DEPARTMENT OF ENVIRONMENTA PE L

STATE OF CONNECTICl DEPARTMENT OF ENVIRONMENTAL PE

SDMS DocID

BUREAU OF WATER MANAGEMENT PERMITTING, ENFORCEMENT & REMEDIATION DIVISION

FEDERAL REMEDIATION PROGRAM

March 10, 1997

Ms. Leslie McVickar ^ ̂ H v j q. ^ v ^ t , U.S. Environmental Protection Agency -^ ̂ i Office of Site Restoration and Remediation Connecticut Superfund Section JFK Federal Building, HEC-CAN6 Boston, MA 02203-2211

Re: Gallup's Quarry Superfund Project, Draft Feasibility Study

Dear Ms. McVickar:

Staff of the Federal Remediation Program of the Permitting, Enforcement and Remediation Division (PERD) of the Connecticut Department of Environmental Protection have reviewed the "Draft Feasibility Study" for the Gallup's Quarry Federal Superfund Project, dated January 27, 1997. The document was prepared by Environmental Science and Engineering, Inc. (ES&E), and was submitted on behalf of the Gallup's Quarry PRP Group. It was received by the Department on January 27, 1997.

Our comments regarding this document are listed below. All references to CGS mean the Connecticut General Statutes, while all references to RCSA mean the Regulations of Connecticut State Agencies.

General Comments

In general this document adequately considers the requirements of our statutes and regulations. However, some revisions are required. These are outlined below in our Specific Comments

Specific Comments

1. Page 1-4, ̂ f2 Area Description

The second sentence should be revised since the GA classification does not in itself imply that site water quality is degraded. The GA classification reflects the State's presumption that the ground water is, at a minimum, suitable for drinking or other domestic uses without treatment. Where this presumption is not correct, the State expects that ground water quality will be restored so that the GA criteria are met. In addition, the sentence incorrectly implies that there is some doubt whether GA criteria are met. In fact, water quality on portions of the site does not meet GA classification criteria.

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Gallup's Quarry Federal Superfund Site State of Connecticut Comments on Draft FS- March 10,1997 Page 2 of 8

2. Page 2-1, ^1 Identification and Screening of Technologies-Introduction

One of the stated goals is to develop Remedial Action Objectives for Constituents of Concern (COCs). A table listing the COCs for each medium should be included. The PRPs should note that under RCSA §22a-133k-l(b) compliance with the Remediation Standard Regulations is required for all substances from a release, not just the COCs. Because the State's remedial criteria are based on more stringent risk ranges than those considered acceptable by EPA, some substances which are not considered COCs may exceed the State's criteria. The State's Remediation Standard Regulations apply to all contaminants present at a concentration above the analytical detection limit as the result of a release, not just those defined as COCs.

3. Page 2-2, f 1 Identification of Remediation Response Objectives

The text notes that the maximum carcinogenic risk calculated for surface soils, subsurface soils, sediments, and surface water under any scenario was 7E-5. Please note that the State has established acceptable risk levels at 1E-6 for individual chemicals and 1E-5 for cumulative risks for exposure to mixtures of carcinogens. While the maximum carcinogenic risk noted is within EPA's acceptable risk range, it exceeds the State's acceptable range.

4. Page 2-7, f 1 Remediation Goals for FPDA Soil

The report compares the Direct Exposure Criteria (DEC) to the Pollutant Mobility Criteria (PMC) for a GA area, noting that the PMC "are more stringent for the COC". While this is generally true for most contaminants, it is not true for metals. For metals, the DEC are based on mass analysis, while the PMC are based on leachate analysis, either by TCLP or SPLP. For this reason the DEC and PMC for metals can not be compared directly. The PRPs have calculated that approximately 700 cubic yards of soil contains contaminants which exceed the GA PMC, and have depicted the location of this soil on Plate 2-1. The report should state whether both the PMC and the DEC for metals were considered in determining the location and amount of soil containing contaminants at concentrations in excess of the PMC. Confirmation samples must demonstrate compliance with both the PMC and DEC. Sampling to confirm compliance with the PMC alone is not acceptable.

