003).
The future groundwater use assumptions are based on the State's groundwater classification, for
purposes of the exposure assumptions used for the risk assessment. For purposes of the
development of remedial objectives and selection of the remedial action, EPA considered the
State's groundwater classification, the State's Groundwater Use and Value Determination (which
is an evaluation prepared by the State to support EPA's RI/FS and remedy selection), as well as
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Soulhirtgton, CT
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interviews EPA conducted with town officials as part of the preliminary reuse assessment, in
order to evaluate the relative value of the aquifer and the time frame needed for restoration
The future surface water use assumptions are based on the State's surface water classification.
Information on the current and potential future uses of land, groundwater and surface water is
summarized below.
1. Land Use
Currently, use of the Site is limited to activities that support on-going groundwater
remediation3. The Operations Area, Cianci property, and Railroad Right-of-Way (i.e., the
parcels where contaminated soils are found) are vacant with the exception of infrastructure
associated with the two NTCRAs. A groundwater treatment building and 700-foot long by
30-foot deep sheet-pile wall installed to the top of bedrock are located on the Cianci property.
A network of groundwater monitoring and recovery wells is located on the Operations Area
and Cianci property (as well as the Town Well Field).
With respect to the Railroad Right-of-Way, the reasonably anticipated future use of the
Railroad Right-of-Way is for recreational purposes. Specifically, there is a strong interest in
redeveloping the Railroad Right-of-Way to create a multi-purpose public path, known as a
"rails-to-trails" greenway, CT DEP has worked on over 100 miles of rails-to-trails projects in
the State of Connecticut. The State's goal, along with other governmental and non-
governmental agencies, is to extend the current trail along the rail corridor in Connecticut,
known as the Farmington Canal Heritage Trail, from New Haven, CT, to the Massachusetts
border. Within the Town of Southington, the Town has received a $1.5 million grant to
complete the rails-to-trails section that runs from the Plantsville section of Southington, north
through the downtown area, and ends in a residential area at the southern end of the Town
Well Field. Town officials in Southington expressed strong commitment to a plan for reuse
of the Railroad Right-of-Way that runs through the Site as a component of the existing rails-
to-trails project.
With respect to the Operations Area (four acres) and Cianci property (ten acres), the
reasonably anticipated future use of these parcels is uncertain. In short, local officials and
community members did not provide any clear or consistent plans for the reuse of these
parcels. These parcels (along with the Railroad Right-of-Way) are currently zoned for
J Pursuant to the 1994 Consent Decree between EPA arid SRSNE, its president and its parent company, all
uses of much of the site property are currently prohibited until EPA issues its Certification of Completion of the
cleanup of the Site. However, EPA's ROD is written as if these restrictions did not exist. EPA has not included a
discussion of these restrictions in order to: (1) simplify the issues to be addressed; and (2) analyze the nature of the
restrictions that will be needed over the long-term. It should also be noted that the Institutional Controls described in
the selected remedy portion of this ROD (Section L) will require modifications to the restrictions required by the
1994 Consent Decree.
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Southington. CT
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commercial/industrial use. Land use within the immediate vicinity of the SRSNE Site is
mixed residential, commercial and light industrial, and is expected to remain so.
As explained in below in Section G of this ROD (risk assessment section), EPA's baseline
risk assessment estimates potential future risks at the Site based on assumptions that the Site
is reused for residential, recreational/trespasser, and industrial/commercial future land use
scenarios. In developing remedial objectives, remedial alternatives, and selecting the
remedial action, EPA has developed a remedial approach that will facilitate the use of the
Railroad Right-of-Way for recreational purposes.
Given the clear desire to reuse the Railroad Right-of-Way for recreational purposes, with an
uncertain plan for the reuse of the Operations Area and the Cianci property, EPA concluded
that these three parcels all should be cleaned up to facilitate recreational use. This approach
was selected because the Railroad Right-of-Way crosses the Site; because recreational use
would be protective; and because selection of multiple uses resulting in multiple soil cleanup
standards would be overly complicated given the relatively small size of these parcels.
Finally, in selecting a cleanup that will facilitate land reuse for recreational purposes, it
should be noted that Connecticut requires cleanup to residential standards where land use has
been identified as recreational. For this reason, in discussing land reuse in the remainder of
this ROD, EPA uses the term "recreational/residential reuse,"
2. Groundwater
Groundwater at the Site is currently not being used for drinking water. Approximately 85
residences on Lazy Lane, Melcon Street, Curtiss Street, Juniper Road, Little Fawn Road and
Carrier Court are on domestic supply wells, however, all these properties are to the west of
and hydraulieally upgradient of the SRSNE Site. The commercial/residential property closest
to the Operations Area, the Southington Police Department building located across Lazy
Lane, the treatment building on the Cianci property, and the commercial/light industrial
properties along Route 10 are all on public water. The Town of Southington's 50-year water
supply plan states that additional sources of water are not expected to be needed until 2020 or
later (Lenard, April 1996). The Town Well Field is located down gradient of the SRSNE Site.
The potential beneficial use of the groundwater at the Site and surrounding areas is for
drinking water. The groundwater at the Site has been classified by CT DEP as GA, GA-
Degraded or GAA (Figure 3). The State's goal for this aquifer is to maintain or restore the
groundwater to its natural quality, suitable for drinking or other domestic uses without
treatment (CT DEP, 1997). Former Production Wells No. 4 and No. 6 are located within this
aquifer but were shut down a number of years ago after contamination was discovered.
In its Groundwater Use and Value Determination (which is an evaluation prepared by CT
DEP to support the RI/FS and remedy selection), CT DEP concluded that the aquifer
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Southington, CT
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underlying the Site and the surrounding areas are of high use and value. The primary factors
which led the State to assign a high use and value to this aquifer were based on quantity and
the likelihood and identification of future water use. In particular, CT DEP's evaluation
indicates that the "quantity" was of high value due to the productivity and yield of the
aquifer. In addition, CT DEP's evaluation indicates that the "likelihood and identification of
future drinking water use" was high due to the fact that the Town of Southington continues to
identify Production Wells No. 4 and No. 6 as inactive sources of water supply and that the
Town has not currently secured any additional water supply sources for future use. Finally,
CT DEP determined that immediate restoration of the aquifer is not required as long as
adequate protection is provided to contain the contaminated groundwater plume.
In connection with EPA's preliminary reuse assessment, EPA met with the Town to discuss
future potential uses of the groundwater. The Town reported that although Production Wells
No. 4 and No. 6 are closed, the Town has not abandoned these wells and it considers its
diversion right (i.e., its right to use the wells) to be a valuable asset. The Town continues to
evaluate its options for future residential and industrial water supply needs.
Based on the State's classification of the groundwater and its use and value determination for
the groundwater, together with the fact that the Town has not currently secured other sources
for future drinking water supply, EPA considers the potential beneficial reuse of the
groundwater at the Site and in the surrounding area (i.e., Production Wells No, 4 and No. 6)
to be drinking water. As explained in Section G of this ROD (risk assessment section),
EPA's baseline risk assessment estimates potential future risks at the Site based on
assumptions that the beneficial use of the groundwater is for drinking water (consistent with
the State's classification of the groundwater). This goal is carried through in the
development of remedial objectives, remedial alternatives, and in the selection of the
remedial action, with particular emphasis on the high value of the aquifer as a potential
public drinking water supply for which immediate restoration is not required as long as the
contaminated groundwater plume is contained.
3. Surface Water
The Quinnipiac River is not used as a drinking water supply. Adjacent to and south of the
SRSNE Site there is limited access to the Quinnipiac River as it is a narrow, shallow meander
bordered by steep banks along Queen Street to the east and the Town Well Field and fenced
Cianci property to the west. Seasonally low water and lack of access leads to little to no
recreational use of the river in the vicinity of the Site. Downstream of the Site, the
Quinnipiac River is used for recreation from Southington to its mouth in New Haven Harbor.
Two recreational areas within the Town of Southington, but at least two miles downriver of
the SRSNE Site, provide public access to the river, including canoe access points. A fish
consumption advisory was placed on the Eight Mile River and the stretch of the Quinnipiac
River north of the Cheshire Gorge after the discovery of a PCB release site in Plantsville. It
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was advised that all species of fish not be eaten due to unacceptably high levels of PCBs in
the fish tissue (CT DEP, 1998).
Surface water along the Quinnipiac River adjacent to the Site is currently classified by CT
DEP as Class C/B (CT DEP, 1992). This means that the state's goal for this surface water
body is Class B, though it is currently degraded to Class C. Class B surface waters are
designated for recreational use, fish and wildlife habitat, agricultural and industrial supply,
and other legitimate uses including navigation. Conditions that result in a Class C
designation are usually correctable, and commonly relate to combined sewer overflows,
urban runoff, inadequate municipal or industrial waste-water treatment, and community-wide
septic system failures (CT DEP, 1992)
Based on the State's classification, EPA considers the potential beneficial reuse of the surface
water to be for recreational use, fish and wildlife habitat, agricultural and industrial supply,
and other legitimates uses including navigation. As explained in Section G of this ROD,
EPA's baseline risk assessment estimates potential future risks at the Site based on
assumptions that the beneficial use of the surface water is consistent with this goal, including
recreational use. This goal is carried through in the development of remedial objectives,
remedial alternatives, and in the selection of the remedial action.
~ ~ ~
Based on current and anticipated future land and groundwater use discussed above, the following
exposure scenarios were considered for the human-health risk assessment (Section G):
Groundwater
• Future human consumption of groundwater.
Soil and Wetland Soil
• Incidental ingestion, inhalation and dermal contact with soil.
• Incidental ingestion and dermal contact with wetland soil.
• Residential, recreational, and industrial/commercial future land use scenarios were
evaluated.
Surface Water
• Incidental ingestion and dermal contact with surface water while swimming in the
Quinnipiac River or wading in its associated wetlands.
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Sediment
• Incidental ingestion and dermal contact with sediments while swimming in the
Quinnipiac River.
Biota
• Ingestion of fish from the Quinnipiac.
For the ecological risk assessment, the ecological receptors were identified as common
aquatic and terrestrial species of flora and fauna. Exposure to soil in the Operations Area
and Cianci property was evaluated, although the presence of pavement and/or scarce
vegetation in these areas provide marginal habitat. Exposure to surface water and soil in
wetlands, and surface water and sediment in the river were considered extensively.
G. SUMMARY OF SITE RISKS
A baseline risk assessment was performed to estimate the probability and magnitude of potential
adverse human health and environmental effects from exposure to contaminants associated with
the Site assuming no remedial action was taken. It provides the basis for taking action and
identifies the contaminants and exposure pathways that need to be addressed by the remedial
action. The public health risk assessment followed a four step process: 1) hazard identification,
which identified those hazardous substances which, given the specifics of the Site were of
significant concern; 2) exposure assessment, which identified actual or potential exposure
pathways, characterized the potentially exposed populations, and determined the extent of
possible exposure; 3) toxicity assessment, which considered the types and magnitude of adverse
health effects associated with exposure to hazardous substances, and 4) risk characterization and
uncertainty analysis, which integrated the three earlier steps to summarize the potential and
actual risks posed by hazardous substances at the Site, including carcinogenic and non-
carcinogenic risks and a discussion of the uncertainty in the risk estimates. A summary of those
aspects of the human health risk assessment which support the need for remedial action are
discussed below followed by a summary of the environmental risk assessment.
1. Human Health Risk Assessment
Approximately 40 of the more than 80 chemicals detected in groundwater and approximately 30
of the more than 65 chemicals detected in soils at the Site were selected for evaluation in the
human health risk assessment as chemicals of potential concern. The chemicals of potential
concern were selected to represent potential site related hazards based on toxicity, concentration,
frequency of detection, and mobility and persistence in the environment and can be found in
Appendix J of the 2005 FS, Tables 2.1 thro 2.9, and Tables 6-2 thru 6-5 of the 1994 RI. From
this, a subset of the chemicals was identified in the feasibility study as presenting a significant
current or future risk and is summarized in Tables G-l thru G-3. These tables contain the
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exposure point concentrations used to evaluate the reasonable maximum exposure (RME)
scenario in the baseline risk assessment for the chemicals of concern. The reasonable maximum
exposure point concentrations for chemicals in groundwater represent the highest average
concentration in any single well (when detections were averaged over the period of time in which
the well was sampled). In keeping with EPA risk assessment guidance, the RME concentrations
for soils were generally based on the maximum detected concentrations rather than the 95%
upper confidence limit (UCL) on the arithmetic mean concentration as the latter was generally
greater than the maximum detected value. In instances in which the 95% UCL on the mean
concentration was less than the maximum concentration, then the 95% UCL on the mean was
used as the RME point concentration for soils.
Potential human health effects associated with exposure to the chemicals of potential concern
were estimated quantitatively or qualitatively through the development of several hypothetical
exposure pathways. These pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future uses, and location of the Site.
At present the Site is vacant, with the exception of a network of groundwater recovery wells, a
sheet-pile wall, and a treatment building for the on-going groundwater remediation. Access to
most of the Site is restricted by fencing or the Quinnipiac River which, along this stretch, has
steep banks and is heavily vegetated. The Railroad Right-of-Way is not fenced, but exposure to
contaminated soil is reduced by the presence of railroad ties and gravel bedding. The Operations
Area and Cianci property only support activities related to the NTCRA 1 and NTCRA 2
Extraction and Treatment System.
A baseline public health risk assessment (RA) was performed by EPA in 1994 (HNUS, May
1994). The 1994 RA evaluated a future potential residential use scenario for groundwater and
potential residential, recreational and trespasser exposure scenarios were considered for contact
with soil, sediment, and surface water. In 1999, the PRP Group updated portions of the risk
assessment for soils and groundwater to incorporate newly collected monitoring data and to
reflect newly issued risk assessment guidance. Additionally, by 1999, two separate non-time
critical removal actions for groundwater had been implemented which altered groundwater
conditions at the site from conditions which formed the basis of the 1994 RA. The RA Update as
it will be referred to henceforth, re-evaluated the potential risks and hazards associated with
incidental ingestion and dermal contact with soils for residential, recreational, and
commercial/industrial land use scenarios and re-evaluated the potential risks and hazards
associated with hypothetical ingestion of groundwater. Risks resulting from other exposure
pathways (e.g. surface water and sediment) were not re-evaluated in the RA Update because no
new data had been collected and risks resulting from exposure to these media (1994 RA) had
been found to be below EPA's benchmarks for remedial actions. EPA's benchmarks for
remedial action include either a cancer risk in excess of 10"4 10"6 or a non-cancer Hazard Index
(HI) greater than one.
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For the purposes of this ROD, potential human exposures4 to contaminants that present an
unacceptable risk in soil, sediments, surface water and groundwater are summarized as follows:
• Risks from potential residential ingestion of overburden or bedrock groundwater from the
Operations Area/Railroad Property.
• Risks to potential residential or worker from exposures to subsurface soils at the
Operations Area/Railroad Property.
Risk posed by the potential consumption of fish obtained from the Quinnipiac River was not
quantified due to the relatively low levels of sediment contamination in the river and the fact that
the Site was not found to have a considerable impact on contaminant levels in the river (1994
RA). A more thorough description of all risks evaluated in the 1994 RA and the RA Update can
be found in Section 6,0 of the 1994 RI or in Appendix J of the 2005 FS (for the RA Update).
Excess lifetime cancer risks were determined for each exposure pathway by multiplying a daily
intake level with the chemical specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to reflect a conservative "upper
bound" of the risk posed by potentially carcinogenic compounds. That is, the true risk is unlikely
4 Reasonable maximum exposures (RME) were characterized for each scenario. In assessing
potential exposures to contaminated groundwater in the 1999 RA Update, a future potential
residential consumer was assumed to ingest 2 liters/day, 350 days/yr for 30 yrs. Current and
future potential residential exposure to soils was evaluated assuming incidental ingestion and
dermal contact were possible. A 30-yr exposure duration comprised of 6 years as a young child
and 24 years as an adult served as the basis for the residential soils exposure evaluations in the
1999 RA Update. Both an adult and a child were assumed to be exposed 350 days/yr for the
residential scenario, and the adult was assumed to ingest 100 mg soil/day whereas a young child
was assumed to ingest 200 mg soil/day. For dermal contact with soils, a soil adherence rate of
0.07 mg soil/cm2 of exposed body surface area was assumed over 5,700 cm2 of body surface area
for an adult whereas for the young child, a soil adherence rate of 0.2 mg soil/cm2 of body surface
area was assumed with contact assumed to occur over 2,900 cm2. Chemical specific dermal
absorption values were as noted in Table G-5.
The RME evaluation for an adult worker's exposure to soil as contained in the 1999 RA Update
included the assumption that exposure would occur for 25 years. During this time, it was
assumed a worker might ingest 100 mg/day of soil for 250 days/yr and contact soil at a rate of 0.2
mg soil/cm2 of body surface area, with 2,500 cm2 of body surface area potentially exposed.
Chemical specific dermal absorption values were as noted in Table G-5,
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to be greater than the risk predicted. The resulting risk estimates are expressed in scientific
notation as a probability (e.g., 1 x 10"6 for 1/1,000,000) and indicate (using this example), that an
average individual is not likely to have greater that a one in a million chance of developing
cancer over 70 years as a result of site-related exposure (as defined) to the compound at the
stated concentration. All risks estimated represent an "excess lifetime cancer risk" - or the
additional cancer risk on top of that which we all face from other causes such as cigarette smoke,
dental x-rays, or exposure to ultraviolet radiation from the sun. The chance of an individual
developing cancer from all other (non-site related) causes has been estimated to be as high as one
in three. EPA's generally acceptable risk range for site related exposure is one in ten thousand
(10"*) to one in a million (10*6). Current EPA practice considers carcinogenic risks to be additive
when assessing exposure to a mixture of hazardous substances. A summary of the cancer
toxicity data relevant to the chemicals of concern is presented in Table G-4.
In assessing the potential for adverse effects other than cancer, a hazard quotient (HQ) is
calculated by dividing the daily intake level by the reference dose (RfD) or other suitable
benchmark. Reference doses have been developed by EPA and they represent a level to which an
individual may be exposed that is not expected to result in any deleterious effect. RfDs are
derived from epidemiological or animal studies and incorporate uncertainty factors to help ensure
that adverse health effects will not occur. A HQ < 1 indicates that a receptor's dose of a single
contaminant is less than the RfD, and that toxic non-carcinogenic effects from that chemical are
unlikely. The Hazard Index (HI) is generated by adding the HQs for all chemical(s) of concern
that affect the same target organ (e.g., liver) within or across those media to which the same
individual may reasonably be exposed. A HI < 1 indicates that toxic non-carcinogenic effects are
unlikely. A summary of the non-carcinogenic toxicity data relevant to the chemicals of concern
at the SRSNE Site is presented in Table G-5.
Excess cancer risk projections for a future potential residential receptor who may consume
untreated groundwater from either the overburden or the bedrock aquifers in the Operations Area
are presented in Tables G-6 and G-7. For a future potential consumer of untreated groundwater
from this area, cancer risks were projected to greatly exceeded EPA's benchmark for remedial
actions of 10"4 to 10"6 and even approached unity. Potential exposures to trichloroethylene and
vinyl chloride were the principal contributors to the excess cancer risk projections. The potential
for adverse non-cancer effects is also possible should groundwater from either the overburden or
the bedrock aquifer in the Operations Area to be used for potable purposes as the Hazard Indices
exceeded unity for potential adverse effects on the liver, kidney, blood, immune system,
CNS/neurotoxicity, body weight, and skin and other various effects. Several of the risk drivers
for non-cancer endpoints include 1,2-dichloroethene, Aroclor 1254, carbon tetrachloride,
tetraehloroethylene, and vinyl chloride While not a component of either the cancer or non-cancer
risk estimation, lead was noted in both the overburden and the bedrock aquifers from the
Operations Area groundwater in excess of the federal MCL of 15 ug/l and numerous other
constituents in Operations Area groundwater were noted well in excess of their corresponding
federal or Connecticut standards for potable water. Risks and hazards attributed to potential
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consumption of groundwater from the Queen St Plume did not exceed EPA's benchmarks for
remedial actions and while risks evaluated in the risk assessment for the potential consumption
of groundwater from the Upgradient Area were in excess of EPA's benchmarks for remedial
action, EPA concluded that the contamination was due to upgradient sources and/or naturally
occurring levels of contamination.
Risks and hazards to potential residential receptors and workers via incidental ingestion and
dermal contact with subsurface soils at the Operations Area/Railroad Property are summarized in
Tables G-8 thru G-10. Potential excess cancer risk resulting from either residential exposure or
occupational exposure to subsurface soils at the Operations Area/Railroad Property via dermal
contact and incidental ingestion were found to exceed EPA's benchmark for remedial actions of
10"4 to 10"6 whereas risks to a trespasser in this area were found to be below EPA's benchmark
for remedial action. Excess cancer risks were projected to be 1 x 10"3 for a future resident's
potential exposure to subsurface soils and were dominated by the risk posed to a young child via
soil ingestion. Excess cancer risk projected for a worker potentially exposed to subsurface soils
from the Operations Area/Railroad Property were slightly less than for a resident (3 x 104) and
again, incidental ingestion dominated the risk estimates. Tetrachloroethylene, trichloroethylene,
2,3,7,8-TCDD equivalents, and PCBs were the compounds contributing most significantly to
these potential excess cancer risks.
The potential for adverse non-carcinogenic effects as a result of potential exposure to subsurface
soils at the Operations Area/Railroad Property is greatest for a child residential receptor as
Hazard Indices exceeded unity for effects on the immune system, kidney, and liver. Adverse
non-cancer effects for an adult resident or a worker potentially exposed to subsurface soils from
this area are not likely as the Hazard Indices did not exceed unity for these receptors. Several
soil constituents in the Operations Area/Railroad Property and Cianci property exceeded the
Connecticut remediation standards for soils (i.e., pollutant mobility criteria and/or direct
exposure concentrations).
While lead was detected in subsurface soils at the Operations Area/Railroad Property, a formal
evaluation of the potential hazards resulting to exposure to lead in soils was not performed as the
average lead concentration for this area (315 mg/kg) was below EPA's screening benchmark of
400 mg/kg for residential land use (OSWER Directive #9355.4-12 July 14, 1994). Because
access to much of the Operations Area/Railroad Property surface soil is restricted due to
pavement and railroad bedding material, risks posed by surface contamination were not
quantified for the Operation Area/Railroad Property. Potential risks to residents, recreational
users/trespassers, and workers from exposure to surface soils at the Cianci Area property were
not found to exceed EPA's benchmarks for remedial action (RA Update).
There are numerous sources of uncertainty and limitations in the risk estimations as calculated
for this Site. The net impact of these uncertainties and limitations to the overall risk estimates is
difficult to discern as some of these factors may lead to an overestimation of risk whereas others
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may lead to an underestimate of risk. Examples of uncertainties in the hazard identification stem
from EPA's limited ability to characterize the full range of potential adverse effects from the
available research. Often, data on specific effects (i.e., developmental effects) are lacking or are
not adequate for inclusion in the hazard assessment. Thus, the risk estimates projected are
limited by our ability to adequately characterize the full range of potential adverse effects on all
potentially susceptible populations that may result from exposure to compounds detected in the
environment.
Risk estimates are also based on the assumption that each of the contaminants persist in the
environment at the concentrations noted historically when dilution, degradation, and
transformation processes may lead to lesser or greater concentrations in the future, or result in the
creation of new compounds having greater or lesser toxicity than those characterized in this
assessment. The exposure assessment also assumes that an individual may be exposed to all
compounds simultaneously which may lead to an overestimation of actual risks if this is not the
case.
A limitation of the exposure assessment is that it did not include potential inhalation exposures to
VOCs that may result from either volatilization of contaminants as a result of domestic water use
or via vapor intrusion should a home be constructed atop a contaminated groundwater plume.
Failure to include consideration of these potential exposure pathways would tend to
underestimate potential risks. A comparison of groundwater concentrations from the overburden
aquifer at the Operations Area Plume to EPA's generic screening levels for vapor intrusion
(OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils, Nov. 2002) reveals that several compounds such as vinyl chloride, TCE,
benzene, chloroform, and PCE may present a significant risk to human health. As EPA's
guidance is merely a screening tool, the potential for vapor intrusion will be evaluated further as
part of remedial design.
Risks projected for exposure to dioxins and furans were assessed using a cancer slope factor of
1.5 x 10s (mg/kg/day)"1 based on a formerly published value from EPA's HEAST database. Had
risks to dioxins and furans been assessed using a recently proposed draft slope factor of 1 x 106
(mg/kg/day)"1, about a seven-fold increase in the cancer risk estimate for this group of chemicals
would have resulted. As dioxins and furans were only detected in the Operations Area soils, the
uncertainty in the dioxin and furan toxicity estimate is not apt to alter the conclusions of the risk
assessment for the Site.
Risks associated with exposure to trichloroethylene (TCE) were quantified using a draft slope
factor for TCE of 0.4 (mg/kg/day)"1 representing the higher end of the range of slope factors
recently proposed [the full range of proposed slope factors is 0.02 - 0.4 (mg/kg/day)"1].
Historically EPA had used a slope factor of 0.011 (mg/kg/day)"1 for evaluating the carcinogenic
potential of TCE, Reliance on the lower end of the proposed range of slope factors or the older
slope factor for TCE would lessen the cancer risks attributed to exposure to TCE by
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approximately 20 fold but would not change the conclusions regarding the significance of the
risks estimated for exposure to contaminants in groundwater or soil at the Operations Area,
Uncertainty is also inherent in EPA's evaluation of cumulative risk and hazard assessments. In
the absence of specific information on the effects of a mixture, EPA assumes dose additivity and
an absence of either synergistic or antagonistic behaviors of the chemicals. To the extent that
these assumptions are incorrect, over or underestimation of risk could result.
2. Ecological Risk Assessment
Procedures for addressing ecological risks are not as standardized as they are for human health
risk assessment. Specific procedures and level of effort for an ecological risk assessment (ERA)
vary significantly depending on site-specific factors, EPA conducted an ecological risk
assessment (ERA) in 1994 (HNUS, 1994). The results of the ERA are summarized below. A
more thorough discussion of the ERA can be found in Section 7 of the 1994 RI Report.
The terrain at the SRSNE Site is generally flat with a gentle downslope towards the Quinnipiac
River. Riverine, wetland and upland habitats are present. The majority of the wetland
communities are associated with the Quinnipiac River. The vegetation along the river is
dominated by mature deciduous trees with a fairly dense understory of deciduous shrubs. The
river banks have moderate to dense vegetation of saplings and shrubs. Wetland types include
forested-scrub/shrub and scrub/shrub emergent palustrine wetlands. Upland habitat types consist
of old fields, stands of deciduous trees, and a powerline right-of-way characterized by low shrubs
and grasses. No known federal or state endangered, threatened, or special concern species have
been identified at the Site.
Surface water, sediment, and soil and wetland soil to depths of 10 feet were considered for the
ERA. Soil deeper than 10 feet and groundwater were not considered during the ERA because
ecological receptors are not expected to be directly exposed to contaminants in those media.
Table 7-3 (surface water), Table 7-4 (sediment) and Table 7-5 (soil) of the 1994 Rl provide
summaries of the toxicity data used to screen for COCs including the occurrence, distribution and
background concentrations. Persistence, toxicity and bioaccumulation potential were also used
as criteria for screening COCs, based on the factors provided in the Superfund Chemical Data
Matrix (SCDM), which is a database generated by EPA (EPA, 1993). The selected ecological
COCs by media are shown in Table G-l 1.
The predominant COCs at the SRSNE Site are known to persist, undergo bioaccumulation and
biomagnify through food webs. Whereas plants and invertebrates are also at potential risk from
the contaminants present at the Site, species at higher levels received special emphasis. The
selection of indicator species to assess the potential effects of contaminant exposure on wildlife
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was based oil such factors as observations in the field, feeding habits, food webs, and routes of
exposure5. The indicator species used for the ERA were:
• Raccoon (Procyon lotor) - omnivore and opportunistic; inhabits wooded areas
interrupted by open fields and water courses.
• Red-tailed hawk (Buteo jamaicensis) - carnivore; inhabits woodlands interspersed with
grassy and brushy fields; uses large trees for nesting and perching.
• Mallard duck {Anas platyrhynchos) - primarily herbivore, but may also eat snails and
insects; prefers shallow water habitats (< 16 inches deep) that enable bottom feeding by
tipping up,
• Eastern garter snake (Thamnophis s. sirtalis) - carnivore, with earthworms accounting for
80 percent of food items; terrestrial, found in moist areas.
• Green frog (Rana clamitans melanota) - herbivore as tadpole; carnivore as adult, feeding
mostly on terrestrial invertebrates (insects and their larvae, worms, spiders), but also on
small fish and aquatic invertebrates; riparian, found along the banks in or at the edge of
water.
Of the COCs identified for this Site, the following were considered in the exposure assessment:
• Benzene
• Xylenes
• Phthalate esters
• PAHs
• 1,2,4-trichlorobenzene
• PCBs or Aroclors
• Dioxin
• Several pesticides
• Metals ^ including cadmium, copper, lead, mercury, nickel, selenium and zinc
The quotient method was used to estimate risk in this ERA. The quotient method consists of
dividing the exposure concentration by an appropriate benchmark toxicity value to produce a risk
estimate. If the quotient is one or more, adverse effects are considered likely to occur; if the
quotient is less than one, no adverse effects are likely to occur and the risks are considered
5 With respect to aquatic organisms, it was assumed that the majority of the species may be of potential
concern. Although invertebrates, in general, represent a significant contribution to the diets of vertebrates, not
enough is known about the types of invertebrates that are present at the Site. Plant species were not included among
indicator species because toxicological information regarding vegetation is generally scarce in the literature.
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minimal. Maximum and mean risk estimates were generated using the quotient method for each
medium-specific COC by using maximum and mean exposure concentrations. If the maximum
risk estimate for a specific COC was greater than one, but the mean risk estimate was below one,
adverse effects due to that contaminant were qualified as possible. If both the mean and the
maximum risk estimates for a given COC were greater than one, then adverse effects due to the
COC were qualified as probable, to reflect the greater likelihood of occurrence. In addition, a
maximum risk estimate greater than one along with a mean risk estimate below one, may indicate
that adverse effects due to the COC may be of a somewhat localized nature, while values greater
than one for both the maximum and the mean risk estimates may indicate that the adverse effects
are more widespread.
Benchmark toxicity values were obtained from a diverse set of information sources and represent
contaminant concentrations that are not expected to cause adverse effects on most ecological
receptors {Table G-15). The risk estimates and characterization of the adverse effects (no,
possible, probable) for each medium are shown on Tables G-12 (surface water), G-13 (sediment)
and G-14 (soil and wetland soil).
The conclusions of the ERA are discussed in detail in sections 7.5 and 7,6 of the 1994 RI and
section 1.5.2 of the 2005 FS. They can be summarized as follows:
• With respect to surface water in the Quinnipiac River and associated wetlands, an
unacceptable ecological risk from PCBs exists in the area of the culvert outfall.
• With respect to riverine sediment and wetland soil, which in the 1994 RI was treated as
sediment, an unacceptable ecological risk from PCBs (Aroclor 1254) and PAHs (bis(2-
ethylhexyl)phthalate and 2-methylnaphthalene) exists in the wetland soils at the culvert
outfall.
3. Basis for Response Action
Because the baseline human-health and ecological risk assessments revealed that future potential
residential and worker exposure to compounds of concern in the subsurface soil at the
Operations/Railroad Property area and that potential exposure to contaminants in groundwater
from this same general area may present an unacceptable human health risk (with excess cancer
risks calculated to be as high as unity (every person who drinks the water would potentially get
cancer over the course of his or her lifetime), and potential exposures estimated at 700 times
greater than benchmarks for the protections of non-cancer effects and due to unacceptable
ecological risks from exposure to contaminants in wetland soil and surface water at the culvert
outfall, actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment,
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H. REMEDIATION OBJECTIVES
Based on preliminary information relating to types of contaminants, environmental media of
concern, and potential exposure pathways, response action objectives (RAOs) were developed to
aid in the development and screening of alternatives, These RAOs were developed to mitigate,
restore and/or prevent existing and future potential threats to human health and/or the
environment from soil and wetland soil, overburden and bedrock groundwater, and NAPL in the
overburden and bedrock aquifers; and to attain applicable or relevant and appropriate
requirements (ARARs). Although surface water at the culvert outfall on the Cianci property also
presented an unacceptable risk due to PCBs, that risk will be addressed by the action taken to
address PCBs in wetland soil at the same location. As a result, no cleanup objectives were
developed for surface water. The RAOs selected for the SRSNE Site are:
• Operations Area/Railroad Soil
Human Health Prevent potential human exposure (dermal contact, ingestion and
inhalation) to soil with contaminants that exceed an excess carcinogenic risk of
10"4 to 10'6, that pose a non-carcinogenic Hazard Index greater than 1, or that
exceed ARARs. Prevent migration of contaminants from soils to groundwater
that would result in groundwater concentrations in excess of ARARs or which
otherwise present an unacceptable risk in groundwater.
Protection of the Environment Prevent migration of contaminants from soils to
groundwater that would result in groundwater concentrations in excess of
ARARs.
• Cianci Property Soil
Human Health Prevent human exposure (dermal contact, ingestion and
inhalation) to soil with contaminants that exceed an excess carcinogenic risk of
10^ to 1CT6, that pose a non-carcinogenic Hazard Index greater than 1, or that
exceed ARARs. Prevent migration of contaminants from soils to groundwater that
would result in groundwater concentrations in excess of ARARs or which
otherwise present an unacceptable risk in groundwater.
Protection of the Environment Prevent ecological risks associated with SRSNE-
related contaminants.
• Overburden NAPL Area
Human Health Reduce or stabilize contaminants in the NAPL area that would
otherwise result in groundwater concentrations that pose a carcinogenic risk in
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excess of 10"4 to 104, non-carcinogenic Hazard Index greater than 1, or that
exceed ARARs.
Protection of the Environment Reduce contaminants in the NAPL area to achieve
one or more of the following;
> Shorten the time frame that groundwater standards are exceeded;
> Shrink the size of the groundwater contaminant plume;
> Reduce groundwater contaminant concentrations; and
> Prevent the migration of NAPL.
• Overburden Groundwater
Human Health Prevent potential human exposure (dermal contact, ingestion and
inhalation) to groundwater in the overburden aquifer with contaminants that pose
an excess carcinogenic risk of 1G"4 to 10"6, non-carcinogenic Hazard Index greater
than 1, or that exceed ARARs.
Protection of the Environment Restore groundwater quality to meet ARARs.
• Bedrock NAPL Area
Human Health Minimize expansion of the extent of contaminated bedrock
groundwater due to further NAPL migration.
Protection of the Environment Minimize expansion of the extent of contaminated
bedrock groundwater due to further NAPL migration.
• Bedrock Groundwater
Human Health Prevent potential human exposure (dermal contact, ingestion and
inhalation) to groundwater in the bedrock aquifer with contaminants that pose an
excess carcinogenic risk of 10"4 to 10"6, non-carcinogenic Hazard Index greater
than 1, or that exceed ARARs.
Protection of the Environment Prevent continuing migration of contaminants that
exceed ARARs, and, restore bedrock groundwater to meet ARARs once VOC
residuals are depleted.
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I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
1. Statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake
remedial actions that are protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory requirements and preferences,
including; a requirement that EPA's remedial action, when complete, must comply with all
federal and more stringent state environmental and facility siting standards, requirements,
criteria or limitations, unless a waiver is invoked; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies in which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a principal element over
remedies not involving such treatment. Response alternatives were developed to be
consistent with these Congressional mandates,
2, Technology and Alternative Development and Screening
CERCLA and National Contingency Plan (NCP) set forth the process by which remedial
actions are evaluated and selected. In accordance with these requirements, a range of
alternatives was developed for the Site.
With respect to source control, the RI/FS developed a range of alternatives in which
treatment that reduces the toxicity, mobility, or volume of the hazardous substances is a
principal element. This range included an alternative that removes or destroys hazardous
substances to the maximum extent feasible, eliminating or minimizing to the degree possible
the need for long term management. This range also included alternatives that treat the
principal threats posed by the Site but vary in the degree of treatment employed and the
quantities and characteristics of the treatment residuals and untreated waste that must be
managed; alternative(s) that involve little or no treatment but provide protection through
engineering or institutional controls; and a no action alternative.
With respect to contaminated groundwater, the RI/FS developed a limited number of
remedial alternatives that attain site-speeific remediation levels within different time frames
using different technologies; and a no action alternative.
As discussed in Section 2 of the FS, soil, NAPL and groundwater treatment technology
options were identified, assessed and screened based on implementability, effectiveness, and
cost (see FS Tables 2-13 thru 2-18). The technologies for soil and NAPL constitute the
source control (SC) component of the remedy. The technologies for groundwater constitute
the management of migration (MM) component of the remedy. The purpose of the initial
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screening was to narrow the number of potential remedial actions for further detailed
analysis while preserving a range of options. Typically, SC and MM technologies that
survive the screening will, in the FS, be assembled into remedial alternatives. Due to the
large number of possible alternatives that would have resulted from combining the options
retained for the six discrete areas of the Site, alternatives were developed for each area
separately in Section 3 of the FS. The area-specific alternatives were also evaluated in detail
separately in Section 4 of the FS. One alternative for each of the six areas was selected and,
in combination, comprises the final remedy for the Site.
J. DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of the source control alternatives (soil/wetland soil
and NAPL) and management of migration alternatives (groundwater) that were evaluated.
1. Source Control Alternatives
The source control (SC) alternatives evaluated at the SRSNE Site are as follows:
Operations Area/Railroad Soil
• No action
• Capping and institutional controls
• Excavation, off-site disposal and institutional controls
Cianci Property Soil
• No action
• Culvert removal and excavation with on-site disposal
• Culvert removal and excavation with off-site disposal
Overburden NAPL Area
• No action
• Hydraulic displacement and monitored natural attenuation
• Hydraulic displacement and enhanced bioremediation
• Hydraulic displacement, chemical oxidation and monitored natural attenuation
• Thermal treatment and monitored natural attenuation
• Excavation and off-site disposal
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Bedrock NAPL Area
• No action
• Institutional controls and monitored natural attenuation
Each of the source control alternatives is summarized below. A more complete, detailed
presentation of each alternative is found in Section 4 of the FS. A comparative analysis of
alternatives is found in Section K of this ROD.
Operations Area/Railroad Soil (OAR) Alternatives
a. Operations Area/Railroad Soil: Alternative OAR-1 - No Action
Under this alternative, no active remediation would be conducted to address the toxicity or
mobility of contaminants in the soil. Exposure to the site soils would continue to be
limited by the asphalt pavement and fencing currently present at the Site, and the
contaminant concentrations would be expected to diminish through natural attenuation
processes. Soil would continue to be a source of contaminants to groundwater. Because
waste is left in place, periodic reviews would be conducted at five year intervals to assess
the long-term appropriateness of continued No Action.
This alternative is not protective, and does not meet applicable or relevant and appropriate
requirements (ARARs) and advisories, criteria and guidance that are "to be considered"
(TBCs). It would not allow for routine monitoring and maintenance of the existing
controls (i.e., the pavement and fencing). It is not consistent with the expected future
recreational/residential land use because over time recreational/residential users will be
exposed to unacceptable levels of contaminants in soil. There are no capital costs
associated with this alternative. See FS Tables 4-1 thru 4-3 for a more information about
this alternative including an evaluation of ARARs/TBCs and estimated costs.
b. Operations Area/Railroad Soil: Alternative OAR-2 - Capping and Institutional
Controls
Under this alternative, a low-permeable, composite RCRA Subtitle C cap would be placed
over the contaminated soil. It would be effective at reducing the potential exposure to soil,
and limiting the mobility of contaminants to groundwater by reducing infiltration.
Institutional controls, such as deed restrictions, would be put in place to ensure that the
property would not be used in a manner that could disturb the cap. This alternative would
include long-term maintenance and monitoring. Because waste is left in place, periodic
reviews would be conducted at five-year intervals to assess the continued protectiveness of
this remedy.
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This alternative is protective and meets all ARARs/TBCs, including RCRA Subtitle C and
the CT RSRs requirements for an "engineered control". It would also be designed and
built in a manner consistent with the expected future recreational/residential land use.
Design and construction is expected to take 3-4 years during which time the institutional
controls would be put in place. The estimated present worth cost of this alternative is
$1,060,000 based on a 30-year operation and maintenance period. See FS Tables 4-4 thru
4-6 for a more information about this alternative including an evaluation of ARARs/TBCs
and estimated costs.
c. Operations Area/Railroad Soil: Alternative OAR-3 - Excavation, Off-Site Disposal
and Institutional Controls
Under this alternative, 17,000 cubic yards of contaminated soil would be excavated and
transported off site for treatment (incineration) and disposal at an existing commercial
treatment facility. The excavated area would be backfilled with clean soil from an off-site
source. Due to the presence of shallow groundwater, excavation would be conducted
during seasonal low groundwater and a groundwater dewatering system may be needed;
any collected groundwater would be treated in the existing on-site treatment system,
modified to accept construction dewatering flows. High levels of respiratory protection
would likely be required to protect workers involved with excavation and soil handling.
Site-perimeter monitoring, and maybe a temporary enclosure over the excavation, would
be needed to protect the near-by residents during implementation of this alternative.
Institutional controls, such as deed restrictions, would be needed to ensure that the
property would not be used in a manner that could disturb soil below the seasonal high
groundwater level, which is the lower limit of the soils excavation, as some degree of
recontamination is possible from contact with contaminated groundwater in the
overburden. This alternative is consistent with the expected future recreational/residential
land use.
This alternative is protective and meets all ARARs/TBCs, including CT emission
standards to control VOCs and fugitive dust emissions during excavation activities.
Design and construction is expected to take 4-5 years during which time the institutional
controls would be put in place. No long-term maintenance or monitoring is required with
this alternative. The capital cost is $13,230,000, See FS Tables 4-7 thru 4-9 for a more
information about this alternative including an evaluation of ARARs/TBCs and estimated
costs.
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Cianci Property Soil (CD Alternatives
a. Cianci Property Soil: Alternative CP-1 - No Action
Under this alternative, no active remediation would be conducted to address the toxicity or
mobility of contaminants in the soil and wetland soil. Furthermore, no action would be
taken to eliminate the potential for contaminated groundwater to be transported via the
existing porous concrete culvert to the Quinnipiac River where it has the potential to
impact surface water and sediments. Unacceptable ecological risk would remain. Soil
would continue to be a source of contaminants to groundwater. Because waste is left in
place, periodic reviews would be conducted at five year intervals to assess the long-term
appropriateness of continued No Action.
This alternative is not protective and does not meet ARARs/TBCs, including CT RSRs for
direct exposure and pollutant mobility. It is not consistent with the expected future
recreational/residential land use. There are no capital costs associated with this
alternative. See FS Tables 4-10 thru 4-12 for a more information about this alternative
including an evaluation of ARARs/TBCs and estimated costs.
b. Cianci Property Soil: Alternative CP-2 - Culvert Removal and Excavation with On-
Site Disposal
Under this alternative, the existing 30-inch diameter concrete culvert that transports
contaminated groundwater to the Quinnipiac River by virtue of its poor condition would
be removed and the trench backfilled. Drainage would be rerouted to the Quinnipiac
River via a new, non-permeable pipe. Isolated hot-spots of contaminated soil and wetland
soil that exceed CT remediation standards for direct exposure or pollutant mobility would
be excavated. Excavation of wetland soil at the culvert outfall would also address
ecological risk. With this alternative, the approximately 900 cubic yards of excavated
material would be consolidated on the Operations Area, prior to that area being capped.
Should the soil capping alternative (OAR-2) not be selected, this alternative cannot be
implemented.
This alternative is protective and meets all ARARs/TBCs, including CT RSRs for soil and
wetland soil that exceeds PMC and DEC, federal and state wetland protection regulations,
and CT emission standards to control VOCs and fugitive dust emissions during excavation
activities. Because some of the material to be excavated is located in a wetland, actions
would be taken to minimize the impacts to this resource in accordance with federal and
state law. These impacts would be temporary in nature (probably less than one to two
months in duration) and would be mitigated by restoration of the wetland. No long-term
maintenance or monitoring on the Cianci property would be required. This alternative is
consistent with the expected recreational/residential land use. The estimated present worth
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cost of this alternative is $310,000. See FS Tables 4-13 thru 4-15 for a more information
about this alternative including an evaluation of ARARs/TBCs and estimated costs,
c. Cianci Property Soil: Alternative CP-3 - Culvert Removal and Excavation with Off-
Site Disposal
This alternative is identical to the previous alternative (CP-2) with the exception that the
900 cubic yards of excavated material would be transported off site and disposed at a
commercial disposal facility,
This alternative is protective and meets all ARARs/TBCs, including all those identified in
CP-2. As with CP-2, there will be temporary impacts to wetlands on-site, and wetland
restoration. No long-term maintenance or monitoring on the Cianci property would be
required. This alternative is consistent with the expected recreational/recreational land
use. The estimated present worth cost of this alternative is $730,000. See FS Tables 4-16
thru 4-18 for a more information about this alternative including an evaluation of
ARARs/TBCs and estimated costs.
Overburden NAPL Area (QNQGU) Alternatives
Four of the six alternatives assembled for the Overburden NAPL Area have as a first step
some form of in-situ physical treatment (hydraulic displacement or thermal treatment). Three
of those four employ the same technology (hydraulic displacement) as the first step; they differ
by what follows in the treatment train. One of the key objectives for this area is to reduce the
mobility of the NAPL source material in the overburden to increase the reliability and efficacy
of the management of migration component of the remedy. Some further mobilization of
NAPL into bedrock may be unavoidable with the in-situ treatment alternatives, as well as with
the excavation alternative. Proper engineering controls will be used to minimize the potential
for inadvertent mobilization of NAPL into the bedrock. All the technologies where waste is
treated in place are expected to achieve the reduction in mobility objective. However, each
will leave behind some amount of source material (i.e., NAPL or VOC mass) that will degrade
over time. The effectiveness of each technology will determine how much residual VOC mass
remains alter treatment.
The Overburden NAPL Area is shown in Figure 6. It is approximately 1.5 acres. It extends
from the water table to the top of bedrock (approximately 47,000 cubic yards) and contains an
estimated 120,000 gallons (1 million pounds) of NAPL. Approximately 84% of the mass of
VOC contamination at the SRSNE Site is believed to be in the form of NAPL in the
overburden, primarily concentrated in the 1.5 acre Overburden NAPL Area.
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a. Overburden NAPL Area: Alternative ONOGU-1 - No Action
Under this alternative, no active remedial measures would be taken to address NAPL in
the overburden aquifer. Although contaminant levels will continue to decline as a result of
on-going natural attenuation processes, there would be no monitoring to evaluate the
effectiveness of this alternative over time. Modeling suggests that it would take an
estimated 400 to 500 years to remove virtually all (99%) of the NAPL in the overburden at
current assumed degradation rates. Periodic reviews would be conducted at five year
intervals to assess the long-term appropriateness of continued No Action.
This alternative is not protective and does not meet ARARs/TBCs, It would not put in
place institutional controls to limit future exposure to contaminated material in this area of
the Site. It would not further progress towards the State's goal for this aquifer which is to
restore the groundwater to its natural quality, suitable for drinking or other domestic uses
without treatment. There are no capital costs associated with this alternative. See FS
Tables 4-19 thru 4-21 for a more information about this alternative including an evaluation
of ARARs/TBCs and estimated costs.
b. Overburden NAPL Area: Alternative ONOGU-2 - Hydraulic Displacement and
Monitored Natural Attenuation
This is the first of three alternatives to treat NAPL in the overburden that would begin with
hydraulic displacement. Hydraulic displacement uses injection and extraction of water at
locations within the treatment zone to increase the horizontal hydraulic gradient.
Increasing the hydraulic displacement will cause the "pooled" or potentially mobile NAPL
to move towards extraction wells or trenches where up to 44% can be recovered for
treatment leaving more than half of the mass to be addressed through monitored natural
attenuation. The existing NTCRA 1 treatment system that contains migration of
overburden contamination would be supplemented with a temporary system to address the
higher flows and greater influent constituent concentrations that would be generated
during the hydraulic displacement period. Any separate phase NAPL that is collected
would be transported off site for safe disposal. See Appendix I of the FS for a more
detailed discussion of hydraulic displacement.
NAPL that remains in the subsurface after the hydraulic displacement step will either be in
small pools or in the "residual" form of NAPL. Hydraulic displacement increases the
surface area of the NAPL left in the subsurface, enhancing the effectiveness of subsequent
treatment. Under this alternative, hydraulic displacement would be followed by monitored
natural attenuation (MNA). MNA is long-term monitoring of the on-going natural
degradation processes to assess the effectiveness over time. Appendix G of the FS
presents an evaluation of site conditions through June 2003 that suggests that biological
degradation has destroyed some of the VOC mass at the Site, a trend that is expected to
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continue. Increasing the surface area of remaining NAPL would be expected to enhance
the rate at which contaminant levels in the Overburden NAPL Area will decline as a result
of on-going degradation processes.
This alternative is protective and would eventually meet all ARARs/TBCs, including
federal and state regulations for drinking water, state discharge requirements, and state
proposed volatilization criteria. This alternative is consistent with the state's goal to
restore the groundwater in this aquifer to its natural quality, suitable for drinking or other
domestic uses without treatment. Hydraulic displacement would reduce the mobility of
NAPL in the overburden. MNA would shorten the time frame that groundwater standards
are exceeded, shrink the size of the overburden groundwater plume, and reduce the
contaminant concentrations. It would take an estimated 300 to 400 years to remove
virtually all (99%) of the NAPL in the overburden at current assumed degradation rates.
Until safe levels are achieved, institutional controls, such as deed restrictions, would be
required under this alternative to prevent exposure to untreated wastes. Periodic reviews
would be conducted at five year intervals to assess the continued protect! veness of this
remedy.
Design and implementation of the hydraulic displacement step is expected to take less than
one year. The estimated present worth of this alternative is $6,190,000. See FS Tables 4-
22 thru 4-24 for a more information about this alternative including an evaluation of
ARARs/TBCs and estimated costs.
c. Overburden NAPL Area: Alternative ONOGU-3 - Hydraulic Displacement and
Enhanced Bioremediation
This alternative is identical to the previous alternative (ONOGU-2) with the exception that
the MNA component would be replaced by enhanced bioremediation. As stated in the
description of ONOGU-2, hydraulic displacement would be expected to remove up to 44%
of the NAPL mass (with implementation of hydraulic displacement expected to be
completed in less than a year).
The hydraulic displacement would then be followed by enhanced bioremediation.
Enhanced bioremediation adds nutrients (in this case, emulsified soybean oil) and/or
bacteriological cultures to more rapidly reduce natural degradation of the mass of
contaminants left in the subsurface after hydraulic displacement. It would take an
estimated 130 years with enhanced bioremediation achieving three times the current rate
of degradation to remove virtually all (99%) of the NAPL in the Overburden NAPL Area,
and an estimated 40 years if enhanced bioremediation is more aggressive and is able to
achieve ten times the current degradation rate.
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As with ONOGU-2, this alternative is protective and meets all ARARs/TBCs, including
federal and state regulations for drinking water, state discharge requirements, and state
proposed volatilization criteria. It meets the State's goal for aquifer restoration; would
require institutional controls to prevent exposure to untreated waste; and would require 5-
year reviews. Design and implementation of the hydraulic displacement step is expected
to take less than one year. The addition of nutrients and/or bacteria would be spread out
over a 20-year time period. The estimated present worth of this alternative is $9,640,000.
See FS Tables 4-25 thru 4-27 for a more information about this alternative including an
evaluation of ARARs/TBCs and estimated costs.
d. Overburden NAPL Area: Alternative ONOGU-4 - Hydraulic Displacement, Chemical
Oxidation and Monitored Natural Attenuation
This alternative is similar to ONOGU-2 with the addition of an in-situ chemical oxidation
step between hydraulic displacement and MNA. As stated in the description of ONOGU-
2, hydraulic displacement would be expected to remove up to 44% of the NAPL mass
(with implementation of hydraulic displacement expected to be completed in less than a
year).
The hydraulic displacement would then be followed by chemical oxidation and MNA.
Chemical oxidation relies on an oxidant to chemically break down the constituents in the
NAPL. Under this alternative, permanganate or persulfate solution would be injected into
the subsurface and recovered using the system installed for hydraulic displacement. As
much as 95% of the NAPL is expected to be removed after the completion of both the
hydraulic displacement and chemical oxidation phases. Further reductions in NAPL mass
would be accomplished through MNA. It would take an estimated 50 to 150 years to
remove virtually all (99%) of the NAPL in the Overburden NAPL Area, assuming current
degradation rates.
Of the technologies being considered for this Site, chemical oxidation is the most sensitive
to the amount of NAPL mass in the subsurface. The amount of oxidant (and therefore
cost) and the time required to inject that oxidant is directly proportional to the amount of
NAPL that needs to be treated. Based on current estimates which put the amount of NAPL
in the Overburden NAPL Area at 1,000,000 pounds, approximately 3,190,000 pounds of
oxidant would be required. The transport, delivery, mixing and injection of this much
oxidant presents significant short-term risks to workers and the community that would be
addressed using standard construction, transportation and industry safety measures.
As with the two previous alternatives, this alternative is protective and meets all
ARARs/TBCs, including federal and state regulations for drinking water, state discharge
requirements, state proposed volatilization criteria and hazardous waste management
requirements. It meets the State's goal for aquifer restoration; would require institutional
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controls to prevent exposure to untreated waste; and would require 5-year reviews. The
hydraulic displacement step would be implemented in less than one year. The oxidant
would be injected during several injection events over a period of 12 to 15 months. The
estimated present worth of this alternative is $20,130,000. See FS Tables 4-28 thru 4-30
for a more information about this alternative including an evaluation of ARARs/TBCs and
estimated costs,
e. Overburden NAPL Area; Alternative ONOGU-5 - Thermal Treatment and Monitored
Natural Attenuation
Under this alternative, the first component of the treatment train would be in-situ thermal
treatment. Heat delivered to the subsurface would convert the NAPL from liquid to a
vapor phase which would be collected and treated on site. There are a number of methods
for delivering heat to the subsurface; thermal conductive heating (TCH) was selected as
the representative technology for purposes of evaluation in the FS, An elaborate
infrastructure is required to implement TCH - a series of heat and vapor extraction wells;
a network of above-ground piping and electrical distribution lines; and a vapor treatment
system that can manage large amounts of contaminants as well as meet CT air emission
regulations. In addition, the entire treatment area would be covered with a temporary cap
to minimize the potential for vapor releases.
Thermal treatment would remove between 95% and 99% of the NAPL mass in the
Overburden NAPL Area. Further reductions in NAPL mass would be accomplished over
the long term through the implementation of an MNA component, as described above in
ONOGU-2. If the thermal technology removes 95% initially, it will take 50 to 150 years
before virtually all (99%) NAPL in the Overburden NAPL Area is removed. If 97% is
removed initially, it will take 40 to 100 years before virtually all NAPL in the Overburden
NAPL Area is removed. If maximum removal rates are attained, virtually all the NAPL
mass in the Overburden NAPL Area would be removed after treatment.
As with previous ONOGU alternatives, this alternative is protective and meets all
ARARs/TBCs including federal and state regulations for drinking water, state discharge
requirements, and state proposed volatilization criteria. It would be designed and
constructed to meet air emission standards, as well as state noise pollution control
requirements. It meets the State's goal for aquifer restoration; would require institutional
controls to prevent exposure to untreated waste; and would require 5-year reviews.
Thermal treatment presents significant potential short-term risks to workers from on-site
operations, and workers and neighboring residents should vapors be released untreated.
These would be addressed through standard construction, health-and-safety, and operating
safety measures. Equipment monitoring and perimeter monitoring of the Site will also
minimize potential short-term risks. The total estimated duration of field operations of the
thermal component is about one year to install and decommission the infrastructure, and
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about one year of actual running time. The estimated present worth of this alternative is
$17,660,000. See FS Tables 4-31 thru 4-33 for a more information about this alternative
including an evaluation of ARARs/TBCs and estimated costs.
f, Overburden NAPL Area: Alternative ONOGU-6 - Excavation and Off-Site Disposal
Under this alternative, all the material in the Overburden NAPL Area from the ground
surface to bedrock would be excavated, staged on site and transported to a licensed RCRA
and/or TSCA hazardous waste treatment and disposal facility. The volume of material that
would be removed would be approximately 50,000 cubic yards, with an additional 10,000
cubic yards removed to maintain stable side slopes during the excavation. Significant de-
watering would have to occur prior to the excavation to lower the water table by as much
as 20 feet. De-watering would continue during construction to manage the contaminated
groundwater and pooled NAPL that is expected to enter the excavation. The groundwater-
NAPL mixture would be treated on site in the existing treatment system, with the addition
of a pre-treatment step to remove NAPL and silt. The excavation would be backfilled with
clean soils. Upward flow of impacted groundwater from the bedrock aquifer would be
expected to recontaminate the backfilled soil, although likely at levels far lower than
before excavation.
Exposure to pooled NAPL is a significant potential short-term risk to on-site workers. The
potential for the release of volatile and particulate emissions during the excavation would
also present a significant short-term risk to on-site workers and the neighboring
community. A temporary enclosure over the excavated area during construction would
control emissions, and personal respiratory protection would likely be required to ensure
that on-site workers are protected.
As with previous ONOGU alternatives, this alternative is protective and meets all
ARARs/TBCs including state discharge regulations and emission standards to control
fugitive dust and excess noise. It meets the state's goal for aquifer restoration. This
alternative would result in the complete removal of NAPL in the Overburden NAPL Area
at the end of construction (3 to 4 years, including design) so institutional controls would
not be needed to prevent exposure to untreated source material. Soil in the Operations
Area would be part of the excavation if this alternative were to be implemented, however,
the Railroad Right-of-Way soils would still need to be addressed. The estimated present
worth of this alternative is $39,970,000. See FS Tables 4-34 thru 4-36 for a more
information about this alternative including an evaluation of ARARs/TBCs and estimated
costs.
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Bedrock NAPL Area (NBGU) Alternatives
Unlike technologies available to address the overburden, technologies for recovering NAPL
from fractured bedrock (such as is present at SRSNE) have shown lower rates of success. As
such, no active remedial measures for the Bedrock NAPL Area, other than monitored natural
attenuation, were carried through for detailed analysis following the initial screening of
possible technologies.
a. Bedrock NAPL Area: Alternative NBGU-1 - No Action
Under this alternative, no active remedial measures would be taken to address NAPL in
the bedrock aquifer. Although contaminant levels will continue to decline as a result of
on-going natural attenuation processes, there would be no monitoring to assess the
progress of these processes. Assuming modest future rates of on-going natural processes
at the Site, modeling6 on the bedrock alone suggests that the bedrock plume will begin to
recede in 125 years and reach cleanup goals in 225 years (see FS Appendix F). Periodic
reviews would be conducted at five year intervals to assess the long-term appropriateness
of continued No Action.
This alternative is not protective and does not meet ARARs/TBCs. There would be no
monitoring and therefore no means to assess whether or not cleanup levels were attained.
It would not put in place institutional controls to limit future exposure to contaminated
material in this area of the Site. Without monitoring, this alternative would not further
progress towards the state's goal for this aquifer which is to restore the groundwater to its
natural quality, suitable for drinking or other domestic uses without treatment. There are
no capital costs associated with this alternative. See FS Tables 4-49 thru 4-51 for a more
information about this alternative including an evaluation of ARARs/TBCs and estimated
costs.
b. Bedrock NAPL Area: Alternative NBGU-2 - Institutional Controls and Monitored
Natural Attenuation
Under this alternative, institutional controls would be placed on a number of properties
that could be affected by contaminants in this area of the Site to prevent exposure to this
contamination. The second component of this alternative would be MNA - long-term
monitoring of natural attenuation processes - as described above in ONOGU-2.
6 All time frame analysis in this ROD is based on mathematical modeling. Some degree of uncertainty is
inherent in such analysis. However, such modeling provides a basis for a relative comparison of remedial
alternatives in order to select the most appropriate cleanup strategy.
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This alternative is protective and meets all ARARs/TBCs, including CT RSRs for
groundwater. In the short term, protection would be achieved when institutional controls
have been put in place. As discussed in NGBU-1, the bedrock plume is expected to begin
to recede in 125 years and reach cleanup goals in 225 years. Costs associated with the
implementation of the institutional controls measures are included with the Overburden
Groundwater alternatives listed below. Operation and maintenance costs including semi-
annual monitoring for the MNA component of the alternative are included in the Bedrock
Groundwater alternatives, also listed below. Therefore, there are no costs associated with
this alternative. See FS Tables 4-52 thru 4-54 for a more information about this
alternative including an evaluation of ARARs/TBCs and estimated costs.
2. Management of Migration Alternatives
Management of migration (MM) alternatives address contaminants that have migrated into
and with the groundwater from the original source of contamination. At the SRSNE Site,
contaminants have migrated from the soil and NAPL in the Operations Area, and the soil
along the Railroad Right-of-Way and Cianci property. The MM alternatives analyzed for this
Site are as follows:
Overburden Groundwater
• No action
• Institutional controls and monitored natural attenuation
• Hydraulic containment and monitored natural attenuation
• Supplemental containment (contingent)
Bedrock Groundwater
• No action
• Institutional controls and monitored natural attenuation
• Hydraulic containment and monitored natural attenuation
Each of the management of migration alternatives is summarized below. A more complete,
detailed presentation of each alternative is found in Section 4 of the FS.
Overburden Groundwater fOGW) Alternatives
a. Overburden Groundwater: Alternative OGW-1 - No Action
Under this alternative, no active remedial measures would be taken to address
contamination in this portion of the Site. Currently, no one is drinking the contaminated
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groundwater so there are no current risks associated with human exposure. However,
overburden groundwater presents a future unacceptable risk should it be used for drinking
in the future. This alternative does not reduce toxicity, mobility, or volume of
contamination through treatment. Over time, natural attenuation processes will very
slowly degrade the contaminants. Absent any monitoring or other activities to assess the
progress of these processes, this reduction could not be documented.
This alternative is not protective and does not meet ARARs/TBCs. It is not consistent
with the State's goal for this aquifer that is to restore the groundwater to its natural quality.
Under this alternative, no institutional controls would be put in place to prevent exposure
to contaminated groundwater, or to vapor emissions in buildings that may be constructed
at the Site in the future. In addition, under this alternative, reductions in contamination
through natural attenuation would not be monitored or documented. Time to meet cleanup
goals is on the order of 225 years, due to the upwelling of contaminated groundwater from
the bedrock into the overburden aquifer. This estimate is based on the assumption that
virtually all (99%) of the NAPL source material in the overburden has been removed from
the Overburden NAPL Area. Periodic reviews would be conducted at five-year intervals
to assess the long-term effectiveness of continued No Action. There are no capital costs
associated with this alternative. See FS Tables 4-37 thru 4-39 for a more information
about this alternative including an evaluation of ARARs/TBCs and estimated costs.
b. Overburden Groundwater: Alternative OGW-2 - Institutional Controls and Monitored
Natural Attenuation
Under this alternative, institutional controls would be put in place on all affected
properties to prevent exposure to contaminated groundwater and to require compliance
with State requirements designed to prevent inhalation exposure to volatile compounds.
This alternative also includes an MNA component, as described in several previous Source
Control alternatives such as ONOGU-2. Appendix G of the FS presents an evaluation of
site conditions through June 2003 that suggests that biological degradation has destroyed
some of the VOC mass at the Site, a trend that is expected to continue.
This alternative is protective and meets all ARARs/TBCs, including federal and state
drinking water standards and State's proposed volatilization criteria. This alternative is
consistent with the State's goal for this aquifer that is to restore the groundwater to its
natural quality. Protection would be achieved in a few years when institutional controls
are put in place. As described in OGW-1, upwelling of contaminated groundwater from
the bedrock is the controlling factor on the timeframe (-225 years) for achieving cleanup
levels in the overburden aquifer (assuming a technology has been put in place in remove
virtually all NAPL from the Overburden NAPL Area). Five-year reviews would be
conducted. The estimated present worth of this alternative is $2,590,000. See FS Tables
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4-40 thru 4-42 for a more information about this alternative including an evaluation of
ARARs/TBCs and estimated costs,
c. Overburden Groundwater: Alternative OGW-3 - Hydraulic Containment and
Monitored Natural Attenuation
Like OGW-2, this alternative would use institutional controls to prevent human exposure
to contaminated groundwater until safe levels are reached. Groundwater would be
hydraulically contained and treated on site. This would create a plume of residual
groundwater contamination outside the containment area that may exceed background
levels (a State of CT ARAR). The groundwater outside the containment area is frequently
referred to in the FS and this ROD as the "severed plume". Under this alternative, the
severed plume would be addressed through MNA.
Unlike OGW-2, hydraulic containment and treatment will continue even after
implementation of the Overburden NAPL Area alternative. The precise configuration of
hydraulic containment may change over time. Specifically, the existing NTCRA 1 and
NTCRA 2 Extraction and Treatment System in its current configuration would continue to
operate under this alternative, at least initially. Groundwater is currently being contained
from migrating further into the Town Well Field by the NTCRA 2 extraction wells.
Groundwater that is downgradient of the influence of the NTCRA 2 extraction wells meets
federal standards but is above background. It is expected that after treatment of the NAPL
in the overburden, the extraction component of NTCRA 1 would no longer be necessary,
and, the sheet-pile wall, or portions thereof, would be removed to facilitate natural
degradation, if it can be demonstrated that doing so will not have a negative impact on
surface water and/or sediment in the Quinnipiac River.
The extracted groundwater would be treated using the existing NTCRA 1 and NTCRA 2
ultra-violet/oxidation (UvOx) system, modified as necessary following completion of the
Overburden NAPL Area alternative to account for changes in contaminants,
concentrations and/or flow. The size of the plume is expected to decrease over time.
Optimization studies would be conducted periodically to assess how the hydraulic
extraction and treatment system might be modified to meet changing conditions. If an
equally effective, protective and ARAR-compliant treatment technology (e.g., Fenton's
Reagent, constructed treatment wetlands, phytoremediation) is identified, it may augment
or even replace the existing UvOx system. The placement of the extraction wells may also
change as the plume changes.
This alternative is protective and meets all ARARs/TBCs, including those specified in
OGW-2 as well as action-specific ARARs for hazardous waste management and discharge
regulations. It is consistent with the state's goal for this aquifer that is to restore the
groundwater to its natural quality. Hydraulic containment will prevent high levels of
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groundwater contamination from spreading further away from the SRSNE property.
Protection would be achieved in a few years when institutional controls are put in place,
As described in OGW-1, upwelling of contaminated groundwater from the bedrock is the
controlling factor on the timeframe (~225 years) for achieving cleanup levels in the
overburden aquifer (assuming a technology has been put in place in remove virtually all
NAPL from the Overburden NAPL Area). Five-year reviews would be conducted. The
estimated present worth of this alternative is $9,570,000. See FS Tables 4-43 thru 4-45 for
a more information about this alternative including an evaluation of ARARs/TBCs and
estimated costs.
d. Overburden Groundwater: Alternative OGW-4 - Supplemental Containment
(Contingent)
This alternative will be implemented contingent upon notification of the planned
reactivation of Production Wells No. 4 and 6, or any new production well in the Town
Well Field regardless of the alternative selected for the overburden groundwater. To
prevent the migration of contaminants in the groundwater plume from reaching the wells,
extraction wells - modeling suggests it could be as many as five - will be installed and the
extracted groundwater would be treated on site in the NTCRA 1 and NTCRA 2 treatment
system. This alternative meets all the ARARs/TBCs specified with OGW-3, The
estimated present worth of this alternative is $1,380,000. See FS Tables 4-46 thru 4-48 for
a more information about this alternative including an evaluation of ARARs/TBCs and
estimated costs.
Bedrock Groundwater (BGW) Alternatives
a. Bedrock Groundwater: Alternative BGW-1 - No Action
This alternative is the same as OGW-1 except it is implemented in the bedrock aquifer.
NAPL in the bedrock would continue to impact the quality of groundwater in the bedrock
for an estimated 225 years. There are no capital costs associated with this alternative. See
FS Tables 4-55 thru 4-57 for a more information about this alternative including an
evaluation of ARARs/TBCs and estimated costs.
b. Bedrock Groundwater: Alternative BGW-2 - Institutional Controls and Monitored
Natural Attenuation
This alternative is the same as OGW-2 except it is implemented in the bedrock aquifer.
NAPL in the bedrock would continue to impact the quality of groundwater in the bedrock
for an estimated 225 years. Costs associated with the implementation of the institutional
controls are included with the OGW-2 and OGW-3 alternatives. Operation and
maintenance would include semi-annual monitoring for the MNA component of this
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alternative. The estimated cost is $660,000. See FS Tables 4-58 thru 4-60 for a more
information about this alternative including an evaluation of ARARs/TBCs and estimated
costs.
c. Bedrock Groundwater: Alternative BGW-3 - Hydraulic Containment and Monitored
Natural Attenuation
This alternative is the same as OGW-3 except it is implemented in the bedrock aquifer.
NAPL in the bedrock would continue to impact the quality of groundwater in the bedrock
for an estimated 225 years. Capital costs of this alternative would be included in the costs
for OGW-3 alternatives. Operation and maintenance would include semi-annual
monitoring for the MNA component of this alternative. The estimated cost is $660,000.
See FS Tables 4-61 thru 4-63 for a more information about this alternative including an
evaluation of ARARs/TBCs and estimated costs.
K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that at a minimum EPA is required to
consider in its assessment of alternatives. Building upon these specific statutory mandates, the
NCP articulates nine evaluation criteria to be used in assessing the individual remedial
alternatives,
A detailed analysis was performed on the alternatives using the nine evaluation criteria in order
to select a site remedy. The following is a summary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation criteria. These criteria are summarized
as follows;
Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be eligible
for selection in accordance with the NCP:
1. Overall protection of human health and the environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy will meet all Federal environmental and more
stringent State environmental and facility siting standards, requirements, criteria or
limitations, unless a waiver is invoked. This assessment also addresses other information
from advisories, criteria, and guidance that is "to be considered."
