Cytec Industries Inc.
Statement of Basis
0 491
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
CYTEC FACILITY
HAVRE DE GRACE, MARYLAND
EPA ID NO. MDD 003 075 942
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Statement of Basis
I. INTRODUCTION
The United States Environmental Protection Agency (EPA) has prepared this Statement
of Basis (SB) to solicit public comment on its proposed remedy for Corrective Action
Units at the Cytec Industries Inc.'s (Cytec) Engineered Materials Facility (Facility or
Site), located in Havre de Grace, Maryland. The Corrective Action Units consist of Solid
Waste Management Units (SWMUs) and Areas of Concern (AOCs). EPA's proposed
remedy consists of expansion of the existing groundwater extraction system and
operation and maintenance of the expanded groundwater extraction system, monitoring
wells and recovery wells. Furthermore, EPA is proposing the compliance with and
maintenance of institutional controls that restrict certain land and groundwater uses at the
Facility. This SB highlights key information relied upon by EPA in making its proposed
remedy decision.
The Facility is subject to EPA's Corrective Action Program under the Solid Waste
Disposal Act, as amended by the Resource Conservation and Recovery Act (RCRA) of
1976, and the Hazardous and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. §§
6901 et seq. (Corrective Action Program). The Corrective Action Program is designed to
ensure that certain facilities subject to RCRA have investigated and cleaned up any
releases of hazardous waste and hazardous constituents that have occurred at their
property. Maryland is not authorized for the Corrective Action Program under Section
3006 of RCRA, 42 U.S.C. §6926; therefore, EPA retains authority in the State of
Maryland for the Corrective Action Program.
This document summarizes the information that can be found in the work plans and
reports submitted by Cytec to EPA during the Verification Investigation (VI), RCRA
Facility Investigation (RFI), and Corrective Measures Study (CMS) activities undertaken
by Cytec. This document also explains the rationale for EPA's proposed remedy for the
Facility. The Administrative Record (AR) for the Facility contains all documents,
including data and quality assurance information, on which EPA's proposed decision is
based. See Section VI, Public Participation, below, for information on how you may
review the AR.
Concurrently with this SB, EPA is soliciting comments on a draft Corrective Action
Permit (Permit). The draft Permit incorporates the remedy proposed in this SB. The
components of EPA's proposed final remedy as described in this SB are contained in the
draft Permit, and will be enforceable thereunder once the Permit is finalized.
EPA will make a decision on the draft Corrective Action Permit after considering the
information submitted during the public comment period. If there are no comments
which result in a change to the draft permit, the final Corrective Action Permit will be
signed and will become effective upon EPA's signature. Otherwise, the final Permit will
become effective forty-five (45) days after the service of notice of the Final Decision or
upon conclusion of any appeals filed. The SB will be incorporated into the final CA
Permit and made a part thereof.
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Information on the Corrective Action Program as well as a fact sheet for the Facility can
be found by navigating http://www.epa.gov/reg3wcmd/correctiveaction.htm.
II. FACILITY DESCRIPTION AND BACKGROUND
The Facility occupies an approximately 27-acre parcel located at 1300 Revolution Street
in Havre de Grace, Maryland (Attachment 1, Figure 1). The Facility began operations in
1962 as American Cyanamid which manufactured structural adhesives for the aerospace
industry. Between 1981 and 1992, a portion of the Facility was used to manufacture
honeycomb core used in conjunction with adhesives to form fuselage and wing
components of aircraft. In 1993, American Cyanamid spun off its chemical operations to
create Cytec Industries, Inc. which included the Facility in Havre de Grace, Maryland.
Currently Cytec Industries, Inc. produces specialty bonding adhesives, including
modified epoxy adhesives, adhesive primers, high-temperature resin systems, and
thermoplastic materials (e.g., graphite, declar) for the aerospace industry.
The Facility is bisected by the Norfolk Southern Railroad and an intermittent stream (a
branch of Lilley Run) (Attachment 1, Figure 2). The adhesive production building is
located on the western portion of the Facility. A warehouse occupies the eastern half of
the Facility. The area surrounding the Facility includes a mixture of light industrial and
high-density residential properties. No structures are present on the area to the east of the
Facility. The local publicly owned treatment works is located immediately southeast of
the Facility boundary. ~
According to Facility personnel, 1,2-dichloroethane (1,2-DCA) was used as a raw
material and for cleaning at the Facility from approximately 1967 through July 1990. A
6,000-gallon underground storage tank (UST) at the UST tank farm located at the
southern corner of the adhesives production building was used to store 1,2-DCA and was
removed in December 1991. Methylene chloride (MCL) was used at the Facility as a raw
material and for cleaning from approximately 1967 through 2003. MCL was stored in a
6,000-gallon UST that was removed in December 1991; in a 3,000-gallon aboveground
storage tank (AST) from September 1992 through December 1993; and in 55-gallon
drums until its use at the Facility was discontinued in 2003.