The report also notes that if an environmental land use restriction is in place, only soils within four feet of the ground surface must meet the PMC. While this is true, it should be noted that if the PRPs are unable to record an environmental land use restriction which ensures that the soil will not be exposed, then the PMC will apply to all soils within 15 feet of ground surface.


5. Page 2-7,12 Remediation Goals for FPDA Soil

This paragraph discusses calculation of alternative PMC, which may be approved by the Commissioner under RCSA §22a-133k-2(d)(3). The text does not indicate whether the PRPs are planning to calculate alternative PMC. If the PRPs are planning to do so, I would encourage them to contact the Department as soon as possible for guidance.

6. Page 2-8, f3 Remediation Goals for FPDA Soil

The text states that no TCLP or SPLP data is available for PCBs, so no direct comparisons can be made to the Pollutant Mobility Criteria. Since PCBs have not been detected in ground water and PCBs "are not very mobile", they are not included as COCs. This is not appropriate. Some additional sampling by TCLP or SPLP is necessary before PCBs can be eliminated from consideration as a COC. The PRPs should note that the fact that a substance has not been detected in ground water is irrelevant if that substance is present in soils at concentrations exceeding the PMC. The State considers any contaminant which exceeds the appropriate PMC to be a potential source of pollution to the waters of the state, regardless of whether the substance is presently leaching to ground water.

The text also notes that "metals concentrations in soils in the [Former Primary Disposal Area] are typically within the normal ranges for background soil within the eastern United States". No reference is provided to back up this statement. In addition, Section 22a-133k-l(a)(6) of the Remediation Standard Regulations defines the background concentration for soil as "the representative concentration of a substance in soil of similar texture and composition outside the subject release area and in the general geographic vicinity of such release area, but not within any other release area". Background concentrations based on literature values or other non site specific sources may not be used for the purpose of determining compliance with the RSRs.

7. Page 2-10, ̂ fl Remediation Goals for Groundwater

The text discusses the requirements for exemption from the volatilization criteria. Among the requirements discussed are that best efforts have been made to ensure that each affected landowner records an environmental land use restriction. The PRPs should note that the Department would interpret "best efforts" to include, if necessary, the payment of reasonable consideration to the affected landowners. The report should specify whether the PRPs are considering use of such an exemption.

8. Page 2-11,1fl Remediation Goals for Groundwater

The text notes that development of an industrial drinking water supply on the site is unlikely due to the proximity of the site to city water. The text should note that this does not rule out the


possibility that industrial water supplies could be developed on this site for process or cooling purposes. The report also states that environmental land use restrictions would be required "to preclude development of properties within the Gallup's plume. This paragraph misstates the purpose of such an environmental land use restriction. Two different types of environmental land use restrictions are used when ground water remediation standards can not be attained. If ground water can not be cleaned up to meet the residential volatilization criteria, an environmental land use restriction may be recorded to prevent the site from being used for residential purposes. If remediation of ground water pollution is determined to be technically impracticable, best efforts must be made to obtain an environmental land use restriction that would ensure that the affected ground water is not used for drinking or other domestic purposes. Neither type of environmental land use restriction would preclude development of a site. The regulations also provide that the volatilization criteria do not apply if no building exists over water polluted with volatile organic contaminants and best efforts are made to obtain an environmental land use restriction prohibiting construction of buildings in areas over the polluted water. This would not preclude construction of buildings in areas of a parcel which do not overly contaminated ground water, or installation of parking lots or other structures which are not buildings.

9. Page 2-26, f7 Institutional Controls- Implementability

The text states that environmental land use restrictions could be implemented on the site, and notes that the Former Primary Disposal Area is limited to one parcel of land. The State does not disagree that Environmental Land Use Restrictions could be implemented on the site. However, such restrictions would be required for all areas underlain by soil with contamination at concentrations exceeding the PMC or DEC, as well as ground water contamination at concentrations exceeding the applicable ground water criteria, both on the Gallup's Quarry property and in downgradient areas. It should also be noted that the PRPs do not presently own or control the Gallup's property. It is uncertain whether the present owners would be willing to record an environmental land use restriction.

