Record of Decision Scovill Industrial Landfill Waterbury Connecticut September 2013


U. S. ENVIRONMENTAL PROTECTION AGENCY
EPA NEW ENGLAND - REGION 1

RECORD OF DECISION
SCOVILL INDUSTRIAL LANDFILL
WATERBURY, CONNECTICUT

SEPTEMBER 2013

SDMS Doc ID 548326

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Table of Contents

PART 1: l lll DECLARATION	05

A.	SITE NAME AND LOCATION	05

B.	STATEMENT OF BASIS AND PURPOSE	05

C.	ASSESSMENT OF SITE	05

D.	DESCRIPTION OF SELECTED REMEDY	05

E.	STATUTORY DETERMINATIONS	08

F.	DATA CERTIFICATION CHECKLIST	08

G.	AUTHORIZING SIGNATURES	09

PART 2: THE DECISION SUMMARY	10

A.	SITE NAME, LOCATION AND BRIEF DESCRIPTION	10

B.	SITE HISTORY AND ENFORCEMENT ACTIVITIES	10

1.	History of Site Activities	10

2.	History of Federal and State Investigations and Removal and Remedial Actions—11

3.	History of CERCLA Enforcement Activities	13

C.	COMMUNITY PARTICIPATION	14

D.	SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION	15

E.	SITE CHARACTERISTICS	17

F.	CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES	24

1.	Land Uses	24

2.	Groundwater/Surface Water Uses	25

G.	SUMMARY OF SITE RISKS	26

1. Human Health Risk Assessment	26

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2.	Ecological Risk Assessment	47

3.	Basis for Response Action	47

H.	REMEDIATION OBJECTIVES	48

I.	DEVELOPMENT AND SCREENING OF ALTERNATIVES	48

J. DESCRIPTION OF ALTERNATIVES	49

1.	Soil Remedial Alternatives Analyzed	49

2.	Vapor Intrusion Remedial Alternatives Analyzed	59

K. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	63

L. THE SELECTED REMEDY	73

M. STATUTORY DETERMINATIONS	87

N. DOCUMENTATION OF SIGNIFICANT CHANGES	91

O. STATE ROLE	92

PART 3: l lll RESPONSIVENESS SUMMARY	93

APPENDICES

Appendix A: Administrative Record Index and Guidance Documents

Appendix B: Figures

Appendix C: Tables

Appendix D: HHRA Tables

Appendix E: ARAR Tables

Appendix F: Connecticut DEEP Letter of Concurrence

Appendix G: References

Appendix H: Acronyms and Abbreviations

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Part 1: The Declaration

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Scovill Industrial Landfill
Waterbury, Connecticut

CT0002265551

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Scovill Industrial
Landfill (the Site), in Waterbury, Connecticut, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA),
42 USC § 9601 et seq.. 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 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 Silas
Bronson Library, 267 Grand Street, Waterbury, and at the United States Environmental
Protection Agency (EPA) Region 1 OSRR Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix A to the ROD) identifies each of the items comprising
the Administrative Record upon which the selection of the remedial action is based.

The State of Connecticut concurs with the Selected Remedy.

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.

This ROD sets forth the selected remedy for the Site, which includes several soil and
vapor intrusion remedial alternatives for the various risk areas defined at the Site. For
consideration of soil exposures, the Site was divided into 10 risk areas (Areas Dl, D3, El, E2,
E3, F, G, H, I, and J) based on current land use and potential exposures. The risk areas are
shown in Figure 1 (Appendix B). The selected alternatives for the 10 risk areas form a
comprehensive approach for this Site that addresses all current and potential future risks caused

ASSESSMENT OF THE SITE

DESCRIPTION OF THE SELECTED REMEDY

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by soil contamination and potential vapor intrusion issues from contaminated groundwater.
These alternatives are briefly described in the paragraphs below.

Soil Remedy

Areas D3, E2, E3, G, and H - In Areas D3, E2, G, and H, the human health risks are
within the EPA acceptable cancer risk range1. Human health risks for these risk areas are below
1 in 10,000 (1.0E-04), which is the threshold for remedial action for the Site. In Area E3, risk is
equal to or greater than 1.0E-04, but no cleanup level (CUL) exceedances were observed that are
considered to be accessible (shallower than 4 feet below the ground surface). Alternative S02
has been selected for these risk areas and will consist of: institutional controls to prevent
potential exposures and excavations in contaminated soil; prevent residential uses in areas that
are not currently used as residential; periodic assessments to ensure institutional controls are
implemented; and Five-Year Reviews to review Site conditions and the protectiveness of
remedy.

Areas Dl, El, and F - Human health risks for these risk areas are unacceptable, or have
soil contaminants levels that exceed the CUL. Alternative S03 has been selected for these risk
areas and will consist of: targeted excavations with off-site disposal to prevent exposure to
contaminated soil in these areas; institutional controls to prevent exposures and excavations in
contaminated soil; periodic assessments to ensure institutional controls are implemented; and
Five-Year Reviews to review site conditions and protectiveness of remedy.

Area J - Human health risks for this risk area exceed the EPA acceptable cancer risk
range and the soil contaminant levels also exceed the CUL. Alternative S06 has been selected
for Area J and will consist of: a pre-design investigation to further characterize the extent of soil
contamination for remedial design and remedial action; soil capping to prevent exposure to
contaminated soil; operation and maintenance (O&M) of the soil cap; institutional controls to
prevent exposures and excavations in contaminated soil and to require the long-term care of the
soil cap; periodic assessments to ensure institutional controls are implemented; and Five-Year
Reviews to review site conditions and protectiveness of remedy.

Area I - Human health risks for this risk area exceed the EPA acceptable cancer risk
range and soil contaminant levels also exceed the CUL. Alternative S08 has been selected for
Area I and will consist of: a pre-design investigation to further characterize the extent of soil
contamination; excavation with off-site disposal to prevent exposure to contaminated soil;
institutional controls to prevent exposures and excavations in contaminated soil; periodic
assessments to ensure institutional controls are implemented; and Five-Year Reviews to review
site conditions and protectiveness of remedy.

1 EPA generally views site-related cancer risks in excess of 1 in 10,000 (1E10 4) to 1 in 1,000,000 (10~6) as
unacceptable. See "Role of the Baseline Risk Assessment in Superfund Remedy Selection
Decisions", EPA 1991.

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Vapor Intrusion Remedy

Area El - The vapor intrusion pathway was determined to be potentially complete for
Area El. Alternative VI3 was selected for Area El (where a building is currently occupied by
residents) and will consist of: a preliminary design investigation to evaluate existence of
exposure pathway and if present install an active soil vapor mitigation to prevent exposure to
potential vapor intrusion from contaminated groundwater; O&M of the active soil vapor
mitigation system; institutional controls to prevent potential exposure by requiring the use of a
vapor mitigation system; and Five-Year Reviews to review site conditions and protectiveness of
remedy.

Area J - The vapor intrusion pathway was determined to be potentially complete for Area
J. Alternative VI2 was selected for Area J (currently undeveloped) and will consist of:
institutional controls to prevent potential exposure by requiring the use of a vapor mitigation
system for new construction; and Five-Year Reviews to review site conditions and protectiveness
of remedy.

In summary, these soil and vapor intrusion remedial actions for the Site include a
combination of soil excavation and capping to remove exposure risks to soil contamination and
prevent contamination migration; active vapor mitigation to prevent potential exposure to vapor
intrusion from groundwater contamination; and institutional controls to prevent exposures. The
major components of this remedy are:

•	Perform pre-design investigations to characterize soil and delineate cleanup level
exceedances (Areas El, I, and J);

•	Perform pre-design investigations to assess contaminant concentrations in indoor air and
sub-slab soil gas, evaluate existing building foundations, and potential vapor intrusion
routes (Area El);

•	Excavate and dispose off-site (Areas Dl, El, F, and I) or consolidate and cap (Area J)
soil that exceeds soil cleanup levels;

•	Construct an active vapor mitigation system within an existing structure (in Area El)
using vapor extraction trenches, exhaust fans, and discharge stacks;

•	Implement restrictions on uses of properties within the Site boundary in perpetuity to
prevent potential human exposure to contaminants in the subsurface soils (all Risk Areas)
and to prohibit activities that might harm the cap including deed restrictions, fencing, and
warning signs (Area J).

•	Implement institutional controls to prevent human exposure to soil, including prevention
of residential uses in areas that are not currently used as residential (Areas D3, E2, G, H,
J and I);

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•	Implement institutional controls to prevent human exposure to soil vapors including
prevention of residential uses in areas that are not currently used as residential (Area J);
requirement of vapor mitigation systems for new construction unless information
demonstrating the systems are not needed is provided to the regulatory agencies (Area J);
and prohibition of the use of first floor residential units without vapor mitigation systems
(Area El) if systems are warranted based on PDI results.

•	Maintain the soil cap (Area J) and vapor mitigation system (Area El) in the long term;
and

•	Perform reviews at least every 5 years to ensure that the remedy remains protective of
human health and the environment (all Risk Areas).

No principal threat waste was identified at the Site. The selected response action addresses
low-level threat wastes by: removing or capping contaminated soils, controlling potential
exposures to contaminated soils or soil vapors through institutional controls (undeveloped
property), and installing an active vapor mitigation system (occupied property).

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 (unless justified by a waiver), and is cost-effective. There are no principal threat wastes
present at the Site. 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. Because there are no principal threat wastes present, the selected remedy does not
achieve the statutory preference for treatment as a principal element.

Because this remedy will result in hazardous substances remaining on-site above levels that
would allow for unlimited use and unrestricted exposure (and because land use restrictions are
necessary), a review will be conducted within 5 years after initiation of remedial action to ensure
that the remedy continues to provide adequate protection of human health and the environment.

F.	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.

•	Chemicals of concern (COCs) and their respective concentrations;

•	Baseline risk represented by the COCs;

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•	Remediation levels established for COCs and the basis for the levels;

•	Current arid future land and ground-water use assumptions used in the baseline risk
assessment and ROD:

•	Land and groundwater use that will be available at the site as a result of the selected
remedy:

•	Estimated capital, O&M, and total present worth costs: discount rate; and the number of
years over which the remedy cost estimates are projected; and

•	Decisive factor(s) that led to selecting the remedy.

This ROD documents the selected remedy for soil contamination and potential vapor
intrusion issues at the Site. This remedy was selected by the EPA with concurrence of the
Connecticut Department of Energy and Environmental Protection (CT DEEP).

Concur and recommended for immediate implementation:

U.S. Environmental Protection Agency

G.

AUTHORIZING SIGNATURES

^ Office of Site Remediation and Restoration
Region 1

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A. SITE NAME, LOCATION AND BRIEF DESCRIPTION

The Scovill Industrial Landfill (the Site, CERCLIS Identification Number
CT0002265551) is located in the City of Waterbury, New Haven County, Connecticut (Figure 1,
Appendix B). The 25-acre Site is generally flat and slopes slightly to the south. The Site is
bounded to the north by residential properties along Newbury Street and Academy Avenue, to
the east by a steep hill topped by residential properties abutting Academy Avenue, to the south
by Meriden Avenue (State Route 69) with commercial property beyond, and to the west by a
steep hill topped by residential properties along Monroe Avenue (Figure 1, Appendix B).

Approximately 18 of the 25 acres of the Site are developed along Meriden Road, Store
Avenue, Dunbar Street, and Newman Street. The developed parcels consist of two- and
three-story residential structures (condominiums and apartment buildings), small commercial
buildings that include a landscaping firm, a child daycare facility, elderly housing, a social club,
a cab service, a former medical office, a used car lot, car repair shop, and a shopping mall (East
Gate Shopping Plaza). Two seasonally wet areas are located at the northeastern and
northwestern boundaries.

The Scovill Manufacturing Company (the Company) used the Site as a landfill from 1919
to the mid-1970s for disposal of ash, cinders, demolition debris, and other wastes generated by
Scovill Manufacturing Company. In 1998, the northern portion of the Site was an undeveloped
6.8-acre parcel, referred to as the Calabrese parcel (Area J). This parcel was in the initial stages
of development when a number of capacitors, ash, cinder, crushed drums containing sludge
material, metal waste, demolition debris and other waste materials were encountered at depths
ranging between 8 and 20 feet below grade. The waste materials contained elevated levels of
polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), and metals. The
Site was listed on the National Priorities List (NPL) on July 27, 2000 and the EPA took on the
role as lead agency.

A more complete description of the Site can be found in Section 1.2 of the Remedial
Investigation (RI) Report (Nobis, 2013a).

B. SITE HISTORY AND ENFORCEMENT ACTIVITIES

1. History of Site Activities

The Company used the Site as a landfill from 1919 to the mid-1970s for disposal of its
ash, cinders, demolition debris, and other wastes generated. The Company manufactured various
metal parts that used aluminum, chromium, copper, silver, tin, and zinc including brass buttons,
belt buckles, clasps, and other products. In addition, the Company produced appliances, small
motors, watches, injection molded plastics, and photographic equipment. The Company also

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produced numerous products for the military during World Wars I and II and the Korean War,
including munitions, fuzes, and brass artillery casings.

The Company's past manufacturing processes included: anodizing, aluminum finishing,
buffing, box making, fastener production, carpentry, metal casting, electrical instrument
calibration and maintenance, metal forging, laundry and cleaning services, metals research and
analyses, painting and lacquering, metal milling, electro-annealing, electroplating, grinding,
wastewater treatment, welding, steam and hot water generation, solenoid coil production, solvent
degreasing, and power generation. Wastes from these operations may have been disposed of at
the Site.

Based on interpretations of historical aerial photographs, there is evidence of Site filling
prior to 1934, which is the earliest available historical image. Filling at the Site commenced
along Meriden Road and progressed northward. Once filling was completed in the southeastern
portion of the Site, the Company subdivided the property and sold it to developers. As the
adjacent wetlands and the stream valley were filled, those portions of the property too were
subdivided and sold for development. Approximately 25 acres were filled, which now
constitutes the Site. A summary of waste filling activities is shown in Figure 2, Appendix B.

By the mid-1990s, the southern portion, which consists of approximately 18 acres, had
been developed for residential and commercial uses. In 1988, the northern portion of the Site
was an undeveloped 6.8-acre parcel, referred to as the Calabrese parcel (Figure 1, Appendix B).
This parcel was in the initial stages of development for a proposed elderly housing complex
when a number of capacitors, ash, cinder, crushed drums containing sludge material, metal
waste, demolition debris and other waste materials were encountered at depths ranging between
8 and 20 feet below grade. The waste materials were found to contain elevated levels of PAHs,
PCBs, and metals. Development of the Calabrese parcel ceased and the parcel remains
undeveloped.

A more detailed description of the Site history can be found in Section 1.3 the RI Report
(Nobis, 2013a).

2. History of Federal and State Investigations and Removal and Remedial Actions

The discovery of PAH, PCB, and metals contamination in soil at the Calabrese parcel led to
subsequent investigations throughout the Site and the NPL listing of the Site in 2000.
Investigations and actions taken to date are summarized below. A more complete description of
these can be found in Sections 1.3 and 2.0 of the RI Report (Nobis, 2013a).

• In 1988, Calabrese initiated excavation activities on the Calabrese parcel for a planned
development. In March 1989, the Connecticut Department of Energy and Environmental
Protection (CT DEEP) inspected the Calabrese parcel following citizen complaints to the
City of Waterbury regarding suspected wetland violations. CT DEEP noted waste

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materials excavated and staged in piles located throughout the property and water within
the excavations exhibited an oily sheen. CT DEEP also observed electrical capacitors,
rusted drums containing sludge material, metal wastes, and other materials and collected
soil samples. Sample results indicated elevated concentrations of PCBs and several
metals. The City of Waterbury issued a cease and desist order on all work being
conducted at the property based on the soil contamination and wetland violations.

• In October 1989, CT DEEP issued a Hazardous Material Order (No. HM-637) to Joseph
Calabrese requiring: investigating the impacts of contamination to human health and the
environment; developing a remedial strategy; and once approved, performing remediation
and follow-up monitoring. Joseph Calabrese attempted to conduct some
investigation/remediation activities; however, the extent of these activities is not
currently known and he did not complete the required work.

• In January 1998, CT DEEP and EPA initiated Phase I site assessment activities at the
Calabrese parcel, and added it to the EPA list of potential Superfund candidate sites. CT
DEEP indicated that numerous capacitors and waste material remained exposed at the
ground surface, and trespassing was evident. Follow-up soil sampling confirmed the
presence of several metals, volatile organic compounds (VOCs), petroleum-related
substances, and PCBs.

• In the spring of 1998, CT DEEP removed approximately 2,300 tons of PCB-
contaminated soil and 18 capacitors from the Calabrese parcel. The area was temporarily
capped with 1 foot of topsoil and hydroseeded. After the installation of the temporary
cap, a fence was installed around the perimeter of the Calabrese parcel.

• In 1999, EPA completed a Site Inspection and collected 124 surface soil samples.

Samples collected from within the Site limits showed elevated levels of PAHs, PCBs, and
metals (chromium, copper, nickel, silver, vanadium, and zinc) (Weston, 1999). These
data were used to support the listing of the Site on the NPL.

• In July 2000, the Site was added to the NPL.

• During the fall of 2002, EPA initiated Phase I of the RI. Phase I included 45 surface and
76 subsurface soil samples, a geophysical survey, and surface water and sediment
sampling.

• In March 2003, EPA issued an Administrative Order to Saltire Industrial, Inc. (Saltire)
(successor to the Company) and others to complete the remaining RI activities. During
the summer of 2004, Saltire's contractors began Phase II of the RI. However, in August
2004, Saltire filed for Chapter 11 Bankruptcy protection and halted any further data

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collection and/or analysis by its contractors. In March 2005, EPA compiled all available
data collected prior to the Saltire bankruptcy.

• From 2008 to 2011, EPA conducted remaining RI (Phase III) activities. Phase III
included surface and subsurface soil sampling for chemical and physical properties,
monitoring well installations, groundwater sampling, vertical groundwater profiling, and
ecological and human health risk assessments. Varying concentrations of numerous
organic and inorganic chemicals were detected in the surface and subsurface soil and
groundwater; but were primarily limited to semi-volatile organic compounds (SVOCs),
PCBs (Area J or Calabrese parcel only), and metals in soil, and sporadic detections of
VOCs in groundwater.

A more detailed description of historic investigations can be found in Sections 1.3 and 2.0
the RI Report (Nobis, 2013a).

3. History of CERCLA Enforcement Activities

• In July 2000, EPA placed the Scovill Site on the NPL making it eligible for federal
assistance for clean up.

• Searches for Potentially Responsible Parties (PRPs) were conducted between 1999
through 2003.

• Information request letters were issued to various parties under Section 104(e) of
CERCLA in 2000, 2001, 2002, and 2004.

• EPA issued letters to Scovill Manufacturing Company, Joseph Calabrese and Calabrese
Construction Company notifying them of their potential liability for costs of cleanup at
the Site.

• EPA issued a Unilateral Administrative Order to Saltire Industrial Inc. (the successor to
Scovill Manufacturing Company), Joseph Calabrese, Calabrese Construction Company
and Store Avenue Associates, LLC (the owner of Area J) in 2003. Saltire started Phase II
of the Remedial Investigation but filed for bankruptcy protection in 2004.

• After Saltire filed for bankruptcy, EPA entered into a settlement agreement with the
bankrupt estate in March 2006.

• A description of EPA's and CT DEEP's investigations of the Site is provided in the
previous section of this ROD (History of Federal and State Investigations and Removal
and Remedial Actions).

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• To date, no remedial or removal action under CERCLA has been performed.

C. COMMUNITY PARTICIPATION

Throughout the Site's history, community concern and involvement has been high. The
EPA has kept the community and other interested parties apprised of Site activities through
informational meetings, fact sheets, press releases and public meetings. Below is a brief
chronology of public outreach efforts.

•	In September 2000, the EPA initiated a community relations plan to address community
concerns and keep citizens informed about and involved in remedial activities.

•	EPA provided the City of Waterbury with grant assistance in July 2004 for a reuse
planning study for a portion of the site.

•	In November 2004 a community meeting was held to undertake a reuse planning process
to develop future land use recommendations for a portion of the Site.

•	In February 2005 a second community meeting was held to discuss the reuse strategy for
a portion of the Site.

•	In October 2008, the EPA held a public informational meeting to describe the plans for
the RI and Feasibility Study (FS).

•	On March 3, 2011, EPA held an informational meeting at the WARC facility in
Waterbury, CT to discuss the results of the RI.

•	In July 2013, EPA made the Administrative Record available for public review on-line as
well as at EPA's offices in Boston and at the Silas Bronson Library, 267 Grand Street,
Waterbury, CT, 06705. The library will be the primary information repository for local
residents and will be kept up to date by EPA.

•	In July 2013, EPA mailed the Proposed Plan to 20 owners of property considered part of
the Site, and 80 nearby property owners.

•	On July 24, 2013, EPA published a notice and brief analysis of the Proposed Plan which
presents the proposed remedy for the Site in the Waterbury Republican American and
made the Proposed Plan available to the public at the Silas Bronson Library.

•	From July 24, 2013 to August 24, 2013, the Agency held a 30-day public comment
period to accept public comments on the alternatives presented in the FS (Nobis, 2013b),
the Proposed Plan, and on any other documents previously released to the public.

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•	On August 6, 2013, EPA held an informational meeting to discuss the results of the RI
and the cleanup alternatives presented in the FS (Nobis, 2013b) and to present the
Agency's Proposed Plan to a broader community audience than those that had already
been involved at the Site. At this meeting, representatives from EPA, CT DEEP, and CT
Department of Public Health (CT DPH) answered questions from the public.

•	On August 6, 2013, the Agency held a public hearing to discuss the Proposed Plan and to
accept any oral comments on the Proposed Plan. A transcript of this hearing, the
comments received, and the Agency's response to comments are included in the
Responsiveness Summary, which is part of this ROD (Part 3).

•	From 2000 through 2011 EPA has issued Fact Sheets and Activity Updates to keep the
community up to date on ongoing activities at the Site.

D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

The selected remedy was developed by combining components of different remedial
alternatives to address potential health risks resulting from exposure to Site contamination
(estimated health risks are summarized by risk area on Figure D-l in Appendix B). In summary,
the remedy provides a comprehensive approach for this Site that addresses all current and
potential future risks caused by soil contamination and potential vapor intrusion issues from
contaminated groundwater. These soil and vapor intrusion remedial actions include soil
excavation and capping to remove exposure risks to soil contamination from the top 4 feet of soil
and prevent leaching of soil contaminants into groundwater; active vapor mitigation to prevent
potential exposure in buildings to vapor intrusion from groundwater contamination; and
institutional controls to prevent exposures.

The remedy was developed to be consistent with ARARs (specifically the state's
Remediation Standard Regulations or RSRs) and the definition of "inaccessible soil". Per the
RSRs, inaccessible soil is defined as follows:

•	Contaminated soil deeper than 4 feet;

•	Contaminated soil deeper than 2 feet below a paved surface; and

•	Contaminated soil below an existing building and/or permanent structure.

Institutional controls are needed to ensure these conditions are maintained.

Specifically, the remedy will utilize:

•	In Risk Areas D3, E2, E3, G and H - Human health risks for these risk areas based on
current uses are below 1.0E-04, the threshold for remedial action for the Site (Areas D3,

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E2, G, and H) or where CULs are not exceeded in accessible soil (Area E3). However,
limited actions are appropriate to prevent exposures in the event of future changes in site
use. Alternative S02 has been selected for these risk areas and will consist of:
institutional controls to prevent potential exposures and excavations in contaminated soil;
prevent residential uses in areas that are not currently used as residential; periodic
assessments to ensure institutional controls are implemented; and Five-Year Reviews to
review Site conditions and the protectiveness of remedy.

•	In Risk Areas Dl, El, and F - Human health risks for these risk areas are equal to or
exceed 1.0E-04, or levels of contaminants in soil exceed the CUL. Alternative S03 has
been selected for these risk areas and will consist of: targeted excavations (within the top
4 feet of soil for PRG exceedances or to the top of groundwater for PMC exceedances)
with off-site disposal to prevent exposure to contaminated soil in these areas; institutional
controls to prevent exposures and excavations in contaminated soil; periodic assessments
to ensure institutional controls are implemented; and Five-Year Reviews to review site
conditions and protectiveness of remedy.

•	In Risk Area J - Human health risks for this risk area exceed 1.0E-04 and levels of
contaminants in soil also exceed the CUL. Alternative S06 has been selected for Area J
and will consist of: a pre-design investigation to further characterize the extent of soil
contamination for remedial design and remedial action; soil capping to prevent exposure
to contaminated soil; operation and maintenance (O&M) of the soil cap; institutional
controls to prevent exposures and excavations in contaminated soil and to require the
long-term care of the soil cap; periodic assessments to ensure institutional controls are
implemented; and Five-Year Reviews to review site conditions and protectiveness of
remedy.

•	In Risk Area I - Human health risks for this risk area exceed 1.0E-04 and levels of
contaminants in soil also exceeds the state's PMC. Alternative S08 has been selected for
Area I and will consist of: a pre-design investigation to further characterize the extent of
soil contamination; excavation with off-site disposal to prevent exposure to contaminated
soil; institutional controls to prevent exposures and excavations in contaminated soil;
periodic assessments to ensure institutional controls are implemented; and Five-Year
Reviews to review site conditions and protectiveness of remedy.

•	In Risk Area El - There is a potential for VOCs to volatilize from groundwater beneath
the existing building and reach indoor living areas in Area El. Therefore presumptive
remedy, Alternative VI3, was selected for Area El (which includes a building currently
occupied by residents) and will consist of: a PDI to evaluate exposure pathway and if
present install an active soil vapor mitigation to prevent exposure to potential vapor
intrusion from contaminated groundwater; O&M of the active soil vapor mitigation
system; institutional controls to prevent potential exposure by requiring the use of a vapor

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mitigation system; and Five-Year Reviews to review site conditions and protectiveness of
remedy; and

• In Risk Area J - There is a potential for VOCs to volatilize from groundwater and reach
future living areas in Area J. Alternative VI2 was selected for Area J (currently
undeveloped) and will consist of: institutional controls to prevent potential exposure by
requiring the use of a vapor mitigation system for new construction; and Five-Year
Reviews to review site conditions and protectiveness of remedy.

The source material waste at the Site, consisting primarily of ash mixed into soil,
constitutes a Low-Level Threat due to the lengthy exposure duration necessary for the identified
Contaminants of Concern (COCs) to create risk, and the general non-mobility of the identified
COCs. There are no Principal Threat Wastes identified for the Site.

The low-level threats that this ROD addresses are summarized in the following table:

Low-Level Threats

Medium

Contaminant(s)

Action To Be Taken

Cancer risks

Soil

Low level PAHs,
PCBs, dioxins, and
few metals

Excavation and off-site
disposal (Areas Dl, El, F,
and I), soil cap (Area J),
institutional controls (All
Risk Areas)

Cancer risks

Groundwater

VOCs

Active vapor mitigation
system (Area El);
institutional controls (Areas
El and J)

E. SITE CHARACTERISTICS

The significant findings of the RI can be found in the 2013 RI Report (Nobis, 2013a) and
are summarized below. In addition, Section 1 of the FS (Nobis, 2013b) contains an overview of
the RI results. Refer also to CT DEEP's Groundwater and Use Value Determination (CT DEEP,
2010) for a more detailed discussion of groundwater use at the Site.

1. Physical Setting

This section has been divided into the following subsections: Site geology, hydrogeology,
surface water hydrology, and groundwater use and value.

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Site Geology

Based on the Phase I (2002), Phase IIA (2004), and Phase III (2008) soil investigations,
along with a subsequent review of available boring logs and field notes, the overburden
subsurface lithology of the Site is interpreted to consist primarily of 12 to 18 feet of a dark
brown, gray, and black ash/waste mixed with varying amounts of silt and sand. A discontinuous
peat layer ranging between 13 to 24 feet below the ground surface (ft bgs) and between 6 inches
and 5 feet in thickness was encountered in the southwestern and central portions of the site.
Deeper sample locations indicate clayey silt/silty clay with little to trace gravel (dense) but these
strata are not described as till. Phase III boring logs for deeper soil borings indicate a saturated,
very dense sandy silt layer with some gravel at depths of between 11 and 22 ft bgs, which is
characterized as till.

The ash material, generally characterized as soft, fine, and black in color, when found was
deepest through central portions of the Site (18 ft bgs) and extends to the southern boundary as
well as the eastern and western side slopes. Along the southern edge of the Site, ash depths
reach approximately 14 ft bgs. The waste appears to terminate at the northern end of the Site
prior to reaching Dallas Avenue in the vicinity of a small wooded area, the adjacent wetlands,
and the Meridian Apartments.

Bedrock at the Site is mapped as Waterbury Gneiss Formation which is characterized as a
dark gray, fine to medium grained composite of schist and gneiss. The seismic refraction study
performed at the site found bedrock sloping south to southeast at approximately 5 percent dip.
The sole bedrock borehole advanced at the Site corroborated the seismic refraction study relative
to depth to bedrock.

Hydrogeology

The groundwater underlying the Site is classified by CT DEEP in the 2011 Connecticut
Water Quality Standards as GB, indicating ".. .a historically highly urbanized area or an area of
intense industrial activity and where public water supply service is available. Such ground water
may not be suitable for human consumption without treatment due to waste discharges, spills or
leaks of chemicals or land use impacts." Based upon available soil boring observations coupled
with permeability data and groundwater elevations, two separate overburden hydrogeologic units
(fill material and till deposits), and one bedrock hydrogeologic unit are present beneath the Site.
Although till was found overlying bedrock, it does not act as an aquaclude based on a relatively
high permeability.

Both overburden aquifer units exhibit similar groundwater flow directions, from
topographically-high zones to lower zones (south to southwest, following the historical flow path
of Carrington Brook). Only one bedrock monitoring well is located at the Site, and groundwater
flow direction could not be determined. Vertical gradient data suggest that minimal vertical flow
exists between the shallow and deeper overburden. These flows are variable, generally

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downward, and reversible on occasion. A consistent vertical flow in the upward direction was
noted between the sole bedrock and deep overburden couplet located at the southern end of Risk
Area J.

Surface Water Hydrology

There are two seasonally wet areas located in depressions on the eastern and western edges
of the Calabrese parcel. These are topographic low areas created by the raised surface of the
Calabrese parcel cap area on one side and the uphill slopes of Monroe Avenue on the west and
Academy Avenue on the east. In the eastern area, precipitation and surface water runoff from
the sloping backyards on Academy Avenue, Dallas Ave and the Sanford Condominiums as well
as a small portion of the Calabrese Parcel are eventually trapped with no outlet by the raised
surface of Radcliffe Avenue. In the western area, precipitation and surface water runoff from the
Calabrese parcel and the sloping backyards on Monroe Avenue and the Meriden Apartments are
eventually trapped with no outlet by the raised area behind 119 Store Avenue. There is no
standing water during dry periods.

Aside from the small pond at Hamilton Park, the nearest surface water body is the Mad
River, located approximately 1 mile southwest and downgradient of the Site. According to the
CT DEEP's Use and Value of Groundwater evaluation, Site groundwater is incorporated into the
regional groundwater flow towards the Mad River.

The Site is located outside of the 500-year floodplain (US Department of Housing and
Urban Development, 1979); however, observations at the Site indicated that topographic low
areas in the northeastern and southwestern portions of the Site are seasonally wet and accumulate
runoff from adjacent on-site and off-site areas.

Groundwater Use and Value

In 2010 CT DEEP determined that the contaminated aquifer within the Review Area for the
Scovill Industrial Landfill NPL Site in Waterbury, Connecticut, is a Low/Medium Use and Value
Aquifer, based on the considerations presented in the Ground Water Use and Value
Determination Document. The CT DEEP has also determined that immediate restoration of the
contaminated aquifer is not required.

2. Conceptual Site Model

The sources of contamination, release mechanisms, exposure pathways to receptors for the
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 illustrates 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

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exposure through contaminant release and migration to potential receptors. The risk assessment
and response action for the contaminated soil and soil vapor at the Site are based on this CSM.

The CSM constructed for this Site is based on the results from three different phases of the RI
program conducted between 2002 and 2011, and includes the following observations:

• Soil mixed with ash is present throughout the 25-acre Site. COCs as determined by the
human health risk assessment (Summarized in Section G.l) primarily consist of PAHs
and metals. PCBs are also COCs in the Calabrese parcel (Area J), only.

• Most of the Risk Areas are currently paved or occupied by buildings or structures. Some
of the occupied areas are vegetated by lawns and turf. Area J is currently undeveloped.

• Contaminated soil exceeding PRGs is present in surface (0 to 2 ft bgs below the turf) and
subsurface soil (2 to 10 ft bgs). No one is currently exposed to contaminated soil.

• If pavement is not maintained or erodes, contaminated soil will become exposed and
potential exposure to residents and commercial/industrial workers will occur resulting in
excess risks in several risk areas.

• Contaminated soil (vanadium) is present at concentrations in discrete locations
throughout the Site that may pose threats to surface water quality, if leached into the
underlying aquifer.

• VOCs have been detected sporadically in monitoring wells in Area El at concentrations
that may pose potential vapor intrusion threats to the residents on the groundwater floor
units in the apartment complex at 119 Store Avenue.

Known and Suspected Sources of Contamination

Landfilled waste reportedly consisted of ash, cinders, debris, metal materials and other
unknown waste materials generated by the Company's operations. Presumably, the ash materials
were derived from the burning of coal; however, the specific components of the wastes disposed
of at the Site are not known. While much of the Site area appeared to have received a consistent
waste material, the waste material excavated from the Calabrese Parcel appeared to contain
materials not observed in other areas of the Site (i.e., high PCB concentrations, capacitors, rusted
drums, and sludge). Additionally, one debris sample collected from 10 to 12 ft bgs on the
Calabrese Parcel contained 16.2% asbestos (chrysotile). No additional potential asbestos
containing materials were found.

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Soil Contamination

Soil contamination at the Site occurs in surface (0-2 ft bgs), subsurface (>2-10 ft bgs), and
deep subsurface (>10 ft bgs). While VOCs were detected in soil samples, only one sample
slightly exceeded the CT DEEP's Remediation Standard Regulations (RSR) Direct Exposure
Criteria (DEC) (Figure E-l, Appendix B). Benzene, carbon tetrachloride, tetrachloroethylene
(PCE), trichloroethylene (TCE), and vinyl chloride exceeded the RSR GB PMC; but subsequent
Synthetic Precipitation Leaching Procedure (SPLP) tests suggest there is little likelihood of
leaching. The elevated VOC concentrations appeared to be limited to areas either currently or
formerly utilized for automotive sales/service or dry cleaning.

SVOCs were detected in soil samples collected throughout the Site area and are
dominated by the presence of PAH compounds associated with the coal ash and combustion by-
products (Figure E-2, Appendix B). The PAH distribution appears to be somewhat consistent
throughout the Site area and waste depths. PAHs detected in Site soil include:
benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)fluoranthene;
dibenz(a,h)anthracene; and indeno(l,2,3-cd)pyrene. Numerous SVOCs (including PAH
compounds) exceeded DEC and PMC throughout the Site. Again, SPLP tests suggest there was
little likelihood of leaching for the SVOCs with the exception of bis(2-ethylhexyl) phthalate in a
couple of samples.

Pesticide concentrations in soil samples did not exceed or slightly exceeded DEC (Figure
E-3, Appendix B). Alpha-chlordane, gamma-chlordane, dieldrin, and heptachlor-epoxide each
exceeded the GB PMC in surface soils. 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, dieldrin, and
heptachlor-epoxide also exceeded GB PMC in subsurface soils. These pesticides have a strong
affinity for sorbing to soil and are unlikely to leach. 4,4'-DDE and 4,4'-DDT are the most
frequently detected pesticides in the surface soil samples, and their distribution may be indicative
of post development application rather than a component of the waste material. With the
extensive reworking of the area as part of the post-Scovill development, an intermixing of any
applied pesticides could have been incorporated into deeper deposits.

PCB and dioxin/furan concentrations exceed DEC in soil samples collected primarily
from the Calabrese parcel, but also on the northern extent of 119 Store Avenue (Area El,
adjacent to the Area J). PCB contamination in surface soil appears to be limited to the central
and southern portions of the Area J (Figure E-4, Appendix B). The limit of PCB contamination
detected in the surface soil is based upon a relatively small number of samples. Given the
reportedly irregular deposition of the waste, there may be additional PCB contamination in parts
of Area J. PCB contamination in the deeper soil zones extends to the north and northeast from
the surface soil PCB contamination to a maximum depth of approximately 20 ft bgs. PCBs were
not detected in SPLP leachate, suggesting that the PCB contamination particularly in the Area J
is unlikely to leach to groundwater.

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Dioxins/furans (as toxicity equivalents, TEQ) were detected in Site soil, primarily in and
adjacent to Area J. There are no RSR DECs for dioxin/furan TEQ. However, a qualitative
comparison with EPA health-based screening levels indicated that dioxin/furan TEQ may be a
potential contaminant of interest.

Several metals including arsenic, beryllium, cadmium, chromium, copper, lead, nickel,
and vanadium exceeded DEC and GB PMC (Figures E-5 through E-9, Appendix B). Beryllium
only exceeds the DEC once out of 213 total samples and is not of concern. Like the SVOCs,
these metals are widely distributed across the Site both laterally and vertically. SPLP analyses of
soil samples collected from across the Site reported three exceedances of the GB PMC for lead
and four exceedances of the vanadium criteria indicating a potential for leaching to groundwater
in some areas of the Site. A supplemental evaluation using a 95% Upper Confidence Limit
confirmed the leaching potential for vanadium but not for lead.

Groundwater Contamination

Overburden groundwater within the shallow aquifer has low concentrations of several
organic and inorganic chemicals. There is no coherent or distinct VOCs contaminant plume.
The groundwater is classified GB and does not serve as a drinking water supply. Of particular
note is the presence of two VOCs, vinyl chloride and 1,1-dichloroethene, in monitoring well
MW-12S located near an occupied apartment complex (in Area El) that exceed the RSR
Groundwater Volatilization Criteria. Detections of vinyl chloride at other monitoring wells were
sporadic, at trace concentrations, from deep overburden groundwater (with overlying shallow
overburden groundwater at non-detect concentrations), or at locations over 100 feet from the
nearest structure. In addition, other VOCs including cis-l,2-dichloroethene, PCE, and TCE also
were sporadically detected in overburden groundwater samples, but did not exceed Volatilization
Criteria. Based on results from the sole bedrock monitoring well, it does not appear that
contamination extends into the bedrock aquifer at this location. The irregular detections and
scattered occurrences across the Site and through time do not suggest a coherent VOC
groundwater plume. Some biodegradation of these compounds is assumed based on the presence
of daughter products (Figure E-10, Appendix B).

The majority of the PAH compounds were detected infrequently in all aquifers. SVOCs
detected more frequently included the PAHs acenaphthene and fluorene, bis(2-
ethylhexyl)phthalate (BEHP), and caprolactam. None of these compounds was detected at
elevated concentrations, and with the possible exception of BEHP, are generally derived from
coal ash or other combustion by-products.

No elevated pesticide or PCB contamination was noted in groundwater samples.

Numerous metals were detected in groundwater samples, both total and dissolved. No
comparisons were made to drinking water criteria because the groundwater underlying the Site
area is classified as GB and is not used as a drinking water source.

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CT DEEP Surface-Water Protection Criteria (SWPC) were exceeded for several chemicals.
A supplemental evaluation showed that Site contaminants do not pose a threat to the nearest
surface water body.

Surface Water Contamination

Several VOCs, SVOCs, and metals were detected in surface water samples collected
from the ephemeral northeast Wetland 1. Total metals concentrations were much greater than
the dissolved metals concentrations, suggesting a significant quantity of suspended solids in the
standing water in the wetland area. Several metals detected in the total metals samples exceeded
acute and chronic values for National and Connecticut water quality criteria. The dissolved
metals samples exceeded only one acute Connecticut and two chronic Connecticut screening
criteria. It is possible that this suspended solid material may also be a contributing factor in the
detection of VOCs and moderately-insoluble SVOCs in these surface water samples. The
presence of previously noted refuse and garbage within this wetland likely contribute to the
detection of these contaminants.

Sediment Contamination

Analytical results of sediment samples collected from the two ephemeral wetlands
reported the presence of a number of organic and inorganic contaminants at concentrations
exceeding screening criteria. Though it is possible that the contaminants may have been Site-
derived, the presence of a large quantity of potentially contaminated debris in and around these
wetland areas and also parking lot and upgradient runoff may also have contributed to the
contaminants present within these wetlands.

Analytical results of sediment samples collected from areas upstream of Wetland 1
identified the presence of numerous SVOCs, several pesticides, and PCBs at concentrations
exceeding screening levels. It is likely that these substances resulted at least partially, from
parking lot runoff or releases onto the adjacent parking lot migrating to either a nearby upstream
storm drain or to the upstream sediment sampling location.

One sample of catch basin bottom sediment was collected from the downstream catch
basin nearest the Site. Minimal PAH contamination was noted in this sample and no PCBs were
detected. Two sediment samples were collected downstream of the Site. One where the
Carrington Brook storm drain and comingled storm water from other parts of urban Waterbury
discharge to the small impoundment pond at Hamilton Park, and the other at the pond outlet
located approximately 0.8 miles southwest of the Site. Low concentrations of VOCs and
pesticides were reported in these samples. SVOC contamination was dominated by PAH
compounds. PCBs were also detected in each of these downstream sediment samples. Low
concentrations of several metals were reported with copper, lead, and zinc exceeding screening
criteria.

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Conceptual Site Model Summary

The CSM is summarized below:

• Chemical concentrations in soil vary widely across the Site, including elevated
concentrations of PAHs, metals, and PCBs (Area J only). These analytes are present in
soil at concentrations exceeding PRGs in surface (0 to 2 ft bgs below the turf) and
subsurface soil (2 to 10 ft bgs). However, no one is currently exposed to contaminated
soil.

• In general, soil contaminants are relatively immobile and do not easily leach to
groundwater. However, vanadium is present at concentrations in discrete locations that
may pose threats to surface water quality, if leached into the underlying aquifer.

• Site groundwater is located in a GB aquifer and is considered unsuitable for potable water
uses.

• Irregular detections and scattered occurrences of various analytes across the Site do not
suggest a contaminant plume in groundwater.

• There is no Principal Threat Waste identified for the Site.

F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

As shown on Figure 1, the Site was divided into 10 exposure "Areas" for risk assessment
purposes. Approximately 18 of the 25 acres of the Site are developed, consisting of two- and
three-story condominiums and apartment buildings (Areas Dl, El, E3, and F), small commercial
buildings (Areas D3, E2, G, and H), and a shopping center (Area I). Area J is undeveloped.
Except for Area E3, which is zoned for residential use, the Site is currently zoned for commercial
use. However, as noted above, some commercially-zoned parcels with apartment buildings are
actually used for residential purposes.

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Land Uses:

Approximately 18 of the 25 acres of the Site are developed along Store Avenue and Dunbar
Street, and consist of two and three story residential structures (single family homes and
apartment buildings), small commercial buildings that include a landscaping firm, child daycare
facility, elderly housing, social club, department store, cab service, former medical office, car
repair shop, and a shopping mall (East Gate Shopping Plaza). The remaining 7-acre parcel is
undeveloped and was in the initial stages of development by Calabrese Construction, Inc. prior to
listing of the Site on the National Priorities List. Approximately 4 of the 7 acres are currently
fenced and posted.

The City of Waterbury, Connecticut is a medium-density city. As of the 2010 US Census,
the city population is estimated at 110,366 people. Land usage in the areas proximal to the Site
is urban and includes both residential and commercial.

Existing municipal zoning of the Site area is primarily classified as Arterial Commercial
with smaller portions classified as Neighborhood Shopping. The only property on the Site zoned
Low-Density Residential is the apartment complex at 136 Store Ave in parcel E3 (City of
Waterbury, 1999). However, other portions of the site are also currently used as residential,
including buildings in Areas El, D1 and F.

The majority of the Site is currently developed. While it is reasonably anticipated that
current land use will remain in place, based on past history at the Site, it is also possible that
properties now zoned commercial could have residential uses in the future (for this reason,
institutional controls will be used to restrict residential uses in certain areas as part of this ROD,
Section L). EPA provided funding for the City of Waterbury to undertake a reuse planning
process to develop future land use recommendations for the undeveloped 6.8-acre Calabrese
Parcel at the northern side of the Site. Community and stakeholder input was sought and
incorporated through an active outreach program which included two public meetings. The
findings indicated that multiple land uses including congregate housing, a medical/senior
wellness center, and passive recreational areas could be located on this parcel. Details of the
planning process can be found in the Reuse Planning Report for the Calabrese Parcel (E2, 2005).

Ground/Surface Water Uses:

The City of Waterbury obtains potable water from a series of reservoirs located between
15 and 30 miles northwest of the Site. An estimated 40,970 people are served by groundwater
potable supplies that are located between one and four radial miles from the Site. City health and
water officials stated that no potable water wells had been installed within the Site or
surrounding area.

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According to the CT DEEP Groundwater Use and Value Determination, the Site overlies
a GB aquifer and the groundwater within the GB classification (which includes the groundwater
beneath the Site) was assigned a value of "Low." The GB aquifer extends south to Interstate 84
and east of the Mad River. Areas west of the Mad River, or south of Interstate 84 are assigned a
GA aquifer status was given a value of "Medium." Since public water is available to all
properties, the State has assigned a Low rating for the Likelihood and Identification of Future
Drinking Water factor. According to the Report, "It is extremely unlikely any private drinking
water wells will be installed within the Review Area [including the Site] in the future because the
Connecticut Public Health Code prohibits a well permit from being issued for any property
which is located within 200 feet of a community water supply system."

Based on the State's groundwater classification and its Groundwater Use and Value
Determination, EPA does not consider the potential beneficial reuse of the groundwater at the
Site and in the surrounding area to be drinking water.

The State has assigned a Medium/Low rating to the area ecological resources including
Carrington Brook and wetlands located in Risk Area J. Carrington Brook is culverted through
the Site. A small pond in Hamilton Park is the only viable swimming and fishing area in the
vicinity of the Site. Observations of fishing at the pond have been made by EPA contractors and
CT DEEP personnel. However, no evidence of swimming in this pond was ever observed.
Additionally, Hamilton Park appears to be the only recreation area near the Site. No other
playgrounds, parks, or other areas are located in the immediate area.

Public input has been solicited throughout the State's process of determining the use and
value of groundwater use at the Site. Several public meetings have been held during the RI
process and input from the public about the use and value of site groundwater was not received.
Public hearings were also held in 1981 and in 1997 when the State established and revised
groundwater goals for the area surrounding the Site. Opportunity for public comment was made
available during public hearings and workshops.

G. SUMMARY OF SITE RISKS

A Site-specific baseline risk assessment was performed to evaluate the likelihood and
degree of potential adverse human health and environmental effects from exposure to
contaminants associated with the Site assuming no remedial action was taken. It is used to
determine the need for taking action and identifies the contaminants and exposure pathways that
need to be addressed by the remedial action. The human health risk assessment (HHRA)
followed a four step process: 1) hazard identification was conducted using site-specific data on
the nature and extent of contamination to identify contaminants of potential concern and to
estimate exposure point concentrations for each medium (e.g., soil or water); 2) exposure
assessment, which identified actual or potential exposure pathways, characterized the potentially
exposed populations, and estimated the frequency and duration of possible exposure; 3) toxicity
assessment, which considered the types and magnitude of adverse health effects associated with

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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 cancer and non-cancer health hazards. The cancer risks and
non-cancer health hazards of the HHRA that exceed EPA's goals for protection, and the
uncertainties in the risk assessment are discussed below followed by a summary of the
environmental risk assessment.

1. Human Health Risk Assessment

Potential human health effects associated with exposure to the chemicals of potential
concern were estimated quantitatively or qualitatively through the development of several
assumed 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. A summary of the estimated risk by risk area is presented in Figure D-l (Appendix B).

Exposure Assessment

For purposes of the HHRA exposure assessment, the Site was divided into parcels and risk
areas. The 16-acre developed parcel, consisting of two- and three-story residential structures
(apartment buildings) and small commercial buildings that include a landscaping firm, child
daycare facility, elderly housing, social club, department store, cab service, medical office, car
repair shop, and a shopping mall (East Gate Shopping Plaza), is referred to as Parcel A. The 4-
acre undeveloped parcel, including the fenced cap area and unfenced undeveloped open space
within the limits of the landfilling activity is referred to as Parcel B (and also known as Area J).
For consideration of soil exposures, the Site was further divided into 10 risk areas based on
current land use and potential exposures. Risk areas are shown on Figure 1.

Parcel A (Areas Dl, D3, El, E2, E3, F, G, H, and I) is developed for a mixture of uses
including apartment buildings, elderly housing, day care, and commercial properties.

