NCD980602163_19900801_Warren County PCB Landfill_SERB C_Binder No. 4 - EPA Guidance on Remedial Action for Superfund Sites with PCB Contamination-OCR

EPA GUIDANCE ON
REMEDIAL ACTJ;.O.~
FOR SUPERFUND SITES
WITH PCB CONTAMINATION
BINDER NO. 4
. '
'----,
&EPA
United States
Environmental Protection
Agency
Superfund
Office of Emergency and
Remedial Response
Washington, DC 20460
Guidance on
Remedial Actions for
Superfund Sites with
PCB Contamination
EPA'540/G-90l007
August 1990
OSWER Directive No. 9355.4-01
August 1990
GUIDANCE ON REMEDIAL ACTIONS FOR SUPERFUND
SITES WITH PCB CONTAMINATION
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
NOTICE
Development of this document was funded by the United States
Environmental Protection Agency. It has been subjected to the
Agency's review process and approved for publication as an EPA
document.
The policies and procedures set out in this document are intended
solely for the guidance of response personnel. They are not
intended, nor can they be relied upon, to create any rights,
substantive or procedural, enforceable by any party in litigation
with the United States. EPA officials may decide to follow this
guidance, or to act at variance with these policies and
procedures based on an analysis of specific site circumstances,
and to change them at any time without public notice.
ii
Executive summary
This document describes the recommended approach for evaluating
and remediating Superfund sites with PCB contamination. It
should be used as a guide in the investigation and remedy
selection process for PCB-contaminated Superfund sites. This
guidance provides preliminary remediat ion goals for various media
that may be contaminated and identifies other considerations
important to ensuring protection of human health and the
environment. In addition, potential applicable or relevant and
appropriate requirements (ARARs) and "to-be-considered" criteria
pertinent to Superfund sites with PCB contamination and their
integration into the RI/FS and remedy selection process are
summarized. This guidance also describes how to develop remedial
alternatives for PCB contaminated materials that are consistent
with Superfund program expectations a nd ARARs. The guidance
concludes with a discussion of considerations unique to PCBs that
should be considered in the nine criteria evaluation and
tradeoffs between options that are likely to occur.
Actions taken at Superfund sites must meet the mandates of the
Comprehensive Environmental Response Compensation and Liability
Act (CERCLA) as provided for in the National Contingency Plan
(NCP). This requires that remedial actions protect human health
and the environment, comply with or waive applicable or relevant
and appropriate requirements, be cost-effective, and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
In addition, there is a preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as a
principal element. Although the basic Superfund approach to
addressing PCB-contaminated sites is c onsistent with other laws
and regulations, this consistency must be documented in the
feasibility study and ROD to demonstrate that ARARs have been
attained or waived. Primary Federal ARARs for PCBs derive from
the Toxic Substances Control Act (TSCA) and the Resource
Conservation and Recovery Act (RCRA).
To identify the areas for which a resp onse action should be
considered, starting point concentrations (preliminary cleanup
goals) for each media are identified. These concentrations
represent the level above which unrestricted exposure may result
in risks exceeding protective Levels. For soils, the preliminary
remediation goals should generally be 1 ppm for sites in or
expected to be in residential areas. Higher starting point
values (10 to 25 ppm) are suggested for sites where non-
residential land use is anticipated. Remediation goals for
ground water that is potentially drinkable should be the proposed
iii
I MCL of .5 ppb. Cleanup levels associated with surface
water should account for the potential use of the suface water as
drinking water, impacts to aquatic lifa, and impacts through the
food chain.
For contaminated material that is contained and managed in place
over the long term, appropriate engineering and institutional
controls should be used to ensure protection is maintained over
time. An initial framework for determining appropriate long-term
management measures is provided.
The Superfund program expectations should be considered in
developing appropriate response options for the
identified area over which some action must take place. In
particular, the expectation that principal threats at the site
should be treated, whenever practicable, and that consideration
should be given to containment of low-threat material, forms the
basis for assembling alternatives. Principal threats will
generally include material contaminated at concentrations
exceeding 100 ppm for sites in residential areas and
concentrations exceeding 500 ppm for sites in industrial areas
reflecting concentrations that are 1 to 2 orders of magnitude
higher than the preliminary remediation goals. Where
concentrations are below 100 ppm, treatment is less likely to be
practicable unless the volume of contaminated material is
relatively low.
The expectations support consideration of innovative treatment
methods where they offer potential for comparable or superior
treatment performance or implementability, fewer/lesser adverse
impacts, or lower costs. This emphasizes the need to develop a
range of treatment options. For PCBs, possible innovative
technologies meeting these criteria _include solvent extraction,
potassium polyethylene glycol dechlorination (KPEG), biological
treatment, and in-situ vitrification.
Protective, ARAR-compliant alternatives will be compared relative
to the five balancing criteria: long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, and cost.
Primary tradeoffs are most likely to occur under the long-term
effectiveness and permanence, implementability, and cost
criteria.
Final decisions should document the PCB concentrations above
which material will be excavated, treatment processes that will
be used, action levels that define the area that will be
contained, long-term management controls that will be
implemented, treatment levels to which the selected remedy will
reduce PCB concentrations prior to disposal, and the time frame
for implementation.
iv
I ·
CONTENTS
Page
Executive Summary.......................................... iii
Tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii
Figures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix
Acknowledgements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x
1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. 1 Purpose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1. 2 Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.3 Focus of This Document With Respect to the
Remedial Process and Superfund Expectations. 3
1.4 organization of Document .....••....•........ 7
2. Regulations and "To-Be-Considered" Guidelines Pertinent
to PCB Contamination Sites....................... 9
2.1 National Contingency Plan ................... 10
2.2 TSCA PCB Regulations ........................ 11
2.2.1 Liquid PCBs at Concentrations Greater
Than 500 ppm. . . . . . . . . . . . . . . . . . . . . . . . . 13
2.2.2 Liquid PCBs at Concentrations Between
50 ppm and 500 ppm ................•.. 13
2.2.3 Non-Liquid PCBs at Concentrations
Greater Than or Equal to 50 ppm ...... 14
2.2.4 PCB Articles, Containers, Electrical
Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2.2.5 TSCA Chemical Waste Landfill
Requirements. . . . . . . . . . . . . . . . . . . . . . . . . 1 7
2.2.6 Storage Requirements ................. 17
2.3 RCRA Regulations Addressing PCBs ............ 19
2.4
2.5
2.6
2.7
2.3.1 Liquid Hazardous Waste With PCBs at
50 ppm or Greater .................... 20
2.3.2 Hazardous Waste With HOCs at 1000 ppm
or Greater .......................... .
Clean Water Act ............................ .
Safe Drinking Water Act .................... .
PCB Spill Cleanup Policy Under TSCA ........ .
2.6.1 Low Concentration, Low Volume Spills
2.6.2
2.6.3
2.6.4
2.6.5
Al 1 Areas ........................... .
Non-Restricted Access Areas ......... .
Industrial Areas ................... ~.
Outdoor Electrical Substations ...... .
Special Situations .................. .
Guidances .................................. .
2.7.1 Draft Guidelines for Permit
Applications and Demonstrations --
20
20
21
22
22
22
22
23
23
23
Test Plans for PCB Disposal by Non-
Thermal Alternate Methods........... 24
V
1
I
2.7.2 Verification of PCB Spill Cleanup by
Sampling 'and Analysis ••.............. 24
2.7.3 Field Manual for Grid Sampling of PCB
Spill Sites to Verify Cleanup ........ 24
2.7.4 Development of Advisory Levels for PCB
Cleanup. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5
2.7.5 · Risk Assessment Guidance for Superfund:
Human Health Evaluation .............. 25
3. Cleanup Level Determination ...................... 26
3.1 Soils ....................................... 27
3.1.1 Preliminary Remediation Goals for
Residential Areas .......•............ 28
3.1.2 Preliminary Remediation Goals for
Industrial Areas ..................... 30
3.1.3 Assessing the Impact to Ground Water. 33
3. 2 Ground Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3
3.3 Sediment .................................... 34
3.4 Ecological Considerations ................... 36
4. Developing Remedial Alternatives ................. 39
4.1 Identifying Principal Threats/Low-Threat
Areas . . . . . . . . . . . . . . • . . . . . . . . . . • . . . • . . . . . . . . . 4 o
4.2 Treatment Methods ........................... 40
4.2.1 Incineration ......................... 42
4.2.2 Chemical Dechlorination (KPEG) ....... 42
4. 2. 3 Biological Treatment. . . . . . . . . . . . . . . . . 44
4.2.4 Solvent Washing/Extraction ........... 45
4.2.5 Solidification/Stabilization ......... 45
4.2.6 Vitrification ........................ 46
4.3 Determining Appropriate Management Controls
Areas Where Concentrations Are Above Action
Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 6
4.3.1 Example Analysis --Long-Term
Management Controls ................. 47
4.4 Dredged Material ............................ 54
4.5 RCRA Hazardous Waste ........................ 54
4.6 Example Options Analysis --Contaminated
Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
5. Analysis of Alternatives and Selection of Remedy. 58
5.1 Evaluating Remedial Alternatives ............ 59
5.1.1 Overall Protection of Human Health and
the Environment ...................... 59
5.1.2 Compliance With ARARs ................ 59
5.1.3 Long-Term Effectiveness and
5.1.4
5.1.5
5.1.6
5.1. 7
Permanence. . . . . . . . . . . . . . . . . . . . . . . . . . . 6 o
Reduction of Toxicity, Mobility, or
Volume through Treatment ............. 61
Short-Term Effectiveness ............. 61
Implementability ..................... 62
Cost ...•..................•.......... 62
vi
5.2 Selection of Remedy .••...........•.......... 62
5.3 Documentation ............................... 63
6. References. • • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
Appendix A.
Appendix B.
Appendix c.
Appendix D.
Appendix E.
Appendix F.
Summary Report of FY82-FY89 Records of
Decision Addressing PCB Contaminated Media .. A-1
Direct Contact Risk Evaluation .............. B-1
Determining Appropriate Long Term Management
Controls --Detailed Calculations for Case
Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1
Case Studies --Pepper Steel, FL; Wide Beach,
NY . . • . • • . . . . . . . . . . • • . • • . . . . . . . . . . . • • . . . . . . . . D-1
PCB Disposal Companies Commercially
Permitted. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1
Superfund Site Examples --Long Term
Management Controls .••.......•........•..... F-1
vii
TABLES
Number Page
2-1 Remediation Options for PCB Waste Under TSCA......... 12
2-2 TSCA Chemical Waste Landfill Requirements ......•...... 17
3-1 Recommended Soil Clean-up Levels .•.................... 27
3-2 Analytical Methods for PCBs .••..•••.••...••••..••..••• 29
3-3 PCB Direct Contact Assumptions •••.••....•.•.•..••.•••• 31
3-4 Chemical and Physical Properties of PCBs .••..•.••..... 32
3-5 PCB Sediment Quality Criteria .••.••••••..•............ 36
4-1 PCB Treatment Methods and Application Consequences .... 43
4-2 Selection of Long-Term Management Controls at PCB-
Contaminated Sites. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 8
4-3 Summary --Example Site Parameters •••••.••.••...•..... 49
4-4 Cover Design --Summary Table ....•..•.•.•...•••..•.... 52
4-5 Example Scenario --Evaluation Results .......•..••.... 53
4-6 Example PCB Compliance Scenarios for Contaminated Soil 57
C-1 Cover Design Summary Table. . • • • • . . . • . . . . • . . . . . . . . . . . . . C-7
C-2 Example Scenario --Results ...••...•.•......•......... C-11
viii
FIGURES
Number Page
1-1 Decision Points in the superfund Process ............•. 4
4-1 Key Steps in the Development of Remedial Alternatives
at Superfund Sites With PCB Contamination .•.•....•.•.. 41
4-2 Cover Designs --Example Scenario ....•..••.••.....•••. 51
C-1 Example Scenario Cap Designs .•••••.....••.••.•.•..•••. C-4
C-2 Evaluation Areas for VADOFT and AT123D •••••••••••••••. C-8
ix
Acknowledgements
We wish to acknowledge the following people who assisted in
preparing this document.
Jennifer Haley, OERR
Betsy Shaw, OERR
Bill Hanson, OERR
Larry Kapustka, ORD/Corvallis
Steve Hwang, ORD/OHEA
Burt Bledsoe, ORD/RSKERL
Ed Barth, ORD/RREL
Jacqueline Moya, ORD/OHEA
Bruce Means, OERR
Chris Zarba, ow
Larry Starfied, OGC
X
Johanna Miller, Region IX
Michael Jassinski, Region I
Mark Fite, Region VI
Jim Orban, Region IV
Barry Lester, Geotrans
Rose Spikula, CH2M Hill
Chapter 1
Introduction
This document describes the recommended approach for
evaluating and remediating Superfund sites with PCB
contamination. It provides starting point cleanup levels
for various media that may become contaminated and
identifies other considerations important to ensuring
protection of human health and the environment that these
cleanup levels may not address. In addition, potential
applicable or relevant and appropriate requirements (ARARs)
and 11to-be-considered11 criteria pertinent to superfund sites
with PCB contamination and their integration into the RI/FS
and remedy selection process are summarized.
The guidance also describes how to develop remedial
alternatives for PCB contaminated materials that are
consistent with Superfund program expectations and ARARs.
The guidance concludes with a discussion of considerations
unique to PCBs that should be considered in the nine
criteria evaluation and likely tradeoffs between options
that are likely to occur.
1
1.1 Purpose
This guidance document outlines the RI/FS and selection
of remedy process as it specifically applies to the
development, evaluation, and selection of remedial actions
that address PCB contamination at Superfund sites. The
principal objectives of this guidance are to:
o Present the statutory basis and analytical framework for
formulating alternatives designed to address PCB
contamination, explaining in particular the regulatory
requirements and other criteria that can shape options for
remediation;
o Describe key considerations for developing remediation
goals for each contaminated media under various
scenarios;
o Outline options for achieving the remediation goals and
the associated ARARs;
o Summarize the key information that generally should be
considered in the detailed analysis of alternatives;
o Discuss key tradeoffs likely to occur in the remedy
selection process;
o Provide guidelines for documenting remedies for PCB
sites in a Proposed Plan and Record of Decision.
Although technical aspects of the investigation,
evaluation, and remediation are not discussed in detail,
pertinent references and, in some cases, summary
information, are provided.
This document is intended for use by EPA remedial
project managers (RPMs), State and other Federal Agency site
managers responsible for Superfund sites involving PCBs,
contractors responsible for conducting the field work and
alternatives evaluation at these sites, and others involved
in the oversight or implementation of response actions at
these sites.
Although each Superfund site may present a unique set of
environmental conditions and potential human health
problems, general guidelines can be established for sites
involving PCBs as the predominant chemical. Utilizing these
general principles, site managers can streamline the RI/FS
and remedy selection process by conducting a more efficient
and effective study. This can be accomplished by: 1)
specifying ARARs and other factors that shape the primary
2
options for remediating such sites, 2) identifying key
information necessary to fully evaluate those options, and
3) focussing on the major tradeoffs likely to emerge in the
comparative analysis upon which remedy selection is based.
Consideration of the factors outlined in this document
should lead to consistent alternatives development and
evaluation at sites involving PCB contamination.
1.2 Background
Approximately 12 percent of the Superfund sites for
which Records of Decision (RODs) have been signed (69 of 581
total RODs as of 9/89) address PCB contamination.
Preliminary assessment/site inspection data from all sites
on the National Priorities List indicates that approximately
17 percent of the sites for which RODs have not yet been
signed also involve PCBs. The RI/FS/remedy selection
process for PCB sites is complicated for a number of
reasons. From a regulatory point of view, there is an
unusually high number of potentially applicable or relevant
and appropriate requirements (ARARs) and pertinent "to-be-
considered" guidelines for actions involving PCB wastes.
PCBs are difficult to address technically due to their
persistence and high toxicity. Finally, a large number of
process options are potentially effective for addressing
PCBs and deserve consideration. The approach outlined in
this document attempts to address all three aspects of PCB
remediation.
1.3 Focus of This Document With Respect to the Remedial
Process and Superfund Expectations
The Superfund remedial process begins with the
identification of site problems during the preliminary
assessment/site inspection, which is conducted before a site
is listed on the National Priorities List. The process
continues through site characterization, risk assessment,
and treatability studies in the RI, the development,
screening, and detailed analysis of remedial alternatives in
the FS, and culminates in the selection, implementation, and
operation of a remedial action. Figure 1-1 shows the steps
comprising the Superfund RI/FS process. Arrows indicate key
decisions specifically addressed in this document.
The various components of the remedial investigation are
not specifically addressed in this document; however,
initial reference material including tables outlining
properties of PCBs, analytical methods available, and data
collection needs/considerations for technologies used to
address PCBs are provided. In addition, a general
discussion of the assessment of PCB impact on ground water
3
.I>,. REMEDIAL INVESTIGATION FEASIBILITY STUDY REMEDY SELECTION I I Sooplng i I ,----·······--------------------·········---, Site Characlerization I---~ I . I , , , , C , , , ~een natives If Necessary ~[;;] , .. I Treatabi~ty 'INTERIM 'ACTION lnvestiga lions , I H Detailed H Identify Analysis of Prelerred Alternatives Alternative , , , . H Drah FS Report/Proposed Plan Public Comment Figure 1-1 DECISION POINTS IN THE SUPERFUND PROCESS ROD
and evironmental considerations which may be pertinent in
the risk assessment is provided.
The focus of this guidance is primarily on the
feasibility study: development and screening of
alternatives, detailed analysis of alternatives, and the
consequent selection of remedy. This process is designed to
meet the overall Superfund goal to select remedial actions
that are protective of human health and the environment,
that maintain protection over time, and that minimize
untreated waste. In addition to the overall goal, Superfund
actions should consider the following program expectations:
o Treatment of principal threats wherever practicable,
o Containment of waste that poses a low long-term threat
or where treatment is impracticable,
o Institutional controls to mitigate short-term impacts or
supplement engineering controls,
o Remedies that combine treatment of principal threats
with containment and institutional controls for
treatment residuals and untreated waste,
o Consideration of innovative technologies,
o Returning contaminated ground water to its beneficial
uses within a time frame that is reasonable, where
practicable.
The implications of these expectations for PCB contaminated
sites is described in appropriate sections of this document.
The development of alternatives involves completing the
following steps, considering the program expectations
described above:
1. Identify remedial action response objectives including
the preliminary remediation goals that define the
appropriate concentration of PCBs that could remain at
the site without management controls.
2. Identify general response actions such as excavation
and treatment, containment, or in-situ treatment.
Identify target areas for treatment and containment
consistent with Superfund program expectations and
consistent with ARARs and TBCs specific to PCB
contamination.
3. Identify process options for various response actions.
Treatment options for PCBs include incineration,
5
solvent extraction, KPEG, or other removal/destruction
methods. Immobilization techniques may also be
considered. Long-term management controls appropriate
for the material remaining on site should be noted.
4. Evaluate/screen process options to determine which are
technically feasible for the site.
5. Combine feasible process options to formulate
alternative remedial actions for detailed analysis.
This document provides general guidance on two primary
aspects of the development of alternatives process that are
considered and revised throughout the completion of the
steps listed above:
o Determination of the appropriate concentration of PCBs
that can remain at a site (remediation goal) under
various site use assumptions. This is based on standard
exposure and fate assumptions for direct contact. A
qualitative consideration of potential migration to
ground water and environmental impacts is included for
site-specific assessment.
This concentration will reflect the level that will
achieve the program goal of protection and will be
achieved through removal and treatment to this level or
by restricting exposure to contamination remaining above
this level.
o Identification of options for addressing contaminated
material and the implications, in terms of long-term
management controls, associated with these options.
Remedial actions will fall into three general
categories: overall reduction of PCB concentrations at
the site (through removal or treatment) such that the
site can be used without restrictions, complete
containment of the PCBs present at the site with
appropriate long-term management controls and access
restrictions, and a combination of these options in
which high concentrations are reduced through removal or
treatment but the levels remaining still warrant some
management controls.
The determination of what combination of treatment and
containment is appropriate will be guided by the program
expectations to treat the principal threats and contain
and manage low-threat material. ~he determination of
what constitutes a principal threat will be site-
specific but will generally include material
contaminated at concentrations of PCBs that exceed 100
ppm (residential areas) or 500 ppm (industrial areas).
6
The type of treatment selected will take into account
the program expectation to consider innovative
treatment. Treatment that is often comparable in
performance to but less costly than incineration may be
attained using solvent extraction or KPEG. In addition,
the potential for adverse affects from incineration can
be removed through use of one of these technologies, in-
situ vitrification, and in some cases, solidification.
For both evaluations, pertinent ARARs and TBCs are
identified.
Finally, this document will: 1) discuss some of the
unique factors associated with response actions at PCB-
contaminated sites that might be considered under the
detailed analysis of alternatives using the evaluation
criteria outlined in the proposed NCP, 2) indicate how these
factors might be evaluated in selecting the site remedy, and
3) outline the findings that should be documented for the
selected remedy.
1.4 Organization of Document
The remainder of this document is divided into four
chapters and six appendices, summarized below. At the
beginning of each chapter a brief summary highlighting the
main points of the section is provided.
Chapter 2 describes the potential ARARs and TBCs most
commonly identified for sites involving PCB contamination.
This discussion has been separated from the background
section because of the complexity of the regulatory
framework.
Chapter 3 provides general guidelines for determining
PCB concentrations appropriate to leave on site under
various scenarios. The primary factors affecting this
determination are the medium that is contaminated, the
exposure assumptions for the site, and the extent and level
of contamination that is to be addressed.
Chapter 4 outlines the remediation options for material
which warrants active response. Options include treatment
that destroys the PCBs and long-term management controls
that prevent exposure to PCBs. The regulatory implication~
of each option are discussed. ·
Chapter 5 summarizes the primary considerations
associated with determining the appropriate response action
for a PCB contaminated Superfund site in terms of the nine
evaluation criteria used in the detailed analysis. Key
tradeoffs likey to occur among alternatives are noted.
7
Finally, the findings specific to actions addressing PCBs
that should be documented in the Record of Decision are
presented.
Appendix A provides a summary of the Superfund sites
involving PCBs for which RODs have been signed, including
type of response action chosen and clean-up levels
specified.
Appendix B provides the detailed calculations supporting
the direct contact risk evaluation presented in Chapter 3.
Appendix C provides the backup calculations and
methodology for the example evaluation of long term
management controls presented in Chapter 4.
Appendix D includes two case studies of Superfund site
actions involving PCB contamination: Peppers Steel, FL
where the remedy involved solidification and Wide Beach, NY
where treatment using the KPEG process was selected.
Appendix E provides a list of the currently permitted
PCB disposal companies and their addresses and phone
numbers. It also includes a list of EPA's Regional PCB
disposal contacts in the TSCA program and their phone
numbers.
Appendix F provides examples of long-term management
controls implemented at several PCB Superfund sites where
varying concentrations of PCBs were left on site.
8
Chapter 2
Potential ARARs and "To-Be-Considered" Guidelines
Pertinent to PCB Contamination Sites
Actions taken at superfund sites must meet the mandates
of CERCLA as provided for in the NCP. This requires that
remedial actions protect human health and the environment,
comply with or waive applicable or relevant and appropriate
requirements, be cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. In
addition, there is a preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as a
principal element. Although the basic superfund approach to
addressing PCB-contaminated sites is consistent with other
laws and regulations, this consistency must be documented in
the feasability study and ROD to demonstrate that ARARs have
been attained or waived. Primary Federal ARARs for PCBs
derive from the Toxic substances control Act (TSCA) and the
Resource Conservation and Recovery Act (RCRA).
TSCA requires that material contaminated with PCBs at
concentrations of 50 ppm or greater be disposed of in an
incinerator or by an alternate method that achieves a level
of performance equivalent to incineration. Liquids at
concentrations above 50 ppm but less than 500 ppm and soils
contaminated above 50 pp~ may also be disposed of in a
chemical waste landfill.
RCRA requirements apply to PCBs when liquid waste that
is hazardous under RCRA contains PCBs at concentrations
greater than 50 ppm or non-liquid hazardous waste contains
total Hoes at concentrations greater than 1000 ppm. The
land disposal restrictions require that prior to placing
this material on the land, it must be incinerated unless a
treatability variance is obtained.
Other requirements that derive from the Clean water Act
(CWA) and Safe Drinking Water Act (SDWA) and their
implementing regulations may apply or be relevant and
appropriate when the site involves surface or ground water
contamination.
9
2.1 National Contingency Plan (NCP) (U.S. EPA, 1990a)
The primary regulation that governs actions at PCB-
contaminated Superfund sites is, of course, the National
Contingency Plan (NCP), which defines the framework for
addressing the requirements of CERCLA. The provisions of
the NCP form the basis for the guidance provided in this
document and will not be discussed in detail here but will
be discussed in each section as they form the basic
structure for the approach. The NCP implements the
following CERCLA requirements:
o Protect human health and the environment (CERCLA Section
121(b))
o Comply with the applicable or relevant and appropriate
requirements (ARARs) of Federal and State laws (CERCLA
Section 121 (d) (2) (A)) or justify a waiver (CERCLA
Section 121 (d) (4))
o Be cost-effective, taking into consideration short-and
long-term costs (CERCLA Section 121(a))
o Utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable (CERCLA Section 121(b))
o Satisfy the preference for remedies that employ
treatment that permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as
a principal element or provide in the ROD an explanation
of why treatment was not chosen. (CERCLA Section 121(b))
The nine evaluation criteria discussed in Section 5 are
designed to elicit the appropriate information that will
form the basis for demonstrating that these requirements
have been satisfied. Because remedies must attain the ARARs
of other Federal and State laws, some background and summary
material on the ARARs that address PCB contamination is
presented in this section.
ARARs for treating or managing PCB-contaminated material
derive primarily from two sets of regulations: the Toxic
Substances Control Act (TSCA) PCB regulations and the
Resource Conservation and Recovery Act (RCRA) land disposal
restrictions (LDRs). Where PCBs affect ground or surface
water, the Safe Drinking Water Act (SDWA) and Clean Water
Act (CWA) may provide potential ARARs for establishing
remediation goals; i.e., Maximum Contaminant Levels (MCLs),
Maximum Contaminant Level Goals (MCLGs), and Water Quality
Criteria (WQC). In addition, the PCB Spill Policy, which is
10
not an ARAR although it is published in the Code of Federal
Regulations, should be considered when determining cleanup
levels at a site. Other "to-be-considered" (TBC)
information is provided by guidances developed by the Office
of Toxic Substances to assist in implementing the PCB
regulations of TSCA.
2.2 TSCA PCB Regulations
The TSCA PCB regulations of importance to Superfund
actions are found in 40 CFR Section 761.60 -761.79, Subpart
D: Storage and Disposal. They specify treatment, storage,
and disposal requirements for PCBs based on their form and
concentration. The disposal options for PCB-contaminated
material are summarized in Table 2-1 and discussed in the
following sections. A final section describes the storage
requirements.
TSCA requirements do not apply to PCBs at concentrations
less than 50 ppm; however, PCBs cannot be diluted to escape
TSCA requirements. Consequently, under TSCA PCBs that have
been deposited in the environment after the effective date
of the regulation, February 17, 1978, are treated, for the
purposes of determining disposal requirements, as if they
were at the concentration of the original material. For
example, if PCB transformers leaked oil containing PCBs at
greater than 500 ppm, the soil contaminated by the oil would
have to excavated and disposed of as if ail of the PCB-
contaminated soil contained PCBs at greater than 500 ppm.
This reflects an interpretation of the anti-dilution
provisions in TSCA (40 CFR 761.l(b)) and was developed with
the intent of eliminating the incentive responsible parties
might have to dilute wastes in order to avoid regulation.
EPA has clarified that the TSCA anti-dilution provisions
are only applicable to CERCLA response actions that occur
once a remedial action is initiated (U.S. EPA, 1990a). In
selecting response action strategies and cleanup levels
under CERCLA, EPA should evaluate the form and concentration
of the PCB contamination "as found" at the site, and dispose
of it in accordance with the requirements of 40 CFR
761.60(a) (2) -(5). Cleanup levels and technologies should
not be selected based on the form and concentration of the
original PCB material spilled or disposed of at the site
prior to EPA's involvement (i.e., the anti-dilution
provision of the PCB rules should not be applied). Because
EPA comes to a site under the CERCLA after the pollution has
already occurred, and is acting under statutory mandate to
select a proper cleanup level, EPA is not subject to the
anti-dilution provision at CERCLA sites when it selects a
remedy. However, the Agency may not further dilute the PCB
11
,----
Table 2-1
RE.MEDIATION OPTIONS FOR PCB WASTE UNDER TSCA
Chemical
PC8 was1e MethOd Drain,
PCB was1e 40CFR concenira1ion Incinerator landfill dispose as
category Section (ppm) (§761. 70) (§761 .75) solid
Liquid PCB 761.80 :i!500 X
Liquids wi1h 761. 75 50-500 X X X X
flash point > 60° c
Liquids wi1h 761 . 75 50-500 X X X
flash poin1 < 600 C
Other liquids Iha! are 268.42[a)[1] 50-500 X X X
also hazardous wastes
Other liquids Iha! are 268.42[a)[1] :i!500 X X
also hazardous wastes
Nonliquids (soil, 761 .60(a)[4] :i!SO X X X
rags, debris)
Dredged materials 761 .60(a](5] :i!SO X X X X
and minicipal sewage
sludge
PCB transformers 761 .60[b)[1] Ni" X X
(drained and flushed)
PCB capacitorsb 761.60[b](2] :i!500 X
PCB capacitors 761 .60(b](4] 50-500 X X
PCB hydraulic machines 761 .60(b)(3] :i!50
PCB con1aminated 761 .60(b](4]
electrical equipment
(except capacitors)
Other PCB anicles 761 .60(b )[5] :i!500 I X xa
Other PCB anicles 761 .60(b](5] 50-500
PCB containers 761 .60[c] :i!5001 X Xd
PCB containers 761 .60(c] <500
All other PCBs 761 .60(8] ~50 X X
aNot specified.
bExemplions for some small capacitors.
cMust also be flushed if hydraulic fluid contains >1,000 ppm PCBs and flushing solvent disposed of in accordance with §761.SO(a).
dDrained liquid must be disposed of In accordance with §761.60(a).
e Must be drained of all frM-flowtng llquld. The dllposal of the drained electrical equipment and other PCB anicles is n01 regulated
W8S18
Xc,d
x"
Xd
by 40 CFR 761 . All liquids fflUII be dlapoMd of In accordance with paragraph (a)(2) or (3) ot §781 .60 (In an incinerator (§781.70), chemical
waste landfill (761 .75), high efflclenc:y boiler, or by an alternative method (§761.60(0)).
f Due 10 a typographical error, 40 CFR 781 (July 2, 1985, p. 163) erroneously states this value • 50 ppm; refer to Federal Register, ~.