10. Page 2-38, ̂ [6 Institutional Controls- Implementability

The text states that institutional controls would involve continuing to enforce existing regulations prohibiting ground water development as a residential supply. The text should specify which regulations currently accomplish this goal. The Department agrees that institutional controls in the form of environmental land use restrictions could be readily implemented, assuming landowners can be induced to record environmental land use restrictions. However, institutional controls would involve more than simply continuing to enforce existing zoning regulations. The PRPs would be required to obtain Environmental Land Use Restrictions as prescribed in the regulations.


11. Page 3-16,1f5 Implementability-Alternative SC4

This option would require dewatering to allow excavation of soils prior to treatment. In addition to the laws and regulations discussed, the a permit for the withdrawal of ground water would potentially be required under the Connecticut Water Diversion Policy Act (COS §22a-365 to 378). A reference to this requirement should be added to the text.

Some on-site treatment alternatives would involve replacement of treated soil onsite. Section 22a-133k-2(h)(l-4) of the Remediation Standard Regulations specifies the circumstances under which treated soils may be reused on the site. Treated soils may be reused at any location on the site or another site if the soil is treated so that no pollutants are detectable in the soil, and no naturally occurring substances are present at concentrations exceeding the site specific background concentration.

Soils which are treated to comply with both the direct exposure and pollutant mobility criteria, but still have detectable contamination may be reused only above the water table, in an area which is not subject to erosion.

12. Page 3-31, f4 Treated Groundwater Discharge

If this process is selected as part of the final remedy, I would encourage the PRPs to contact me as early as possible regarding water discharge permitting requirements. They should also be aware that a General Permit is available for many discharges to a sanitary sewer system from a ground water remediation system. Under the General Permit, the PRPs would be required to register the discharge and to comply with certain effluent limitations and operating requirements. Use of the general permit could significantly reduce the time required for permitting. This comment applies also to the discussion on page 3-36 regarding Alternative MM-4.

13. Page 3-3 3, f4 Impiementability- Alternative MM3

The "Ground Water Extraction Permit" referenced here is actually a Groundwater Diversion Permit.

14. Page 4-1 l,p

The text states that contaminant concentrations would drop below Remediation Standard levels in less than 11 years. This statement conflicts with statements elsewhere that vinyl chloride concentrations would remain above Remediation Standard levels for approximately 27 years. This statement should be clarified.


15. Page 4-15, f7 Compliance with ARARs- Alternative SC2

In the second to last sentence, the word "affect" should be replaced with "effect".

16. Page 4-45, |6 Compliance with ARARs- Alternative MM2

The text states that compliance with Connecticut Ground Water Quality Standards and Connecticut Ground Water Protection Criteria, among other ARARs, would be required. It notes that these all provide numerical standards for various contaminants. This statement must be revised to include the volatilization and surface water protection criteria, as well as the background concentration for groundwater. If a substance is part of a release, but no criteria for that substance are included in the RSRs, appropriate criteria must be developed for the Commissioner's approval, and those criteria must be met. Each criteria is applicable in specific circumstances as specified in the Remediation Standard Regulations. In addition, the Connecticut Groundwater Quality Standards, which were adopted pursuant to CGS §22a-426, should not be confused with the Remediation Standard Regulations. The Groundwater Quality Standards do not provide numerical criteria for specific substances in groundwater. Instead they specify a hierarchy of uses for various classifications, and list the State's broad policy goals for ground water quality. The only criteria listed for GA waters are "as naturally occurs" for dissolved oxygen, pH, and chemical constituents, and "none other than of natural origin" for oils and grease, color and turbidity, coliform bacteria, and taste and odor. The Water Quality Standards should be listed as ARARs, separately from the various criteria specified in the Remediation Standard Regulations.

17. Page 4-53, \\ Treated Groundwater Discharge

The report states that discharge limits for totals VOCs would be approximately 10 ug/1. While this limit is useful for the purpose of comparing various alternatives proposed in the FS, the PRPs should be aware that the actual limits may be different. Effluent limitations are set on a case- by- case basis, based on the chemical characteristics and flow rate of both the discharge and the receiving water body. The Department would require that the proposed discharge comply with individual effluent limitations for a suite of contaminants, as well as acute and chronic toxicity requirements.