Specifically, Areas Dl, El, E3, and F are currently used as residential properties (El is occupied
by primarily elderly housing); Areas D3, G, H, and I are currently used as commercial
properties; Area E2 is currently used as a daycare facility. It is reasonable to expect that each of
these developed areas will continue its current use in the future. Based on the Site's history,
there is also a possibility that properties that are currently zoned commercial could have
residential uses in the future. For purposes of the HHRA, the future uses were assumed to be the
same as current uses (the more likely scenario). However, in developing the risk management
approach for this ROD, the possibility that commercial properties may be used for residential
purposes in the future was taken into account. Future residential exposures at current
commercial properties were not evaluated in the HHRA, but were later evaluated in the FS using
the same data, exposure assumptions, and toxicity values used in the HHRA.

Under current conditions, Parcel B (Area J) is undeveloped, with no regular activities
occurring at the Site. The capped portion of Parcel B is fenced (Figure 1, Appendix B). Access

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to Parcel B is generally controlled by the fencing; however, there is no gate security. Beyond the
fencing, Parcel B consists of undeveloped open space, including wetlands. Parcel B (Area J) is
expected to be used for commercial purposes in the future; however, there are no restrictions
currently in place prohibiting future residential use. Groundwater located beneath the Site is not
currently used as a source of potable water. Receptors are not expected to contact groundwater.
However, contaminants in shallow groundwater may volatilize into current or future indoor air
spaces at Parcel A or into future buildings at Parcel B. Current or future human receptors may
potentially be exposed to volatiles in indoor air.

Hazard Identification

Forty-five of the more than 136 chemicals detected in soils at the site were selected for
evaluation in the HHRA as chemicals of potential concern. Twenty-one of the more than 126
chemicals detected in groundwater at the site were selected for evaluation in the HHRA 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 A, Tables A-2.2 and
A-2.5 of the final HHRA (Nobis, 2011). From this, a subset of the chemicals was identified in
the FS as presenting a significant current or future risk. These are referred to as the chemicals of
concern (COCs) in this ROD and summarized in Tables G-l through G-4 (Appendix D). These
tables contain the exposure point concentrations (EPCs). EPCs are the contaminant
concentrations for a given environmental medium at the point of human contact and are used in
the qualitative risk evaluation of the reasonable maximum exposure scenario (RME) in the
baseline risk assessment for the COCs. The RME is defined as the highest exposure that is
reasonably expected to occur at the Site.

Exposure Pathways

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 to be greater than the risk predicted. The resulting risk estimates are expressed in
scientific notation as a probability (e.g., 1E-06 or 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 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 10"4to 10"6. Current
EPA practice considers carcinogenic risks to be additive when assessing exposure to a mixture of

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hazardous substances. A summary of the cancer toxicity data relevant to the chemicals of
concern is presented in Table G-5 (Appendix D).

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 reference
concentration (RfC). A summary of the noncarcinogenic toxicity data relevant to the chemicals
of concern is presented in Table G-6 (Appendix D). An HQ < 1 indicates that an exposed
individual's dose of a single contaminant is less than the RfD or RfC and that a toxic effect is
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. An HI < 1 indicates that adverse non-carcinogenic effects
are unlikely for chronic exposure.

The following is a brief summary of the exposure pathways that were found to present a
significant risk. Only those exposure pathways deemed relevant to the remedy being proposed
are presented in this ROD. Risk characterization for these exposure pathways are summarized
Tables G-7 through G-16. For purposes of the HHRA (and discussion below), surface soil refers
to 0 to 2 ft bgs and aggregate soil is 0 to 10 ft bgs. A summary of estimated risk by risk area is
presented on Figure D-l in Appendix B. Readers are referred to Section 6.0 of the HHRA and
Section 1.5.1 of the FS for a more comprehensive risk summary of all exposure pathways
evaluated for all chemicals of potential concern and for estimates of the central tendency risk.

Current and Future Residents. Exposure to Soil

Unacceptable risks were found for:

1) Current age-adjusted lifetime residents, potentially exposed to surface soil at Areas Dl,
E3, and F;

2) Future age-adjusted lifetime residents, potentially exposed to surface soil at Areas D3,
El, G, H, I, and J;

3) Future age-adjusted lifetime residents, potentially exposed to aggregate soils at Areas Dl,
D3, El, E2, E3, F, G, H, I, and J;

4) Future child residents, potentially exposed to surface or aggregate soils at Areas G and J;
and

5) Future adult residents, potentially exposed to surface or aggregate soils at Area J.

Current and potential future residential receptors were evaluated for potential exposure to soil
via incidental ingestion, dermal contact, and inhalation of fugitive dust and vapors. Non-cancer
risks for residents are evaluated separately for adults and children. Cancer risks are evaluated for
an age-adjusted lifetime resident combining child and adult exposures. The following
assumptions used in the evaluations of residential soil exposures apply to both surface soil and
aggregate soil exposures.

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Adult residents were assumed to be exposed to soil 350 days per year 24 years, ingesting
100 milligrams (mg) of soil per day and contacting soil with hands, forearms, lower legs, and
head (5,700 square centimeters [cm2]). Child residents (ages 0-6 years) were assumed to be
exposed to soil 350 days per year for 6 years ingesting 200 mg of soil per day and contacting soil
with hands, forearms, lower legs, feet, and head (2,800 cm2). Values of 0.07 milligrams per
square centimeter per event (mg/cm2-event) and 0.2 mg/cm2-event were used as soil-to-skin
adherence factors (SSAF) for adult and child exposures, respectively. For all residents,
inhalation of dust and soil vapor exposures assumed exposure occurs 24 hours per day.

Tables G-7 and G-8 depict the carcinogenic risk summary for the COCs in surface soil
evaluated to reflect present and potential future residential exposures to soil via ingestion, dermal
contact and inhalation of dust and vapors corresponding to the RME scenario. Details of route-
specific risks for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC
are provided in Appendix D, Tables G-7A through G-7C and Tables G-8A through G-8F.

Table G-9 depicts the carcinogenic risk summary for the chemicals of concern in
aggregate soil evaluated to reflect potential future residential exposures to soil corresponding to
the RME scenario. Details of route-specific risks for ingestion, dermal contact, and inhalation of
dust or soil vapors for each COC are provided in Appendix D, Tables G-9A through G-9J.

Tables G-10 and G-l 1 depict the non-carcinogenic risk summary for the chemicals of
concern in surface soil and aggregate soil evaluated to reflect potential future residential child
exposures to soil corresponding to the RME scenario. Details of route-specific hazard quotients
for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in
Appendix D, Tables G-10A and G-10B and Tables G-l 1A and G-l IB.

Tables G-12 and G-13 depict the non-carcinogenic risk summary for the chemicals of
concern in surface soil and aggregate soil evaluated to reflect potential future residential adult
exposures to soil corresponding to the RME scenario. Details of route-specific hazard quotients
for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in
Appendix D, Tables G-12A and Table G-l3A.

Table G-7

Risk Characterization Summary - Carcinogens- Current Resident Exposures to Surface Soil

Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Age-Adjusted Lifetime

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Exposure Routes Total

Soil

Surface
Soil

Soil On-site

Area D1

Benzo(a)
anthracene

5.4 x 106

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Benzo(a)
pyrene

6.2 x 105

Benzo(b)
fluoranthene

8.3 x 106

Dibenz(a,h) anthracene

2.2 x 105

Indeno

(1,2,3-cd)
pyrene

6.1 x 106

Arsenic

1.1 x 105

D1 Surface Soil risk total=

1.2 x 10"4

Soil On-site

Area E3

Benzo(a)
anthracene

1.2 x 105

Benzo(a)
pyrene

9.5 x 105

Benzo(b)fluoranthene

1.1 x 105

Dibenz(a,h) anthracene

1.7 x 105

Indeno

(1,2,3-cd)
pyrene

6.6xl0"6

Arsenic

1.1 x 105

Total Chromium

1.1 x 106

E3 Surface Soil risk total=

1.6 x 10"4

Soil On-site
Area F

Benzo(a)
anthracene

1.3 x 105

Benzo(a)
pyrene

7.1 x 105

Benzo(b)
fluoranthene

1.4 x 105

Benzo(k)
fluoranthene

1.4 x 106

Dibenz(a,h) anthracene

2.4 x 105

Indeno(l,2,3-cd)
pyrene

5.2 x 106

Arsenic

2.0 x 10 5



F Surface Soil risk total=

1.5 xlO"4



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Risk Characterization

This table provides risk estimates for the significant current residential surface soil exposure pathways. These risk estimates are based on a
reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of
a current lifetime resident's exposure to surface soil, as well as the toxicity of the COCs. The total risk from direct exposure to contaminated soil
at each area of this site to a current lifetime resident is shown above. Details of route-specific risks for ingestion, dermal contact, and inhalation
of dust or soil vapors for each COC are provided in Appendix D, Tables G-7A through G-7C. The estimated chromium cancer risks shown on
the Appendix D tables are based on the assumption that total chromium is 100% hexavalent chromium. Chromium speciation sampling at the
Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the chromium cancer risks shown on the Appendix D
tables for chromium overestimate risks from exposure to chromium. Total chromium risks and total area risks on the above table have been
adjusted to reflect the chromium speciation data. The COCs contributing most to these risk levels are the PAHs and arsenic in soil (Nobis,
2013b). These risk levels indicate that if no clean-up action is taken, an individual would have an increased probability of 1.2 to 1.6 in 10,000 of
developing cancer as a result of site-related exposure to the COCs.







Table G-8





Risk Characterization Summary - Carcinogens - Future Resident Exposures to Surface Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted Lifetime

Medium

Exposure

Exposure

Chemical of Concern

Carcinogenic Risk



Medium

Point



Exposure Routes Total

Soil

Surface
Soil

Soil On-site
Area

Benzo(a)
anthracene

2.6 x 105







Benzo(a)
pyrene

2.6 x 10^







Benzo(b)
fluoranthene

3.8 x 105







Benzo(k)
fluoranthene

2.4 x 106







Dibenz(a,h) anthracene

2.1 x 105







Indeno

(1,2,3-cd)
pyrene

5.8 x 106







Arsenic

3.0 x 105







Total Chromium

1.6 x 10 6





D3 Surface Soil risk total=

3.8 x 10"4





Soil On-site
Area El

Benzo(a)
anthracene

1.2 x 10 5







Benzo(a)
pyrene

1.0 x 10^







Benzo(b)
fluoranthene

7.0 x 106

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Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

1.2 x 10 5

5.8 x 106

9.0 x 106

El Surface Soil risk total= 1.5x10

Soil On-site
Area G

Benzo(a)
anthracene

Benzo(a)
pyrene

Benzo(b)
fluoranthene

Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

Total Chromium

5.5 x 106

6.2 x 105

6.3 x 10 6

1.7 x 105

3.9 x 106

5.3 x 10 5

3.5 x 106

G Surface Soil risk total= 1.5 x 10

Soil On-site
Area H

Benzo(a)
anthracene

Benzo(a)
pyrene

Benzo(b)
fluoranthene

Benzo(k)
fluoranthene

Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

1.9 x 10 5

2.0 x 10^

2.3 x 105

2.4 x lO"6

6.6 x 105

1.6 x 10 5

9.8 x 106

H Surface Soil risk total= 3.4 x 10

Soil On-site
Area I

Benzo(a)
anthracene

Benzo(a)
pyrene

3.0 x 105

2.9 x 10^

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Benzo(b)
fluoranthene

4.9 x 105







Benzo(k)
fluoranthene

1.6 x 10 6







Dibenz(a,h) anthracene

3.8 x 105







Indeno

(1,2,3-cd)
pyrene

7.5 x 10 6







Arsenic

1.4 x 10 5





I Surface Soil risk total=

4.3 x 10"4





Soil On-site
Area J

Benzo(a)
anthracene

1.5 x 105







Benzo(a)
pyrene

1.1 x 10^







Benzo(b)
fluoranthene

1.2 x 10 5







Dibenz(a,h) anthracene

3.4 x 105







Indeno

(1,2,3-cd)
pyrene

7.5 x 10 6







Aroclor 1254

5.2 x 105







Aroclor 1260

2.7 x 106







Arsenic

1.2 x 10 5







Total Chromium

7.3 x 10^







Vanadium

1.1 x 10"6





J Surface Soil risk total=

9.8 x 10^

Risk Characterization

This table provides risk estimates for the significant future residential surface soil exposure pathways. These risk estimates are based on a
reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of
a future lifetime resident's exposure to surface soil, as well as the toxicity of the COCs. The total risk from direct exposure to contaminated
surface soil at each area of this site to a future lifetime resident is shown above. Details of route-specific risks for ingestion, dermal contact, and
inhalation of dust or soil vapors for each COC are provided in Appendix D, Tables G-8A through G-8F. The estimated chromium cancer risks
shown on the Appendix D tables are based on the assumption that total chromium is 100% hexavalent chromium. Chromium speciation
sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the chromium cancer risks shown on the
Appendix D tables for chromium overestimate risks from exposure to chromium. Total chromium risks and total area risks on the above table
have been adjusted to reflect the chromium speciation data. The COCs contributing most to these risk levels are PAHs and arsenic in surface soil
at each area and total chromium in surface soil at Area J. These risk levels indicate that if no clean-up action is taken, an individual would have
an increased probability of 1.5 to 9.8 in 10,000 of developing cancer as a result of site-related exposure to the COCs.

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Table G-9

Risk Characterization Summary - Carcinogens - Future Resident Exposures to Aggregate Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted Lifetime

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Exposure Routes Total

Soil

Aggregate
Soil

Soil On-site

Area D1

Benzo(a)
anthracene

3.8 x 106

Benzo(a)
pyrene

5.9 x 105

Benzo(b)
fluoranthene

7.7 x 10"6

Dibenz(a,h) anthracene

1.2 x 10 5

Indeno

(1,2,3-cd)
pyrene

4.8 x 106

Arsenic

9.7 x 106

Vanadium

1.2 x 10 6

D1 Aggregate Soil risk total=

1.0 x 10"4

Soil On-site

Area D3

Benzo(a)
anthracene

2.1 x 105

Benzo(a)
pyrene

2.3 x 10^

Benzo(b)
fluoranthene

3.4 x 105

Benzo(k)
fluoranthene

1.5 x 106

Dibenz(a,h) anthracene

7.8 x 105

Indeno

(1,2,3-cd)
pyrene

1.6 x 10 5

Arsenic

1.9 x 10 5

D3 Aggregate Soil risk total=

4.0 x 10^

Soil On-site

Dioxins (2,3,7,8-TCDD TEQ)

2.5 x 10 6

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Area El

Benzo(a)
anthracene

Benzo(a)
pyrene

Benzo(b)
fluoranthene

Benzo(k)
fluoranthene

Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

3.7 x lO"5

3.3 x 1(T

4.8 x 105

1.9 x 10 6

1.4 x 10 5

7.2 x lO"6

8.6 x 106

El Aggregate Soil risk total=

4.6 x 10^

Soil On-site
Area E2

Dioxins (2,3,7,8-TCDD TEQ)

Benzo(a)
anthracene

Benzo(a)
pyrene

Benzo(b)
fluoranthene

Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

1.3 x 10 6

1.2 x 10 5

1.3 x 10^

1.7 x lO 5

1.1 x 105

6.4 x 106

1.1 x 105

E2 Aggregate Soil risk total=

1.9 x 10^

Soil On-site
Area E3

Benzo(a)
anthracene

Benzo(a)
pyrene

Benzo(b)
fluoranthene

Dibenz(a,h) anthracene

Indeno

(1,2,3-cd)
pyrene

Arsenic

9.5 x 10 6

7.4 x lO 5

8.7 x lO"6

1.3 x 10 5

5.0 x lO"6

1.3 x 10 5

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Total Chromium

2.6 x 106

E3 Aggregate Soil risk total=

1.3 x 10^

Soil On-site
Area F

Benzo(a)
anthracene

1.1 x 105

Benzo(a)
pyrene

9.1 x 105

Benzo(b)
fluoranthene

1.2 x 10 5

Benzo(k)
fluoranthene

1.2 x 10 6

Dibenz(a,h) anthracene

2.2 x 105

Indeno

(1,2,3-cd)
pyrene

4.9 x 106

Arsenic

1.9 x 10 5

Total Chromium

5.5 x 10 6

F Aggregate Soil risk total=

1.7 x 10^

Soil On-site

Area G

Benzo(a)
anthracene

4.4 x 106



Benzo(a)
pyrene

4.7 x 105

Benzo(b)
fluoranthene

6.6 x 106

Dibenz(a,h) anthracene

1.3 x 10 5

Indeno

(1,2,3-cd)
pyrene

2.6 x 106

Arsenic

3.4 x 105

Total Chromium

2.1 x 106



G Aggregate Soil risk total=

1.1 x 10^

Soil On-site

Area H

Benzo(a)
anthracene

3.5 x 10 5

Benzo(a)
pyrene

3.7 x 10^

Benzo(b)
fluoranthene

4.2 x 105

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Benzo(k)
fluoranthene

4.4 x 106

Dibenz(a,h) anthracene

9.9 x 105

Indeno

(1,2,3-cd)
pyrene

1.8 x 105

Arsenic

3.6 x 105

H Surface Soil risk total=

6.0 x 10^

Soil On-site
Area I

Benzo(a)
anthracene

3.6 x 10^

Benzo(a)
pyrene

3.1 x 103

Benzo(b)
fluoranthene

1.3 x 10^

Benzo(k)
fluoranthene

8.3 x 10 6

Chrysene

4.0 x 106

Dibenz(a,h) anthracene

7.6 x 10^

Indeno

(1,2,3-cd)
pyrene

2.6 x 10^

Arsenic

2.6 x 105

I Aggregate Soil risk total=

4.6 x 103

Soil On-site
Area J

Dioxins (2,3,7,8-TCDD TEQ)

7.2 x 106

Benzo(a)
anthracene

1.0 x 10 5

Benzo(a)
pyrene

8.3 x 10 5

Benzo(b)
fluoranthene

9.7 x 106

Dibenz(a,h) anthracene

1.9 x 10 5

Indeno

(1,2,3-cd)
pyrene

6.8 x 106

Aroclor 1254

1.0 x 10 5



Aroclor 1260

1.2 x 10 6

Arsenic

1.2 x 10 5

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Total Chromium

2.0 x 10^

J Aggregate Soil risk total=

3.6 x 10^

Risk Characterization

This table provides risk estimates for the significant future residential surface soil exposure pathways. These risk estimates are based on a
reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of
a future lifetime resident's exposure to aggregate soil, as well as the toxicity of the COCs. The total risk from exposure to contaminated
aggregate soil at each area of this site to a future lifetime resident is shown above. Details of route-specific risks for ingestion, dermal contact,
and inhalation of dust or soil vapors for each COC are provided in Appendix D, Tables G-9 A through G-9 J. The estimated chromium cancer
risks shown on the Appendix D tables are based on the assumption that total chromium is 100% hexavalent chromium. Chromium speciation
sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the chromium cancer risks shown on the
Appendix D tables for chromium overestimate risks from exposure to chromium. Total chromium risks and total area risks on the above table
have been adjusted to reflect the chromium speciation data. The COCs contributing most to these risk levels are PAHs and arsenic in aggregate
soil. These risk levels indicate that if no clean-up action is taken, an individual would have an increased probability of 1 in 10,000 to 4.6 in
1,000 of developing cancer as a result of site-related exposure to the COCs.

Table G-10

Risk Characterization Summary - Non-Carcinogens - Future Child Resident

Exposures to Surface Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary
Target
Organ

Non-Carcinogenic Hazard Quotient

Exposure Routes Total

Soil

Surface
Soil

Soil Area
G

Antimony

Blood

1.3

Receptor Hazard Index =

5.0

Blood Hazard Index =

1.9

Soil

Surface
Soil

Soil Area J

Aroclor
1254

Eyes and
Immune
system

10

Total

Chromium

(as

chromium

VI)

None
Observed

60

Nickel

Body
Weight

1.2

Receptor Hazard Index =

73

Eyes and Immune system Hazard Index =

10

None Observed Hazard Index =

60

Body Weight Hazard Index =

1.2

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Risk Characterization

This table provides the hazard index (sum of hazard quotients) for future child residential Area G and Area J surface soil exposure pathways.
The Risk Assessment Guidance (RAGS) for Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer
effects. The estimated Area G HI of 5.0 indicates that the potential for adverse non-cancer effects could occur from exposure to contaminated
soil containing antimony. The estimated Area J HI of 73 indicates that the potential for adverse non-cancer effects could occur from exposure
to contaminated soil containing PCBs, chromium, and nickel. Details of route-specific hazard quotients for ingestion, dermal contact, and
inhalation of dust or soil vapors for each COC are provided in Appendix D, Tables G-10A and G-10B. The estimated chromium HI is based
on the assumption that total chromium is 100% hexavalent chromium. Chromium speciation sampling at the Site indicates total chromium
consists of just 1.54% hexavalent chromium. Therefore, the HI for total chromium greatly overestimates concerns for exposure to chromium.
This overestimated HI does not have any effect on remedy selection or cleanup goals. An unacceptable noncancer hazard exists for other
COCs. Chromium remains a COC based on potential cancer risks.

Table G-ll

Risk Characterization Summary - Non-Carcinogens - Future Child Resident
Exposures to Aggregate Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary Target Organ

Non-Carcinogenic Hazard Quotient
Exposure Routes Total

Soil

Aggregate
Soil

Soil Area
G

Antimony

Blood

1.3

Receptor Hazard Index =

4.6

Blood Hazard Index =

1.9

Soil

Aggregate
Soil

Soil Area J

Aroclor 1254

Eyes and Immune system

2.0

Total Chromium
(as chromium VI)

None Observed

Receptor Hazard Index =

Eyes and Immune system Hazard Index =

2.0

None Observed Hazard Index =

Risk Characterization

This table provides HQs for each route of exposure and the HI (sum of HQs) for future child residential Area G and Area J aggregate soil
exposure pathways. The RAGS for Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer effects.
The estimated Area G HI of 4.6 indicates that the potential for adverse non-cancer effects could occur from exposure to contaminated soil
containing antimony. The estimated HI of 21 at Area J indicates that the potential for adverse non-cancer effects could occur from exposure to
contaminated soil containing PCBs and chromium. Details of route-specific hazard quotients for ingestion, dermal contact, and inhalation of
dust or soil vapors for each COC are provided in Appendix D, Tables G-11A and G-11B. The estimated chromium HI is based on the
assumption that total chromium is 100% hexavalent chromium. Chromium speciation sampling at the Site indicates total chromium consists
of just 1.54% hexavalent chromium. Therefore, the HI for total chromium greatly overestimates concerns for exposure to chromium. .

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Table G-12

Risk Characterization Summary - Non-Carcinogens - Future Adult Resident

Exposures to Surface Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary Target Organ

Non-Carcinogenic Hazard Quotient
Exposure Routes Total

Soil

Surface
Soil

Soil Area J

Aroclor 1254

Eyes and Immune system

1.2

Total Chromium
(as chromium VI)

None Observed

6.5

Receptor Hazard Index =

8.1

Eyes and Immune system Hazard Index =

1.2

None Observed Hazard Index =

6.5

Risk Characterization

This table provides HQs for each route of exposure and the HI (sum of HQs) for future adult residential Area J surface soil exposure
pathways. The RAGS for Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer effects. The
estimated HI of 8.1 indicates that the potential for adverse non-cancer effects could occur from exposure to contaminated soil containing
PCBs and chromium. Details of route-specific hazard quotients for ingestion, dermal contact, and inhalation of dust or soil vapors for each
COC are provided in Appendix D, Table G-12A. The estimated chromium HI is based on the assumption that total chromium is 100%
hexavalent chromium. Chromium speciation sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium.
Therefore, the HI for total chromium greatly overestimates concerns for exposure to chromium. .

Table G-13

Risk Characterization Summary - Non-Carcinogens - Future Adult Resident
Exposures to Aggregate Soil

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary Target Organ

Non-Carcinogenic Hazard Quotient

Exposure Routes Total

Soil

Aggregate
Soil

Soil Area J

Total Chromium
(as chromium VI)

None Observed

1.8

Receptor Hazard Index =

2.3

None Observed Hazard Index =

1.8

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Risk Characterization

This table provides HQs for each route of exposure and the HI (sum of HQs) for future adult residential Area J aggregate soil exposure
pathways. The RAGS for Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer effects. The
estimated HI of 2.3 indicates that the potential for adverse noncancer effects could occur from exposure to contaminated soil chromium.
Details of route-specific hazard quotients for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in
Appendix D, Table G-13A. The estimated chromium HI is based on the assumption that total chromium is 100% hexavalent chromium.
Chromium speciation sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the HI for total
chromium greatly overestimates concerns for exposure to chromium.

Current and Future Industrial/Commercial Workers. Exposure to Soil

Unacceptable risks were found for:

1) Future industrial/commercial workers, potentially exposed to surface soil at Area J; and

2) Future industrial/commercial workers, potentially exposed to aggregate soil at Area I.

Current or future industrial/commercial workers were evaluated for potential exposure to
soil via incidental ingestion, dermal contact, and inhalation of fugitive dust and vapors. The
following assumptions used in the evaluations of industrial/commercial worker soil exposures
apply to both surface soil and aggregate soil exposures.

Industrial/commercial workers were assumed to be exposed to Site soil for 250 days per
year for 25 years, ingesting an average of 100 mg of soil per day and contacting soil with head,
hands, and forearms (3,300 cm2). A value of 0.2 mg/cm2-event was used as the SSAF for adult
industrial/commercial workers. For all industrial/commercial workers, inhalation of dust and
soil vapor exposures assumed exposure to dust occurs 8 hours per day.

Table G-14 depicts the carcinogenic risk summary for the chemicals of concern in
aggregate soil evaluated to reflect potential future industrial/commercial worker exposures to soil
corresponding to the RME scenario. Details of route-specific risks for ingestion, dermal contact,
and inhalation of dust or soil vapors for each COC are provided in Appendix D, Table G-14 A.

Tables G-15 and G-16 depict the non-carcinogenic risk summary for the chemicals of
concern in surface soil and aggregate soil evaluated to reflect potential future
industrial/commercial worker exposures to soil corresponding to the reasonable maximum
exposure (RME) scenario. Details of route-specific hazard quotients for ingestion, dermal
contact, and inhalation of dust or soil vapors for each COC are provided in Appendix D, Tables
G-15 A and Table G-16 A.

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Table G-14

Risk Characterization Summary - Carcinogens - Future Industrial/Commercial Worker

Exposures to Aggregate Soil

Scenario Timeframe: Future

Receptor Population: Industrial/Commercial Worker
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Exposure Routes Total

Soil

Aggregate
Soil

Soil On-site
Area I

Benzo(a)
anthracene

2.5 x 10 5

Benzo(a)
pyrene

2.1 x 10^

Benzo(b)
fluoranthene

8.8 x 106

Dibenz(a,h) anthracene

5.3 x 10 5

Indeno

(1,2,3-cd)
pyrene

1.8 x 105

Arsenic

6.2 x 106

I Aggregate Soil risk total= 3.3 x 10^

Risk Characterization

This table provides risk estimates for the significant future industrial/commercial worker aggregate soil exposure pathways. These risk estimates
are based on a reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency
and duration of a future industrial/commercial worker's exposure to aggregate soil at Area I, as well as the toxicity of the COCs. The total risk
from exposure to contaminated aggregate soil at this area of this site to a future industrial/commercial worker's is estimated to be 3.3 x 10"4 . .
Details of route-specific risks for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in Appendix D,
Table G-14 A. The estimated chromium cancer risks shown on the Appendix D tables are based on the assumption that total chromium is 100%
hexavalent chromium. Chromium speciation sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium.
Therefore, the chromium cancer risks shown on the Appendix D tables for chromium overestimate risks from exposure to chromium. Total area
risks on the above table have been adjusted to reflect the chromium speciation data. The COCs contributing most to this risk level are P AHs in
soil. This risk level indicates that if no clean-up action is taken, an individual would have an increased probability of 3 in 10,000 of developing
cancer as a result of site-related exposure to the COCs.

Table G-15

Risk Characterization Summary - Non-Carcinogens - Future Industrial/Commercial Worker

Exposures to Surface Soil

Scenario Timeframe: Future

Receptor Population: Industrial/Commercial Worker
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary T arget Organ

Non-Carcinogenic Hazard Quotient

Exposure Routes Total

Soil

Surface
Soil

Soil Area J

Aroclor 1254

Eyes and Immune system

1.1

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Total

Chromium (as
chromium VI)

None Observed

4.6

Receptor Hazard Index =

5.9

Eyes and Immune system Hazard Index =

1.1

None Observed Hazard Index =

4.6

Risk Characterization

This table provides the HI (sum of HQs) for future industrial/commercial worker Area J surface soil exposure pathways. The RAGS for
Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer effects. The estimated HI of 5.9 indicates
that the potential for adverse non-cancer effects could occur from exposure to contaminated soil containing PCBs and chromium. Details of
route-specific hazard quotients for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in Appendix D,
Table G-15A. The estimated chromium HI is based on the assumption that total chromium is 100% hexavalent chromium. Chromium
speciation sampling at the Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the HI for total chromium
greatly overestimates concerns for exposure to chromium. .

Table G-16

Risk Characterization Summary - Non-Carcinogens - Future Industrial/Commercial Worker

Exposures to Aggregate Soil

Scenario Timeframe:
Receptor Population:
Receptor Age: Adult

Future

Industrial/Commercial Worker

Medium

Exposure
Medium

Exposure
Point

Chemical of
Concern

Primary T arget Organ

Non-Carcinogenic Hazard Quotient

Exposure Routes Total

Soil

Aggregate
Soil

Soil Area J

Total

Chromium (as
chromium VI)

None Observed

1.3

Receptor Hazard Index =

1.7

None Observed Hazard Index =

1.3

Risk Characterization

This table provides the HI (sum of HQs) for future industrial/commercial worker Area J aggregate soil exposure pathways. The RAGS for
Superfund states that, generally, a HI greater than 1 indicates the potential for adverse non-cancer effects. The estimated HI of 1.7 indicates
that the potential for adverse non-cancer effects could occur from exposure to contaminated soil containing chromium. Details of route-
specific HQs for ingestion, dermal contact, and inhalation of dust or soil vapors for each COC are provided in Appendix D, Table G-16A. The
estimated chromium HI is based on the assumption that total chromium is 100% hexavalent chromium. Chromium speciation sampling at the
Site indicates total chromium consists of just 1.54% hexavalent chromium. Therefore, the HI for total chromium greatly overestimates
concerns for exposure to chromium.

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Cancer Risk Summary

Cancer risks due to exposure to soils and vapor intrusion are summarized below.

Exposure to Soils

As shown on Tables G-7 through G-9 and G-14, the cancer risk estimates exceed the EPA
acceptable cancer risk range (10"4 to 10"6) for: 1) current residents exposed to surface soils at
three areas (Areas Dl, E3, and F); 2) future residents potentially exposed to surface soils at
four current commercial areas (Areas D3, G, H, and I), at one residential property for elderly
residents assuming the elderly housing is converted to become housing for families with
children (Area El), at one commercial property being used as a daycare facility assuming it is
converted to residential (Area E2), and at the currently undeveloped parcel (Area J); 3)
potential future residents at each of the ten areas assuming future exposure to aggregate soils
(0-10 feet); and 4) future industrial/commercial workers at Area I assuming future exposure to
aggregate soils (0-10 feet). The dominant risk drivers are carcinogenic PAHs
(benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(b)fluoranthene, chrysene,
dibenz(a,h)anthracene, and indeno(l,2,3-cd)pyrene), arsenic, chromium, and PCBs (at Area J
only). Dioxins are also risk drivers at Areas E2 and J. While dioxin TEQ was identified as a
contributor to cancer risk, the detected concentrations are below the selected cleanup levels
(CULs) (see L.4.a for more detail on CUL selection.)

Vapor Intrusion

Although no quantitative risks were estimated for potential exposures to groundwater
contaminants via vapor intrusion, this pathway was evaluated for Parcel A (Areas Dl, D3, El,
E2, E3, F, G, H, and I) and Parcel B (Area J) through comparison of inhalation risk-based
screening criteria to shallow groundwater sampling results. The qualitative vapor intrusion
screening evaluation indicated potential risks from vapor intrusion. Chloroform, TCE, vinyl
chloride, and mercury concentrations in shallow groundwater exceed the screening levels in
Parcel A. The subsequent Tier II analysis found the maximum mercury concentration
corresponded to an acceptable risk level for residential indoor air exposure (HQ less than 1) so
mercury was not considered to be a contaminant of concern. Of particular concern is Area El,
where elevated concentrations (maximum of 12 ug/L in March 2010 from MW-12S) of vinyl
chloride are sporadically detected and correspond to a risk level of slightly over 1.0 x 10"4 for
residential indoor air exposures (see the HHRA, Section 4.2.3). These risks may combine with
risks from future residential exposures to soil, yielding higher risks of 2.5 x 10"4 (in combination
with risks from surface soil) or 5.6 x 10"4(in combination with risks from aggregate soil).

In addition, shallow groundwater concentrations of vinyl chloride in Area J (currently
undeveloped) exceeded screening levels (CT RSRs). Therefore, potential risks from vapor
intrusion may be present in future scenarios if the property was developed.

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Although elevated concentrations of vinyl chloride were detected in Area Dl, these
concentrations were limited to the deep overburden monitoring well (MW-9D, Figure E-10 in
Appendix B). VOCs were generally not present in the overlying shallow overburden
groundwater at this location (MW-9S). In Area F, sporadic VOCs were detected at trace
concentrations at a location over 100 feet from the nearest structure.

Non-Cancer Health Hazards Summary

In addition to the cancer risks, non-cancer hazard indices exceeding 1.0 indicated
potential adverse non-cancer effects for future adult and child residents from exposures to soil at
several areas. If the value of the HI exceeds 1.0, there is a potential for non-carcinogenic health
effects associated with that particular chemical mixture, and therefore it is necessary to segregate
the HQs by target organ effects. Target organ-specific His below 1 are unlikely to result in
adverse effects. Target organ-specific hazard indices are less than 1.0 in all areas, except two -
Areas G and J. As shown on Tables G-13 and G-15 through G-18, these target organ-specific
His exceed 1 for child residents (Areas G and J), adult residents (Area J), and
industrial/commercial workers (Area J). At Area G, estimated His indicated potential adverse
non-cancer effects on blood predominantly resulting from exposures to antimony in either
surface soils or aggregate soil. At Area J, estimated His indicated potential adverse non-cancer
effects on the eyes and immune system for future child and adult residents and
industrial/commercial workers predominantly resulting from exposures to PCBs (Aroclor 1254)
in surface soils and for future child residents from exposures to PCBs in aggregate soil, and for
future child residents on body weight predominantly resulting from exposures to nickel in either
surface soils or aggregate soil. No target organ is specified for non-carcinogenic effects of
chromium; however, at Area J, the estimated chromium individual contaminant His for future
resident or industrial/commercial worker exposures to chromium in either surface soil or
aggregate soil indicated potential adverse non-cancer effects.

The Integrated Exposure and Uptake Biokinetic (IEUBK) model was used to evaluate the
hazard potential posed by future residential exposure of young children less than 7 years of age
as the most sensitive receptor group to surface soil or aggregate soil at Area G and aggregate soil
at Area H should these current commercial properties be redeveloped for residential use.
Population geometric standard deviation set to 1.6. The outcome of the model revealed that 48%
of future residential children exposed to surface soil at Area G, 39% of future residential children
exposed to aggregate soil at Area G; and 9% of future residential children exposed to aggregate
soil at Area H are predicted to have blood lead levels greater than 10 micrograms per deciliter
(|ig/dL). It is EPA policy to protect 95% of the sensitive population against blood lead levels in
excess of 10 |ig/dL blood.

Uncertainties of the HHRA

The process of evaluating human health cancer risks and non-cancer His involves
multiple steps. Inherent in each step of the process are uncertainties that ultimately affect the

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final cancer risks and non-cancer His. Uncertainties may exist in numerous areas. Sources
of uncertainty in the HHRA include exposure and toxicity assessments. These are further
discussed below.

Exposure Assessment

The parameter values used to describe the extent, frequency, and duration of exposure
were selected to produce an upper-bound estimate of exposure in accordance with USEPA
guidance to be protective of the RME individual. Exposures and estimated potential risks may
be overestimated.

Toxicity Assessment

There is uncertainty associated with all toxicity values. However, the CSFs were
developed to represent plausible upper bound estimates, which means that EPA is reasonably
confident that the actual cancer risk will not exceed the estimated risk calculated using the CSF.
The toxicity of hexavalent chromium with respect to cancer effects is under review by EPA's
Integrated Risk Information System (IRIS) program.

For dermal exposure pathways, the absence of dermal toxicity criteria necessitated the use of
oral toxicity data. A default absorption of 100% was assumed except when oral bioavailability
factors were available to modify the oral toxicity criteria. The risk estimates for the dermal
pathways may be over-or underestimated.

2. Ecological Risk Assessment

The preponderance of the evidence indicated a low potential for impact on the long-term
health and stability of the benthic invertebrate community in Wetland 1 (except perhaps in a few
focused areas with high levels of COCs) and of the local water column invertebrate and larval
amphibian communities in Wetland 2. A high potential for risk to benthic invertebrates was
found in one area of Wetland 2 abutting Newbury Street (Figure 1), potentially due to
concentrations of copper and/or the oily sheen observed during sediment sampling and toxicity
testing. There is also the potential for localized and short-lived, but significant risk to water
column invertebrates and larval amphibians in the vicinity of the metal "cage" at the southern tip
of Wetland 1.

Wetland 2 receives surface runoff from surrounding areas including several streets and at
least one parking lot. Anthropogenic sources of copper include brake dusts and the wear of
engine bearings and parts. Oil leaks from the engine blocks convey contamination (including
metals) into the environment. Because there has been observable sheen in Wetland 2, one may
conclude that oil leaks from vehicles and road dusts (including brake dusts) are conveyed as
storm runoff from the streets into Wetland 2, resulting in the accumulation of the oil and possibly
heavy metals that may pose risk to the benthic invertebrates.

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The two on-site wetlands are degraded and are of low functional value. Both receive
surface water runoff that conveys oils, heavy metals, and other contaminants from nearby parcels
and roadways. Based on the quality of the habitats provided by the wetlands and minimal Site-
related impacts, no further action will be considered.

3.	Basis for Response Action

Because the baseline human health risk assessment revealed that current or future residential
and future industrial/commercial workers' exposure to compounds of concern in surface and
aggregate soils via incidental ingestion, dermal contact, and inhalation of fugitive dust and
vapors may present an unacceptable human health risk (cancer risk greater than 10"4 and
noncancer HI of greater than 1), 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.

4.	Chemical of Concern Selection

Contaminants of Concern (COCs) were identified based on the human health risk
assessment (Section G.l) and ecological risk assessment (Section G.2) results for chemicals in
environmental media identified during the RI. The COC selection process is detailed in Section
2.4 of the Final FS, and results are summarized in Table L-l and L-2 of Appendix C.

Summaries of PRGs and PMCs exceedances for Site COCs are presented in Figures E-l 1
through E-l5 (Appendix B). For soil COCs, data is presented in various depth intervals,
including 0-2 fit bgs, 2-4 ft bgs, and 4-10 ft bgs.

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 the environment
from soil and vapor intrusion; and to attain applicable or relevant and appropriate requirements
(ARARs). The RAOs for the selected remedy for Site are:

Soil RAOs

• Protection of Human Health RAO - The soil RAO for the protection of human health is
to prevent potential direct exposure (inhalation, dermal contact, or ingestion) to soil with
contaminant concentrations exceeding the risk-based goals, ARARs, or site-specific
background concentrations.

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•	Protection of the Environment RAO - The soil RAO for the protection of the
environment is to prevent the potential transport of soil contaminants to groundwater.

Vapor Intrusion RAOs

•	Protection of Human Health RAO - The vapor intrusion RAO for the protection of
human health is to prevent potential exposure to soil vapor contaminants resulting from
localized groundwater VOCs contamination that would result in cancer risk greater than
1.0E-04 to 1.0E-06, or a non-carcinogenic risk greater than a HI of 1.

In order to achieve the soil and vapor intrusion RAOs, soil cleanup and vapor intrusion
screening levels were established. The cleanup and screening levels are discussed in Section
L.4.

I. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A.	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.

B.	Technology and Alternative Development and Screening

CERCLA and the NCP set forth the process by which remedial actions are evaluated and
selected. In accordance with these requirements, a range of alternatives were developed for the
site.

With respect to source control, the RI/FS developed a range of alternatives that mitigate
potential health risks. Because the Site has no principal threat wastes, treatment was not a
principal element to reduce the toxicity, mobility, or volume of the hazardous substances. This
range also included alternatives that involve little or no treatment but provide protection through
engineering or institutional controls; and a no action alternative.

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As discussed in Section 3.0 of the FS, soil and vapor intrusion treatment technology options
were identified, assessed and screened based on implementability, effectiveness, and cost. These
technologies were combined into source control (SC) alternatives. Section 4.0 of the FS
presented the remedial alternatives developed by combining the technologies identified in the
previous screening process in the categories identified in Section 300.430(e)(3) of the NCP. The
purpose of the initial screening was to narrow the number of potential remedial actions for
further detailed analysis while preserving a range of options. From this initial screening,
remedial options were combined and eight soil and four vapor intrusion remedial alternatives
were selected for detailed analysis. Each alternative was then evaluated in detail in Sections 5.0,
6.0, and 7.0 of the FS.

J. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each source control alternative evaluated,
including both soil and vapor intrusion alternatives.

1. Soil Alternatives Analyzed

The soil alternatives analyzed for the Site include:

•	SOI - No Action [all Areas];

•	S02 - Limited Action, Institutional Controls, Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and Ft];

•	S03 - Targeted Remediation (Targeted Excavation and Off-site Disposal), Institutional
Controls, Periodic Assessments, and Five-Year Reviews [PRG and PMC Exceedances
within Areas Dl, El, F];

•	S04 - Targeted In-Situ Physical Treatment (Solidification/Stabilization), Institutional
Controls, Periodic Assessments, and Five-Year Reviews [PRG and PMC Exceedances
within Areas Dl, El, F];

•	S05 - Pre-Design Investigations, Excavation and Off-site Disposal, Institutional
Controls, Periodic Assessments, and Five-Year Reviews [Area J];

•	S06 - Pre-Design Investigations, Soil Cap, Institutional Controls, Operation and
Maintenance, Periodic Assessments, and Five-Year Reviews PRG and PMC Exceedances
within Area J];

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• S07 - Pre-Design Investigations, Targeted Remediation (Targeted Excavation and Off-
site Disposal), Institutional Controls, Periodic Assessments, and Five-Year Reviews
[Area J]; and

• S08 - Pre-Design Investigations, Excavation and Off-site Disposal, Institutional
Controls, Periodic Assessments, and Five-Year Reviews [Area I].

Each of the eight soil alternatives is summarized below and in Figures J-l through J-8
(Appendix B). Detailed evaluations of each alternative are found in Section 5.1 of the FS and
are included as Tables J-l through J-8 (Appendix E).

Alternative SOI - No Action [all Areas]

Although this alternative does not achieve the RAOs, it is retained as a baseline alternative for
comparison in accordance with the NCP and the RI/FS Guidance. Under this alternative, there
will be no reduction of risk in the near term. Reduction of risks in the long term may occur
gradually; however, the likelihood is low for natural degradation of Site contaminants.

This alternative is not protective and does not meet ARARs. There are no capital costs
associated with this alternative. A detailed evaluation of this alternative is included in Table J-l
(Appendix E). In addition, Tables J-13, J-14, and J-l5 (Appendix E) provides an evaluation of
compliance with ARARs for Alternative SOI.

Alternative S02 - Limited Action, Institutional Controls, Periodic Assessments, and Five-
Year Reviews [Areas D3, E2, E3, G, and H]

This alternative involves no active treatment, but provides protection of human health by
preventing or controlling potential exposures to contaminated soil through institutional controls.
This alternative is applicable to Areas where the HHRA concluded that risk is less than 1.0E-04,
but where there could be unacceptable risk if the Areas were used for residential purposes in the
future (Areas D3, E2, G, and H). This alternative also applies to Area E3, where the risk is equal
to or greater than 1.0E-04, but no exceedances of Preliminary Remediation Goals (PRGs) were
observed in soils that are considered to be accessible. Components of this alternative include:

• Institutional Controls - Use restrictions to limit, govern, or prevent excavations in
contaminated fill, and to prevent unacceptable exposures to contaminants. Use
restrictions may be in the form of a deed restriction, easement or covenant consistent with
state law, other enforceable mechanisms, zoning ordinances, or a combination thereof.
The following institutional controls will be implemented:

o IC-1 - Prevent future excavation of on-site soils for use or disposal beyond the
property boundary without state regulatory approval;

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o IC-2 - Prevent future residential use, unless the area is already currently being

used as residential use without federal/state regulatory approval.; and
o IC-3 - Prevent excavation and re-use of soil from 4 feet below ground surface (ft
bgs) or deeper without state regulatory approval.

• Periodic Assessments - Periodic assessments will be performed to ensure that
Institutional Controls (i.e., IC-1, IC-2, and IC-3) are implemented to protect human
health and the environment in accordance with the requirements of the selected remedy.
Site conditions and protectiveness of remedy will be reviewed at that time.

• Five-Year Reviews - Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. Use restrictions, consistent with state
law, will prevent potential exposure to soil contaminants in these Areas if the institutional
controls are periodically assessed and enforced. In the short term, protection would be achieved
when institutional controls have been put in place. Reductions of Site contaminant
concentrations in the long term may occur gradually; however, the likelihood is low for natural
degradation of Site contaminants. Periodic assessments would be performed to ensure
institutional controls are implemented; and five-year reviews would be conducted. The
estimated present worth of this alternative is $233,000. A detailed evaluation of this alternative
is presented in Table J-2 (Appendix E). In addition, an evaluation of compliance with ARARs
is presented in Tables J-13, J-14, and J-15 (Appendix E).

Alternative S03 - Targeted Remediation (Targeted Excavation and Off-site Disposal),
Institutional Controls, Periodic Assessments, and Five-Year Reviews [PRG and PMC
Exceedances within Areas Dl, El, F]

This alternative uses targeted excavations coupled with off-site disposal and institutional
controls to prevent exposure to contaminated soil at the Site. The excavations will be at
locations with PRG and PMC exceedances in Areas Dl, El, and F, where estimated risk is equal
to or greater than 1.0E-04. Components of this alternative include:

• Pre-Design Investigation - Conduct a soil investigation at the neighboring residential
properties (110, 118, 126, and 134 Monroe Avenue) in the vicinity of Area El to further
delineate the extent Site COCs.

• Targeted Excavation and Off-site Disposal - Excavate and dispose of identified PRG and
PMC exceedances within Risk Areas Dl, El, and F. Targeted excavation and disposal
(approximately 144 cubic yards [cy]) includes the following:

o For PRG exceedances, remove pavement or surface vegetation, excavate to 4 ft
below ground surface (bgs), backfill with 3.5 feet clean fill and 6 inches topsoil,
and revegetate or backfill and restore pavement;

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o For PMC exceedances, remove pavement or surface vegetation, excavate to the
top of groundwater, backfill with clean fill, topsoil, vegetation, and/or pavement,
if applicable;
o Dust control during excavation;
o Confirmation sampling; and
o Off-site disposal of excavated materials.

• Institutional Controls - The institutional controls described in Alternative S02 will be
implemented, except IC-2 because Areas Dl, El, and F are already used for residential
purposes.

• Periodic Assessments - Periodic assessments will be performed to ensure that
Institutional Controls are implemented to protect human health and the environment in
accordance with the requirements of the selected remedy.

• Five-Year Reviews - Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs in
shallow soil because soil contaminated above applicable DECs, PMCs, or background levels
established as PRGs will be excavated to 4 feet and disposed of off-site. In addition, use
restrictions, consistent with state law, will prevent excavation and use of deeper soil and prevent
potential exposure to soil contaminants. In the short term, protection would be achieved through
the targeted removal of soil. Remaining risk would be managed by implementing, monitoring,
and enforcing institutional controls. Periodic assessments would be performed to ensure
institutional controls are implemented; and five-year reviews would be conducted. The
estimated present worth of this alternative is $382,000. A detailed evaluation of this alternative
is provided in Table J-3 (Appendix E). In addition, an evaluation of compliance with ARARs is
presented in Tables J-13, J-14, and J-15 (Appendix E).

Alternative S04 - Targeted In-situ Physical Treatment (Solidification/Stabilization),
Institutional Controls, Periodic Assessments, and Five-Year Reviews [PRG and PMC
Exceedances within Areas Dl, El, F]

This alternative uses targeted in-situ solidification/stabilization of PRG and PMC exceedances
to prevent potential exposure to contaminated soil and leaching to groundwater in Areas Dl, El,
and F. At targeted locations, soil and soil COCs would be encapsulated in-situ to form a solid
material. Components of this alternative include:

• Pre-Design Investigation - Conduct soil investigations in the vicinities of PRG and PMC
exceedances in Areas Dl, El, and F to further delineate the extent of the exceedance and
at the neighboring residential properties in the vicinity of Area El to further delineate the
extent of Site COCs.