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Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate the elements of one alternative to
another that meet the threshold criteria:
3. Long-term effectiveness and permanence addresses the criteria that are utilized to
assess alternatives for the long-term effectiveness and permanence they afford, along with
the degree of certainty that they will prove successful,
4. Reduction of toxicity, mobility, or volume through treatment addresses the degree to
which alternatives employ recycling or treatment that reduces toxicity, mobility, or
volume, including how treatment is used to address the principal threats posed by the site.
5. Short term effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed during the
construction and implementation period, until cleanup goals are achieved.
6. Implementabtlity addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
7. Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as
present-worth costs.
Modifying Criteria
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The modifying criteria are used as the final evaluation of remedial alternatives, generally after
EPA has received public comment on the RI/FS and Proposed Plan;
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8, State acceptance addresses the State's position and key concerns related to the preferred
alternative and other alternatives, and the State's comments on ARARs or the proposed
use of waivers.
9. Community acceptance addresses the public's general response to the alternatives
described in the Proposed Plan and RI/FS report.
Following the detailed analysis of each individual alternative, a comparative analysis, focusing
on the relative performance of each alternative against the nine criteria, was conducted. This
comparative analysis can be found Section 5 of the FS.
The section below presents a brief narrative summary of the alternatives and the strengths and
weaknesses according to the detailed and comparative analysis. Only those alternatives which
satisfied the first two threshold criteria were balanced and modified using the remaining seven
criteria.
Comparative Analysis of Remedial Alternatives for Source Control:
Comparative Analysis of Remedial Alternatives for Operations Area/Railroad Soil (OAR
Alternatives)
Overall Protection of Human Health and the Environment
The No Action alternative (OAR-1) will not protect human health and the environment because
no action would be taken to address the risks posed by contaminated soil.
Alternatives OAR-2 (Capping/ICs) and OAR-3 (Excavation/Off-site Disposal/ICs) will protect
human health and the environment. These alternatives will eliminate exposure to contaminated
soil exceeding cleanup levels. Alternatives OAR-2 will prevent exposure by placing the
contaminated material under a multi-layer cap on site, and using institutional controls such as
deed restrictions to prevent future disturbance of the cap/contaminated material. Institutional
controls are only adequate and reliable if they are monitored for compliance and enforced in the
long term. Alternative OAR-3 which removes soil that poses an unacceptable risk provides the
greatest degree of overall protection by permanently removing this material from the Site.
Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative OAR-1 does not meet ARARs, or other advisories, criteria and
guidance that are "to be considered" (TBCs). The remaining alternatives can be designed and
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constructed to meet ARARs/TBCs.
ARARs/TBCs for these alternatives are associated with direct exposure to and pollutant mobility
from contaminants in the soil, air pollution control and noise control. Alternative OAR-2
(Capping/ICs) would be required to meet hazardous waste landfill capping requirements as well
as other hazardous waste handling and storage regulations. Tables 4-2,4-5 and 4-8 in the FS
show all of the ARARs/TBCs for these alternatives.
Long-Term Effectiveness and Permanence
The No Action alternative OAR-1 does not provide any long-term effectiveness or permanence.
Alternatives OAR-2 (Cap/ICS) and OAR-3 (Excavation/Off-site Disposal/ICs) will provide both
long-term effectiveness and permanence. Regular inspections and cap maintenance would be
required under Alternative OAR-2 in order to remain effective in the long term, as would
periodic reviews of the effectiveness of the remedy since hazardous materials would be left on
site.
Alternative OAR-3 provides the greatest degree of long-term effectiveness and permanence
because the contaminated material is excavated and permanently removed from the Site.
Reduction of Toxicity, Mobility, or Volume Through Treatment
There is no reduction in toxicity, mobility or volume under the No Action alternative OAR-1.
Alternative OAR-2 (Cap/ICS) will reduce mobility, although not by treatment, of the chemical
compounds that are placed beneath the cap by preventing water from coming into contact with
the contaminated material and leaching into the groundwater. Alternative OAR-3
(Excavation/Off-site Disposal) will reduce toxicity, mobility and volume, although not by
treatment, by removing the contaminated soil from the Site.
Short-Term Effectiveness
The No Action alternative OAR-1 has no short-term impacts since there would be no short-term
risks posed to the community or on-site workers during implementation of the alternative, nor
impacts to the environment. However, the No Action alternative would not achieve protection at
any time.
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Alternative OAR-2 (Cap/ICS) has moderate potential short-term impacts to on-site workers and
the community that would have to be addressed. Particulate and VOC emissions may increase
during construction of the cap. This can be addressed with proper health and safety procedures,
standard dust control techniques, and air monitoring around the perimeter of the Site. Alternative
OAR-3 (Excavation/Off-site Disposal) has the greatest potential for short-term impacts due to the
magnitude of risk posed to on-site workers and the community during the excavation and
transport of highly-contaminated soil.
Alternatives OAR-2 and OAR-3 would both be protective immediately after implementation.
lmplementability
Alternative OAR-1 (No Action) is the easiest to implement because no remedial actions are
required.
The remaining OAR alternatives involve the use of capping and/or excavation that are both
proven technologies and are both technically and administratively implementable. The
excavation of the Operations Area (OAR-3) will pose the most challenge to implement as it will
require dewatering of a highly-contaminated volume of material.
Cost
Alternative OAR-1 (No Action) has no capital costs associated with it and the costs associated
with required five-year reviews are low. Alternative OAR-2 (Capping/ICs) at $ 1,060,000 has
relatively moderate costs. Alternative OAR-3 (Excavation/Off-site Disposal) has a relatively
high cost at $13,230,000.
State Acceptance
CT DEP has expressed its support for alternative OAR-2 (Capping and Institutional Controls).
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions that EPA responded to in the Responsiveness Summary,
The PRP Group has expressed support for capping the Operations Area/Railroad soil.
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Comparative Analysis of Remedial Alternatives for Cianci Property Soil (CP Alternatives')
Overall Protection of Human Health and the Environment
The No Action alternative (CP-1) will not protect human health and the environment because no
action would be taken to address the risks posed by contaminated soil and wetland soil.
Alternatives CP-2 (Excavation/On-site Disposal) and CP-2 (Excavation/Off-site Disposal) will
protect human health and the environment. These alternatives will eliminate exposure to
contaminated soil and wetland soil exceeding cleanup levels. Alternative CP-2 will prevent
exposure by placing the contaminated material under a multi-layer cap on site. Alternative CP-3
which removes soil and wetland soil that poses an unacceptable risk provides the greatest degree
of overall protection by permanently removing this material from the Site,
Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative CP-1 does not meet ARARs/TBCs. The remaining alternatives can be
designed and constructed to meet ARARs/TBCs.
ARARs/TBCs for CP-2 (Excavation/On-site Disposal) and CP-3 (Excavation/Off-site Disposal)
are associated with direct exposure to and pollutant mobility from contaminants in the soil and
wetland soil, air pollution control and noise control. Alternative CP-2 would be required to meet
hazardous waste landfill capping requirements as well as other hazardous waste handling and
storage regulations. Alternative CP-2 and CP-3 have wetland and floodplain considerations due
to the removal of contaminated soil from wetlands and floodplains. Tables 4-11,4-14 and 4-17
in the FS show all of the ARARs/TBCs for these alternatives.
Long-Term Effectiveness and Permanence
The No Action alternative CP-1 does not provide any long-term effectiveness or permanence.
Alternatives CP-2 (Excavation/On-site Disposal) and CP-3 (Excavation/Off-site Disposal) will
provide both long-term effectiveness and permanence. Regular inspections and cap maintenance
would be required under Alternative CP-2 in order for this alternative to remain effective in the
long term, as would periodic reviews of the effectiveness of the remedy since hazardous
materials would be left on site.
Alternative CP-3 provides the greatest degree of long-term effectiveness and permanence
because the contaminated material is excavated and permanently removed from the Site.
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Reduction of Toxicity, Mobility, or Volume Through Treatment
There is no reduction in toxicity, mobility or volume under the No Action alternative CP-1.
Alternative CP-2 (Excavation/On-site Disposal) will reduce mobility, although not by treatment,
of the chemical compounds that are placed beneath the cap by preventing water from coming into
contact with the contaminated material and leaching into the groundwater. Alternative CP-3
(Excavation/Off-site Disposal) will reduce toxicity, mobility and volume, although not by
treatment, by removing the contaminated soil and wetland soil from the Site. In addition, by
replacing the existing porous culvert, both CP-2 and CP-3 will eliminate this pathway for
contaminated groundwater to reach surface water.
Short-Term Effectiveness
The No Action alternative CP-1 has no short-term impacts since there would be no short-term
risks posed to the community or on-site workers during implementation of the alternative, nor
impacts to the environment. However, the No Action alternative would not achieve protection at
any time.
Alternative CP-2 (Excavation/On-site Disposal) and CP-3 (Excavation/Off-site Disposal) have
moderate potential short-term impacts to on-site workers and the community that would have to
be addressed. Particulate and VOC emissions may increase during excavation of the hot spots on
the Cianci property. This can be addressed with proper health and safety procedures, standard
dust control techniques, and air monitoring around the perimeter of the Site.
The excavation of wetland soils under alternatives CP-2 and CP-3 will result in short-term
impacts to the environment. However, both alternatives include actions to minimize impacts,
restore habitat and prevent the loss of flood storage capacity, so the impacts will be temporary.
Alternatives CP-2 and CP-3 would both be protective immediately after implementation.
Implementability
Alternative CP-1 (No Action) is the easiest to implement because no remedial actions are
required.
The remaining CP alternatives involve the use of excavation that is a proven technology and is
both technically and administratively implementable. Alternatives CP-2 (Excavation/On-site
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Disposal) and CP-3 (Excavation/Off-site Disposal) would also require compliance with federal
and state wetland and floodplain requirements, but this is not expected to limit the
implementability of these alternatives.
Cost
Alternative CP-1 (No Action) has no capital costs associated with it and the costs associated with
required five-year reviews are low. Alternative CP-2 (Excavation/On-site Disposal) at $310,000
and CP-3 (Excavation/Off-site Disposal) at $730,000 have relatively modest costs.
State Acceptance
CT DEP has expressed its support for alternative CP-2 (Excavation/On-site Disposal).
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions that EPA has responded to it the Responsiveness Summary.
The PRP Group has expressed its support of the following activities: "the isolated areas of soil
on the Cianci property contaminated with polyaromatic hydrocarbons (PAHs), polychlorinated
biphenyls (PCBs), and metals should be placed under [the cap that would be installed over
Operations Area/Railroad soils]; the culvert crossing the Cianci property should be replaced, and
the wetlands soils at the culvert outfall should be placed under that cap."
Comparative Analysis of Remedial Alternatives for the Overburden NAPL Area (ONOGU
Alternatives)
Overall Protection of Human Health and the Environment
The No Action alternative (ONOGU-1) will not protect human health and the environment
because no action would be taken to address risks posed by the contaminants in the overburden
NAPL area.
Alternative ONOGU-6 (Excavation/Off-site Disposal) provides the greatest overall protection of
human health and the environment from exposure to NAPL in the Overburden NAPL Area by
removing it and taking it off site. The remaining alternatives for the Overburden NAPL Area
(ONOGU-2 thru ONOGU-5) all will achieve cleanup objectives and will be equally protective of
human health and the environment in the long term. They differ from each other in the amount
of NAPL mass that remains after implementation of the initial phase(s) of treatment.
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Alternatives GNOGU-5 (Thermal Treatment/MNA) and 0NOGU-4 (Hydraulic
Displacement/Chemical Oxidation/MNA) will remove upwards of 95% of the NAPL mass prior
to MNA, The hydraulic displacement component of ONOGU-3 and ONOGU-2 will remove up
to 44% of NAPL mass, leaving more than half to be addressed by enhanced bioremediation
(ONOGU-3) or MNA (ONOGU-2).
Following the initial phase of treatment, Alternative ONOGU-2 (Hydraulic Displacement/MNA)
has the longest duration to achieve further reductions in contamination in comparison to all of the
other alternatives, aside from no action. The time frame for achievement of further reductions
following the initial phase of treatment is comparable for ONOGU-3 (Hydraulic
Displacement/Enhanced Bioremediation), ONOGU-4 (Hydraulic Displacement/Chemical
Oxidation/MNA), and ONOGU-5 (In-Situ Thermal Treatment/MNA). However, there is greater
uncertainty in the effectiveness of enhanced bioremediation (ONOGU-3), and thus greater
uncertainty with respect to the time frame for achieving further reductions in contamination.
All of the Overburden NAPL Area alternatives (except No Action) include provisions for
institutional controls to prevent human exposure to NAPL. All these alternatives (including No
Action) include five-year reviews to ensure that the remedy remains protective.
Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative ONOGU-1 does not meet ARARs. The remaining alternatives can be
designed and constructed to meet ARARs/TBCs.
ARARs/TBCs that are common to all NAPL source control alternatives in the overburden aquifer
are associated with federal safe drinking water, state hazardous waste management regulations,
state remediation standards for groundwater, state air pollution control, and control of noise
requirements. The alternatives with a hydraulic displacement component (ONOGU-2 thru
ONOGU-4) have additional state water quality standards and substantive discharge permit
requirements to meet. Alternative ONOGU-5 (Thermal Treatment/MNA) will also have to meet
additional air emission standards. Tables 4-20, 4-23,4-26,4-29,4-32 and 4-35 in the FS show
all of the ARARs/TBCs for these alternatives.
Long-Term Effectiveness and Permanence
The No Action alternative ONOGU-1 does not provide any long-term effectiveness or
permanence that can be assessed.
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Alternative ONOGU-6 (Excavation/Off-site Disposal) would have the highest long-term
effectiveness and permanence in the Overburden NAPL Area in that it would result in the
permanent removal of all the NAPL and contaminated soil from the treatment area. Alternatives
ONOGU-2 thru ONQGU-5 would have comparable long-term permanence, although alternatives
ONOGU-4 (Hydraulic Displacement/Chemical Oxidation/MNA) and ONOGU-5 (Thermal
Treatment/MNA) would have greater long-term effectiveness than ONOGU-2 (Hydraulic
Displacement/MNA) and ONOGU-3 (Hydraulic Displacement/Enhanced Bioremediation)
because ONOGU-4 and ONOGU-5 are expected to remove at least 95% of the NAPL mass
during the initial phase(s) of active treatment. The hydraulic displacement component of
ONOGU-2 and ONOGU-3 is expected to remove only 44% of NAPL mass, leaving more than
half to be addressed by enhanced bioremediation (ONOGU-3) or MNA (ONOGU-2).
The deposition of manganese oxides during the chemical oxidation step of ONOGU-4 (Hydraulic
Displacement/Chemical Oxidation/MNA) could affect its long-term efficiency. The ability for
enhanced bioremediation (ONOGU-3) to achieve a rate three times to ten times the current rate
of on-going natural degradation cannot be assured; in fact, there may be no increase over current
rates (see Appendix G of the FS).
Alternatives ONOGU-2 thru ONOGU-5 would also include post-treatment monitoring to support
either the MNA or enhanced bioremediation component and would require five-year reviews to
determine protectiveness and effectiveness over time.
Reduction of Toxicity, Mobility, or Volume Through Treatment
The No Action alternative, ONOGU-1, will not reduce contaminant toxicity, mobility or volume
through removal and/or active treatment.
Alternatives ONOGU-2 (Hydraulic Displacement/MNA), ONOGU-3 (Hydraulic
Displacement/Enhanced Bioremediation), ONOGU-4 (Hydraulic Displacement/Chemical
Oxidation/MNA) and ONOGU-5 (Thermal Trcatment/MNA) would ultimately achieve a similar
level of reduction in contaminant toxicity, mobility and volume through treatment in the long
term. However, more contaminants would be removed in a shorter period of time under
ONOGU-4 and ONOGU-5 than under ONOGU-2 and ONOGU-3. This would result in more
immediate reductions in contaminant toxicity, mobility and volume under ONOGU-4 and
ONOGU-5. The mobility of contaminants in the Overburden NAPL Area would be reduced at
the completion of the hydraulic displacement phase of ONOGU-2 thru ONOGU-4, and at the
completion of the thermal phase of ONOGU-5. The toxicity and volume would be further
reduced upon completion of the subsequent treatment steps (i.e., MNA, chemical oxidation or
enhanced bioremediation). In the short-term, PCBs, metals or other contaminants may remain at
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concentrations above groundwater cleanup levels after treatment under ONOGU-2 thro ONOGU-
5. However, their concentrations are expected to meet groundwater cleanup levels in the long
term as solubility of PCBs (which are co-located with the NAPL) decreases, and, metals stabilize
with the removal of solvents from the subsurface. Alternative ONOGU-6 (Excavation/Off-site
Disposal) would have the greatest reduction in contaminant toxicity, mobility and volume by
removing contaminants from the Site.
Short-Term Effectiveness
Alternative ONOGU-1 (No Action) has no short-term impacts since there would be no short-
term risks posed to on-site workers or the community during implementation, nor impacts to the
environment. With no action taken to reduce risk, natural degradation processes would remove
virtually all (99%) of the NAPL mass in the overburden aquifer in 400 to 500 years.
Alternatives ONOGU-2 (Hydraulic Displacement/MNA), and ONOGU-3 (Hydraulic
Displacement/Enhanced Bioremediation) would have some potential short-term impacts to on-
site workers and the community that would have to be addressed and no environmental impacts
that would have to be addressed. Alternative ONOGU-4 (Hydraulic Displacement/Chemical
Oxidation/MNA) would have additional potential short-term impacts associated with the
transportation, handling and injection of large volumes of oxidant chemicals. Alternatives
ONOGU-5 (Thermal Treatment/MNA) and ONOGU-6 (Excavation/OfT-site Disposal) have
potentially greater impacts resulting from the complexity of the alternatives, the potential for
escape of emissions during construction and operation and/or transporting large quantities of
contaminated material over public roadways. Approximately 2,400 truckloads of excavated
material would be sent, under ONOGU-6, to a hazardous waste treatment and disposal facility,
such as Model City, NY, over existing public roads and highways. A similar number of
truckloads of clean backfill materials would be brought to the Site. These potential impacts
would be addressed by following standard health, safety and transportation practices, and
monitoring.
In terms of time until the groundwater is protected from the impacts of NAPL in the Overburden
NAPL Area, ONOGU-6 ranks the highest as NAPL is removed from the system in three to four
years. The hydraulic displacement component of ONOGU-2 thru ONOGU-4 is expected to
remove up to 44% of the NAPL mass in less than a year. With MNA (ONOGU-2), virtually all
(99%) of the remaining NAPL mass would be removed in 300 to 400 years. With enhanced
bioremediation (ONOGU-3), virtually all of the remaining NAPL mass would be removed in 40
to 130 years, depending on how aggressive a degradation rate can be achieved. With chemical
oxidation and MNA (ONOGU-4), virtually all of the remaining NAPL mass would be removed
in 50 to 150 years. The thermal treatment technology (ONOGU-5) will remove between 95%
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and 99% of the NAPL mass in less than a year. With MNA following thermal treatment, virtually
all mass would be removed in 50 to 150 years if the thermal treatment technology is able to
remove 95% of the mass; 40 to 100 years if thermal treatment removes 97% of the mass; and in
about one year if thermal treatment attains a removal efficiency rate of 99%.
Imp!ementa bility
The no-action alternative ONOGU-1 is technically and administratively implementable.
Other than ONOGU-1, ONOGU-2 (Hydraulic Displaeement/MNA) and ONOGU-3 (Hydraulic
Displacement/Enhanced Bioremediation) would be the simplest to construct and operate. The
initial construction requirements for alternative ONOGU-4 (Hydraulic Displacement/Chemical
Oxidation/MNA) would be similar, although the chemical oxidation component would require
additional infrastructure for mixing and injecting oxidant into the subsurface. Alternative
ONOGU-6 (Excavation/Off-site Disposal) would be significantly more complex because of the
need to dewater the aquifer and control particulate and volatile emissions during the excavation.
Alternative ONOGU-5 (Thermal Treatment/MNA) requires a complex infrastructure and
engineering to ensure the successful control of groundwater migration, and, the capture and on-
site treatment of recovered solvent vapors making this alternative the most challenging to
implement.
The potential for downward mobilization of NAPL during the implementation of any of the
ONOGU alternatives could increase the amount of time to achieve cleanup levels. The risk for
downward mobilization is greatest for ONOGU-5 and ONOGU-6. However, this risk can be
minimized or eliminated using engineering controls.
Cost
There are no capital costs associated with the No Action alternative ONOGU-1. The cost of the
five-year reviews has been included in the OGW alternatives.
The cost of treatment in the Overburden NAPL Area with hydraulic displacement and either
MNA (ONOGU-2) or enhanced bioremediation (ONOGU-3) are at the lower end of the range in
comparison to the remaining alternatives at $6,190,000 and $9,640,000, respectively.
Alternatives ONOGU-4 (Hydraulic Displacement/Chemical Oxidation/MNA) and ONOGU-5
(Thermal Treatment/MNA) are in the middle of the range at $20,130,000 and $17,660,000,
respectively. The most expensive alternative to implement is ONOGU-6 (Excavation/Off-site
Disposal) at $39,970,000. Because chemical oxidation is sensitive to mass estimates (i.e., more
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Sou thing ton. CT
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NAPL requires more oxidant), the cost of implementation of ONGGU-4 has the greatest
potential to be an underestimate.
State Acceptance
CT DEP has expressed its support for the selection of in-situ thermal treatment technology with
MNA (ONOGU-5) to address the Overburden NAPL Area. However, CT DEP has decided not
to concur on the component of the selected remedy that requires institutional controls to prevent
exposure to vapor emissions.
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions that EPA has responded to in the Responsiveness
Summary, The PRP Group opposes the use of in-situ thermal treatment technology at the Site,
for numerous reasons as summarized in the Responsiveness Summary. The PRP Group also
opposes the use of any active treatment technologies to address the Overburden NAPL Area, but
in comparing these alternatives has expressed a preference for hydraulic displacement and
enhanced bioremediation (ONOGU-3).
Comparative Analysis of Remedial Alternatives for Bedrock NAPL Area (NGBU Alternatives)
Overall Protection of Human Health and the Environment
The No Action alternative (NBGU-1) will not protect human health and the environment because
no action would be taken to address risks posed by the contaminants in the bedrock NAPL area.
Alternative NBGU-2 (ICs/MNA) will provide protection of human health and the environment
through the use of institutional controls to prevent exposure to contaminants that exist as NAPL
in fractures in the bedrock, and, MNA to monitor the attainment of groundwater cleanup levels
over the long term. The bedrock plume is expected to begin to recede in 125 years and achieve
cleanup goals in 225 years, assuming that a treatment technology has been implemented that
removes virtually all the NAPL in the Overburden NAPL Area.
Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative, NGBU-1, does not meet ARARs/TBCs. The remaining alternative
(NGBU-2) (ICs/MNA) can be designed and constructed to meet ARARs. The ARARs/TBCs for
NBGU-2 include federal safe drinking water levels and state remediation standards for
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groundwater. Tables 4-50 and 4-53 in the FS show all of the ARARs/TBCs for these
alternatives.
Long-Term Effectiveness and Permanence
The No Action alternative NGBU-1 does not provide any long-term effectiveness or permanence
that can be assessed. Alternative NBGU-2 (ICs/MNA) will provide long-term effectiveness and
permanence by restricting exposure to contaminants in the bedrock NAPL area through
institutional controls, and MNA to achieve cleanup levels.
Reduction of Toxicity, Mobility, or Volume Through Treatment
The No Action alternative NGBU-1 will not reduce contaminant toxicity, mobility or volume
through removal and/or active treatment. Alternative NBGU-2 (ICs/MNA) has a monitoring
component that would document the natural degradation processes that will reduce the toxicity,
mobility and volume of NAPL in the fractured bedrock over time.
Short-Term Effectiveness
Alternatives NBGU-1 (No Action) and NBGU-2 (ICs/MNA) have no short-term impacts on the
community or on-site workers during implementation, nor do they present short-term
environmental impacts. In the short term, NBGU-2 would provide protectiveness with the
implementation of institutional controls, which NBGU-1 would not do. With MNA, NBGU-2
would effectively monitor reductions in contamination over time due to natural attenuation.
Implementabihty
The no-action alternative NBGU-1 is technically and administratively implementable.
Alternative NBGU-2 (ICs/MNA) is technically implementable, although the institutional controls
may present minor administrative implementability issues.
Cost
There are no capital costs associated with the No Action alternative NBGU-1. The cost of the
five-year reviews has been included in the OGW alternatives.
There are no additional costs associated with NBGU-2 (ICs/MNA). The costs associated with
implementation of the institutional controls are included in the Overburden Groundwater (OGW)
alternatives. MNA costs are included in the Bedrock Groundwater (BGW) alternatives.
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State Acceptance
CT DEP has expressed its support for MNA (NGBU-2). However, CT DEP has decided not to
concur on the component of the selected remedy that requires institutional controls to prevent
exposure to vapor emissions.
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions that EPA has responded to in the Responsiveness
Summary. The PRP Group has expressed support for restricting the future use of Site
groundwater.
Comparative Analysis of Remedial Alternatives for Management of Migration:
Comparative Analysis of Remedial Alternatives for Overburden Groundwater fQGW
Alternatives')
Overall Protection of Human Health and the Environment
The No Action alternative (OGW-1) will not protect human health and the environment because
no action would be taken to address risks posed by the dissolved contaminants in the overburden
aquifer.
The alternatives for Overburden Groundwater, OGW-2 (TCs/MNA) and OGW-3 (Hydraulic
Containment/MNA) rely on institutional controls to prevent human exposure to the dissolved
contaminants in the groundwater as well as any NAPL that is outside the area targeted for
treatment under the ONOGU alternatives. Alternative OGW-3 is more protective than OGW-2
because the hydraulic containment component prevents the highly contaminated groundwater
plume from spreading. Due to the upwelling of contaminated groundwater from the bedrock,
both OGW-3 and OGW-2 have the same time frame for achieving cleanup goals in the
overburden aquifer (~ 225 years) assuming a technology has been implemented that removes
virtually all (99%) of the NAPL in the Overburden NAPL Area.
The contingent remedy OGW-4 is protective because it would ensure that additional containment
measures are taken if municipal supply wells in the Town Well Field are activated in the future.
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Southington, CT
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Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative OGW-1 does not meet ARARs/TBCs. The remaining alternatives can
be designed and constructed to meet ARARs/TBCs.
Alternatives OGW-2 (ICs/MNA) and OGW-3 (Hydraulic Containment/MNA) and contingent
action OGW-4 have common ARARs/TBCs including federal safe drinking water levels and
state remediation standards for groundwater. Alternative OGW-3 has additional state
ARARs/TBCs for hazardous waste management, discharge to surface water, air pollution control
and control of noise. ARARs/TBCs for contingent alternative OGW-4 are the same as OGW-3.
Tables 4-38,4-41,4-44 and 4-47 in the FS show all of the ARARs/TBCs for these alternatives.
Long-Term Effectiveness and Permanence
The No Action alternative OGW-1 does not provide any long-term effectiveness or permanence
that can be assessed.
The Overburden Groundwater alternatives, OGW-2 (ICs/MNA) and OGW-3 (Hydraulic
Containment/MNA), both will provide long-term effectiveness and permanence by restricting the
use of groundwater through institutional controls, and MNA to achieve cleanup levels. However,
OGW-3 will provide a higher level of long-term effectiveness and permanence than OGW-2
because the hydraulic containment component will prevent the spread of the contaminated
groundwater plume that greatly exceeds federal drinking water standards.
The contingent action (OGW-4) provides long-term effectiveness and permanence by ensuring
that additional containment measures are taken in the event that municipal wells are activated in
the future.
Reduction of Toxicity, Mobility, or Volume Through Treatment
The No Action alternative OGW-1 will not reduce contaminant toxicity, mobility or volume
through removal and/or active treatment.
The MNA component of the Overburden Groundwater alternatives OGW-2 (ICs/MNA) and
OGW-3 (Hydraulic Containment/MNA) would both result in the permanent and irreversible
reduction in contaminant toxicity, mobility and volume through treatment, by the natural
degradation processes that occur in the subsurface. The hydraulic containment component of
OGW-3 would provide greater reduction in mobility of the plume, and the groundwater treatment
system would permanently reduce the toxicity and volume of dissolved contaminants in the
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South ington, CT
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extracted groundwater. Alternative OGW-3 (and contingent action OGW-4) would also prevent
contamination from migrating further into the Town Well Field.
Short-Term Effectiveness
Alternatives OGW-1 (No Action) and OGW-2 (ICs/MNA) have no short-term impacts since
there would be no short-term risks posed to on-site workers or the community during
implementation, nor impacts to the environment. There is somewhat higher risk to on-site
workers under OGW-3 (Hydraulic Containment/MNA) and the contingent action OGW-4, as
these alternatives require the handling of contaminated groundwater and treatment residuals.
However, these risks would be addressed by following standard health and safety practices.
In the short term, both OGW-2 and OGW-3 would provide protectiveness with the
implementation of institutional controls, which OGW-1 would not do.
Implementahility
The No Action alternative OGW-l is technically and administratively implementable.
Alternatives OGW-2 (ICs/MNA) and OGW-3 (Hydraulic Containment/MNA) and the contingent
action OGW-4, are all easily implementable, and, technically and administratively feasible. The
institutional controls required for these alternatives may present minor administrative
implementability issues. The groundwater extraction and treatment system required by
Alternatives OGW-3 make it slightly more difficult to implement than OGW-2.
Cost
The cost of the five-year reviews has been included in the OGW alternatives, so although there
are no capital costs associated with the No Action alternative, OGW-1 carries a cost of $80,000.
The cost of implementing institutional controls across the extent of the groundwater plume and
monitoring the natural degradation (OGW-2) in the overburden is $2,590,000. Adding hydraulic
containment (OGW-3) increases the cost to $9,570,000. The cost of additional containment
under OGW-4 is $1,380,000.
State Acceptance
CT DEP has expressed its support for pumping, treating and monitoring groundwater, and
restricting the use of contaminated groundwater combined with monitored natural attenuation,
(OGW-3) as well as supplemental groundwater containment (OGW-4) if municipal wells are
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Southington, CT
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activated by the Town of Southington in future. However, CT DEP has decided not to concur on
the component of the selected remedy that requires institutional controls to prevent exposure to
vapor emissions.
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions which EPA has responded to in the Responsiveness
Summary. The PRP Group states in its comments that it supports the containment and treatment
of contaminated groundwater until it is demonstrated that natural degradation processes balance
the on-going dissolution of contaminants.
Comparative Analysis of Remedial Alternatives for Bedrock Groundwater (BGW Alternatives)
Overall Protection of Human Health and the Environment
The No Action alternative (BGW-1) will not protect human health and the environment because
no action would be taken to address risks posed by the dissolved contaminants in the bedrock
aquifer.
The alternatives for Bedrock Groundwater, BGW-2 (ICs/MNA) and BGW-3 (Hydraulic
Containment/MNA) rely on institutional controls to prevent human exposure to the dissolved
contaminants in the groundwater as well as any NAPL that exists in the fractures. Alternative
BGW-3 affords greater protection than BGW-2 because the hydraulic containment component
prevents highly contaminated groundwater from spreading. Under both BGW-3 and BGW-2,
NAPL in the bedrock would continue to impact the quality of groundwater in the bedrock for an
estimated 225 years.
Compliance with Applicable or Relevant and Appropriate Environmental Requirements (ARARs)
The No Action alternative BGW-1 does not meet ARARs/TBCs. The remaining alternatives can
be designed and constructed to meet ARARs/TBCs.
Alternatives BGW-2 (ICs/MNA) and BGW-3 (Hydraulic Containment/MNA) have common
ARARs/TBCs including federal safe drinking water levels and state remediation standards for
groundwater. Alternative BGW-3 has additional state ARARs/TBCs for hazardous waste
management, discharge to surface water, air pollution control and control of noise. Tables 4-56,
4-59 and 4-62 in the FS show all of the ARARs/TBCs for these alternatives.
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Southington, CT
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Long-Term Effectiveness and Permanence
The No Action alternative BGW-1 does not provide any long-term effectiveness or permanence
that can be assessed.
The Bedrock Groundwater alternatives, BGW-2 (ICs/MNA) and BGW-3 (Hydraulic
Containment/MNA), will both provide long-term effectiveness and permanence by restricting the
use of groundwater through institutional controls, and MNA to achieve cleanup levels. However,
BGW-3 will provide a higher level of long-term effectiveness and permanence than OGW-2
because the hydraulic containment component will prevent the spread ofhighly contaminated
groundwater that greatly exceeds safe drinking water standards.
Reduction of Toxicity, Mobility, or Volume Through Treatment
The No Action alternative BGW-1 will not reduce contaminant toxicity, mobility or volume
through removal and/or active treatment.
Bedrock Groundwater alternatives BGW-2 (ICs/MNA) and BGW-3 (Hydraulic
Containment/MNA) have a monitoring component that would document the natural degradation
processes that will reduce the toxicity, mobility and volume of NAPL in the fractured bedrock
over time. Alternative BGW-3 would provide greater reduction in mobility of contaminants
through the use of hydraulic containment, and, toxicity and volume of contaminants through
treatment of the extracted groundwater. Alternative BGW-3 would also prevent contamination
from migration further into the Town Well Field.
Short-Term Effectiveness
Alternatives BGW-1 (No Action) and BGW-2 (ICs/MNA) have no short-term impacts on the
community or on-site workers during implementation, nor do they present short-term
environmental impacts. Alternative BGW-3 (Hydraulic Containment/MNA) has somewhat
higher risks to on-site workers as it requires the handling of contaminated groundwater and
treatment residuals. However, these risks would be addressed by following standard health and
safety practices.
In the short term, BGW-2 and BGW-3 would provide protectiveness with the implementation of
institutional controls, which BGW-1 would not do. In the long term, all the BGW alternatives
would likely achieve protection in an estimated 225 years due to natural degradation processes,
assuming that a treatment technology has been implemented that removes virtually all the NAPL
in the Overburden NAPL Area.
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Southington, CT
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Implementability
The No Action alternative BGW-1 is technically and administratively implementable.
Alternatives BGW-2 (ICs/MNA) and BGW-3 (Hydraulic Containment/MNA) are both easily
implementable, and, technically and administratively feasible. The institutional controls required
for all these alternatives may present minor administrative implementability issues. The
groundwater containment and treatment system required by Alternatives OGW-3 and BGW-3
make them slightly slightly more difficult to implement than OGW-2 and BGW-2.
Cost
The cost of the five-year reviews has been included in the OGW alternatives, so there are no
capital costs associated with the BGW No Action alternatives. Because the contaminated
bedrock aquifer sits below the contaminated overburden aquifer, there is some overlap in costs.
The costs associated with implementation of the institutional controls and hydraulic containment
of the bedrock aquifer are included in the OGW alternatives. The incremental cost of conducting
MNA in the portion of the bedrock plume that extends farther than the overburden plume under
alternatives BGW-2 (ICs/MNA) and BGW-3 (Hydraulic Containment/MNA) is $660,000.
State Acceptance
CT DEP has expressed its support for pumping, treating and monitoring groundwater, and
restricting the use of contaminated groundwater combined with natural attenuation (BGW-3).
However, CT DEP has decided not to concur on the component of the selected remedy that
requires institutional controls to prevent exposure to air emissions.
Community Acceptance
The community has not expressed support or disapproval of any components of the remedial
action, but has raised some questions which EPA has responded to in the Responsiveness
Summary. The PRP Group states in its comments that it supports containment and treatment of
contaminated groundwater until it is demonstrated that natural degradation processes balance the
on-going dissolution of contaminants.
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Soulhinglon, CT
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L. THE SELECTED REMEDY
1. Summary of the Rationale for the Selected Remedy
The remedy selected for the SRSNE Superfund Site is a comprehensive remedy that utilizes
source control and management of migration components to address all the contamination at the
Site. Source controls measures are required to address soil and wetland soil in the Operations
Area, Railroad Right-of-Way, and Cianci property and NAPL in the overburden and bedrock that
present unacceptable risks to human health or to environmental receptors and/or exceed ARARs.
The management of migration components address contaminants in groundwater in the
overburden and bedrock that present unacceptable risks to human health and/or exceed ARARs.
Of all the alternatives, the selected remedy best satisfies the statutory criteria for remedy
selection.
The selected remedy calls for contaminants in the Overburden NAPL Area beneath the
Operations Area to be treated by heating them in place to reduce the toxicity, mobility and mass
of this reservoir of contaminants that impacts groundwater quality. Contaminated soil and
wetlands soils at the Site will be consolidated and capped to eliminate the potential for
contaminants to leach to groundwater, and, to protect human health and ecological receptors
from direct exposure to contamination. Groundwater in the overburden and bedrock that exceeds
appropriate levels will be captured and treated on site. Contaminated groundwater outside the
capture zone will be treated through monitored natural attenuation, as will the contaminants that
have come to reside in the bedrock NAPL area.
The State's goal for the aquifer at the Site is to return it to its natural quality. This remedy is
consistent with that goal.
Approximately 84% of the mass of VOC contamination at the Site is in the form ofNAPL and
the greatest concentration is found in the 1.5-acre Overburden NAPL area. Within
approximately one year of implementation of in-situ thermal treatment of the overburden, the
selected remedy is expected to remove 95% to 99% of the NAPL in this area. Eventual
restoration of the contaminated groundwater plume in both overburden and bedrock to cleanup
levels is expected to take longer than 225 years, which is the estimated time frame for the entire
plume at the Site to achieve safe drinking water standards.
This remedy includes institutional controls such as CT Environmental Land Use Restrictions
(ELURs) to prevent exposure to contaminated groundwater, contaminants in subsurface soils,
and contaminants in NAPL areas, and to prohibit activities that might harm the cap. These
restrictions will also prohibit construction above any portion of the groundwater plume that
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exceeds the State's proposed volatilization criteria, if remedial design studies confirm the need
for these restrictions. The cap will require long-term monitoring. Reviews of the effectiveness of
the remedy will be conducted at least every five years to ensure that it remains protective over
time.
Finally, the remedy includes a contingent action for additional groundwater containment, if
needed.
The remedy set forth in this ROD addresses the following unacceptable risks;
• Potential future exposure to soils and wetlands soils contaminated with organic
solvents, PCBs, and metals that present an unacceptable risk to human health and
ecological receptors;
• Potential future exposure to contaminants in the overburden and bedrock NAPL
areas that present an unacceptable risk to human health;
* Potential future exposure to contaminated groundwater that could be used as a
drinking water source and present an unacceptable risk to human health; and
* Potential future exposure to volatile chemicals emanating to the air from the
subsurface that presents an unacceptable risk to human health (assuming that
remedial design studies confirm the presence of this unacceptable risk).
• Operations Area/Railroad Soil; OAR-2 - Capping and Institutional Controls
• Cianci Property Soil; CP-2 - Culvert Removal and Excavation with On-Site
Disposal
• Overburden NAPL Area; ONOGU-5 - Thermal Treatment and Monitored
Natural Attenuation
• Bedrock NAPL Area; NBGU-2 - Institutional Controls and Monitored Natural
Attenuation
• Overburden Groundwater; OGW-3 - Hydraulic Containment and Monitored
Natural Attenuation
• Overburden Groundwater (Contingent Remedy): OGW-4 - Supplemental
Containment
2. Description of Remedial Components
The alternatives that comprise this remedy are as follows:
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* Bedrock Groundwater: BGW-3 - Hydraulic Containment and Monitored Natural
Attenuation
A detailed description of each component of the selected remedy is presented below. This
comprehensive description incorporates each of the remedial alternatives that comprise the
remedy, describes the sequencing of remedial activities to be performed at the Site, and describes
the remedial activities that will be performed concurrently and over the long-term.
a. In-Situ Thermal Treatment
The first step in the remedial action will be in-situ thermal treatment of the Overburden
NAPL Area,
The selected remedy calls for the design and construction of a system to deliver heat to
the subsurface for the purpose of removing NAPL in the Overburden NAPL Area
primarily by converting it from a liquid to vapor phase. The Overburden NAPL Area is
generally shown on Figure 6 and extends to the top of bedrock. The thermal technology
(or technologies) will be determined during design. VOC contamination in the treatment
zone will be reduced to levels that are not indicative of the presence of pooled or residual
NAPL (as further explained in the discussion entitled NAPL Performance Standards,
below). EPA estimates that the attainment of such levels would be comparable to a VOC
mass reduction within the treatment zone of 95 to 99%.
Construction and implementation of this technology will be executed in a manner that
minimizes the risk of mobilizing pools of NAPL, particularly to the bedrock. If
dewatering is necessary to facilitate the effectiveness of this technology, the extracted
groundwater or NAPL/groundwater mixture will be treated to meet ARARs/Connecticut
discharge requirements prior to discharge to the Quinnipiac River.
Vapors generated in the subsurface will be captured with a vapor extraction system and
treated on site. The vapor treatment system will be specified during design but will likely
consist of condensation and recovery as liquids, and thermal oxidation and scrubbing of
residual vapors, likely with carbon polishing. The system will be designed to manage the
large amounts of contaminants that are expected to be removed from the subsurface, and,
meet federal and state air emission regulations. It is expected that the entire treatment
area will be covered with a temporary cap to minimize the potential for vapor releases.
Treatment residues from the vapor treatment system will be stored and handled in
accordance with state and federal hazardous waste management regulations.
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Southington, CT
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The Site will be monitored continuously during implementation of thermal treatment. The
monitoring program will include redundant safe-guards and monitoring at the Site's
perimeter to minimize the potential impacts to on-site workers and the community in the
unlikely event that unacceptable levels of emissions are released during treatment. The
monitoring program will also include a community outreach component that provides
residents with the information they need to recognize and respond to a release.
Pre-Desien Studies Prior to design of the in-situ thermal treatment system, the following
activities will be performed:
• A boring program to delineate the extent of the Overburden NAPL Area beyond
the northwestern comer of the SRSNE facility,
• An evaluation to determine the contaminant concentrations that are not indicative
of the presence of pooled or residual NAPL, Site-specific conditions, including
the types of compounds found in SRSNE NAPL, heterogeneities in the
unconsolidated unit in the overburden aquifer and groundwater cleanup times,
will be considered during this evaluation.
• A comprehensive set of criteria will be developed to evaluate the performance of
the thermal technology during and after implementation,
• Bench-scale tests to evaluate vapor treatment needs and options.
• An evaluation may be conducted to confirm design specifications to achieve
performance standards described below (see NAPL Performance Standards),
evaluate methods to control groundwater migration into the treatment zone,
confirm vapor treatment equipment sizing, and evaluate the potential for
equipment corrosion.
• A plan shall be prepared that identifies measures to be taken to address potential
downward mobilization of DNAPL, minimize the potential for vapor releases,
and identify safety measures to be put in place during implementation of in-situ
thermal treatment.
EPA will establish performance standards for the in-situ thermal treatment during
remedial design. These standards will be equivalent to a 95% to 99% reduction of the
NAPL mass within the treatment zone.
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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Design, construction, and implementation of in-situ thermal treatment is expected to be
completed in approximately one to two years, from installation to equipment
decommissioning and removal from the Site, not including the pre-design studies.
In order to evaluate the performance of the in-situ thermal treatment technology, a
sampling program will be established as part of the implementation of this technology.
b. Excavation
Following in-site thermal treatment, contaminated soil and wetland soil will be excavated
and consolidated.
The selected remedy calls for the excavation of approximately 900 cubic yards (total) of
soil and wetland soil from the Cianci property and culvert outfall as shown on Figure 7.
Contaminated soils/wetlands soils in excess of the soil cleanup standards, described
below (see Soil and Wetland Soils Cleanup Levels), will be excavated.
If dewatering is necessary to facilitate the removal of contaminated material, the extracted
groundwater or NAPL/groundwater mix will be treated to meet ARARs/Connecticut
discharge requirements prior to discharge to the Quinnipiac River. Erosion and sediment
control devices will be used during excavation to prevent contaminated materials from
impacting wetlands and the Quinnipiac River.
The excavated material will be temporarily stored on site prior to consolidation beneath
the Operations Area cap. The material will be stored and handled in accordance with
state and federal hazardous waste management regulations. Should PCBs in
concentrations greater than 50 ppm be encountered during excavation/consolidation, they
will be disposed off site in accordance with the requirements of the Toxic Substances
Control Act (TSCA) and Connecticut's regulations for disposition of PCBs.
The selected remedy also calls for the removal of a 30-inch concrete culvert. Drainage to
the Quinnipiac River will be re-routed through a new impermeable pipe expected to be
36-inches in diameter. The location of the new pipe will be determined during design.
Any sediment that has accumulated in the culvert will be handled, stored and
consolidated beneath the cap in the same manner as the excavated materials from the
Cianci property and culvert outfall.
Because excavation in floodplains and wetlands is unavoidable, measures will be taken to
minimize impacts of and during construction, to the extent practicable. Best management
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Solvents Recovery Service of New England
Southington, CT
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September 2005
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practices will be used throughout the Site to minimize adverse impacts on the wetlands,
floodplains, wildlife and its habitat. Damage to wetlands during excavation will be
mitigated through erosion control measures. These impacts will be temporary in nature
and will be mitigated by restoration of the areas upon completion. The disturbed areas
will be restored to their pre-excavation habitat type. The excavated areas will be back-
filled with clean materials that provide a suitable substrate for flora typical of the habitat
type. The culvert trench will be back-filled with a low permeability soil or clay to prevent
it from becoming an infiltration pathway, topped with soil to allow for re-vegetation.
Wetlands restoration with indigenous species will be conducted consistent with the
requirements of Federal and State wetlands protection laws. The floodplains will be
returned to their natural levels so as to prevent the loss of storage capacity.
During design, a sampling plan will be developed for testing the walls of the excavation
to ensure that all material exceeding cleanup levels has been removed. A habitat
restoration plan, including reporting requirements to demonstrate compliance with the
plan, will also be developed during design.
c. Multi-layer Cap
The consolidated contaminated soil and wetland soil will then be capped (Figure 8).
The selected remedy calls for construction of a low-permeability, multi-layer
("composite") RCRA Subtitle C cap over the existing asphalt cover in the Operations
Area and along the Railroad Right-of-Way. Material removed from the Cianci property,
culvert outfall and concrete culvert will be consolidated in the Operations Area prior to
capping. Portions of the Operations Area and Railroad Right-of-Way will be filled with
sub-base material and graded to provide positive drainage of surface water runoff from
the new cap toward the new drainage pipe that will be installed to replace the concrete
culvert. No side slope will be graded more steeply than three horizontal to one vertical
(3:1).
The cap will cover all soil/wetland soil that exceeds soil/wetland soil cleanup standards,
as described below (see Soil and Wetland Soil Cleanup Levels).
The cap will be designed, constructed and maintained to meet the requirements the CT
RSRs for an "engineered control" and will have a permeability of less than 1 x 10"6
cm/sec. The cap will also be designed to meet the requirements of the following EPA
guidance document and Region 1 technical memorandum: Final Covers on Hazardous
Waste Landfills and Surface Impoundments (EPA/530-S W-89-047) and Technical
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Solvents Recovery Service of New England
Southingion, CT
Final
September 2005
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Memorandum: Revised Landfill Cap Design Guidance Proposed for Unlined Hazardous
Waste Landfills in EPA Region 1, dated February 5,2001, Cap design will be consistent
with the expected future land use of the Railroad Right-of-Way as a bike path.
Stormwater runoff from capped areas that is discharged to the Quinnipiac River will be
managed in a manner consistent with ARARs,
Because the Overburden NAPL Area lies beneath the area to be capped, it is anticipated
that the in-situ thermal technology may reduce the concentration of contaminants in the
overlying soils. EPA maintains the flexibility to modify the capping component of the
remedy if treatment has reduced the amount of contaminated soil that exceeds cleanup
levels. The modifications may include reducing the size of the cap, and/or excavating
isolated "hot spots" of contaminated soil in lieu of capping assuming these response
actions can be conducted in a protective, ARARs compliant, effective, and cost-effective
manner.
Based on current data, EPA does not believe that a vapor control system will be a
necessary component of the multi-layer cap. However, further analysis of this issue will
be performed during pre-design.
Pre-Design Studies Prior to the design of the cap, the following pre-design studies will
be completed:
• A soil investigation to be conducted after implementation of the in-situ
thermal component to re-assess the size of the area to be capped. This will
include sampling to determine the background concentrations for dioxin. This
investigation may be done in conjunction with the post-thermal treatment
sampling program to determine whether NAPL Performance Standards have
been achieved. To be considered during this re-assessment are any changes to
cleanup levels or guidance documents for the contaminants detected (e.g.,
dioxin, PCBs), See discussion entitled Updated Assessments, below.
• An evaluation to confirm that, post-thermal treatment, a vapor control system
is an unnecessary component of the multi-layer cap. If a vapor control system
is found to be needed, the selected remedy will include a vapor control system
as a component of the multi-layer cap.
d. Hydraulic Containment and Treatment of Overburden and Bedrock Groundwater
Contamination (Including Contingency for Supplemental Containment)
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Solvents Recovery Service of New England
Souttiington. CT
Final
September 2005
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The selected remedy calls for the extraction and treatment of groundwater in the
overburden and bedrock aquifers that exceeds acceptable levels. Initially, the
containment and treatment system will be the system of recovery wells, sheet piling, and
on-site ultraviolet oxidation (UvOx) treatment with discharge to the Quinnipiac River that
currently operates at the Site pursuant to two AOCs. In short, the selected remedy
requires the continued operation of the NTCRA 1 and NTCRA 2 Groundwater Extraction
and Treatment System that is currently operating at the Site.
The plume of groundwater that exceeds federal drinking water standards or risk based
levels is expected to change over time with implementation of the source control
components of this remedy, natural attenuation and changes in hydrogeologic conditions.
In addition, notification from the Town of Southington that it plans to reactivate
Production Wells No. 4 and/or No. 6, or install or use additional wells in the Town Well
Field that could cause the plume that exceeds federal drinking water standards or risk
based levels to move, triggers the need for supplemental containment (contingent
alternative OGW-4).
As such, the selected remedy includes modifications or enhancements to the extraction
and/or treatment system to increase effectiveness and/or decrease the costs or time of
operation. All modifications and enhancements must be conducted in a protective,
ARARs-compliant, effective, and cost-effective manner. These future
modifications/enhancements include as appropriate (but are not limited to):
• Discontinuation of pumping at individual wells where cleanup goals have been
attained and maintained;
• Installation of additional extraction wells, horizontal extraction wells, collection
trenches, or subsurface barriers to facilitate or accelerate cleanup of the
contaminant plume;
• Removal of the NTCRA 1 sheet-pile wall in part or in whole;
• Replacement of the UvOx treatment system in part or in whole with a more
effective or efficient method of treatment (e.g., Fenton's reagent, constructed
treatment wetlands, phytoremediation) of lower flows or concentrations;
• Modifications to the groundwater monitoring program; and
• Installation of additional containment measures, such as extraction wells,
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Solvents Recovery Service of New England September 2005
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horizontal extraction wells, collection trenches, or subsurface barriers, that are
sufficient to prevent the migration of groundwater that presents unacceptable risk
and/or exceeds federal drinking water standards and risk based levels in the event
that the Town of Southington notifies EPA that is plans to reactivate Production
Well No. 4 or No, 6, or install or use additional wells in the Town Well Field,
As part of the selected remedy, EPA expects to enter into a written agreement with the
Town of Southington which will establish a procedure through which the Town would
notify EPA of its plans to reactivate Production Well No. 4 and/or No. 6, or to install or
use other wells in the Town Well Field.
Any modification/enhancements to the NTCRA 1/2 Groundwater System will be
implemented in a manner consistent with ARARs/statc water quality standards and
discharge requirements.
Hydraulic containment and treatment will continue until federal drinking water standards
and risk based levels are attained in the overburden and bedrock groundwater within the
capture zone of the current NTCRA 1/2 Groundwater System.
Pre-Design Studies As soon as practicable, the following study will be performed:
• A study will be performed to evaluated the current capture zone of
the NTCRA 1/2 Groundwater System to ensure that all contaminants
that exceed federal drinking water standards and risk based levels
will be contained.
e. Monitored Natural Attenuation of Overburden and Bedrock Plume Until Groundwater
Cleanup Levels are Attained
The goal of this remedial action is to restore groundwater throughout the Site to its
natural quality. Aquifer restoration of the entire plume is expected to take longer than
225 years which is the estimated time frame for the entire plume to meet federal drinking
water standards and risk based levels. Restoration of groundwater to natural quality will
be achieved by reliance on naturally-occurring biological, physical and chemical
attenuation processes in the subsurface and groundwater (which is expected to be
enhanced by all of the other components of the remedial action, including in-situ thermal
treatment of the Overburden NAPL Area). These naturally-occurring processes are
collectively referred to as "natural attenuation". Monitoring the result of these processes
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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throughout the plume(s) Is an integral part of this remedial technology, known as
monitored natural attenuation (MNA).
Monitoring will be used to:
* Delineate the plume(s) in three dimensions;
* Evaluate the effectiveness of institutional controls (e.g., evaluate whether any
activities at or near the Site are adversely affecting the plume);
* Assess temporal and special variations in plume chemistry and geometry; and
* Assess progress in meeting the long-term remedial objective(s).
The adequacy of the existing monitoring well network will be assessed throughout the life
of the remedy, including an assessment at the following times: (1) during pre-design; (2)
immediately after the active remediation phase is completed; and (3) during long-term
monitoring of the MNA component of the remedy. The selected remedy includes future
modifications to the existing monitoring well network as determined to be necessary
during pre-design and throughout the performance of the remedial action. The location of
wells, well screens, monitoring parameters, and frequency will be specified during design
and will be updated as conditions at the Site change. Performance monitoring reports,
including a summary of the data and any recommended actions, will be submitted yearly.
The report will include:
* Background and site description;
* Evaluation of new data;
* Summary of data interpretation;
* Evaluation of MNA conceptual model (to be developed during pre-design);
* Evaluation of institutional controls (e.g., evaluation of whether any activities at
the Site are adversely affecting the groundwater plume); and
* Recommendations.
MNA will be performed until the final groundwater cleanup levels have been met, as
provided below (see discussion of final cleanup levels in section entitled Interim
Groundwater Cleanup Levels).
Pre-Design Studies Prior to implementation of MNA in the "severed plume" (that
portion of the plume in the overburden and bedrock aquifers that is outside the hydraulic
containment system) and the Bedrock NAPL Area, an evaluation of the existing network
of monitoring wells will be completed. The purpose of the evaluation is to assess the
ability of the current monitoring scheme to meet the four stated uses of data collected
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Solvents Recovery Service of New England
Southirigton, CT
Final
September 2005
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during monitoring (outlined above) and provide recommendations for modifications if it
does not. This evaluation will be updated periodically. The first re-evaluation of the
monitoring scheme will be conducted no later than upon completion of in-situ thermal
treatment in the Overburden NAPL Area.
f. Vapor Intrusion
The selected remedy is designed to prevent exposure to volatile chemicals emanating
from the subsurface into overlying buildings that may be constructed in the future,
through the implementation of institutional controls.
Pre-Design Studies Prior to implementation of the institutional controls, a study will be
performed: (1) to confirm vapor intrusion risks (lO"4 to 10"*) at the Site consistent with
current screening analysis, and (2) to more precisely define the eastern extent of the
plume in the overburden aquifer. Based on interpolated data from the remedial
investigation, the plume is underlying portions of several parcels along Queen Street (but
is not currently underlying any currently-existing buildings). One of the purposes of this
study will be to determine which parcels and locations exceed federal risk levels and
therefore require these institutional controls.
g. Institutional Controls
The remedy includes implementation and enforcement of institutional controls, which
will be in the form of Environmental Land Use Restrictions (ELURs) consistent with
State requirements. These ELURs will be recorded in the appropriate local land records
office, and they will run with the land. Among other things, these restrictions will
prohibit the following activities:
• Prohibit activities that could harm the capped areas of the Site.
• Prohibit groundwater use or extraction of all groundwater that exceeds federal
drinking water standards, risk based levels or CT Groundwater Protection Criteria
(Appendix C in the CT RSRs).
• Prohibit soil excavation and other activities that might result in exposure to
contaminated subsurface soils and untreated NAPL and NAPL-contaminatcd
materials in the overburden and bedrock aquifers.
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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• Prohibit construction above groundwater plume that exceeds the State's proposed
volatilization criteria, unless construction is designed to prevent vapor intrusion
consistent with State requirements.
~ Otherwise impose such restrictions necessary to protect human health and the
environment and maintain the integrity of the remedy.
In implementing the institutional controls, EPA may decide that other forms of
institutional controls are preferable to, or should be implemented along with, ELURs.
Such institutional controls might include local ordinances and/or other state regulations
that are enforceable and reliable for long-term protection.
The restrictions on the use of groundwater will extend from the Operations Area and
Cianci property to all down gradient areas where the contaminated plume that exceeds
federal drinking water standards, risk based levels or Appendix C of the CT RSRs have
come to be located. The restrictions will also include a buffer zone around the
contaminated area adequate to insure that new private or public water supply wells in the
vicinity would not induce movement of the contaminants into uncontaminated areas or
interfere with any remedial action at the Site. Groundwater use restrictions will remain in
effect until federal drinking water standards, risk based levels or Appendix C of the CT
RSRs are achieved.
Once the institutional controls have been implemented, compliance with the restrictions
will be monitored and enforced to ensure that the institutional controls are effective.
Over time, EPA will also evaluate whether restrictions can be removed or modified
because acceptable levels have been met at the Site.
h. Wetlands and Floodplain Restoration
Much of the excavation on the Cianci property will be conducted within the 100-year
floodplain of the Quinnipiac River (Figure 7). At the culvert outfall, excavation will take
place within wetlands. As such, this work will be conducted consistent with federal and
state wetland and floodplain requirements, including habitat restoration. Access areas
and roads, staging/handling areas, etc., that have been constructed during implementation
of the remedy will also undergo habitat restoration. The goal of restoration is to restore
the functions and values of the various habitats affected by the remediation.
Pre-Design Studies Prior to construction of the remedial action, a study will be
performed (1) to determine the current functions and values of the areas to be affected by
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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the remediation; and (2) to evaluate actions to minimize impacts to the wetlands and
floodplains, to the extent practicable.
i. Long-term Monitoring
An environmental monitoring program will be implemented to evaluate the performance
of the groundwater containment and treatment system and the overall effectiveness of the
remedy including the MNA component. Performance monitoring will be conducted to
insure the proper operation of the remedy and satisfy CT RSR monitoring requirements.
Performance monitoring will include periodic monitoring, and necessary maintenance, of
the capped areas, groundwater treatment system influent and effluent, compliance with
the institutional controls and the entity responsible for maintaining, implementing and
enforcing the institutional controls. It is expected that groundwater performance
monitoring will be more frequent (e.g., 3-4 times a year) after implementation of the
active components of the remedy until the groundwater conditions have reached
equilibrium.
j. Five-year Reviews
To the extent required by law, EPA will review the Site at least once every five years after
the initiation of remedial action at the Site if any hazardous substances, pollutants or
contaminants remain at the Site to assure that the remedial action continues to protect
human health and the environment.
k. Changes to the Remedy
The selected remedy may be modified as a result of the remedial design and construction
processes. Changes to the remedy described in this Record of Decision will be
documented in a technical memorandum in the Administrative Record for the Site, an
Explanation of Significant Differences or a Record of Decision Amendment, as
appropriate.
3. Summary of the Estimated Remedy Costs
The estimated costs for each component of the remedy are summarized in the table below. A
more detailed break down of the costs can be found in Tables L-3 thru L-8.
The costs for operation and maintenance have been projected over 30 years, using the 7%
discount rate per EPA guidance (A Guide to Developing and Documenting Cost Estimates
Record of Decision
Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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During the Feasibility Study, July 2000). The cost of replacing equipment has been included as a
recurring cost. The cost estimates also include contingencies to cover unknowns, unforeseen
circumstances, or unanticipated conditions that were not possible to evaluate from the data on
hand at the time the estimate was prepared. Contingencies are typically applied as a percentage
of the total cost of construction or operation and maintenance activities cost, rather than applied
to individual cost elements. Contingencies were factored into each component of the remedy,
consistent with the ranges provided in EPA's aforementioned guidance.
The plumes in the overburden and bedrock aquifers that require hydraulic containment and
treatment are generally located in the same portion of the Site, The Bedrock NAPL Area is
located within the bedrock plume, For this reason, it was convenient to assign certain costs to
one component, rather than try to allocate between them all. The cost of implementing
institutional controls for groundwater and exposure to NAPL in the subsurface in both the
overburden and bedrock aquifers is included with OGW-3. The cost of hydraulic containment
and treatment for groundwater in both the overburden and bedrock aquifers is also included in
OGW-3. The cost for implementing MNA in the Bedrock NAPL Area is included in BGW-3.
Summary Table of Estimated Costs o
f Selected Remedy
Component
Initial and
Recurring
Capital Costs
Thermal
Treatment
Operating
Cost1
Annual
O&M2
Site
Closure
Capital
Costs3
Contin-
gencies 4
Total
OAR-2
570,000
-
120,000
-
370,000
1,060,000
CP-2
160,000
-
0
-
130,000
290,000
ONOGU-5
5
8,710,000 6
2,710,000
120,0007
-
6,580,000
17,660,000s
NBGU-2
09
-
0,u
-
0
0
OGW-3 11
1,240,000
-
5,960,000
220,000
2,150,000
9,570,000
BGW-3
0 12
-
500,000
-
160,000
660,000
Totals
10,680,000
2,710,000
6,700,000
220,000
9,390,000
29,240,000
OGW-4 13
280,000
-
620,000
4,000
477,000
1,380,000
Note: Costs in table are rounded to nearest $10,000.
1 Applies to ONOGU-5 component only.
2 Total present worth for 30 years with 7% discount rate.
3 Total present worth with single future payment factor equal to 0.356.
4 Includes contingencies for remedial design; project administration/management cost;
construction management; scope and bid/construction.
5 VOC mass estimated at 1,000,000 pounds.
6 Includes $1,500,000 for pre-design study
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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7 Total present worth for 5 years withno discount rate.
8 Reflects $460,000 "savings" from implementation of pilot study.
9 Institutional controls included with OGW-3.
10 MNA sampling included with BGW-3 O&M.
11 Includes cost of 5-year reviews for entire remedy.
12 Hydraulic containment included with OGW-3,
13 Cost of contingent remedy not included in overall cost of remedy.
There are two major sources of uncertainty that could have an affect on the estimated costs. The
first affects the cost of implementing the thermal treatment component. The cost of thermal is
based on interpretations of the results of the NAPL delineation study which estimates that
1,000,000 pounds of VOC mass are present in the subsurface in the treatment zone. While this
estimate is believed to be a conservative one, there exists the possibility that the VOC mass is an
underestimate. Assuming twice the NAPL is present (i.e., 2,000,000 pounds) the cost of
implementing thermal treatment would increase by an estimated $1,3 million.
The second source of uncertainty affects the cost of implementing hydraulic containment and
treatment until acceptable levels are attained. The costs presented in the FS are based on nearly
ten years of operating the existing NTCRA 1/2 Groundwater System at current concentrations
and volumes. With implementation of the source control components of this remedy, in addition
to on-going natural degradation, the size of and the contaminant concentrations contained within
the groundwater plumes are expected to decrease over time. These changes should make it
possible to re-design a containment/treatment system that will require less robust treatment
and/or a smaller containment area, resulting in significant savings not reflected in the FS. Based
on estimates from the parties currently conducting the work, the yearly cost of operation of the
NTCRA 1 and NTCRA 2 Groundwater Excavation and Treatment System is $500,000 per year.
The information in the cost tables is based on the best available information regarding the
anticipated scope of the remedial alternative. Changes in the cost elements are likely to occur as a
result of new information and data collected during the engineering design of the remedial
alternative. Changes to the remedy, including but not limited to the cost of the remedy, may be
documented in the form of a memorandum in the Administrative Record file, as an Explanation
of Significant Differences, or ROD amendment. The order-of-magnitude engineering cost
estimates provided in this ROD are expected to be within +50 to -30 percent of the actual project
costs.
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Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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4. Expected Outcomes of the Selected Remedy
An expected outcome of the selected remedy is that the SRSNE Site will no longer present a
future unacceptable risk to human health from direct exposure (ingestion, dermal contact,
inhalation of dust) to contaminated soils and wetland soils, and will be suitable for future
recreational or residential use. The soils at the SRSNE Site will no longer be a source of
contaminants leaching to groundwater from precipitation and surface runoff. The SRSNE Site
will no longer present an unacceptable risk to ecological receptors from contact with
contaminated soil in the wetlands, and habitat in the impacts areas will be restored to support a
healthy ecosystem. The porous concrete culvert will no longer act as a preferential pathway for
contaminated groundwater to reach the Quinnipiac River.
Another expected outcome of the selected remedy is that groundwater at the SRSNE Site will not
present a future unacceptable health hazard to human health through direct exposure (ingestion,
dermal contact, inhalation) and will meet Connecticut's goal of aquifer restoration to its natural
quality. Hydraulic containment will prevent further migration of contamination. Groundwater is
expected to be restored to federal drinking water standards or risk based levels in approximately
225 years. Thermal treatment of 95% to 99% of the mass of contaminants in the Overburden
NAPL area enhances the effectiveness and reliability of the hydraulic containment system
protecting the public water supply. Institutional controls will prevent unacceptable health
hazards to humans from direct exposure (ingestion, dermal contact) to contaminated materials in
the subsurface.
It is also expected that the cap which will be placed over contaminated soil along the Railroad
Right-of-Way will not restrict anticipated recreational land use. The Railroad Right-of-Way runs
across the Site between the Operations Area and the Cianci property and is a segment of the
planned Farmington Canal Heritage Trail which will run for 60 miles along abandoned rail
corridors from New Haven, CT to the Massachusetts border. Cleanup to the soil standards
included in this ROD on the Cianci property should allow for unrestricted access to this parcel.
The Operations Area could also be used for activities that wouldn't impede proper maintenance
of the cap and which were consistent with institutional controls necessary to protect the integrity
of the cap.
Cleanup to the soil cleanup levels included in this ROD on the Cianci property allows this parcel
to be used for residential/recreational/commercial/industrial use, provided the institutional
controls are met (e.g., no excavation for a foundation or utilities that would result in exposure to
contaminated materials in the deep subsurface in the Cianci property).
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Southington, CT
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Interim groundwater cleanup levels, arid soil and wetland soil cleanup levels have been
established, and are presented below. NAPL Performance Standards have also been established
and are presented below. Although there was a potential ecological risk in surface water from
PCBs at the culvert outfall, a surface water cleanup level has not been established. This is
because the cleanup level established for soil will result in the removal of wetland soil
contaminated with PCBs in the same location that is affecting surface water quality. As a result,
cleanup of the wetland soils should diminish surface water impacts.
a. Interim Groundwater Cleanup Levels
Because the aquifer under the Site is a Class GA aquifer, which is a potential source
of drinking water, interim cleanup levels have been set based on the most stringent of
the following ARARs: MCLs and non-zero MCLGs established by EPA and RSRs
established by CT DEP. Generally the CT RSRs will control as CT RSRs are more
restrictive than the federal MCLs and non-zero MCLGs. Table L-l summarizes the
interim groundwater cleanup levels for substances pursuant to CT RSRs. This list
also includes all compounds in groundwater which exceed a federal MCL or a non-
zero MCLG or were found to pose a cancer risk in excess of 10* or a non-cancer
Periodic assessment of the protection afforded by remedial actions will be made as the
remedy is being implemented and at the completion of the remedial action. At the
time that interim groundwater cleanup levels identified in this ROD, ARARs, and
newly promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy have been achieved and have not been exceeded for a
period of three consecutive years, a risk assessment shall be performed on all residual
groundwater contamination to determine whether the remedial action is protective.
This risk assessment of the residual groundwater contamination shall follow EPA
procedures and will assess the cumulative carcinogenic and non-carcinogenic risks
posed by all chemicals of concern (including but not limited to the chemicals of
concern in Table L-l) via relevant exposure pathways. If, after review of the risk
assessment, the remedial action is not determined to be protective by EPA, the
remedial action shall continue until either protective levels are achieved, and are not
exceeded for a period of three consecutive years, or until the remedy is otherwise
deemed protective or is modified. These protective residual levels shall constitute the
final cleanup levels for this ROD and shall be considered performance standards for
this remedial action.
HIM.
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Soothington, CT
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September 2005
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All interim groundwater cleanup levels identified in this ROD, ARARs, and newly
promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy and the protective levels determined as a consequence of
the risk assessment of residual contamination, must be met at the completion of the
remedial action at the points of compliance. Because waste has been left in place, the
point of compliance for groundwater cleanup levels is to the edge of the waste
management unit(s). At this Site, interim cleanup levels must be met throughout the
contaminated groundwater plume (except for under the cap) including throughout the
severed plume.
b. Soil and Wetland Soil Cleanup Levels
As indicated in the discussion of land use is Section F of this ROD, EPA is selecting a
remedial action that will allow for the reuse of the Site for recreational purposes.
Because CT DEP cleanup requirements for recreational site use are the same as its
cleanup requirements for residential use, a residential exposure scenario and
associated CT DEP residential cleanup standards for soils were considered for this
remedy. (This ROD has sometimes used the phrase "recreational/residential" in
referring to reuse of the Site and the related soil and wetland cleanup levels.)
Because CT remediation standards are ARARs, promulgated direct exposure criteria
(DEC) for residential soils and pollutant mobility criteria (PMC) for a GA aquifer
were identified as the cleanup levels for soils and wetland soils as shown in Table L-
2. DEC are designed to protect the health of individuals who may come in contact
with the soil whereas PMC address soil leaching concerns and protection of the
underlying aquifer for use as a potable water supply. Some PMCs are expressed as a
soil leachate concentration (in units of mg/1) whereas other PMCs are expressed as a
soil concentration (mg/kg). There are substances found in soil and wetland soil at
SRSNE that are within EPA's acceptable risk range but which exceed the more
stringent CT standards for remediation of soils. Because there is not a DEC or PMC
for 2,3,7,8-TCDD-TEQs, EPA's policy governing the cleanup of dioxins (OSWER
Directive #9200.4-26 April 1998) in soils was also considered in the selection of soil
cleanup levels. In the case of lead, EPA's Integrated Exposure Uptake Biokinetic
(IEUBK) model for lead was used to develop a concentration in soil that would
protect 95% of a potentially exposed population from blood lead levels in excess of
10 fxg/dl (micrograms per deciliter of blood). This approach is consistent with EPA's
1994 OSWER Directive 9355.4-12 for lead and because the resulting value of 400
mg/kg is more stringent than the DEC (500 mg/kg) the EPA policy number for lead
was identified in Table L-2. The soil and wetland soil cleanup levels will also be
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Southington, CT
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protective of ecological receptors in the area of the culvert outfall as the cleanup
levels identified for human-health protection are more restrictive than levels needed
for protection of ecological health.