18. Page 4-53,1J3 Institutional Controls, Monitoring and Reviews

The text notes that environmental land use restrictions would be required for 5 properties which would be impacted by the plume, while institutional controls might be required on several other properties to "prohibit installation of a production well until remediation goals are met". The meaning of this phrase should be clarified. I assume that this refers to properties which are not currently impacted by the plume, but which could become contaminated if operation of a


production well caused the plume to migrate toward the well. This comment applies also on page 4-67.

19. Page 4-56, f 1 Compliance with ARARs- Alternative MM3

The text states that since the discharge would comply with State surface water discharge requirements, this option would be exempt from the requirements of the Water Diversion Policy Act. The PRPs should be aware that the proposed ground water extraction system would not necessarily be exempt from the obligation to obtain a diversion permit. COS § 22a-377 specifies that "discharges permitted under the provisions of section 22a-430" are exempt from obtaining a diversion permit. This provision applies to the discharge of water, rather than to withdrawal. This comment applies also to the first full paragraph on page 4-70.

The meaning of the last sentence in this paragraph is unclear. The report should clarify whether the intended reference is to the long-term ground water monitoring requirements for RCRA waste disposal facilities. Those standards are Relevant and Appropriate Requirements. This comment applies also to the discussion regarding Alternative MM4 in the second paragraph on page 4-70.

20. Table 2-1 Chemical Specific ARARs

Connecticut Groundwater Standards- Page 2 of 3

The citation here is incorrect. Although the Ground Water Quality Standards were adopted pursuant to CGS §22a-426, they are not statutes themselves. There is no Section IV of CGS §22a-426. Section IV is part of the Water Quality Standards. This comment applies also to the citation of CGS §22a-426II on page 3 of Table 2-1. A list of state ARARs was previously provided to the PRPs through their copy of my letter to you dated August 1, 1996. The PRPs should refer to that list of ARARs for proper citations and other information regarding ARARs. I have enclosed a new copy of our list of ARARs.

Connecticut Drinking Water Regulations- Page 3 of 3

The citation provided is incorrect and incomplete. The proper citation should be to RCSA §19-13-6102 (e)(l-6). The standards are more properly referred to as the Standards for Quality of Public Drinking Water.

21. Table 2-2 Action Specific ARARs

Connecticut Hazardous Waste Management Regulations


These regulations should be more specifically cited as RCSA §§22a-449(c)-100 through 110and22a-449(c)-ll.

22. Table 2-3 Location Specific ARARs Page 2 of 3

Connecticut Public Health Code

The correct citation for portion of the Public Health Code concerning Water Supply Wells is RCSA §19-13-B51(m).

23. Table 2-4 Ground Water Remediation Goals and Table 2-5 FPDA Soil Remediation Goals

These tables list various criteria from the Remediation Standard Regulations but do not specifically list which criteria will be used as cleanup goals at the site. These goals should be identified in these tables, together with any Federal ARAR values.

If you have any questions concerning this letter, please contact me at (860) 424-3768.

Sincerely,

Mark R. Lewis Senior Environmental Analyst Permitting, Enforcement& Remediation Division Bureau of Water Management

cc: Gary Wilson, ES&E Brian O'Mara, TRC Trisha Haught, PRP Executive Committee Roberta Barbieri, PRP Technical Committee

Enclosure (ARARs Table)

Gallup's Quarry Federal Superfund Site List of State Applicable or Relevant and Appropriate Requirements

March 10,1997

Requirement

Hazardous Waste Management: Generator & Handler Requirements-General Standards, Listing & Identification

Hazardous Waste Management: Generator Standards

Hazardous Waste Management: Transporter Standards

Hazardous Waste Management: TSDF Standards

Hazardous Waste Management: Interim Status Facilities and Ground water Monitoring requirements, Closure and Post Closure Requirements

Hazardous Waste Management: Management Standards for Specific Waste Types

Hazardous Waste Management: Land Disposal Restrictions

Hazardous Waste Management: Permit Requirements

Citation

RCSA §§22a449(c)100-101

RCSA §22a449(c)102

RCSA §22a449(c)103

RCSA §22a449(c)104

RCSA §22a449(c)105

RCSA §22a449(c)106

RCSA §22a449(c)108

RCSA §22a449(c)HO

Action Specific

Status

Relevant and Appropriate (Applicable to Investigation Derived Waste)


Offsite Requirement






ARARs

Synopsis of Requirement

These sections establish standards for listing and identification of hazardous waste. The standards of 40 CFR §§260-261 are incorporated by reference. Chromium is not exempted from listing as a hazardous waste.