III. SUMMARY OF ENVIRONMENTAL INVESTIGATIONS
On April 1991, EPA prepared a Final RCRA Facility Assessment (RFA) Report. The
RFA Report identified areas with the potential for a release to soil, groundwater, and
surface water. The RFA Report recommended that certain areas be investigated further.
The areas identified were the printline acid accumulation area, the outside sump, waste
oil accumulation area, honeycomb core building, adhesives building sanitary sewer,
Dowanol EE underground tank line leak, and the MEK underground tank leak. Based on
the results of the RFA, on September 27, 1991, EPA issued American Cyanamid a
Corrective Action Permit (MDD 003 075 942) (1991 Permit). The 1991 Permit required
that American Cyanamid conduct environmental investigations at the Facility. The
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specific Areas of Concern (AOCs) and SWMUs identified in the 1991 Permit include:
SWMU 6-Spent Acid Truck Loading Pad, SWMU 7-RCRA Spent Acid Tank Facility,
SWMU 10-Outside Sump, SWMU 18-Waste Oil Accumulation Area, AOC-1-
Underground Storage Tanks (UST) Area, AOC-2-Adhesives Building Sanitary Sewer,
and AOC-3-Honeycomb Core Building Sanitary Sewer (See Figure 2). Since 1991,
Cytec has performed and completed numerous investigations at the Facility. All stages of
the corrective action process for the SWMUs and AOCs identified in the 1991 Permit are
completed. The predominant contaminant of concern (COC) in groundwater at the
Facility is 1,2-DCA. Other compounds detected above screening criteria in groundwater
are: chloroethane, chloroform, MCL, TCE, and vinyl chloride. The investigations
performed at the Facility are summarized below.
A. AOC-1 Underground Storage Tank Area
^ '
The Verification Sampling Report, Area of Concern No. 1 Underground Storage Tank
Area addresses the former UST area (AOC-1). Five 6,000-gallon USTs were registered
with the Maryland Department of Environment (MDE) and were last known to contain
methyl ethyl ketone (MEK), 2-ethoxyethanol (EE), methanol (MEOH), ethylene
dichloride (EDC), and MCL. In December 1991, Cytec took these five USTs
permanently out of service. Soil samples were, analyzed from three exploratory borings
and five monitoring wells during 1991 (see Figure 3).
MW-1A well groundwater had 12 ug/1 of methylene chloride. MW-2 well groundwater
had 1,800 ug/1 of methylene chloride. MW-3 well groundwater had 2,200 ug/1 of
methylene chloride and 37 ug/1 of vinyl chloride. MW-4 well groundwater had 49,000
ug/1 of methylene chloride. The Maximum Contaminant Level for methylene chloride is
5 ug/1 and vinyl chloride is 2 ug/1. These applicable Maximum Contaminant Levels for
methylene chloride and vinyl chloride are codified at 40 CFR Part 141 and promulgated
pursuant to the Safe Drinking Water Act, Section 42 U.S.C. § 300f et seq.
UST Area soil samples collected from the vadose zone (from the surface to groundwater)
did not detect any COCs.
B. AOC-2, AOC-3, SWMUs 6, 7,10, and 18
The Verification Sampling Report, SWMUs No. 6, 7, 10, 18, and AOCs No. 2 and 3
presents the investigative findings for AOC-2, AOC-3, and SWMUs 6, 7, 10, and 18.
Soil boring samples from SWMU 18 were analyzed for several constituents (VOCs,
Semi-VOCs, and PCBs) commonly found in fuels and oils. Soil boring and groundwater
samples from the remainder of the SWMUs and AOCs were analyzed for hexavalent,
trivalent, and total chromium. Cytec concluded that there was no contamination present
above Heath Based Numbers (HBNs) in either the four SWMUs or the two AOCs, and
therefore no further investigation was recommended.
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C. Facility Wide Soils
A Phase II Soil Investigation was conducted to characterize the potential presence of
COCs in on-site soils that may be acting as ongoing sources of groundwater impacts.
The investigiation was prompted by the detection of elevated groundwater concentrations
of COCs in fence line groundwater monitoring wells MW-12D with the highest detected
concentration at the well of 8,400 ug/1 1,2 DCA and MW-13D with the highest detected
concentration at the well of 12,000 ug/11,2 DCA (Figure 3). These concentrations are not
attributable to AOC-1. Because these impacts were not attributable to any documented
releases, the soil investigation focused on subsurface structures, such as piping, where
potential impacts could have gone unobserved. In addition, soil adjacent to the drum
storage area was investigated based on its proximity to the area of greatest COC impact
to groundwater. As presented in the Phase IIRFI Report Addendum, Table 1, 1,2-DCA
was detected at .42 milligram per kilogram (mg/kg) in vadose zone soil samples at SB-2
(3.5 to 4 feet below ground surface (bgs)), which is located approximately 100 feet from
the southeast edge of the adhesives building. Methylene chloride was detected at 2 mg/kg
in SB-6 (at 6 to 7 feet bgs) and SB-8 (at 7.5 to 8 feet bgs) iat .58 mg/kg, which are located
approximately 15 feet from the southwest and northwest edges of the adhesives building,
respectively.