These cleanup levels in soil and wetland soil are consistent with ARARs and attain
EPA's risk management goal for remedial actions, and have been determined by EPA
to be protective of human health, ecological health and the aquifer. Risk and hazard
posed by compounds in Table L-2 for which background concentrations have yet to
be determined and thus cleanup levels have not been specified will not result in any
additional site-related risk or hazard. These cleanup levels must be met at the
completion of the remedial action for soil beyond the extent of the cap in the
Operations Area and along the Railroad Right-of-Way, and, in soil and wetland soil
on the Cianci property, after excavation of hotspots. The soil depths to which these
cleanup levels apply will be in accordance with CT regulations which specify that
DEC apply from the ground surface down to a depth of 15 feet below the surface
unless the soil is inaccessible as defined in the CT RSRs. PMC apply down to the
low water table with exceptions that restrict PMCs down to the high water table as
noted in the CT RSRs.
c. Updated Assessments
EPA's new Cancer Guidelines and Supplemental Guidance (March 2005) will be used
as the basis for EPA's analysis of all new carcinogenicity risk assessments. If updated
carcinogenicity risk assessments become available, EPA will determine whether an
evaluation should be conducted as part of the remedial design to assess whether
adjustments to the target cleanup levels for this remedial action are needed in order
for this remedy to remain protective of human health.
d. NAPL Performance Standards (to be developed during Remedial Design)
VOC contamination will be reduced to levels that are not indicative of the presence of
pooled or residual NAPL. This is expected to result in a VOC mass reduction in the
treatment zone of 95 to 99%. Average and maximum concentrations for VOCs in the
subsurface will be determined during pre-design. Site-specific conditions, including
the types of compounds found in SRSNE NAPL, heterogeneities in the
unconsolidated unit in the overburden aquifer and groundwater cleanup times, will be
considered during this evaluation.
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Southington, CT
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September 2005
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These interim performance standards must be met throughout the thermal treatment
zone. Because these performance standards are expected to result in a VOC mass
reduction of95-99%, they attain EPA's risk management goals for remedial action
and are protective of human health. These interim performance standards will be
applied to the overburden in the treatment zone shown generally in Figure 6b, from
the ground surface to the top of bedrock. A pre-design boring program beyond the
northwest corner of the Operations Area may result in an expansion of the treatment
zone.
At the time these performance standards are attained in the field, EPA will evaluate
whether to continue to operate the in-situ thermal treatment system where EPA
determines that appreciable amounts of DNAPL continue to be recovered from the
Overburden NAPL Area. These will become the final NAPL performance standards.
M. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the SRSNE Site is consistent with CERCLA
and, to the extent practicable, the NOP. The selected remedy is protective of human health and
the environment and will comply with ARARs while at the same time being cost effective. In
addition, the selected remedy utilizes permanent solutions and alternate treatment technologies or
resource recovery technologies to the maximum extent practicable, and satisfies the statutory
preference for treatment that permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element.
1. The Selected Remedy is Protective of Human Health and the Environment.
The SRSNE Site is a highly-contaminated piece of property adjacent to both residential and
commercial areas, upgradient of a municipal well field. The contaminants of most concern to
EPA at this Site are chlorinated and non-chlorinated VOCs, SVOCs, PCBs, dioxin and
metals. These are present in soil and wetland soil, and in overburden and bedrock aquifers, at
levels that present a risk or potential risk to human health and/or the environment. The
dissolved VOCs are at particularly high levels, at tens, hundreds, or in some cases thousands
of times their regulatory limits. The volume of contaminated soils is approximately 18,000
cubic yards. Groundwater contaminants and contaminants in the NAPL area of the site are
highly mobile.
The selected remedy will protect human health and the environment through the treatment of
contaminants in the overburden NAPL area by in-situ thermal treatment, and by capping
contaminated soil and wetland soil on site. By containing, pumping and treating
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SoutWngton, CT
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groundwater, the selected remedy will prevent existing high concentrations of contaminants
in groundwater from migrating towards a potential public water supply. By monitoring the
progress of natural degradation of contaminated groundwater outside the capture zone, the
selected remedy will restore both the overburden and bedrock aquifers to meet Connecticut
cleanup goal which is natural quality sometime after 225 years. Until safe levels are
achieved, human health will be protected by preventing exposure to contaminated
groundwater through the use of institutional controls. This remedy also relies on institutional
controls to prevent exposure to volatile compounds that may emanate from the subsurface.
The cap will eliminate the threat of exposure to human health via direct contact with or
ingestion of contaminated soil and wetland soil. The selected remedy will reduce potential
human health risk levels within or below EPA's acceptable risk range of 104 to 10"6 and will
reduce the potential for adverse non-cancer health effects. It will reduce potential human
health risk levels to protective ARARs levels, i.e., the remedy will comply with ARARs and
To Be Considered criteria, including newly-proposed Connecticut volatilization criteria. The
selected remedy will eliminate risks posed to environmental receptors from contaminated
wetland soils. Short-term risks can be effectively controlled using standard engineering and
health and safety practices, and monitoring. In addition, no significant adverse cross-media
impacts are expected from the selected remedy.
At this Site, where EPA expects to reduce the NAPL mass in the overburden area of the Site
by 95% to 99% within approximately one year of implementation of thermal treatment, it is
technically practicable to restore the groundwater at the Site even though cleanup levels are
not expected to be attained throughout the plume for a long time (225 years). To do
otherwise, would require continued operation of the NTCRA 1/2 Groundwater System for
approximately 400 to 500 years. The selection of a remedy that may cut the time frame for
containment in half, based on modeling, is reasonable. By addressing the significant
contamination at this Site, the remedial action will eliminate the threat that site-contaminants
pose to the public drinking water supply in the Town Well Field.
At the time that interim groundwater cleanup levels identified in this ROD, ARARs, and
newly promulgated ARARs and modified ARARs that call into question the protectiveness of
the remedy have been achieved and have not been exceeded for a period of three consecutive
years, a risk assessment shall be performed on the residual ground water contamination to
determine whether the remedy is protective. This risk assessment of the residual ground
water contamination shall follow EPA procedures and will assess the cumulative
carcinogenic and non-carcinogenic risks posed by ingestion of groundwater, inhalation of
VOCs from domestic water use, and exposure to volatile chemicals emanating from the
subsurface. If, after review of the risk assessment, the remedy is not determined to be
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Southington, CT
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protective by EPA, the remedial action shall continue until protective levels are achieved and
have not been exceeded for a period of three consecutive years, or until the remedy is
otherwise deemed protective. These protective residual levels shall constitute the final
cleanup levels for this ROD and shall be considered performance standards for any remedial
action.
2. The Selected Remedy Complies with ARARs.
The selected remedy will comply with all federal and any more stringent state ARARs that
pertain to the Site. In particular, this remedy will comply with the following federal ARARs:
• Resource Conservation and Recovery Act (RCRA)
• Toxic Substances Control Act (TSCA)
• Clean Water Act
• Safe Drinking Water Act
• Clean Air Act
• Fish and Wildlife Coordination Act
• Executive Order 11988 (Floodplain Management)
• Executive Order 11990 (Protection of Wetlands)
In addition, the selected remedy will comply with the following, in some cases more
stringent, State of Connecticut ARARs:
• Remediation Standard Regulations (RSR)
• Hazardous Waste Management Regulations
• Air Pollution Control
• Control of Noise
• Surface Water and Wetlands, Inland Wetlands and Watercourses Act
• Disposition of PCBs
• Water Quality Standards
• Water Discharge Permit Regulations
The following policies, advisories, criteria, and guidances will also be considered during the
implementation of the remedial action:
• EPA Guidance for Final Covers on Hazardous Waste Landfills and Surface
Impoundments
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• Revised Landfill Cap Design Guidance Proposed for Unlined Hazardous Waste
Landfills in EPA Region 1
• Connecticut Guidance for Soil Erosion and Sediment Control
• Proposed Revisions (March 2003) Volatilization Criteria (will be an ARAR as part of
Connecticut's RSR, if adopted)
• EPA Reference Doses and EPA Carcinogen Assessment Group Potency Factors
• EPA Health Advisories
A thorough discussion of these requirements as well as all other ARARs for this Site is found
in the FS Tables 4-5,4-14, 4-32, 4-44,4-47, 4-53, and 4-62 which have been included in this
ROD as Appendix D.
3. The Selected Remedy is Cost-Effective.
In EPA's judgment, the selected remedy is cost-effective because the remedy's costs are
proportional to its overall effectiveness (see 40 CFR 300.430(f)(l)(ii)(D)), This
determination was made by evaluating the overall effectiveness of those alternatives that
satisfied the threshold criteria (i.e., that are protective of human health and the environment
and comply with all federal and any more stringent ARARs, or as appropriate, waive
ARARs). Overall effectiveness was evaluated by assessing three of the five balancing
criteria in combination - long-term effectiveness and permanence; reduction in toxicity,
mobility, and volume through treatment; and short-term effectiveness. The overall
effectiveness of each alternative then was compared to the alternative's costs to determine
cost-effectiveness. The relationship of the overall effectiveness of this remedial alternative
was determined to be proportional to its costs and hence represents a reasonable value for the
money to be spent.
The estimated present worth cost of the six components that comprise the selected remedy is
$29,240,000. Capping and institutional controls for the soil in the Operations Area and along
the Railroad Right-of-Way at $1,060,000 is significantly less expensive than excavation and
off-site shipment of the contaminated soil ($13,230,000) and, provided the cap is properly
maintained and institutional controls remain in place and are adequately monitored and
enforced, offer similar overall protection and can be designed in a manner consistent with the
anticipated future recreational/residential land use. With the cap going in on the Operations
Area, it is more cost-efficient to consolidate the material excavated from the Cianci property
under the cap which costs $310,000, than to ship it off site for disposal which costs $730,000.
The cost of institutional controls and MNA of the plumes in the overburden and bedrock
aquifers is 53,250,000. To add hydraulic containment, which is a component of the selected
remedy, increases the cost to $10,230,000. Hydraulic containment will reduce toxicity and
volume of contaminated groundwater at the Site by treatment. In comparison to the other
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Southington, CT
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September 2005
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alternative, hydraulic containment is the only option that will prevent contaminated
groundwater from migrating further into the Town Well Field, which is a potential public
water supply.
After an assessment of the proportionality of cost to overall effectiveness, EPA determined
that in-situ thermal treatment which costs 517,660,000 is the most cost-effective of the
alternatives evaluated for the Overburden NAPL Area because it has the potential to remove
the greatest amount of NAPL mass in the shortest period of time, and by doing so, shrink the
size of the groundwater containment plume, reduce groundwater contaminant concentrations
and shorten the timeframe that groundwater standards are exceeded. Of all the treatment
technologies considered, chemical oxidation, while it can be very effective, is the most
sensitive to mass estimates (i.e., more NAPL requires more oxidant). The alternative with
chemical oxidation which is estimated to cost $20,130,000 has the greatest potential to be an
underestimate. The cost of excavation is $39,970,000 and is just too costly considering that
even with excavation of the overburden NAPL area, the NAPL in the bedrock and in the
overburden outside the treatment zone will continue to impact groundwater quality for a long
time. The remaining alternatives, with the exception of the no-action alternative, will all
eventually attain cleanup levels. Where they differ is the amount of contamination that is
permanently removed during the initial phase of treatment train. Hydraulic displacement is
expected to remove up to 44% of NAPL mass in a relatively short period of time
(approximately one year). Hydraulic displacement and MNA ($6,190,000) is expected to
remove virtually all (99%) of the NAPL mass in the Overburden NAPL Area in 300 to 400
years, assuming the current rate of natural attenuation. Hydraulic displacement and enhanced
bioremediation ($9,640,000) would remove virtually all the NAPL mass in 130 years if
enhanced bioremediation can achieve a rate three times the current rate, and 40 years if
enhanced bioremediation can achieve a rate ten times the current rate. In-situ thermal
treatment is expected to remove between 95 and 99% of the NAPL mass in the Overburden
NAPL Area in a relatively short period of time (one year for installation and equipment
decommissioning and approximately one year of actual heating). If the technology removes
95% of the NAPL mass initially, it will take 50 to 150 years before virtually all (99%) is
removed with MNA. If 97% is removed initially, it will take 40 to 100 years before virtually
all is removed. If maximum removal rates are attained, virtually all the NAPL mass would be
removed at the end of implementation of the thermal component.
Moreover, in comparing the ONOGU alternatives, the estimated time frames for achievement
of reductions in the initial phases for hydraulic displacement and enhanced bioremediation is
uncertain, The actual rate of remediation as estimated above may, in fact, be as low as zero
based on uncertainties presented in Appendix G to the FS. This factor adds uncertainty to the
cost-effectiveness of ONOGU-3.
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Southington, CT
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September 2005
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Finally, it should be noted that the current estimated yearly cost of operation of the NTCRA 1
and NTCRA 2 Groundwater Extraction and Treatment System is $500,000 per year. With
the implementation of the source control components of this remedy, in addition to on-going
natural attenuation, the size of and the contaminant concentrations contained within the
groundwater plumes are expected to decrease over time. These changes should make it
possible to re-design a containment/treatment system that will require less robust treatment
and/or a smaller containment area, resulting in significant savings not reflected in the present
worth cost estimate for hydraulic containment ($10,293,000).
4. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable.
From those alternatives that attain ARARs and are protective of human health and the
environment, EPA identified the alternative for each of the six components that utilizes
permanent solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable. This determination was made by deciding which
provides the best balance of trade-offs in terms of 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through treatment; 3) short-term
effectiveness; 4) implementability; and 5) cost. The balancing test emphasized long-term
effectiveness and permanence and the reduction of toxicity, mobility and volume through
treatment; and considered the preference for treatment as a principal element, the bias against
off-site land disposal of untreated waste, and community and state acceptance. In EPA's
judgment, the selected remedy provides the best balance of trade-offs, for the reasons
discussed below.
Capping the contaminated soil in the Operations Area and along the Railroad Right-of-Way,
in conjunction with institutional controls and long-term maintenance, offers the same overall
protection of human health and environmental as excavation, at a fraction of the cost, and
with fewer short-term impacts to on-site workers and the community. It can be designed to
be consistent with future use as a recreational/residential area. The volume of contaminated
soil and wetland soil to be excavated from the Cianci property and culvert sediment is
relatively small, and placing it under the cap is less than half the cost of shipping it off site
for disposal.
In-situ thermal treatment with MNA was selected for treating the overburden aquifer because
it has the potential to remove the greatest amount of contaminants in the Overburden NAPL
Area in the shortest period of time, at a comparatively moderate cost. This may translate to
the most savings in containment and/or treatment of the dissolved phase plume over the long
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Southington, CT
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term. Based on expected reductions in contamination due to in-situ thermal treatment and
MNA, modification of the configuration of the containment and/or treatment system, as
appropriate, is anticipated, which may result in savings below the current estimated $500,000
yearly cost for operations of the NTCRA 1/2 Groundwater System. In-situ thermal is a
complex technology to design, construct and operate, and will require careful planning,
engineering and monitoring to minimize any short-term impacts to on-site workers and the
community during implementation.
In-site thermal treatment was also selected to address the overburden NAPL area because it
will be more effective in the long-term than hydraulic displacement with MNA or hydraulic
displacement with enhanced bioremediation. Hydraulic displacement will remove up to 44%
of the mobile NAPL in the Overburden NAPL Area, which leaves more than half to be
addressed by MNA or enhanced bioremediation. Degradation rates three or ten times the
current rate may not be realistic or attainable, which would impact the effectiveness of
enhanced bioremediation. Hydraulic displacement with chemical oxidation would be
effective, assuming the large amount of oxidant that would be required is commercially
available, although its effectiveness may be impacted by the deposition of manganese oxides
during the chemical oxidation step.
Institutional controls and MNA were selected for the Bedrock NAPL Area because it offers
more overall protection of human health and the environment than the no-action alternative.
The hydraulic containment component offers greater long-term effectiveness for the
overburden and bedrock groundwater than institutional controls and MNA along because it
prevents the spread of groundwater with contaminants that greatly exceed cleanup levels.
Finally, CT DEP expressed its support for each of the components of the remedial action,
with the exception of the institutional controls to prevent exposure to vapor emissions.
The community did not express support or disapproval of any components of the remedial
action, but raised some questions that EPA has responded to in the Responsiveness
Summary. The PRP Group was generally supportive of the selected remedy with the
following exceptions. First, the PRP Group opposes the use of any active treatment
technologies to address the Overburden NAPL Area, but in comparing these alternatives, has
expressed a preference for hydraulic displacement and enhanced bioremediation. Second, the
PRP Group supports the containment and treatment of contaminated groundwater until it is
demonstrated that natural degradation balances the on-going dissolution of contaminants.
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Soulhington, CT
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5. The Selected Remedy Satisfies the Preference for Treatment Which Permanently and
Significantly Reduces the Toxicity, Mobility or Volume of the Hazardous Substances as a
Principal Element.
By treating the Overburden NAPL Area with in-situ thermal treatment, the selected remedy
reduces permanently and significantly the toxicity, mobility and volume of the contaminants
in this area, which are the principal and on-going threat to groundwater quality at and
adjacent to the Site,
By consolidating contaminated soil and wetland soil under a cap in the Operations Area, and
capping the Railroad Right-of-Way, further reductions in mobility of an on-going threat to
groundwater quality is achieved, although not through treatment.
By treating contaminated groundwater through hydraulic containment and treatment, as well
as monitored natural attenuation, the selected remedy permanently and significantly reduces
the toxicity, mobility and volume of contaminants in the groundwater. The NTCRA 1 and
NTCRA 2 Groundwater Extraction and Treatment System has already reduced an estimated
12,500 pounds of VOCs at the Site.
By utilizing treatment as a significant portion of the remedy, the statutory preference for
remedies that employ treatment as a principal element is satisfied,
6, Five-Year Reviews of the Selected Remedy are Required.
Because this remedy will result in hazardous substances remaining on-site above levels that
allow for unlimited use and unrestricted exposure, a review will be conducted within five
years after initiation of the remedial action, and every five years after that, to ensure that the
remedy continues to provide adequate protection of human health and the environment.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan for a comprehensive site-wide remedy for the SRSNE Site on
June 9, 2005. The source control portion of the preferred alternative included in-situ thermal
treatment of NAPL in the overburden aquifer, monitored natural attenuation of the NAPL in the
bedrock aquifer, and excavation, consolidation and capping of soil and wetland soils that pose
human-health and ecological risks. The management of migration portion of the preferred
alternative included containment and treatment of groundwater in the overburden and bedrock
aquifers that exceeds cleanup levels, and monitored natural attenuation of a residual plume
outside the capture zone until the groundwater is cleaned up to natural quality. The remedy also
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Southinflton, CT
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called for institutional controls to prevent human exposure to contaminated groundwater, and
soil/wetland soil/vapor emissions, as well as NAPL in the subsurface, and, to prevent activities
that are inconsistent with the proper maintenance of the cap. The remedy includes a monitoring
program and, because waste is being left in place, reviews every five years to ensure the remedy
remains protective.
Although no significant changes were made to the proposed plan, this ROD has specified certain
measures to be taken in performance of the selected remedy, and provided for additional
flexibility in performance, including, but not limited to: possible future adjustments to the
NTCRA 1/2 Groundwater System, possible soil excavation, if appropriate, following
performance of in-situ thermal treatment, and further delineation of the NAPL performance
standards,
EPA reviewed all written and verbal comments submitted during the public comment period. It
was determined that no significant changes to the remedy, as originally identified in the proposed
plan, were necessary.
O. STATE ROLE
The Connecticut Department of Environmental Protection has reviewed the various alternatives
and has indicated its support for the selected remedy. The State has also reviewed the Remedial
Investigation, Risk Assessment and Feasibility Study to determine if the selected remedy is in
compliance with applicable or relevant and appropriate state environmental and facility siting
laws and regulations. The State of Connecticut concurs with all components of the remedy for
the SRSNE Site with the exception of the institutional controls to prevent exposure to vapor
emissions. A copy of the State's letter is attached as Appendix E.
Record of Decision
Solvents Recovery Service of New England
Southington, CT
Final
September 2005
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PART 3
RESPONSIVENESS SUMMARY
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Solvents Recovery Service of New England, Inc
Responsiveness Summary
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SOLVENTS SERVICE OF NEW ENGLAND RESPONSIVIENESS SUMMARY
PREFACE
The U. S. Environmental Protection Agency (EPA) held a 60-day public comment period
from June 9, 2005 through August 8, 2005 to provide an opportunity for public comment
on the Proposed Plan to address contamination at the Solvents Recovery Service of New
England Superfund Site (SRSNE) in Southington, CT. EPA prepared the Proposed Plan
based on the results of the Remedial Investigation (RT) and Feasibility Study (FS). The RI
was conducted to determine the nature and extent of contamination and to identify
potential risks to human health and the environment. The FS examined and evaluated
various options, or alternatives to address the contamination. The Proposed Plan
presented EPA's preferred alternative for the Site, before the start of the comment period.
All documents which were used in EPA's selection of the preferred alternative were
placed in the site Administrative Record, which is available for public review at EPA
Records Center, One Congress St, Boston, Massachusetts, and at the Southington Public
Library, 255 Main Street, Southington, CT.
The purpose of this Responsiveness Summary is to document EPA's responses to the
questions and comments raised during the public comment period. EPA considered all of
the comments summarized in this document before selecting the final remedial
alternative to address contamination at the Site.
The Responsiveness Summary is organized into the following sections:
A. Overview of the Remedial Alternatives Considered in the FS and the
Proposed Plan, including the Preferred Alternatives—This section briefly
outlines the remedial alternatives evaluated in the FS and the Proposed Plan,
including EPA's preferred alternative.
B. Site History and Background on Community Involvement and Concerns
This section provides a brief history of the site and an overview of community
interests and concerns regarding the site.
C. Summary of Comments Received During the Public Comment Period—This
section summarizes and provides EPA's responses to the oral and written
comments received from the public during the comment period.
A OVERVIEW OF THE REMEDIAL ALTERNATIVES CONSIDERED
IN THE FS AND THE PROPOSED PLAN
Using information gathered during the RI and the risk assessments, EPA identified
several cleanup objectives for the SRSNE site.
The primary cleanup objectives are to mitigate, restore and/or prevent existing and future
potential threats to human health and/or the environment from soil and wetland soil,
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overburden and bedrock groundwater, and non-aqueous phase liquid or NAPL. Cleanup
levels for soil and groundwater are set at levels that EPA and Connecticut Department of
Environmental Protection (CT DEP) consider protective of human health and the
environment.
After identifying the cleanup objectives, EPA developed and evaluated potential cleanup
alternatives to address site contamination. The FS describes the cleanup alternatives and
the criteria EPA used to narrow the potential alternatives to control sources of
contamination and address migration of contaminants,
EPA's Selected Remedy includes the following features:
• In-situ thermal treatment of contaminants in the overburden NAPL area until
site-specific NAPL performance standards are achieved;
• Excavate, consolidate and cap soil and wetland soil that exceed soil cleanup
levels;
• Capture and treat contaminated groundwater in both the overburden and bedrock
aquifers;
• Over time, modification of the configuration of the on-site groundwater
extraction and treatment system, as appropriate;
• Monitored natural attenuation;
• Institutional controls;
• Long term operation and maintenance;
• Five year reviews.
In the Feasibility Study Report, the estimated net present worth of the remedy is
$29,260,000, This alternative was selected because it achieved the best balance among
the criteria which EPA is required by law to evaluate cleanup options. The selected
remedy provides an effective reduction in human health risk through a combination of
source control, management of migration and treatment technologies. The remedy will
attain Federal and State cleanup standards, reduce the volume and toxicity of
contaminated material and utilize permanent solutions to the extent possible.
All of the remedial alternatives considered for implementation at the site are described in
the Record of Decision and are discussed in detail in the FS.
A. BACKGROUND AND COMMUNITY INVOLVEMENT AND CONCERNS.
Site History
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The SRSNE Site is located in the Town of Southington, Connecticut, in Hartford County,
approximately 15 miles southwest of the City of Hartford, It is located on Lazy Lane,
just off Route 10 {Queen Street), and adjacent to the Quinnipiac River.
From 1955 to 1991, Solvents Recovery Service, which later became Solvents Recovery
Service of New England, Inc. (SRSNE), operated as a spent solvent processing and
reclamation facility at the site. Millions of gallons of waste solvents and oils were
handled, stored and processed in the Operations Area. Spent solvents were processed in a
distillation column. Contaminant-laden distillation process water was channeled into a
drainage ditch along the Railroad Right-of-Way and into a buried culvert that discharged
to the Quinnipiac River. Samples of solvents appear to have been discarded in a leach
field. The still bottoms and liquid waste by-products were first disposed of in at least two
unlined lagoons in the Operations Area, and later burned in an open pit. Overflow from
the lagoons drained onto the neighboring Cianci property. Ash from the burn pit was
used as fill in the Operations Area. After 1976, the solvents were blended to create a fuel
product for use in rotary kilns. There are numerous documented instances of leaks and
spills to bare ground. None of the original facility structures remain.
After 1976, operations at SRSNE focused on blending the sludge and still bottoms with
flammable liquid wastes for use as a waste-fuel product for rotary kilns. In 1988, the
batch stills used in the distillation process were removed, and fuel blending became the
primary enterprise of the facility until it closed in 1991.
Past operating practices, such as the use of lagoons and a leach field, contributed to
contamination on the SRSNE Operations Area and surrounding properties. Poor
housekeeping from a variety of practices, including the unloading and loading of tank
trucks, the transfer of spent solvents to storage tanks, as well as the improper handling
and storage of drams, resulted in numerous leaks and spills to the bare ground and into
the underlying aquifer.
The presence of volatile organic compounds (VOCs) in drinking water forced the closing
of the Town of Southington's Production Well No. 4 in 1976, and Production Well No. 6
in 1979. Subsequent environmental investigations revealed that SRSNE was a major
source of VOC contamination to the groundwater ill this area.
From 1983 to 1988, EPA and the State of Connecticut took enforcement actions to
compel SRSNE to cleanup the facility and its operations. SRSNE failed to comply with
these enforcement efforts. In 1992, EPA removed soil contaminated with volatile organic
compounds (VOCs) and polychlorinated biphenyls (PCBs) from a drainage ditch along
the eastern side of the Operations Area. Chemicals stored on site were also removed.
From 1995 to 2005, the Potentially Responsible Parties' Group (PRP Group-businesses
and individuals that sent waste material to SRSNE) installed and operated a groundwater
and containment system for the overburden and bedrock aquifers. In addition, they
completed various remedial investigations and feasibility studies.
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History of Community Involvement
Prior to the PRP Group undertaking actions under the direction of EPA and CT DEP to
contain and treat contaminated groundwater, community concern and involvement was
high. At this time, community participation can be characterized as moderate to low,
EPA, CT DEP and the SRSNE PRP Group have kept the community and other interested
parties apprised of site activities through informational meetings, fact sheets, press
releases, open houses, and public meetings,
C. SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
This Responsiveness Summary addresses comments pertaining to the Proposed Plan that
were received by EPA during the 60-day public comment period (June 9 to August 8,
2005). The Proposed Plan was mailed to 271 members of the general public, elected
officials and local media, and 454 individuals with some association to the SRSNE PRP
Group. Nine sets of written comments were received - five from the general public, one
from Elsie Patton on behalf of CT DEP, and three on behalf of the 250-300 members of
the SRSNE PRP Group, one of which was a request to extend the comment period from
30 days to 60 days. Four individuals submitted verbal comments at the public hearing on
June 30, 2005, including Gus Moody on behalf of the SRSNE PRP Group.
What follows are EPA's responses to significant comments that pertain to the remedial
action. Where possible, EPA has grouped similar comments, and prepared a single
response, A copy of the transcript of the public hearing and copies of all written
comments received during the 60-day comment period can be found in the
Administrative Record.
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1. Request for Extension to the Comment Period
One request was made to extend the comment period by 30 days. This request was
made by the PRP Group.
EPA Response to Comment 1
On June 29,2005, EPA issued a press release to announce that the comment period
had been extended by 30 days. The 60-day comment period ran from June 9 thru
August 8, 2005.
2. State Support for EPA's Preferred Remedy
Elsie Patton, Director of Planning and Standards, Bureau of Waste Management, on
behalf of the CT DEP, submitted comments in support of the following components
of EPA's proposed remedy:
• In-situ thermal treatment of the overburden aquifer;
• Excavation, consolidation and capping of contaminated soils and wetland
soils on site;
• Pumping, treating and monitoring groundwater, and restricting use of
contaminated groundwater combined with monitored natural attenuation;
and
• Supplemental groundwater containment if municipal wells in the Curtiss
Street Town Well Field are activated by the Town of Southington in the
future.
CT DEP also states that it is their belief that in-situ thermal treatment of the
overburden aquifer will result in the greatest removal of non-aqueous phase liquid
(NAPL) from the groundwater in the shortest time frame.
EPA Response to Comment 2
After review of all the comments received, EPA agrees that the above components of
the proposed remedy should be selected for the SRSNE Site. Like the State of
Connecticut, EPA believes that in-situ thermal treatment of the overburden aquifer
will result in the greatest removal of NAPL, which is the primary threat to
groundwater quality at this site, in the shortest time frame.
The State's comments did not include a specific discussion of EPA's proposed
institutional controls that, among other things, would prevent human exposure to
vapors emanating from the subsurface. Following receipt of the State's comments,
and further discussions with the State, the State decided not to concur in this
component of the remedy, EPA expects to engage in further discussion with the State
regarding the planned institutional controls following issuance of the Record of
Decision.
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3. Comments Offering Alternative Remedies
Three commenters offered different remedies to address the contamination at the
SRSNE Site. These include:
• Continuation of the existing groundwater containment and treatment
system only;
• Excavation of the contaminated materials;
• Capping without in-situ thermal treatment of the overburden;
• Sealing the bedrock and reclassifying the groundwater; and
• Hydraulic displacement and enhanced bioremediation of the NAPL in the
overburden aquifer instead of in-situ thermal treatment,
EPA Response to Comment 3
With the exception of sealing the bedrock and reclassifying the groundwater, all of
the alternatives suggested were evaluated and carefully considered during the
Feasibility Study (FS). EPA feels that the selected remedy, which is the remedy that
was proposed in May 2005, provides both short-term and long-term protection of
human health and the environment; attains all federal and state applicable or relevant
and appropriate environmental requirements; reduces the toxicity, mobility and
volume of contamination at the site; is cost effective and utilizes permanent solutions
to the maximum extent practicable. Reclassification of the groundwater is discussed
further in EPA's response to comments 8 and 17.
4. "Strategic Vision" of the PRP Group
The PRP Group submitted as a comment their "strategic vision" for the SRSNE Site
which states "in relevant part as follows: 'The ultimate outcome of the PRPs'
involvement at the SRSNE Site is that the site is remediated in a cost-effective
manner to pose no unacceptable risk to human health or the environment, future use
of the site is controlled to prevent future risks, and the public understands the issues
involved and trusts the actions of the PRPs and the government.
EPA Response to Comment 4
EPA acknowledges that the PRP Group has done a considerable amount of work at
the Site pursuant to two Administrative Orders on Consent (AOCs) including
performance of response actions to contain and treat contaminated groundwater at the
Site, completion of the remedial investigation and preparation of a feasibility study.
However, in making a remedy decision, EPA is trusted with the authority to make
decisions regarding the SRSNE Site on behalf of the United States. As such, EPA is
required to meet the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA, or "Superfund") and the
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National Contingency Plan (NCP) and is not bound by the strategic vision of the
SRSNE PRF Group.
5, Comment that The Site Poses No Current Risk to Public Health
The PRP Group states that their remedial actions and investigation over the last
decade have resulted in a stable, fully-contained and well-characterized site that poses
no current risk to public health. They also identify as a "key issue" what, if any,
remedial measures in addition to those already implemented at the site are
appropriate,
EPA Response to Comment 5
EPA also believes that the SRSNE Site poses no current risk to human health, as a
result of early response actions taken at the Site by both the PRP Group and EPA,
Prior to the PRP Group's involvement with the Site beginning in 1994, EPA
conducted emergency removals of PCB-contaminated soil and hazardous chemicals
in the on-site laboratory. The PRP Group has implemented two non-time critical
removal actions to contain highly-contaminated groundwater in the overburden and
bedrock aquifers. For the vast majority of Superfund sites listed on the NPL, there is
no current human health risk, and if one is identified during site characterization
activities, than it is typically addressed by EPA's removal program. The main goal of
Superfund's remedial program is to prevent future risk in the long term to human
health as well as ecological receptors. This approach of phasing actions - early
response to address more immediate threats and long-term remediation to address
future risks - is consistent with the NCP. The contaminant concentrations at the
SRSNE site are tens, hundreds and in some cases thousands of times their regulatory
limits resulting in an unacceptable human health risk (with excess cancer risks
calculated to be as high as unity (every person who drinks the water would potentially
get cancer over the course of his or her lifetime), and potential exposures estimated at
700 times greater than benchmarks for the protections of non-cancer). There are few
Sites in New England, and possibly the United States, that if left unaddressed, would
pose a greater risk to human health and the environment. At least 120,000 gallons of
highly-mobile NAPL (1,000,000 pounds) are estimated to reside in the overburden
aquifer, upgradient of a potential public drinking supply. The current response
actions at the site (i.e., NTCRA 1 and NTCRA 2) are preventing the groundwater
plume from getting larger, but are not treating the soil and NAPL in the subsurface.
6. PRPs Express Support for Many Components of the Proposed Remedy
The PRP Group comments indicate that they agree with many of the components of
EPA's proposed remedy, including the following: the Operations Area and adjacent
railroad grade soils should be capped; soil contaminated with PAHs, PCBs, and
metals on the Cianci property should be placed under the cap; the culvert crossing the
Cianci property should be replaced, and the wetland soils at the culvert outfall should
be placed under the cap; the future use of the groundwater should be restricted; and
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contaminated groundwater should be contained and treated until it is demonstrated
that natural degradation processes balance the ongoing dissolution of contaminants.
EPA Response to Comment 6
After review of all the comments received, EPA agrees that these components of the
remedy in the Proposed Plan should be selected for the SRSNE Site. With respect to
groundwater containment, EPA's ROD specifies that containment will continue in
order to ensure that contaminated groundwater does not migrate until acceptable
levels as defined in the ROD are attained. EPA's selected remedy, of course, also
includes other components. To the extent that the PRP Group has commented on
other components of the remedy, such as, thermal treatment of the overburden NAPL
area, EPA's responses to such comments are addressed below (see, e.g., EPA's
response to comments 9, 11, and 12).
7. PRP Concern that EPA Has Not Complied with Public Participation
Requirements of CERCLA and the NCP
The PRP Group expressed concern that public participation requirements of
CERCLA and the NCP were not met for a number of reasons:
a) Key documents were not included in the administrative record;
b) Documents were not placed in record contemporaneously (i.e., at the time they
were written);
c) Lack of communication with public regarding on-going technical discussions
with the PRP Group; and
d) PRP Group was negatively impacted by having to research and locate many
materials EPA should have placed in the administrative record.
EPA Response to Comment 7
a) As part of their comments, the PRP Group provided a computer disk (CD)
containing 36 documents that they believe should have been included in the
administrative record. Because EPA adds all comments received during the public
comment period to the administrative record, these documents that were submitted
along with the PRP Group's comments have now been added to the administrative
record.
EPA also reviewed the record that was available to the public at the time of issuance
of the Proposed Plan in order to evaluate the PRP Group's concern that the Agency
failed to comply with public participation requirements of CERCLA and the NCP
because these documents were not previously included in the record. We conclude
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that the Agency's record as available at the time of the public comment period
contained all of the proper documents.
Most of the "key" documents included on the PRP Group's computer disk consist of
PRP drafts of the FS, or, correspondence between EPA and the PRP Group regarding
PRP drafts of the FS. EPA never approved these draft versions of the FS, in part
because they were incomplete with respect to source reduction, contained
inaccuracies, unsupportable technical information, unsupportable cost estimates, and
were not written in plain English. EPA did not use these drafts of the FS as they were
supplied by the PRP Group for remedy selection purposes, so, under the NCP, EPA is
not required to include these draft documents in the administrative record. Moreover,
the public could not have provided meaningful comment based on a review of these
draft documents or correspondence regarding draft documents. The final FS was
included in the administrative record.
Similarly, several documents on the PRP Group's CD consist of draft RI deliverables,
and correspondence between EPA and the PRP Group regarding PRP drafts of RI
deliverables. These documents were not relevant to remedy selection because the
draft documents were incomplete or contained inaccuracies, nor could the public have
provided meaningful comment based on a review of these drafts or correspondence
regarding these drafts. The final RI deliverables were included in the administrative
record.
Other documents included letters from EPA counsel and PRP Group counsel. These
are enforcement related in that they dealt with the RI/FS process, for example,
responding to the PRP Group's concerns about EPA's use of redline-strikeout format
in reviewing PRP deliverables (see EPA's response to comment 10). None of the
documents concerning the RI/FS process were relevant to remedy selection.
Another document identified by the PRP Group as belonging in the administrative
record, which was mistakenly attributed to EPA, presents a number of "analysis
factors" that the PRP Group was suggesting that EPA use in place of or in addition to
the NCP-mandated nine criteria for remedy selection. Because EPA neither
considered nor relied on these analysis factors in selecting a remedy, it is not
appropriate for inclusion in the administrative record.
Still other documents are studies performed by the PRP Group in 1994 under the
administrative consent order for completion of the first non-time critical removal
action (or NTCRA) at the SRSNE Site. Again, these documents are irrelevant to
remedy selection. The results of monitoring that has been done to show compliance
of the NTCRA 1 (containment of contaminated overburden groundwater) and
NTCRA 2 {containment of contaminated bedrock groundwater) extraction and
treatment systems and how the groundwater plumes have been changing in terms of
concentrations, shape and areal extent, over time, are relevant and were included in
the administrative record. These reports are Demonstration of Compliance Reports
No. 1 thru No. 56 (except Nos. 38,39 and 40) which cover the time period 1995 to
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2004, and, Interim Monitoring Reports No. 1 thru No. 13 (except Nos. 6, 8, 9 and 10)
which cover the time period 1999 to the first half of 2005.
Another document that EPA did not consider or rely on for the remedy selection is a
letter from CT DEP to the PRP Group's consultant, BBL, regarding the PRP Group's
proposed use of a specific monitoring well, TW-12, as a background well for the
purpose of establishing groundwater cleanup levels. During discussions between
EPA, CT DEP and the PRP Group in the early months of2005, the Agencies were
informed that well TW-12 was no longer a viable monitoring well. Groundwater
cleanup levels in the ROD are based on EPA risk numbers, CT RSRs, and in the case
of inorganics, a background study to be conducted during design. In short, this
document was also not relevant to remedy selection.
The PRP Group also expressed concern that a 2002 document that outlines a process
for distinguishing outwash, ablation till and basal till within the potential overburden
NAPL zone should be in the administrative record but is not. The outcome of this
evaluation to distinguish outwash, ablation till and basal till is reflected in the report
of the NAPL Delineation Pilot Study conducted in November 2003 and the May 2005
FS, both of which arc in the administrative record. As a result, EPA believes the
appropriate information was included in the administrative record file.
EPA does not appear to have in its files three documents included on the PRP
Group's CD as they were not authored by or addressed to EPA, nor was EPA copied.
One of these is a PRP Group internal memorandum.
The PRP Group misidentified two other documents as missing from the
administrative record when in fact they are in the administrative record with the
document identification numbers 4875 and 5624.
Of the 36 documents included on the PRP Group's CD, there is a three-page
document that arguably could have been included in the 14,000 page administrative
record. This is EPA's approval in 1996 of the PRP Group's RI workplan. Because
the 1998 Rl report is included in the administrative record, EPA believes that this
oversight was not substantive (i.e., it was clear from the record including the
proposed plan that the 1998 RI was a final EPA-approved document).
At the time of issuance of the proposed plan, EPA's administrative record included
nearly 400 documents (approximately 14,000 pages). Among these were numerous
documents that EPA added in response to the PRP Group's request that they be
included in the administrative record. The two most notable ones are the 1999
Environ report entitled Remedy Implementation Risk Evaluation, and Risks of
Vertical Mobilization of DNAPL during Thermal Remediation (Appendix W of the
May 2005 FS). EPA believes that that PRP Group requested that these documents be
placed in the administrative record specifically because they concern risks associated
with various remedial alternatives, including, but not limited to, the risks of vapor
release and contaminant migration associated with certain thermal remedies.
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Although EPA did not agree with all the conclusions presented in these documents,
EPA did consider each during remedy selection, and EPA properly added these
documents to the administrative record,
EPA's administrative record as a whole, including the final FS and Proposed Plan,
makes plain that in-situ thermal treatment of the Overburden NAPL Area contains a
short-term risk from the potential escape of emissions during construction and
operation, as well as a risk of downward mobilization of contaminants into the
bedrock. (See, e.g., Proposed Plan at 17, 20, 21, and 22). Thus, the public had a fair
opportunity to consider the issues that the PRP Group claims were somehow excluded
from the record.
Finally, EPA guidance states where PRPs are performing the RI/FS, the PRPs must
submit all technical information to EPA, but EPA is responsible for decisions on what
documents comprise the administrative record. PRPs cannot be responsible for
decisions on what documents comprise the administrative record, because of, "among
other things, the potential for a conflict of interest." See Final Guidance on
Administrative Records for Selecting CERCLA Response Actions (1990), page 32.
EPA reviewed the voluminous documentation that was generated during the course of
the RI/FS and included in the record those documents that it considered or relied on,
including those documents that it considered but ultimately rejected. Draft PRP
documents that contained inaccuracies, unsupportable technical information, were
irrelevant or repetitious of information contained elsewhere were properly excluded
from the record.
b) The PRP Group also comments that EPA did not place documents into the record
contemporaneously, i.e., at the time that these documents were written. Since the
early 1990's, EPA has placed numerous documents into the administrative record,
including EPA's remedial investigation (RI) report and the PRP Group's remedial
investigation report, prepared after the PRP Group agreed to perform the remainder
of the remedial investigation in 1997. EPA's RI report (Volumes 1-4, TetraTech
NUS) was placed in both repositories shortly after it was published in 1994 and the
PRP Group's RI report (Volumes 1-2, BBL) was similarly placed in both
repositories shortly after it was published in June 1998. These were the most
comprehensive final technical documents available concerning the Site prior to
issuance of the final FS in 2005. The baseline human-health and ecological risk
assessments are included in 1994 RI Report.
The Agency acknowledges that for several years after issuance of the PRP Group's
RI report in 1998, it did not add a significant number of records to the
administrative record file. During this period, EPA and the PRP Group were
working on the FS, which was not finalized until May 2005, shortly before issuance
of the Proposed Plan. As soon as the FS was final, EPA made it available to the
public. It is not unusual for the number of additions to the administrative record file
to decrease during the time EPA is working on a draft document, particularly after
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issuance of the RI. This is due, in part, to the fact that EPA does not generally
include draft documents in the administrative record.
Even if it would have been advisable for EPA to have prepared an update or a fact
sheet for the public during the time before the final FS was issued, or if there were
some deliverables that were finalized during this time period that could have been
made available (such as quarterly sampling results that demonstrated that NTCRA
1/2 Groundwater System continued to perform successfully, update to the human-
health risk assessment, or results of follow-up soil sampling on the Cianci
property), EPA does not believe that failure to take these actions violated the public
participation requirements of CERCLA or the NCP, or in any way harmed the
public participation process at this Site.
In general, not all communities desire or request regular input in the Superfund
process. See 55 Fed. Reg. 8767 (1990) ("the degree of appropriate [public]
involvement will vary with the characteristics of the site and the nature of the
response."). After the SRSNE facility closed and the NTCRA 1/2 system was up
and operational, the degree of public inquiries to EPA about the Site greatly
diminished. During the time that EPA and PRP Group were working on the FS,
neither the Town nor members of the community requested that EPA produce a
written update or fact sheets or provide any other information concerning
developments at the Site. EPA nevertheless provided outreach to the community
during this period, as explained in response I.e.
As the first step in the remedy selection process, EPA identifies its preferred
remedy and presents it to the public in a Proposed Plan. See 40 C.F.R. §
300.430(f)(2). The purpose of the Proposed Plan is to supplement the RI/FS and
provide the public with a reasonable opportunity to comment. See 40 C.F.R. §
300.430(f)(2). EPA's Proposed Plan for this Site is written in plain English, and
provides a relatively easy to understand description of EPA's preferred alternative,
including in-situ thermal treatment, as well as the other alternatives under
consideration, in comparison to the comprehensive more technical evaluation
provided in the FS itself. See, e.g., Proposed Plan at 22 (for a three paragraph
description on: "What are in situ thermal treatment methods? How do they work?
Why use in situ thermal treatment?") The Proposed Plan makes plain that in-situ
thermal treatment technology includes a risk of vapor emissions during construction
and operation of this technology, and a risk of downward mobilization of NAPL
contaminants. See Proposed Plan at 17,20, 21, and 22. EPA mailed a copy of the
Proposed Plan to 271 members of the community including the general public,
elected officials and local media. EPA discussed these risks at an informational
meeting on June 8, 2005, including a discussion of how these risks will be
addressed. Other than the PRP Group, no one requested an extension of the thirty-
day public comment period. Other than the PRP Group, no one submitted
comments in which they expressed a concern about the risks of vapor emissions or
downward migration of contaminants; no one indicated that they were confused
about the proposed remedy because it was too complicated or complex; and no one
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expressed concern about the public participation provided by EPA into the remedy
selection process.
For these reasons, EPA concludes (1) that the Agency complied with CERCLA and
NCP requirements to add documents to the record contemporaneously, including
but not limited tathe EPA RI Report which contain the baseline human-health and
ecological risk assessment and the PRP Group RI Report that were placed in the
record file in Boston and Southington in 1994 and 1998, respectively; (2) that few
documents were finalized and ready to be placed in the administrative record file
during the time period of concern to the PRP Group; (3) that those documents that
were finalized during the period of concern were placed in the administrative record
in advance of the public comment period, but to the extent that they were not placed
in the administrative record contemporaneously, these documents were generally
supplemental in nature (i.e., they generally supplemented the large amount of data
that had already been placed in the administrative record file and was available to
the public); and (4) that the community had a meaningful opportunity to comment
on EPA's preferred alternative and the other alternatives considered in the FS,
including but not limited to the risk of vapor emissions and the potential for
downward migration during performance of EPA's preferred alternative.
c) In the view of the PRP Group, there has been a lack of public participation at the
SRSNE Site. EPA has addressed general concerns about public participation in the
Agency's responses to comments, as provided in parts 7.a. and 7.b., above.
However, EPA adds the following:
EPA has conducted public participation outreach activities in the Town of
Southington throughout EPA's involvement at the SRSNE Site. In the early
years when the SRSNE facility was in operation, community concern was
high. However, since the SRSNE facility closed in 1991, and groundwater
containment was implemented in 1995, the concerns expressed by the
community and the Town about the Site have diminished significantly.
The PRP Group focuses their comments on the time period since 1998. Since
1997, Jim Murphy has served as EPA's Community Involvement Coordinator
for the SRSNE Site and the Old Southington Landfill Site, both of which are
located in the Town of Southington (a community of about 40,000 people).
On a regular basis since 1997, Jim Murphy has visited the Town, spoken with
the Town Manager and other representatives of the Town, visited or viewed
the SRSNE Site and the surrounding area, visited the library in the Town of
Southington which is the local repository for the administrative record for
both SRSNE and Old Southington, spoken with the Town librarians to
determine whether the library has seen a lot of interest in viewing the SRSNE
and Old Southington administrative record files, and visited the homes of
community members that live near both Sites.
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Notwithstanding these continuing efforts, community participation has been
moderate to low since the start-up of the NTCRA 1 groundwater containment
and treatment system in 1995 as shown by the following examples. In July
1991, EPA awarded the community group SAFE (Southington Association for
the Environment) a technical assistance grant to help them with their review
of Site documents which can be highly-technical in nature. The initial amount
of the award was $49,600. In September 1998, SAFE received an additional
$25,000. EPA did not receive comments from SAFE on any major
documents, including the PRP Group's 1998 remedial investigation report. In
October 2003, EPA closed out the grant, which had a remaining balance of
close to $34,000 that the community group had not spent, due to inactivity.
This is indicative of the trend EPA has observed at the Site - a high level of
interest while SRSNE was an operating facility which began to diminish with
the implementation of groundwater containment and treatment in 1995.
In June, 1998, EPA sent out a mailing to approximately 950 residents of
Southington and other interested parties to invite them to a public meeting
concerning the SRSNE Site. A notice regarding this meeting was also placed
in the local newspaper, hand delivered to residents in the immediate vicinity
of the Site, and posted in the town hall and public library. Only a small
number of community members attended the meeting (two residents and one
local reporter signed the sign-in sheet). A 10-page fact sheet was prepared for
the meeting and was mailed to those on the Site mailing list following the
meeting.
During the first 6 months of 1999, Jim Murphy made at least 4 trips to
Southington to introduce a new Remedial Project Manager to town officials
and local residents.
In August 1999, the PRP Group held an "open house" at the SRSNE Site.
EPA sent an invitation to the open house to approximately 550 persons. Less
than 10 residents and members of the media attended the event. A 19-page
fact sheet was also made available at the open house. Later that year in
October, EPA mailed and hand delivered a flyer announcing the beginning of
environmental field work activities at the SRSNE Site.
During 2000-2001, EPA held numerous meetings with town officials and two
public meetings concerning remedial action activity at the Old Southington
Landfill, Notice of all public meetings was sent to residents in the vicinity of
SRSNE. While making approximately 12 trips to Southington during 2000-
2001, Jim Murphy routinely drove by the SRSNE site and occasionally
stopped to speak to local residents at both Southington Superfund sites.
In 2003, Jim Murphy and others interviewed the Town Manager and four
other Town officials, as well as three members of the community, in
connection with EPA's Preliminary Reuse Assessment. At that time, the only
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concern expressed by either the Town or members of the community was that
they were anxious to have the cleanup decision finalized.
EPA provided notice to the community concerning the public information
meeting on June 8, 2005, and the public hearing on June 30, 2005, by mailing
271 copies of the Proposed Plan to local residents, officials, and media, and to
454 individuals with some association with the PRF Group. Copies of the
plan were also distributed door-to-door along Lazy Lane and made available
to the general public at the Southington Library and Southington Town Hall.
EPA staff contacted local print media and were interviewed by reporters from
the Meriden Record-Journal and the Waterbury Republican-American
newspapers. Several articles about EPA's preferred alternative and both
public meetings appeared in the local press. In addition to representatives of
the PRP Group and the regulatory agencies, approximately eight citizens,
town officials, and media members attended the June 8 meeting;
approximately 15 citizens, town officials, and media members attended the
public hearing on June 30.
Jim Murphy has been involved with the SRSNE Site for the last eight years,
and Karen Lumino, the Remedial Project Manager, for the last seven years.
At no point during their involvement with the SRSNE Site has either one
received any written or verbal requests for additional public participation from
the Town or the community (e.g., requests for meetings with EPA, additional
documentation, or greater public input) nor have they received complaints
from the Town or the community that they are dissatisfied with EPA's public
participation efforts.
For the many reasons stated above, EPA believes that its effort is
commensurate with the public's interest in the SRSNE Site and as such, has
satisfied its public participation responsibilities.
d) Finally, the PRP Group states that it was negatively impacted by having to research
and locate many materials that EPA should have placed in the administrative
record. Because EPA does not agree that any of the documents on the PRP Group's
CD should have been placed in the administrative record, EPA does not believe that
its actions negatively impacted the PRP Group.
8. Comments Regarding Potential Future Use of the Site and EPA's Response to
Public Concerns and Desires as Expressed in the Preliminary Reuse Assessment
Two sets of comments were received that pertain to the future reuse of the SRSNE
Site.
The first eommenter, the PRP Group, is uncomfortable with the selected remedy
because in its opinion, it may not address public concerns and desires concerning
reuse of the Site as expressed during interviews with EPA for the Preliminary Reuse
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Assessment (EPA, September 2003), In particular, they feel that in-situ thermal
treatment is akin to a "reuse that would ... result in air emissions" which neighboring
residents oppose, and, would result in a significant delay in returning the site to a
beneficial reuse. The PRP Group further opines that either of the remedies that they
prefer, immediate capping with TI determination and groundwater reclassification
with no active NAPL remediation, or, hydraulic displacement of the NAPL zone,
would return the Site to the expected future reuse sooner than EPA's selected remedy.
The second commenter asked when the conversion of the railroad easement to a bike
path will be completed.
EPA Response to Comment 8
EPA's selected remedy addresses the concerns and is fully consistent with the desires
raised by the community. The first commenter (the PRP Group) appears to
misunderstand the purpose of EPA's reuse assessment. The purpose of the reuse
assessment is to assess the likely long-term use and reuse scenarios for the property,
not to assess the use of the property during the relatively short period of time that
cleanup activities will be on-going.
Based upon the community's reuse plans, EPA has decided to clean up the Site so
that it would be acceptable for recreational use in the future. EPA's decision to clean
up the property to recreational standards is consistent with the Site's potential use as a
component of the rails-to-trails project endorsed by the community, town officials,
and the State of Connecticut, which owns the railroad easement. It is the
understanding of the Agency that the PRP Group also supports the reuse of the Site
for the rails-to-trails project.
The PRPs also state that the selected remedy would adversely impact the time to
complete the proposed rails-to-trails project, a key concern of the community. The
selection of in-situ thermal technology over other treatment technologies has little
impact on the time frame to complete the project. With the exception of complete
excavation which would allow the Site to be reused in the shortest amount of time,
the remaining treatment technologies could be implemented in about the same
amount of time (6 months to two years). The remedy proposed by the commenter as
being the "fastest route" to rails-to-trails conversion is wholly dependent on
reclassification of the groundwater at the SRSNE site. Connecticut however has not
reclassified the groundwater at the Site and has expressed support for EPA's decision
to cleanup the Site to drinking water standards at this Site. While it is true that a
request for reclassification of the groundwater in the vicinity of the SRSNE site to
Class GB could be prepared and submitted, EPA believes it is unlikely that such a
request would be approved by CT DEP, as explained in EPA's response to comment
17. •
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In response to the second commenter, EPA expects to have the site ready for
construction of the bike path in approximately four to six years from implementation
of the remedy. The actual construction of the bike path is not a component of this
remedy, nor could it be a component of any remedial action taken under the
Superfund program as it is viewed as an enhancement and is not necessary for the
protection of human health and the environment. However, EPA does attempt to
leave Superfund sites in a condition that supports the anticipated future use of the site,
The remedy selected for the SRSNE site supports the bike path in two ways. First,
the cleanup levels selected for soil are protective of adults and children who may
come in direct contact with soils at the Site under a recreational reuse scenario.
Second, the cap that will be constructed along the railroad easement will be designed,
built and maintained in a manner to allow for reuse as a bike path.
9. Comments Regarding EPA's Response to Community Concerns Regarding Air
Emissions Associated with the Selected Remedy
The PRP Group states that the opposition of the residents living near the SRSNE Site
to any remedial alternative that results in air emissions cannot be overstated, and, that
EPA dismissed these concerns without providing the residents with sufficient
information regarding the emissions issues. The PRP Group also states that
community concern about the risks associated with air emissions from the selected
remedy will be even greater when they learn that EPA screened out similar thermal
options in the June 2005 feasibility study for the Durham Meadows site, also in
Connecticut, due to "volatilization concerns to nearby inhalation receptors,"
The commenter also asked EPA to provide the basis upon which it draws the
conclusion that in-situ thermal treatment can be operated safely at SRSNE and
questions why EPA did not discuss the experiences at the Silresim Site and
conclusions of the Durham Meadows FS.
A second commenter asked if in-situ thermal technology had been used elsewhere in
the USA, and if so, where and how often.
EPA Response to Comment 9
EPA disagrees with the PRP Group's comment that EPA dismissed the public's
concerns about air emissions. EPA fully recognizes the seriousness of the public's
concern about the potential for air emissions, despite the fact that the only comment
received on this issue came from PRP Group. EPA shares these concerns. As a
condition of remedy selection, EPA considered only remedial alternatives that would
comply with Connecticut's standards for regulating air emissions, which are ARARs
for the selected remedy. Our understanding is that the PRP Group has already
received a preliminary determination from at least one thermal vendor that
Connecticut discharge criteria for volatile organic compounds can be met for this
Site. The specific components of the in-situ thermal technology designed to
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reduce/eliminate emissions, and the potential risk to neighboring residents include the
following;
a) A thermal oxidizer, potentially with vapor phase carbon adsorption
canisters on the effluent end, will be used to destroy or trap the
contaminants that are recovered from the ground in the vapor phase.
Emissions from the thermal oxidizer will be monitored to ensure that they
meet Connecticut discharge requirements.
b) Fugitive emissions will be controlled by maintaining a vacuum on the
subsurface throughout the heating, and for a period after heating to ensure
that vapors are not emitted that are above Connecticut emissions
standards. A vapor barrier will be installed on the surface of the treatment
area and it will extend approximately 10 feet beyond the limits of the area
to be treated. Backup blowers and generators will be used to ensure that
vapors are captured in case of a failure of the primary blower or a general
power failure.
c) Monitoring will be conducted during installation and operation of the
thermal remediation system. At a minimum, the monitoring program will
include monitoring of breathing space of on-site workers during all
invasive activities such as drilling; perimeter air monitoring throughout
construction, heating and system cool-down; and monitoring of the
effluent from the thermal oxidizer as required by state law.
The methods described above for reducing/eliminating the potential risk from air
emissions are standard operating procedures for in-situ thermal projects. In-situ
thermal desorption was used to recover contaminants similar to those at the SRSNE
Site (PCE) from an area immediately adjacent to a residential area. (A picture of this
installation was shown at the June 8, 2005, public meeting.) The system operated for
approximately eight months, and air monitoring was performed at least once a day
during construction and operation. Air concentrations at the perimeter of the
treatment area never exceeded acceptable levels. At Air Force Plant 4, Fort Worth,
Texas, electrical resistance heating was used to remediate contaminants similar to
those at the SRSNE Site (TCE) from underneath an occupied building. Continuous
air monitoring was performed within the building during operation of the remediation
system and no air emissions of concern were recorded.
EPA does not agree that that insufficient information was given to the public
regarding emission issues. Prior to mailing the proposed plan, EPA went door-to-
door in the immediate neighborhood of the site to inform residents of EPA's preferred
alternative and to notify them of the upcoming public comment period. EPA's
proposed plan clearly states that in-situ thermal technology has potentially greater
short-term impacts resulting from the complexity of the technology and the potential
for escape of emissions during implementation. At the public information meeting on
June 8, 2005, the day before the comment period began, EPA's expert on in-situ
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thermal technologies, Dr. Eva Davis, of the Robert S. Kerr Environmental Research
Center, was brought in from Ada, Oklahoma, to discuss the potential risks from use
of this technology and the engineering and monitoring that has been successfully
employed at other sites - including those immediately adjacent to residential
properties, main transportation arteries or even under occupied buildings - to
safeguard the public.
In addition, although EPA did not agree with the report, EPA included in the
Administrative Record a report authored by Environ Corporation for the SRSNE PRP
Group entitled Remedy Implementation Risk Evaluation (November 1999). This
report laid out the PRP Group's concerns regarding emissions from the site. As a
result, the community has access to "both sides" of the discussion regarding this
issue. As stated earlier, no comments were received from the general public
expressing concern about the risks associated with vapors from the use of in-situ
thermal treatment at the SRSNE site.
As to the matter of similar in-situ thermal technologies being screened out from the
feasibility study for the Durham Meadows site due to "volatilization concerns to
nearby inhalation receptors," this is a true statement although presented as it was by
the commenter as a stand-alone conclusion without the benefit of the specifics of the
site is misleading. In-situ thermal technologies were considered for treatment of the
contamination at Merriam Manufacturing (not Durham Manufacturing). However,
unlike at SRSNE where the contamination targeted for treatment with in-situ thermal
is at tens of feet below the ground surface, most of the contamination at Merriam
Manufacturing is at a depth of 0 - 1 foot, essentially at the soil surface, and thermal
remediation is not applicable. Generally speaking, the further from the ground
surface the contamination is, the easier it is to run an in-situ thermal system without
releases of volatilized organics into the atmosphere. Thus, EPA's decision to screen
out in-situ thermal technologies at Merriam is not relevant to the SRSNE Site. It is
however interesting to note that at one location at the Merriam Manufacturing facility
where contamination exists at depth, EPA's proposed remedy calls for soil vapor
extraction, a technology that like in-situ thermal, facilitates the removal of
contaminants by drawing them up as a vapor phase to be collected/treated on the
surface.
Contrary to the statement made by the PRP Group, in-situ thermal treatment is not an
untested technology. EPA bases its conclusion that in-situ thermal treatment can be
operated safely on the fact that is has been operated safely at approximately 100 sites,
either as small-scale demonstration projects or full-scale implementation, across the
country over the last 12 years. With every application, something new is learned that
can be applied to future applications. In the case of the Silresim site, which the
commenter mentioned specifically, the venting problems were due to a clogged fitting
that did not allow vapors to be extracted, and prolonged contact of condensed vapors
with CPVC pipe, which caused the pipe to deteriorate. The pipe failed and vapors
that were below harmful levels were released into the atmosphere. These problems
will be avoided at SRSNE by the use of different above-ground piping materials.
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Finally, EPA did include in its presentation to the public on June 8, 2005, some of the
engineering concerns and challenges associated with in-situ thermal treatment, but
did not discuss the technical issues presented by other sites, including Silresim and
Merriam Manufacturing, because it was more important to discuss how site-specific
issues would be addressed at SRSNE than to detail experiences at other sites that have
employed this technology.
10, PRP Comment that EPA "Violated" the RI/FS Administrative Order on Consent
The PRP Group stated their concern that "EPA did not provide coherent and
comprehensive comments on the Group's June 25, 2004 draft FS" and as such,
"violated" the administrative order under which the FS was conducted.
EPA Response to Comment 10
This is a comment on an enforcement issue, not a comment on remedy selection and
does not necessitate a response. However, EPA does not agree with the assertion that
EPA did not provide "coherent and comprehensive comments on the PRP Group's
June 25, 2004 draft FS" and as such, violated the administrative order for the RI/FS.
As stated by the commenter, one of the options available to the Agency under the
administrative order is "disapprove the deliverable and modify the deliverable itself
to cure any deficiencies". Consistent with that option, EPA provided the PRP Group
with comments on the first three chapters of the FS on January 28, 2005, and
continued to provide such comments until May when the PRP Group printed the FS
for the Administrative Record,
In an effort to move our NPL sites into the remedy selection phase, in the last couple
of years, EPA has taken advantage of technological advances in word processing to
provide the majority of its comments on draft documents such as feasibility studies in
redline-strikeout format. This is consistent with the administrative order and saves
significant time in both our preparing detailed comments on a line-by-line basis and
also assists the PRP Group in interpreting our comments and in making the
appropriate edits. The redline-strikeout format has been successfully used in the past
by the government and private parties in negotiating legal settlements in the
Superfund program and EPA sees no reason why it cannot be used in drafting
technical documents.
11, PRP Comment that EPA Violated CERCLA and the NCP by Failing to Specify
Measurable and Achievable Remedial Action Objectives for the NAPL Zone
Alternatives
The PRP Group has expressed concern that EPA selected a remedy for the
Overburden NAPL Zone based on remedial action objectives included in the FS that
do not meet the requirements of CERCLA and the NCP because they are not
measurable and not achievable. They also claim that absent a quantitative remedial
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action objective, it is not possible to say which risks, if any, have been reduced and to
what extent the remedial goal is achieved.
EPA Response to Comment 11
The remedial action objectives were developed based upon numerous meetings and
discussions with the PRP Group, as well as technical personnel in EPA Headquarters,
EPA Regional Offices, and EPA's Robert S. Kerr Environmental Research Center
and are fully consistent with CERCLA and the NCP1.
The commenter is correct in that rather than leave considerable quantities of
hazardous substances unaddressed at the SRSNE site, EPA has selected a remedy that
will actively treat the contamination that remains at the Site. This is consistent with
the mandate in the NCP to protect human health and the environment and the
preference in CERCLA for remedial actions that reduce the toxicity, mobility or
volume of materials comprising principal threats through treatment. In this case,
cleanup objectives were identified that specified the contaminant (NAPL), the media
of concern (Overburden NAPL Area), the potential pathway (principal threat to
potential drinking water supply) and remedial goals (each alternative evaluated for
the NAPL zone had an identified performance standard (see Tables 4-22,4-25, 4-28,
4-31 and 4-34 of the May 2005 FS). As a result, EPA disagrees with the commenter
that EPA failed to identify measurable and achievable goals for the selected
alternative or indeed for any of the other alternatives evaluated in the FS. The FS
included a rational technology based endpoint for each alternative in the NAPL zone.
In addition, both the FS and the proposed plan make it plain that in-situ thermal
technology is expected to reduce the VOC concentrations in soil in the treatment area
to a level that is indicative of the absence of pooled or residual NAPL, which is
expected to result in 95% to 99% reduction of contaminants in the overburden NAPL
area. This reduction in VOC concentrations in soil is both measurable and
achievable. Following performance of in-situ treatment technology, cleanup
standards are expected to be attained throughout the plume over the long-term. This
is also both measurable and achievable. EPA's remedial approach at this Site is
similar to cleanups in which EPA first requires a performance based goal for a pump
and treat technology (i.e., groundwater cleanup until substantial further reductions in
contamination cannot be achieved through pump and treat technology because
stabilization, or asymptotic levels, have been achieved, as in the case of the Sullivan's
Ledge Site in New Bedford, MA), followed by the termination of pump and treat with
1 An analysis of remedial action objectives was one of four major issues evaluated by EPA's DNAPL
Expert Panel, convened in the summer of 2001, which resulted in the document entitled The DNAPL
Remediation Challenge: Is There a Case for Source Depletion? (EPA, December 2003). The Expert Panel
noted a trend at DNAPL sites to move away from the use of drinking water standards as a measure of
success for mass removal and instead adopting the following goals: a) mass removal goals, b) removal of
DNAPL "to the maximum extent practicable", and c) removal or stabilization of "mobile" DNAPL. The
Expert Panel characterized these as more "flexible regulatory strategies for DNAPL source zones, which
may result in a greater range of acceptable remedial action objectives for the source zone other than
meeting MCLs throughout the contaminated zone."
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reliance oil a second technology, such as monitored natural attenuation, until cleanup
standards are attained over the long. In both cases, the cleanup objective, while
performance based rather than concentration based, is nevertheless measurable and
attainable
All the active remedial options considered for Overburden NAPL Area will achieve
the remedial action objectives for NAPL source removal. The evaluation, then, of the
different technologies turned on how much NAPL each would remove, in what time
frame, the relative cost, and the "track record" for each of the technologies. In the
end, EPA selected in-situ thermal treatment because of the potential to remove the
most NAPL in the shortest period of time, at a relatively moderate cost, and because
it is a more proven technology than enhanced bioremediation which is considered by
many, including EPA's DNAPL Expert Panel, to be still in an early stage of
development.
EPA disagrees with the commenter's assertion that risk reduction is unknown. By
implementing a remedy that significantly reduces the volume, toxicity or mobility of
the NAPL - which is a principal threat waste at the SRSNE Site - the potential for
future human contact and exposure has been significantly reduced, the risk of future
releases into the environment is significantly reduced, and the risk of failure of the
containment portion of the remedy is significantly reduced.
12, PRP comment that no existing technology will fullv remove the NAPL "source"
from overburden or bedrock at the Site.
The PRP Group, citing EPA guidance and publications, states that it is not possible to
clean up groundwater with NAPL contamination to drinking water standards. They
also state their belief that in-situ thermal technology is not yet "proven" and if applied
at the SRSNE Site could cause more harm than good.
EPA Response to Comment 12
EPA disagrees. First, as indicated in one of the EPA guidance documents relied on
by the PRP Group, EPA should consider "the state of ground-water remediation
science at the time" that an evaluation of available technologies is performed. See
EPA's Guidance for Evaluating the Technical Impracticability of Ground-Water
Restoration (September 1993), page 8. At this Site, the PRP Group's own modeling
based on current scientific information provides more than adequate technical support
for EPA's conclusion that drinking water standards can be attained at this Site. The
State agrees with EPA's conclusion.
Second, the PRP Group's comments as a whole fail to mention that without active
treatment of the overburden NAPL area, continued operation of the NTCRA 1 and
NTCRA 2 Groundwater Extraction and Treatment System, at a current yearly cost of
$500,000, would likely be needed for 400-500 years. Given the need for continued
containment at this Site, the selection of a remedy tha$ may cut the time frame for
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containment in half, based on modeling, is reasonable. While the time frame for
attainment of acceptable standards under EPA's remedy is very long, it is
significantly shorter than if no active measures were to be taken to address the
overburden NAPL area.
Third, much of the information cited by the commenter is dated. Over the past ten
years, as treatment technologies to address NAPL have moved out of the lab and into
the field, EPA's thinking with respect to NAPL contamination has evolved. As the
continued annual costs and uncertainties associated with long-term management of
NAPL sites, particularly dense NAPL or DNAPL, become apparent, EPA and others
are reassessing the factors controlling decisions on whether to implement DNAPL
source reduction actions. EPA has not acknowledged, in recent times, that in-situ
remediation technologies are incapable of restoring groundwater to clean up
standards. In fact, EPA shared with the PRP Group information about a restoration to
near safe levels accomplished recently at Young-Rainey STAR (Pinellas, Florida)
using a combination of in-situ thermal technologies (steam injection and electrical
resistance hearing). Concerned that requiring thermal remediation at SRSNE to
achieve MCLs at the time the thermal system is turned off might be too costly, EPA
adopted a more flexible approach, and selected a remedy consisting of thermal
treatment to remove mobile NAPL, then allowing natural processes to complete
groundwater restoration.