3:514-31568 (May 3,1979) (USEPA).
9Drained of any free-flowing llquld and liquid Incinerated In a §781 .70 Incinerator.
hDecontaminoted In compliance with §781. 79.
12
Decon1am,n a1,on
'I!'
'I!'
waste in order to avoid the TSCA PCB disposal requirements
as part of a CERLCA cleanup.
2.2.1 Liquid PCBs at Concentrations Greater Than 500 ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. High Eff. Alt.
761.70 Boiler Method
761. 60 761.60{e)
Liquid PCB 761.60 X X
Other Liq.
also Haz. 268.42(a) (1) X X
Liquid PCBs at concentrations greater than 500 ppm must
be disposed of in an incinerator which complies with 40 CFR
761.70 or by an alternative disposal method that achieves a
level of performance equivalent to incineration as provided
under 761. 60 (e). This h?.s been interpreted to imply that
treatment residuals must contain less than 2 ppm PCBs.
2.2.2 Liquid PCBs at Concentrations Between 50 ppm and 500
ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. High Eff. Alt. Chem.
761.70 Boiler Method Waste
761.60 761.60(e)Landfl.
761. 75
Liq. w/ 761. 75 X X X X
flash pt > 60C
Liq. w/ 761. 75 X X X
flash pt < 60C
Other liq.268.42(a) (a) X X X
also haz.
Liquid PCBs at concentrations between 50 ppm and 500
ppm, can be disposed of in an incinerator or high efficiency
boiler as described above, or in a facility that provides an
alternative method of destroying PCBs that achieves a level
of performance equivalent to incineration (equivalent
method) approved under 40 CFR 761.60(e) (i.e., demonstrate
13
. ,
achievement of less than 2 ppm PCBs in the treatment
residual).
Liquids at these concentrations with a flash point
greater than 60 degrees Centigrade (not considered ignitable
as defined in 761.75(b) (8) (iii)) other than mineral oil
dielectric fluid, can also be disposed of in a chemical
waste landfill which complies with 40 CFR 761.75. However,
the following actions must be taken:
o Bulk liquids must be pretreated and/or stabilized (e.g.,
chemically fixed, evaporated, mixed with dry inert
absorbant) to reduce its liquid content or increase its
solid content so that a non-flowing consistency is
achieved;
o Containers of liquid PCBs must be surrounded by an
amount of inert sorbant material capable of absorbing
all of the liquid contents of the container.
2.2.3 Non-Liquid PCBs at Concentrations Greater Than or
Equal to 50 ppm
Remediation Options for PCB Waste Under TSCA/RCRA
Waste cat. 40CFR Sec. Incin.
761. 70
Non-liq. 761.60(a) (4) X
soil, rags,
debris
Dredged 761.60(a) (5) X
material, munic.
sewage sludge
Alt. Chem. Method
Treatmt. Waste Apprvd.
761.60(e)Landfl. by RA
761.75 761.60(a) (5)
X X
X X X
Soils and municipal sludges contaminated with PCBs at
concentrations greater than or equal to 50 ppm can be
disposed of in an incinerator, treated by an equivalent
method, or disposed of in a chemical waste landfill.
Industrial sludges with PCB concentrations greater than 500
ppm may not be landfilled. The determination of whether
contaminated material should be considered a soil or an
industrial sludge should be made site specifically
consistent with the current process for classifying material
subject to the land disposal restrictions as either a pure
waste or a soil and debris contaminated with a waste.
14
' l
Dredged materials and municipal sewage treatment sludges
that contain PCBs at concentrations greater than or equal to
50 ppm can also be disposed of by methods other than those
noted above that are approved by the Regional Administrator.
It must be demonstrated that disposal in an incinerator or
chemical waste landfill is not reasonable and appropriate,
and that the alternate disposal method will provide adequate
protection to health and the environment.
2.2.4 PCB Articles, Containers, Electrical Equipment
Remediation Options for PCB Waste Under TSCA/RCRA
Waste Cat. 40CFR Sec. Incin. Alt. Chem. Drain Decon.
761.70 Treatmt. Waste Dispose
761.60(e)Landfl.as sol.
761.75 waste
PCB 761.60(b) (1) X X X
transformers
PCB 761. 60 (b) (2)
capacitors
(>= 500 ppm)
PCB 761. 6 0 ( b) ( 4 )
capacitors
(50 -500 ppm)
PCB hyd. 761.60(b) (3)
machines
PCB elec.761.60(b) (4)
equip.
PCB 761.60(b) (5)
articles
(>=500 ppm)
PCB 761. 60 (b) (5)
articles
(50 -500 ppm)
PCB 761.60(c)
containers
(>=500 ppm)
PCB 761.60(c)
containers
(<500 ppm)
X X
X X X
X
X
X X X
X
X X X
X
PCB transformers and capacitors (by definition (40CFR
761.60) these contain 500 ppm PCB or greater as opposed to
15
. x--:;
X
L
PCB-contaminated electrical equipment which contains less
than 500 ppm) must be disposed of in an incinerator, by an
alternate method which can achieve a level of performance
equal to incineration, or in a chemical waste landfill.
However, special procedures must be followed for disposing
of transformers in chemical waste landfills and a special
showing indicating that incineration capacity does not
exist, that incineration of the capacitors will interfere
with the incineration of liquid PCBs, or other good cause,
must be made for disposing capacitors in landfills. These
are described in 40 CFR 761.60(b).
PCB-contaminated electrical equipment (this includes
transformers and other equipment other than capacitors which
contain PCBs between 50 ppm and 500 ppm) must be drained of
all free flowing liquid. The liquid must be disposed of in
an incinerator, by an equivalent method, or in a chemical
waste landfill. The drained equipment is not covered under
TSCA regulations. PCB-contaminated capacitors must be
disposed of in an incinerator or a chemical waste landfill.
PCB articles and containers with PCB concentrations
greater than 500 ppm must be incinerated or disposed of in a
chemical waste landfill provided all free flowing liquid is
drained and incinerated. PCB articles and containers with
PCB concentrations between 50 ppm and 500 ppm must be
disposed of by draining all free flowing liquid and
appropriately disposing of the liquid. The drained articles
and containers can be disposed of as municipal solid waste.
2.2.5 TSCA Chemical Waste Landfill Requirements
The requirements for chemical waste la are
describe in 4 CFR Section 761.75 and outlined in Table 2-
2. As indicated, the regulations do not require caps
because the regulations were designed for operating
landfills. Where Superfund remedial actions will leave PCBs
in place or where PCB-contaminated material is excavated,
treated, and re-dis osed at concentrations that still ose a
re , in consisten with chemical waste landfill
equirements is general! a ropriate. (Long-term
nagemen controls for PCB-con aterial enerally
w a so ara lel RCRA closures.) However, some of the
equirements specified under TSCA may not always be
appropriate for existing waste disposal sites like those
addressed by Superfund. When this is the case, it may be
appropriate to waive certain requirements, such as liners,
under the TSCA waiver provisions, 761.75(c) (4).
Requirements may be waived when it can be demonstrated that
operation of the landfill will not present an unreasonable
risk of injury to health or the environment. This
16
r
I
Table 2-2
TSCA CHEMICAL WASTE LANDFILL REQUIREMENTS
(40 CFR SECTION 761.75)
I . Located in thick, relatively impermeable formation such as large area clay pans, or:
• On soil with high clay and silt content with the following parameters:
· in-place soil thickness of four feet or compacted soil liner thickness of three feet
-permeability equal to or less than I x 10-7
-percent soil passing No. 200 Sieve, greater than 30
-liquid limit greater than 30
-plasticity index greater than 15.
•Ona synthetic membrane liner (minimum thickness of 30 mils.) providing permeability equivalent to the soil
described above including adequate soil underlining and soil cover to prevent excessive stress on or rupture of
the liner.
2. A. Bottom of the landfill liner system or natural in-place soil barrier at least 50 feet from the historical high
ground water table. Floodplains, shorelands, and ground water recharge areas shall be avoided and there shall
be no hydraulic connection between the site and standing or flowing surface water.
B. If the landfill is below the 100-year floodwater elevation, surface water diversion dikes should be constructed
around the perimeter with a minimum height equal to two feet above the 100-year floodwater elevation.
If the landfill is above the 100-year floodwater elevation, diversion structures capable of diverting all of the
surface water runoff from 24-hour, 25-year storm.
3. Located in an area of low to moderate relief to minimize erosion and to help prevent landslides or slumping.
4. Sampling of designated surface watercourses monthly during disposal activities and
once every six months after disposal is completed.
5. Ground water monitoring at a minimum of three points (equally spaced on a line through the center of the
landfill), sampling frequency determined on a site specific basis (not specified in regulation) samples analyzed
for PCBs, pH, specific conductance, and chlorinated organics.
6. Leachate Collection System:
A. Gravity flow drainfield installed above the liner (recommended for use when semi-solid or leachable solid ..-
wastes are placed in a lined pit excavated into a relatively unsaturated homogeneous layer of low permeable
soil) or
B. Gravity flow drainfield installed above the liner and above a secondary liner (recommended for use when
semi-liquid or leachable solid wastes are placed in a lined pit excavated into relatively permeable soil) or
C. Network of porous ceramic cups connected by hoses/tubing to a vacuum pump installed along the si~e_s and
under the bottom of the waste disposal facility liner (recommended for relatively permeable unsaturatcll soil
immediately adjacent to the bottom and/or sides of the disposal facility).
7. Installation of a six foot woven mesh fence, wall, or similar device to prevent unauthoriud persons and animals.
Note: Waiver Provision (761.75 (c)(4) )· One or more of the above requirements may be waived as long as operation
of the landfill will not present an unreasonable risk of injury to health or the environment.
17
demonstration may require column studies verifying that PCB
movement through the soil will not adversely affect ground
water. These waivers are distinct from the six waivers from
ARARs provided under CERCLA Section 121(d) (2), which may
also be invoked under appropriate circumstances.
2.2.6 Storage Requirements
The requirements for storage of PCBs are described in 40
CFR Section 761.65. The regulations specify that PCBs at
concentrations of 50 ppm or greater must be disposed of
within one year after being placed in storage. The
regulations also include structural requirements for
facilities used for the storage of PCBs and requirements for
containers used to store PCBs.
PCBs stored as part of a Superfund action should be
placed in facilities that meet the following specifications:
o Provide an adequate roof and walls to prevent rain
water from reaching the stored PCBs,
o Provide an adequate floor which has continuous curbing
with a minimum six inch high curb,
o Contain no drain valves, floor drains, expansion
joints, sewer lines, or other openings that would
permit liquids to flow from the curbed area,
o Floors and curbing constructed of continuous smooth and
impervious materials, to minimize penetration of PCBs;
and
o Not located at a site that is below the 100-year flood
water elevation.
PCBs subject to TSCA should not be stored longer than one
year. In some cases, PCB-contaminated material may be
generated during the RI/FS that will require storage that
may exceed the one-year limitation under TSCA. Where the
final disposition of the waste will be specified in the ROD,
the exceedence of the TSCA storage limitation may be
justified using a CERCLA waiver. An interim remedy waiver
under CERCLA could be invoked. Since the removal action is
interim in nature and the remedy determined in the ROD will
comply with ARARs for final disposition of the waste, a
waiver of the ARAR is justified. A memorandum supporting
the action should be prepared and placed in the
administrative record to document the finding.
18
2.3 RCRA Regulations Addressing PCBs
Closure requirements described under RCRA are considered
potentially applicable or relevant and appropriate at
Superfund sites. A detailed discussion of these
requirements is not presented in this document since they
are not specific to PCBs. Instead, guidelines for long
term management controls consistent with RCRA closure
requirements that are warranted under various closure
scenarios are provided in section 4.3. (Further discussion
of the closure requirements under RCRA and their use at
Superfund sites can be found in the CERCLA Compliance With
Other Laws Manual (U.S. EPA, 1989b) .)
PCBs are specifically addressed under RCRA in 40 CFR 268
which describes the prohibitions on land disposal of various
hazardous wastes. Note that RCRA regulations only apply to
waste that is considered hazardous under RCRA; i.e., listed
in 40 CFR 261.3 or characteristic as described in 40 CFR
261.2. PCBs alone are not a RCRA hazardous waste; however,
if the PCBs are mixed with a RCRA hazardous waste they may
be subject to land disposal restrictions as summarized
below.
PCBs are one of the constituents addressed by the land
disposal restrictions under the California List Wastes.
This subsection of wastes covers liquid hazardous wastes
containing PCBs at concentrations greater than or equal to
50 ppm and non-liquid hazardous wastes containing total
concentrations of HalogenatedOrganic compounds (HQCs) &t
concentrations greater than 1000 m. CBs are included in
prov1 ed in the regulation (Appendix III
part
2.3.1 Liquid Hazardous Waste With PCBs at 50 ppm or Greater
As described in 40 CFR 268.42(a) (1), liquid hazardous
(RCRA listed or characteristic) wastes containing PCBs at
concentrations greater than or equal to 500 ppm must be
incinerated in a facility meeting the requirements of 40 CFR
761.70. Liquid hazardous wastes containing PCBs at
concentrations greater than or equal to 50 ppm but less than
500 ppm must be incinerated or burned in a high efficiency
boiler meeting the requirements of 40 CFR 761.60.
A method of treatment equivalent to the required
treatment may also be used under a treatability variance
procedure if the alternate treatment can achieve a level of
performance equivalent to that achieved by the specified
method as described in 40 CFR 268.42(b).
19
2.3.2 Hazardous Waste With HOCs at 1000 ppm or Greater
Liquid and non-liquid hazardous wastes containing HOCs
in total concentration greater than or equal to 1000 ppm
must be incinerated in accordance with the requirement of 40
CFR 264 Subpart 0.
Again, a method of treatment equivalent to the required
treatment, under a treatability variance, may also be used.
Special considerations are pertinent for waste that
falls into the category of soil and debris from a CERCLA
remedial action or RCRA Corrective Action. The land
disposal restrictions for CERCLA soil and debris went into
effect November 8, 1988; however, no standards for disposal
were published at that time. Consequently soil and debris
contaminated with hazardous waste is banned from land
disposal unless it meets existing standards for the pure
waste or qualifies for a treatability variance. The
preamble to the NCP, established a general presumption that
a treatability variance is warranted for CERCLA soil and
debris. Alternate treatment levels should be justified
based on the treatability variance guidance levels (U.S.
EPA, 1989h). For PCBs, residuals after treatment should
contain .1 to 10 ppm PCBs for initial concentrations up to
100 ppm and above 100 ppm, treatment should achieve 90 to
99% reduction in concentration to qualify for a treatability
variance.
Finally, hazardous wastes for which the treatment method
is incineration or the treatment standard was based on
incineration are subject to a 2-year capacity extension from
the time that the standard went into place. Wastes that
qualify for a capacity extension can be disposed without
meeting the treatment requirements; however, they must be
disposed of in a facility that is in compliance with the
minimum technology requirements established for landfills in
section 3004(0) of RCRA. The capacity extension for
California List wastes when they are present in CERCLA soil
and debris extends until November 8, 1990.
2.4 Clean Water Act
The Clean Water Act establishes requirements and
discharge limits for actions that affect surface water.
Water Quality Criteria (WQC} indicating concentrations of
concern for surface water based on human exposure through
drinking the water and ingesting fish as well as
concentrations of concern to aquatic life have been
developed for many compounds. For PCBs, the WQC for chronic
20
exposure through drinking water and fish ingestion is
.000079 ppb based on an excess cancer risk of 10·6 • This
assumes consumption of 6.5 grams of estuarine fish and
shellfish products and 2 liters of water per day over a 70
year lifetime. The level is the same if consumption of
water is excluded indicating a relative negligible impact
due to this source.
Acute toxicity to freshwater aquatic life is estimated
to occur only at concentrations above 2 ppb. Acute toxicity
to saltwater aquatic life is estimated to occur only at
concentrations above 10 ppb. The water quality criteria for
chronic effects are .014 ppb and .03 ppb for fresh and
saltwater aquatic life, respectively.
These values are used as guides in the development of
water quality standards for surface water that are enforced
at the State level. States may account for other factors in
establishing these standards including physical, chemical,
biological, and economic factors. State standards and/or
WQC are ARAR for surface water discharges. More detailed
discussion of the CWA ARARs can be found in the CERCLA
Compliance Manual (U.S. EPA, 1989b).
2.5 Safe Drinking Water Act
Under the Safe Drinking Water Act (SOWA), Maximum
Contaminant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) are established. MCLs for carcinogens are
generally set at levels that reflect an excess cancer risk
due to drinking 2 liters of water per day over a 70 year
life of between 10·4 and 10·6 • They are set as close as
practicable to the MCLG (which for carcinogens is zero)
accounting for the use of the best available technology,
cost, and analytical capabilities. MCLs must be attained by
public water supplies. MCLGs are goals set at levels that
would result in no known or anticipated adverse effects to
human health over a lifetime. At Superfund sites, MCLs and
non-zero MCLGs may be relevant and appropriate to
contaminated ground water that is or could be used as
drinking water.
An MCL of .5 ppb was proposed for PCBs in May 1989 (U.S.
EPA, 1989d). The MCLG is zero because PCBs are possible
carcinogens. As a proposed MCL, the .5 ppb level is a TBC
that EPA recommends be considered in determining the
appropriate cleanup level for potentially drinkable ground
water. (The MCL for PCBs is expected to be finalized by
September 1990.) More detailed discussion of the SOWA
ARARs can be found in the CERCLA Compliance Manual (U.S.
EPA, 1989b).
21
2.6 PCB Spill Cleanup Policy Under TSCA
The PCB Spill Cleanup Policy was published in 40 CFR
761.120 -761.139 on April 2, 1987 and describes the level
of cleanup required for PCB spills occurring after May 4,
1987 (the effective date). Because it is not a regulation
and only applies to recent spills (reported within 24 hours
of occurrence), the Spill Policy is not ARAR for Superfund
response actions; however, as a codified policy representing
substantial scientific and technical evaluation it has been
considered in developing the guidance cleanup levels
discussed in section 3. A summary of th~-policy follows.
2.6.1 Low Concentration, Low Volume Spills All Areas
For spills of low concentration PCBs (50 ppm to 500 ppm)
involving less than one pound of PCBs, cleanup in accordance
with procedural performance requirements is required. The
requirements consist of double wash rinse and cleanup of
indoor residential surfaces to 10 micrograms (ug) per 100
square centimeters (cm2) analyzed by a wipe test, and
excavation of all soils within the spill area plus a 1-foot
lateral boundary of soil and other ground media and
backfilling with clean (less than 1 ppm PCB) soil. No
confirmation sampling is required.
2.6.2 Non-Restricted Access Areas
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound PCBs by weight in
non-restricted access areas, materials such as household
furnishings and toys must be disposed of and soil and other
similar materials must be cleaned up to 10 ppm PCBs,
provided that the minimum depth of excavation is 10 inches.
In addition, a cap of at least 10 inches of clean materials
must be placed on top of the excavated area. Indoor and
outdoor surfaces must be cleaned to 10 ug/100 cm2 , but low
contact outdoor surfaces may be cleaned to 100 ug/100 cm2
and encapsulated. Post clean-up sampling is required.
2.6.3 Industrial Areas
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound in industrial and
other restricted access areas, cleanup of soil, sand, and
gravel to 25 ppm PCBs is required. Indoor high contact and
outdoor high contact surfaces must be cleaned to 10 ug/100
22
cm2• Indoor low contact surfaces may be cleaned to 10
ug/100 cm2 or to 100 ug/100 cm2 and encapsulated. outdoor
low contact surfaces may be cleaned to 100 ug/100 cm2 • Post
cleanup sampling is required.
2.6.4 Outdoor Electrical Substations
For spills of 500 ppm or greater PCBs and spills of low-
concentration PCBs of more than one pound at an outdoor
electrical substation, cleanup of solid materials such as
soils to 25 ppm or to 50 ppm (with a sign posted) is
required. All surfaces must be cleaned to 100 ug/100 cm2 •
Post cleanup sampling is required.
2.6.5 Special Situations
For particular situations, decontamination to site-
specific requirements established by EPA Regional Offices is
required. These situations are:
1. Spills that result in direct contamination of surface
waters;
2. Spills that result in direct contamination of sewers or
sewage treatment systems;
3. Spills that result in direct contamination of any
private or public drinking water sources;
4. Spills which migrate to and contaminate surface waters,
sewers, or drinking water supplies;
5. Spills that contaminate animal grazing land; and
6. Spills that contaminate vegetable gardens.
2.7 Guidances
Several documents have been produced that provide
background information and guidance on complying with the
regulations and policy described above. Pertinent
information provided by some of the more important documents
are described in this section. This material is "to-be-
considered" in developing remedies at Superfund sites.
23
2.7.1 Draft Guidelines for Permit Applications and ✓-
Demonstrations --Test Plans for PCB Disposal by Non-
Thermal Alternate Methods (U.S. EPA, 1986c)
The most significant information in this document
affecting actions taking place at Superfund sites is the
discussion provided on evaluating the "equivalency" of
technologies to incineration. As described in section 2.2,
most PCB-contaminated material can be treated by an
alternate method provided that it can achieve a level of
performance equivalent to an incinerator or a high
efficiency boiler. The guidance manual indicates that an
equivalent level of performance for an alternate method of
treatment of PCB-contaminated material is demonstrated if it
reduces the level of PCBs to less than 2 ppm measured in the
treated residual. The residual can then be disposed of on-
site without further regulation. Otherwise, the material
must be treated as if it were contaminated at the original
level (i.e., disposed of in a chemical waste landfill or
incinerated).
This level was based on the practical limit of
quantification for PCBs in an organic matrix and
consequently does not apply to aqueous or air emissions
produced by the treatment process. For aqueous streams the
guidance provides that they must contain less than 3 ppb
PCBs. Releases to air must be less than 10 ug of PCBs per
cubic meter. It should be noted that these levels apply to
treatment processes only and were not intended to be used as
cleanup standards for reentry or reuse.
2.7.2 Verification of PCB Spill Cleanup by Sampling and
Analysis (U.S. EPA, 1985b)
This document describes methods for sampling and
analyzing PCBs in various media. It also includes basic
sampling strategies, identification of sampling locations,
and guidance on interpreting sampling results. This manual
may be useful in developing sampling plans at Superfund
sites and in identifying appropriate methods for complicated
sampling, for instance sampling of structures.
2.7.3 Field Manual for Grid Sampling of PCB Spill Sites to
Verify Cleanup (U.S. EPA, 1986b)
This manual provides a step-by-step guidance for using
hexagonal grid sampling primarily for determining if cleanup
levels have been attained at the site. It discusses
preparation of the sample design, collection, handling and
preservation of the samples taken, maintenance of quality
24
assurance and quality control, and documentation of sampling
procedures used. It is a companion to the guidance
described in section 2.7.2 that discusses in more detail the
rationale and techniques selected. The field manual
addresses field sampling only and does not provide
information on laboratory procedures. This guidance may be
useful in specifying the appropriate sampling after or
during remedial action to assess progress toward achieving
cleanup goals.
2.7.4 Development of Advisory Levels for PCB Cleanup (U.S.
EPA 1986a)
This document provides the basis for the cleanup levels
developed in the PCB Spill Policy. It discusses the
assumptions made in addressing the dermal contact,
inhalation, and ingestion pathways and may provide useful
information for completing risk assessments at Superfund
sites. An update to the calculations made in this document
to account for recent policy on standard ingestion
assumptions and revised cancer potency factor for PCBs has
been provided in a memorandum (U.S. EPA, 1988d).
2.7.5 Risk Assessment Guidance for Superfund: Human Health
Evaluation (RAG) (U.S. EPA, 1989e)
This document describes the human health evaluation
process conducted as part of the risk assessment at
Superfund sites. It includes standard assumptions for
various exposure pathways that have been used to calculate
starting point action levels in section 3 of this document.
A second volume, Environmental Evaluation Manual,
addressing the environmental evaluation provides general
guidelines on considerations pertinent to evaluating the
impact of contamination on the environment.
25
Chapter 3
Cleanup Level Determination
This section describes various scenarios and
considerations pertinent to determining the appropriate
level of PCBs that can be left in each media that is
contaminated to achieve protection of human health and the
environment. For soils, the starting point action level
(preliminary remediation goal) is 1 ppm for sites where
unlimited exposure under residential land use is assumed.
Higher starting point values (10 to 25 ppm) are suggested
for sites where the exposure scenario is industrial.
Remediation goals for ground water that is potentially
drinkable should be the proposed MCL of .s ppb. Cleanup
levels associated with surface water should account for the
potential use of the surface water as drinking water,
impacts to aquatic life, and impacts through the food chain.
Occasionally, stormwater runoff to nearby streams can
contribute significant environmental or health risks,
e~pecially to those eating contaminated fish.
26
3.1 Soils
The concentration of PCBs in the soil above which some
action should be considered (i.e., treatment or containment)
will depend primarily on the exposure estimated in the
baseline risk assessment based on current and potential
future land use. This section has correspondingly been
organized according to categories of alternatives
differentiated by the expected direct contact that will
occur. Other factors influ~ncing the concentration to which
soils should be excavated or contained include the impact
the residual concentration will have on ground water and
potential environmental impacts. Since these pathways are
pertinent to all site categories, they are discussed in
separate sections. The guideline concentrations provided in
this section do not imply that action must be taken at a
Superfund site, rather they indicate the area over which
some action should be considered once it has been determined
that action is necessary to provide protection of human
health and the environment.
A summary of the guidelines discussed in this section is
presented in Table 3-1.
TABLE 3-1
Recommended Soil Action Levels --Analytical Starting
Points
(Considers ingestion, inhalation, and dermal contact only)
Land Use
Residential
Industrial
PCB Action Levels (ppm)
1 ppm
10 -25 ppm
These action levels and the assumptions discussed in the
following sections can be used to reduce the need for
detailed site-specific risk assessments; however, future
site uses should be well understood and final cleanup levels
must still reflect all relevant exposure pathways and be
defensible on a site-specific basis.
The analysis of PCBs is complicated by the fact that
there are 209 different PCB compounds1 (Alford-Stevens,
1986). Common analytical methods are listed in Table 3-2.
1Aracholors are groups of PCBs with different overall
percentages of chlorine. For example, Arochlor 1242 contains 42%
chlorine made up of tri-and tetra-chlorinated biphenyls. PCB
isomers are those compounds that have the same number of chlorine
atoms. Individual PCBs isomers, of which there are 209, are
called congeners.
27
3.1.1 Preliminary Remediation Goals for Residential Areas
The concentration that defines the area over which some
action must be taken is the concentration of PCBs that can
protectively be left on site without management controls.
In areas where land use is residential, this concentration
will be based on standard assumptions for direct contact
dermal, ingestion, and inhalation --and should consider
potential impact to ground water, which is discussed in
section 3.1.4.
For Superfund sites, the risk remaining after
remediation should generally fall within the range of 10-4
to 10-6 individual excess cancer risk. Based on the
standard exposure assumptions associated with residential
land use (ingestion, inhalation, and dermal contact),
concentrations of .1 ppm PCBs to 10 ppm PCBs will generally
fall within the protective range. A concentration of 1 ppm
PCBs equates to approximately a 10-s excess cancer risk
8ssuming no soil cover or management controls. The 1 ppm
starting point for residential scenarios reflects a
protective, quantifiable concentration for soil. Lower
concentrations (e.g., reflecting a 10-6 risk level) are not
generally quantifiable and in many cases will be below
background concentrations. (Because of the persistence and
pervasiveness of PCBs, PCBs will be present in background
samples at many sites.) A concentration of 1 ppm PCBs
should therefore generally be the starting point for
analysis at PCB-contaminated Superfund sites where land use
is residential. Alternatives should reduce concentration to
this level or limit exposure to concentrations above this
level.