During activities completed as part of the Phase III RFI, soil samples were collected from
the newly installed monitoring well locations on-site (MW-5D, MW-6D, MW-24, MW-
25, and MW-26) and off-site (MW-27) (see Figure 3). As presented in attached Table 1,
none of the vadose zone soil samples contained COCs.
Soil samples were collected from one on-site location (MW-25I) and two off-site
locations (MW-14I and MW-15I) (see Figure 3) during the Phase IV RFI. As presented
in attached Table 1, none of the vadose zone soil samples contained COCs above their
respective Soil Screening Levels (SSLs).
Vadose zone soil impacts, are limited to three locations, all approximately 100 feet from
the adhesives Facility building and at depths ranging from 3.5 feet bgs to 8 feet bgs. The
low-level concentrations in this area do not represent potential sources of impact to
groundwater and are also below the respective residential and industrial Screening Levels
(SLs) for direct exposure scenario. Thus the soils do not present and unacceptable risk to
human health and the environment.
D. Facility Wide Groundwater
The Phase 1 RCRA Facility Investigation Report describes the results of the EPA-
approved RCRA Facility Investigation Work Plan, dated August 17, 1994. The Phase I
RFI focused on assessing the impact of past activities at AOC-1 and investigating both
quality and flow for overburden groundwater downgradient of AOC-1. Results of the
Phase I RFI identified the following COCs for groundwater: 1,2-DCA, carbon disulfide,
chloroform, MCL, trichloroethene (TCE), tetrachloroethene (PCE), 1,1,2-trichloroethane
(TCA), and vinyl chloride. The highest concentrations of these COCs were detected
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adjacent to the former AOC-1 source area. 1,2-DCA was detected at concentrations
ranging from 29 to 52,000 ug/1. MCL was detected at concentrations ranging from 100 to
26,000 ug/1. .
In 1998, the Facility conducted Phase II RFI activities to define the nature and the
horizontal and vertical extents of groundwater contaminant migration beneath and
adjacent to the Facility. Groundwater quality was evaluated through the collection of
overburden groundwater samples from twenty-four (24) permanent monitoring wells (See
Figure 3) and thirty-six (36) temporary Geoprobe® points. Samples of groundwater
showed 1,2-DCA and MCL as the principal COCs in groundwater. The other COCs
concentrations are several orders of magnitude lower than 1,2-DCA and MCL. The
highest concentration of 1,2-DCA was found at MW-3 at 44,000 ug/1. MCL was detected
in MW-4 at 490 ug/1. The groundwater sampling results from the deeper locations did
not find the boundries of the 1,2-DCA plume. The results of the Phase II RFI suggested a
need for further delineation of COCs, particularly 1,2-DCA in deeper overburden
groundwater at off-site locations, downgradient and to the east {Phase IIRCRA Facility
Investigation Report, BBL 1998).
A bedrock groundwater investigation which comprised the Phase II RFI Addendum
involved the installation of three shallow bedrock boreholes, packer testing, installation
of bedrock monitoring -wells, and groundwater sampling (See Figure 3). Based on the
findings of the bedrock groundwater investigation, the Phase II RCRA Facility
Investigation Addendum concluded that the focus of the Facility stabilization and
remediation should remain on the deep overburden beneath and to the east of the Facility.
The concentrations of COCs were highest in the overburden and decreased in the bedrock
the deeper the samples were taken. The highest concentration of 1,2-DCA in the bedrock
was 5,600 ug/1 and was located under the former UST area (MWBR-1).
A Phase III RFI was completed during 2006 to provide additional data to evaluate the
possibility of a separate source of COCs in deeper overburden groundwater near
monitoring well MW-13 and at the off-site area north of the Facility near monitoring well
MW-18 to address the conclusions reached from the Phase II RFI (See Figure 3). The
Phase III investigation activities included the installation of six on-site monitoring wells
and one off-site monitoring well; collection of soil samples from the new monitoring well
locations; and collection of groundwater samples from all newly installed wells and select
existing monitoring wells. The investigation results confirmed that impacts of COCs in
on-site soils are limited. None of the sample results had COCs above SLs or SSLs.
Groundwater analytical results also confirmed that 1,2-DCA is the principal COC in
deeper overburden groundwater both on and off-site. The highest concentration of 1,2-
DCA was from an off-site well MW-27 at 12,000 ug/1. The second highest concentration
of 1,2-DCA was an on-site well MW-6 which had a concentration of 9,000 ug/1 of 1,2-
DCA.