The PRP Group claims that thermal remediation is not a proven technology and has
never been applied where "there is pooled DNAPL in a heterogeneous, low-to-
medium permeability overburden above fractured bedrock that contains dipping
fractures". While it is true that all sites are different and thus no site identical to
SRSNE has been treated before, none of the known characteristics of the Site would
indicate that it cannot be safely and effectively treated by thermal remediation. All
sites have some amount of heterogeneity. However, heterogeneity is typical of
subsurface geologic conditions. Other sites that have been treated by thermal
remediation, such as East Gate Disposal Yard at Fort Lewis Army Logistics Center
and ICN Pharmaceuticals in Portland, Oregon, have a similar degree of heterogeneity.
The fact that there is fractured rock beneath the SRSNE Site will not interfere with
the treatment of the overburden. Pooled DNAPL has also been present at other sites,
notably at an industrial site in Tampa, Florida and in the pilot study at the Silresim
Site. Pooled DNAPL does not present an undue challenge for thermal remediation.
The PRP Group also cited a number of research projects funded by the US
Government involving in-situ thermal technologies as further evidence that they are
not yet "proven" technologies. EPA is directly involved in several of the research
projects cited and believes federal support reflects the great interest in and
acknowledged potential of these technologies. Thermal technologies will continue to
develop and evolve as they are applied and technology vendors adapt their systems to
meet the needs of a particular site.
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Citing the EPA Expert Panel Report on DNAPL remediation (EPA, December 2003),
the PRP Group identified three potential adverse impacts of DNAPL source
depletion, as evidence of the uncertainty regarding the benefits and risks of
implementing aggressive partial mass removal technologies, all three of which could
"increase life-cycle costs of site cleanup." Other relevant considerations include the
following explicit benefits of partial mass removal, which were identified by the
Expert Panel along with the adverse impacts, but which the PRP Group failed to list
in their comments: 1) mitigating the future potential for human contact and exposure
through long-term reduction of volume, toxicity and mobility of the DNAPL; 2)
reducing the duration and cost of other technologies employed in conjunction with the
source removal technology; and 3) reducing the life-cycle cost of site cleanup. The
expert panel report also identified other implicit benefits of DNAPL source-zone
depletion, including: 1) minimizing risks of failure of long-term containment
strategies; 2) mitigating public stakeholders' concerns; and 3) minimizing future
uncertain transaction costs associated with management of the site.
Of particular concern to the commenter is the potential for downward migration of
DNAPL from the overburden to the fractured bedrock during in-situ thermal
remediation. Downward mobilization of DNAPLs during thermal remediation has
been a concern of researchers developing thermal technologies almost from the start,
as it was observed in the lab in sand box experiments where steam injection was used
to recover DNAPLs, Engineering approaches to reduce or eliminate downward
migration during steam injection have been developed, and steam injection to recover
DNAPLs has been used safely in the field. However, it should be noted that steam
injection has already been screened out for the SRSNE Site due to unrelated reasons
and downward migration has not been observed during heating with the use of other
thermal technologies because concentrated condensation fronts do not develop during
application of these technologies. An examination of the possible forces that could
cause downward migration during heating shows that it is unlikely to occur for
contaminants such as TCE and PCE, which comprise a great percentage of the
particular contaminants in DNAPL found at SRSNE (Heron, G., T.H. Christensen, T.
Heron, and T.H. Larson, Thermally enhanced remediation at DNAPL sites: The
competition between downward mobilization and upward volatilization, Proceedings
of the First International Conference on Remediation of Chlorinated and Recalcitrant
Compounds, Monterey, CA, 1998). In fact, recent experiments conducted by Dr.
Kent Udell at the University of California - Berkeley and observed by EPA show that
DNAPL will tend to rise in porous media rather than fall as bubbles are formed that
migrate upward, carrying with them liquid DNAPL attached to that bubble. The
remedy at SRSNE will be designed to minimize the potential for downward migration
by heating first just below the contaminated zone to take advantage of this upward
migration mechanism.
13. PRP Comment in Favor of a Technical Impracticability Determination
The PRP Group believes that a determination of technical impracticability (TI) is
appropriate for the SRSNE Site and questions EPA's justification for not granting
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such a waiver after initially considering one. A number of site-specific factors are
included in the comment that the commenter believes supports the TI determination.
The commenter also provides a list of "smaller and less complex" Superfund sites in
Region 1 that were granted TI waivers in support of what they believe is an Agency
policy in favor of TI waivers at DNAPL sites.
EPA Response to Comment 13
The commenter is correct that over 10 years ago EPA allowed the PRP Group to
begin an evaluation during the Remedial Investigation of whether or not a TI waiver
was appropriate for the SRSNE Site. Since that time however, changes in the
understanding of the distribution and behavior of NAPL as well as advances in NAPL
treatment technologies have taken place. As a result, in March 2001, EPA redirected
the PRP Group to study and evaluate more folly in the Feasibility Study treatment
technologies to address the very highly contaminated groundwater (contaminant
concentrations at the SRSNE site are tens, hundreds and in some cases thousands of
times their regulatory limits resulting in an unacceptable human health risk with
excess cancer risks calculated to be as high as unity (every person who drinks the
water would potentially get cancer over the course of his or her lifetime), and
potential exposures estimated at 700 times greater than benchmarks for the
protections of non-cancer.)
Although the commenter points to a number of sites where EPA has granted TI
waivers, it is difficult, if not impossible, to compare the remedial decisions made at
one Superfund site to another as each site presents its own unique issues regarding
site characteristics and risk, nature of the contamination, location of the site, and
community and state interests. Each site is evaluated independently by EPA. In the
1980's and 1990's, there were no remediation techniques that had been developed to
the extent that significant mass removal of VOCs present in the form of DNAPL
could be achieved in a variety ofhydrogeologic settings, thus, it was appropriate in
1989 to grant a TI waiver to Sullivan's Ledge, and in 1995 to grant one at Pease Air
Force Base. Contaminants such as PCBs and creosote, which are present at
O'Connor, Hocomonco Pond and Pinette's Salvage Yard, are much more difficult to
remediate than the chlorinated solvents present at SRSNE, thus, those sites may more
easily qualify for a TI waiver. The groundwater at the Tansitor site has a very low
yield and is not a potential drinking water source (i.e., the State has reclassified the
groundwater), which is a very different situation than exists at SRSNE. In addition,
the contamination at Tansitor is confined to a small area and is not migrating away
from the source, thus no active containment measures are needed. Although Loring
AFB is listed twice in the PRP's list of Superfund sites, the site has only one TI
waiver and it is for DNAPL in fractured bedrock. The DNAPL at the Durham
Meadows site is also believed to be in the fractured bedrock. No remediation
technologies have been demonstrated to be capable of achieving groundwater cleanup
goals in fractured bedrock, although the research project carried out at the quarry site
at Loring demonstrated the potential for steam injection to recover significant
amounts of contaminants from fractured bedrock. In the future, remedial
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technologies may be available for bedrock at these sites and the bedroek at SRSNE as
well.
The PRP Group also states that EPA's remedy decision at SRSNE is arbitrary and
capricious in nature because it is based on direct field observations of pooled and
residual DNAPL. The PRP Group suggests that the presence of DNAPL should be
based on converging lines of evidence and interpretation of potential and probable
DNAPL zones (i.e., based on evaluation of indirect data), rather than direct visual
observation of actual site conditions. At the SRSNE Site, where potential and
probable NAPL zones were defined ten years ago to aid in the safe drilling and
installation of monitoring wells, there was utility to using these designations, which
were based on the best available site-specific information, for the TI evaluation in the
mid-1990s in the remedial investigation. However, these designations were
abandoned for the overburden aquifer (not, it should be noted, the bedrock aquifer) in
2003 in favor of a field-based program to determine the extent of DNAPL for the
purposes of delineating an overburden NAPL zone to target for treatment in the
feasibility study. EPA's contention was and continues to be that so-called "indirect
indicators" and "converging lines of evidence" are appropriate to use to recognize
that a site is a NAPL site, as is the case at the Durham Meadows Site where DNAPL
has never been directly observed. But EPA feels it is inappropriate to use indirect
indicators and converging lines of evidence to delineate where specifically at a site
the DNAPL is located, as the PRP Group argued. The PRP Group's point of view
was apparently based on a misunderstanding of EPA's 1992 Guidance on Estimating
Potential Occurrence of DNAPL at Superfund Sites. To the extent that the PRP Group
is suggesting that EPA should not rely on direct field observations of the location of
DNAPL at the SRSNE Site, the PRP Group's contention is unsupportable.
The PRP Group also submitted a comment citing a number of recommendations and
conclusions from the National Research Council (NRC) for the National Academies'
2005 report entitled Source Zone Assessment and Remediation for support of its
position that a determination of technical impracticability is appropriate for the
SRSNE Site. The recommendations and conclusions are very broad in that they
address source remediation technologies in general. The NRC is quoted as saying
"there is a significant lack of data and information upon which to make definitive
statements about source remediation". While the data available to the NRC may have
been lacking, there is a significant amount of data that has been collected in the area
of thermal remediation over the last dozen or so years. While it may be true that
some remediation technologies have not been adequately demonstrated for use on low
permeability materials, that is not the case for thermal treatment. Thermal treatment
has successfully treated a number of sites with very tight, low permeability soils or
clays. In addition, another conclusion reached stated that the effectiveness of source
remediation technologies is uncertain at sites where explosive materials are a concern.
This conclusion is not relevant for the SRSNE Site as no explosives have been found
at SRSNE nor would they be expected to be. However, EPA does agree with the
general conclusion that "each technology has the potential to produce negative side
effects that need to be accounted for in the design and implementation of that
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technology", EPA points the reader to Section 4.4.5 of the FS (page 4-11, and Table
4-31) and Section L of the ROD where EPA has identified the potential side effects
with remediation of the source zone, and laid out steps to be taken in the design and
implementation of the remedy to address these concerns. Such concerns have been
addressed at other sites that have used thermal technology.
The PRP Group makes the point in a number of places that no technology currently
exists that will achieve applicable groundwater standards at the SRSNE Site in less
than 100 to 200 years, therefore instead of attempting to reduce as much of the
principal threat waste as possible, the PRP Group believes that the response required
by the NCP is a TI determination. This reasoning appears to reflect a general
misunderstanding of what a TI determination and subsequent TI waiver would
accomplish at SRSNE, Regardless of whether groundwater standards can be
achieved, EPA would still require removal of DNAPL to the extent practicable, where
significant reduction of current or future risk will result. See Guidance for
Evaluating the Technical Impracticability of Groundwater Restoration (EPA,
September 1993), at 8. Given the conditions at the SRSNE Site (highly-contaminated
drinking water source, an estimated 84% of the NAPL at the site in the overburden
with the greatest concentration confined to a relatively small area of 1.5 acres, to
depths of 25 to 40 feet), a TI waiver in and of itself very likely would not have a
significant impact on the selected remedy. In short, EPA would continue to require
active treatment of the overburden NAPL area in order to significantly reduce the
NAPL mass and thus significantly reduce the potential for future human contact and
exposure to high levels of contaminants, the risk of future releases into the
environment due to migration, and the risk of failure of the containment portion of the
remedy.
14, PRP comment that EPA's selected remedy for the SRSNE is inconsistent with the
Silresim "precedent".
The PRP Group states that EPA is being inconsistent because it selected in-situ
thermal to achieve mass removal at SRSNE but did not select it at the Silresim Site
(Lowell, MA) after performing a pilot study of the technology. The PRP Group
further comments that EPA "has elected instead to maintain the existing cap, long-
term groundwater treatment and institutional controls for the foreseeable future" and
if that approach constitutes a "protective remedy" at Silresim, it should also be
protective at SRSNE.
EPA Response to Comment 14
It is EPA's opinion that the remedy selected for the SRSNE Site is consistent with the
remedy selected at the Silresim Site and equally protective. The source reduction
component of the Silresim remedy includes soil vapor extraction (SVE). The purpose
of the in-situ thermal pilot study at Silresim was to evaluate its effectiveness as an
augmentation of the existing SVE system which had already removed an appreciable
amount of contaminant mass. The pilot study showed electrical resistance heating
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(ERH) to be very effective at removing mass even in the very tight, low permeability
soils at the Silresim Site. The reason it was not selected was due to the fact that the
addition of ERH at this point in the cleanup did not significantly shorten the length of
time it would take to reach the cleanup objectives for the Site when compared to
continuing with SVE only. At SRSNE, it is expected that thermal treatment will cut
in half the time needed to reach federal drinking water standards than it would
without source reduction. EPA believes that the PRP Group's assertion that EPA has
selected inconsistent remedies at SRSNE and Silresim that are not equally protective
is unfounded.
15. Other Potential Sources of Contamination in Town Wells No. 4 and No. 6
The PRP Group expressed concern that because there are other possible sources of
contamination to the aquifer that serves municipal Production Wells No. 4 and 6,
these wells are not likely to be used in the future. The PRP Group also states its
belief that maintaining these wells as an official public water supply is a "fiction that
misleads the public", as it is "exceedingly unlikely that Town residents will ever
consent to the use of these wells again" as a public water supply.
EPA Response to Comment 15
Regardless of whether there are other sources of contamination to the aquifer that
serves Production Wells No. 4 and 6, extremely high levels of contamination from the
SRSNE site is found in the aquifer that serves these wells. This contamination is a
potential source to any drinking water well that is currently located or could come to
be located in the vicinity of the Site in the future.
The PRP Group's belief that the Town Well Field will likely never be used for
drinking water is contrary to the community's express wishes. The Town has the
serious responsibility for planning for the long-term drinking water needs of its
inhabitants. The Town has not abandoned these wells nor has it currently secured any
additional water supply sources for future use. The Town includes the diversion
rights for these two wells in its long-term water supply plan. Moreover, CT DEP has
advised EPA that it would be unlikely to reclassify the groundwater in this area
because: the aquifer is capable of supporting a significant public water supply;
groundwater quality will eventually be restored to a background quality; and the
Town continues to include these wells in its long-term water supply plans.
The State is also committed to taking appropriate actions to ensure that other potential
other sources of contamination to the town wells are adequately addressed over the
long-term, including remediation under the State's property transfer law.
Finally, the commenter states incorrectly that Mr. Edward Pocock III, the President of
the Southington Board of Water Commissioners, made comments concerning the
town wells at the SRSNE Site Public Hearing. Mr. Pocock's comments were made
on June 8, 2005 during a public informational meeting. He did not make them at the
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public hearing for the SRSNE Site that was held on June 30, 2005. No one
representing the Southirigton Board of Water Commissioners offered verbal
comments at the public hearing, nor, for that matter were written comments submitted
during the comment period.
16. PRP Comment that EPA Unlawfully Eliminated Reclassification from the June
2000 Draft FS
The PRP Group claims that EPA's direction to eliminate reclassification as an option
in their June 2000 draft FS has no "legal or factual basis". The PRP Group goes on to
assert that this directive "effectively and unjustifiably" eliminates the technical
impracticability (TI) option under CT DEP's regulations.
EPA Response to Comment 16
CT DEP has advised EPA that, in its view, the groundwater at the Site is not suitable
for reclassification, nor would it be reasonable to approve a request for a technical
impracticability variance under the State's remediation program. (See EPA response
to comment 17). Moreover, EPA does not believe that it is technically impracticable
to attain drinking water standards at this Site. (See EPA response to comment 13).
To the extent that the PRP Group claims that EPA somehow unlawfully eliminated
groundwater reclassification from the FS, EPA responds that groundwater
reclassification is not a remedial alternative or technology that can be selected by
EPA. EPA's decision to more fully evaluate treatment technologies to address
groundwater contamination at the Site was fully supported by advances in technology
that have taken place within the past ten years.
17, Comments concerning whether groundwater at the Site should be reclassified.
Two sets of comments were received that pertain to reclassification of the
groundwater.
The first commenter questions why treatment to federal drinking water standards is
necessary since in his opinion no one will drill a well in that area and recommends
that the groundwater be reclassified.
The second commenter (the PRP Group) states its belief that for federal and state
action to be considered other than arbitrary and capricious, the groundwater at
SRSNE must be reclassified to GB, as was done at Old Southington Landfill, another
Superfund site in Southington.
EPA Response to Comment 17
Federal drinking water standards are applicable to the cleanup at the SRSNE Site
because the groundwater at the Site has been classified by CT DEP as GA, GA-
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Degraded or GAA. In short, the State's goal for this aquifer is to maintain or restore
the groundwater to its natural quality.
Even if some local citizens might feel that they do not want or need to use the water
currently, both state and local officials believe the aquifer is a valuable future
resource that should not be abandoned because of contamination from the SRSNE
Site. A request for reclassification of the groundwater in the vicinity of the SRSNE
site to GB could be prepared and submitted; however, such a request is not likely to
be approved by CT DEP for the following reasons: the aquifer is capable of
supporting a significant public water supply; the groundwater quality of the aquifer
will eventually be restored to background quality; and the Town continues to include
Production Wells No. 4 and 6 in its long-term water supply plans.
EPA believes that it is technically practicable to restore the groundwater at the Site to
cleanup levels based on the modeling presented in the FS. Although these levels will
only be attained over a very long time frame, EPA believes that this time frame is
reasonable because the implementation of active treatment in the overburden NAPL
area will cut in half the time needed to meet safe levels (and contain contaminated
groundwater). Similarly, CT DEP has advised EPA that it would not be reasonable to
approve a request for a variance due to technical impracticability under state law
because it expects that groundwater will be restored, even though the time frame for
restoration is very long.
Finally, there is no basis for the claim that federal and state action is arbitrary and
capricious because the groundwater at Old Southington Landfill was reclassified,
whereas the groundwater at SRSNE was not. Aside from both being located in
Southington, the two sites and the potential use and value of the groundwater are
dissimilar. The Town of Southington's 1989 request for reclassification of the
aquifer near the Old Southington Landfill to GB was approved by the State in 1993.
The reclassification was not relevant to the presumptive capping remedy that EPA
selected for the Site in 1993; EPA has not yet selected a remedy for the groundwater
at Old Southington Landfill. The Town's request for reclassification was approved
by the State because: the Town had surrendered its rights to Production Well No. 5,
which was located near the Old Southington Landfill; the Town had physically
abandoned Well No. 5; and the Town no longer included any contribution from Well
No. 5 in its long-term water supply plans as a resource needed to meet future demand.
18. PRP Group support for Hydraulic Displacement and Enhanced In-Situ
Bioremediation over In-Situ Thermal Treatment
The PRP Group recommended the use of hydraulic displacement (HD) followed by
enhanced in-situ bioremediation (EISB) be used to remove NAPL mass in the
overburden aquifer stating that in combination, these technologies comprise the
fastest and most aggressive NAPL remedial option that can be safely and reliably
implemented at the SRSNE Site without significantly increasing short-term risk of
downward NAPL mobilization or health-based risks.
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In addition, the PRP Group asks what significant reduction in current or future risk
EPA expects to achieve by incremental mass removal afforded by in-situ thermal
treatment over hydraulic displacement and enhanced in-situ bioremediation.
EPA Response to Comment 18
Based on the information available to EPA, we disagree that HD and EISB are faster,
more aggressive, safer or more reliable than in-situ thermal,
HD is expected to remove up to 44% of the pooled NAPL in the overburden, which
means 56% or more will not be removed (see Section 4.4.3 of the May 2005 FS).
With HD, only pools one meter or larger are expected to be mobilized towards
extraction wells and removed, which means that pools one meter or smaller will
remain untouched (see Appendix I of the May 2005 FS, page 2). There is significant
uncertainty then regarding the rate of removal for the second critical step, EISB, in
the treatment process. There is limited or no basis to estimate the actual increase in
the rate of removal that will be achieved at the SRSNE Site over what is occurring at
the Site without enhancements. The feasibility study looked at three different
scenarios. If EISB increases the current rate of degradation by approximately three
times its current rate, 99% of the mass in the Overburden NAPL Area is estimated to
be removed in 130 years (see Table 4-25 in the May 2005 FS). If the rate of
degradation increased ten-fold, the FS estimated it would take 40 years to reach the
99% total removal rate. However, it appears to be just as likely that there will be no
increase in the current rate of degradation (Appendix G of the May 2005 FS, page
16). That scenario would be identical then to the HD and MNA alternative which
estimated the time to reach the 99% removal rate at 300 to 400 years (see Table 4-22
in the May 2005 FS). As a result, there is a much greater uncertainty factor with the
use of this technology. Furthermore, EISB will be implemented in five rounds over
the course of 20 to 30 years (see Table 4-27 of the May 2005 FS), On the other hand,
in-situ thermal technology is expected to remove between 95% and 99% of the NAPL
in the overburden treatment zone in one to two years, including installation, heating
and equipment decommissioning (see Tables 4-31 and 4-33 in the May 2005 FS). By
comparison, HD/EISB seems neither fast nor aggressive and definitely less certain.
Nor does EPA believe HD and EISB are safer or more reliable than in-situ thermal
treatment. In fact, EPA knows of no site similar to SRSNE where the HD/EISB
combination has been used to reduce NAPL mass. By comparison, in-situ thermal
technologies have been used at over 100 sites with demonstrable success. This is
supported by the DNAPL Expert Panel that was convened by EPA. The panel's
position was that while in-situ thermal technologies were sufficiently developed and
ready for deployment at DNAPL-impacted sites, in-situ biodegradation (i.e., EISB) is
still in an early development stage (EPA, December 2003). Dehalococcoides
ethenogenes is the only known microorganism that dechlorinates PCE and TCE to
ethene (Maymo-Gattel, X., ¥. Chien, J.M. Gossett, and S.H. Zinder. 1997). Isolation
of a bacterium that reductively dechlorinates tetrachloroethene to ethene. Science
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276:1568-1571.). Dehalococcoides are slow growing, "finicky" microorganisms
which causes some concern as to their survival and growth rate and therefore the
reliability of the technology over the long term.
EPA does not agree that the risk of vertical pool mobilization from HD
implementation is necessarily minimal because it is a 'depleting' technology that does
not involve the buildup of NAPL banks. While EPA would agree that the tail end of
a pool of NAPL moving towards a recovery well is being depleted, NAPL build up
could occur at the leading end of the pool, especially if it intersects with other pools
moving towards the same recovery well, possibly resulting in vertical downward
migration of the NAPL. By contrast, in-situ thermal remediation will not attempt to
move liquids over significant distances in the subsurface, but instead will convert the
contaminants to vapors that are buoyant and will move upward in the subsurface.
With regard to the question about incremental risk reduction from in-situ thermal
treatment over HD and EISB, for the reasons discussed above, EPA has greater
certainty that more mass removal will be accomplished in a shorter period of time
with in-situ thermal treatment than could be achieved with HD and EISB. NAPL
mass is the principal threat at the site and is the primary source of on-going
contamination to a potential drinking water supply.
19. PRP Group's Concern that Global Climate Change/Preservation of Natural
Resources Should Be Considered bv EPA in Remedy Selection.
The PRP Group claims that thermal technology uses significant amounts of power,
and estimate that thermal remediation at the Site would use as much energy as 910
households in one year. In contrast, they claim that HD would use as much energy as
165 households in one year. The PRP Group disagrees with EPA's decision to
eliminate from the FS an estimate of the greenhouse gases that would be emitted
under each alternative.
EPA Response to Comment 19
In general, EPA certainly supports conservation of natural resources. However, in the
FS process, as detailed in EPA's Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA (1988), EPA evaluates the risks to human
health and the environment, including an evaluation of short-term and long-term
effectiveness of each remedial alternative, at or in the vicinity of the site property that
is evaluated as part of the RI. For example, EPA considers such things as the effects
of truck traffic during performance of the remedy on the local community, or the
potential harm to wetlands or environmental receptors at the Site due to operation of
the remedy. Consideration of greenhouse gas emission issues is beyond the scope of
EPA's RI/FS evaluation. Therefore, EPA properly excluded the PRP Group's
evaluation of greenhouse gas emissions from the RI/FS because it was not relevant.
20. NCP Requires a Cost-Benefit Analysis of Partial NAPL Mass Removal
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For the Cape Fear Site (Fayetteville, NC), EPA recommended that thermal treatment
not be considered unless it can be shown to be as cost-effective as conventional pump
and treat. The PRP Group asserts that this type of cost-benefit analysis is required by
the NCP, and questions why this approach was not used at the SRSNE site.
EPA Response to Comment 20
The NCP does not require that a cost-benefit analysis be done before EPA can select
a mass removal technology. Instead, EPA is directed to compare "the cost to
effectiveness of each alternative individually and ... the cost and effectiveness of
alternatives in relation to one another." (NCP preamble, 55 Fed. Reg. 8728). Cost is
a factor to be considered if an alternative can be shown to be protective and ARAR
compliant.
The decision to implement a remedy with a source-depletion component is based on
highly site-specific conditions and criteria, as well as the goals and objectives of the
remedial action. At the Cape Fear site, the goal is to reduce NAPL mass to
concentrations that will not leach out of soil and continue to affect water quality in
the overburden; there is no bedrock at the Cape Fear site. Contrast that with the
SRSNE site where there is DNAPL in the fractured bedrock that is not undergoing
aggressive treatment, and as a result, will need to be contained for a long time
regardless of what happens in the overburden. The difference is that without mass
removal in the overburden, it would take 400 to 500 years to reach federal drinking
water standards using a basic pumping and treating technology whereas with mass
removal in the overburden, that time frame is reduced to approximately 225 years. In
addition to shortening the time frame that groundwater standards are exceeded, mass
removal at the SRSNE site will protect the containment remedy by preventing the
migration of highly mobile NAPL. It is also expected to shrink the size of the
groundwater contaminant plume over time and reduce groundwater contaminant
concentrations. These outcomes will allow for a less expensive
containment/treatment system, and will support the return of the northern portion of
the town well field for beneficial use as drinking water. EPA believes that thermal
technology is cost-effective2 at the SRSNE Site in light of all of the above
considerations.
Finally, it is worth noting that the in-situ thermal pilot test at the Cape Fear site was
highly successful. Electrical resistance heating was able to remove an estimated 5000
gallons of creosote from a 50-75 square foot area. Creosote is much harder to move
out of the soils than the type of DNAPL at the SRSNE Site which has a density close
to that of water and is highly mobile.
2 Fractured bedrock remediation continues to be an area of great interest. In fact, there are at least three
sites in EPA New England where the bedrock is being actively remediated. These are Eastern Surplus,
Eastland Woolen Mill and Union Chemical. All sites have used chemical oxidation, none have TI waivers
and 2 of the 3 use federal funds. As advances in DNAPL treatment technology advance, it may become
more cost-effective to treat the DNAPL in the bedrock at SRSNE than to contain it for 225 years.
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21. In-Situ Thermal Pilot Test
Two commentcrs asked that a pilot test for in-situ thermal be performed prior to full-
scale implementation. One of these commenters (the PRP Group) disagrees with
EPA's reported unit price for full-scale electrical resistance heating at a site in
Skokie, Illinois, and provided a different unit price.
EPA Response to Comment 21
EPA is not convinced that a pilot test for thermal remediation is required for the
SRSNE site, as enough other sites have been completed to demonstrate the mass
removal capabilities of thermal remediation for VOCs in a variety of hydrogeologic
settings. EPA will consider whether or not a pilot test is needed during remedial
design.
EPA cannot comment on the new unit price proposed by the PRP Group for the site in
Skokie, Illinois as none of the calculations or assumptions that were used were
provided to EPA. However, EPA is aware that cost estimates developed in the FS are
just that - estimates. That is why EPA recommends that cost estimates include
contingencies for scope, bid, project management, remedial design and construction
management. At SRSNE, this amounts to an additional $9,390,000, or 32% of the
total cost of the selected remedy, to cover unknowns, unforeseen circumstances, or
unanticipated conditions and to reduce the risk of possible cost overruns.
22. PRP Comment that Cost Estimates in the FS and Proposed Plan are Misleading
The PRP Group submitted a comment objecting to the 7% discount rate used by EPA
to develop cost estimates for the FS, preferring instead a rate of 3.1%, It is their
opinion that the rate of 7% is "inappropriate, unsupported, unrealistic, based on
outdated guidance and contraiy to direction from the Office of Management and
Budget (OMB)". The PRP Group also suggests that EPA's direction to use a higher
discount rate was a "financial sleight of hand" that enabled the Agency to avoid an
internal review process with the National Remedy Review Board that is mandated
where overall remedy cost exceeds $30 million.
EPA Response to Comment 22
EPA does not agree that the 7% discount rate is inappropriate, unsupported,
unrealistic, based on outdated guidance or contrary to direction from the OMB. In
fact, the 7% discount rate was established through an economic analysis performed
by OMB and can be found in OMB Circular A-94 {Guidelines and Discount Rates for
Benefit-Cost Analyses of Federal Programs) which provides guidance for the use of
discount rates in economic analyses performed by the Federal government. EPA
changed its policy to 7% (OSWER Directive 9355.3-20) in order to be consistent with
Circular A-94 issued by OMB.
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Perhaps the source of the misunderstanding is the lower rate that appears in Appendix
C to OMB Circular A-94, which is updated annually around the time of the
President's budget submission to Congress. The rates in Appendix C are based on
interest rates from Treasury notes and bonds and the published rate for 2005 is 3.1%,
As discussed in EPA/Army Corps of Engineers guidance for developing cost
estimates (A Guide to Developing and Documenting Cost Estimates During the
Feasibility Study, July 2000), the lower rate is appropriate for use at Federal facilities
because the Federal government has a different "cost of capital" from the private
sector. However, a discount rate of 7% that appears in the main portion of Circular
A-94 (and is not updated annually) is generally appropriate for non-Federal facility
sites, such as SRSNE.
EPA does not agree with the assertion that the discount rate was adjusted to a higher
rate in a "financial sleight of hand" to avoid internal review with the National
Remedy Review Board. In fact, it was during preliminary consultation with the
Board in early spring 2005 that the region was advised that 7% is the number that
should be used to be consistent with other sites that had gone before the Board
including the following from EPA New England: New Bedford Harbor, MA (1996),
Fletcher Paint, NH (1996), Beede Waste Oil, NH (2000) and Iron Horse Park, MA
(2003), When the 7% discount rate was applied to SRSNE, the estimated cost of
EPA's preferred alternative came in under the criterion that mandates internal review
by the National Remedy Review Board.
23, Reasonable Time Frame
One commenter asked the rationale for EPA's various determinations of what is a
"reasonable" time in which to achieve restoration to ARARs at different site within
EPA New England,
EPA Response to Comment 23
As indicated in EPA's response to prior comments, EPA's decisions are site-specific.
"[N]o single time frame can be specified during which restoration must be achieved
to be considered technically practicable ..." (TI Guidance, at 16). Moreover, as set
forth in the NOP, the time frame for restoration of groundwater will be one that is
"reasonable given the particular circumstances of the site." 40 C.F.R. §
300.430(a)( 1 )(iii)(F).
At SRSNE, CT DEP determined, in its Groundwater Use and Value Determination
(May 2005) in support of EPA's RI/FS and remedy selection, that immediate
restoration of the aquifer underlying the Site is not required as long as adequate
protection is provided to contain the contaminated groundwater plume. At the same
time, CT DEP found that the aquifer was one of high use and value due, in part, to the
fact that it is capable of supporting a significant public water supply and because the
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Town continues to include Production Wells No. 4 and 6 in its long-term water
supply plans.
Given these factors, and given that in-situ thermal treatment is expected to achieve a
95%-99% reduction in NAPL in the Overburden NAPL Area, where the greatest
concentration of NAPL at the Site is believed to be, within about one year of
implementation thereby cutting in half the time needed to attain drinking water
standards (and for containment), EPA considers the time frame for attainment of safe
drinking water levels (—225 years) to be reasonable at this Site.
* -j ~ . r-T-i1 "I » T , T"">i
24. In-situ Thermal Hot Floor
The PRP Group asserts that EPA "changed its mind" between November 2004 and
June 2005 regarding the necessity of a "hot floor" as a component of the in-situ
thermal remedy and asked that the Agency provide the information to justify that
change.
EPA Response to Comment 24
EPA did not change its mind on the matter of a hot floor for the application of
thermal remediation to the SRSNE Site. EPA disagreed with the need for the
extensive and costly hot floor proposed by the PRP Group in draft FS submitted in
June 2004, but endorses the hot floor proposed by the PRP Group in the May 2005 FS
which is reduced in extent (see Appendix V of the May 2005 FS, page 17).
25. Basis for Restoration to ARARs
The PRP Group asked EPA to provide the basis of the conclusions that groundwater
at the SRSNE will be restored to ARARs.
EPA Response to Comment 25
The basis of EPA's conclusions regarding the ability of groundwater to be restored to
ARARs are the modeling efforts and conclusions in the May 2005 FS.
26. All Remedial Options Not Discussed at the Public Meeting
The PRP Group asks why the public was not informed at the public meeting of other
alternatives, such as hydraulic displacement and enhanced in-situ bioremediation that
would also achieve the ONOGU cleanup objectives.
EPA Response to Comment 26
The public was informed of all the alternatives considered for the SRSNE site and the
pluses and minuses of each alternative in the Proposed Plan dated May 2005, in full
compliance with the NCP. An unusually large number of alternatives were
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considered for this Site - six for soil and wetland soil, seven for groundwater and
eight for NAPL. There was insufficient time at the public meeting to go through each
of the alternatives and also adequately explain EPA's proposed alternative. EPA
therefore provided copies of the Proposed Plan at the meeting, pointed people to all of
the alternatives discussed in the Proposed Plan, and focused on the remedy being
proposed by EPA. EPA also was available to respond to any questions posed by the
public,
27. Another De Minimis Settlement
One commenter asked when EPA might offer another de minimis settlement to small-
volume parties associated with the SRSNE Site.
EPA Response to Comment 27
This is not a comment on the proposed remedy but rather a comment on the
enforcement process. However, EPA has not yet decided on whether or not it will
offer a third round of de mimimis settlements. It there is one, it will likely be as part
of the negotiations with the PRP Group to perform the remedy selected in the ROD.
The terms of any future de minimis settlement are unknown at this point.
28. Past Permitting and Licensing History
Several questions were asked by one commenter about the past permits and licenses,
the timing of the facility operations vis-a-vis the municipal production wells,
historical violations and to what extent the public was made aware of them, past
monitoring results and so forth,
EPA Response to Comment 28
Questions such as these that pertain to the SRSNE facility while it was in operation
are not relevant to the selection of a remedy and as such do not require a response as
part of the Superfund responsiveness summary.
However, for historical information, the commenter should review the administrative
record, copies of which are located at the Southington library and at EPA's office in
Boston. If the commenter seeks additional information beyond what is found in the
administrative record, the commenter can contact CT DEP or EPA.
29. Frequency of Testing and Reporting Requirements
One commenter asked a several part question concerning the testing of volatiles and
equipment, and whether or not the results will be made available to the public. The
commenter also asked if the facility was required to report such things as errors,
mishaps and hazards to EPA and other governmental agencies.
38
-------
One person made the comment that although he lives in the neighborhood (on
Hightower Road in Southington) he did not receive a proposed plan and recommends
that the plan be mailed to people at least within five thousand feet.
EPA Response to Comment 30
The proposed plan was mailed to approximately 230 residences on about 20 streets in
the area bounded by Lazy Lane on the north, Queen Street on the east, West Street on
the west, and Hart Street on the south. This neighborhood extends approximately one
mile west of the SRSNE Site. Sabina Drive and Kane Street (south of Hart Street and
immediately southwest of the Site) were also included. Hightower Road is in the
neighborhood south of Hart Street. This entire neighborhood (approximately 12
streets) will be added to the EPA distribution list for future mailings.
31. Wetlands
One commenter asked if any wetlands will be filled as a result of this remedy and
whether or not an Army Corps permit was required.
EPA Response to Comment 31
No wetlands will be filled as a result of this remedy, and an Army Corps permit will
not be required.
There will, however, be work conducted in wetlands or floodplains. Significant,
high-level contamination exists in a small area of wetland soils at the culvert outfall
on the Cianci property. EPA has made the determination that there is no practicable
alternative to excavation. Damage to surrounding wetlands during the excavation
will be reduced using erosion control measures. Wetland restoration with indigenous
species will be conducted consistent with the requirements of federal and state
wetlands protection laws. Floodplains will be returned to their natural levels so as to
prevent the loss of storage capacity.
32. Neighbors' Concerns with In-Situ Thermal
One commenter asked if residents in similar situations have voiced concerns
regarding in-situ thermal treatment.
EPA Response to Comment 32
Numerous in-situ thermal treatment projects have been completed at locations
directly adjacent to, and in several cases beneath inhabited structures. Many of these
projects have been completed under State cleanup programs. EPA lacks information
on the extent to which residents had voiced concerns at these sites, however, available
information indicates that the remedial actions were completed with adequate and
appropriate controls on odors, noise, dust and air emissions. In-situ thermal treatment
40
-------
is currently underway at an EPA-lead removal action at a dry cleaner in North
Dakota, and a contract has been awarded and design has begun for an in-situ thermal
remedy at an EPA-lead remedial action at a solvent site in Southern California, In
both eases, EPA has addressed residents' concerns sufficiently to allow these
remedies to proceed in a protective manner.
As described above in response to comment 29, EPA will be working with residents
and local officials to update the Community Involvement Plan and tailor
communication activities to fit their needs. For this plan we will work to identify
what kinds of information people would like to have at their fingertips during in-situ
thermal remediation such as how to recognize a problem if one occurs, what to do if
there is an emergency, and who to contact.
33. Job Requirements to Monitor In-Situ Thermal Process
One commenter inquired as to the job requirements of a person who would monitor
the Site during implementation of the thermal treatment process, specifically training
or education background.
EPA Response to Comment 33
For a site like SRSNE, it can be expected that in addition to round-the-clock
monitoring, an operator will be on site ten hours/day, six days/week, and that a
second operator is likely to be present eight hours/day, five days/week during
implementation. These people will be trained in construction and operation of the
equipment used on site, health and safety issues related to the equipment, and will
have experience working on electrical equipment. The head operator will have
worked on at least one site prior to the SRSNE Site, and will have experience with the
vapor control and treatment system being used at the SRSNE Site. In addition, a
local person (within 20 to 30 minutes of the Site) will be on call when the operators
are not on site, and the on-site operator will have at least daily (and often more
frequent) conversations with the lead engineers and project managers.
34. Potential Vandalism or Fire
One commenter asked if the buildings currently on site will be removed or
demolished to prevent possible vandalism and diminish the chance for major fire,
EPA Response to Comment 34
All buildings associated with the SRSNE facility have been removed. The
Operations Area is vacant. The only structure that currently exists on site is the
building that houses the treatment system for the groundwater that is collected,
treated on site to applicable permit limits, and discharged to the Quinnipiac River.
41
-------
Appendix A
Figures
-------
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GRAPHIC SCALE
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CLASSIFICATION
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l/M/O* I* «»-M HI «MJ
-------
OVERBURDEN CONTAINMENT AREA BOUNDARY
- OVERBURDEN
groundwater unit
• PORTION OF PLUME '/%
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SOUTHINGTON. CONNECTICUT
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I FIGURE
4
-------
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-------
-------
Appendix B
Tables
-------
T"A&i€ £•-1
Organic Compound Groups Detected at SRSNE Site
VOLATILE ORGANIC COMPOUNDS
CHLORINATED
AROMATIC
HYDROCARBONS
HYDROCARBONS
KETONES
Chloroethane
Benzene
Acetone
Methylene Chloride
Toluene
2-Butanone
1,1- Dichloroethene
Ethyl Beneze
2-Hexanone
1,2 - Dichloroethene
Styrene
4- Methyl - 2 - Pentanone
Trichloroethene
1,1,1- Trichloroethane
Carbon tetrachloride
T etraehloroethene
Chlorobenzene
SEMI-VOLATILE ORGANIC COMPOUNDS
POLYNUCLEAR
AROMATIC
HYDROCARBONS
PHTHALATES
PHENOLS
OTHER SVOCS
Naphthalene
Dimethyl Phthalate
Phenol
1,2 - Dichlorobenzene
2 -M ethyl naph thai ene
Diethyl Phthalate
2-Methylphenol
Isophorone
Acenaphthylene
Di-n-butylphthalate
4-Methylphenol
Benzoic Acid
Acenaphthene
Butylbenzylphthalate
4-Chloro-3-
4-Chloraniline
Dibenzofuran
Bis(2-ethylhexyl)-
methylphcnol
Fluorene
phthalate
Phenanthrene
Di-n-octylphthalate
Anthracene
Fluoranthene
Pyrene
Benzo(a)arithraeene
Chrysene
B enzo (b) fl uoranth en e
Benzo(a)pyrene
Ideno( 1,2,3 -cd)pyrene
Dibenz(a,h)anthraeene
Benzo(ghi)perylene
-------
TABLE & - I I
SUMMARY OP ECOLOGICAL CHEMICALS OF CONCERN
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
Chemical
Environmental Media
VOLATILE ORGANIC COMPOUNDS
Surface
Water
Sediment
Soil
Benzene
X
Xylenes (total)
X
X
X
SEMIVOLATILE ORGANIC COMPOUNDS
Aeenaph.th.ene
X
Acenaphthylene
X
X
Anthracene
X
X
Benzo(a)anthracene
X
X
Benzo(a)pyrene
X
X
Benzo(b)fluoranthene
X
Benzo(k)fluoranthene
X
Benzo(g,h,i)perylene
X
Bis(2 -ethylhexyl)phthalate
X
X
X
Butyl benzyl phthalate
X
X
Chrysene
X
X
Dibenzofuran
X
Diethyl phthalate
X
Di-n-butyl phthalate
X
X
Di-n-octyl phthalate
X
X
Fluorene
X
X
Fluoranthene
X
Indeno(1,2,3 -cd)pyrene
X
2-Methylnaphthalene
X
X
Naphthalene
X
X
Phenanthrene
X
X
_1» 2,4 -Trichlorobenzene
X
-------
STOKAKY OF ECOLOGICAL CHEMICALS OP CONCERN
SOLVENTS RECOVERY S1RVXC1 OF NEW ENGLAND, INC. SUPERFOND SITE
S OUTBINGTON, CONNECTICUT
PAGE 2 of 2
Chemical
Environmental &
ledia
PESTICIDES/POLYCHLORINATED
BIPHENYLS (PCBs)/DIOXINS
Surface
Water
Sediment
Soil
Aldrin
X
Alpha- Chiordane
X
Aroclor-1016
X
Aroclor-1248
X
Aroclor-1254
X
X
X
Aroclor-1260
X
X
4,4'-DDD
X
4,4'-DDE
X
X
4,4'-DDT
X
X
Dieldrin
X
X
Endrin
X
X
Endosulfan I
X
Endosulfan IX
X
Gamma-BHC (Lindane)
X
Gamma - Chi ordane
X
X
Heptachlor epoxide
X
X
Methoxychlor
X
DioxillS {as Toxicity Equivalent
Concentrations for 2,3,7,8-TCDD)
X
METALS
Cadmium
X
X
X
Copper
X
X
X
Lead
X
X
X
Mercury-
X
X
Nickel
X
Selenium
X
Zinc
X
-------
TABLE G-1
SUMMARY OF CHEMICALS OF CONCERN AND EXPOSURE POINT CONCENTRATIONS
OPERATIONS AREA PLUME; OVERBURDEN GROUNDWATER
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC
Scenario Timeframe: Future
Medium; Overburden Groundwater
Exposure Medium; Overburden Groundwater
Minimum
Maximum
Exposure Point Concentration
Exposure Point
Chemical of
Units
Frequency of
Concentration
Concentration
Value (3)
Units
Rationale
Concern
Detection
(1)(2)
(1>(2)
Potable Water
1,1,1 -Trich toroethane
ug/L
84/264
0.5
204000
204000
ug/L
Region 1 Policy
1,1-Dichloroethane
ug/L
102/264
0.5
14380
14380
ug/L
Region 1 Policy
1,1-Dichioroethene
ug/L
31/264
0,5
6910
6910
ug/L
Region 1 Policy
2-Butanone
ug/L
38/250
2.5
470000
470000
ug/L
Region 1 Policy
4-Methyl-2-pentanone
ug/L
33/249
2.5
57000
57000
ug/L
Region 1 Policy
Acetone
ug/L
38/236
2.5
320000
320000
ug/L
Region 1 Policy
Benzene
ug/L
49/264
0.5
2500
2500
ug/L
Region 1 Policy
Chlorobenzene
ug/L
26/259
0.5
2500
2500
ug/L
Region 1 Policy
Chloroethane
ug/L
28/259
0.5
3717
3717
ug/L
Region 1 Policy
cis-1,2-Dichloroethene
ug/L
58/137
0.5
221250
221250
ug/L
Region 1 Policy
Ethylbenzene
ug/L
114/264
0.5
84300
84300
ug/L
Region 1 Policy
M,P-Xylene
ug/L
48/118
0.9
8600
8600
ug/L
Region 1 Policy
Methylene chloride
ug/L
19/264
0.5
9000
9000
ug/L
Region 1 Policy
O-Xylane
ug/L
32/118
0.5
3550
3550
ug/L
Region 1 Policy
Tetraohloroathene
ug/L
26/264
0.5
14000
14000
ug/L
Region 1 Policy
Tetrahydrofuran
ug/L
49/217
2.75
52000
52000
ug/L
Region 1 Policy
Toluene
ug/L
95/264
0.5
132000
132000
u^L
Region 1 Policy
trans-1,2-Dichloroethene
ug/L
14/155
0.5
6958
6958
ug/L
Region 1 Policy
Trtebloroethene
ug/L
44/264
0.5
95000
95000
ug/L
Region 1 Policy
Vinyl chloride
ug/L
6S/264
0.5
11900
11900
ug/L
Region 1 Policy
Xylenes, Total
ug/L
107/249
0.5
14000
14000
ug/L
Region 1 Policy
4-Methyi phenol
ug/L
13/30
3
1100
1100
ug/L
Region 1 Policy
Aroclor-1260
ufl/L
2/30
0.5
95
95
ug/L
Region 1 Policy
Page 1 of 2
-------
TABLE G-1
SUMMARY OF CHEMICALS OF CONCERN AND EXPOSURE POINT CONCENTRATIONS
OPERATIONS AREA PLUME: OVERBURDEN GROUNDWATER
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC
Scenario Timeframe: Future
Medium: Overburden Groundwater
Exposure Medium: Overburden Groundwater
Minimum
Maximum
Exposure Point Concentration
Exposure Point
Chemical of
Units
Frequency of
Concentration
Concentration
Value (3)
Units
Rationale
Concern
Detection
(1)(2)
(t)(2)
Arsenic
ug/L.
26/29
1.1
42
42
ug/L
Region 1 Policy
Barium
ug/L
30/30
178
20000
20000
ug/L
Region 1 Policy
Beryllium
ug/'t
20/25
0.2
30
30
ug/L
Region t Policy
Cadmium
ug/L
7/18
0.5
46
46
ug/L
Region 1 Policy
Chromium
ug/L
26/29
2.6
420
420
ug/L
Region 1 Policy
1,2-Dichloroethene, total
ug/L
95/222
1
136625
136625
ug/L
Region 1 Policy
Lead
ug/L
27/30
3.55
85
85
ug/L
Region 1 Policy
Manganese
ug/L
39/39
20.8
23067
23067
ug/L
Region 1 Policy
Nickel
ug/L
25/29
7.9
320
320
ug/L
Region 1 Policy
Thallium
ug/L
1/11
0.65
2
2
ug'L
Region 1 Policy
Vanadium
ug/L
27/29
30
750
750
ug/L
Region 1 Policy
Notes:
(1) The lowest concentration observed from all wells when concentrations observed in each well were averaged over the period in which it was sampled.
(2) Data qualifiers not included (potential for more than one qualifier as a result of data spanning several years).
(3) The exposure point concentration for groundwater is the highest average concentration observed from all wells, when concentrations observed in each well were averaged over the period in
which the well was sampled per Region 1 policy.
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in overburden groundwater from the Operations Area deemed
pertinent to the remedy for the protection of human health (i.e., the concentrations that were used to estimate the exposure and risk). The table includes the range of concentrations detected
for each COC, as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples collected at the Site), the EPC, and how the EPC was derived.
Page 2 of 2
-------
TABLE G-2
SUMMARY OF CHEMICALS OF CONCERN AND EXPOSURE POINT CONCENTRATIONS
OPERATIONS AREA PLUME; BEDROCK GROUNDWATER
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC.
Scenario Timeframe: Future
Medium: Bedrock Groundwater
Exposure Medium: Bedrock Groundwater
Minimum
Maximum
Exposure Point
Chemical of
Units
Frequency of
Concentration
Concentration
Exposure Point Concentration
Concern
Detection
(1)(2)
(1}<2)
Value (3)
Units
Rationale
Potable Water
1,1,1 -T richloroethane
ug/L
55/147
0.5
64238
64238
ug/L
Region 1 Policy
1,1-Dichloroethane
ug/L
68/147
0.5
5000
5000
ug/L
Region 1 Policy
1,1-Dlchloroetheos
ug/L
46/147
0.5
5100
5100
ug/L
Region 1 Policy
1,2-Dichloroethane
ug/L
11/146
0.5
5000
5000
ug/L
Region 1 Policy
2-Butanone
ug/L
23/129
2.5
72375
72375
ug/L
Region 1 Policy
4-Methy(-2-pentanone
ug/L
36/146
2.5
25000
25000
ug/L
Region 1 Policy
Acetone
ug/L
27/128
2.5
55500
55500
ug/L
Region 1 Policy
Benzene
ug/L
40/147
0.5
5000
5000
ug/L
Region 1 Policy
Carbon tetrachloride
ug/L
10/146
0.5
5000
5000
ug/L
Fiegion 1 Policy
Chlorobenzene
ug/L
14/146
0.5
5000
5000
ug/L
Region 1 Policy
Chloroethane
ug/L
49/146
0.5
5000
5000
ug/L
Region 1 Policy
cis-1,2-Dichloroethene
ug/L
48/80
0.5
110000
110000
ug/L
Region 1 Policy
Ethylbenzene
ug/L
73/147
0.5
9300
9300
ug/L
Region 1 Policy
M.P-Xylene
ug/L
28/61
1.0
18000
18000
ug/L
Region 1 Policy
Methylene chloride
ug/L
15/146
1,0
11000
11000
ug/L
Region 1 Policy
O-Xylene
ug/L
23/62
0.5
6600
6600
ug/L
Region 1 Policy
T etrachloroethene
ug/L
35/147
0.5
51000
51000
ug/L
Region 1 Policy
Tetrahydrofuran
ug/L
42/113
2.75
50000
50000
ug/L
Region 1 Policy
Toluene
ug/L
66/147
0.5
92000
92000
ug/L
Region 1 Policy
trans-t ,2-Dichloroethene
ug/L
7/83
0.4
5000
5000
ug/L
Region 1 Policy
Trichioroethena
ug/L
62/147
0.5
730000
730000
ug/L
Region 1 Policy
Vinyl chloride
ug/L
47/147
0.5
12730
12730
ug/L
Region 1 Policy
Xylenes, Total
ug/L
63/145
1.0
25000
25000
ug/L
Region 1 Policy
4-Methyt phenol
ug/L
11/32
3.0
570
570
ug/L
Region 1 Policy
Naphthalene
ug/L
10/32
0.5
25
25
ug/L
Region 1 Policy
Page 1 of 2
-------
TABLE G-2
SUMMARY OF CHEMICALS OF CONCERN AND EXPOSURE POINT CONCENTRATIONS
OPERATIONS AREA PLUME; BEDROCK GROUNDWATER
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC,
Scenario Timeframe: Future
Medium: Bedrock Groundwater
Exposure Medium: Bedrock Groundwater
Minimum
Maximum
Exposure Point
Chemical of
Units
Frequency of
Concentration
Concentration
Exposure Point Concentration
Concern
Detection
(1)(2)
(1)(2)
Value (3)
Units
Rationale
Aroc/or-1254
ug/L
2/32
0.5
97
97
ug/L
Region 1 Policy
Arsenic
ug/L
19/25
1.45
49
49
ug/L
Region 1 Policy
Barium
ug/L
32/32
24.0
12000
12000
ug/L
Region 1 Policy
Beryllium
ug/L
14/21
0,15
52
52
ug/L
Region 1 Policy
Cadmium
ug/L
2/16
0.5
20
20
ug/L
Region 1 Policy
Chromium
ug/L
19/31
2.25
760
760
ug/L
Region 1 Policy
Copper
ug/L
21/29
1.75
1600
1600
ug/L
Region 1 Policy
1,2-Diehloroethene, total
ug/L
78/124
1.0
120000
120000
ug/L
Region 1 Policy
Lead
ug/L
23/28
0.95
190
190
ug/L
Region 1 Policy
Manganese
ug/L
39/39
28.0
43000
43000
ug/L
Region 1 Policy
Nickel
ug/L
18/29
2.7
790
790
ug/L
Region 1 Policy
Thallium
ug/L
1/12
0.65
3.8
3,8
ug/L
Region 1 Policy
Vanadium
ug/L
21/31
2.9
1300
1300
ug/L
Region 1 Policy
Notes:
(1) The lowest average concentration observed from ail walls, when concentrations observed in each well were averaged over the period of which It was reported.
(2) Data qualifiers not included (potential for more than one qualifier as a result of data spanning several years).
(3) The exposure point concentration for ground water is the highest average concentration observed from all wells, when concentrations observed in each well were averaged over the period in
which the well was sampled per Region 1 policy.
The table represents the chemicals of concern (COCs) and exposure point concentrations {EPCs) for each of the COCs detected in bedrock groundwater from the Operations Area deemed
pertinent to the remedy for the protection of human health (i.e., the concentrations that were used to estimate the exposure and risk). The table includes the range of concentrations detected
for each COC, as well as the frequency of detection (i.e.
the number of times the chemical was detected in the samples collected at the Site), the EPC, and how the EPC was derived.
Page 2 of 2
-------
TABLE G-3
SUMMARY OF CHEMICALS OF CONCERN AND EXPOSURE POINT CONCENTRATIONS
OPERATIONS AREA/ RAILROAD PROPERTY: SUBSURFACE SOILS
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Subsurface Soil
Maximum
Exposure Point
Chemical of
Units
Frequency of
Arithmetic
95% UCL
Concentration
Exposure Point Concentration
Concern
Detection
Mean
on the Mean (1)
(Qualifier]
Value (2)
Units
Rationale
Subsurface Soil
Lead
mg/kg
3/3
314
1.4E+29
1750 J
1750
mg/kg
Maximum
Arsenic
mg/kg
3/3
2.91
1.2E+05
5.5
5.5
mg/kg
Maximum
Cadmium
mg/kg
3/3
170
4.8E+08
389
389
mg/kg
Maximum
Vinyl chlonde
mg/kg
1/32
0.12
4.1E+02
0.4 J
0.4
mg/kg
Maximum
Trichtoroethene
mg/kg
24/32
1.15
1.4E+04
430
430
mg/kg
Maximum
Arocior-1016
mg/kg
2/3
0,17
8.0E+16
1.2 J
1.2
mg/kg
Maximum
Aroclor-1260
mg/kg
3/3
1.44
5.1E+09
5 J
5
mg/kg
Maximum
Aroclor-1254
mg/kg
3/3
3.05
2.7E+06
11 J
1t
mg/kg
Maximum
PCBs, total
mg/kg
3/3
4.92
1.06E+07
17.2
17.2
mg/kg
Maximum
bis(2-Ethythexyl)phthalate
mg/kg
3/3
16.1
1.9E+17
120 J*
120
mg/kg
Maximum
Tetrachloroethene
mg/kg
31/32
3.9
1.1E+05
1200
1200
mg/kg
Maximum
2,3,7,8-TCDD
mg/kg
4/8
0.000011
0.0017
0.0003
0.0003
mg/kg
Maximum
2,3,7,8-TCOF
mg/kg
1/8
0.00013
Q.00048
0.0041
0.00046
mg/kg
95% UCL
2,3,4,7,8-PeCDF
mg/kg
1/8
0 000081
0.00097
0.00034
0,00034
mg/kg
Maximum
1.2,3,7,8-PeCDF
mg/kg
1/8
0.00019
0.00082
0.00016
0.00016
mg/kg
Maximum
1,2,3,6,7,8-HxCDF
mg/kg
1/8
0.00029
0.033
0.00021
0.00021
mg/kg
Maximum
2,3,4,6,7,8-HxCDF
mg/kg
1/8
0.000085
0,00040
0.00021
0.00021
mg/kg
Maximum
1,2,3,4,6,7,8-HpCDF
mg/kg
1/8
0.00070
0 04700
0.00049
0,00049
mg/kg
Maximum
1,2,3,4,7,8-HxCDF
mg/kg
1/8
0.00016
0.00058
0.00038
0.00038
mg/kg
Maximum
Notes:
(1) The 95% upper confidence limit (UCL| of the arithmetic mean lor a lognormai distribution was calculated according to USEPA (1992), Supplemental Guidance to RAGS: Calculating the
Concentration Term.
(2) As per USEPA (1989), the exposure point concentration is the lesser of the 95% UCL on the mean and the maximum concentration.
Qualifiers:
J = Indicates that the compound was analyzed for and determined to be present in the sample below the reporting limit.
* - Duplicate analysis not within control limits.
The table represents the chemicals of concern (COGs) and exposure point concentrations (EPCs) (or each of the COCs detected in subsurfacial soils at the Operations Area/Railroad Properly deemed
pertinent to the remedy for the protection ot human health (i.e., the concentrations that were used to estimate the exposure and risk). The table includes the range of concentrations detected for each
COC, as well as the frequency of detection (i.e., the number of times the chemical was detected from the samples collected at the Site}, the EPC, and how the EPC was derived.
Page 1 of 1
-------
TABLE G-4
CANCER TOXICITY DATA - ORAL/DERMAL
SOLVENTS RECOVERY SYSTEM OF NEW ENGLAND. INC.
Chemical
Oral Cancer Slop# Factor (1)
Weight of Evidence/
Date(s)
of
Cancer Guideline
Oral CSF
(MM/DD/YYYY)
Concern
Value
Units
Description (3)
Source(s)
t,1,1-Trichloroeiharie (a)
-
¦
D
IRIS
8/1/1991
1,1 -Dichloroethene (a)
-
-
C
IRIS
8/13/2002
1,2-Dichloroe thane
9.10E-02
(rng/kg-day)-1
B2
IRIS
1/1/1991
2,3,7,8-TCDD
1.50E+05
(mg/kg-day)-1
B2
(HEAST)
7/31/1999
2,3,7,8-TCDF
1.5QE+G4
(mg/kg-day)-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
2,3,4,7,8-PeCDF
7,50 £+04
(mg/kg-day)-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
1,2,3,7,8-PeCDF
7.50E+03
(mg/kg-day)-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
1,2,3,6,7,8-HxCDF
1.50E+04
(mg/kg-day)-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
2,3,4,6,7,8-HxCDF
1.50E+04
(mg/kg-day)-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
1,2,3,4,6,7,8-HpCDF
1.50E+03
(mg/kg-day)-l
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
1,2,3.4,7,8-HxCDF
1.50E+04
(mg/kg-dayj-1
B2
(HEAST), WHO TEF (4)
7/31/99, 12/98
Aroclor-1016 (b)
7.00E-02
(mg/kg-day)-1
B2
IRIS
12/15/1999
Aroclor-1254 (b)
2.00E+00
(mg/kg-day)-1
B2
IRIS
12/15/1999
Aroclor-1254 (d)
4.00E-01
(mg/kg-day)-1
B2
IRIS
12/15/1999
Arock)r-1260 (b)
2.00E+00
(mg/kg-day)-1
B2
IRIS
12/15/1999
Aroclor-1260 (d)
4.00E-01
(mg/kg-dayH
B2
IRIS
12/15/1999
Arsenic
1.50E+00
(mg/kg-day)-1
A
IRIS
6/1/1995
Benzene
5.50E-02
(mg/kg-day)-1
A
IRIS
4/17/2003
Benzo(a)pyrene
7.30E+00
(mg/kg-day)-l
B2
IRIS
3/31/1987
bis(2-Ethylhexyl)phthalate
1.40E-02
(mg/kg-day)-1
B2
IRIS
2/1/1993
Carbon tetrachloride
1.30E-0I
(mg/kg-day)-1
B2
IRIS
6/1/1991
Chtoroethane
2.90E-03
(mg/kg*day)-1
-
NCEA/Region 9
10/1/1991
Chloroform
1 .OOE-02
(mg/kg-day)-i
B2
IRIS
10/19/2001
Copper (c)
-
-
-
•
-
Lead (c)
-
-
-
-
-
Methylene chloride
7.5QE-03
(mg/kg-day)-1
B2
IRIS
1/1/1991
PCBs. total (b)
2.00E+00
(mg/kg-day)-i
B2
IRIS
12/15/1999
PCBs, total (d)
4.00E-01
fmg/kg-day)-1
B2
IRIS
12/15/1999
Tetrachloroethene
5.40E-01
(mg/kg-day)-1
-
Cal-Modified,-'Region 9
10/1/2004
Tetrahydrofuran
7.60E-03
(mg/kg-day)-l
-
NCEA/Region 9
10/1/2004
Trichloroethene
4.OOE-01
(mg/kg-day)-1
-
NCEA/Region 9
10/1/2004
Vinyl chloride
7.2QE-01
(mg/kg-day)-1
A
IRIS
8/7/2000
Page 1 of 2
-------
TABLE G-4
CANCER TOXICITY DATA -- ORAL/DERMAL
SOLVENTS RECOVERY SYSTEM OF NEW ENGLAND, INC.
Notes;
1) Toxicity reference values from USEPA's Integrated Risk Information System (IRIS), and HEAST, NCEA, and PPTRV values as presented in the USEPA Region 9 Preliminary
Remediation Goals (PRGs) The Risk Assessment Information System (RAlS) was also consulted (www,risk.lsd.oml.gov/tox/tox_values) and contains toxicity reference values from
RIS, HEAST and other information sources.
2) Dermal risk evaluated tor COC's in soils only. COCs listed in this table do not require adjustment of the oral slope factor for dermal risk evaluations.
3) Weight-of-Evidence/Cancar Guideline information obtained from IRIS and RAIS (October 1999). Refer to key below.
(4) Oral cancer slope factor for dioxin congeners is the cancer slope factor for 2,3.7,8-TCDD muliplied by the World Health Organization's (WHO's) congener-specific toxicity equivalency
factors (TEFs). (The uncertainty section of the 1999 RA Update describes the USEPA-proposed dioxin cancer slope factor of 1 x 10s )
a) No toxicity data. Oral SF removed from IRIS
(b) Upper-bound slope factor for total PCB (soil ingestion)
c) No toxicity data
(d) Upper-bound slope factor for total PCB for ingestion of water-soluble congeners,
Key EPA Group
-: Not available A - Human carcinogen
RIS: Integrated Risk Information System, U.S. EPA B1 - Probable human carcinogen - Indicates that limited human data are available
NC£A; National Center for Environmental Assessment, U.S. EPA B2 - Probable human carcinogen - indicates sufficient evidence in animals and inadequate or no
WHO TEF: World Health Organization Toxic Equivalency Factor evidence in humans
Cal-Modifled: California Environmental Protection Agency C - Possible human carcinogen
HEAST: Health Effects Assessment Summary Table D - Not classifiable as a human carcinogen
Region 9: EPA Region 9 Preliminary Remediation Goals Database E - Evidence ot noncarcinogenicity
This table provides the carcinogenic risk information which is relevant to the contaminants of concern in groundwater and soils. At this time, slope factors are not available for the dermal
route of exposure. Thus, the dermal slope factors used in the risk assessment wore extrapolated from oral values.
Page 2 of 2
-------
TABLE G-5
NON-CANCER TOXICITY DATA -- ORAL/DERMAL
SOLVENTS RECOVERY SYSTEM OF NEW ENGLAND, INC
Chemical
of
Concern
Chronic/
Subchronic (1)
Oral RfO (2)
Absorption
Efficiency
{for Dermal)
(3)
Adjusted RfD {for
Dermal) (4)
Primary
Target
Organ(s) (1)
Combined
Uncertainty/Modifying
Factors (5)
Source(s)
Date(s)
(MM/DD/YYYY)
Value
Units
Value
Units
1,1,1-Trichlofoetharie
-
2.80E-01
mg/kg-day
-
-
-
NA
NA
NCEA
10/1/2004
1,1-Oichloroethene
Chronic
5.Q0E-02
mg/kg-day
-
-
-
liver
UF=1000
IRIS
8/13/2002
1,1-Dichloroathane
1.00E-01
mg/kg-day
-
..
--
--
-
HEAST/Region 9
10/1/2004
1,2-Dichloroethene, total
Subchronic
1.00E-02
mg/kg-day
-
-
-
blood chemistry
UF=1Q00
IRIS
10/1/2004
2-Butanone
Chronic
6.OOE-01
mg/kg-day
-
-
-
fetal weight
UF=30QQ
IRIS
9/26/2004
4- Methyl-2- pentanone
Subchronic
3.0OE-02
mg/kg-day
-
-
-
liver, kidney
NA
HEAST/Region 9
10/1/2004
4-Methylphenol
Subchronic
5.00E-03
mg/kg-day
-
-
-
neurotoxicity
NA
HEAST/Region 9
10/1/2004
Acetone
Subchronic
9.00E-Q1
mg/kg-day
-
-
kidney
UF=1000
IRIS
7/31/2003
Aroclor-1016
Chronic
7.00E-05
mg/kg-day
-
-
fetal weight
UF=100
IRIS
6/1/1994
Areolar-1254
Chronic
2.00E-05
mg/kg-day
-
-
-
immune system
UF=300
IRIS
6/1/1994
Arsenic
Chronic
3.00E-04
mg/kg-day
-
-
-
skin
UF=3
IRIS
6/1/1995
Barium
Subehronic/Chronic
7.0QE-02
mg/kg-day
0.07
4.9E-03
mg/kg-day
kidney
UF=3
IRIS
1/21/1999
Benzene
4.00E-03
mg/kg-day
blood
UF=3Q0
IRIS
4/17/2003
Beryllium
Chronic
2.00E-03
mg/kg-day
0-007
1.4E-05
nng/kg-day
small intestine
UF=300
IRIS
4/3/1998
bis(2 Elhythexyt)phthalate
Chronic
2.0QE-02
mg/kg-day
-
-
-
liver
Uf-=1000
IRIS
5/1/1991
Cadmium (a)
Chronic
5.00E-04
mg/kg-day
-
-
--
kidney
UF= 10
IRIS
2/1/1994
Cadmium (b)
Chronic
1,00E-03
mg/kg-day
0.025
2.5E-05
mg/kg-day
kidney
UF=10
IRIS
2/1/1994
Carbon tetrachloride
Subchronic
7.00E-04
mg/kg-day
-
-
-
liver
UF=1Q00
IRIS
6/1/1991
Chloro benzene
Subchronic
2.00E-02
mg/kg-day
-
-
-
liver
UF=1000
IRIS
4/1/1993
Chloroethane
-
4.00E-01
mg/kg-day
-
-
-
-
-
NCEAt Region 9
10/1/2004
Chromium (d)
Chronic
3.00E-03
mg/kg-day
0.025
7.5E-05
mg/kg-day
none *
UF=300
IRIS
9/3/199S
cis-1,2-Dichloroethene
Subchronic
1.00E-02
mg/kg-day
-
-
-
blood chemistry
NA
PPRTV/Region 9
10/1/2004
Copper
-
4.00E-02
mg/kg-day
-
-
-
-
-
HEAST/Region 9
10/1/2004
Ethylbenzena
Subchronic
1.00E-01
mg/kg-day
-
-
-
liver,kidney
UF=100Q
IRIS
6/1/1991
Lead (c)
-
-
-
-
-
-
--
-
-
-
M,P-Xylene (e)
Chronic
2.00E-01
mg/kg-day
-
-
-
body weight
UF=100
IRIS
2/21/2003
Manganese (b)
Chronic
7.0OE-O2
mg/kg-day
0.04
2.8E-03
mg/kg-day
CNS
--
EPA-Recommenec
12/2005
Manganese (a)
Chronic
2.40E-02
mg/kg-day
-
-
--
CNS
-
EPA-Recommenec
12/2005
Methylene chloride
Chronic
6.00E-02
mg/kg-day
-
-
-
liver
UF=1Q0
IRIS
3/1/1998
Nickel
Chronic
2.00E-02
mg/kg-day
0.04
B.0E-04
mg/kg-day
body and organ weight
UF=300
IRIS
12/1/1996
O-Xylene (e)
Chronic
2.00E-01
mg/kg-day
-
-
-
body weight
UF=100
IRIS
2/21/2003
Tetrachloroethene
Chronic
1.00E-02
mg/kg-day
-
-
-
liver
UF=1000
IRIS
3/1/1998
Tetrahydroturan
-
2.10E-01
mg/kg-day
-
-
-
-
-
NCEA'Region 9
10/1/2004
Thallium (f)
Subchronic
6.60E-05
mg/kg-day
-
-
-
none
UF=3000
IRIS
9/1/1990
Toluene
Subchronic
2.00E-01
mg/kg-day
-
-
-
liver,kidney
UF=1000
IRIS
10/1/2004
trans-1,2-Dichloroethene
Subchronic
2.00E-02
mg/kg-day
-
-
-
blood chemistry
UF=1000
IRIS
1/1/1989
Vanadium
Chronic
7.00E-03
mg/kg-day
0.026
1.8E-04
mgfltg-day
--
NA
NCEA/PRG
10/1/2004
Viny Chloride
3.00E-03
mg/kg-day
liver
UF=30
IRIS
8/7/2000
Xylenes, lotal
Chronic
2.00E-01
mg/kg-day
body weight
UF=100
IRIS
2/21/2003
Page 1 of 2
-------
TABLE G-5
NON-CANCER TOXICITY DATA - ORAUDERMAl
SOLVENTS RECOVERY SYSTEM OF NEW ENGLAND, INC
Notes:
(1) As reported in Ihe oral RfD summary (IRIS) and oral RfD basis (EHRAV).
(2) Toxicity reference values from USEPA's Integrated Risk Information System (IRIS), and HEAST, NCEA, and PPTRV values as presented in the USEPA Region 9 Preliminary Remediation Goals (PRGs).