This section establishes standards for various classes of generators. The standards of 40 CFR §262 are incorporated by reference. Storage requirements given at 40 CFR §265.15 are also included.

This section establishes standards for hazardous waste transporters. The standards of 40 CFR §263 are incorporated by reference.

This section establishes standards for treatment, storage, and disposal of hazardous waste, and establishes standards for closure, post closure, and ground water monitoring. The standards of 40 CFR §264 are incorporated by reference. Underground injection of hazardous wastes, and placement of free liquids in landfills are prohibited.

This section establishes interim status standards for treatment, storage, and disposal of hazardous waste, and establishes standards for closure, post closure, and ground water monitoring. The standards of 40 CFR §265 are incorporated by reference. The Commissioner may require ground water monitoring based on site specific considerations.

This section establishes standards for specific types of wastes, including waste oil and spent lead acid batteries being reclaimed. The standards of 40 CFR §266 are incorporated by reference.

This section incorporates by reference the Federal Land Disposal Restrictions given at 40 CFR §268.

This section incorporates by reference the Federal hazardous waste permitting requirements given at 40 CFR §§270 & 124.

Pagel of 5


March 10,1997

^

Requirement

Solid Waste Management

Solid Waste Management

Disposition of PCBs

transportation of Oils and Chemical Liquids

Control of Noise Regulations

Water Pollution Control



Water Quality Standards

Citation

RCSA §§22a209-1 to 15

COS 22a-208a through 208c

COS §22a-467

COS §22a-454

RCSA §§22a69-1 to 69-7.4

RCSA §§22a430-1 to 8

COS §22a430b

CGS §22a-430

CGS §22a-426

Action Specific

Status

Relevant and Appropriate



Offsite requirement

Applicable

Applicable

Applicable

Applicable

Applicable

ARARs


These standards establish operating and closure standards for solid waste disposal areas including closure, post-closure, and groundwater monitoring requirements. Note that the definition of Solid Waste is given in CGS §22a207.

A permit is required for construction, alteration or operation of a solid waste management facility, or to receive, dispose of , process or transport solid waste in a solid waste facility, volume reduction plant, solid waste disposal area, recycling facility, recycling center, transfer station or biomedical waste facility.

This section requires that PCBs be disposed under a permit issued by the Commissioner. PCBs may also be disposed of under a written approval of the Commissioner in a manner which results in the destruction of the PCB or in a manner not inconsistent with the Requirements of the Toxic Substances Control Act (TSCA), listed at 40CFR §761.

These rules require permits for persons who transport oils and chemical liquids.

These regulations establish allowable noise levels. They would apply to construction activities on the site.

These rules establish permitting requirements and criteria for water discharge to surface water, ground water and POTWs.

This section establishes general permits for many categories of discharges including storm water, and discharges to a POTW by a ground water remediation system. General permits may require that the discharge be registered with the Commissioner prior to initiating the discharge.

This section prohibits discharge to the waters of the State without a permit.

Connecticut's Water Quality Standards were adopted under this statute. They establish specific numeric criteria, designated uses, and anti degradation policies for groundwater and surface water.

Page 2 of 5


Requirement

Connecticut Water Diversion Policy Act

Air Pollution Control-Stationary Sources

Air Pollution Control-Control of Paniculate Emissions

\ir Pollution Control*Control of Organic ^ Compound Emissions

Air Pollution Control-Control of Odors

Air Pollution Control-Control of Hazardous Air Pollutants

Regulations for the Well Drilling Industry

Registration and permitting of wells and well drillers

CT Guidelines for Soil Erosion and Sediment "ontrol

%•

Citation

COS §§22a365 to 378

RCSA §22a174-3

RCSA §22a174-18

RCSA §22a174-20

RCSA §22a174-23

RCSA §22a174-29

RCSA 25128-33 through 64

COS 25- 126 thru 131

CT Council on Soil and Water Conservation

March 10,1997

Action Specific ARARs

Status Synopsis of Requirement

Applicable These rules regulate many diversions of the waters of the State. Several broad categories are exempt, including any diversion of less than 50,000 gallons per day and any discharge permitted under COS §22a-430.