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• In-situ Physical Treatment - Target PRG and PMC exceedances within Areas Dl, El,
and F using solidification/stabilization to treat and immobilize COCs.

o Perform bench and field pilot testing;

o Use mechanical mixing and low-permeability materials to encapsulate
contaminated materials at targeted depths (4 ft bgs for PRG and top of
groundwater for PMC exceedances, a volume of approximately 9.3 cy); and
o Confirmation sampling.

• Institutional Controls - The institutional controls described in Alternative S02 will be
implemented except IC-2 because Areas Dl, El, and F are already used for residential
purposes.

• Periodic Assessments - Periodic assessments will be performed to ensure that
Institutional Controls (i.e., IC-1 and IC-3) are implemented to protect human health and
the environment in accordance with the requirements of the selected remedy.

• Five-Year Reviews - Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs in
shallow soil because soil contaminated above applicable DECs, PMCs, or background levels
established as PRGs will be encapsulated in-situ. In addition, use restrictions, consistent with
state law, will prevent excavation and use of deeper soil and prevent potential exposure to soil
contaminants. This alternative effectively reduces risks through targeted solidification/
stabilization. Remaining risk would be managed by implementing, monitoring, and enforcing
institutional controls. Periodic assessments would be performed to ensure institutional controls
are implemented; and five-year reviews would be conducted. The estimated present worth of
this alternative is $400,000. A detailed evaluation of this alternative is provided in Table J-4
(Appendix E). In addition, an evaluation of compliance with ARARs is presented in Tables J-13,
J-14, and J-15 (Appendix E).

Alternative S05 - Pre-Design Investigations, Excavation and Off-site Disposal,

Institutional Controls, Periodic Assessments, and Five-Year Reviews [Area J]

This alternative uses a pre-design investigation (PDI) to further characterize Area J. The PDI
will delineate PRG and PMC exceedances. This alternative will use excavation coupled with
off-site disposal, backfilling, and institutional controls to prevent exposure to contaminated soil
in Area J. Alternative S05 assumes that based on the PDI, a portion of Area J rather than
discrete "hot spots" will need to be addressed because of PRG exceedances. Components of this
alternative include:

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• Pre-Design Investigations - Perform PDI to delineate PRG and PMC exceedances and
further characterize Area J for PCBs presence. Evaluate the management of stormwater
during and after construction activities.

• Excavation and Off-site Disposal - Excavate and dispose of PRG and PMC exceedances
within Risk Area J. The excavation and disposal may include the following:

o For PRG exceedances, remove all surface vegetation and excavate to 4 ft bgs;
o For PMC exceedances, remove all surface vegetation and excavate to the top of

groundwater;
o Backfill with clean fill at excavation areas;

o Disposal volumes are dependent on the PDI results. Dispose of PMC
exceedances (approximately 420 cy) as non-hazardous and remaining PRG
exceedances (approximately 12,800 cy) includes the following range of possible
volumes, considered for cost sensitivity:

¦ S05A - all 12,800 cy non-hazardous (PCBs < 50 mg/Kg, passes toxicity
characteristic leaching procedure [TCLP] metals),

¦ S05B - 2,200 cy hazardous (PCBs > 50 mg/Kg, fails TCLP metals),
10,600 CY non-hazardous,

¦ S05B - 4,400 cy hazardous (PCBs > 50 mg/Kg, fails TCLP metals), 8,400
CY non-hazardous, and

¦ S05D - all 12,800 cy hazardous (PCBs > 50 mg/Kg, fails TCLP metals);
o Dust control during excavation; and

o Confirmation sampling.

• Institutional Controls - The institutional controls described in Alternative S02 will be
implemented, including the restriction on residential use. In addition, access restrictions,
such as a fence and warning signs, may also be implemented.

• Five-Year Reviews - Assessments will be performed no less than every 5 years at every
Five-Year Review. Review Site conditions and protectiveness of remedy every 5 years.

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performed to ensure institutional controls are implemented; and five-year reviews would be
conducted. The estimated present worth of alternatives S05A, S05B, S05C, and S05D is
$4,551,000, $5,662,000, $6,772,000, and $11,013,000, respectively. A detailed evaluation of
this alternative is provided in Table J-5 (Appendix E). In addition, an evaluation of compliance
with ARARs is presented in Tables J-13, J-14, and J-15 (Appendix E).

Alternative S06 - Pre-Design Investigations, Soil Cap, Institutional Controls, Operation
and Maintenance, Periodic Assessments, and Five-Year Reviews [Area J]

This alternative uses a PDI to further characterize Area J. The PDI will delineate PRG and
PMC exceedances. The installation of a soil cap coupled with institutional controls will be used
to prevent exposure to contaminated soil in Area J. Components of this alternative include:

• Pre-Design Investigations - Perform PDI to delineate PRG and PMC exceedances and
further characterize Area J. Evaluate the management of stormwater during and after
construction activities.

• Excavation and Consolidation - Excavate 6 discrete PMC exceedances and PRG
exceedances outside of the planned cap area. The excavation and disposal may include
the following:

o For PRG exceedances, remove all surface vegetation and excavate to 4 ft bgs;
o For PMC exceedances, remove all surface vegetation and excavate to the top of
groundwater;

o Consolidate PRG exceedances within planned cap area;
o Dust control during excavation; and
o Confirmation sampling.

• Soil Cap - Install a soil cap to prevent direct contact with contaminated soil within Area
J. The soil cap will be approximately 86,200 SF and raise the ground surface by
approximately 2 feet. The soil cap will consist of a geotextile, barrier layer (cobbles, 1
foot), soil cover (1 foot), and surface vegetation.

• Off-Site Disposal - Excavated soil that exceeds the PMC (approximately 420 cy was
assumed) will be sent for off-site disposal.

• Institutional Controls - The institutional controls described in Alternative S02 will be
implemented, including the restriction on residential use. In addition, a deed restriction,
easement, covenant or other enforceable mechanism will be required to ensure long-term
care of cap components, including repairs, and to establish limitations on and
requirements for future construction in Area J to maintain the integrity of the cap. Access
restrictions, such as a fence and warning signs, may also be implemented.

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• Operation and Maintenance - Long-term operation and maintenance of the soil cap will
be required to ensure the area is not disturbed. The cap inspections will take place
annually.

• Five-Year Reviews - Assessments will be performed no less than every 5 years at every
Five-Year Review. Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs because
soil contaminated above applicable DECs, PMCs, or background levels established as PRGs will
be covered with a soil cap. The cap will comply with standards for addressing bulk PCB
remediation wastes with concentrations of < 25 ppm PCBs found at 40 C.F.R. § 761.61. The
soil cap will meet the standards for high occupancy areas, including minimum thickness
requirements, the permeability, sieve, liquid limit and plasticity index parameters in 40 C.F.R. §
761.75(b)(l)(ii) through (v), and RCRA landfill closure requirements at 40 C.F.R. § 264.310(a).
In addition, use restrictions, consistent with state law and 40 C.F.R. §761.61(a)(8), will prevent
excavation and use of deeper soil and prevent potential exposure to soil contaminants. In the
short term, protection would be achieved through the containment of contaminated soil in Area J.
Remaining risk would be managed by implementing, monitoring, and enforcing institutional
controls. Long-term operation and maintenance of the soil cap will be required to ensure the
area is not disturbed. Periodic assessments would be performed to ensure institutional controls
are implemented; and five-year reviews would be conducted. The estimated present worth of the
alternative is $1,416,000. A detailed evaluation of this alternative is provided in Table J-6
(Appendix E). In addition, an evaluation of compliance with ARARs is presented in Tables J-13,
J-14, and J-15 (Appendix E).

Alternative S07 - Pre-Design Investigations, Targeted Remediation (Targeted Excavation
and Off-site Disposal), Institutional Controls, Periodic Assessments, and Five-Year Reviews
[Area J]

This alternative uses a PDI to further characterize Area J to delineate PRG and PMC
exceedances. This alternative assumes 48 discrete PRG and 6 PMC exceedance locations will be
identified during the PDI. Targeted excavations (similar to Alternative S03 in Areas Dl, El,
and F) coupled with off-site disposal, capping/containment (as appropriate), and institutional
controls to prevent exposure to contaminated soil in Area J. Components of this alternative
include:

• Pre-Design Investigations - Perform PDI to delineate PRG and PMC exceedances and
further characterize Area J. Evaluate the management of stormwater during and after
construction activities.

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• Targeted Excavations and Off-site Disposal - Excavate and dispose of PRG and PMC
exceedances within Risk Area J. Targeted excavations and disposal includes the
following:

o For PRG exceedances, remove all surface vegetation, excavate to 4 ft bgs, backfill

with 3.5 feet clean fill and 6 inches topsoil, and revegetate;
o For PMC exceedances, remove surface vegetation, excavate to the top of

groundwater, backfill, and revegetate;
o Dispose of contaminated soil off-site (approximately 516 cy);
o Dust control during excavation; and
o Confirmation sampling.

• Five-Year Reviews - Assessments will be performed no less than every 5 years at every
Five-Year Review. Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs because
soil contaminated above applicable DECs, PMCs, or background levels established as PRGs will
be excavated to 4 feet and disposed of off-site. In addition, use restrictions, consistent with state
law, will prevent excavation and use of deeper soil and prevent potential exposure to soil
contaminants. In the short term, protection would be achieved through the targeted removal of
soil with PRG exceedances in Area J. Remaining risk would be managed by implementing,
monitoring, and enforcing institutional controls. Periodic assessments would be performed to
ensure institutional controls are implemented; and five-year reviews would be conducted. The
estimated present worth of the alternative is $1,293,000. A detailed evaluation of this alternative
is provided in Table J-7 (Appendix E). In addition, an evaluation of compliance with ARARs is
presented in Tables J-13, J-14, and J-15 (Appendix E).

Alternative S08 - Pre-Design Investigations, Excavation and Off-site Disposal,

Institutional Controls, Periodic Assessments, and Five-Year Reviews [Area I]

This alternative uses a PDI to further characterize Area I. The PDI will delineate PRG and
PMC exceedances. An excavation coupled with off-site disposal and institutional controls to
prevent exposure to contaminated soil in Area I. Components of this alternative include:

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• Pre-Design Investigations - Perform PDI to delineate PRG and PMC exceedances and
further characterize Area I.

• Excavation and Off-site Disposal - Excavate and dispose of PRG and PMC exceedances
within Risk Area I. Excavation and disposal may include the following:

o Remove all surface vegetation, excavate to 2 or 4 ft bgs (PRG exceedance) and

top of groundwater (PMC exceedance);
o Install backfill (clean fill and asphalt) in excavation areas;
o Dispose of contaminated soil off-site;
o Dust control during excavation; and
o Confirmation sampling.

Several excavation scenarios were considered for cost sensitivity. The excavation
scenarios are dependent on the PDI results and include the following:

o S08A - Targeted excavation and off-site disposal of 30 discrete PRG (4 ft bgs)

and 1 PMC (top of groundwater) exceedances, approximately 130 cy.
o S08B - Excavation and off-site disposal of a 24,600 square foot (sf) area. PRG
exceedances will be excavated to 4 ft bgs and PMC exceedances to the top of
groundwater, approximately 3,714 cy.
o S08C - Excavation and off-site disposal of a 24,600 sf area. PRG exceedances
will be excavated to 2 ft bgs and PMC exceedances to the top of groundwater,
approximately 1,892 cy.

• Operation and Maintenance (S08C only) - Long-term operation and maintenance of the
pavement will be required to ensure the area is not disturbed.

• Institutional Controls - The institutional controls described in Alternative S02 will be
implemented, including the restriction on residential use.

• Five-Year Reviews - Assessments will be performed no less than every 5 years at every
Five-Year Review. Review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs because
soil contaminated above applicable DECs, PMCs, or background levels established as PRGs will
be excavated to 2 or 4 feet and disposed of off-site. In addition, use restrictions, consistent with
state law, will prevent excavation and use of deeper soil and prevent potential exposure to soil
contaminants. In the short term, protection would be achieved through the removal of soil with

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PRG exceedances in Area I. Remaining risk would be managed by implementing, monitoring,
and enforcing institutional controls. Long-term operation and maintenance of the pavement
(S08C only) will be required to ensure the area is not disturbed. Periodic assessments would be
performed to ensure institutional controls are implemented; and five-year reviews would be
conducted. The estimated present worth of alternatives S08A, S08B, and S08C is $434,000,
$1,518,000, and $1,062,000, respectively. A detailed evaluation of this alternative is provided in
Table J-8 (Appendix E). In addition, an evaluation of compliance with ARARs is presented in
Tables J-13, J-14, and J-15 (Appendix E).

2. Vapor Intrusion Alternatives Analyzed

The vapor intrusion alternatives analyzed for the Site include:

• VII - No Action [Areas El and J];

• VI2 - Limited Action, Institutional Controls, Periodic Assessments, and Five-Year
Reviews [Areas El and J];

• VI3 - Active Soil Vapor Mitigation System, Institutional Controls, Operation and
Maintenance, and Five-Year Reviews [Area El]; and

• VI4 - Passive Soil Vapor Mitigation System, Institutional Controls, Operation and
Maintenance, and Five-Year Reviews [Area El],

Each of the four vapor intrusion alternatives is summarized below and in Figures J-9 through
J-13 (Appendix B). Detailed presentations of each alternative are found in Section 5.2 of the FS
and are provided in Tables J-9 through J-12 (Appendix E).

Alternative VII - No Action [Areas El and J]

This alternative was developed as a baseline case, as required by the NCP, to which all other
vapor intrusion alternatives may be compared. Under this alternative, there will be no reduction
of risk in the near term. Reduction of risk in the long term will occur gradually as natural
attenuation of groundwater through abiotic and biotic degradation and advection takes place.

This alternative is not protective and does not meet ARARs. There are no capital costs
associated with this alternative. A detailed evaluation of this alternative is provided in Table J-9
(Appendix E); and an evaluation of compliance with ARARs is presented in Tables J-16, J-17,
and J-18 (Appendix E).

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Alternative VI2 - Limited Action, Institutional Controls, Periodic Assessments, and Five-
Year Reviews [Areas El and J]

This alternative involves no passive or active vapor collection, removal, or treatment of Area
El and J but provides limited protection of human health by preventing or controlling potential
exposures to contaminated soil vapor through institutional controls. Components of this
alternative include:

•	Institutional Controls - Use restrictions will be implemented to limit, govern, or prevent
new construction without the installation of a soil vapor barrier and/or vapor mitigation
system and prohibit residential occupation of 1st floor apartments within existing building
(Area El). Use restrictions may be in the form of a deed restriction, easement or
covenant consistent with state law or other enforceable mechanisms. The following
institutional controls will be implemented:

o VIIC-1 - Prohibit the use of first floor residential units without the use of vapor
mitigation systems, unless information that demonstrates the systems are not
needed is provided to the regulatory agencies for review and approval; and
o VIIC-2 - Any new constructions will require the use of vapor mitigation systems,
unless information that demonstrates the systems are not needed is provided to the
regulatory agencies for review and approval.

•	Periodic Assessments - Periodic assessments will be performed to verify that there are no
prohibited uses, consistent with institutional controls.

•	Five-Year Reviews - Review Site conditions and protectiveness of remedy every 5 years.

This alternative does not include mitigation measures to prevent vapor intrusion; and
therefore, is not protective. It does not meet ARARs (RSRs) in Area El, which is currently in
residential use. However, this alternative complies with the ARARs (RSRs) in Area J, because
institutional controls will be used to prevent residential use and new construction unless
appropriate vapor mitigation systems are installed. This alternative can reduce risk in the short
term if institutional controls are implemented, monitored, and enforced. Periodic assessments
would be performed to ensure institutional controls are implemented; and five-year reviews
would be conducted. The estimated present worth of this alternative is $134,000. A detailed
evaluation of this alternative is provided in Table J-10 (Appendix E); and an evaluation of
compliance with ARARs is presented in Tables J-16, J-17, and J-18 (Appendix E).

Alternative VI3 - Active Soil Vapor Mitigation System, Institutional Controls, Operation
and Maintenance, and Five-Year Reviews [Area El]

This alternative uses active vapor mitigation to create a pressure differential across the
residential building slab to promote migration of subsurface soil gases into a collection system

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that prevents the entry of volatilized groundwater VOCs into occupied residential apartment
units on the building's first floor in Area El (119 Store Avenue). Potential exposure to
contaminated soil vapors would be mitigated in Area El. Components of this alternative
include:

• Pre-Design Investigation - Perform PDI to assess contaminant concentrations in indoor
air and sub-slab soil gas, existing building foundation, and potential vapor intrusion
routes. The results of the PDI will be used to design the vapor mitigation system.

• Active Vapor Mitigation System - Install an active vapor mitigation system at each of the
existing first floor residential units, A1 through A4. Seal vapor migration pathways
(underground utility penetrations, cracks, and/or sumps). Install a vapor barrier to
minimize vapor migration pathways. Construct an active vapor mitigation system using
vapor extraction trenches, piped to fans, and exhausted through discharge stacks to
atmosphere.

• Institutional Controls - Use restrictions will be implemented to prevent the residential use
of the first floor in existing structures without the use of a vapor mitigation system, and to
limit, govern, or prevent new construction without the installation of a soil vapor barrier
and/or vapor mitigation system. Use restrictions may be in the form of a deed restriction,
easement or covenant consistent with state law or other enforceable mechanisms, as well
as signage. The following institutional controls will be implemented:

o VIIC-1 - Residential use of the existing first floor apartments will be prohibited
unless vapor mitigation systems are in use, or information demonstrating that
vapor intrusion no longer presents an unacceptable health risk is reviewed and
approved by the appropriate regulatory agencies; and
o VIIC-2 - Any new constructions will require the use of vapor mitigation systems,
unless information that demonstrates the systems are not needed is provided to the
regulatory agencies for review and approval.

• Operation and Maintenance - O&M will be performed to ensure proper functioning of
the vapor mitigation system.

• Five-Year Reviews - review Site conditions and protectiveness of remedy every 5 years.

This alternative is protective and meets all ARARs. This alternative will meet RSRs through
the installation and O&M of active vapor mitigation systems in the existing building's residential
units on the ground floor. This alternative can reduce risk in the short term through active
mitigation of soil vapor into the residential units on the ground floor at 119 Store Avenue in Area
El. In addition, institutional controls will prevent the use of the residential units without the use
of a mitigation system. Periodic assessments would be performed to ensure institutional controls
are implemented; and five-year reviews would be conducted. The estimated present worth of

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this alternative is $616,000. A detailed evaluation of this alternative is provided in Table J-l 1
(Appendix E); and an evaluation of compliance with ARARs is presented in Tables J-16, J-17,
and J-18 (Appendix E).

Alternative VI4 - Passive Soil Vapor Barrier and Mitigation System, Institutional
Controls, Operation and Maintenance, and Five-Year Reviews [Area El]

This alternative uses a combination of a passive vapor barrier and passive vapor mitigation to
minimize vapor migration pathways and create a slight pressure differential across the
foundation slab to promote migration of subsurface soil gases into a collection system that
prevents the entry of volatilized groundwater VOCs into occupied residential apartment units.
Potential exposure to contaminated soil vapors would be mitigated in Area El. Components of
this alternative include:

•	Pre-Design Investigation - Perform PDI to assess contaminant concentrations in indoor
air and sub-slab soil gas, existing building foundation, and potential vapor intrusion
routes. The results of the PDI will be used to design the vapor mitigation system.

•	Passive Vapor Mitigation System - Install a passive vapor mitigation system at each of
the existing first floor residential units, A1 through A4. Install a passive vapor barrier,
minimizing vapor migration pathways. Construct a passive sub-slab venting system
using vapor collection trenches, solar chimneys, barometric check valves and discharge
stacks to atmosphere.

•	Institutional Controls - Use restrictions will be implemented to prevent the residential use
of the first floor in existing structures without the use of a vapor mitigation system, and to
limit, govern, or prevent new construction without the installation of a soil vapor barrier
and/or vapor mitigation system. Use restrictions may be in the form of a deed restriction,
easement or covenant consistent with state law or other enforceable mechanisms, as well
as signage. The following institutional controls will be implemented:

o VIIC-1 - Residential use of the existing first floor apartments will be prohibited
unless vapor mitigation systems are in use, or information demonstrating that
vapor intrusion no longer presents an unacceptable health risk is reviewed and
approved by the appropriate regulatory agencies; and
o VIIC-2 - Any new constructions will require the use of vapor mitigation systems,
unless information that demonstrates the systems are not needed is provided to the
regulatory agencies for review and approval.

•	Operation and Maintenance - O&M will be performed to ensure proper functioning of
the vapor mitigation system.

•	Five-Year Reviews - review Site conditions and protectiveness of remedy every 5 years.

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This alternative is protective and meets all ARARs. This alternative will meet RSRs through
the installation and O&M of passive vapor mitigation systems in the existing building's
residential units on the ground floor. This alternative can reduce risk in the short term through
passive mitigation of soil vapor into the residential units on the ground floor at 119 Store Avenue
in Area El. In addition, institutional controls will prevent the use of the residential units without
the use of a mitigation system. Periodic assessments would be performed to ensure institutional
controls are implemented; and five-year reviews would be conducted. The estimated present
worth of this alternative is $571,000. A detailed evaluation of this alternative is provided in
Table J-12 (Appendix E); and an evaluation of compliance with ARARs is presented in Tables J-
16, J-17, and J-18 (Appendix E).

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 (Section 6.0 of the FS). 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 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.

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:

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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. Implementability 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 O&M costs, as well as present-worth costs.
Modifying Criteria

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:

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 in Tables K-l and K-2 (Appendix C). A detailed description
of the comparative analysis can be found in Section 7.0 of the FS.

The following sections present the nine criteria and a brief narrative summary of the soil and
vapor intrusion 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.

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1. Soil Alternatives Analyzed

The soil alternatives were evaluated using the nine criteria and are summarized in the sections
below.

Overall Protection of Human Health and the Environment

Alternative SOI provides the least amount of protection of human health and the
environment because no actions will be taken to reduce the risk presented by contamination in
soil. Alternative S02 relies on institutional controls to: 1) prevent human exposure to
contaminated soil in Areas where risk is less than 1.0E-04 (Areas D3, E2, G, and H) and equal to
or greater than 1.0E-04, but no PRG exceedances were observed in soils that are considered
accessible (Area E3); 2) prevent current commercial use properties from converting to residential
use without agency approval; and 3) prevent the excavation and off-Site transport of soil without
agency approval.

Alternatives S03, S05, S07, and S08 provide overall protection of human health and the
environment by excavation and off-site disposal of soils with PRG and PMC exceedances across
the majority of the Site. S03 will address Areas Dl, El, and F, and S07 will address Area J
using targeted excavations. S05 will use larger excavations to address exceedances in Area J.
Various excavation scenarios (targeted and larger excavations) are proposed in Alternative S08
to address exceedances in Area I. In the near- and long-term, Alternatives S03, S05, S07, and
S08 will be protective of human health and the environment.

Alternative S04 provides overall protection of human health and the environment using
targeted in-situ physical treatment to solidify and stabilize soils with PRG and PMC exceedances
in Areas Dl, El, and F. In the near- and-long term, this Alternative will be protective of human
health and the environment. However, there is uncertainty about the effectiveness of treatment.
This alternative requires bench and pilot testing to evaluate the immobilization of contaminants
and leachability of the solidified material.

Alternative S06 provides overall protection of human health and the environment using a
soil cap to contain soils with PRG exceedances in Area J. In addition, PMC exceedances will be
excavated and transported off-site for disposal. In the near- and long-term, Alternative S06 will
be protective of human health and the environment.

Overall, Alternatives S03, S05, S07, and S08 are the most protective of human health
and the environment, followed by S06, S04, S02, and SOI. For Areas D3, E3, E2, G, and H,
S02 (limited action) is the only remedial option available, other than SOI (no action). For Areas
Dl, El, F, S03 (targeted excavation and off-site disposal) will be more protective than S04 (in-
situ solidification/stabilization). For Area J, S05 (large-scale excavation) will be more
protective than S06 (soil cap) or S07 (targeted excavations). For Area I, S08B (large-scale

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excavation to 4 ft bgs) will be more protective than either S08A (targeted excavations) or S08C
(large-scale excavation to 2 ft bgs).

Compliance with Applicable or Relevant and Appropriate Requirements

Compliance with chemical-specific, location-specific, and action-specific ARARs are
summarized in Tables 6-13, 6-14, and 6-15 of the FS, respectively. Alternative SOI will not
meet the chemical-specific ARARs including the PMC, DEC, or reduce potential health risks to
acceptable levels in a reasonable time frame. Alternative S02 will meet ARARs by using
institutional controls to prevent exposure to Site COCs that exceed the Preliminary Remediation
Goals (PRGs) in Areas D3, E2, E3, G, and H.

Alternatives S03, S04, S05, S06, S07, and S08 will meet the chemical-specific
ARARs in the portions of the Site where CERCLA response actions are being taken.

Alternatives S03 (Areas Dl, El, and F), S05 (Area J), S07 (Area J), and S08 (Area I) will meet
RSRs using targeted and larger excavations and off-site disposal of soils contaminated above
applicable PRGs (DECs, PMCs, or the background levels). S05 will address applicable PRG
exceedances using solidification/stabilization in Areas Dl, El, and F. S06 will address PRG
exceedances using a soil cap in Area J meeting the requirements of the TSCA regulations at 40
C.F.R. §761.61.

Alternatives S03, S04, S05, S06, S07, and S08 will be designed to meet the location-
specific ARARs. Alternatives S05, S06, and S07 may require construction activities adjacent
to Area J wetlands; a PDI will evaluate stormwater drainage and potential wetland impacts.
The alternative will comply with the location-specific ARARs and avoid and minimize potential
damage to wetlands. If damage cannot be avoided, then wetland mitigation will be performed to
comply with the ARARs. Alternative S06 complies with the regulations implementing Section
404 of the Clean Water Act at 40 C.F.R. Part 230 et seci.. as it is the least environmentally
damaging practicable alternative that attains remedial action objectives.

Alternatives S03, S04, S05, S06, S07, and S08 will be designed to meet the action-
specific ARARs. Alternatives S03, S05, S06, S07, and S08 include backfilling and capping
(S06 only). The backfill and soil cap will be designed to comply with the RSRs and action-
specific ARARs. In addition, Alternatives S05 and S07 include the excavation, temporary
storage, and off-site disposal of PCB contaminated soil. These alternatives will be designed and
implemented to include handling, storage, and disposal procedures that comply with ARARs,
including TSCA regulations governing capping of bulk PCB remediation wastes at 40 C.F.R.
§761.61 and Connecticut regulations.

Overall, all active alternatives (S03 through S08) are generally comparable in their
ability to comply with the chemical-, location-, and action-specific ARARs. Particular care will
be taken during construction activities adjacent to wetlands and storage and off-site disposal of
PCB contaminated soil to comply with ARARs for the Area J alternatives (S05, S06, and S07).

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Long-Term Effectiveness and Permanence

Alternative SOI provides the least long-term effectiveness and permanence because no
actions will be taken to control exposure over time or to permanently reduce the level of
contaminants in soil in the long term. While natural degradation processes may reduce the
concentrations of contaminants, the process kinetics may not be appreciable and the residual risk
will remain for a very long time. Similar to SOI, Alternative S02 will not satisfy CERCLA's
statutory preference for treatment. However, this alternative is applicable to Areas where risk is
less than 1.0E-04 (Areas D3, E2, G, and H) and Areas where risk is equal to or greater than 1.0E-
04, but no PRG exceedances were observed that are considered to be accessible (Area E3).
Therefore, protection of human health can be controlled using institutional controls. The long-
term effectiveness is only as good as the measures taken to ensure the reliability of controls
(proper implementation, monitoring, and enforcement of institutional controls).

Alternatives S03, S05, S07, and S08 will provide permanent reduction in the
contaminant mass with the excavation and off-site disposal of soils with PRG exceedances
(DECs, PMCs, or background levels). S03 and S07 will use targeted excavations focusing on
relatively small areas (1 square yard [sy] each) to remove PRG exceedances in Areas Dl, El,
and F and Area J, respectively. S05 will use larger excavations, 38,300 sy in Area J, for the
removal of PRG exceedances. S08 will use various excavation scenarios (ranging from several
small excavations at 1 sy each to one large excavation at 2,730 sy) in Area I for the removal of
PRG exceedances. The targeted and larger excavations and the backfilling will effectively
redefine the remaining contaminated soil at these locations as "inaccessible" per the RSRs. As a
result, these alternatives will decrease risks to acceptable levels in the near- and long-term.
However, PRG exceedances will remain in soil at deeper depths. These alternatives would rely
on institutional controls to prevent the excavation of soil.

Similar to Alternatives S03, S05, S07, and S08, Alternative S04 provides a permanent
reduction of risk through solidification/stabilization of PRG exceedances in Areas Dl, El, and F.
This treatment alternative will prevent potential exposure to contaminated soil and the potential
migration of contaminants to groundwater. The long-term effectiveness of this Alternative will
be confirmed during the treatability and pilot studies. Testing will evaluate the immobilization
of contaminants and leachability of the solidified material. This alternative would rely on
institutional controls to prevent the excavation of soil and the encapsulated materials.

Alternative S06 also provides a permanent reduction of risk through the capping of PRG
exceedances and the excavation and off-site disposal of PMC exceedances in Area J, as long as
the soil cap is maintained in the long-term. This alternative will prevent potential exposure to
contaminated soil and the potential migration of contaminants to groundwater. The soil cap will
effectively render the remaining contaminated soil in Area J as unavailable to contact through an
engineering control. As a result, the alternative will decrease risks to acceptable levels in the
near- and long-term. However, PRG exceedances will remain in the soil below the soil cap.

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These alternatives would rely on institutional controls to prevent the excavation of soil and long-
term maintenance of the soil cap.

Overall, Alternatives S03, S05, S07, and S08 provide the most long-term effectiveness
and permanence, followed by S06, S04, S02, and SOI. For Areas D3, E3, E2, G, and H, S02
(limited action) is the only remedial option available, other than SOI (no action) and is therefore
more effective. For Areas Dl, El, F, S03 (targeted excavation and off-site disposal) will be
more effective and permanent than S04 (in-situ solidification/stabilization). For Area J, S05
(large-scale excavation) will be more effective and permanent than S06 (soil cap) or S07
(targeted excavations). For Area I, S08B (large-scale excavation to 4 ft bgs) will be more
effective and permanent than either S08A (targeted excavations) or S08C (large-scale
excavation to 2 ft bgs).

Reduction of Toxicity, Mobility, or Volume Through Treatment

Alternative S04 will reduce toxicity through treatment. Alternative S06 will isolate
contaminants and possibly reduce mobility through treatment. The other alternatives analyzed
do not reduce toxicity, mobility, or volume through treatment. However, alternatives S03, S05,
S07, and S08 employ excavation and off-Site disposal of contaminated soil, which will reduce
the volume of contaminated media at the Site.

Based on the RI results, it was determined that there are no Principal Threat Wastes at the
Site. Therefore, this evaluation criterion, which is principally applicable to sites with Principal
Threat Wastes, is not a significant criterion for the Site.

Short-Term Effectiveness

No active remedial actions are associated with Alternative SOI; therefore, no risks to the
community, workers, or the environment during implementation. Alternative S02 will not
impact the community, workers, or the environment as no actions other than the implementation
of institutional controls and periodic assessments are required. This alternative is effective in the
near-term because it prevents the potential exposure to contaminated soil in Areas D3, E2, E3, G,
and H.

Alternatives S03, S05, S07, and S08 include active excavation and handling of
contaminated soil and are effective in the short-term. Alternatives S04 and S06 include
solidification/ stabilization and a soil cap, respectively, and are also effective in the near-term.
Active remedial alternatives, S03, S04, S05, S06, S07, and S08, would be implemented in a
year or less time. The potential risks to the community, on-site workers, and the environment are
expected to be minimal with proper design and controls.

Environmental impacts on the Site during Alternatives S03, S04, S05, S06, S07, and
S08 are anticipated to be minimal. Construction activities will avoid potential damage to

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wetland areas or will include wetland mitigation if damage cannot be avoided. Alternative S04
will include control measures to prevent adverse impacts to local groundwater during injection
and soil mixing activities.

Overall, Alternative S06 provides the most short-term effectiveness, followed by S03,
S05, S07, S08, S04, S02, and SOI. For Areas D3, E3, E2, G, and H, S02 (limited action) is
the only remedial option available, other than SOI (no action) and is therefore more effective in
the near-term. For Areas Dl, El, F, S03 (targeted excavation and off-site disposal) will be more
effective in the short-term than S04 (in-situ solidification/stabilization). For Area J, S06 (soil
cap) is more effective in the near-term than S05 (large-scale excavation) or S07 (targeted
excavations). For Area I, S08B (large-scale excavation to 4 ft bgs) will be more effective and
permanent than either S08A (targeted excavations) or S08C (large-scale excavation to 2 ft bgs).

Implementability

Alternative SOI is the easiest to implement when compared with the other alternatives
because no actions are required. Alternative S02 includes institutional controls and periodic
assessments, which are readily implementable.

Alternatives S03, S05, S07, and S08 will require construction and waste transportation
firms with heavy equipment to implement the targeted and larger excavations and off-site
disposal. Equipment and materials are readily available. S05 is more difficult to implement
than the other Alternatives due to the larger excavation areas.

Alternative S04 will require a specialized engineering firm (which are limited) with
testing capabilities, reagents, and equipment to implement the in-situ physical treatment.
Alternative S06 will require a construction firm with heavy equipment to construct the soil cap.

Of the active remediation alternatives (S03, S04, S05, S06, S07, and S08), S04 and
S06 are regarded as the green alternative with in-situ targeted physical treatment and a soil cap,
respectively. The heavy construction and transportation equipment associated with S03, S05,
S07, and S08 will result in the emissions of combustion byproducts, including particulates,
carbon dioxide, nitrogen oxides, sulfur dioxide, heavy metals, and VOCs.

Overall, Alternative SOI is the easiest to implement, followed by S02, S03, S04, S06,
S07, S05, and S08.

Cost

The estimated present worth costs for the alternatives, not including Alternative SOI (no
action), range from $233,000 for Alternative S02 (limited action in Areas D3, E3, E2, G, and H)
to $11,013,000 for Alternative S05D (excavation and disposal in Area J). Alternative S05 is the
most expensive alternative, followed by S08, S06, S07, S04, S03, S02, and SOI.

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For Areas D3, E3, E2, G, and H, S02 is the only remedial option available, for which
there is only one costs analysis. For Areas Dl, El, F, S03 (targeted excavation and off-site
disposal) will cost less than S04 (in-situ solidification/stabilization). For Area J, S06 (soil cap)
costs less than S05 (excavation and off-site disposal) for large areas of contaminated soil. If
there are discrete areas of contamination, then S07 would cost less than either S05 or S06. For
Area I, costs under S08 will be dependent of the volume and areal extent of contaminated soil
that warrant action.

State Acceptance

CT DEEP has expressed its support for the selection of S02 for Areas D3, E3, E2, G, and
H; S03 for Areas Dl, El, and F; S06 for Area J; and S08B for Area I.

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.

2. Vapor Intrusion Alternatives Analyzed

The vapor intrusion alternatives were evaluated using the nine criteria and are summarized in the
sections below.

Overall Protection of Human Health and the Environment

Alternative VII provides the least amount of protection of human health and the
environment because no actions will be taken to reduce the risk presented by vapor intrusion
from contaminated groundwater. Alternative VI2 relies on institutional controls to prevent
potential human exposure to vapor intrusion by contaminated groundwater.

Alternatives VI3 and VI4 provide overall protection of human health by extracting soil
gases from below Area El building's slab and preventing the migration of contaminated vapor
into occupied residential apartments. In the near- and long-term, Alternatives VI3 and VI4 will
be protective of human health and the environment.

Overall, VI3 (active mitigation) will be most protective of human health and the
environment, followed by VI4 (passive mitigation), VI2 (limited action), and VII (no action).

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Compliance with Applicable or Relevant and Appropriate Requirements

Alternatives VII will not meet the chemical-specific ARARs. For Area J, Alternative
VI2 will use institutional controls preventing residential use and requiring installation of vapor
mitigation systems for future commercial buildings which would comply with the requirements
of the ARARs. VI3 and VI4 will meet the chemical-, location-, and action-specific ARARs
through active and passive vapor mitigation systems, respectively.

Overall, the active alternatives (VI3 and VI4) are comparable in their ability to comply
with the chemical-, location-, and action-specific ARARs.

Long-Term Effectiveness and Permanence

Alternative VII provides the least long-term effectiveness and permanence because no
actions will be taken to control exposure to soil vapor over time or to permanently reduce the
groundwater contamination in the long term. Alternative VI2 relies on institutional controls in
the long-term to prevent potential exposures to vapor intrusion from contaminated groundwater.
The long-term effectiveness of Alternative VI2 is only as good as the measures taken to ensure
the reliability of controls.

Alternatives VI3 and VI4 will provide a reduction of vapor intrusion using active and
passive mitigation systems, respectively. Alternatives VI3 and VI4 are dependent on the proper
implementation, operation and maintenance, monitoring, and enforcement of institutional
controls to remain effective.

Overall, of the active alternatives, VI3 (active mitigation) will be more effective and
permanent than VI4 (passive mitigation).

Reduction of Toxicity, Mobility, or Volume Through Treatment

The alternatives analyzed do not directly reduce toxicity, mobility or volume through
treatment. However, based on the RI results, it was determined that there are no Principal Threat
Wastes on the Site. Therefore, this evaluation criterion, which is principally applicable to sites
with Principal Threat Wastes is not a significant criterion for the Site.

Short-Term Effectiveness

No active remedial actions are associated with Alternatives VII and VI2; therefore, no
risks to the community, workers, or the environment during implementation. Alternatives VI3
and VI4 include active and passive soil vapor mitigation, respectively. Residents will be
temporarily evacuated while these alternatives are under construction. Site workers will use
proper personal protection equipment and appropriate health and safety protocols will be

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followed when implementing the alternatives. No risk to the environment is anticipated with
Alternatives VI3 and VI4.

Overall, the active alternatives (VI3 and VI4) are comparable in their effectiveness in the
near-term.

Implementability

Alternative VII is the easiest to implement when compared with the other alternatives
because no actions are required. Alternative VI2 includes institutional controls and long-term
monitoring, which are readily implementable.

VI3 and VI4 will require an environmental remediation firm with experience in soil
vapor mitigation to construct and operate the active and passive mitigation systems, respectively.
Equipment and materials are readily available. Fluctuations in naturally occurring atmospheric
conditions can limit the reliability of VI4. VI4 is slightly more difficult to implement than VI3;
and both are more difficult than VII and VI2.

Of the active remediation alternatives (VI3 and VI4), VI4 is regarded as the green
alternative with passive soil vapor mitigation. Alternative VI4 requires the least amount of
energy because mitigation relies on naturally occurring atmospheric conditions to passively vent
soil vapor to the atmosphere.

Overall, Alternative VII is the easiest to implement, followed by VI2, VI4, and VI3.

Cost

The estimated present worth costs for the alternatives, not including Alternative VII (no
action), range from $134,000 for Alternative VI2 (limited action) to $616,000 for Alternative
VI3 (active vapor mitigation). Alternative VI3 is the most expensive alternative, but is only
slightly more expensive than VI4 (passive vapor mitigation), followed by VI2 and VII.

State Acceptance

CT DEEP has expressed its support for the selection of VI2 for Area J and VI3 for Area

El.

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.

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L. THE SELECTED REMEDY

1. Summary of the Rationale for the Selected Remedy

The selected remedy is a comprehensive set of measures that utilizes source control
components to address the principal Site risks. Because action at this Site is being taken
pursuant to CERCLA and the NCP, federal standards (rather than state standards) are applied
when considering whether risks at the Site warrant a response action. Based on the evaluation
of risks which consider current and future uses of the Site, COCs exceeding background
concentrations pose excess risks greater than 1.0 E-04 cancer risk, the upper end of EPA's
acceptable risk range, or a non-cancer HI of 1.0. These health risks exceed EPA's threshold for
response actions under CERCLA.

Source control measures are required to prevent potential exposure to contaminated soil
at the Site. In addition, vapor intrusion control measures will be used to prevent potential
exposure to VOCs in soil vapor that may off-gas from contaminated groundwater. Of all the
alternatives evaluated, the selected remedy best satisfies the statutory criteria for remedy
selection.

The selected remedy combines several soil and vapor intrusion alternatives.
Contaminated soil at the Site will be addressed using S02 (institutional controls) for Areas D3,
E3, E2, G, and H; S03 (targeted excavations and off-site disposal) for Areas Dl, El, F; S06
(soil cap) for Area J; and S08B (excavation and off-site disposal) for Area I. In addition, vapor
intrusion threats will be address using VI2 (institutional controls) for Area J (unoccupied) and
VI3 (active vapor mitigation) for Area El (occupied existing structure).

The selected remedy set forth in this ROD addresses the following unacceptable risks:

• Potential direct exposure (inhalation, dermal contact, or ingestion) to soil contaminants;

and

• Potential exposure to soil vapor contaminants resulting from localized groundwater VOC

contamination.

The selected remedy also addresses potential transport of soil contaminants (vanadium)
above the PMC to groundwater.

2. Description of Remedial Components

The following alternatives comprise the selected remedy.

Soil Alternatives:

• Areas D3, E3, E2, G, and H - S02 Institutional Controls;

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• Areas Dl, El, and F - S03 Targeted Excavations and Off-Site Disposal and Institutional
Controls;

• Area J - S06 Pre-Design Investigation, Soil Cap, Operation and Maintenance, and
Institutional Controls; and

• Area I - S08B Pre-Design Investigation, Excavations and Off-Site Disposal, and
Institutional Controls.

Vapor Intrusion Alternatives:

• Area El - VI3 conduct PDI and if exposure pathway exists install an Active Vapor
Mitigation, Operation and Maintenance, and Institutional Controls; and

• Area J - VI2 Institutional Controls.

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.

Because hazardous substances, pollutants or contaminants will remain at the Site EPA
will review the Site to the extent required by law at least once every 5 years after the initiation of
remedial action at the Site to assure that the remedial action continues to protect human health
and the environment.

The selected remedy may change somewhat as a result of the remedial design and
construction processes. Changes to the remedy described in this ROD will be documented in a
technical memorandum in the Administrative Record for the Site, an Explanation of Significant
Differences or a ROD Amendment, as appropriate.

a. Soil Remedy

Several remedial options were selected for the various Risk Areas at the Site. The soil
remedy for specific areas is described in the sections below to meet cleanup levels (CULs).

CULs are discussed under Section L.4.a.- Soil Cleanup Levels.

Areas D3, E3, E2, G, and H

The soil remedy for Areas D3, E3, E2, G, and H includes institutional controls, periodic
assessments, and Five-Year Reviews.

Institutional Controls - Institutional controls are non-engineered actions, such as administrative
and legal controls, that help to minimize the potential exposure to contaminants or protect the
effectiveness of response actions. Institutional controls are used to limit land and/or resource
use, or provide information that help guide or modify human activities at sites [EPA, 2012],

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Institutional controls will be implemented to limit, govern, or prevent excavations in
contaminated fill, and to prevent unacceptable exposures to contaminants. Use
restrictions may be in the form of a deed restriction, easement or covenant consistent with
state law, other enforceable mechanisms, zoning ordinances, or a combination thereof.
The following institutional controls will be implemented:

o IC-1: Prevent future excavation of on-site soils for use or disposal beyond the

property boundary without state regulatory approval;
o IC-2: Prevent future residential use unless the areas are already currently used as

residential without federal/state regulatory approval, and
o IC-3: Prevent any excavation and re-use of soil from 4 ft bgs or deeper without state
regulatory approval.

Periodic Assessments - Periodic assessments will be performed to ensure that Institutional
Controls (i.e., IC-1, IC-2, and IC-3) are being implemented and are protective of human health
and the environment in accordance with the requirements of the selected remedy. The frequency
of periodic assessments will be determined at every Five-Year Review.

Five-Year Reviews - Reviews will be performed once every 5 years to assess Site conditions and
to ensure that the remedy remains effective and protective. Assessments will be performed to
review onsite conditions, land use, zoning, and new regulations or ordinances to identify changes
that may affect the protectiveness of the remedial alternative/selected remedy.

The institutional actions, periodic assessments, and five-year reviews are included as integral
components of the other soil remedies in other Areas to ensure the long-term effectiveness of
alternatives where soils exceeding CULs remain on the Site.

Areas Dl, El, and F

The soil remedy for Areas Dl, El, and F includes PDI, utility clearance, targeted soil
excavations, confirmation sampling, backfilling, soil disposal, dust control, decontamination,
institutional controls, periodic assessments, and Five-Year Reviews.

Pre-Desisn Investigation - Four soil boring locations will be installed on neighboring residential
properties at Area El (110, 118, 126, and 134 Monroe Avenue). Samples will be collected from
2 ft bgs, 4 ft bgs, and from top of groundwater and analyzed for Site COCs (metals and PAHs).
Soil sampling results will be used to further delineate Site COCs at this Site boundary.

Utility Clearance - Prior to the targeted excavations, a utility clearance survey will be performed
to delineate potential utilities and avoid interference. The survey would be performed using a
combination of electromagnetic induction, magnetometry, utility locator and ground penetrating

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radar techniques to locate and map the locations of potential utilities within each of the
excavation areas.

Targeted Soil Excavation - Alternative S03 addresses potential human exposure to
contaminated soils exceeding CULs and addresses contaminant concentrations that exceed PMC
in Areas Dl, El, and F using small, targeted excavations, with an area of 1 square yard. CUL
exceedances will be excavated to a depth of 4 feet below ground surface (ft bgs). Clean fill and
pavement will effectively redefine the remaining contaminated soil at these locations as
"inaccessible" per the RSRs (further discussed in Backfilling section below). In addition, soil
will be excavated to the top of groundwater at PMC exceedances.

The deeper excavations at PMC exceedances (estimated to be approximately 10 ft bgs) in
Areas Dl and El will require sloping for construction worker safety and excavation stability. A
slope of 2 to 1 has been assumed at these locations. A total excavation volume of approximately
144 cy is estimated for the CUL and PMC exceedances in Areas Dl, El, and F. The excavated
soil will be replaced with clean, imported fill and finished with pavement.

Confirmation Sampling - The sidewalls (and bottoms at PMC exceedance excavations) of the
excavations will be sampled for confirmation purposes. At PMC exceedances, five confirmation
sampling locations (four sidewalls and one bottom) will be collected per excavation. At CUL
exceedance locations, the excavation depth will be limited to a maximum of 4 ft bgs per ARARs
(CT RSRs). Therefore, no confirmation bottom sample will be needed and four confirmation
sampling locations at the four sidewalls will be collected per CUL exceedance excavation.

Confirmation samples will be analyzed for the specific COCs associated with the CUL or PMC
exceedances(s) at the excavation. Confirmation sampling results will be compared to the
associated CUL or PMC. If the COC concentration at a confirmation sampling location exceeds
the respective CUL or PMC, the excavation will continue an additional 1 linear yard in the
direction of the exceedance. Additional confirmation samples will be collected at the new
sidewall(s) or bottom of the excavation. The excavation will continue until additional
confirmation sampling results are less than the CUL or PMC values.

In addition, confirmation groundwater monitoring will be conducted to determine that the
applicable ground-water protection criteria, SWPC and volatilization criteria have been met,
consistent with RSRs (Sections 22a-133k-l through 22a-133k-3). The SWPC is the only
applicable criterion at the Site; therefore, samples will be analyzed for PMC analytes. Data will
be used to evaluate potential SWPC exceedances following construction activities.

Backfill - Clean soil will be backfilled at each targeted excavation consistent with the conditions
prior to the excavation. At CUL exceedances, backfill will be consistent with RSRs (Sections
22a-133k-l through 22a-133k-3) to render deeper contaminated soil inaccessible through
excavation and replacement of shallow soils. Backfill will consist of bituminous pavement top
coat (1 inch), bituminous pavement binder (2 inch), and compacted bank-run sand and gravel to

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4 ft bgs or deeper at PMC exceedances, all placed successively. At CUL exceedance locations, a
warning marker consisting of a non-woven geotextile will be placed at the backfill and
contaminated soil interface.

Soil Disposal - Excavated soil would be disposed of off-site. Based on RI data, the RCRA
Subtitle D landfill option has been selected for the disposal of soil from Areas Dl, El, and F.

Dust Control During Construction - Critical to implementation will be the suppression of dust
and monitoring of perimeter up- and down-wind air quality. An air quality management and
monitoring program will be established in each of the active targeted excavation areas.