The Risk Assessment information System (RAIS) was also consulted (www.risk.Isd.oml.govAox/tox .values) and contains toxicity reference values from IRIS, HEAST and other information sources.
(3) Dermal risk evaluated for COPC in soils only. Dermal absorption efficiencies listed in this table and dermal absorption factors (listed below) are those summarized in the Draft Dermal Absorption Guidance
(USEPA, 1998).
(4) Adjusted RfD = RfD * Absorption Efficiency
(5) As listed in the IRIS Oral RIO summary.
* No critical effect reported.
Oral Rfd for manganese as recommended by USEPA
(a) Oral RfD manganese for water exposure.
(b) Oral RfD for manganese for dietary exposure.
(c) No toxicity data.
(d) Toxicity value for Chromium VI
(e) Toxicity data for xylene
(f) Toxicity data adjusted from the RfD for thallium chloride
Dermal Absortion Factors used in Risk Calculations tor Soil (RAGS Part E: Supplemental Guidance tor Dermal Risk Assessment. EPA 1998).
PCBs = 0.14
PAHs = 0.13
Dioxins = 0.03
Arsenic = 0.03
Cadmium = 0.01
This table provides non-carcinogenic risk information which is relevant to the contaminants of concern in groundwater and soils.
A toxicity value is not available for lead. Lead hazards were evaluated qualitatively against a screening concentration of 400 mg/kg for soils and the MCL of 15 ug/l for
groundwater. Dermal RfDs are not available for any of the COCs. Dermal RfDs can be extrapolated from oral RfDs by applying an adjustment factor as appropriate.
Dermal absorption factors for compunds from soils were obtained for the few compounds for which guidance is available (RAGS Part E, EPA 1998).
Page 2 of 2
-------
TABLE G-6
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA: OVERBURDEN GROUNDWATER
Scenario Timeframe. Future
ieceptor Population Resident
leceptor Age Adult
Medium
Exposure
Exposure
Chemical
Carcinogenic Risk
Non-Carcinogenic Hazard Ouotsem
Medium
Poirrt
of
Concern
ingestion
Inhalation
Dermal
Externa!
Exposure
Primary
Ingestion
Inhaiation
Dermal
Exposure
(Radiation*
Routes Total
Target Qrgan(s)
Routes Total
Overburden
Ovenburden
Potabfe
1,1,1 -T richtorcethane
m
-
NA
NA
ZE+Of
•
2, £+01
Groundwater
Groundwater
Water
1,1-Dichloroeihane
m
-
•
NA
NA
4. E+00
4.E+OG
1,1-Dicftioroethene
NA
-
-
NA
liver
4 E+00
.
4.E+00
1,2-Qqhloretherte,icxal
m
-
NA
Liver
4 E+02
-
4.E+02
2-Butanone
NA
-
-
NA
Fetal Weight
2.E+01
2.E+01
4-Mefhyl'2-pentanone
NA
-
NA
Liver, Kidney
2.E+01
2.E+01
4-Memyiphenot
NA
NA
Neurotoxicity
6,Ef00
6E400
Acetone
NA
-
NA
Liver, Kidney
1 .E+G1
1.E+G1
Aluminum
NA
NA
NA
NA
NA
Arodor-1260
4.E-04
4.E-04
Immune System
NA
NA
Arsenic
7.6-0*
-
7E-04
Skirt
4, E+00
-
4. E+CH)
Barium
NA
NA
Kidney
8.6+00
.
a.E+oo
Benzene
2.6-03
-
-
2.E-03
NA
2-6+01
-
2.E+Q1
Cadmium
NA
-
NA
Kidney
3.E+O0
.
3.E+O0
Chiorobenzene
NA
-
NA
Liver
3.E+00
-
3.E+00
CWoraethane
1.E-04
-
-
1.E-04
NA
3.E-01
3-E*01
Chromium
NA
-
NA
NA
4. E+00
•
4.E+00
cis-1,2-Dichioroethene
NA
-
NA
Blood
$£*02
.
6.E+02
Ethyl&enzene
NA
NA
Liver, Kidney
2.E-M31
2E+01
Lead
NA
NA
NA
NA
_
NA
Manganese
NA
-
-
NA
CNS
3.E+01
-
3.E+G1
Methylene chioride
8.E-D4
-
8.E-0*
Liver
4.E+OQ
-
4.E+00
T etrachioro&thena
8.E-02
-
-
8.E-02
Liver
4.E+01
-
-
4.£+01
T^frahydrofuran
5.E-D3
•
-
5.E-G3
NA
7.£*OG
-
7. E+00
Toluene
NA
-
NA
Livef,Kidney
2.E+01
2.6+01
irans-1 2-0«cWoroeihene
NA
-
NA
Blood
1.E+01
1,6+01
Tnchiofoethene
it.E-01
-
4.E-01
NA
NA
NA
Vanadium
NA
-
NA
NA
3-E+OQ
-
a.e+oo
vmyf chfonde
¦ 7.E-01
-
-
7.E-01
NA
1.E+02
1.6+02
Xylenes, total
NA
NA
Body Weight
2.E+00
2.E+00
Page 1 of 2
-------
TABLE G-6
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA OVERBURDEN GROUNDWATER
Scenario Timeframe; Future
Recepior Population: Resident
Receptor AQe: Adult
MecJium
Exposure
Medium
Exposure
Point
Chemical
of
Concern
Carcinogenic Risk
Non-Cancmogenic Hazard Quotient
Ingestion
Inhalation
Dermal 1 ExfernaJ
[ (Radiation)
Exposure
Routes Total
Primary
Target Organ(s)
Jngetsficm J Jnh^atiw
OermaJ
Exoosuw
Routes Total
Chemical TotaJ
1
1.6+00
|
1 1.E+03
Radionuclide Totai
NA
|
NA
I
II NA
Exposure Point Totai
||
1.E+00
¦
| 1.E*03
Total Adult Resident Risk for Overburden GrDyndwai^jP^^^^^5^! Total Adult Resident Hazard for Overburden Groundwater,
Notes-
Cherr>eais included in ihe risk assessment summary hav& cancer risks greater ihan I0'a and/or noncancer hazards greater jhan 1. 70
-------
TABLE G-7
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA PLUME: BEDROCK GROUNDWATER
Scenario Timeframe; Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure
Point
Chemical
ot
Concern
Carcinogenic Risk
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
External
(Radiation
Exposure
Routes Total
Primary
Target Organ(s)
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Bedrock
Bedrock
Potable
1, t, 1 -T richloroethane
NA
-
•
-
NA
NA
6.E+0Q
-
-
6.E+00
Groundwater
Groundwater
Water
1.1 -Diehloroethane
NA
-
-
-
NA
NA
1.E+00
-
-
t.E+OO
i,i-Dichloroett)ene
NA
-
-
¦
NA
Liver
3.E+0Q
•
-
3.E+00
1,2-Dichloroethane
5.E-03
-
-
-
5.E-03
NA
NA
-
-
NA
1,2-Dichlorethene,total
NA
-
-
-
NA
Liver
3.E+02
-
•
3.E+02
2-Butanone
NA
-
-
-
NA
Fetal Weight
3.E+00
-
-
3.E+00
4-Mothyl-2-pentanone
NA
-
-
*
NA
Liver, Kidney
9.E+00
•
*
9.E+Q0
4-Methyt phenol
NA
-
-
-
NA
Neurotoxicity
3.E+00
-
-
3.E+00
Acetone
NA
-
-
-
NA
Liver, Kidney
2.E+00
-
-
2.E+00
Aluminum
NA
•
-
•
NA
NA
NA
•
-
NA
Aroclor 1254
4.E-04
-
-
-
4.E-04
Immune System
1.E+02
-
•
1.E+02
Arsenic
9.E-04
-
-
-
9.E-04
Skin
4.E+00
-
-
4.E+00
Barium
NA
-
-
NA
Kidney
5.E+00
-
-
5.E+00
Benzene
3.E-03
-
-
-
3.E-03
NA
3.E+01
-
-
3.E+01
Cadmium
NA
-
-
-
NA
Kidney
1.E+00
-
-
1.E+00
Carbon tetrachloride
a.E-03
-
-
8.E-03
Liver
2.E+02
-
¦
2.E+02
Chloro benzene
NA
-
-
-
NA
Liver
7.E+O0
-
-
7.E+00
Chloroethane
2.E-04
•
-
-
2.E-04
NA
3.E-01
•
¦
3.E-01
Chromium
NA
-
-
-
NA
NA
7.E+00
-
•
7.E+00
cis-1,2-Dichforoethene
NA
•
-
-
NA
Blood
3.E+Q2
-
-
3.E+02
Copper
NA
-
-
-
NA
NA
t.E+00
-
-
t.E+OO
Ethylberizene
NA
-
-
-
NA
Liver, Kidney
3.E+Q0
-
-
3.E+00
Lead
NA
-
-
-
NA
NA
NA
-
-
NA
M,P-Xylene
NA
•
-
-
NA
Body Weight
2.E+00
•
-
2.E+00
Page 1 of 3
-------
TABLE G-7
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA PLUME: BEDROCK GROUNDWATER
Scenario Timeframe; Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical
Carcinogenic Risk
Non-Carcinogenic Hazard Quotient
Medium
Point
of
Concern
Ingestion
Inhalation
Dermal
External
Exposure
Primary
Ingestion
Inhalation
Dermal
Exposure
(Radiation
Routes Total
Target Organ(s)
Routes Total
Manganese
NA
-
-
-
NA
CNS
8.E+00
-
-
5.E+01
Methylene chloride
1.E-03
-
-
-
1.E-03
Liver
5.E+00
-
-
5.E+00
Nickel
NA
-
-
-
NA
Body, Organ Weight
1.E+GO
•
-
1 ,E+0Q
Tetrachtoroethene
3.E-01
-
-
-
3.E-01
Liver
1.E+02
-
-
1.E+02
Tetrahydrofuran
4.E-03
-
-
-
4.E-03
NA
7.E+00
-
-
7.E+00
Thallium
NA
-
-
-
NA
Blood
2.E+G0
-
-
2.E+00
Toluene
NA
-
-
-
NA
Liver,Kidney
1.E+G1
•
-
1.E+01
trans-1,2-Dichloroethene
NA
-
-
-
NA
Blood
7.E+00
*
-
7.E+00
Trichloroethene
3.E+00
-
-
-
1.E+00
NA
NA
-
-
NA
Vanadium
HA
-
-
-
NA
NA
5.E+00
-
-
5.E+00
Vinyl chloride
7. £-01
-
-
-
7.E-01
NA
1.E+02
-
-
1.E+02
Xylenes, total
NA
-
-
-
NA
Body Weight
3.E+00
-
-
3.E+00
Chemical Total
2.E+00
1.E+03
Page 2 of 3
-------
TABLE G-7
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA PLUME: BEDROCK GROUNDWATER
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: A dull
Medium
Exposure
Medium
Exposure
Point
Chemical
of
Concern
Carcinogenic Risk
Ingestion Inhalation Dermal | Externa! Exposure
(Radiation] Routes Total
Non-Carcinogenic Hazard Quotient
Primary Ingestion
Target Organ(3) |
Inhalation! Dermal
Exposure
Routes Total
Radionuclide Total
NA
NA
NA
Exposure Point Total
2.E+00
1.E+03
Notes:
2, E+00 [Total Adult Resident Hazard for Bedrock Groundwater
Target-specific hazard indices greater than 1 are included in the total target organ hazard index tor overburden groundwater.
NA = not available
Total Adult Resident Risk tor Bedrock Groundwater
Chemicals included in the risk assessment summary have cancer risks greater than 10"® and/or n on cancer hazards greater than 1.
Total [Liver] HI Across Bedrock Groundwater =
Total [Kidney] HI Across Bedrock Groundwater =
Total [Blood] HI Across Bedrock Groundwaters
Total [immune System] HI Across Bedrock Groundwater =
Total [CNS/naurotoxicity] HI Across Bedrock Groundwater =
Total [Body Weight] HI Across Bedrock Groundwater =
Total [Skin] HI Across Bedrock Groundwaters
l.E+03
7.E+02
3.E+01
3.E+02
1.E+02
5.E+01
7. E+00
4. E+00
This table provides carcinogenic and non-carcinogenic risk estimates for the consumption of groundwater obtained from the bedrock aquifer at the Operations
Area. These risk estimates are based on reasonable maximum exposure assumptions. The excess lifetime cancer risk for a potential consumer of groundwater
from the bedrock aquifer at the Operations Area approaches unity, indicating a very high probability that an individual may develop cancer from site were exposure j
to occur. There is also a high probability that an individual may experience adverse effects on the liver, blood, immune, kidney, nervous system, and other organs
or systems if the bedrock groundwater were consumed. Vinyl chloride, trichiorethene, tetrachloroethene, 1,2-dichloroethene, PCBs, carbon tetrachloride were key
contributors to these risk estimates.
Page 3 of 3
-------
TABLE G-8
RISK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA/ RAJLRQAD PROPERTY SUBSURFACE SOUS
RESIDENTIAL ADULT
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adutt
Medium
Exposure
Exposure
Chemcal
Carcinogenic RjsK
Non-Carcinogenic Hazard Quotient
Medium
Point
of
Concern
Ingestion
Inhalation
Dermal
External
Radiation)
Exposure
Routes Total
Primary
Target Organ(sj
Ingestion
Inhalation
Derma!
Exposure
Routes Total
Subsurface
Soil
Subsurface Soil
Subsurface
Scii
Arsenic
4.E-06
-
5.E-07
4.E-06
Skin
3 E*02
-
3.E-03
3.E-02
TricWoroetftene
8.E-Q5
--
-
S.E-05
NA
NA
-
NA
Aroclar-1280
5.E-06
-
3.E-06
8E-06
Immune System
NA
-
NA
NA
ArocEor-1254
1.E-05
-
6.E-06
-
2E-05
Immune System
BE-01
-
4.E-01
1.E+G0
Teirachloroeihene
3.E-04
-
-
-
3.E-04
Liver
2.E-01
-
-
2.E-01
2.3J.B-TCDD
2.E-Q5
-
3.E-G6
2.E-05
NA
NA
*
NA
NA
2,3.7,8-TCDF
3.E-06
4.E-07
.
3E-06
MA
NA
-
NA
HA
2,3,4,7,8-PeCDF
1.E-05
-
i.B-oe
1.E-05
NA
NA
.
NA
NA
1,2.3,4,7,B-HxCDF
3.E-06
-
3.E-07
-
3.E-06
NA
NA
NA
NA
Chemical Total
4E-04
T.E-fOO
|
Radionuclide Total
| NA
NA
Exposure Point Total
|| 4E-G4
I
1.E+QO
Notes:
Total Adult Resident Risk tor Subsurface Soil
4.E-04
Total Adutt Resident Hazard for Subsurface Soil
I.E-fOO
-¦ = D§rmal risk riot evaluated
Chemicals included in the risk assessment summary have cancer risks greater than 10* anchor noncancer risks greater than 1.
Total (Liver) HI Across Subsurface Soil =
HibeJow 1
na = not avajlabie
Total [ImmuneJ HI Across Subsurface Soil -1
1.E+00
This table provides carcinogenic and non-carcinogenic risk estimates for a potential adult resident who may ingest or touch soils (presently below the surface) at the Operations Area/
Railroad Property. These risk estimates are based on reasonable maximum exposure assumptions. The excess lifetime cancer risk for a potential adutt residential receptor from
subsurface soil contamination at the Operations Area/ Railroad Property is 4 x 10 * which exceeds EPA's acceptable cancer risk range. TetrachJoretherie, PCBs, and tricWorethen© were
key contributors to these risk estimates. Adverse non-carcinogenic effects are not likely for this receptor as ail hazard indices were less than or equal to unity.
Page 1 of 1
-------
TABLE G-1Q
RiSK ASSESSMENT SUMMARY
REASONABLE MAXIMUM EXPOSURE
OPERATIONS AREA/ RAILROAD PROPERTY SUBSURFACE SOILS
WORKER
r-—==—i
Recepior Population Worker
Reefeptor Age Adult
Medium
Exposure
Exposure
Chemical
Carcinogenic RisK
Non-Carcmogenic Hazard Quotient
Medium
Point
of
Concern
Ingestion
inhalation
Dermal
External
(RadfaJjan)
Exposure
Routes Total
Primary
Target Organs)
Ingestion
inhalation
Dermal
Exposure
Routes Toial
Subsurface
Soil
Suasurface
Soil
Subsuriace
Soil
Arsenic
Tnchioroeihene
3.E-06
6.E-05
4.E-07
3 E-06
6E-05
Skin
NA
2.E-Q2
NA
-
3.E-03
2 E-02
NA
ArocSoM2S0
3 E-06
2.E-06
5 E-06
Immune System
NA
NA
NA
ArocteM254
8 E 06
a E-06
.
1.E-G5
Immune System
5.E-01
-
4 E 01
9.E-G1
Tet rachtoroel hene
2.E-04
2.E-04
liver
1 e-ot
"
t.E-01
2,37,8-TCDD
2.E-05
2.E-06
-
2E-05
NA
NA
NA
NA
2,3,7,8-TCOF
2M-W
3C-07
2 E-06
NA
NA
NA
NA I
2,3,4,73-PeCDF
9E-06
i eoe
\ E-OS
NA
MA
NA
NA
1.2.3,6.7.8-HxCDF
l.E-06
2 E-Q7
1 E-06
NA
NA
NA
NA
2.3.4.6,7, S-HxCOF
1 E-06
2.E-07
.
1 E-06
NA
NA
NA
NA
1,2/M, 7.8-HxCDF
2. E-06
3.E-07
-
2 E-06
NA
NA
-
NA
NA
Chemical Tola!
3 E-04
1.E+00
Radionuclide Total
NA
1 NA
Exposure Point Total
|
3E-04
| 1.6*00
Notes
Total ActuK Worker Risk for SutJsurfaee Soli'
3 E 04
falai Aduii Worker Hazard Across Subsurface Saif
t.e+oo
- - Dermal risk not evaluated
Chemicals included in the risk assessment summary have cancer risks greater than 10* and/or noncancer risks greater man i
Total jUverj Hi Across Subsurface Soti =
Hi below 1
Target-specilsc hazard indices are less than 1, and are therefore not included in the total organ hazard index for surface soil.
Total llmmune] HI AcrossSubsurlace Soil =5
HI below 1
NA .* not available
Total |Skm] HI Across Subsurface Sotl =
[ HI below t
This table provides carcinogenic and non-carcinogenic risk estimates for a potential worker who may ingest or touch soils from the subsurface at the Operations Area/ Railroad Property. These risk estimates are based on
reasonable maximum exposure assumptions. The excess lifetime cancer risk for an adult worker from potential exposure to subsurface soil contamination at the Operations Area/ Railroad Property Is 3 x 10*4 which exceeds
EPA's acceptable cancer risk range. Tetrachloroethene and trichloroethene were key contributors to these risk estimates. Adverse non-carcinogenic effects are not likely for this receptor as all hazard indices were less than
lor ©qua) to unity.
Page 1 of 1
-------
TABLE G-IX-
RISK ESTIMATES FOR SURFACE WATER COQs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
MAXIMUM
MEAN
BENCH-
MAXIMUM
MEAN
ADVERSE
SECTOR
COCs
CONCEN-
CONCEN-
MARK 1
RISK
RISK
EFECTS
TRATION
TRATION
Upstream
Xylenes (jjq/U
NO
ND
5000.00
ND
ND
no
Bls(2-ethylhexvl)phthaJate (yg/L)
4.50
4.50
3.00
1.50
1.50
Probable
Aroclor-1254 (yg/L)
ND
ND
0.014
ND
ND
no
Cadmium Ojq/L)
ND
ND
0.87
ND
ND
no
Copper Cwa/Ll
4.60
4.60
. 8.86
0.52
0.52
no
Lead Ijjq/L)
2,50
2.05
2.07
1.21
0 99
Possible
Cumulative risk
3.23
3.01
Down-
stream
Xylenes (yg/U
ND
ND
5000.00
ND
ND
no
B ls(2 - ethylhexyl)phthaiate (yfl/U
5.00
5.00
3.00
1.67
1,67
Probable
Aroclor-1254 (pg/L)
ND
ND
0.014
ND
ND
no
Cadmium frig/LJ
ND
NO
0.B7
ND
ND
no
Copper (mo/L)
180,00
32.52
8.86
20.32
3.67
Probable
Lead (ya/Ll
3.80
2 22
2.07
1.84
1,07
Probable
Cumulative risk
—
—
23.82
6.41
Floodplaln
Xylenes (yg/Ll
ND
ND
5000.00
ND
ND
no
Bls(2-ettiytiexyl)phthalaie {yg/U
ND
ND
3.00
ND
ND
no
Aroclor-1254 (WP/L3
ND
ND
0.014
ND
ND
no
Cadmium {yg/LS
ND
ND
0.87
ND
ND
no
Copper (ma/L)
4.60
4 00
8.86
0,52
0.45
no
Lead (uq/L)
320
2.18
2.07
1,55
1.05
Probable
Cumulative risk I —
2.07
1,50
Cluvert
outfall/
$0d|D srss
Xylenes {yg/U
37.00
17,00
5000.00
0.01
0.0034
no
Bis(2-ethylhexyl)phthalate («a/D
3.50
350
3.00
1.17
1.17
Probable
Aroclor-1254 (jjq/L)
0.8S
0.62
0.014
60.71
44.29
Probable
Cadmium (jjg/L)
ND
ND
0.87
ND
ND
no
Copper ing/L}
ND
ND
8.86
ND
ND
no
Lead (mo/L)
2.50
1.83
2.07
1.21
0.881 Possible
Cumulative risk
__
—
63.10
46.34
Seasonal
ponds
Xylenes (yg/L)
1.00
1.00
5000 00
0.0002
0.0002
no
Bls(2-ethylhexyl)phthalate (yg/L)
ND
ND
3.00
ND
ND
no
Aroclor-1254 frfg/L)
NO
ND
0.014
ND
NO
no
Cadmium (yg/L)
48.15
25.32
087
55.34
29.10
Probable
Copper Cmq/L)
10.90
8.38
886
1.23
0.95
Possible
Lead (uq/L)
3.50
2.50
2,07
1.69
I 1.21
Probable
Cumulative risk
—
—
58.271 31.26
NOTES:
1. Benchmark toxicity values from Table 7-13
ND - Not detected
-------
TABLE' &*- 13
RISK ESTIMATES FOR SEDIMENT COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC, SUPERFUND SITE
SOUTHINQTON, CONNECTICUT
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE!
EFFECTS
Upstream
Xylenea (wo/l)
c)
ND
ND
5000,00
ND
ND
no '
Acenaphthene (yo/g oc)
b)
11.17
6.59
140.00
0.08
0 05
no
Acenaphthytene (ua/a oc)
b)
4,77
4.77
140.00
0.03
0.03
no
Anthracene (fjg/Kg)
a)
840.00
296.10
85.00
988
3.48
Probable
ienzo(a)anthracene (M9/Kg)
a>
1900.00
564.20
230.00
8,26
2,45
Probable
Benzo(a)pyrene (Ma/Kg)
1200.00
446.93
400,00
3.00
1.12
Probable
Bls(Z-ethythexyl)phthalate (yg/l) c)
0,25
0.10
3.00
0.08
0.03
no
Butyl benzyl phthaiate (ao/0
0.29
0.29
3.00
0.10
0.10
no
Chrysene Gua/Kg)
a)
2000.00
627.67
400.00
5.00
1.57
Probable
Dibenzofuran (no/Kg)
a)
280.00
224.67
230.00
1.22
0.98
Possible
Di-n-butvi phthaiate fc/g/l)
c)
ND
ND
3.00
ND
ND
no
Dl-n-octyt phthaiate (jjq/Kcj)
a)
184.67
184.67
NA
NA
NA
no
Fluorene (wo/i)
e)
1.72
0.82
8.20
0.21
0,10
no
2-Methyinaphthaiene (yg/Kg)
ND
ND
65.00
ND
ND
no
Naphthalene Cmo/I)
c)
ND
ND
620.00
ND
ND
no
Phenanthrene (yg/g oc)
b)
122.62
32.60
120.00
1.02
0.27
Possible
AJdrin (yg/Kg)
a)
ND
ND
10.00
ND
ND
no
Alpha-Chlordane (ug/l)
c)
0,0001
0.0001
0.0043
0.02
0.02
no
ArociOr 1254 (^jg/l)
e)
0,0011
0.0011
0.014
0.08
0.08
no
Aroclor 1260 (pg/l)
c)
ND
ND
0.014
ND
ND
no
4,4'—DDO (jug/I)
c)
0.00003
0.000031 0.001
0.03
003
no
4,4'-DDE (uQfl)
c>
ND
ND
0.001
ND
ND
no
4,4'-DDT ipg/i)
c)
0,00023
0.00023
0.001
0.23
0.23
no
Dieldrin (vqIq oc)
b)
ND
ND
9.00
ND
ND
no
Endrin ftjg/g oc)
b)
0.038
0.038
4,00
0.01
0.01
no
Endosulfan I (yg/l)
c)
ND
ND
0.056
ND
ND
no
Gamma-Chlordane Cjq/I)
c)
ND
ND
0,0043
ND
ND
no
Heptachlor epoxide ipo/i)
c)
0.00006
0.00006
0.0038
0.02
0.02
no
Cadmium (mg/Kg)
a)
20.10
5.14
1.00
20.10
5.14
Probable
Copper (mg/Kg)
a)
87,25
28.96
100,00
0.87
0,29
no
Lead (mg/Kg)
a)
45.90
20.54
50 00
0.92
0.41
no
Mercury (mg/Kg)
a)
0.19
0.09
0.10
1.90
0,90
Possible
Nickel (mg/Kg)
a>
53.00
17.68
100.00
0.53
0.18
no
Zinc (mq/Kq)
a)
73.35
33.76
100.00
0.73
0.34
no
Cumulative risk
—
—•
__
54.33
17.82
¦¦¦
NOTES:
1, Benchmark toxicity values from Table 7-13
a) Sediment concentration
b) Sediment concentration par gram of organic carbon
c) Estimated Interstitial water concentration I benchmark toxicity value for surface water concentration
g oc - Grams of organic carbon
NA - Appropriate Benchmark toxictty value no! available; Kp value not available for the calculation of
Interstitial water concentrations (see Table 7-9),
NO - Not detected
-------
RISK ESTIMATES FOR SEDIMENT COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
PAGE 2 OF 5
SECTOR j
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Down-
Xylenes toa/ft
e)
0.10
010
5000.00
0.00002
0.00002
no
stream
Acenaphthene (jig/o oc)
b)
33.66
13.69
140.00
0.24
0.10
no
Acenaphthylene iuala oc)
V
8.83
SJ2
140.00
0.06
0.04
no
Anthracene ftto/Ka)
a)
1400.00
294.19
85.00
16.47
3.46
Probable
BenzoMartthracene (tm/Ka)
a)
1800.00
605.8S
230.00
7.63
2.63
Probable
Benzo(a)pyrene too/Kg)
a)
1400.00
466.70
400.00
3.50
1.22
Probable
Bis{2-elhylhsxvftpftthaiate )
0.085
0.085
4.00
0.02
0.02
no
Endosulfan I (wo/I)
c)
ND
ND
0.056
ND
ND
no
Gamma-Chiordane Uta/I}
C)
0.00019
0.00011
0.0043
0.04
0.03
no
Heptachtor epoxide faa/l)
e)
ND
ND
0.0038
ND
ND
no
Cadmium (rrtg/Ka)
a)
25.80
i,17
1.00
25.90
6.17
Probable
Copper (ma/Ka)
a)
464.00
85,39
100.00
4.64
0,85
Possible
Lead (mg/Kg)
a)
212.00
53.37
50.00
4,24
1.07
Probable
Mercury (mg/Kg)
a)
0.30
0.11
0.10
3.00
1.10
Probable
Nickel (ma/Ka)
a)
70.50
21.19
100.00
0.71
0.21
no
Zinc (mq/Ko)
a)
166.00
49.76
100,00
1,66
0.50
Possible
Cumulative risk
__
,—
—
80,62
1 23.45
H^Hi
NOTES;
1. Benchmark toxicity valuta from Table 7-13
a) Sediment concentration
b) Sediment concentration per gram of organic carbon
c) Estimated interstitial water concentration / benchmark toxicity value tor surface water concentration
g oe - Grams of organic carbon
NA - Appropriate benchmark toxicity value not available; Kp value not available tor the calculation of
Interstitial water concentrations (see Table 7-9).
NO - Not detected
-------
RISK ESTIMATES FOR SEDIMENT COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUNO SITE
SOUTH1NGTON, CONNECTICUT
PAGE 3 OF 5
SECTOR
COCS
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK1
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Floodplain
Xylenes (mo/I)
c)
ND
ND
5000.00
ND
ND
no
Acenaphthene £yg/a oc)
b)
6.67
6.67
140.00
0.05
0.05
no
Acenaphthylene (mq/q oc)
b)
35.96
30.24
140.00
0.26
0.22
no
Anthracene (ya/Ko)
a)
560.00
369.72
85,00
6.59
4.35
Probable
SenzofaJanthracene (wo/Kg)
a)
2600 00
619.72
230.00
11.30
2.69
Probable
Ben20(a)pyrene (yg/Ko)
a)
2500.00
619.72
400.00
6.25
1.55
Probable
Bls(2~ethylhexvilphthalate (uo/l) ci
0.17
0.14
3.00
0.06
0,05
no
Butyl benzyl phthalate (wal)
c)
NO
ND
3.00
ND
ND
no
Chrysene (yg/Kq)
a)
2500.00
636.39
400.00
6.25
1,59
Probable
Dibenzofuran (yfl'Kg)
a)
55.00
55.00
230.00
0.24
0.24
. no
01-n-butyl phthalate (yg/l)
c)
0.18
0.18
3.00
0.06
0.06
no
Dl-n-octyl phthalate (ws/Kq)
a)
ND
ND
NA
ND
ND
no
Fluorene (jjq/0
c)
1.88
1.88
8.20
0.23
0,23
no
2-Methylnaphthalene ivo/Kg)
a)
ND
ND
65.00
ND
ND
no
Naphthalene (/jq/I)
c)
ND
ND
620.00
ND
ND
no
Phenanthrene (yg/a oc)
192.98
48.66
120.00
1,61
0.41
Possible
Aldrtn (ama)
a>
ND
NO
10.00
NO
ND
no
Alpha-Chlordane fcig/I)
c>
ND
ND
0.0043
ND
ND
no
Aroctor 1254 (mo/I)
c)
ND
ND
0.014
ND
ND
no
Aroctor 1260 (mq/I)
C)
0.00113
0.00112
0.014
0.08
0.08
no
4,4'—DDO 0/O/0
C)
0.0001
0.0001
0.001
0.10
0.10
no
4,4-DDE ium
C)
0.0008
0.0006
0.001
0.80
0.60
no
4,4'—DDT (tfQ/l)
c)
0.0016
0.0011
0.001
1.60
1.10
Probable
Dieldrln fcjg/g oc)
*>)
0.140
0.140
9,00
0.02
0.02
no
Endrin OiQ/a oc)
b)
0.148
0.148
4,00
0,04
0.04
no
Endosutfan i {yg/f)
c)
0.0103
0,0103
0.056
0,18
0.18
no
Gamma-Chlordane (yg/l)
c)
0.00024
0.00024
0.0043
0,06
0.06
no
Heptachlor epoxide (yg/i)
C)
0,00025
0.00025
0.0038
0,07
0.07
no
Cadmium (ma/Kq)
a)
68.80
15.16
1.00
68.80
15,16
Probable
Copper (mg/Kg)
a)
473.00
134 50
100.00
4.73
1.35
Probable
Lead (mg/Kg)
a)
493.00
139.27
50.00
9,86
2.79
Probable
Mercury (mg/Ko)
a)
1.20
0,35
0.10
12.00
3.50
Probable
Nickel {mg/Kg)
a)
112.00
31.09
100.00
1.12
0.31
Possible
Zinc (ma/Kq)
a)
283.00
124.61
100,00
2.83
1.25
Probable
Cumulative risk
— I 135.17
38.01
NOTES:
1. Benchmark toxicity values from Table 7-13
a} Sediment concentration
b) Sediment concentration per gram of organic carton
c) Estimated Interstitial water concentration / benchmark toxicity value tor surface water concentration
goe - Grama of organic carbon
NA - Appropriate benchmark toxicity value not available; Kp value not available for the calculation of
interstitial water concentrations (see Table 7-9).
ND - Not detected
-------
RISK ESTIMATES FOR SEDIMENT COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTWNGTON, CONNECTICUT
PAGE 4 OF 5
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK '
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Culvert
Xylenes (mo/0
c)
0.30
0 30
5000.00
0.00006
0.00006
no
outfall/
Acenaphthene iuo/a oc)
b)
ND
ND
140.00
ND
ND
no
seep area
Acenaphthyierw (uq/q oc)
b)
28.4?
24.75
140.00
0.20
0.18
no
Anthracene (uo/Ka\
«)
183.33
171.00
85.00
2.16
2.01
Probable
Beri20{a)anthracene fcig/Kg)
340.00
230.17
230.00
1.48
1.00
Probable
Beri2o(a)pvrene (yg/Kg)
a)
255.00
231.17
400.00
0.64
0.58
no
Bis(2-elhy1hexyl)phthalate fao/fl c)
18.70
8.32
3.00
6.23
2.77
Probable
Butyl benzyl phthalate (yg/l)
c)
4.82
2.33
3.00
1.61
0.78
Possible
Chrysene (wg/Kg)
a)
375.00
283.17
400.00
0.94
0.71
no
Dibenzofuran (yg/Kg)
a)
ND
ND
230.00
ND
ND
m
Di-n-butyl phthalate (yo/D
c)
0.73
0,67
3.00
0.24
0.22
no
Dl-n-octyl phthalate (yfl/Kg)
a)
740.00
411.23
NA
NA
NA
no
Fluorene (mq/I)
c)
1.04
1,04
8 20
0.13
0.13
no
2-Methylnaphthalene (ys/Kg)
a)
191.00
182.17
65.00
2.94
2.80
Probable
Naphthalene (yg/l)
=)
15.61
14,10
620.00
0.03
0.02
no
Phenanthrene (yg/g oc)
b)
48.51
31.96
120.00
0.40
0.27
no
Aldrln (yo/Kg)
a)
14.00
6.98
10.00
1.40
0.70
Possible
Alpha-Chlordane big/1)
c)
ND
ND
0.0043
ND
ND
no
Aroclor 1254 (yg/I)
c)
0.7493
0.2145
0.014
53.52
15.32
Probable
Aroclor 1260 (uofl)
c)
0.01744
0.00495
0.014
1.25
0.35
Possible
4,4"—ODD 6ig/l)
c)
ND
ND
0.001
ND
ND
rio
4,4'—DDE (yg/l)
c)
ND
ND
0.001
ND
ND
no
4,4'—DDT (yg/l)
c)
ND
ND
0.001
ND
ND
rio
Dleldrln (uq/q oc)
b)
ND
ND
900
ND
ND
no
Endrin (yg/o oc)
b)
ND
ND
4.00
ND
ND
no
Endosulfan 1 (yg/l)
c)
0.0129
0.0129
0.056
0,23
0.23
no
Gamma-Chlordane (yg/l)
c)
ND
ND
0.0043
ND
ND
no
Heptachlor epoxide (yg/l)
c)
ND
ND
0.0038
ND
ND
no
Cadmium (mo/Kg)
a)
12.10
6.51
1.00
12.10
6.51
Probable
Copper (mg/Kg)
a)
76.20
30.38
100.00
0.76
0.30
no
Lead (mg/Kg)
a)
113.00
49.78
50.00
2.26
1.00
Probable
Mercury (mg/Kg)
a)
0.52
0.21
0.10
5.20
2.10
Probable
Nickel (mg/Kg)
a)
40.20
15.27
100.00
0.40
0.15
no
Zinc (mo/Ka)
a)
114.00
58.77
100.00
1.14
0.59
Possible
Cumulative risk
--
—
—
95.25
38.72
NOTES;
1. Benchmark toxicity values from Table 7-13
a) Secttment concentration
b) Sediment concentration per gram of organic carbon
c) Estimated interstitial water concentration / benchmark toxicity value for surface water concentration
goc - Grams of organic carbon
NA - Appropriate benchmark toxicity value not available; Kp value not available for the calculation of
Interstitial water concentrations (see Table 7-9),
ND - Not detected
-------
RISK ESTIMATES FOR SEDIMENT COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUNO SITE
SOU7HINQTON, CONNECTICUT
PAGE 5 OF 5
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Seasonal
Xylenes (uo/0
c)
ND
ND
5000.00
ND
ND
no
Ponds
Acerwphthen# (Uf3/Q oc)
ND
ND
140.00
ND
ND
rta
Acenaphthylerte (uo/g oc)
b)
ND
ND
140.00
ND
ND
no
Anthracene (uqIKq)
a)
ND
ND
85.00
ND
ND
no
Benzo(a)anthracene CMS/ Kg)
a)
150.00
150.00
230.00
0.65
0.65
no
Benzo(a)pyrene (ugfKa)
a)
154,00
154,00
400.00
0.39
0.39
no
Bis(2-ethylhexyt}phthaJate (ma/I]
c)
0.19
0.19
3.00
0.06
0.06
no
Butyl benzyl phthalate Ojq/I)
0.55
0,55
3.00
0.18
0.18
no
Chrysene (jig/Kg)
a)
175.00
118.50
400.00
0.44
0.30
no
Dlbenzofuran (pg/Kg)
a)
ND
NO
230,00
ND
ND
no
Di-n-butyl phthalate (yg/l)
c)
ND
ND
3.00
ND
ND
no i
01-n-octyl phthalate (wo/Kg)
a)
ND
ND
NA
ND
ND
no
Fluorene (mq/I)
c)
ND
ND
8.20
ND
ND
no
2-Methylnaphthalene Gifl/Kg)
a)
ND
ND
65.00
ND
ND
no
Naphthalene (yg/l)
c)
ND
ND
620.00
ND
ND
no
Phenanthrene (*ig/g oc)
b)
8.54
8.54
120.00
0.07
0.07
no
Aldrin fag/Kg)
a)
2.57
2.57
10.00
0.26
0.26
no
Alpha-Chiordane (yg/l>
c)
0.0046
0.0046
0.0043
1.07
1.07
Probable
Aroctor 1254 (yg/l)
C)
NO
ND
0.014
ND
ND
no
Aroctor 1260 (yg/l)
e]
0.00047
0.00047
0.014
0.03
0.03
no
4,4'—ODD (wo/ft
c)
NO
NO
0.001
ND
ND
no
4,4'—DDE (uo/l)
c)
ND
ND
0.001
ND
ND
no
4,4'-DDT 0/g/l)
c)
ND
ND
0,001
ND
ND
no
Dieldrin (mS/o oc)
b)
ND
ND
9.00
ND
ND
no
Endrin (hqIq oc)
b)
NO
ND
4.00
ND
ND
no
Endosulfan 1 tuo/l)
c)
ND
ND
0.056
ND
ND
no
Gamma-Chlordane iuaft)
c)
0.00462
0.00462
0.0043
1.07
1.07
Probable
Heptachtor epoxide (wo/I)
c)
ND
ND
0.0038
ND
ND
no
Cadmium (mo/Kq)
a)
10.25
5.33
1.00
10.25
5.33
Probable
Copper (mo/Kg)
a)
21.53
14.64
100,00
0.22
0.15
no
Lead (mo/Kg)
a)
56.38
44.04
50.00
1.13
0.88
Possible
Mercury (mq/Kq)
a)
041
0 28
0.10
4.10
2.80
Probable
Nickel (mg/Kg)
a)
4,45
3.42
100,00
0.04
0,03
no
Zinc f mq/Kq)
a)
67.60
43.89
100.00
0,68
0.44
no
Cumulative risk
20 64
13,72
NOTES:
t. Benchmark toxicity values from Table 7-13
a) Sediment concentration
b) Sediment concentration per gram at organic carbon
c) Estimated tntersiftial water concentration / benchmark toxicity value for surface water concentration
goc - drams of organic carbon
NA - Appropriate benchmark toxicity value riot available; Kp value not available for the calculation of
interstitial water concentrations (see Table 7-9).
ND - Not detected
-------
TABLE
RISK ESTIMATES FOR SOIL COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC, SUPERFUND SHE
SQUTHINGTON, CONNECTICUT
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Cianci
Benzene (m^Kq)
650.00
197.60
500.00
1,30
0.40
Possible
Property/
Xylenes (na/Ka)
760000.00
73739.11
5000.00
152.00
14.75
Probable
SRSNE
Acenaphfiylene (ya/Kg)
130.00
96.50
10000.00
0,01
0.01
no
FacMty
Anthracene jyaKo)
190.00
110.00
10000.00
0,02
0.01
no
Benrofalamhracene (yttfKo)
490.00
346.20
1000.00
0,49
0.35
no
Benzofalpyrene (wo'Ka)
740.00
355.54
1000.00
0,74
0.36
no
Ben£o(b)fluofanlftene {yoTCg)
1800.00
484.15
1000.00
1.80
0.48
Possible
BenzoOOftuoranthene (no'Kg)
1800.00
484.15
1000.00
1.80
0.48
Possible
Benzo(aMperylene (uafKg)
280.00
137.67
1000.00
0.28
0.14
no
Bte{2-eiftyt)exvf)ph#iaiat8 fya'Kg)
120000.00
13942.72
70000.00
1.71
0.20
Possible
Butyl benzyl phthalate big/Kg)
8600.00
1564.54
70000.00
0.12
0.02
no
Chrysstw WKg)
600 00
358.76
5000.00
0.12
0.07
no
Diethyl phthalats ftig/Kg)
1600.00
428.60
70000.00
0.02
0.01
no
Dl-n-butyl phthalats (y^Kg)
5700.00
1168.63
70000.00
0.08
0.02
no
Di-n-octyt phthalats M)
1450.00
489.33
70000.00
0.02
0.01
no
Fluorene (uafKo)
160.00
126.33
10000.00
0.02
0.01
no
Fkioranthene (mq/Kq)
1100.00
417.02
10000.00
0.11
0.04
no
Indenofl,2.3-cdlpyrene (ya'Ka)
3gQ
-------
RISK ESTIMATES FOR SOIL COCs
SOLVENTS RECOVERY SOT/ICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINOTON, CONNECTICUT
PAGE 2 OF 4
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Southing-
Benzene (yg/Kg)
NO
ND
50000
ND
ND
no
ton Well
Xylenes (yg/Kg)
NO
ND
5000.00
ND
ND
no
Field
Acenapttihyiene (uq/Ko)
ND
ND
10000.00
ND
ND
no
Anthracene (yg/Kg)
NO
ND
10000.00
ND
ND
no
ienzofaHanttiracane (yg/Kq)
Benzo(a)pyrene (yg/Kg)
BenzoMffcoraniwrie (yg/Kg)
BenzDOOfluoranthena (yo/Kol
ND
ND
SO.OO
50.00
NO
ND
SO.OO
50.00
1000.00
1000.00
1000.00
1000.00
ND
ND
0.05
0.05
ND
ND
0.05
0.05
no
no
no
no
Benaj(g,h,Opervtene (yo/Kgj
ND
ND
1000.00
ND
ND
no
Bis(2-etfiylhexyi)phtnaiat8 (yftfKg)
BuM benzyl phthaiaie (yg/Kg)
ND
ND
ND
ND
70000.00
70000.00
ND
ND
ND
ND
no
no
Chrysene {ua'Kg)
ND
ND
5000.00
ND
ND
no
Diethyl pftthaiate (yg/Kg)
ND
ND
70000.00
ND
ND
no
Di-n-Duivi pnmaJate Iuq/Kq)
ND
ND
70000,00
ND
ND
no
Dl-n-octyl phthalata (uq/Kq)
ND
ND
70000.00
ND
ND
no
Fluorene (wo'Kq)
ND
ND
10000.00
ND
ND
no
Fboranthene (yg/Kg)
53.00
48.00
10000.00
0.0053
0.0048
no
lndeno(1,2,3-cd)pwene (yg/Kq)
2-Mettiylnaptiihaiene (yg/Kp)
Naphtfiatow (yg/Kg)
ND
ND
ND
ND
ND
ND
1000.00
5000.00
5000.00
ND
ND
ND
ND
NO
ND
no
no
no
Pherianthrens (yo'Ka)
ND
ND
5000.00
ND
ND
no
1,2,4-T rtchlorobenzene (yg/Kg)
ND
ND
1000.00
ND
ND
no
Aroctor 1016 (yg/Kg)
ND
ND
1000.00
ND
ND
no
Arocior 1248 (MoKg)
27.00
20.25
1000.00
0.03
0.02
no
Arocior 1254 (yaiKg)
56.00
23,63
1000,00
0,06
0.02
no
Arocior 1260 (yg/Kg)
41.00
22,13
1000.00
0,04
002
no
4,4'—DDE (yg/Kg)
27.00
490
500.00
0.05
0.01
no
4,4'-DDT (yg/Kg)
28.00
4.87
500.00
0.06
0.01
no
Dieldrin (yg/Kg)
2.20
1.60
500,00
0,0044
0 0032
no
Endrin (yg/Kg)
0.43
0,35
500.00
0.0009
0.0007
no
Endosuifan II (yg/Kg)
1.80
1.27
500.00
0.0036
0.0025
no
Qamma-BHC {lindane, wo/Kg)
1.10
1.03
500.00
0.0022
0.0021
no
Gamma-Chlordane (jug/Kg)
ND
ND
500,00
ND
ND
no
Heptachlor epoxide (yg/Kg)
ND
ND
500.00
ND
ND
no
Methoocvchlor (yg/Kg)
20,00
10.19
500.00
0.04
0.02
no
Downs (Toxicity Equivalent Gone, yg/Kg)
NA
NA
030
NA
NA
no
Cadmium (mo/Kg)
1.70
0.51
5.00
0.34
0,10
no
Copper (mo/Kg)
13.70
9.51
100.00
0.14
0.10
no
Lead (ma/Ka)
32.00
16.73
200.00
0.16
0.08
no
Mercury (mg/Kg)
1.20
0.27
2.00
0.60
0.14
no
Selenium (ma/Ka)
ND
ND
300
ND
ND
no
I
Cumulative risk
—
—
—
1.63
0.64
NOTES:
1. Benchmaric toxicity values from TaWe 7-13
NA - Not analyzed
ND-Not delected
-------
RISK ESTIMATES FOR SOIL. COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUNO SITE
SOUTWNGTON, CONNECTICUT
PAGE 3 OF 4
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
6£nCh-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE
EFFECTS
Upstope
Benzene (u&Kq)
ND
ND
500.00
ND
ND
no
Area
Xylenes (yfl/Ka)
NO
ND
5000.00
ND
ND
no
Acenapfrtiyteoe ftiofKsfl
71.50
71 50
10000.00
0.01
0.01
no
Anthracene tejKa)
117.00
117,00
10000.00
0.01
0.01
no
Benzo(a)anthrac®ne (yg/Kg)
180.00
180.00
1000.00
0.18
0.18
no
BenzD(a)pyrane (MQ/Kg)
180.00
180.00
1000.00
0.18
0.18
no
Benzo(b)fluofarrthene Cug/Kg)
140.00
111.00
1000.00
0.14
0.11
no
Benzo(k)ftuoran thane (yatCg)
120.00
101.00
1000.00
0.12
0.10
no
Banzofa.h.ftpervtene fcjgfl
-------
RISK ESTIMATES FOR SOIL COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC SUPERFUND SfTE
SOLTTHINGTON, CONNECTICUT
PAGE 4 OF 4
SECTOR
COCs
MAXIMUM
CONCEN-
TRATION
MEAN
CONCEN-
TRATION
BENCH-
MARK'
MAXIMUM
RISK
MEAN
RISK
ADVERSE)
EFFECTS I
I
Queen
Benzene (no/Kg)
ND
ND
500.00
ND
NO
no
Street
Xylenes (uoiKa)
ND
ND
5000.00
ND
NO
no I
Acsnaphtftytene (aa'Kg)
ND
ND
10000.00
ND
ND
no 1
Anthracene (yofKo)
320.00
232.50
10000.00
0.03
0.02
no
Benzo(a)anthracene fao/Kg)
380.00
208.75
1000.00
0.38
0.21
no
Benzo(a)mrane (mo/Kb)
55,00
55.00
1000.00
0.06
006
no
BenzD(b)fiuoranthene (wo/Kg)
810.00
333,75
1000,00
0.81
0.33
no
Benzo(k)fluoran there ft/g/Kg]
1000.00
371.63
1000.00
1.00
0.37
Possible
8enzD(q,h.0peivlene ttio/Kal
340,00
237.50
1000.00
0.34
0.24
no
Bis(2-etnyihe*yOPhthalate tug/Kg)
NO
ND
70000.00
NO
ND
no
Butyl benzyl ctithalate (yg/Kg)
ND
ND
70000.00
ND
ND
no
Chrysene tetfKg)
390.00
186,50
5000.00
0.08
0.04
no |
Diethyl phthaJate (ya'Ko)
ND
ND
70000.00
ND
ND
no |
Dl-n-butyl prtfwuaJ® (uq/Kq)
ND
NO
70000.00
ND
ND
no
Dl-n-octyl pftihalais (ya/Ka)
ND
ND
70000.00
ND
ND
no
Fluorene (uq/Kq)
ND
ND
10000.00
ND
ND
no
Fluoranthene MKQ)
740.00
296,25
10000.00
0.07
0.03
no
lndeno( 1,2,3-cd)pyrene kg/Kg)
360.00
242.50
1000.00
0.36
0.24
no
2-Melhylnaphthatene (wo'Kg)
ND
ND
5000.00
ND
ND
no
Naphthalene Ujq/Kq)
ND
ND
5000.00
ND
ND
no
Phenamhiene fcjQ/KQ)
300.00
152.75
5000.00
0.06
0.03
no
1,2,4—Tridilorobenzene tua/Ka)
ND
ND
1000.00
ND
ND
no
Arocior 1016 (MS^Kg)
ND
ND
1000,00
ND
ND
no
Aroctar 1248 fag/Kg)
ND
ND
1000.00
ND
ND
no
Aroctor 1254 Oj^Kq)
9.00
9.40
1000.00
0.01
0.01
no
Aroclor 1260 tug/Kg)
ND
ND
1000.00
ND
ND
no
4,4*-ODE (wo/Kg)
1.65
1.21
500.00
0.0033
0.0024
no
4,4-DDT (ua/Ka)
5.35
2.22
500.00
0.0107
0.0044
no
Dieldhn fcig/Kg)
2.00
1.69
500.00
0.0040
0.0034
no
Endrin fcig/Kfl)
ND
ND
500,00
ND
ND
no
Endosulfan tl (pg/Kg)
0.73
0.50
500.00
0.0015
0.0010
no
Qamma-BHC (lindane, tig/Kg)
ND
ND
500.00
NO
ND
no
Gamrna-Chlordane (uq/Kq)
ND
ND
500.00
NO
ND
no
Heptachlor epoxide (no/Kg)
0.16
0.16
500.00
0.0003
0.0003
no
Methoxycftlor (tig/Kg)
6.90
6.90
500.00
0.01
0.01
no
Dkwins (Toxicity Equivalent Cone, ua/Ka)
NA
NA
0.30
NA
NA
no
Cadmium (mg/Kg)
NO
ND
5.00
ND
ND
no
Copper (mo/Kg)
13.40
9.34
100.00
0.13
0.09
no
Lead (m^Kg)
30.80
25.19
200.00
0.15
0.13
no
Mercury (m^Kg)
0,12
0,07
2.00
0.06
0.04
no
Selenium (rna/Kal
ND
ND
3.00
ND
NO
no
Cumulative risk
—
—
—
3.58
1.86
HHI
NOTES:
1 Benchmark values from Table 7-13
NA- Not analyzed
ND - Not delected
-------
TABLE Gr - I S
BENCHMARK TOXICITY VALUES FOR ECOLOGICAL COCs1
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC, SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
Chemical
¦ — --
| Benchmark/Environmental Media [
VOLATILE ORGANIC COMPOUNDS
Surface
Water
Sediment2
Soil
Benzene
500 (ig/kg'"
Xylenes (total)
5,000 M/l"1
5,000 jig/t^
5,000 M/kg™
SEMIVOLATILE ORGANIC COMPOUNDS
Acenaphthene
HO *9/S«"
AcenaphthyIerse
140 m/sjm
10,000 #g/kga'
Anthracene
85 ng/kg'71
10,000 #g/kg®
Bento C a J ant h racene
230 M/k8<7'
1,000 jig/kg151
Benzo(a)pyrene
400 HS/k$m
1,000 jig/kg13'
' BemoCWf luoranthene
1,000 M/kg°'
Benzo(k)f I uorarithene
1,000 us/kg'31
Benio(g,h ri)perylene
1,000 M/kg®'
Bi$(2-ethylhexyl)phrhalate
3 MB/l'"
3 fig/l""
70,000 (tg/kg181
Butyl benzyl phthalate
3 ml l
70,000 jtg/kgao'
Chryeene
400 pg/kg'7!
5,000 ng/kg,nl
Dibenzofuran
230 ng/ks"21
Otethyt phthalate
70 , 000 (ig/kg"01
Oi-n-butyl phthalate
3 jig/l'"'
70,000 »g/kg"0'
Di -rvoctyl phthalate
3 rnnm
70,000 iig/kg"01
Fluorene
8.2 M/l1"1
10,000 (tg/kgai
(F luoranthene
10,000 (ig/kg'31
Indeno{1,2,3-cd)pyrene
1,000 (tg/kg®
2-Hethylnaphthalene
65 #g/kgm
5,000 jig/kg"41
Naphthalene
620 wlVm
5,000 (ig/ka™
Phenarithrene
120 »9/gJ1*
5,000 #9/kgw
1,2,4 -T r f eh I orobemene
1,000 ng/kg""
-------
benchmark toxicity values for ECOLOGICAL COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
PAGE 2 Of 4
Chemical
Benchmark
c/Environmental Media J
PESTICIDBS/POLYCHLORINATED
BIFHEHYLS
-------
(continued)
BENCHMARK TOXICITY VALUES FOR ECOLOGICAL COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
PAGE 3 Of 4
Footnotes
CAWQC chronic Ambient Water Quality Criteria.
SQC Sediment Quality Criteria.
gx Grams of organic carbon.
1 - Benchmark toxicity values are presented only for the contaminants that were
selected as COCs in each environmental media, as presented on Table 7-6.
2 - Depending on the availability of appropriate benchmarks in the literature, the
benchmark values selected for sediment COCs represent either benchmarks for
surface water concentrations
-------
(continued)
BENCHMARK TOXICITY VALUES FOR ECOLOGICAL COCs
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. SUPERFUND SITE
SOUTHINGTON, CONNECTICUT
PAGE 4 Of 4
Footnotes
12 - No CAWQC, SQC or toxicity data available for this polynuclear aromatic
hydrocarbon (PAH), The ER-L value for benzo(a)anthracene (Long and Morgan,
1991} was used because its value is intermediate in the range of ER-L values
for the PAHs considered as COCs at SRSNE.
13 - No CAWQC or SQC available. Benchmark value estimated by acute LCW/100, based
on the assumption that an acute LCM for a sensitive species divided by 100
provides a reasonable and adequate level of protection for other sensitive
species under chronic exposure conditions. An LCM {96 hours) of 820 jjg/1 has
been reported for fluorene in rainbow trout (Eisler, 1987a).
14 - The "soil contamination indicator value" for naphthalene (Richardson, 1987) was
used based on the affinity in chemical structure.
15 - CAWQC (U.S. EPA, 1986).
16 - Proposed SQC for phenanthrene (U.S. EPA, 1991c).
17 - Wisconsin's interim criteria for sediments from Great Lakes harbors for
disposal in water (WDNR, 1985).
18 - CAWQC (U.S. EPA, 1991f).
19 - No CAWQC available; the CAWQC for 4,4'DDT (U.S. EPA, 1991f) was used based on
the affinity in chemical structure.
20 - Proposed SQC for dieldrin (U.S. EPA, 1991d).
21 - Proposed SQC for endrin (U.S. EPA, 1991e).
22 - Concentration of dioxin not to be exceeded in soil according to the Missouri
Department of Natural Resources (MDNR, 1988).
* - CAWQC adjusted to a total hardness of 71.353 mg equivalent CaCO,/l, following
the procedure presented by U.S. EPA (1991f). The total hardness value was
calculated based on site-average surface water concentrations for calcium and
magnesium, using the formula presented by Clesceri at ml. (1989):
Hardness (mg equivalent CaCOj/1) = 2.497 (Ca, mg/1) + 4.118 (Mg, mg/1)
-------
TABLE L-1
INTERIM CLEANUP LEVELS FOR GROUNDWATER '
Interim Cleanup
Basis of Interim
Chemical Name
Units
Level1
Cleanup Level
1,1,1-T richloroethane
ug/l
0.5
CT RSR
1,1,1,2-T etrachloroethane
ug/l
0.5
CT RSR
1.1,2-Trichloroethane
ug/J
0.5
CT RSR
1,1-Dichloroethane
ug/l
0.5
CT RSR
1,1-Dichloroethene
ug/l
0.5
CT RSR
1,2-Dibromo-3-chloropropane
ug/l
0.05
CT RSR
1,2-Dichlorobenzene
ug/l
0.5
CT RSR
1,2-Dichloroethane
ug/l
0.5
CT RSR
1,4-Dichlorobenzerie
ug/i
0.5
CT RSR
2-Butanone
ug/l
5
CT RSR
2-Hexanone
ug/l
5
CT RSR
4-Methyl-2-pentanone
ug/l
5
CT RSR
Acetone
ug/l
5
CT RSR
Benzene
ug/l
0.5
CT RSR
Bromomethane
ug/l
0.5
CT RSR
Carbon Disulfide
ug/l
0.5
CT RSR
Carbon tetrachloride
ug/l
0.5
CT RSR
Chlorobenzene
ug/l
0.5
CT RSR
Chloroethane
ug/l
0.5
CT RSR
Chloroform
ug/l
0,5
CT RSR
Chloromethane
ug/l
0.5
CT RSR
cis-1,2-Dichloroethene
ug/l
0.5
CT RSR
Ethylbenzene
ug/l
0.5
CT RSR
Methylene chloride
ug/l
0.5
CT RSR
Styrene
ug/l
0.5
CT RSR
Tetrachloroethene
ug/l
0.5
CT RSR
Tetrahydrofuran
ug/l
0.5
CT RSR
Toluene
ug/l
0.5
CT RSR
trans-1,2-Dichloroethene
ug/l
0.5
CT RSR
trans-1,3-Dichloropropene
ug/l
0.5
CT RSR
Trichloroethene
ug/l
0.5
CT RSR
Vinyl chloride
ug/l
0.5
CT RSR
Xylenes
ug/l
0.5
CT RSR
1,2,4-Trichlorobenzene
ug/t
2
CT RSR
2,4-Dimethylphenol
ug/l
10
CT RSR
2-Methylphenol
ug/l
10
CT RSR
4-Methylphenol
ug/l
10
CT RSR
Benzoic Acid
ug/l
10
CT RSR
bis(2-Ethylhexyl)phthalate
ug/l
10
CT RSR
Di-n-butyl phthalate
ug/l
10
CT RSR
Di-n-octyl phthalate
ug/l
10
CT RSR
Hexaehlorobutadiene
ug/l
0.45 2
CT RSR
Isophorone
ug/l
10
CT RSR
Napthalene
ug/l
0.5 3
CT RSR
Phenol
ug/l
10
CT RSR
Aroclor-1254
ug/l
0.5
CT RSR
Aroclor-1260
ug/l
0.5
CT RSR
Page 1 of 2
-------
TABLE L-1
INTERIM CLEANUP LEVELS FOR GROUNDWATER 1
Interim Cleanup
Basis of Interim
Chemical Name
Units
Level1
Cleanup Level
Aluminum
ug/l
(1)
CT RSR
Antimony
ug/l
(D
CT RSR
Arsenic
ug/l
(1)
CT RSR
Barium
ug/l
(1)
CT RSR
Beryllium
ug/l
(1}
CT RSR
Cadmium
ug/l
(D
CT RSR
Chromium (Total)
ug/l
(1)
CT RSR
Cobalt
ug/l
(D
CT RSR
Copper
ug/l
(D
CT RSR
Iron
ug/l
(1)
CT RSR
Lead
ug/l
(1!
CT RSR
Manganese
ug/l
(1)
CT RSR
Nickel
ug/l
(1!
CT RSR
Silver
ug/l
(1)
CT RSR
Thallium
ug/l
(1)
CT RSR
Vanadium
ug/l
(1)
CT RSR
Zinc
ug/l
IV
CT RSR
4,4'-DDD
ug/l
0.1
CT RSR
Aldrin
ug/l
0.05
CT RSR
Ethanol
ug/l
1000
CT RSR
Isopropanol
ug/l
1000
CT RSR
Methanol
ug/l
1000
CT RSR
Sec-Butanol
ug/i
1000
CT RSR
Notes:
1. CT Remediation Standards Regulation requires that "Remediation of groundwater in a GA area shall result in reduction
of each substance therein to a concentration equal to or less than the background concentration for groundwater of such
substance...." (RCSA 22a-133k-3(a)(2). Where background concentrations are reported as non-detects, the analytical
detection level as defined in the CT RSRs shall be the remedial goal. Background levels for metals will be established
based on future field sampling and laboratory analyses.
2. A special request to the laboratory is needed to provide an analytical detection limit of 0.45 ug/l for
hexachlorobutadiene.
3. The analytical detection limit for napthalene is 0,5 ug/l via EPA Test Method 8260.
Page 2 of 2
-------
TABLE 1-2
SOIL AND WETLAND SOIL CLEANUP LEVELS FOR THE PROTECTION OF HUMAN HEALTH AND THE AQUIFER1
Connecticut
Residential
Connecticut GA,
GAA Pollutant
Soil Cleanup
Non-
Carcinogenic
Direct Exposure
Mobility Criteria
Level
Basis of Cleanup
Carcinogenic
Hazard
Non-cancer Target
Chemical Name
Criteria (mg/kg)
(mg/kg)2
(mg/kg)1
Level
Risk3
Quotient3
Endpoint
1,1,1-Trichlorethane
500
4
4
CT RSR
-
NA
-
1,1,2,2-T etrachloroethane
3,1
0.01
0.01
CTRSR
2.E-08
1 .E-05
liver
1.1 2-Trichloroethane
11
0.1
0.1
CT RSR
1 .E-G7
3.E-03
blood
1,1-Dichloroethane
500
1,4
1.4
CTRSR
-
3.E-03
kidney
1,1-Diehloroefhene
1
0.14
0.14
CT RSR
-
1.E-03
liver
1,2-Dichloroethene, Total
500
1.4
1.4
CTRSR
-
3.E-02
blood
1,2-Dichloropropane
9
0.1
0.1
CTRSR
3.E-07
NA
-
2-Butanone
500
8
8
CTRSR
-
4.E-03
fetal weight
4-Melhyl-2-pentanone
500
7
7
CTRSR
-
1.E-03
liver/ kidney
Acetone
500
14
14
CT RSR
-
1.E-03
kidney
Benzene
21
0.02
0.02
CT RSR
3.E-08
1.E-03
blood
Carbon tetrachloride
4.7
0.1
0.1
CTRSR
4.E-07
5.E-02
liver
Chlorobenzene
500
2
2
CT RSR
-
1 E-02
liver
Chlorodibromomethane
7.3
0,01
0.01
CT RSR
9.E-09
3.E-04
liver
Chloroform
100
0.12
0,12
CT RSR
6.E-07
2.E-03
liver
Ethylbenzene
500
10.1
10,1
CTRSR
-
5.E-03
liver
Methylene chloride
82
0.1
0.1
CTRSR
1 .E-08
5. E-05
liver
Styrene
500
2
2
CTRSR
-
5.E-04
blood/ immune
Tetrachloroethene
12
0.1
0.1
CT RSR
2.E-07
3.E-03
liver
Toluene
500
20
20
CTRSR
-
3. E-02
liver/kidney
Trichloroethene
56
0.1
0.1
CT RSR
2.E-06
6.E-03
liver/ kidney/
developmental
Vinyl chloride
0.32
0.04
0.04
CTRSR
5.E-07
1.E-03
liver
Xylenes, Total
500
19.5
19,5
CT RSR
-
7. E-02
body weight
2-Methylnapthalene
474
0.98
0.98
CTRSR
NA
NA
-
4-Chloroaniline
270
1
1
CT RSR
-
4.E-03
spleen
4-Mathylphenol
340
0.7
0.7
CT RSR
-
2.E-03
nervous system
Benzo(a)anthracene
1
1
1
CTRSR
2.E-06
-
-
Benzo(a)pyrene
1
1
1
CTRSR
2.E-05
-
-
Benzo(b)fluoranthene
1
1
1
CT RSR
2.E-06
-
-
Benzo(k)fluoranthene
8,4
1
1
CT RSR
2.E-07
-
-
bis(2-Ethylhexyl)phthalate
44
1
1
CT RSR
3.E-08
1.E-03
liver
Chrysene
84
1
1
CTRSR
2.E-08
-
-
Dibenzofurari
270
1
1
CTRSR
-
7.E-03
kidney
Di-n-butyl phthalate
1000
14
14
CTRSR
-
2.E-03
mortality
Di-n-octyl phthalate
1000
2
2
CT RSR
-
8.E-04
liver/thyroid
Page 1 of 3
-------
TABLE L-2
SOIL AND WETLAND SOIL CLEANUP LEVELS FOR THE PROTECTION OF HUMAN HEALTH AND THE AQUIFER1
Chemical Name
Connecticut
Residential
Direct Exposure
Criteria (mg/kg)
Connecticut GA,
GAA Pollutant
Mobility Criteria
(mg/kg) 2
Soil Cleanup
Level
(mg/kg)1
Basis of Cleanup
Level
Carcinogenic
Risk 3
Non-
Carcinogenic
Hazard
Quotient 3
Non-cancer Target
Endpoint
Fluoranthene
1000
5.6
5.6
CTRSR
-
2.E-03
liver
lndeno(1,2,3-cd)pyrene
1
1
1
CTRSR
2.E-06
-
-
Pherianthrene
1000
4
4
CT RSR
NA
NA
-
Pyrene
1000
4
4
CT RSR
-
2.E-03
kidney
2,3,7,8 TCDD -TEQ
NA4
NA4
tower of
0.001 mg/kg or
background 4
EPA Policy"/
background
To be
determined
PCBs Total
1
0,0005 mg/l2
1 mg/kg and
0.0005 mg/l2
CT RSR
5.E-06
9.E-01
immune
Antimony
27
0.006 mg/l2
27 mg/kg and
0.006 mg/l 2
CTRSR
9.E-01
mortality/ blood
Arsenic
10
0.05 mg/l2
10 mg/kg and
0.05 mg/l2
CTRSR
3.E-05
5.E-01
skin
Barium
4700
1 mg/l 2
4700 mg/kg and
1 mg/l2
CTRSR
9.E-01
kidney
Beryllium
2
0.004 mg/l2
2 mg/kg and
0,004 mg/l2
CTRSR
1.E-09
1.E-02
small intestine
Cadmium
34
0.005 mg/l2
34 mg/kg and
0.005 mg/l 2
CT RSR
2.E-08
9.E-01
kidney
Chromium*3
3900
0.05 mg/l 2's
3900 mg/kg and
0.05 mg/l"
CT RSR
.
3.E-02
none
Chromium'6
100
0.05 mg/l2,5
100 mg/kg and
0.05 mg/l 2,s
CT RSR
3.E-06
5.E-01
none
Lead
500
0.015 mg/l2
400 mg/kg 6 arid
0.015 mg/l 2
EPA Policy a/ CT RSR
NA
NA6
nervous system
Total Cancer Risk7 =
7.E-05
Cumulative HI by Target Endpoint
kidney
2.E+00
immune
9.E-01
mortality
9.E-01
skin
5.E-01
other
endpoints
HI below 1
Page 2 of 3
-------
TABLE L-2
SOIL AND WETLAND SOIL CLEANUP LEVELS FOR THE PROTECTION OF HUMAN HEALTH AND THE AQUIFER1
Notes;
NA = Not Available or Not Applicable
1. Soil Cleanup levels are the more stringent of the Connecticut Residential Direct Exposure Criteria (RDEC) or Pollutant Mobility Criteria
{PMC) for those depths of soil where both RDEC arid PMC apply, and where both RDEC and PMC are expressed in mass concentrations (e.g.
mg/kg). Cleanup levels for those substances where PMC are leachate concentrations (see footnote 3), both RDEC and PMC apply except for
lead where the cleanup level is based on EPA policy (see footnote 7} and the CT PMC for lead. Cleanup levels may revert to background
concentrations if adequate documentation is provided.
2. For inorganics and PCBs, the Pollutant Mobility Criteria are based on leachate concentrations (expressed in mg/l) as obtained via either
the SPLP or TCLP leaching procedures.
3. Cancer risk and non-cancer hazard are based on residential exposure and assume exposure parameters consistent with EPA Region 9
Preliminary Remediation Goals which reflect ingestion, dermal contact, and inhalation of the soil medium. Values for PCBs and inorganics
reflect risk or hazard for cleanup levels expressed as a soil concentration (mg/kg).
4. There are no CT residential DEC or PMC for 2,3,7,8 TCDD-TEQ (Dioxin) in the CT RSRs. EPA and CT DEP have agreed that the cleanup
level for 2,3,7,8-TCDD TEQ will be the lower of the EPA policy for residential sites (0.001 mg/kg per OSWER Directive # 9200.4-26 April 1998)
and the background concentration which wiil be determined based on future field study, or another concentration consistent with CT RSRs, but
not lower than background.
5. The PMC based cleanup levels for chromium (both trivalent and hexavalent) are based on a total chromium concentration.
6. The value of 400 mg/kg lead protects 95% of the exposed population from blood lead levels in excess of 10 ug/dl consistent with EPA's
policy for lead (OSWER Directive #9355.4-12 July 14,1994).
7. The total cancer risk does not include the risk attributed to 2,3,7,8 TCDD-TEQs as the cleanup level will be determined during remedial
design.
