SDMS US EPA REGION V -1

SOME IMAGES WITHIN THISDOCUMENT MAY BE ILLEGIBLE

DUE TO BAD SOURCEDOCUMENTS.

OOOtO:

RECORD OF DECISIONOPERABLE UNIT #4

FLOODPLAINS/WETLANDS AREAFIELDS BROOK SITE, ASHTABULA OHIO

OUTLINE

DECLARATION FOR THE RECORD OF DECISION........... p. it

RECORD OF DECISION SUMMARY........................ p. 1I. SITE NAME, LOCATION, AND DESCRIPTION........ p. 1II. SITE HISTORY AND ENFORCEMENT ACTIVITIES..... p. 2III. HIGHLIGHTS OF COMMUNITY PARTICIPATION. ...... p. 3IV. SUMMARY OF SITE CHARACTERISTICS............. p, 4

A) Overview................................. p. 5B) FWA Exposure Units....................... p. 6C) Summary of Sampling Data................. p. 7D) Soil Sampling Data Summary............... p. 8E) Summary of Soils Data for FEU 2.......... p. 9F) Summary of Soils Data for FEU 3.......... p. 10G) Summary of Soils Data for FEU 4.......... p. 10H) Summary of Soils Data for FEU 6.......... p. 11I) Summary of Soils Data for FEU 8.......... p. 12

V. HUMAN HEALTH RISK ASSESSMENT ............... p. 12A) Chemicals of Concern. ..................... p. 12B) Exposure Assessment..;................... p. 13C) Human Health Risk Assessment............. p. 14

VI. ECOLOGICAL RISK ASSESSMENT ................. p. 17VII. SCOPE OF THE SELECTED REMEDY ............... P. 17VIII. DESCRIPTION OF ALTERNATIVES:................ p. 17

A) Overview and Discussion.................. p. 17B) Alternative Listing...................... p. 20

I.. SUMMARY OF COMPARATIVE EVALUATION OFALTERNATIVES ........................... p. 23

A) THRESHOLD CRITERIA....................... p. 24B) PRIMARY BALANCING CRITERIA............... p. 27C) MODIFYING CRITERIA....................... p. 29

.. THE SELECTED REMEDY.......................... p. 31A) Detailed Requirements of the

Selected Remedy........................ p. 311) Remedial Action Objectives and

Cleanup Goals..................... p. 312) Excavation, Cover, and Disposal

Requirements ...................... p. 343) Landfill Requirements............... p. 344) Post-Cleanup Sampling Requirements., p. 355) Remedial Activity Locations......... p. 366) Other Requirements.................. p. 37

B) ARARs to be Met.......................... p. 38.I. EXPLANATION OF SIGNIFICANT CHANGES. ......... P./ 41.II. STATUTORY DETERMINATIONS.................... p * 41

ATTACHMENT 1: RESPONSIVENESS SUMMARY.............. p. 42I. Comments to 11/96 FWA Proposed Plan..... p. 42

A) Written Comments................... p. 42B) Verbal Comments.................... p. 58

II. Comments to U.S. EPA's 10/96Ecological Risk Assessment............ p. 63

III. Comments to EPA's FWA Human Health

Risk Assessment....................... p. 69IV. Comments to the "Development of the

Cleanup Goals {CUGs}" Section of EPA'sFWA Human Health Risk Assessment...... p. 76

V. Comments to the FWA RemedialInvestigation Report.................. p. 77

FIGURES:Figure 1Figure 2Figure 3Figure 4Figure 5Figure 6Figure 7Figure 8Figure 9

TABLES:Table 1-1Table 1-2Table 1-3Table 1-4Table 1-5Table 2-1Table 2-2Table 2-3Table 2-4Table 3:Table 4-1Table 4-2Table 4-5

Table 5:

Fields Brook Superfund siteReaches and Exposure Units of Fields BrookFEU 2-A Response AreasFEU 2-B Response AreasFEU 3 Response AreasFEU 4 Response AreasFEU 6 Response AreasFEU 8 Response AreasOn-Site Landfill Cross-Section