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A Phase IV RFI report was completed during 2007 to fill in gaps in the understanding of
contaminated groundwater in the intermediate and deeper portions of the groundwater
(lower Talbot) and if pumping from one zone would affect the other. The Phase IV
investigation revealed that the overburden (soils over bedrock) has three layers. The
shallow overburden formation (upper Talbot) is made of 10 to 20 feet deep of silty soil.
The intermediate overburden consists of sand and gravel.- The deeper layer also consists
of sand and gravel. The intermediate and deeper zones are separated by a silty clay layer.
The Phase IV RFI report concluded that 1,2-DCA is the predominant COC in
groundwater at the Facility. The highest COC concentrations were observed within the
intermediate overburden groundwater beneath the northern portion of the adhesives
Facility building and neighboring properties northeast and downgradient from the Facility
boundary. In October 2008, EPA approved the Final Phase IV RFI Report which
triggered the commencement of the development of a Corrective Measures Study (CMS)
Work Plan.
On May 3, 2011, the Facility also conducted groundwater sampling to characterize
current conditions at the Facility. The sampling focused on contamination in three water
bearing zones: Shallow Overburden, Intermediate Overburden and Deep Overburden.
The Shallow Overburden is 33.76 to 43.58 feet above mean sea level. The Intermediate
Overburden is 22.29 to 40.73 feet above mean sea level. Deep Overburden is -.86 to
37.02 feet above mean sea level.
Shallow Overburden Zone
The sampling results did not detect any COCs in the Shallow Overburden zone above the
Maximum Contaminant Levels or Risk Based Concentrations (RBCs).
Intermediate and Deep Overburden Zones
The following COCs were detected above Maximum Contaminant Levels and RBCs in
intermediate and deep overburden zone groundwater in May 2011:
• 1,1,2-Trichloroethane was detected above the Maximum Contaminant Level of 5 ug/L
- in one of the 30 samples at a concentration of 5.4 ug/L (MW-25).
• 1,2-Dichloroethane was detected above the Maximum Contaminant Level of 5 ug/L in
19 of the 30 samples collected at concentrations ranging from 42 ug/L (MW-14I) to
1,300,000 ug/L (DDC Well).
• Methylene chloride was detected above the Maximum Contaminant Level of 5 ug/L in
seven of the 30 samples collected at concentrations ranging from 8 ug/L (MW-23) to
2,900,000 ug/L (DDC Well).
• Trichloroethene was detected above the Maximum Contaminant Level of 5 ug/L in
eight of the 30 samples collected at concentration ranging from 5.9 ug/L (MW-16) to 160
ug/L (MW-26).
• Vinyl chloride was detected above the Maximum Contaminant Level of 2 ug/L in three
of the 30 samples collected at concentrations ranging from 4.9 ug/L (MW-26) to 8.3 ug/L
(MW-16).
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Bedrock Zone
The following COCs were detected above Maximum Contaminant Levels and Risk
Based Criteria (RBCs) in samples collected from the bedrock zone groundwater in May
2011:
• 1 ,2-Dichloroethane was detected above the Maximum Contaminant Level of 5 ug/L in
two of the four samples collected at concentrations ranging from 350 ug/L (MWBR-4) to
1,400 ug/L (MWBR-1).
• Methylene chloride was detected above the Maximum Contaminant Level of 5 ug/L in
two of the four samples collected at concentrations ranging from 12 ug/L (MWBR-4) to
17 ug/L (MWBR-3).
• Trichloroethene was detected above the Maximum Contaminant Level of 5 ug/L in one
of the four samples collected at a concentration of 91 ug/L (MWBR-1).
• Vinyl chloride was detected above the Maximum Contaminant Level of 2 ug/L in one
of the four samples collected at a concentration of 310 ug/L (MWBR-4).
The predominant COC in groundwater at the Facility is 1,2-DCA. Other compounds
detected above screening criteria in groundwater are: chloroethane, chloroform, MCL,
TCE, and vinyl chloride. Impacts to groundwater appear on-site beneath operational
areas and extend off the Facility to the northeast. Only limited groundwater
contamination has been identified in shallow groundwater at the Facility; the majority of
COCs have been detected at greater depths. The contamination has migrated from the
source to the intermediate overburden. The highest detected concentrations of COCs
observed in the most recent round of groundwater sampling are present east of the
Adhesive Production Building. There are no known historic or current uses of
chloroethane, chloroform, TCE, and vinyl chloride.
D. Interim Measures
Concurrent with the implementation of the RFI, Cytec has completed a preliminary
evaluation of applicable remedial alternatives and pilot studies to contain chlorinated
volatile organic carbon impacts in Facility groundwater and implemented various interim
remedial measures of their own accord. Cytec used previous studies to assist with the
location and type of appropriate remedial systems for groundwater. An evaluation of the
geology, hydrology and extend of the contamination was conducted.