Decontamination - Temporary decontamination stations will be constructed at each targeted
excavation location. Heavy equipment used during the excavations will undergo dry
decontamination and will consist of physical removal of soil adhering to the equipment prior to
moving to the next excavation location. The soil removed will be collected and disposed of
offsite with the excavated soils.

Before the heavy equipment leaves the Site after the targeted soil excavations, it will undergo a
full decontamination process involving high-pressure steam-cleaning. A decontamination pad
will be constructed to contain the decontamination residuals. The pad will be constructed with a
slope so that wastewater will flow towards a sump. The steam-cleaning will be supplemented
with additional scrubbing to remove encrusted materials from equipment. Wastewater will be
transferred from the sump into drums for characterization and offsite disposal.

Institutional Controls - Same as Areas D3, E3, E2, G, and H, except without IC-2 because Areas
Dl, El, and F are already used for residential purposes.

Periodic Assessments - Same as Areas D3, E3, E2, G, and H.

Five-Year Reviews - Same as Areas D3, E3, E2, G, and H.

Area J

The soil remedy for Area J includes PDI, utility clearance, excavation and consolidation,
soil disposal, confirmation sampling, backfilling, soil cap, dust control, decontamination,
institutional controls, operation and maintenance, periodic assessments, and five-year reviews.

Pre-Desisn Investigations - The PDI will be conducted to better characterize soil and PMC and
CUL exceedances in Area J. Once the PDI is complete, the data will be assessed and used in the
remedial design for Area J.

The PDI will include a sampling grid of 50 feet on center, approximately 72 soils boring
locations. Following subsurface utility clearance, soil borings will be advanced using direct-

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push technology drill rigs. Soil samples (excluding asphalt pavement and fill material) would be
collected from the 0, 2, and 4 ft bgs depth intervals and analyzed onsite using a mobile
laboratory for PAHs, metals, and PCBs (for comparison to CULs). 20% of the soil samples
would be sent off-site for fixed laboratory analyses. In addition, 10% of the soil borings will be
completed to the top of groundwater. Samples will be collected at the final depth and will be
analyzed for SPLP analyses (for comparison to PMC) at a fixed laboratory.

The PDI will include an evaluation of the Area J wetlands and stormwater management during
and after construction. The PDI results will be used to design a Site drainage plan and potential
wetlands mitigation plan, if wetlands are impacted by construction activities. Stormwater can be
managed through discharge to the existing local drainage system.

Utility Clearance - Same as Areas Dl, El, and F.

Excavation and Consolidation - This alternative assumes 10 discrete CUL exceedances exist
outside of the planned soil cap area. These CUL exceedances will be excavated and consolidated
within the planned cap area. The CUL exceedance excavations will require the removal of soil
to a depth of 4 ft bgs. In addition, this alterative includes the excavation of 6 discrete PMC
exceedances. PMC exceedances will be excavated for off-site disposal.

Soil Disposal - Excavated soil (from PMC exceedances) would be disposed of off-site
(estimated to be approximately 420 cy). Excavated soil volumes and contamination
concentrations will be determined during the PDI. However, this alternative assumes soil will be
disposed of at a non-hazardous waste landfill. Similar to other alternatives, waste
characterization sampling results will confirm the waste profile of the material.

Decontamination - Same as Areas Dl, El, and F.

Confirmation Sampling - At CUL and PMC exceedance excavations, the confirmation sampling
will be the same as Areas Dl, El, and F.

Backfill - At CUL and PMC exceedance excavations, backfill will be consistent with the RSRs
(Sections 22a-133k-l through 22a-133k-3) to render contaminated soil inaccessible through
excavation and replacement of shallow soils. Backfill will consist of 3.5 feet (or deeper at PMC
locations) of common fill and 6 inches of topsoil, which will be revegetated. At CUL
exceedance locations, a warning marker consisting of a non-woven geotextile will be placed at
the backfill and remaining contaminated soil interface.

Soil Cap - This alternative uses a soil cap to prevent direct contact with contaminated soil within
Area J. Based on RI data, the soil cap will be approximately 86,200 sf and raise the ground
surface by approximately 2 feet. The soil cap will consist of a geotextile warning layer, barrier
layer (cobbles, 1 foot), soil cover (1 foot), and surface vegetation.

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Dust Control During Construction - Water would be required for dust suppression during
excavations in Area J. A temporary water service would be installed to provide water to the
undeveloped Area J.

In addition, monitoring of perimeter up- and down-wind air quality is critical to ensure the safety
of neighboring properties, especially where elevated PCB soil concentrations are documented.
An air quality management and monitoring program will be established that includes the real-
time monitoring of dust with (with a PCB-specific dust action level based on historic PCB soil
concentrations) using a real-time dust meter.

Institutional Controls - Same as Areas D3, E3, E2, G, and H, including the restriction on
residential use. In addition, a deed restriction, easement, covenant or other enforceable
mechanism will be required to ensure long-term care of cap components, including repairs, and
to establish limitations on and requirements for future construction in Area J to maintain the
integrity of the cap. Access restrictions, such as a fence and warning signs, may also be
implemented.

Operation and Maintenance - Long-term operation and maintenance of the soil cap will be
required to ensure the area is not disturbed. The cap inspections will take place annually.

Periodic Assessments - Same as Areas D3, E3, E2, G, and H.

Five-Year Reviews - Same as Areas D3, E3, E2, G, and H.

Area I

The soil remedy for Area I includes PDI, utility clearance, excavation, confirmation
sampling, backfilling, soil disposal, dust control, stockpile management, decontamination,
institutional controls, periodic assessments, and five-year reviews.

Pre-Desisn Investigations - The PDI will be conducted to better characterize soil and PMC and
CUL exceedances in Area I. Once the PDI is complete, the data will be assessed and used in
the remedial design for Area I.

The PDI will include a sampling grid of 50 feet on center, approximately 40 soils boring
locations. Following subsurface utility clearance, soil borings would be advanced using direct-
push technology drill rigs. Soil samples (excluding asphalt pavement and fill material) would be
collected from the 0, 2, and 4 ft bgs depth intervals and analyzed onsite using a mobile
laboratory for PAHs and metals (for comparison to CULs). 20% of the soil samples would be
sent off-site for fixed laboratory analyses. In addition, 10% of the soil borings will be completed
to top of groundwater. Samples will be collected at the final depth and will be analyzed for
SPLP analyses (for comparison to PMC) at a fixed laboratory.

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Utility Clearance - Same as Areas Dl, El, and F.

Excavation - Alternative S08 would reduce potential human exposure to contaminated soils by
removing soil with contaminants exceeding CULs and addresses contaminant concentrations that
exceed PMC. CUL exceedances will be excavated to a depth of 4 ft bgs. Clean fill and
pavement will effectively redefine the remaining contaminated soil at these locations as
"inaccessible" per the RSRs. In addition, soil will be excavated to the top of groundwater at
PMC exceedances. The deeper excavations at PMC exceedances (estimated to be approximately
10 ft bgs) will require sloping for construction worker safety and excavation stability (a slope of
2 to 1).

This alternative assumed an excavation area of 24,600 sf and volume of 3,714 cy. However,
excavated soil areas and volumes will be determined during the PDI.

Confirmation Sampling - Side walls will be sampled every 25 feet along the CUL exceedance
excavations in Area I. At PMC exceedances, the sidewalls and bottoms of the excavations will
be sampled for confirmation purposes. Confirmation samples will be analyzed for the specific
COCs associated with the CUL or PMC exceedances(s) in the Areas (PAHs and metals).
Confirmation sampling results will be compared to the associated CUL or PMC (Tables L-l and
L-2 of Appendix C). If the COC concentration at a confirmation sampling location exceeds the
respective CUL or PMC, the excavation will continue an additional 1 linear yard in the direction
of the exceedance. The excavation will continue until additional confirmation sampling results
are less than the CUL or PMC.

Consistent with RSRs (Section 22a-133k-3(g)(2)(C)), confirmation groundwater monitoring will
be conducted to determine that the "applicable ground-water protection criteria, surface-water
protection criteria and volatilization criteria have been met." SWPC is the only applicable
criterion at the Site; therefore, samples will be analyzed for PMC analytes. Data will be used to
evaluate potential SWPC exceedances following construction activities.

Backfill - Same as Areas Dl, El, and F.

Soil Disposal - Excavated soil would be disposed of off-site as non-hazardous. The volume of
soil requiring disposal was assumed to be 3,714 cy; however, excavated soil volumes and
contamination concentrations will be determined during the PDI. Waste characterization
sampling results will confirm the waste profile of the material. Due to the sizes of the
excavations, it is anticipated the soil will require temporary storage or stockpiling while it is
being characterized for disposal.

Dust Control During Construction - Same as Areas Dl, El, and F.

Stockpile Management - A temporary soil stockpile area will be necessary to stage excavated
soil while it is being characterized for disposal. A soil stockpile area will consist of a bermed

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area surrounded by erosion controls to prevent the migration of contaminants in the event that
rainwater falls onto the stockpiled soil. The stockpile area will be lined to prevent intermingling
between contaminated soil and the underlying ground surface. In addition, covers will be
installed to prevent contact with rainwater and wind and eliminate runoff or wind erosion.
Polyethylene plastic sheeting (6 millimeter or greater) would be used for the bottom liner and
cover.

Decontamination - Same as Areas Dl, El, and F.

Institutional Controls - Same as Areas D3, E3, E2, G, and H, including the restriction on
residential use

Periodic Assessments - Same as Alternative Areas D3, E3, E2, G, and H.

Five-Year Reviews - Same as Areas D3, E3, E2, G, and H.

b. Vapor Intrusion Remedy

Two remedial alternatives were selected for the two Risk Areas potentially affected by vapor
intrusion issues (Areas El and J). The selected vapor intrusion remedial alternatives for these
areas are described in the sections below.

Area El

The presumptive remedy for Area El includes a PDI, an active vapor mitigation system,
vapor barrier, start-up testing, O&M, institutional controls, periodic assessments, and five-year
reviews.

Pre-Desisn Investigation - A PDI will be performed to further evaluate the vapor intrusion
pathway underneath the 119 Store Ave building. The PDI may include, but not be limited to,
groundwater monitoring, sub-slab soil gas sampling, an exposure pathway evaluation, indoor air
sampling, and/or other investigatory means of determining whether a vapor mitigation system is
necessary. Sampling results would be compared to CT RSRs. If it is deemed necessary, the
PDI would obtain information on the design or as-built drawings for the existing structure (119
Store Avenue). If the as-built drawings are not available, a survey would be performed and
record available building information during a facility inspection. In addition, tests may be
performed to estimate air permeability of soil under the slab or foundation of the four apartment
units and to estimate the radius of influence of horizontal extraction trenches. Subsurface
conditions and foundation construction will also be evaluated to determine the potential for
permeation of soil vapors through both the subsoil and floor slab.

If a vapor mitigation system is found to be necessary based on the exposure pathway evaluation,
a sub-slab soil vapor and indoor air investigation will be conducted at the residential apartment
units on the ground floor to further characterize potential vapor intrusion. The investigation data

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will be used to establish a baseline for indoor air and subsurface soil gas conditions. At each
residential apartment, one indoor air sample will be collected and one sub-slab vapor sampling
port location will be installed and sampled. Samples will be analyzed for VOCs. The PDI
results will be evaluated, and if determined to be necessary, will be used to design the active
vapor mitigation system.

Active Vapor Mitigation System - Depending on the PDI results, an active vapor mitigation
system would be installed at each of the residential units on the ground floor at 119 Store
Avenue. Each system will consist of a vapor extraction trench, conveyance piping, vent fan, and
vapor discharge stack. The ground floor apartments would need to be evacuated for at least 3
weeks while the active vapor mitigation systems are installed (including the vapor intrusion
barrier). Once the apartments are evacuated, the carpeting or other flooring would be removed
and preserved for re-installation.

The concrete slab foundation would be cut to accommodate the vapor extraction trench
construction. The trench dimensions are anticipated to be 28 inches wide by 25 feet long by 34
inches deep and will be excavated by hand. The extraction piping installed within the trench
would run from the trench through to a penetration at the exterior wall. Vapors would be
collected in a 4-inch slotted PVC screen installed within the extraction trench. The PVC pipe
would be surrounded by a filter sleeve and a sand pack. After the horizontal piping has been
installed, the concrete slab floor would be replaced and sealed.

At the exterior of the building, the pipe would connect to a fan, which draws soil gas from the
subslab area through the extraction piping. Each of the four apartment units would have
individual vapor mitigation systems with dedicated fans that require an electrical power source.
Each active vapor mitigation system will have a dedicated vapor discharge stack. The vapor
discharge stacks would span the height of the building to the roof and would discharge the soil
gases to the atmosphere away from windows and air intake locations. Ball valves installed at the
fans will control vapor flow from the subsurface. In addition, a condensate bypass would trap
and drain any condensed liquid.

Vapor Intrusion Barrier - Implementation of the vapor mitigation systems will require all
potential pathways to be sealed using a vapor intrusion barrier, reducing the potential for subslab
vapors to enter the residential units. A vapor intrusion barrier would be installed in each of the
residential units. Installation of the vapor intrusion barriers will entail the installation of the
vapor barrier membrane over the existing foundation and the placement of 2 inches of new
concrete over the membrane for protection. All accessible penetrations through the floor will be
sealed.

Diagnostic Start-Uv Testing - Following the installation of the active vapor mitigation system
and prior to turning the system "on", diagnostic testing will be performed at system start-up to
ensure the system is working as designed. Testing will consist of applying a vacuum to the
vapor extraction trench and measuring pressure responses at vapor monitoring wells. Four vapor

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monitoring wells will be installed within the hallways and garage and are co-located with vapor
extraction trenches in the residential apartments. These locations were selected because the
vapor monitoring wells would be accessible when the apartments are occupied, if needed.

Operation and Maintenance - Monthly inspection of the vapor mitigation systems for 1 year and
quarterly thereafter will ensure the system is functional and operating as intended. The
frequency of inspections will be further evaluated during the Five-Year Reviews. At a
minimum, pressure measurements at the vapor mitigation systems and the vapor monitoring
wells will be collected during O&M visits using a portable pressure manometer.

The vapor mitigation systems will be maintained during inspections or during additional visits if
needed. Replacement of parts will be performed when needed based on inspection results.

At the CT DEEP's request, two rounds of sub-slab sampling, spaced 6 months apart, will be
conducted. The data will be reviewed and evaluated during the Five-Year Review to determine
the future frequency for sampling and the continued need for operating the systems.

Institutional Controls - Use restrictions will be implemented to prevent the residential use of the
first floor in existing structures without the use of a vapor mitigation system, and to limit,
govern, or prevent new construction without the installation of a soil vapor barrier and/or vapor
mitigation system. Use restrictions may be in the form of a deed restriction, easement or
covenant consistent with state law or other enforceable mechanisms, as well as signage. The
following institutional controls will be implemented:

o VIIC-1 - Residential_use of the existing first floor apartments will be prohibited
unless vapor mitigation systems are in use, or information demonstrating that
vapor intrusion no longer presents an unacceptable health risk is reviewed and
approved by the appropriate regulatory agencies; and
o VIIC-2: Any new construction will require the use of vapor mitigation systems,
unless information that demonstrates the systems are not needed is provided to the
regulatory agencies for review and approval.

Periodic Assessments - Periodic assessments will be performed to verify that there are no
prohibited uses, consistent with institutional controls. The assessments will use available
information to assess potential changes in vapor migration pathways and changes in regulations.
The frequency of periodic assessments will be determined at every Five-Year Review.

Five-Year Reviews - Reviews will be conducted every 5 years to assess groundwater conditions,
land use within Area El, the effectiveness of the vapor intrusion barrier and mitigation system,
and whether the selected remedy is protective.

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Area J

The vapor intrusion remedy for Area J includes institutional controls, periodic
assessments, and five-year reviews.

Institutional Controls - Use restrictions will be implemented to prevent new construction
without the installation of a soil vapor barrier and/or vapor mitigation system. Use restrictions
may be in the form of a deed restriction, easement or covenant consistent with state law or other
enforceable mechanisms, as well as signage. The restrictions would remind parcel owners of
potential vapor intrusion issues and the need to comply with the RSR requirements to protect
occupants of structures from VOCs that could volatilize from underlying groundwater.

o VIIC-2: Any new construction will require the use of vapor mitigation systems,
unless information that demonstrates the systems are not needed is provided to the
regulatory agencies for review and approval.

Five-Year Reviews - Same as Area El.

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 breakdown of the costs can be found in Appendix D of the FS (Nobis,
2013b).

The costs for periodic assessments, five-year reviews, and O&M (if applicable), have
been projected over 30 years, using the 7% discount rate per EPA guidance (A Guide to
Developing and Documenting Cost Estimates During the FS, July 2000). 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.

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Risk Areas

Capital Costs

Annual O&M

Contingencies

Total

Soil Remedy

D3, E2, E3, G, and H

$70,000

$124,000

$39,000

$233,000

Dl, El, and F

$175,000

$124,000

$83,000

$382,000

$867,000

$202,000

$347,000

$1,416,000

$996,000

$124,000

$398,000

$1,518,000

Vapor Intrusion Remedy

$202,000

$347,000

$67,000

$616,000

$3,500

$62,000

$1,500

$67,000

Totals

$2,313,500

$983,000

$935,500

$4,232,000

There are uncertainties associated with the soil volumes that will require remediation that
could affect the estimated costs for Areas J and I. These uncertainties will be addressed by the
PDIs that will further characterize soil CUL and PMC exceedances in these risk areas. Based on
PDI results, capital costs may change. Soil volumes and contaminant concentrations will
directly affect excavation (S06 and S08), capping (S06), and soil disposal costs (S08).

The information in this cost estimate summary table 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. Major changes may be documented in the form
of a memorandum in the Administrative Record file, an Explanation of Significant Differences,
or a ROD amendment. This is an order-of-magnitude engineering cost estimate that is expected
to be within +50 to -30 percent of the actual project cost.

4. Expected Outcomes of the Selected Remedy

The primary expected outcome of the selected remedy is that the Site will no longer
present unacceptable risks to human health from future direct exposure (ingestion, dermal
contact, inhalation of dust) to contaminated soils and will prevent potential exposure to soil
vapor contaminants resulting from localized groundwater contamination. The estimated time
necessary to implement the selected remedy is approximately 2 years. The selected remedy will
also provide environmental and ecological benefits such as protecting groundwater by removing
soil contamination that could potentially migrate to groundwater. It is anticipated that the
selected remedy will also provide socio-economic and community revitalization impacts such as
increased property values, environmental justice concerns addressed, and enhanced human uses
of ecological resources.

After determining that risks fall outside EPA's acceptable risk range and that remedial
action was therefore warranted under CERCLA and the NCP, EPA developed appropriate soil
cleanup levels (CULs) and vapor intrusion screening levels for the COCs. These levels are
discussed in the sections below.

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a. Soil Cleanup Levels

Soil cleanup levels were based on ARARs, risk-based calculations, EPA policy, and
background concentrations. The soil cleanup levels are presented in Table L-3 (Appendix C).

ARARs - The state's promulgated Direct Exposure Criteria (DEC) for residential and
commercial/industrial scenarios were also used as cleanup levels for soils. The DEC are meant
to protect the health of individuals who may come in contact with contaminated soil. In addition,
to meet the State's GB aquifer protection criteria, the State's Pollutant Mobility Criterion (PMC)
for vanadium was selected as a soil CUL.

Risk-Based Calculations - Where the State promulgated DECs are not available, risk-
based soil CULs were developed for COCs in surface and subsurface soil. These CULs for
carcinogenic COCs have been set at a 1 E-06 excess cancer risk level considering exposures via
dermal contact, incidental ingestion, and inhalation. CULs for COCs in soils having non-
carcinogenic effects were derived for the same exposure pathway(s) and correspond to a HQ = 1.

EPA Policy - The residential cleanup goal for PCBs is consistent with EPA policy A
Guide on Remedial Actions at Superfund Sites with PCB Contamination (EPA, 1990).

Background Concentrations - Cleanup goals cannot be set below background
concentrations, consistent with EPA Policy on Background Threshold Values (BTVs) (EPA,
2002). If the Site-specific concentration of a contaminant in background soil is greater than the
risk-based calculation, the background concentration is set as the CUL. BTVs were identified
using results of sampling from nearby areas that were outside of the Site boundary. BTVs were
used as CULs for select PAHs. Elevated concentrations of PAHs in soils are common in urban
areas, partially due to incidental releases from normal operation of motor vehicles and use of
pavement.

Table L-3 (Appendix C) summarizes the selected CULs for carcinogenic and non-
carcinogenic COCs that are protective of direct contact exposures with contaminated soils.

These CULs must be met at the completion of the remedial action. These soil CULs attain
EPA's risk management goal for remedial actions and have been determined by EPA to be
protective.

b. Vapor Intrusion Screening Levels

The vapor intrusion screening levels are based on ARARs and are presented in Table L-3
(Appendix C). The state's promulgated soil vapor Volatilization Criteria (VC) for residential
and commercial/industrial scenarios are meant to protect the health of individuals who may come
in contact with potential vapor intrusion from contaminated soil vapor.

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Table L-3 (Appendix C) summarizes the selected screening levels for COCs that are
protective of potential vapor intrusion. These screening levels must be met at the completion of
the remedial action. These vapor intrusion screening levels attain EPA's risk management goal
for remedial actions and have been determined by EPA to be protective.

M. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Site is consistent with CERCLA and,
to the extent practicable, the NCP. The selected remedy is protective of human health and the
environment, will comply with ARARs and is cost effective. In addition, the selected remedy
utilizes permanent solutions to the maximum extent practicable.

1. The Selected Remedy is Protective of Human Health and the Environment

The remedy at this Site will adequately protect human health and the environment by
eliminating, reducing or controlling exposures to human and environmental receptors through
soil excavation and off-site disposal or capping, vapor intrusion mitigation, and institutional
controls. More specifically, the remedy includes both soil response actions and vapor intrusion
mitigation actions, as described in the bullets below:

Soil:

•	Areas D3, E3, E2, G, and H - S02 [Institutional Controls];

•	Areas Dl, El, and F - S03 [Targeted Excavations and Off-Site Disposal and Institutional
Controls];

•	Area J - S06 [Pre-Design Investigation, Soil Cap, Operation and Maintenance, and
Institutional Controls]; and

•	Area I - S08B [Pre-Design Investigation, Excavations and Off-Site Disposal, and
Institutional Controls],

Vapor Intrusion:

•	Area El - VI3 [PDI and if necessary, Active Vapor Mitigation, Operation and
Maintenance, and Institutional Controls]; and

•	Area J - VI2 [Institutional Controls],

The selected remedy will reduce potential human health risk levels such that they do not
exceed EPA's acceptable risk range of 10"4 to 10"6 for incremental carcinogenic risk in accessible
soils (up to 4 ft bgs) and such that the non-carcinogenic hazard is below a level of concern, HI
below 1. It will reduce potential human health risk levels to protective ARARs levels, Le., the
remedy will comply with ARARs. In addition, the selected remedy will reduce the potential for
soil contaminants to migrate to groundwater, such that they do not exceed the PMC.

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Implementation of the selected remedy will not pose any unacceptable short-term risks or cause
any cross-media impacts.

At the time that the newly promulgated ARARs and modified ARARs that call into question
the protectiveness of the remedy have been achieved and have not been exceeded in shallow
soils, a risk assessment shall be performed on the residual soil contamination to determine
whether the remedy is protective. This risk assessment of the residual soil contamination shall
follow EPA procedures and will assess the cumulative carcinogenic and non-carcinogenic risks
posed by PAHs and metals across the Site and PCBs in Area J only. If, after review of the risk
assessment, the remedy is not determined to be 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

•	Toxic Substances Control Act

•	Clean Water Act (National Pollutant Discharge Elimination System and Section 404)

•	Clean Air Act

•	National Historic Preservation Act

The RCRA Land Ban requirements are not considered ARARs for this Site.

In addition, the selected remedy will comply with the following state ARARs:

•	Remediation Standard Regulations

•	Hazardous and Solid Waste Management Regulations

•	Air Pollution Control

•	Control of Noise

•	Surface Water and Wetlands, Inland Wetlands and Watercourses Act

•	Disposition of PCBs

•	Environmental Protection Act

The following policies, advisories, criteria, and guidances will also be considered during the
implementation of the remedial action:

•	Connecticut Guidance for Soil Erosion and Sediment Control

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•	EPA Reference Doses and EPA Carcinogen Assessment Group Potency Factors

•	EPA Health Advisories

•	EPA PCB Contamination Guidance

•	EPA Policy on the Role of Background in the CERCLA Cleanup Program

•	Executive Order (Invasive Species)

A discussion of how these requirements will be attained may be found in Tables J-13 through
J-18 in Appendix E.

3. The Selected Remedy is Cost-Effective

In the Lead Agency's judgment, the selected remedy is cost-effective because the remedy's
costs are proportional to its overall effectiveness (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 — long-term
effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment;
and short-term effectiveness, in combination. 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 various Risk Areas and associated components
that comprise the selected soil remedy is $3,549,000. For Areas D3, E2, G, and H (where risks
are below 1.0E-04) and Area E3 (where risk is equal to or greater than 1.0E-04, but no CUL
exceedances were observed that are considered to be accessible), institutional controls
(Alternative S02) is the only remedial option available. For Areas Dl, El, F, where discrete
CUL and PMC exceedances occur, targeted excavation and off-site disposal (Alternative S03)
will cost less than in-situ solidification/stabilization (Alternative S04). For Area J, a soil cap
(Alternative S06) will cost significantly less than excavation and off-site disposal (Alternative
S05) for the large area and volume of contaminated soil. For Area I, the cost for excavation and
off-site disposal to 4 ft bgs (Alternative S08B) are more expensive than the other S08 scenarios
(A: targeted excavations, and C: excavation to 2 ft bgs). However, this alternative is likely
realistic of site conditions to be determined during the PDI. In addition, excavation to 4 ft bgs
(S08B) will avoid long-term O&M of the pavement that will be required if the excavation was
completed to 2 ft bgs (S08C).

The estimated present worth cost of the selected vapor intrusion remedy is $683,000. For
Area J (unoccupied parcel), institutional controls (Alternative VI2) is the only remedial option
available. For Area El (occupied existing structure), PDI to evaluate exposure pathway and if
necessary install an active vapor mitigation (VI3) is the most expensive active alternative; but is
only slightly more expensive than passive mitigation (VI4) and is more protective.

Record of Decision
Scoviii Industrial Landfill
Waterbury, Connecticut

September 2013
Page 90 of 93

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Record of Decision
Part 2: The Decision Summary

The estimated present worth cost of the selected remedy (soil and vapor intrusion) for the Site is
$4,232,000.

4. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or

Resource Recovery Technologies to the Maximum Extent Practicable

Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs,
and that are protective of human health and the environment, EPA identified which alternatives
utilizes permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination was made by deciding
which one of the identified alternatives provides the best balance of trade-offs among
alternatives 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. The selected remedy provides the best balance of trade-offs among the
alternatives.

The Site consists of low-level threat wastes that can be reliably managed in the long-term
using permanent solutions consisting of the containment of contaminated soil and the use of
institutional controls to prevent potential exposures. When remedial technologies and process
options were evaluated, a number of active treatment options were considered. While active
treatment would be effective in addressing Site contaminants and reducing risks, their much
higher costs did not afford more protection than non-treatment approaches to protect human
health. Therefore, most treatment options were eliminated from consideration because their
costs were not commensurate with the degree of protection afforded.

The majority of the contaminated soil is currently covered by asphalt or concrete pavement,
by building footprints, or by vegetated cover. State ARARs indicate that if contaminated soil
were to be covered by 2 feet of clean and pavement, or 4 feet of soil, or an alternative cover, the
contaminated soil would be considered inaccessible, and protective of human health. Therefore,
the use of containment and targeted excavation (with appropriate backfilling) would render
deeper contaminated soil inaccessible, and eliminate potential exposure pathways. The use of
institutional controls (e.g., deed restrictions, local ordinances, zoning, etc.) will be effective in
the long term in ensuring the deeper soil will not be disturbed without regulatory agency
approval and oversight.

The primary contaminants of concern (PAHs and metals across the Site and PCBs in Area J)
are non-volatile, generally sorb to soil, and are relatively immobile. The use of containment and
targeted excavations is appropriate prevent or minimize the mobility of these contaminants.

Record of Decision
Scoviii Industrial Landfill
Waterbury, Connecticut

September 2013
Page 91 of 93

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Record of Decision
Part 2: The Decision Summary

5. The Selected Remedy Significantly Reduces the Mobility and Volume of the

Hazardous Substances as a Principal Element

The use of containment and targeted excavation (with appropriate backfilling) and capping of
contaminated soils at Area J will isolate contaminants, thus reducing mobility, and will reduce
the volume of contaminated media at the Site.. The selected remedy does not, however, satisfy
the preference for treatment which permanently reduces the toxicity of hazardous substances as a
principal element. However, based on the RI results, it was determined that there are no
Principal Threat Wastes on the Site. Therefore, this evaluation criterion, which is principally
applicable to sites with Principal Threat Wastes, is not a significant factor at the Site.

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 5 years
after initiation of the remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.

N. DOCUMENTATION OF NO SIGNIFICANT CHANGES

In compliance with statutory requirements for ensuring the public has the opportunity to
comment on major remedy selection decisions, a +proposed plan was prepared presenting
Alternatives S02, S03, S06, S08B, VI2, and VI3 as the preferred alternatives.

EPA presented a Proposed Plan (soil excavation and capping, vapor intrusion mitigation, and
institutional controls) for soil and vapor intrusion remediation of the Site on July 16, 2013.

More specifically:

Soil:

• Areas D3, E3, E2, G, and H - S02 Institutional Controls;

• Areas Dl, El, and F - S03 Targeted Excavations and Off-Site Disposal and Institutional
Controls;

• Area J - S06 Pre-Design Investigation, Soil Cap, Operation and Maintenance, and
Institutional Controls; and

• Area I - S08B Pre-Design Investigation, Excavations and Off-Site Disposal, and
Institutional Controls.

Vapor Intrusion:

• Area El - VI3 Active Vapor Mitigation, Operation and Maintenance, and Institutional
Controls; and

• Area J - VI2 Institutional Controls.

Record of Decision
Scoviii Industrial Landfill
Waterbury, Connecticut

September 2013
Page 92 of 93

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Record of Decision
Part 2: The Decision Summary

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 CT DEEP reviewed the various alternatives and has indicated its support for the selected
remedy. The State also reviewed the RI, Risk Assessment, and FS reports 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 the selected
remedy for the Site. A copy of the declaration of concurrence is attached as Appendix F.

Record of Decision
Scoviii Industrial Landfill
Waterbury, Connecticut

September 2013
Page 93 of 93

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Record of Decision
Part 3: The Responsiveness Summary

THE RESPONSIVENESS SUMMARY

A. PREFACE

In July 2013, the United States Environmental Protection Agency (EPA) issued a Proposed Plan
to address remediation at the Scovill Landfill Superfund Site (Site) in Waterbury, Connecticut.
The Proposed Plan was based on the Human Health Risk Assessment, Remedial Investigation,
and Feasibility Study. These reports, the Proposed Plan, and all supporting documents were
presented in the Administrative Record and made available at the public information repositories
located at the Silas Bronson Library in Waterbury, Connecticut and at EPA's office in Boston,
Massachusetts.

EPA published notices of availability of the draft Proposed Plan and Administrative Record in
the Waterbury Republican American on July 24, 2013 and released the final Proposed Plan to
the public on July 25, 2013. EPA also held a Public Meeting to answer questions on August 6,
2013 at the WARC in Waterbury. A Public Hearing was held on August 6, 2013 also at the
WARC in Waterbury. A transcript was created for the August 6, 2013 hearing and has been
made part of the Administrative Record for this Record of Decision. In addition to the oral
comments, several written comments were provided on the Proposed Plan. Outlined below is a
summary of comments received from the public and other interested parties during the public
comment period and EPA's response to those comments. Similar comments have been
summarized and grouped together. The full text of all written and oral comments received during
the comment period has been included in the Administrative Record.

B. SUMMARY OF CITIZENS' COMMENTS

Ten individuals submitted comments, either during the public hearing, in writing, or both. Where
appropriate, EPA has grouped similar comments and prepared a single response.

Comment #1:

One commenter expressed support for EPA in cleaning up Superfund sites.
EPA Response:

EPA appreciates the commenter's support for EPA.

Comment #2:

Several commenters questioned the timeline for the remediation, how long it will take and what
is the schedule going forward.

EPA Response:

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Once the Record of Decision (ROD) is signed by the EPA Director of Office of Site Remediation
and Restoration, the Remedial Design/Remedial Action phase can begin. The expected
remedy will require a pre-design investigation to refine those areas with chemicals of concern
and minimize unnecessary remediation in those areas. This will reduce costs and lessen
disruptions on those properties. The pre-design investigation is expected to begin during the
next federal fiscal year (starting October 2013) so the remedial design can start in 2014. The
start date and duration of the remedial action phase will be dependent on the results of the pre-
design investigation, access, and availability of funding.

Comment #3:

Several commenters expressed a concern because they were not advised that their rented
apartments were located on a Superfund Site. They also questioned why there is no disclaimer
about a Superfund Site in their lease. Apparently the daycare facility is required to disclose this
to their clients so why not the landlords?

EPA Response:

EPA does not regulate notification to apartment tenants. The property owners and landlords are
aware of the fact that their property on the Site is part of the Scovill Industrial Landfill Superfund
Site. . EPA did hold several public meetings during the course of the Remedial Investigation to
inform the residents of the progress of the Site investigation and cleanup. We note that the
contaminated soils that were investigated are generally isolated below pavement, below
building foundations, or below vegetated surfaces. If contaminated soil is isolated or is
considered to be "inaccessible", then residents are not likely to be exposed chemicals in the
soil, resulting in no unacceptable health risks. With respect to notifications made by Toddler
Town Day Care, this is part of the CT Department of Public Health licensing requirements for
this facility.

Comment #4:

Several tenants living in apartments on the Site questioned why they weren't informed about the
public meeting and hearing. They also questioned why homeowners outside the Site were sent
mailings.

EPA Response:

Notices about the public hearing and public meeting as well as a copy of the Proposed Plan
were mailed to property owners both on, and adjacent to, the Site based on records in the City
of Waterbury Assessor's Office. EPA sent the notices to property owners with apartment
buildings and requested that they distribute them to tenants. The homes outside of the
landfilled area are single family units or condominiums with individual owners. A public notice of
the meeting also appeared in the Waterbury Republican American on July 24, 2013 to inform
the general public about the meeting.

Comment #5:

Several commenters requested that EPA provide the resources and funding to proceed with the
remediation.

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EPA Response:

Assuming funding is available, EPA is planning to proceed with the development of the pre-
design studies at area E1, area I, and area J starting in the winter of 2013. EPA and CT DEEP
also plan to start to work with property owners as soon as possible to record institutional
controls and/or land use restrictions on the Site properties. EPA will perform the remedial
design and remedial action at the Site. Funding for the cleanup will come either from the
Superfund or any remaining potentially responsible parties Costs funded by Superfund are
allocated by EPA Headquarters to the Regions on a priority basis (i.e. from highest to lowest
priority) based on degree of contamination and human health risk. EPA has already recovered
funds from the successor to Scovill Manufacturing, Saltire Industrial, Inc.. which filed for
bankruptcy protection in 2005. EPA filed a claim in the bankruptcy court and recovered
approximately $520,000. That money has largely been spent during the Site investigation. EPA
continues to investigate whether claims to recover the cost of cleanup can be brought against
any other potentially responsible parties, but has not yet made any determinations whether to
pursue further cost recovery from other parties.

Comment #6:

Several commenters questioned why landowners on the Site should be considered to help pay
for any remediation costs because they were not the ones who created the contamination.
Similarly, multiple commenters questioned why EPA was not pursuing other companies that
used to be owned by the Scovill Manufacturing Company or the Department of Defense (DOD)
that engaged Scovill to make war time material.

EPA Response:

jn 1985, Scovill, Inc. underwent a corporate reorganization in which it transferred the assets and
liabilities of its six divisions to six new and separate corporations, and transferred all other
remaining assets and liabilities to a new corporation, Scovill, Inc. (incorporated in Delaware),
which was renamed Saltire Industrial, Inc. in 1994. Under an EPA administrative order, Saltire
completed a portion of the remedial investigation for the Site, until it filed for bankruptcy in
2005. EPA settled with Scovill during its bankruptcy for $5.3 million, but because its claim was
only a general unsecured claim, EPA only received a distribution of about $520,000, which has
largely been spent. EPA continues to investigate its potential claims for the costs of cleanup
against other parties, including the corporations formed out of Scovill's divisions in 1985. EPA
is also still investigating potential claims against the Department of Defense.

Because CERCI-A imposes liability on certain categories of persons, regardless of their fault or
negligence, current landowners of record are strictly liable for cleanup by statute. Depending
upon the circumstances of the landowner's purchase, however, s/he may qualify for an
exemption to liability as a bona fide prospective purchaser or innocent landowner. Also, under
EPA policy, the Agency does not ordinarily pursue costs from current landowners of residential
homes between one and four units. EPA also takes a landowner's ability to pay into
consideration when evaluating cost recovery options.

Comment #7:

One resident asked if there will be another public meeting after the Record of Decision is
finalized and will there be any additional notification or a web site to check for results.

EPA Response:

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There is no public meeting planned for when the Record of Decision is finalized. But EPA will
be placing the Record of Decision on the Site's website which is:
www.epa.qov/reqion1/superfund/sites/scovill.

Comment #8:

Some commenters and residents asked what are the remediation plans. How can they find out
about the plans?

EPA Response:

EPA evaluated several alternatives during the Feasibility Study and described the preferred
remedial alternatives in the Proposed Plan. These alternatives include a combination of
excavation with off-site disposal, vapor extraction, institutional controls, and/or land use
restrictions. A detailed description of the selected remedy can be found in the Record of
Decision as well as on the Site web page: www.epa.qov/reqion1/superfund/sites/scovill.

Comment #9:

One resident asked when will EPA have a solution to the problems at the Scovill Site.
EPA Response:

As detailed above, EPA has developed a remedial approach described in the Proposed Plan
that is included in the Record of Decision. Following the signing of the Record of Decision, EPA
will begin the pre-design studies to finalize remediation plans.

Comment #10:

Several commenters and residents were worried about cancer risks based on what they read in
the newspaper and asked why, if there is no current risk to residents, why is EPA proceeding
with a remedial action.

EPA Response:

EPA conservatively evaluated the current and future potential risks for the reasonable maximum
exposure (RME) which is the highest exposure expected to occur at the site. Although EPA
believes that people are not currently contacting chemicals at this time, EPA believes that site
conditions could change in the future and thus wants to take necessary steps to ensure that
exposure does not occur in the future.

Comment #11:

One commenter suggested that because housing and a daycare center have existed on Site
without any apparent ill health effects, that the Site be "grandfathered" and exempt from any
further remediation and environmental restrictions.

EPA Response:

EPA evaluated the potential for adverse health effects under current land use as well as future
potential land use. Using EPA's risk assessment process, EPA identified potential health risks
associated with exposure to site contaminants. Although EPA believes that people are not

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currently contacting chemicals at this time, EPA believes that necessary steps must be taken to
ensure that exposure does not occur in the future should site conditions change.

Comment #12:

One commenter objected that the residents and neighbors of the Site are not being given a
permanent solution if waste is left in place and will be subject to land use restrictions as well as
any future changes in state or federal hazardous waste regulations. In particular, there was a
concern for the four single family homes on Monroe Street where only a small back edge of the
property was included on the Site. The commenter suggested that any contaminated soil on
these four properties be replaced with clean soil.

EPA Response:

EPA carefully evaluated the various remedial alternatives using nine criteria including overall
protection of human health and the environment, compliance with regulations and statutes, cost,
implementability, and long term effectiveness and permanence. The preferred alternative in the
Proposed Plan provides the best balance of the nine criteria. Because some waste will be left in
place, the properties will be subject to land use restrictions, primarily in the form of
Environmental Land Use Restrictions (ELURs) required under Connecticut law. The land use
restrictions will provide that certain activities will be prohibited without CT DEEP approval.

With respect to the four single family homes on Monroe Street, part of the pre-design
investigation is to determine if there are soils exceeding remediation goals for the portions of the
properties on the Scovill Site and, if so, their possible vertical extent. If contaminated soils do
not exist below a four foot depth, then institutional controls would likely not be necessary at
those properties.

Comment #13:

One commenter viewed any remediation in areas other than the Calabrese parcel as
economically unrealistic because the subsoil contamination is "miniscule" compared to the other
urban contamination within the City.

EPA Response:

As discussed above, cost is only one consideration in evaluating remedial alternatives. EPA
must also protect human health and the environment as well as comply with state and federal
regulations and statutes.

Comment #14:

One homeowner asked if her house was going to be included in the remediation based on a
rotten egg smell coming from the back of the property and the trees falling down behind her
house.

EPA Response:

This particular property is outside of the Scovill Site boundary where no Scovill ash was
deposited on the property. The rotten egg smell is naturally occurring and is coming from
decaying vegetation in the seasonally wet area behind her property and to the west of the
Calabrese parcel. The trees on the slope behind the house are falling down because ongoing
erosion is weakening the root structure. Those trees at the bottom of the slope are discolored
because the roots are constantly saturated by the seasonally standing water.

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Comment #15:

One commenter questioned whether the soil following remediation will be safe for planting a
garden or growing fruits and vegetables.

EPA Response:

The Human Health Risk Assessment (HHRA) did not specifically evaluate vegetable gardening
or light agriculture scenarios. However, those areas where the upper two to four feet of soil are
replaced as part of the remediation probably would not present a risk for gardening. However, it
is still a good idea to use raised beds for any gardening of fruits or vegetables that will be
consumed. This is consistent with the CT Department of Public Health statewide guidance. For
more information about safe gardening, refer to the CT DPH factsheet. .
http://www.ct.gov/dph/lib/dph/environmental_health/eoha/pdf/vegetable_uptake_fact_sheet.pdf
The land use restrictions for the industrial/commercial properties are presumed to limit
excavation activities, including gardening.

Comment #16:

Several commenters understood that paved areas did not present exposure to contaminated
materials beneath them but expressed concern on whether unpaved properties provided risk
concerns. A common concern expressed was the unpaved area of the Calabrese Parcel.

EPA Response:

All of the soil samples in "unpaved" areas are collected from below the turf or the root zone.
The soil from below the vegetated surface was collected and analyzed. So, although the
Calabrese parcel is unpaved, the soils with chemicals that may be of concern are actually
covered by vegetation. If vegetation is present, then the contaminated soil cannot easily
become airborne.

CT DEEP's previous removal action excavated and took off site 2,300 tons of PCB-
contaminated soil from the central portion of the Calabrese parcel. CT DEEP then placed 1 foot
of clean soil over the excavation area. Thus, contaminated soil identified by the EPA
investigations is either below the turf or below at least 1 foot of clean soil.

Comment #17:

Several tenants of 119 Store Avenue understood that vapor mitigation will only impact residents
of the ground floor, but expressed concerns about walking through the lobby and common room
located on the ground floor and the building's circulation system.

EPA Response:

Historically, a few volatile organic compounds have been sporadically detected in groundwater
near 119 Store Ave. Although EPA determined that while risks are limited, pending results of
the PDI, a vapor mitigation system is planned to be installed in the four residential units located
on the ground floor at 119 Store Avenue as a preventative measure.

The pre-design investigation (prior to vapor mitigation system construction) will include an
evaluation to better assess if there is an exposure pathway into the building. If it is determined
that an exposure pathway exists, the PDI will further evaluate the existing structure and

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potential vapor intrusion pathways as well as an indoor air investigation. This information will be
used to further characterize potential vapor intrusion issues at the ground floor and throughout
the building. The risk from vapor intrusion is based on the assumption that a person is exposed
to it over long periods of time (i.e. all day every day in their homes) and so the risk to people just
passing through an area would be much lower.

Comment #18:

Several commenters have expressed concern regarding air quality during the various
remediation efforts.

EPA Response:

Various instruments will be used to monitor the ambient air quality during intrusive phases of
remediation (i.e., excavation). If air monitoring levels exceed established health and safety
limits which are set lower than levels that would pose a risk, work will be stopped and various
measures will be implemented to further control air emissions. Measures will be taken to control
dust during construction as well.

Comment #19:

One commenter expressed a concern regarding clean surface soil becoming contaminated over
time due to natural shifting of soil moving up through vegetation and tree roots.

EPA Response:

During the soil remediation, clean fill will be used to backfill excavation areas. EPA does not
anticipate the clean fill material to become contaminated with Site chemicals of concern with
time. Similar remediation approaches have been taken at other Superfund sites throughout the
country with notable success.

Comment #20:

Several commenters have expressed concern regarding chemicals of concern degassing from
soil and moving with liquids such as groundwater.

EPA Response:

The chemicals of concern found at the Site consist of Polynuclear Aromatic Hydrocarbons
(PAHs), metals, and PCBs (found only at Area J). PAHs and PCBs by nature tend to adhere to
the soil and not migrate into groundwater. Metals however can migrate into the groundwater.
However, at select locations (referred to as pollutant mobility criteria exceedances), metal
concentrations in soil are elevated and will be removed (at depths greater than 4 feet below the
ground surface) to be protective of Site groundwater.

Comment #21:

Several commenters have expressed concern regarding soil contamination beyond Site
borders.

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EPA Response:

The extent of Scovill fill has been well defined in historical aerial photo documentation as well as
through soil testing, and field observation. The historical photos document the extent of filling
operations at the Site by the Scovill Manufacturing Company from as early as 1934 through the
late 1970s when Scovill Manufacturing Company sold off the last Site parcels. The Remedial
Investigation report has figures that depict the limits of historical filling by Scovill at the Site.

Comment #22:

Several commenters have expressed concern regarding the odor of rotten eggs emanating from
their backyard and the volume of mosquitoes.

EPA Response:

The odor of rotten eggs and a significant presence of mosquitoes are likely associated with
standing water containing decaying vegetation. These issues are unrelated to the Site's
chemicals of concern and potential exposure risks to Site soil. However, prior to remedial
construction activities, stormwater drainage will be evaluated and designed to avoid pooling and
standing water.

Comment #23:

One resident expressed concern regarding beryllium dumping at the Site.

EPA Response:

EPA has not found information regarding beryllium disposal at the Site. However, beryllium is a
naturally occurring element and is typically present in oil and coal. Therefore, the ash resulting
from the combustion of oil and coal will likely contain beryllium. Because ash from the Scovill
Manufacturing Company was disposed of at the Site, it is reasonable to have beryllium present
in the subsurface soil that had been mixed with ash. 274 soils samples were collected at the
Site and beryllium was detected at relatively low levels in approximately 80% of the samples,
which suggests that ash is the likely source of beryllium. The Connecticut residential soil
standard for beryllium is 2 mg/Kg. The average surface and subsurface beryllium
concentrations at the Site are 0.93 and 1.22 mg/Kg, respectively. Only one out of the 274
samples (at 2.5 mg/Kg) slightly exceeded the residential soil standard. As a result, beryllium is
not considered a chemical of concern for the risk assessment at the Site.

Comment #24:

One resident expressed concern regarding radon contamination at the Site.

EPA Response:

Radon occurs naturally throughout New England and is generally associated with certain types
of bedrock found close to or at the Earth's surface. Bedrock at the Site is approximately 50 feet
below the ground surface. As a result, radon is not considered a Site chemical of concern and
testing by EPA is not planned. However, the tenant or landlord can test for radon. Radon kits
are relatively inexpensive and are readily available at most hardware stores. If testing shows
elevated levels present inside the building, it would be prudent for the landlord to take
appropriate measures such as sealing cracks in the foundation or installing a radon system to
prevent radon from migrating into the building.

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Comment #25:

Several residents have expressed concern regarding the quality of drinking water at the Site.
Another concern was testing of the drinking water.

EPA Response:

The groundwater in this area of CT, including the Site, is classified by the State as "GB", which
means it is unsuitable for drinking water purposes. All buildings at the Site are serviced by the
public water supply and there are no private wells in this area. Drinking water is provided by the
City of Waterbury's Water Department. The sources of drinking water for Waterbury are the
Shepaug and Cairns Reservoirs, not groundwater. Water from the reservoirs is treated at the
Harry P. Danaher Water Treatment Plan located in Thomaston, CT before being distributed into
the water supply system. The water supply is routinely tested and the results are presented at
the City's website (http://www.waterburvct.org/content/9569/9605/9642/10305/default.aspx).

EPA has performed several rounds of groundwater sampling to characterize the nature of
chemicals in groundwater, but does not intend to test drinking water which is unrelated to the
Site.