Summary of Soils Data for FEU 2Summary of Soils Data for FEU 3Summary of Soils Data for FEU 4Summary of Soils Data for FEU 6Summary of Soils Data for FEU 8FWA CUGs: Residential CarcinogenFWA CUGs: Residential Non-CarcinogenFWA CUGs: Industrial CarcinogenFWA CUGs: Industrial Non-CarcinogenFWA Human Health and Ecological COCsLocation-specific ARARsAction-specific ARARsDischarge Limitations to Surface Water and theCity of Ashtabula POTWFWA Alternative Evaluation

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AMD LOCATION

Fields Brook Site, Operable Unit IV, Floodplains/Wetlands Area,Ashtabula , Ohio

STATEMENT OP BASIS AND PURPOSE

This decision document represents the selected Final RemedialAction for the Fields Brook Site, Operable Unit IV(Floodplains/Wetlands Area) , in Ashtabula, Ohio. This action waschosen in accordance with the Comprehensive EnvironmentalResponse, Compensation and Liability Act of 1980 (CERCLA) , asamended by the Superfund Amendments and Reauthorization Act of1986 (SARA) , and to the extent practicable, with the National Oiland Hazardous Substances Contingency Plan (NCP) . The decisionscontained herein are based on information contained in theadministrative record for this site.

The State of Ohio does not concur with the selected remedy. Thenon- concurrence letter is attached to this Declaration.

ASSESSMENT OF THE REMEDY

Actual or threatened releases of hazardous substances from thesite, if not addressed by implementing the response actionselected in this Record of Decision (ROD) , may present animminent and substantial endangerment to public health, welfare,or the environment.

DESCRIPTION OF THE

This remedy is intended to be the final action for Operable UnitIV {Floodplains/Wetlands Area, "FWA") of this site. This finalaction includes excavation and on-site containment ofcontaminated soils and sediments; backfilling and revegetation inthe FWA; installing a cover in certain areas of the FWA; removalof trees; operation and maintenance and post closure care of thecover and containment facility; imposition of institutionalcontrols; and future monitoring. This final action addresses themigration pathways of incidental ingestion of FWA soil andsediments and dermal absorption of contaminants in FWA soil andsediments .

/The major components of the selected remedy include:

Excavation or cover of contaminated soils and sediments inthe FWA that exceed cleanup action levels; backfill of allexcavation and cover areas with hydric- compatible soils;

•— T —

Removal of all trees in excavation areas, and removalof all trees below 12" diameter at basal height (dbh)in cover areas, with vegetation in response areasconsidered contaminated, and with live vegetation aboveground surface considered clean if it can bedecontaminated;

Revegetation of all backfill and cover areas, andrevegetation of all areas disturbed duringconstruction, using erosion mats and native vegetation;

Construction of a temporary access road to allow access toand along the FWA from the roadways during construction,made of crushed stone and 1/4-inch thick geonet liner, andto be removed after construction and disposed of either inthe on-site landfill or if clean in other on-site or off-site areas;

Consolidatipn of excavated soils and sediments,construction debris, and roadways constructed toimplement the remedy if determined to be contaminated,within an on-site fenced-in containment cell (landfill)to be built on one of the industrial properties locatedwithin the Fields Brook watershed;

Construction of a minimum of three downgradient wellsand one upgradient well to monitor the long-termeffectiveness of the landfill;

Long term operation and maintenance and post closure care ofthe remedial action to help ensure its effectiveness;

Long term monitoring including sampling of FWA surface soilsand sediments, and backfill and cover areas, and monitoringof wetland conditions at specific locations and forparameters defined in the Record of Decision Summary, toverify the effectiveness of the remedial action;

Placement of institutional controls on deeds and title forproperties where: contamination will remain in the FWA; thelandfill will be constructed; or hazardous substances,pollutants or contaminants will remain above levels thatallow for unlimited use and unrestricted exposure. For thelandfill, the deed restrictions must prevent residential,industrial or other development on the landfill./ For allother properties, the deed restrictions must provide noticeto any subsequent purchaser or prospective developer of thepresence of hazardous substances and of the requirement toconduct all development activities in such a manner as tonot release contamination towards Fields Brook; and

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Implementation of access restrictions, including enclosingthe entire landfill area with a fence and posted warningsigns.