Page 3 of 3
-------
Table L"3 DRAFT
SRSNE Superfund Site
Feasibility Study
Operations Area and Railroad Remedial Alternatives Cost Estimate
Alternative OAR-2: Capping and Access Control
III IHMIIIIWHI'll'iWIiitill Hi I'.HI'i! ' V-'
A, Initial Capital Costs
1
Institutional Controls
100
man hours
$250
$25,000
2
Mobilization/Demobilization
1
LS
$20,000
$20,000
3
Site Preparation/Erosion Control Measures
1
LS
$20,000
$20,000
4
Clean Fill, including backfill and compaction
500
CY
$30
$15,000
5
Granular Subbase (Operations Area)
2,300
SY
£14
$32,200
6
Subbase Leveling
2,300
SY
$14
$32,200
7
Non-woven Geotextile
10,100
SY
$3
$30,300
8
HDPE Geomembrane
10,100
SY
$12
$121,200
9
Granular Cushion Layer
2,300
SY
$14
$32,200
10
Asphalt Cap
10,100
SY
$11
$111,100
11
Restoration/Revegetation of Access Areas
1
LS
$10,000
$10,000
13
Well abandon/conversion
10
Well
$500
$5,000
14
RR Grade Remediation (cap)
14a
Clean Fill, Backfill & Compaction
1,000
CY
$30
$30,000
14b
Rough Grading
2,950
SY
$0.98
$2,891
14c
Non-woven Geotextile
2,950
SY
$5
$14,750
14d
HDPE Geomembrane
2,950
SY
$12
$35,400
14e
Asphalt Cap
2,950
SY
$11
532,450
Initial Capital Cost Subtotal:
$569,691
Rounded To:
$570,000
4/6/2005
Page 1 of 3
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Operations Area and Railroad Remedial Alternatives Cost Estimate
Alternative OAR-2: Capping and Access Control
B. Recurring Capital Costs
No Recurring Capital Costs
$0
C. Annual Operation and Maintenance Costs (30 year Present Worth)
1
Inspection & MainL of cover
150
man hours
$75
$11,250
2
Verification of Institutional Controls
20
man hours
$115
$2,300
3 Annual Report
20
man hours
$115
$2,300
Annual O&M Cost Subtotal;
$13,550
Total Annual O&M Cost;
$10,000
Present Worth Factor (30-year, 7%);
12.41
Total Present Worth of Annual O&M Cost (rounded):
$120,000
$690,000
Aggregate Present Worth of Total Cost:
Remedial Design (15%)
$103,500
Project Administration/Management Cost (8%)
$55,200
Construction Management (10%)
$69,000
Scope Contingency (10%)
$69,000
Bid or Construction Contingency (10%):
$69,000
Subtotal
$1,055,700
Rounded To;
$1,060,000
4/6/2005
Page 2 of3
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Operations Area and Railroad Remedial Alternatives Cost Estimate
Alternative OAR-2: Capping and Access Control
Notes:
1. Institutional controls includes implementing a ELUR to limit future usage of the Site and prevent disturbance of
the cap.
2. Mobilization/demobilization includes site preparation and staging/handling area for equipment and materials.
3. Costs include materials and installation and are based on past project experience, published references and
vendor estimates. Costs do not include costs associated with sales tax, bonding, financial costs insurance, etc.
4. Clean fill, including backfill and compaction, is assumed necessary to regrade the railroad grade for proper
surface runoff to the relocated drainage culvert (along Lazy Lane).
5. Subbase leveling assumes that approximately 25% of the Operations Area (particularly area surrounding
concrete pads) will need to be filled with gravel subbase material prior to liner installation.
6. Geotextile Liner will be Type 2, Non-Woven (16 oz/sq.yd).
7. Geomembrane will be 40 mil HDPE.
8. Granular Subbase will be 8" thick.
9. Asphalt cap will consist of a 2-1/2" bituminous concrete base course with a 1-1/2" bituminous concrete wearing
surface.
10. Contingency includes unforeseen legal and administrative fees.
11. LS-lump sum.
12. Costs rounded to the nearest $ 10,000.
13. Inspection and maintenance of the asphalt cap includes cost for surface sealing
4/6/2005
Page 3 of 3
-------
Table L, -
SRSNE Superfund Site
Feasibility Study
DRAFT
Cianci Property Remedial Alternatives
Alternative CP-2 - Culvert Removal and Excavation with On-Site Disposal
'¦* Dcrijriprion *-a~ LvSl^l^aiBiitity ! I ». I
A. Initial Capital Costs
1
Mobilization/Demobilization
1
LS
$10,000
$10,000
2
Access Area Development
1
LS
$20,000
$20,000
3
Site Preparation/Erosion Control Measures
I
LS
$5,000
$5,000
4
Pipe Removal/Drainage Swale Construction
4a
Flowable Fill (RR Culvert)
6
CY
$50
$275
4b
Pipe Excavation
300
LF
$15
$4,500
4c
Soil Removal
20
CY
$12
$240
4d
General Backfill
150
CY
$30
$4,500
4e
Pipe Installation Underneath RR Tracks
30
LF
$100
$3,000
4fl
Drainage Swale Excavation
293
CY
$12
$3,516
5
Culvert Outfall Remediation
5a
Sediment Excavation
500
CY
$12
$6,000
5b
Stabilization Agent
167
TN
$60
$10,020
5c
Material Handling
500
CY
$6
$3,000
5d
Special Fill
278
CY
$20
$5,560
5e
On-site Disposal
500
CY
$10
$5,000
5f
Replacement Culvert Installation (36" HDPE)
350
LF
$75
$26,250
6
Cianci Property Soils
6a
Soil Excavation
400
CY
$12
$4,800
6b
General Backfill
400
CY
$15
$6,000
6c
On-site Disposal
400
CY
$10
$4,000
1
Restoration/Revegetation of Access Areas
1
LS
$15,000
$15,000
%
Revegetation of Excavated Areas
1
LS
$25,000
$25,000
Initial Capital Cost Subtotal;
$161,661
Rounded To:
$160,000
4/6/2005
Page 1 of 3
-------
SRSNE Superfund Site
Feasibility Study
DRAFT
Cianci Property Remedial Alternatives
Alternative CP-2 - Culvert Removal and Excavation with On-Site Disposal
tlnH" ¦ ItateOM 1"•••«-&» •¦
B. Recurring Capital Costs
No Recurring Capital Costs $0
C. Annual Operation and Maintenance Costs (30 year Present Worth )
I
No O&M Costs 1 LS $0
$0
Annual G&M Cost Subtotal:
$0
Total Annual O&M Cost:
$0
Present Worth Factor (30-year, 7%):
12.41
Present Worth of Annual O&M Cost:
$0
Aggregate Present Worth of Total Cost:
$180,000
Remedial Design (15%)
$27,000
Project Administration/Management Cost (8%)
$14,400
Construction Management (10%)
$18,000
Scope Contingency (25%)
$45,000
Bid or Construction Contingency (15%):
$27,000
Subtotal
$311,400
Rounded To:
$310,000
4/6/2005
Page 2 of 3
-------
SRSNE Superfund Site
Feasibility Study
DRAFT
Cianci Property Remedial Alternatives
Alternative CP-2 - Culvert Removal and Excavation with Cn-Site Disposal
Notes:
1. Remedial design includes engineering of replacement pipe to handle additional run-off from capped area
2 Mobilization/demobilization is taken as a lump sum based on project size.
3. Access area development includes clearing and preparation of an equipment staging/handling area and the
construction of temporary gravel access roads,
4. Site preparation/erosion control costs include the installation and maintenance of silt fences and/or straw bales
around the perimeter of the site, and the installation of silt containment systems downstream of active
remediation areas.
5. Pipe removal and drainage swale construction costs include: (a) excavation of the existing 30" diameter
drainage pipe, plugging of RR culvert; (b) the installation of a new section of 30" pipe to transmit storm water
underneath the existing railroad tracks.
6. Culvert outfall remediation costs are based on the removal of the top foot of sediment over a 140 by 100 foot
area centered around sediment sample SD3-36. Costs assume materials would be handled and stabilized to pass
the paint filter test for disposal. Approximately 6 inches of special fill material, indicative of wetlands soils,
would be placed over the excavated area prior to restoration.
7. Excavation of Cianci soils assumes the removal of soil in 4 isolated areas to a depth of one foot (and to a depth
of 2 ft at SB-905). Following excavation, clean fill materials will be placed to match the existing grade.
8. Restoration and revegetation of access areas includes removal and disposal of gravel, replacement of excavated
stockpiled fill, followed by topsoil and vegetation.
9. Revegetation of excavated areas includes hydro seeding, and the placement of revegetation matting (i.e., jute
mat) at the culvert outfall, the drainage ditch, and in the newly constructed drainage swale.
4/6/2005
Page 3 of 3
-------
Table L- §
SRSNE Superfund Site
Feasibility Study
DRAFT
Overburden NAPL Area Remedial Alternatives Cost Estimate
Alternative ONOGU-S: Thermal Treatment and MNA
•WR.
i
' UuitCosf"^
A. Initial Capital Costs
I
1
Thermal Treatment Design and Construction
la
PreMobilization and Procurement
I
LS
$350,000
$350,000
$350,000
$350,000
lb
Mobilization
900
man hours
$75
$67,500
$67,500
$67,500
lc
Install Well Field and Electrodes
1
LS
$ 2,500,000
$2,500,000
$2,500,000
$2,500,000
Id
Construct Cover
1
LS
$500,000
$500,000
$500,000
$500,000
le
Piping and Electrical
1
LS
$450,000
$450,000
$450,000
$450,000
If
Utility Installation
1
LS
$80,000
$80,000
$80,000
$80,000
If
Treatment System (Vapor & Condensate)
1
LS
$1,300,000
$1,300,000
$1,300,000
$1,800,000
lh
Condensate Pumping and Separation
1
LS
$162,000
$162,000
$162,000
$162,000
li
Final Post-Installation Modifications
1
LS
$45,000
$45,000
$45,000
$45,000
lj
Decommission cap and equipment
1
LS
$390,000
$390,000
$390,000
$390,000
Ik
Site Clearance & demobilization
1
LS
$69,000
$69,000
$69,000
569,000
11
Contractor Internal Management/Coordination
1
LS
$200,000
$200,000
$200,000
$200,000
Ira
Pre- and Post-Treatment Sampling and Analysis
1
LS
$250,000
$250,000
$250,000
$250,000
In
Perimeter barrier (1,300* linear, 20' avg. depth)
26,000
SO FT
$16
$416,000
$416,000
$416,000
lo
Earthwork and grading
7,260
SQ YD
$5
$36,300
$36,300
$36,300
IP
Fiber optic relocation
1
LS
$75,000
$75,000
$75,000
575,000
iq
NTCRA Infrastructure Modifications (Abandon RW-
# l m nr* /•/! • 1 - * TTr^T^T"' JT 4 •,
5, MWD-601, realign HDPE forcemain, etc.)
1
LS
$50,000
$50,000
$50,000
$50,000
lr
Pilot Study (assumes 50' by 50' by 20' deep target
zone)
1
LS
$1,500,000
$1,500,000
$1,500,000
$1,500,000
2
Well Abandonment
2a
Monitoring Well Abandonment
10
well
$500
$5,000 1 $5,000 1 $5,000
2b
System Well Abandonment
525
well
$500
$262,500 | $262,500 1 $262,500
Initial Capital Cost Subtotal:
$8,708,300 | $8,708,300 | $9,208,300
Total Initial Capital Cost (rounded):
$8,710,000 11 $8,710,000 II $9210,000
Page 1 of 4
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Overburden NAPL Area Remedial Alternatives Cost Estimate
Alternative ONOGU-S: Thermal Treatment and VINA
m
is*
as
\ ' , «. » ¦ H.'f fcT* ' * 9
flMBRSSfrWefc -
' ] V ''HrWw5D0,d^
¦' "iff l7utt» .«!»'* y*jhx5
BgmJniEM ^toBF
B. Thermal Treatment Operating Cost (2 people, 24 hrs/day, 200 days for 95% removal)
1
Operating ISTD System
9,600
man hours
$95
$912,000
$912,000
$912,000
2
Air Monitoring (~ 2 RCRA perf tests)
2
LS
S50,000
$100,000
$100,000
$100,000
3
Utilities
3a
Electricity
7,700,000
KW-Hr
$0.11
$847,000
$847,000
$847,000
3b
Natural Gas
80,000
Therm (100 rf)
$0.60
$24,000
$48,000
$96,000
3c
Potable Water
1,000,000
gallons
$0.03
$30,000
$30,000
$30,000
4
Field Supplies
1
LS
$170,000
$170,000
$170,000
$170,000
S
Contractor Management/Reporting
I
LS
$250,000
$250,000
$250,000
$250,000
6
Interim Soil Sampling
1
LS
$75,000
$75,000
$75,000
$75,000
7
Condensed NAPL Disposal
23,000
kg
$2.10
$48,300
$96,600
$193,200
8
Caustic 25%NaOH HCL neutralization
120,000
Gal
$1.25
$75,000
$150,000
$300,000
9
Brine Disposal
64,800
gal
$0.50
$16,200
$32,400
$64,800
Thermal O&M Cost Subtotal;
$2,547,500
$2,711,000
$3,038,000
. jEr ¦»
3.-. S
1
Total Ope
rating Capital Cost (rounded):
.r- -1"" 1 ¦¦¦ ¦ f.
^ Wn^^aJnitCW *
$2,550,000
.
$2,710,000
$3,040,000
C. Monitoring Costs {5 Years of Monitoring, 10 wells, twice per year, VOCs + MNA parameters)
1
Compliance Monitoring
100
man hours
$95
$9,500
$9,500
$9,500
2
Analytical
24
analysis
$500
$12,000
$12,000
$12,000
3
Equipment
20
each
$125
$2,500
$2,500
$2,500
Subtotal Annua! O&M Cost:
$24,000
$24,000
$24,000
Total Annual O&M Cost:
$24,000
$24,000
524,000
Present Worth Factor (5 years, no discount):
5
5
5
Total Present Worth of Annual O&M Cost (rounded);
$120,000
$120,000
1120,000
Page 2 of 4
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Overburden NAPL Area Remedial Alternatives Cost Estimate
Alternative QNOGU-5: Thermal Treatment and MNA
V " I • 1^"* "V ' ^ ^
W *
Aggregate Present Worth of Total Cost:
SI 1,380,000
$11,540,000
$12,370,000
Remedial Design (6%)
$682,800
$692,400
$742,200
Project Administration/Management Cost (5%)
$569,000
$577,000
$618,500
Construction Management (6%)
$682,800
$692,400
$742,200
Scope Contingency (25%)
$2,845,000
$2,885,000
$3,092,500
Bid or Construction Contingency (15%):
$1,707,000
$1,731,000
$1,855,500
| | Total Cost
$17,866,600
$18,117,800
$19,420,900
Rounded To:
$17,870,000
$18,120,000
$19,420,000
Remedial Cost Reduction Associated with Successful Pilot Study
Pilot Study m 3,9% of ONOGU Volume, Assumed Cost Reduction = 3.9% of Capital + O&M Costs)
($460,000)
Total Cost - 95% Removal (Rounded);
$17,660,000
Page 3 of 4
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Overburden NAPL Area Remedial Alternatives Cost Estimate
Alternative ONOGU-5: Thermal Treatment and MXA
Notes:
1. Thermal Treatment assumes 30% and Final Design.
2. System Instrumentation and Equipment includes additional cost for a back-up power supply
3. IDW Volumes: ,74 cubic yard per well
4. Mobilization & Demobilization includes cost for shipment of equipment and decontamination
5. Install Well Field- includes cost for drillers time and materials to install well field consisting of 450 20' deep Heater Wells and conductors/elements,
450 4' deep vapor Extraction Wells, and 75 20' pressure/temperature monitoring locations
6. Construct Cover- Cover will consist of a asphalt or concrete cover to minimize heat loss, contain vapors, and to ensure adequate heating
7. Utility Installation includes cost for electrical and natural gas installations and upgrades
8. Well Abandonment-10 wells within the Operations Area will be abandoned prior to the installation of the well field,
9. Vapor treatment assumes capture and treatment of up to 850,000 pounds of VOCs during thermal remediation, and treatment using condensation,
thermal oxidation, acid-gas scrubbing and other measures as needed to comply with ARARs.
10. Operations and maintenance costs assume 200 days of operation, and use of NTCRA system for final treatment of groundwater. Additional NTCRA
G&M costs are not included.
11. LS - lump sum.
12. Long-term monitoring includes labor and materials for semi-annual monitoring of ONOGU ground-water quality utilizing a subset of the existing on-
site ground-water monitoring well network. This assumes that 10 wells will sampled semi-annually for VOCs and MNA parameters.
13 Pilot Study necessary to determine implementabiiity and ability to achieve target clean up goals, to confirm ability to control grounwater migration,
and to confirm selection of materials of construction, Scope assumed to be similar to Silresim Site.
Page 4 of 4
-------
DRAFT
Table L~(o
SRSNE Superfund Site
Feasibility Study
NAPL in Bedrock Groundwater Unit Remedial Alternatives Cost Estimate
Alternative NBGU-2: institutional Measures and MNA
'a- ¦¦^eseriirtiori'-^r-
A. Initial Capital Costs
1
No Initial Capital Costs
$0
B. Recurring Capital Costs
1
No Recurring Capital Costs
so
C. Annual Operation and Maintenance Costs (30 year Present Worth)
1
MNA costs included with BGW-2 and BGW-3
$0
Annual O&M Cost Subtotal:
$0
Total Annual O&M Cost:
$0
Present Worth Factor (30-year, 7%):
12.41
Total Present Worth of Annual O&M Cost;
$0
Aggregate Present Worth of Total Cost;
$0
Rounded To:
SO
Notes:
1. Institutional controls costs included with OGW-2 and OGW-3 costs
2. LS - lump sum
4/6/2005
Page 1 of I
-------
DRAFT
Table 1-7
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-3: Hydraulic Containment and MNA
Quantity!
mm
A. Initial Capital Costs
1
Institutional Controls
200
man hours
$250
$50,000
2
Sheet Pile Removal (Create Gaps)
1
LS
$100,000
$100,000
3
Initial Groundwater Sampling
3a
Sampling
800
man hours
$95
$76,000
3b
Analytical
240
analysis $500
$120,000
3c
Equipment
200
each
S125
$25,000
4
Final Post-HD System Modification
1,000
man hours
$115
$115,000
5
New Equipment
1
LS
$500,000
$500,000
Initial Capital Cost Subtotal:
$986,000
Total Initial Capital Cost (rounded):
$990,000
B. Recurring Capital Costs
I Equipment Replacement
1
LS
$500,000
$500,000
Recurring Capital Cost Subtotal;
$500,000
Total Recurring Capital Cost
$500,000
Armualization Factor (15 years, 7%)
0.040
Total Annualized Recurring Capital Cost
$19,900
Present Worth Factor (30-year, 7%);
12.41
Total Present Worth of Recurring Capital Cost (rounded):
$250,000
4/6/200S
Page 1 of 5
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-3: Hydraulic Containment and MNA
fa*---.
jfcpT* " f \ v
*iF& '
-
IsIS
.Quantit>
C. Annual Operation and Maintenance Costs (Extraction and Treatment for 30 years)
1
System Operation and Maintenance
3,000
man hours
$75
$225,000
la
System Utilities
100000
KW hours
SO. 15
$15,000
lb
Well redevelopment
200
man-hours
$75
$15,000
lc
Development Chemicals
550
gallons
$5
$2,750
Id
Replacement Equipment Cost
12
days
$1,000
$12,000
le
Spare Parts
1
LS
$30,000
$30,000
If
System Chemicals
2000
gallons
S5
$10,000
lg
Laboratory Analysis
50
each
$500
$25,000
Ih
Filter Cake Disposal Costs
30
CY
$500
$15,000
2
Compliance Monitoring
208
man hours
$75
$15,600
3
Annual MNA Sampling and Analysis
3a
MNA Sampling
200
man hours
$95
$19,000
3 b MNA Analytical
60
analysis
$600
$36,000
3c MNA Equipment
60
each
$125
$7,500
4
Complete Round of TCL/TAL every five years
200
wells
4a Sampling
160
man hours
$95
$15,200
4b Analytical
48
analysis
$500
$24,000
4c Equipment
40
each
$125
$5,000
5
Five Year Reviews
1
LS
$5,000
$5,000
Annual O&M Cost Subtotal:
$477,050
Total Annual O&M Cost (rounded);
$480,000
Present Worth Factor (30-year, 7%);
12.41
Total Present Worth of Annual O&M Cost
(rounded):
$5,960,000 j
4/6/2005
Page 2 of 5
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative QGVV-3: Hydraulic Containment and MNA
Htsw?
j-'1 ^ '' i
-* ¦¦ - Description::--
* ¦
Quantify
Unitf-1?
wppflS
Unit Cost
"V-C.
S.Cast' k "
D. Site Closure Capital Costs
1
Monitoring Well Abandonment
300
Wells
$1,000
$300,000
2
Well Abandonment IDW
555
CY
$75
$41,625
3
Demobe of equipment
1,000
man hours
$115
$115,000
4
Dismantling NTCRA GW Treat. Bldg.
1,000
man hours
$75
$75,000
5
Demo & Disposal
22,000
kg
5
$99,000
Subtotal Site C
osure Cost;
5630,625
Total Site Closure Cost:
S630,000
Single Future Payment Factor
0.356
Total Present Worth of Site Closure Cost (rounded):
$220,000
Aggregate Present Worth of Total Cost:
$7,420,000
Remedial Design (3%)
$222,600
Project Administration/Management Cost (5%)
$371,000
Construction Management (1%)
$74,200
Scope Contingency (10%)
$742,000
Bid or Construction Contingency {10%):
$742,000
Subtotal
$9,571,800
Rounded To:
$9,570,000
4/6/2005
Page 3 of5
-------
DRAFT
SRSNE Super fund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-3: Hydraulic Containment and MNA
Notes:
I,
2.
3.
Long-term monitoring includes labor and materials for semi-annual monitoring of ground-water quality
utilizing the existing on-site ground-water monitoring wells. This assumes that a subset of approximately 25
wells would be sampled for MNA parameters (including VOCs) semi-annually.
Institutional controls includes implementing an ELUR to limit future usage of the Site and use of Site ground
water. Because these institutional controls would be in addition to those employed as part of the vadose zone
soil remedy, the costs included for this alternative would be additive to those costs included in the vadose
soil alternatives.
It is assumed that hydraulic containment would be achieved by pumping existing well RW-13 and one new
downgradient extraction well. For the purpose of cost estimation, the additional downgradient well is
assumed to pump at the same rate as the existing well at the TI Boundary for a total influent flow rate of 45
gpm to the remedial treatment system from NTCRA2.
4/6/2005
Page 4 of 5
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-3: Hydraulic Containment and MNA
tions
tiUiilW
T/mr*5"
—a:
^SbV"' '*&
--Gust
4, Installation of extraction wells includes one backup overburden pumping well and one downgradient
pumping well.
5- Equipment replacement cost assumes 50% of the initial capital construction cost will be required within 15
years of commencing operation to replace mechanical components (e.g. pumps, valves, well rehabilitation),
including the equipment installed as part of the NTCRA 1 system.
6. Long-term operation and maintenance costs include all costs necessary to operate and maintain the pumping
wells and the remedial treatment system including: equipment repair, energy costs, carbon regeneration and
off-gas treatment.
7. LS - lump sum.
8. Contingency includes unforeseen legal and administrative fees and insurance.
9. Initial sampling assumes one round of 200 wells for TCL/TAL parameters.
10. Assumes sampling 25 wells for VOCs and MNA parameters twice per year
' 1 • Assumes sampling 200 wells for TCL/TAL parameters once every five years
12. Assumes the Groundwater Treatment System and Equipment will be removed at Site Closure
13. Assumes all Groundwater monitoring wells will be abandoned at Site Closure.
14 Costs for NTCRA O&M are based on past project experience.
4/6/2005
Page 5 of 5
-------
DRAFT
Table L- f
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-4; Supplemental Containment (Contingent)
• ['AijirnQriry- ¦> ubihhc
—. V1 .w
*" a#- v8^
A. Initial Capital Costs
1
Installation of Additional Wells
3
EA
$85,000
$255,000
2
Tie-in to Existing System
1
LS
525,000
$25,000
Initial Capital Cost Subtotal:
$280,000
Total Initial Capital Cost (rounded):
$280,000
B. Recurring Capital Costs
No Recurring Capital Costs $0
C. Annual Operation and Maintenance Costs (30+ years)
1
Additional O&M Costs
1 LS
$50,000
S50,000
Annual O&M Cost Subtotal:
$50,000
Total Annual O&M Cost:
$50,000
Present Worth Factor'(30-year, 7%):
12.41
Total Present Worth of Annual O&M Cost (rounded):
$620,000
4/6/2005
Page 1 of 2
-------
DRAFT
SRSNE Superfund Site
Feasibility Study
Groundwater Remedial Alternatives Cost Estimate
Alternative OGW-4: Supplemental Containment (Contingent)
D. Site Closure Capital Costs
1
Well Abandonment
la
Well Abandonment
5
Wells
$1,000
$5,000
lb
Well Abandonment IDW
9
CY
$75
$694
2
Infrastructure Abandonment
5
LS
$1,000
$5,000
Subtotal Site Closure Cost;
$10,694
Total Site Closure Cost;
$11,000
Single Future Payment Factor
0.356
Total Present Worth of Annual O&M Cost (rounded):
54,000
Aggregate Present Worth of Total Cost:
$900,000
Remedial Design (6%)
$54,000
Project Administration/Management Cost (3%)
$27,000
Construction Management (4%)
$36,000
Scope Contingency (25%)
$225,000
Bid or Construction Contingency (15%):
$135,000
Subtotal
$1,377,000
Rounded To:
$1,380,000
Notes:
1. The cost for this alternative would be in addition to the cost for the OGW-3 ground-water remedial alternative.
2. LS - lump sum.
3. Assumes extraction wells will be abandoned at site closure.
4/6/2005
Page 2 of 2
-------
DRAFT
Table
SRSNE Superfund Site
Feasibility Study
Bedrock Groundwater Unit Remedial Alternatives Cost Estimate
Alternative BGW-3; Hydraulic Containment and MNA
."'vtaetoHptibn *- '-49wuitiM<2ostH
A. Initial Capital Costs
1 Remedial Design (incl below)
0
man hours SO
$0
Annual Capitol Cost Subtotal;
SO
Total Initial Capital Cost {rounded}*
so
B. O&M Costs (NTCRA Extraction and Treatment)
1 O&M Costs included with OGW-3
$0
Annual O&M Cost Subtotal:
$0
Total Annual O&M Cost:
$0
Present Worth Factor (30-year, 7%);
12.41
Total Annual O&M Cost:
$0
4/6/2005
Page 1 of2
-------
DRAFT
Table
SRSNE SuperfundSite
Feasibility Study
Bedrock Groundwater Unit Remedial Alternatives Cost Estimate
Alternative BGW-3; Hydraulic Containment and MNA
C. Annual Operation and Maintenance Costs (30 years)
1
Monitored Natural Attenuation Sampling
120
man hours
$95
$11,400
2
Analytical
36
analysis
$750
$27,000
Annual O&M Cost Subtotal;
$38,400
Total Annual O&M Cost:
$40,000
Present Worth Factor (30-year, 7%):
12.41
Total Present Worth of Annual O&M Cost (rounded):
Aggregate Present Worth of Total Cost:
$500,000
Remedial Design (6%)
$30,000
Project Administration/Management Cost (6%)
$30,000
Construction Management (0%)
$0
Scope Contingency (10%)
$50,000
Bid or Construction Contingency (10%):
$50,000
Subtotal
$660,000
Rounded To:
$660,000
Notes:
1. Bedrock Hydraulic Containment and ELUR Costs covered in OG W options
2. LS - lump sum
3. Assumes sampling 15 wells for VOCs and MNA parameters twice per year
4/6/2005
Page 2 of 2
-------
Appendix C
Glossary of Terms and Acronyms
-------
DRAFT
7. List of Acronyms
ACL
alternate concentration limit
AOC
Administrative Order on Consent
ARAR
applicable or relevant and appropriate requirement
AST
aboveground storage tank
AWQC
Ambient Water Quality Criteria
BGW
bedrock groundwater unit
B&M
Boston & Maine
BBL
Blasland, Bouck and Lee, Inc.
BEI1P
bis (2-ethylhexyl) phthalate
BTEX
benzene, toluene, ethylbenzene, xylenes
CAA
Clean Air Aet
CAWQC
chronic ambient water quality criteria
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
ch4
methane
CL&P
Connecticut Light & Power
C02
carbon dioxide
COC
chemical of concern
COPC
chemical of potential concern
CT DEP
Connecticut Department of Environmental Protection
cvoc
chlorinated volatile organic compound
CWA
Clean Water Act
DCE
dichloroethylene
DEC
risk-based Direct Exposure Criteria (CT DEP)
DHC
dehaloeoccoides
DNAPL
dense non-aqueous phase liquid
EE/CA
engineering evaluation/cost analysis
EISB
enhanced in situ biological treatment
ELUR
Environmental Land Use Restrictions
ERA
ecological risk assessment
ER-L
effects range - low
FS
feasibility study
GRA
general response action
GWPC
ground water protection criteria
GWUVD
Ground Water Use & Value Determination
HASP
Health and Safety Plan
III
hazard index
HNUS
Halliburton NUS Environmental Corporation
HQ
hazard quotient
IMS
interim monitoring and sampling
LDR
RCRA Land Disposal Restrictions
LNAPL
light non-aqueous phase liquid
LTTD
low temperature thermal desorption
MCL
RCRA Maximum Contaminant Level
MCLG
RCRA Maximum Contaminant Level Goal
MNA
monitored natural attenuation
NAAQS
National Ambient Air Quality Standards
NAPL
non-aqueous phase liquid
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
7-1
-------
DRAFT
NBGU
NAPL in the Bedrock Groundwater Unit
NPDES
National Pollutant Discharge Elimination System
NPL
National Priority List
NTCRA
non-lime critical removal action
OGW
overburden groundwater unit
O&M
operation and maintenance
OIS
on-site ground-water interceptor system
ONOGU
observed NAPL in the Overburden Groundwater Unit
OSHA
Occupational Safety and Health Administration
PAH
polycyclic aromatic hydrocarbon
PCB
polychlorinated biphenyl
PCE
tetrachloroethene
PCR
polymerase chain reaction
PLFA
phospholipid fatty acid
PMC
pollutant mobility criteria
POTW
publicly owned treatment work.
PMC
Pollutant Mobility Criteria (CT DEP)
ppb
part per billion
PPE
persona] protective equipment
ppm
parts per million
PRG
preliminary remediation goal
PRP
potentially responsible party
QA/QC
quality assurance/quality control
RA
risk assessment
RAGs
risk assessment guidance (USEPA)
RAO
remedial action objective
RCRA
Resource Conservation and Recovery Act
RID
reference dose
RI
remedial investigation
ROD
record of decision
RSR
Remediation Standard Regulations (CTDEP)
SAFE
Soulhington Association for the Environment
SARA
Superfund Amendments and Reauthorization Act
SDWA
Safe Drinking Water Act
SIP
state implementation plan
SITE
Superfund Innovative Technology Evaluation program
SOW
scope of work
SRSNE
Solvents Recovery Service of New England, Inc.
SVE
soil vapor extraction
SVOC
semi-volatile organic compound
TAG
Technical Assistance Grant
TBC
"to be considered" criteria
TCA
trichloroethane
TCE
trichlorocthylene
TCLP
Toxicity Characteristic Leaching Procedure
TI
technical impracticability
TSCA
Toxic Substances Control Act
TSDF
treatment storage and disposal facility
TEX
toluene, ethyl benzene, and xylenes
UCL
upper confidence limit
UCONN
University of Connecticut
USAF
United States Air Force Center for Environmental Excellence
7-2
-------
DRAFT
USEPA United States Environmental Protection Agency
USGS United States Geological Survey
UvOx ultraviolet oxidation
VC vinyl chloride
VOC volatile organic compound
7-3
-------
DRAFT
8. Glossary
Administrative Order On Consent (AOC): A legal agreement signed by EPA and an individual, business, or
other entity through which the violator agrees to pay for correction of violations, take the required corrective or
cleanup actions, or refrain from an activity. It describes the actions to be taken, may be subject to a comment
period, applies to civil actions, and can be enforced in court.
Applicable or Relevant and Appropriate Requirements (ARAR): Any state or federal statute that pertains to
protection of human life and the environment in addressing specific conditions or use of a particular cleanup
technology at a Supcrfund site.
Activated Carbon: A highly adsorbent form of carbon used to remove odors and toxic substances from liquid
or gaseous emissions. In waste treatment it is used to remove dissolved organic matter from waste water.
Aerobic Treatment: Process by which microbes decompose complex organic compounds in the presence of
oxygen and use the liberated energy for reproduction and growth.
Aerobic: Life or processes that require, or are not destroyed by, the presence of oxygen.
Air Pollutant: Any substance in air that could, in high enough concentration, harm man, other animals,
vegetation, or material. Pollutants may include almost any natural or artificial composition of airborne matter
capable of being airborne. They may be in the form of solid particulates, liquid droplets, gases, or in
combination thereof. Generally they fall into two main groups: (1) those emitted directly from identifiable
sources and (2) those produced in the air by interaction between two or more primary pollutants, or by reaction
with normal atmospheric constituents, with or without photoactivation.
Air Pollution Control Device: Mechanism or equipment that cleans emissions generated by an incinerator by
removing pollutants that would otherwise be released to the atmosphere.
Air Stripper: A treatment system that removes volatile organic compounds (VOCs) from contaminated ground
water or surface water by forcing an air stream through the water and causing the compounds to evaporate.
Ambient Air: Any unconfined portion of the atmosphere: open air, surrounding air.
Anaerobic: A life or process that occurs in, or is not destroyed by, the absence of oxygen.
Aquifer: An underground geologic formation, or group of formations, containing usable amounts of ground
water that can supply wells and springs.
Attenuation: The process by which a compound is reduced in concentration over time, through absorption,
adsorption, degradation, dilution, and/or transformation.
Bacteria: Microscopic living organisms that can aid in pollution control by metabolizing organic matter in
media such as ground water, soil, oil spills, and sewage.
Bedrock: Any solid rock exposed at the surface of the earth or overlain by unconsolidated overburden soil.
Bedrock Groundwater (BGW): Groundwater and the fractured consolidated rock matrix that contain
contaminant concentrations exceeding acceptable risk levels or regulatory criteria.
8-1
-------
DRAFT
Biodegradable: Capable of decomposing rapidly under natural conditions.
Biological Treatment: A treatment technology that uses bacteria to consume organic waste.
Bioremediation. Use of living organisms to clean up oil spills or remove other pollutants from soil, water or
wastewater; use of organisms such as non-harmful insects to remove agricultural pests or counteract diseases of
trees, plants, and garden soil.
Cap: A layer of clay, or other impermeable material installed over the top of a landfill or contaminated area of
soil to prevent entry of rainwater and minimize leaching of pollutants into ground water.
Carbon Adsorption: A treatment system that removes contaminants from ground water or surface water by
forcing it through tanks containing activated carbon treated to attract the contaminants.
Chlorinated Solvents: An organic solvent containing chlorine atoms, e.g., methylene chloride and 1,1,1-
trichloromethane, often used in aerosol spray containers and paint.
Chronic Toxicity: The capacity of a substance to cause long-term poisonous human health effects.
Cleanup: Actions taken to deal with a release or threat of release of a hazardous substance that could affect
humans and/or the environment. The term "cleanup" is sometimes used interchangeably with the terms
remedial action, removal action, response action, or corrective action.
CFH: Code of Federal Regulations
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): (Commonly
known as Superfund) This law, enacted by Congress on December 11, 1980, created the Superfund program.
Specifically, CERCLA established prohibitions and requirements concerning closed and abandoned hazardous
waste sites; provided for liability of persons responsible for releases of hazardous waste at these sites; and
established a trust fond to provide for cleanup when no responsible party could be identified.
Consent Decree: A legal document, approved by a judge, that formalizes an agreement reached between EPA
and potentially responsible parties (PRPs) through which PRPs will conduct all or part of a cleanup action at a
Superfund site; cease or correct actions or processes that are polluting the environment; or otherwise comply
with EPA initiated regulatoiy enforcement actions to resolve the contamination at the Superfund site involved.
Contaminant: Any physical, chemical, biological, or radiological substance or matter that has an adverse effect
on air, water, or soil.
Dechlorination: Removal of chlorine from a substance by chemically replacing it with hydrogen or hydroxide
ions in order to detoxify a substance.
Dense Non-Aqueous Phase Liquid (DNAPL): A non-aqueous phase liquid (NAPL) that is more dense than
water and would tend to migrate below the water table.
Ecological Impact: The effect that a man-made or natural activity has on living organisms and the non-living
(abiotic) environment.
Ecological Risk Assessment: The application of a formal framework, analytical process, or model to estimate
the effects of human action(s) on a natural resource and to interpret the significance of those effects in light of
the uncertainties identified in each component of the assessment process. Such analysis includes initial hazard
identification, exposure and dose-response assessments, and risk characterization.
8-2
-------
DRAFT
Effluent: Wastewater, treated or untreated, that flows out of a treatment facility, sewer, or industrial outfall
Generally refers to wastes discharged into surface waters.
Effluent Limitations: Restrictions established by a State or EPA on quantities, rates, and concentrations in
wastewater discharges.
Emission: Pollution discharged into the atmosphere from smokestacks, other vents, and surface areas of
commercial or industrial facilities; from residential chimneys; and from motor vehicle, locomotive, or aircraft
exhausts,
Exccedcnce: Concentration that is greater than the pollutant levels permitted by environmental protection
standards,
Ex-Situ: Moved from its original place; excavated; removed or recovered from the subsurface.
Feasibility Study: Analysis of the practicability of a proposal; e.g., a description and analysis of potential
cleanup alternatives for a site. The feasibility study usually recommends selection of a cost-effective
alternative. It usually starts as soon as the remedial investigation is underway; together, they are commonly
referred to as the "ROT'S".
General Response Action (GRA): Actions identified/taken for each media of interest that will contain, treat or
remove potential health-threatening environmental events such as spills, sudden releases. GRAs are developed
to satisfy the remedial action objectives for the site.
Generator: A facility or mobile source that emits pollutants into the air or releases hazardous waste into water
or soil.
Ground Water: Water found beneath the earth=s surface that fills pores between materials such as sand, soil, or
gravel. In aquifers, ground water occurs in sufficient quantities that it can be used for drinking water, irrigation,
and other purposes.
Hazard Quotient (HQ): A value calculated during risk assessment of non-carcinogens that is equal to the
average intake (based on ingestion rate and exposure duration) divided by the reference dose. A HQ value
greater than 1 indicates that a calculated exposure is greater than the reference dose for a given constituent, and
that there may be some potential for health concerns.
Hazardous Waste; By-products of society that can pose a substantial or potential hazard to human health or the
environment when improperly managed. Possesses at least one of four characteristics (ignitability, couosivity,
reactivity or toxicity), or appears on special EPA lists.
Hydraulic Gradient: In general, the direction of ground water flow due to changes in the depth of the water
table.
Infiltration: The penetration of water through the ground surface into sub-surfacc soil.
In-Situ: Remaining in original place.
Leacbate: Water that collects contaminants as it trickles through waste (e.g. landfills), and may result in
hazardous substances entering surface water, ground water or soil.
Leaching: The process by which soluble constituents are dissolved and filtered through the soil by a percolating
fluid (e.g. rain water).
8-3
-------
DRAFT
Light Non-Aqueous Phase Liquid (LNAPL): A non-aqueous phase liquid (NAPL) that is less dense than
water and would tend to remain above the water table.
Maximum Contaminant Level (MCL): The maximum permissible level of a contaminant in water delivered to
any user of a public system. MCLs are enforceable standards.
Maximum Contaminant Level Goal (MCLG): Under the Safe Drinking Water Act (SDWA), a non-
enforceable concentration of a drinking water contaminant, set at the level at which no known or anticipated
adverse effects on human health occur and which allows an adequate safety margin. The MCLG is usually the
starting point for determining the regulated MCL.
Media: Specific environments- air, water, soil - which are the subject of regulatory concern and activities.
Mitigation: Measures taken to reduce adverse impacts on the environment.
Monitoring Wells: Wells drilled at specific locations on or off a hazardous waste site where ground water can
be sampled at selected depths and studied to determine the direction of ground water flow and the types and
amounts of contaminants present.
National Ambient Air Quality Standards (NAAQS): Standards established by EPA that apply to outside air
throughout the country.
National Oil and Hazardous Substances Contingency Plan (NCP): The federal regulation that guides
determination of the sites to be corrected under both the Superfund program and the program to prevent or
control spills into surface waters or elsewhere.
National Pollutant Discharge Elimination System (NPDES): A provision of the Clean Water Act which
prohibits discharge of pollutants into waters of the United States unless a permit is issued by EPA, a state, or,
where delegated, a tribal government on an Indian reservation.
National Priority List (NPL): EPA=s list of the most serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial action under Superfund. The list is based primarily on the score a site
receives from the Hazard Ranking System. EPA is required to update the NPL at least once per year. A site
must be on the NPL to receive money from the Superfund trust fund for remedial action.
Non-Aqueous Phase Liquid (NAPL): Contaminants that remain as the original bulk liquid in the subsurface
(also referred to as "free product").
Non-Time Critical Removal Action (NTCRA): Non-emergency removal action that is conducted prior to
completion of the remedial investigation in an effort to expedite cleanup or containment of contaminated sites,
NTCRAs are often implemented where the complexity of the remedial investigation may require an extended
period of time to evaluate and determine the appropriate final remedial action,
Organic Compound: Animal or plant-produced substances containing mainly carbon, hydrogen, nitrogen, and
oxygen.
Outfall: The place where effluent is discharged into receiving waters.
Overburden: Unconsolidated rock and soil comprising the uppermost geologic formation above bedrock.
Overburden Groundwater: Groundwater and saturated soil that contain contaminant concentrations exceeding
acceptable risk levels or regulatory criteria.
8-4
-------
DRAFT
Oxidation; The addition of oxygen that breaks down organic waste or chemicals such as cyanides, and phenols
by bacterial and chemical means.
Particulates: Fine liquid or solid particles such as dust, smoke, mist, fumes, or smog, found in air or emissions.
Parts Per Billion (ppb)/Parts Per Million (pprn) Units commonly used to express contaminant ratios or
concentration, especially when defining the maximum permissible amount of a contaminant in water, land or air.
Permeability; The rate at which liquids pass through soil or other materials in a specified direction.
Personal Protective Equipment (PPE): Any equipment or clothing designed to shield or isolate individuals
from the chemical, physical, and biologic hazards that may be encountered at a hazardous waste site. PPE
should appropriately protect the respiratory system, skin, eyes, face, hands, feet, head, body, and hearing.
Phytoremediation: An in-situ remediation technique that uses plants to remove, stabilize, and destroy
contaminants in soil and sediment.
Plume: A visible or measurable discharge of a contaminant from a given point of origin (e.g., dissolved phase
contamination in groundwater, downgradient from the initial release or spill).
Potentially Responsible Party (PEP): Any individual or company-including owners, operators, transporters or
generators-potentiaily responsible for, or contributing to a spill or other contamination at a Superfimd site.
Whenever possible, through administrative and legal actions, EPA requires PRPs to clean up hazardous sites
they have contaminated.
Preliminary Remediation Goals (PRGs): Chemical-specific, numeric cleanup criteria for each environmental
media that provide the basis for development and comparison of remedial alternatives and the framework to
evaluate the relative effectiveness of each respective alternative.
Publicly Owned Treatment Works (POTW): A waste-treatment works owned by a state, unit of local
government, or Indian tribe, usually designed to treat domestic wastewater.
Quality Assurance/Quality Control (QA/QC): A system of procedures, checks, audits, and corrective actions
to ensure that all work is of the highest achievable quality.
Record of Decision (ROD): A public document that explains which cleanup alternative(s) will be used at
National Priority List sites.
Reference Dose (RfD): The concentration of a chemical known to cause health problems; also referred to as the
ADD, or acceptable daily intake.
Release: Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing into the environment of a hazardous or toxic chemical or extremely hazardous
substance.
Remedial Action (RA); The actual construction or implementation phase of a Superfiind site cleanup that
follows remedial design.
Remedial Action Objective (RAO): Remedial action objectives specify media-specific or site-specific goals
for the protection of human health and the environment,
8-5
-------
DRAFT
Remedial Design: The phase of remedial action that follows the remedial investigation/feasibility study and
includes development of engineering drawings and specifications for a site cleanup.
Remedial Investigation (RI): An in-depth study designed to gather data needed to determine the nature and
extent of contamination at a Supcrfund site; establish site cleanup criteria; identify preliminary alternatives for
remedial action; and support technical and cost analyses of alternatives. The remedial investigation is usually
done with the feasibility study. Together they are usually referred to as the "RI/FS".
Remediation: Cleanup or other methods used to remove or contain a toxic spill or hazardous materials from a
Superfund site.
Removal Action: Short-term immediate actions taken to address releases of hazardous substances that require
expedited response.
Residual: Amount of a pollutant remaining in the environment after a natural or technological process has taken
place, e.g., the particulates remaining in air after it passes through a scrubbing or other process.
Resource Conservation and Recovery Act (RCRA): A law enacted in 1976 to protect the quality of ground
water, surface water, air and land from contamination by solid waste. It established the first comprehensive
federal regulatory program for controlling hazardous waste and provided grants and technical assistance to
States to help improve their waste management techniques.
Risk: A measure of the probability that damage to life, health, property, and/or the environment will occur as a
result of a given hazard.
Risk Assessment: Qualitative and quantitative evaluation of the risk posed to human health and/or the
environment by the actual or potential presence and/or use of specific pollutants,
State Implementation Plans (SIP): EPA-approved state plans for the establishment, regulation, and
enforcement of air pollution standards.
Superfund; The program operated under the legislative authority of CI: RC I. A and SARA that funds and carries
out EPA solid waste emergency and long-term removal and remedial activities. These activities include
establishing the National Priorities List, investigating sites for inclusion on the list, determining their priority,
and conducting and/or supervising cleanup and other remedial actions.
Superfund Amendments and Reauthorization Act (SARA): Legislation that amended the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) on October 17, 1986. SARA reflected
EPA's experience in administering the complex Superfund program during its first six years and made several
important changes and additions to the program. SARA stressed the importance of permanent remedies and
innovative treatment technologies; required Superfund actions to consider the standards and requirements found
in other State and Federal environmental laws and regulations; provided new enforcement authorities and
settlement tools; increased State involvement; increased the focus on human health problems; encouraged
greater citizen participation; and increased the size of the Trust Fund to $8.5 billion.
Surface Water: All water naturally open to the atmosphere (rivers, lakes, reservoirs, ponds, streams,
impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors directly influenced by surface
water.
Technical Assistance Grant (TAG); As part of the Supcrfund program, Technical Assistance Grants of up to
$50,000 are provided to citizens' groups to obtain assistance in interpreting information related to cleanups at
Superfund sites or those proposed for the National Priorities List. Grants are used by such groups to hire
8-6
-------
DRAFT
technical advisors to help them understand the site-related technical information for the duration of response
activities.
Toxic Pollutants: Materials that cause death, disease, or birth defects in organisms that ingest or absorb them.
The quantities and exposures necessary to cause these effects can vary widely.
Toxic Substance: A chemical or mixture that may present an unreasonable risk of injury to health or the
environment.
Treatability Studies; Tests of potential cleanup technologies conducted in a laboratory.
Treatment, Storage, and Disposal Facility (TSDF): Site where a hazardous substance is treated, stored, or
disposed of, TSDFs are regulated by EPA and states under RCRA.
Trial Burn: An incinerator test in which emissions are monitored for the presence of specific organic
compounds, particulates, and hydrogen chloride.
Unsaturated Zone; The area below ground surface and above the water table where soil pores are not fully
saturated, although some water may be present.
Vadose Zone: The unsaturated zone.
Variance: Government permission for a delay or exception in the application of a given law, ordinance, or
regulation.
Volatile: Any substance that evaporates readily.
Volatile Organic Compound (VOC): Any organic compound that is characterized by being highly mobile in
ground water and tends to readily volatilize or evaporate into the atmosphere.
Wastewater: The spent or used water from a home, community, farm, or industry that contains dissolved or
suspended matter.
Water Quality Criteria: Levels of water quality expected for its designated use. Criteria are based on specific
levels of pollutants that would make the water harmful if used for drinking, swimming, farming, fish production,
or industrial processes.
Water Table: The level of ground water.
Wetlands: An area that is saturated by surface or ground water with vegetation adapted for life under those soil
conditions, as swamps, bogs, fens, marshes, and estuaries.
8-7
-------
Appendix D
ARARs Tables
-------
Draft
Table 4-5
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs -Operations Area/Railroad Soil
Alternative OAR-2: Capping and Institutional Controls
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical-
Specific
State of
Connecticut
Remediation Standard
Regulations for soil
CGS 22a-133k,
RCSA 2a-133k-
2
Applicable
These regulations establish direct
exposure and pollutant mobility criteria
for contaminated soils based on either
industrial or residential use of the Site.
Contaminated soil exceeding these
values would be managed according
to these standards (through a
variance), including land use
restrictions, and construction of an
engineered control to prevent
exposure to soil.
Y
Location
Specific
None apply.
Action-
Specific
State of
Connecticut
Hazardous Waste
Regulations
CGS 22a ch
445
RCSA §22a-
449(c) 100
through 119
Relevant and
Appropriate
These regulations establish standards
for treatment, storage and disposal of
hazardous waste and remediation waste,
groundwater monitoring and
requirements for closure and post-
closure of hazardous waste facilities.
All treatment, storage and disposal
standards. Emergency requirements,
groundwater monitoring
requirements and landfill closure
and post closure requirements
would be met by this alternative.
Y
Air Pollution Control
CGS 22a ch
446c
RCSA §22a-
174-1 to 33
Applicable
These regulations include requirements
(o control emissions. Pollutant
abatement controls/measures are
required.
Would comply with emission
standards to control fugitive dust
from excavation activities.
Y
Control of Noise
RCSA §22a-
69-1 to 7.4
Applicable
These regulations establish allowable
noise levels; and would apply to
construction activities at the site,
All construction activities on-site
would comply with these noise
level requirements.
Y
To Be
Considered
Federal
EPA Technical Guidance
Document; Final Covers
on Hazardous Waste
Landfills and Surface
Impoundments
EFA/530-SW-
89-047
TBC
Presents technical specifications for the
design of multi-barrier covers at
landfills at which hazardous wastes
were disposed.
Will be considered during the
design of the cap.
Y
5/20/2005
Page I
-------
Drsft
ABAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
•w/AiRAR
Technical Memorandum;
Revised Landfill Cap
Design Guidance
Proposed for Unlined
Hazardous Waste
Landfills in EPA Region
1
Dated February
5, 2001
TBC
Provides guidance for landfill cap
design for unlined hazardous waste
landfills at Superfund site in EPA
Region 1.
Will be considered during the
design of the cap.
Y
5/20/2005
Page 2
-------
Draft
Table 4-14
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Cianci Property Soil
Alternative CP-2: Culvert Removal and Excavation with Onsite Disposal'
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical-
Sped fie
State of
Connecticut
Remediation Standard
Regulations for soil
CGS 223-133k;
RCSA 22a-l33k-2
Applicable
These regulations establish direct
exposure and pollutant mobility criteria
for contaminated soils based on either
industrial or residential use of the Site.
These regulations would be used to
determine the cleanup levels for
soil/sediment. Contaminated
soil/sediment exceeding PMC or
DEC values would be excavated.
Y
Location-
Specific
Federal
Fish and Wildlife
Coordination Act
16 U.S.C. 661
Applicable
This order protects fish and wildlife
when federal actions result in control or
structural modification of a natural
stream or body of water.
Appropriate agencies would be
consulted should remedial action
involve modification to a waterway.
Y
Clean Water Act
(CWA)-Discharge to
Waters of the United
States, Section 404
33 USC 1344; 40
CFR Part 230 and
33 CFR Parts 320-
323
Applicable
These rules regulate the discharge of
dredge and fill materials in wetlands and
navigable waters. Such discharges are
not allowed if practicable alternatives are
available.
There is no practical alternative to
address contaminated sediment and
relocation of the culvert in the
wetlands, Measures will be taken to
minimize impacts.
Y
State of
Connecticut
Surface Water and
Wetlands, Inland
Wetlands and
Watercourses Act
CGS 22a-36
through 45
Applicable
This rule regulates any activities within
or affecting inland wetlands involving
removal or deposition of material or any
obstruction, construction, alteration or
pollution of such wetlands.
Would meet requirements for
removal or deposition of materia! or
any obstruction, construction,
alteration or pollution of wetlands.
Y
Action-
Specific
Federal
Toxic Substances
Control Act
15 USC 2601,40
CFR 761
Applicable
Soil containing PCBs>50 ppm is
regulated under this Act.
Should PCBs be encountered during
excavation/consolidation they will
be addressed in accordance with
these requirements.
Y
(-eidcvaS
CAettrv
/^\cA- - 5ecJhct i -(-/zvw
pO'lo^cSOi/VU^*
i*_ {j&t£K£sS .
ARARs associated with placing contaminated soil and sediment under Operations Area cap are included in Table 4-3
5/20/2005
Page I
S taoufiJL- cCstoti dk£sj~"
ta
-------
Draft
Table 4-14 (Continued)
3RSNE Siiperfund Site
Feasibility Study
Evaluation of ARARs - Cianci Property Soil
Alternative CP-2: Culvert Removal and Excavation with Onsite Disposal
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Action-
Specific
(cont)
State of
Connecticut
Hazardous Waste
Management: Land
Disposal Restrictions
and Corrective Action
Management Units
CGS 22a ch 445
RCSA §22a-
449(c)-108,-104
Relevant and
Appropriate
These regulations establish treatment
standards for placement/disposal of
hazardous waste.
Contaminated soil/sediment would
be excavated and disposed of on-
site by placing it in the Operations
Area beneath the cap. AH
excavated soil/sediment would be
evaluated prior to placement
beneath the cap to ensure
compliance with LDR.
Soil/sediment requiring further
treatment would be managed in
accordance with requirements of
these regulations.
Y
Hazardous Waste
Management
CGS 22a ch 445
RCSA §22a-
449(c) 100
through 119
Relevant and
Appropriate
These regulations establish standards for
treatment, storage and disposal of
hazardous waste, remediation waste
treatment, storage and disposal,
groundwater monitoring and
requirements for closure and post-closure
of hazardous waste facilities.
Soil and sediment would be handled
in accordance with these
requirements.
Y
Disposition of PCBs
CGS 22a-467
Relevant and
Appropriate
This regulation establishes prohibitions
of, and requirements for the disposal,
storage, and marking of PCBs and PCB
waste. The standard requires the
handling of PCB waste to be consistent
with the Toxic Substances Control Act
(TSCA) listed at 40 CFR 761.
Sampling data indicates that levels
of PCBs are low and would not
trigger these requirements. Should
these levels be exceeded during the
cleanup, PCBs will be managed in
accordance with these requirements.
Y
Air Pollution Control
CGS 22a ch 446c
RCSA §22a-!74-l
to 33
Applicable
These regulations include requirements
to control emissions. Pollutant abatement
controls/measures are required. Specific
standards pertain to fugitive dust (18b).
Would comply with emission
standards to control fugitive dust
from excavation/construction
activities with dust control
measures.
Y
5/20/200S
Page 2
-------
Draft
Table 4-14 (Continued)
SRSNE Suptrfund Site
Feasibility Study
Evaluation of ARARs - Cianci Property Soil
Alternative CP-2: Culvert Removal and Excavation with Onsite Disposal
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
! Aetion-
! Specific
(ami)
State of
Connecticut
(cont)
Control of Noise
RCSA §22a-69- 1
to 7.4
Applicable
These regulations establish allowable
noise levels; and would apply to
construction activities at the site.
All construction activities on-site
would comply with these noise
level requirements.
Y
Water Quality Standards
CGS 22a-426
Applicable
The Connecticut Water Quality
Standards establish specific numeric
criteria for surface water. The standards
provide criteria for maintaining the
quality of surface waters through
limitations on point source discharges
and implementation of reasonable
controls or best management practices.
Extracted N APL'groundwater that
may be collected during dewatering
that is discharged to surface water
would be treated to meet the
requirements of these regulations.
zjjJLvicrrro
/*> \ru_sr\<2r{
Y
dGokAc'v"
€ .
Water Pollution Control:
Connecticut Discharge
Permit Regulations
CGS 22a ch 446k
RCSA |22a-430-I
to 8
Applicable
These regulations establish the
requirements for discharge to surface
water.
The effluent discharge from£F
Would meet the
substantive requirements of these
regulations.
Y
, To Be
Considered
Federal
Floodplain Management
Executive Order
E.O, 11988
Relevant and
Appropriate
Federal agencies are required to avoid
any action in floodplains if there is a
practicable alternative.
There is no practical alternative to
address contaminated sediment and
the location of the culvert in the
floodplain. Measures will be taken
to minimize impacts.
Y
Protection of Wetlands
Executive Order
E.O. 11990
Relevant and
Appropriate
Federal agencies are required to avoid
construction in wetlands if there is a
practicable alternative.
There is no practical alternative to
address contaminated sediment and
the location of the culvert in the
wetlands. Measures will be taken to
minimize impacts.
Y
Connecticut
Guidance
Connecticut Guidance
for Soil Erosion and
Sediment Control
CT Council on
Soil and Water
Conservation
TBC
This document includes guidance for
development, adoption and
implementation of erosion and sediment
control program.
These guidelines would be
considered during excavation
activities to protect wetland and
aquatic resources.
Y
5/20/2005
Page 3
-------
Draft
Table 4-32 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden N APl Zone
Alternative ONOGU-5: Thermal Treatment and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Action-
Specific
Federal
RCRA Air Emission
Standards for Equipment
Leaks
40 CFR 264
Subpart BB
Relevant and
Appropriate if
treatment
involves
groundwater
with organic
concentrations
of at least 10%
by weight.
Standards for air emissions for equipment
that contains or contacts hazardous
substances with organic concentrations of at
least 10% by weight.
If these requirements are
determined to be relevant and
appropriate, then the substantive
requirements of these regulations
will be met in addressing emissions
from thermal treatment.
Y
RCRA Air Emission
Standards for Process
Vents
40 CFR 264
Subpart AA
Relevant and
Appropriate if
threshold
concentrations
are met.
Standards for air emissions from process
vents associated with treatment of hazardous
substances and have total organic
concentrations of 10 ppiti or greater.
If these requirements are
determined to be relevant and
appropriate, then the substantive
requirements of these regulations
will be met in addressing emissions
from thermal treatment
Y
State of
Connecticut
Hazardous Waste
Management
Regulations
CGS 22a ch 445
RCSA §22a-
449(c)
Applicable
These regulations establish standards for
treatment, storage and disposal of hazardous
waste and remediation waste, groundwater
monitoring and requirements for closure and
post-closure of hazardous waste facilities
Treatment residues (spent filtration
residue and activated carbon) could
contain high concentrations of
regulated constituents. If
determined to be hazardous waste,
will be stored on site consistent with
these requirements before being
shipped offsitc for disposal. NAPL
collected from the thermal treatment
process will be stored on site
consistent with these requirements
before being shipped off site for
disposal. Groundwater will be
monitored. General facility,
preparedness and prevention,
contingency plan and emergency
procedures will also be met
Y
5/20/2005
Page 2
-------
Draft
Table 4-32 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden NAPL Zone
Alternative ONOCU-5; Thermal Treatment and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
wr/ARAR
Action-
Specific
(cont.)
State of
Connecticut
(cont.)
Air Pollution Control
CGS 22a ch 446c
RCSA lj 22a-174-1
to 33
Applicable
These regulations include requirements to
control emissions. Pollutant abatement
controls/measures may be required. Specific
standards pertain to fugitive dust and control
of air toxics.
Would comply with emission
standards, requirements for
pollution abatement, and
requirements for control of fugitive
dust from construction activities
with dust control measures. Will
take appropriate measures to
address state air toxics
requirements.
Y
Control of Noise
RCSA §22a-69- 1
to 7,4
Applicable
These regulations establish allowable noise
levels; and would apply to construction
activities at the site.
All construction activities on-site
would comply with these noise
level requirements.
Y
5/20/2005
Page 3
-------
Draft
Table 4-53
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Bedrock NAPL Zone
Alternative NBGII-2: Institutional Controls and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical-
Specific
Federal
Safe Dnnkinc Water Act
{SDWA}:
Maximum Contaminant
Levels (MCLs) and non-
zero Maximum
Contaminant Level
Goals (MCLGs)
Pub. L. 93-523;
40 CFR 141
Relevant and
Appropriate
These regulations establish primary drinking
water regulations and goals pursuant the
SDWA.
Would achieve compliance
eventually through monitored
natural attenuation, therefore,
alternative would meet ARAR
Y
EPA Reference Doses
(RfDs) and EPA
Carcinogen Assessment
Group Potency Factors
To Be
Considered
RfD is an estimate of human daily oral
exposure that is likely to be without an
appreciable risk of non-cancer effects. The
potency factors are used as qualitative
weight-of-evidence judgment as to the
likelihood of a chemical being a carcinogen.
Will be considered in developing
groundwater clean up levels.
EPA Health Advisories
To Be
Considered
A health advisory is an estimate of
acceptable drinking water levels for a
chemical based upon health effects.
Will be considered in developing
groundwater clean up levels.
State of
Connecticut
Remediation Standard
Regulations for
groundwater
COS 22a-133k;
RCSA j)22a-133k-
3
Relevant and
Appropriate
These regulations establish groundwater
cleanup standards. Requirements are based
on groundwater in the area being classified
by the state as GA-degraded
Would achieve compliance
eventually through monitored
natural attenuation, therefore,
alternative would meet ARAR
Y
Location-
Specific
None apply.
Action-
Specific
None apply.
5/20/2005
Page 1
-------
Draft
Table 4-44
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater Unit
Alternative OGW-3: Hydraulic Containment and MNA
ARAR
Category
Regulator)'
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical'
Specific
Federal
Safe Drinking Water Act
(SDWA):
Maximum Contaminant
Levels (MCLs) and non-
zero Maximum
Contaminant Level
Goals (MCLGs)
Pub. L. 93-523;
4UCFR 141
Re levant and
Appropriate
These regulations establish primary drinking
water regulations and goals pursuant the
SDWA.
Would eventually achieve
compliance through natural
attenuation.
Y
EPA Reference Doses
(RfDs) and EPA
Carcinogen Assessment
Group Potency Factors
To Be
Considered
RfD is an estimate of human daily oral
exposure that is likely to be without an
appreciable risk of non-cancer effects. The
potency factors are used as qualitative
weight-of-evidence judgment as to the
likelihood of a chemical being a carcinogen.
Will be considered in developing
groundwater clean up levels.
EPA Health Advisories
To Be
Considered
A health advisory is an estimate of
acceptable drinking water levels for a
chemical based upon health effects.
Will be considered in developing
groundwater clean up levels.
State of
Connecticut
Remediation Standard
Regulations far
groundwater
CGS 22a-133k;
RCSA §22a-133k-
3
Applicable
These regulations establish groundwater
cleanup standards. Requirements are based
on groundwater in the area being classified
by the state as GA»degraded.
Would eventually achieve
compliance though natural
attenuation. May apply the
provision in regulation for
exemption from restoring
groundwater to background once
remediation has met GWFS and
other ARAR/risk based cleanup
levels.
Y
Proposed Revisions -
Connecticut's
Remediation Standard
Regulations
Volatilization Criteria,
March 2003
Proposed
Revisions to
portions of RCSA
§§22a-133k-l
through 3
TBC
Will be
applicable (as
part of the
RSRs) when
adopted
Revises how volatilization criteria are
calculated, incorporated revised transport
models and updated risk information, and
volatilization criteria are applied.
Would eventually achieve
compliance though natural
attenuation.
5/20/2005
Page 1
-------
Draft
Table 4-44 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater Unit
Alternative OGW-3: Hydraulic Containment and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Location-
Specific
None apply.
Aclion-
Specific
State of
Connecticut
Hazardous Waste
Management
CGS 22a ch 445
RCSA §22a-
449(c) 100
through 119
Applicable
These regulations establish standards for
treatment, storage and disposal of hazardous
waste and remediation waste, groundwater
monitoring and requirements for closure and
post-closure of hazardous waste facilities
Treatment residues (spent filtration
residue and activated carbon) could
contain high concentrations of
regulated constituents. If
determined to be hazardous waste,
will be stored on site consistent with
these requirements before being
shipped offsite for disposal.
Groundwater will be monitored in
accordance with these requirements.
Y
Water Quality Standards
CGS 22a-426
Applicable
The Connecticut Water Quality Standards
establish specific numeric criteria for
surface water. The standards provide
criteria for maintaining the quality of surface
waters through limitations on point source
discharges and implementation of
reasonable controls or best management
practices.
Extracted groundwater that is
discharged to surface water would
be treated in a manner would meet
the requirements of these
regulations.
Y
Water Pollution Control:
Connecticut Discharge
Permit Regulations
CGS 22a ch 446k
RCSA §22a-430-1
to 8
Applicable
These regulations establish the requirements
for discharge to surface water.
The effluent discharge from the
treatment facility would meet the
substantive requirements of these
regulations.
Y
Air Pollution Control
CGS 22a ch 446c
RCSA §22a* 174-1
to 33
Applicable
These regulations include requirements to
control emissions. Pollutant abatement
controls/measures may be required. Specific
standards pertain to fugitive dust (18b).
Would comply with emission
standards, requirements for
pollutant abatement and
requirements for control of fugitive
dust from construction/excavation
activities with dust control measures
Y
5/20/2005
Page 2
-------
Draft
Table 4-44 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater Unit
Alternative OGW-3: Hydraulic Containment and MNA
ARAR
Category
Regulatory
Levei
Requirement
Citation
Status
Synopsis
Evaluation
Caraply
w/ARAR
Control of Noise
RCSA §22a-69- 1
to 7.4
Applicable
These regulations establish allowable noise
levels; and would apply to construction
activities at the site.
All construction activities on-site
would comply with these noise
level requirements.
Y
5/20/2005
Page 3
-------
Draft
Table 4-47
SR5NE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater
Alternative OGW-4: Supplemental Containment (Contingent)
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical-
Specific
Federal
Safe Drinking Water Act
(SDWA):
Maximum Contaminant
Levels (MCLs) and non-
zero Maximum
Contaminant Level
Goals (MCLGs)
Pub. L. 93-523;
40 CFR 141
Relevant and
Appropriate
These regulations establish primary drinking
water regulations and goals pursuant the
SDWA.
Would eventually achieve
compliance through natural
attenuation.
¥
EPA Reference Doses
(RfDs) and EPA
Carcinogen Assessment
Group Potency Factors
To Be
Considered
RiD is an estimate of human daily oral
exposure that is likely to be without an
appreciable risk of non-cancer effects. The
potency factors are used as qualitative
weight-of-evidenee judgment as to the
likelihood of a chemical being a carcinogen.
Will be considered in developing
groundwater clean up levels.
EPA Health Advisories
To Be
Considered
A health advisory is an estimate of
acceptable drinking water levels for a
chemical based upon health effects.
Will be considered in developing
groundwater clean up levels.
State of
Connecticut
Remediation Standard
Regulations for
groundwater
CGS 22a-13 3k;
RCSA fj22a-I33k-
3
Applicable
These regulations establish groundwater
cleanup standards. Requirements are based
on groundwater in the area being classified
by the state as GA-degraded.
Would eventually achieve
compliance through natural
attenuation. May apply the
provision in regulation for
exemption from restoring
groundwater to background once
remediation has met GWPS and
other ARAR/risk based cleanup
levels.
Y
5/20/2005
Page 1
-------
Draft
Table 4-47 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater Unit
Alternative OGW-4: Supplemental Containment (Contingent)
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Proposed Revisions -
Connecticut's
Remediation Standard
Regulations
Volatilization Criteria,
March 2003
Proposed
Revisions to
portions of RCSA
§§22a-I33k-l
through 3
Will be
applicable (as
part of the
RSRs) when
adopted
Revises how volatilization criteria are
calculated, incorporated revised transport
models and updated risk information, and
volatilization criteria are applied.
Would eventually achieve
compliance through natural
attenuation.
Location-
Specific
None apply.
Action-
Specific
State of
Connecticut
Hazardous Waste
Management
Regulations
CGS 22a ch 445
RCSA §22a-
449(c) 100
through 119
Applicable
These regulations establish standards for
treatment, storage and disposal of hazardous
waste and remediation waste, groundwater
monitoring and requirements for closure and
post-closure of hazardous waste facilities
Treatment residues (spent filtration
residue and activated carbon) could
contain high concentrations of
regulated constituents, If
determined to be hazardous waste,
will be stored on site consistent with
these requirements before being
shipped offsite for disposal.
Groundwater will be monitored in
accordance with these requirements.
Y
Water Quality Standards
CGS 22a-426
Applicable
The Connecticut Water Quality Standards
establish specific numeric criteria for
surface water. The standards provide
criteria for maintaining the quality of surface
waters through limitations on point source
discharges and implementation of
reasonable controls or best management
practices.
Extracted groundwater that is
discharged to surface water would
be treated in a manner would meet
the requirements of these
regulations.
Y
Water Pollution Control:
Connecticut Discbarge
Permit Regulations
CGS 22a ch 446k
RCSA §22a-430-I
to 8
Applicable
These regulations establish the requirements
for discharge to surface water.
The effluent discharge from the
treatment facility would meet the
substantive requirements of these
regulations.
Y
5/20/2005
Page 2
-------
Draft
Table 4-47 (Continued)
SRSNE Snperfund Site
Feasibility Study
Evaluation of ARARs - Overburden Groundwater Unit
Alternative OGW-4: Supplemental Containment (Contingent!
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Air Pollution Control:
Control of Particulate
Matter
COS 22a ch 446c
RCSA§22»-174-1
to 20
Applicable
These regulations include retirements to
control emissions. Pollutant abatement
controls/measures may be required. Specific
standards pertain to fugitive dust (18b).
Would comply with emission
standards to control fugitive dust
from construction/excavation
activities with dust control measures
Y
Control of Noise
RCSA §22a-fi9- !
to 7.4
Applicable
These regulations establish allowable noise
levels; and would apply to construction
activities at the site.