As part of the development of the cleanup levels in the
PCB Spill Cleanup Policy, a detailed analysis of the direct
contact pathways was performed by the EPA Office of Health
and Environmental Assessment (U.S. EPA, 1986a). This
analysis was subsequently updated to account for the revised
cancer potency factor and ingestion assumptions (U.S. EPA,
1988d). This analysis estimates risk levels associated with
various concentrations of PCBs based on physical parameters
of PCB 1254. It is also estimated that a 10 inch cover of
clean soil will reduce risks by approximately one order of
magnitude. Using some of the basic assumptions associated
with PCBs (e.g., mobility, volatility, absorption) described
in this analysis and the standard exposure assumptions for
residential land use presented in the Risk Assessment
Guidance (U.S. EPA, 1989e), risk levels associated with
various concentrations of PCBs in soil were calculated (see
Appendix B). This analysis forms the basis for the
28
Table 3-2
ANALYTICAL METHODS FOR PCBs
,
Matrix Method GC GC/MS
1 Detection Limit Quantification Limit -
Oil Bellar and Lichtenberg yes less than 2 ppm 2 ppm
ASTM 04059 yes less than 2 ppm 2 ppm
-------

-
-----
Soil/
Sediment
Method 680
3,5
yes -100 ppb 1 ppm
Method 608 yes 0.1 -

0
.5 ppb 80 ppb
-------------------
Water EPA Method 505 yes 0.1 -

0
.5 ppb not given
Air
(Microextraction) (based on the
4 arochlor present)
Method 508A
(Perchlorination) 0.1 -0.5 ppb (as not given
decachlorobiphenyl)
Method 680 yes -100 ppb 1 ppm
3,5
Method 608 yes 0.1 -

0
.5 ppb 0.5 ppb
---------------------
NIOSH Method 5503 yes
Florosil sorbent,
hexane extraction,
GC/ECD
1 Detection limit indicates the concentration above which the presence of PCBs will be detected by
the analytical method.
2 Quantification limit indicates the concentration above which the quantity of PCBs present can be
determined.
3 U.S. EPA, 1986d.
4 U.S. EPA, 1988a., Glaser, 1981.
5 Method 608 depends on the presence of an intact Arochlor. Analysts can estimate possible PCB
concentrations when intact Arochlors are not present. However, if this is done the presence of
PCBs should be confirmed using Method 680. Method 680 can identify PCB isomers.
29
--
--
--
analytical starting point summarized here. The primary
assumptions and an example calculation for a PCB
concentration of 1 ppm are shown in Table 3-3. It should be
noted that some of these assumptions may be overly
conservative on a site-specific basis. For example, the
calculation for the inhalation pathway assumes that someone
is on the site 24 hours a day for 30 years and that the
concentration of PCBs in the air in a house on this site
will be the same as the concentration in the air outside.
In many cases, partial covering of the soil will limit the
level of PCBs that can volatilize. Another consideration is
that the calculation was based on the properties of Arachlor
1254 and properties may vary for different congeners as
shown in Table 3-4. Toxicities may also vary (McFarland,
1989; Kimbrough, 1987; Safe, 1985), though there is limited
information on this and the toxicity based on Arachlors 1254
or 1260 should generally be used.
As noted above, these calculations reflect direct
exposure assumptions only and may not be appropriate where
ground water or ecological habitats are potentially
threatened. These levels are consistent with the guidance
provided by the PCB Spill Cleanup Policy which recommends a
10 ppm cleanup level with a 10 inch cover for residential
areas.
3.1.2 Preliminary Remediation Goals for Industrial/Remote
Areas
In remote areas or areas where land use is industrial, a
more appropriate concentration at which to start analysis
may be 10 to 25 ppm, since direct exposure is less frequent
than for residential land use and higher concentrations will
be protective. (Under the PCB Spill Policy this category
includes sites that are more than .1 km from
residential/commercial areas or where access is limited by
either man-made or natural barriers (e.g., fences or
cliffs).) For example, at Superfund sites located in
industrial areas ingestion and inhalation exposures are more
limited than for a residential area. Even assuming exposure
equivalent to that in residential areas, these levels (10 to
25 ppm) are still within the acceptable risk range
(approximately 10·4> based on the direct contact exposure
pathways, and in fact will reflect a lower risk due to the
reduced frequency of exposure expected at the site. This is
consistent with the PCB Spill Cleanup Policy which
recommends a cleanup level of 25 to 50 ppm for sites in
industrial or other reduced access areas.
30
Table 3-3
PCB DIRECT CONTACT ASSUMPTIONS
(See Appendix B for detailed calculation)
INGESTION:
Soil ingestion ( 1 to 6 years)
Soil ingestion (7 to 24 years)
Body weight child
Body weight adult
Absorption of PCBs from
ingested soil
INHALATION
Adult inhalation rate
Lung absorption of inhaled PCBs
DERMAL
Surface area (3 -18 years)
Surface are (adult)
Soil to skin adherence factor
Exposure frequency (child)
Exposure frequency (adult)
Adsorption fraction
0.2 g/dayl
0.1 g/dayl
16 kgl
70 kgl
30%2
30 m31dayl
50%
0.4 m2/eventl
0.31 m2/event 1
2. 77 mg/cm2/l
132 events/yearl
52 events/year
10%3
To estimate exposure, the average concentration of PCBs in soil over the exposure period is
calculated. The concentration of PCBs will decrease with time due to volatilization.
EXAMPLE CALCULATION
At 1 ppm PCB initial soil concentration:
Average concentration over 10 inches over 6 years = 0.54 ppm
Average concentration over 10 inches over 30 years= 0.28 ppm
Risk due to soil ingestion = 2 X 1 o-6
Risk due to inhalation = 7 X 1 o-6
Risk due to dermal contact = 7 X 1 o-6
Total risk (all pathways) = 1.6 X 10-5
~U.S. EPA, 1989e
2u.S. EPA, 1986a
3u.S. EPA, 1986a
31
Table 3-4
CHEMICAL AND PHYSICAL PROPERTIES OF PCBs
Molecular Specific
PCB Weight Kow Gravity
PCB-1016
(Arochlor 1016) 257.9 24,000
PCB-1221 200.7 12,000 1.182
PCB-1232 232.2 35,000 1.266
PCB-1242 266.5 380,000 1.380
PCB-1248 299.5 1,300,000 1.445
PCB-1254 328.4 1,070,000 1.538
PCB-1260 377.5 14,000,000 1.620
PCB-1262 1.646
PCB-1268 1.810
PCB-1270 1.947
PCB-2565 1.727
PCB-4465 1.712
PCB-5442 1.434
PCB-5460 1.740
2,2',5,5'-Tetra-
chlorobiphenyl
2,2',3,4,5-Penta-
chlorobiphenyl
a Hutzinger et al., 1974, Monsanto Chemical Co., undated.
b Mac Kay and Leinonen, 1975.
c Hwang, 1982, and U.S. EPA, 1980b.
Solubility
in Water
(mg/I)
0.42
15.0
1.45
0.24
-2 5.4 X 10
1.2 X 1 ff2
-3 2.7 X 10
-2 4.6 X 10
2.2 X 10-2
Bioaccumulation factor: 31,200 Ukg, (U.S. EPA, 1986a)
Soil-water partition coefficient (U.S. EPA, 1980a): 22 -1938 L/kg.
32
a Vapor
Pressure
(mm Hg)
at 25°C
4 X 10-4
6.7 X 10-4
4.06 X 10-3
4.06 X 10-4
4.94 X 10-4
7.71 X 10-5
4.05 X 10-5
Henry's Law
Constant
(atm-nf/gmol)
5.73 X 10-4 b
3.51 X 10-3 b
8.37 X 10-3 C
7.13 X 10-J
C
3.1.3 Assessing the Impact to Ground Water
Generally, PCB soil cleanup levels based on direct
contact assumptions will provide sufficient protection of
ground water. However, if ground water is very shallow,
oily compounds are or were present, or the unsaturated zone
has a very low organic carbon content, an additional
evaluation of the residual concentration that will not
exceed levels found to be protective for ground water should
be made.
There are many factors such as soil permeability,
organic carbon content, and the presence of organic
colloids, which can influence PCB movement from soil into
ground water. The situation is complicated by the low
solubility of PCBs and the prevalence of their occurrence as
solutes in oils. At this point the migration of PCBs to
ground water can only be described qualitatively. Table 3-4
lists factors affecting migration for several PCBs.
PCBs are very immobile under conditions where the PCB
concentration in the aqueous phase is controlled by the
aqueous solubility of PCBs and transport is governed by
partitioning between the water and soil. However, low
solubility compounds like PCBs may migrate through
facilitated transport on colloidal particles (Backhus, 1988)
or dissolved in more mobile substances such as oils if
present as a separate phase (U.S. EPA, 1989f). Measurements
of dissolved organic carbon (DOC) in leachate may help
assess this movement since PCBs will sorb to the organic
material. Concentrations of PCBs in water samples exceeding
PCB water solubility indicate that PCBs are being
solubilized by something other than water. PCBs in oils
will be mobile if the oil itself is present in volumes large
enough to move a significant distance from the source. If
immiscible fluid flow is significant, PCB transport
predictions must be based on immiscible fluid flow models.
3.2 Ground Water
If PCBs have contaminated potentially drinkable ground
water, ground water response actions should be considered. ·•
As discussed above, PCBs generally have low mobility but can
be transported with oils in which they may be dissolved. A
problem that arises is that once the immiscible fluid has
been immobilized through capillary retention in the soil
pore space (termed the residual saturation), PCB transport
is governed by the rate at which the PCBs dissolve from the
oil into the water moving past the residually saturated oil.
This is a very slow process with the residual saturation
serving as a long-term source of contamination.
33
Emulsification of the residual oil, and PCB transport in
micelles may also occur.
PCBs have also been found to migrate within aquifers
sorbed to colloidal particles. This movement can be
assessed through analyzing both filtered and unfiltered
ground water samples for PCBs (U.S. EPA, 1989f and U.S. EPA,
1989g).
In both scenarios described above, PCBs can be found in
unfiltered ground water samples at levels that exceed health
based concentrations. The proposed MCL for PCBs is .5 ppb
reflecting a 10-4 excess cancer risk. (Proposed MCLs are
considered TBC for ground water that is potentially
drinkable.) These situations are also very difficult to
address actively. In the first case, residual oil lodged in
pore spaces continues to be a source of PCBs and are very
difficult to remove through traditional pump and treat
methods. In the case of PCBs present on particulates, the
rate of removal through ground water extraction may be very
limited and substantial amounts of clean water will be
affected as it is pulled into the contaminated zone.
Because of the technical impracticability of reducing
concentrations to health-based levels, remedies designed to
prevent further migration of contaminants may be the only
viable option for portions of the contaminated ground water.
This may involve removing more soluble organics present
which increase the mobility of the PCBs present.
3.3 Sediment
The cleanup level established for PCB-contaminated
sediment may be based on direct contact threats using
exposure assumptions specific to the site if the surface
water is used for swimming. More often, the impact of PCBs
on aquatic life and consumers of aquatic life will drive the
cleanup level. Interim criteria for sediment based on
achieving and maintaining WQC in the surface water have been
developed for several chemicals (U.S. EPA, 1989a). The
approach used to estimate these values is called the
Equilibrium Partioning Approach (EP) which is based on two
interrelated assumptions. First, that the interstitial
water concentration of the contaminant is controlled by
partitioning between the sediment and the water at
contaminant concentrations well below saturation in both
phases. Thus, the partitioning can be calculated from the
quantity of the sorbent on the sediment and the appropriate
sorption coefficient. For nonpolar organic contaminants,
the primary sorbent is the organic carbon on the sediment;
therefore, the partition coefficient is called the organic
carbon normalized partition coefficient, Koc· Second, the
34
toxicity and the accumulation of the contaminant by benthic
organisms is correlated to the interstitial, or pore water
concentration and not directly to the total concentration of
the contaminant on the sediment.
When the EP approach is used to estimate sediment
quality criteria, chronic water quality criteria (WQC) (U.S.
EPA 1980c and U.S. EPA 1985a) are used to establish the "no-
effect" concentration in the interstitial water. The
interstitial water concentration (Cw) is then used with the
partition coefficients (K0c) and the following equation:
to calculate the concentration of the contaminant on the
sediment (Csed) that at equilibrium will result in this
interstitial water concentration. This concentration on the
sediment will be the numerical criteria value (SQC).
Interim sediment quality criteria for PCBs are shown in
Table 3-5. These values were derived using the Koc value of
6.14 for PCBs which was estimated using the median of the
log mean Kow values for Arochlor 1242. Confidence limits
(95%) around this Koc value based on preliminary uncertainty
estimates range from 5.44 to 6.85. The WQC concentration of
.014 ug/L for freshwater aquatic life (U.S. EPA, 1980b) is
derived using the residue value of .64 ug/g from studies
with mink and the mean bioconcentration factor for salmonids
of 45,000. The WQC concentration of .03 ug/L PCBs for
saltwater was not used. Instead, a WQC concentration of
.024 ug/L for saltwater was calculated using the FDA Action
level of 2.0 ug/g, a mean BCF of 10,400 and a lipid value
for benthic species of 8.0 percent. Therefore, the SQC
concentrations in Table 3-5 are intended to protect wildlife
consumers of freshwater benthic species and the
marketability of saltwater benthic species.
To determine if the sediment concentration of a nonpolar
contaminant exceeds the sediment criteria values, the
concentration of the contaminant and the organic carbon
content of the sediment must both be known. Because the
sediment criteria values are presented as normalized to
organic carbon content (i.e., presented on a per organic
carbon weight basis --ug/gC), the normalized sediment
concentrations of the contaminants must be calculated.
These normalized concentrations can then be directly
compared with the interim values shown in Table 3-5. SQC
concentrations do not apply to sediments containing less
than 0.5% organic carbon.
If concentrations of PCBs in sediments exceed these SQC
values, chemical monitoring of indigenous benthic and water
35
! )
column species should be instituted to determine if prey
species of wildlife or marketable benthic or water column
species contain unacceptable concentrations of PCBs.
Monitoring of indigenous wildlife species will provide
insights into actual extent of exposure to PCBs from a
specific site relative to reference sites. This is
particularly important where the areal extent or the
heterogeneity of sediment contamination by PCBs is great and
because biomagnification of PCBs in food chains is not
considered in deriving the aquatic life WQC concentrations.
If chemical monitoring of biota fails to indicate that uses
are impaired, the need for extensive remediation based on
exceedence of SQC values should be questioned.
TABLE 3-5
PCB Sediment Quality Criteria1
Sediment Quality
Criteria (ug/gC)
Sediment
Cone. (ug/g)
WQC -Freshwater
. 014 ug/L
WQC -Saltwater
.024 ug/L
Mean 95% Confid.
Int.
19 3.8 -99
(.38
oc =
1.9
-9.9)
33 6.6 -170 3.3
(.66 -17)
10% oc = 1%
.19
(.038 -.99)
.33
(. 066 -1. 7)
Based on Koc= 6.14 (5.44 -6.85). If these SQC are
exceeded chemical monitoring of PCB concentrations in
indigenous biota is recommended prior to decisions on
ecological risks or remediation. These SQC apply to
sediments whose organic carbon (OC) concentrations are
greater than .5%.
3.4 Ecological Considerations
The occurrence of PCBs at Superfund sites often poses
significant threat to wildlife. Mobility of PCBs into
ground water, into air, and through biological vectors can
result in adverse ecological impacts beyond the immediate
boundaries of the site. It is important to consider
interactive ecological processes relative to PCB
contamination as part of the remedial investigation. This
evaluation can provide insights into other avenues of human
exposure in addition to ensuring protection of wildlife.
Assessments of PCB sites by the Department of the
36
Interior have concluded that PCB concentrations of 1 -

2

ppm
will be protective of wildlife such as migratory birds and
that providing a soil cover over more highly contaminated
areas can further mitigate threats to acceptable levels.
However, the uncertainty regarding environmental impacts
described below may warrant more in-depth analysis at sites
where this pathway may be of particular significance; e.g.,
sensitive species, high agricultural use.
It may be important to note that, from a toxicological
and ecological perspective, not all PCB congeners will have
the same effects. Discrimination of congeners appears
operative at many physical, chemical, and biological levels:
primary source materials differ from environmental samples;
toxicity values differ among congeners; persistence in the
environment varies; and bioaccumulation potential varies
among congeners and across trophic levels. Consequently, an
established environmental concentration based on total PCB
concentration (i.e., irrespective of the specific congeners)
may show little relationship to biological phenomena (e.g.,
food chain contamination, toxicity, etc.).
Metabolism of PCBs can occur in a diverse group of
organisms including bacteria, plants, and animals. (Fungi
almost certainly possess similar capabilities.) For the
most part the lesser chlorinated congeners are more readily
subject to metabolism, whereas the penta-, hexa-, and
heptachlorinated forms are quite recalcitrant. Metabolism
should not be equated with degradation, because certain
conversions are better thought of as modifications of the
parent compound; and in some cases the modified forms may
become more toxic, more water-soluble, more bioavailable.
To date the best evidence for degradation is demonstrated
for certain bacteria which are capable of dechlorinating the
lesser cholorinated congeners.
Toxicity sympto~s are most clearly observed in animals
(Focardi, 1989 and Aulerich, 1986). Usually the symptoms
are sublethal. Chronic exposures lead to disrupted hormone ,;
balances, reproductive failure, teratomas, or carcinomas.
Plants do not appear to exhibit detectable toxicity
responses to PCBs (Fletcher, 1987a and Fletcher, 1987b).
Biological contamination may occur through a variety of
routes. Aquatic organisms may incorporate PCBs from water,
sediment, or food items. Subterranean animals, similarly
accumulate PCBs via dermal contact and ingestion
(Tarradellas, 1982). Exposure scenarios in above-ground
37
terrestrial populations additionally may occur via
volatilization. The least understood features of food web
contamination are those related to the uptake, fate and
transport of PCB congeners in plants.
38
Chapter 4
Developing Remedial Alternatives
As described in Section 1, one of the superfund
expectations is that principal threats at a site will be
treated wherever practicable and that low-threat material
will be contained and managed. Treatment and disposal
options for PCB contaminated material are governed by the
type of material that is contaminated and the concentration
of PCBs in the material that is to be disposed. Principal
threats will generally include material contaminated at
concentrations exceeding 100 ppm or 500 ppm depending on the
land use setting. Where concentrations are below 100 ppm
(less than 2 orders of magnitude above the starting point
action level), treatment is less likely to be practicable
unless the volume of contaminated material is relatively
low.
The treatment options for contaminated soils and sludges
mixed with soil are discussed in this chapter. (Consistent
with the superfund expectations and TSCA requirements, PCB
liquids generally will be incinerated. Aqueous PCB streams
generally will be treated by traditional treatment systems
such as carbon adsorption.) There are three primary options
for non-liquid PCBs at concentrations of 50 ppm or greater
that are compliant with TSCA ARARs (there is no separate
consideration given to non-liquid PCBs at concentrations
greater than 500 ppm):
1. Incineration;
2. Treatment equivalent to incineration;
3. Disposal in a chemical waste landfill.
There are additional options for addressing PCB contaminated
dredged material. superfund expectations indicate that
innovative treatment methods should be considered where they
offer comparable or superior treatment performance,
fewer/lesser adverse impacts, or lower costs than more
demonstrated technologies. For PCBs, possible innovative
technologies meeting these criteria include solvent
extration, KPEG, biological treatment, and in-situ
vitrification. ,;
For low-threat material that is contained and managed in
place over the long term, appropriate engineering and
institutional controls should be used to ensure protection
is maintained over time. An initial framework for
determining appropriate long-term management controls is
provided in Table 4-2. As indicated by this table,
institutional controls alone are not sufficient to provide
protection except in cases where the concentrations
remaining are low and the expected land use is industrial.
39
4.1 Identifying Principal Threats/Low-Threat Areas
The process for developing alternatives at Superfund
sites with PCB contamination described below is outlined in
the flow chart in Figure 4-1.
Once the area over which some action must be taken to
reduce risks has been identified; i.e., areas contaminated
above 1 ppm PCBs (residential) or areas contaminated above
10 -25 ppm PCBs (industrial), the wastes comprising the
principal threat at the site should be identified. These
wastes will include soil contaminated at 2 to 3 orders of
magnitude above the action level. For sites in residential
areas, principal threats will generally include soils
contaminated at concentrations greater than 100 ppm PCBs.
For sites in industrial areas, PCBs at concentrations of 500
ppm or greater will generally constitute a principal threat.
Consistent with Superfund expectations, the principal
threats at the site should be treated. Treatment methods
are described in Section 4.2.
In some cases, it may be appropriate to treat material
contaminated at concentrations lower than what would
otherwise define the principal threats because it is cost
effective considering the cost of treatment verses the cost
of containment, because the site is located in a sensitive
area such as a wetland, or because the site is located in an
area where containment is unreliable such as a floodplain.
In other cases, it may be appropriate to contain the
principal threats as well as the low-threat material because
there are large volumes of contaminated material, because
the PCBs are mixed with other contaminants that make
treatment impracticable, or because the principal threats
are not accessible; e.g., sites where they are buried.
Material that is not treated but is above actions levels
should be contained to prevent access that would result in
exposures exceeding protective levels. A framework of long-
term management controls for various site scenarios is
provided in section 4.3.
4.2 Treatment Methods
Several methods have been used or are currently being
evaluated to reduce the toxicity, mobility, or volume of
PCB-contaminated material. Depending on the volume of
material to be treated, the other contaminants that may be
present, and the consistency of the contaminated material,
one or more of these methods should be considered as options
for addressing the principal threats.
40
Figure 4-1 -Key Steps in the Development of Remedial Alternatives for PCB-Contaminated Superfund Sites• --
Residential
Industrial
XXX Containment
•:•:·::;::;:: :uJr
?t'="'' Contain residues and Partially Treat u y reat
remaining material Treat to levels requiring fewer Treat to levels for wh ich no
(See Table 3) long-term management controls long-term management controls i:~oo~~~&t llll (See Table
3
,;-=.;;:;,, ~~~~sd~~~ access restrictions) ar
it
,ri,, At'UJ#~ fl .A
...... ========;;;;;.
• These numbers are guidance only and should not be treated as regulations.
41
In addition to incineration, there are several other
technologies that result in the destruction or removal of
PCBs in contaminated soil. These methods can be used with
no long-term management of treatment residuals if they can
be shown to achieve a level of performance equivalent to
incineration, as required in 40CFR761.60(e). As described
in guidance (U.S. EPA, 1986c), this determination can be
made by demonstrating that the solid treatment residuals
contain less than or equal to 2 ppm PCBs using a total waste
analysis. When a remedial action alternative for a
Superfund site involves use of a technology that can achieve
substantial reductions but residual concentrations will
still exceed 2 ppm, the alternative should include long-term
management controls as outlined later in Table 4-2. This
will not be considered equivalent treatment but will be
treated as closure of an existing hazardous waste unit
consistent with TSCA chemical waste landfill requirements
(RCRA closure -40CFR 264.301 and TSCA chemical waste
, landfill -40CFR 761.75). As described in Table 4-2,
certain long term management controls may be waived using
the TSCA waiver provision, depending on the concentration of
PCBs remaining and other site-specific factors.
A brief discussion of some of the pertinent
considerations for several treatment technologies that
address PCBs follows. The evaluations described below
provide the substantive considerations pertinent to
treatment of PCBs on Superfund sites. When material is
transported off-site for treatment, the treatment facility
must be permitted under TSCA. Table 4-1 summarizes
important considerations and consequences associated with
the use of the various technologies that should be accounted
for in developing and evaluating alternative remedial
actions.
4.2.1 Incineration
Incineration, covered in 40CFR761.70, should achieve the
equivalent of six 9 1 s (99.9999%) destruction removal
efficiency. This is indicated by the requirement that mass
air emissions from the incinerator stack shall not be
greater than .001 g PCB/kg of PCB contaminated material fed
into the incinerator.
4.2.2 Chemical Dechlorination (KPEG)
Chemical reagents prepared from polyethylene glycols and
potassium hydroxide have been demonstrated to dechlorinate
PCBs through a nucleophilic substitution process. Studies
42
Table 4-1
PCB TREATMENT METHODS AND APPLICATION CONSEQUENCES
Methods
Incineration
Biological Treatment
Solidification
Vitrification
KPEG (Potassium Polyethylene Glycolate)
Solvent Washing/Extraction
Granular Activated Carbon
43
Considerations/Conseguences
• Cost
• Residual disposal (ash, scrubber water)
• Public resistance
• Efficiency
• By-products
• Treatment time
• Not proven effective for all
PCB congeners
• Volatilization
• 1..eachability
• Physical strength
• Life of composite's integrity
• Cost
• Volatilization
• 1..eachability
• Cost (varies with reagent recycleability)*
• Efficiency (varies with Arochlor type)
• Aqueous wastes must be dewatered either
as a pre-step or in a reactor
• Volatilization of solvent
• Solvent recovery
• Inability of solvent to extract all PCBs
• Several extraction steps
• Solvent residual remains in extracted soil
• Extracts require destruction via other
methods
• Removal efficiency in soil has not been
established
• Spent carbon requires treatment/disposal
have shown that the products of the reaction are non-toxic,
non-mutagenic, and non-bioaccumulative (desRosiers, 1987).
Treatability studies in Guam and at the Wide Beach Superfund
Site in New York have shown that PCB concentrations can be
reduced to less than 2 ppm. However, variable
concentrations in material to be treated will result in
varying efficiencies of the treatment system and systems
must be monitored carefully to ensure that sufficient
reaction time is allowed.
This technology can achieve performance levels that are
considered equivalent to incineration; however, treatability
studies generally will be required to demonstrate that the
concentration reductions can be achieved on a consistent
basis for the material that is to be treated. In some
cases, cost-effective use of the KPEG process will result in
substantial reductions of PCB concentrations, but the
residual levels may still be above 2 ppm, in which case
chemical waste landfill requirements will also need to be
met.
4.2.3 Biological Treatment
Some work has been done on the use of microbes to
degrade PCBs either through enhancing conditions for
existing microbes or mixing the contaminated material with
engineered microbes (Quensen, 1988; Bedard, 1986; Unterman,
1988; Abramowicz, 1989). The use of this process requires
detailed treatability studies to ensure that the specific
PCB congeners present will be degraded and that the
byproducts of the degradation process will not be toxic.
For in-situ application, it is possible that extensive
aeration and nutrient addition to the subsurface will
increase the mobility of PCBs through transport on
particulates. This phenomenon should be considered when
potential ground wat~r contamination is a concern.
In-situ application does not trigger TSCA requirements
(unless disposal occurred after February 17, 1978) and the
primary consideration should be attainment of cleanup levels
established for the site based on the evaluation of factors
described in Chapter 3. Biological processes involving the
excavation of contaminated material for treatment in a
bioreactor that can be shown to achieve residual
concentrations of less than or equal to 2 ppm PCBs can be
considered equivalent treatment. Treatment residuals can be
re-deposited on site without long-term management controls
as long as treatment byproducts do not present a threat to
human health and the environment.
44
4.2.4 Solvent Washing/Extraction
Solvent washing/extraction involves removing PCBs from
excavated contaminated soil and concentrating them in a
residual side stream that will require subsequent treatment,
generally incineration. Often the solvent can be recovered
by taking advantage of certain properties of the solvent
being used. Aliphatic amines (e.g., triethylamine [TEA]),
used in the Basic Extractive Sludge Treatment (B.E.S.T.),
exhibit inverse miscibility. Below 15 degrees c, TEA can
simultaneously solvate oils and water. Above this
temperature, water becomes immiscible and separates from the
oil and solvent. Consequently, a process can be designed to
remove water and organics at low temperatures, separate the
water from the organic phase at higher temperatures, and
recover most of the solvent through distillation. The high
concentration PCB stream is then typically incinerated.
A similar process, called critical fluid extraction,
involves taking advantage of increased solvent properties of
certain gases (e.g., propane) when they are heated and
compressed to their "critical point.'' Once the PCBs have
been extracted, the pressure can be reduced allowing the
solvent to vaporize. The solvent can be recovered and the
remaining PCBs sent to an incinerator.
Treatability tests run to date have indicated that there
is probably a limit to the percentage reduction (on the
order of 99.5%) achievable with these processes. Repeat
applications can increase the reductions obtained and
studies have shown that PCB concentrations in the extracted
soil of less than 2 ppm can be achieved. However, it may
not be cost-effective for sites where there are large
volumes of material at very high concentrations.
4.2.5 Solidification/Stabilization
The terms solidification and stabilization are sometimes
used interchangeably, however, subtle differences should be
recognized. Solidification implies hardening or
encapsulation to prevent leaching, whereas stabilization
implies a chemical reaction or bonding to prevent leaching.
Solidification of PCBs can be accomplished by use of
pozzolons such as cement or lime. Encapsulation, rather
than bonding, occurs to prevent leaching of the PCBs. There
is some evidence in the literature that the excess
hydroxides are substituted on the biphenyl ring resulting in
a dechlorination reaction (U.S. EPA, 1988c). The
dechlorinated product would probably be less toxic than the
parent molecule. Stabilization may be accomplished using a
modified clay or other binder to bond to the PCB preventing
45
I
I ! ,,
l
leaching of the PCBs even under extreme environmental
conditions. This product will probably be stable over time
because of the binding, but no changes in the parent
molecules are expected.
To assess the reduction in mobility achieved through
solidification, leaching analysis, such as the Toxicity
Characteristic Leaching Procedure (TCLP), should be
performed before and after solidification. Since PCB
migration potential is reduced but the PCBs are still
present in the waste and the long term reliability of the
treatment process is uncertain, long-term management
controls as outlined in Table 4-2, based on the
concentration of PCBs stabilized or up to a factor of 10
lower (based on the results of the performance evaluation),
should be incorporated into the alternative.