In the fall of 1996, Cytec selected the Direct Drive Convection (DDC) groundwater
remediation system for a pilot study. The DDC system is an in-situ groundwater
remediation system involving in-well air sparging. Details of this system and its
installation and results are presented in the Phase II RCRA RFI Report which is included
in the AR. Following the completion of an initial 12-week pilot program, Cytec extended
the operation of the DDC system for continued remediation of the lower Talbot
groundwater beneath the southeast end of the Facility. From the completion of the 12-
week pilot program and through its continuous operation from December 1996 through
July 1999, an estimated (based on analysis of exhaust air samples) 70 pounds of 1,2-DCA
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and 118 pounds of methylene chloride had been removed from the lower Talbot by the
DDC system.
The results of the in-situ air-stripping system pilot test indicated that such systems do not
provide sufficient treatment and stabilization of groundwater impacts. Therefore, in 2001,
a remediation system involving only groundwater extraction was implemented at the
Facility.
In 2001, Cytec installed a groundwater extraction system at MW-10D which is screened
within a high-permeability zone. MW-10D is located in the area of the overburden
aquifer with the highest contamination. MW-10D is also located at the down gradient
edge of the Facility and serves to control migration of impacted groundwater off-site.
Groundwater is extracted from monitoring well MW-10D and pumped approximately
2,500 feet from the Facility to the City of Havre de Grace Publicly Operated Treatment
Works (POTW) through a dedicated, double-contained pipeline. As a requirement of
Cytec's National Pollutant Discharge Elimination System (NPDES) permit to discharge
industrial wastewater from the Facility to the City POTW, Cytec must provide monthly
compliance reports to the POTW that describe recorded daily flow data, measured
weekly pH data, and annual effluent sample results. Effluent limitations required by
Cytec's NPDES permit include maintaining a pH greater than 5.0 standard units and
discharging no more than 15,000 gallons per day or 500 gallons in any 30-minute period.
The groundwater extraction system is designed to operate at an average flow rate of 7.5
gallons per minute to the POTW, and typically pumps approximately 250,000 gallons of
extracted groundwater to the POTW each month.
IV. PROPOSED REMEDY
EPA's proposed remedy for the Facility consists of the following components:
A. Soils
Based on the available information, there are currently no unacceptable risks to human
health and the environment via the soil for the present and anticipated use of the Facility
property (industrial use). However, residual soil contamination remains at the Facility,
thus the proposed remedy for soils is institutional controls (See Section C) to restrict the
Facility to non-residential use, to protect the integrity of the groundwater portion of the
remedy (See Section B below) thereby enhancing the overall protectiveness of the
remedy.
B. Groundwater - Long Term Monitoring
The proposed remedy for the groundwater is the combination of groundwater use
restrictions (See Section C below), enhancement of the existing groundwater extraction
system through installation of two additional on-site wells, and the implementation of a
groundwater monitoring program until groundwater clean-up standards are met. Based
on the data collected during the RFI and a subsequent round of groundwater sampling
that the Facility conducted on . May 3, 2011 to characterize current conditions at the
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Facility , the groundwater plume appears to be stable (not migrating), and concentrations
of constituents of concern are either stable or declining over time. Groundwater is not
used on the Facility for drinking water, and there are no known downgradient users of
off-site groundwater between the Facility boundary and the Chesapeake Bay.
C. Institutional Controls
Institutional Controls (ICs) are generally non-engineered instruments such as
administrative and/or legal controls that minimize the potential for human exposure to
contamination and/or protect the integrity of a remedy. Under EPA's proposed remedy,
some concentrations of contaminants remain in the soils and groundwater at the Facility
above levels appropriate for residential uses. As a result, the proposed remedy will
require the Facility to implement ICs in order to restrict use of Facility property and
groundwater to prevent human exposure to contaminants while such contaminants remain
in place.
These ICs may be implemented through State of Maryland Well Construction
Regulations, Article Title 9, Subtitle 13, Annotated Code of Maryland; Code of Maryland
Regulation (COMAR), Title 26, Subtitle 4, Chapter 4, COMAR 26.04.04 (Regulations)
local ordinances and local zoning requirements, and through site-specific institutional
controls required by Permit Conditions. The ICs will restrict land use to non-residential
uses and prohibit the use of groundwater as a source of potable water
The ICs shall contain the following land and groundwater use restrictions:
1. Groundwater at the Facility shall not be used for any purpose other than
industrial usage and to conduct the operation, maintenance, and monitoring
activities required by EPA unless it is demonstrated to EPA that, (1) such use
will not pose a threat to human health of the environment or adversely affect
or interfere with the selected final remedy and (2) EPA provides prior written
approval for such use;
2. No new wells shall be installed on Facility property unless EPA provides prior
written approval to install such wells;
3. The Facility property shall not be used for residential purposes unless it is
demonstrated to EPA that such use will not pose a threat to human health or
the environment or adversely affect or interfere with the selected remedy, and
EPA provides prior written approval for such use;
D. Reporting
EPA's proposed remedy includes the following reporting requirements:
Compliance with and effectiveness of institutional controls and engineering controls
implemented at the Facility shall be evaluated every three (3) years. The evaluation will
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include, but not be limited to, a review of groundwater data from the Facility, review of
groundwater and land uses within 1 mile of the Facility property boundary, and zoning
maps or planning documents that may affect future land use in the impacted area. A
report documenting'the findings C>f the evaluation shall be provided to EPA.