All construction activities on-site
would comply with these noise
level requirements.
Y
S/20/2005
Page 3
-------
Draft
Table 4-62
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Bedrock Groundwater Unit
Alternative BCW-3: Hydraulic Containment and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Chemical-
Specific
federal
Safe Drinking Water Act
(SDWA):
Maximum Contaminant
Levels (MCLs) and non-
zero Maximum
Contaminant Level
Goals (MCLGs)
Pub. L. 93-523;
40 CFR 141
Relevant and
Appropriate
These regulations establish primary drinking
water regulations and goals pursuant the
SDWA,
Would eventually achieve
compliance through monitored
natural attenuation.
Y
EPA Reference Doses
(RfDs) and EPA
Carcinogen Assessment
Group Potency Factors
To Be
Considered
RID is an estimate of human daily oral
exposure that is likely to be without an
appreciable risk of non-cancer effects. The
potency factors are used as qualitative
weight-ol'-cvidencc judgment as to the
likelihood of a chemical being a carcinogen.
Will be considered in developing
groundwater clean up levels.
EPA I ieaJth Advisories
To Be
Considered
A health advisory is an estimate of
acceptable drinking water levels for a
chemical based upon health effects.
Will be considered in developing
groundwater clean up levels.
Stale of
Connecticut
Remediation Standard
Regulations for
groundwater
CGS 22a-133k;
RCSA §22a-133k«
3
Applicable
These regulations establish groundwater
cleanup standards. Requirements are based
on groundwater in the area being classified
by the state as GA-degraded.
Would eventually achieve
compliance through monitored
natural attenuation. May apply the
provision in regulation for
exemption from restoring
groundwater to background once
remediation has proceeded to meet
GWPS.
Y
Location-
Specific
None apply.
5/20/2005
Page 1
-------
Draft
Table 4-62 (Continued)
SRSNE Superfund Site
Feasibility Study
Evaluation of ARARs - Bedrock Groundwater Unit
Alternative BGW-3: Hydraulic Containment and MNA
ARAR
Category
Regulatory
Level
Requirement
Citation
Status
Synopsis
Evaluation
Comply
w/ARAR
Action-
Specific
State of
Connecticut
Hazardous Waste
Management: Storage
Requirements
CGS 22a ch 445
RCSA §22a-
449(c) 100
through 119
Applicable
These regulations establish standards for
treatment, storage and disposal of hazardous
waste and remediation waste, groundwater
monitoring and requirements for closure and
post-closure of hazardous waste facilities.
Treatment residues (spent filtration
residue and activated carbon) could
contain high concentrations of
regulated constituents. If
determined to be hazardous waste,
will be stored on site consistent with
these requirements before being
shipped offsite for disposal, ,
Y
Water Quality Standards
CGS 22a-426
Applicable
The Connecticut Water Quality Standards
establish specific numeric criteria for
surface water. The standards provide
criteria for maintaining the quality of surface
waters through limitations on point source
discharges and implementation of
reasonable controls or best management
practices.
Extracted groundwater that is
discharged to surface waters would
be treated in a manner that is
consistent with the requirements of
this rule.
Y
j #
Water Pollution Control:
Connecticut Discharge
Permit Regulations
CGS 22a ch 446k
RCSA §22a-430-l
to 8
Applicable
These regulations establish the requirements
for discharge to surface water.
The effluent discharge from the
treatment facility would meet the
substantive requirements of these
regulations.
Y
Air Pollution Control;
Control of Particulate
Matter
CGS 22a ch 446c
RCSA §22a-174-1
to 20
Applicable
These regulations include requirements to
control emissions. Pollutant abatement
controls/measures may be required. Specific
standards pertain to fugitive dust (18b).
Would comply with emission
standards to control fugitive dust
from construction activities with
dust control measures
Y
Control of Noise
RCSA §22a-69-1
to 7.4
Applicable
These regulations establish allowable noise
levels; and would apply to construction
activities at the site.
All construction activities on-site
would comply with these noise
level requirements.
Y
5/20/2005
Page 2
-------
Appendix E
CT DEP Letter of Concurrence
-------
09/30/05 FRI IS;33 FAX 18604244081
Waste Planning
0004
DEPARTMENT OF ENVIRONMENTAL PROTECTION
79 ELM STREET HARTFORD, CT 06106-5127
PHONE: 860-424-3001
STATE OF CONNECTICUT
Gina McCarthy
Commissioner
September 30,2005
Ms. Susan Stud lien
Director
Office of Site Remediation and Restoration
EPA New England
1 Congress Street, Suite 1100 (Mail Code HIO)
Boston MA 02114-2023
Subject; Letter of Partial Concurrence with Proposed Remedy for The Solvents Recovery Service of New
England, Inc. (SRSNE) Site, Southington CT
Dear Ms. Studlien,
The Connecticut Department of Environmental Protection (DEP) has reviewed the remedy being
selected by EPA for the Solvents Recovery Service of New England (SRSNE) site in Southington,
Connecticut. DEP concurs with most components of the selected remedy, but does not concur with the
component of the remedy in which EPA is proposing to address the risk to public health posed by the
volatile organic compounds in shallow ground water that may migrate into existing or future buildings
overlying the ground water plume.
DEP concurs with the following components of the selected remedy which comply with State
ARARS and which will fully protect human health and the environment:
* the in-situ treatment of subsurface source material (non-aqueous phase liquid or NAPL)
in the overburden aquifer beneath the Operations Area
* consolidation and capping of surface source material (contaminated soil and wetland soil)
* maintenance and monitoring of the cap and monitoring of groundwater over the long
term
* capture and on-site treatment of groundwater which exceeds federal safe drinking water
-standards in both the overburden and bedrock aquifers
* monitoring of natural attenuation of NAPL in the deep subsurface (bedrock) and
contaminated groundwater outside the capture zone until cleanup levels are achieved
across the entire Site in an estimated 100 to 200 years.
Further, DEP supports the proposed collection of additional data to delineate the edge of the
shallow groundwater plume. However, DEP does not concur with the vapor intrusion component of the
remedy which proposes a risk assessment on each separate parcel overlying the plume to determine if
volatile organic compounds in groundwater at that portion of the plume exceeds EPA's acceptable risk
range. DEP's position is that, once it has already been demonstrated that volatile organic compounds in
the shallow groundwater plume at the SRSNE site pose risk outside EPA's acceptable risk range,
Connecticut's Remediation Standard Regulations are applicable requirements (ARARs) over the full area!
extent of the shallow groundwater plume (regardless of parcel boundaries) without any additional parcel-
specific risk assessments. If exceedances of the volatilization criteria for groundwater contained in
Connecticut's Remediation Standard Regulations are identified anywhere in the shallow groundwater
-------
09/30/05 FRI 18:33 FAX 18804244081
Waste Planning
0005
Solvents Recovery Service NPL Site
Letter of Partial Concurrence
September 30,2005
Page 2
plume, the action described in the remedy for shallow groundwater (institutional controls to restrict the
construction of buildings into which vapors could migrate) to address this condition should be triggered.
Because of the approach being proposed by EPA for the parcels described above, DEP does not believe
the proposed remedy for vapor intrusion complies with State ARARs for groundwater and we are
concerned that the final remedial actions will not be adequately protective of public health with respect to
vapor intrusion.
However, DEP supports every other component of the remedy, all of which are in compliance
with State ARARS, protective of public health and the appropriate actions necessary to restore an
important drinking water resource in Connecticut
Yours truly,
Commissioner
GM/cal
-------
Appendix F
References
-------
REFERENCES
Agency for Toxic Substance and Disease Registry (ATSDR), United States Public Health
Service, Department of Health and Human Services. Public Health Assessment, Solvents
Recovery Service of New England, Southington, Hartford County, Connecticut,
CERCLIS No. CTD009717604. July 21, 1992.
Blasland, Bouck & Lee, Inc. (BBL). Remedial Investigation Report. June 1998.
Connecticut Department of Environmental Protection (CT DEP). Water Quality
Standards. Surface-Water Quality Standards Effective May 15, 1992.
Connecticut Department of Environmental Protection (CT DEP). Water Quality
Standards. Ground-Water Quality Standards Effective April 12, 1996.
Connecticut Department of Environmental Protection (CT DEP). State of Connecticut
Remediation Standard Regulations. January 1996.
Connecticut Department of Environmental Protection (CT DEP). Groundwater Use and
Value Determination. May 2005.
Halliburton NUS (HNUS) Environmental Corporation. Final Remedial Investigation
Report: Remedial Investigation/Feasibility Study. SRSNE Site, Southington,
Connecticut. May 1994.
United States Environmental Protection Agency (EPA). Preliminary Reuse Assessment,
Solvents Recovery Service of New England, Inc, Southington, Connecticut. September
2003.
-------
Appendix G
Administrative Record Index and Guidance Documents
-------
Solvents Recovery Service of New England
NPL Site Administrative Record
Record of Decision (ROD)
Index
Prepared by
EPA New England
Office of Site Remediation & Restoration
September 2005
-------
Introduction to the Collection
This is the Administrative Record for the Solvents Recovery Service of New England Superfund
site, Southington, CT, Record of Decision (ROD), released September 2005. The file contains
site-specific documents and a list of guidance documents used by EPA staff in selecting a
response action at the site.
This file replaces the administrative record file for the Record of Decision (ROD) Proposed Plan,
released June 2005. This file includes, by reference, the administrative record files for the
Solvents Recovery Service of New England, NPL Site, issued June 26, 1992; NPL Site
Addendum, issued July 9, 1992; NPL Site Addendum issued September 17, 1992; Removal
Action Addition, issued October, 1992; Removal Action III (Laboratory Chemicals), issued
December 1993; DeMinimus Settlement, issued September 29, 1994; Non-Time Critical
Removal Action (NTCRA) #2, issued June, 1995; and DeMinimus Settlement Supplement,
issued September 28, 1995.
The administrative record file is available for review at:
Southington Public Library
225 Main Street
Southington, CT 07489
(860) 628-0947 (phone)
(860) 628-0488 (fax)
http://www.southingtonlibrarv.org/
EPA New England Superfund Records & Information Center
1 Congress Street, Suite 1100 (HSC)
Boston, MA 02114 (by appointment)
617-918-1440 (phone)
617-918-1223 (fax)
www.epa.gov/region01/superfund/resource/records.htm
Questions about this administrative record file should be directed to the EPA New England site
manager. An administrative record file is required by the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA).
Some of the documents in this collection are available as a Portable Document Format (PDF)
file. The PDF process maintains the look and presentation of the original document. To view
PDF files, you will need Adobe Acrobat Reader software loaded on your computer. This
software is available, free of charge, from Adobe Software [this is a link to
http://www.adobe.com1. To ensure you will be able to see a PDF file in its entirety, please obtain
the most recent version of the free Adobe Reader from the Adobe Web site.
(http://www.adobe.com/products/acrobat/readstep.htmn
-------
AR Collection: 3651
OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
10/5/2005
Page 1 of 115
01: SITE ASSESSMENT
6241 POTENTIAL HAZARDOUS WASTE SITE IDENTIFICATION, PRELIMINARY ASSESSMENT (PA), SOLVENTS
RECOVERY SERVICE OF NEW ENGLAND, SOUTHTNGTON (CT)
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
Doc Date: 08/29/1979
File Break: 01.02
# of Pages: 9
5690 HYDROGEOLOGIC INVESTIGATION, SOUTHTNGTON (CT), FINAL DRAFT
Author: WARZYN ENGINEERING INC
Addressee: us EpA REGION 1
Doc Type: REPORT
Doc Date: 11/12/1980 # of Pages: 222
File Break: 01.18
6240 POTENTIAL HAZARDOUS WASTE SITE, SITE INSPECTION REPORT
Author: MARGRET HANLEY ECOLOGY & ENVIRONMENT INC
Addressee: ROBERT OMEARA US EPA REGION 1
Doc Type: REPORT
Doc Date: 05/05/1982 # of Pages: 12
File Break: 01.03
5689 HYDROGEOLOGIC ASSESSMENT REPORT, FINAL
Author: WEHRAN ENGINEERING CORP
Addressee:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: REPORT
Doc Date: 10/01/1982 # of Pages: 56
File Break: 01.18
-------
AR Collection: 3651
OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
02: REMOVAL RESPONSE
6243 ENGINEERING REPORT FOR OFF-SITE GROUNDWATER INTERCEPTOR SYSTEM INCLUDING FINAL
ENGINEERING DRAWINGS AND EQUIPMENT SPECIFICATIONS
Author: LOUREIRO ENGINEERING ASSOCIATES INC
Addressee: YORK WASTEWATER CONSULTANTS INC
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: REPORT
5179 ESTIMATES OF VOLATILE ORGANIC COMPOUNDS CAPTURED BY ON-SITE SYSTEM
Author: LIYANG CHU NUS/TETRA TECH INC
Addressee: MATTHEW R HOAGLAND US EPA REGION 1
Doc Type: LETTER
5094 DOCUMENTATION FOR SHALLOW WELL INTERCEPTOR SYSTEM, INCLUDING TWO TABLES
SUMMARIZING GROUNDWATER LEVELS IN HYDRAULIC VERIFICATION WELLS AND GROUNDWATER
INTERCEPTOR WELLS AND 1 FIGURE DEPICTING GROUNDWATER CONTOURS, ALL BASED ON
Author: SARAH F JOHNSON TRC COMPANIES INC
Addressee: BRIAN NADEAU SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
10/5/2005
Page 2 of 115
Doc Date: 02/28/1984 # of Pages: 28
File Break: 02.06
Doc Date: 02/09/1990 # of Pages: 13
File Break: 02.01
Doc Date: 07/23/1991 # of Pages: 6
File Break: 02.03
Doc Type: LETTER
-------
AR Collection: 3651
OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
10/5/2005
Page 3 of 115
02: REMOVAL RESPONSE
5650 REMOVAL PROGRAM SUPPLEMENTAL SITE INVESTIGATION
Author: ROY F WESTON INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 06/01/1992 # of Pages: 242
File Break: 02.02
8307 REQUEST FOR REMOVAL ACTION AT THE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND SITE
Author: GARY LIPSON US EPA REGION 1
Addressee: JULIE BELAGA US EPA REGION 1
Doc Type: MEMO
Doc Date: 08/28/1992 # of Pages: 13
File Break: 02.09
5562 ENGINEERING EVALUATION / COST ANALYSIS (EE/CA) FOR NON-TIME CRITICAL REMOVAL ACTION
(NTCRA), FINAL
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 12/01/1992
File Break: 02.02
# of Pages: 334
4883 RESPONSIVENESS SUMMARY FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
Doc Date: 04/01/1993 # of Pages: 52
File Break: 02.02
-------
AR Collection: 3651
OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
10/5/2005
Page 4 of 115
02: REMOVAL RESPONSE
8330 REQUEST FOR REMOVAL ACTION AT THE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND SITE
Author: MICHAEL NALIPINSKI US EPA REGION 1
Addressee:
PAULGKEOUGH US EPA REGION 1
Doc Type: MEMO
Doc Date: 04/01/1993 # of Pages: 22
File Break: 02.09
8306 REQUEST FOR REMOVAL ACTION AT THE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND SITE,
ACTION MEMORANDUM
Author: DOROTHY L GIRTEN US EPA REGION 1
Addressee: PAULGKEOUGH US EPA REGION 1
Doc Type: MEMO
Doc Date: 11/08/1993
File Break: 02.09
# of Pages:
5590 ENGINEERING EVALUATION / COST ANALYSIS (EE/CA) REPORT, FOR NON-TIME CRITICAL REMOVAL
(NTCRA) 2, FINAL
Author:
Addressee:
NUS/TETRA TECH INC
US EPA REGION 1
Doc Type: REPORT
Doc Date: 11/01/1994
File Break: 02.02
# of Pages: 392
6258 100% GROUNDWATER CONTAINMENT AND TREATMENT SYSTEM DESIGN REPORT FOR NON-TIME
CRITICAL REMOVAL ACTION (NTCRA) 1
Author: BLASLAND BOUCK & LEE INC
Addressee:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 12/01/1994 # of Pages: 476
File Break: 02.06
Doc Type: REPORT
-------
AR Collection: 3651
OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
10/5/2005
Page 5 of 115
02: REMOVAL RESPONSE
225371 CONCEPTUAL WETLANDS MITIGATION PLAN
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 04/01/1995 # of Pages: 43
File Break: 02.02
6245 DEMONSTRATION OF COMPLIANCE PLAN FOR NON-TIME CRITICAL REMOVAL (NTCRA) 1
Author: BLASLAND BOUCK & LEE INC
Addressee: SRS pRp GROUP
Doc Type: REPORT
Doc Date: 06/01/1995 # of Pages: 113
File Break: 02.06
6259 GROUNDWATER CONTAINMENT AND TREATMENT SYSTEM IMPLEMENTATION WORK PLAN FOR
NON-TIME CRITICAL REMOVAL ACTION (NTCRA) 1
Author:
Addressee:
BLASLAND BOUCK & LEE INC
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: WORK PLAN
Doc Date: 06/01/1995
File Break: 02.06
# of Pages: 18
8308 REQUEST FOR REMOVAL ACTION AT THE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND SITE,
SOUTHINGTON, CT [NON-TIME CRITICAL REMOVAL ACTION (NTCRA) #2]
Author: KELLY S MCCARTY US EPA REGION 1
Addressee:
JOHN P DEVILLARS US EPA REGION 1
Doc Date: 06/01/1995
File Break: 02.09
# of Pages: 48
Doc Type: MEMO
-------
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OU3(SITEWIDE) ROD ADMIN RECORD
AR Collection QA Report
***For External Use***
10/5/2005
Page 6 of 115
02: REMOVAL RESPONSE
4930 NON-TIME CRITICAL REMOVAL ACTION (NTCRA) 1 AS-BUILT DESIGN DOCUMENTS, ATTACHMENTS
2-5, WITH TRANSMITTAL
Author: EDWARD R LYNCH BLASLAND BOUCK & LEE INC
Addressee:
KELLY S MCCARTY US EPA REGION 1
Doc Type: DRAWING
Doc Date: 08/30/1995 # of Pages: 13
File Break: 02.06
4931 NON-TIME CRITICAL REMOVAL ACTION (NTCRA) 1 AS-BUILT DESIGN DOCUMENTS, ATTACHMENT 1
Author: BLASLAND BOUCK & LEE INC
Addressee:
Doc Type: DRAWING
Doc Date: 08/30/1995 # of Pages: 1
File Break: 02.06
225372 DETAILED WETLANDS MITIGATION DESIGN
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 09/01/1995 # of Pages: 66
File Break: 02.02
5334 APPROVAL OF DEMONSTRATION OF COMPLIANCE PLAN 1 FOR NON-TIME CRITICAL REMOVAL
ACTION (NTCRA) 1
Author: KELLY S MCCARTY US EPA REGION 1
Addressee:
A J MOODY SRS PRP GROUP
Doc Type: LETTER
Doc Date: 09/22/1995 # of Pages: 1
File Break: 02.06
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02: REMOVAL RESPONSE
5584 ON-SITE INTERCEPTOR SYSTEM, MONITORING WELL ABANDONMENT ACTIVITIES DURING NON-TIME
CRITICAL REMOVAL ACTION (NTCRA) 1
Author: EDWARD R LYNCH BLASLAND BOUCK & LEE INC
Addressee: KELLY S MCCARTY US EPA REGION 1
Doc Type: LETTER
Doc Date: 10/26/1995 # of Pages: 20
File Break: 02.06
5335 APPROVAL OF DEMONSTRATION OF COMPLIANCE REPORT 2 FOR NON-TIME CRITICAL REMOVAL
ACTION (NTCRA) 1
Author: KELLY S MCCARTY US EPA REGION 1 Doc Date: 11/01/1995 # of Pages: 1
Addressee: A J MOODY SRS PRP GROUP File Break: 02.06
Doc Type: LETTER
5337 DEMONSTRATION OF COMPLIANCE REPORT 3 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 09/01-31/1995
Author:
Addressee:
BLASLAND BOUCK & LEE INC
SRS PRP GROUP
Doc Date: 11/01/1995 # of Pages: 49
File Break: 02.06
Doc Type: REPORT
5585 ON-SITE INTERCEPTOR SYSTEM, MONITORING WELL ABANDONMENT REPORT REVIEWED AND
FOUND ADEQUATE
Author: MARK R LEWIS CT DEPT OF ENVIRONMENTAL PROTECTION Doc Date: 11/06/1995 # of Pages: 1
Addressee: KELLY S MCCARTY US EPA REGION 1 File Break- 02.01
Doc Type: LETTER
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02: REMOVAL RESPONSE
5586 COMMENTS ON ON-SITE INTERCEPTOR SYSTEM AND MONITORING WELL ABANDONMENT DURING
NON-TIME CRITICAL REMOVAL ACTION 1 (NTCRA) REPORT AND PRIVATE WELL MONITORING
REPORT
Author: LIYANG CHU NUS/TETRA TECH INC
Addressee: KELLY S MCCARTY US EPA REGION 1
Doc Type: LETTER
Doc Date: 11/09/1995 # of Pages: 3
File Break: 02.01
5336 APPROVAL OF DEMONSTRATION OF COMPLIANCE REPORT 3 FOR NON-TIME CRITICAL REMOVAL
ACTION (NTCRA) 1
Author: KELLY S MCCARTY US EPA REGION 1 Doc Date: 11/21/1995 # of Pages: 1
Addressee: A J MOODY SRS PRP GROUP File Break: 02.06
Doc Type: LETTER
5338 DEMONSTRATION OF COMPLIANCE REPORT 4 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 11/01-30/1995
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee:
KELLY S MCCARTY US EPA REGION 1
Doc Date: 12/06/1995 # of Pages: 22
File Break: 02.06
Doc Type: REPORT
5339 DEMONSTRATION OF COMPLIANCE REPORT 5 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 12/01-31/1995
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee:
KELLY S MCCARTY US EPA REGION 1
Doc Date: 01/05/1996 # of Pages: 21
File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
5340 DEMONSTRATION OF COMPLIANCE REPORT 6 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 01/01-31/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC Doc Date: 02/06/1996 # of Pages: 21
Addressee: SHEILA M ECKMAN US EPA REGION 1 File Break: 02.06
Doc Type: REPORT
5341 DEMONSTRATION OF COMPLIANCE REPORT 7 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 02/01-01/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC Doc Date: 03/06/1996 # of Pages: 22
Addressee: SHEILA M ECKMAN US EPA REGION 1 File Break- 02.06
Doc Type: REPORT
5342 DEMONSTRATION OF COMPLIANCE REPORT 8 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 03/01-31/1996, LETTER MISDATED, RECEIVED 04/09/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 03/06/1996 # of Pages: 22
File Break: 02.06
5343 DEMONSTRATION OF COMPLIANCE REPORT 9 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 04/01-30/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC Doc Date: 05/06/1996 # of Pages: 22
Addressee: SHEILA M ECKMAN US EPA REGION 1 File Break- 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
5344 DEMONSTRATION OF COMPLIANCE REPORT 10 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 05/01-01/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Date: 06/06/1996
File Break: 02.06
# of Pages: 22
Doc Type: REPORT
5345 DEMONSTRATION OF COMPLIANCE REPORT 11 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 06/01-30/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 07/03/1996 # of Pages: 23
File Break: 02.06
5593 DESIGN AND STUDY WORK PLAN FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA) 2
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 08/01/1996 # of Pages: 61
File Break: 02.06
5346 DEMONSTRATION OF COMPLIANCE REPORT 12 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 07/01-31/1996
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Date: 08/06/1996 # of Pages: 22
File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
5348 DEMONSTRATION OF COMPLIANCE REPORT 13 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 08/01-31/1996
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5349 DEMONSTRATION OF COMPLIANCE REPORT 14 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 09/01-30/1996
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5350 DEMONSTRATION OF COMPLIANCE REPORT 15 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 09/01-31/1996
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5351 DEMONSTRATION OF COMPLIANCE REPORT 16 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 11/01-27/1996
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 09/05/1996 # of Pages: 21
File Break: 02.06
Doc Date: 10/04/1996 # of Pages: 20
File Break: 02.06
Doc Date: 11/06/1996 # of Pages: 21
File Break: 02.06
Doc Date: 12/06/1996 # of Pages: 20
File Break: 02.06
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02: REMOVAL RESPONSE
5352 DEMONSTRATION OF COMPLIANCE REPORT 17 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 11/28-31/1996
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5354 CERTIFICATION STATEMENT FOR DEMONSTRATION OF COMPLIANCE REPORT 18 FOR NON-TIME
CRITICAL REMOVAL ACTION (NTCRA) 1
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5353 DEMONSTRATION OF COMPLIANCE REPORT 18 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 01/01-31/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5355 DEMONSTRATION OF COMPLIANCE REPORT 19 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 02/01-28/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 01/06/1997 # of Pages: 21
File Break: 02.06
Doc Date: 01/06/1997 # of Pages: 2
File Break: 02.06
Doc Date: 02/06/1997 # of Pages: 20
File Break: 02.06
Doc Date: 03/06/1997 # of Pages: 23
File Break: 02.06
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02: REMOVAL RESPONSE
5356 CERTIFICATION STATEMENT FOR DEMONSTRATION OF COMPLIANCE REPORT 19 FOR NON-TIME
CRITICAL REMOVAL ACTION (NTCRA) 1
Author: HANDEX OF NEW ENGLAND INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 03/10/1997 # of Pages: 2
File Break: 02.06
5357 DEMONSTRATION OF COMPLIANCE REPORT 20 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 03/01-31/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 04/04/1997
File Break: 02.06
# of Pages: 21
5658 DEMONSTRATION OF COMPLIANCE REPORT 21 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 04/01-30/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee:
US EPA REGION 1
Doc Date: 05/07/1997 # of Pages: 19
File Break: 02.06
Doc Type: REPORT
5659 DEMONSTRATION OF COMPLIANCE REPORT 22 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 05/01-05/31/1997
Author: GERALD H CRESAP HANDEX OF NEW ENGLAND INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 06/09/1997
File Break: 02.06
# of Pages: 20
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02: REMOVAL RESPONSE
5661 DEMONSTRATION OF COMPLIANCE REPORT 23 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 06/01-30/1997
Author: GERALD H CRESAP HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5358 DEMONSTRATION OF COMPLIANCE REPORT 24 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 07/01-31/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5359 DEMONSTRATION OF COMPLIANCE REPORT 25 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 08/01-31/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5360 DEMONSTRATION OF COMPLIANCE REPORT 26 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 09/01-30/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 07/07/1997 # of Pages: 20
File Break: 02.06
Doc Date: 08/08/1997 # of Pages: 19
File Break: 02.06
Doc Date: 09/08/1997 # of Pages: 18
File Break: 02.06
Doc Date: 10/06/1997 # of Pages: 19
File Break: 02.06
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02: REMOVAL RESPONSE
5361 DEMONSTRATION OF COMPLIANCE REPORT 27 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 10/01-31/1997
Author: HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5662 DEMONSTRATION OF COMPLIANCE REPORT 28 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 11/01-30/1997
Author: GERALD H CRESAP HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5663 DEMONSTRATION OF COMPLIANCE REPORT 29 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 12/01-31/1997
Author: GERALD H CRESAP HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
5664 DEMONSTRATION OF COMPLIANCE REPORT 30 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 01/01-30/1997
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: REPORT
Doc Date: 11/08/1997 # of Pages: 18
File Break: 02.06
Doc Date: 12/05/1997 # of Pages: 18
File Break: 02.06
Doc Date: 01/06/1998 # of Pages: 18
File Break: 02.06
Doc Date: 02/06/1998 # of Pages: 18
File Break: 02.06
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02: REMOVAL RESPONSE
5665 DEMONSTRATION OF COMPLIANCE REPORT 31 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 01/31-02/27/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
Doc Type: REPORT
5667 DEMONSTRATION OF COMPLIANCE REPORT 32 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 03/01-31/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: KAREN LUMINO US EPA REGION 1
Doc Type: REPORT
5668 DEMONSTRATION OF COMPLIANCE REPORT 33 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 04/01-30/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
Doc Date: 03/06/1998 # of Pages: 18
File Break: 02.06
Doc Date: 04/09/1998 # of Pages: 17
File Break: 02.06
Doc Date: 05/07/1998 # of Pages: 20
File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
5669 DEMONSTRATION OF COMPLIANCE REPORT 34 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 05/01-31/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
Doc Type: REPORT
5670 DEMONSTRATION OF COMPLIANCE REPORT 35 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 06/01-30/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
Doc Type: REPORT
5674 DEMONSTRATION OF COMPLIANCE REPORT 36 FOR NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
1, 07/01-30/1998
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
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Doc Date: 06/05/1998 # of Pages: 20
File Break: 02.06
Doc Date: 07/07/1998 # of Pages: 20
File Break: 02.06
Doc Date: 10/07/1998 # of Pages: 25
File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
5676 CERTIFICATION PAGE FOR QUARTERLY DEMONSTRATION OF COMPLIANCE REPORT 36
Author: ELIZABETH M ANDERSON HANDEX OF NEW ENGLAND INC
Addressee:
KAREN LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 10/07/1998 # of Pages: 2
File Break: 02.06
5620 INTERIM MONITORING AND SAMPLING PLAN, 06/1998, REVISED 11/1998
Author: BLASLAND BOUCK & LEE INC
Addressee: SRS pRp GROUP
Doc Type: WORK PLAN
Doc Date: 11/01/1998 # of Pages: 17
File Break: 02.06
5725 NON-TIME CRITICAL REMOVAL ACTION (NTCRA) #2 TECHNICAL MEMORANDUM, FINAL; UPDATED BY
LETTER 05/25/1999, APPROVED BY US EPA 07/08/1999
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Date: 11/24/1998
File Break: 02.02
# of Pages: 135
Doc Type: REPORT
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5678 QUARTERLY DEMONSTRATION OF COMPLIANCE REPORT 37 FOR NON-TIME CRITICAL REMOVAL
ACTION (NTCRA) 1, 10/01-30/1998
Author: JOSEPH LANDWYN HANDEX OF NEW ENGLAND INC
Addressee: CHRISTOPHER P MCCLURE HANDEX OF NEW ENGLAND INC
KAREN LUMINO US EPA REGION 1
Doc Type: REPORT
5644 INTERIM MONITORING AND SAMPLING REPORT 1
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee: KAREN LUMINO US EPA REGION 1
Doc Type: LETTER
5726 RESPONSE TO US EPA COMMENTS REGARDING DRAFT NON-TIME CRITICAL REMOVAL ACTION
(NTCRA), TWO TECHNICAL MEMORANDUM
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee: BYRON MAH US EPA REGION 1
Doc Type: LETTER
Doc Date: 01/07/1999 # of Pages: 26
File Break: 02.06
Doc Date: 02/17/1999 # of Pages: 45
File Break: 02.06
Doc Date: 05/25/1999 # of Pages: 4
File Break: 02.02
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02: REMOVAL RESPONSE
5623 DEMOLITION OF OPERATIONS AREA
Author: DE MAXIMIS INC
Addressee:
Doc Type: REPORT
Doc Date: 07/01/1999 # of Pages: 190
File Break: 02.02
5727 NOTICE OF APPROVAL OF NON-TIME CRITICAL REMOVAL ACTION (NTCRA), TWO TECHNICAL
MEMORANDUM
Author: MARY JANE ODONNELL US EPA REGION 1
Addressee: SRS pRp GROUP
Doc Date: 07/08/1999
File Break: 02.02
# of Pages: 1
Doc Type: LETTER
5645 INTERIM MONITORING AND SAMPLING REPORT 2
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
BYRON MAH US EPA REGION 1
Doc Date: 08/03/1999 # of Pages: 29
File Break: 02.06
Doc Type: LETTER
44020 FINAL NON-TIME CRITICAL REMOVAL ACTION (NTCRA) 2 100% GROUND WATER SYSTEM DESIGN
REPORT
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Date: 11/01/1999 # of Pages: 104
File Break: 02.02
Doc Type: REPORT
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222203 DEMONSTRATION OF COMPLIANCE REPORT #41 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 01/06/2000 # of Pages: 26
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
222204 DEMONSTRATION OF COMPLIANCE REPORT #42 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1, [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 04/07/2000 # of Pages: 25
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
18685 INTERIM MONITORING AND SAMPLING REPORT #4
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee: BYRON MAH US EPA REGION 1
Doc Type: REPORT
Doc Date: 07/05/2000 # of Pages: 29
File Break: 02.06
222205 DEMONSTRATION OF COMPLIANCE REPORT #43 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 07/10/2000 # of Pages: 26
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
222206 DEMONSTRATION OF COMPLIANCE REPORT #44 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 10/21/2000 # of Pages: 27
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
222207 DEMONSTRATION OF COMPLIANCE REPORT #45 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 01/05/2001 # of Pages: 28
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
18686 INTERIM MONITORING AND SAMPLING REPORT #5
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee: BYRON MAH US EPA REGION 1
Doc Type: REPORT
Doc Date: 01/09/2001 # of Pages: 35
File Break: 02.06
222208 DEMONSTRATION OF COMPLIANCE REPORT #46 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC Doc Date: 04/09/2001 # of Pages: 25
Addressee: SRSNE SITE PRP GROUP File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
19238 RESPONSES TO EPA COMMENTS ON THE DRAFT NTCRA 2 100% GROUNDWATER SYSTEM DESIGN
REPORT
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
KAREN LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 05/30/2001 # of Pages: 4
File Break: 02.02
222209 DEMONSTRATION OF COMPLIANCE REPORT #47 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC
Addressee: SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 07/06/2001
File Break: 02.06
# of Pages: 25
222210 DEMONSTRATION OF COMPLIANCE REPORT #48 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL]
Author: HANDEX OF NEW ENGLAND INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 10/08/2001
File Break: 02.06
# of Pages: 26
222211 DEMONSTRATION OF COMPLIANCE REPORT #49 FOR NON-TIME-CRITICAL REMOVAL ACTION
(NTCRA) 1 [WITH TRANSMITTAL DATED 1/8/01 IN ERROR]
Author: HANDEX OF NEW ENGLAND INC
Addressee:
SRSNE SITE PRP GROUP
Doc Date: 01/08/2002 # of Pages: 26
File Break: 02.06
Doc Type: REPORT
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02: REMOVAL RESPONSE
225373 INTERIM MONITORING AND SAMPLING REPORT NO. 7
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: REPORT
Doc Date: 01/09/2002
File Break: 02.06
# of Pages: 35
229273 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 DEMONSTRATION OF COMPLIANCE
REPORT #50, JANUARY 1 THROUGH MARCH 29, 2002, FIRST QUARTER 2002 [WITH TRANSMITTAL
DATED 04/18/2002]
Author:
Addressee:
HANDEX OF NEW ENGLAND INC
SRS PRP GROUP
Doc Type: REPORT
Doc Date: 03/29/2002
File Break: 02.06
# of Pages: 38
229274 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 DEMONSTRATION OF COMPLIANCE
REPORT #51, APRIL 1 THROUGH JUNE 30, 2002, SECOND QUARTER 2002 [WITH TRANSMITTAL DATED
06/10/2002]
Author: HANDEX OF NEW ENGLAND INC
Addressee: SRS pRp GROUP
Doc Type: REPORT
Doc Date: 06/30/2002
File Break: 02.06
# of Pages: 40
229275 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 DEMONSTRATION OF COMPLIANCE
REPORT #52, JULY 1 THROUGH SEPTEMBER 30, 2002, THIRD QUARTER 2002
Author: HANDEX OF NEW ENGLAND INC
Addressee:
SRS PRP GROUP
Doc Date: 09/30/2002
File Break: 02.06
# of Pages: 38
Doc Type: REPORT
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229276 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 DEMONSTRATION OF COMPLIANCE
REPORT #53, OCTOBER 1 THROUGH DECEMBER 31, 2002, FOURTH QUARTER 2002
Author: HANDEX OF NEW ENGLAND INC
Addressee:
SRS PRP GROUP
Doc Type: REPORT
Doc Date: 12/31/2002 # of Pages: 38
File Break: 02.06
229277 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 DEMONSTRATION OF COMPLIANCE
REPORT NO. 54, 1 JANUARY THROUGH 31 MARCH 2003, FIRST QUARTER 2003
Author: WESTON SOLUTIONS INC
Addressee: SRS pRp GROUP
Doc Type: REPORT
Doc Date: 03/31/2003 # of Pages: 41
File Break: 02.06
229278 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 ANNUAL DEMONSTRATION OF
COMPLIANCE REPORT NO. 55, 1 JANUARY THROUGH 31 DECEMBER 2003
Author: WESTON SOLUTIONS INC
Addressee:
SRS PRP GROUP
Doc Type: REPORT
Doc Date: 12/31/2003 # of Pages: 89
File Break: 02.06
229279 INTERIM MONITORING AND SAMPLING REPORT NO. 11
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: REPORT
Doc Date: 01/06/2004
File Break: 02.06
# of Pages: 57
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229280 INTERIM MONITORING AND SAMPLING REPORT NO. 12
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: REPORT
Doc Date: 07/06/2004
File Break: 02.06
# of Pages: 59
229289 NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) NO. 1 AND 2 ANNUAL DEMONSTRATION OF
COMPLIANCE REPORT NO. 56, 1 JANUARY THROUGH 31 DECEMBER 2004
Author: WESTON SOLUTIONS INC
Addressee: SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 12/31/2004 # of Pages: 1
File Break: 02.06
229281 INTERIM MONITORING AND SAMPLING REPORT NO. 13
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: REPORT
Doc Date: 01/06/2005
File Break: 02.06
# of Pages: 59
229285 PROPOSED WORK, CONTINUED OPERATION OF THE COMBINED NON-TIME-CRITICAL REMOVAL
ACTION (NTCRA) 1 AND 2 CONTAINMENT SYSTEMS
Author: ROBERT KIRSCH HALE AND DORR LLP
Addressee:
AUDREY ZUCKER US EPA REGION 1
Doc Date: 02/14/2005 # of Pages: 1
File Break: 02.01
Doc Type: LETTER
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229284 EXTENSION OF OPERATIONS OF NON-TIME-CRITICAL REMOVAL ACTION (NTCRA) CONTAINMENT
SYSTEMS
Author: MARY JANE ODONNELL US EPA REGION 1
Addressee:
ROBERT KIRSCH HALE AND DORR LLP
Doc Date: 02/15/2005 # of Pages: 1
File Break: 02.01
Doc Type: LETTER
6414
03: REMEDIAL INVESTIGATION (RI)
WORK IN SUPPORT OF EPA ENFORCEMENT CASE, CONTAMINATION OF CURTISS STREET WELL
FIELD, SOUTHINGTON, CT, TDD F1-8077-01A, DRAFT
Author: PAUL EXNER ECOLOGY & ENVIRONMENT INC
Addressee:
MERRILL S HOHMAN US EPA REGION 1
Doc Date: 10/31/1980 # of Pages: 148
File Break: 03 .04
Doc Type: REPORT
6413 INFORMATION OBTAINED REGARDING GROUNDWATER CONTAMINATION SOUTHEAST OF
PRODUCTION WELL 4, SOUTHINGTON, CT, TDD Fl-8104-09
Author: MARGRET HANLEY ECOLOGY & ENVIRONMENT INC
Addressee: MICHAEL PARISE US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/27/1981 # of Pages: 4
File Break: 03.01
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03: REMEDIAL INVESTIGATION (RI)
5526 HYDROGEOLOGIC ASSESSMENT REPORT, FINAL
Author: WEHRAN ENGINEERING CORP
Addressee:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: REPORT
Doc Date: 10/01/1982 # of Pages: 55
File Break: 03 .04
5514 ENGINEERING REPORT FOR OFF-SITE GROUNDWATER INTERCEPTOR SYSTEM, ADDENDUM 1
Author: ERM NEW ENGLAND INC
Addressee: YORK WASTEWATER CONSULTANTS INC
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: REPORT
Doc Date: 06/08/1984 # of Pages: 33
File Break: 03 .04
5527 ENGINEERING REPORT FOR OFF-SITE GROUNDWATER INTERCEPTOR SYSTEM, ADDENDUM 1 TO
02/28/1984 SUBMITTAL
Author: YORK WASTEWATER CONSULTANTS INC
Addressee:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 06/22/1984 # of Pages: 64
File Break: 03 .04
Doc Type: REPORT
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03: REMEDIAL INVESTIGATION (RI)
5120 PRELIMINARY HEALTH ASSESSMENT
Author: US PUBLIC HEALTH SERVICE/ATSDR
Addressee:
Doc Type: REPORT
Doc Date: 12/15/1988 # of Pages: H
File Break: 03.09
5538 LABORATORY REPORT OF 16 GROUNDWATER SAMPLES FROM OFF-SITE WELLS, TAKEN ON
05/17-18/1989
Author: KEITH E WARNER YORK WASTEWATER CONSULTANTS INC
Addressee: jAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: LETTER
Doc Date: 06/20/1989 # of Pages: 11
File Break: 03 .02
5535 BIOTOXICITY MONITORING TEST RESULTS, FOR MONITORING DONE 01/15-19/1990, OF PLANT
EFFLUENT AND WATER FROM QUINNIPIAC RIVER
Author: ENVIRONMENTAL SCIENCE CORP
Addressee:
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: REPORT
Doc Date: 01/01/1990
File Break: 03 .02
# of Pages: 20
5528 LABORATORY REPORT FOR WATER SAMPLES TAKEN 01/16/1990 FROM PLANT EFFLUENT AND RIVER
EFFLUENT
Author: ENVIRONMENTAL SCIENCE CORP
Addressee:
PAUL LETENDRE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 01/16/1990
File Break: 03 .02
# of Pages: 10
Doc Type: SAMPLING & ANALYSIS DATA
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03: REMEDIAL INVESTIGATION (RI)
5530 LABORATORY REPORT FOR WATER SAMPLES TAKEN 01/17/1990 FROM PLANT EFFLUENT AND RIVER
EFFLUENT
Author: ENVIRONMENTAL SCIENCE CORP
Addressee:
PAUL LETENDRE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 01/17/1990 # of Pages: 10
File Break: 03 .02
Doc Type: SAMPLING & ANALYSIS DATA
5537 LABORATORY REPORT FOR MONITORING DONE 01/17/1990
Author: ENVIRONMENTAL SCIENCE CORP
Addressee: mjchaEL SUSCA TRC COMPANIES INC
Doc Type: REPORT
Doc Date: 01/17/1990 # of Pages: 15
File Break: 03 .02
5531 LABORATORY REPORT FOR WATER SAMPLES TAKEN 01/18/1990 FROM PLANT EFFLUENT AND RIVER
EFFLUENT
Author: ENVIRONMENTAL SCIENCE CORP
Addressee:
PAUL LETENDRE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 01/18/1990 # of Pages: 11
File Break: 03 .02
Doc Type: SAMPLING & ANALYSIS DATA
5532 LABORATORY REPORT FOR WATER SAMPLES TAKEN 01/19/1990 FROM PLANT EFFLUENT AND RIVER
EFFLUENT
Author: ENVIRONMENTAL SCIENCE CORP
Addressee:
PAUL LETENDRE SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Date: 01/19/1990
File Break: 03 .02
# of Pages: 9
Doc Type: SAMPLING & ANALYSIS DATA
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03: REMEDIAL INVESTIGATION (RI)
5533 TOXICITY REPORT FOR COMPARATIVE TOXICITY TESTING
Author: CAROL E BOWER NEW ENGLAND BIOASSAY INC
Addressee: XHOMAS MCGLOIN ENVIRONMENTAL SCIENCE CORP
Doc Type: LETTER
5002 SAMPLING AND ANALYSIS PLAN FOR REMEDIAL INVESTIGATION / FEASIBILITY STUDY (RI/FS), FINAL
Author: NUS/TETRA TECH INC Doc Date: 05/01/1990 # of Pages: 147
Addressee: US EPA REGION 1 File Break: 03.02
Doc Type: WORK PLAN
5605 TRANSMITTAL FOR ADDENDUM TO PRELIMINARY HEALTH ASSESSMENT BASED ON 05/1990 SAMPLING
DATA
Author: MARTHA DEE KENT US PUBLIC HEALTH SERVICE/ATSDR
Addressee: LOUISE A HOUSE US PUBLIC HEALTH SERVICE/ATSDR
Doc Type: LETTER
5606 ADDENDUM TO PRELIMINARY HEALTH ASSESSMENT BASED ON 05/1990 SAMPLING DATA
Doc Date: 01/25/1990 # of Pages: 34
File Break: 03 .02
Doc Date: 10/15/1990 # of Pages: 1
File Break: 03.01
Author: US PUBLIC HEALTH SERVICE/ATSDR
Addressee:
Doc Type: REPORT
Doc Date:
File Break:
10/15/1990 # of Pages: 6
03.09
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03: REMEDIAL INVESTIGATION (RI)
222216 RESIDENTIAL WELL SAMPLING LISTING, WITH REDACTIONS
Author: LIYANG CHU NUS/TETRA TECH INC
Addressee: MARGARET VELIE US EPA REGION 1
Doc Type: LETTER
Doc Date: 12/18/1990 # of Pages: 4
File Break: 03 .02
5621 SURFACE GEOPHYSICAL SURVEYS
Author: HAGER-RICHTER GEOSCIENCE INC Doc Date: 04/01/1991 # of Pages: 28
Addressee: NUS/TETRA TECH INC File Break: 03.04
Doc Type: REPORT
5200 RESPONSE TO REQUEST FOR INFORMATION REGARDING CONTAMINATION IN GROUNDWATER AND
SURFACE WATER, INCLUDES TWO TABLES
Author: BETSY SHAW US EPA REGION 1 Doc Date: 08/19/1991 # of Pages: 4
Addressee: DARRELL KERN File Break: 03.01
Doc Type: LETTER
5728 PROPOSED TECHNOLOGIES FOR TREATABILITY STUDIES
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 10/01/1991 # of Pages: 47
File Break: 03 .04
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5525 PHASE 2 TECHNICAL MEMORANDUM, FINAL
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 06/01/1992 # of Pages: 538
File Break: 03 .04
5587 SEISMIC REFRACTION SURVEY
Author: HAGER-RICHTER GEOSCIENCE INC
Addressee: NUS/TETRA TECH INC
Doc Type: REPORT
Doc Date: 06/01/1992 # of Pages: 39
File Break: 03 .04
5178 PUBLIC HEALTH ASSESSMENT
Author: US DHHS/US PUBLIC HEALTH SERVICE
Addressee:
Doc Type: REPORT
Doc Date: 07/21/1992 # of Pages: 75
File Break: 03.09
5589 WETLANDS EVALUATION STUDY, TECHNICAL MEMORANDUM, FINAL
Author: NUS/TETRA TECH INC Doc Date: 12/01/1993 # of Pages: 48
Addressee: US EPA REGION 1 File Break: 03.04
Doc Type: REPORT
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03: REMEDIAL INVESTIGATION (RI)
5624 SOIL, GROUNDWATER, ADDITIONAL STUDIES WORK PLAN, FINAL
Author: ENSR CONSULTING & ENGINEERING
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 03/01/1994 # of Pages: 464
File Break: 03 .07
4877 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 1 OF 4, TEXT, FINAL
Author: NUS/TETRA TECH INC
Addressee: us EpA REGION 1
Doc Type: REPORT
Doc Date: 05/01/1994 # of Pages: 462
File Break: 03 .06
4878 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 2 OF 4, TABLES, FINAL
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 05/01/1994 # of Pages: 371
File Break: 03 .06
4879 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 3 OF 4, FIGURES, APPENDIX A OF VOLUME 4 OF 4,
FINAL
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 05/01/1994 # of Pages: 330
File Break: 03 .06
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4880 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 4 OF 4, APPENDICES B THROUGH H, FINAL
Author: NUS/TETRA TECH INC
Addressee:
US EPA REGION 1
Doc Type: REPORT
Doc Date: 05/01/1994 # of Pages: 533
File Break: 03 .06
4875 GROUNDWATER TECHNICAL MEMORANDUM, SOIL STUDY & ADDITIONAL STUDIES REPORT, VOLUME
1, DRAFT
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Type: REPORT
Doc Date: 06/01/1994 # of Pages: 426
File Break: 03 .04
238241 GROUNDWATER TECHNICAL MEMORANDUM, SOILS STUDY, AND ADDITIONAL STUDIES REPORT,
VOLUME 1 - GROUNDWATER TECHNICAL MEMORANDUM
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Type: REPORT
Doc Date: 06/01/1994
File Break: 03 .04
# of Pages: 1
238242 GROUNDWATER TECHNICAL MEMORANDUM, SOILS STUDY, AND ADDITIONAL STUDIES REPORT,
VOLUME 2 - SOILS STUDY REPORT
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Type: REPORT
Doc Date: 06/01/1994
File Break: 03 .04
# of Pages: 1
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03: REMEDIAL INVESTIGATION (RI)
238243 GROUNDWATER TECHNICAL MEMORANDUM, SOILS STUDY, AND ADDITIONAL STUDIES REPORT,
VOLUME 3 - ADDITIONAL STUDIES REPORT
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Date: 06/01/1994
File Break: 03 .04
# of Pages: 1
Doc Type: REPORT
238244 SAMPLE IDENTIFICATION NUMBERS
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Type: MEMO
Doc Date: 11/21/1994 # of Pages: 1
File Break: 03.01
238245 RESULTS OF COMPREHENSIVE GROUNDWATER SAMPLING
Author: ENSR CONSULTING & ENGINEERING
Addressee:
Doc Type: LETTER
Doc Date: 06/19/1995 # of Pages: 1
File Break: 03.01
5648 PRIVATE WELL MONITORING REPORT, ASSOCIATED WITH NON-TIME CRITICAL REMOVAL ACTION
(NTCRA) 1
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Date: 10/01/1995
File Break: 03 .02
# of Pages: 62
Doc Type: REPORT
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5591 REMEDIAL INVESTIGATION (RI) WORK PLAN
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 11/01/1995 # of Pages: 197
File Break: 03 .07
4952 COMMENTS REGARDING REMEDIAL INVESTIGATION WORK PLAN, PREPARED BY BLASLAND, BOUCK
& LEE INC, 11/1995.
Author: MARK R LEWIS CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee:
Doc Type: LETTER
Doc Date: 01/23/1996 # of Pages: 9
File Break: 03 .07
4953 ADDENDUM TO REMEDIAL INVESTIGATION (RI) WORK PLAN IN RESPONSE TO COMMENTS BY
HALLIBURTON NUS, CT DEP AND US EPA
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Date: 02/13/1996 # of Pages: 10
File Break: 03 .07
Doc Type: LETTER
4960 EPA COMMENTS ON DRAFT REMEDIAL INVESTIGATION WORK PLAN & DRAFT PROJECT OPERATIONS
PLAN, ATTACHMENT 1 TO ADDENDUM 2 OF REMEDIAL INVESTIGATION WORK PLAN.