STATUTORY DETERMINATIONS

This final Remedial Action is protective of human health and theenvironment, complies with Federal and State applicable orrelevant and appropriate requirements and is cost-effective. Theselected remedial action utilizes permanent solutions andconsidered use of alternative treatment technologies to themaximum extent practicable. However, due to the significantvolume and heterogeneous distribution of waste at the Site,treatment as a principle element is not considered practicable atthe Site. Thus, this remedy does not address the statutorypreference for treatment that reduces toxicity, mobility, orvolume as a principal element. However, treatment is a secondaryelement in that landfill leachate liquids will be collected andtreated resulting in destruction of hazardous substances.

A review of the remedy will be conducted five years aftercommencement of the remedial action to ensure that the remedycontinues to provide adequate protection of human health and theenvironment.

30. Sff?Date David A. Ullrich

Acting Regional Administrator

OhtaB*SUtc ot Ohio Buviittnmttibt Prorwtion Ag*ncy

MM *g iraaui- *u-xac MX. <«H) •*< a»» P.O. Box 1049

Commixa, OH 43215-1099 Cohtrnbu*, OH 43216-1040

RE: Field:* Brook Superftmd SiteFloodplatn/WetlanOhio EPA ID# 20Aahtabula County

T in ,Q07 Floodplatn/Wetland AreaJune I0* 1997 Ohio EPA ID# 204-0300

Valdas V. AdamkusRegional DirectorUSEPA Region V77 We»t Jackson Blvd.Chicago, IL 60604

Dear Mr. Adaraku*:

This letter is in response to the Record of Decision (ROD) for the floodplain / wetland areaoperable unit (FWA) of the Fields Broolr Superfund Site in Ashtobulo County, Ohio.

Th« State of Ohio has expressed concerns about the selected remedy tor the FWA in commentletters and in technical meetings with USEPA. Our concerns are included as part of Attachment1 to the ROD (Responsiveness Summary for the FWA) This letter contains comments from thenatural resource trustees (Ohio EPA, U.S. Dept of the Interior and NOAA) on the 1 1/96Proposed Plan for the FWA. Our major concerns are over the protectiveness and permanence ofthe selected remedy.

USEPA 's selected remedy would remove PCB contaminated soils above the 50 mg/kgtsocontour in th« occupational exposure units and would remove soils above the 30 mg/kgisocontour in the residential exposure units. Areas in the residential units between 6 and 30mg/kg would be u>vered with 6 inches of hydric compatible soil. Ohio EPA recommended thatthe FWA soils be excavated to lower concentration isocontour* in both occupational andresidential areas and that the cover remedy be replaced with excavation. We would prefer thatthe removal goals fall within the 1 to 10 rngftg range for residential areas and 10 to 25 m^kgrange in occupational areas that has been traditionally used for PCB cleanups. We recognizethai ihb would substantially increase the cost of the remedy and result in greater short termdamage to the FWA however h would provide a more protective and permanent remedy forhuman hearth and the environment

Ohio EPA does not believe that die cover remedy in the residential area will be either adequatelyprotective or permanent. A limited soil cover will be susceptible to damage by human activity,burrowing animals, erosion, freeze/thaw and other biological and physical processes. Wecontinue to disagree with the exposure frequencies USEPA used to calculate the cleanup goals(CUGc). USEPA assumed that, in the loidtmtial area, exposure frequency to FWA soib wouldbe 6 1 days/yr for children, 1 10 days/yr for adolescents and 3 7 days/yr for adults over A 10 yen-period. We do not feel that these exposure frequencies are sufficiently protective for areas of theFWA that arc directly behind resiffencps and fWl that 270 days/yr for all ages is a reasonablyconservative exposure frequency that takes into account inclement weather conditions

Quotgt V. \fefovfch, QOWVTWNftflcy P. I >o ••*•!•. Lt QovwnorDonald ft. Schngarfttt. Ofracior