Applicable This regulation requires section requires permits to construct and operate stationary sources of emissions, and requires those sources to meet specified standards. Pollution abatement controls may be required. Specific standards are listed for many pollutants. Any landfill with potential emissions of any particular air pollutant including methane exceeding 5 tons per year requiresa permit under subsection 3(a)l(K). Active gas collection systems with emissions controls may be required.

Applicable This subsection sets specific standards for paniculate emissions. Specific standards include Fugitive Dust (18b), and Incineration (18c). Gas flares are regulated as incinerators.

Applicable Subsection (f) sets standards for emission of organic compounds. Incineration of organic halocarbons is prohibited under subsection (f)(6)(A).

Applicable This section prohibits emission of any substance that constitutes a nuisance because of objectionable odor.

Applicable This section establishes testing requirements and allowable stack concentrations for many specific substances.

Applicable These rules apply mainly to any new water supply or withdrawal wells. The rules specify that non water supply wells must be constructed so that they are not a source or cause of groundwater contamination. Procedures for abandonment of wells apply to both water supply wells and other types of wells.

Applicable Well drillers must be registered and permits and fees are required for each water supply well drilled. Separate registrations apply to water supply and non-water supply drillers. Permits are not required for non water supply wells. However, the driller must file a completion report for both water supply wells and non-water supply wells.

Applicable The guidelines provide technical and administrative guidance for the development, adoption and implementation of erosion and sediment control program.

Page 3 of5

4


Requirement

Public Health Code Well Permit Requirements

Requirement

Aquifer Protection Areas

Stream Channel Encroachment

Regulation of Dredging and Erection Structures ind Placement by Fill in ̂ idal, Coastal, or %—

Navigable Waters

Surface Water and Wetlands- Inland Wetlands and Watercourses Regulations

Surface Water and Wetlands- Inland Wetlands and Watercourses Act-General Permit Requirements

Citation

RCSA §1913-B51

Citation

CGS 22a-354 through 354bb

CGS 22a-342 through 350

CGS 22a-359 through 363

RCSA §§22a39-1 to 15

CGS§ 22a-45a

March 10,1997

Action Specific ARARs


Applicable Prohibits issuance of a permit for drilling of a water supply well for any property where the boundary is within 200 feet of an approved water supply. Specifies separation distances between wells and pollution sources. Gives construction standards for water supply wells.

Location-Specific ARARs


Applicable These statutes provide for the municipal regulation of various activities in aquifer protection areas.

Applicable These statutes prohibit the establishment of any obstruction or encroachment, without a permit from DEP, within designated stream channel encroachment lines.

Applicable These statutes control activities in navigable waters of the state waterward of the high tide line.

Applicable Regulates any operation within or use of a wetland or watercourse involving removal or deposition of material, or any obstruction, construction, alteration, or pollution of such wetlands or watercourses.

Applicable This section authorizes the Commissioner to adopt a general permit for various minor activities including installation of water quality monitoring equipment, excavation of test pits and core sampling. The Department is currently drafting a general permit, and expects to issue the general permit before the final remedy is selected for this site.

Page 4 of 5


March 10,1997

Chemical Specific ARARs

Requirement Citation Status

Standards for Public RCSA 19-13 Relevant and Drinking Water Quality B101 through Appropriate

B102

Remediation Standard RCSA §22a Applicable Regulations 133kl-to3


MCLs established under these standards are health-based limits for certain chemical substances in drinking water. Action levels are also established under this act.

These regulations provide specific numeric cleanup criteria for a wide variety of contaminants in soil. They provide separate criteria for threats to human health and environmental receptors posed by direct contact with contaminants, and for risks to environmental receptors posed by migration of contaminants via ground water or soil vapor.

Page 5 of 5

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