4.2.6 Vitrification
Vitrification involves the use of high power electrical
current (approximately 4 MW) transmitted into the soil by
large electrodes which transform the treated material into a
pyrolyzed mass. Organic contaminants are destroyed and/or
volatilized, and inorganic contaminants are bound up in the
glass-like mass that is created. Volatilized organics must
be captured and treated. Since this process is often
performed in-situ without disturbing the contaminated
material, the requirements of TSCA would not be applicable
unless disposal occurred after February 17, 1978. Also, it
is often advantageous to consolidate contaminated material
into one area for purposes of applying the process in which
cases TSCA requirements would apply for PCBs at
concentrations greater than 50 ppm since this movement
constitutes disposal. Because the process results in
complete pyrolosis of the PCBs in the affected area it is
considered equivalent to incineration and no long-term
management would be warranted based on the PCBs. The
perimeter of the treated area should be tested using the
TCLP to determine if long term management controls are
warranted in areas where gradations in temperature resulted
in lower levels of PCB destruction.
4.3 Determining Appropriate Management Controls for Areas
Where Concentrations Are Above the Action Levels
Consistent with the Superfund expectations low-threat
material should generally be contained on site. As
described above, this will generally include soil with PCBs
at concentration of less than 100 ppm (residential) or PCBs
at concentrations of less than 500 ppm (industrial). The
46
management controls that should be implemented for the
material that remains at these sites above the action level
will depend on the material that is to be contained and
hydrogeological and meteorological factors associated with
the site. Controls may include caps, liners, leachate
collection systems, ground water monitoring, surface water
controls, and site security. A general framework of
appropriate controls under various site scenarios is
provided in Table 4-2. If disposal of PCBs subject to TSCA
{concentrations greater than 50 ppm) occurred after 1978,
then the long-term management controls required for chemical
waste landfills must be addressed for material that is not
incinerated or treated by an equivalent method. As noted in
the Table, where low concentrations of PCBs will remain on
site and direct contact risks can be reduced sufficiently,
minimal long term management controls are warranted.
Controls should ensure that PCBs will not pose a threat to
the ground water or any nearby surface water. TSCA waivers
of particular chemical waste landfill requirements may be
justified. Where TSCA landfill requirements are not
applicable {post-78 disposal of >50 ppm PCB material
did/does not occur), they will not be relevant and
appropriate since RCRA closure requirements are generally
the relevant ant appropriate requirement; consequently, the
use of the TSCA waiver provision will not be necessary.
4.3.1 Example Analyses --Long-Term Management Controls
To illustrate the process of determining the appropriate
long-term management controls for low-threat PCB
contamination that will remain at a site, an example was
developed. A description of the models used in this
evaluation is provided in Appendix c. The parameters used
in this analysis are generally conservative. They are
summarized in Table 4-3. Four different source area PCB
concentrations were evaluated: 5 ppm, 20 ppm, 50 ppm, and
100 ppm.
The determination of the appropriate long term management
controls for this example site was based on preventing
access to concentrations of PCBs exceeding the action level
{residential, 1 ppm; industrial 10 -25 ppm) and preventing
migration of PCBs to the ground water at concentrations that
exceed the proposed drinking water standard --.5 ppb. The
migration to ground water pathway was assessed by
determining the infiltration projected through four
different cap designs and then modeling the migration of
PCBs from the source area to and into the ground water.
47
& --------------------------· ··-· ·-----Table 4-2 -Selectlon of Long-Term Management Controls To Be Considered for PCB-Contaminated Sites / 0'47' POTENTIAL BASIS FOR TSCA WAIVER (711.75 (c) (4) I ¥ OF INDICATED CHEIICAL WASTE LANDRLL REOOREMENT(S) S1 1M-• Non!astrided ACC8II Clean Closln No waivers requlnid; clean closure 1-10 Al Daplhs • Nonreslrlded ACC8II Hybri!Closure 2 X 3 X X X X Low PCB concemration Design and ln!lallalion at I prol8C1"'8 0IMlr sysllffl Evalua1lon at PCB migration to GW and SW 10-25 I Al Daplhs I . lililed ACC8II I Hybril Closure 2 X 3 X X X X Low PCB concantrarlon Design and Installation at a prol8Cl"'8 0IMlr syslem • Deed Notice Evaluallon at PCB migration to GW and SW 2S-100 I Al Deplhs I . Restrk1ed Aa:891 Landlll Closure X X 4 X 3 X X Ralallvetf low PCB concantratlon lff'l)lemanlalion at a GW mon•omg program • FIIOOII I I I I I I I I I I I I I I I Evaluation ol PCB migration to GW and SW • Deed Notice Design and ln9lallaflon at a prol8Cl"'8 cover system 1100-500 I 3-50 Feat , • Restricted Aa:891 Landll1 Closure X X X 4 X X X ~ at GW monlomg program • FIIIC8 Design and lll!llllation at a prol8Cl"'8 CMr system • Deed Notice EvaluaJlon at PCB migration to GW and SW > 50 Feat I . Restrk1ed Aa:891 Landlll Closure X 5 X 4 X X X Design and lnslallallon at I prol8Cl"'8 0IMlr syslem • FIIIC8 Demonslrate IUlli:lent depth to GW to prolec1 tuman health and • Deed Notice the IIMIOl'llnn EvaluaJlon at PCB migration to GW and SW >500 I 3-50 Feat I • Restrk1ed Aa:891 I Landlll Closure X X X X X X 4 X Demonstrate other long-tenn management controls wtl provide • FIIIC8 Mlnl111.1m adequate prolec11on ol GW • Deed Notice Technology > 50 Feat I • Restricted Aa:891 I Landlll Closu19 X X X X X X 4 X X Demonstrate 9Ullk:lent depth to GW and long-term management oontrols • FIIIC8 Mlnl111.1m to prolecl human health and the environment • Deed Notice Technology IIT'f)lementation at GW mon•omg program Evaluation ol PCB migration to GW and SW GW • ground waler; SW • surface waler , Cover system may range lrom 12' soil cap tor low concentrations to a full RCRA cap IOI' c:oncer1rations exceeding 500 ppm. ~ The need tor a cover system wil depend on the land use ~.e., residential Of' lndustria~. 40 CFR 761.75(b)(3) requln1s that lanctils be located at least 501881 above the I-qi-water lable. 4 In aceotdance with 40 CFR 761.75(bK•I W the site is located below the 100-year floodwater elevatlon. lMll'Slon dikes shall be construded 110Und1he perimeter of 1he landfil &ile with a minimum heigl1 equal to 21eet above the 100-year floodwater elevation. Flood protection IOI' landfils above the 100-yaar floodwater elevation Is not applicable to closed landlil units. s When the ste Is bcaled In a permeable tonnation, lncorpOl'alion ol this lo~tenn managanwnl comot should be evaklated.
Table 4-3
SITE PARAMETERS
Source Area--5 Acres
Average Regional Flow 310 ft/year
Porosity of Soil-0.25
Bulk Density of Soil-1.97 g/m.l
Time-Peak 70 years from 0-10,000 years
Contaminated zone organic content-5.0%
Qean unsaturated zone organic content-0.5%
Saturated zone organic content-0.1 %
PCB half-life--50 years
Depth of Contamination-10 feet
Depth to Groundwater-20 feet
Thickness of Saturated Zone--5 feet
49
ll l
I l ·
'' ': !
The four caps evaluated in this analysis are:
1. Twelve-inch soil cap
2. Twelve-inch soil cap with 24-inch clay layer
3. 24-inch soil cap, flexible membrane liner, and 12-inch
cover soil, and
4. RCRA minimum technology cap including 24-inch soil cap,
12-inch sand drainage layer, flexible membrane liner,
24-inch clay layer, and 12-inch cover soil.
These caps are pictured in Figure 4-2. The infiltration
expected through each of these caps, presented in Table 4-4,
(given the site conditions presented in Table 4-3) was
estimated using the Hydrologic Evaluation of Landfill
Performance (HELP) model and the migration of PCBs to and
into the ground water was estimated using a combination of a
one-dimensional unsaturated zone finite-element flow and
transport module called VADOFT (U.S. EPA, 1989f) and an
analytical solute/heat transport module called AT123D (Yeh,
1981) .
The results of this analysis are summarized in Table 4-
5. PCB concentrations in ground water were estimated for
each of the four cap designs and four different PCB source
concentrations. Based on this analysis, the following
recommendations for caps would be made:
5 ppm PCBs Source At this concentration the threat of PCB
migration to ground water at concentrations that would
exceed the proposed MCL of .5 ppb under the given site
conditions is unlikely. The maximum concentration averaged
over 70 years (occuring after 945 years) is .099 ppb with
only a soil cap. The soil cover would be recommended for
sites in residential areas to prevent contact with
concentrations above 1 ppm, the starting point action level.
20 ppm PCBs Source Again, the analysis indicates that the
threat to ground water is not significant. With only a soil
cap, the maximum concentration expected is .4 ppb. For
sites in residential areas, a cement cover and a deed notice
may be warranted to prevent contact with PCBs exceeding the
1 ppm starting point action level.
50 ppm PCBs Source At 50 ppm, PCB concentrations in the
ground water are projected to exceed the .5 ppb level
slightly --approximately 1 ppb. At this concentration, for
the site conditions presented, cap design 2 (Figure 4-2)
would be recommended. The combination of a low-permeability
cover soil and the soil cap will prevent PCBs from migrating
to the ground water at levels that exceed .5 ppb. With the
reduced infiltration the maximum PCB concentration projected
for the ground water (occurring after 1645 years) is .3 ppb.
Again, a deed notice would be warranted to prevent direct
50
DESIG'-: I
DESIGN 2
DESIGN 3
DESIGN4
Landfill •
Design
(Minimum
Technology)
'/////////
Figure 4-2
Cap Design Details
~3-5%
,._--Vegetation
'/////////
...-12" Soil Top Layer ....... ,., ...... ................. • .... L. .........
~ Waste ~
..,__ 3-5%
,.---Vegetation
'////////,
~ 24" Soil Top Layer
·~ ~ "'-FML 20 mil 1--K=lx10· 1~sec
':~':~':~'h:~': ~~':~':~':~':~•/ """'12" Cover Soil--K=3.7xlO""cm!sec .... ,.,.,.. ·-· -··· ~ Waste ~
~ Vegetation
'Oij//.i'lizl,/.lzlzl'//liiii;----..,__ ___ 3_-5_% __ -...zlzlzl'//.IZI'//._,,.,. ---24" Soil Top Layer
-----2 12" Sand -K=lxlO cm/sec ..,__ 2 % :::::::::::::::::::::::::::,:;;:::::::::. 'k"""' 1 14
~'!!l!!l!!ll!!!lll!!l------~!1!!1111!!!1!!!1~ ~ FML 20 mil --K=lxlO cm/sec
..,~~~ ~~~ -7 ~24" Clay --K=lxlO cm/sec ~,,..,..,,...,,.,...,,.... __________ .....,,,_,,....,,._,
~ ~...-12"CovcrSoil--K=3.7xlO""cmJsec
·~ / ~
.......__,_ Original Subgrade ~
• RCRA Minimum Technology Landfill bottom liner design for remedial actions requiring RCRA landfill consauction.
51
Table 4-4
COVER DESIGN SUMMARY TABLE (ANNUAL VALUES)
Infiltration
Cover Site Area Precip. Runoff Evapotrans. (Cu. Ft.)/
Design (Acres) (Cu.Ft.) (Cu~ Ft.) (Cu. Ft.) Acre
1 2 258,877 3,349 113,134 71,467
2 2 285,877 78,164 114,628 33,529
3 2 258,877 127,318 131,170 226
4 2 2S5,877 94,262 118,162 1
: I
I
52
.1
VI w C".ap l>Hfan I .099 Soll C :onc•nlralhtn 5 ppm Cap Cap °""" l>Hfan 2 J .029 0.0 T .. lo 4-5 SATURATED ZONE DF.1"111 AND TIMF. AV.'.RAGED CONCENTRATIONS IIF.NF.ATII TIIE SOURCE (PPII) AND TIME or PEAK CONCENTRATION (YEARS) Soll Conc•nlrallo11 20 ppm Soll Conconlrallo• 50 ppm Soll Contt11tnllon IINI ppm Tp ... (Y•an) Cap Cap Cap C■p Cap C.ap C■p C■p C■p C■p Cap C■p C■p Cap Cap C■p C:■p DHl~n l>Hlp l>Hfan l>Hfan l>Hlp l>Hfan O.,.fan l>nfan 'lHfan DH .. n l>Hfan l>Hlp l>Ht.., l>Hlp l>Hfan f>Klitn IIH,.,. .. I 2 J .. I 2 ·' 4 I 2 J .. I 2 J .. 0.0 .396 .116 0.0 0.0 .990 .290 0.0 0.0 1.98 .580 0.0 0.0 945 1645 .. ..
contact with the soil in the future.
100 ppm PCBs Source At 100 ppm, PCB concentrations in the
ground water are projected to exceed the .5 ppb level
slightly --approximately .6 ppb, even with the addition of
a low-permeability cover soil. At this concentration, for
the site conditions presented, the cap design 3 (Figure 4-2)
would be recommended. The addition of a flexible membrane
liner reduces infiltration sufficiently to prevent migration
of PCBs to the ground water. Consistent with Table 4-2, a
deed notice, fence, and periodic ground water monitoring
would also be recommended.
4.4 Dredged Material
A special allowance is made under TSCA for dredged
material and municipal sewage treatment sludges in section
761.60(a) (5) (iii). If, based on technical, environmental,
and economic considerations, it can be shown that disposal
in an incinerator or chemical waste landfill is not
reasonable or appropriate and that an alternative disposal
method will provide adequate protection to health and the
environment, this alternate disposal method will meet the
substantive requirements of TSCA. Since these showings are
integral components of any remedy selected at a Superfund
site, Superfund actions involving PCB-contaminated dredged
material generally will be consistent with TSCA.
4.5 RCRA Hazardous Waste
As noted in section 2.3.2, special consideration must be
given to PCB-contaminated soil that also contains material
considered hazardous under RCRA. Soil containing
constituents that make it hazardous under RCRA that is
excavated for the purpose of treatment or disposal must be
treated consistent with the land disposal restrictions prior
to placement and residuals managed in accordance with
Subtitle C closure requirements. This means that a specific
treatment method must be applied, or specified concentration
levels must be attained for the waste contained in the soil,
or a treatability variance must be obtained to establish
alternate treatment standards. For soil and debris from
CERCLA sites the need for a treatability variance is
presumed (preamble to NCP, 55 Federal Register 8760-61,
March 8, 1990). Treatment guidelines for constituents found
in RCRA hazardous waste have been developed for use in
treatability variances and should be used as a guide in
determining the reductions in contaminant levels that should
be attained by alternative treatment methods.
54
PCBs alone are not considered hazardous under RCRA since
tney are addressed under the TSCA regulations; however, land
disposal restrictions do address PCBs under the California
List Waste provisions for cases where PCBs are mixed with a
waste that is considered hazardous under RCRA. If the waste
is hazardous under RCRA, and the concentration of
halogenated organic compounds exceeds 1000 ppm, the land
disposal restrictions associated with California List Waste
become applicable. A list of compounds regulated under the
qategory of halogenated organic compounds is provided in 40
CFR part 268 Appendix III. PCBs are included on this list.
Soil with HOCs exceeding 1000 ppm that is also considered
h~zardous under RCRA, must be incinerated or treated under a
treatability variance. Under a treatability variance,
treatment should achieve residual HOC concentrations
consistent with the levels specified for a treatability
variance for Superfund soil and debris. PCB concentrations
must be reduced to .1 -10 ppm for concentrations up to 100
ppm, and percent reductions of 90 -99.9% must be achieved
for higher concentrations (U.S. EPA, 1989h). If
solidification is used, the levels specified under
treatability variance guidelines apply to leachate obtained
from application of the Toxicity Characteristic Leaching
Procedure (TCLP).
The implications of the land disposal restrictions vary
somewhat depending on whether the waste present is a listed
hazardous waste or is hazardous by characteristic. If the
soil contains a listed hazardous waste, once treatment
consistent with the land disposal restrictions (i.e.,
specified treatment or concentration reductions consistent
with the levels provided in the treatability variance
guidelines for soil and debris) is employed, the residual
after treatment must be disposed of in a landfill that meets
the requirements of a RCRA Subtitle C Landfill. It may be
possible to delist the residuals to demonstrate that it is
no longer hazardous; this may be done for wastes on-site as
part of the ROD; for wastes to be sent off-site, EPA
Headquarters should be consulted regarding de-listing. If
the concentration of PCBs remaining still exceeds 2 ppm, the
landfill should also be consistent with a chemical waste
landfill described under TSCA. As discussed in Section 4.~,
fulfillment of RCRA Subtitle C Landfill Closure requirements
will also guarantee fulfillment of TSCA chemical waste
landfill requirements.
If the soil contains material that makes it hazardous
because of a characteristic; e.g., leachate concentrations
exceed levels specified in 40 CFR 261.24, the soil should be
treated to established BOAT levels, if any; if BOAT
concentrations are not specified, the soil should be treated
such that it no longer exhibits the characteristic. Once
55
I .
i I
l I
I'
the BDAT level is achieved (if any) or the characteristic
has been removed, it may be possible to land dispose the
waste and Subtitle C landfill requirements would not be
applicable but rather, the waste would be considered a solid
waste and governed by Subtitle D. However, when PCBs are
present in the waste, long term management controls
consistent with the guidelines given in Section 4.2 should
be employed.
4.6 Example Options Analysis --Contaminated Soil
Table 4-6 outlines the ARARs that may have to be addressed
for wastes with different constituents including those that
will make the waste hazardous because either a listed waste
is present or the material exhibits a hazardous
characteristic.
56
Table 4-6
EXAMPLE PCB COMPLIANCE SCENARIOS FOR CONTAMINATED SOIL
Waste Type and
Concentration
PCBs > 50 ppm
PCBs > 50 ppm,
RCRA listed waste, and
HOCs < I ,()()()ppm
[in this case PCBs
not covered by RCRA]
PCBs > 50 ppm,
RCRA listed waste,
and HOCs > 1,000 mg/kg
PCBs > 50 ppm,
RCRA characteristic
metal waste, and
HOCs < 1,000 mg/kg
• PCBs > 50 ppm,
RCRA characteristic
metal waste, and
HOCs > 1,000 ppm
Restriction(s)
in Effect
TSCA
TSCA
RCRALDRs
Compliance Options to
Meet Restrictions *
• Dispose of in chemical waste landfill;
• Incinerate; Q[
• Use equivalent treatment to 2 ppm (solid residue) or
3 ppb (aqueous phase)
• Must also be consistent with chemical waste
landfill if final PCB concentration exceeds 2
ppm (solid residue)
• Treat to LOR treatment standard for listed
waste; m:
• Obtain an equivalent treatment method
petition; m:
• Obtain a treatability variance (soil and
debris concentration levels as TBC); and
• Dispose of according to Subtitle C restrictions
·, ----------------
TSCA
RCRALDRs
TSCA
RCRALDRs
TSCA
RCRALDRs
57
• Dispose of in chemical waste landfill if final
PCB concentration exceeds 2 ppm (solid residue)
• Treat to LOR PCB (i.e., incinerate) and
listed waste treatment standard; m:
• Obtain an equivalent treatment method
petition; m:
• Treat to treatability variance levels for
Superfund soil and debris; aru1
• Dispose of according to Subtitle C restrictions
• Dispose of in chemical waste landfill if final
PCB concentration exceeds 2 ppm (solid residue)
• Treat to BOAT or Treatability Variance levels and dispose
according to Subtitle C restrictions
• Solidify to remove characteristic (based on TCLP) and
dispose according to Subtitle D restrictions
• Dispose of in chemical waste landfill if PCB
concentration exceeds 2 ppm (solid residue)
• Incinerate to LOR treatment standard for
HOCs, solidify ash; QC
• Treat by equivalent method, solidify; Q[
• Treat to treatability variance levels for PCBs
in soil and debris
• Treat residuals to meet BDAT/freatability Variance
and dispose according to Subtitle C or remove
characteristic and dispose according to Subtitle D
restrictions
. I
Chapter 5
Analysis of Alternatives and Selection of Remedy
Consistent with program expectations, it will generally
be appropriate to develop a range of alternatives for sites
with PCB contamination, including alternatives that involve
treatment of the principal threats using methods described
in chapter 4 or more innovative methods in combination with
long-term management of low-threat wastes consistent with
the framework provided. As described in the Guidance on
Conducting Remedial Investigations/ Feasibility studies
Under CERCLA, alternatives are initially screened on the
basis of effectiveness, implementability, and cost (order of
magnitude). Those alternatives that are retained are
analyzed in detail against the nine evaluation criteria.
58
5.1 Evaluating Remedial Alternatives
The overall response options at any site range from
cleaning up the site to levels that would allow it to be
used without restrictions to closing the site with full
containment of the wastes. Alternatives retained for
detailed analysis are evaluated on the basis of the
following criteria:
o Overall protection of human health and the environment
o Compliance with ARARs
o Long-term effectiveness and permanence
o Reduction of toxicity, mobility, or volume through
treatment
o Short-term effectiveness
o Implementability
o Cost
o State acceptance
o Community acceptance
The sections that follow will discuss in turn the first
seven of these criteria and the special considerations that
may be appropriate when PCB contamination is to be
addressed. State and community acceptance are important
criteria but are generally handled no differently for PCB
sites than they are for other contaminated sites.
5.1.1 overall Protection of Human Health and the Environment
Overall protection of human health and the environment
is achieved by eliminating, reducing, or controlling site
risks posed through each pathway. As covered in section 3,
this includes direct contact risks, potential migration to
ground water, and potential risks to ecosystems. Often
alternatives will involve a combination of methods (e.g.,
treatment and containment) to achieve protection. In
general, remedies for PCB sites will involve reducing high
concentrations of PCBs through treatment and long-term
managment of materials remaining. The methods of protection
used to control exposure through each pathway should be
described under this criterion.
5.1.2 Compliance With ARARs
As outlined in section 2, the primary ARARs for
alternatives addressing PCB contamination derive from the
TSCA and the RCRA, and for actions involving PCB
contaminated ground water and/or surface water, the SDWA and
the CWA.
59
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J' l' 'I
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Since RCRA closure requirements are generally relevant
and appropriate at Superfund sites even when a hazardous
waste is not involved, a discussion of the measures taken at
the site for the alternative being considered that are
consistent with the RCRA requirements is warranted.
TSCA is applicable where disposal occurred after
February 17, 1978 including any alternatives involving
movement of material with 50 ppm or greater PCBs and
compliance with the substantive requirements must be
addressed. For alternatives that do not achieve the
standards specified for treatment of PCBs under TSCA,
consistency with long-term management controls associated
with a chemical waste landfill must be demonstrated.
Consistency may be achieved by complying with the specified
landfill requirements or meeting the substantive findings to
support a waiver as provided in the TSCA regulations (40 CFR
761. 75).
Although the PCB Spill Policy is not ARAR, it is an
important TBC. A statement indicating the relationship
between the cleanup levels selected and the cleanup levels
in the Spill Policy for alternatives involving no or minimal
long term management controls is usually warranted.
Because PCBs adhere strongly to soil, it may be
impracticable to reduce concentrations in the ground water
to the proposed MCL level of .5 ppb throughout the entire
plume, for sites where PCBs have migrated to the saturated
zone. PCBs adsorbed to particulates can be removed in
extraction wells; however, they will be drawn through the
aquifer very slowly. A waiver from State standards or the
MCL once it becomes final may be warranted for sites where
ground water restoration time frames are estimated to be
very long or where cleanup cannot be achieved throughout the
entire area of attainment. Interim remedies (extraction for
a specified period of time such as 5 years) to assess the
practicability of extraction or other techniques may be
worthwhile to determine the feasibility of achieving
drinking water levels or at a minimum, reducing risks to the
extent practicable.
5.1.3 Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses how well
a remedy maintains protection of human health and the
environment after remedial action objectives have been met.
Alternatives that involve the removal or destruction of PCBs
to the extent that no access restrictions are necessary
for protection of human health and the environment provide
the greatest long-term effectiveness and permanence. The
60
uncertainty associated with achieving remediation goals for
the treatment methods considered may distinguish
alternatives with respect to this criterion. Alternatives
that limit the mobility of PCBs through treatment such as
solidification/stabilization afford less long-term
effectiveness and permanence than alternatives that
permanently destroy the PCBs, although solidification in
combination with management controls can be very reliable
based on the site-specific circumstances involved.
Generally, alternatives relying solely on long-term
management controls such as caps, liners, and leachate
collection systems to provide protection have the lowest
long-term effectiveness and permanence; however, this may be
appropriate where low-concentration material is to be
contained or where excavation is not practicable. Many
alternatives will involve combinations of treatment and
containment and will consequently fall at various points
along the permanence continuum depending on the volume and
concentration of residuals remaining on site.
5.1.4 Reduction of Toxicity, Mobility, or Volume Through
Treatment
The anticipated performance of treatment technologies
used in the alternatives is evaluated under this criterion.
Alternatives that do not involve treatment achieve no
reduction of toxicity, mobility, or volume through treatment
and should not be described as doing so under this criterion
(e.g., placing a cap over contaminated soil does not reduce
mobility of PCBs through treatment). Alternatives that use
treatment methods that have a high certainty of achieving
substantial reductions (at least 90%} of PCBs have the
greatest reduction of toxicity. Alternatives that treat the
majority of the contaminated material through these
processes achieve the greatest reduction in volume.
Alternatives that utilize methods to encapsulate or
chemically stabilize PCBs achieve reduction of mobility;
however, most of these processes also increase the volume of
contaminated material and this must be considered.
5.1.5 Short-Term Effectiveness
The effectiveness of alternatives in protecting human
health and the environment during construction and
implementation is assessed under short-term effectiveness.
This criterion encompassess concerns about short-term
impacts as well as the length of time required to implement
the alternatives. Factors such as cross-media impacts, the
need to transport contaminated material through populated
areas, and potential disruption of ecosystems may be
61
,l 1,
i
,1 I '
pertinent. Because PCBs do volatilize, remedies involving
excavation will create short-term risks through the
inhalation pathway. For actions involving large volumes of
highly contaminated material this risk may be substantial;
however, it can be controlled.
5.1.6 Implementability
The technical and administrative feasibility of
alternatives as well as the availability of needed goods and
services are evaluated to assess the alternative's
implementability. Many of the treatment methods for PCBs
require construction of the treatment system on-site since
commercial systems for such techniques as KPEG and solvent
washing may not be readily available. Other methods, such
as bioremediation, require extensive study before their
effectiveness can be fully assessed. This reduces the
implementability of the alternative. Offsite treatment and
disposal facilities must be permitted under TSCA and usually
under RCRA as well if other contaminants are present. This
may affect the implementability of alternatives that require
PCB material be taken offsite due to treatment and disposal
facility capacity problems and the need to transport
contaminated material. Finally, the implementability of
alternatives involving long-term management and limitations
on site access to provide protection may be limited by the
site location; e.g., flood plain, residential area.
5.1.7 Cost
Capital and operation and maintenance costs are
evaluated for each alternative. These costs include design
and construction costs, remedial action operating costs,
other capital and short-term costs, costs associated with
maintenance, and costs of performance evaluations, including
monitoring. All costs are calculated on a present worth
basis.
5.2 Selection of Remedy
The remedy selected for the site should provide the best
balance of tradeoffs among alternatives with respect to the
nine evaluation criteria. First, it should be confirmed
that all alternatives provide adequate protection of human
health and the environment and either attain or exceed all
of their ARARs or provide grounds for invoking a CERCLA
waiver of an ARAR. Some of the key tradeoffs for sites with
62
PCB contamination include:
o Alternatives that offer a high degree of long-term
effectiveness and permanence and reduction of toxicity,
mobility, or volume through treatment, such as
incineration, generally involve high costs. Short-term
effectiveness for such alternatives may be low since
risks may increase during implementation due to the
need to excavate and possibly transport contaminated
material, resulting in cross-media impacts.
o Alternatives that utilize innovative methods, often
less costly than incineration, to reduce toxicity,
mobility, or volume are often more difficult to
implement due to the need for treatability studies and
to construct treatment facilities onsite. In addition,
the treatment levels achievable and the long term
effectiveness and permanence may be less certain.
o Alternatives that involve stabilization to reduce the
mobility of PCBs and limit cross-media impacts that may
result from incineration (particularly important when
other contaminants such as volatile metals are present)
at a lower cost than other treatment methods, have
higher uncertainty over the long term but may provide
advantages in long-term effectiveness over alternatives
that simply contain the waste in place.
o Alternatives that simply contain PCBs do not utilize
treatment to reduce toxicity, mobility, or volume of
the waste, have lower long-term effectiveness and
permanence than alternatives involving treatment, but
are generally less costly, easy to implement, and pose
minimal short-term impacts.
The relative trade-offs based on these considerations will
vary depending on site specific considerations discussed in
earlier sections; i.e., concentration and volume of PCBs,
site location, and presence of other contaminants.
5.3 Documentation
Typically, a ROD for a PCB-contaminated site should
include the following unique components in addition to the
standard site characterization and FS summary information
described in the Guidance on Preparing Superfund Decision
Documents:
o Remediation goals defined in the FS. For the selected
63
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I
remedy, the ROD should describe:
-Cleanup levels above which PCB-contaminated material
will be excavated. A comparison of the levels
selected to PCB Spill Policy levels and explanation
of why they differ may be warranted.