Author: SHEILA M ECKMAN US EPA REGION 1
Addressee: BRUCE R THOMPSON DEMAXIMISINC
Doc Type: LETTER
Doc Date: 04/04/1996 # of Pages: 9
File Break: 03 .07
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4959 ADDENDUM 2 TO REMEDIAL INVESTIGATION (RI) WORK PLAN PREPARED BY BLASLAND, BOUCK &
LEE INC, 11/1995
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
SHEILA MECKMAN US EPA REGION 1
Doc Type: WORK PLAN
Doc Date: 06/07/1996 # of Pages: 10
File Break: 03 .07
4961 ADDENDUM 3 TO REMEDIAL INVESTIGATION (RI) WORK PLAN SUBMITTED BY BLASLAND, BOUCK &
LEE INC, 11/1995
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee: SHEILA M ECKMAN US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/18/1996 # of Pages: 6
File Break: 03 .07
4967 SAMPLING AND ANALYSIS PLAN, PART 1 OF 2, QUALITY ASSURANCE PROJECT PLAN (QAPP)
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 08/01/1996 # of Pages: 247
File Break: 03 .04
4968 SAMPLING AND ANALYSIS PLAN, PART 2 OF 2, FIELD SAMPLING PLAN
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 08/01/1996 # of Pages: 188
File Break: 03 .04
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4969 SITE MANAGEMENT PLAN
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: WORK PLAN
Doc Date: 08/01/1996 # of Pages: 121
File Break: 03 .04
238246 APPROVAL OF REMEDIAL INVESTIGATION WORKPLAN AND DRAFT PROJECT OPERATIONS PLAN
Author: MARY JANE ODONNELL US EPA REGION 1
Addressee: WILLIAM C MORRIS UNITED INDUSTRIAL SERVICES
Doc Type: LETTER
Doc Date: 08/14/1996 # of Pages: 1
File Break: 03.01
5594 CANCER INCIDENCE IN SOUTHINGTON, CT 1968-1991 IN RELATION TO EMISSIONS
Author: CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee: US PUBLIC HEALTH SERVICE/ATSDR
Doc Type: REPORT
Doc Date: 03/01/1997 # of Pages: 73
File Break: 03.09
238247 COMMENTS ON THE DRAFT REMEDIAL INVESTIGATION REPORT
Author: SHEILA M ECKMAN US EPA REGION 1
Addressee: WILLIAM C MORRIS UNITED INDUSTRIAL SERVICES
Doc Type: LETTER
Doc Date: 01/22/1998 # of Pages: 1
File Break: 03 .06
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238248 COMMENTS ON THE DRAFT REMEDIAL INVESTIGATION REPORT
Author: KAREN M LUMINO US EPA REGION 1
Addressee:
WILLIAM C MORRIS UNITED INDUSTRIAL SERVICES
Doc Type: LETTER
Doc Date: 02/27/1998 # of Pages: 1
File Break: 03 .06
4932 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 1 OF 2, TEXT & FIGURES
Author: BLASLAND BOUCK & LEE INC
Addressee: SRS pRp GROUP
Doc Type: REPORT
Doc Date: 06/01/1998 # of Pages: 248
File Break: 03 .06
4933 REMEDIAL INVESTIGATION (RI) REPORT, VOLUME 2 OF 2, APPENDICES
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRS PRP GROUP
Doc Type: REPORT
Doc Date: 06/01/1998 # of Pages: 776
File Break: 03 .06
5647 INTERIM MONITORING AND SAMPLING REPORT 3
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
BYRON MAH US EPA REGION 1
Doc Type: LETTER
Doc Date: 01/05/2000 # of Pages: 28
File Break: 02.06
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03: REMEDIAL INVESTIGATION (RI)
6078 LIST OF DATA VALIDATION REPORTS AVAILABLE FOR REVIEW THROUGH EPA NEW ENGLAND
SUPERFUND RECORDS CENTER
Author:
Addressee:
Doc Type: LIST
Doc Date: 05/03/2000 # of Pages: 3
File Break: 03 .02
04: FEASIBILITY STUDY (FS)
238250 FIRST DRAFT FEASIBILITY STUDY, VOLUMES 1, 2 & 3
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 11/01/1998 # of Pages: 1
File Break: 04.06
238251 FIRST DRAFT FEASIBILITY STUDY, APPENDICES
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 11/01/1998 # of Pages: 1
File Break: 04.06
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5622 PROPOSAL AND RATIONAL REGARDING GROUNDWATER BACKGROUND LOCATION, WITH
ATTACHMENTS
Author: GARY R CAMERON BLASLAND BOUCK & LEE INC
Addressee:
MARTIN M BESKIND CT DEPT OF ENVIRONMENTAL PROTECTION
Doc Type: LETTER
Doc Date: 07/27/1999 # of Pages: 38
File Break: 04.01
6759
REMEDY IMPLEMENTATION RISK EVALUATION
Author: ENVIRON CORP
Addressee: SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 11/01/1999 # of Pages: 431
File Break: 04.06
238252 EPA ELIMINATES SOIL EXCAVATION FROM FEASIBILITY STUDY
Author: BRUCE R THOMPSON DE MAXIMIS INC
Addressee:
BLASLAND BOUCK & LEE INC
Doc Type: MEMO
Doc Date: 02/28/2000 # of Pages: 1
File Break: 04.01
238253 TRANSMITTAL OF NOTES ON THE 2/1/00 MEETING SRSNE INC RI/FS OVERSIGHT RAC
Author: LIYANG CHU TETRA TECH NUS INC
Addressee:
BYRON MAH US EPA REGION 1
Doc Type: LETTER
Doc Date: 03/06/2000 # of Pages: 1
File Break: 04.01
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238254 SECOND DRAFT FEASIBILITY STUDY VOLUMES 1, 2 & 3
Author: BLASLAND BOUCK & LEE INC
Addressee:
SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 06/01/2000
File Break: 04.06
# of Pages: 1
238255 SECOND DRAFT FEASIBILITY STUDY APPENDICES
Author: BLASLAND BOUCK & LEE INC
Addressee: SRSNE SITE PRP GROUP
Doc Type: REPORT
Doc Date: 06/01/2000
File Break: 04.06
# of Pages: 1
238256 EXPRESSION OF DISAPPOINTMENT IN EPA'S CHANGE IN APPROACH TO SITE CONDITIONS
Author: ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR
Addressee: SRSNE SITE PRP GROUP
MARY JANE ODONNELL US EPA REGION 1
Doc Date: 01/26/2001 # of Pages: 1
File Break: 04.01
Doc Type: LETTER
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04: FEASIBILITY STUDY (FS)
238257 RESPONSE TO LETTER EXPRESSING DISAPPOINTMENT IN EPA'S CHANGE IN APPROACH TO SITE
CONDITIONS
Author: GRETCHEN MUENCH US EPA REGION 1
Addressee: ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR
Doc Type: LETTER
238258 RESPONSE TO PRELIMINARY EPA/CTDEP COMMENTS ON THE JUNE 2000 DRAFT FEASIBILITY STUDY
Author: SRSNE SITE PRP GROUP
Addressee:
Doc Type: MISC
238259 DISTINGUISHING OUTEWASH, ABLATION TILL AND BASAL TILL WITHIN THE SRSNE SITE POTENTIAL
OVERBURDEN NAPL ZONE
Author: SRSNE SITE PRP GROUP
Addressee:
Doc Type: MISC
238260 TABLE - DRAFT FEASIBILITY STUDY - REMEDIAL ACTION OBJECTIVES, GENERAL RESPONSE
ACTIONS, TECHNOLOGY TYPES AND PROCESS OPTIONS
Author: SRSNE SITE PRP GROUP
Addressee:
10/5/2005
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Doc Date: 02/26/2001 # of Pages: 1
File Break: 04.01
Doc Date: 11/01/2001 # of Pages: 1
File Break: 04.06
Doc Date: 08/21/2002 # of Pages: 1
File Break: 04.06
Doc Date: 07/11/2003 # of Pages: 1
File Break: 04.06
Doc Type: MISC
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04: FEASIBILITY STUDY (FS)
238261 TABLE - DRAFT FEASIBILITY STUDY - IDENTIFICATION AND SCREENING OF REMEDIAL
TECHNOLOGIES AND PROCESS OPTIONS FOR SATURATED SOILS CONTAINING NAPL
Author: SRSNE SITE PRP GROUP
Addressee:
Doc Date: 08/12/2003 # of Pages: 1
File Break: 04.06
Doc Type: MISC
238262 TABLE - DRAFT FEASIBILITY STUDY - SUMMARY OF DETAILED EVALUATION CRITERIA
Author: SRSNE SITE PRP GROUP
Addressee:
Doc Type: MISC
Doc Date: 08/20/2003 # of Pages: 1
File Break: 04.06
238263 TABLE - INITIAL SCREENING OF ALLTERNATTVES - RISKS POSED, PRINCIPLE THREATS, REMEDIAL
ACTION OBJECTIVES AND RELATED PROCESS OPTIONS
Author: SRSNE SITE PRP GROUP
Addressee:
Doc Type: MISC
Doc Date: 08/20/2003 # of Pages: 1
File Break: 04.06
222219 PRELIMINARY REUSE ASSESSMENT
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
Doc Date:
File Break:
09/01/2003 # of Pages: 35
04.06
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04: FEASIBILITY STUDY (FS)
229282 NAPL DELINEATION PILOT STUDY SCOPE
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: REPORT
Doc Date: 10/24/2003 # of Pages: 23
File Break: 04.06
238264 TABLE - REVISED PRINCIPLE AND REMEDIAL ACTION OBJECTIVES
Author: US EPA REGION 1
Addressee:
Doc Type: MISC
Doc Date: 11/13/2003 # of Pages: 1
File Break: 04.06
225370 NAPL DELINEATION PILOT STUDY
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee: KAREN M LUMINO US EPA REGION 1
Doc Type: MEMO
238272 THIRD DRAFT FEASIBILITY STUDY REPORT, VOLUME 1
Doc Date: 12/12/2003 # of Pages: 1
File Break: 04.06
Author: BLASLAND BOUCK & LEE INC
Addressee:
Doc Type: REPORT
Doc Date:
File Break:
06/01/2004 # of Pages: 1
04.06
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04: FEASIBILITY STUDY (FS)
238273 THIRD DRAFT FEASIBILITY STUDY REPORT, APPENDICES
Author: BLASLAND BOUCK & LEE INC
Addressee:
Doc Date: 06/01/2004
File Break: 04.06
# of Pages: 1
Doc Type: REPORT
238265 COST EXPERIENCE UTILIZING IN SITU THERMAL PROCESS TO ADDRESS CHLORINATED SOLVENT
ORGANIC COMPOUND (CVOC) CONTAMINATION
Author: JIM CUMMINGS US EPA - OFFICE OF EMERGENCY & REMEDIAL RESPONSE
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Date: 10/05/2004
File Break: 04.01
# of Pages: 1
Doc Type: MEMO
238266 COMMENTS ON THE DRAFT FEASIBILITY STUDY
Author: EVA L DAVIS US EPA
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Date: 10/07/2004
File Break: 04.06
# of Pages: 1
Doc Type: MEMO
238267 ELECTRICAL RESISTANCE HEATING TECHNOLOGY SCREENING REPORT, SOLVENTS RECOVERY
SERVICE OF NEW ENGLAND SUPERFUND SITE
Author: THERMAL REMEDIATION SERVICES
Addressee:
Doc Type: REPORT
Doc Date: 11/04/2004 # of Pages: 1
File Break: 04.06
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04: FEASIBILITY STUDY (FS)
238268 ASSESSMENT REPORT ON THE VIABILITY OF IN-SITU THERMAL TREATMENT, SOLVENTS RECOVERY
SERVICE OF NEW ENGLAND SUPERFUND SITE
Author: TETRA TECH NUS INC
Addressee:
Doc Type: REPORT
10/5/2005
Page 48 of 115
Doc Date: 11/22/2004 # of Pages: 1
File Break: 04.06
238289 FOCUSED GROUNDWATER SAMPLING PROGRAM
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 02/04/2005 # of Pages: 3
File Break: 04.02
238269 SRSNE PRP GROUP EXPRESSES CONCERNS ABOUT THE PROCESS OF FINALIZING THE FEASIBILITY
STUDY AND SELECTING A REMEMDY FOR THE SITE
Author: CYNTHIA V BAILEY GEORGIA-PACIFIC CORP
Addressee: ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR
SRSNE SITE PRP GROUP
MARY JANE ODONNELL US EPA REGION 1
Doc Date: 02/23/2005 # of Pages: 1
File Break: 04.06
Doc Type: LETTER
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04: FEASIBILITY STUDY (FS)
238270 RESPONSE TO SRSNE PRP GROUP'S EXPRESSION OF CONCERNS ABOUT THE PROCESS OF FINALIZING
THE FEASIBILITY STUDY AND SELECTING A REMEMDY FOR THE SITE
Author: MARY JANE ODONNELL US EPA REGION 1
Addressee: CYNTHIA V BAILEY GEORGIA-PACIFIC CORP
ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR
SRSNE SITE PRP GROUP
Doc Type: LETTER
238271 RESPONSE TO EPA'S 2/25/04 LETTER TO SRSNE PRP GROUP
Doc Date: 02/25/2005 # of Pages: 1
File Break: 04.06
Author: CYNTHIA V BAILEY GEORGIA-PACIFIC CORP
Addressee: ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR
SRSNE SITE PRP GROUP
MARY JANE ODONNELL US EPA REGION 1
Doc Date: 03/07/2005
File Break: 04.06
# of Pages: 1
Doc Type: LETTER
222220 DRAFT FEASIBILITY STUDY (FS) REPORT
Author:
Addressee:
Doc Type: REPORT
Doc Date:
File Break:
05/01/2005 # of Pages: 1
04.06
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04: FEASIBILITY STUDY (FS)
229296 PROPOSED PLAN
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
222217 GROUNDWATER USE AND VALUE DETERMINATION
Author: CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee:
Doc Type: REPORT
229305 CT DEP REQUEST FOR CLARIFICATION OF EPA'S RECENT APPLICABLE OF RELEVANT AND
APPROPRIATE REQUIREMENTS (ARAR) INTERPRETATION
Author: CHRIS LACAS CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: MEMO
229306 EPA'S POSITION REGARDING THE CONNECTICUT REMEDIATION STANDARD REGULATIONS (RSRS) AS
APPLICABLE OF RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
Author: GRETCHEN MUENCH US EPA REGION 1
Addressee: KAREN MLUMINO US EPA REGION 1
10/5/2005
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Doc Date: 05/01/2005 # of Pages: 1
File Break: 04.09
Doc Date: 05/12/2005 # of Pages: 19
File Break: 04.06
Doc Date: 05/24/2005 # of Pages: 1
File Break: 04.05
Doc Date: 06/01/2005 # of Pages: 1
File Break: 04.05
Doc Type: MEMO
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04: FEASIBILITY STUDY (FS)
238237 REQUEST FOR EXTENSION OF PUBLIC COMMENT PERIOD
Author: ROBERT C KIRSCH WILMER CUTLER PICKERING HALE & DORR Doc Date: 06/24/2005 # of Pages: 1
Addressee: MARY JANE ODONNELL US EPA REGION 1 File Break: 04.09
Doc Type: LETTER
238290 RESULTS OF BACKGROUND GROUNDWATER INVESTIGATION FOR METALS
Author: MICHAEL J GEFELL BLASLAND BOUCK & LEE INC
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 08/16/2005 # of Pages: 7
File Break: 04.02
238293 COMMENTS ON BACKGROUND SAMPLING INFORMATION
Author: STEPHEN MANGION US EPA REGION 1
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: MEMO
Doc Date: 09/12/2005 # of Pages: 2
File Break: 04.01
238292 VAPOR INTRUSION ISSUES AT SRSNE SITE
Author: SARAH LEVENSON
Addressee:
Doc Type: MEMO
US EPA REGION 1
Doc Date:
File Break:
09/30/2005 # of Pages: 1
04.01
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04: FEASIBILITY STUDY (FS)
238294 COMMENTS ON BACKGROUND SAMPLING INFORMATION
Author: MARTIN M BESKIND CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: MEMO
05: RECORD OF DECISION (ROD)
238231 COMMENTS ON THE PROPOSED PLAN
Author: SEVERINO V BO VINO SOUTHINGTON (CT) RESIDENT
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: LETTER
238234 COMMENTS ON THE PROPOSED PLAN
Author: VICTOR ZAGER SOUTHINGTON (CT) RESIDENT
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 10/03/2005 # of Pages: 1
File Break: 04.01
Doc Date: 07/01/2005 # of Pages: 1
File Break: 05.03
Doc Date: 07/01/2005 # of Pages: 1
File Break: 05.03
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05: RECORD OF DECISION (ROD)
238236 COMMENTS ON THE PROPOSED PLAN
Author: MICHELLE ALLAIRE SOUTHINGTON (CT) RESIDENT
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/01/2005 # of Pages: 2
File Break: 05.03
238233 COMMENTS ON THE PROPOSED PLAN
Author: IRENE AHERN NAJARIAN SOUTHINGTON (CT) RESIDENT
Addressee: KAREN M LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/07/2005 # of Pages: 4
File Break: 05.03
238235 COMMENTS ON THE PROPOSED PLAN
Author: KELLY BRAYFIELD SOUTHINGTON (CT) RESIDENT
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/11/2005 # of Pages: 1
File Break: 05.03
238238 COMMENTS ON THE PROPOSED PLAN, INCLUDES CD-ROM
Author: BRUCE R THOMPSON DE MAXIMIS INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/25/2005 # of Pages: 10
File Break: 05.03
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05: RECORD OF DECISION (ROD)
238230 STATE COMMENTS ON THE PROPOSED PLAN
Author: ELSIE PATTON CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee:
MARY JANE ODONNELL US EPA REGION 1
Doc Type: LETTER
Doc Date: 08/05/2005 # of Pages: 2
File Break: 05.03
238232 COMMENTS ON THE PROPOSED PLAN
Author: MANI TUCCITTI SOUTEHNGTON (CT) RESIDENT
Addressee: KAREN MLUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 08/08/2005 # of Pages: 1
File Break: 05.03
238239 COMMENTS ON THE PROPOSED PLAN
Author: BRUCE R THOMPSON DE MAXIMIS INC
Addressee:
KAREN M LUMINO US EPA REGION 1
Doc Type: LETTER
Doc Date: 08/08/2005 # of Pages: 121
File Break: 05.03
238285 RECORD OF DECISION
Author: US EPA REGION 1
Addressee:
Doc Type: REPORT
Doc Type: RECORD OF DECISION
Doc Date: 09/30/2005 # of Pages: 379
File Break: 05 .04
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10: ENFORCEMENT/NEGOTIATION
6746 CONSENT DECREE, CIVIL ACTION H-79-704 (JAC), CT FUND FOR THE ENVIRONMENT INC,
SOUTHINGTON CITIZENS' ACTION GROUP, EDWARD AVERY, JOAN BRADLEY
Author: US EPA REGION 1
Addressee:
Doc Type: LITIGATION
4891 REQUEST FOR INFORMATION, INCLUDES LIST OF RECIPIENTS [AVAILABLE ON MICROFILM AT EPA
SUPERFUND RECORDS CENTER]
Author: MERRILL S HOHMAN US EPA REGION 1
Addressee:
Doc Type: LETTER
222233 DE MINIMIS SETTLEMENT OFFER
Author: JACK LOONEY CT OFFICE OF THE ATTORNEY GENERAL Doc Date: 04/19/1994 # of Pages: 159
Addressee: GRETCHEN MUENCH US EPA REGION 1
File Break: 10.05
LLOYD SELBST US EPA REGION 1
US EPA REGION 1
SRSNE DEMINIMIS PARTIES
10/5/2005
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Doc Date: 02/23/1983 # of Pages: 30
File Break: 10.08
Doc Date: 12/07/1992 # of Pages: 1
File Break: 10.05
Doc Type: LITIGATION
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10: ENFORCEMENT/NEGOTIATION
4886 CONSENT DECREE AT FILING, CA H-79-704 (JAC), CA H-90-598 (JAC)
Author: US DEPT OF JUSTICE
Addressee: US EPA REGION 1
Doc Type: LITIGATION
6767 ADMINISTRATIVE ORDER ON CONSENT FOR REMOVAL ACTION, US EPA REGION 1 CERCLA DOCKET
1-94-1045, WITH APPENDICES A AND B
Author: JOHN P DEVILLARS US EPA REGION 1
Addressee:
Doc Type: LITIGATION
6760 ADMINISTRATIVE ORDER ON CONSENT FOR REMOVAL ACTION AND REMEDIAL INVESTIGATION /
FEASIBILITY STUDY (RI/FS), US EPA REGION 1 CERCLA DOCKET 1-97-1000
Author: LINDA M MURPHY US EPA REGION 1
Addressee:
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Doc Date: 09/16/1994 # of Pages: 54
File Break: 10.08
Doc Date: 09/18/1994 # of Pages: 121
File Break: 10.07
Doc Date: 02/06/1997 # of Pages: 105
File Break: 10.07
Doc Type: LITIGATION
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11: POTENTIALLY RESPONSIBLE PARTY
4896 MASTER NOTICE LETTER TO GENERATORS, NOTICE OF POTENTIAL LIABILITY AND REQUEST FOR
PARTICIPATION IN CLEANUP ACTIVITIES
Author: MERRILL S HOHMAN US EPA REGION 1
Addressee:
Doc Type: LETTER
10/5/2005
Page 57 of 115
Doc Date: 06/11/1992 # of Pages: 6
File Break: 11 05
6747 MODEL INVITATION TO PERFORM OR FINANCE A REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) AND NON-TIME-CRITICAL REMOVAL ACTION (NTCRA), NOTICE OF DECISION NOT TO USE
SPECIAL NOTICE PROCEDURES
Author: LINDA M MURPHY US EPA REGION 1
Addressee:
Doc Type: LETTER
Doc Date: 06/16/1995
File Break: 11 05
# of Pages: V
13: COMMUNITY RELATIONS
5066 SOUTHINGTON CANCER CLUSTER HEALTH STUDY PRELIMINARY INVESTIGATION
Author: CT DEPT OF HEALTH SERVICES
Addressee:
Doc Type: FACT SHEET
Doc Date:
File Break:
01/01/0001 # of Pages: 1
13.05
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13: COMMUNITY RELATIONS
5111 SOLVENTS RECOVERY BREAKS CLEANUP TIMETABLE
Author: CHRISTIAN WIHTOL MERIDEN RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/01/0001 # of Pages: 2
File Break: 13.03
5186 PRESS RELEASE CONCERNING CONSENT DECREE RESOLVING A LAW SUIT
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 01/01/0001 # of Pages: 1
File Break: 13.03
5438 RESIDENT WARNED ON WATER USE; CHEMICAL DEGREASER REGISTERS AS STATE TESTS PRIVATE
WELLS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/01/0001 # of Pages: 2
File Break: 13.03
6712 CHANGES IN EPA'S SUPERFUND MAY REDUCE WORK FOR LAWYERS
Author: LESLIE BROBERG PROVIDENCE (RI) BUSINESS NEWS
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/01/0001 # of Pages: 1
File Break: 13.03
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13: COMMUNITY RELATIONS
5105 DRINKING WATER TESTS FIND CANCER-CAUSING CHEMICALS, TEN OF TWO HUNDRED DRINKING
WATER SUPPLIES CONTAIN ORGANIC CHEMICALS THAT COULD CAUSE CANCER AFTER PROLONGED
EXPOSURE
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5104 DISCUSSION OF MEETING ON SOUTHINGTON (CT) PUBLIC WELL CONTAMINATION
Author: MELVIN J SCHNEIDERMEYER CT DEPT OF ENVIRONMENTAL PROTECTION
Addressee: STEPHEN ELLS US EPA REGION 1
Doc Type: LETTER
5103 CONCERN OVER SOUTHINGTON (CT) WATER SUPPLY
Author: JOANNE FOSTER SOUTHINGTON CITIZENS ACTION GROUP [SRS]
Addressee: STEPHEN ELLS US EPA REGION 1
Doc Type: LETTER
5107 CITIZEN ACTION GROUPS URGE A STRONG STAND BY EPA TO PREVENT CONTINUED
CONTAMINATION IN SOUTHINGTON (CT)
Author: WANDA A RICKERBY CONNECTICUT ENVIRONMENTAL CAUCUS
Addressee: LESLffi CAROTHERS CT DEPT OF ENVIRONMENTAL PROTECTION
Doc Type: LETTER
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Doc Date: 03/07/1979 # of Pages: 1
File Break: 13.03
Doc Date: 04/27/1979 # of Pages: 2
File Break: 13.01
Doc Date: 05/13/1979 # of Pages: 2
File Break: 13.01
Doc Date: 08/16/1979 # of Pages: 2
File Break: 13.01
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13: COMMUNITY RELATIONS
5187 ANNOUNCEMENT THAT EPA HAS FILED A CIVIL COMPLAINT AGAINST SOLVENTS RECOVERY
SERVICE INC & LORI ENGINEERING CO, UNDER RCRA
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 12/17/1979 # of Pages: 1
File Break: 13.03
5115 SOLVENTS RECOVERY ASKS PERMISSION TO DISCHARGE WASTE-WATER INTO RIVER
Author: E JEAN NICHOLS SOUTHINGTON NEWS
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/22/1984 # of Pages: 1
File Break: 13.03
5113 SOLVENTS' PLANS DRAW OPPOSITION
Author:
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/26/1984 # of Pages: 2
File Break: 13.03
5109 REQUEST FOR HELP FOR PEOPLE LIVING NEAR SITE
Author: SIGMUND YORSKI
Addressee:
US EPA REGION 1
Doc Type: LETTER
Doc Date: 11/19/1984 # of Pages: 2
File Break: 13.01
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5188 CONSTRUCTION TO BEGIN ON GROUNDWATER CLEANUP SYSTEM AT SOUTHTNGTON HAZARDOUS
WASTE SITE
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 11/21/1984 # of Pages: 2
File Break: 13.03
5108 EPA MONITORING PROGRESS AT SITE, MEETING SCHEDULED TO DISCUSS CLEANUP STEPS
Author: PATRICK A PARENTEAU USEPAREGION1 DocDate: 11/27/1984 #ofPages: 1
Addressee: siGMUND YORSKI File Break: 13.01
Doc Type: LETTER
5189 CONSTRUCTION OF WELLS COMPLETE AT SOUTHTNGTON HAZARDOUS WASTE SITE
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
DocDate: 05/21/1985 # of Pages: 2
File Break: 13.03
5190 GROUNDWATER CLEANUP BEGINS AT SOUTHTNGTON HAZARDOUS WASTE SITE
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date:
File Break:
12/20/1985 # of Pages: 2
13.03
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13: COMMUNITY RELATIONS
5100 SUGGESTS SENDING CANCER INCIDENCE STUDY TO BOSTON UNIVERSITY SCHOOL OF PUBLIC
HEALTH
Author: JOHN R PODGURSKI US EPA REGION 1
Addressee: marje tuCCITTO SAFE [SRS] SOUTfflNGTON ASSOCIATION FOR THE ENVIRONMENT
Doc Type: LETTER
Doc Date: 03/21/1989 # of Pages: 1
File Break: 13.01
5116 RESPONSE TO REQUEST FOR INFORMATION, WITH SITE DESCRIPTION ATTACHED
Author: MARGARET LESHEN US EPA REGION 1
Addressee: JAMES GRIFFIN
Doc Type: LETTER
Doc Date: 11/08/1989 # of Pages: 2
File Break: 13.01
5101 HAND-DRAWN MAP SHOWING INCIDENCE OF CANCER IN SOUTfflNGTON (CT) AREA, WITH
HANDWRITTEN TRANSMITTAL
Author: MARIE TUCCITTO SAFE [SRS] SOUTfflNGTON ASSOCIATION FOR THE ENVIRONMENT
Addressee:
US EPA REGION 1
Doc Date: 04/03/1990
File Break: 13.01
# of Pages: 2
Doc Type: LETTER
5203 TOWN REACTS TO INQUIRY, RESIDENTS AWAITING MORE INFORMATION ABOUT CANCER CASES
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
06/01/1990 # of Pages: 1
13.03
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13: COMMUNITY RELATIONS
5216 CANCER STUDY GETS HEAVY RESPONSE
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 06/01/1990 # of Pages: 1
File Break: 13.03
5202 POSSIBLE ENVIRONMENT LINK TO BE STUDIED IN SOUTHINGTON CANCER CASES; HIGH CANCER
DRAWS STATE ATTENTION
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 06/11/1990 # of Pages: 2
File Break: 13.03
5204 TIMES GOES BY SO SLOWLY AND POISON CAN DO SO MUCH
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 06/13/1990 # of Pages: 1
File Break: 13.03
5205 OFFICIALS SEEK ANSWERS TO CANCER CASES, EPIDEMIOLOGIST AND RESIDENTS MEET TO DISCUSS
CANCER CLUSTER
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Date: 06/14/1990
File Break: 13.03
# of Pages: 2
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5206 RESIDENTS FEAR WATER-CANCER LINK, RESIDENTS ASK ASSURANCE ON DRINKING WATER SAFETY,
NEWS REPORT OF PUBLIC MEETING
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5207 SOUTHINGTON GROUP WANTS FACTS ON ALLEGED HIGH CANCER RATE. RESIDENTS FEAR
CHEMICAL CONTAMINATION OF WATER SUPPLY MAY HAVE CAUSED PROBLEM
Author: WATERBURY REPUBLICAN AMERICAN
Addressee:
Doc Type: NEWS CLIPPING
5208 TEST SET FOR WELLS IN SOUTHINGTON, STATE AND LOCAL OFFICIALS WILL RANDOMLY SELECT
AND TEST RESIDENTIAL WELLS FOR POSSIBLE CONTAMINANTS
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
5209 SEARCHING FOR ANSWERS IN SOUTHINGTON, PROOF LINKING CANCER TO POLLUTION ELUSIVE,
DELAYS IN CLEANUP FRUSTRATE NEIGHBORS, TWO ARTICLES
Author: HARTFORD COURANT
Addressee:
10/5/2005
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Doc Date: 06/17/1990 # of Pages: 4
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5210 STATE PROBES SOUTHTNGTON CANCERS
Author:
Addressee:
Doc Type: NEWS CLIPPING
5211 FIVE WELLS TESTED IN CANCER INQUIRY, SAMPLES TAKEN FROM PRIVATE WELLS NEAR CHEMICAL
RECYCLING COMPANY
Author:
Addressee:
Doc Type: NEWS CLIPPING
5213 STATE SAYS COMPANY DISCHARGED UNTREATED WASTE WATER INTO RIVER, SRS CHARGED WITH
VIOLATING WATER DISCHARGE PERMIT
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5215 CITIZEN'S GROUP TO FIGHT SOLVENTS, CITIZENS' ACTION GROUP, SOUTHINGTON OPPOSING
SOLVENTS, WILL APPLY FOR A TECHNICAL ASSISTANCE GRANT
Author: NEW BRITAIN HERALD
Addressee:
10/5/2005
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File Break: 13.03
Doc Date: 06/27/1990 # of Pages: 1
File Break: 13.03
Doc Date: 06/29/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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***For External Use***
13: COMMUNITY RELATIONS
5064 PRESS CONFERENCE INFORMATION
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
5065 EPA BEGINS REMEDIAL INVESTIGATION (RI), DESCRIPTION OF REMEDIAL INVESTIGATION (RI) /
FIELD STUDIES, WITH BACKGROUND INFORMATION ON SITE, INCLUDES ANNOUNCEMENT OF PUBLIC
MEETING
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
5191 MEDIA ADVISORY CONCERNING A PRESS CONFERENCE TO BE HELD TO ANNOUNCE LAW SUIT
AGAINST SOLVENTS RECOVERY SERVICE, DRAFT
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
5826 INFORMATION ABOUT CANCER CLUSTERS
Author: CT DEPT OF PUBLIC HEALTH
Addressee: BETSY SHAW US EPA REGION 1
Doc Type: FACT SHEET
10/5/2005
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Doc Date: 07/01/1990 # of Pages: 1
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Doc Date: 07/01/1990 # of Pages: 2
File Break: 13.05
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13: COMMUNITY RELATIONS
5117 REQUEST FOR INFORMATION ABOUT SITE AND FOR COPIES OF DOCUMENTS
Author: MARIE TUCCITTO SAFE [SRS] SOUTfflNGTON ASSOCIATION FOR THE ENVIRONMENT
Addressee:
US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/10/1990
File Break: 13.01
# of Pages: 1
5217 RESIDENTS ASK FOR COUNCIL'S SUPPORT IN OPPOSING SRS, CITIZENS SEEKHELP IN OPPOSING
RENEWAL OF SRS OPERATING PERMIT
Author: SOUTEHNGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/12/1990 # of Pages: 1
File Break: 13.03
5068 EPA ANNOUNCES PUBLIC MEETING TO DESCRIBE FIELD TESTING
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 07/13/1990
File Break: 13.03
# of Pages: 2
5192 EPA ANNOUNCES PUBLIC MEETING TO DESCRIBE FIELD TESTING AT SOLVENTS RECOVERY SERVICE
SUPERFUND SITE IN SOUTfflNGTON (CT) STATUS OF RCRA PERMIT APPLICATION WILL ALSO BE
DISCUSSED
Author: US EPA REGION 1
Addressee:
Doc Date: 07/13/1990
File Break: 13.03
# of Pages: 2
Doc Type: PRESS RELEASE
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13: COMMUNITY RELATIONS
5218 TOWN TO MAKE SOLVENTS SUIT DECISION AFTER JULY 26, BOARD OF WATER COMMISSIONERS Wil l,
WAIT UNTIL AFTER A MEETING WITH EPA BEFORE DECIDING WHETHER TO TAKE LEGAL ACTION
AGAINST SOLVENTS RECOVERY SERVICE OF NEW ENGLAND INC
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/13/1990
File Break: 13.03
# of Pages: 1
5067 INVITATION TO PUBLIC MEETING ON REMEDIAL INVESTIGATION / FEASIBILITY STUDY (RI/FS) AND
RCRA PERMIT RENEWAL ISSUES
Author: MARGARET LESHEN US EPA REGION 1
Addressee: CT DEpT qf ENVIRONMENTAL PROTECTION
CT OFFICE OF THE ATTORNEY GENERAL
US PUBLIC HEALTH SERVICE/ATSDR
Doc Date: 07/16/1990
File Break: 13.01
# of Pages: 1
Doc Type: MEMO
5219 TOWN LOOKS FOR FEDERAL CLEANUP; CITIZENS' GROUP UNHAPPY WITH PLANS FOR
CHEMICAL-RECYCLING PLANT
Author: HARTFORD COURANT
Addressee:
Doc Date: 07/17/1990
File Break: 13.03
# of Pages: 1
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5220 OFFICIALS WANT TO PRESSURE SOLVENTS ON WASTE CLEANUP, MEMBERS OF SOUTHTNGTON
OPPOSING SOLVENTS CLAIM THAT SRSNE IS NOT LIVING UP TO ITS END OF CONSENT DECREE
SIGNED IN 1982
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5221 COUNCIL CONDUCTS WORKSHOP TO REVIEW SAFETY, CLEANUP AT SOLVENTS, CITIZENS' GROUP
QUESTIONS TOWN'S ABILITY TO CONTROL EMERGENCIES AT SRSNE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
5222 EPA RIPS WASTE SITE FAILURES; LEAKS CONTINUING; NEIGHBORS FURIOUS, SRSNE HAS NOT TAKEN
ALL STEPS REQUIRED IN CONSENT DECREE SIGNED IN 1983
Author: WATERBURY REPUBLICAN AMERICAN
Addressee:
Doc Type: NEWS CLIPPING
5225 EPA TO EXPLAIN SRS ONGOING FIELD TESTING, EPA WILL HOLD MEETING TO DISCUSS SRS RCRA
PERMIT RENEWAL AND 3 PHASE REMEDIAL INVESTIGATION (RI) INTO NATURE AND EXTENT OF
CONTAMINATION
Author: SOUTHINGTON OBSERVER
Addressee:
10/5/2005
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Doc Date: 07/19/1990 # of Pages: 1
File Break: 13.03
Doc Date: 07/19/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5226 NEW PROBE OF SOLVENTS REQUESTED
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/19/1990 # of Pages: 1
File Break: 13.03
5227 SAFE TO PREPARE FOR EPA'S VISIT, SAFE (SOUTHINGTON ASSOCIATION FOR THE ENVIRONMENT)
WAS FORMERLY SOS (SOUTHINGTON OPPOSING SOLVENTS)
Author:
Addressee:
NEW BRITAIN HERALD
Doc Date: 07/20/1990
File Break: 13.03
# of Pages: 1
Doc Type: NEWS CLIPPING
5228 OFFICIALS EYE AIR QUALITY AT SOLVENTS, CT DEP EXPECTS TO ORDER SRS TO CONTROL AIR
POLLUTION FROM GROUNDWATER CLEANUP SYSTEM
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/21/1990 # of Pages: 1
File Break: 13.03
5193
EPA ANNOUNCES FILING OF A SUIT
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date:
File Break:
07/24/1990 # of Pages: 3
13.03
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13: COMMUNITY RELATIONS
5229 COUNCIL HEARS RESIDENTS' CONCERNS ABOUT CHEMICAL OPERATION, FIRE PREPAREDNESS AND
AIR POLLUTION WERE RESIDENTS MAIN CONCERNS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5230 EPA SUIT WOULD OUST SOLVENTS, EPA AND DOJ FILED SUIT TO FORCE CLOSURE OF SOLVENTS
RECOVERY SERVICE OF NEW ENGLAND INC FACILITY, A SEPARATE ACTION ASKS $8 MILLION IN
FINES AND PENALTIES FOR VIOLATION OF CONSENT DECREE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
5231 EPA WANTS TO SEE SOUTHINGTON PLANT CLOSED, FINED $8 MILLION
Author: ASSOCIATED PRESS
Addressee:
Doc Type: NEWS CLIPPING
5232 EPA MOVES TO CLOSE SOUTHINGTON SITE, FEDERAL GOVERNMENT FILES LAWSUIT TO FORCE
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND TO CLOSE AND TO PAY AT LEAST $8.8 MILLION
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
10/5/2005
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Doc Date: 07/25/1990 # of Pages: 1
File Break: 13.03
Doc Date: 07/25/1990 # of Pages: 2
File Break: 13.03
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***For External Use***
13: COMMUNITY RELATIONS
5233 FEDS SUE TO SHUT DOWN SOLVENTS WASTE SITE, FEDERAL GOVERNMENT MOVES TO SHUT DOWN
AND FINE COMPANY FOR VIOLATING A 1983 AGREEMENT TO CLEAN SITE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5236 OFFICIALS, RESIDENTS APPLAUD EPA SUITS, EPA FILED TWO LAWSUITS AGAINST SOLVENTS,
SEEKING PLANT CLOSURE AND OVER $8 MILLION IN FINES
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5240 FEDS SUE SOUTHTNGTON WASTE FIRM; US SUES TO SHUT SOLVENTS RECOVERY SERVICE
Author:
Addressee:
Doc Type: NEWS CLIPPING
5241 EPA MOVES TO CLOSE WASTE-TREATMENT SITE; GOVERNMENT SEEKING MILLIONS IN PENALTIES
FROM SOUTHTNGTON FIRM, EPA SAYS SOLVENTS RECOVERY SERVICE OF NEW ENGLAND INC IS ONE
OF STATE'S LARGEST POLLUTERS
Author: WATERBURY REPUBLICAN AMERICAN
Addressee:
10/5/2005
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Doc Date: 07/25/1990 # of Pages: 2
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Doc Date: 07/25/1990 # of Pages: 2
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Doc Type: NEWS CLIPPING
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***For External Use***
13: COMMUNITY RELATIONS
5242 RECYCLING FIRM FACES FEDERAL SUIT, SUITS RESULT FROM SOLVENTS RECOVERY SERVICE OF
NEW ENGLAND INC'S FAILURE TO CORRECT NUMEROUS VIOLATIONS
Author: BOSTON GLOBE (BOSTON MA)
Addressee:
Doc Type: NEWS CLIPPING
5243 SOLVENTS FIRM FACING FEDERAL POLLUTION SUITS, FEDERAL OFFICIALS SEEK CLOSURE OF
FACILITY AND MORE THAN $8 MILLION IN FINES
Author:
Addressee:
Doc Type: NEWS CLIPPING
5247 EPA DISCUSSES CLEANUP PLANS AT SHS TONIGHT, MEETING AT SOUTHTNGTON HIGH SCHOOL
Author: SOUTEHNGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
5201 LONG TASK IN STORE, SOUTHTNGTON CLEANUP COULD TAKE THIRTY YEARS, NEWSPAPER REPORT
ON PUBLIC MEETING HELD IN SOUTHINGTON (CT)
Author: HARTFORD COURANT
Addressee:
10/5/2005
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Doc Date: 07/26/1990 # of Pages: 2
File Break: 13.03
Doc Date: 07/27/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5248 RESIDENTS CRITICAL OF EPA, SAY AGENCY MOVED TOO SLOW ON SOLVENTS, REPORT OF PUBLIC
MEETING
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/27/1990 # of Pages: 1
File Break: 13.03
5250 RESIDENTS DISGUSTED WITH EPA, DEMAND IMMEDIATE ACTION AGAINST SOLVENTS RECOVERY,
REPORT OF PUBLIC MEETING
Author:
Addressee:
NEW BRITAIN HERALD
Doc Date: 07/27/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
5255 EPA WARNS WASTE TAKES TIME TO CLEAR; RESIDENTS SAY THEY CAN'T WAIT
Author: WATERBURY REPUBLICAN AMERICAN
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/27/1990 # of Pages: 3
File Break: 13.03
5267 30-YEAR CLEANUP FEARED; SOUTHINGTON GETS BAD NEWS ON WASTE PLANT
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
07/27/1990 # of Pages: 1
13.03
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13: COMMUNITY RELATIONS
5268 EPA MEETING ON SOLVENTS LEAVES SOME QUESTIONS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/27/1990 # of Pages: 1
File Break: 13.03
5270 SOLVENTS: IT COULD TAKE DECADES TO CLEAN UP SITE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/29/1990 # of Pages: 2
File Break: 13.03
5272 NEWSMAKER: MERRILL HOHMAN, EPA'S POINT MAN FOR SOLVENTS CLEANUP
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/30/1990
File Break: 13.03
# of Pages: 1
5364 SAFE MEMBERS EXPAND ROLE BEYOND ONE POLLUTER, GROUP CHANGED NAME TO REFLECT
CHANGE OF IMAGE, APPLIED FOR TECHNICAL ASSISTANCE GRANT
Author: SOUTEHNGTON OBSERVER
Addressee:
Doc Date: 08/02/1990 # of Pages: 2
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5102 CITIZEN ADVOCACY GROUPS CONCERNS ABOUT INCIDENCE OF CANCER IN SOUTHTNGTON (CT)
Author: MARIE TUCCITTO SAFE [SRS] SOUTfflNGTON ASSOCIATION FOR THE ENVIRONMENT
Addressee:
BARRY JOHNSON US DHHS/US PUBLIC HEALTH SERVICE
Doc Type: LETTER
Doc Date: 08/07/1990
File Break: 13.01
# of Pages: 2
5118 RESPONSE TO REQUEST FOR DOCUMENT COPIES AND INFORMATION
Author: MARGARET LESHEN US EPA REGION 1
Addressee: marje TUCCITTO SAFE [SRS] SOUTHINGTON ASSOCIATION FOR THE ENVIRONMENT
Doc Type: LETTER
Doc Date: 08/08/1990
File Break: 13.01
# of Pages: 1
5365 SAFE ASKS US SURGEON GENERAL TO SHUT DOWN SOLVENTS, CITIZENS' GROUP UNSATISFIED WITH
EPA AND STATE RESPONSE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 08/08/1990
File Break: 13.03
# of Pages: 1
5366 AGENCY TO CONSIDER RESIDENTS' COMPLAINTS, ATSDR WILL WAIT FOR FURTHER INFORMATION
BEFORE DECIDING WHETHER TO INVESTIGATE SRSNE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 08/09/1990
File Break: 13.03
# of Pages: 1
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13: COMMUNITY RELATIONS
5367 SAFE PUSHED TO CLOSE SRS, IMPATIENT WITH EPA DUE PROCESS IN CLOSING SRS, LOCAL GROUP
HAS CONTACTED US SURGEON GENERAL
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
5119 DISCUSSION OF EPA ACTIONS AGAINST SOLVENTS RECOVERY SERVICES
Author: JULIE BELAGA US EPA REGION 1
Addressee: PAMELA CARDONE SOS [SRS] SOUTHINGTON OPPOSING SOLVENTS
THOMAS CARDONE SOS [SRS] SOUTHINGTON OPPOSING SOLVENTS
DAN VENDETTI SOS [SRS] SOUTHINGTON OPPOSING SOLVENTS
ROBERTA VENDETTI SOS [SRS] SOUTHINGTON OPPOSING SOLVENTS
Doc Type: LETTER
5369 TOWN APPEALS RULING BY EPA ON SLUDGE, TOWN WANTS EPA TO REVERSE DECISION THAT
SLUDGE IS HAZARDOUS WASTE, NOT SEWAGE SLUDGE
Author: HARTFORD COURANT
Addressee:
10/5/2005
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File Break: 13.03
Doc Date: 08/13/1990 # of Pages: 2
File Break: 13.01
Doc Date: 08/14/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5214 NEIGHBORHOOD EFFORT FOR INDUSTRIAL CLEANUP: CITIZENS ACTION COMMITTEE TO FORM
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
5371 SOLVENTS REQUESTS AN EXTENSION; REQUESTS MORE TIME TO PREPARE RESPONSES TO LAWSUITS
FILED BY US ATTORNEY
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5373 EPA MAKING MOTIONS TO DISMISS PETITION, REJECTION OF PETITION TO RECLASSIFY SLUDGE
PILE AS NON-HAZARDOUS WASTE IS IMMINENT
Author: THOMSATON EXPRESS
Addressee:
Doc Type: NEWS CLIPPING
5374 PROOF AND DUE PROCESS SLOW ACTION AGAINST SRS; EPA AND STATE NEED SUBSTANTIATED
PROOF BEFORE THEY CAN ACT
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
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Doc Date: 08/16/1990 # of Pages: 1
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Doc Date: 08/16/1990 # of Pages: 1
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Doc Date: 08/16/1990 # of Pages: 2
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13: COMMUNITY RELATIONS
5375 TOWN WANTS EPA TO RECONSIDER RULING; APPEAL OF RULING ON SEWAGE SLUDGE
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5377 30-DAY EXTENSION SOUGHT IN WASTE CASE; SRS REQUESTS EXTENSION TO SUBMIT RESPONSE TO
TWO FEDERAL LAWSUITS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5378 EXTENSION GRANTED FOR RESPONSE TO SUITS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
5379 RESIDENTS IN AREA NEAR SOLVENTS TO GET PUBLIC WATER SURVEY; 129 HOMES Wil l, BE
SURVEYED BY SOUTHINGTON WATER DEPARTMENT TO SEE IF THEY WANT PUBLIC WATER
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
10/5/2005
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Doc Date: 08/17/1990 # of Pages: 1
File Break: 13.03
Doc Date: 08/21/1990 # of Pages: 1
File Break: 13.03
Doc Date: 08/21/1990 # of Pages: 1
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13: COMMUNITY RELATIONS
5194 US EPA ANNOUNCES TECHNICAL ASSISTANCE GRANT APPLICATION TO BE FILED
Author: US EPA REGION 1
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 08/23/1990 # of Pages: 2
File Break: 13.03
5381 SOLVENTS PROBE SOUGHT; PETITION DEMANDING AN INVESTIGATION AND POSSIBLE LEGAL
ACTION AGAINST SRSNE WAS FILED WITH CT DEP
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 08/23/1990 # of Pages: 1
File Break: 13.03
5412 SAFE APPLIES FOR FEDERAL GRANT; SOUTHINGTON ASSOCIATION FOR THE ENVIRONMENT INTENDS
TO APPLY FOR A TECHNICAL ASSISTANCE GRANT FROM EPA
Author:
Addressee:
NEW BRITAIN HERALD
Doc Date: 08/27/1990
File Break: 13.03
# of Pages: 1
Doc Type: NEWS CLIPPING
5416 EPA FILES SUIT UNDER SUPERFUND AT OPERATING FACILITY
Author:
Addressee:
Doc Date: 08/29/1990 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5417 SOLVENTS' NEIGHBORS FAULT INTER-AGENCY COOPERATION; RESIDENTS COMPLAIN OF LACK OF
COMMUNICATION BETWEEN AGENCIES
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5419 ACTIVISTS SEEK FEDERAL GRANT TO AID FIGHT AGAINST SOLVENTS; CITIZENS' GROUP WANTS
GRANT TO HIRE CONSULTANTS TO EVALUATE CLEANUP
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5421 EPA ANNOUNCES GRANT TO BE FILED FOR SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
SUPERFUND SITE; SOUTHTNGTON ASSOCIATION FOR THE ENVIRONMENT FILED FOR TECHNICAL
ASSISTANCE GRANT
Author
Addressee:
Doc Type: NEWS CLIPPING
5423 PRIVATE WELL TESTS BEGIN IN OCTOBER; EPA HAS HIRED NUS TO TEST WELLS WITHIN 2 MILES OF
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND SUPERFUND SITE
Author: SOUTLUNGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
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Doc Date: 08/29/1990 # of Pages: 1
File Break: 13.03
Doc Date: 08/31/1990 # of Pages: 1
File Break: 13.03
Doc Date: 09/04/1990 # of Pages: 1
File Break: 13.03
Doc Date: 09/27/1990 # of Pages: 1
File Break: 13.03
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13: COMMUNITY RELATIONS
5425 ENVIRONMENTAL CLEANUP BEGINS WITH SOLVENTS RECOVERY; EDITORIAL, ELECTION ISSUES '90
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/27/1990 # of Pages: 2
File Break: 13.03
5427 PRIVATE WELL TESTING TO BEGIN ON MONDAY
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/11/1990 # of Pages: 1
File Break: 13.03
5428 ATTORNEY HIRED TO CHALLENGE RULING; SELECTMEN HIRED ENVIRONMENTAL ATTORNEY TO
DISPUTE CLASSIFICATION OF SEWAGE PLANT AS HAZARDOUS WASTE SITE
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/17/1990 # of Pages: 1
File Break: 13.03
5430 SAFE SEEKS GRANT FOR SUPERFUND STUDY
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
10/18/1990 # of Pages: 1
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13: COMMUNITY RELATIONS
5432 STATE TO BEGIN CANCER SURVEY; EPA REVIEWS STUDY OF SOLVENTS; STATE WILL SEND OUT
HEALTH QUESTIONNAIRES TO CHART CANCER RATES
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 11/27/1990
File Break: 13.03
# of Pages: 1
5433 PANEL PLANNING TO TOUR SOLVENTS RECOVERY PLANT; CONSERVATION COMMISSION Wil l, TOUR
FACILITY BEFORE MAKING RECOMMENDATIONS ON AIR EMISSIONS PERMIT SUBMISSION BY SRSNE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 12/19/1990
File Break: 13.03
# of Pages: 1
5436 DIRTY WAR OVER SOLVENTS RECOVERY STARTS NEW YEAR; SOUTHTNGTON HAZARDOUS WASTE
FIRM FACING MOUNTING LEGAL CHALLENGES
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 12/30/1990 # of Pages: 2
File Break: 13.03
5442 SOLVENTS' LEGAL TANGLE, EDITORIAL
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/06/1991
File Break: 13.03
# of Pages: 1
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13: COMMUNITY RELATIONS
5472 APPLICATION FOR FINANCIAL ASSISTANCE, WITH ATTACHMENTS
Author: THOMAS WILLAMETZ SAFE [SRS] SOUTfflNGTON ASSOCIATION FOR THE ENVIRONMENT
Addressee:
US EPA REGION 1
Doc Type: FORM
Doc Date: 01/08/1991 # of Pages: 37
File Break: 13.07
5441 EPA LEARNS TOWN STILL WORRIED OVER SOLVENTS; REPORT OF PUBLIC MEETING
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/09/1991 # of Pages: 1
File Break: 13.03
5443 PERMIT EXPIRES TODAY FOR SOLVENTS RECOVERY; PLANT WILL CONTINUE TO OPERATE UNTIL
PERMITS ARE EITHER APPROVED OR DENIED
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 01/21/1991 # of Pages: 1
File Break: 13.03
5444 PROTESTERS WANT SOLVENTS CLOSED
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
01/22/1991 # of Pages: 1
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13: COMMUNITY RELATIONS
5446 BLUMENTHAL ASKS TEMPORARY HALT TO SOLVENTS RECOVERY OPERATIONS; STATE ATTORNEY
GENERAL REQUESTS TEMPORARY INJUNCTION AGAINST SRSNE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5769 ATTORNEY GENERAL MOVES TO CLOSE LAZY LANE FIRM
Author: SOUTEHNGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
5770 SOLVENTS UNVEILS REVISED STORAGE WAREHOUSE PLANS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5691 STATE GOES TO COURT MONDAY AGAINST LAZY LANE FIRM; INJUNCTION AGAINST SRSNE AS A
RESULT OF ALLEGED PERMIT VIOLATIONS
Author: SOUTEHNGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
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Doc Date: 01/25/1991 # of Pages: 1
File Break: 13.03
Doc Date: 02/21/1991 # of Pages: 2
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13: COMMUNITY RELATIONS
5692 STATE, SOLVENTS OFFICIALS AGREE TO TEMPORARY CLOSURE, TWO ARTICLES
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 02/28/1991 # of Pages: 2
File Break: 13.03
5693 WASTE COMPANY AGREES TO SHUT DOWN IN MONTH; SRSNE TO SHUT DOWN MARCH 29
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 02/28/1991 # of Pages: 1
File Break: 13.03
5694 COMPANY CLOSING SOON OWES TOWN $91,000; SRSNE SHARE OF LEGAL AND ENVIRONMENTAL
STUDY COSTS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 03/13/1991 # of Pages: 1
File Break: 13.03
5695 CLEANUP OFFICIALS WORRIED ABOUT SOLVENTS' SOLVENCY; SRSNE IS BEHIND IN PAYMENTS FOR
ENVIRONMENTAL STUDIES
Author: RECORD JOURNAL
Addressee:
Doc Date: 03/13/1991 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5696 SOLVENTS MEETS STATE DEADLINE FOR CLOSURE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 03/29/1991 # of Pages: 1
File Break: 13.03
5182 COMMUNITY RELATIONS PLAN, FINAL DRAFT
Author: NUS/TETRA TECH INC
Addressee: us EpA REGION 1
Doc Type: WORK PLAN
Doc Date: 04/01/1991 # of Pages: 31
File Break: 13.02
5697 DEATH PENALTY' FORCES SOLVENTS TO CLOSE UP SHOP; LACK OF LIABILITY INSURANCE
REQUIRED BY COURT ORDER
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 05/31/1991 # of Pages: 1
File Break: 13.03
5089 PHASE 1 INVESTIGATION REPORT AND PUBLIC MEETING
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
Doc Date: 07/01/1991 # of Pages: 11
File Break: 13.05
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5698 LOW LEVELS OF TWENTY-FIVE CHEMICALS AND HEAVY METALS FOUND IN SAMPLES, PARTIAL LIST
SHOWN
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/08/1991 # of Pages: 1
File Break: 13.03
5699 EPA STUDY LISTS CONTAMINANTS FOUND NEAR SOLVENTS PLANT SITE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/08/1991 # of Pages: 1
File Break: 13.03
5471 APPROVAL OF APPLICATION FOR FINANCIAL ASSISTANCE AND AWARD OF TECHNICAL ASSISTANCE
GRANT
Author: JULIE BELAGA US EPA REGION 1 Doc Date: 07/11/1991 # of Pages: 7
Addressee: PAULGKEOUGH US EPA REGION 1
File Break: 13.07
THOMAS WILLAMETZ SAFE [SRS] SOUTHINGTON ASSOCIATION FOR THE ENVIRONMENT
Doc Type: LETTER
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13: COMMUNITY RELATIONS
5700 SAFE WINS $50G GRANT FOR WORK AT SOLVENTS; TECHNICAL ASSISTANCE GRANT AWARDED TO
SOUTHINGTON ASSOCIATION FOR THE ENVIRONMENT
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
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Doc Date: 07/12/1991 # of Pages: 1
File Break: 13.03
5084 AGENDA FOR PUBLIC MEETING, 07/18/1991
Author: Doc Date: 07/18/1991 # of Pages: 1
Addressee:
File Break: 13.04
Doc Type: LIST
5701 SAFE FOR A YEAR AND BEYOND
Author: SOUTHINGTON OBSERVER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/18/1991 # of Pages: 2
File Break: 13.03
5702 CARCINOGENS FOUND NEAR SOLVENTS RECOVERY, EPA SAYS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
07/18/1991 # of Pages: 1
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5703
FINDINGS ON PLANT CHEMICALS ALARM RESIDENTS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/19/1991 # of Pages: 1
File Break: 13.03
5704 SOLVENTS CLEANUP DISSATISFIES SOME; RESIDENTS AT PUBLIC MEETING UNSATISFIED WITH
MONITORING PERFORMANCE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/19/1991 # of Pages: 1
File Break: 13.03
5705 FINDINGS ON PLANT CHEMICALS ALARM SOUTHTNGTON RESIDENTS; RESIDENTS AT PUBLIC
MEETING AIR CONCERNS
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/19/1991 # of Pages: 1
File Break: 13.03
5706 OUT-OF-COURT AGREEMENT SOUGHT WITH SOLVENTS; EPA SEEKS SETTLEMENT
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 07/24/1991 # of Pages: 1
File Break: 13.03
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5707 CARCINOGEN, PCBS FOUND IN DUMP; SOUTHTNGTON LANDFILL
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 08/01/1991 # of Pages: 1
File Break: 13.03
5708 FEDERAL OFFICIALS, RESIDENTS TOUR SOLVENTS SITE; TWO RESIDENTS AND ATSDR
REPRESENTATIVE TOUR SITE
Author: RECORD JOURNAL
Addressee:
Doc Date: 09/07/1991 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
5709 DEP SURPRISED BY METHANE FIND AT MEADOWS; DEP INVESTIGATES POSSIBLE ILLEGAL DUMPING
BYSRS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/13/1991 # of Pages: 1
File Break: 13.03
5710 TOWN SEEKING SOLVENTS' ASSETS TO PAY DEBT; SRS OWES $115,000 FOR LANDFILL STUDY
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
09/14/1991 # of Pages: 1
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13: COMMUNITY RELATIONS
5711 SOIL TESTS INCONCLUSIVE; TESTS DONE AT MEADOWS CONDOMINIUM
Author:
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/18/1991 # of Pages: 1
File Break: 13.03
5713 EPA PUTS LIEN ON SOLVENTS SITE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/27/1991 # of Pages: 1
File Break: 13.03
5714 HOMEOWNERS WANT BREAK FROM TAXING, TOXIC DUMP
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/28/1991 # of Pages: 1
File Break: 13.03
5715 SOIL TESTS AT CONDOS REVEAL NO HAZARDS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
10/25/1991 # of Pages: 1
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13: COMMUNITY RELATIONS
5716 SOLVENTS CLEANUP DISCUSSED; CT DEP, STATE HEALTH OFFICIALS MEET WITH SAFE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5717 SOLVENTS EXPOSED SOME TO TOXINS, ANALYSIS SO FAR DOESN' T INDICATE THREAT TO HEALTH
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5081 PUBLIC MEETING SUMMARY, 07/18/1991, WITH TRANSMITTAL
Author: LIYANG CHU NUS/TETRA TECH INC
Addressee: BETSY SHAW US EPA REGION 1
Doc Type: LETTER
5718 PUBLIC INTEREST KEY TO SOLVENTS SECRETS
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File Break: 13.03
Doc Date: 11/05/1991 # of Pages: 11
File Break: 13.04
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
11/17/1991 # of Pages: 1
13.03
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5719 STOP AND SHOP PLAN CRITICIZED, SPREAD OF SOLVENTS' TOXINS FEARED; OPPONENTS FEAR
EXCAVATION Wil l, CAUSE SPREAD
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 11/21/1991 # of Pages: 1
File Break: 13.03
5720 TOXICITY TEST EYED FOR STORE SITE; DEVELOPERS MAY PERFORM SOIL AND GROUNDWATER
TESTS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 11/23/1991 # of Pages: 1
File Break: 13.03
5721 FORUM TO DISCUSS SOLVENTS REPORT; MEETING TO DISCUSS DRAFT HEALTH ASSESSMENT
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 11/29/1991 # of Pages: 1
File Break: 13.03
5722 RESIDENTS, UNLIKE FEDS, NOT IMPRESSED BY SOLVENTS STUDY; RESIDENTS SAY REPORT DOES NOT
ANSWER QUESTIONS
Author: RECORD JOURNAL
Addressee:
Doc Date: 12/03/1991
File Break: 13.03
# of Pages: 1
Doc Type: NEWS CLIPPING
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13: COMMUNITY RELATIONS
5723 MARKET SITE FREE OF CONTAMINATION, DEVELOPER SAYS; PRELIMINARY REPORT SHOWS NO SOIL
OR GROUNDWATER CONTAMINATION
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
5510 EPA BEGINS FINAL PHASE OF REMEDIAL INVESTIGATION / FEASIBILITY STUDY (RI/FS)
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
5511 EPA TO REMOVE CONTAMINATED SOIL FROM SOLVENTS RECOVERY SERVICES OF NEW ENGLAND
SUPERFUND HAZARDOUS WASTE SITE
Author: US EPA REGION 1
Addressee:
Doc Type: NEWS CLIPPING
5091 EPA PROPOSES ACTION TO MINIMIZE MIGRATION OF CONTAMINATED GROUNDWATER, REDUCE
SOIL CONTAMINATION
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
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File Break: 13.03
Doc Date: 05/01/1992 # of Pages:
File Break: 13.05
Doc Date: 09/11/1992 # of Pages: 2
File Break: 13.03
Doc Date: 12/01/1992 # of Pages: 12
File Break: 13.05
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4910 TRANSCRIPT OF PUBLIC HEARING
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
Doc Date: 01/20/1993 # of Pages: 12
File Break: 13.04
4908 TRANSMITTAL FOR FINAL PUBLIC HEARING
Author: NUS/TETRA TECH INC
Addressee: MICHAEL NALIPINSKI US EPA REGION 1
Doc Type: LETTER
Doc Date: 03/22/1993 # of Pages: 1
File Break: 13.01
6713 MILLIONS TARGETED FOR CLEANUP, SOUTHTNGTON 1ST; NEW TOXINS FOUND
Author:
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/07/1993 # of Pages: 1
File Break: 13.03
6714 EPA TO PUSH AHEAD WITH SOLVENTS' CLEANUP, FIRST PART OF PLAN WOULD STEM SPREAD OF
CONTAMINATION
Author: RECORD JOURNAL
Addressee:
Doc Date: 04/07/1993 # of Pages: 1
File Break: 13.03
Doc Type: NEWS CLIPPING
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6715 SYSTEM TO TREAT TAINTED GROUNDWATER; EPA Wil l, INSTALL SYSTEM TO CAPTURE AND TREAT
GROUNDWATER
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/07/1993 # of Pages: 1
File Break: 13.03
6716 EPA TO START CLEAN UP OF SOLVENTS SUPERFUND SITE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/07/1993 # of Pages: 1
File Break: 13.03
6717 TOXIC DUMP TARGETED
Author: MANCHESTER JOURNAL INQUIRER
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/08/1993 # of Pages: 1
File Break: 13.03
4909 CONTAMINATION SPREAD FARTHER THAN THOUGHT
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/16/1993 # of Pages: 1
File Break: 13.03
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6718 TOXINS' SPREAD WILL SPEED EFFORT AT SOLVENTS' SITE
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/17/1993 # of Pages: 1
File Break: 13.03
6719 TESTS SHOW POLLUTION GOES BEYOND RIVER; RESIDENTS SAY RESULTS CAST DOUBT ON
TREATMENT SYSTEM AT SOLVENTS SITE
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/17/1993 # of Pages: 1
File Break: 13.03
6720 EPA OFFICIAL TO DISCUSS CLEANUP; PUBLIC MEETING AT SOUTHTNGTON PUBLIC LIBRARY
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/28/1993 # of Pages: 1
File Break: 13.03
6721 EPA OFFICIALS TO ANSWER SOLVENTS QUERIES; PUBLIC MEETING AT SOUTHTNGTON PUBLIC
LIBRARY
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 04/29/1993 # of Pages: 1
File Break: 13.03
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6722 EPA SPEEDS CLEANUP AS TOXINS SPREAD
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
6723 RESIDENTS URGE CAUTION ON CHEMICAL CLEANUP
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
6724 RESIDENTS WARN EPA TO BE CAREFUL IN ITS CLEANUP OF CONTAMINATION
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
6725 IT'S TIME TO REFORM SUPERFUND
Author: JAMES C SHAW SPIROL INTERNATIONAL Doc Date: 05/22/1993 # of Pages: 1
Addressee: WILLIMANTIC CHRONICLE
File Break: 13.03
Doc Type: NEWS CLIPPING
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Doc Date: 04/30/1993 # of Pages: 1
File Break: 13.03
Doc Date: 04/30/1993 # of Pages: 1
File Break: 13.03
Doc Date: 04/30/1993 # of Pages: 1
File Break: 13.03
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6726 $65,000 GRANT TO FUND STUDY OF SUPERFUND SITE'S EFFECTS
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 06/09/1993 # of Pages: 1
File Break: 13.03
6728 ' CASH OUT' OFFER PLANNED FOR SRS SITE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/08/1993 # of Pages: 1
File Break: 13.03
6729 AGENCY ADDS TO LONG LIST OF THOSE LIABLE FOR CLEANUP OF SOLVENTS SUPERFUND SITE
Author: NEW BRITAIN HERALD
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 09/08/1993 # of Pages: 1
File Break: 13.03
6730 FEDS AT WORK ON CLEANUP FOR TOWN'S SUPERFUND SITES
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
09/13/1993 # of Pages: 1
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6731 WEICHSEL CRITICIZES SUPERFUND-SITE 'HYSTERIA'
Author: RECORD JOURNAL
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/20/1993 # of Pages: 1
File Break: 13.03
5595 EPA SEEKS COMMENTS ON INTERIM CLEANUP ACTION
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
Doc Date: 11/01/1994 # of Pages: 5
File Break: 13.05
4912 ADDITIONAL FIELD WORK MOVES CLEANUP FORWARD
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
Doc Date: 07/01/1996 # of Pages: 6
File Break: 13.05
5597 SOUTHINGTON CANCER INCIDENCE STUDY, HEALTH INFORMATION ON HAZARDOUS WASTE SITES
Author: CT DEPT OF PUBLIC HEALTH
Addressee:
Doc Type: FACT SHEET
Doc Date:
File Break:
10/01/1997 # of Pages: 6
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5602 STUDY LOOKS AT CANCER NEAR PLANT; STUDY RELEASED BY CT DEP LOOKS FOR LINKS BETWEEN
SRSNE AND CANCER IN SOUTHINGTON, CT
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/21/1997 # of Pages: 1
File Break: 13.03
5603 HEALTH OFFICIALS TAKING LOOK AT STUDY LINKING CANCER, FACTORY; STUDY RELEASED BY CT
DEP LOOKS FOR LINKS BETWEEN SRSNE AND CANCER IN SOUTHINGTON, CT
Author: HARTFORD COURANT
Addressee:
Doc Type: NEWS CLIPPING
Doc Date: 10/27/1997 # of Pages: 1
File Break: 13.03
5598 PROGRESS UPDATE, FOR SUPERFUND CLEANUP AT SRSNE
Author: US EPA REGION 1
Addressee:
Doc Date: 06/01/1998
File Break: 13.05
# of Pages: 10
Doc Type: FACT SHEET
5600 A CITIZEN'S GUIDE TO PHYTOREMEDIATION
Author: US EPA REGION 1
Addressee:
Doc Type: FACT SHEET
Doc Date:
File Break:
08/01/1998 # of Pages: 6
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5601 OPEN HOUSE ANNOUNCEMENT AND PROGRESS UPDATE
Author: US EPA REGION 1
Addressee:
Doc Date: 08/01/1999
File Break: 13.05
# of Pages: 2
Doc Type: FACT SHEET
238288 PROPOSED PLAN MATT TNG LIST ADDRESSES
Author: US EPA REGION 1
Addressee:
Doc Type: LIST
Doc Date: 05/31/2005 # of Pages: 48
File Break: 13.06
238287 MAILING LIST
Author: US EPA REGION 1
Addressee:
Doc Type: LIST
Doc Date: 06/03/2005 # of Pages: 12
File Break: 13.06
238286 NOTICE OF PUBLIC COMMENT PERIOD FOR PROPOSED PLAN
Author: US EPA REGION 1
Addressee:
Doc Type: NEWS CLIPPING
Doc Date:
File Break:
06/10/2005 # of Pages: 1
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238229 TRANSCRIPT OF PUBLIC HEARING
Author: US EPA REGION 1
Addressee:
Doc Type: PUBLIC MEETING RECORD
Doc Date: 06/30/2005 # of Pages: 19
File Break: 13.04
238291 COMMUNITY INVOLVMENT ACTIVITY, 1997 - 2005
Author: JIM MURPHY US EPA REGION 1
Addressee:
Doc Type: MEMO
Doc Date: 09/29/2005 # of Pages: 3
File Break: 13.01
14: CONGRESSIONAL RELATIONS
5452 SRSNE'S LISTING MAY PUT THEM OUT OF BUSINESS
Author: JAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Addressee: RONALD LEFRANCOIS US CONGRESS ADMINISTRATIVE AIDE
Doc Type: LETTER
Doc Date: 08/28/1987 # of Pages: 4
File Break: 14.01
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14: CONGRESSIONAL RELATIONS
5451 SRSNE'S PROBLEMS RESULTING FROM NATIONAL PRIORITIES LIST (NPL) LISTING
Author: NANCY L JOHNSON US HOUSE OF REPRESENTATIVES
Addressee: LEE M THOMAS US EPA - OFFICE OF SOLID WASTE & EMERGENCY RESPONSE
Doc Type: LETTER
5453 UPDATE ON STATUS OF SUPERFUND SITES IN SOUTHINGTON (CT)
Author: JULIE BELAGA US EPA REGION 1
Addressee: ANNPDANDROW CT HOUSE OF REPRESENTATIVES
ANGELO F FUSCO CT HOUSE OF REPRESENTATIVES
Doc Type: LETTER
5454 UPDATE ON STATUS OF SUPERFUND SITES IN SOUTHINGTON (CT)
Doc Date: 09/14/1987 # of Pages: 2
File Break: 14.01
Doc Date: 06/22/1990 # of Pages: 2
File Break: 14.01
Author: JULIE BELAGA US EPA REGION 1
Addressee: JOSEPH I LIEBERMAN US SENATE
Doc Type: LETTER
Doc Date:
File Break:
07/02/1990 # of Pages: 2
14.01
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14: CONGRESSIONAL RELATIONS
5121 REQUEST FOR REVIEW OF CONSTITUENTS' CONCERNS WITH REGULATORY PROBLEMS
Author: CHRISTOPHER J DODD US SENATE
Addressee:
JULIE BELAGA US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/19/1990 # of Pages: 3
File Break: 14.01
5195 STATEMENT OF BRUCE A MORRISON, DEMOCRAT FOR GOVERNOR, ON SITUATION IN SOUTHTNGTON
(CT)
Author: BRUCE A MORRISON BRUCE A MORRISON FOR GOVERNOR COMMITTEE
Addressee:
Doc Type: PRESS RELEASE
Doc Date: 07/26/1990 # of Pages: 2
File Break: 14.01
5455 INFORMATION ON RESIDENTIAL WELL SAMPLING
Author: JULIE BELAGA US EPA REGION 1
Addressee:
STEVEN CASEY CT SENATE
Doc Type: LETTER
Doc Date: 10/12/1990 # of Pages: 1
File Break: 14.01
5469 DISCONTENT WITH REGION'S HANDLING OF SUPERFUND PROCESS
Author: ARTHUR T BLUMER SOUTHINGTON (CT) DEPT OF HEALTH
Addressee:
JOSEPH I LIEBERMAN US SENATE
Doc Type: LETTER
Doc Date: 02/26/1991 # of Pages: 1
File Break: 14.01
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14: CONGRESSIONAL RELATIONS
5468 DISCONTENT WITH REGION'S HANDLING OF SUPERFUND PROCESS, SPECIFICALLY COMMUNITY
INVOLVEMENT
Author: JOSEPH I LIEBERMAN US SENATE
Addressee: JULIE BELAGA US EPA REGION 1
Doc Type: LETTER
Doc Date: 03/13/1991 # of Pages: 1
File Break: 14.01
5456 RESPONSE TO LETTER CONCERNING PUBLIC INVOLVEMENT AT SUPERFUND SITES
Author: JULIE BELAGA US EPA REGION 1
Addressee: JOSEPH I LIEBERMAN US SENATE
Doc Type: LETTER
Doc Date: 03/27/1991 # of Pages: 2
File Break: 14.01
4914 CONSTITUENT'S LIABILITY FOR CHEMICAL DUMPING IN CONNECTICUT
Author: CHESTER ATKINS US HOUSE OF REPRESENTATIVES
Addressee: MERRILL S HOHMAN US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/02/1992 # of Pages: 1
File Break: 14.01
4919 CONSTITUENT QUESTIONS EPA'S CLAIM AGAINST SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
POTENTIALLY RESPONSIBLE PARTIES (PRPS)
Author: WILLIAM J ENGLISH CERTIFIED TAPE & LABEL
Addressee:
PETER BLUTE US HOUSE OF REPRESENTATIVES
Doc Date: 02/24/1993 # of Pages: 1
File Break: 14.01
Doc Type: LETTER
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14: CONGRESSIONAL RELATIONS
4918 CONSTITUENT LISTED AS A POTENTIALLY RESPONSIBLE PARTY (PRP)
Author: PETER BLUTE US HOUSE OF REPRESENTATIVES
Addressee:
PAULGKEOUGH US EPA REGION 1
Doc Type: LETTER
Doc Date: 03/15/1993 # of Pages: 1
File Break: 14.01
4915 EXPLANATION OF LIABILITY GENERATORS UNDER CERCLA
Author: PAUL G KEOUGH US EPA REGION 1
Addressee: PETER BLUTE US HOUSE OF REPRESENTATIVES
Doc Type: LETTER
Doc Date: 04/09/1993 # of Pages: 2
File Break: 14.01
4913 CONFUSION OVER SIMILARITY OF COMPANY NAMES
Author: PETER G TORKILDSEN US HOUSE OF REPRESENTATIVES Doc Date: 08/18/1993 # of Pages: 2
Addressee: PAULGKEOUGH US EPA REGION 1 File Break: 14.01
Doc Type: LETTER
4921 RESPONSE TO LETTER ON BEHALF OF HOAGUE-SPRAGUE LEASING CO
Author: PAUL G KEOUGH US EPA REGION 1
Addressee: PETER G TORKILDSEN US HOUSE OF REPRESENTATIVES
Doc Type: LETTER
Doc Date: 09/16/1993 # of Pages: 2
File Break: 14.01
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14: CONGRESSIONAL RELATIONS
4916 POSSIBLE MISTAKEN IDENTITY
Author: JOHN F KERRY US SENATE
Addressee:
PAULGKEOUGH US EPA REGION 1
Doc Type: LETTER
Doc Date: 10/04/1993 # of Pages: 3
File Break: 14.01
4917 COSTS INCURRED BY SMALL BUSINESSES IN SUPERFUND CLEANUP
Author: JOSEPH I LIEBERMAN US SENATE
Addressee: PAULGKEOUGH US EPA REGION 1
Doc Type: LETTER
Doc Date: 10/18/1993 # of Pages: 3
File Break: 14.01
4922 RESPONSE TO LETTER ON BEHALF OF HOAGUE-SPRAGUE LEASING CO.
Author: PAUL G KEOUGH US EPA REGION 1
Addressee: JOHNF KERRY US SENATE
Doc Type: LETTER
Doc Date: 10/22/1993 # of Pages: 2
File Break: 14.01
5604 SEARCH FOR COST EFFECTIVE REMEDIATION TECHNOLOGIES
Author: JOHN P DEVILLARS US EPA REGION 1
Addressee:
NANCY L JOHNSON US HOUSE OF REPRESENTATIVES
Doc Date: 04/24/1996 # of Pages: 1
File Break: 14.01
Doc Type: LETTER
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***For External Use***
16: NATURAL RESOURCE TRUSTEE
5470 UPDATED PRELIMINARY NATURAL RESOURCES SURVEY
Author: JONATHAN P DEASON US DEPT OF THE INTERIOR
Addressee: MERRILL S HOHMAN US EPA REGION 1
Doc Type: LETTER
4927 QUINNIPIAC RIVER SEDIMENT SAMPLING FOR NOAA NATURAL RESOURCES RELEASE
Author: MICHAEL NALIPINSKI US EPA REGION 1
Addressee: KENNETH FINKELSTEIN US NATIONAL OCEANIC ATMOSPHERIC ADMINISTRATION
Doc Type: LETTER
4925 NOTIFICATION TO TRUSTEES OF NEGOTIATIONS WITH POTENTIALLY RESPONSIBLE PARTIES (PRPS)
CONCERNING NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
Author: MICHAEL NALIPINSKI US EPA REGION 1
Addressee: WILLIAM PATTERSON US DEPT OF THE INTERIOR
Doc Type: LETTER
4926 NOTIFICATION TO TRUSTEES OF NEGOTIATIONS WITH POTENTIALLY RESPONSIBLE PARTIES (PRPS)
CONCERNING NON-TIME CRITICAL REMOVAL ACTION (NTCRA)
Author: MICHAEL NALIPINSKI US EPA REGION 1
Addressee: KENNETH FINKELSTEIN US NATIONAL OCEANIC ATMOSPHERIC ADMINISTRATION
Doc Type: LETTER
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Doc Date: 10/29/1991 # of Pages: 9
File Break: 16.05
Doc Date: 05/04/1993 # of Pages: 1
File Break: 16.01
Doc Date: 10/21/1993 # of Pages: 2
File Break: 16.01
Doc Date: 10/21/1993 # of Pages: 2
File Break: 16.01
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17: SITE MANAGEMENT RECORDS
4928 SEVEN AERIAL PHOTOGRAPHS, EPIC ROLL /016 FR225-227, 232, 504, 505, 511, WITH TRANSMITTAL
Author: DAVID E STRZEMPKO ROY F WESTON INC
Addressee:
RUTHLEABMAN US EPA REGION 1
Doc Type: PHOTOGRAPH
Doc Date: 08/20/1992 # of Pages: 1
File Break: 17.04
4929 ADMINISTRATIVE IMPROVEMENTS DEMONSTRATION PROJECTS
Author: MERRILL S HOHMAN US EPA REGION 1 Doc Date: 06/02/1993 # of Pages: 4
Addressee: TIMOTHY FIELDS JR US EPA - OFFICE OF SOLID WASTE & EMERGENCY RESPONSE File Break- 17 07
Doc Type: MEMO
19: RCRA (OBSOLETE)
5280 NOTIFICATION OF RECEIPT OF HAZARDOUS WASTE FROM A FOREIGN SOURCE
Author: JAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Addressee: JOHN R PODGURSKI US EPA REGION 1
Doc Type: LETTER
Doc Date: 11/25/1986 # of Pages: 1
File Break: 19.01
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19: RCRA (OBSOLETE)
5281 SRSNE AND SAFETY-KLEEN ANTICIPATE SIGNING A PURCHASE AND SALE AGREEMENT UNDER
WHICH SAFETY-KLEEN Wil l, ACQUIRE SRSNE ASSETS IN EXCHANGE FOR SAFETY-KLEEN STOCK
Author: JAMES STEWART LOWENSTEIN SANDLER
Addressee: MERRILL S HOHMAN US EPA REGION 1
Doc Type: LETTER
5282 PROPOSED TRANSACTION BETWEEN SRSNE AND SAFETY-KLEEN Wil l, NOT GO FORWARD BEFORE
YEAR'S END
Author: JAMES STEWART LOWENSTEIN SANDLER
Addressee: MERRILL S HOHMAN US EPA REGION 1
Doc Type: LETTER
5283 SUGGESTION THAT SRSNE, US EPA AND STATE MEET TO CONFIRM COMMON GOALS AND BARRIERS
Author: JAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Addressee: BARRY L GIROUX CT DEPT OF ENVIRONMENTAL PROTECTION
Doc Type: LETTER
5284 REQUEST THAT SRSNE WITHDRAW CLAIM OF CONFIDENTIALITY FOR ITS PART B APPLICATION
Author: MARGARET LESHEN US EPA REGION 1
Addressee: jAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: LETTER
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Doc Date: 12/03/1986 # of Pages: 3
File Break: 19 01
Doc Date: 12/13/1986 # of Pages: 1
File Break: 19.01
Doc Date: 02/23/1988 # of Pages: 1
File Break: 19.01
Doc Date: 06/10/1988 # of Pages: 1
File Break: 19.01
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19: RCRA (OBSOLETE)
5285 EXPOSURE OF ON-SITE WORKERS TO HIGH LEVELS OF VOLATILE ORGANIC COMPOUNDS FROM AN
ORGANIC VAPOR ANALYZER, AND TO EXPOSED ASBESTOS AT SITE
Author: MARGARET LESHEN US EPA REGION 1
Addressee: us NATIONAL OCEANIC ATMOSPHERIC ADMINISTRATION
Doc Type: LETTER
5286 CONFIRMATION OF CONVERSATION TO REPORT OF MECHANICAL PROBLEM WITH COOLING TOWER,
PROGRESS TOWARDS REPAIR, USE OF HARD PIPE AND NECESSARY EASEMENT WERE ALSO
DISCUSSED
Author: JAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Addressee: MARGARET LESHEN US EPA REGION 1
Doc Type: LETTER
5294 INDUSTRIAL HYGIENE SURVEY TO DETERMINE EMPLOYEE EXPOSURE TO SOLVENT VAPORS
Author: ATLANTIC ENVIRONMENTAL INC
Addressee:
Doc Type: REPORT
5289 CONFIRMATION OF MEETING, 04/07/1989, PLANNED IMPROVEMENTS
Author: MATTHEW R HOAGLAND US EPA REGION 1
Addressee: RUSSELL W BARTLEY TRC COMPANIES INC
Doc Type: LETTER
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Doc Date: 06/16/1988 # of Pages: 1
File Break: 19 01
Doc Date: 11/01/1988 # of Pages: 1
File Break: 19.01
Doc Date: 11/04/1988 # of Pages: 13
File Break: 19.01
Doc Date: 04/03/1989 # of Pages: 1
File Break: 19.01
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19: RCRA (OBSOLETE)
5291 RESPONSE TO CONCERN REGARDING RESPIRATORY PROTECTION FOR WORKERS ON PRODUCTION
LINE
Author: RUSSELL W BARTLEY TRC COMPANIES INC
Addressee:
MATTHEW R HOAGLAND US EPA REGION 1
Doc Type: LETTER
Doc Date: 06/06/1989
File Break: 19.01
# of Pages: 2
5295 REQUEST FOR ADDITIONAL INFORMATION NEEDED TO ASSESS INDUSTRIAL HYGIENE SURVEY
Author: MATTHEW R HOAGLAND US EPA REGION 1
Addressee: CARLETON H BOLL SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Doc Type: LETTER
Doc Date: 06/16/1989 # of Pages: 2
File Break: 19.01
5296 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NEEDED TO ASSESS INDUSTRIAL HYGIENE
SURVEY
Author: RUSSELL W BARTLEY TRC COMPANIES INC
Addressee:
MATTHEW R HOAGLAND US EPA REGION 1
Doc Type: LETTER
Doc Date: 07/07/1989
File Break: 19.01
# of Pages: 2
5298 RESPONSE TO QUESTION RAISED ABOUT MISSING INFORMATION AFTER REVIEW OF SRSNE
INSPECTION LOGS
Author: JAMES R HULM SOLVENTS RECOVERY SERVICE OF NEW ENGLAND
Addressee:
JOHN R PODGURSKI US EPA REGION 1
Doc Type: LETTER
Doc Date: 01/23/1990 # of Pages: 4
File Break: 19.01
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19: RCRA (OBSOLETE)
5300 ERNEST R GEDEON HAS BECOME DIRECTOR FOR ENVIRONMENTAL COMPLIANCE AT SRSNE, AND
Wil l, BE RESPONSIBLE FOR DRAFTING RENEWAL APPLICATION FOR PART B PERMIT
Author: CARLETONH BOLL SOLVENTS RECOVERY SERVICE OF NEW ENGLAND Doc Date: 02/26/1990 # of Pages: 1
Addressee: MARGARET LESHEN US EPA REGION 1 File Break- 19.01
Doc Type: LETTER
Number of Documents in Collection436
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EPA Region 1 AR Compendium GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at the EPA Region I Superfund Records Center in
Boston, Massachusetts.
TITLE
INTERIM FINAL GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES UNDER CERCLA.
DOCDATE OSWER/EPA ID DOCNUMBER
10/1/1988 OSWER #9355.3-01 2002
TITLE
ATSDR HEALTH ASSESSMENTS ON NPL SITES (DRAFT)
DOCDATE OSWER/EPA ID DOCNUMBER
6/16/1986 5000
TITLE
PROTECTION OF WETLANDS: EXECUTIVE ORDER 11990. 42 FED. REG. 26961 (1977).
DOCDATE OSWER/EPA ID DOCNUMBER
5/24/1977 C003
TITLE
FINAL REVISIONS TO OMB CIRCULAR A-94 ON GUIDELINES AND DISCOUNT RATES FOR BENEFIT-COST ANALYSIS.
DOCDATE OSWER/EPA ID DOCNUMBER
6/25/1993 OSWER 9355.3-20 C214
TITLE
GUIDE ON REMEDIAL ACTIONS AT SUPERFUND SITES WITH PCB CONTAMINATION. QUICK REFERENCE FACT SHEET.
DOCDATE OSWER/EPA ID DOCNUMBER
8/1/1990 OSWER 9355.4-01 FS C254
TITLE
FINAL GROUND WATER USE AND VALUE DETERMINATION GUIDANCE
DOCDATE OSWER/EPA ID DOCNUMBER
4/4/1996 C278
TITLE
DRAFT FINAL GUIDELINES FOR ECOLOGICAL RISK ASSESSMENT
DOCDATE OSWER/EPA ID DOCNUMBER
7/18/1997 C366
TITLE
RULES OF THUMB FOR SUPERFUND REMEDY SELECTION (EPA 540-R-97-013)
DOCDATE OSWER/EPA ID DOCNUMBER
8/1/1997 OSWER 9355.0-69 C473
TITLE
COMMUNITY RELATIONS IN SUPERFUND: A HANDBOOK
DOCDATE OSWER/EPA ID DOCNUMBER
1/1/1992 EPA 540/R-92/009 C488
TITLE
APPROACH FOR ADDRESSING DIOXIN IN SOIL AT CERCLA AND RCRA SITES
DOCDATE OSWER/EPA ID DOCNUMBER
4/13/1998 OSWER 9200.4-26 C504
TITLE
FINAL OSWER DIRECTIVE "USE OF MONITORED NATURAL ATTENUATION AT SUPERFUND, RCRA CORRECTIVE ACTION, AND
UNDERGROUND STORAGE TANK SITES"
DOCDATE OSWER/EPA ID DOCNUMBER
4/21/1999 OSWER 9200.4-17P C512
Thursday, October 06, 2005
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EPA Region 1 AR Compendium GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at the EPA Region I Superfund Records Center in
Boston, Massachusetts.
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME 1, HUMAN HEALTH EVALUATION MANUAL, INTERIM
DOCDATE OSWER/EPA ID DOCNUMBER
1/1/1998 OSWER 9285.7-01 D C530
TITLE
GUIDANCE FOR EVALUATING THE TECHNICAL IMPRACTICABILITY OF GROUND-WATER RESTORATION.
DOCDATE OSWER/EPA ID DOCNUMBER
9/1/1993 EPA 540-R-93-080 C532
TITLE
ECOLOGICAL RISK ASSESSMENT AND RISK MANAGEMENT PRINCIPLES FOR SUPERFUND SITES
DOCDATE OSWER/EPA ID DOCNUMBER
10/7/1999 OSWER 9285.7-28 P C563
TITLE
FINAL GUIDANCE ON ADMINISTRATIVE RECORDS FOR SELECTING CERCLA RESPONSE ACTIONS
DOCDATE OSWER/EPA ID DOCNUMBER
3/1/1989 OSWER NO. 9833.3A-1 C576
TITLE
SOIL SCREENING GUIDANCE: USER'S GUIDE
DOCDATE OSWER/EPA ID DOCNUMBER
7/1/1996 OSWER NO. 9355.4-23 C577
TITLE
EXECUTIVE ORDER 11988, FLOODPLAIN MANAGEMENT
DOCDATE OSWER/EPA ID DOCNUMBER
5/24/1977 EO 11988 C578
TITLE
THE DNAPL REMEDIATION CHALLENGE: IS THERE A CASE FOR SOURCE DEPLETION?
DOCDATE OSWER/EPA ID DOCNUMBER
12/1 /2003 E PA/600/R-03/143 C581
TITLE
A GUIDE TO DEVELOPING AND DOCUMENTING COST ESTIMATES DURING THE FEASIBILITY STUDY
DOCDATE OSWER/EPA ID DOCNUMBER
7/1/2000 OSWER 9355.0-75 C582
TITLE
A GUIDE TO PRINCIPLE THREAT AND LOW LEVEL THREAT WASTES
DOCDATE OSWER/EPA ID DOCNUMBER
11/1/1991 9380.3-06FS C622
Thursday, October 06, 2005
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