Comment #26:

One commenter expressed concern regarding potential groundwater contamination beyond the
Scovill Site boundary.

EPA Response:

The principal chemicals of concern at Scovill are PAHs, metals, and some PCBs (found in
northern Area J only) in soil. Testing during the Remedial Investigation showed that these
chemicals do not easily migrate from the soil into groundwater. Groundwater in the southern
part of the Site does not exceed regulatory thresholds. Additionally, the groundwater in this part
of Waterbury is classified by CT DEEP as "GB", which means it is unsuitable for drinking water
purposes. All residents are serviced by municipal water connections from surface water supply
sources. Additional analyses during the Remedial Investigation also showed that groundwater
from the Scovill Site does not exceed any regulatory criteria when it reaches surface water
bodies.

Comment #27:

Several commenters expressed concern over the development of the Calabrese parcel
following remediation. They wanted to know what the future development plans were and to
make sure that the City of Waterbury was involved with any development plans. One
commenter suggested that the degree of remediation should depend on the intended use and if
the land is left undeveloped, it should revert back to being a wetland.

EPA Response:

Because the land is currently zoned commercial, any remediation will need to meet the state's
industrial/commercial remedial criteria under the Remediation Standard Regulations. EPA and
CT DEEP have been in communication with the Mayor's office regarding applicable regulatory
criteria for future development, but EPA is not responsible for developing this land. Any
development or future land use decisions belong to the property owner of record in concert with
any lien holders.

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Comment #28:

Several commenters were concerned with how dust would be controlled during remediation
activities and if businesses will be forced to close.

EPA Response:

EPA will work closely with the community and local businesses prior to beginning remedial
activities to minimize any disruptions. Dust control and suppression is an integral part of any
excavation plan. Engineering control measures such as covering excavated soil, wetting down
soil piles and excavations, etc., will be in place during remedial activities.

C. COMMENTS FROM THE HOUSE OF REPRESENTATIVES

These comments were submitted by House Republican Whip, Selim G. Noujaim.

Comment #29

What alarms me and the residents are that no new information nor solutions were presented at
this meeting versus the previous public hearing which was conducted by yourself and
moderated by me at the same location many years ago.

EPA Response:

The public meeting that was held on August 6, 2013 was for EPA to address the proposed
remedy as articulated in the Proposed Plan for the Site, and to answer questions. That same
night following the public meeting, EPA held a formal public hearing to allow people the
opportunity to provide EPA oral comments on the Proposed Plan. The previous EPA meeting
was held on February 2011. At this meeting EPA informed the community and other interested
parties that the remedial investigation was completed and explained what was found during the
investigation. EPA also went over what were the next steps and schedule leading to a Record
of Decision scheduled to be finalized by September 2013. Between the time period of the
February 2011 meeting and the August 2013 meeting, EPA has finalized the Remedial
Investigation report, Report, Feasibility Study report, and the Proposed Plan.

Comment #30

I must stress that the residents are very anxious, upset, and worried about their health as well
as the health of their children and grandchildren. I am, therefore, requesting an immediate and
speedy solution by EPA to this issue. We must allocate the necessary resources by the
appropriate agencies to decontaminate the properties and to make the residents whole. I look
forward to your prompt response.

EPA Response:

The Site in its current state does not pose a health risk to the on-site residents or workers
because there is no current route of exposure to the contaminants of concern. The reason for
implementing the proposed remedy is to prevent future potential risk should Site conditions
change. Please see response to comment #17 which addresses the concern relating to vapor
intrusion. Costs funded by Superfund are allocated by EPA Headquarters to the Regions on a
priority basis (i.e. from highest to lowest priority) based on degree of contamination and human
health risk. Once funding is available for this site, EPA will immediately start the preliminary
remedial investigation at Areas E1, I and J as well as work with CT DEEP and on-site property
owners to implement land use restrictions. After the preliminary remedial investigation is
completed, the remedial design and remedial construction would begin. EPA plans to inform

Page 10 of 11

09/05/13

-------
and work closely with City officials and on-site and nearby community regarding all future field
work and respective schedules.

These comments were submitted by District Aid to Congresswoman Elizabeth Esty.
Comment #31

This is Ryan Baldassario from Congresswoman Esty's office in Connecticut. I wanted to say
thank you for the presentation last night, and I wanted to commend you and your staff for
dealing very professionally. I have a few minor questions for you. (1) Along the line of
questioning from constituents, is there a source of funding for the remediation plans at this
stage? Are there opportunities for EPA grants or is this money coming mostly from CT
sources?

EPA Response:

See EPA Response to comment #30. In addition, the cost for implementing the remedy would
come from EPA's Superfund account which is distributed to sites on a priority basis. CT would
pick up the costs for the long term operation & maintenance following the implementation of the
remedy. EPA has not yet made a determination as to whether or not it will seek some cost
recovery from property owners.

Page 11 of 11

09/05/13

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AH Loiiecfion 6.3034
ROD Admin. Record

AM Collection Index Report
* "For External Use***

Phase 01: SITE ASSESSMENT

II !¦! ^\IM, illii !!!< S!; KS \ W ' M i'l	It! J'UKS 11)11 !i!t f \i VKBI if |-\lt' < !>!¦ iff!' -.i mil i I Mil M HI \i i *M» -i.! M !¦! KJ 1 Ml M! t

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-------
AR ( ollciiiim 63034
ROD Admin. .Record
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Hi Ml !» \5 IM ! •>! VI !•=¦» «: ¦¦¦'• i-f ::¦!( i K	i ! V! I I I I f K II I M II! I)-

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0/26/201J

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9/26/2013
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B

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190|NewburyiSf; %

|ltl86 newbu^

225 Academy^ve:

fel 5Academy Ave.

,Newbury>

|-180iNewbup/j

i-209 Academy Ave. |\\'p

-Z. ilUi72'Newburyj
m '.I i *» ' ftdd

,72|pallas Avi

'203 Academy Ave.

1168 Newbury

L71 Newbury

197 Academy Ave.

250 M°£rO'e-

MW2S

[l63 Newbury

187 Academy Ave.

| 24^tsA°nr°e
V \

K&vre st.

232 Monroe Ave.

175 Academy Ave.

i16 7. Acad emyAve.

1431Newbury/St.

iSSm

161 Academy Ave.

•'212 Monroe"

15 5 Ac a d e m y Ave.

,148 Academy Ave

149 Academy Ave.

204 Monroe^



141 Academy Ave'J p

WETLAND 1

135 Academy Ave?!1.

MonroeWy

129 Academy Ave.

rtfAoWf£TAv t

*AMonr^

166 Monroe

OALTON

IWETLAND 2

™ 58 Monroe

MW3D
[MW3B1

150 Monroe

•142JMonroe5Ave: •-

nMntttfJirra

134 Monroe Ave.

HlNDSDALE

67 Academy Ave.

ajwartB

126 Monroe Ave:

. 55 Ac a d e'my Avej

Monro^

110 Monroe

;3.1 ^A'cade m y, Ave:

41 Dunbar St.

100 Monroe Ave.

25 Academy Ave'

88 Monroe Ave.

'goCrfw'

\19 Academy Ave'

\ X

MW9S

1MW9DJ

MW8S

17 Dunbar St.

MW8D



[5jDunbarLSj

M • AV

[NEWM^

|MW7Si
IMW7D

'OON'ACD

iMeriden Rd.

263 Meriden Rd.

27'" Newman'Ave.

28l*Me]

MW6

:mw6d

UFRlPfcJil

Notes

1. Storm Drain locations provided by City of Waterbury, CT.

Drawn By: JH

Checked By: LC

September 2013

Revision No. 03

APPROXIMATE SCALE
75	150

300
Feet

Estimated Limit of Scovill nn Calabrese Property
Derived/Placed Fill

Approximate Seasonal
Wetland Area

i	 Risk Area Boundaries

"	Modern Roads

Assessor's Parcel
Boundaries

x-

Monitoring Wells
¦ X Fenceline

Storm Drain

Underground Route of
Carrington Brook/
Storm Drain

Modern Ground
Surface Contour

FIGURE 1

Site Plan
Scovill Industrial Landfill
Waterbury, CT

lzmsTEk

Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
-------
.FUXDCklFFE-WB



meridem

Zoning / Use Designation

Current Use

-Current Zoning

Zoning / Use Definition

C = Commercial

C* = Future Commercial Exposed

to Surface Soil
Ca= Commercial Arterial
Cn= Commercial Neighborhood

Shopping
D = Daycare

R = Unrestricted Residential
Re= Elderly Residential
T = Trespasser
V = Vacant

Present Scenario Risk
(Surface)

Future Scenario Risk
(Aggregata)

l_.

Estimated Limit of
Scovill Derived/
Placed Fill

Risk Area Limits

Modern Roads



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

FIGURE D1

ZONING DESIGNATION AND
ESTIMATED RISK BY RISK AREA
SCOVILL INDUSTRIAL LANDFILL SITE
WATERBURY, CONNECTICUT

PREPARED BY: JH

PROJECT NO. 80018

CHECKED BY: BA

DATE: JULY 2013



DONALD

terrace

TT
J

ON A AVE- 1

J

s
o
z
71

hiNDSPALEAVE-

Notes:

1. Parcel boundaries provided by the City of
Waterbury, Connecticut.

2. Location of all features is approximate. Map is for
reference purposes only. Nobis Engineering, Inc.
makes no claims, warranties, representations,
expressed or implied, relating to the completeness,
accuracy, or reliability of the data shown.

0 50 100 200

-------
AUTVRE

rAMONAAVE.

rADCLIFFE AVI

dalton

HINDSDW-E

SB45 4.5 ft
TCE 21000

s0UTHW

SB145 9 ft

BZ2100

NEWMANWENUE_

DONALD TERRACE

SB18 13 ft

TCE 1800
PCE 12000

SB121 13 ft

CF 400 J
CT 4000

mErIDEN

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E1

Volatile Organic Compounds
In Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

Abbreviations:

BR - Bromodichloromethane
BZ - Benzene
CF - Chloroform
CT - Carbon Tetrachloride
PCE - Tetrachloroethene
TCE - Trichloroethene
VC - Vinyl Chloride

Shape Indicator

/\ PMC Action Level
( | DEC Action Level

~ lor Indicator

O £ 1 x Action Level
O > 1 - 5 x Action Level
O > 5 -10 x Action Level
O > 10 - 50 x Action Level
Q > 50 x Action Level

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All
results are reported in MQ'Kg.

2.	"J" indicates that the result was estimated.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled
by TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

Notes:

-------
SS-25 0.5 ft

BaA 1200
BbF 2000 J
BkF 1400 J
2 ft

BaA 1200
BbF 1200

2,4-Dinitrotoluene

2,6-Dinitrotoluene

2-Methy I naphthalene

Bis(2-Chloroethyl) Ether

Bis(2-Ethyl hexyl) Phthalate

Benzo(A)Anthracene

Benzo(A)Pyrene

Benzo(B)Fluoranthene

Benzo(K)Fluoranthene

Carbazole

Chrysene

Dibenz(A,H)Anthracene

Dibenzofuran

Fluoranthene

lndeno(l,2,3-cd)Pyrene

N-Nitro-Di-N-Propylamine

Phenanthrene

Pyrene	

SS27 0.5 ft
BaA 1700
BaP 1500
BbF 1600
BkF 1200 J
IndP 1200
2 ft

BaA 6200
BaP 3900
BbF 3700
BkF 3000 J
DahA 1200
IndP 2600

SS150 1 ft

BaA 2400 J
BbF 2000 J
BkF 1900 J
IndP 1500 J

SB15 5 ft

BaA 2600
BaP 2500
BbF 2500
BkF 2100
IndP 2400

IndP

NDPA

Pha

SB171 12 ft

BaA 7400 D
BaP 8400 D
BbF 11000 D
BkF 5700 D
IndP 1500

SS-37 2 ft

BaA 3400
BaP 2600
BbF 2800
BkF 1900
IndP 1700

MW3D 8ft
BaP 1200
BbF 2300

SB14

SB13 15 ft
BaA 7900
BaP 6600
BbF 6000
BkF 6200
DahA1100 J
IndP 5700

SB151 17 ft

BaA 3300
BaP 3200
BbF 3300
BkF 2700

SB155 7 ft

BaA 2900
BaP 3300 D
BbF 4000 D
BkF 2200

SS-40 0.5 ft

BaA 1800
BaP 1500
BbF 2700
BkF 1300
IndP 1600

SB156 16 ft

2-MN 6800 J
BaA 55000
BaP 47000
BbF 43000
BgP32000
BkF 38000
Carb 23000
Chry 53000
DahA 12000
Dbf 16000
Flt180000 D
IndP 37000
Pha 180000 D
Pyr 100000

SB153 7 ft

BaA 7200 D
BaP 7300 D
BbF 11000 DJ
BkF 6300 D
IndP 2100 J

SB150 7 ft

BaA 6200 DJ

SB47 6 ft

BaA 1200
BaP 1300
BbF 2600 J
18 ft

BaA 13000
BaP 10000
BbF 17000 J
Chr 14000
DahA 2000 J
IndP 3800 J

SB27 10 ft

2-MN 6200 J
BaA 58000 J
BaP 53000 J
BbF 43000 J
BgP 35000 J
BkF 51000 J
Carb 17000 J
Chr 69000 J
DahA 13000 J
Dbf 15000 J
Fit 160000
IndP 41000 J
Pha160000
Pyr 170000
15 ft

BaA 2400
BbF 2500
BkF 2000
IndP 1600 J

SB190 9 ft

BaA11000 D
BaP 9400 D
BbF 9000 D
BkF 10000 D
Chr 12000 D
DahA 2900
IndP 7700 D

SB152 7 ft

BaA 3600 D
BaP 3100 D
BbF 3200 D
BkF 2400

SB154 7 ft

2,4-Dnt 530
2,6-Dnt 1200
BbF 1300 J
B2E 1800
NDPA 1000

SS10 0.25 ft
BaA 1200
BaP 1500
BbF 1700
BkF 1400

SB202 9 ft

BaA 7700
BaP 6300
BbF 6100
BkF 7200
DahA 1200 J
IndP 4600

SS15 0.25 ft
BaA 3200
BaP 4300
BbF 5000
BkF 4900
DahA 1200 J
IndP 3800

SB193 9 ft

BaA 2000
BaP 2300
BbF 2800
BkF 2400
IndP 1800

MW4D2 ft
BaA 4400
BaP 4300
BbF 7300
8.5 ft

BbF 1300 J
15 ft

BaA 8000
BaP 9200 J
BbF 13000 J
DahA 2100 J
IndP 5000 J

SB149 17 ft

BaA 1300
BaP 1500
BbF 2200
BkF 2300

SB04 5 ft
B2EP 16000 J

S191 9 ft

BaA 2900
Bbf 2000
BaP 1900
BkF 1900

SS142 17 ft

BaA 6700 D
BaP 5600 D
BbF 6600 D
BkF 6300 D

SB194 9 ft

BkF 1300

SB46 7.5 ft

BaA 2000 J
BaP 1900 J
BbF 2400 J
BkF 1700 J

SS38 0.5 ft
BaP 1200 J
BbF 3000
¦ w —:

SB38 4 ft
BaA 4400
BaP 4700
BbF 7600
DahA 1600
IndP 3200

SS09 0.25 ft
BaA 1800
BaP 2100
BbF 2700
BkF 1900

SB14 2 ft

BaA 4000
BaP 3300
BbF 3800
BkF 2300

SS-07 0.5 ft

BaA 1100
BbF 1400 J
BkF 1900 J
2 ft

BaA 2000
BaP 1200
BbF 2000 J
BkF 2500 J

SB139 16 ft
BaA 1900
BaP 1500
BbF 2700
BkF 2000

SB200 9 ft

BaA 2800
BaP 3100
BbF 3100
BkF 3500

SB45 4 ft

BaA 8800
BaP 9400
BbF 11000
BkF 11000
Chr 12000
DahA 1400 J
5.5 ft

BaA 11000
BaP 11000
BbF 12000
BkF 9100
Chr 12000
DahA 2700 J
IndP 5700

SS128 7 ft

BaA 3200 D
BaP 3400 D
BbF 4700 D
BkF 3000 D

SS118 2 ft

BaA 3800 D
BaP 3800 D
BbF 5600 D
BkF 3600 D

SS114 2 ft

BaA 2500
BaP 3400 D
BbF 3200 D
BkF 2500

SB144 12 ft

BaA 14000 D
BaP 18000 J
BbF 19000 D
BkF 15000 D
Chr 15000 D
IndP 3200

SS-05 2 ft

BaA 3100
BaP 2200
BbF 3400 J
BkF 4400 J

SS-14 2 ft

_ BaA 4000 \
' BaP 3300

BbF 3800 =
' BkF 2300
- \ \
SB143 12 ft
BaA 4300 D
BaP 4700 D
BbF 7100 D
BkF 4500 D

SB18 20 ft

BaA 17000 D
BaP 14000
BbF 11000

Shape Indicator

Color Indicator

Notes

PMC Action Level

£ 1 x Action Level

1. Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All results are

reported in mq'KQ-

2.	"J" indicates that the result was estimated. "D" indicates that the result was obtained from a dilution of the sample.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled by TetraTech) 2004,
and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

BkF 11000
Chr 16000 D
DahA 2100 J
IndP 6900
Pyr 41000 D

DEC Action Level

>	1 - 5 x Action Level

>	5 -10 x Action Level

>	10 - 50 x Action Level

>	50 x Action Level

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E2

SVOCs In Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
ALTYRE

SB23 5 ft
Dieldrin 9.8 DJ

SB22 5 ft

Dieldrin 9.6 DPJ

rAMONA

SB187 10 ft

Dieldrin 38 P

SB171 12 ft

Dieldrin 9.4

SS-34 0.5 ft

Alpha-Chlordane 160 JEB
Gamma-Chlordane 96
Heptachlor Epoxide 46
2 ft

Alpha-Chlordane 160 JEB
Gamma-Chlordane 110 J

SB08 5 ft

Dieldrin 37 DJ

RADCLIFFEAV6.

SS-37 0.5 ft

Alpha-Chlordane 99 JEB

dalton

SB07 5 ft

Dieldrin 18 J

SS-31 0.25 ft .>0
Alpha-Chlordi§ne 69 DP

SBIffi 5 ft

Dieldfin 130 DP
^ Hepjjftchlor Epoxide 37 DP

SS27 0.25 ft
Heptachlor Epoxide 25

Dieldrin 14 P
Dieldrin 22 P

hindsdale_

SS-36 0.%
Dieldrin 8.9%B

SS-18 0.5 ft

Dieldrin 21 EB

SB156 16 ft

Aldrin 24 J

Alpha-Chlordane 150 DP
Dieldrin 14 J

SB13 15 ft
Dieldrin 8.2 DPJ

SOUTHW'ICK

NEV^Mi WENUE.

DONALD TERRACE

SS14 0.25 ft
4,4'-DDT 1300 D
Dieldrin 44 DPJ

MER1D£N

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E3

Pesticides In Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

Shape Indicator

/\ PMC Action Level
( | DEC Action Level

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All
results are reported in MQ'Kg.

2.	"J" indicates that the result was estimated. "D" indicates that the result was obtained from a dilution of
the sample. "EB" indicates thatanalyte was detected in the Equipment Blank. "P" indicates a percentage of
dilution between columns.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled by
TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

Color

o
o
o
o

Indicator

£ 1 x Action Level

>	1 - 5 x Action Level

>	5 -10 x Action Level

>	10 - 50 x Action Level

>	50 x Action Level

Notes:

-------
CAP 16 7 ft

A-1260 1500 DJ
A-1254 300 J
PC B 1846

CAP 16 12 ft

A-1242 1900 D
A-1254 350
A-1260 250 J
PCB2500

CAP 18 12 ft

A-1260 2100 D
PCB2100

CAP 13 3 ft

A-1254 770 DJ
A-1260 1800 DJ
PCB 2570

CAP09 12 ft

A-1254 1700 D
A-1260 220 DJ
PCB 3900

CAP08 16 ft

A-1254 5700 DJ
A-1260 3700 DJ
PCB 9400

CAP04 12 ft

A-1254 2000 D
A-1260 2500 DJ
PCB 4500

SS-23 2 ft

A-1254 19000 J
PCB 19000

SB14 5 ft

A-1254 3200 DP
PCB 3200

Notes

Shape Indicator

Color Indicator

Abbreviations

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All
results are reported in MQ'Kg.

2.	PAH Toxic equivalent was calulated using ESTIMATED ORDERS OF POTENTIAL POTENCY
FOR CARCINOGENIC PAHs from EPA, 1993; EPA Region I, 1994a.

3.	"J" indicates that the result was estimated. "D" indicates that the result was obtained from a dilution
of the sample. "P" indicates a percentage of dilution between columns.

4.	Substances with no detections above screening criteria are not reported.

5.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

6.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled
by TetraTech) 2004, and Nobis 2008.

7.	Parcel boundaries provided by City of Waterbury, CT.

DEC Action Level

£ 1 x Action Level

A-#### = Aroclor

PCB = Polychlorinated Biphenyls

> 1 - 5 x Action Level

> 5 -10 x Action Level

> 10 - 50 x Action Level

> 50 x Action Level

N

Drawn By: JH | Checked By: BA



FIGURE E4

liW/Td

	 Modern Roads

Assessor's Parcel Boundaries







Buildings

PCBs In Soil Samples
Scovill Industrial Landfill

Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street

/I

Date: May 2013 | Revision No. 00









I

APPROXIMATE SCALE

j j Risk Area Limits



Waterbury, Connecticut

Lowell, MA 01851
T(978) 683-0891

II

0 75 150 300







www.nobiseng.com

14









Client-Focused, Employee-Owned

-------
SB40

2 ft-As 20.7

Shape Indicator

Color Indicator

DEC Action Level

£ 1 x Action Level

> 1 - 5 x Action Level

> 5 -10 x Action Level

> 10 - 50 x Action Level

> 50 x Action Level

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E5

Arsenic in Surface
Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All
results are reported in mg/Kg.

2.	"J" indicates that the result was estimated.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled
by TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

Notes:

-------
SB161

SB149

SB147

SB02

10	ft As - 13.1

, I E 5

SB141

11	ft As-22.6

SB11

10ft As - 10.7

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E6

Arsenic in Subsurface

Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

Shape Indicator

( ) DEC Action Level

Notes:

Color Indicator

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action levels. All
results are reported in mg/Kg.

2.	"J" indicates that the result was estimated. "D" indicates that the result was obtained from a
dilution of the sample. "EB" indicates that the analyte was detected in the Equipment Blank.
indicates duplicate analysis not within control limits

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA (compiled
by TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

o
o
o
o

£ 1 x Action Level

>	1 - 5 x Action Level

>	5 -10 x Action Level

>	10 - 50 x Action Level

>	50 x Action Level

-------
SS-25

0.5 ft - Chromium 12900 J
0.5 ft - Copper 28800 J
0.5 ft - Nickel 1780 J
2 ft - Chromium 19200 J
2 ft - Copper 35300 J
2 ft-Nickel 2460 J

2 ft - Copper 6810 J

SB188

10 ft - Copper 9820

111 ¦—i	L_

MW3D

8 ft - Copper 3980

9 ft - Copper 42300

12 ft - Cadmium 42.5 J
12 ft - Copper 9510

SB12

20 ft - Cadmium 35.4
20 ft-Copper4260*

SB196

9 ft - Cadmium 40.4
9 ft - Copper 7990

SB11

10 ft-Copper 14500

SS14	I

0.25 ft-Copper 13700*|

Shape Indicator

Color Indicator

DEC Action Level

N

Drawn By: JH | Checked By: BA



FIGURE E7





Assessor's Parcel Boundaries





Beryllium, Cadmium, Chromium,

1





J Buildings

Engineering a Sustainabfe Future
Nobis Engineering, Inc.
585 Middlesex Street

/I

Date: May 2013 | Revision No. 00



Copper and Nickel in Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut

$





I

APPROXIMATE SCALE
0 75 150 300

|	 j Risk Area Limits



Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

5 ft -

Copper 3960'

Notes:

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action
levels. All results are reported in mg/Kg.

2.	"J" indicates that the result was estimated. "D" indicates that the result was obtained from a
dilution of the sample. "*" indicates duplicate analysis not within control limits.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA
(compiled by TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

SB150

7 ft - Copper 2530 J
	1	

£ 1 x Action Level

>	1 - 5 x Action Level

>	5 -10 x Action Level

>	10 - 50 x Action Level

>	50 x Action Level

-------
Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

Assessor's Parcel Boundaries
Buildings

|	 j Risk Area Limits

FIGURE E8

Lead in Soil Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

Notes:

1.	Tags indicate Well ID, sample depth below ground surface, and results exceeding action
levels. All results are reported in mg/Kg.

2.	"J" indicates that the result was estimated. "N" indicates spiked sample recovery not within
control limits. indicates duplicate analysis not within control limits.

3.	Substances with no detections above screening criteria are not reported.

4.	Comparison action levels are derived from State of Connecticut Regulation 22a-133k-1.

5.	Data collected by Weston START 1999, Foster Wheeler under task by M&E 2002, CRA
(compiled by TetraTech) 2004, and Nobis 2008.

6.	Parcel boundaries provided by City of Waterbury, CT.

SB119

Shape Indicator

( | DEC Action Level

Color Indicator

O £ 1 x Action Level
O > 1 - 5 x Action Level
O > 5 -10 x Action Level
O > 10 - 50 x Action Level
Q > 50 x Action Level

7 ft - 1680 J

-------
-------
MW-3

DALTONAVE.

Dec-OS Mar-09 Jun-09 Sep-09 Dec-OC Mar-10 Jun-10 Sep-10

_L1

MW-9S

LLi	L

hindsdaleave.

MW3
MW3D

IW.3B	i'r

MW11S

Dec-08 Mar-09 Jun-09 Sep-09 Dec-09 Mar-10 Jun-10 Sep-10

\ K z

MW-9D

S0UTHWcK.



f/k\
/ / \









<2f/ / \\

\^A \\

\ / w ^

*v\ / /

wr

Dec-08 Mar-09 Jun-09 Sep-09 Dec-09 Mar-10 Jun-10 Sep-10

'd'ONACD terrace

__L.

	—NEWMANWE.^	

MW7S

MW-6

Dec-08 Mar-09 Jun-09 Sep-09 Dec-09 Mar-10 Jun-10 Sep-10

Dec-OS Mar-09 Jun-09 Sey-09 Dec-09 Mar-10 Jun-10

Vv V V V w /m / vvv

MW-12D

MW4

Dec-08 Mar-09 Jun-09 Sep-09 Dec-09 Mar-10

Notes:

1.	Only locations with detects are displayed with results.

2.	Comparison action levels are derived from Volatization Criteria for
Groundwater State of Connecticut Regulation 22a-133k-1.

3.	Data collected by Nobis 2008-2010.

4.	Results are reported in ^g/L.

5.	Parcel boundaries provided by City of Waterbury, CT.

SI

MW-5

Dec-08 Mar-09 Jun-09 Sep-09 Dec-09 Mar-10 Jun-10 Sep-10

^7

1,1-Dichloroethene
Trichloroethene
Vinyl Chloride

Action Levels (|ig/L)

DCE

TCE

VC

Residential
Volatization Criteria

1

219

2

Commercial
Volatization Criteria

6

540

2

N

Drawn By: JH

Checked By: BA

Date: May 2013

Revision No. 00

APPROXIMATE SCALE
75	150

300
Feet

Modern Roads

Estimated Limit of Scovill
Derived/Placed Fill

i	

j Risk Area Limits

Assessor's Parcel Boundaries
Buildings

Monitoring Well Locations

FIGURE E10

DCE, TCE, and Vinyl Chloride
Detections in Groundwater Samples
Scovill Industrial Landfill
Waterbury, Connecticut



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
-------
-------
-------
Notes:

1.	Sample locations by Nobis 2008.

2.	SPLP analysis for Vanadium.

3.	Land Use:

C/l = Commercial/Industrial
DAY= Daycare
RES = Residential

4.	All units are micrograms per liter

^Drawm^By^JH^J^^Checked^By^LC^

June 2013

I

Revision No. 01

Legend

I	J Area Limits

APPROXIMATE SCALE
50 100	200

) Feet

O

Sample Location with
no PMC Exceedances

Sample Location with
PMC Exceedances

FIGURE E14

Summary of PMC
Exceedances in Soil
Scovill Industrial Landfill
Waterbury, CT



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
-------
-------
rAMONA

NEWMAJ^ AVENUJ.

DONACDterrace

meriden

FIGURE J2

Layout of Soil
Alternatives S03 and S04
Scovill Industrial Landfill
Waterbury, CT

ixrsisrm

Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

AUTYRE ST.

DALTONAVE.













alMHSD/5

.LEAVE.



r	

i

i

i r

\ 1

i 1

	RADCLIFFE ave.--



i 1

i

i 1

> 1

1 ¦ \

i

i > I

I 1

i ¦

1 i

1 i

©

		—

i

1 i

1 i

• 		V

" i

i



PMC Exceedances

PRG Exceedances

Drawn By: JH

Checked By: LC

July 2013

Revision No. 01

APPROXIMATE SCALE
75	150

~1 Feet

J Lim it of Scovill Derived/Placed Fill Yss/ssh Areas Affected by Alternatives S03 and S05
j Risk Area Boundaries

Assessor's Parcel Boundaries

-------
L

1"

T2"

PAVED AREAS

UNPAVED AREAS

^^TOP^CQAT^^

;b'nderX//^

BANK RUN=
SAND AND

OWARNLNG LAYER

h	1 I I	1 I I	:	1 I I	1 I I

BANK RUN
SAND AND
GRAVEL

42"

48"

NOT TO SCALE

A J obi

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax(978)683-0966
	www.nobiseng.com	

FIGURE J3

ALTERNATIVES S03, S05, AND S07
PRG EXCEEDANCES BACKFILL SECTIONS
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY, CONNECTICUT

DRAWN BY: JH

PROJECT:

80018

APPROVED BY: LC

JULY 2013

-------
PAVED AREAS

120

^^TOP/COAT^^

J	I

BANK RUN
SAND AND
GRAVEL

UNPAVED AREAS

-i 11—i i i—111—i i i-

BANK RUNk-
SAND AND

114"

120"

J	L

NOT TO SCALE

A J obi

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax(978)683-0966
	www.nobiseng.com	

FIGURE J4

ALTERNATIVES S03, S05, AND S07
PMC EXCEEDANCES BACKFILL SECTIONS
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY, CONNECTICUT

DRAWN BY: JH

PROJECT:

80018

APPROVED BY: LC

JULY 2013

-------
Drawn By: JH I Checked By: LC

June 2013

Revision No. 01

APPROXIMATE SCALE
0 50 100	200

] Feet

Estimated Limit of Scovill
Derived/Placed Fill

!	J Area Limits

Y7A Pre-Design Investigation Area

Estimated Extent of PRG
| Exccedances based on Rl data.
1	J (S06-Soil Cap Area)

Roads

Assessor's Parcel Boundaries

FIGURE J5

Layout of Soil Alternative

S05 and S06
Scovill Industrial Landfill
Waterbury, CT



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
SOIL CAP

SURFACE VEGETATION

NOT TO SCALE

A J obi

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax(978)683-0966
	www.nobiseng.com	

FIGURE J6

ALTERNATIVE S06 SOIL CAP
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY, CONNECTICUT

DRAWN BY: JH

PROJECT:

80018

APPROVED BY: LC

JUNE 2013

-------
-------
BANK RUN;
SAND AND

gravel

/BINDER

////

BANK RUN
SAND AND:
GRAVEL

WARNING LAYER

CONTAMINATED
SOIL

y/A/A/A/

/BINDER

////

BANK RUN
SAND AND
GRAVEL

WARNING LAYER

CONTAMINATED A
SOIL

X<\X<^X<\X

A J obi

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax(978)683-0966
	www.nobiseng.com	

FIGURE J8

ALTERNATIVE S08 PRG AND
PMC EXCEEDANCES BACKFILL SECTIONS
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY, CONNECTICUT

DRAWN BY: JH

PROJECT:

80018

APPROVED BY: LC

JULY 2013

I	S08 A+B PRG

: 2" Y///kmjrR/. •

S08C PRG

^^TOPCOAT^X^

S08 PMC

-*-\\\^top coAf^:

NOT TO SCALE

-------
Parcels Subject to
Institutional Controls

Address

Map-Lot

134 Monroe Ave.

299-121

126 Monroe Ave.

299-122

119 Store Ave.

300-1



300-2

Drawn By: JH

Checked By: LC

July 2013

Revision No. 02

APPROXIMATE SCALE
75	150

) Feet

J Limit of Scovill Derived/Placed Fill ~ Assessor's Parcel Boundaries
j Risk Area Boundaries	I I Area Affected by Alternative VI2

FIGURE J9

Layout of Vapor Intrusion

Alternative VI2
Scovill Industrial Landfill
Waterbury, CT



Engineering a Sustainable Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T(978) 683-0891
www.nobiseng.com
Client-Focused, Employee-Owned

-------
-------
MAINTENANCE
AREA

A3

*

A2

& HALLWAY &

MECHANICAL/STORAGE

V

GARAGE AREA-

A1



o

CD
CD
-<

MECHANICAL/
STORAGE

NOT TO SCALE

legend

	 VAPOR TRENCH

# VAPOR DISCHARGE STACKS
-0- VAPOR MONITORING WELL
INTERIOR WALLS
EXTERIOR WALL

Nobis

Future
Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax (978) 683-0966
	www.nobiseng.com	

FIGURE Jll

119 STORE AVENUE
GROUND FLOOR LAYOUT
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE

	WATERBURY, CONNECTICUT

DRAWN BY: JH	APPROVED BY: [c

PROJECT: 80018	JULY 2013

-------
Condensate
Drain Tube

NEW

CONCRETE PATCH

CARPET OR
ORIGINAL FLOORING

XxXXXxXXX^XxXXXxX^XxX^XxX^XxXXXxXX^

s.'.y'*S.y*S.y*S.y*S.y*/r.y*S.y*S.y'S.y'/.y'S.y'S.y'S.y'S.y'S.y*S.y*S.y*S.y*S.y*S.y*S.y*S.y*s^



^1-

m

*S.y*S.ytf.y*'.y*S.y*S.y*S.y*.'.y**.y*S.y*.'.y*S.y*.*y*S.y*.'.y*S.
f.ysS.yi/.y *S.y*S.y *S.y*S.y*/.y*S.y*S.y *S.y *S.y*S.y *S.y*S.'.

¦	Vf.\s:.•••>•;;.•>:••>	•¦';¦.-¦ v/-i

¦	¦¦ .. .*. ¦¦ •»• v- .¦••¦•. j •.¦•¦ -. -t.

a

28"

'•/ <• •/<• •/ '.• •
'• •/'•v'•



- 2" CONCRETE
VAPOR BARRIER

¦ CONCRETE
FOUNDATION

6" BENTONITE CHIPS

2/12 SAND

4" DIA. 0.020" SLOTTED
SCH 40 SCREEN







	4" SCH 40 PVC







LOCATED AT ROOF

ROOF



































J

~

rr

rv

FOUNDATION

	



VAPOR

EXTRACTION TRENCH

	J



NOTE: FIELD LOCATE TO MINIMIZE
DISRUPTION TO FACILITY

FAN & CONDENSATE
BYPASS

(SEE DETAIL 1)

4" BALL VALVE

PIPE SUPPORT (TYP.)

¦GROUND SURFACE

90' ELBOW

(1) Fan and Condensate Bypass
(Not to Scale)

(2) Extraction Trench Details
(Not to Scale)

(3) Vapor Discharge Stack
(Not to Scale)

•19a

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, MA 01851
T (978) 683-0891
www. nobiseng .com

Client-Focused, Employee-Owned

FIGURE J12

ACTIVE VAPOR MITIGATION

SYSTEM DETAILS (VI3)
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY. CONNECTICUT

DRAWN BY:

JH

PROJECT:

80018.10

APPROVED BY:

LC

JULY 2013

-------
BAROMETRIC CHECK VALVE

4 SCH 40 PVC
LOCATED AT ROOF

• NEW

CONCRETE PATCH

¦ CARPET OR
ORIGINAL FLOORING



tit™

*Sly*.' .•*S.y*S.,W*S.y*S.y*S.y*.\y*S.y*S.y*S.y*S.y*S.y*S.y*S.y*S.y*S.y*.

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CONCRETE
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D

6 BENTONITE CHIPS

•2/12 SAND

• 4 DIA. 0.020 SLOTTED
SCH 40 SCREEN

•••

.. *	•* •*.



(1) Collection Trench Details
(Not to Scale)

VAPOR -
COLLECTION TRENCH

4-5* ELBOWS

NOTE: FIELD LOCATE TO MINIMIZE
DISRUPTION TO FACILITY

90" ELBOW

(2) Vapor Discharge Stack
(Not to Scale)

'	1

FIGURE J13

WNobisM

PASSIVE VAPOR MITIGATION

SYSTEM DETAILS (VI4)
SCOVILL INDUSTRIAL LANDFILL
SUPERFUND SITE
WATERBURY. CONNECTICUT

Engineering a Sustainable Future

Nobis Engineering, Inc.
585 Middlesex Street
Lowell, Massachusetts 01851
Tel (978) 683-0891
Fax (978)683-0966
www.nobiseng.com

DRAWN BY: JH

APPROVED BY: LC

PROJECT: 80018.10

JULY 2013

-------
A
P
P
E
N
D
I

X
C

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

5.4E-06



















Benzo(a)pyrene

6.2E-05











Age-Adjusted Resident

Surface Soil

See child

1.2E-04

Benzo(b)fluoranthene

8.3E-06

NE









Dibenz(a,h)anthracene

2.2E-05







Risk Area D1 -









lndeno(1,2,3-cd)pyrene

6.1E-06









Current/Future









Arsenic

1.1E-05











Adult Resident

Surface Soil

See child

NE

—



0.13

No

—





Child Resident

Surface Soil

Not a COPC

NE

—



1.1

No

—





Construction Worker

Aggregate Soil

NE

5.7E-06

Vanadium

5.1E-06

1.5

No

—













Benzo(a)anthracene

3.8E-06



















Benzo(a)pyrene

5.9E-05











Age-Adjusted Resident

Aggregate Soil

See child

1.0E-04

Benzo(b)fluoranthene

7.7E-06

NE









Dibenz(a,h)anthracene

1.2E-05







Risk Area D1 - Future









lndeno(1,2,3-cd)pyrene

4.8E-06

















Arsenic

9.7E-06



















Vanadium

1.2E-06











Adult Resident

Aggregate Soil

See child

NE

—



0.25

No

—





Child Resident

Aggregate Soil

Not a COPC

NE

—



1.8

No

—













Benzo(a)anthracene

1.8E-06











Industrial/ Commercial
Worker







Benzo(a)pyrene

1.8E-05









Risk Area D3 -

Surface Soil

0%

3.2E-05

Benzo(b)fluoranthene

2.7E-06

0.12

No

—



Current/Future







Dibenz(a,h)anthracene

1.5E-06



















Arsenic

7.4E-06











Construction Worker

Aggregate Soil

NE

2.4E-06





0.90

No

—













Benzo(a)anthracene

1.4E-06



















Benzo(a)pyrene

1.6E-05









Risk Area D3 - Future

Industrial/ Commercial

Aggregate Soil

0%

3.1E-05

Benzo(b)fluoranthene

2.3E-06

0.092

No





Worker

Dibenz(a,h)anthracene

5.5E-06















lndeno(1,2,3-cd)pyrene

1.1E-06



















Arsenic

4.7E-06









MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient

Risk Area D3 - Future

Age-Adjusted Resident

Surface Soil

See child

3.8E-04

Benzo(a)anthracene

2.6E-05

NE

-

-













Benzo(a)pyrene

2.6E-04



















Benzo(b)fluoranthene

3.8E-05



















Benzo(k)fluoranthene

2.4E-06



















Dibenz(a,h)anthracene

2.1E-05



















lndeno(1,2,3-cd)pyrene

5.8E-06



















Arsenic

3.0E-05



















Chromium VI

1.6E-06











Adult Resident

Surface Soil

See child

NE

—

—

0.17

No

—





Child Resident

Surface Soil

0.23%

NE

—

—

1.5

No

-



Risk Area D3 - Future

Age-Adjusted Resident

Aggregate Soil

See child

4.0E-04

Benzo(a)anthracene

2.1E-05

NE

—

—













Benzo(a)pyrene

2.3E-04



















Benzo(b)fluoranthene

3.4E-05



















Benzo(k)fluoranthene

1.5E-06



















Dibenz(a,h)anthracene

7.8E-05



















lndeno(1,2,3-cd)pyrene

1.6E-05



















Arsenic

1.9E-05











Adult Resident

Aggregate Soil

See child

NE

—

—

0.13

No

—





Child Resident

Aggregate Soil

0.051%

NE

—

—

1.1

No

—





Adult Resident (Elderly

Surface Soil

See child

1.4E-05

Benzo(a)pyrene

7.8E-06

0.12

No







Only)

Arsenic

2.8E-06















Benzo(a)anthracene

4.7E-06



















Benzo(a)pyrene

3.9E-05









Risk Area E1 -
Current/Future

Child Recreational

Surface Soil

Not a COPC

5.6E-05

Benzo(b)fluoranthene

2.7E-06

0.43

No





Visitor

Dibenz(a,h)anthracene

4.5E-06













lndeno(1,2,3-cd)pyrene

2.2E-06



















Arsenic

2.8E-06











Groundskeeper

Surface Soil

Not a COPC

1.1E-05

Benzo(a)pyrene

6.4E-06

0.071

No







Arsenic

2.0E-06







Construction Worker

Aggregate Soil

NE

6.1E-06

Vanadium

4.2E-06

1.3

No

—



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 3 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

1.2E-05



















Benzo(a)pyrene

1.0E-04











Age-Adjusted Resident

Surface Soil

See child

1.5E-04

Benzo(b)fluoranthene

7.0E-06

NE









(Families)

Dibenz(a,h)anthracene

1.2E-05

















lndeno(1,2,3-cd)pyrene

5.8E-06



















Arsenic

9.0E-06











Child Resident

Surface Soil

Not a COPC

NE

—



0.96

No

-













2,3,7,8-TCDD TEQ

2.5E-06



















Bis(2-chloroethyl)ether

1.8E-06









Risk Area E1 - Future









Hexachlorobenzene

1.2E-06

















N-Nitrosodi-n-propylamine

5.4E-06











Age-Adjusted Resident
(Families)







Benzo(a)anthracene

3.7E-05











Aggregate Soil

See child

4.6E-04

Benzo(a)pyrene

3.3E-04

NE

—

—











Benzo(b)fluoranthene

4.8E-05



















Benzo(k)fluoranthene

1.9E-06



















Dibenz(a,h)anthracene

1.4E-05



















lndeno(1,2,3-cd)pyrene

7.2E-06



















Arsenic

8.6E-06











Adult Resident

Aggregate Soil

See child

NE

—



0.23

No

—





Child Resident

Aggregate Soil

Not a COPC

NE

—



1.8

No

-













Benzo(a)anthracene

2.8E-06



















Benzo(a)pyrene

2.4E-05











Daycare Child

Surface Soil

Not a COPC

4.1E-05

Benzo(b)fluoranthene

4.3E-06

0.63

No





Risk Area E2 -
Current/Future

Dibenz(a,h)anthracene

5.1E-06













lndeno(1,2,3-cd)pyrene

2.3E-06

















Arsenic

3.0E-06











Industrial/ Commercial

Surface Soil

Not a COPC

8.1E-06

Benzo(a)pyrene

3.9E-06

0.071

No







Worker

Arsenic

1.8E-06







Construction Worker

Aggregate Soil

NE

1.5E-06





0.84

No

-



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 4 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient



Industrial/ Commercial
Worker







Benzo(a)pyrene

9.0E-06









Risk Area E2 - Future

Aggregate Soil

0%

1.5E-05

Benzo(b)fluoranthene

1.2E-06

0.093

No

—











Arsenic

2.7E-06









Risk Area E2 - Future

Age-Adjusted Resident

Surface Soil

See child

9.8E-05

Benzo(a)anthracene

6.6E-06

NE

—

—













Benzo(a)pyrene

5.6E-05



















Benzo(b)fluoranthene

1.0E-05



















Dibenz(a,h)anthracene

1.2E-05



















lndeno(1,2,3-cd)pyrene

5.4E-06



















Arsenic

7.3E-06











Adult Resident

Surface Soil

See child

NE

—

—

0.11

No

-





Child Resident

Surface Soil

Not a COPC

NE

—

—

0.89

No

-



Risk Area E2 - Future

Age-Adjusted Resident

Aggregate Soil

See child

1.9E-04

2,3,7,8-TCDD TEQ

1.3E-06

NE

—

—













Benzo(a)anthracene

1.2E-05



















Benzo(a)pyrene

1.3E-04



















Benzo(b)fluoranthene

1.7E-05



















Dibenz(a,h)anthracene

1.1E-05



















lndeno(1,2,3-cd)pyrene

6.4E-06



















Arsenic

1.1E-05











Adult Resident

Aggregate Soil

See child

NE

—

—

0.13

No

—





Child Resident

Aggregate Soil

0.092%

NE

—

—

1.1

No

—



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 5 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

1.2E-05



















Benzo(a)pyrene

9.5E-05



















Benzo(b)fluoranthene

1.1E-05











Age-Adjusted Resident

Surface Soil

See child

1.6E-04

Dibenz(a,h)anthracene

1.7E-05

NE

—

—













lndeno(1,2,3-cd)pyrene

6.6E-06



















Arsenic

1.1E-05









Risk Area E3 -









Chromium VI

1.1E-06









Current/Future

Adult Resident

Surface Soil

See child

NE

—



0.15

No

—





Child Resident

Surface Soil

Not a COPC

NE

—



1.3

No

-













Benzo(a)pyrene

6.0E-06











Groundskeeper

Surface Soil

Not a COPC

1.2E-05

Dibenz(a,h)anthracene

1.1E-06

0.092

No

—













Arsenic

2.5E-06











Construction Worker

Aggregate Soil

NE

1.4E-06





1.1

No

—













Benzo(a)anthracene

9.5E-06



















Benzo(a)pyrene

7.4E-05



















Benzo(b)fluoranthene

8.7E-06











Age-Adjusted Resident

Aggregate Soil

See child

1.3E-04

Dibenz(a,h)anthracene

1.3E-05

NE

—

—



Risk Area E3 - Future









lndeno(1,2,3-cd)pyrene

5.0E-06



















Arsenic

1.3E-05



















Chromium VI

2.6E-06











Adult Resident

Aggregate Soil

See child

NE

—



0.16

No

—





Child Resident

Aggregate Soil

0.14%

NE

—



1.3

No

-



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 6 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

1.3E-05



















Benzo(a)pyrene

7.1E-05



















Benzo(b)fluoranthene

1.4E-05











Age-Adjusted Resident

Surface Soil

See child

1.5E-04

Benzo(k)fluoranthene

1.4E-06

NE

—

—



Risk Area F -









Dibenz(a,h)anthracene

2.4E-05









Current/Future









lndeno(1,2,3-cd)pyrene

5.2E-06



















Arsenic

2.0E-05











Adult Resident

Surface Soil

See child

NE

—



0.19

No

—





Child Resident

Surface Soil

0.18%

NE

—



1.6

No

—





Construction Worker

Aggregate Soil

NE

2.2E-06

Vanadium

1.4E-06

1.3

No

—













Benzo(a)anthracene

1.1E-05



















Benzo(a)pyrene

9.1E-05



















Benzo(b)fluoranthene

1.2E-05











Age-Adjusted Resident

Aggregate Soil

See child

1.7E-04

Benzo(k)fluoranthene

1.2E-06

NE







Risk Area F - Future

Dibenz(a,h)anthracene

2.2E-05















lndeno(1,2,3-cd)pyrene

4.9E-06



















Arsenic

1.9E-05



















Chromium VI

5.5E-06











Adult Resident

Aggregate Soil

See child

NE

—



0.23

No

—





Child Resident

Aggregate Soil

0.21%

NE

—



1.9

No

—





Industrial/ Commercial
Worker







Benzo(a)pyrene

4.4E-06









Risk Area G -

Surface Soil

0.40%

2.0E-05

Dibenz(a,h)anthracene

1.2E-06

0.40

No

—



Current/Future







Arsenic

1.3E-05











Construction Worker

Aggregate Soil

NE

1.9E-06





2.1

No

—



Risk Area G - Future

Industrial/ Commercial

Aggregate Soil

0.20%

1.4E-05

Benzo(a)pyrene

3.3E-06

0.36

No





Worker

Arsenic

8.2E-06





MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 7 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient

Risk Area G - Future

Age-Adjusted Resident

Surface Soil

See child

1.5E-04

Benzo(a)anthracene

5.5E-06

NE

-

-













Benzo(a)pyrene

6.2E-05



















Benzo(b)fluoranthene

6.3E-06



















Dibenz(a,h)anthracene

1.7E-05



















lndeno(1,2,3-cd)pyrene

3.9E-06



















Arsenic

5.3E-05



















Chromium VI

3.5E-06











Adult Resident

Surface Soil

See child

NE

—

—

0.56

No

-





Child Resident

Surface Soil

48%

NE

—

—

5.0

Blood

Antimony

1.3

















Zinc

0.58

Risk Area G - Future

Age-Adjusted Resident

Aggregate Soil

See child

1.1E-04

Benzo(a)anthracene

4.4E-06

NE

—

—













Benzo(a)pyrene

4.7E-05



















Benzo(b)fluoranthene

6.6E-06



















Dibenz(a,h)anthracene

1.3E-05



















lndeno(1,2,3-cd)pyrene

2.6E-06



















Arsenic

3.4E-05



















Chromium VI

2.1E-06











Adult Resident

Aggregate Soil

See child

NE

—

—

0.51

No

—





Child Resident

Aggregate Soil

39%

NE

—

—

4.6

Blood

Antimony

1.3

















Zinc

0.61











Benzo(a)anthracene

1.3E-06



















Benzo(a)pyrene

1.4E-05









Risk Area H -
Current/Future

Industrial/ Commercial

Surface Soil

Not a COPC

2.5E-05

Benzo(b)fluoranthene

1.6E-06

0.081

No





Worker

Dibenz(a,h)anthracene

4.6E-06













lndeno(1,2,3-cd)pyrene

1.1E-06



















Arsenic

2.4E-06











Construction Worker

Aggregate Soil

NE

3.7E-06

Benzo(a)pyrene

1.3E-06

1.5

No

—



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 8 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

2.5E-06



















Benzo(a)pyrene

2.6E-05









Risk Area H - Future

Industrial/ Commercial

Aggregate Soil

0%

4.8E-05

Benzo(b)fluoranthene

2.9E-06

0.17

No





Worker

Dibenz(a,h)anthracene

6.9E-06















lndeno(1,2,3-cd)pyrene

1.3E-06



















Arsenic

8.8E-06









Risk Area H - Future

Age-Adjusted Resident

Surface Soil

See child

3.4E-04

Benzo(a)anthracene

1.9E-05

NE

—

—













Benzo(a)pyrene

2.0E-04



















Benzo(b)fluoranthene

2.3E-05



















Benzo(k)fluoranthene

2.4E-06



















Dibenz(a,h)anthracene

6.6E-05



















lndeno(1,2,3-cd)pyrene

1.6E-05



















Arsenic

9.8E-06











Adult Resident

Surface Soil

See child

NE

—

—

0.12

No

—





Child Resident

Surface Soil

Not a COPC

NE





1.0

No





Risk Area H - Future

Age-Adjusted Resident

Aggregate Soil

See child

6.0E-04

Benzo(a)anthracene

3.5E-05

NE

—

—













Benzo(a)pyrene

3.7E-04



















Benzo(b)fluoranthene

4.2E-05



















Benzo(k)fluoranthene

4.4E-06



















Dibenz(a,h)anthracene

9.9E-05



















lndeno(1,2,3-cd)pyrene

1.8E-05



















Arsenic

3.6E-05











Adult Resident

Aggregate Soil

See child

NE

—

—

0.25

No

—





Child Resident

Aggregate Soil

8.98%

NE

—

—

2.1

No

—



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 9 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient











Benzo(a)anthracene

2.1E-06











Industrial/ Commercial
Worker







Benzo(a)pyrene

2.0E-05











Surface Soil

Not a COPC

3.3E-05

Benzo(b)fluoranthene

3.5E-06

0.12

No

—



Risk Area I -
Current/Future







Dibenz(a,h)anthracene

2.7E-06

















Arsenic

3.4E-06

















Benzo(a)anthracene

1.3E-06











Construction Worker

Aggregate Soil

NE

1.9E-05

Benzo(a)pyrene

1.1E-05

1.1

No







Dibenz(a,h)anthracene

2.7E-06















Vanadium

1.5E-06



















Benzo(a)anthracene

2.5E-05



















Benzo(a)pyrene

2.1E-04









Risk Area I - Future

Industrial/ Commercial

Aggregate Soil

0%

3.3E-04

Benzo(b)fluoranthene

8.8E-06

0.16

No





Worker

Dibenz(a,h)anthracene

5.3E-05















lndeno(1,2,3-cd)pyrene

1.8E-05



















Arsenic

6.2E-06









Risk Area I - Future

Age-Adjusted Resident

Surface Soil

See child

4.3E-04

Benzo(a)anthracene

3.0E-05

NE

—

—













Benzo(a)pyrene

2.9E-04



















Benzo(b)fluoranthene

4.9E-05



















Benzo(k)fluoranthene

1.6E-06



















Dibenz(a,h)anthracene

3.8E-05



















lndeno(1,2,3-cd)pyrene

7.5E-06



















Arsenic

1.4E-05











Adult Resident

Surface Soil

See child

NE

—

—

0.13

No

—





Child Resident

Surface Soil

Not a COPC

NE

—

—

1.1

No

—



MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 10 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient

Risk Area I - Future

Age-Adjusted Resident

Aggregate Soil

See child

4.6E-03

Benzo(a)anthracene

3.6E-04

NE

-

-













Benzo(a)pyrene

3.1E-03



















Benzo(b)fluoranthene

1.3E-04



















Benzo(k)fluoranthene

8.3E-06



















Chrysene

4.0E-06



















Dibenz(a,h)anthracene

7.6E-04



















lndeno(1,2,3-cd)pyrene

2.6E-04



















Arsenic

2.6E-05











Adult Resident

Aggregate Soil

See child

NE

—

—

0.24

No

—





Child Resident

Aggregate Soil

0.25%

NE

—

—

2.0

No

—













Benzo(a)pyrene

5.6E-06













Surface Soil

NE

4.0E-05

Dibenz(a,h)anthracene

1.8E-06

3.4

None

Total Chromium as 100%

2.5

Risk Area J -
Current/Future



Aroclor 1254

3.9E-06

Observed

Chromium VI

T respasser







Chromium VI

2.5E-05











Sediment

NE

9.6E-06

Benzo(a)pyrene

5.9E-06

0.052

No











Dibenz(a,h)anthracene

1.1E-06









Surface Water

NE

6.8E-06

Benzo(a)pyrene

5.2E-06

0.021

No

—













Benzo(a)anthracene

1.5E-05



















Benzo(a)pyrene

1.1E-04



















Benzo(b)fluoranthene

1.2E-05



















Dibenz(a,h)anthracene

3.4E-05









Risk Area J - Future

Age-Adjusted Resident

Surface Soil

See child

9.8E-04

lndeno(1,2,3-cd)pyrene

7.5E-06

NE

—

—



Aroclor 1254

5.2E-05



















Aroclor 1260

2.7E-06



















Arsenic

1.2E-05



















Chromium VI

7.3E-04



















Vanadium

1.1E-06









MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 11 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient

















Eyes and
Immune

Aroclor 1254

1.2



Adult Resident

Surface Soil

See child

NE

—



8.1

System





















None
Observed

Total Chromium as 100%
Chromium VI

6.5



Child Resident

Surface Soil

0.35%

NE





73

Eyes and
Immune
System

Aroclor 1254

10







None
Observed

Total Chromium as 100%
Chromium VI

60

















Body Weight

Nickel

1.2











Benzo(a)anthracene

1.1E-06



Eyes and
Immune
System

Aroclor 1254

1.1

Risk Area J - Future

Industrial/ Commercial

Surface Soil

0%

7.0E-05

Benzo(a)pyrene

7.4E-06

5.9









Worker

Dibenz(a,h)anthracene

2.4E-06

None
Observed

Total Chromium as 100%
Chromium VI













Aroclor 1254

1.5E-05



4.6











Arsenic

3.0E-06















Chromium VI

3.9E-05



















2,3,7,8-TCDD TEQ

7.2E-06



















Benzo(a)anthracene

1.0E-05



















Benzo(a)pyrene

8.3E-05



















Benzo(b)fluoranthene

9.7E-06











Age-Adjusted Resident

Aggregate Soil

See child

3.6E-04

Dibenz(a,h)anthracene

1.9E-05

NE









lndeno(1,2,3-cd)pyrene

6.8E-06

















Aroclor 1254

1.0E-05



















Aroclor 1260

1.2E-06



















Arsenic

1.2E-05



















Chromium VI

2.0E-04









MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 12 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient



Adult Resident

Aggregate Soil

See child

NE

—



2.3

None
Observed

Total Chromium as 100%
Chromium VI

1.8

















Eyes and
Immune

Aroclor 1254

2.0



Child Resident

Aggregate Soil

0.12%

NE





21

System











None

Total Chromium as 100%

16

















Observed

Chromium VI











2,3,7,8-TCDD TEQ

1.8E-06



















Benzo(a)pyrene

5.8E-06











Industrial/ Commercial

Aggregate Soil

0%

2.8E-05

Dibenz(a,h)anthracene

1.3E-06

1.7

None

Total Chromium as 100%

1.3

Risk Area J - Future

Worker

Aroclor 1254

3.1E-06

Observed

Chromium VI









Arsenic

2.9E-06



















Chromium VI

1.1E-05



















2,3,7,8-TCDD TEQ

1.6E-06



















Benzo(a)pyrene

5.2E-06











Groundskeeper

Aggregate Soil

0%

2.5E-05

Dibenz(a,h)anthracene

1.2E-06

1.5

None

Total Chromium as 100%

1.1



Aroclor 1254

2.8E-06

Observed

Chromium VI











Arsenic

2.7E-06



















Chromium VI

9.5E-06



















Chromium VI

6.7E-06



Lungs/

Total Chromium as 100%
Chromium VI





Construction Worker

Aggregate Soil

NE

1.1E-05

Vanadium

2.9E-06

7.5

Respiratory
System

5.4

MA-3767-2013

Nobis Engineering, Inc.

-------
Table E-1
Summary of Risks by Risk Areas1
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 13 of 13







Lead Model

RME

Property

Scenario/ Receptor

Media

Results 1 %
with blood
lead level
greater
than 10

Total
Cancer
Risks2

Major contributors to total
cancer risk
(individual cancer risk >1E-06)

Individual COC
cancer risks

Total Non-
cancer Hazard
Index3

Organ-specific
Hazard Index
above 1.0

Major contributors to

non-cancer organ-
specific Hazard Index
above 1.0

Individual
COC hazard
quotient

Notes:

1)	Lead evaluation is performed only where lead is a COPC and only for child residents (IEUBK Model) and industrial/commercial workers or groundskeepers (Adult Lead Model)

Based on 2011 Chromium speciation data, total chromium consists of 1.54% hexavalent chromium. Calculated cancer risks from total chromium, which were based on hexavalent

2)	chromium toxicity values, have been multiplied by 1.54% to estimate cancer risks from hexavalent chromium. Total cancer risks have been reduced to reflect the revised total cancer risks
with the decreased contribution from total chromium.

3)

Calculated hazard indices from total chromium were based on hexavalent chromium non-cancer toxicity values. However, based on 2011 Chromium speciation data, total chromium
consists of only 1.54% hexavalent chromium. Therefore HQs from chromium are overestimated.

NE	Not Evaluated

RME	Reasonable Maximum Exposure

2,3,7,8-TCDD TEQ Dioxins and Furans 2,3,7,8-TCDD Toxic Equivalents

COC	Contaminant of Concern - Major contributors to total cancer risk with individual cancer risk >1E-06.

	CR	Cancer risk

	Cancer Risks are above 1E-04.	Exposure Scenario

Non-cancer Hazard Indices are above 1.

MA-3767-2013

Nobis Engineering, Inc.

-------
Table K-1

Comparative Analysis of Soil Alternatives Summary
Scovill Industrial Landfill Site
Waterbury, Connecticut

Soil Alternatives



















S01 - No Action







NA



•

low

TBD

TBD

S02 - Limited Action, Institutional Controls, Periodic Assessments,
and Five-Year Reviews [Areas D3, E2, E3, G, and H]

•

•

•

NA

•

•

low

TBD

TBD

S03 - Targeted Remediation (Targeted Excavation and Off-site
Disposal), Institutional Controls, Periodic Assessments, and Five-
Year Reviews [PRG and PMC Exceedances within Areas D1, E1,
and F]

•

•

•

NA

•

•

med

TBD

TBD

S04 - Targeted In-Situ Physical Treatment
(Solidification/Stabilization), Institutional Controls, Periodic
Assessments, and Five-Year Reviews [PRG and PMC Exceedances
within Areas D1, E1, and F]

•

•





•

•

med

TBD

TBD

S05 - Pre-Design Investigations, Limited Excavation and Off-Site
Disposal, Institutional Controls, Long-Term Monitoring, and Five-
Year Reviews [ Area J]

•

•

•

NA

•

•

high

TBD

TBD

S06 - Pre-Design Investigations, Soil Cap, Institutional Controls,
Operation and Maintenance, Periodic Assessments, and Five-Year
Reviews [Area J]

•

•

•

NA

•

•

med

TBD

TBD

S07 - Pre-Design Investigations, Targeted Remediation (Targeted
Excavation and Off-site Disposal), Institutional Controls, Periodic
Assessments, and Five-Year Reviews [Area J]

•

•

•

NA

•

•

high

TBD

TBD

S08 - Pre-Design Investigations, Excavation and Off-site Disposal,
Institutional Controls, Periodic Assessments, and Five Year
Reviews [Area I]

•

•

•

NA

•

•

med

TBD

TBD

Legend

TBD

Does not meet criterion
Partially meets criterion
Meets criterion

To be determined and addressed during the Public Comment Period.

MA-3767-2013

Nobis Engineering, Inc.

-------
Table K-2

Comparative Analysis of Vapor Intrusion Alternatives Summary
Scovill Industrial Landfill Site
Waterbury, Connecticut

Vapor Intrusion Alternatives



















V11 - No Action







NA



•

low

TBD

TBD

VI2 - Limited Action, Institutional Controls, Periodic Assessments,
and Five-Year Reviews [Areas E1, J]







NA





low

TBD

TBD

VI3 - Active Soil Vapor Mitigation System, Institutional Controls,
Operations & Maintenance, and Five-Year Reviews [Area E1]

•

•

•

NA





med

TBD

TBD

VI4 - Passive Soil Vapor Mitigation System, Institutional Controls,
Operations & Maintenance, and Five-Year Reviews [Area E1]

•

•



NA





med

TBD

TBD

Legend

Does not meet criterion
Partially meets criterion
Meets criterion

To be determined and addressed during the Public Comment Period.

MA-3767-2013

-------
Table L-1

Potential Soil Residential Preliminary Remediation Goals
Scovill Landfill Superfund Site
Waterbury, Connecticut

Analyte

Background Threshold
Value-Based PRGs 1

Risk-Based PRGs 2

ARAR-based
PRGs

Policy

Recommended Residential PRGs

Surface Soil
(mg/Kg)

Sub-surface
Soil (mg/Kg)

Res.
E-06

(mg/Kg)

Res.
E-05

(mg/Kg)

Res.
E-04

(mg/Kg)

Res.
Hl=1

(mg/Kg)

CT RSR -
DEC Res.
(mg/Kg)

EPA3
(mg/Kg)

Surface Soil
(mg/Kg)

Basis

Sub-surface
Soil (mg/Kg)

Basis

PAHs

Benzo(a)anthracene

3.424

0.715

0.15

1.5

15

na

1

na

3.4

BTV

1

RSR

Benzo(a)pyrene

3.748

0.776

0.015

0.15

1.5

na

1

na

3.7

BTV

1

RSR

Benzo(b)fluoranthene

5.143

1.067

0.15

1.5

15

na

1

na

5.1

BTV

1.1

BTV

Benzo(k)fluoranthene

3.582

0.685

1.5

15

150

na

8.4

na

8.4

RSR

8.4

RSR

Dibenz(a,h)anthracene

0.628

0.324

0.015

0.15

1.5

na

1

na

1

2008 Draft

1

2008 Draft

lndeno(1,2,3-cd)pvrene

1.945

0.508

0.15

1.5

15

na

1

na

1.9

BTV

1

2008 Draft

PCBs, Dioxins

Dioxin TEQ-CalEPA4

na

na

4.5E-06

4.5E-05

4.5E-04

na

na

na

5.E-05

risk-based

5.E-05

risk-based

Dioxin TEQ - HEAST 5

na

na

3.9E-06

3.9E-05

3.9E-04

na

na

na

Dioxin TEQ - IRIS 6

na

na

na

na

na

5.0E-05

na

na

PCBs

na

na

0.22

2.2

22

1.1

1 1

1

EPA/RSR

1

EPA/RSR

Metals

Antimony7

na

na

na

na

na

31.3

27

na

27

RSR

27

RSR

Arsenic

13.4

10.43

0.39

3.9

39

22

10

na

13.4

BTV

10.4

BTV

Chromium -Trivalent

na

na

na

na

na

120,000

3,900

na

3,900

RSR

3,900

RSR

Chromium - Hexavalent

na

na

0.293

2.93

29

15,200

100

na

100

RSR

100

RSR

Nickel7

na

na

na

na

na

1,550

1,400

na

1,400

RSR

1,400

RSR

Vanadium 7

51

41

227

2270

22,700

390

470

na

470

RSR

470

RSR

Abbr.:

CT RSR - CT Remediation Standard Regulations (RCSA 22a~133~1 through -3)
Res. - residential

DEC - RSR Direct Exposure Criteria
VOCs - volatile organic compounds
PAHs - Polycyclic aromatic hydrocarbons
PCBs - polychlorinated biphenyls

PRGs - Preliminary Remediation Goals

Dioxin TEQ - 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) Toxicity Equivalent
ARAR - Applicable or Relevant and Appropriate Requirement

na - not applicable, tbd - to be determined

Legend:

Notes:

8.4

1

Appendix A to 22a~133k-1 to 22a~133k~3 of the CT RSRs
2008 Draft Criteria per CT DEEP (2012)

1.	Based on Upper Simultaneous Limit 95 (USL 95) prepared by A. Singh, Apr. 5, 2012.

2.	Risk-based PRG values development presented in Appendix C.

3.	For PCBs. based on A Guide on Remedial Actions at Superfund Sites With PCB Contamination . EPA
Publication No. 9355.4-01FS, Fact Sheet, Aug. 1990.

4.	Based on CalEPA CSF of 1.3E+05 (mg/kg-day) 1

5.	Based on HEAST CSF of 1.5E+05 (mg/kg-day) 1

6.	Based on IRIS Feb. 17, 2012 non-cancer RfD of 7E-10 mg/kg-day.

7.	PRGs have been developed and will apply should land use convert to residential use in Areas G (Sn) and J (Ni
and V).

MA-3767-2013

Nobis Engineering, Inc.

-------
Table L-2

Potential Soil Commercial/Industrial Preliminary Remediation Goals
Scovill Landfill Superfund Site
Waterbury, Connecticut

Analyte

Background Threshold
Value-Based PRGs 1

Risk-Based PRGs2

ARAR-based
PRG

Policy

Recommended Comm./lnd. PRGs

Surface Soil
(mg/Kg)

Sub-surface
Soil
(mg/Kg)

Com./lnd.
E-06

(mg/Kg)

Com./lnd.
E-05

(mg/Kg)

Com./lnd.
E-04

(mg/Kg)

Com./lnd.
Hl=1

(mg/Kg)

CT RSR - DEC
Ind./Com.
(mg/Kg)

EPA3
(mg/Kg)

Surface Soil
(mg/Kg)

Basis

Sub-surface
Soil
(mg/Kg)

Basis

PAHs

Benzo(a)anthracene

3.424

0.715

2.1

21

210

na

7.8

na

7.8

RSR

7.8

RSR

Benzo(a)pyrene

3.748

0.776

0.21

2.1

21

na

1

na

3.7

BTV

1

RSR

Benzo(b)fluoranthene

5.143

1.067

2.1

21

210

na

7.8

na

7.8

RSR

7.8

RSR

Benzo(k)fluoranthene

3.582

0.685

21

210

2,100

na

78

na

78

RSR

78

RSR

Dibenz(a,h)anthracene

0.628

0.324

0.21

2.1

21

na

1

na

1

RSR

1

2008 Draft

lndeno(1,2,3-cd)pvrene

1.945

0.508

2.1

21

210

na

7.8

na

7.8

RSR

7.8

2008 Draft

PCBs, Dioxins

Dioxin TEQ-CalEPA4

na

na

1.84E-05

1.84E-04

1.84E-03

na

na na

6.00E-04

risk-based

6.00E-04

risk-based

Dioxin TEQ - HEAST5

na

na

1.59E-05

1.59E-04

1.59E-03

na

na

na

Dioxin TEQ - IRIS 6

na

na

na

na

na

6.00E-04

na

na

PCBs

na

na

0.74

7.4

74

11

10

10-25

10

EPA/RSR

10

EPA/RSR

Metals

Antimony

na

na

na

na

na

410

8,200

na

8,200

RSR

8,200

RSR

Arsenic

13.4

10.43

1.6

16

160

255

10

na

13.4

BTV

10.4

BTV

Chromium -Trivalent

na

na

na

na

na

1,500,000

51,000

na

51,000

RSR

51,000

RSR

Chromium - Hexavalent

na

na

5.57

55.7

557

3,100

100

na

100

RSR

100

RSR

Nickel

na

na

na

na

na

20,000

7,500

na

7,500

RSR

7,500

RSR

Vanadium

51

41

1140

11,400

114,000

5,200

14,000

na

14,000

RSR

14,000

RSR

Abbr.:	Legend

CT RSR - CT Remediation Standard Regulations (RCSA 22a~133~1 through -3)

Comm./lnd.- commercial/industrial

DEC - RSR Direct Exposure Criteria	Notes:

VOCs - volatile organic compounds
PAHs - Polycyclic aromatic hydrocarbons
PCBs - polychlorinated biphenyls

PRGs - Preliminary Remediation Goals

Dioxin TEQ - 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) Toxicity Equivalent
ARAR - Applicable or Relevant and Appropriate Requirement

na - not applicable, tbd - to be determined

7.8

Appendix A to 22a-133k-1 to 22a-133k-3 of the CT RSRs
2008 Draft Criteria per CT DEEP (2012)

1.	Based on Upper Simultaneous Limit 95 (USL 95) prepared by A. Singh, Apr. 5, 2012.

2.	Risk-based PRG values development presented in Appendix C.

3.	For PCBs, based on A Guide on Remedial Actions at Superfund Sites With PCB
Contamination. EPA Publication No. 9355.4-01 FS, Fact Sheet, Aug. 1990.

4.	Based on CalEPA CSF of 1.3E+05 (mg/kg-day)"1

5.	Based on HEAST CSF of 1.5E+05 (mg/kg-day)"1

6.	Based on IRIS Feb. 17, 2012 non-cancer RfD of 7E-10 mg/kg-day.

7.	Site-specific risk-based PRGs were developed using site-specific ratio of hexavalent to
total chromium ratio of 1.54%.

MA-3767-2013

Nobis Engineering, Inc.

-------
Table L-3

SOil Clean-Up Levels and Soil Gas Screening Levels
Scovill Landfill Superfund Site
Waterbury, Connecticut

Soil Contaminant of
Concern

Residential Soil Clean-Up Levels

Comm./lnd. Soil Clean-Up Levels

Surface

Soil
(mg/Kg)

Basis

Sub-
surface
Soil

Basis

Surface Soil
(mg/Kg)

Basis

Sub-surface
Soil
(mg/Kg)

Basis

Benzo(a)anthracene

3.4

BTV

1

RSR DEC

7.8

RSR DEC

7.8

RSR DEC

Benzo(a)pyrene

3.7

BTV

1

RSR DEC

3.7

BTV

1

RSR DEC

Benzo(b)fluoranthene

5.1

BTV

1.1

BTV

7.8

RSR DEC

7.8

RSR DEC

Benzo(k)fluoranthene

8.4

RSR

8.4

RSR DEC

78

RSR DEC

78

RSR DEC

Di benz(a,h)anth racene

1

2008 Draft

1

2008 Draft

1

RSR DEC

1

2008 Draft

indeno(1,2,3-cd)pyrene

1.9

BTV

1

2008 Draft

7.8

RSR DEC

7.8

2008 Draft

Dioxin TEQ

5.E-05

risk-based

5.E-05

risk-based

6.00E-04

risk-based

6.00E-04

risk-based

PCBs

1

EPA/RSR

1

EPA/RSR
DEC

10

EPA/RSR
DEC

10

EPA/RSR
DEC

Antimony

27

RSR

27

RSR DEC

8,200

RSR DEC

8,200

RSR DEC

Arsenic

13.4

BTV

10.4

BTV

13.4

BTV

10.4

BTV

Chromium - Trivalent

3,900

RSR

3,900

RSR DEC

51,000

RSR DEC

51,000

RSR DEC

Chromium - Hexavalent

100

RSR

100

RSR DEC

100

RSR DEC

100

RSR DEC

Nickel

1,400

RSR

1,400

RSR DEC

7,500

RSR DEC

7,500

RSR DEC

Vanadium

470

RSR

470

RSR DEC

14,000

RSR DEC

14,000

RSR DEC

Soil Gas Contaminant
of Concern

Soil Gas
Screening
Levels
(ug/m3)

Basis

Chloroform

22

RSR VC

Trichloroethene

38

RSR VC

Vinyl Chloride

3

RSR VC

Abbr.:

BTV - Background Threshold Values
DEC - RSR Direct Exposure Criteria

EPA - A Guide on Remedial Actions at Superfund Sites With PCB Contamination, EPA Publication No. 9355.4-
01FS, Fact Sheet, Aug. 1990.

RSR - CT Remediation Standard Regulations (RCSA 22a-133-1 through -3), Amended June 27, 2013

PCBs - polychlorinated biphenyls

VC - RSR Volatilization Criteria for Soil Vapor

Dioxin TEQ - 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) Toxicity

-------
A
P
P
E
N
D
I

X
D

-------
TABLE G-7A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA D1
WATERBURY, CONNECTICUT

Scenario Timeframe: Current/Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area D1

PAHs

























Benzo(a)anthracene

3.9E-06



1.5E-06

5.4E-06

















Benzo(a)pyrene

4.5E-05



1.7E-05

6.2E-05

















Benzo(b)fluoranthene

6.0E-06



2.3E-06

8.3E-06

















Dibenz(a,h)anthracene

1.6E-05



6.1E-06

2.2E-05

















lndeno(1,2,3-cd)pyrene

4.4E-06



1.7E-06

6.1E-06

















Metals

























Arsenic

9.9E-06



9.4E-07

1.1E-05

















Chromium Total

5.1E-05





5.1E-05

















Chemical Total

1.4E-04



3.0E-05

1.7E-04















Exposure Point Total



1.7E-04









Air at Risk Area D1

PAHs

























Benzo(a)anthracene



6.5E-11



6.5E-11

















Benzo(a)pyrene



7.5E-10



7.5E-10

















Benzo(b)fluoranthene



1.0E-10



1.0E-10

















Dibenz(a,h)anthracene



2.9E-10



2.9E-10

















lndeno(1,2,3-cd)pyrene



7.4E-11



7.4E-11

















Metals

























Arsenic



5.4E-09



5.4E-09

















Chromium Total



9.5E-07



9.5E-07

















Chemical Total



9.5E-07



9.5E-07















Exposure Point Total



9.5E-07







Surface Soil Total



1.7E-04





Soil Total



1.7E-04





Total Risk Across All Media

1.7E-04

Total Hazard Across All Media

-------
TABLE G-7B
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA E3
WATERBURY, CONNECTICUT

Scenario Timeframe: Current/Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area E3

PAHs

























Benzo(a)anthracene

9.0E-06



3.5E-06

1.2E-05

















Benzo(a)pyrene

6.8E-05



2.6E-05

9.5E-05

















Benzo(b)fluoranthene

8.0E-06



3.1E-06

1.1E-05

















Dibenz(a,h)anthracene

1.3E-05



4.8E-06

1.7E-05

















lndeno(1,2,3-cd)pyrene

4.7E-06



1.8E-06

6.6E-06

















Metals

























Arsenic

1.0E-05



9.8E-07

1.1E-05

















Chromium Total

6.8E-05





6.8E-05

















Chemical Total

1.8E-04



4.0E-05

2.2E-04















Exposure Point Total



2.2E-04









Air at Risk Area E3

PAHs

























Benzo(a)anthracene



1.5E-10



1.5E-10

















Benzo(a)pyrene



1.1E-09



1.1E-09

















Benzo(b)fluoranthene



1.3E-10



1.3E-10

















Dibenz(a,h)anthracene



2.3E-10



2.3E-10

















lndeno(1,2,3-cd)pyrene



7.9E-11



7.9E-11

















Metals

























Arsenic



5.6E-09



5.6E-09

















Chromium Total



1.3E-06



1.3E-06

















Chemical Total



1.3E-06



1.3E-06















Exposure Point Total



1.3E-06







Surface Soil Total



2.2E-04





Soil Total



2.2E-04





Total Risk Across All Media

2.2E-04

Total Hazard Across All Media

-------
TABLE G-7C
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA F
WATERBURY, CONNECTICUT

Scenario Timeframe: Current/Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area F

PAHs

























Benzo(a)anthracene

9.1E-06



3.5E-06

1.3E-05

















Benzo(a)pyrene

5.1E-05



2.0E-05

7.1E-05

















Benzo(b)fluoranthene

1.0E-05



4.0E-06

1.4E-05

















Benzo(k)fluoranthene

1.0E-06



3.8E-07

1.4E-06

















Dibenz(a,h)anthracene

1.7E-05



6.6E-06

2.4E-05

















lndeno(1,2,3-cd)pyrene

3.8E-06



1.5E-06

5.2E-06

















Metals

























Arsenic

1.8E-05



1.7E-06

2.0E-05

















Chromium Total

6.2E-05





6.2E-05

















Chemical Total

1.7E-04



3.7E-05

2.1E-04















Exposure Point Total



2.1E-04









Air at Risk Area F

PAHs

























Benzo(a)anthracene



1.5E-10



1.5E-10

















Benzo(a)pyrene



8.6E-10



8.6E-10

















Benzo(b)fluoranthene



1.7E-10



1.7E-10

















Benzo(k)fluoranthene



1.7E-10



1.7E-10

















Dibenz(a,h)anthracene



3.1E-10



3.1E-10

















lndeno(1,2,3-cd)pyrene



6.3E-11



6.3E-11

















Metals

























Arsenic



9.7E-09



9.7E-09

















Chromium Total



1.1E-06



1.1E-06

















Chemical Total



1.2E-06



1.2E-06















Exposure Point Total



1.2E-06







Surface Soil Total



2.1E-04





Soil Total



2.1E-04





Total Risk Across All Media

2.1E-04

Total Hazard Across All Media

-------
TABLE G-8A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA D3
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area D3

PAHs

























Benzo(a)anthracene

1.9E-05



7.1E-06

2.6E-05

















Benzo(a)pyrene

1.9E-04



7.1E-05

2.6E-04

















Benzo(b)fluoranthene

2.7E-05



1.1E-05

3.8E-05

















Benzo(k)fluoranthene

1.8E-06



6.8E-07

2.4E-06

















Dibenz(a,h)anthracene

1.5E-05



5.8E-06

2.1E-05

















lndeno(1,2,3-cd)pyrene

4.2E-06



1.6E-06

5.8E-06

















Metals

























Arsenic

2.8E-05



2.6E-06

3.0E-05

















Chromium Total

9.9E-05





9.9E-05

















Chemical Total

3.8E-04



1.0E-04

4.8E-04















Exposure Point Total



4.8E-04









Air at Risk Area D3

PAHs

























Benzo(a)anthracene



3.1E-10



3.1E-10

















Benzo(a)pyrene



3.1E-09



3.1E-09

















Benzo(b)fluoranthene



4.6E-10



4.6E-10

















Benzo(k)fluoranthene



2.9E-10



2.9E-10

















Dibenz(a,h)anthracene



2.8E-10



2.8E-10

















lndeno(1,2,3-cd)pyrene



7.0E-11



7.0E-11

















Metals

























Arsenic



1.5E-08



1.5E-08

















Chromium Total



1.8E-06



1.8E-06

















Chemical Total



1.9E-06



1.9E-06















Exposure Point Total



1.9E-06







Surface Soil Total



4.8E-04





Soil Total



4.8E-04





Total Risk Across All Media

4.8E-04

Total Hazard Across All Media

-------
TABLE G-8B
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA E1
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area E1

PAHs

























Benzo(a)anthracene

8.9E-06



3.4E-06

1.2E-05

















Benzo(a)pyrene

7.3E-05



2.8E-05

1.0E-04

















Benzo(b)fluoranthene

5.1E-06



2.0E-06

7.0E-06

















Dibenz(a,h)anthracene

8.6E-06



3.3E-06

1.2E-05

















lndeno(1,2,3-cd)pyrene

4.2E-06



1.6E-06

5.8E-06

















Metals

























Arsenic

8.2E-06



7.8E-07

9.0E-06

















Chromium Total

5.7E-05





5.7E-05

















Chemical Total

1.7E-04



3.9E-05

2.0E-04















Exposure Point Total



2.0E-04









Air at Risk Area E1

PAHs

























Benzo(a)anthracene



1.5E-10



1.5E-10

















Benzo(a)pyrene



1.2E-09



1.2E-09

















Benzo(b)fluoranthene



8.5E-11



8.5E-11

















Dibenz(a,h)anthracene



1.6E-10



1.6E-10

















lndeno(1,2,3-cd)pyrene



7.0E-11



7.0E-11

















Metals

























Arsenic



4.5E-09



4.5E-09

















Chromium Total



1.1E-06



1.1E-06

















Chemical Total



1.1E-06



1.1E-06















Exposure Point Total



1.1E-06







Surface Soil Total



2.1E-04





Soil Total



2.1E-04





Total Risk Across All Media

2.1E-04

Total Hazard Across All Media

-------
TABLE G-8C
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA G
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area G

PAHs

























Benzo(a)anthracene

4.0E-06



1.5E-06

5.5E-06

















Benzo(a)pyrene

4.5E-05



1.7E-05

6.2E-05

















Benzo(b)fluoranthene

4.6E-06



1.7E-06

6.3E-06

















Dibenz(a,h)anthracene

1.2E-05



4.7E-06

1.7E-05

















lndeno(1,2,3-cd)pyrene

2.8E-06



1.1E-06

3.9E-06

















Metals

























Arsenic

4.9E-05



4.6E-06

5.3E-05

















Chromium Total

2.2E-04





2.2E-04

















Chemical Total

3.4E-04



3.1E-05

3.7E-04















Exposure Point Total



3.7E-04









Air at Risk Area G

PAHs

























Benzo(a)anthracene



6.6E-11



6.6E-11

















Benzo(a)pyrene



7.5E-10



7.5E-10

















Benzo(b)fluoranthene



7.6E-11



7.6E-11

















Dibenz(a,h)anthracene



2.2E-10



2.2E-10

















lndeno(1,2,3-cd)pyrene



4.7E-11



4.7E-11

















Metals

























Arsenic



2.6E-08



2.6E-08

















Chromium Total



4.1E-06



4.1E-06

















Chemical Total



4.2E-06



4.2E-06















Exposure Point Total



4.2E-06







Surface Soil Total



3.7E-04





Soil Total



3.7E-04





Total Risk Across All Media

3.7E-04

Total Hazard Across All Media

-------
TABLE G-8D
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA H
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area H

PAHs

























Benzo(a)anthracene

1.4E-05



5.3E-06

1.9E-05

















Benzo(a)pyrene

1.5E-04



5.7E-05

2.0E-04

















Benzo(b)fluoranthene

1.6E-05



6.3E-06

2.3E-05

















Benzo(k)fluoranthene

1.7E-06



6.6E-07

2.4E-06

















Dibenz(a,h)anthracene

4.8E-05



1.8E-05

6.6E-05

















lndeno(1,2,3-cd)pyrene

1.2E-05



4.5E-06

1.6E-05

















Metals

























Arsenic

8.9E-06



8.5E-07

9.8E-06

















Chromium Total

5.3E-05





5.3E-05

















Chemical Total

3.0E-04



9.3E-05

3.9E-04















Exposure Point Total



3.9E-04









Air at Risk Area H

PAHs

























Benzo(a)anthracene



2.3E-10



2.3E-10

















Benzo(a)pyrene



2.5E-09



2.5E-09

















Benzo(b)fluoranthene



2.7E-10



2.7E-10

















Benzo(k)fluoranthene



2.9E-10



2.9E-10

















Dibenz(a,h)anthracene



8.7E-10



8.7E-10

















lndeno(1,2,3-cd)pyrene



1.9E-10



1.9E-10

















Metals

























Arsenic



4.8E-09



4.8E-09

















Chromium Total



9.8E-07



9.8E-07

















Chemical Total



9.9E-07



9.9E-07















Exposure Point Total



9.9E-07







Surface Soil Total



3.9E-04





Soil Total



3.9E-04





Total Risk Across All Media

3.9E-04

Total Hazard Across All Media

-------
TABLE G-8E
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE - RISK AREA I
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area 1

PAHs

























Benzo(a)anthracene

2.2E-05



8.3E-06

3.0E-05

















Benzo(a)pyrene

2.1E-04



8.1E-05

2.9E-04

















Benzo(b)fluoranthene

3.6E-05



1.4E-05

4.9E-05

















Benzo(k)fluoranthene

1.1E-06



4.3E-07

1.6E-06

















Dibenz(a,h)anthracene

2.7E-05



1.1E-05

3.8E-05

















lndeno(1,2,3-cd)pyrene

5.4E-06



2.1E-06

7.5E-06

















Metals

























Arsenic

1.3E-05



1.2E-06

1.4E-05

















Chromium Total

5.5E-05





5.5E-05

















Chemical Total

3.7E-04



1.2E-04

4.9E-04















Exposure Point Total



4.9E-04









Air at Risk Area 1

PAHs

























Benzo(a)anthracene



3.6E-10



3.6E-10

















Benzo(a)pyrene



3.5E-09



3.5E-09

















Benzo(b)fluoranthene



6.0E-10



6.0E-10

















Benzo(k)fluoranthene



1.9E-10



1.9E-10

















Dibenz(a,h)anthracene



5.0E-10



5.0E-10

















lndeno(1,2,3-cd)pyrene



9.0E-11



9.0E-11

















Metals

























Arsenic



6.9E-09



6.9E-09

















Chromium Total



1.0E-06



1.0E-06

















Chemical Total



1.0E-06



1.0E-06















Exposure Point Total



1.0E-06







Surface Soil Total



4.9E-04





Soil Total



4.9E-04





Total Risk Across All Media

4.9E-04

Total Hazard Across All Media

-------
TABLE G-8F
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J

		WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident

Receptor Age: Age-Adjusted	

Medium

Exposure

Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium



of Potential
Concern

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Soil

Surface Soil

Surface Soil at Risk Area J

PAHs

























Benzo(a)anthracene

Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene

1.1E-05
7.7E-05
9.0E-06
2.4E-05
5.4E-06



4.2E-06
2.9E-05
3.4E-06
9.3E-06
2.1E-06

1.5E-05
1.1E-04
1.2E-05
3.4E-05
7.5E-06

















PCBs

























Aroclor-1254
Aroclor-1260

3.6E-05
1.9E-06



1.6E-05
8.4E-07

5.2E-05
2.7E-06

















Metals

























Arsenic
Chromium Total
Vanadium

1.1E-05
4.7E-02



1.1E-06

1.2E-05
4.7E-02

















Chemical Total

4.7E-02



6.6E-05

4.7E-02















Exposure Point Total









4.7E-02















Air at Risk Area J

PAHs

























Benzo(a)anthracene

Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene



1.8E-10
1.3E-09
1.5E-10
4.4E-10
9.0E-11



1.8E-10
1.3E-09
1.5E-10
4.4E-10
9.0E-11

















PCBs

























Aroclor-1254
Aroclor-1260



1.9E-09
1.0E-10



1.9E-09
1.0E-10

















Metals

























Arsenic
Chromium Total
Vanadium



6.1E-09
8.7E-04
1.1E-06



6.1E-09
8.7E-04
1.1E-06

















Chemical Total



8.7E-04



8.7E-04















Exposure Point Total









8.7E-04













Surface Soil Total





4.8E-02





Soil Total





4.8E-02





Total Risk Across All Media 4.8E-02

Total Hazard Across All Media

-------
TABLE G-9A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA D1
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area D1

PAHs

























Benzo(a)anthracene

2.7E-06



1.0E-06

3.8E-06

















Benzo(a)pyrene

4.3E-05



1.6E-05

5.9E-05

















Benzo(b)fluoranthene

5.5E-06



2.1E-06

7.7E-06

















Dibenz(a,h)anthracene

8.6E-06



3.3E-06

1.2E-05

















lndeno(1,2,3-cd)pyrene

3.5E-06



1.3E-06

4.8E-06

















Metals

























Arsenic

8.9E-06



8.4E-07

9.7E-06

















Chromium Total

4.9E-05





4.9E-05

















Vanadium

























Chemical Total

1.2E-04



2.5E-05

1.5E-04















Exposure Point Total



1.5E-04









Air at Risk Area D1

PAHs

























Benzo(a)anthracene



4.6E-11



4.6E-11

















Benzo(a)pyrene



7.2E-10



7.2E-10

















Benzo(b)fluoranthene



9.2E-11



9.2E-11

















Dibenz(a,h)anthracene



1.6E-10



1.6E-10

















lndeno(1,2,3-cd)pyrene



5.8E-11



5.8E-11

















Metals

























Arsenic



4.8E-09



4.8E-09

















Chromium Total



9.2E-07



9.2E-07

















Vanadium



1.2E-06



1.2E-06

















Chemical Total



2.2E-06



2.2E-06















Exposure Point Total



2.2E-06







Aggregate Soil Total



1.5E-04





Soil Total



1.5E-04





Total Risk Across All Media

1.5E-04

Total Hazard Across All Media

-------
TABLE G-9B
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA D3
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area D3

PAHs

























Benzo(a)anthracene

1.5E-05



5.7E-06

2.1E-05

















Benzo(a)pyrene

1.7E-04



6.4E-05

2.3E-04

















Benzo(b)fluoranthene

2.4E-05



9.3E-06

3.4E-05

















Benzo(k)fluoranthene

1.1E-06



4.2E-07

1.5E-06

















Dibenz(a,h)anthracene

5.6E-05



2.2E-05

7.8E-05

















lndeno(1,2,3-cd)pyrene

1.2E-05



4.5E-06

1.6E-05

















Metals

























Arsenic

1.8E-05



1.7E-06

1.9E-05

















Chemical Total

2.9E-04



1.1E-04

4.0E-04















Exposure Point Total



4.0E-04









Air at Risk Area D3

PAHs

























Benzo(a)anthracene



2.5E-10



2.5E-10

















Benzo(a)pyrene



2.8E-09



2.8E-09

















Benzo(b)fluoranthene



4.1E-10



4.1E-10

















Benzo(k)fluoranthene

























Dibenz(a,h)anthracene

























lndeno(1,2,3-cd)pyrene



1.9E-10



1.9E-10

















Metals

























Arsenic

























Chemical Total



3.6E-09



3.6E-09















Exposure Point Total



3.6E-09







Aggregate Soil Total



4.0E-04





Soil Total



4.0E-04





Total Risk Across All Media

4.0E-04

Total Hazard Across All Media

-------
TABLE G-9C
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA E1
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area

bis(2-Chloroethyl)ether

6.5E-07























Dioxins/Furans

























2,3,7,8-TCDD TEQ

2.3E-06



2.2E-07

2.5E-06

















Hexachlorobenzene

9.4E-07



3.0E-07

1.2E-06

















N-Nitrosodi-n-propylamine

4.1E-06



1.3E-06

5.4E-06

















PAHs

























Benzo(a)anthracene

2.7E-05



1.0E-05

3.7E-05

















Benzo(a)pyrene

2.4E-04



9.0E-05

3.3E-04

















Benzo(b)fluoranthene

3.5E-05



1.3E-05

4.8E-05

















Benzo(k)fluoranthene

1.4E-06



5.2E-07

1.9E-06

















Dibenz(a,h)anthracene

1.0E-05



4.0E-06

1.4E-05

















lndeno(1,2,3-cd)pyrene

5.2E-06



2.0E-06

7.2E-06

















Metals

























Arsenic

7.8E-06



7.4E-07

8.6E-06

















Chromium Total

6.0E-05





6.0E-05

















Chemical Total

3.9E-04



1.2E-04

5.1E-04















Exposure Point Total



5.1E-04









Air at Risk Area E1

bis(2-Chloroethyl)ether



1.14E-06



1.1E-06

















Dioxins/Furans

























2,3,7,8-TCDD TEQ



1.3E-10



1.3E-10

















Hexachlorobenzene



5.1E-11



5.1E-11

















N-Nitrosodi-n-propylamine



2.2E-10



2.2E-10

















PAHs

























Benzo(a)anthracene



4.5E-10



4.5E-10

















Benzo(a)pyrene



3.9E-09



3.9E-09

















Benzo(b)fluoranthene



5.8E-10



5.8E-10

















Benzo(k)fluoranthene



2.3E-10



2.3E-10

















Dibenz(a,h)anthracene



1.9E-10



1.9E-10

















lndeno(1,2,3-cd)pyrene



8.7E-11



8.7E-11

















Metals

























Arsenic



4.2E-09



4.2E-09

















Chromium Total



1.1E-06



1.1E-06

















Chemical Total



2.3E-06



2.3E-06















Exposure Point Total



2.3E-06







Aggregate Soil Total



5.2E-04





Soil Total



5.2E-04





Total Risk Across All Media

5.2E-04

Total Hazard Across All Media

-------
TABLE G-9D
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA E2
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area E2

Dioxins/Furans

























2,3,7,8-TCDD TEQ

1.1E-06



1.1E-07

1.3E-06

















PAHs

























Benzo(a)anthracene

8.7E-06



3.3E-06

1.2E-05

















Benzo(a)pyrene

9.3E-05



3.6E-05

1.3E-04

















Benzo(b)fluoranthene

1.2E-05



4.7E-06

1.7E-05

















Dibenz(a,h)anthracene

8.3E-06



3.2E-06

1.1E-05

















lndeno(1,2,3-cd)pyrene

4.6E-06



1.8E-06

6.4E-06

















Metals

























Arsenic

1.0E-05



9.4E-07

1.1E-05

















Chromium Total

4.4E-05





4.4E-05

















Chemical Total

1.8E-04



5.0E-05

2.3E-04















Exposure Point Total



2.3E-04









Air at Risk Area E2

Dioxins/Furans

























2,3,7,8-TCDD TEQ



6.4E-11



6.4E-11

















PAHs

























Benzo(a)anthracene



1.4E-10



1.4E-10

















Benzo(a)pyrene



1.6E-09



1.6E-09

















Benzo(b)fluoranthene



2.1E-10



2.1E-10

















Dibenz(a,h)anthracene



1.5E-10



1.5E-10

















lndeno(1,2,3-cd)pyrene



7.7E-11



7.7E-11

















Metals

























Arsenic



5.4E-09



5.4E-09

















Chromium Total



8.2E-07



8.2E-07

















Chemical Total



8.2E-07



8.2E-07















Exposure Point Total



8.2E-07







Aggregate Soil Total



2.3E-04





Soil Total



2.3E-04





Total Risk Across All Media

2.3E-04

Total Hazard Across All Media

-------
TABLE G-9E
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA E3
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area E3

PAHs

























Benzo(a)anthracene

6.9E-06



2.6E-06

9.5E-06

















Benzo(a)pyrene

5.3E-05



2.0E-05

7.4E-05

















Benzo(b)fluoranthene

6.3E-06



2.4E-06

8.7E-06

















Dibenz(a,h)anthracene

9.7E-06



3.7E-06

1.3E-05

















lndeno(1,2,3-cd)pyrene

3.6E-06



1.4E-06

5.0E-06

















Metals

























Arsenic

1.2E-05



1.1E-06

1.3E-05

















Chromium Total

1.7E-04





1.7E-04

















Chemical Total

2.6E-04



3.2E-05

2.9E-04















Exposure Point Total



2.9E-04









Air at Risk Area E3

PAHs

























Benzo(a)anthracene



1.2E-10



1.2E-10

















Benzo(a)pyrene



8.9E-10



8.9E-10

















Benzo(b)fluoranthene



1.0E-10



1.0E-10

















Dibenz(a,h)anthracene



1.8E-10



1.8E-10

















lndeno(1,2,3-cd)pyrene



6.0E-11



6.0E-11

















Metals

























Arsenic



6.4E-09



6.4E-09

















Chromium Total



3.1E-06



3.1E-06

















Chemical Total



3.1E-06



3.1E-06















Exposure Point Total



3.1E-06







Aggregate Soil Total



2.9E-04





Soil Total



2.9E-04





Total Risk Across All Media

2.9E-04

Total Hazard Across All Media

-------
TABLE G-9F
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA F
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area F