-Treatment levels to which the selected remedy will
reduce PCB concentrations prior to re-depositing
residuals onsite or in a landfill. The consistency
of these levels with the TSCA requirements (i.e.,
the requirement to demonstrate achievement of 2 ppm
or less in solid treatment residue for material that
will remain on site with no controls), and RCRA LDR
requirements for hazardous wastes, should be noted.
o A description of technical aspects of the remedy, such
as the following (should be included in alternative
descriptions):
-Treatment process, including the disposition of all
effluent streams and residuals.
-Time frame for completing the remedy and controls
that will be implemented during this time to ensure
protection of human health and the environment.
-Long term management actions or site controls that
will be implemented to contain or limit access to
PCBs remaining on site. The consistency with RCRA
closure and TSCA chemical waste landfill measures,
and necessary TSCA waivers, should be indicated.
64
Chapter 6
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Hutzinger, O.; Safe, s.; Zitko, V., eds., The Chemistry of PCBs,
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Safe, s.; Robertson, L,; Sawyer, T.; Bandierra, S.; Safe, L.;
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from Earthworms, International Journal of Enviornmental
Analytical Chemistry 13:55-67, 1982.
U.S. EPA, Attenuation of Water-Soluble Polychlorinated Biphenyls
By Earth Materials, EPA-600/2-80-027, Office of Research and
Development, 1980a.
U.S. EPA, CERCLA Compliance With Other Laws Manual: Part 1,
EPA/540/G-89/009, Office of Solid Waste and Emergency
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66
U.S. EPA,: Determination of Henry's Law Constants of Selected
Priority Pollutants, Municipal Environmental Research
Laboratory, Cincinnati, OH, April 1980b.
U.S. EPA, Development of Advisory Levels for Polychlorinated
Biphenyls (PCBs) Cleanup, EPA/600/6-86/002, Office of
Research and Development, May 1986a.
U.S. EPA, Equilibrium Partitioning Approach to Generating Sediment
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U.S. EPA, Exposure Factors Handbook, EPA 600/8-89/043, Office of
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U.S. EPA, Field Manual for Grid Sampling of PCB Spill Sites to
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68
APPENDIX A
SUMMARY REPORT
FY82 -FY89 RECORDS OF DECISION ADDRESSING PCB-CONTAMINATED MEDIA
: ;,
> ..... SUMMARY REPORT OF FY82 THROUGH FY89 RECORDS OF DECISION WHICH ADDRESS POLYCHLORINATED BIPHENYLS AS A CONTAMINANT OF CONCERN SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS RD/RA COMPLETE AROCHLORS PRE-TREATMENT REGION 01 Cannon Engineering/Plymouth, MA [03/31/88] CF ] Decontamination of all structures and $2,700,000 RD: 89/4 Not RA: 91/4 Stated debris with offsite disposal; Capital Cost excavation of contaminated soils with onsite thermal aeration; excavation of PCB contaminated soils and offsite incineration and disposal; restrict ground water use; ground water monitoring . Norwood PCBs, MA [09/29/89] CF l Excavation and onsite treatment of PCB-contaminated soils and sediments using solvent extraction; area specific soil target cleanup levels established based on area risk assessment exposure scenarios; offsite incineration of oil extract from solvent extraction process; soil cover over treated soils; decontamination of machinery using solvents; extraction and treatment of PCB-contaminated ground water using carbon adsorption with offsite disposal of spent carbon; ground water use controls; and wetlands restoration. O'Connor, ME [09/27 /89] [RP] Excavation and onsite ~reatment of approximately 23,500 c~bic yards of soil and sediments containing PCBs $16,100,000 RD: 91/3 1016 Present Yorth RA: 92/4 1254 1260 $13,590,000 RD: 91/4 1260 Present Yorth RA: 94/1 CONCENTRATION Not Stated 2,060 ppm sediment 200,000 ppm max EXCAVATION LEVELS Not Stated 1-25 ppm Not Stated ESTIMATED VOLUME Not Stated RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration selected. 31,550 Incineration was selected cubic yards for oil extract from solvent extraction process. Incineration was chosen only as a contingency remedy for soil and sediment due to higher cost. 23,500 Incineration was not cubic yards selected as primary treatment due to its
► N SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY using solvent extraction; solvent extract will be incinerated offsite; treated soils containing lead levels >248ppm will undergo solidification/stabilization treatment and offsite disposal; backfilling using clean and treated soils; punping and offsite treatment of approximately 195,000 gallons of surface water containing PCBs;·and extraction and onsite treatment of PCB (Arochlor 1260) contaminated ground water using filtration/carbon adsorption. Ottati & Goss, NH [01/16/87) [S ] =-'...,..-,.,..,;....,..,,..:_.· •· -•~~•h ~ (CONTINUED) COSTS RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION Excavation of PCB contaminated soil and $6,055,000 RD: 89/2, Not 143 ppm sediment and treatment using Present Worth subsequent Stated incineration following test burn; RCRA RD start delisting evaluation to be conducted for-ash residuals; aeration of other contaminated soils, including PCB soil with concentrations less than 20 ppm; pilot study to be conducted to demonstrate the aeration process. Pinette's Salvage Yard, ME [05/30/89) [F J Excavation and offsite incineration of $3,420,000 PCB-contaminated soil with offsite disposal of ash; excavation and onsite solvent extraction of 5-50 ppm PCB Capital Cost pending trial RA: 91/4 RD: 90/4 Not RA: 91/4 Stated 92 ppm EXCAVATION LEVELS 1 ppm (sediment), 20 ppm (soil) 1 ppm ESTIMATED VOLUME RATIONALE WHY INCINERATION WAS NOT SELECTED short-term air quality impacts on local corrmJnity and onsite workers. 14,000 EPA feels that the cubic yards recommended health-based excavation criterion of 20 ppm is appropriate for this site and is consistent with EPA draft guidance (Development of Advisory Levels for PCB Cleanup). Soil aeration will be consistent with RCRA requirements achieving 1 ppm for sediments with less than 20 ppm PCBs. 2,200 Incineration for PCB cubic yards concentrations above 50 ppm. Solvent extraction for PCB concentrations
> vl SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY contaminated soil with collection of treatment waters in onsite storage tanks and treatment by carbon adsorption and disposal (unspecified) of carbon filters and water, offsite incineration and disposal of PCB oil by-products, and onsite backfilling of treated soils; consolidation of 500 cubic yards of 1·5 ppm PCB soil into excavated areas and cover with< 1 ppm PCB soil; extraction and onsite treatment of contaminated ground water using filtration and carbon adsorption with reinjection of treated water and disposal of carbon residuals (unspecified); offsite disposal of debris affecting remediation activities; O&M; Re-Solve, MA [07 /01 /83] CF l Excavation of oil leachate soils and four unlined lagoons with offsite disposal at a RCRA hazardous waste facility; capping, regrading, and revegetating of the six acre site. Re-Solve, MA C09/24/8n [F l COSTS $3,050,000 Capital Cost Dechlorination of PCB-contaminated $17,038,000 soils using potassium polyethylene Present Worth glycol (KPEG) with onsit~ disposal of treated soils. Rose Disposal Pit, MA [09/23/88] [RP] $6,450,000 (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 83/4 Not RA: 87/4 Stated RD: 90/4 Not RA: 93/1 Stated RD: 90/3 Not Not Stated 3,000 ppm Excavation of soil and sediment with onsite incineration and disposal; Present Worth RA: 91/3 Stated Not Stated EXCAVATION LEVELS Not Stated 1 ppm (sediment), 25 ppm (soil) 13 ppm ESTIMATED VOLUME 3,900 cy (soil), 3, 100 cy (lagoon) RATIONALE WHY INCINERATION WAS NOT SELECTED between 5 ppm and 50 ppm. Replace and cover for PCBs below 5 ppm. Incineration was not considered as a remedial alternative in this Record of Decision. 22,500 Incineration not selected cubic yards due to limited facilities (availability) and length of implementation time. 15,000 cubic yards Incineration selected.
-..:.. __ SITE NAME, STATE [ROO SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY recovery of subsurface free product with offsite thermal destruction and disposal; extraction of ground water and treatment using air stripping and carbon adsorption with discharge to the aquifer. South Municipal Yater Supply Yell, NH Excavation and/or dredging of 1,170 cubic yards of wetlands sediments containing PCB levels >1ppm followed by offsite incineration and disposal of residuals; in-situ treatment of 7,500 cubic yards of soil contaminated by ► volatile organic c~unds using carbon I ~ adsorption for air emissions; ground water treatment using air stripping; and ground water restrictions. Sullivan's Ledge, MA [06/29/89] CF COSTS [09/27 /89] [F l $3,394,519 Present Yorth Excavation of contamianted soil and $10,000,000 sediment with dewatering and onsite Present Yorth solidification and disposal; excavation, clearing, and onsite and offsite disposal of debris; capping of eleven of the twelve acre site; extraction and onsite treatment of contaminated ground water with onsite discharge of treated water to surface water or to a secondary treatment plant; diversion and lining of surface water; ground water institutional controls; O&M. (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 91/3 Not RA: 92/4 Stated RD: 91/1 Not RA: 92/4 Stated Not Stated 2,400 ppm EXCAVATION LEVELS 1 ppm 10 ppm (soils), 1 ppm (sediment) ESTIMATED VOLUME 1, 170 cubic yards 24,200 cy (soil), 1,900 cy (seds) RATIONALE YHY INCINERATION YAS NOT SELECTED Incineration selected. Selected remedy is cost-effective considering tong-term effectiveness and the significant reduction of mobility equivalent to other treatment alternatives (i.e., incineration).
SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY \Jells G&H, MA [09/14/89] [F l COSTS RD/RA COMPLETE (CONTINUED) AROCHLORS PRE-TREATMENT CONCENTRATION Excavation of PCB-contaminated soils with onsite incineration and backfilling of excavated areas; in-situ volatilization of 7,600 cubic yards of soils contaminated with volatile organic COll1)0Unds using carbon adsorption for emissions; and extraction of ground water and treatment using air stripping and carbon adsorption. $68,400,000 RD: 91/3 Not Not Stated Present \Jorth RA: 93/2 Stated SUBTOTAL 11 > REGION 02 I VI Bridgeport Rental & Oil, NJ [12/31/84] [F l Excavation and onsite incineration of $35,050,000 oily waste, sediment and sludge using Present \Jorth a pyrotech mobile incinerator. Burnt Fly Bog, NJ [11/16/83] [S l Excavation and offsite disposal of liquids, sludges, asphalt pines, druns, and contaminated soils from lagoons and wetlands; restoration of site contours and revegetation; ground water monitoring. $7,310,000 Capital Cost RD: 88/2 Not RA: 92/4 Stated RD: 86/3 Not RA: 89/4 Stated >500 ppm 245 ppm EXCAVATION LEVELS 1.04 ppm Not Stated 8.5 ppm ESTIMATED VOLUME RATIONALE \JHY INCINERATION \JAS NOT SELECTED 3,100 Incineration selected. cubic yards 60,000 cubic yards Not Stated Incineration selected. There are no mobile incinerators presently avaliable which can reliably incinerate PCB waste. In addition, the process would generate ash residual, wastewater, and air emmissions which would require treatment or secure disposal.
> °' .,,,....._,._.,-r~· .:,-!::;_,,:~-:.~-•..,;~~ SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY Burnt Fly Bog, NJ [09/29/88) [S l COSTS Excavation of contaminated materials $6,100,000 and offsite disposal; containment of Present Uorth contaminated soil in westerly wetlands; construction of a security fence and access road; treatability studies will determine the most appropriate remedy for the westerly wetlands. Chemical Control, NJ [09/23/87] [F l In-situ fixation of contaminated soil $7,280,000 (drill large diameter soil borings, Capital Cost inject chemical fixating material and mix with soil); treatability studies will be conducted during remedial design. Clothier Disposal, NY [12/28/88) [S l (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 90/2 Not RA: 91/2 Stated RD: 91/2 1242 1254 RA: 93/1 1260 232 ppm 6 ppm Cover contaminated soil conta1n1ng less $500,000 RD: 89/3 1242 2.7 ppm than 1 ppm PCBs with one foot of clean Present Uorth RA: 90/4 soil; installation of rip rap to prevent soil erosion; long-term ground water, surface water, air and sediment monitoring; institutional controls including land use and deed restrictions. EXCAVATION LEVELS 5 ppm (soils) Not Stated 1 ppm ESTIMATED VOLUME 62,000 cy (soil) 1,400 cy (seds) RATIONALE UHY INCINERATION UAS NOT SELECTED Contamination found in the downstream area, while significant enough to pose a threat in the stream, is at sufficiently low concentration that treatment is not warranted. At this low concentration, EPA feels that containment in a RCRA or TSCA permitted facility would be protective. 18,000 Incineration is more cubic yards expensive than the selected alternative and does little to further reduce risk at the site. 2,500 EPA determined that the cubic yards risk levels associated with the residual contamination was minimal and within the range considered acceptable for Superfund remedies. The selected remedy provides additional protection by reducing the threat of contact and ingestion through capping.
> -.J SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY GE Moreau, NY [07/13/87] [RP] COSTS Excavation of 8,600 cubic yards of soil $4,664,000 with onsite disposal within existing slurry wall containment area; cap disposal area; extention of public water supply to approximately 100 homes; institutional controls. Hooker/Hyde Park, NY [11/26/85] [FE] Capital Cost Extraction and onsite phase _separation $17,000,000 of non-aqueous phase liquids (NAPL) Total Cost from ground water followed by thermal destruction. Hudson River PCB, NY [09/25/84] CF l In-situ containment of remnant shoreline deposits; covering of .affected areas with soil, regrading, and seeding; stabilization of river bank, if necessary. Kin-Bue Landfill, NJ [09/30/88] [RP] $2,950,000 Capital Cost (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 87/4 Not RA: 89/3 Stated RD: 86/4 1248 RA: 92/1 RD: 89/4 Not RA: 92/1 Stated 3,000 ppm 3,000 ppm 1,000 ppm Extraction of ground water and aqueous $16,635,000 RD: 90/2 Not 5,822 ppm phase leachate and onsite treatment Present Worth RA: 93/1 Stated using carbon)dsorption and aerobic/~robic biodegradation treatment with onsite residual EXCAVATION LEVELS Not Stated Not Stated Not Applicable Not Stated ESTIMATED VOLUME 8,600 RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration onsite or cubic yards offsite for some 8,600 cubic yards of material would be prohibitively expensive compared to the other two remedial alternatives described. Incineration was therefore eliminated from future consideration. Not Stated Incineration selected. Not The capital costs Applicable .associated with constructing a multi-incinerator system -that would have the 3,000,000 gallons (leachate) capacity to handle the massive amounts of PCB sediment (at the site) would approach 250 million dollars. It would be difficult for a single incinerator facility to dedicate itself to handling such a large volune of hazardous
> 00 __ § __ ",r',rA cc'_@-c'L~ SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY discharge to surface water; collection and offsite incineration of oily phase leachate; installation of a slurry wall and cap with periodic monitoring; O&M. Krysowaty Farm, NJ [06/20/84] [F] COSTS Excavation and offsite disposal of $2,164,014 contaminated soils and wastes at an Capital Cost approved PCB facility; monitoring of onsite wells; provide alternate water supply to affected residents; post-closure environmental monitoring. Ludlow Sand & Gravel, NY [09/30/88] [FE] (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RD: 85/4 1221 RA: 86/2 1260 CONCENTRATION 300 ppm Excavation of contaminated soil and sediment and onsite consolidation, disposal, and capping; collection of leachate using either a passive drain system or an active extraction well system and dewatering of contaminated leachate and ground water with onsite discharge of effluent to surface water or offsite discharge; rrultimedia monitoring. $3,727,000-RD: 91/1 Not 482 ppm $14,548,900 RA: 93/2 Stated Present Worth EXCAVATION LEVELS Not Stated 10 ppm ESTIMATED VOLUME -• ----------RATIONALE WHY INCINERATION WAS NOT SELECTED waste. Even if an incinerator dedicated itself to disposing Kin-Bue wastes, it is estimated that it would take 35 years to c~lete incineration. 4,000 PCB contamination at the cubic yards site did not exceed 500 ppm; therefore, disposal of contaminated soils will occur in a TSCA approved landfill. If soils are encountered with PCB levels above 500 ppm, these soils will be incinerated per TSCA requirements. 10,000 Thermal treatment cubic yards (incineration) was not expected to offer significant increases in protectiveness to public health and the environment, or short-or long-term effectiveness for the increased cost.
> I ,,c, SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY Renora, NJ [09/29/87] [FE] COSTS Excavation and offsite landfilling of $1,344,000 PCB-contaminated soils; excavation and Capital Cost onsite biodegradation of PAH-contaminated soils; backfilling; grading; and revegetation. Swope Oil & Chemical, ·NJ [09/27 /85] CF ] Excavation and offsite incineration of $3,134,683 PCB "hot spots"; removal of tanks, buildings, and debris with offsite incineration; extraction and offsite incineration of aqueous tank contents; offsite disposal of non-aqueous tank contents; excavation of PCB contaminated soil and buried sludge area with offsite disposal. Total Cost Wide Beach Development, NY [09/30/85] [S] Conduct pilot study on KPEG (potassiun $9,295,000 polyethylene glycol) treatment to determine effectiveness in neutralizing the PCB contaminated soil. York Oil, NY [02/09/88] [F ] Present Worth Excavation and dewatering of PCB $6,500,000 contaminated soil and sediments with Capital Cost solidification in a mobile onsite unit, the stabilized material will be tested to verify its non-leachability and then disposed onsite; extraction of ground water with onsite treatment using an oil skimmer and oil/watt!"r separator with discharge into a modular water treatment unit; offsite treatment (to (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 88/4 1260 RA: 90/4 RD: 88/4 1242 1248 RA: 90/4 1254 1260 RD: 89/2 1254 RA; 91/1 RD: 91/1 1248 RA: 93/2 1254 1260 37,000 ppm 500 ppm 1,026 ppm 210 ppm EXCAVATION LEVELS 5 ppm 5 ppm 10 ppm 10 ppm (soil) 1 ppb (ground water) ESTIMATED VOLUME RATIONALE WHY INCINERATION WAS NOT SELECTED 1,100 Excavation and offsite cubic yards disposal also may include offsite incineration as a component of the selected remedy. 145 cy > 50 ppm 8,650 cy < 50 ppm 22,300 Total site contamination not incinerated due to cost. Incineration not retained cubic yards as a viable alternative through preliminary screening. No rationale was provided in the ROD. 30,000 cubic yards 25,000 gallons Incineration was not selected because further treatment of the residual ash following thermal destruction may be needed to fuse the high concentration of metals found onsite into the residual ash in a non-hazardous form. 'i{,:.~-t.-\;:,--;r.;,:.·
r.._jro..,o,,.-..· > -0 ··--~·,-__ ·-."':'. __ _ SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY be selected following treatability studies) of PCB-contaminated tank oils; demolition and decontamination of the eq,ty storage tanks. SUBTOTAL 15 REGION 03 Delaware Sand & Gravel, DE [04/22/88] Excavation of PCB-contaminated soil at Drun Disposal Area and Ridge Area; temporary onsite storage followed by onsite mobile incineration of excavated soil and waste; treatability studies; residual ash will be analyzed and disposed onsite. ~ COSTS [FE] $18,250,000 Total Cost Douglassville Disposal, PA [06/24/88] [S l Removal, transportation, and offsite incineration of liquid and sludge tank waste; decontamination of tanks, piping, processing equipment, and building materials designated for salvage or reuse to a level not to exceed 100 ug/100 square centimeters PCBs on the surface; offsite disposal of building rubble, concrete, asphalt, and other materials that cannot be decontaminated to less than 50 ppm PCBs and treatment (dewatering or incineration) of generated decontamination fluids. $4,050,000 Capital Cost (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RD: 90/2 Not RA: 93/4 Stated RD: 89/3 1260 RA: 91/1 CONCENTRATION 49 ppm 6,400 ppm EXCAVATION LEVELS Not Stated Not Stated ESTIMATED VOLUME 29,722 cubic yards 200,000 gallons RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration selected. Incineration selected.
► ...... ...... SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY Douglassville Disposal, PA [06/30/89] Excavation and onsite thermal treatment of contaminated soils, sludges and sediments with solidification and onsite disposal of ash residuals; installation of soil covers in contaminated source areas; deed restrictions. Fike Chemical, W [09/29/88] [F l Excavation and removal of tanks and druns with offsite incineration and disposal; drainage and onsite treatment of lagoon sludge using ion exchange or chemical oxydation; wastewater treatment using granulated activated carbon with offsite residual discharge to surface water. Lehigh Electric, PA [02/11/83] CF J Excavation and offsite disposal of soils.greater than 50 ppm; additional removal of soil where cost-effective; demolition of buildings onsite; grading and revegetation; O&M. M.W. Manufacturing, PA [03/31 /89] [F Excavation of contaminated waste and soil followed by offsite incineration at a RCRA permitted facility; incinerator ash will be disposed offsite at a RCRA landfill. (CONTINUED) COSTS [S l $39,280,670-$53,619,000 Capital Cost RD/RA COMPLETE RD: 90/3 AROCHLORS Not RA: 91/4 Stated $13,130,000 RD: 89/2 Not Present Worth RA: 90/1 Stated $6,401,000 Capital Cost $2,061,000 Capital Cost RD: 84/1 RA: 84/4 RD: 89/4 RA: 90/1 Not Stated Not Stated PRE-TREATMENT CONCENTRATION 1,889 ppm Not Stated 110,000 ppm 54 ppm EXCAVATION LEVELS Not Stated Not Stated 50 ppm Not Stated ESTIMATED VOLUME 48,400 cubic yards Not Stated 18,800 cubic yards 875 cubic yards RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration selected. Incineration selected. There are no mobile incinerators permitted to operate in Pennsylvania. Operating costs also would be excessive, making this option not cost-effective. Incineration selected.
> -N ··-·---·· SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS Ordinance Works Disposal, W [03/31/88] [FE] Onsite mobile incineration and containment of excavated soils and sediments; onsite disposal of non-EP toxic ash residuals in an inactive landfill; offsite disposal of EP toxic ash at an approved RCRA facility; close inactive landfill using multi-layer cap. SUBTOTAL 7 REGION 04 Airco Carbide, KY [06/24/88] [RP] $6,718,000 Present Worth Excavation and consolidation of $6,090,000 contaminated sediments and surface Present Worth soils in former Burn Pit Area and cap; extraction of ground water and onsite treatment using air stripping, carbon adsorption, and oil/water seperation with discharge of treated water offsite to surface water; deed restrictions; construction of organic vapor recovery system; construction of flood plain protection dike; installation of a leachate extraction system and upgrade existing clay cap. Geiger/C&M Oil, SC [06/01 /87] [F l Excavation and onsite thermal treatment $7,700,000 of soil to remove organics followed by Present Worth solidification/stabilization of thermally treated soil following treatability studies. (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RD: 91/2 1016 RA: 93/4 1260 RD: 89/3 Not RA: 91/4 Stated RD: 89/2 1254 RA: 91/4 CONCENTRATION 229 ppm 4 ppm (seds) 4 ppm EXCAVATION LEVELS 5 ppm Not Stated 1 ppm ESTIMATED VOLUME Not Stated RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration selected. 5,000 Incineration was not cubic yards retained as a viable alternative through preliminary screening. No rationale was provided in the ROD. 11,300 cubic yards Incineration selected.
> -vl SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS Goodrich, B.F. Chemical Group, KY [06/24/88] [RP] Extraction of ground water and $6,090,000 treatment using air stripping, carbon Present Worth adsorption, and oil/water separation with discharge of treated water to surface water; deed restrictions; excavation and placement of the contaminated surface soils in former burn pit area and cap; construction of an organic vapor recovery system; construction of a flood protection dike; installation of a leachate extraction system and upgrade existing landfill clay cap. Mowbray Engineering, AL [09/25/86] [F l Excavation of contaminated soils and $750,000 either on-or offsite incineration or Capital Cost onsite stabilization/solidification of these soils. Newport D~, KY [03/27 /88] [FE] Restoration and extention of leachate $516,000 collection system; resoration, Capital Cost regrading, and revegetation of clay cap; monitoring of ground wa~er and soil; o&M. (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RD: 89/3 Not RA: 91/4 Stated RD: No RD date; removal action will be conducted to implement ROD; solidi-fication was chosen as the selected action; RA: 87/4 1260 RD: 88/1 1242 RA: 88/1 1260 CONCENTRATION 4 ppm (seds) 1,500 ppm 1,020 ppm EXCAVATION LEVELS Not Stated 25 ppm Not Applicable ESTIMATED VOLUME RATIONALE WHY INCINERATION WAS NOT SELECTED 5,000 Incineration not retained cubic yards as a viable alternative through preliminary screening. No rationale was provided in the ROD. 4,800 Incineration preferred in cubic yards ROD, however, Regional Coordinator stated that solidification was selected by the removal program. Not Applicable Incineration was not considered as a remedial alternative in this Record of Decision.
__,.,,..--,,;:~~~-~---·~-,,,,...,_.,,_ -,,.,---.... ·-----•··• ,. .. __ . -'-·--· ··------• --•----··--------·-·------~-r:~.:~~-> ...... +>-(CONTINUED) SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS RD/RA COMPLETE AROCHLORS PRE-TREATMENT [09/18/89] [F 1 $14,180,249 RD: 90/4 1254 Newsom Brothers Old Reichold, MS Excavation of PCB-contaminated sediments and soils with offsite disposal; excavation of non-PCB contaminated black tar-like waste material with offsite treatment using incineration and offsite disposal of ash at a RCRA landfill Present Yorth RA: 92/2 Pepper's Steel & Alloy, FL [03/12/86] [FE] Solidification of PCB contaminated soils with a cement type mixture and onsite placement of residuals; residual analysis of solidified soils prior to disposal. $5,212,000 RD: 87/1 Not Present Yorth RA: 89/3 Stated Smith's Farm Brooks, KY [09/29/89] CF J Excavation of PCB contaminated soil, $26,900,000 RD: 91/1 1248 waste material and sediments from site Present Yorth RA: 93/3 1254 Area B with onsite incineration followed by solidification/fixation of treatment residuals; capping of soils in Area A; construction of leachate collection system; access restrictions; and ground water monitoring. SUBTOTAL 8 1260 CONCENTRA Tl ON 10 ppm sediment 2,700 ppm 6, 100-13, 100ppm EXCAVATION LEVELS 0.12 ppm 1 ppm 2 ppm ESTIMATED VOLUME 48,370 RATIONALE YHY INCINERATION YAS NOT SELECTED Incineration for soils and cubic yards sediments was not selected due to uncertainty over volll!le of material to be treated and lack of acceptance by State and coomJnity. Higher cost was considered a minor influence in decision. 48,000 Incineration was not cubic yards selected due to serious environmental disadvantages (2-16% of lead escapes into the aquifer), inavailability of incinerators, complexity of waste matrix, time intensive remedy, costly, and requires additional waste handling. 26,200 cubic yards Incineration selected.
> -Ut SITE NAME, STATE [ROO SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY REGION 05 A&F Materials/Greenup, IL [06/14/85] Excavation and offsite disposal of soil contaminated above reconmended action levels; decontamination and removal of onsite equipment and buildings; ground water monitoring; o&M. Alsco Anaconda, OH [09/08/89] [RP] Excavation of 50 cubic yards of sludge with PCB levels >500ppm followed by offsite incineration and disposal; excavation of remaining 3,250 cubic yards of sludge and soils (PCB concentrations <500ppm) with offsite disposal in compliance with all RCRA and TSCA regulations; backfilling excavated areas; and deed restrictions. COSTS [FE] $824,000 Capital Cost $4,161,066 Capital Cost Belvidere Municipal Landfill #1, IL [06/30/88] [S l Soils in the drum disposal area will be $5,617,000 resa~led and those containing greater Present Worth than 50 ppm P~Bs will either be excavated and incinerated offsite or left in place and capped with a soil cover; soils contaminated with less than 50 ppm PCBs will be consolidated with the landfill material prior to capping. RD/RA COMPLETE RD: 84/3 RA: 85/4 RD: 91/3 RA: 93/4 RD: 90/1 RA: 92/3 (CONTINUED) AROCHLORS PRE-TREATMENT CONCENTRATION Not Not Stated Stated Not 3,000 ppm max Stated sludge 1242 51,000 ppm 1254 1260 EXCAVATION LEVELS 1 ppm Not Stated 50 ppm ESTIMATED VOLUME 1,332 cubic yards 3,300 cubic yards Not Stated RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration was not considered as a remedial alternative in this Record of Decision. Incineration selected for PCB concentrations >500ppm. Incineration selected for soils containing greater than 50 ppm PCBs.