V. Adarakus

Page - 2 -

In an effort to reduce duplicaikm of agency efforts on Superfund Sites, Ohio EPA, in 1996,relinquished its role as m active participant in the technical review and comment process for theFields Brook Site and thus left it toUSEPA to negotiate an acceptable remedy with the FieldsBrook Action Group (FRAG) Our rok after that was as A trustee of natural re*nirce«. As suchwe have provided comments along with the other trustees. The trustee group attempted tonegotiate changes lu (he remedy with FAAG during the past year but were unable to persuadeFBAG to make any changes to the remedy. Instead we reached an agrcemom in principle for afinancial settlement whh FBAG to compensate the trustees for past and future injuries to thenatural mources The FBAG agreed to fund the aquUhion and enhancement of wetlands andsome Atture biological jnonitoring to assess continuing damages and, we hope, to measure someimprovement over time.

Our final effort to affect changes to the remedy came in die form of comments the trusteesprovided to USEPA during the public comment period for Ihe Proposed Plan (Attachment l).USEPA offers responses to each of our comments but does not propose to make any changes tome remedy. In view of this and for all of the reasons stated in this letter and in the trusteecomments, Ohio EPA does not concur with the ROD for the Field* Brook FWA operable unit.

fr*» to contact Ohio ETA should you lutve tiny questions or concerns regarding thisletter

Ohio Environmental Protection Agency

DRS/RSWwmk "

cc: Jenny Tiell. Deputy Director, COJan Carlson, DERR, COMike Czeczele, DERR, CORay Beuimier, DERR, COBill SkowroDski, District Chief, NEDOBob Wyscnski, Assistant District Chief, NEDORod Beals, DERR. NEDO

Steve Love, DERR, NEDOSig Williams, DERR; NEDOHeidi Serin, DERR, COJeff Hnnfley, Legit, COPeter Whttahouse, DERR, COVancttti Slexyenvald, DERR, COTim Kern, Ohio AGO

RECORD OF DECISION SUMMARYFLOODPLAINS/WETLANDS AREA

FIELDS BROOK SITE, ASHTABULA OHIO

I. SITE NAME, LOCATION, AND DESCRIPTION

The Fields Brook site is located in northeast Ohio, in AshtabulaCounty, approximately 55 miles east of Cleveland, Ohio. Thebrook drains a six square-mile watershed including an industrialarea where manufacturing activities ranging from metal-fabrication to chemical production have occurred over the past50 years. Sediments of the brook and the Ashtabula River arecontaminated with polychlorinated biphenyls (PCBs), chlorinatedbenzene compounds, chlorinated solvents, hexachlorobutadiene,polyaromatic hydrocarbons (PAHs), arsenic, and other hazardoussubstances.

The Fields Brook Site (Site) was placed on the NationalPriorities List (NPL) for hazardous waste sites on September 8,1983. The site consists of Fields Brook, its tributaries, andany surrounding areas which contribute, potentially maycontribute, or have contributed to the contamination of the brookand its tributaries. The site is a multi-source site andinvolves multiple media, including soil, sediment, groundwaterand surface water.

The U.S. EPA divided the site into four areas of concern, threeof which have been designated as "operable units" (OUs)associated with the Fields Brook Superfund site (See Figure 1).The Sediment OU (OU#1) involves the cleanup of contaminatedsediment in Fields Brook and its tributaries. The Source ControlOU (OU#2) involves the location and cleanup of sources ofcontamination to Fields Brook to prevent recontamination of thebrook and Floodplains/Wetlands Area (FWA). The Ashtabula RiverArea of Concern involves determining the type and amount ofcontamination in the Ashtabula River, the effect the Fields Brookand other contamination sources have had on the'river sediments,and any risks to human health and the environment. The FWA OU(OU#4) involves the cleanup of contaminated soils and sedimentsin the FWA which are located within the 100-year floodplain areasurrounding Fields Brook and outside of the channel and sideslopeareas of Fields Brook. The FWA is the subject of this Record ofDecision document.