V. EVALUATION OF EPA'S PROPOSED REMEDY DECISION
This section provides a description of the criteria EPA uses to evaluate proposed
remedies consistent with EPA guidance under the CA Program. The criteria are applied
in two phases. In the first phase, EPA evaluates three decision threshold criteria as
general goals. In the second phase, for those remedies which meet the threshold criteria,
EPA then evaluates seven balancing criteria to determine which proposed decision
alternative provides the best relative combination of attributes.
A. Threshold Criteria
1. Protect Human Health and the Environment - EPA's proposed remedy
protects human health and the environment by eliminating, reducing, and/or
controlling unacceptable risk through the remediation of contaminated
groundwater and the implementation of institutional controls to prevent
potential current and future human exposure. The existing State of Maryland
well construction regulations will aid in minimizing exposure to
contaminated groundwater by restricting the installation of wells in
contaminated water sources. The proposed ICs restrict the use of and
exposure to contaminated groundwater at the Facility. With respect to future
uses, the proposed remedy requires groundwater use restrictions to minimize
the potential for human exposure to contamination and protect the integrity of
the remedy
2. Achieve Media Cleanup Objectives - The media cleanup objectives of the
proposed remedy are as follows: groundwater should meet EPA's Maximum
Contaminant Levels and SLs as applicable for contaminants of concern , and
soil should remain below SSLs and SLs for industrial use. EPA's proposed
remedies meet the appropriate cleanup objectives based on assumptions
regarding current and reasonably anticipated land and groundwater use(s).
Soils at the Facility already meet media cleanup objectives for industrial use
and the anticipated future land use for the Facility is industrial. Operation of
an expanded on-site groundwater extraction system would maintain hydraulic
control of impacted groundwater. Groundwater cleanup goals will be
achieved more quickly with enhancement of this system, as additional
groundwater would be extracted from throughout the 1,2-DCA plume area.
3. Remediating the Source of Releases - In its RCRA remedy decisions, EPA
seeks to eliminate and/or reduce further releases of hazardous wastes or
hazardous constituents that may pose a threat to human health and the
environment. Operation of an expanded groundwater extraction system
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would continue to maintain hydraulic control and provide additional
remediation of the impacted groundwater, as contaminated groundwater
would be recovered directly from the 1,2-DCA source area. At SMWUs and
AOCs where contamination is left in place, i.e., sources which are
undergoing remediation, institution controls will be implemented to restrict
residential use.
B. Balancing/Evaluation Criteria
1. Long-Term Effectiveness - EPA's proposed decision requires the compliance
with and maintenance of land use and groundwater use restrictions referred to
herein as Institutional Controls (ICs) at the Facility. The proposed ICs which
' EPA anticipates will be implemented through a permit will maintain
protection of human health and the environment over time by controlling
exposure to the hazardous constituents remaining in groundwater and
protecting the integrity of the remedy. EPA has also proposed long-term
effectiveness will also be assured by the operation and maintenance of an
expanded groundwater extraction system. The system will allow for hydraulic
control of impacted groundwater.
2. Reduction of Toxicity, Mobility, or Volume of the Hazardous
Constituents - Operation of an expanded groundwater extraction system will
reduce the volume of COCs migrating from the 1,2-DCA source areas, at the
Facility, and neighboring areas thereby reducing mobility. The reduction in
the mobility of COCs will reduce the potential risk associated with migration
of groundwater impacts (reducing the toxicity) by maintaining hydraulic
control. The system will remove COCs from the subsurface through
groundwater extraction (reducing the volume), and the extracted water will be
discharged to the POTW, where it will receive treatment, destroying the
COCs (also reducing the toxicity).
3. Short-Term Effectiveness - Installation of equipment to expand the
groundwater stabilization system will pose minimal impact to nearby
receptors. Minor truck traffic to deliver supplies and conduct drilling will be
required; however, all work will be completed on the Facility. In addition,
EPA anticipates that the land use and groundwater use restrictions will be
fully implemented shortly after the issuance of the Final Decision and
Response to Comments.
4. Implementability - The two components of EPA's proposed remedy are
readily implementable. EPA proposes to implement the institutional controls
through a permit and the existing groundwater stabilization will be upgraded
with readily available equipment to handle the proposed increase in flow and
provide more efficient system operation.
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5. Cost - The estimated capital cost of the remedy is $237,000. The additional
Operation and Maintenance cost (inclusive of long-term monitoring) for this
alternative ranges from $76,000 to $106,000. The total present wbrth cost
estimate for this alternative is approximately $1,255,000.