.~-·~•.~ --·--~-·••.-~-··.···----~~_'":'"" > -°' (CONTINUED) SITE NM, STATE CROO SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED -REMEDY COSTS RO/RA COMPLETE AROCHLORS PRE-TREATMENT Bowers Landfill, OH [03/31 /89] [RP] Capping; management of surface debris; $4,267,500 RD: 90/4 1242 erosion control and monitoring of Present Worth RA: 92/1 1248 ground water; o&M. cs ] 12,076,500 Cross Brothers Pail, IL [09/28/89] Wes-.:,ling·of localized PCB soil area to identify existence of PCB source; if identified the source area.will be excavated and incinerated offsite at a TSCA incinerator; installation of-a passive .ground water-collection and soil flushing system; ground ~ater monitoring; ·and deed and .access restrictions. Fields Brook, OH [09/30/86] [F ] Excavation of contaminated sediment with-temporary storage, dewatering, test burns and onsite· thermal treatment followed by onsite disposal of ash in a RCRA/TSCA .landfill, unless determined to be non-hazardous. Present Worth $12,260,000 Capital Cost Fort Wayne Reduction, IN [08/26/88] CF l 1254 RD: 91/2 1242 RA: 92/4 1248 1254 1260 RD: 91/3 Not RA: 94/1 Stated Excavation of the western portion of $10,020,000 RD: 91/3 Not · the site for removal of 4,600 buried intact. drums and incineration of the drum contents onsite or offsite; reconsolidation of excavated soils and wastes onsite followed by hybrid . closure consisting of a compacted, continuous soil cover. Present Worth RA: 91/4 Stated CONCENTRATION 36 ppm 42,900-112,000 pp 518 ppm 14.2 ppm cXCAVATION LEVELS Not Stated 10 ppm 50 ppm 10 ppm ESTIMATED VOLUME Not Stated 5 cubic yards RATIONALE "HY INCJNE~TIOII "AS NOT SELECTED Incineration was not considered as an alternative remedy, and no rationale rationale was provided in the ROO. Incineration selected. 16,000 Incineration selected. cubic yards 230,000 gal Lons Incineration selected for drum contents; incineration not selected for contaminated soil due to high costs.
C CONTINUED) SIT£ WME, STATE (ROD SIGtl l>ATE] (LEAD) COSTS RD/RA AROCttLOH PRE-TREATMENT EXCAVATION ESTIMTED RATIONALE WHY I NC I NERA Tl ON . C0MPONENTS OF THE SELECTED REMEDY CMPLETE CONCENTRA Tl ON LEVELS VOLUME · WAS NOT .SELECTED LaSalle "Electrical Utilities, IL (08/29/86) CF l Exeavatfon and inctneration of $26,400,000 RD: 87/4 1248 5,800 ppm 5 ppm 25,530 Incineration selected. contaminated soil and clean fill Present Worth RA: 90/1 1254 cubic yards excavated areas; decontamination of onsite structures. LaSalle Electrical Utilities, IL (03/30/88) CF J -€~ewatfon·and IIObile onsite $34,495,180 RO: 89/Z 1248 11,000,.. 5 ppm 2:S,500 Incineration selected. incineration of PCB contaminated soi ls Present Worth RA: 93/l 1254 (surface) cubic yards and strea sedi111ents wfth subsequent 10 ppa ash analysis to determine final (subsoils) disposal location; high pressure flushing and mechanical cleaning of > sewer lines, and collection and treatment (to be detailed during -design, but will include phase -..J separation, filtration, and air str·ipping) of ground water containing PCBs at concentrations above 1 ppb. Laskin/Poplar Oil, OH C08/09/84] CF l Excavation and offsite incineration of $1,043,000 RD: 86/2 Not 500 ppm Not 250,000 Incineration selected. PCB· contaminated waste water and oils. Total Cost RA: 92/4 Stated Stated gallons Laskin/Poplar Oil, OH C09/30/87] CF l Excavation and incineration of oils, $4,377,500 RD: 89/3 1221 144 ppm ~ ppm 71,100 Incineration selected. sludges and highly contaminated soils Present Worth RA: 92/2 1242 cubic yards and offsite disposal of ash residuals. 1254 1260 Laskin/Poplar Oil, OH C06/29/89] cs ] Thermal destruction of contaminated $11,000,000 RD: 91/2 Not Not Not 5,000 Incineration selected. soils, ash and debris with onsite Capital Cost RA: 92/4 Stated Stated Stated cubic yards disposal of ash if delisted or offsite disposal at a RCRA hazarcf<lijs waste landfill; demolition and thermal
__ _._,_ ~ ~~r:-~..:,_..;.. . .;,.;..;.-:; -.:.'"'~--~=:-:---:~-.:--"'::~:::::::.:===:::-'.":" .. -::-.. -------·· ··---·· ---~-·--~-. -, > ,_. 00 SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY destruction or decontamination of dioxin contaminated structures, if these structures cannot be decontaminated then contain in a concrete vault onsite and cap for t~rary storage; drain retention and freshwater ponds with discharge to surface water and treatment as necessary; construct a multi-layer cap over soils exceeding performance levels; dewater site by natural ground water flow to surface water; ground and surface water monitoring and land use restrictions. Liquid Disposal, MI [09/30/87] [S l Excavation and onsite disposal of debris with solidification/fixation of COSTS $21,743,100 Capital Cost RD/RA COMPLETE RD: 90/2 RA: 92/4 ( CON Tl NUED) AROCHLORS PRE-TREATMENT Not Stated CONCENTRATION Not Stated EXCAVATION LEVELS Not Stated ESTIMATED VOLUME 136,650 cubic yards RATIONALE WHY INCINERATION WAS NOT SELECTED The level of treatment afforded by incineration, soil and waste; extraction of ground while desirable, water onsite and treatment using air particularly for PCBs, is strippers or ion exchange with not cost-effective for the discharge to surface water; LDI site contaminants. construction of a slurry wall and cap. Miami County Incinerator, OH [06/30/89] [F ] Excavation and consolidation of ash wastes and contaminated soils with disposal in north or south landfill and capping; vapor extraction and treatment of exhaust; extraction and treatment (unspecified) of ground water with discharge to POTW; pretreatment of ground water (unspecified) if necessary; alternate water supply. $1,700,000-RD: 92/1 Not $3,500,000 RA: 92/2 Stated Present Worth Not Stated Background Levels 22,000 cubic yards Incineration would cost six to seven times as much as the selected remedy (vapor extraction) without providing a proportionate benefit. Incineration would leave a residue which would need to be disposed onsite or at an appropriate landfill offsite.
>--"' SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY Midco I, IN [06/30/89] [RP] Excavation and onsite treatment of 12,400 cubic yards of contaminated soil and waste and 1,200 cubic yards of contaminated sediments by a combination of vapor extraction and solidification/stabilization followed by onsite disposal; installation and operation of a ground water pllll>ing system to intercept contaminated ground water followed by reinjection into a deep well; installation of RCRA cap. Midco 11, IN (06/30/89] [RP] Excavation and onsite treatment of 35,000 cubic yards of contaminated soil and waste, and 500 cubic yards of sediments by solidification/stabilization followed by onsite disposal of the solidified waste; installation and operation of a pllll>ing system to intercept contaminated ground water followed by discharge to a deep injection well; installation of RCRA cap. Ninth Avenue Dump, IN [09/20/88] CF l Containment of the oil layer by constructing a soil-bentonite slurry wall extending into the clay layer 30 feet below the surface; extraction of oil and ground water within the containment area with treat~nt of ground water using oil/water' separator and discharge into a ground water COSTS $9,094,000 Capital Cost $11,755,400 Capital Cost $1,960,000 Capital Cost (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RD: 91 / 1 1242 RA: 93/1 1254 1248 RD: 91/1 Not RA: 93/4 Stated RD: 90/3 RA: 92/1 1248 1254 1260 CONCENTRATION 44 ppm < 50 ppm 1,500 ppm EXCAVATION LEVELS Not Stated Not Stated Not Stated ESTIMATED VOLUME 12,400 cy (soil) 1,200 cy (seds) 35,000 cy (soil) 500 cy (seds) 250,000-700,000 gal Lons .,:,,,~~r .. ...-..:,;. RATIONALE ijHY INCINERATION ijAS NOT SELECTED Incineration is more expensive than the selected alternative and does little to further reduce risk at the site. Incineration is more expensive than the selected alternative and does little to further reduce risk at the site. Incineration not selected because the oil layer is contaminated with chlorinated dibenzo-dioxins as well as PCBs and it may be difficult to find a commercial incinerator
-· --· --· 'Mlihf_--~-=~~~,._~ ---(CONTINUED) SITE NAME, STATE [ROO SIGN DATE] [LEAD] COSTS RD/RA AROCHLORS PRE-TREATMENT EXCAVATION ESTIMATED RATIONALE IJHY INCINERATION COMPONENTS OF THE SELECTED REMEDY COMPLETE CONCENTRATION LEVELS VOLUME IJAS NOT SELECTED recharge system; temporary onsite willing to accept dioxin storage of contaminated oil in a contaminated waste, and a secondary containment structure meeting mobile incinerator may not RCRA and TSCA tank storage be cost-effective. requirements. Ninth Avenue Dunp, IN [06/30/89] CF l Excavation of oil contaminated waste, $22,209,000 RD: 91/3 Not Not Not 36,000 Incineration selected. fill, debris, and sediments from on-Present IJorth RA: 93/4 Stated Stated Stated cubic yards and offsite surface water followed by onsite thermal destruction in a mobile incinerator; extraction, treatment (unspecified) and reinjection of > contaminated ground water inside slurry wall to promote soil flushing; N discharge of a small quantity of ground 0 water outside slurry wall to compensate for infiltration; capping. Outboard Marine/Johnson, IL [05/15/84] CF l Dredge, dewater and fixate the four $13,890,000 RD: 85/3 Not 155,000 ppm 50 ppm 222,400 Fund balancing used to contaminated "hot spots" containing Capital Cost RA: 91/4 Stated cubic yards waive applicable laws. with PCB contaminated soil and sediments Incineration not retained with offsite disposal. Total amount of as a viable alternative PCBs is estimated to be 771,200 pounds. through preliminary screening. Outboard Marine/Johnson, MI [03/31/89] CF l Amendment: Construction of three $19,000,000 RD: 90/2 Not 710,000 ppm > 500 ppm Not There are no PCB containment cells to hold contaminated Present IJorth RA: 91/4 Stated (sediment) Stated extraction or soil soil and sediment; excavation of > 10,000 ppm treatment technologies PCB-contaminated sediment and soil with (Soil) specified in this ROO. onsite thermal or chemical extraction, There is no rationale (or an effective alternative treatment) documented in the ROO with offsite disposal of extracted concerning which treatment PCBs; placement of treated sediment and technology will be selected.
> N -SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY soil in lined and capped contairvnent cells; treatment of dredge water by sand filtration and carbon adsorption with discharge to either an offsite sanitary sewer or onsite. Rose Township Dunp, Ml (09/30/87) cs ] Excavation of contaminated soil with onsite incineration and onsite or offsite residual ash disposal; extraction and treatment of contaminated ground water using chemical coagulation, air stripping, and activated carbon adsorption with onsite discharge of treated water; O&M. Schmalz Dump, WI [08/13/85) CF l COSTS $32,547,000 Capital Cost Excavation and offsite disposal or $2,088,300 offsite incineration and offsite Capital Cost residual ash disposal of contaminated building debris. Sumnit National Liquid Disposal, OH (06/30/88) CF l \ (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 90/3 Not RA: 92/3 Stated RD: 87/4 Not RA: 89/1 Stated 980 ppm 3,100 ppm Excavation and onsite mobile $25,000,000 RD: 90/2 Not Not Stated incineration of PCB contaminated soil, Present Worth RA: 95/3 Stated sediment, and debris, including tank contents with disposal of incinerated residual in an onsite RCRA landfill; pre-burn tests will be required to demonstrate the type of thermal destruction to be employed ,at the site. EXCAVATION LEVELS 10 ppm Not Stated Not Stated ESTIMATED VOLUME 50,000 cubic yards RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration selected. 3,500 Incineration is an option cubic yards for PCB-contaminated debris removed from the site. 32,000 Incineration selected. cubic yards 88,000 gallons
_,._ _______ ··--, •.. ::....= ·•· ___ .. _.:.:.--· _: · __ ---:===::::::.::__:=· =-·=-=-~-=-~~·•~-!!!:'.!·•~-!C~~·~!!*!!l!•!!!!~-!9~ .. ~~~~-f-~-~~·~•~--~-~-i:~.::.~.=:::~--:--:~==-::--------· ~·~ --· ► N N (CONTINUED) SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS RD/RA COMPLETE AROCHLORS PRE-TREATMENT Wedzeb, IN [06/30/89) CF J Flushing and decontamination of sewer $24,500 RD: 91/2 Not lines; filtration of sewer water to Present Worth RA: 93/3 Stated remove PCB contaminated sediments; monitoring of the water and refiltering, if necessary with discharge to a POTW; analyze two barrels of sediment and 20 barrels of RI generated waste; > 50 ppm PCB levels will be treated by offsite incineration and levels< 50 ppm PCB will be disposed offsite at a EPA approved site. SUBTOTAL 24 REGION 06 French Limited, TX [03/24/88) [F J In-situ biodegradation of sludges and $47,000,000 contaminated soils using indigenous Present Worth bacteria with aeration of the lagoon waste to enhance the degradation process; residues from the treatment process will be stabilized and disposed onsite. Geneva Industries, TX [09/18/86) CS J Offsite disposal of surface structures $14,992,000 RD: 90/1 Not RA: 95/2 Stated RD: 88/1 Not to hazardous waste landfill; excavation Capital Cost RA: 91/3 Stated of soils with> 100 ppm PCBs and druns with offsite disposal to an EPA-approved facility; construction of a multi-layer clay cap and slurry wall; extraction and treatment of ground CONCENTRATION 370 ppm (seds) 616 ppm 1,750 ppm EXCAVATION LEVELS 10 ppm 23 ppm 100 ppm ESTIMATED VOLUME Not Stated RATIONALE WHY INCINERATION WAS NOT SELECTED Incineration for PCB concentrations above 50 ppm, offsite TSCA land disposal for concentrations below 50 ppm. 149,000 Incineration is more cubic yards expensive than the selected alternative and does little to further reduce risk at the site. 22,500 The selected remedy offers cubic yards the same level of protection for public health and the environment. Since onsite incineration was found to generally cost more than
> N w (CONTINUED) SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION water using carbon adsorption with discharge to adjacent flood control channel. Gurley Pit, AR [10/06/86] [FE] Construction of an onsite pond water $5,780,000 RD: 88/4 Not tre~tment unit with discharge to Bayou; Capital Cost RA: 91/2 Stated removal of contaminated solids from pond water and dispose with pit sludge; removal of oil from pond water using oil/water separator with treatment using PCB-approved incinerator; extraction and stabilization of pit sludge with pond solids with onsite disposal; excavation of soil and sediments with onsite disposal with stabilized material; cap stabilized wastes; O&M. Hardage/Criner, OK [11/14/86] CFEJ Extraction of surface and ground water $68,000,000 RD: 1260 with separation of NAPL followed by Present Worth currently offsite incineration of organic liquids with offsite disposal of ash residuals, or onsite incineration with onsite disposal of solid ash residuals, and either recycle or treat (unspecified) residual liquids followed by offsite discharge; onsite treatment of soils negotiating with PRP: 89/1; RA: assuming RP judgment 92/4 20 ppm > 50 ppm EXCAVATION LEVELS Not Stated Not Stated ESTIMATED VOLUME 17 cy Coil), 15,984 cy (sludge) .~ • .-,;....:.._Ct.-'.ii<).1;;'?~~ RATIONALE WHY INCINERATION WAS NOT SELECTED offsite remedies, offsite disposal has been selected as the remedy for this site. The large increase in cost for incineration for a small gain in contairvnent weighted against incineration of sludge waste. In addition, a large quantity of waste would have to be transported to an incinerator. This would increase the danger of exposure of the public through accidental spills. Offsite incineration was selected for the small quantity of PCB-contaminated oil removed from the ponded water. 175,000 Determine soil treatment cubic yards remedy during remedial design.
> <i•~~--:--~~-,::-·~·---SITE NAME, STATE [ROD SIGN DATE] [LEAD] . COMPONENTS OF THE SELECTED REMEDY and debris by one or more of the following: chemical neutralization, solidification, dewatering, chemical oxidation/reduction, air stripping; rotory-kiln incineration bench-scale test to be conducted for moisture content and reactions of soil/fluid combinations and if successful, conduct pilot study and emissions testing. MOTCO, TX [03/15/85] CF l COSTS Excavation and offsite incineration of S42,300,000 PCB I iquid organics at a ·permitted .Capital Cost TSCA facility; excavation and offsite disposal of PCB-contaminated tars and ~ sludges at a RCRA landfill; extraction of pit water and treatment at an industrial waste water treatment plant. Sheridan Disposal Services, TX [12/29/881 [RP] Excavation and onsite biotreatment of S28,346,000. all sludges; debris, floating oil and Capital Cost emulsion, anct soils contafnfng > 25 ppa of PCBs; residuals,. reduced to < 50 ppm-PCBs, will be stabilized onsite, returned to the pond and capped; if the residuals are> 50 ppm PCBs, the pond will be a RCRA c~l iant landfill; decontantfriatfon and disposal of all onsite tanks and processing equipment with onsite treatment (unspeci· fied) or offsite disposal depending on contents; treatment of storm and waste water streams to remove solids, metal and organics witft·• di-scharge to surface water: institutional controls. -·¥~• ¥--~· -~-::::---~=-..::...;___ __ _ (CONTINUED) RD/RA C~LETE AROCHLORS PRE-TREATMENT RD: 86/4 Not RA: 94/1 Stated Rik 91/f Not RAt Not Stilted Available CONCENTRATION 100 PJllll 2ZS-Pflll EXCAVATION LEVELS Not Stated 25 PJllll ESTIMATED VOLUME RATIONALE WHY INCINERATION WAS NOT SELECTED 18,000 lncineratioi, selected. cubic:yards .. '(~ 44,000 c•kyards :~..:t-Biorelllediation significantly reduces IIIDbHtty,,toxkfty and wlUDe and essentially elimina-tes the source of contamination to the grouid water. Incineration is·. mechanically CQIIIPlex, using highly.specialized costly equipnent and operators and would have required approved offsite • · disposal of ash.·
> I t..,) VI (CONTINUED) SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY COSTS RD/RA COMPLETE AROCHLORS PRE-TREATMENT Sol Lynn/Industrial Transformers, TX [03/25/881 CF l Excavation and treatment of $2,200,000 contaminated soil with an alkali metal Present Worth polyethylene glycolate CAPEG) reagent in a batch reactor; pretreatment, if necessary, and discharge of liquid by-products of treatment to a POT~; APEG feasibility testing will be conducted during the design phase. SUBTOTAL 7 REGION 07 Doepke Disposal Holliday, KS [09/21/89] [RP] RD: 90/4 Not RA: 93/2 Stated Removal and offsite treatment of contaminated liquids ponded l.l'lder former·surface i~ntsr construction of an impermeable rrulti·layer cap over majority of Naste area, including soils contaminated with PCBs; deed and access restrictions; and ground water monitoring. SS,970,000 RD: 91/1 1248 SUBTOTAL 1· REGION 09 Lorentz Barrel & Drum, CA [09/28/881 Extraction of PCB contaminated ground Present Worth RA:. 93/J: 1254 .. -. 1260 [FE] S3,238,000 water and onsite treatment using a Present Worth RD: 90/1 1221 RA: 91/4 1242 1254 1260 packaged ozone-UV system with discharge of treated effluent onsite to a storm • I .. sewer. CONCENTRATION 350 ppm .07·.393 PP' 6.4 Pfllll EXCAVATION LEVELS 25 ppm Not Stated 0.065 ppb ESTIMATED VOLUME RATIONALE WHY INCINERATION WAS NOT SELECTED 2,400 Incineration not selected cubic yards because it is not cost-effective and no additional protection would be provided by this treatment. Not St41ted Not Stated 0.-tO· the' ....... itude Of waste Md le» ,ca, concentrations· further-studies .. u l be perforMd to fully characterize soils. Incineration not considered as· alternative for this operable unit. Incineration ... s not discussed as• treataent alternative in the ROD. .. ~ _,:,.. ,,_,'}~.,.. ·{Sd.>C·.::•~,•
> N O'I .,._c,-_..c ... SITE NAME, STATE [ROD SIGN DATE) [LEAD) COMPONENTS OF THE SELECTED REMEDY HGH Brakes, CA (09/29/88) [FE) COSTS RD/RA COMPLETE (CONTINUED) AROCHLORS PRE-TREATMENT CONCENTRATION Excavation of PCB-contaminated soil with offsite disposal of soil; extraction and treatment of wastewater from dewatering process in a mobile treatment system (unspecified) and discharge of treated water either onsite or to a POTU; soil containing> 50 ppm PCBs will be transported to a Class I TSCA·permitted disposal facility; soil containing 10·50 ppm PCBs will be transported to a Class II CA OOHS-permitted facility; demolition of processing building, crushing of the concrete slab and excavation of the underlying soil contaminated with> 10 ppm PCBs followed by transportation and offsite disposal of the contaminated concrete in an appropriate disposal facility. $5,369,300 RD: 90/4 Not 4,500 ppm Present Uorth RA: 91/4 Stated SUBTOTAL 2 REGION 10 COlllllencement Bay-Near Shore/Tide Flats, YA (09/30/89) Source remediation involving control $32,300,000 of effluent sources; PCB-contaminated Total Cost sediment remediation includes natural attenuation and utilization, as appropriate, of four alternatives including in-situ capping, confined aquatic disposal, confined nearshore [RP) RD: 93/4 Not RA: 94/4 Stated Not Stated EXCAVATION LEVELS 10 ppm 1,500 ppm sediment ESTIMATED VOLUME RATIONALE UHY INCINERATION UAS NOT SELECTED 13,510 Incineration was not cubic yards selected because of conmJnity opposition and limited availability of incinerators. 1,181,000 cubic yards Most problem areas are characterized by significant metals contamination, which is not mitigated by incineration. Additionally, marine
> I N -.l SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY disposal, and removal and upland disposal onshore; site use restrictions; and sediment monitoring. Commencement Bay/NTF, UA [12/30/87] [FE] COSTS Excavation and stabilization of PCB $3,400,000 contaminated soils; extraction and Present Uorth stabilization of ponded water and sediments with onsite disposal of treatment residuals and asphalt capping of the entire stabilized matrix. Northwest Transformer, UA [09/15/89] CF l Excavation, consolidation and treatment $771,000 of soils with PCB concentrations Total Cost > 10 ppm using in-situ vitrification; well abandonment; construction of soil cover; and ground water monitoring. Pacific Hide & Fur Recycling, ID [06/28/88] [RP] Excavation of contaminated soil with $1,890,000 solidification of soils; _installation Present Uorth of soil cover over solidified soils with either on-or offsite disposal; onsite containment of contaminated soils if solidification found to be not viable through a pilot study; dl!tontamination of debris with either on-or offsite disposal. (CONTINUED) RD/RA AROCHLORS PRE-TREATMENT COMPLETE CONCENTRATION RD: 91/1 Not RA: 92/1 Stated RD: 91/4 1260 RA: 93/2 RD: 89/4 Not RA: 91/4 Stated 204 ppm 1-10 ppm Not Stated EXCAVATION LEVELS 1 ppm <soil) 2 ppb (ponded water) 10 ppm 25 ppm (restricted) 10 ppm (non-restricted) ESTIMATED VOLUME RATIONALE UHY INCINERATION UAS NOT SELECTED sediments were found to have very low BTU content, making incineration extremely energy intensive and less cost effective considering the volume of contaminated material. 45,000 Incineration not selected cubic yards as a viable alternative through a preliminary feasibilty study due to high cost. 1,200 The thermal destruction cubic yards ion process best for this site was determined to be vitrification based on ease of mobilization, lower cost, lack of residuals, and local acceptance of treatment process. 8,200 Incineration not selected cubic yards as a viable alternative through preliminary screening due to difficulty of iq>lementation. ,.,,,;·,
> N 00 ----·"'="="';='=' ... !":!'!it' . .:,,,, -~:cc . -· -~--...:...::.:=:..;:;;_-:--_______ SITE NAME, STATE [ROD SIGN DATE] [LEAD] COMPONENTS OF THE SELECTED REMEDY Queen City Farms, WA [10/24/85] [FE] Phase separation of sludge with solidification and liquid stabilization. Offsite disposal of contaminated soil. COSTS $3,439,000 Total Cost Western Processing/Phase II, WA [09/25/85] CF l Conduct bench-scale tests using In· $18,100,000 situ solidification/stabilization; If Present Worth successful, conduct pilot studies. SUBTOTAL 6 TOTAL 81 (CONTINUED) RD/RA COMPLETE AROCHLORS PRE-TREATMENT RO: 87 /1 1260 RA: 87/1 RD: 88/4 Not RA: 89/2 Stated CONCENTRATION 125 ppm 1,128 ppm EXCAVATION LEVELS Not Stated 2 ppm, (Offs ite) 50 ppm (Onsite) .s::.. ___ ...__ .• ESTIMATED VOLUME ---RATIONALE WHY INCINERATION WAS NOT SELECTED 5,200 Indneration not selected clbic yards due to cost, limited incinerator capacity and difficulty in transportation. 10,650 clblc yards Incineration not retained as a viable alternative through preliminary screening.
APPENDIX B
DIRECT CONTACT RISK CALCULATION
__ ,, ____________________ _
Risk Calculations for an Individual contacting PCB Contaminated
Soil
Risk are calculated below for an individual in contact with PCB
contaminated soil at three concentrations, 0.1 ppm, 1 ppm, and 10
ppm. The pathways considered are soil ingestion, dermal contact
and inhalation of volatilized PCBs.
Soil Ingestion Scenario
Some of the PCB in the soil is going to volatilize throughout the
years. Therefore, if a more in-depth assessment is required, the
volatilization of PCB needs to be accounted for. The equations
used to account for the volatilization of PCBs from the soil over
certain period of time are derived in Appendix A of the EPA
document titled Development of Advisory Levels for Polychlorinated
Biphenyls (PCBs} Cleanup (U.S. EPA, 1986a}.
Assumptions
Exposure Factor Value Reference or Comment
Child Ingestion
rate (mg/day} 200 U.S. EPA, 1989f
Adult Ingestion
rate (mg/day} 100 U.S. EPA, 1989f
Exposure Duration
for a child (yrs} 6 U.S. EPA, 1989f
Exposure Duration
for an aduld (yrs} 24 (30 -6}
Exposure Frequency
(days/yr} 365 U.S. EPA, 1989f
Body weight
child (kg} 16 U.S. EPA, 1989f
Body weight
adult (kg\ 70 U.S. EPA, 1989f .
Absorption fraction 30% U.S. EPA 1986a
Exposure = C X IR X EF X ED
BW x AT
l
l I
where,
C = concentration of PCB in soil
IR= intake rate
ED= exposure duration
EF = exposure frequency
BW =bodyweight
AT= averaging time (70 yrs for a carcinogen)
To estimate exposure, the average concentration of PCBs in soil
over the exposure period is calculated. The concentration of PCBs
will decrease with time due to volatilization. This concentration
is estimated using the equation A-35 from the 1986 PCB cleanup
guidance for an uncovered surface.
erf _z_ dz
2 t
where,
Cs= average concentration of PCB in soil (ppm)
Cso = initial concentration of PCB in soil (ppm)
z = depth of contamination (cm)
t
= constant defined by ---~ixE [E + PS X (1 -E) X Ka/HJ
= exposure time divided by 4 (sec)
= effective diffusivity (cm2/s) = o. x E1/3
1
Di = molecular diffusivity (cm2/s)
E = pore porosity (unitless)
Ps = bulk density of soil (g/cm3 )
Ka = soil/water partition coefficient (mg/g soil)/(mg/cm3 water)
H = Henry's Law Constant (atm-m3/gmol)
2
Example calculation for the following set of assumptions:
cso = 1 ppm
z = 25.4 cm (10 inches)
Di = 0.05 cm 2/s
E = 0.35
ps = 2.65 g/cm3
Kd = 1000 (mg/g soil)/(mg/cm3 water)
H = 8.37 X 10-3 (atm-m3/gmol)
t = 6 yrs/4 = 1.89 X 108 sec/4 = 4.73 X 107 sec
cs = 1 erf z dz
25.4 21.53
This equation is solved by assuming different values of z and
evaluating the error function using the table attached. Then the
integral is evaluated numerically using the Trapezoidal Rule.
z (cm)
0
5
10
15
20
25
erf(x)
0
0.2550
0.4847
0.6778
0.8116
0.9103
Using the Trapezoidal Rule:
f(x) dx = b -a [f(x0 ) + 2 f(x1 ) + 2 f(x2) + ••• 2 f(xn_1 ) + f(xn)l
2n
cs =(25.4 -0) (0 + 2(.02550) + 2(0.4847) + 2(0.6778) + 2(0.8116)
(25.4) (2) (5)
+ 0.9103]
C5 = 0.54 ppm
The same procedure is used to determine the average concentration
for a period of 30 yrs which yields a concentration of 0.28 ppm
for the adult exposure.
3
I :
I , I
l
i !I I I
' ~ ~~-·. Example calculation for soil ingestion by a child at an initial
concentration of 1.0 ppm
Exposure= _0~·~5~4=---.:m=g"-'x..._=2~0~0--.....::m~g_.x-=-------'3~6~5-=d=a~y~s:........=.x=----6a.-Y-r=-=s--=-=x'-'"1,_ __ x..._--=l'------
kg day yr 16 kg 70 yrs
X yr X 10-6 kg
365 days mg
= 5.8 x 10-7 mg/kg-day
Similarly, the adult exposure is estimated.
Exposure= ~0~·~2~8'----"m~g __ x..._=l~0~0--=m~g.........,x~~3~6=5--=d=a~y~s......_.x.:._,2~4-=-~Y=r=s--=-x"-----'l=---=x'-~l=------
kg day yr 70 kg 70 yrs
X yr X 10-6 kg
365 days mg
= 1.4 x 10-7 mg/kg-day
The total exposure is calculated by adding the child and the adult
exposure.