iThe FWA has been divided geographically into distinct butcontinuous portions. In order to facilitate locating featuresand sampling points along Fields Brook and its tributaries, thestream and system has been divided into segments identified by aunique numbering system involving stream reaches, which aredepicted on Figure 2. The eastern portion of the Fields Brookwatershed drains Ashtabula Township and the western portiondrains the eastern portion of the city of Ashtabula. The mainchannel is 3.9 miles in length and begins at Cook Road, just

south of the Penn Central Railroad tracks. From this point,Fields Brook flows northwest to Middle Road, then west to itsconfluence with the Ashtabula River. From Cook Road downstreamto State Route 11, Fields Brook flows through an industrializedarea. Downstream of State Route 11 to near its confluence withthe Ashtabula River, Fields Brook flows through undeveloped andresidential areas in the City of Ashtabula. Fields Brookdischarges to the Ashtabula River approximately 8,000 feetupstream from Lake Erie. The City of Ashtabula has a populationof about 23,000.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

The industrial zone of Ashtabula is concentrated around FieldsBrook and is comprised of several chemical industries and wastedisposal sites. Manufacturing has occurred since the early1940*8 in this area. Activities ranging from metal-fabricationto production of complex chemical products occurred onapproximately 18 separate industrial properties, and the decadesof industrial activity along Fields Brook and its tributariesresulted in the release of chemical contamination to the FieldsBrook watershed, particularly the sediments of Fields Brook, theFWA soils and sediments, and the soils surrounding theindustries. These media are contaminated with PCBs, chlorinatedbenzene compounds, chlorinated ethenes (solvents),hexachlorobutadiene, chromium, arsenic, and other organic andinorganic contaminants.

Between April 1983 and July 1986, a Remedial Investigation/Feasibility Study (RI/FS) was conducted on the Fields BrookSediment OU by the U.S. EPA. The 1986 RI/FS included a baselinehuman health risk assessment which demonstrated human healthrisks not only for exposure to the brook sediment, but alsoexposure in the FWA. The U.S. EPA issued a Record of Decision(ROD) in September 1986 detailing a cleanup remedy that U.S. EPA,with the concurrence of Ohio Environmental Protection Agency(OEPA), determined to be necessary for the Fields Brooksediments. The 1986 ROD consists of the following components:excavation, treatment and disposal of sediment from Fields Brook,an RI/FS to identify current sources of contamination to thebrook and to develop ways to stop further contamination, and aninvestigation to address the nature and extent of contaminationin the Ashtabula River and Harbor. '

In late 1986, the U.S. EPA began negotiating with a number ofPotentially Responsible Parties (PRPs) to conduct the sourcecontrol OU#2 RI/FS activities and sediment operable unit designactivities. The PRPs are comprised of the companies who areconsidered the owners and operators of the chemical industriesand waste disposal sites surrounding Fields Brook. The PRPs alsoinclude the companies who, by contract, agreement, or other

means, either accepted, or arranged for transport, disposal ortreatment of, hazardous substances within the Fields Brook site.

The PRPs initiated a voluntary assessment of the nature andextent of contamination in the FWA of the Fields Brook ripariancorridor. Field activities were initiated in Spring of 1993.Following an extended comment period on the original ecologicalrisk assessment work plan, the U.S. EPA prepared a separateecological risk assessment work plan for the Fields Brook FWA inMarch, 1994. Significant portions of this work plan wereincorporated into the PRPs work plan. Three rounds of FWA soilsampling, additional flora and biota sampling and fieldinvestigations, and a wetland survey which identified the sizeand location of wetlands that could be affected by the FieldsBrook cleanup, were completed by the spring of 1995.

The PRPs prepared and submitted to U.S. EPA an initial draftbaseline ecological risk assessment report in June of 1994.Following U.S. EPA review and comment, the PRPs submitted asecond draft of the ecological risk assessment in June of 1995,and upon revision, submitted a third draft in October, 1995. Toproduce a more acceptable assessment of potential risk toecological receptors at the site, U.S. EPA prepared a separateecological risk assessment report in February of 1995. Resultsof these efforts are discussed within U.S. EPA's October 1996Ecological Risk Assessment.

