0 8 lllVIROIIDIIIAL no71CIO AGDCY UGIO I

J J K IIDIUL 80ILDIG 808TO IIA 02203-2211

IWIOIWIDUX

DATil July 1990

IOBJ1 Detailed Evaluation and Cobullparative Analysis ot Alternatives

lltOIC1 Edward H Hathaway RPM ME VT Superfund

10 1 Site File

I IDtroduotioD I

The purpose of this bullebullorandua i s to present the follovinq (i) IPAbull a evaluat ion of the asaubull pti onbull ubulled by Textron Inc and bhart Corporat i on Respondents to EPA Adainistrati ve Order Docket No I-89shy1019 (Respondents ) in prepari ncJ the draft 1990 Pocuaed feasibility Study (FFS) Report for the Old Sprinvfield Landfill alta ancl the r elledial alternatives that were developed on the baaia of those aaauptions ( ii) a de tailed evaluation of the alternatives described in the July 1190 Proposed Plan for the HCOnd operable unit at the aite1 and (iii) a c011parative analysis of thoH alternatives It ia intendedt~tY-=~a~-1~~-~~ rmiddot~i~e~tI~preparect pr epared for Respondents by REMCOR Inc and the 1990 suppleaental Feaa1b11 1ty study (SFS) prepared for EPA by IBASCO Inc by prov1d1nv addit ional docuaentat i on for the conclusions pres ented in the PropoedPlan

II Baaio Aasupti oaa iD 1181

The alternatives developed in the FFS Report are baaed on a set of aasubullptions regarding risk aaaessaent ARAR deterwinations and rectial action objectives with which EPA disagrees and which are not consistent with current agency pol icy middot

Each of these assubullptions is discussed below

r A Risk Assessment

A Baseline Risk Aaaeaaaent is a docuaent which identifies the current and tuture potential threats to huaan health and the anvironaent and serves as the basis for detanininq if an alternative is protective of huaan health and the anvironaent EPA released a draft final Endanqaraant Aaaeaaaant (EA) for the Old Springfield Landfill in June 1988 The EA was developed as the baseline risk aaaaaaaant for the 1988 fiat operable unit Record of Decision (ROD) and tor the alternative evaluations perforae4 for the second operable unit

Thera was no raquirant for Raaponclanta to perfolJI and aubait a new

~8l~rmiddot~middot~tt~8R~nn8cm~~~~~r~ct~ FFS Report Respondents vera adviaad that if revisions to the ItA vera contaaplatad such revisions bullauat be baaed upon validated results and auat alao ba conaiatant with the Region I Supplaaantal Riak Aaaasant Guidance for Superfund and the NCP bull Thera ware no validated rasulta of the rrs which suggested a need to ravba the riak aasaaaaent Raapondanta ware further adviaed in that latter that bullthe only sectionbull of the revised risk bullbull--nt that are still warranted are the auuary

-_ of the ICP endanqarent bullbullbullbullbullbullbullant and the cleacription of the 1 iapl-ntation of operable unit 1bullJ

nle baHlina risk aaaaaaHnt autitted aa part of the June litO revised draft FFS Report waa not prepared accordinc to the IPA Region 1

~bulliricu~bullr-~4 of the critical

1 Rasponclanta changed the currant uaa acanario froa raaidantial which waa the aaauaption in the 1988 ampA to casual traspaaaar Expoaura scenariobull are developed to aiaulata poaaibla axpoauraa in the abaanca of alta apecific infonaation and to account for the variability in contaainant diatribution and land uaa Praaent uaa acanarioa include thoaa that have a praaant potential of occurring as vall aa thoaa known to occur The raaidential scenario ia appropriate a~nce thia exposure ia known to have occurred (the aobile hOM park waa occupied on-aite until Juna- ltSIO) - tbe--ovner of the property is-atill reaidinq on-aite and a aore extenaive reaidential acenario can potentially occur again Therefore Raapondantabull uaa of the caaual traapasaar scenario b inappropriate aa a current usa exposure scenario and is not consiatant with EPA quidance

4 Respondents include the impleaentation of Operable Unit No 1 aa

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an assumption in the baseline risk assessment In particular the FFS Report relies upon the successful iaplaaentation of institutional controls required by the first Operable Unit ROD The role of the baseline risk assassaant b to address the risk associated with a site in the absence of any raaedial action or control includinq institutional controls lbe effectiveness of the institutional controls in controlling risk aay be considered in evaluating the effectiveness of a particular raaedial alternative but not as part of the baseline risk aaaassnt This ia aat forth in the praable to the National Contingency Plan (NCP) (55 FR 8566 8710-8711 (Karch 6 1990)) Therefore any baseline risk aaaeasaant auat assess the baseline risk without the control aeasuraa

3 The risk asaasant in the rrs Report inclwtea the uae of relative potency factors as opposed to the cancer potency factor for benao(a)pyrene to eatiaata the riaka posed by polycyclic aroaatic hydrocarbons (PARa ) Respondents rely upon a r eport beincJ prepared for the EPA Office of Health and lnvironaental Assesabullnt to justify their usa of relative potency factors This report is not in final fora and has not bean issued by the Agancy This report is currently beinq revised It y not be relied upon to support a revision to the 1988 A vhicb directly contradicts EPA RecJion I quidance in this area

4 In the revision of the risk resulting froa inhalation of landfill 9as contuinated by volatile Of9anic capounda (VOCa) Respondents used a tricbloroethylana (TCB) inhalation cancer potency factor that baa been withdrawn fro the Intetrated Risk Inforution Syst (IRIS) pendinq further review

5 The baseline risk asHsaMnt in the rrs Report uaas 30 years and 9 years aa the plausible aaxiaw~ and avara9bull exposure duration under a residential scenar i o Evan when an exposure ia lass than lifati in duration doaea are still averaged over a 70 year lifetiM for carcinogenic affects Therefore uainq a shorter duration to assess the carcinogenic affects is inappropriate

6 The baseline risk asaeaant in the PPS Report uses the 95 upper confidn~bull liait to derive exposUyenbull point concentrations The EPA Recion I office relies upon a aaxiaUJt concentration as well as an average concentration The 95 upper confidence liait aay ba used if such usage ia supported with appropriate data (as noted in EPA CJUidance) This would be used in addition to but not as a substitute for an average and aaxiaua concentration as required by EPA Region I Respondents aade no atteapt to consult with Region I to support the usa

or the 95t contidence liait and has not supplied any aupportinq data

In auary EPA intaina that the 1988 EA ia the only appropriate baaeline riak aaaeaaaent acceptable for uae in evaluatir19 aource control alternativebull for th8 Old Springfield Landfill For the reaaou atated above the baaelinbull risk aaaeaaaant preaented in the reviae4 draft rrs Raport ia unacceptable

The current and future potential riaka identified by the 1988 EA which auat be addreaaed by the source control operable unit are

1 ir19eation of contaainated groundwater

2 lonq-tera exposure to PCB and PAH contuination in the aoil froa handli09 or ingeation and

J inhalation ot contaminants in landfill gas

a Deteraination ot ARAJW

The 1988 rs Report and the 1988 ROD both identify the Resource conaervation and Recovery Act (RCRA) bullbull an ARAR for the Old Springfield Landfill Under the NCP 40 CPR Part 300 for an alternative to be eli9ible tor aelection bullbull the redial action it auat Met all of ita respective ARAJta unleaa a waiver ia juatitied under the Caprehenaive lnvironaental Reaponae Capenaation and Liability Act (CDCIA) soction Ul(d) (4)

RCRA hazardoua vaate cloaure requirnta 40 CPR Part 264 Subpart G and hazardous waate landfill cloaure requirebullnta 40 CPR 264310 Subpart N are ARARbull tor a substantial part ot tha raaedial action Under Part 2U Subpart G closure of a hazardoua waata diapoaal facility auat be dona ao abull to control ainiaiza or aliainate bullpostshyclosure escape ot hazardous waste hazardous constituentbull leachate contaainated run-off or hazardous waste decoaposition products to the ground or surface waters middot or to the ataoapherbullmiddot Section 264310 Subpart N provides specific closure requireaenta for a hazardous wasta landfill

Purauant to the NCP EPA has deterained that the hazardous waste cloaure requireaenta are not applicable to the site because the RCRA requirenta were proaulqated after the Old springfield Landfill ceased operation However EPA haa deterained that the RCRA hazardous waste

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landfill closure requireMnta are relevant and appropriate to the remedial action The 1988 FS indicates the presence of RCRA-liated hazardous wastes at the site In addition other aubatancea c1iapoaed of and found at the site are aiaUar to RCRA hazardous wastes Objectives of the reaedial action such aa preventinq the leaching of soil contaainanta to the groundwater and preventing the public contact with contaainated soil or leachate that aay present a risk are aiailar to the purposes of the RCRA hazardous waste landfill closure requireunta The source control operable unit ia itself aiailar to the closure activities requlated by the requireaents and the aediua to be addressed is aiailar to the aediua requlated by RCRA requireaenta

In certain areaa of tbe aite however the RCRA requirnta while relevant have been detenined not to be appropriate to the reaedial action The aide alopea alonq waate areaa 2 and l are autticiently ateep that a nlti-layer cap would not be auitable For the liaited area of the ateep aide alopea along waate areaa 2 and 3 EPA haa deterained that the RCRA hazardoua waate landfill closure requirnta are not appropriate

In addition to conaiderinq the RCRA landfill cloaure requirnta relevant and appropriate EPA alao conaidera the July 1989 Technical Guidance Docment Pinal Cevera on Hazardgye lletbull bullndfilla aMI lur(bullsbull lepoundMntbull a To Be Conaidered (TBC) criterion tor help in detemlnirMJ the protectiveneaa of alternativea Tbia fJUidance docuaent providu the technical baaia tor iapl~tation of the RCRA AltAR and r~a the uae of a nlti-layer cap vith natural and aynthetic -teriala To Het landfill cloaure requirnta the cap auat be placed over vaate areaa 2 J and 4 which are the identified areaa of haaardoua waate diapoaal The FPS Report doea not include a aintJle alternative which would cover all of the waate areas It a lao doea not include a cap or cover which aeeta the requireaenta described in the technical guidance docuaent referred to above

EPA determines ARARs and TBCs for a site The FFS Report ignorea both EPA 1 s previoua detellllination in the 1988 FS Report that RCRA vaa an ARAR tor thia aite and EPAs directive in ita May 10 1990 co-ent letter that RCRA ahould be conaidered an ARAR Since the 1988 PS EPA haa iaaued the technical guidance docuaent referred to above whiCh the -middot-shyRegion conaiders a TBC and which waa sent to Respondents When a atatute or regulation ia identified aa an ARAR a proposed re-dial action alternative auat attain auch AltAR absent a waiver purauant to CERCLA aection 12l(d)(4) (see also the NCP aection J00 400(f(1)(i)) Rather than proceed on the basis that RCRA ia an ARAR however

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Respondents used RCRA tor so11e but not all alternatives

When the FFS does consider RCRA landfill closure requir-nta an ARAR it deacribea hybrid closure as a aechaniaa for aatiafying the requireaent Hybrid closurebull has never been proaulgated bullbull a rule under RCRA The preallble to the NCP refers to the preaable of the earlier proposed NCP (53 PR 51446) for a cUacuseion of hybrid closurebull The preaable to the proposed NCP states that this type of closure is identical to landfill diapoaal closure except that the cover requirnts are relaxed because the wastes being contained do not pose a threat to 9round water At the Old Springfield Landfill the wastes clearly present a threat to groundwater Therefore the bullhybrid closurebull concept cannot be applied in a aannar that aatisfiea the RCRA landfill cloaure requirebullnta Only thoaa alternativebull which include a RCRA cap over all areaa where a RCRA cap ia relevant and appropriate can aatiaty ARARa

0

All of the alternativebull retained tor detailed evaluation in the FFS Report leave waate in place Therefore the RCRA haaardoua waata cloaure raquirnta bulluat be conaidered aa potential ARARa and the RCRA techni011l quidanca ahould be conaidared a TBC EPA no acceptable juatitication tor not conaiclering the RCRA haaardoua waate cloaura r89Ulationa aa relevant and appropriate

c a-dial ampotloa ObjaotlYeal

Reapondanta raviaad the readial action objectivebull in tbe FP8 Report A reviaion of redial action objectivebull waa not a requi~nt tor the PPS Report Alao the Reapondentabull reviaiona to the r~ial action objectivebull are baaed upon concluaiona generated bullbull a reault of the reviaad riak aaaeaaMnt which EPA conaidara unacceptable for the reaaona atated above in II A The raMclial action objectivebull preaanted in the 1988 ROD and 1990 SFS are the appropriate objectivebull for uaa in the FFS

III EValuation of Alternativebull

In the following discuaaion each of the aix alternativebull retained for detailed conaideration in tbe FFS b re-evaluated baaed upon the aaawaptiona EPA conaidera appropriate uaing the nina criteria liatad and daacribad in tha NCP These alternatives are nUIIbared 6 throuqh 11 in the Proposed Plan Section III of thia bulleaorandu will than provide

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

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1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