Total exposure= 7.2 x 10-7 mg/kg-day
Cancer risk is then calculated using a cancer potency factor for
PCBs of 7.7 (mg/kg,day)-l and multiplying by an absorption factor
of 30%. The table below summarizes the total exposure and risk
from soil ingestion (child+ adult) for the three concentration
values.
Soil Concentration
(ppm)
0.1
1.0
10
Dermal Contact Scenario
Total Exposure
(mg/kg-day)
7.2 X 10-8
7.2 X 10-7
7.2 X 10-6
Risk
2 X 10-7 [B2]
2 X 10-G (B2]
2 X 10-5 [B2]
As in the soil ingestion scenario, the concentration of PCB in the
soil is needs to be avjraged over the p•riod of exposure to account
for the volatilizatidn of PCBs. Exposure is estimated for both a
child and an adult. ,A ~hild ages 3 -18 years old wearing shorts
and short sleeve shirt is assumed to be exposed 3 times/week during
the spring .and fall and 5 times/week during the summer months. The
adult is assumed to be wearing long pants and short sleeve shirt
while gardening 1 day/wk during· spring, fall and summer.
4
Assumptions
Exposure Factor Value
Surface area
arms, hands and legs
(a~erage 3 -18 yrs)
(m /event) 0.40
Surface area
arms and 9ands
(adult) m 0.31
Soil to skin
adhere2ce factor
(mg/cm ) 2.77
Exposure frequency
( child) ( events/yr) 132
Exposure frequency
(adult) ( events/yr) 52
Exposure duration
(child) (yr) 15
Exposure duration
(adult) (yr) 12
Body weight (child) (kg) 38
Body weight (adult) (kg) 70
Absorption f:::-action 10%
Exposure= C x SA x AF X EF X ED
BW x AT
where,
SA= surface area (cm2/event)
AF= soil -skin adherence factor
Reference
U.S. EPA, 1989f
U.S. EPA, l989f
U.S. EPA, l989f
U.S. EPA, 1989f
judgement
(18 -3)
(30 -18)
U.S. EPA 1989c
U.S. EPA 1989c
U.S. EPA 1988a
The absorption fraction is based on a study the was conducted by
Versar/Mobil to measure the dermal bioavailability of dioxin (TC~D)
and trichlorobiphenyl (TCB) sorbed to soil. Results of this study
will be incorporated into a draft report titled Dermal Absorption
of Dioxins and PCBs from Soil (U.S. EPA, 1988a) which is being
revised by Versar for the Office of Toxic Substances. In vitro
dermal absorption through human skin resulted in 8% absorption for
TCB in low organic content soil (0.77% organic matter) and 10% in
high organic content soil (19.35%). It is important to understand
5
...,..,
t ,,
l I \ '·
the uncertainties associated with these values. These are based
on only one experiment and the TCB content in the soil was 1000
ppm.
To estimate the exposure through the dermal route, the average
concentration of PCBs in the soil needs to be estimated and
volatilization of PCBs accounted for using the same procedure
described in the soil ingestion scenario. The average
concentration of PCB in the soil after a period of 15 yrs is 0.38
ppm which is used for the child scenario and 0.28 after 30 yrs
which is used for the adult scenario.
Dermal exposure is estimated for a child exposed to soil with an
initial concentration of 1 ppm of PCBs .
Exposure= 0.38 mg X . 40 m2 X 132 events x 2.772mg X
kg event yr cm
X 1 X 1 X yr X 10-6 kg X 104
38 kg 70 yrs 365 days mg
= 8.6 x 10-6 mg/kg-day
In this case, as in the adult calculation event =
exposure for an adult is estimated below.
Exposure= 0.28 mg x 0.31 m2
kg event
x 2.77 ~g x 52 events
cm yr
x 12 yrs x 1 x
15 yrs
c~2
m
day.
70 yrs 70 kg 365 day mg m
= 8.4 x 10-7 mg/kg-day
The
Then risk is estimated by multiplying the total exposure (child+
adult) times the cancer potency factor for PCB and multiplying by
the absorption factor of 10%. The table below summarizes exposure
and risk for the three soil concentrations.
Soil Concentration
(ppm)
0.1
1.0
10
Vapor Inhalation Scenario
Total Exposure
(mg/kg-day)
9.4 X 10-7
9.4 X 10-6
9.4 X 10-4
Risk
7 X 10-7 [B2]
7 X 10-6 [B2]
7 X 10-5 [B2]
Exposure to volatilized PCB is estim~ted for an individual standing
on fite. · Jf risk estimates exceed the cleanup value range of
10--10-, then off-site air concentrations need to be estimated
using dispersion models. In order to use dispersion· models, site
6
specific data such as meteorological data are necessary. on site
air concentrations are estimated by using a "box model" described
in the 1986 PCB guidance document (U.S. EPA, 1986a).
C = Q
Ls XV X H
where,
Q = flux rate (g/sec) Q = Emission rate x Area
Ls= width dimension of contaminated area (m)
V = average wind speed at mixing height (m/s)
H = mixing height (m)
At the mixing height the V = 0.5 x wind speed. A wind speed of 10
mph (4.5 m/s) which is the average in the United states is used.
The flux rate is estimated using the model described in the 1986
PCB guidance document (U.S. EPA, 1986a). It is assumed that the
contaminated soil is uncovered and the depth of contamination is
25 cm.
Emission rates are tabulated below.
Soil Concentration (ppm)
0.1
1.0
10
Emission rates (g/cm2 -s)
9.9 X 10-l5
9.9 X 10-l4
9.9 X lO-l 3
To estimate the concentration in air, a mixing height of 2 m and
a width Ls of 45 mare assumed. These are the values assumed in
the 1986 PCb guidance document (U.S. EPA, 1986a). Air
concentrations are tabulated below.
Soil Concentration (ppm)
0.1
1.0
10
Air Concentration (g/m3 )
9.9 X 10-lO
9.9 X 10-9
9.9 X 10-8
Inhalation exposure is estimated for an adult using the assumptions
listed below.
Exposure Pactor
Adult I~halation
rate (m /day)
Exposure Duration
(yrs)
Body weight
Assumptions
Value Reference
30 U.S. EPA, 1989f
30 U.S. EPA, 1989f
7
......
i.
1
adult (kg) :
Absorption fraction
70
50%
Exposure= 9,9 X 10-lO g X 30 m3
X 103 mg
g
day
-1.8 x 10-1 mg/kg-day
X
U.S. EPA, 1989f
U.S. EPA 1986a
30 yrs X 1 X
70 kg
1
70 yrs
Exposure and risks are tabulated below for the three concentration
values.
Soil Concentration (ppm) Exposure Risk
(mg/kg-day)
0.1 1.7 X 10-7 7 X 10-7 [B2]
1.0 1. 7 X 10-6 7 X 10-6 [B2]
10 l.7x 10-5 7 X 10-5 [B2]
8
Uncertainties
Sources of uncertainty include measured values that may not
be accurate or representative, use of mathematical models which
may not reflect the physical or chemical process actually occurring
and assumptions on the selection of parameters in the mod~ls.
The analysis conducted used the physical and chemical
properties of Aroclor 1254 to estimate air emission rates because
this will yield the most conservative estim~te. On the other hand,
the Agency derived a Cancer Potency Factor for Aroclor 1260, which
is the most toxic of the Aroclor~ and uses it tQ be representative
of other PCB mixtures. However,1imission rate results may not be
affected significantly since tnese two Aroclors have similar
physical and chemical properties ::
Human behavior patterns can strongly affect exposure results.
Based on the limitations of our knowiedge, the values for the
exposure duration and frequency for the pathways considered are
intended to be best reasonable upperbound estimates. For example,
the vapor inhalatio~ scenario · assumes that a person will be
breathing at a 30 m /day rate 24 hours/day for a period of 39
years. It also assumes that the concentration indoors will be the
same as the concentration outdoors. These assumptions are
considered reasonable since it is possible to observe certain
subpopulations (i.e., housewife} spending the majority of their
time at their residence without air conditioning.
In the soil ingestion scenario, the exposure values obtained
do not account for children with pica behavior. Exposure estimates
that will reflect this type of behavior will be considerably
higher.
The rate of air emission through volatilization was calculated
using the model developed in the 1986 PCB guidance (U.S. EPA,
1986a}. The model is based on theoretical mass-balance equations
to account for fundamental physical/chemical transport processes.
No empirical data are available to validate the model. Values of
the parameters that are input into the model are based on soil
characteristics such as E and Ps, physical laws such as Di, or
determined empirically such as Kd. The latter is one of the major
sources of uncertainty. The Kd depends not only on the chemical
but also in the soil characteristics (i.e., organic carbon
content) •.. ,.:,A Kd based on highly adsorbable soil was used which will
result in a higher emission rate than if a less adsorbable S'Oil
such as sandy soils is used.
There are also uncertainties with the values used for
absorption factors. For example, the absorbtion factor of 10% used
in the dermal exposure scenario is based on very limited data.
This assumption was based on one study which used a concentration
of tetrachlorobiphenyl of 1000 ppm in the soil. It is likely that
the absolute dermal absorption at lower concentrations in the soil
will tend to be less.
APPENDIX C
DETERMINING APPROPRIATE LONG-TERM MANAGEMENT CONTROLS
DETAILED CALCULATIONS FOR CASE STUDY
: ,
Introduction
To illustrate the process of determining the appropriate
long-term management controls for low-threat PCB contamination
that will remain at a site, an example analysis is provided.
Several source concentrations are evaluated.
The evaluation presented in this Appendix concentrates on
ensuring that PCBs remaining will not adversely affect the quality
of the ground water. Where concentrations remaining on site are
higher than levels determined to be safe for direct contact,
measures to prevent or limit access to the contaminated areas
should be instituted. For concentrations within an order of
magnitude of the health-based level, a soil or cement cover with a
deed notice may be sufficient. Higher concentrations will require
fencing and management of the cover over time.
The process used in this assessment involved two primary
steps:
1. Evaluation of potential cap designs and their impact
on infiltration through the contaminated zone.
2. Evaluation of the migration of PCBs to and into the
ground water.
Once this was completed the concentrations of PCBs in the ground
water was compared to the drinking water standard, .5 ppb, to
identify the cap which prevented infiltration to the extent
necessary to prevent degradation of the ground water.
This first section of this appendix provides a description of
the site including the values of parameters necessary for the
evaluation of PCB migration. Next the cap designs considered are
presented with the description of the analysis of the infiltration
expected. Finally, the model which estimates PCB migration to
ground water is described and the resulting ground water
concentrations for the various scenarios considered is presented.
Description of Site and Variations
The description of the site focusses on the factors that
would affect the migration of PCBs and consequently indicate a
need for a different level of control. These include:
o Size of PCB source area --area and depth
o Concentration of PCBs
o PCB biodegradation rate
1
Ii'. r •
: Ii I l ! ,t '! 1-I· l, :
, i
,I
''
,,
l'
1 l
'
i ,,
' '
,,
,q 1~
I'
I.
I
o Depth to ground water and thickness of saturated zone of
interest
o Flow of ground water
o Rate of infiltration through the contaminated zone
o Soil porosity
o Organic carbon content of soil
o Bulk density of soil
The values of these factors used in the scenario evaluated in this
example are discussed below.
Size of Site The site evaluated in this analysis covers 5 acres
and the contamination is assumed to extend 10 feet vertically.
Concentration of PCBs PCB concentrations are assumed to be the
same throughout the contaminated zone. Concentrations of 5, 20,
50 and 100 ppm were evaluated to provide examples where long t~rm
management controls short of the minimum technology requirements
under RCRA and the chemical waste landfill requirements under TSCA
can usually be justified. (As shown in Table 3-4, in the unusual
case where PCBs at concentrations exceeding 500 ppm are left on
site, minimum technology requirements are generally warranted.)
PCB Biodegradation Rate Since the model evaluates PCB migration
over very long time frames (up to 10,000 years) it seemed
appropriate to incorporate some estimate of PCB biodegradation.
Several studies have documented highly variable PCB biodegradation
rates (Quensen, 1988; Bedard, 1986; Brown, 1987). A half life of
50 years was assumed in this analysis.
Depth to Ground Water/Thickness of Saturated Zone The ground
water table is encountered at 20 feet below the surface. A
saturated thickness of 5 feet was assumed since this represents a
conservative minimum screened interval for a well.
Flow of Ground Water The ground water is flowing at 310 feet per
year. This is a typical flow for a sand and gravel aquifer and
would be sufficient to provide 150 gallons per day with a 60-foot
wide capture zone from a well screened over the first five feet.
This is the minimum amount of water assumed to be used by a family
of four. This reflects a very conservative scenario since few
wells are screened through a thickness of only 5 feet. In most
cases, wider intervals would be screend and greater dilution of
PCBs would occur.
Rate of Infiltration Through the Saturated Zone The infiltration
values used in this analysis were developed using the Hydrologic
2
Evaluation of Landfill Performance (HELP); version II, computer
program (U.S. EPA, 1984). This program was used to estimate
runoff, evapotranspiration, and infiltration rates through the four
cap designs considered. Climatic conditions of the City of
Seattle, Washington, were used to model rainfall, temperature, and
other daily climatological data. Seattle was picked after
preliminary estimates showed that the combination of climatic
conditions in that city was one of the most extreme of all U.S.
climates and would therefore represent a conservative scenario. A
more detailed description of the use of the HELP model is presented
below.
Soil Porosity The porosity of the soil was assumed to be 25%
which corresponds to a mixed sand and gravel (Fetter, 1980).
Organic Carbon Content of Soil The first
assumed to have an organic content of 5%.
was assumed to have an organic content of
content of the soil in the saturated zone
This is a farely typical range.
10 feet of soil was
The 10 feet below that
.5%. The organic
was assumed to be .1%.
Bulk Density of Soil A bulk density of 1. 97 g/ml was used base.d
on the porosity of .25 and the density of quartz, 2.63 g/ml.
Cap Designs/Infiltration Evaluation
Four different cover systems were considered. These are
shown in Figure C-1. As indicated cover system 1 is simply a 12
inch soil cap, cover system 4 reflects the RCRA cover design
guidance (U.S. EPA, 1989d), and cover systems 2 and 3 reflect
intermediate cover systems. Given the fact that climatological
conditions are the same for all alternatives and that soil
properties do not change, the only variables are the number of
layers, their type, and their thicknesses. Brief descriptions of
the physical properties of each layer used in the design models
are presented below:
Vegetative soil layer This layer consists of sand~ loam. The
permeability of this soil is approximately 1 X 10-cm/sec. This
permeability is considered moderate-to-high when compared to other
soils.
Sand drainage layer This layer consists of clean, coarse sand.
The permeability of this sand is approximately 1 X 10-2 cm/sec.
This sand is considered a highly permeable soil.
Synthetic drainage layer (geonet) This layer is typically made of
two high density polyethylene (HOPE) strands bonded together in a
crossing pattern. Geonets are called geocomposites when they are
sandwiched between two layers of geotextile fabric. Geonets and
geocomposites are typically characterized by their
transmissivities. The transmissivity of a layer equals the
3
i'
l ;-) ' q I. 'J'.
·1
l:•,i
I 1:
I
' t l
\ 1·1 • r
1:1· t I
i .
,I
i
r'. ,!
I ,
,\ I
11 ' I 1
:\,
DESIGN
DESIGN 2
DESIGN 3
PESIQN4
LandnII •
Design
(Minimum
Technology)
Figure C-1
Cap Design Details
..,_--Vegetation
'/////////
,..-12" Soil Top Layer
,._____ Waste ______,,
,,...--Vegetation
:z,...z'iilz!z!:,,✓,!z!z..,z■.~:::::::_11(~ _-_-_-_--3:.5:_%'"" _-_-_-_-_:.•1/.!z.,,.z11z!z!z,...z1z~.,, .._ 12 .. Soil Top Layer
~ Vegetation
'////////,
~ 24" Soil Top Layer
~""-1 -14 "',.. ,.._,,.. FML 20 mil•· K=lxlO crn/sec
... ,...,,,,... ...... 'P" •• ...-. -------....,., .,., ... , ... ,...,,,....., "Iii:;. r C 5o· K 3 7 0-4cm/ -:;:::::;::;::;.": ·-:;.}~~}~:.."" .. ;.-:· · '12" over il--= . x 1 sec ...............
~ Waste ~
~ Vegetation
1/~/.fiiiZ■1/✓-■z■zl:,,/lijiii;----...-___ 3_-5_% __ •iilzliz■:,,✓-■z■zl:,,✓,j,"",, 24" Soil Top Layer
...---2 _______________ 'k"" 12" Sand --K=lxlO cm/sec
...-2 % ,=,=,=,=,=:e,=,,,,,,,=,=,: ~ FML 20 mil 1--K=lxlO 14cm/sec .. ~~1!1!1!~~!1!!111~~-.-------■~~ll!ll~!l!~ll!II, ~ .7
...------24" Clay --K=lxlO cm/sec ~.....,,...,,.-.,-----------~-------~ ~ ~ 12" Cover Soil--K=3.7x10-4cm/sec
~/ ~
.......___ Original Subgrade __..__;,
• RCRA Minimum Technology Landfill bottom liner design for remedial actioru requiring RCRA landfill consuuc:tion.
C-4
permeability of that layer multiplied by its thickness.
Therefore, the permeability of a geonet can be calculated by
dividin2 its transmissivity by its thickness. A transmissivity of
5 X 10-m2/sec is assumed for a 1/4-inch-thick geonet,
corresponding to a permeability of 7.8 cm/sec. This permeability
is considered extremely high when compared to permeabilities of
soil classes.
Compacted clay barrier layer This layer consists of mechanically
compacted clay. The permeability of this layer is approximately 1
X 10-7 cm/sec. This clay is considered a highly impermeable soil.
Synthetic barrier layer This layer consists of a flexible
synthetic membrane (FML). Typically, FMLs are considered
impermeable. Thus, their effectiveness is measured by estimating
the number and size of holes or defects that would be expected
from manufacturing or installation operations. It is believed,
for the purposes of comparison, that the permeability of this
layer is approximately equivalent to 1 X 10-14 cm/sec. This
permeability is considerably lower than the permeabilities of soil
classes. However, in the HELP-II model this layer is considered
impermeable and a leakage fraction, corresponding to the number and
sizes of holes, is used to estimate the inflow rate through th~
layer.
Cover soil layer This layer consists of firm sandy clay loam.
Its permeability is approximately 1 X 10-4 cm/sec. This
permeability is considered moderate, when compared to
permeabilities of other soils.
The Hydrologic Evaluation of Landfill Performance (HELP);
version II, computer program (U.S. EPA, 1984) is a quasi-two-
dimensional hydrologic model of water movement that was developed
by the U.S. Army Corps of Engineers Waterways Experiment Station
in Vicksburg, Mississippi, for the EPA Hazardous Waste Engineering
Research Laboratory, Cincinnati, Ohio. Help-II models water
movement across, into, through, and out of landfills. It uses
climatological, soil, and landfill design data. The model accounts
for the effects of runoff, surface storage, evapotranspiration,
soil moisture storage, lateral drainage, hydraulic head on barrier
layers, infiltration through covers, and percolation from liners.
The model does not account for lateral inflow of ground water or
surface water runon, nor does it account for surface slopes of the
cover for runoff. The program reports peak daily, average monthly,
and average annuual water budgets. The HELP-II model, which is
currently being recommended by EPA for estimating infiltration
through cover systems, has readily available climatological data
for 102 U.S. cities, including Seattle, Washington. The
climatological data consists of daily precipitation values from
1974 through 1978. Other daily climatological data are
stochastically generated using a model developed by the
Agricultural Research Service
5
' : ' '
(Richard~on, 1984).
The soil and cover design data are entered either manually or
by selecting default soil characteristics. Each landfill was
assumed to have the following design characteristics:
1. SCS RCN, 69; this value corresponds to a runoff curve
number, under average antecedent moisture conditions, for
a fairly grassed soil that has a moderate infiltration
rate.
2. Drainage media slope, 2 percent; this value represents the
minimum cover slope allowed by RCRA minimum technology
guidance; it has very little effect on the HELP model when
under 20 percent.
3. Drainage length (spacing between collectors), 500 feet;
this value was selected because RCRA does not require
collection pipes in the cover system and therefore, it is
unlikely to find any collectors on the cover.
Table C-1 summarizes the pertinent values for the four cap designs
considered in this analysis. The infiltration value indicated 'is
the value used for the infiltration entering the contaminated zone
in the calculation of PCB migration to the water table.
PCB Migration To Ground Water
The PCB attenuation analysis was performed using EPA's one-
dimensional unsaturated zone finite-element flow and transport:
module, VADOFT (U.S. EPA, 1989g), coupled to the analytical
solute/heat transport AT123D (Yeh, 1981). The finite-element
module was used to evaluate vertical PCB transport in the
unsaturated zone and to generate time varying mass flux rates at
the water table which were used as input to AT123D which was used
to simulate mass transport in the saturated zone (Figure C-2).
AT123D was used to determine a time series of depth averaged
concentrations beneath the PCB source. The results were then time
averaged over the seventy-year period representing the years of
peak concentrations occurring within a 10,000-year period.
VADOFT is a one-dimensional, non-linear, finite-element code
used to evaluate variably saturated groundwater flow and solute
transport. Solute transport in the unsaturated zone is described
by the following governing equation:
OvSwRv(dC/dt) = Dy(d2C/dZ2 ) -Vy(dC/dZ) -vOvSwRvC (1)
where: Oy = the effective porosity
Sw = the saturation
Vv = the vertical Darcy velocity
V = the decay coefficient
6
Table C-1
COVER DESIGN SUMMARY TABLE (ANNUAL VALUES)
Infiltration
Cover Site Area Precip. Runoff Evapotrans. (Cu. Ft.)/
Design (Acres) (Cu.Ft.) (Cu. Ft.) (Cu. Ft.) Acre
1 2 258,877 3,349 113,134 71,467
2 2 285,877 78,164 114,628 33,529
3 2 258,877 127,318 131,170 226
4 2 285,877 94,262 118,162 1
C-7
z :;: Q 5 ~ 'Tl -C') C: ;::c, tTl r,, N tTl <: > r-' C: > -3 -0 z > ;::c, tTl > en .,, 0 ;::c, <: > ·O ·o ~ > z 0 > -3 -N v.) 0 " 8-Q ◄ 11 ◄ 4 : ~ N I ~ s . a·• .• ·•:.·.-·:.·.-T-')),~~~,, '-,," .... , , ~ ~, ~ ~,, -, I ::, Q) -(D Q. N 0 ::, (D ◄ ◄ i!ll .;fE 11: l . ·11. ', : ~ l ! j '\'. q I, 'ii) ;_, I. \I ;!I
R~ = 1 + ((KdPb)/(ovSw) = the retardation coefficient (2)
l<d_ = the adsorption coefficient
and
Pb= the bulk density of the soil
For transport simulations using a steady-state flow field and
where there is no decay, or the decay rate is not a function of
the saturation, the nonlinear flow analysis may be avoided for
highly adsorptive chemicals. For chemicals with large adsorption
coefficients (e.g., greater than 10) such as PCB's:
( 3)
and the saturation terms in Equations (1) and (2) cancel and can
be disregarded. This circumvents the need for the nonlinear flow
analysis and allows the transport analysis to be performed using a
default Darcy velocity equal to the infiltration rate. Transient
finite-element solute transport analyses were performed for the
period of interest to generate time series of mass flux rates that
were used as a boundary condition for AT123D.
AT123D, an analytical method based on Green's function
techniques, simulates three-dimensional advective/dispersive
transport in porous media. The three-dimensional solute transport
equation on which AT123D is based can be written as:
Dx(d2C/dx2 ) + Dy(d2C/dy2) + Dz(d2C/dz2 ) -Vs(dC/dx) =
Rs(dC/dt) + Rs sC + ((qC)/(Bos)) + M/os ( 4)
where: x, y' z
C
= spatial coordinates in the longitudinal,
lateral and vertical directions, respectively
= dissolved concentration of chemical
Dx, Dy, Dz = dispersion coefficients in the x, y, and z
directions, respectively
q
B
M
s
= one-dimensional, uniform seepage velocity in
the x direction
= retardation factor in the saturated zone
= elapsed time = effective first-order decay coefficient in the
saturated zone = net recharge outside the facility percolating
directly into and diluting the contaminant
plume = the thickness of the saturated zone = the constant or time dependent mass flux ra'ne
By taking the products of various directionally independent
spatially integrated Greens functions the model allows for the
application of linear, planar and volumetric mass flux sources to
a porous medium which is of infinite extent in the flow direction
and can be considered to be of either infinite or finite extent in
9
I,
I
[·
I l
the dire~tions perpendicular to flow. Temporally, the Greens
functions represent instantaneous sources which are numerically
integrated with respect to time to allow for a constant mass flux
or a time variant mass flux source condition. The general
solution can be written as follows:
C(s,y,z,t) = (5)
where: t = time of interest = variable of integration
The term Fijk is the product of the three-directionally-
independent Greens functions (Yeh, 1981). since the source term
is a mass flux rate, a decay term accounting for dilution due to
infiltration of water was utilized. This dilution factor is shown
in the second to last term of Equation (4). For these simulations
the source was approximated as a fully penetrating rectangular
prismatic source with a surface area equal to the source area. The
fully penetrating source was used to circumvent the need to depth
average values of the concentrations.
· RESULTS
The results of the analysis described above are summarized in
table C-2. PCB concentrations in ground water were estimated for
each of the four cap designs and four different PCB source
concentrations. Based on this analysis, the following
recommendations for caps could be made:
5 ppm PCBs Source At this concentration the threat of PCB
migration to ground water at concentrations that would exceed the
proposed MCL of .5 ppb under the given site conditions is
unlikely. The maximum concentration averaged over 70 years
(occuring after 945 years) is .099 ppb with only a soil cap. The
soil cover would be recommended for sites in residential areas to.
prevent contact with concentrations above 1 ppm, the starting
point action level.
20 ppm PCBs Source Again, the analysis indicates that the threat
to ground water is not significant. With only a soil cap, the
maximum concentration expected is .4 ppb. For sites in
residential areas, a cement cover and a deed notice may be
warranted to prevent contact with PCBs exceeding the 1 ppm
starting point action level.
50 ppm PCBs Source At 50 ppm, PCB concentrations in the ground
water are projected to exceed the .5 ppb level slightly --
approximately 1 ppb. At this concentration, for the site
.conditions presented, the second cap illustrated in Figure C-1
would be recommended. The combination of a low-permeability cover
10
? ~ ~ Tal,le c.z SATIJRATED ZONE DEPTH AND TIME AVERAGED CONCENTRATIONS BF.NEATH THE SOURCE (PPII) AND TIME OF PEAK CONCENTRATION (YF.ARS) Sell Contt11lnllon 5 ffm C■p c .. , C■p On .... Dntan O..lpl I z l .099 .029 0.0 Source Arc1--S Acres Avcn1,e Rcgion•I ~low 310 r1~r l'nm•i1y of Soil--0.2S llulk l>cnsily of Soil--1.97 g/ml C■p O..lpl .. 0.0 Timc--Pc•k 70 years rrom 0-10,000 years Con11min11cd zone orsanlc con1cn1--S.0% Clean unuturalcd zone organic conlcn1--0.S% S.1ura1cd wnc organic 0001cn1--0.I% PCR h•lr-li!c--SO years Ocpth of Cont•minalion••IO rec1 OtJ>lh 10 Omun<1w111cr--20 !ttt 'lbickncu o( S.luralcd Zonc:--S reel Soll Conttntrallon ze ppm c., C■p C■p c .. , o....., Dnlan o....., 0...,. I 1 l .. .396 .116 0.0 0.0 SITE PARAMETF.RS Soll Coll<flllrallon 541 ppm Soll COllffnlral .... 100 ppm C■p c .. , C■p C■p C■p C■p C■p C■p C■p 0..lpl l>Hlp 0...,. Dnlp Dnlp l>Hlp 0...lp 0..lpl 0..lpl I z l .. I z l .. I .990 .290 0.0 0.0 1.98 .S80 0.0 0.0 94S Tp ... (YHnl C■p C■p C■p l>Hljin Dnlgn Dnlan z l .. l64S .. ..
'I
soil and the soil cap will prevent PCBs from migrating to t he
ground water at levels that exceed .5 ppb. With the reduce
infiltration the maximum PCB concentration projected for the
ground water (occurring after 1645 years) is .3 ppb. Again, a
deed notice would be warranted to prevent direct contact wi th the
soil in the future. Consistent with Table 4-2, a fence and some
ground water monitoring (annual) would be recommended.
100 ppm PCBs Source At 100 ppm, PCB concentrations in the ground
water are projected to exceed the .5 ppb level slightly --
approximately .6 ppb, even with the addition of a low-
permeability cover soil. At this concentration, for the site
conditions presented, the third cap illustrated in Figure C-1
would be recommended. The addition of a flexible membrane liner
reduces infiltration sufficiently to prevent migration of PCBs to
the ground water. Consistent with Table 4-2, a deed notice,
fence, and periodic ground water monitoring would also be
recommended.
12
APPENDIX D
CASE STUDIES
PEPPER STEEL, FL AND WIDE BEACH, NY
SITE ~AME: Pepper's Steel and Alloys, Florida.