PAHs

























Benzo(a)anthracene

7.9E-06



3.0E-06

1.1E-05

















Benzo(a)pyrene

6.6E-05



2.5E-05

9.1E-05

















Benzo(b)fluoranthene

8.9E-06



3.4E-06

1.2E-05

















Benzo(k)fluoranthene

8.6E-07



3.3E-07

1.2E-06

















Dibenz(a,h)anthracene

1.6E-05



6.1E-06

2.2E-05

















lndeno(1,2,3-cd)pyrene

3.5E-06



1.3E-06

4.9E-06

















Metals

























Arsenic

1.7E-05



1.6E-06

1.9E-05

















Chromium Total

3.6E-04





3.6E-04

















Chemical Total

4.8E-04



4.1E-05

5.2E-04















Exposure Point Total



5.2E-04









Air at Risk Area F

PAHs

























Benzo(a)anthracene



1.3E-10



1.3E-10

















Benzo(a)pyrene



1.1E-09



1.1E-09

















Benzo(b)fluoranthene



1.5E-10



1.5E-10

















Benzo(k)fluoranthene



1.4E-10



1.4E-10

















Dibenz(a,h)anthracene



2.9E-10



2.9E-10

















lndeno(1,2,3-cd)pyrene



5.9E-11



5.9E-11

















Metals

























Arsenic



9.3E-09



9.3E-09

















Chromium Total



6.6E-06



6.6E-06

















Chemical Total



6.7E-06



6.7E-06















Exposure Point Total



6.7E-06







Aggregate Soil Total



5.2E-04





Soil Total



5.2E-04





Total Risk Across All Media

5.2E-04

Total Hazard Across All Media

-------
TABLE G-9G
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA G
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential





















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area G

PAHs

























Benzo(a)anthracene

3.2E-06



1.2E-06

4.4E-06

















Benzo(a)pyrene

3.4E-05



1.3E-05

4.7E-05

















Benzo(b)fluoranthene

4.7E-06



1.8E-06

6.6E-06

















Dibenz(a,h)anthracene

9.5E-06



3.7E-06

1.3E-05

















lndeno(1,2,3-cd)pyrene

1.9E-06



7.1E-07

2.6E-06

















Metals

























Arsenic

3.1E-05



2.9E-06

3.4E-05

















Chromium Total

1.3E-04





1.3E-04

















Chemical Total

2.2E-04



2.3E-05

2.4E-04















Exposure Point Total



2.4E-04









Air at Risk Area G

PAHs

























Benzo(a)anthracene



5.4E-11



5.4E-11

















Benzo(a)pyrene



5.7E-10



5.7E-10

















Benzo(b)fluoranthene



7.9E-11



7.9E-11

















Dibenz(a,h)anthracene



1.7E-10



1.7E-10

















lndeno(1,2,3-cd)pyrene



3.1E-11



3.1E-11

















Metals

























Arsenic



1.7E-08



1.7E-08

















Chromium Total



2.5E-06



2.5E-06

















Chemical Total



2.5E-06



2.5E-06















Exposure Point Total



2.5E-06







Aggregate Soil Total



2.4E-04





Soil Total



2.4E-04





Total Risk Across All Media

2.4E-04

Total Hazard Across All Media

-------
TABLE G-9H
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA H
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area H

PAHs

























Benzo(a)anthracene

2.6E-05



9.8E-06

3.5E-05

















Benzo(a)pyrene

2.6E-04



1.0E-04

3.7E-04

















Benzo(b)fluoranthene

3.0E-05



1.2E-05

4.2E-05

















Benzo(k)fluoranthene

3.2E-06



1.2E-06

4.4E-06

















Dibenz(a,h)anthracene

7.1E-05



2.7E-05

9.9E-05

















lndeno(1,2,3-cd)pyrene

1.3E-05



5.0E-06

1.8E-05

















Metals

























Arsenic

3.3E-05



3.1E-06

3.6E-05

















Chromium Total

5.8E-05





5.8E-05

















Chemical Total

5.0E-04



1.6E-04

6.6E-04















Exposure Point Total



6.6E-04









Air at Risk Area H

PAHs

























Benzo(a)anthracene



4.3E-10



4.3E-10

















Benzo(a)pyrene



4.4E-09



4.4E-09

















Benzo(b)fluoranthene



5.0E-10



5.0E-10

















Benzo(k)fluoranthene



5.3E-10



5.3E-10

















Dibenz(a,h)anthracene



1.3E-09



1.3E-09

















lndeno(1,2,3-cd)pyrene



2.2E-10



2.2E-10

















Metals

























Arsenic



1.8E-08



1.8E-08

















Chromium Total



1.1E-06



1.1E-06

















Chemical Total



1.1E-06



1.1E-06















Exposure Point Total



1.1E-06







Aggregate Soil Total



6.6E-04





Soil Total



6.6E-04





Total Risk Across All Media

6.6E-04

Total Hazard Across All Media

-------
TABLE G-91
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE - RISK AREA I
WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Age-Adjusted

Medium

Exposure

Exposure

Chemical



Carcinogenic Risk



Non-Carcinogenic Hazard Quotient



Medium

Point

of Potential

















Concern

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure















Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area 1

PAHs

























Benzo(a)anthracene

2.6E-04



1.0E-04

3.6E-04

















Benzo(a)pyrene

2.2E-03



8.5E-04

3.1E-03

















Benzo(b)fluoranthene

9.1E-05



3.5E-05

1.3E-04

















Benzo(k)fluoranthene

6.0E-06



2.3E-06

8.3E-06

















Chrysene

2.9E-06



1.1E-06

4.0E-06

















Dibenz(a,h)anthracene

5.5E-04



2.1E-04

7.6E-04

















lndeno(1,2,3-cd)pyrene

1.9E-04



7.1E-05

2.6E-04

















Metals

























Arsenic

2.3E-05



2.2E-06

2.6E-05

















Chromium Total

4.0E-05





4.0E-05

















Chemical Total

3.4E-03



1.3E-03

4.6E-03















Exposure Point Total



4.6E-03









Air at Risk Area 1

PAHs

























Benzo(a)anthracene



4.3E-09



4.3E-09

















Benzo(a)pyrene



3.7E-08



3.7E-08

















Benzo(b)fluoranthene



1.5E-09



1.5E-09

















Benzo(k)fluoranthene



1.0E-09



1.0E-09

















Chrysene



4.8E-10



4.8E-10

















Dibenz(a,h)anthracene



1.0E-08



1.0E-08

















lndeno(1,2,3-cd)pyrene



3.1E-09



3.1E-09

















Metals

























Arsenic



1.3E-08



1.3E-08

















Chromium Total



7.5E-07



7.5E-07

















Chemical Total



8.2E-07



8.2E-07















Exposure Point Total



8.2E-07







Aggregate Soil Total



4.6E-03





Soil Total



4.6E-03





Total Risk Across All Media

4.6E-03

Total Hazard Across All Media

-------
TABLE G-9J
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J

		WATERBURY, CONNECTICUT

Scenario Timeframe: Future
Receptor Population: Resident

Receptor Age: Age-Adjusted	

Medium

Exposure
Medium

Exposure Point

Chemical
of Potential
Concern

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area J

Dioxins/Furans



















2,3,7,8-TCDD TEQ

6.6E-06



6.3E-07

7.2E-06











PAHs



















Benzo(a)anthracene

Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene

7.6E-06
6.0E-05
7.0E-06
1.4E-05
4.9E-06



2.9E-06
2.3E-05
2.7E-06
5.3E-06
1.9E-06

1.0E-05
8.3E-05
9.7E-06
1.9E-05
6.8E-06











PCBs



















Aroclor-1254
Aroclor-1260

7.2E-06
8.4E-07



3.2E-06
3.7E-07

1.0E-05
1.2E-06











Metals



















Arsenic
Chromium Total

1.1E-05
1.3E-02



1.0E-06

1.2E-05
1.3E-02











Chemical Total

1.3E-02



4.1E-05

1.3E-02













Exposure Point Total









1.3E-02













Air at Risk Area J

Dioxins/Furans



















2,3,7,8-TCDD TEQ



3.7E-07



3.7E-07











PAHs



















Benzo(a)anthracene

Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene



1.3E-10
1.0E-09
1.2E-10
2.5E-10
8.2E-11



1.3E-10
1.0E-09
1.2E-10
2.5E-10
8.2E-11











PCBs



















Aroclor-1254
Aroclor-1260



3.9E-10
4.5E-11



3.9E-10
4.5E-11











Metals



















Arsenic
Chromium Total



6.0E-09
2.4E-04



6.0E-09
2.4E-04











Chemical Total



2.4E-04



2.4E-04













Exposure Point Total









2.4E-04













Aggregate Soil Tota





1.3E-02





Soil Total





1.3E-02





Total Risk Across All Media 1.3E-02

Total Hazard Across All Media

-------
TABLE G-1 OA
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE - RISK AREA I

		WATERBURY, CONNECTICUT

Scenario Timeframe: Future

Receptor Population: Industrial/Commercial Worker

Receptor Age: Adult	

Medium

Exposure

Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium



of Potential

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure







Concern







Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area 1

PAHs

























Benzo(a)anthracene

1.4E-05



1.2E-05

2.5E-05

















Benzo(a)pyrene

1.2E-04



9.9E-05

2.1E-04

















Benzo(b)fluoranthene

4.8E-06



4.1E-06

8.8E-06

















Dibenz(a,h)anthracene

2.9E-05



2.5E-05

5.3E-05

















lndeno(1,2,3-cd)pyrene

9.7E-06



8.3E-06

1.8E-05

















Metals

























Arsenic

5.2E-06



1.0E-06

6.2E-06

















Chromium Total

2.1E-06





2.1E-06

















Chemical Total

1.8E-04



1.5E-04

3.3E-04















Exposure Point Total









3.3E-04















Air at Risk Area 1

PAHs

























Benzo(a)anthracene



3.4E-10



3.4E-10

















Benzo(a)pyrene



2.9E-09



2.9E-09

















Benzo(b)fluoranthene



1.2E-10



1.2E-10

















Dibenz(a,h)anthracene



7.9E-10



7.9E-10

















lndeno(1,2,3-cd)pyrene



2.5E-10



2.5E-10

















Metals

























Arsenic



2.5E-09



2.5E-09

















Chromium Total



5.9E-08



5.9E-08

















Chemical Total



6.6E-08



6.6E-08















Exposure Point Total









6.6E-08













Aggregate Soil Tota





3.3E-04





Soil Total





3.3E-04





Total Risk Across All Media 3.3E-04

Total Hazard Across All Media

-------
TABLE G-11A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA G
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Child



Medium

Exposure
Medium

Exposure
Point

Chemical
of Potential
Concern

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal Exposure
| Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal Exposure
| Routes Total

Soil

Surface Soil

Surface Soil at Risk Area G

Metals





I







I

Antimony





...

Blood

1.3



I 13

Chemical Total





... |



1.3



| 13



Exposure Point Total







I 1-3



Surface Soil Total







I 1-3

Soil Total







I 1-3

Total Risk Across All Media

Total Hazard Across All Media	1.3

-------
TABLE G-11B
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Child



Medium

Exposure

Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium



of Potential

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure







Concern







Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil

Surface Soil at Risk Area J

PCBs

























Aroclor-1254









Eyes, Immune system

7.4



2.9

10







Metals

























Chromium Total









None observed

59





59







Nickel









Body weight

1.2





1.2







Chemical Total











68



2.9

71





Exposure Point Total



















71





Air at Risk Area J

PCBs

























Aroclor-1254

























Metals

























Chromium Total









Respiratory tract



0.096



0.096







Nickel









Respiratory tract



0.015



0.015







Chemical Total













0.11



0.11





Exposure Point Total



















0.11



Surface Soil Total









71

Soil Total









71

Total Risk Across All Media

Total Hazard Across All Media

Total Eye HI Across All Media
Total Immune System HI Across All Media
Total Body Weight HI Across All Media
Total Lung/Respiratory Tract HI Across All Media

-------
TABLE G-12A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA G
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Child



Medium

Exposure
Medium

Exposure
Point

Chemical
of Potential
Concern

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal Exposure
| Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal Exposure
| Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area G

Metals





I







I

Antimony





...

Blood

1.3



I 13

Chemical Total





... |



1.3



| 13



Exposure Point Total







I 1-3



Aggregate Soil Total







I 1-3

Soil Total







I 1-3

Total Risk Across All Media

Total Hazard Across All Media	1.3

-------
TABLE G-12B
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Child



Medium

Exposure

Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium



of Potential

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure







Concern







Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area J

PCBs

























Aroclor-1254









Eyes, Immune system

1.5



0.58

2.0







Metals

























Chromium Total









None observed

16





16







Chemical Total











18



0.58

18





Exposure Point Total



















18





Air at Risk Area J

PCBs

























Aroclor-1254

























Metals

























Chromium Total









Respiratory tract



0.026



0.026







Chemical Total













0.026



0.026





Exposure Point Total



















0.026



Aggregate Soil Tota









18

Soil Total









18

Total Risk Across All Media

Total Hazard Across All Media

Total Eye HI Across All Media
Total Immune System HI Across All Media
Total Lung/Respiratory Tract HI Across All Media

-------
TABLE G-13A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Adult



Medium

Exposure 1 Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium

of Potential

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure



|

Concern







Routes Total

Target Organ(s)







Routes Total

Soil

Surface Soil Surface Soil at Risk Area J

Metals





1







1





Chromium Total





...

None observed

6.4



1 64





Chemical Total





|



6.4



| 64



[Exposure Point Total







II -







II 6.4



1 Air at Risk Area J

Metals





1







1





Chromium Total





...

Respiratory tract



0.096

1 0.096





Chemical Total





|





0.096

| 0.096



[[Exposure Point Total



















| 0.096



Surface Soil Total







| 6.5

Soil Total









| 6.5

Total Risk Across All Media

Total Hazard Across All Media
Total Lung/Respiratory Tract HI Across All Media

-------
TABLE G-14A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Resident

Receptor Age: Adult



Medium

Exposure 1 Exposure Point

Chemical

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient



Medium

of Potential

Ingestion

Inhalation

Dermal

Exposure

Primary

Ingestion

Inhalation

Dermal

Exposure



|

Concern







Routes Total

Target Organ(s)







Routes Total

Soil

Aggregate Soil Aggregate Soil at Risk Area J

Metals





1







I





Chromium Total





...

None observed

1.7



I 17





Chemical Total





|



1.7



| 17



[Exposure Point Total







II -







II 17



1 Air at Risk Area J

Metals





1







I





Chromium Total





...

Respiratory tract



0.026

I 0.026





Chemical Total





|





0.026

| 0.026



[[Exposure Point Total



















| 0.026



Aggregate Soil Total







| 1.8

Soil Total









| 1.8

Total Risk Across All Media

Total Hazard Across All Media
Total Lung/Respiratory Tract HI Across All Media

-------
TABLE G-15A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Industrial/Commercial Worker

Receptor Age: Adult



Medium

Exposure
Medium

Exposure Point

Chemical
of Potential
Concern

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Soil

Surface Soil

Surface Soil at Risk Area J

PAHs



















Benzo(a)anthracene
Benzo(a)pyrene
Dibenz(a,h)anthracene

5.7E-07
4.0E-06
1.3E-06



4.9E-07
3.4E-06
1.1E-06

1.1E-06
7.4E-06
2.4E-06











PCBs



















Aroclor-1254

8.0E-06



7.4E-06

1.5E-05











Metals



















Arsenic
Chromium Total

2.5E-06
2.4E-03



5.0E-07

3.0E-06
2.4E-03

None observed

4.5





4.5

Chemical Total

2.5E-03



1.3E-05

2.5E-03



4.5





4.5



Exposure Point Total









2.5E-03









4.5



Air at Risk Area J

PAHs



















Benzo(a)anthracene
Benzo(a)pyrene
Dibenz(a,h)anthracene



1.4E-11
1.0E-10
3.5E-11



1.4E-11
1.0E-10
3.5E-11











PCBs



















Aroclor-1254



3.9E-10



3.9E-10











Metals



















Arsenic
Chromium Total



1.2E-09
6.9E-05



1.2E-09
6.9E-05

Respiratory tract



0.023



0.023

Chemical Total



6.9E-05



6.9E-05





0.023



0.023



Exposure Point Total









6.9E-05









0.023



Surface Soil Total





2.5E-03



4.6

Soil Total





2.5E-03



4.6

Total Risk Across All Media 2.5E-03

Total Hazard Across All Media

4.6

-------
TABLE G-16A
RISK SUMMARY
REASONABLE MAXIMUM EXPOSURE
SCOVILL INDUSTRIAL LANDFILL SITE ¦ RISK AREA J
WATERBURY, CONNECTICUT

Scenario Timeframe:

Future

Receptor Population:

Industrial/Commercial Worker

Receptor Age: Adult



Medium

Exposure
Medium

Exposure Point

Chemical
of Potential
Concern

Carcinogenic Risk

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Primary
Target Organ(s)

Ingestion

Inhalation

Dermal

Exposure
Routes Total

Soil

Aggregate Soil

Aggregate Soil at Risk Area J

Dioxins/Furans



















2,3,7,8-TCDD TEQ

1.5E-06



2.9E-07

1.8E-06











PAHs



















Benzo(a)pyrene
Dibenz(a,h)anthracene

3.1E-06
7.2E-07



2.7E-06
6.2E-07

5.8E-06
1.3E-06











PCBs



















Aroclor-1254

1.6E-06



1.5E-06

3.1E-06











Metals



















Arsenic
Chromium Total

2.5E-06
6.7E-04



4.9E-07

2.9E-06
6.7E-04

None observed

1.2





1.2

Chemical Total

6.8E-04



5.6E-06

6.8E-04



1.2





1.2



Exposure Point Total









6.8E-04









1.2



Air at Risk Area J

Dioxins/Furans



















2,3,7,8-TCDD TEQ



7.3E-11



7.3E-11











PAHs



















Benzo(a)pyrene
Dibenz(a,h)anthracene



7.9E-11
2.0E-11



7.9E-11
2.0E-11











PCBs



















Aroclor-1254



7.7E-11



7.7E-11











Metals



















Arsenic
Chromium Total



1.2E-09
1.9E-05



1.2E-09
1.9E-05

Respiratory tract



0.0063



0.0063

Chemical Total



1.9E-05



1.9E-05





0.0063



0.0063



Exposure Point Total









1.9E-05









0.0063



Aggregate Soil Tota





7.0E-04



1.3

Soil Total





7.0E-04



1.3

Total Risk Across All Media 7.0E-04	Total Hazard Across All Media	1.3

Total Lung/Respiratory Tract HI Across All Media 	0.0063

-------
A
P
P
E
N
D
I

X
E

-------
Table J-1

Chemical-Specific ARARs and TBCs for Soil Alternatives SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year Reviews [PRG
and PMC Exceedances within Areas D1,
E1,F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization), Institutional
Controls, Periodic Assessments, and

Five-Year Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Federal Criteria, Advisories, and Guidance

EPA Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
(EPA/540/G-90/007)

To Be
Considered

This document describes the
recommended approach for developing
remediation goals and selecting remedies
at Superfund sites with PCB
contamination.

This policy would be used when
developing clean up goals within Area J,
an area with PCB contamination in soil.

Under SOI, no action will be taken to
address Area J. Therefore, SOI will not
be consistent with this TBC.

Area J is not included in Alternative S02.
Therefore, this TBC would not be applicable.

Area J is not included in Alternative S03.
Therefore, this TBC would not be applicable.

Area J is not included in Alternative S05.
Therefore, this ARAR would not be
applicable.

EPA Risk Reference Doses

To Be
Considered

A reference dose is an estimated daily oral
exposure to a contaminant by humans that
is unlikely to have an appreciable risk of
non-carcinogenic effects.

The cancer potency factor is used as
qualitative weight-of-evidence judgment as
to the likelihood of a chemical being a
carcinogen.

Reference doses and cancer potency
factors were used to evaluate non-
carcinogenic and carcinogenic health
risks associated with site-related
contaminants, and were used to develop
PRGs.

Reference doses and cancer potency factors
were used to evaluate non-carcinogenic and
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Reference doses and cancer potency factors
were used to evaluate non-carcinogenic and
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Reference doses and cancer potency
factors were used to evaluate non-
carcinogenic and carcinogenic health risks
associated with site-related contaminants,
and were PRGs.

Cancer Slope Factors

To Be
Considered

Slope factors are developed by EPA from
health effects assessments and provide
the most current information on cancer
risks caused by exposure to contaminants.

Cancer slope factors were used to
evaluate carcinogenic health risks
associated with site-related contaminants,
and were used to develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with
site-related contaminants, and were used to
develop PRGs.

Guidelines for Carcinogenic
Risk Assessment,
EPA/630/P-03/001F

To Be
Considered

These guidelines provide guidance on
conducting risk assessments involving
carcinogens.

These guidelines for assessing cancer
risks can also be used to develop PRGs
for carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

Supplemental Guidance for
Assessing Susceptibility from
Early-Life Exposure to
Carcinogens, EPA/630/R-
03/003F

To Be
Considered

These guidelines provide guidance on
conducting risk assessments involving
carcinogens in children.

These guidelines for evaluating cancer
risks in children were also used to
develop PRGs for carcinogens.

These guidelines for evaluating cancer risks in
children were also used to develop PRGs for
carcinogens.

These guidelines for evaluating cancer risks in
children were also used to develop PRGs for
carcinogens.

These guidelines for evaluating cancer risks
in children were also used to develop PRGs
for carcinogens.

EPA Policy Statement on
Role of Background in the
CERCLA Cleanup Program
(OSWER 9285.6-07P)

To Be
Considered

This policy clarifies EPA's preferred
approach in considering background
natural and anthropogenic concentrations
in the remedy selection process.

Background soil chemical concentrations
were considered in the PRGs
development and selection process.

Background soil chemical concentrations were
considered in the PRGs development and
selection process.

Background soil chemical concentrations were
considered in the PRGs development and
selection process.

Background soil chemical concentrations
were considered in the PRGs development
and selection process.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-1

Chemical-Specific ARARs and TBCs for Soil Alternatives SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year Reviews [PRG
and PMC Exceedances within Areas D1,
E1,F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization), Institutional
Controls, Periodic Assessments, and

Five-Year Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

State Criteria, Advisories, and Guidance

Connecticut Remediation
Standard Regulations (RSR)
(22a-133k-1 to22a-133k-3 )

Applicable, if a
response action
is warranted
under CERCLA
and the NCP

These regulations establish allowable
numeric direct exposure criteria (DEC) for
soils and pollutant mobility criteria (PMC)
under residential and commercial/
industrial land use conditions. The RSR
also provide alternative means to assess
and evaluate compliance with regulatory
requirements.

The RSR DECs were considered in the
development of PRGs for Site soil.

SOI will not attain this ARAR because no
actions will be taken to mitigate or
remediate soil contaminants.

The RSR DECs were considered in the
development of PRGs for Site soil.

S02 will attain this ARAR because use
restrictions will prevent potential exposure to
soil contaminants in these Areas if the ICs are
periodically assessed and enforced.

The RSR DECs were considered in the
development of PRGs for Site soil.

S03 will attain this ARAR because soil
contaminated above applicable DECs, PMCs,
or background levels established as PRGs will
be excavated to 4 feet and disposed of off-
site. Use restrictions will prevent excavation
and use of deeper soil and prevent potential
exposure to soil contaminants.

The RSR DECs were considered in the
development of PRGs for Site soil.

S04 will attain this ARAR because soil
contaminated above applicable DECs,
PMCs, or background levels established as
PRGs will be encapsulated in-situ. Use
restrictions will prevent excavation and use
of deeper soil and prevent exposure to soil
contaminants.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-2

Location-Specific ARARs and TBCs for Soil Alternatives SOI - S04
Scovill Industrial Landfill Site
Waterbury, Connecticut

REQUIREMENT

STATUS

REQUIREMENT SYNOPSIS

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional
Controls, Periodic Assessments,
and Five-Year Reviews [Areas D3,
E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year Reviews
[PRG and PMC Exceedances within
Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year Reviews
[PRG and PMC Exceedances within
Areas D1, E1, F]

Federal Criteria, Advisories, and Guidance

Protection of
Wetlands (Executive
Order 11990)
Statement of
Procedures on
Floodplain
Management and
Wetland Protection
(June 5, 1979)

To Be
Considered

Federal agencies are required to avoid adversely
impacting wetlands unless there is no practicable
alternative and the proposed action includes all
practicable measures to minimize harm to
wetlands that may result from such use.

Not applicable. No action will be
implemented under SOI.

Not applicable. There are no wetlands
in Areas D3, E2, E3, G, and H.

Not applicable. There are no wetlands in
Areas D1, E1, and F.

Not applicable. There are no wetlands in
Areas D1, E1, and F.

Clean Water Act (33
U.S.C. 1251 etseq.y,
Section 404,
Compensatory
Mitigation for Losses
of Aquatic
Resources (40 CFR
230)

Applicable, if

wetland

impacted

Outlines requirements for the discharge of
dredged or fill materials into surface waters
including wetlands. Such discharges are not
allowed if there are practicable alternatives with
less adverse impacts. Sets standards for
restoration and mitigation required as a result of
unavoidable impacts to aquatic resources.

Not applicable. No action will be
implemented under SOI.

Not applicable. There are no wetlands
in Areas D3, E2, E3, G, and H.

Not applicable. There are no wetlands in
Areas D1, E1, and F.

Not applicable. There are no wetlands in
Areas D1, E1, and F.

National Historic
Preservation Act
(NHPA)

(16 U.S.C. 470)

Applicable, if
such

resources are
identified

Pursuant to Sections 106 and 110(f) of the NHPA,
as amended, CERCLA response actions are
required to take into account the effects of the
response activities on any historic property
included or eligible for inclusion on the National
Register of Historic Places.

Not applicable. No action will be
implemented.

If significant historic properties
(including prehistoric or
archaeological) are identified, then the
requirements of these regulations will
be followed. S02 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. S03 will
comply with this ARAR.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. S04 will
comply with this ARAR.

State Criteria, Advisories, and Guidance

Connecticut
Environmental
Protection Act
(Public Act 82-367)

Applicable, if
such

resources are
identified

This regulation directs that the provisions of CGS
Sections 22a-15 through 22a-19, inclusive of the
Connecticut Environmental Protection Act, shall
also be applicable to historic structures and
landmarks, and are defined as those properties
that are listed or under consideration for listing as
individual units on the National Register of
Historic Places or which are part of a district listed
or under consideration for listing determined by
the State Historic Preservation Board.

Not applicable. No action will be
implemented.

If significant historic properties
(including prehistoric or
archaeological) are identified, then the
requirements of these regulations will
be followed. S02 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. S03 will
comply with this ARAR.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. S04 will
comply with this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Federal Criteria, Advisories, and Guidance

TSCA - PCB
Storage, Capping
and Disposal
(40 CFR 761.61)

Applicable

These regulations establish standards for the
storage, decontamination, capping, and
response to PCB remediation waste.

Not applicable. Because no action will
be performed under SOI, handling of
PCB remediation waste will not be
required.

PCB contaminated soil in Area J is not
addressed by Alternative S02.
Therefore, this ARAR would not be
applicable.

PCB contaminated soil in Area J is not
addressed by Alternative S03.
Therefore, this ARAR would not be
applicable.

PCB contaminated soil in Area J is not
addressed by Alternative S04.
Therefore, this ARAR would not be
applicable.

Clean Water Act

NPDES

Regulations

(Stormwater

Discharges)

(40 CFR
122.26(c)(ii)(C))

Applicable

Discharges of stormwater associated with
construction activities affecting one acre or
more are required to implement measures,
including best management practices, to control
pollutants in stormwater discharges during and
after construction activities.

Not applicable. No action will be
implemented under SOI.

Not applicable. S02 involves use
restrictions and no active remediation.

The targeted excavations of S03 will be
designed and implemented to comply
with the substantive provisions of the
construction general permit for
stormwater requirements, such as best
management practices.

The in-situ physical treatment of S04
will be designed and implemented to
comply with the substantive provisions
of the construction general permit for
stormwater requirements, such as best
management practices.

Invasive Species
(Executive Order
13112)

To Be
Considered

Federal agencies are directed to prevent the
introduction of invasive species and provide for
their control and to minimize the economic,
ecological, and human health impacts that
invasive species cause when requiring actions
that impact the environment.

Not applicable. No action will be
implemented under SOI.

Not applicable. No active remediation
activities that will affect the environment
are anticipated for Areas D3, E2, E3, G,
and H under S02.

The targeted remediation under S03 is
unlikely to result in the introduction of
invasive species in Areas D1, E1, F.
However, appropriate measures will be
taken to prevent and minimize
unintentional impacts.

The targeted in-situ remediation under
S03 is unlikely to result in the
introduction of invasive species in
Areas D1, E1, F. However,
appropriate measures will be taken to
prevent and minimize unintentional
impacts.

Polychlorinated
Biphenyl (PCB) Site
Revitalization
Guidance Under
the Toxic

Substances Control
Act (TSCA), US
EPA Nov. 2005

To Be
Considered

This EPA guidance provides information on
characterizing, cleaning up, containing, and
disposing of PCB waste (for example, soil and
other debris generated as a result of any PCB
spill cleanup). The guidance provides
directions for compliance with 40 CFR Part 761.

Not applicable. No action will be
implemented under SOI.

Not applicable. PCBs are not COCs for
Areas D3, E2, E3, G, and H.

Not applicable. PCBs are not COCs for
Areas D1, E1, and F.

Not applicable. PCBs are not COCs for
Areas D1, E1, and F.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

State Criteria, Advisories, and Guidance

Reporting of
Certain Significant
Environmental
Hazards by Owners
of Contaminated
Real Property (CGS
§22a-6u)

Applicable

After Oct. 1, 1998, when certain conditions
described in the regulation are encountered by
a technical environmental professional
collecting soil, water, vapor or air samples for
the purposes of investigating or remediating
sources of pollution to the waters of the State,
certain notifications to the property owner, the
client, the Commissioner, and in some cases,
the local fire department are required. The
property owner may have to post the notice
onsite if certain activities are undertaken onsite.
Information is available from
httD://www.ct.aov/deeD/cwD/view.asD?a=2715&
a=324976&deDNav GID=1626..

Not applicable. No action will be
implemented under SOI.

Not applicable. S02 involves use
restrictions and no construction.
Therefore, this ARAR is not applicable.

During S03 implementation, if polluted
groundwater, soil, or soil vapor is
encountered that meet certain
conditions, the appropriate parties will
be notified. S03 will comply with this
ARAR.

During S04 implementation, if polluted
groundwater, soil, or soil vapor is
encountered that meet certain
conditions, the appropriate parties will
be notified. S03 will comply with this
ARAR.

Report of
Discharge, Spill,
Loss, Seepage,or
Filtration (CGS
§22a-450)

Applicable

Requires reporting of spills to DEEP.

Information is available at
httD://www.ct.aov/deeD/cwD/view.asD?A=2692&
Q=322584.

Not applicable. No action will be
implemented under SOI.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous
waste occurs during S02 implementation,
S02 will comply with the reporting and
notification requirements of this ARAR.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous
waste occurs during S03
implementation, S03 will comply with
the reporting and notification
requirements of this ARAR.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous
waste occurs during S04
implementation, S04 will comply with
the reporting and notification
requirements of this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 3 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Hazardous Waste
Management:
Generator &
Handler

Requirements -
General Standards,
Listing, and
Identification

(RCSA 22a-
449(c) 100-101)

Applicable, if
hazardous
waste is
generated

These sections establish standards for listing
and identification of hazardous waste. The
standards of 40 CFR 260-261 are incorporated
by reference. Chromium is not exempted from
listing as a hazardous waste..

Not applicable. No action will be
implemented under SOI.

Not applicable. Under S02, periodic
assessments and evaluations will not
result in generation of investigation-
derived waste.

Prior to off-site disposal, excavated
contaminated soil will undergo testing
for RCRA characteristics to determine
the appropriate waste classification and
disposal options. S03 will comply with
this ARAR

S04 may result in the generation of
unused reagents that require disposal.
These materials will be tested for RCRA
characteristics to determine the
appropriate waste classification and
disposal options. S04 will comply with
this ARAR.

Hazardous Waste
Management:
Generator
Standards
(RCSA 22a-
449(c) 102)

Applicable, if
hazardous
waste is
generated

This section establishes standards for various
classes of generators. The standards of 40
CFR 262 are incorporated by reference.
Storage requirements given at 40 CFR 265.15
are also included. These regulations govern
manifesting, packaging, labeling, marking,
placarding, record keeping and reporting
requirements.

Not applicable. No action will be
implemented under SOI.

Not applicable. No hazardous wastes
expected to be generated.

S03 will comply with the substantive
provisions of these requirements during
the temporary storage of excavated
soils which constitute hazardous
wastes, prior to off-site disposal.

S04 may result in the generation of
unused reagents that require disposal.
S04 will comply with the substantive
provisions of these requirements during
the temporary storage of excess
materials which constitute hazardous
wastes, prior to off-site disposal.

Hazardous Waste
Management:
Management
Standards for
Specific Waste
Types (RCSA
§22a-449(c)106)

Applicable, if
the specific
hazardous
wastes are
identified

This section establishes standards for specific
types of wastes, including waste oil and spent
lead acid batteries being reclaimed. The
standards of 40 CFR §266 are incorporated by
reference. .

Not applicable. No action will be
implemented under SOI.

Not applicable. No hazardous wastes
expected to be generated.

If the specific wastes identified in this
ARAR are found, S03 will comply with
this ARAR's requirements in the
handling and management of the
wastes.

If the specific wastes identified in this
ARAR are found. S04 will comply with
this ARAR's requirements in the
handling and management of the
wastes.

Solid Waste
Management
(RCSA §§22a-209-
1 to 16)

Relevant and
Appropriate, if
solid waste is
disposed.

These standards establish operating and
closure standards for solid waste disposal
areas including closure, post-closure, and
groundwater monitoring requirements. Note
that the definition of Solid Waste is given in
CGS §22a-207. See

httD://www.caa.ct.aov/2011/Dub/chao446d.htm.
Solid Waste Regulations are available at
httD://www.ct.aov/deeD/lib/deeD/reaulations/22a
/22a-209-1throuah16.Ddf

Not applicable. No action will be
implemented under SOI.

Not applicable. No active remediation
will be implemented under S02.

Not applicable. On-site solid waste
disposal will not occur under S03.

Not applicable. On-site solid waste
disposal will not occur under S04.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 4 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

General Permit for
Contaminated Soil
and/or Sediment
Management
(Staging and
Transfer)(DEP-SW-
GP-001) CGS §
22a-208a(1))

Applicable

The substantive requirements of this permit
must be meet. Fact sheet is available at
httD://www.ct.aov/deeD/cwD/view.asD?a=2709&
a=329620&deDNav GID=1646

Not applicable. No action will be
implemented under SOI.

Not applicable. No active remediation will
be performed under S02.

S03 will comply with the substantive
requirements of this ARAR during
active remediation that result in
excavation, handling, and storage of
contaminated soil. As needed,
stockpile controls, erosion and dust
controls, and access will be limited.

S04 will comply with the substantive
requirements of this ARAR during
active remediation that result in
excavation, handling, and storage of
contaminated soil. As needed,
stockpile controls, erosion and dust
controls, and access will be limited.

httD://www.ct.aov/deeD/lib/deeD/Permits and Li
censes/Factsheets Waste/soilstaaina fs.odf.

Registration is required dependent on volume
to be managed (>1000 CY, > 10,000 CY, or
exceeds 45 day duration).

General conditions include control of stockpiles,
erosion and dust control, characterization, etc.

General Permits
(for various
activities)

Applicable

Substantive requirements of the general
permits must be attained, The General Permit
Program Fact Sheet (DEEP-FS-004) is
available from the following web
Daae:httD://www.ct.aov/deeD/cwD/view.asD?a=2
709&a=324154&deDNav GID=1643#SoilStaain

Not applicable. No action will be
implemented under SOI.

Not applicable. No active remediation will
be performed under S02.

As appropriate, S03 will comply with
the substantive requirements of this
ARAR during active remediation.

As appropriate, S05 will comply with
the substantive requirements of this
ARAR during active remediation.

a-

The following General Permit relates to
remedial actions at the Site:

• Stormwater and Dewaterina

Wastewaters from Construction

Activities fDEEP-PERD-GP-015^

Temporary
Authorization
(TA)/Emergency
Authorization (EA)
(CGS 22a-6K)

Applicable

This statute a temporary or emergency
authorization, under certain condition, for many
activities that require a permit. The substantive
requirements of a TA must be met. Temporary
Authorization (TA)/ Emeraencv Authorization

Not applicable. No action will be
implemented under SOI.

Not applicable. No active remediation will
be performed under S02.

If during remedial action
implementation an emergency
discharge to groundwater, surface
water, or a sanitary sewer is required,
S03 will comply with the substantive
requirements of this ARAR.

If during remedial action implementation
an emergency discharge to
groundwater, surface water, or a
sanitary sewer is required, S04 will
comply with the substantive
requirements of this ARAR.

(EA) for In-situ Remediation

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 5 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Disposition of PCBs
CGS §22a-463
through 469.
Disposition of PCB
regulated by 22a-
467

Applicable

This statute requires that PCBs be disposed of
in a manner consistent with TSCA
requirements.

Not Applicable. No action will be
implemented under SOI.

Not applicable. PCBs are not COCs for
Areas D3, E2, E3, G, and H.

Not applicable. PCBs are not COCs for
Areas D1, E1, and F.

Not applicable. PCBs are not COCs for
Areas D1, E1, and F.

Control of Noise
(RSCA Section
22a-69-1 to 69-7.4)

Applicable

These Regulations establish allowable noise
levels for different classes of noise zones and
would apply to construction activities at a site.

Not applicable. No action will be
implemented under SOI.

Not applicable. S02 involves no
construction activities. Therefore, this
ARAR is not applicable.

During S03 implementation, noise
levels will be monitored and S03 will
comply with the allowable noise levels
defined in this ARAR.

During S04 implementation, noise
levels will be monitored and S04 will
comply with the allowable noise levels
defined in this ARAR.

Water Pollution
Control -

Regulations (RCSA
§§22a-430-1 to 8,
& CGS §§22a-430)

Applicable

These regulations establish permitting
requirements and criteria for water discharge to
groundwater.

httD://www.ct.aov/deeD/lib/deeD/reaulations/22a
/22a-430-1and2.Ddf.

httD://www.ct.aov/deeD/lib/deeD/reaulations/22a
/22a-430-3and4.Ddf.

httD://www.ct.aov/deeD/lib/deeD/reaulations/22a
/22a-430-6and7.Ddf.

httD://www.ct.aov/deeD/lib/deeD/reaulations/22a
/22a-430-8.Ddf.

Not applicable. No action will be
implemented under SOI.

Not applicable. Under S02, no discharge
of water is anticipated.

Discharges of water to ground or
surface water is not expected as part of
S03, Should discharge of water to
groundwater be required during
implementation, the substantive
requirements of this ARAR will be met.

The injection of stabilization materials
into soil, which has the potential to
affect groundwater is treated as a
discharge to groundwater. The
substantive requirements of this ARAR
will be met.

Air Pollution Control
- Control of
Particulate
Emissions (Sec.
22a-174-18)

Applicable

This subsection sets specific standards for
particulate emissions. Specific standards
include Fugitive Particulate Matter (18c).

See

httD://www.ct.aov/deeD/lib/deeD/air/reaulations/
mainreas/sec18.Ddf.

Reasonable precautions must be taken to
prevent particulate matter from becoming
airborne during demolition and construction
activities and material handling operations.

Not applicable. No action will be
implemented under SOI.

Not applicable. Periodic assessments
and site evaluations will not result in
fugitive dust generation under S02.

Air monitoring and best engineering
practices will be employed to minimize
fugitive dust emissions during targeted
excavations. S03 will comply with this
ARAR.

Air monitoring and best engineering
practices will be employed to minimize
fugitive dust emissions during in-situ
physical treatment (solidification/
stabilization) using heavy equipment
and large-diameter augers. S04 will
comply with this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 6 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Air Pollution
Control-Control of
Odors (RCSA
§22a-174-23)

Applicable

This section prohibits emission of any
substance that constitutes a nuisance because
of objectionable odor.

See

httD://www.ct.aov/deeD/lib/deeD/air/reaulations/
mainreas/sec23.Ddf

Not applicable. No action will be
implemented under SOI.

Assessment activities are unlikely to
generate odors under S02. However
should odors be generated, appropriate
measures will be taken to mitigate the
conditions.

If odors are generated during the
implementation of S03, appropriate
measures (covering, source removal,
dilution) will be taken to mitigate the
conditions.

If odors are generated during the
implementation of S04, appropriate
measures (covering, source removal,
dilution) will be taken to mitigate the
conditions.

Well Drilling (CGS
§§ 25-126 through
137)

Applicable, if
wells are
drilled or
abandoned

Peizometers, containment recovery wells and
monitoring wells are included in the definition of
(and regulated as) as "non-water supply wells".
Well drillers must be registered, and the driller
must file a completion report for non-water
supply wells. Pursuant to CGS §25-131 (c).

See

httD://www.caa.ct.aov/2011/Dub/chao482.htm#
Sec25-126.htm and

httD://www.ct.aov/dcD/lib/dcD/Ddf/well drillina r
eaulations.odf

Not applicable. No action will be
implemented under SOI.

If monitoring wells are installed or
abandoned, S02 will comply with the
substantive requirements of this ARAR.

If monitoring wells are installed or
abandoned, S03 will comply with the
substantive requirements of this ARAR.

If monitoring wells are installed or
abandoned, S04 will comply with the
substantive requirements of this ARAR.

MA-3767-2013

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 7 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

Regulations for the
Well Drilling
Industry (RCSA
§25-128-33 through
64)

Applicable, if
wells are
drilled or
abandoned

Non-water supply wells must be constructed so
that they are not a source or cause of
groundwater contamination. Procedures for
abandonment of wells apply to both water wells
and other types of wells.
httD://www.ct.aov/dcD/lib/dcD/Ddf/well drillina r
eaulations.Ddf

Not applicable. No action will be
implemented under SOI.

If monitoring wells are installed or
abandoned, S02 will comply with the
requirements of this ARAR.

If monitoring wells are installed or
abandoned, S03 will comply with the
requirements of this ARAR.

If monitoring wells are installed or
abandoned, S04 will comply with the
requirements of this ARAR.

CT Guidelines for
Soil Erosion and
Sediment Control
(May 2002)
(adopted pursuant
to CGS 22a-328)

Revised document
issued May 2002,
also identified as
DEP Bulletin 34

To Be
Considered

The Guidelines provide technical and
administrative guidance for the development,
adoption, and implementation of erosion and
sediment control programs.

The Guidelines are available electronically in 4
parts (from

httD://www.ct.aov/deeD/cwD/view.asD?a=2720&
a=325660&deDNav GID=1654 ) as listed

Not applicable.

Not applicable.

S03 will use best management
practices to be consistent with these
guidelines during the targeted
excavations and storage and handling
of excavated contaminated soil.

S04 will use best management
practices to be consistent with these
guidelines when using heavy equipment
to implement in-situ remediation.

below:

httD://www.ct.aov/deeD/lib/deeD/water inland/se
sc/sesc intra toc.odf

httD://www.ct.aov/deeD/lib/deeD/water inland/se
sc/secs chaDter 1 5.Ddf
httD://www.ct.aov/deeD/lib/deeD/water inland/se
sc/secs aDDendix a k.Ddf

httD://www.ct.aov/deeD/lib/deeD/water inland/se
sc/secs aDDendix I m.Ddf.















MA-3767-2013

Nobis Engineering, Inc.

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Table J-3

Action-Specific ARARs and TBCs for Soil Alternatives for SOI to S04
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 8 of 8

Requirement

Status

Requirement Synopsis

ALTERNATIVE SOI
No Action

ALTERNATIVE S02
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas D3, E2, E3, G, and H]

ALTERNATIVE S03
Targeted Remediation (Targeted
Excavation and Off-site Disposal),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

ALTERNATIVE S04
Targeted In-Situ Physical Treatment
(Solidification/Stabilization),
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [PRG and PMC
Exceedances within Areas D1, E1, F]

CT DEEP Final Site

Characterization

Guidance

Document,

September 2007,

revised December

2010

To Be
Considered

This provides guidance to persons preparing
environmental site assessments of potentially
contaminated properties. The Final Site
Characterization Guidance Document is
available at

httD://www.ct.aov/deeD/lib/deeD/site clean ud/o
uidance/Site Characterization/Final SCGD.Ddf

Not applicable.

Not applicable. No characterization will be
performed under S02.

For designing and implementing PDIs.
S03 will consider the guidance.

For designing and implementing PDIs.
S04 will consider the guidance.

Guidance for
Groundwater
Monitoring for
Demonstrating
Compliance with
the Connecticut
Remediation
Standard
Regulations ,
3/17/2006

To Be
Considered

httD://www.ct.aov/deeD/lib/deeD/site clean up/a
uidance/awm auidance for demonstrating co
moliance with ct rsr.odf

Not applicable.

Not applicable. No sampling will be
performed.

As appropriate, relevant groundwater
monitoring guidance will be consulted.

As appropriate, groundwater monitoring
guidance will be consulted.

Guidance for
Collecting
and Preserving Soil
and Sediment
Samples for
Laboratory
Determination of
Volatile Organic
Compounds, Final
2/28/2006

To Be
Considered

The Guidance document is available at:

httD://www.ct.aov/deeD/lib/deeD/site clean ud/o
uidance/soil samDlina voc final wcomments.D
df.

Not applicable.

If sampling is performed understate
oversight during O&M, this guidance will
be followed.

If sampling is performed understate
oversight during O&M, this guidance
will be followed.

If sampling is performed understate
oversight during O&M, this guidance
will be followed.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-4

Chemical-Specific ARARs and TBCs for Soil Alternatives S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and Off-
site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

Federal Criteria, Advisories, and Guidance

EPA Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
(EPA/540/G-90/007)

To Be
Considered

This document describes the
recommended approach for developing
remediation goals and selecting remedies
at Superfund sites with PCB
contamination.

This policy would be used when
developing clean up goals within Area J,
an area with PCB contamination in soil.

This TBC was considered when
establishing soil Preliminary Remediation
Goals (PRGs) for PCBs. S05 will be
consistent with this TBC because the
excavation to be conducted in Area J will
decrease PCB contaminant levels to the
PRG, which will be protective of human
health.

This policy would be used when developing
clean up goals within Area J, an area with PCB
contamination in soil.

This TBC was considered when establishing
soil Preliminary Remediation Goals (PRGs) for
PCBs. S06 will be consistent with this TBC
because the excavation to be conducted in
Area J will decrease PCB contaminant levels to
the PRG, which will be protective of human
health.

This policy would be used when developing
clean up goals within Area J, an area with
PCB contamination in soil.

This TBC was considered when establishing
soil Preliminary Remediation Goals (PRGs) for
PCBs. S07 will be consistent with this TBC
because the excavation to be conducted in
Area J will decrease PCB contaminant levels
to the PRG, which will be protective of human
health.

Area J is not included in Alternative S08.
Therefore, this ARAR would not be
applicable.

EPA Risk Reference Doses

To Be
Considered

A reference dose is an estimated daily oral
exposure to a contaminant by humans that
is unlikely to have an appreciable risk of
non-carcinogenic effects.

The cancer potency factor is used as
qualitative weight-of-evidence judgment as
to the likelihood of a chemical being a
carcinogen.

Reference doses and cancer potency
factors were used to evaluate non-
carcinogenic and carcinogenic health
risks associated with site-related
contaminants, and were used to develop
PRGs.

Reference doses and cancer potency factors
were used to evaluate non-carcinogenic and
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Reference doses and cancer potency factors
were used to evaluate non-carcinogenic and
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Reference doses and cancer potency
factors were used to evaluate non-
carcinogenic and carcinogenic health risks
associated with site-related contaminants,
and were PRGs.

Cancer Slope Factors

To Be
Considered

Slope factors are developed by EPA from
health effects assessments and provide
the most current information on cancer
risks caused by exposure to contaminants.

Cancer slope factors were used to
evaluate carcinogenic health risks
associated with site-related contaminants,
and were used to develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with site-
related contaminants, and were used to
develop PRGs.

Cancer slope factors were used to evaluate
carcinogenic health risks associated with
site-related contaminants, and were used to
develop PRGs.

Guidelines for Carcinogenic
Risk Assessment,
EPA/630/P-03/001F

To Be
Considered

These guidelines provide guidance on
conducting risk assessments involving
carcinogens.

These guidelines for assessing cancer
risks can also be used to develop PRGs
for carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

These guidelines for assessing cancer risks
can also be used to develop PRGs for
carcinogens.