6. Community Acceptance - EPA will evaluate the community's acceptance of
the proposed remedy during the public comment period and will be described
in the Final Decision and Response to Comments.
7. State/Support Agency Acceptance - EPA will evaluate the State of
Maryland's acceptance of the proposed remedy based on comments received
from MDE during the public comment period and will describe the State's
position in the Final Decision and Response to Comments.
VI. PUBLIC PARTICIPATION
Written comments on this SB- and the Draft Corrective Action Permit will be accepted
during the forty-five (45) day public comment period. A final permit decision regarding
the remedy proposed for the Facility will not be made until the public comment period
has closed and all comments have been evaluated and addressed. Based on new
information or comments from the public, EPA may modify the proposed remedy and/or
the Draft Corrective Action Permit.
Following review of the comments, EPA will respond to comments and finalize the
remedy and the Permit. The proposed remedy in this SB is a preliminary determination
and should another remedy be selected based upon public comment or new information,
any significant differences from this SB could cause a reopening of the public comment
period and the reissuance of a revised SB.
The public comment period will last forty-five (45) calendar days from the date of the
public notice in order to provide an opportunity for public comment and involvement
during the evaluation of this proposal. This SB provides only a summary description of
the investigations and activities performed at this Facility. EPA encourages the public to
review the documents in the AR to gain a more comprehensive understanding of the
activities that have been conducted at the Facility and the proposals under consideration.
The AR contains all information considered by EPA in reaching this proposed decision.
It is available for public review during normal business hours at:
U.S. Environmental Protection Agency Region 3
1650 Arch Street
Philadelphia, PA 19103-2029
Contact: Leonard Hotham
Remedial Project Manager
Office of Remediation (3LC20)
Phone: (215) 814-5778
Email: hotham.leonard@epa.gov
13
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Cytec Industries Inc.
Statement of Basis
Written comments must be postmarked within forty-five (45) calendar days of the public
notice. EPA will address all comments received during the public comment period in the
Final Permit and Response to Comments.
If requested, during the forty-five (45) day public comment period, EPA will hold a
public hearing to accept oral comments on the proposed remedies and the alternatives.
Comments made at the hearing will be transcribed, and a copy of the transcript will be
added to the AR. Any interested person may request a public hearing or additional
information by mailing or e-mailing to the above address.
Attachments
Figure 1: Location Map
Figure 2: SWMUs and AOC location map
Figure 3r Monitoring Wells Location Map
Table 1: Summary of Site-Wide Soil Results
Administrative Record Index
Abraham Ferdas, Director
Land and Chemicals Division
US EPA, Region III
14
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Figure 1
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REFERENCE: BASE MAP USGS 7.5 MIN. QUAD., HAVRE DE GRACE, MD, 1992.
2000' 0 2000'
Approximate Scale: 1" = 2000'
^*1
Area Location
i
CYTEC ENGINEERED MATERIALS INC.
HAVRE DE GRACE, MARYLAND
CORRECTIVE MEASURES STUDY REPORT
SITE LOCATION MAP
& ARCADIS
FIGURE
1
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Figure 2
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LEGEND:
® UPPER TALBOT MONITORING WELL
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Figure 3
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teisruus w ice i iw/i/zi^CBiNiMd BioTindndanswiGd —uruaeaovd ruioma twos* noai/zt^iBAvs 9Ma"iM6Som0«auooooui«Kaj»»oo0U3v\3snovHAMvoAN3V9
tou) 'J3lMdO '.-NO W.V1 VTOOOHISVH H NOSSN3MS n--VU. IMSAASeOUM'SVU H31SH'd 'ONITIJHOS "V tlDYNSSOd '1 '90 AOf(l//W3 ynOUS/AW AN asnOVMAS 'MO
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Table 1
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Table 2
Summary of Vadose Zone Soil Sampling Results - Detected Constituents
Cytec Industries Inc.
Havre de Grace, Maryland
Corrective Measures Study Report
I VI I Phase IIRFI Addendum
appira
t . rl, lUh ,
i 1
nn
Iff!!