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alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

an assumption in the baseline risk assessment In particular the FFS Report relies upon the successful iaplaaentation of institutional controls required by the first Operable Unit ROD The role of the baseline risk assassaant b to address the risk associated with a site in the absence of any raaedial action or control includinq institutional controls lbe effectiveness of the institutional controls in controlling risk aay be considered in evaluating the effectiveness of a particular raaedial alternative but not as part of the baseline risk aaaassnt This ia aat forth in the praable to the National Contingency Plan (NCP) (55 FR 8566 8710-8711 (Karch 6 1990)) Therefore any baseline risk aaaeasaant auat assess the baseline risk without the control aeasuraa

3 The risk asaasant in the rrs Report inclwtea the uae of relative potency factors as opposed to the cancer potency factor for benao(a)pyrene to eatiaata the riaka posed by polycyclic aroaatic hydrocarbons (PARa ) Respondents rely upon a r eport beincJ prepared for the EPA Office of Health and lnvironaental Assesabullnt to justify their usa of relative potency factors This report is not in final fora and has not bean issued by the Agancy This report is currently beinq revised It y not be relied upon to support a revision to the 1988 A vhicb directly contradicts EPA RecJion I quidance in this area

4 In the revision of the risk resulting froa inhalation of landfill 9as contuinated by volatile Of9anic capounda (VOCa) Respondents used a tricbloroethylana (TCB) inhalation cancer potency factor that baa been withdrawn fro the Intetrated Risk Inforution Syst (IRIS) pendinq further review

5 The baseline risk asHsaMnt in the rrs Report uaas 30 years and 9 years aa the plausible aaxiaw~ and avara9bull exposure duration under a residential scenar i o Evan when an exposure ia lass than lifati in duration doaea are still averaged over a 70 year lifetiM for carcinogenic affects Therefore uainq a shorter duration to assess the carcinogenic affects is inappropriate

6 The baseline risk asaeaant in the PPS Report uses the 95 upper confidn~bull liait to derive exposUyenbull point concentrations The EPA Recion I office relies upon a aaxiaUJt concentration as well as an average concentration The 95 upper confidence liait aay ba used if such usage ia supported with appropriate data (as noted in EPA CJUidance) This would be used in addition to but not as a substitute for an average and aaxiaua concentration as required by EPA Region I Respondents aade no atteapt to consult with Region I to support the usa

or the 95t contidence liait and has not supplied any aupportinq data

In auary EPA intaina that the 1988 EA ia the only appropriate baaeline riak aaaeaaaent acceptable for uae in evaluatir19 aource control alternativebull for th8 Old Springfield Landfill For the reaaou atated above the baaelinbull risk aaaeaaaant preaented in the reviae4 draft rrs Raport ia unacceptable

The current and future potential riaka identified by the 1988 EA which auat be addreaaed by the source control operable unit are

1 ir19eation of contaainated groundwater

2 lonq-tera exposure to PCB and PAH contuination in the aoil froa handli09 or ingeation and

J inhalation ot contaminants in landfill gas

a Deteraination ot ARAJW

The 1988 rs Report and the 1988 ROD both identify the Resource conaervation and Recovery Act (RCRA) bullbull an ARAR for the Old Springfield Landfill Under the NCP 40 CPR Part 300 for an alternative to be eli9ible tor aelection bullbull the redial action it auat Met all of ita respective ARAJta unleaa a waiver ia juatitied under the Caprehenaive lnvironaental Reaponae Capenaation and Liability Act (CDCIA) soction Ul(d) (4)

RCRA hazardoua vaate cloaure requirnta 40 CPR Part 264 Subpart G and hazardous waate landfill cloaure requirebullnta 40 CPR 264310 Subpart N are ARARbull tor a substantial part ot tha raaedial action Under Part 2U Subpart G closure of a hazardoua waata diapoaal facility auat be dona ao abull to control ainiaiza or aliainate bullpostshyclosure escape ot hazardous waste hazardous constituentbull leachate contaainated run-off or hazardous waste decoaposition products to the ground or surface waters middot or to the ataoapherbullmiddot Section 264310 Subpart N provides specific closure requireaenta for a hazardous wasta landfill

Purauant to the NCP EPA has deterained that the hazardous waste cloaure requireaenta are not applicable to the site because the RCRA requirenta were proaulqated after the Old springfield Landfill ceased operation However EPA haa deterained that the RCRA hazardous waste

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middot

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landfill closure requireMnta are relevant and appropriate to the remedial action The 1988 FS indicates the presence of RCRA-liated hazardous wastes at the site In addition other aubatancea c1iapoaed of and found at the site are aiaUar to RCRA hazardous wastes Objectives of the reaedial action such aa preventinq the leaching of soil contaainanta to the groundwater and preventing the public contact with contaainated soil or leachate that aay present a risk are aiailar to the purposes of the RCRA hazardous waste landfill closure requireunta The source control operable unit ia itself aiailar to the closure activities requlated by the requireaents and the aediua to be addressed is aiailar to the aediua requlated by RCRA requireaenta

In certain areaa of tbe aite however the RCRA requirnta while relevant have been detenined not to be appropriate to the reaedial action The aide alopea alonq waate areaa 2 and l are autticiently ateep that a nlti-layer cap would not be auitable For the liaited area of the ateep aide alopea along waate areaa 2 and 3 EPA haa deterained that the RCRA hazardoua waate landfill closure requirnta are not appropriate

In addition to conaiderinq the RCRA landfill cloaure requirnta relevant and appropriate EPA alao conaidera the July 1989 Technical Guidance Docment Pinal Cevera on Hazardgye lletbull bullndfilla aMI lur(bullsbull lepoundMntbull a To Be Conaidered (TBC) criterion tor help in detemlnirMJ the protectiveneaa of alternativea Tbia fJUidance docuaent providu the technical baaia tor iapl~tation of the RCRA AltAR and r~a the uae of a nlti-layer cap vith natural and aynthetic -teriala To Het landfill cloaure requirnta the cap auat be placed over vaate areaa 2 J and 4 which are the identified areaa of haaardoua waate diapoaal The FPS Report doea not include a aintJle alternative which would cover all of the waate areas It a lao doea not include a cap or cover which aeeta the requireaenta described in the technical guidance docuaent referred to above

EPA determines ARARs and TBCs for a site The FFS Report ignorea both EPA 1 s previoua detellllination in the 1988 FS Report that RCRA vaa an ARAR tor thia aite and EPAs directive in ita May 10 1990 co-ent letter that RCRA ahould be conaidered an ARAR Since the 1988 PS EPA haa iaaued the technical guidance docuaent referred to above whiCh the -middot-shyRegion conaiders a TBC and which waa sent to Respondents When a atatute or regulation ia identified aa an ARAR a proposed re-dial action alternative auat attain auch AltAR absent a waiver purauant to CERCLA aection 12l(d)(4) (see also the NCP aection J00 400(f(1)(i)) Rather than proceed on the basis that RCRA ia an ARAR however

I I

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)

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Respondents used RCRA tor so11e but not all alternatives

When the FFS does consider RCRA landfill closure requir-nta an ARAR it deacribea hybrid closure as a aechaniaa for aatiafying the requireaent Hybrid closurebull has never been proaulgated bullbull a rule under RCRA The preallble to the NCP refers to the preaable of the earlier proposed NCP (53 PR 51446) for a cUacuseion of hybrid closurebull The preaable to the proposed NCP states that this type of closure is identical to landfill diapoaal closure except that the cover requirnts are relaxed because the wastes being contained do not pose a threat to 9round water At the Old Springfield Landfill the wastes clearly present a threat to groundwater Therefore the bullhybrid closurebull concept cannot be applied in a aannar that aatisfiea the RCRA landfill cloaure requirebullnta Only thoaa alternativebull which include a RCRA cap over all areaa where a RCRA cap ia relevant and appropriate can aatiaty ARARa

0

All of the alternativebull retained tor detailed evaluation in the FFS Report leave waate in place Therefore the RCRA haaardoua waata cloaure raquirnta bulluat be conaidered aa potential ARARa and the RCRA techni011l quidanca ahould be conaidared a TBC EPA no acceptable juatitication tor not conaiclering the RCRA haaardoua waate cloaura r89Ulationa aa relevant and appropriate

c a-dial ampotloa ObjaotlYeal

Reapondanta raviaad the readial action objectivebull in tbe FP8 Report A reviaion of redial action objectivebull waa not a requi~nt tor the PPS Report Alao the Reapondentabull reviaiona to the r~ial action objectivebull are baaed upon concluaiona generated bullbull a reault of the reviaad riak aaaeaaMnt which EPA conaidara unacceptable for the reaaona atated above in II A The raMclial action objectivebull preaanted in the 1988 ROD and 1990 SFS are the appropriate objectivebull for uaa in the FFS

III EValuation of Alternativebull

In the following discuaaion each of the aix alternativebull retained for detailed conaideration in tbe FFS b re-evaluated baaed upon the aaawaptiona EPA conaidera appropriate uaing the nina criteria liatad and daacribad in tha NCP These alternatives are nUIIbared 6 throuqh 11 in the Proposed Plan Section III of thia bulleaorandu will than provide

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

~~t~t~ bullbull tu~~cr~-tt=~~~lfdc~

1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

I I I

JJillbullrJ trl

If f( IbullI

I I

)

alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

or the 95t contidence liait and has not supplied any aupportinq data

In auary EPA intaina that the 1988 EA ia the only appropriate baaeline riak aaaeaaaent acceptable for uae in evaluatir19 aource control alternativebull for th8 Old Springfield Landfill For the reaaou atated above the baaelinbull risk aaaeaaaant preaented in the reviae4 draft rrs Raport ia unacceptable

The current and future potential riaka identified by the 1988 EA which auat be addreaaed by the source control operable unit are

1 ir19eation of contaainated groundwater

2 lonq-tera exposure to PCB and PAH contuination in the aoil froa handli09 or ingeation and

J inhalation ot contaminants in landfill gas

a Deteraination ot ARAJW

The 1988 rs Report and the 1988 ROD both identify the Resource conaervation and Recovery Act (RCRA) bullbull an ARAR for the Old Springfield Landfill Under the NCP 40 CPR Part 300 for an alternative to be eli9ible tor aelection bullbull the redial action it auat Met all of ita respective ARAJta unleaa a waiver ia juatitied under the Caprehenaive lnvironaental Reaponae Capenaation and Liability Act (CDCIA) soction Ul(d) (4)

RCRA hazardoua vaate cloaure requirnta 40 CPR Part 264 Subpart G and hazardous waate landfill cloaure requirebullnta 40 CPR 264310 Subpart N are ARARbull tor a substantial part ot tha raaedial action Under Part 2U Subpart G closure of a hazardoua waata diapoaal facility auat be dona ao abull to control ainiaiza or aliainate bullpostshyclosure escape ot hazardous waste hazardous constituentbull leachate contaainated run-off or hazardous waste decoaposition products to the ground or surface waters middot or to the ataoapherbullmiddot Section 264310 Subpart N provides specific closure requireaenta for a hazardous wasta landfill

Purauant to the NCP EPA has deterained that the hazardous waste cloaure requireaenta are not applicable to the site because the RCRA requirenta were proaulqated after the Old springfield Landfill ceased operation However EPA haa deterained that the RCRA hazardous waste

IJi~l=t( bullbullI

I I

middot

)

landfill closure requireMnta are relevant and appropriate to the remedial action The 1988 FS indicates the presence of RCRA-liated hazardous wastes at the site In addition other aubatancea c1iapoaed of and found at the site are aiaUar to RCRA hazardous wastes Objectives of the reaedial action such aa preventinq the leaching of soil contaainanta to the groundwater and preventing the public contact with contaainated soil or leachate that aay present a risk are aiailar to the purposes of the RCRA hazardous waste landfill closure requireunta The source control operable unit ia itself aiailar to the closure activities requlated by the requireaents and the aediua to be addressed is aiailar to the aediua requlated by RCRA requireaenta

In certain areaa of tbe aite however the RCRA requirnta while relevant have been detenined not to be appropriate to the reaedial action The aide alopea alonq waate areaa 2 and l are autticiently ateep that a nlti-layer cap would not be auitable For the liaited area of the ateep aide alopea along waate areaa 2 and 3 EPA haa deterained that the RCRA hazardoua waate landfill closure requirnta are not appropriate

In addition to conaiderinq the RCRA landfill cloaure requirnta relevant and appropriate EPA alao conaidera the July 1989 Technical Guidance Docment Pinal Cevera on Hazardgye lletbull bullndfilla aMI lur(bullsbull lepoundMntbull a To Be Conaidered (TBC) criterion tor help in detemlnirMJ the protectiveneaa of alternativea Tbia fJUidance docuaent providu the technical baaia tor iapl~tation of the RCRA AltAR and r~a the uae of a nlti-layer cap vith natural and aynthetic -teriala To Het landfill cloaure requirnta the cap auat be placed over vaate areaa 2 J and 4 which are the identified areaa of haaardoua waate diapoaal The FPS Report doea not include a aintJle alternative which would cover all of the waate areas It a lao doea not include a cap or cover which aeeta the requireaenta described in the technical guidance docuaent referred to above