Supplemental Guidance for
Assessing Susceptibility
from Early-Life Exposure to
Carcinogens, EPA/630/R-
03/003F

To Be
Considered

These guidelines provide guidance on
conducting risk assessments involving
carcinogens in children.

These guidelines for evaluating cancer
risks in children were also used to
develop PRGs for carcinogens.

These guidelines for evaluating cancer risks in
children were also used to develop PRGs for
carcinogens.

These guidelines for evaluating cancer risks in
children were also used to develop PRGs for
carcinogens.

These guidelines for evaluating cancer risks
in children were also used to develop PRGs
for carcinogens.

EPA Policy Statement on
Role of Background in the
CERCLA Cleanup Program
(OSWER 9285.6-07P)

To Be
Considered

This policy clarifies EPA's preferred
approach in considering background
natural and anthropogenic concentrations
in the remedy selection process.

Background soil chemical concentrations
were considered in the PRGs
development and selection process.

Background soil chemical concentrations were
considered in the PRGs development and
selection process.

Background soil chemical concentrations were
considered in the PRGs development and
selection process.

Background soil chemical concentrations
were considered in the PRGs development
and selection process.

MA-3767-2013

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Table J-4

Chemical-Specific ARARs and TBCs for Soil Alternatives S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and Off-
site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

State Criteria, Advisories, and Guidance

Connecticut Remediation
Standard Regulations (RSR)
(22a-133k-1 to22a-133k-3 )

Applicable, if a
response action
is warranted
under CERLCA
and the NCP.

These regulations establish allowable
numeric direct exposure criteria (DEC) for
soils under residential and commercial/
industrial land use conditions. The RSR
also provide alternative means to assess
and evaluate compliance with regulatory
requirements.

The RSR DECs were considered in the
development of PRGs for Site soil.

S05 will attain this ARAR because soil
contaminated above applicable DECs,
PMCs, or background levels established
as PRGs will be excavated to 4 feet and
disposed of off-site. Use restrictions will
prevent excavation and use of deeper soil
and prevent potential exposure to soil
contaminants.

The RSR DECs were considered in the
development of PRGs for Site soil.

S06 will attain this ARAR because soil

contaminated above applicable DECs, PMCs,

or background levels established as PRGs will

be covered for with a soil cap. .. ....

... . .. ^ Use restrictions
will prevent excavation and use of deeper son

and prevent potential exposure to soil

contaminants.

The RSR DECs were considered in the
development of PRGs for Site soil.

S07 will attain this ARAR because soil
contaminated above applicable DECs, PMCs,
or background levels established as PRGs will
be excavated to 4 feet and disposed of off site.
Use restrictions will prevent excavation and
use of deeper soil and prevent potential
exposure to soil contaminants.

The RSR DECs were considered in the
development of PRGs for Site soil.

S08 will attain this ARAR because soil
contaminated above applicable DECs,
PMCs, or background levels established as
PRGs will be excavated to 2 or 4 feet and
disposed of off site. Use restrictions will
prevent excavation and use of deeper soil
and prevent potential exposure to soil
contaminants.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-5

Location-Specific ARARs and TBCs for Soil Alternatives S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and Off-
site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations,
Excavation and Off-site Disposal,
Institutional Controls, Periodic
Assessments, and Five-Year
Reviews [Area I]

Federal Criteria, Advisories, and Guidance

Protection of Wetlands
(Executive Order
11990) Statement of
Procedures on
Floodplain
Management and
Wetland Protection
(June 5, 1979)

To Be
Considered

Federal agencies are required to avoid adversely
impacting wetlands unless there is no practicable
alternative and the proposed action includes all
practicable measures to minimize harm to wetlands
that may result from such use.

Wetlands have been identified in Area J.

During the implementation of S05, erosion
and sediment controls and other actions will
be taken to minimize the potential impacts to
the wetlands. Alternative S05 will comply
with this ARAR.

Wetlands have been identified in Area J.

During the implementation of S06, erosion
and sediment controls and other actions will
be taken to minimize the potential impacts to
the wetlands. Alternative S06 will comply
with this ARAR.

Wetlands have been identified in Area J.

During the implementation of S07, erosion
and sediment controls and other actions will
be taken to minimize the potential impacts to
the wetlands. Alternative S07 will comply
with this ARAR.

There are no wetlands in Area I. This
ARAR is not applicable.

Clean Water Act (33
U.S.C. 1251 etseq.)]
Section 404,
Compensatory
Mitigation for Losses of
Aquatic Resources (40
CFR230)

Applicable, if

wetland

impacted

Outlines requirements for the discharge of dredged
or fill materials into surface waters including
wetlands. Such discharges are not allowed if there
are practicable alternatives with less adverse
impacts. Sets standards for restoration and
mitigation required as a result of unavoidable
impacts to aquatic resources.

It is not expected that discharges of dredged
or fill material will occur in wetlands at Area
J; however, if during PDI it is determined that
discharges of dredged or fill material into
wetlands are unavoidable, mitigation will be
performed.

It is not expected that discharges of dredged
or fill material will occur in wetlands at Area J
as part of S06; however, if during PDI it is
determined that discharges of dredged or fill
material into wetlands are unavoidable,
mitigation will be performed. Alternative
S06 is the least environmentally damaging
practicable alternative that achieves the
remedial action objectives. Alternative S06
will comply with this ARAR.

It is not expected that discharges of dredged
or fill material will occur in wetlands at Area J
as part of S07; however, iff during PDI it is
determined that discharges of dredged or fill
material into wetlands are unavoidable,
mitigation will be performed.

There are no wetlands in Area I. This
ARAR is not applicable.

National Historic
Preservation Act
(NHPA)

(16 U.S.C. 470)

Applicable, if
such resources
are identified

Pursuant to Sections 106 and 110(f) of the NHPA,
as amended, CERCLA response actions are
required to take into account the effects of the
response activities on any historic property included
or eligible for inclusion on the National Register of
Historic Places.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations
will be followed. S05 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations
will be followed. S06 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations will
be followed. S07 will comply with this ARAR.

If significant historic properties
(including prehistoric or archaeological)
are identified, then the requirements of
these regulations will be followed. S08
will comply with this ARAR.

State Criteria, Advisories, and Guidance

Connecticut
Environmental
Protection Act (Public
Act 82-367)

Applicable, if
such resources
are identified

This regulation directs that the provisions of CGS
Sections 22a-15 through 22a-19, inclusive of the
Connecticut Environmental Protection Act, shall
also be applicable to historic structures and
landmarks, and are defined as those properties that
are listed or under consideration for listing as
individual units on the National Register of Historic
Places or which are part of a district listed or under
consideration for listing determined by the State
Historic Preservation Board.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations
will be followed. S05 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations
will be followed. S06 will comply with this
ARAR.

If significant historic properties (including
prehistoric or archaeological) are identified,
then the requirements of these regulations will
be followed. S07 will comply with this ARAR.

If significant historic properties
(including prehistoric or archaeological)
are identified, then the requirements of
these regulations will be followed. S08
will comply with this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

Federal Criteria, Advisories, and Guidance

TSCA - PCB Storage,
Capping and Disposal
(40 CFR 761.61)

Applicable

These regulations establish standards for the
storage, decontamination, capping, and response to
PCB remediation waste.

S05 will comply with this ARAR during
excavations, decontamination, and off-site
disposal of PCB-contaminated soil (>25 mg/Kg)
in Area J.

S06 will comply with this ARAR during
excavations, capping, decontamination, and
off-site disposal of PCB-contaminated soil
(>25 mg/Kg) in Area J.

S07 will comply with this ARAR during
targeted excavations, decontamination, and
off-site disposal of PCB-contaminated soil
(>25 mg/Kg) in Area J.

Not applicable. PCBs not a COC for
Area I.

Clean Water Act

NPDES Regulations

(Stormwater

Discharges)

(40 CFR

122.26(c)(ii)(C))

Relevant and
Appropriate

Discharges of stormwater associated with
construction activities affecting one acre or more are
required to implement measures, including best
management practices, to control pollutants in
stormwater discharges during and after construction
activities.

The excavations of S05 will be designed and
implemented to comply with the substantive
provisions of the construction general permit for
stormwater requirements, such as best
management practices.

The excavations of S06 will be designed and
implemented to comply with the substantive
provisions of the construction general permit
for stormwater requirements, such as best
management practices.

The excavations of S07 will be designed and
implemented to comply with the substantive
provisions of the construction general permit
for stormwater requirements, such as best
management practices.

The excavations of S08 will be designed
and implemented to comply with the
substantive provisions of the
construction general permit for
stormwater requirements, such as best
management practices.

Invasive Species
(Executive Order
13112)

Relevant and
Appropriate

Federal agencies are directed to prevent the
introduction of invasive species and provide for their
control and to minimize the economic, ecological,
and human health impacts that invasive species
cause when requiring actions that impact the
environment.

Wetlands have been identified in Area J.

During the implementation of S05, actions will
be taken to prevent and minimize the
introduction of invasive species in the wetlands.
Alternative S05 will comply with this ARAR.

Wetlands have been identified in Area J.
During the implementation of S06, actions will
be taken to prevent and minimize the
introduction of invasive species in the
wetlands. Alternative S06 will comply with
this ARAR.

Wetlands have been identified in Area J.
During the implementation of S07, actions
will be taken to prevent and minimize the
introduction of invasive species in the
wetlands. Alternative S07 will comply with
this ARAR.

The excavations under S08 are unlikely
to result in the introduction of invasive
species in Area I. However,
appropriate measures will be taken to
prevent and minimize unintentional
impacts.

Polychlorinated
Biphenyl (PCB) Site
Revitalization
Guidance Under the
Toxic Substances
Control Act (TSCA),
US EPA Nov. 2005

To Be
Considered

This EPA guidance provides information on
characterizing, cleaning up, containing, and
disposing of PCB waste (for example, soil and other
debris generated as a result of any PCB spill
cleanup). The guidance provides directions for
compliance with 40 CFR Part 761.

Under S05, PCB-contaminated soils that are
excavated will be characterized and addressed
consistent with this Guidance.

Under S06, PCB-contaminated soils that are
excavated will be characterized and
addressed consistent with this Guidance.

Under S07, PCB-contaminated soils that are
excavated will be characterized and
addressed consistent with this Guidance.

Not applicable. PCBs not a COC for
Area I.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

State Criteria, Advisories, and Guidance

Disposition of PCBs
CGS §22a-463
through 469.
Disposition of PCB
regulated by 22a-467

Applicable

This statute requires that PCBs be disposed of in a
manner consistent with TSCA requirements.

Under S05, PCB-contaminated soils that are
excavated will be characterized and addressed
in accordance with this ARAR.

Under S06, PCB-contaminated soils that are
excavated will be characterized and
addressed in accordance with this ARAR.

Under S07, PCB-contaminated soils that are
excavated will be characterized and
addressed in accordance with this ARAR.

Not applicable. PCBs not a COC for
Area I.

Reporting of Certain
Significant
Environmental
Hazards by Owners
of Contaminated Real
Property (CGS §22a-
6u)

Applicable

After Oct. 1, 1998, when certain conditions described
in the regulation are encountered by a technical
environmental professional collecting soil, water,
vapor or air samples for the purposes of investigating
or remediating sources of pollution to the waters of
the State, certain notifications to the property owner,
the client, the Commissioner, and in some cases, the
local fire department are required. The property
owner may have to post the notice onsite if certain
activities are undertaken onsite. Information is
available from

httD://www.ct.aov/deeD/cwD/view.asD?a=2715&a=32
4976&deDNav GID=1626.

During S05 implementation, if polluted
groundwater, soil, or soil vapor is encountered
that meet certain conditions, the appropriate
parties will be notified. S05 will comply with
this ARAR.

During S06 implementation, if polluted
groundwater, soil, or soil vapor is encountered
that meet certain conditions, the appropriate
parties will be notified. S06 will comply with
this ARAR.

During S07 implementation, if polluted
groundwater, soil, or soil vapor is
encountered that meet certain conditions, the
appropriate parties will be notified. S07 will
comply with this ARAR.

During S087 implementation, if polluted
groundwater, soil, or soil vapor is
encountered that meet certain
conditions, the appropriate parties will be
notified. S08 will comply with this
ARAR.

Report of Discharge,
Spill, Loss, Seepage,
or Filtration (CGS
§22a-450)

Applicable

Requires reporting of spills to DEEP. Information is
available at

http://www.ct. qov/deep/cwp/view.asp?A=2692&Q=32
2584

If a spill, loss, seepage or filtration of petroleum,
chemicals, or hazardous waste occurs during
S05 implementation, S05will comply with the
reporting and notification requirements of this
ARAR.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous waste
occurs during S06 implementation, S06 will
comply with the reporting and notification
requirements of this ARAR.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous waste
occurs during S07 implementation, S07 will
comply with the reporting and notification
requirements of this ARAR.

If a spill, loss, seepage or filtration of
petroleum, chemicals, or hazardous
waste occurs during S08
implementation, S08 will comply with the
reporting and notification requirements of
this ARAR.

State Criteria, Advisories, and Guidance (cont.)

Hazardous Waste
Management:
Generator & Handler
Requirements -
General Standards,
Listing, and
Identification
(RCSA 22a-
449(c)100-101)

Applicable, if
hazardous
waste is
generated

These sections establish standards for listing and
identification of hazardous waste. The standards of
40 CFR 260-261 are incorporated by reference.
Chromium is not exempted from listing as a
hazardous waste.

Prior to off-site disposal, excavated
contaminated soil will undergo testing for RCRA
characteristics to determine the appropriate
waste classification and disposal options. S05
will comply with this ARAR

Prior to off-site disposal, excavated
contaminated soil will undergo testing for
RCRA characteristics to determine the
appropriate waste classification and disposal
options. S06 will comply with this ARAR

Prior to off-site disposal, excavated
contaminated soil will undergo testing for
RCRA characteristics to determine the
appropriate waste classification and disposal
options. S07 will comply with this ARAR

S08 may result in the generation of
unused reagents that require disposal.
These materials will be tested for RCRA
characteristics to determine the
appropriate waste classification and
disposal options. S08 will comply with
this ARAR

Hazardous Waste
Management:
Generator Standards
(RCSA 22a-
449(c)"! 02)

Applicable, if
hazardous
waste is
generated

This section establishes standards for various
classes of generators. The standards of 40 CFR 262
are incorporated by reference. Storage requirements
given at 40 CFR 265.15 are also included.

S05 will comply with the substantive provisions
of these requirements during the temporary
storage of excavated soils which constitute
hazardous wastes, prior to off-site disposal.

S06 will comply with the substantive
provisions of these requirements during the
temporary storage of excavated soils which
constitute hazardous wastes, prior to off-site
disposal.

S07 will comply with the substantive
provisions of these requirements during the
temporary storage of excavated soils which
constitute hazardous wastes, prior to off-site
disposal.

S08 will comply with the substantive
provisions of these requirements during
the temporary storage of excavated soils
which constitute hazardous wastes, prior
to off-site disposal.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 3 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

Hazardous Waste
Management:
Management
Standards for Specific
Waste Types (RCSA
§22a-449(c)106)

Applicable, if
the specific
hazardous
wastes are
identified

This section establishes standards for specific types
of wastes, including waste oil and spent lead acid
batteries being reclaimed. The standards of 40 CFR
§266 are incorporated by reference.

If the specific wastes identified in this ARAR are
found, S05 will comply with this ARAR
requirements in the handling and management
of the wastes.

If the specific wastes identified in this ARAR
are found. S06 will comply with this ARAR
requirements in the handling and management
of the wastes.

If the specific wastes identified in this ARAR
are found, S07 will comply with this ARAR
requirements in the handling and
management of the wastes.

If the specific wastes identified in this
ARAR are found, S08 will comply with
this ARAR requirements in the handling
and management of the wastes.















State Criteria, Advisories, and Guidance (cont.)

General Permit for
Contaminated Soil
and/or Sediment
Management (Staging
and Transfer)(DEP-
SW-GP-001) CGS §
22a-208a(1))

Applicable

The substantive requirements of this permit must be
meet. Fact sheet is available at
http://www.ct. qov/deep/cwp/view.asp?a=2709&q=32
9620&depNav GID=1646

http://www.ct.aov/deep/lib/deep/Permits and Licens
es/Factsheets Waste/soilstaaina fs.pdf.

Registration is required dependent on volume to be
managed (>1000 CY, > 10,000 CY, or exceeds 45
day duration).

General conditions include control of stockpiles,
erosion and dust control, characterization, etc.

S05 will comply with the substantive
requirements of this ARAR during active
remediation that result in excavation, handling,
and storage of contaminated soil. As needed,
stockpile controls, erosion and dust controls,
and access will be limited.

S06 will comply with the substantive
requirements of this ARAR during active
remediation that result in excavation, handling,
and storage of contaminated soil. As needed,
stockpile controls, erosion and dust controls,
and access will be limited.

S07 will comply with the substantive
requirements of this ARAR during active
remediation that result in excavation,
handling, and storage of contaminated soil.
As needed, stockpile controls, erosion and
dust controls, and access will be limited.

S08 will comply with the substantive
requirements of this ARAR during active
remediation that result in excavation,
handling, and storage of contaminated
soil. As needed, stockpile controls,
erosion and dust controls, and access
will be limited.

General Permits (for
various activities)

Applicable

Substantive requirements of the general permits
must be attained, The General Permit Program Fact
Sheet (DEEP-FS-004) is available from the following
web page:

http://www.ct. qov/deep/cwp/view.asp?a=2709&q=32
4154&depNav GID=1643#SoilStaaina. The followina

As appropriate, S05 will comply with the
substantive requirements of this ARAR during
active remediation.

As appropriate, S06 will comply with the
substantive requirements of this ARAR during
active remediation.

As appropriate, S07 will comply with the
substantive requirements of this ARAR
during active remediation.

As appropriate, S08 will comply with the
substantive requirements of this ARAR
during active remediation.

General Permits relates to remedial actions at the
Site:

• Stormwater and Dewaterina Wastewaters
from Construction Activities (DEEP-PERD-
GP-015)

Temporary
Authorization
(TA)/Emergency
Authorization (EA)
(CGS 22a-6K)

Applicable

This statute provides for a temporary or emergency
authorization, under certain conditions, for many
activities that require a permit. The substantive
reauirements of a TA must be met. Temporary
Authorization (TA)/ Emerqencv Authorization (EA)

If during remedial action implementation an
emergency discharge to groundwater, surface
water, or a sanitary sewer is required, S05 will
comply with the substantive requirements of
this ARAR.

If during remedial action implementation an
emergency discharge to groundwater, surface
water, or a sanitary sewer is required, S06 will
comply with the substantive requirements of
this ARAR.

If during remedial action implementation an
emergency discharge to groundwater,
surface water, or a sanitary sewer is
required, S07 will comply with the
substantive requirements of this ARAR.

If during remedial action implementation
an emergency discharge to groundwater,
surface water, or a sanitary sewer is
required, S08 will comply with the
substantive requirements of this ARAR.

for In-situ Remediation

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 4 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

State Criteria, Advisories, and Guidance (cont.)

Control of Noise
(RSCA Section 22a-
69-1 to 69-7.4)

Applicable

These Regulations establish allowable noise levels
for different classes of noise zones and would apply
to construction activities at a site.

See:

http://www.ct.qov/deep/lib/deep/requlations/22a/22a-
69-1throuqh7.pdf

During S05 implementation, noise levels will be
monitored and S05 will comply with the
allowable noise levels defined in this ARAR.

During S06 implementation, noise levels will
be monitored and S06 will comply with the
allowable noise levels defined in this ARAR.

During S07 implementation, noise levels will
be monitored and S07 will comply with the
allowable noise levels defined in this ARAR.

During S08 implementation, noise levels
will be monitored and S08 will comply
with the allowable noise levels defined in
this ARAR.

Water Pollution
Control - Regulations
(RCSA §§22a-430-1
to 8 & CGS §§22a-
430)

Applicable

These regulations establish permitting requirements
and criteria for water discharge to groundwater.
http://www.ct.qov/deep/lib/deep/requlations/22a/22a-
430-1and2.pdf.

http://www.ct.qov/deep/lib/deep/requlations/22a/22a-
430-3and4.pdf.

http://www.ct.qov/deep/lib/deep/requlations/22a/22a-
430-6and7.pdf,

http://www.ct.qov/deep/lib/deep/requlations/22a/22a-
430-8.pdf.

During S05 implementation, should discharge
of water to groundwater be required, the
substantive requirements of this ARAR will be
met. S05 will comply with this ARAR.

During S06 implementation, should discharge
of water to groundwater be required, the
substantive requirements of this ARAR will be
met. S06 will comply with this ARAR.

During S07 implementation, should
discharge of water to groundwater be
required, the substantive requirements of this
ARAR will be met. S07 will comply with this
ARAR.

During S08 implementation, should
discharge of water to groundwater be
required, the substantive requirements of
this ARAR will be met. S08 will comply
with this ARAR.

Air Pollution Control -
Control of Particulate
Emissions (Sec. 22a-
174-18)

Applicable

This subsection sets specific standards for
particulate emissions. Specific standards include
Fugitive Particulate Matter (18c).

See

http://www.ct.qov/deep/lib/deep/air/requlations/mainr
eqs/sec18.pdf.

Reasonable precautions must be taken to prevent
particulate matter from becoming airborne during
demolition and construction activities and material
handling operations.

Air monitoring and best engineering practices
will be employed to minimize fugitive dust
emissions during excavation and earth moving
using heavy equipment. S05 will comply with
this ARAR.

Air monitoring and best engineering practices
will be employed to minimize fugitive dust
emissions during excavation and earth moving
using heavy equipment S06 will comply with
this ARAR.

Air monitoring and best engineering practices
will be employed to minimize fugitive dust
emissions during excavation and earth
moving using heavy equipment S07 will
comply with this ARAR.

Air monitoring and best engineering
practices will be employed to minimize
fugitive dust emissions during excavation
and earth moving using heavy
equipment S08 will comply with this
ARAR.

Air Pollution Control -
Control of Odors
(RCSA §22a-174-23)

Applicable

This section prohibits emission of any substance that
constitutes a nuisance because of objectionable
odor.

See

http://www.ct.qov/deep/lib/deep/air/requlations/mainr
eqs/sec23.pdf

If odors are generated during the
implementation of S05, appropriate measures
(covering, source removal, dilution) will be
taken to mitigate the conditions.

If odors are generated during the
implementation of S06, appropriate measures
(covering, source removal, dilution) will be
taken to mitigate the conditions.

If odors are generated during the
implementation of S07, appropriate
measures (covering, source removal,
dilution) will be taken to mitigate the
conditions.

If odors are generated during the
implementation of S08, appropriate
measures (covering, source removal,
dilution) will be taken to mitigate the
conditions.

Well Drilling (CGS §§
25-126 through 137)

Applicable, if
wells are drilled
or abandoned

Piezometers, containment recovery wells and
monitoring wells are included in the definition of (and
regulated as) as "non-water supply wells". Well
drillers must be registered, and the driller must file a
completion report for non-water supply wells.
Pursuant to CGS §25-131(c). See
http://www.cqa.ct.qov/2011/pub/chap482.htm#Sec25
-126.htm and

http://www.ct.qov/dcp/lib/dcp/pdf/well drillinq requlat
ions.pdf

If monitoring wells are installed or abandoned,
S05 will comply with the substantive
requirements of this ARAR.

If monitoring wells are installed or abandoned,
S06 will comply with the substantive
requirements of this ARAR.

If monitoring wells are installed or
abandoned, S07 will comply with the
substantive requirements of this ARAR.

If monitoring wells are installed or
abandoned, S08 will comply with the
substantive requirements of this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 5 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

State Criteria, Advisories, and Guidance (cont.)

Regulations for the
Well Drilling Industry
(RCSA §25-128-33
through 64)

Applicable, if
wells are drilled
or abandoned

Non-water supply wells must be constructed so that
they are not a source or cause of groundwater
contamination. Procedures for abandonment of wells
apply to both water wells and other types of wells.

http://www.ct.qov/dcp/lib/dcp/pdf/well drillina requlat

ions.pdf

If monitoring wells are installed or abandoned,
S05 will comply with the requirements of this
ARAR.

If monitoring wells are installed or abandoned,
S06 will comply with the requirements of this
ARAR.

If monitoring wells are installed or
abandoned, S07 will comply with the
requirements of this ARAR.

If monitoring wells are installed or
abandoned, S08 will comply with the
requirements of this ARAR.

CT Guidelines for Soil
Erosion and Sediment
Control (May 2002)
(adopted pursuant to
CGS 22a-328)

Revised document
issued May 2002,
also identified as DEP
Bulletin 34

To Be
Considered

The Guidelines provide technical and administrative
guidance for the development, adoption, and
implementation of erosion and sediment control
programs.

The Guidelines are available electronically in 4 parts
(from

http://www.ct. aov/deep/cwp/view.asp?a=2720&a=32
5660&depNav GID=1654 ) as listed below:
http://www.ct.aov/deep/lib/deep/water inland/sesc/se
sc intro toc.pdf

http://www.ct.aov/deep/lib/deep/water inland/sesc/se
cs chapter 1 5.pdf

S05 will use best management practices to be
consistent with these guidelines when using
heavy equipment

S06 will use best management practices to be
consistent with these guidelines when using
heavy equipment

S07 will use best management practices to
be consistent with these guidelines during the
targeted excavations and storage and
handling of excavated contaminated soil.

S08 will use best management practices
to be consistent with these guidelines
when using heavy equipment





http://www.ct.aov/deep/lib/deep/water inland/sesc/se
cs appendix a k.pdf













http://www.ct.aov/deep/lib/deep/water inland/sesc/se
cs appendix I m.pdf.























State Criteria, Advisories, and Guidance (cont.)

CT DEEP Final Site
Characterization
Guidance Document,
September 2007,
revised December
2010

To Be
Considered

This provides guidance to persons preparing
environmental site assessments of potentially
contaminated properties. The guidance advocates
the use of a conceptual site model and phased
investigations. The Final Site Characterization
Guidance Document is available at
http://www.ct.aov/deep/lib/deep/site clean up/auida
nee/Site Characterization/Final SCGD.pdf

For designing and implementing PDIs. S05 will
consider the guidance.

For designing and implementing PDIs. S06
will consider the guidance.

For designing and implementing PDIs. S07
will consider the guidance.

For designing and implementing PDIs.
S08 will consider the guidance.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-6

Action-Specific ARARs and TBCs for Soil Alternatives for S05 to S08
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 6 of 6

Requirement

Status

Requirement Synopsis

ALTERNATIVE S05
Pre-Design Investigations, Excavation and
Off-site Disposal, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S06
Pre-Design Investigations, Soil Cap,
Institutional Controls, Operation and
Maintenance, Periodic Assessments, and
Five-Year Reviews [PRG and PMC
Exceedances within Area J]

ALTERNATIVE S07
Pre-Design Investigations, Targeted
Remediation (Targeted Excavation and
Off-site Disposal), Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Area J]

ALTERNATIVE S08
Pre-Design Investigations, Excavation

and Off-site Disposal, Institutional
Controls, Periodic Assessments, and
Five-Year Reviews [Area I]

Guidance for

Groundwater

Monitoring for

Demonstrating

Compliance with the

Connecticut

Remediation

Standard

Regulations,

3/17/2006

To Be
Considered

httD://www.ct.aov/deeD/lib/deeD/site clean UD/auida
nce/qwm quidance for demonstratinq compliance
with ct rsr.Ddf

As appropriate, relevant guidance documents
will be consulted.

As appropriate, relevant groundwater
monitoring documents will be consulted.

As appropriate, relevant groundwater
monitoring documents will be consulted.

As appropriate, relevant groundwater
monitoring documents will be consulted.

Guidance for
Collecting

and Preserving Soil a
nd Sediment Samples
for Laboratory
Determination of
Volatile Organic
Compounds, Final
2/28/2006

To Be
Considered

The Guidance document is available at:
http://www.ct.qov/deep/lib/deep/site clean up/quida
nce/soil samplinq voc final wcomments.pdf.

If sampling is performed understate oversight
during O&M, this guidance will be followed.

If sampling is performed understate oversight
during O&M, this guidance will be followed.

If sampling is performed under State
oversight during O&M, this guidance will be
followed.

If sampling is performed understate
oversight during O&M, this guidance will
be followed.



MA-3767-2013

Nobis Engineering, Inc.

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Table J-7

Chemical-Specific ARARs and TBCs for Vapor Intrusion Alternatives
Scovill Industrial Landfill Site
Waterbury, Connecticut

Requirement

Status

Requirement Synopsis

ALTERNATIVE VI1
No Action

ALTERNATIVE VI2
Limited Action, Institutional Controls,
Periodic Assessments, and Five-Year
Reviews [Areas E1 and J]

ALTERNATIVE VI3
Active Soil Vapor Mitigation System,
Institutional Controls, Operation and
Maintenance, and Five-Year Reviews
[Area E1]

ALTERNATIVE VI4
Passive Soil Vapor Mitigation
System, Institutional Controls,
Operation and Maintenance, and
Five-Year Reviews [Area E1].

Federal Criteria, Advisories, and Guidance

OSWER Draft
Guidance for
Evaluating the Vapor
Intrusion to Indoor Air
Pathway from
Groundwater and Soils
(EPA 530-D-02-004,
November 2002)

To Be Considered

This EPA guidance establishes a methodology
for assessing potential indoor air risks to human
health that may result from volatilization of
contaminants from groundwater and soil vapor
into an overlying building.

The guidance was used in the
HHRA to identify VOC
concentrations in groundwater that
pose potential vapor intrusion risks.

The guidance was used in the HHRA to
identify VOC concentrations in
groundwater that pose potential vapor
intrusion risks.

The guidance was used in the HHRA to
identify VOC concentrations in
groundwater that pose potential vapor
intrusion risks.

The guidance was used in the HHRA to
identify VOC concentrations in
groundwater that pose potential vapor
intrusion risks.

State Regulatory Criteria, Advisories, and Guidance

Connecticut
Remediation Standard
Regulations (RSR)
(22a-133k)

Applicable

The RSRs provide the allowable volatilization
criteria (VC) for groundwater, soil gas, and indoor
air concentrations that would be protective of
human health if volatile contaminants in
groundwater are present.

The regulation requires remediation of VOC
contaminated groundwater below a building used
for residential or industrial/commercial activity to
concentrations equal to or below the VC. It
allows exemption from the Volatilization Criteria
if: (i) the concentrations of contaminants in soil
vapors below a building do not exceed
volatilization criteria for soil gas (ii) measures are
taken to prevent the migration of such
substances into any overlying building, (iii) a
program is implemented to maintain and monitor
all such measures, and (iv) notice of such
measures has been submitted to the
Commissioner.

Under 22a-133k(3)(C)(3)(A), if an environmental
land use restriction on the property prevents
residential use, remediation of a volatile organic
substance is not required if the concentration is
less than the VC for industrial/commercial use.

VI1 will not comply with this ARAR
because no action will be
implemented to address potential
vapor intrusion risks due to
groundwater contamination.

VI2 will not comply with this ARAR at
Area E1, which is currently in residential
use, because this alternative does not
include remediation of contaminated
groundwater or mitigation measures
preventing vapor intrusion.

V12 will comply with this ARAR at Area
J, because institutional controls will be
used to prevent residential use and new
construction unless appropriate vapor
mitigation system s are installed.

The RSR groundwater VC were
considered for the VI Screening Levels
development.

VI3 will comply with this ARAR though
installation and monitoring of active
vapor mitigation systems in the existing
building's residential units on the ground
floor.

The RSR groundwater VC were
considered for the VI Screening Levels
development.

VI4 will comply with this ARAR though
installation and monitoring of passive
vapor mitigation systems in the existing
building's residential units on the ground
floor.

The RSR groundwater VC were
considered for the VI Screening Levels
development.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-8

Location-Specific ARARs and TBCs for Vapor Intrusion Alternatives
Scovill Industrial Landfill Site
Waterbury, Connecticut

Requirement

Status

Requirement Synopsis

ALTERNATIVE VI1
No Action

ALTERNATIVE VI2
Limited Action, Institutional
Controls, Periodic Assessments,
and Five-Year Reviews [Areas E1
and J]

ALTERNATIVE VI3
Active Soil Vapor Mitigation
System, Institutional Controls,
Operation and Maintenance, and
Five-Year Reviews [Area E1]

ALTERNATIVE VI4
Passive Soil Vapor Mitigation
System, Institutional Controls,
Operation and Maintenance, and
Five-Year Reviews [Area E1].

Federal Regulatory Requirements

National Historic
Preservation Act (16
U.S.C. 470 et sea.. 40
CFR 800)

Applicable, if such resources are
identified

Pursuant to Sections 106 and 110(f) of
the NHPA, as amended, CERCLA
response actions are required to take
into account the effects of the response
activities on any historic property
included or eligible for inclusion on the
National Register of Historic Places.

Not applicable.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. VI2 will
comply with this ARAR.

VI3 will comply with this ARAR. If
significant historic properties (including
prehistoric or archaeological) are
identified during implementation of the
active vapor mitigation systems, then the
requirements of these regulations will be
followed. Significant historic features or
artifacts are not expected to be
encountered during installation of vapor
mitigation systems beneath existing
buildings.

VI4 will comply with this ARAR. If
significant historic properties (including
prehistoric or archaeological) are
identified during implementation of the
passive vapor mitigation systems, then
the requirements of these regulations will
be followed. Significant historic features
or artifacts are not expected to be
encountered during installation of vapor
mitigation systems beneath existing
buildings.

State Regulatory Requirements

Connecticut
Environmental
Protection Act (Public
Act 82-367)

Applicable, if such resources are
identified

This regulation directs that the provisions
of CGS Sections 22a-15 through 22a-19,
inclusive of the Connecticut
Environmental Protection Act, shall also
be applicable to historic structures and
landmarks, and are defined as those
properties that are listed or under
consideration for listing as individual
units on the National Register of Historic
Places or which are part of a district
listed or under consideration for listing
determined by the State Historic
Preservation Board.

Not applicable.

If significant historic properties (including
prehistoric or archaeological) are
identified, then the requirements of these
regulations will be followed. VI2 will
comply with this ARAR.

VI3 will comply with this ARAR. If
significant historic properties (including
prehistoric or archaeological) are
identified during implementation of the
active vapor mitigation systems, then the
requirements of these regulations will be
followed. Significant historic features or
artifacts are not expected to be
encountered during installation of these
systems beneath existing buildings.

VI4 will comply with this ARAR. If
significant historic properties (including
prehistoric or archaeological) are
identified during implementation of the
passive vapor mitigation systems, then
the requirements of these regulations will
be followed. Significant historic features
or artifacts are not expected to be
encountered during installation of these
systems beneath existing buildings.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-9

Action-Specific ARARs and TBCs for Vapor Intrusion Alternatives
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 1 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE VI1
No Action

ALTERNATIVE VI2
Limited Action,
Institutional Controls,
Periodic Assessments, and
Five-Year Reviews [Areas
E1 and J]

ALTERNATIVE VI3
Active Soil Vapor Mitigation System,
Institutional Controls, Operation and
Maintenance, and Five-Year Reviews
[Area E1]

ALTERNATIVE VI4
Passive Soil Vapor Mitigation System,
Institutional Controls, Operation and
Maintenance, and Five-Year Reviews
[Area E1].

Federal Criteria, Advisories, and Guidance

RCRA Air Emission
Standards for
Process Vents (40
CFR 264, Subpart
AA)

Relevant and Appropriate, if
threshold limit is exceeded

Provides requirements and treatment
limits applicable to air stripping facilities
that treat RCRA wastes with total VOCs of
10 ppm by weight or greater.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
anticipated that VOC concentrations at the
active vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by vapor
mitigation systems exceed the thresholds,
then air pollution control devices will be
used to meet this ARAR.

VI4 will comply with this ARAR. It is not
anticipated that VOC concentrations at
the passive vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by
vapor mitigation systems exceed the
thresholds, then air pollution control
devices will be used to meet this ARAR.

RCRA Air Emission
Standards for
Equipment Leaks (40
CFR 264, Subpart
BB)

Relevant and Appropriate, if
threshold limit is exceeded

This regulation contains air pollutant
emission standards for equipment leaks at
hazardous waste TSD facilities. This
subpart applies to equipment that contains
or contacts hazardous wastes with organic
concentrations of at least 10 percent by
weight.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
anticipated that VOC concentrations at the
active vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by vapor
mitigation systems exceed the thresholds,
then air pollution control devices will be
used to meet this ARAR.

VI4 will comply with this ARAR. It is not
anticipated that VOC concentrations at
the passive vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by
vapor mitigation systems exceed the
thresholds, then air pollution control
devices will be used to meet this ARAR.

National Emission
Standards for
Hazardous Air
Pollutants

(NESHAPS) (40 CFR
61, Subparts F & J)

Relevant and Appropriate, if
threshold limit is exceeded

Regulates VOC emissions from specific
source categories. Establishes allowable
numerical limits for emissions of benzene
and vinyl chloride for specific stationary
source categories. Applies to benzene
emissions if the facility produces more
than 1,102 tons per year of benzene.
Applies to specific vinyl chloride process
units if numerical limits are exceeded.
Provides requirements for monitoring,
testing, reporting, and repairs.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
anticipated that VOC concentrations at the
active vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by vapor
mitigation systems exceed the thresholds,
then air pollution control devices will be
used to meet this ARAR.

VI4 will comply with this ARAR. It is not
anticipated that VOC concentrations at
the passive vapor mitigation systems will
exceed the thresholds. However, if
concentrations of VOCs captured by
vapor mitigation systems exceed the
thresholds, then air pollution control
devices will be used to meet this ARAR.

MA-3767-2013

Nobis Engineering, Inc.

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Table J-9

Action-Specific ARARs and TBCs for Vapor Intrusion Alternatives
Scovill Industrial Landfill Site
Waterbury, Connecticut
Page 2 of 2

Requirement

Status

Requirement Synopsis

ALTERNATIVE VI1
No Action

ALTERNATIVE VI2
Limited Action,
Institutional Controls,
Periodic Assessments, and
Five-Year Reviews [Areas
E1 and J]

ALTERNATIVE VI3
Active Soil Vapor Mitigation System,
Institutional Controls, Operation and
Maintenance, and Five-Year Reviews
[Area E1]

ALTERNATIVE VI4
Passive Soil Vapor Mitigation System,
Institutional Controls, Operation and
Maintenance, and Five-Year Reviews
[Area E1].

State Criteria, Advisories, and Guidance

Hazardous Waste
Management:
Generator Standards
(RSCA Section 22a-
449(c) 102)

Relevant and Appropriate

This section of the rule establishes
standards for various classes of
generators. The standards of 40 CFR 262
are incorporated by reference. This rule
applies to treatment residues that fail
hazardous characteristic tests that are
generated from treatment systems.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
anticipated that air pollution control
devices will be needed on the active vapor
mitigation systems. However, if air
pollution control devices are used to
capture or treat emissions from the vapor
mitigation systems, treatment residues
that are determined to be hazardous will
be properly managed and disposed of to
comply with this ARAR.

VI4 will comply with this ARAR. It is not
anticipated that air pollution control
devices will be needed on the passive
vapor mitigation systems. However, if air
pollution control devices are used to
capture or treat emissions from the vapor
mitigation systems, treatment residues
that are determined to be hazardous will
be properly managed and disposed of to
comply with this ARAR.

Air Pollution Control -
Control of Organic
Compound
Emissions

RCSA §22a-174-20

Applicable, if allowable limits are
exceeded

Subsection (f) sets standards for emission
of organic compounds. Limits organic
compound emissions to 40 pounds per
day or 8 pounds per hour.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
anticipated that air pollution control
devices will be needed on the active vapor
mitigation systems.

If air emissions of organic compounds
from the active vapor mitigation systems
are expected to exceed the limits of this
ARAR, then pollution control devices will
be used to reduce emissions to meet the
ARAR requirements.

VI4 will comply with this ARAR. It is not
anticipated that air pollution control
devices will be needed on the passive
vapor mitigation systems.

If air emissions of organic compounds
from the active vapor mitigation systems
are expected to exceed the limits of this
ARAR, then pollution control devices will
be used to reduce emissions to meet the
ARAR requirements.

Air Pollution Control
- Control of Odors
(RCSA Section 22a-
174-23(c))

Applicable, if allowable limits are
exceeded

These regulations require that odors
determined to be a nuisance (defined by
exceedance of identified standards or
otherwise determined by the
commissioner) must be investigated and
remediated.

Not applicable.

Not applicable. .

VI3 will comply with this ARAR. Only
minimal odors are anticipated from
installation and operation of the active
vapor mitigation systems. Any nuisance
odors will be addressed as required by
this regulation.

VI4 will comply with this ARAR. Only
minimal odors are anticipated from
installation and operation of the passive
vapor mitigation systems. Any nuisance
odors will be addressed as required by
this regulation.

Air Pollution Control -
Hazardous Air
Pollutants (RCSA
Section 22a-174-29)

Applicable if allowable limits are
exceeded

These regulations identify the maximum
allowable stack concentrations for specific
hazardous air pollutants and specify the
testing requirements. Allowable limits are
provided in Table 29-1 of this regulation.

Not applicable.

Not applicable.

VI3 will comply with this ARAR. It is not
expected that air emissions of hazardous
air pollutants from the active vapor
mitigation system will exceed the limits of
this ARAR.

If air emissions of hazardous air
pollutants from the active vapor mitigation
systems are expected to exceed the limits
of this ARAR, then pollution control
devices will be used to reduce emissions
to meet the maximum allowable stack
concentrations.

VI4 will comply with this ARAR. It is not
expected that air emissions of hazardous
air pollutants from the passive vapor
mitigation system will exceed the limits of
this ARAR.

If air emissions of hazardous air
pollutants from the passive vapor
mitigation systems are expected to
exceed the limits of this ARAR, then
pollution control devices will be used to
reduce emissions to meet the maximum
allowable stack concentrations.

MA-3767-2013

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Connecticut Department of

ENERGY &

. i NVIRONMENTAL

PROTECTION

79 Elm Street • Hartford, CT 06106-5127

www.ct.gov/deep

Affirmative Action/Equal Opportunity Employer

September 25, 2013

James T. Owens, III

Director, Office of Site Remediation & Restoration

U.S. Environmental Protection Agency

Region 1 - New England

5 Post Office Square, Suite 1.00

Mail Code OSRR07-5

Boston, MA 02109-3912

Dear Mr. Owens:

The Connecticut Department of Energy and Environmental Protection (DEEP) concurs with
the remedial action selected by EPA for the Scovill Industrial Landfill Superfund Site in
Waterbury, Connecticut. The remedial action includes limited soil excavation, a soil cap, an
active soil vapor mitigation system, and environmental land use restrictions to prevent
exposures to soil contaminants left in place. The remedial action is described in detail in the
"USEPA Proposed Plan, Scovill Industrial Landfill Superfund Site, Waterbury, Connecticut"
dated July 2013. and in the Record of Decision titled "Record Of Decision Summary, Scovill
Industrial Landfill, Waterbury, Connecticut".

Concurrence with EPA's selected remedial action for the Scovill Industrial Landfill Superfund
site, shall in no way affect the Commissioners authority to institute any proceeding to
prevent or abate violations of the law, prevent or abate pollution, recover costs and natural
resource damages, and to impose penalties for violations of law, including but not limited to
violations of any permit issued by the Commissioner.

Sincerely,

Macky McCleary
Deputy Commissioner

MM/SG

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References

City of Waterbury; Bureau of Engineering; Geographic Information Systems Division, 1999.
WaterburyCT. Zoning Districts. 1999.

Connecticut (State of) Department of Energy and Environmental Protection (DEEP), 2010.
Scovill Industrial Landfill Federal National Priorities List Superfund Site, Waterbury,
Connecticut, Groundwater Use and Value Determination. September 2010.
(http://www.epa.qov/reqion1/superfund/sites/scovill/542234.pdf)

Connecticut (State of) Department of Energy and Environmental Protection (DEEP), 2011.
2011 Connecticut Water Quality Standards. 2011.

E2, Inc. (E2), 2005. Planning for the Future: A Reuse Planning Report for the Calabrese Parcel
of the Scovill Industrial Landfill Superfund Site. June, 2005.

Nobis Engineering, Inc., 2011. Final Human Health Risk Assessment, Scovill Industrial Landfill
Superfund Site Waterbury, Connecticut. June 2011.
(http://www.epa.qov/reqion1/superfund/sites/scovill/540437.pdf)

Nobis Engineering, Inc. (Nobis), 2013a. Remedial Investigation, Scovill Industrial Landfill

Superfund Site, Waterbury, Connecticut. May 2013.

(http://www.epa.qov/reqion1/superfund/sites/scovill/540436.pdf)

Nobis Engineering, Inc. (Nobis), 2013b. Feasibility Study, Scovill Industrial Landfill Superfund
Site, Waterbury, Connecticut. July 2013.
(http://www.epa.qov/reqion1/superfund/sites/scovill/542225.pdf)

Roy F. Weston (Weston), 1999. Draft Site Inspection Report for Scovill Industrial Landfill,
Waterbury, Connecticut. Roy F. Weston Superfund Technical Assessment and
Response Team, Burlington, MA. 17 September 1999.

United States Department of Housing and Urban Development; Federal Insurance

Administration, 1979. Flood Insurance Rate Map, City of Waterbury, Connecticut, New
Haven County. Community-Panel Number 090091 0008 B. November 1, 1979.

United States Environmental Protection Agency (EPA), 1990. A Guide on Remedial Actions at
Superfund Sites with PCB Contamination. August 1990.

United States Environmental Protection Agency (EPA), 1991. Role of the Baseline Risk
Assessment in Superfund Remedy Selection Decisions. April 22, 1991.

United States Environmental Protection Agency (EPA), 2000. A Guide to Developing and
Documenting Costs Estimates During the Feasibility Study. July 2000.

United States Environmental Protection Agency (EPA), 2002. Role of Background in the
CERCLA Cleanup Program. May 1,2002.

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United States Environmental Protection Agency (EPA), 2008. Provisional Peer Reviewed
Toxicity Values for Cobalt (CASRN 770-48-4). 25 August 2008.

United States Environmental Protection Agency (EPA), 2012. Institutional Controls: A Guide to
Planning, Implementing, Maintaining, and Enforcing Institutional Controls at
Contaminated Sites. OSWER 9355.0 89, EPA 540 R 09001, December 2012.

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Acronyms & Abbreviations

ARARs

Applicable or Relevant and Appropriate Requirements

BEHP

Bis(2-ethylhexyl)phthalate

CERCLA

Comprehensive Environmental Response, Compensation and Liability Act



of 1980

cm2

Square Centimeters

coc

Chemicals of Concern

Company

Scovill Manufacturing Company

CSM

Conceptual Site Model

CT DEEP

Connecticut Department of Energy and Environmental Protection

CT DPH

Connecticut Department of Public Health

CUL

Cleanup Level

cy

Cubic Yards

DEC

Direct Exposure Criteria

EPA

United States Environmental Protection Agency

EPC

Exposure Point Concentration

ft bgs

Feet Below Ground Surface

FS

Feasibility Study

HHRA

Human Health Risk Assessment

HI

Hazard Index

HQ

Hazard Quotient

IEUBK

Integrated Exposure and Uptake Biokinetic

mg

Milligrams

mg/cm -event Milligrams per Square Centimeter per Event

mg/Kg

Milligrams per Kilogram

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OSRR

Office of Site Remediation and Restoration

PAH

Polycyclic Aromatic Hydrocarbons

Parcel A

Risk Areas D1, D3, E1, E2, E3, F, G, H, and I

Parcel B

Risk Area J, Calabrese Parcel

PCBs

Polychlorinated Biphenyls

PCE

Tetrachloroethylene

PDI

Pre-Design Investigation

PMC

Pollutant Mobility Criteria

PRGs

Preliminary Remediation Goals

PRPs

Potentially Responsible Parties

RAGS

Risk Assessment Guidance

RAOs

Response Action Objectives

RfC

Reference Concentrations

RfD

Reference Dose

Rl

Remedial Investigation

RME

Reasonable Maximum Exposure

ROD

Record of Decision

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RSR

Remediation Standard Regulations

Saltire

Saltire, Inc.

SARA

Superfund Amendments and Reauthorization Act of 1986

SC

Source Control

sf

Square Feet

Site

Scovill Industrial Landfill

SPLP

Synthetic Precipitation Leaching Procedure

SSAF

Soil-to-Skin Adherence Factors

SVOCs

Semi-Volatile Organic Compounds

SWPC

Surface-Water Protection Criteria

sy

Square Yard

TBC

To Be Considered

TEQ

Toxicity Equivalency

TCE

Trichloroethylene

TCLP

Toxicity Characteristic Leaching Procedure

UCL

Upper Confidence Limit

Mg/dL

Micrograms per Deciliter

Mg/m3

Microgram per Cubic Meter

Mg/Kg

Micrograms per Kilogram

VOCs

Volatile Organic Compounds

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