SITE DESCRIPTION: Tr~ ,iti> tv'r 11nii>-: ~n-acres in Medley, Fl0rida. approximately 10 miles
northwest of Miami overlying the Biscayn~ Aquifer. This aquifer is used as a sole source drinking
water supply for a large population. This location has been the site of a variety of businesses
including the manufacture of batteries and fiberglass boats, repair of trucks and heavy equipment
and an automobile scrap operation. Batteries, underground storage tanks, transformers, discarded
oil tanks and other miscellaneous debris have accumulated as a result of disposal from past and
present operations at the site. Contaminants have been identified within the soil, sediments and
ground water.
WASTE DESCRlPTION: The contaminants of concern are polychlorinated biphenyls (PCBs),
organic compounds and metals such as lead, arsenic, cadmium, chromium, copper, manganese,
mercury, zinc and antimony. The quantities and concentrations of the primary contaminants are:
• PCBs -48,000 cubic yards of soil at 1.4 ppm to 760 ppm,
12,000 gallons of free oils with concentrations up to 2,700 ppm;
• Lead -21,500 cubic yards of soil at 1, l 00 ppm to 98,000 ppm;
Arsenic -9,000 cubic yards of soil at concentrations greater than 5 ppm.
;
PAJ}{WA YS OF CONCERN: Of significant concern is ground water transpon of PCBs and lead'
to private wells and lead intake due to ingestion from direct contact with local soils. Air particulate
matter containing PCBs provides a possible inhalation exposure pathway to onsite workers and
offsite to neighboring residents.
TREATMENT TECHNOLOGY SELECTED: The recommended remedial alternative involves the
excavation of PCB contaminated soils> l ppm and solidifying with a cement-based material
followed by onsite placement. Soils contaminated with> 100 ppm lead or> 5 ppm arsenic will be
excavated and chemically fixed (stabilized), thus reducing dissolution and diffusion rates. Free
oils contaminated with PCBs will be treated offsite at a Toxics Substances Control Act (TSCA)
approved incinerator. The off site disposal of the free oil is cost-effective, implementable and
satisfied the disposal requirements of TSCA Part 761.60(a). The solidified mass will be replaced
onsite approximately 4-5 feet above ground water level.
EQUIVALENT TREATMENT: TSCA regulation 761.60(a)(4) requires that soils containing
PCBs at concentrations greater than 50 ppm be destroyed by incineration or disposed in a chemical
waste landfill. TSCA 761.60(e) provides for the approval of alternative methods of disposal
which achieve a level of performance equivalent to incineration and protective of human health and
the environment. The TSCA Spill Cleanup Policy (Part 761.120) covers spills which occurred
since May 4, 1987. Spills which occurred before that date are to be decontaminated to
requirements established at the discretion of EPA, usually through its regional offices. TSCA
regulation 761.123 defines the relationship of the PCB Spill Cleanup Policy to other statutes. The
Policy does not affect cleanup standards or requirements for the reporting of spills imposed, or fo
be imposed under other Federal statutory authorities including CERCLA. Where more than one
requirement applies, the stricter standard must be met. PCB spills at Pepper's Steel took place
during a period between 1960 through the early 1980's, therefore the PCB Spill Cleanup Policy is
not applicable to this situation.
D-1
'I
I l' I;
.i
I
Incineration was deemed u~acceptable due to high metal content in the contaminated soils. The
volatilization of the metals would result in significant air discharges even with the implementation
of air conrrol mechanisms OR the incinerator. Dependi'1g ('!'"! •~~ ~;r Mn1:al method used, srri~~ber
waters or bag house filters contaminated with metals, 2.r.d .netals in th~ incinerated ash, would
require appropriate disposal. Off site disposal in a chemical waste landfill was eliminated as an
option due to high cost, inhalation risks and concerns of off site transponation of the material.
The selected remedial action addresses direct contact risk reduction by rendering the PCB matrix
immobile through chemical fixation. In addition, the solidified mass will be covered with a 12-
inch layer of crushed limestone to fwther eliminate these threats. Since PCB contaminated soil
with concentrations> 1 ppm will be solidified, the action is consistent with the TSCA PCB Spill
Cleanup Policy (761.125) which recommends a 10 ppm cleanup level for a site with nonrestricted
access.
Of chief concern with the fixation method is the long term integrity of the fixed mass related to near
surface ground water or infiltrating rainwater which may contribute to migration of the
contaminants. To assess risk of injury to health or the environment, the EPA performed rreatabiliry
studies on the solid mix to define performance standards. The tests performed to verify the
integrity of the solidified matrix were Toxic Characteristic Leaching Procedure (TCLP), Extraction
Procedure (EP) Toxicity, ANS 16-1 and a modified MCC-11. Fate and modeling (method not
provided) were used to establish ground water action levels to monitor for failure of the
technology. This remedial action warrants the submission of a waiver under 40 CFR 761.75(a)(4).
for chemical waste landfills. Under this regulation the EPA Adminisrrator may waive cenain
landfill requirements if it is determined that the landfill does not present an unreasonable risk of
injury or adverse effects to health or the environment. This alternative satisfactorily addresses
specific concerns in TSCA chemical waste landfill requirements by providing leachate collection,
monitoring wells and a liner or fill to maintain the solidified mass above the ground water table.
Parameters for the rreatability studies were set using the Water Quality Criteria Standard of 0.079
ng/1 PCBs in water for PCBs at the propeny line several hundred feet from the solidified mass.
Using ground water modeling, a level of 7 ppb PCB in leachate from the solidified mass was
established as the maximum allowable concentration which would yield an acceptable risk at the
receptor. Results from the treatability studies all indicated concentrations of PCBs in leachate of
less than the detectable limit of 1 ppb.
This remedial action can be viewed to be consistent with two areas of TSCA PCB disposal
policies. The solidification of the waste and leachate monitoring provide additional protective
measures than are required in the chemical waste landfill regulations. The action also achieves a
level of performance equivalent to incineration. Analysis of leachate from the solidified mass
shows no PCBs at a detection limit of 1 ppb, which suppons the conclusion that the mobility of
PCBs into the surrounding environment is essentially destroyed.
D-2
SITE :--.rAME: Wide Beach, i\'Y
SJ.IF DF.SCRIPTION: The Wide Beach Development site is located in a small lake'.'.i~e ~~~~~•n_;~,
in Brant, New York, approximately 48 km south of Buffalo. The Development cover:, 22
hectares, 16 of which are developed for residential use. The site is bordered on the west by Lake
Erie, on the south by wetlands and on the east and nonh by residential and agricultural propeny.
Between 1968 and 1987, 155 cubic meters (approximately 744 barrels) of waste oil, some
containing polychlorinated biphenyls (PCBs), was applied to roadways for dust control by the
Wide Beach Homeowners Association. In 1980, the installation of a sewer line resulted in
excavation of highly contaminated soils and SUIJ)lus soil was then used to fill in several yards and a
nearby grove of trees.
The Erie County Department of Environmental Planning investigated a complaint in 1981 of cx:iors
coming from nearby woods. They discovered 19 drums in the woods and two contained PCB-
contaminated waste oil. Alened to a potential problem subsequent investigatory sampling revealed
the presence of PCBs in dust, soil, vacuum cleaner dust, and water samples from private wells.
In 1985 the EPA perfom,ed an action to protect the public from the immediate concern until
implementation of a long-tern, measure. The action involved the paving of roadways and drainage
ditches, decontamination of homes by rug shampooing, vacuuming, and replacement of air
conditioner and furnace filters and protection of individual private wells by installation of
paniculate filters.
WASTE DESCRIPTION: The primary containment at the Wide Beach site is PCBs, found over
the majority of the site in all environmental media. The most significant contaminations were
found in the sewer trench wells, soils adjacent to the roadways and wetlands sediments.
Maximum PCB concentrations from the following areas were:
• drainage ditch samples -1,026 ppm;
• yards and open lot samples -600 ppm;
• unpaved driveway samples -390 ppm;
• roadway samples -226 ppm;
• sediment samples from marsh area -126 ppm
The concentration of PCBs in one catch basin sample was 5,300 ppm. Investigations revealed that
one of eight monitoring wells, and all six sewer trench wells were contaminated with PCBs.
Drinking water sampling studies discovered PCB contamination in 21 of 60 residential wells,
however, the level of contamination was low ranging from 0.06 ug/l to 4.56 ug/1.
PATHWAYS OF CONCERN: The primary pathway of concern is through the ingestion of PCB
contaminated soils. Additional potential concerns involve the environmental impact of
contamination on the surrounding marshlands.
TREATMENT TECHNOLOGY SELECTED: The recommended remedial alternative involves the
excavation of contaminated soils > 10 ppm PCBs, onsite chemical treatment to destroy PCBs and
soil residual replacement. The recommended treatment will involve removing 5,600 cubic meters
of soil from the roadway, 8,500 cubic meters from drainage ditches, 1,500 cubic meters from
unpaved driveways and 13,000 cubic meters from back and front yards. The chemical treatment
for the 28,600 cubic yards of contaminated soil consists of a two step procedure. First, PCB
molecules are extracted from the soils using solvents. The solvents are then treated with Potassium
Polyethylene Glycol (KPEG), to remove chlorine atoms from the PCB molecule. This slurry is
then pumped to a jacketed, internally agitated, batch reactor where the mixture is maintained at a
soil moisture content of 2-3 percent for two hours at a temperature of 140 degrees Celsius while
D-3
1· r
the dechlorinatio~ reaction takes place. Th is stage is followed by several water washes, and solids
separation. The soils will be replaced onsite after the PCB contaminated marrix is treated to 2 ppm.
EQUIVALENT TR~AIMENT TSCA regulation 761.60(a)(4) requires that soils containing
PCBs at concentrations greater than 50 ppm be destroyed by incineration or disposed in a chemical
waste landfill. TSCA 761.60(e) provides for the approval of alternative methods of disposal
which achieve a level of performance equivalent to incineration and are protective of human health
and the environment. Incineration was rejected as a remedial alternative option during the remedial
investigation and was not documented in the Record of Decision. Off site landfilling of the PCB
soils was rejected due to concerns of excessive cost, dust release during excavation and possible
exposure risks during transport.
Primary concerns with this treannent technology include the ability to attain the 10 ppm level for
soil decontamination, and the potential formation of toxic end products through use of the reaction
vessel. To address these concerns pilot plant treatability studies were performed to assess the
effectiveness of potassium polyethylene glycol in dechlorinating the PCBs, and to determine
important design parameters for the reaction vessel such as physical dimensions, operation
temperatures and detention time. The results from one run revealed a reduction from 260 ppm in
soil to under 2 ppm in the treated residual. Runs were performed on soil at 80 ppm PCBs which is
the average concentration at the site. The results indicated that the 10 ppm PCB levels could be
achieved consistently. Lab tests in the bench scale treatability study revealed no mutagenic effects
with the soil , indicating that the residuals are non-toxic. The results of both KPEG bench scale
and pilot plant treatability studies showed that PCB concentrations or 10 ppm or lower can be
achieved successfully without hazardous end products, which eliminates the primary concerns with
this treatment.
The 2 ppm cleanup level was derived by Best Demonstrated Available Technology (BDA T) values,
TSCA policy, and health-based criteria identified in the risk assessment. The TSCA policy for
evaluating whether treatment is equivalent to incineration (TSCA 761.60(e)) defines successful
equivalent treatment by the level of PCBs in the treatment residual. A concentration of 2 ppm is
considered to indicate the treatment has achieved a level of performance equivalent to incineration.
The selected treatment destroys PCBs in contaminated soils therefore eliminating the potential risk
identified in the risk assessment (i.e., direct contact threats). KPEG also provides protection
through permanent and significant reduction of toxicity, mobility and volume of the waste, and
complies with all relevant and appropriate requirements set forth in TSCA. Since this method has
achieved a level of performance equivalent to incineration through pilot studies and it has been
shown to be protective of human health and the environment, it is an acceptable alternative to
incineration.
D-4
APPENDIX E
PCB DISPOSAL COMPANIES, COMMERCIALLY PERMITTED
; ,
PCB DISPOSAL COMPANIES
COMMERCIALLY PERMITTED
NOV29m3
* Permitted to operate in all ten EPA Regions
COMPANY
INCINERATOR
ENSCO
ENSCO
General Electric
Pyrochem/Aptus
Rollins
SCA Chemical
Services
U.S. Department
of Energy/
Martin Marietta
Energy Systems
WESTON
ALTERNATE TiiEBMN:
Ecova Corporation
Ogden Environmental
services·, Inc.
(formerly GA
Technologies, Inc.)
J.M. HUber
corporation
,O.H. Materials
Corporation
ADDRESS
P.O. Box 1957
El Dorado, AR 71730
P.O. Box 8513
Little Rock, AR 72215-8513
100 Woodlawn Ave.
Pittsfield, MA 01201
P.O. Box 907
Coffeyville, KS
P.O. Box 609
Deer Park, TX 77536
PHONE No.
501-223-4160
501-223-4100 *
413-494-3729
3 16 -2 5 l -6. 3 8 0
7 l 3 -4 7 9-6 0,0 l
11700 South Stony Island Ave. 312-646-5700
Ct.icago, IL 60617
Federal Office Building
Room G-108
P.O. Box E
Oak Ridge, TN 37830
One Weston Way
West Chester, PA 19380
12790 Merit Drive
Suite 220, Lock Box 145
Dallas, Texas 75251
P.O. Box 85178
San Diego, CA 92138-5178
P.O. Box 2831
Borger, TX 79007
16406 u.s. Route 224 East
P.O. Box 551
Findlay, Ohio 45839-0551
615-576-0973
215-692-3030 *
214-404-7540 *
800-876-4336 *
or
619-455-3,045
806-274-6331
800-537-9540 *
CHEMICAL
American Mobile Ofl
Purification Co.
Chemical Waste
Management
Exceltech, Inc.
General Electric
General Electric
National Oil
Processing/Aptus
Niagara Mohawk Power
Corporation
PPM' Inc.
ENSR Operations
(formerly Sunohio)
T & R Electric Supply
Company, Inc.
Transformer
Consultants
Trinity Chemical co.
Inc.
PHYSICAL SIPNU\TION
ENSCO
National Electric/
Aptus
Quadrex HPS, Inc.
Unison Transformer
Services, Inc.
233 Broadway, 17th Floor
New York, NY 10279
1550 Balmer Road
Model City, NY 14107
41638 Christy Street
Fremont, CA 94538
One River Road
Schenectady, NY 12345
One River Road
Schenectady, NY 12345
P.O. Box 1062
Coffeyville, KS 67337
300 Erie Boulevard West
Syracuse, NY 13202
1875 Forge Street
Tucker, GA 30084
1700 Gateway Blvd. S.E.
Canton, OH 44707
Box 180
Colman, SD 57017
P.O. Box 4724
Akron, OH 44310
6405 Metcalf, Cloverleaf 3
Suite 313
Shawnee Mission, KS 66202
1015 Louisiana Street
Little Rock, AR 72202
P.O. Box 935
Coffeyville, KS 67337
1940 N.W. 67th Place
Gainesville, FL 32606
P.O. Box 1076
Henderson, KY 42420
212-267-707 3 *
716-754-8231
415-659-0404
518-385-3134
518-385-3134 *
800-345-6573
315-474-1511
404-934-0902 *
216-452-0837 *
800-843-7994
800-321-9580 *
913-831-2290
501-223-4100 *
800-345-6573
904-373-6066 *
800-544-0030
PHYSICM. SE;PARATIQlll continued
General Electric One River Road
Schenectady, NY 12345
PCB TRANSFORMER DECOMMISSIONING
G&L Recovery
Systems, Inc.
BIOLOGICAL
Detox Industries,
Inc.
PIPELINE REMOVAL
Texas Eastern Gas
Pipeline Company
CHEMICAL WASTE LANDFILLS
Casmalia Resources
CECOS International
CECOS International
Chemical Waste
Management
Chemical W.Ste
Managemeiit
Chem-Security Systems
Incorporated
Envirosafe Services
Inc. of Idaho
'scA Chemical services
1302 West 38th Street
Ashtabula, Ohio 44004
12919 Dairy Ashford
Sugar Land, TX 77478
P.O. Box 2521
Houston, Texas 77252-2521
559 San Ysidro Road
P.O. Box 5275
Santa Barbara, CA 93150
56th St. & Niagara Falls
Boulevard
Niagara Falls, NY 14302
5092 Aber Road
Williamsburg, OH 45176
Alabama Inc. Box 55
Emelle, AL 35459
Box 471
Kettlernan City, CA 93239
Star Route
Arlington, OR 98712
P.O. Box 417
Boise, ID 83701
Box 200
Model City, NY 14107
518-385-3134 •
216-992-8665
713-240-0892
713-759-5167 •
805-937-8449
716-282-2676
513-720-6114
205-652-9721
209-386-9711
5 0 3 -

4

5

4

-

2

7
, 7 7
208-384-1500
716-754-8231
'' ':
CHEMICAL WASTE LANDFILLS continued
u. s. Ecology, Inc.~
U.S. Pollution
Control, Inc.
Box 578
Beatty, NV 89003
Grayback Mountain
Knolls, UT 84074
702-553-2203
405-528-8371
U.S. EPA REGIONAL DISPOSAL CONTACTS
?.ec i,;r1 :
(Connect.i c..:t, i·lai r.e, r-!assachuser.t.s ,
Rhode Island, Vermont )
Tony Palermo
Air Management Division
Environmental Protection Agency, Region I
John F. Kennedy Fedetal Building
Boston, Massachusetts 02203
[phone], FTS 835-3279
Region II
. ' ..,,_ ..... '
(New Jersey, New York, Puerto Rico, Virgin Islands)
John Brogard
Air and Waste Management Division
Environmental Protection Agency, Region II
26 Federal Plaza
Dan Kraft
FTS 340-6669
New York, New York 10278
[phone], FTS 264-8682
Region III
(Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia)
Edward Cohen (3HW40)
Hazardous Waste Management Division
Environmental Protection Agency, Region III
841 Chestnut Street
Philadelphia, Pennsylvania 19107
[phone], FTS 597-7668
Region IV
(Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, south Carolina, Tennessee)
Robert Stryker, PCB coordinator
Pesticic1• anc1 Toxic Substances Branch
Envirore•■tal Prot.ection Agency, Region IV
345 courtl-and Street ~ N.E.
Atlanta, Georgia 30365
[phone], FTS 257-3864
: ,
j.'
'i
l'' t
St~e ::.do,. S i:non
Pes~:cises ar.d Toxic Substances Branch (SS-?TSB-1)
En vironment al Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois 60604
[phone], FTS 886-6087
Region YI
(Arkansas, Louisiana, New Mexico, Oklahoma, Texas)
Jim Sales Donna Mullins
Hazardous Waste Management Division FTS 255-7244
Environmental Protection Agency, Region VI
Allied Bank Tower
1445 Ross Avenue
Dallas, Texas 75202-2733
[phone], FTS 255-6785
Region VII
(Iowa, Kansas, Missouri, Nebraska)
Leo Alderman, PCB Coordinator
Doug Elders
Toxic and Pesticides Branch
Environmental Protection Agency, Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
[phone], FTS 757-2835
Region VIII
(Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming)
Dan Bench [phone], FTS 330-1732
Tom Pauling [phone], FTS 330-1747
Paul Grimm [phone], FTS 330-1443 --1..-°t'-/ -I \57
Toxic SUbatances Branch
Environaental Protection Agency, Region VIII
One Den119r Place
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
[phone], FTS 564-1442
G~e~ :zaj~o~ski (T-5-21
Pest ~cides and Toxics Branch
Enviror~ental Protection Agency, Region IX
215 Fremont Street
San Francisco, California 94105
[phone], FTS 454-7295
Region x
(Alaska, Idaho, Oregon, Washington)
Cathy Massimino (HW-114)
Hazardous Waste Management Branch
Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101
[phone], FTS 399-4153
Bill Hedgebeth
FTS 399-7369
APPENDIX F
LONG TERM MANAGEMENT CONTROLS AT PCB-CONTAMINATED SITES
SUPERFUND EXAMPLES
-::::-/ -~-,,<~• ◄ SU,.P.RnJND EXAMPLFS-UJNG-TEII.M MANAGF.MF,HT C.ONTitOLc; ...... ,ca Flaoll'O .._ .... c-.-~ ~-c.~ ....... 1 ~ S&1t-,aoo O....l 1.-.15-irft.A:hwWaa .,.._. ... ....,.,_1 ·-) c.-..111.--. C-..0-..,. -u.... .... ._..,._ I. Ouati nd Ga.. . ... _clN_....,.. &c::natc 10(,.;r) :IJl (""') Groundwalcr. 0-2 feel 9adllra10pl0il . -Umullllh,atcrweffa "'-""· NH c,n...,> . Orf-&ilc iadeentioa ----rtanMd Int f"HIIP . C:.p Ga:>k>cY: 1LKal 1Mb; Uldlrat,_,..t . Acnht• -Ear.cl Nd Ital ~lcr 2. Rc-Sahoc. MA w ... cnl11pfaide111diin -.. IS-5'2.000 2S(,ajry Groulldwatcr.50-60k:a R-•-. -Grounct-lCT-elb. N<w1h Oan-=-th., MA "'""' C:.p --... pbnflCd for pump (7/2AM7) Sc:waat n:cAaal.tlioe . Oft4hc l~f (dec:MoriMlk>a) GeoioeYeuncl.ln¥d.lllt. .1nc.llrca41RC111 ,aa.,ry . Wc0and ro.ontion h<droct EarKt and lral rro-ao-atff l. Cltiamcal Coatrol Varietyol ... cftl . 1111-ena rm1im M M Groundwater: I •3 tea 1-3 Cool ,.-..,_. None -i:l1Dbctb, NJ ....... . Dcbril tanc,11191 --N■••ral (9/2AA17) Slonn~~ ~ .. -lilly -,pcnocabloday, 5,eanc sue (fcnC"C} und; Iii!; twcdroct .. Wide Roch . Wa11tol~oadm . Eur,11im 0.0S-1026 10 GcolocYc olky .. _,_, Noae-(aoc~■ . None NM< Bnnt.NY "'""' Chc111icallff;alacal afhyJcuy. f,-n•raS .Uk: n:sidcatill (9oo.1!S) UIIIICft'"'ffJ) s. Yon Oil . -· .1-210 Groano-a&cr. lOICCI Noec (JUbiliDlial -Gro.ino-.1n'wdil Moen, NY St.1...,m: ..._ ....... ~tc,,.,,a.&,ated N■,.,_I pianned for pwnp 1 (219""') . Ofl411C iac:Nler'llioa Geooos:Js s<aciol bodroct ao.11. -,,cnacahk) tm~bk days andtrcatl!nitftl f.alf'K'I aftd tral ~•er ,... .. M-E,,1-,,oc . )acn1Wamp 0ooe ...... N.D.-'2t,aj1) 2S GmllndwMtt IA fcec 2, ....... _...,_ . -NMe ,AL 1 ran&tnmu:r ,q.Tf' pane F.u:rn1c --21ec1~•~ (9/llM6) Suhih&r: ' ~-undy: day. roa; a.,a,.21«1 .. fld, hmolont syntbcoc hM"r 1. f'cppc:r'a Sled A AlkJ:p :iaaaatl'WNI -·· l.5•7'°flnil) I Groundwa1cr: 54 feet 12iaehc:lcnahnl . N,-~-,nctcn1 Modi<)', FL St•Nl17.r: ..-....... .......... Jrrot1n0,,l<slrr~lb. ("112M6) 0(1-Mlf" fttciftcnlioft GNlktgr. fill; pnt; pbnrw:d Int pump C:.p , ...... ,.,. •~ ucauncn1 Eau-at:1 Hd trnt ,,,,..,..,er a. 8c:tvldctt uodfill Laftdfill r:..a~•c-9-Sl,000 so Grounctwllta: 7 lcet RCRA..,.... . None (im..ifldwala9'Clt. ll<Mda<, IL Drvm L>apoul OH -MIC MciflenlKlfl ttct,ow Mlr1K"e punned for pump (6-00&) l.andfiH ~' .... , Jm'd: anJ tn::anneru C:.p bodroct E.xtna •ad 1n:a1 rmolldw9lcr Sccvtc Mlt: .. Fo<,W...,. Ovmpns •ra . E.,cowo1e 034-14.2 10 GnN1•dw•1uer: 10-IS fttt 2 feet day Hd ll NMe Gn"°'ftdwlltn wtlll Fnn w-,nc, ID R«-ycitnJ punt On-sue IM'1RCntlOII ~•url»cc lftC'hc:I \OrfC'l•ln-e ~ planM'd lur f"H"P ("'2i>IAA) Cap C .cnk>CY: OUl.,..h undl ,.~ 1rc-auncn1 Con1amiun1 .. n and fDYrb; lalt:t ~-f.11.-.C, attd ln:::111 rroufMNf'llt,:r "''"· and fitta SoN:un-111e
.~.-~·--:,-;:,-.-.,-_--,._•,-,--:-~.,i; -:-:~----. ·-:-:.-'w:I I N i> C: !" 8 I ~ I C) 0 31 f;l ~ "' "' 0 '.,, . a, ~ "' -I!' "' 0 ., ... ,._.,...._IIIOOO..l , ...... ,s..a.,....... 10. FrftdlUmnC'd . u ..... ...,.. ~.lX (:VZ4MAI II. er-.cac1:11rcat . Sao,,.... BaylNc>,S"""' l"acoma. WA (12/J0,117) 12. raar.: Hide aad Fur . r--.., atpodtoro rocatdJo. ID . Saopyonl (6/lMIII) IJ . .1 PiaM"tfl $.aMfC Yard _,,.... w-..~MF. . T~dildec1ric (5/'.IAl9) """'""" I 4. b S11Uin■·s ud,e 0..,,-, "'"' 8n1Cont MA , ............. 1rn...-,,,.., u.• ~ Bed(Of'd Hart,or-. 1 ................... ~ Spot Na 8111:U<d·• Bay. MA ("1") ........ ~niro.,ou, . Oil-Sic• R«uC-.,,,PA Or-'lt'IAIJl l7 . .aoTCMllol~ . --~ _..,.tCoo"')'.MA ............... Dn1t (1199) . r-•..,..., •c.~fld ~ Uc•ulN:'d • • MffUil.-e. .·~-:.~--,;.~,. .. ,-,_~...,.: •• ---:;-,;;...t•-"'-,----; • .. F u1 __ .-·,: .... -'"_., '!-.·_:. ~I!!• . __ "'•~_:_!!~~ •---:--:._•_-__ _ ~UPP:llrt.lP,,0 EXAMP't.£5.-J.DN(;.TD.M MANACF.MIF.HT C:ONTW01.o; 1-rca ,_,..,. '--c-... c--·--(".NK.,._ • .,_..., ~ ... .....,.,,.., ,,.., c--c---U..n ... 1..-.llilf,tec"da,a I•-• ~ lrcaCIIICM H.D.-416 2l Oto._....cr. ic.:1"-50 -. -(;n....,...ff~ $Utt.tale rccc bdcMo swt.ce . H•-"'"~,..._..,Of' '~'-'""' ..,..__ f'Umpa-.lln:,tCIIIC'IIIII l:.ac.w.to 0-llM I Omu..,_.a: 11-12re.:1 21111Ct1caeca6cd -(in...,..a . Sl•ti.litc hdow 1urfacc -· --•onttt:•,...ca C.p °"""CY-r,11;_...., J'll'f"llllCd Ro-~ . -· 10-25 . Gn:i.--..cr.::O(C'l:I t..o.~or . t..o.pa"aabi .. cp ... _ . SlabdilC ---K<.:RAop C-,,.addecllo Cop ....... __.. . SI.Wiad ... mal loKnC .. lilMI' Uftd0-,C..l._.1Acld•&a , .... )00 , G~ 0-2:Grca 4incka-,....CIJ . -~,.,.,,. ... aMcm.twc ----NIChcla1011C;a-ctc c-..,: ........ .,_ s,-Mtici.,er:rt11 ...., ... ...,cvy.,1aaa1 filt bednxi -· 2.-(-1) G~irr. 1oorea 2fft'fcta,:II_.... . -Gn,uadwaCCT ,_... Suibdaze ---bulCcrlOltl2MICka map~p&aoacd(or Cap G""'°IY-q-,;.,_,.., .1A■dJ'aml;2(ect pump Md ,ra,,_. EJ.ttKI Ind Ital sn,undwala" i• trac1,11·al haimd ¥qel.lf¥1Ct0'&; Rot0tt-.ct1Andl wqcc111CN1 Sccu~t.i1c Rotnau.e l..ont lffl'II l"OOfttCOrint C.,,..1 identiRcd • • -. G~1irr. )feetllNldhJII: . -N""" .allc:rnaow: (ICldu•mc) CIOIIUIDUlllll)lt dllil: 10 ~•hcttet.pcf diffllUllla ffflllll 1ohalelll C..app1111.:k1111ftedNN HD·l0.000 c;,.,....a-: !era, .... j SJ11filc1ic: liMr, -Ci~a" IIICfllMWC ("'"'I rccc to JI 1er1 '° lW1'..acc pn,lect!M IOd; ........ Gcotocr, t'ill;aauntoi,,,a-. 1,.-,oet 'tfllC'l'tl••---C.,,...idcntlflCd•• l~-U.000 10-,0 . ......,, n1;_,., l,_.,.....r . --... ......... <-•1 cn-tJlaaalfoll;-aa,cp1.c uore li■cr, ... .ltp"l:'p(C rcotm:tk hit.r. r• ..,._,,.._