EPA determines ARARs and TBCs for a site The FFS Report ignorea both EPA 1 s previoua detellllination in the 1988 FS Report that RCRA vaa an ARAR tor thia aite and EPAs directive in ita May 10 1990 co-ent letter that RCRA ahould be conaidered an ARAR Since the 1988 PS EPA haa iaaued the technical guidance docuaent referred to above whiCh the -middot-shyRegion conaiders a TBC and which waa sent to Respondents When a atatute or regulation ia identified aa an ARAR a proposed re-dial action alternative auat attain auch AltAR absent a waiver purauant to CERCLA aection 12l(d)(4) (see also the NCP aection J00 400(f(1)(i)) Rather than proceed on the basis that RCRA ia an ARAR however

I I

I I

)

I I

I

Respondents used RCRA tor so11e but not all alternatives

When the FFS does consider RCRA landfill closure requir-nta an ARAR it deacribea hybrid closure as a aechaniaa for aatiafying the requireaent Hybrid closurebull has never been proaulgated bullbull a rule under RCRA The preallble to the NCP refers to the preaable of the earlier proposed NCP (53 PR 51446) for a cUacuseion of hybrid closurebull The preaable to the proposed NCP states that this type of closure is identical to landfill diapoaal closure except that the cover requirnts are relaxed because the wastes being contained do not pose a threat to 9round water At the Old Springfield Landfill the wastes clearly present a threat to groundwater Therefore the bullhybrid closurebull concept cannot be applied in a aannar that aatisfiea the RCRA landfill cloaure requirebullnta Only thoaa alternativebull which include a RCRA cap over all areaa where a RCRA cap ia relevant and appropriate can aatiaty ARARa

0

All of the alternativebull retained tor detailed evaluation in the FFS Report leave waate in place Therefore the RCRA haaardoua waata cloaure raquirnta bulluat be conaidered aa potential ARARa and the RCRA techni011l quidanca ahould be conaidared a TBC EPA no acceptable juatitication tor not conaiclering the RCRA haaardoua waate cloaura r89Ulationa aa relevant and appropriate

c a-dial ampotloa ObjaotlYeal

Reapondanta raviaad the readial action objectivebull in tbe FP8 Report A reviaion of redial action objectivebull waa not a requi~nt tor the PPS Report Alao the Reapondentabull reviaiona to the r~ial action objectivebull are baaed upon concluaiona generated bullbull a reault of the reviaad riak aaaeaaMnt which EPA conaidara unacceptable for the reaaona atated above in II A The raMclial action objectivebull preaanted in the 1988 ROD and 1990 SFS are the appropriate objectivebull for uaa in the FFS

III EValuation of Alternativebull

In the following discuaaion each of the aix alternativebull retained for detailed conaideration in tbe FFS b re-evaluated baaed upon the aaawaptiona EPA conaidera appropriate uaing the nina criteria liatad and daacribad in tha NCP These alternatives are nUIIbared 6 throuqh 11 in the Proposed Plan Section III of thia bulleaorandu will than provide

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

~~t~t~ bullbull tu~~cr~-tt=~~~lfdc~

1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

I I I

JJillbullrJ trl

If f( IbullI

I I

)

alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

)

landfill closure requireMnta are relevant and appropriate to the remedial action The 1988 FS indicates the presence of RCRA-liated hazardous wastes at the site In addition other aubatancea c1iapoaed of and found at the site are aiaUar to RCRA hazardous wastes Objectives of the reaedial action such aa preventinq the leaching of soil contaainanta to the groundwater and preventing the public contact with contaainated soil or leachate that aay present a risk are aiailar to the purposes of the RCRA hazardous waste landfill closure requireunta The source control operable unit ia itself aiailar to the closure activities requlated by the requireaents and the aediua to be addressed is aiailar to the aediua requlated by RCRA requireaenta

In certain areaa of tbe aite however the RCRA requirnta while relevant have been detenined not to be appropriate to the reaedial action The aide alopea alonq waate areaa 2 and l are autticiently ateep that a nlti-layer cap would not be auitable For the liaited area of the ateep aide alopea along waate areaa 2 and 3 EPA haa deterained that the RCRA hazardoua waate landfill closure requirnta are not appropriate

In addition to conaiderinq the RCRA landfill cloaure requirnta relevant and appropriate EPA alao conaidera the July 1989 Technical Guidance Docment Pinal Cevera on Hazardgye lletbull bullndfilla aMI lur(bullsbull lepoundMntbull a To Be Conaidered (TBC) criterion tor help in detemlnirMJ the protectiveneaa of alternativea Tbia fJUidance docuaent providu the technical baaia tor iapl~tation of the RCRA AltAR and r~a the uae of a nlti-layer cap vith natural and aynthetic -teriala To Het landfill cloaure requirnta the cap auat be placed over vaate areaa 2 J and 4 which are the identified areaa of haaardoua waate diapoaal The FPS Report doea not include a aintJle alternative which would cover all of the waate areas It a lao doea not include a cap or cover which aeeta the requireaenta described in the technical guidance docuaent referred to above

EPA determines ARARs and TBCs for a site The FFS Report ignorea both EPA 1 s previoua detellllination in the 1988 FS Report that RCRA vaa an ARAR tor thia aite and EPAs directive in ita May 10 1990 co-ent letter that RCRA ahould be conaidered an ARAR Since the 1988 PS EPA haa iaaued the technical guidance docuaent referred to above whiCh the -middot-shyRegion conaiders a TBC and which waa sent to Respondents When a atatute or regulation ia identified aa an ARAR a proposed re-dial action alternative auat attain auch AltAR absent a waiver purauant to CERCLA aection 12l(d)(4) (see also the NCP aection J00 400(f(1)(i)) Rather than proceed on the basis that RCRA ia an ARAR however

I I

I I

)

I I

I

Respondents used RCRA tor so11e but not all alternatives

When the FFS does consider RCRA landfill closure requir-nta an ARAR it deacribea hybrid closure as a aechaniaa for aatiafying the requireaent Hybrid closurebull has never been proaulgated bullbull a rule under RCRA The preallble to the NCP refers to the preaable of the earlier proposed NCP (53 PR 51446) for a cUacuseion of hybrid closurebull The preaable to the proposed NCP states that this type of closure is identical to landfill diapoaal closure except that the cover requirnts are relaxed because the wastes being contained do not pose a threat to 9round water At the Old Springfield Landfill the wastes clearly present a threat to groundwater Therefore the bullhybrid closurebull concept cannot be applied in a aannar that aatisfiea the RCRA landfill cloaure requirebullnta Only thoaa alternativebull which include a RCRA cap over all areaa where a RCRA cap ia relevant and appropriate can aatiaty ARARa

0

All of the alternativebull retained tor detailed evaluation in the FFS Report leave waate in place Therefore the RCRA haaardoua waata cloaure raquirnta bulluat be conaidered aa potential ARARa and the RCRA techni011l quidanca ahould be conaidared a TBC EPA no acceptable juatitication tor not conaiclering the RCRA haaardoua waate cloaura r89Ulationa aa relevant and appropriate

c a-dial ampotloa ObjaotlYeal

Reapondanta raviaad the readial action objectivebull in tbe FP8 Report A reviaion of redial action objectivebull waa not a requi~nt tor the PPS Report Alao the Reapondentabull reviaiona to the r~ial action objectivebull are baaed upon concluaiona generated bullbull a reault of the reviaad riak aaaeaaMnt which EPA conaidara unacceptable for the reaaona atated above in II A The raMclial action objectivebull preaanted in the 1988 ROD and 1990 SFS are the appropriate objectivebull for uaa in the FFS

III EValuation of Alternativebull

In the following discuaaion each of the aix alternativebull retained for detailed conaideration in tbe FFS b re-evaluated baaed upon the aaawaptiona EPA conaidera appropriate uaing the nina criteria liatad and daacribad in tha NCP These alternatives are nUIIbared 6 throuqh 11 in the Proposed Plan Section III of thia bulleaorandu will than provide

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

~~t~t~ bullbull tu~~cr~-tt=~~~lfdc~

1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

I I I

JJillbullrJ trl

If f( IbullI

I I

)

alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

)

I I

I

Respondents used RCRA tor so11e but not all alternatives

When the FFS does consider RCRA landfill closure requir-nta an ARAR it deacribea hybrid closure as a aechaniaa for aatiafying the requireaent Hybrid closurebull has never been proaulgated bullbull a rule under RCRA The preallble to the NCP refers to the preaable of the earlier proposed NCP (53 PR 51446) for a cUacuseion of hybrid closurebull The preaable to the proposed NCP states that this type of closure is identical to landfill diapoaal closure except that the cover requirnts are relaxed because the wastes being contained do not pose a threat to 9round water At the Old Springfield Landfill the wastes clearly present a threat to groundwater Therefore the bullhybrid closurebull concept cannot be applied in a aannar that aatisfiea the RCRA landfill cloaure requirebullnta Only thoaa alternativebull which include a RCRA cap over all areaa where a RCRA cap ia relevant and appropriate can aatiaty ARARa

0

All of the alternativebull retained tor detailed evaluation in the FFS Report leave waate in place Therefore the RCRA haaardoua waata cloaure raquirnta bulluat be conaidered aa potential ARARa and the RCRA techni011l quidanca ahould be conaidared a TBC EPA no acceptable juatitication tor not conaiclering the RCRA haaardoua waate cloaura r89Ulationa aa relevant and appropriate

c a-dial ampotloa ObjaotlYeal

Reapondanta raviaad the readial action objectivebull in tbe FP8 Report A reviaion of redial action objectivebull waa not a requi~nt tor the PPS Report Alao the Reapondentabull reviaiona to the r~ial action objectivebull are baaed upon concluaiona generated bullbull a reault of the reviaad riak aaaeaaMnt which EPA conaidara unacceptable for the reaaona atated above in II A The raMclial action objectivebull preaanted in the 1988 ROD and 1990 SFS are the appropriate objectivebull for uaa in the FFS

III EValuation of Alternativebull

In the following discuaaion each of the aix alternativebull retained for detailed conaideration in tbe FFS b re-evaluated baaed upon the aaawaptiona EPA conaidera appropriate uaing the nina criteria liatad and daacribad in tha NCP These alternatives are nUIIbared 6 throuqh 11 in the Proposed Plan Section III of thia bulleaorandu will than provide

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

~~t~t~ bullbull tu~~cr~-tt=~~~lfdc~

1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

I I I

JJillbullrJ trl

If f( IbullI

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)

alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

a compar ative ana lysis of a ll 11 alternatives considered i n the Pr oposed Plan

Alternatives 1 t hrough 5 are described in t he 1988 rs where they are evaluated baaed upon the ni ne criteria The cappi ng alternat i ve a lternat ive 2 i n the 1988 r s has been further eva l uated i n the 1990 SFS The 1990 SFS re-evaluated alternative 2 o f the 1988 PS in light of current si t e i nforat i on Al ternatives 3 4 a nd 5 ver a not re-eva l uated i n t he 1990 srs becauae the current ait e i n foraation doea not ampU94Jeampt that such a r eevaluation would a ffect the r eaedy s e lection ror the nine criteria evaluation of alte rnatives 1 through 5 the 1988 rs and 1990 srs ahould be consulted

Alternatiye 6 Uiated in the FFS bull bull altematiye 21 ranging tn4 Cqyerina of contaainoted Soila Thia alternative would entail covering s oils that pres ent an unacceptable cancer risk associated with direct contact and incidental inqeation of aoila contaainated with PCBe and PAHa A two foot cover of fill would be placed over an aru of approxitely 16 acrbullbull middot A 3500 ft chain link fence would be constructed around waste areabull 2 3 and 4 and the tarn seepa to

J prevent access to the s ite areas of concern Nothing would be done to

~~t~t~ bullbull tu~~cr~-tt=~~~lfdc~

1 OVerall prgtestion gf HuMP Health and the lnyimtJMnt Alte rnative 6 does not include a aurea to prevent the risks associated with ingeation of containated grounclwate r or inhalation of landfill 9aaea contai ning volatile orqanic coapounda (VOCs ) By not reducing the aobil ity of contaainanta i n the unaaturat ed zone alternative 6 c1oea not rec1uce the r iak poaed by the i ngest i on of gr oundwate r vhi ch ia contaainated A soil cover of unclassified fil l would not control landfill gas eaiaaiona in a aanner that would a llow for treataent of t he qaaea prior to release to the ataosphere Alternative 6 would address the risk associated with the direct contact with contaainated soils by covering those aite soils identified as representing an unacceptable lifetibulle cancer risk For the reasons stated abova - alternativa 6 is not protective of huan health and the environaent

2 Compliance with ARABSmiddot Alternative 6 would not coaply with the RCRA landfill closure requireaenta nor the TBC technical guidance It does not include a cover which meets the criteria listed in 40 CFR Part 264 Subparts G and N referred to in IIB above In particular

I I I

JJillbullrJ trl

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alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

I I

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alternative 6 does not provide for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide long-tara ainiaization of aiqration of liquids through the closed landfill In addition a soU cover is not conaiatent with the reconded design of a cover tor a hazardous waste landfill as described in the RCRA technical quidance docuent By not covering the entire plateau portion of the waste areas alternative 6 would fail to cover all of the areas subject to the ARAR Alternative 6 does not include aeaaurea to ensure the integrity of the aide slopes which are auaceptible to elope failure