Ml
HP
wsm
TiT"
Detected Volatile Organics
1,1,2-Trichloroethane
0.000082
mq/kq
NA
0.47 U
600 U
0.76 U
0.51 U
0.52 U
0.52 U
0.49 U
0.50 U
0.47 U
1,2-Dichloroethane
0.000044
mq/kq
0.72 U
0.47 U
wamum
0.76 U
0.51 U
0.52 U
0.52 U
0.49 U
0.50 U
0.47 U
Acetone
4.4
mq/kq
1.4 U
NA
NA
NA
NA
NA
NA
NA
NA
NA
Bromofluorobenzene
mq/kq
NA
5.2
5.7
7.5
5.2
4.9
5.3
4.8
4.4
4.4
Chloroform
0.000055
mq/kq
NA
0.47 U
0.60 U
0.76 U
0.51 U
0.52 U
0.52 U
0.49 U
0.50 U
0.47 U
Methylene Chloride
0.0012
mq/kq
0.72 U
0.47 U
0.60 U
0.76 U
0.51 U
0.52 U
wmmm
wmmm
musmm
0.47 U
Trichloroethene
0.00061
mq/kq
NA
0.47 U
0.60 U
0.76 U
0.51 U
0.52 U
0.52 U
0.49 U
0.50 U
0.47 U
Phase IH RFI I
Li
;;
Jl. !i i.'Lfli
"W?] WĄMM
il MfM
WW
Issmm
"
tee®®®#
WMMiM
Rfllflp
Detected volatile Organics
I
1,1,2-Trichloroethane
0.000082
mq/kq
0.0027 U
0.0027 U
0.0028 U
0.0027 U
0.0030 U
0.0026 U
0.0030 U
0.0033 U
0.0030 U
0.0028 U
0.0028 U
0.0028 U
1,2-Dichloroethane
0.000044
mq/kq
0.0018 U
0.0018 U
0.0019 U
0.0018 U
0.0020 U
0.0017 U
0.0020 U
0.0022 U
0.0020 U
0.0019 U
0.0019 U
0.0019 U
Acetone
4.4
mq/kq
NA
NA
NA
NA
NA
NA
0.023
0.0055 U
NA
NA
NA
0.0047 U
Bromofluorobenzene
mq/kq
NA -
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Chloroform
0.000055
mq/kq
0.0045 U
0.0046 U
0.0048 U
0.0044 U
0.0050 U
0.0044 U
0.0050 U
0.0055 U
0.0050 U
0.0047 U
0.0047 U
0.0047 U
Methylene Chloride
0.0012
mq/kq
0.0027 U
0.0027 U
0.0028 U
0.0027 U
0.0030 U
0.0026 U
0.0030 U
0.0033 U
0.0030 U
0.0028 U
0.0028 U
0.0028 U
Trichloroethene
0.00061
mq/kq
0.00090 U
0.00090 U
0.0010 U
0.00090 U
0.0010 U
0.00090 U
0.0010 U
0.0011 U
0.0010 U
0.0010 U
0.00090 U
0.00090 U
.
I Phase IV RFI
n
|
llEMal
lillllil
iill
I
I Detected Volatile Organics |
1,1.2-Trichloroethane
0.000082
mq/ka
0.0028 U
0.0032 U
0.0030 U
0.0036 U
1,2-Dichloroethane
0.000044
ma/ka
0.0019 U
0.0022 U
0.0020 U
0.0024 U
Acetone
4.4
mg/kq
NA
NA
NA
NA
Bromofluorobenzene
mq/kq
NA
NA
NA
NA
Chloroform
0.000055
mq/kq
0.0047 U
0.0054 U
0.0050 U
0.0060 U
Methylene Chloride
0.0012
mq/kq
0.0012 J
0.0032 U
0.0030 U
0.0036 U
Trichloroethene
0.00061
mq/kq
0.0010 U
0.0011 U
0.0010 U
0.0012 U
Notes:
SSL - USEPA Region 3 Risk-Based Soil Screening Levels (SSLS) for Protection of Groundwater (September 2008).
Bolded and shaded results indicate exceedance of the SSL.
U - Compound not detected above reported sample quantitation limit.
J - The compound was identified; however, the associated numerical value is an estimated concentration.
1. VI - Verification Sampling Report, Area of Concern No. 1 Underground Storage Tank Area (Groundwater Technology, Inc., 1992).
2. Phase II RFI Addendum - Phase li RCRA Facility Investigation Report (RFI) Addendum (BBL, 1999).
3. Phase III RFI - Phase III RFI {ARCADIS BBL, 2007).
4. Phase IV RFI - Phase IV RFI {ARCADIS, 2008).
G:\WP\EC\B0044039\Tables\Tables 2 and 3_soil.xlsx
Page 1 of 1
12/22/2011
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Administrative Record for Cvtec
1. Final Phase II RCRA Facility Assessment (RFA) (1990-1991)
2. Corrective Action Permit (MDD 003 075 942) (September 27,1991)
3. Verification Sampling Report Area of Concern No. I Underground Storage Tank Area,
Groundwater Technology, Inc. [GTI] (October 5,1992)
4. The Verification Sampling Report, SWMUs No. 6, 7,10,18, and AOCs No. 2 and 3 (GTI, October
6,1992)
5. The Phase I RCRA Facility Investigation Report (BBL, 1995) >
6. Phase II RCRA Facility Investigation Report, (BBL, April 1998, Revised January 1999)
7. Phase II RCRA Facility Investigation Addendum (BBL, September 1999)
8. Phase III RFI Report, ARCADIS-BBL, (2007)
9. Final Phase IV RCRA RFI Report (October 22, 2008)
10. Corrective Measures Study (January 2012)
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