3 lQna-terw ICCectiyeneea and Pwrynbullncbull The lOhCj-ten effectiveness and perunenca of alternative 6 is liaited by Hveral factors Firat the waste r ina in place rather than beint treated or reoved Second the lonq-ter atfectiveneaa and perunence ia dependant on the proper inatallation and aaintenanca of the fence and aoil cover Third alternative 6 doea not provide any urea to preclude the infiltration of water into contuinated aoil ancl the aubaaquant leachlft9 of contaainanta to the 9roundwatar Fourth alternative 6 includebull no featuru to aclclreaa the lOftl)-tera threat of alope failure on the ateep uatem aide alopea Finally alternative cs vould not addreaa the riaka aaaociated vith inhalation of landfill 9aa containinq voca

4 Btdygtion of Toxigity Mgbility and VPlllM tbrguqb TraatMnt Alternative 6 vould not involve any nduction in toxicity obility or voluaa throu9h treatnt

5 Sbort-tera Efftctiybullnbullbullbull middot No abort-tara iapactbull to the caunity conatruction workerbull or the anvironaent would be expected froa thia alternative Alternative 6 raliea upon natural tlushinq and natural degradation to achieve the remedial action objectives

6 Iwpleaentability Alternative 6 uses standard construction techniques and would be readily implementable

7 ~ Respondentsbull estiaated capital coat to ibullplebullent alternative 6 is 378000 The net present value of thia alternative is $510000 see the 1990 FFS for the detailed cost sheets for this alternative

8 state Acceptonce Will be addressed in the ROD follcwing the public comment period

9 Copupity Accaotanca Will ba addrassad in the ROD folloWlllCJ the public co-ent period

Alternatiye 7 lliatgd in thg FFS os alternative 3) Fgncinq Inwtallatiop of Sourca CQntrol Well and Coygrinq of Contawinotad Soil a Thibull alternative would include all of the eleaants of alternative 6 and adds the installation of a source control wall The source control well would be des iqned to rave containated groundwater froa the sand ancl vravel unit underneath waste area 3 This well would puap water into the groundwater treatnt sy1tea

1 OVerall Protection of HUMQ Health and the EnyimMept Alternative 7 takes liaited bullbullbullurea to prevent the ri1ka a1sociated with iDCJeltion of contaainated groundwater By not reducincJ the ability of contaainants in the unsatura t ed zone alternative 7 doebull not reduce the risk posed by the iftCJestion of groundwater which i s contaainated throuqh the continued aiqration of continanta Alternative 7 would address the risk associated with the direct contact with contaainated soils Alternat ive 7 takeamp no Maauraa to prevent the risks bullbullsociated with the inhalation of landfill tbull- containinv voca A soil cover of unclassified fill would not control landfill 901 ai11ion1 in a Mnner that vould allow for treatent of tbe 9a_ prior to release to tbe ataapbere The aource control vall llhould reduce tbe ability of contuinantbull in the sand and gravel unit beneath the va1te ar and thus contribute to a reduction in riska associated with the iDCJeamption of 9roundwater However for the reasons stated above alternative 7 ia not protective of hWNn health and the environaent

2 Cobullpliapce yith ARABSmiddot Alternative 7 would not coaply with the RCRA landfill closure requireaents nor the TBC technical quidance It does not include a cover which aeets the criteria lilted in 40 CFR Part 264 Subparts G and H referred to in IIB above In particular alternative 7 doebull not provi de for a cover that will have a peraeability lower than the natural soils below the waste nor would the cover provide lonq-tena 111ini111ization of 111igration of liquids throuqh the closed landfill In addition a soil cover is not consistent with the recoqanded desiqn f)f a ccwer for a hazardous waste landfill as described in the RCRA tachnical guidance docuaent By not covering the entire plateau portion of the waste areas alternative 7 would fail to cover all of the areas subject to the ARAR Alternative 7 does not include aeasures to ensure the inteqrity of the aide slopes which are susceptible to slope failure

J IQna-tto B(Ctgtiyanbullbullbull and fetaAnange The middotsource control well should be effective in reclucinq the aobility of contaainants in the deep qroundwater However the lonq-tera effectiveneaa and peraanence of alternative 7 ia liaited by the aaH factors described in alternative 6 In addition lonq-tera effectiveness of alternative 7 would also be dependent on the loll9-tera aaintenance of the source control well

4 Rtdugtion of Toxicity Mobility and yoluae through Trtatwant Alternative 7 would not involve any reduction in toxicity obility or volUie throu9h treataent except that voluaa and toxicity reduction achieved by treampting the extracted 9roundwater in the treatent syst constructed for the 1st operable unit

5 sbort-terw IC(tgtiyeneee No short-tem iapacts to the ~unity construction workers or the enviroftiMI1t would be expected fro this elternative Alternative 7 relies upon natural tluahinq and natural d84)radation for thbull ahallow groundwater to achieve the reaedial action objectives

0 6 Iaplebullntability Alternative 7 uaea standard construction

techniquu and would be readily iaplntable The construction of the source control vall would involve the use of state of the art drillift9 equi-nt

7 csta Respondentsbull estited capital coat to blpl-tt alternative 7 ia 495000 The net present value of thi8 alternative is $692000

8 state Acceptance Will be addressed in the ROD follovibCJ the public caaent period

9 CoMunity Acceptance Will be addressed in the ROD following the public couent period

Alternatiye 8 C1 isted in the FFS as alternatiye 5) Fencina Inetallation of Soyrca Control Well Soil Yioor Extraction Croa Waste Area 3 and Covorina contaainated Soi 1 Areaa outside of Waste Area 3 This alternative would include all of the elements of alternative 1 and adds the iapleaentation of a soil vapor extraction systea to remove VOCs froa the unsaturated soilwaste in waste area J Approxiaately 20shy25 vapor extraction Wtlls would be installed The deep wells would also rebullove shallow groundwater The gases withdrawn by the soil vapor systea would be treated to prevent the release ot contabullinants into the

10

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lti~ lt (bullI

J IQna-tto B(Ctgtiyanbullbullbull and fetaAnange The middotsource control well should be effective in reclucinq the aobility of contaainants in the deep qroundwater However the lonq-tera effectiveneaa and peraanence of alternative 7 ia liaited by the aaH factors described in alternative 6 In addition lonq-tera effectiveness of alternative 7 would also be dependent on the loll9-tera aaintenance of the source control well

4 Rtdugtion of Toxicity Mobility and yoluae through Trtatwant Alternative 7 would not involve any reduction in toxicity obility or volUie throu9h treataent except that voluaa and toxicity reduction achieved by treampting the extracted 9roundwater in the treatent syst constructed for the 1st operable unit

5 sbort-terw IC(tgtiyeneee No short-tem iapacts to the ~unity construction workers or the enviroftiMI1t would be expected fro this elternative Alternative 7 relies upon natural tluahinq and natural d84)radation for thbull ahallow groundwater to achieve the reaedial action objectives

0 6 Iaplebullntability Alternative 7 uaea standard construction

techniquu and would be readily iaplntable The construction of the source control vall would involve the use of state of the art drillift9 equi-nt

7 csta Respondentsbull estited capital coat to blpl-tt alternative 7 ia 495000 The net present value of thi8 alternative is $692000

8 state Acceptance Will be addressed in the ROD follovibCJ the public caaent period

9 CoMunity Acceptance Will be addressed in the ROD following the public couent period

Alternatiye 8 C1 isted in the FFS as alternatiye 5) Fencina Inetallation of Soyrca Control Well Soil Yioor Extraction Croa Waste Area 3 and Covorina contaainated Soi 1 Areaa outside of Waste Area 3 This alternative would include all of the elements of alternative 1 and adds the iapleaentation of a soil vapor extraction systea to remove VOCs froa the unsaturated soilwaste in waste area J Approxiaately 20shy25 vapor extraction Wtlls would be installed The deep wells would also rebullove shallow groundwater The gases withdrawn by the soil vapor systea would be treated to prevent the release ot contabullinants into the

10

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lti~ lt (bullI

)

air It is estiaated that 90-95 percent of the waste in waste area J is unsaturated Soil vapor extraction would decrease the concentrations of those contaainanta still in the waste above the water table

1 OV1roll Prot1ction of Hugo Health and thg Enyironwent Alternative B includes liaited Maaurea to prevent the riaka associated with inqeation of contaainated groundwater It would address the risk associated with the direct contact with contaainated soils It would also address the inhalation of landfill gases froa waste area 3 and would contribute to reduciDCJ containation in the unsaturated ampone thereby reducinq the risk frGa~ inqeation of containated ~tar froa waste area 3 The aource control well llhould reduce the JIObility of containanta in the aand and gravel unit bllneatb the waste ar and thus contribute to a reduction in riaka aaaociated with the invution of groundwater However alternative 8 would not include any aura to prevent the riak aaaociatecl with the inhalation of landfill gaHa fro waate areaa 2 and 4 A aoil cover of unclaaaitied fill would not control lancJtill gaa iaaiona in a aanner that would allov tor treataent of the gaaea prior to release to the ataoaphere For the reaaona atated above alternative 8 ia not protective of huaan health and the environaent

- 2 Cgwplianga yith ARABS Alternative 8 would not coply with the

~~f~~~ou~~=-=t=0~~~ri~r~~~~ fi~ ~~ 264 Subparta G and N referred to in IIB above In particular alternative 8 doea not provide tor a cover that will have a pereability lover than the natural aoila below the waate nor would the cover provide long-tara ainibullization of bulligration of liquidbull throu9h the cloaed landfill In addition a soil cover b not conaiatent with the reco-ended deaign of a cover tor a hazardous waste landfill aa deacribed in the RCRA technical 9Uidance docuant By not covering the entire plateau portion of the waate areas alternative 8 would tail to cover all of the areas aubjact to the ARAR Alternative 8 doea not include bulleaaures to ensure the integrity of the aide slopes which are susceptible to slope failure

J Long-term Efftctiytness and Perpanence The soil vapor extraction systebull should be effective in reducing the levels of VOCs in the unsaturated zone of waste area J The source control well should be effective in reducing the ability of contabullinants in the deep groundwater However the long-tara effectiveneaa and per11anence of alternative 8 is liaited by the saae factors described in alternatives 6 and 7 above except that alternative 8 would provide long-tara

11

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Itil lt~ (bullbull1

effectiveness with respect to the voca in the unsaturateltl zone of waste area 3

4 Reduction of Toxicity Mobility and VOluy through Traataent Alternative 8 would involve the reduction in voluae for waste area 3 through treatMnt using soil vapor extraction and vapor phase carbon No reduction of TMV would be achieved for wasta araaa 2 or 4 Scme reduction in THV would be achieved through the treataent of groundwater puaped froa the source control well into the aanag-nt of aigration traataent ayat

5 Shprt-tfm ICCectiyeneaa No abort-tar iJIPampCts to the coaunity construction workers or the environMnt would be expected troa this alternative Alternative 8 raliea upon natural fluahinq and natural dBCJradation to achieve the rSial action objectives for waste areas 2 and 4 soil vapor extraction would reduce the tiMfr required to achieve rebulledial action objectivebull in the leachate seep at wasta area 3

6 IEl-ntability Alternative 8 usea atancbrd conatruction techniques and would be readily iapleMntable for the soil cover Soil vapor extraction baa not been coonly uaed on aixed waste landfillo An initial pilot toot would be required to dotonoino tho proper apaciDCJ of extraction vella

7 ~ Respondents eatiuted capital coat to iQl_t alternative 1 is 1638000 The nat present value of this alternative ia $2514000

8 State Asceptance Will be addressecl in the ROD followinq the public co-ant period

9 Copynity Acceptance Will be addressed in the ROD following the public coDent period

Alternative 9 (listed in the FFS as alttrnatiye 6) Fencing Inatallation oc middot Sourct Control Well cappina of Waste Area 3 and Coytrina of contaainated soils outlide of Waste Area 3 This alternative would include fencing a source control well and a s acre cover over contaminated soil outside waste area 3 as described in source control alternative 7 It would a lao include the installation of a RCRA cap on the 2 5 acre plateau portion of waste area 3 The cap would include a passive soil venting ayatea and treataent of the collected gases

12

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fl(lI1 Oyeroll Protection ot Human Health and the Enyironwant

Alternative 9 would partially address the risks associatecl with ingestion of contaainatecl groundwater and inhalation of laJdfill qaaea contaainated by VOCs for waste area J It would address the risk associated with direct contact with contaainated soils for all waste areas Alternative 9 would also reduce the infiltration of water into waste area J which would prevent the continued contaaination of groundwater by contaainanta in the unsaturated zone The source control well would reduce the obility of contaaination in the aancl and gravel unit However alternative 9 does not inclucle aeaaurea vbich would control the lateral inflow of water into waste area J It would not prevent the aigration of water thouqh waste areaa 2 and 4 and would not addreaa the riaka associated with inqestion of qroundwater or inhalation of landfill gaaea contaainated by voca froa waate areaa 2 or 4 For the reaaona atated above alternative 9 would not be protective of huaan health and the environaent

2 Cowpliapgbull with ARABbullmiddot Alternative 9 would not fully coaply with ARAb Alternative 9 would aeet the RCRA 40 CFR 264310 Subpart N landfill cloaure requiruenta for waste area 3 only The aoil cover on

0 aelected areaa of waste areaa 2 and 4 would not bullet the RCRA landfill cloaure requirnta The aoil cover for areaa outaide vaate area 3 doea not t the criteria liateci in 40 CFR 264310 Subpart N vbich requirea that the cover be of a pereability lover than the natural aoila below the vaate and that it provide long-tam ainiaiaation of aiqration of liquida through the cloaed lanclfill Alao a aoil cover ia not conaiatent with the recaaended design of a cover for a baaardoua waate landfill aa deacribed in the TBC technical guidance docuaent The cap deacribed in alternative 9 contains aeveral deviationbull froa the cap described in the TBC technical quidance

J Lonq-tiQ Effectiyeness and PeQanence The lonq-tem effectiveness and penaanence of alternative 9 for waste areas 2 and 4 is liaited by the saae factors described in alternative 6 above Alternative 9 would not include measures to insure the inteqrity of the side slopes along waste areas 2 or 3 This could result in a failure of the cap The cap over waste area J would reduce the continued_aigration---middot of contamination frobull the unsaturated soilwaste zone into the groundwater

4 Reduction ot Toxicity Mobility and Volume through Treatment Alternative 9 would not involve any significant reduction in toxicity aobility or volume through treataent Some reduction in TMV would be

ll

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achieved through the treataent of groundwater puaped froa the source control well i nto the treataent systea constructed as part of the 1st operable unit

5 Short-tera Effgctiyanass No short-t8ra iapacts to the couunity construction workers or the environaent would be expected from this alternative Alternative 9 relies upon natural flushinq and natural degradation to achieve the reaedial action objectives at waste area 2 and 4

6 Jwpl-ntability Alternative 9 uses standard conatruction techniques and would be readily iaplentable

1 ~ Respondentsbull estiaated capital cost to iW~pl-nt alternative 9 is 1546000 The net present value of this alternative is $1888000

8 state Acceptance Will be addressed in the ROD following the public co-ant period

g cqpunity Agceptance Will be addressed in the ROD following the public c~t period

Alternatiye 10 (liated in the FFS II alternotiye 7) hnginal Jnetellation gf lgurgt Cgntml Well 1 ceppiM gC Vtata A[Mbull 3 end t and COYerina gf CQntoaiatecl leila gytaide gf hate Arg 3 lbis alternative would include all of the ele-nts of alternative 9 and adele the placent of a 2 2 acre RCRA Cap on waste area 4

1 OVe rall Prgtgctign of Hugo Heolth and tba EnyimQMpt Alternative 10 would partially address the risJta associated with ingestion of contaainatecl grounclvater and inhalation of lancltill gases contaainatecl by vocs for waste areas 3 and 4 It would address the risk associated with direct contact with contaainated s oils for all waste areas It would also reduce the infiltration of water into waste areas 3 and 4 which would prevent the continued contamination of groundwater by contaainants in the unsaturated zone The source control well would also recluce the aobility of contaainati9n in tbbull bulland and rayel unit However alternative 10 does not include measures which would control the lateral intlow of water into waste area 4 and does not fully control the lateral inflow of water into waste area 3 In addition alternative 10 would not prevent the aigration of water though waste area 2 and would not address the risks associated with ingestion ot groundwater or inhalation of landfill gases contabullinated by VOCs troa

IJi~ middot lt(rrIII

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effectiveness with respect to the voca in the unsaturateltl zone of waste area 3

4 Reduction of Toxicity Mobility and VOluy through Traataent Alternative 8 would involve the reduction in voluae for waste area 3 through treatMnt using soil vapor extraction and vapor phase carbon No reduction of TMV would be achieved for wasta araaa 2 or 4 Scme reduction in THV would be achieved through the treataent of groundwater puaped froa the source control well into the aanag-nt of aigration traataent ayat

5 Shprt-tfm ICCectiyeneaa No abort-tar iJIPampCts to the coaunity construction workers or the environMnt would be expected troa this alternative Alternative 8 raliea upon natural fluahinq and natural dBCJradation to achieve the rSial action objectives for waste areas 2 and 4 soil vapor extraction would reduce the tiMfr required to achieve rebulledial action objectivebull in the leachate seep at wasta area 3

6 IEl-ntability Alternative 8 usea atancbrd conatruction techniques and would be readily iapleMntable for the soil cover Soil vapor extraction baa not been coonly uaed on aixed waste landfillo An initial pilot toot would be required to dotonoino tho proper apaciDCJ of extraction vella

7 ~ Respondents eatiuted capital coat to iQl_t alternative 1 is 1638000 The nat present value of this alternative ia $2514000

8 State Asceptance Will be addressecl in the ROD followinq the public co-ant period

9 Copynity Acceptance Will be addressed in the ROD following the public coDent period

Alternative 9 (listed in the FFS as alttrnatiye 6) Fencing Inatallation oc middot Sourct Control Well cappina of Waste Area 3 and Coytrina of contaainated soils outlide of Waste Area 3 This alternative would include fencing a source control well and a s acre cover over contaminated soil outside waste area 3 as described in source control alternative 7 It would a lao include the installation of a RCRA cap on the 2 5 acre plateau portion of waste area 3 The cap would include a passive soil venting ayatea and treataent of the collected gases

12

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fl(lI1 Oyeroll Protection ot Human Health and the Enyironwant

Alternative 9 would partially address the risks associatecl with ingestion of contaainatecl groundwater and inhalation of laJdfill qaaea contaainated by VOCs for waste area J It would address the risk associated with direct contact with contaainated soils for all waste areas Alternative 9 would also reduce the infiltration of water into waste area J which would prevent the continued contaaination of groundwater by contaainanta in the unsaturated zone The source control well would reduce the obility of contaaination in the aancl and gravel unit However alternative 9 does not inclucle aeaaurea vbich would control the lateral inflow of water into waste area J It would not prevent the aigration of water thouqh waste areaa 2 and 4 and would not addreaa the riaka associated with inqestion of qroundwater or inhalation of landfill gaaea contaainated by voca froa waate areaa 2 or 4 For the reaaona atated above alternative 9 would not be protective of huaan health and the environaent

2 Cowpliapgbull with ARABbullmiddot Alternative 9 would not fully coaply with ARAb Alternative 9 would aeet the RCRA 40 CFR 264310 Subpart N landfill cloaure requiruenta for waste area 3 only The aoil cover on

0 aelected areaa of waste areaa 2 and 4 would not bullet the RCRA landfill cloaure requirnta The aoil cover for areaa outaide vaate area 3 doea not t the criteria liateci in 40 CFR 264310 Subpart N vbich requirea that the cover be of a pereability lover than the natural aoila below the vaate and that it provide long-tam ainiaiaation of aiqration of liquida through the cloaed lanclfill Alao a aoil cover ia not conaiatent with the recaaended design of a cover for a baaardoua waate landfill aa deacribed in the TBC technical guidance docuaent The cap deacribed in alternative 9 contains aeveral deviationbull froa the cap described in the TBC technical quidance

J Lonq-tiQ Effectiyeness and PeQanence The lonq-tem effectiveness and penaanence of alternative 9 for waste areas 2 and 4 is liaited by the saae factors described in alternative 6 above Alternative 9 would not include measures to insure the inteqrity of the side slopes along waste areas 2 or 3 This could result in a failure of the cap The cap over waste area J would reduce the continued_aigration---middot of contamination frobull the unsaturated soilwaste zone into the groundwater

4 Reduction ot Toxicity Mobility and Volume through Treatment Alternative 9 would not involve any significant reduction in toxicity aobility or volume through treataent Some reduction in TMV would be

ll

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achieved through the treataent of groundwater puaped froa the source control well i nto the treataent systea constructed as part of the 1st operable unit

5 Short-tera Effgctiyanass No short-t8ra iapacts to the couunity construction workers or the environaent would be expected from this alternative Alternative 9 relies upon natural flushinq and natural degradation to achieve the reaedial action objectives at waste area 2 and 4

6 Jwpl-ntability Alternative 9 uses standard conatruction techniques and would be readily iaplentable

1 ~ Respondentsbull estiaated capital cost to iW~pl-nt alternative 9 is 1546000 The net present value of this alternative is $1888000

8 state Acceptance Will be addressed in the ROD following the public co-ant period

g cqpunity Agceptance Will be addressed in the ROD following the public c~t period

Alternatiye 10 (liated in the FFS II alternotiye 7) hnginal Jnetellation gf lgurgt Cgntml Well 1 ceppiM gC Vtata A[Mbull 3 end t and COYerina gf CQntoaiatecl leila gytaide gf hate Arg 3 lbis alternative would include all of the ele-nts of alternative 9 and adele the placent of a 2 2 acre RCRA Cap on waste area 4

1 OVe rall Prgtgctign of Hugo Heolth and tba EnyimQMpt Alternative 10 would partially address the risJta associated with ingestion of contaainatecl grounclvater and inhalation of lancltill gases contaainatecl by vocs for waste areas 3 and 4 It would address the risk associated with direct contact with contaainated s oils for all waste areas It would also reduce the infiltration of water into waste areas 3 and 4 which would prevent the continued contamination of groundwater by contaainants in the unsaturated zone The source control well would also recluce the aobility of contaainati9n in tbbull bulland and rayel unit However alternative 10 does not include measures which would control the lateral intlow of water into waste area 4 and does not fully control the lateral inflow of water into waste area 3 In addition alternative 10 would not prevent the aigration of water though waste area 2 and would not address the risks associated with ingestion ot groundwater or inhalation of landfill gases contabullinated by VOCs troa

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fl(lI1 Oyeroll Protection ot Human Health and the Enyironwant

Alternative 9 would partially address the risks associatecl with ingestion of contaainatecl groundwater and inhalation of laJdfill qaaea contaainated by VOCs for waste area J It would address the risk associated with direct contact with contaainated soils for all waste areas Alternative 9 would also reduce the infiltration of water into waste area J which would prevent the continued contaaination of groundwater by contaainanta in the unsaturated zone The source control well would reduce the obility of contaaination in the aancl and gravel unit However alternative 9 does not inclucle aeaaurea vbich would control the lateral inflow of water into waste area J It would not prevent the aigration of water thouqh waste areaa 2 and 4 and would not addreaa the riaka associated with inqestion of qroundwater or inhalation of landfill gaaea contaainated by voca froa waate areaa 2 or 4 For the reaaona atated above alternative 9 would not be protective of huaan health and the environaent

2 Cowpliapgbull with ARABbullmiddot Alternative 9 would not fully coaply with ARAb Alternative 9 would aeet the RCRA 40 CFR 264310 Subpart N landfill cloaure requiruenta for waste area 3 only The aoil cover on

0 aelected areaa of waste areaa 2 and 4 would not bullet the RCRA landfill cloaure requirnta The aoil cover for areaa outaide vaate area 3 doea not t the criteria liateci in 40 CFR 264310 Subpart N vbich requirea that the cover be of a pereability lover than the natural aoila below the vaate and that it provide long-tam ainiaiaation of aiqration of liquida through the cloaed lanclfill Alao a aoil cover ia not conaiatent with the recaaended design of a cover for a baaardoua waate landfill aa deacribed in the TBC technical guidance docuaent The cap deacribed in alternative 9 contains aeveral deviationbull froa the cap described in the TBC technical quidance

J Lonq-tiQ Effectiyeness and PeQanence The lonq-tem effectiveness and penaanence of alternative 9 for waste areas 2 and 4 is liaited by the saae factors described in alternative 6 above Alternative 9 would not include measures to insure the inteqrity of the side slopes along waste areas 2 or 3 This could result in a failure of the cap The cap over waste area J would reduce the continued_aigration---middot of contamination frobull the unsaturated soilwaste zone into the groundwater

4 Reduction ot Toxicity Mobility and Volume through Treatment Alternative 9 would not involve any significant reduction in toxicity aobility or volume through treataent Some reduction in TMV would be

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IJilllbull=tJ rrlIbullI

achieved through the treataent of groundwater puaped froa the source control well i nto the treataent systea constructed as part of the 1st operable unit

5 Short-tera Effgctiyanass No short-t8ra iapacts to the couunity construction workers or the environaent would be expected from this alternative Alternative 9 relies upon natural flushinq and natural degradation to achieve the reaedial action objectives at waste area 2 and 4

6 Jwpl-ntability Alternative 9 uses standard conatruction techniques and would be readily iaplentable

1 ~ Respondentsbull estiaated capital cost to iW~pl-nt alternative 9 is 1546000 The net present value of this alternative is $1888000

8 state Acceptance Will be addressed in the ROD following the public co-ant period

g cqpunity Agceptance Will be addressed in the ROD following the public c~t period

Alternatiye 10 (liated in the FFS II alternotiye 7) hnginal Jnetellation gf lgurgt Cgntml Well 1 ceppiM gC Vtata A[Mbull 3 end t and COYerina gf CQntoaiatecl leila gytaide gf hate Arg 3 lbis alternative would include all of the ele-nts of alternative 9 and adele the placent of a 2 2 acre RCRA Cap on waste area 4

1 OVe rall Prgtgctign of Hugo Heolth and tba EnyimQMpt Alternative 10 would partially address the risJta associated with ingestion of contaainatecl grounclvater and inhalation of lancltill gases contaainatecl by vocs for waste areas 3 and 4 It would address the risk associated with direct contact with contaainated s oils for all waste areas It would also reduce the infiltration of water into waste areas 3 and 4 which would prevent the continued contamination of groundwater by contaainants in the unsaturated zone The source control well would also recluce the aobility of contaainati9n in tbbull bulland and rayel unit However alternative 10 does not include measures which would control the lateral intlow of water into waste area 4 and does not fully control the lateral inflow of water into waste area 3 In addition alternative 10 would not prevent the aigration of water though waste area 2 and would not address the risks associated with ingestion ot groundwater or inhalation of landfill gases contabullinated by VOCs troa

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achieved through the treataent of groundwater puaped froa the source control well i nto the treataent systea constructed as part of the 1st operable unit

5 Short-tera Effgctiyanass No short-t8ra iapacts to the couunity construction workers or the environaent would be expected from this alternative Alternative 9 relies upon natural flushinq and natural degradation to achieve the reaedial action objectives at waste area 2 and 4

6 Jwpl-ntability Alternative 9 uses standard conatruction techniques and would be readily iaplentable

1 ~ Respondentsbull estiaated capital cost to iW~pl-nt alternative 9 is 1546000 The net present value of this alternative is $1888000

8 state Acceptance Will be addressed in the ROD following the public co-ant period

g cqpunity Agceptance Will be addressed in the ROD following the public c~t period

Alternatiye 10 (liated in the FFS II alternotiye 7) hnginal Jnetellation gf lgurgt Cgntml Well 1 ceppiM gC Vtata A[Mbull 3 end t and COYerina gf CQntoaiatecl leila gytaide gf hate Arg 3 lbis alternative would include all of the ele-nts of alternative 9 and adele the placent of a 2 2 acre RCRA Cap on waste area 4

1 OVe rall Prgtgctign of Hugo Heolth and tba EnyimQMpt Alternative 10 would partially address the risJta associated with ingestion of contaainatecl grounclvater and inhalation of lancltill gases contaainatecl by vocs for waste areas 3 and 4 It would address the risk associated with direct contact with contaainated s oils for all waste areas It would also reduce the infiltration of water into waste areas 3 and 4 which would prevent the continued contamination of groundwater by contaainants in the unsaturated zone The source control well would also recluce the aobility of contaainati9n in tbbull bulland and rayel unit However alternative 10 does not include measures which would control the lateral intlow of water into waste area 4 and does not fully control the lateral inflow of water into waste area 3 In addition alternative 10 would not prevent the aigration of water though waste area 2 and would not address the risks associated with ingestion ot groundwater or inhalation of landfill gases contabullinated by VOCs troa

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wasta area 2 For the reasons stated above alterniltive 10 would not be protective of huaan health and the envirorent

2 Coaplionca with ARABbullmiddot Alternative 10 would not fully coaply with AltARs Alternative 10 would aeet the RCRA 40 CFR 264310 Subpart N landfill closure requirements for waste areas 3 and 4 only The soil cover on selected areas of waste area 2 would not aeet the RCRA landfill closure requirements The soil cover for areas outside waste areas 3 and 4 does not aeet the criteria listed in 40 CFR 264310 Subpart N which requires that the cover be of a pemeability lower than the natural eoila below the bullwaste and that it provide lonq-tem ainiaization of ai9ration of liquids throuCJh the closed landfill Also a soU cover i~ not consistent with the reconcled design of a cover for a haampardoua waate landfill aa described in the TBC technical quidance docult The cap deacribecl in alternative 10 containbull aeveral deviationbull troll the cap deacribecl in the TBC technical guidance

J Ipnq-tbullrw E(fectiyenaaa and Parunence The loDCJ-tem effectiveneaa and peraanence of alternative 10 for waate area 2 ia 11aitecl by the aaae factor deacribed in alternative 6 above Alternative 10 would not include bullbullbullurea to inaure the integrity of the aide alopea alonq vaate areaa 2 or J Tbia could rult in a failure of the cap Tha cap over waate areaa J and 4 would reduce the continued ai9ration of contaaination froa the unaaturatad aoilvaata 1one into the 9roundvater

4 Redygtion oC Toxicity IIQbUity and yolup thrgugh TrytMnt Alternative 10 would not involve a significant reduction in toxicity ability or voluaa through treataant bull Capping doea reduce the aobility of contaainanta in the unsaturatacl zona but not thrOUCJh treatant Soae reduction in IMV would ba achieved through the treataent of groundwater pupad frobull the aource control wall into the traataant systaa constructed as part ot the 1st operable unit

5 Short-tbullrw ECfectiyeness No short-term iapacts to the couunity construction workers or the environment would be expected trobull thb alternative

6 Iwplamentobility middot Alternative 10 ~S~-8 Standard construction techniques and would be readily ibullplementabla Capping is a coiiDionly used engineering practice

1 kQG Respondents eatiaated capital cost to bplement alternative 10 ia 2367000 The net present value of this alternative

15

is $2813000

8 stata Acceptance Will be addressed in the ROD f ollowi09 t he public co-ant ~riod

9 Cogunity Acceptance Will be addressed in the ROD following the public couaent period

Alternatiybull 11 lliattd in the PPS 01 alternatiye 9) PegciM J Inetollotign gf Soorca CQgtrol Wll CORRina g( Woete A[JI 3 yith RriMter 1lurry plll ap4 Cpyttina Q( ContpiMted Rpilt Pytefdt Q( Jlobulltbull Ana l Jhb alternative would include all of the el-ta of alternative 9 and actda the deaiqn and conatruction of a alurry wall around the peritar of vaata area 3 The vall would be a 900 ft lont 45 ft deap aolid barriar raducinq groundwater flow into the waata

1 OVarell Protection of HUMP Health eQ4 the lnyirgnunt Alternative 11 would addreaa the rbU aaaociatad with inc)eation of containated groundvatar and inhalation of landfill gaaea contaainated by voca tor vaata area 3 It would addreaa the riak eaaociated with direct contact with contaainatad aoila for all vaate araaa It would alao ltlduce the infiltration of water into vaate area 3 wbicb would prevent tiM continuad contaaination of 9roundwater by contaainante in the unturated aone be aource control vall would alao reduce the bullability of contaaination in the nd and 9Tave1 unit However alternative 11 would not pravent tha bulligration of water thOUCJh waate araaa Z and 4 and would not actdreaa the riaU aa~ampoeiatad with ingeation of groundwater or inhalation of landfill gaaea contabullinated by voca frobull waate areal 2 or 4 Por the reaaona attad above alternative 11 would not be protective of huaan health and the envirorment

2 Cobullpliance with ARABbullmiddot Alternative 11 would not fully COJIPlY with ARARs Alternative 11 would aeet the RCRA 40 CFR 264310 Subpart N landfill closure requirabullents for waste area 3 only The aoil cover on selected areaa of waata areas 2 and 4 would not aaet the RCRA landfill closure requirebullents The soil cover for areas outside wasta araa 3 does not meet the criteria listed in 40 CFR 264310 subpart N which requiras that the cqver be lf_ a perJ~eability lover than the naturl soilbull below the waste and that it provide lonq-tera bullinibullization of bulliqration of liquids through tha closad landfill Aho a soil cover ia not consistent with the reco-ended deaign of a cover for a hazardous wasta landfill as deacribed in tha TBC technical quidance docuent Tha cap described in altarnativa 11 contains several deviations frobull the cap described in the TBC tachnical quidance

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3 Lona Tara Ef(egtivane11 ond Ptrunbullnce The lonq-teB effectiveneaa and peraanenca of alternative 11 for waate areaa 2 anct 4 ia liaited by the aa factora deacribed in alte rnative 6 above Alternative 11 would not include Maaurea to inaure the inteqrity of the a ide alopea along waate areaa 2 or J Thia could reault in a failure of the cap A cap with a alurry wall would require long tara aaintenance to enaure the continued decreaae in aobility of contaainanta in the uns aturated zone The cap and alurry vall OYer vaate area l would effectively reduce the continued bull19Zation of contaaination froa the unsaturated aoilvaata ampone into the fJIOWdwater

4 Rl4ug11M in tpxicity llqbility or VOlUM thrguqh TVAMtmiddot Jbia alternative doea not -ploy treataent bullbull a tbod of reduciDCJ the toxicity IIObility or volue throuvh treatnt of the principle thrta at the aite SCMUCe control vella would be uaecS to extract 9roundvater froa the aand and 9ravel unit which would then be treatecS aa part of the aana9-nt of ai9Zation ayat CappincJ while reducincJ the IIObility of contaainanta by preventil9 the infiltration of water doebull not reduce the toxicity aobility or voluae through treatnt A aoil cover would not aatiafy thia criteria

5 aMa-yp IC(egtiyiJ)III No abort ter i~cta are expected fro the bpl_tation of thb alternative

6 rpt~tability lbe conatruction of the aoil cover cap and alurry vall involve the uae of COMan conatruction practicebull and would be ipl_table It aay be difficult to conatruct a alurry vall into the till at depthbull below 50 ft

1 ~ Reapondenta eatiuted capital coat for alternative 11 ia $ 2236000 The net preaent value of alternative 11 ia $ 2 579000

8 statbull Assaptonce State acceptance vill be addreaaed in the ROD following the public coM ent peri od

9 Copunity Acctptanct Couuni t y acceptance Will be addr e ssed i n the ROD d~_rinq_ th~ p~)gt~ic coent period

IV Coa parative Analyst

This section aakea comparisons aaong the eleven remedial alternatives in order to identify the relative advantaqes and disadvantages bullbullonq

17

is $2813000

8 stata Acceptance Will be addressed in the ROD f ollowi09 t he public co-ant ~riod

9 Cogunity Acceptance Will be addressed in the ROD following the public couaent period

Alternatiybull 11 lliattd in the PPS 01 alternatiye 9) PegciM J Inetollotign gf Soorca CQgtrol Wll CORRina g( Woete A[JI 3 yith RriMter 1lurry plll ap4 Cpyttina Q( ContpiMted Rpilt Pytefdt Q( Jlobulltbull Ana l Jhb alternative would include all of the el-ta of alternative 9 and actda the deaiqn and conatruction of a alurry wall around the peritar of vaata area 3 The vall would be a 900 ft lont 45 ft deap aolid barriar raducinq groundwater flow into the waata

1 OVarell Protection of HUMP Health eQ4 the lnyirgnunt Alternative 11 would addreaa the rbU aaaociatad with inc)eation of containated groundvatar and inhalation of landfill gaaea contaainated by voca tor vaata area 3 It would addreaa the riak eaaociated with direct contact with contaainatad aoila for all vaate araaa It would alao ltlduce the infiltration of water into vaate area 3 wbicb would prevent tiM continuad contaaination of 9roundwater by contaainante in the unturated aone be aource control vall would alao reduce the bullability of contaaination in the nd and 9Tave1 unit However alternative 11 would not pravent tha bulligration of water thOUCJh waate araaa Z and 4 and would not actdreaa the riaU aa~ampoeiatad with ingeation of groundwater or inhalation of landfill gaaea contabullinated by voca frobull waate areal 2 or 4 Por the reaaona attad above alternative 11 would not be protective of huaan health and the envirorment

2 Cobullpliance with ARABbullmiddot Alternative 11 would not fully COJIPlY with ARARs Alternative 11 would aeet the RCRA 40 CFR 264310 Subpart N landfill closure requirabullents for waste area 3 only The aoil cover on selected areaa of waata areas 2 and 4 would not aaet the RCRA landfill closure requirebullents The soil cover for areas outside wasta araa 3 does not meet the criteria listed in 40 CFR 264310 subpart N which requiras that the cqver be lf_ a perJ~eability lover than the naturl soilbull below the waste and that it provide lonq-tera bullinibullization of bulliqration of liquids through tha closad landfill Aho a soil cover ia not consistent with the reco-ended deaign of a cover for a hazardous wasta landfill as deacribed in tha TBC technical quidance docuent Tha cap described in altarnativa 11 contains several deviations frobull the cap described in the TBC tachnical quidance

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3 Lona Tara Ef(egtivane11 ond Ptrunbullnce The lonq-teB effectiveneaa and peraanenca of alternative 11 for waate areaa 2 anct 4 ia liaited by the aa factora deacribed in alte rnative 6 above Alternative 11 would not include Maaurea to inaure the inteqrity of the a ide alopea along waate areaa 2 or J Thia could reault in a failure of the cap A cap with a alurry wall would require long tara aaintenance to enaure the continued decreaae in aobility of contaainanta in the uns aturated zone The cap and alurry vall OYer vaate area l would effectively reduce the continued bull19Zation of contaaination froa the unsaturated aoilvaata ampone into the fJIOWdwater

4 Rl4ug11M in tpxicity llqbility or VOlUM thrguqh TVAMtmiddot Jbia alternative doea not -ploy treataent bullbull a tbod of reduciDCJ the toxicity IIObility or volue throuvh treatnt of the principle thrta at the aite SCMUCe control vella would be uaecS to extract 9roundvater froa the aand and 9ravel unit which would then be treatecS aa part of the aana9-nt of ai9Zation ayat CappincJ while reducincJ the IIObility of contaainanta by preventil9 the infiltration of water doebull not reduce the toxicity aobility or voluae through treatnt A aoil cover would not aatiafy thia criteria

5 aMa-yp IC(egtiyiJ)III No abort ter i~cta are expected fro the bpl_tation of thb alternative

6 rpt~tability lbe conatruction of the aoil cover cap and alurry vall involve the uae of COMan conatruction practicebull and would be ipl_table It aay be difficult to conatruct a alurry vall into the till at depthbull below 50 ft

1 ~ Reapondenta eatiuted capital coat for alternative 11 ia $ 2236000 The net preaent value of alternative 11 ia $ 2 579000

8 statbull Assaptonce State acceptance vill be addreaaed in the ROD following the public coM ent peri od

9 Copunity Acctptanct Couuni t y acceptance Will be addr e ssed i n the ROD d~_rinq_ th~ p~)gt~ic coent period

IV Coa parative Analyst

This section aakea comparisons aaong the eleven remedial alternatives in order to identify the relative advantaqes and disadvantages bullbullonq

17

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3 Lona Tara Ef(egtivane11 ond Ptrunbullnce The lonq-teB effectiveneaa and peraanenca of alternative 11 for waate areaa 2 anct 4 ia liaited by the aa factora deacribed in alte rnative 6 above Alternative 11 would not include Maaurea to inaure the inteqrity of the a ide alopea along waate areaa 2 or J Thia could reault in a failure of the cap A cap with a alurry wall would require long tara aaintenance to enaure the continued decreaae in aobility of contaainanta in the uns aturated zone The cap and alurry vall OYer vaate area l would effectively reduce the continued bull19Zation of contaaination froa the unsaturated aoilvaata ampone into the fJIOWdwater

4 Rl4ug11M in tpxicity llqbility or VOlUM thrguqh TVAMtmiddot Jbia alternative doea not -ploy treataent bullbull a tbod of reduciDCJ the toxicity IIObility or volue throuvh treatnt of the principle thrta at the aite SCMUCe control vella would be uaecS to extract 9roundvater froa the aand and 9ravel unit which would then be treatecS aa part of the aana9-nt of ai9Zation ayat CappincJ while reducincJ the IIObility of contaainanta by preventil9 the infiltration of water doebull not reduce the toxicity aobility or voluae through treatnt A aoil cover would not aatiafy thia criteria

5 aMa-yp IC(egtiyiJ)III No abort ter i~cta are expected fro the bpl_tation of thb alternative

6 rpt~tability lbe conatruction of the aoil cover cap and alurry vall involve the uae of COMan conatruction practicebull and would be ipl_table It aay be difficult to conatruct a alurry vall into the till at depthbull below 50 ft

1 ~ Reapondenta eatiuted capital coat for alternative 11 ia $ 2236000 The net preaent value of alternative 11 ia $ 2 579000

8 statbull Assaptonce State acceptance vill be addreaaed in the ROD following the public coM ent peri od

9 Copunity Acctptanct Couuni t y acceptance Will be addr e ssed i n the ROD d~_rinq_ th~ p~)gt~ic coent period

IV Coa parative Analyst

This section aakea comparisons aaong the eleven remedial alternatives in order to identify the relative advantaqes and disadvantages bullbullonq

17

them with respect to the 9 criteria

1 OVerall Protection of Huaan Health and the Environaent

Alternatives 2-5 would provide for overall protection of huaan health and the environaent by preventinq direct contact with contabullinated soils preventing the inhalation of contabullinanta in landfill gas and reducing the infiltration and underground aigration of water to prevent the continued leaching of contaainanta into the groundwater Alternative 1 the no action alternative would not ntiafy thia priteria nor would alternatives 6 through 11 1be no action alternative ctoea not include Maaures which provide for protection of huaan health and the environaent Alternatives 6 and 7 do not adc1reaa the potential riak aaaociatad with the inhalation of landfill CJbullbull uiaaiona for the entire aite Alternativu t and 11 do not adclrbullbullbull the potential riak froa inhalation of lanclfill 9bullbull aaiaaiona fr011 vaata areaa 2 and 4 Alternative 10 cloea not acldreaa the potential riak froa inhalation of landfill gaaea froa vaate area

2 Alternative 6 doea not reduce or control the riak poaed by inqeating contaainated groundwater or prevent the leaching of aoil contaainanta into the 9roundwater Alternativebull 7 and a do not prevent the infiltration of water which could contact contaainated

J waate or aoil and carry the contaaination into the 9rounclvatar Altarnativu t ancl 11 do not prevent the infiltration of vatar thrQU9h the unsaturated zona containirMJ contaainated aoiltvaata Alternativea 6-11 vould reduce the direct contact threat Alternativebull 6-11 and the no action alternative do not include aaurea to prevent the failure of the aide alopea

Of the alternativebull which aatiafy the firat criterion alternativebull 4 and 5 are the only onaa that would uae treataant which paraanently reduces the toxicity 110bility or voluae of the contaainanta Alternatives 2 and 3 would provide for the aiqnificant i-obilization of contaainants in the unsaturated zone Of the alternatives which leave the waste in place alternative 2 provides for the greatest degree of containaent of the wastes It is also the only alternative which leaves waste in place that considers the

_p_qtential failure of the side slopes and includes measures to prevent such a failure

2 Compliance with Applicable or Relevant and Appropriate Requirements ARARs)

Alternatives 2-5 would bulleat all ARARs Alternative 1 and

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alternativea 6-11 do not satisfy ARARa The soil cOver contemplated Iby alternatives 6-11 does not satisfy the RCRA requireaents for hazardous waste landfill closure Alternatives 6 through 11 do not include a cap on all three waste areas Of all the alternatives which would leave waste in place only alternative 2 would include a cover over the portions of the waste areas on the plateau subject to the RCRA closure regulations Alternative 2 also would involve construction of a cap consistent with RCRA technical guidance for final covers on hazardous waste landfills

3 bull Lonq-tera ffativenus and Peraanence

Alternative 1 and alternatives 6-11 would provide less long tera effectivanus and peraanence than alternatives 234 and 5 The lonq-tera effectiveness of alternative 2 is dependent upon the proper installation and aaintenance of the cap For alternatives 1 2 3 and 6 through 11 the waste would rebullain in place Whereas alternatives 4 and 5 it successfully iaplnted would provide greater loftCJ tara effectiveness becauu the waste would be treated or reaoved Alternative 8 would reduce the voluu of contaaination in the unHturated 1one tor waste area 3 which would have a siqnificant iJ~PBct on reducinq the level of VOCs in landfill gas bull

_ 4 Reduction of Toxicity Mobility or Voluae thrOQ9b treataent

Only alternatives 4 and 5 would achieve a significant reduction in volUM aobility or toxicity throu9h treataent Alternative 8 would reduce the volUM of contaaination in the unsaturated zone throu9h vacuua extraction and vapor phase carbon treataent An active gas collection ayat- included in alternative 2 would a lao achieve sae reduction in the volUIIe of the voca in the unsaturated zone through treataent of the collected 9ases Alternatives 1 3 and 6 would not reduce toxicity aobility or volllle throu9h treataent Alternatives 7-11 and alternative 2 would all reduce the aobility and voluae of contaainants in the deep 9roundwater through the use of source control well (a to pump contaminated groundwater to the leachate collection and treatment system

5 Short-taramiddot Effectiveness

All of the alternatives middotretained for detailed evaluation would be effective in the short-ten Because of the potential for the release of contaainanta during any excavation activities special en9ineering precautions would have to be taken to bullinimize the potential for

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contuinant eaiaaiona to enaure abort tara protection of vorkera and area reaidenta durin conatruction activitiea Alternative 2 would be coapleted in a aborter tiae fr than aource control alternativebull 3 through 5 Alternativea 6 and 7 would be conatructed in a aborter ti fraae than the other alternativea None of the alternativebull that would leave the waate in place would reault in the cleanup of the aite in a tiae frbull aiqnificantly aborter than any other alternative

6 Iaplntability

Alternative 2 and alternativebull 6 tbrou9b 11 would be iapleaentable becauae capa french draina and gaa colleCtion ayat are coonly uaed enqineerinq practicea Alternative 5 would involve the uee of an innovative technolOCJY (in-aitu vitrification) which would-require careful deaiqn atudiu Alternative 8 180il vapor extraction would require a pilot atu4y prior to full aale bpl~tation All the other aouroe control alternativu vould be ilopl-le ftle poaallgtle probl aeaociated vith the availability of clay uy requin the conaideration of alternative duipa for the cap Any altarnate deriqn vould be expected to achieve a level of perforaance equivalent to or exceedincJ the requir~ta liated in the ltCitA tecbnical 911idance docuaent Side alope atabilhetion -ld be difficult to ilopl-t in certain areaa or the eite ftle aide elope atabiliaation of waate area 3 would involve the uae of coaon

truction tecbniqu The aide alope atabiliaation of vaate area 2 -ld nvuino aono -lu -inMrini praotiou ftle oonetruotiOD or the fnonab dnoin to 25 fMt vould nvuino the UH Of -ialhed construction practiceamp

7 Coot

Alternativu 3 4 and 5 Bra auch aore expenaive than alternative 2 The coata for alternativebull 6 through 11 y be undereatited due to the lack of adequate controlbull relatinq to groundwater flov ancl aielbull alope atabilization Alternative 2 ia the leaat coatly of the alternativebull vbicb an adequately protective and attain AURa

8 State Acceptance

State acceptance vill be addreaaed in the ROD and deterained follovi9 the public couent periocl

20

middotmiddot

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9 Coamunity Acceptance

co-unity acceptance will be addressed in the ROD detenined durinq the public co-ent period

V Concl usion

Of the nine criterie protection of public health and copliance vith all ARARa are conaicSered the threshold requiranta that all reMdi auat et EPA bahncea the tradeoffamp UIOnCJ alternatives vith respect to lon-tena effectiveness and peraanence reduction of toxicity aobility or volWM throu9h treataent ahort-terll effectiveness i~leaentability and coat State and ~ity concerns are considered aa IIOdifyinq criteria factored into a final balancinq of all criteria to Hlect a r-edy

lhe tvo threaholcS criteria are deecribed in nction 300430 of the NCP AccordincJ to the NCP overall protection of huaan health ancS tbe environaent and COIIPlianc vith AltARS are the tvo criteria bullthat eaab alternative auat Met in order to be eliqible for aelection bull fte preallble to the Karch 1990 NCP states that bullthe r-cSy selection procaaa requires that alternativu auat ba deaonatrated to ba protective ancS ARAR-c011pliant (or juatify a waiver) in middotorder to ba eliqible for conaicSera tion in the balancinq proceaa by which the reedy is Hlected bull (NCP 55 FR 8726) Section 121 of CERCLA requires the selection of an alternative which is protective of huan health and the environaent anct attains ARARs

For any alternative to satisfy the first threshold criterion overall protection of huaan health and the envirom~ent at a ainiaua the three potential risks aentioned above bullust be acSdressed Any a~ternati_v4_ which results in leaving the waste in place aust include aeaaurea to prevent the leaching of soil contaainants to qroundwater prevent the release of landfill qasesbullcontaininq VOCs and prevent hUIIan contact with contaminated soil These measures aust be applied to waste areas 2 J and 4 At this tibulle there is no basis for assuming that the described risks relate to only certain waste areas

21

Baaed upon the cletailecS evaluation of alternativebull and coparative analybullibull of alternativebull EPA habull detenined that alternativebull 2 3 4 and 5 would ~ protective of huaan bealth and the anvironaent by preventinq direct contact with contaainatecl bulloilbull preventihC) the inhalation of contaainantbull in landfill qabull and reducihCJ the infiltration and underqround bulliqration of water to prevent the continued leaching of contabullinanta into the groundwater Alternatives 2-5 would et all ARARa

Aa deacribed above altemativu 6 throU9h 11 vbile retained for final conbullidera~ion in tbe PFS vould not aatibullfy the two threbullhold criteria if the proper bullbullbullUIIptiona were considered

22

1. barcode 580454
2. barcodetext SDMS Doc ID 580454

r(=tbullrtill

alternativea 6-11 do not satisfy ARARa The soil cOver contemplated Iby alternatives 6-11 does not satisfy the RCRA requireaents for hazardous waste landfill closure Alternatives 6 through 11 do not include a cap on all three waste areas Of all the alternatives which would leave waste in place only alternative 2 would include a cover over the portions of the waste areas on the plateau subject to the RCRA closure regulations Alternative 2 also would involve construction of a cap consistent with RCRA technical guidance for final covers on hazardous waste landfills

3 bull Lonq-tera ffativenus and Peraanence

Alternative 1 and alternatives 6-11 would provide less long tera effectivanus and peraanence than alternatives 234 and 5 The lonq-tera effectiveness of alternative 2 is dependent upon the proper installation and aaintenance of the cap For alternatives 1 2 3 and 6 through 11 the waste would rebullain in place Whereas alternatives 4 and 5 it successfully iaplnted would provide greater loftCJ tara effectiveness becauu the waste would be treated or reaoved Alternative 8 would reduce the voluu of contaaination in the unHturated 1one tor waste area 3 which would have a siqnificant iJ~PBct on reducinq the level of VOCs in landfill gas bull

_ 4 Reduction of Toxicity Mobility or Voluae thrOQ9b treataent

Only alternatives 4 and 5 would achieve a significant reduction in volUM aobility or toxicity throu9h treataent Alternative 8 would reduce the volUM of contaaination in the unsaturated zone throu9h vacuua extraction and vapor phase carbon treataent An active gas collection ayat- included in alternative 2 would a lao achieve sae reduction in the volUIIe of the voca in the unsaturated zone through treataent of the collected 9ases Alternatives 1 3 and 6 would not reduce toxicity aobility or volllle throu9h treataent Alternatives 7-11 and alternative 2 would all reduce the aobility and voluae of contaainants in the deep 9roundwater through the use of source control well (a to pump contaminated groundwater to the leachate collection and treatment system

5 Short-taramiddot Effectiveness

All of the alternatives middotretained for detailed evaluation would be effective in the short-ten Because of the potential for the release of contaainanta during any excavation activities special en9ineering precautions would have to be taken to bullinimize the potential for

19

I I

I

JJj~ middot

contuinant eaiaaiona to enaure abort tara protection of vorkera and area reaidenta durin conatruction activitiea Alternative 2 would be coapleted in a aborter tiae fr than aource control alternativebull 3 through 5 Alternativea 6 and 7 would be conatructed in a aborter ti fraae than the other alternativea None of the alternativebull that would leave the waate in place would reault in the cleanup of the aite in a tiae frbull aiqnificantly aborter than any other alternative

6 Iaplntability

Alternative 2 and alternativebull 6 tbrou9b 11 would be iapleaentable becauae capa french draina and gaa colleCtion ayat are coonly uaed enqineerinq practicea Alternative 5 would involve the uee of an innovative technolOCJY (in-aitu vitrification) which would-require careful deaiqn atudiu Alternative 8 180il vapor extraction would require a pilot atu4y prior to full aale bpl~tation All the other aouroe control alternativu vould be ilopl-le ftle poaallgtle probl aeaociated vith the availability of clay uy requin the conaideration of alternative duipa for the cap Any altarnate deriqn vould be expected to achieve a level of perforaance equivalent to or exceedincJ the requir~ta liated in the ltCitA tecbnical 911idance docuaent Side alope atabilhetion -ld be difficult to ilopl-t in certain areaa or the eite ftle aide elope atabiliaation of waate area 3 would involve the uae of coaon

truction tecbniqu The aide alope atabiliaation of vaate area 2 -ld nvuino aono -lu -inMrini praotiou ftle oonetruotiOD or the fnonab dnoin to 25 fMt vould nvuino the UH Of -ialhed construction practiceamp

7 Coot

Alternativu 3 4 and 5 Bra auch aore expenaive than alternative 2 The coata for alternativebull 6 through 11 y be undereatited due to the lack of adequate controlbull relatinq to groundwater flov ancl aielbull alope atabilization Alternative 2 ia the leaat coatly of the alternativebull vbicb an adequately protective and attain AURa

8 State Acceptance

State acceptance vill be addreaaed in the ROD and deterained follovi9 the public couent periocl

20

middotmiddot

IJir=tlrr

I

9 Coamunity Acceptance

co-unity acceptance will be addressed in the ROD detenined durinq the public co-ent period

V Concl usion

Of the nine criterie protection of public health and copliance vith all ARARa are conaicSered the threshold requiranta that all reMdi auat et EPA bahncea the tradeoffamp UIOnCJ alternatives vith respect to lon-tena effectiveness and peraanence reduction of toxicity aobility or volWM throu9h treataent ahort-terll effectiveness i~leaentability and coat State and ~ity concerns are considered aa IIOdifyinq criteria factored into a final balancinq of all criteria to Hlect a r-edy

lhe tvo threaholcS criteria are deecribed in nction 300430 of the NCP AccordincJ to the NCP overall protection of huaan health ancS tbe environaent and COIIPlianc vith AltARS are the tvo criteria bullthat eaab alternative auat Met in order to be eliqible for aelection bull fte preallble to the Karch 1990 NCP states that bullthe r-cSy selection procaaa requires that alternativu auat ba deaonatrated to ba protective ancS ARAR-c011pliant (or juatify a waiver) in middotorder to ba eliqible for conaicSera tion in the balancinq proceaa by which the reedy is Hlected bull (NCP 55 FR 8726) Section 121 of CERCLA requires the selection of an alternative which is protective of huan health and the environaent anct attains ARARs

For any alternative to satisfy the first threshold criterion overall protection of huaan health and the envirom~ent at a ainiaua the three potential risks aentioned above bullust be acSdressed Any a~ternati_v4_ which results in leaving the waste in place aust include aeaaurea to prevent the leaching of soil contaainants to qroundwater prevent the release of landfill qasesbullcontaininq VOCs and prevent hUIIan contact with contaminated soil These measures aust be applied to waste areas 2 J and 4 At this tibulle there is no basis for assuming that the described risks relate to only certain waste areas

21

Baaed upon the cletailecS evaluation of alternativebull and coparative analybullibull of alternativebull EPA habull detenined that alternativebull 2 3 4 and 5 would ~ protective of huaan bealth and the anvironaent by preventinq direct contact with contaainatecl bulloilbull preventihC) the inhalation of contaainantbull in landfill qabull and reducihCJ the infiltration and underqround bulliqration of water to prevent the continued leaching of contabullinanta into the groundwater Alternatives 2-5 would et all ARARa

Aa deacribed above altemativu 6 throU9h 11 vbile retained for final conbullidera~ion in tbe PFS vould not aatibullfy the two threbullhold criteria if the proper bullbullbullUIIptiona were considered

22

1. barcode 580454
2. barcodetext SDMS Doc ID 580454

contuinant eaiaaiona to enaure abort tara protection of vorkera and area reaidenta durin conatruction activitiea Alternative 2 would be coapleted in a aborter tiae fr than aource control alternativebull 3 through 5 Alternativea 6 and 7 would be conatructed in a aborter ti fraae than the other alternativea None of the alternativebull that would leave the waate in place would reault in the cleanup of the aite in a tiae frbull aiqnificantly aborter than any other alternative

6 Iaplntability

Alternative 2 and alternativebull 6 tbrou9b 11 would be iapleaentable becauae capa french draina and gaa colleCtion ayat are coonly uaed enqineerinq practicea Alternative 5 would involve the uee of an innovative technolOCJY (in-aitu vitrification) which would-require careful deaiqn atudiu Alternative 8 180il vapor extraction would require a pilot atu4y prior to full aale bpl~tation All the other aouroe control alternativu vould be ilopl-le ftle poaallgtle probl aeaociated vith the availability of clay uy requin the conaideration of alternative duipa for the cap Any altarnate deriqn vould be expected to achieve a level of perforaance equivalent to or exceedincJ the requir~ta liated in the ltCitA tecbnical 911idance docuaent Side alope atabilhetion -ld be difficult to ilopl-t in certain areaa or the eite ftle aide elope atabiliaation of waate area 3 would involve the uae of coaon

truction tecbniqu The aide alope atabiliaation of vaate area 2 -ld nvuino aono -lu -inMrini praotiou ftle oonetruotiOD or the fnonab dnoin to 25 fMt vould nvuino the UH Of -ialhed construction practiceamp

7 Coot

Alternativu 3 4 and 5 Bra auch aore expenaive than alternative 2 The coata for alternativebull 6 through 11 y be undereatited due to the lack of adequate controlbull relatinq to groundwater flov ancl aielbull alope atabilization Alternative 2 ia the leaat coatly of the alternativebull vbicb an adequately protective and attain AURa

8 State Acceptance

State acceptance vill be addreaaed in the ROD and deterained follovi9 the public couent periocl

20

middotmiddot

IJir=tlrr

I

9 Coamunity Acceptance

co-unity acceptance will be addressed in the ROD detenined durinq the public co-ent period

V Concl usion

Of the nine criterie protection of public health and copliance vith all ARARa are conaicSered the threshold requiranta that all reMdi auat et EPA bahncea the tradeoffamp UIOnCJ alternatives vith respect to lon-tena effectiveness and peraanence reduction of toxicity aobility or volWM throu9h treataent ahort-terll effectiveness i~leaentability and coat State and ~ity concerns are considered aa IIOdifyinq criteria factored into a final balancinq of all criteria to Hlect a r-edy

lhe tvo threaholcS criteria are deecribed in nction 300430 of the NCP AccordincJ to the NCP overall protection of huaan health ancS tbe environaent and COIIPlianc vith AltARS are the tvo criteria bullthat eaab alternative auat Met in order to be eliqible for aelection bull fte preallble to the Karch 1990 NCP states that bullthe r-cSy selection procaaa requires that alternativu auat ba deaonatrated to ba protective ancS ARAR-c011pliant (or juatify a waiver) in middotorder to ba eliqible for conaicSera tion in the balancinq proceaa by which the reedy is Hlected bull (NCP 55 FR 8726) Section 121 of CERCLA requires the selection of an alternative which is protective of huan health and the environaent anct attains ARARs

For any alternative to satisfy the first threshold criterion overall protection of huaan health and the envirom~ent at a ainiaua the three potential risks aentioned above bullust be acSdressed Any a~ternati_v4_ which results in leaving the waste in place aust include aeaaurea to prevent the leaching of soil contaainants to qroundwater prevent the release of landfill qasesbullcontaininq VOCs and prevent hUIIan contact with contaminated soil These measures aust be applied to waste areas 2 J and 4 At this tibulle there is no basis for assuming that the described risks relate to only certain waste areas

21

Baaed upon the cletailecS evaluation of alternativebull and coparative analybullibull of alternativebull EPA habull detenined that alternativebull 2 3 4 and 5 would ~ protective of huaan bealth and the anvironaent by preventinq direct contact with contaainatecl bulloilbull preventihC) the inhalation of contaainantbull in landfill qabull and reducihCJ the infiltration and underqround bulliqration of water to prevent the continued leaching of contabullinanta into the groundwater Alternatives 2-5 would et all ARARa

Aa deacribed above altemativu 6 throU9h 11 vbile retained for final conbullidera~ion in tbe PFS vould not aatibullfy the two threbullhold criteria if the proper bullbullbullUIIptiona were considered

22

1. barcode 580454
2. barcodetext SDMS Doc ID 580454

9 Coamunity Acceptance

co-unity acceptance will be addressed in the ROD detenined durinq the public co-ent period

V Concl usion

Of the nine criterie protection of public health and copliance vith all ARARa are conaicSered the threshold requiranta that all reMdi auat et EPA bahncea the tradeoffamp UIOnCJ alternatives vith respect to lon-tena effectiveness and peraanence reduction of toxicity aobility or volWM throu9h treataent ahort-terll effectiveness i~leaentability and coat State and ~ity concerns are considered aa IIOdifyinq criteria factored into a final balancinq of all criteria to Hlect a r-edy

lhe tvo threaholcS criteria are deecribed in nction 300430 of the NCP AccordincJ to the NCP overall protection of huaan health ancS tbe environaent and COIIPlianc vith AltARS are the tvo criteria bullthat eaab alternative auat Met in order to be eliqible for aelection bull fte preallble to the Karch 1990 NCP states that bullthe r-cSy selection procaaa requires that alternativu auat ba deaonatrated to ba protective ancS ARAR-c011pliant (or juatify a waiver) in middotorder to ba eliqible for conaicSera tion in the balancinq proceaa by which the reedy is Hlected bull (NCP 55 FR 8726) Section 121 of CERCLA requires the selection of an alternative which is protective of huan health and the environaent anct attains ARARs

For any alternative to satisfy the first threshold criterion overall protection of huaan health and the envirom~ent at a ainiaua the three potential risks aentioned above bullust be acSdressed Any a~ternati_v4_ which results in leaving the waste in place aust include aeaaurea to prevent the leaching of soil contaainants to qroundwater prevent the release of landfill qasesbullcontaininq VOCs and prevent hUIIan contact with contaminated soil These measures aust be applied to waste areas 2 J and 4 At this tibulle there is no basis for assuming that the described risks relate to only certain waste areas

21

Baaed upon the cletailecS evaluation of alternativebull and coparative analybullibull of alternativebull EPA habull detenined that alternativebull 2 3 4 and 5 would ~ protective of huaan bealth and the anvironaent by preventinq direct contact with contaainatecl bulloilbull preventihC) the inhalation of contaainantbull in landfill qabull and reducihCJ the infiltration and underqround bulliqration of water to prevent the continued leaching of contabullinanta into the groundwater Alternatives 2-5 would et all ARARa

Aa deacribed above altemativu 6 throU9h 11 vbile retained for final conbullidera~ion in tbe PFS vould not aatibullfy the two threbullhold criteria if the proper bullbullbullUIIptiona were considered

22

1. barcode 580454
2. barcodetext SDMS Doc ID 580454

Baaed upon the cletailecS evaluation of alternativebull and coparative analybullibull of alternativebull EPA habull detenined that alternativebull 2 3 4 and 5 would ~ protective of huaan bealth and the anvironaent by preventinq direct contact with contaainatecl bulloilbull preventihC) the inhalation of contaainantbull in landfill qabull and reducihCJ the infiltration and underqround bulliqration of water to prevent the continued leaching of contabullinanta into the groundwater Alternatives 2-5 would et all ARARa

Aa deacribed above altemativu 6 throU9h 11 vbile retained for final conbullidera~ion in tbe PFS vould not aatibullfy the two threbullhold criteria if the proper bullbullbullUIIptiona were considered

22

1. barcode 580454
2. barcodetext SDMS Doc ID 580454