U.S. EPA prepared separate baseline Ecological and Human HealthRisk Assessments for the FWA in 1996. The PRPs voluntarilyconducted an RI/FS for the Fields Brook FWA, and have prepared aFWA Feasibility Study under U.S. EPA oversight. These studiesassess human and ecological risks and cleanup alternatives andform the basis for cleanup decisions in the wetland areas. Thesereports have been placed in the information repositories for thissite. These reports are the primary documents in the FWA OU#4administrative record which were used to develop and issue theProposed Plan for the FWA in November 1996.

III. HIGHLIGHTS OF COMMUNITY PARTICIPATION

Various public meetings and availability sessions have been heldby U.S. EPA in Ashtabula between 1984 and the present; to discussthe general progress of the ongoing Fields Brook siteinvestigations.

U.S. EPA has provided regular updates of Fields Brook siteactivities to the Ashtabula River Remedial Action Plan (RAP)Advisory Council at the monthly RAP meetings in Ashtabula.

On May 26-27, 1993, U.S. EPA conducted several availabilitysessions and a public meeting in Ashtabula to update the public

regarding activities for all four areas of concern, including theFWA, of the Fields Brook Site. After the meeting, U.S. EPAprovided the RAP Council and interested citizens with a writtenresponse to comments and questions raised at the variousmeetings. *

On September 26, 1996, U.S. EPA conducted another publicavailability session in Ashtabula, and provided the public with adetailed update regarding the various FWA studies, risk issuesand cleanup alternatives being considered to be conducted. InNovember 1996, U.S. EPA provided the public with a written'question and answer1 response to comments and questions raisedat the September meeting.

U.S. EPA issued a Proposed Plan for the FWA in November 1996.U.S. EPA provide<J a public comment period on the FWA ProposedPlan from November 13, 1996 through January 17, 1997, andconducted an evening public meeting on the FWA Proposed Plan onNovember 21, 1996 in Ashtabula. Also, U.S. EPA met withofficials from the City, Township, and County of Ashtabula onNovember 21, 1996 prior to the evening public meeting andprovided these officials with a status update regarding theFields Brook site and the FWA. U.S. EPA!s response to the publiccomments received are summarized in the attached ResponsivenessSummary, which is Attachment 1 of this Record of Decision. ThisROD will become part of the Administrative Record pursuant to theNCP Section 300.825 (a)(2). The Administrative Record can befound at the Site repositories located at:

1) Ashtabula County District Library335 West 44th StreetAshtabula, OH

2) U.S. Environmental Protection AgencyWaste Management Division Records Center, 7th Floor77 West Jackson Blvd.Chicago, IL

IV. SUMMARY OP SITE CHARACTERISTICS

A) Overview:

The FWA consists of the 100-year floodplain of Fields' Brook. Asreported in The Soil Survey of Ashtabula County, Ohio, publishedby the U.S. Department of Agriculture Soil Conservation Service,much of the FWA has a natural subsurface composed of glacialdeposits overlying bedrock. Bedrock surfaces in variouslocations in the lower reaches of Fields Brook (generally fromRoute 11 down to the Ashtabula River), and surface glacial andFields Brook sediment depositional soils occur frequently acrossthe entire FWA. In the upper reaches of Fields Brook (upstream

of State Street), depth of bedrock approaches approximately 30 to40 feet. The bedrock is primarily shale with an upper sandstoneunit approximately 3 feet thick. The bedrock is generally notconsidered a favorable source of groundwater because of its lowpermeability, low porosity, and relatively low yields (less than3 gpm).

The groundwater in the FWA generally flows towards and dischargesinto Fields Brook. In general, Fields Brook is a 'receivingstream1, meaning that it receives groundwater from thesurrounding areas including the FWA. Because the soils and siltsin the FWA are generally of very slow permeability and poornatural drainage, the speed of groundwater within the FWA soilsis generally very slow (1 to 3 feet/year). The combination oflow hydraulic conductivity and relatively slow groundwatermigration has generally prevented people and industries fromusing the grouncjwater in the area, and has prevented contaminantsfrom entering the groundwater and flowing to Fields Brook viagroundwater.

The FWA soils mostly do not drain well (i.e., not muchinfiltration of rainwater occurs), and the soils are essentiallyflat at the surface without hills. The FWA soils are comprisedof either geologically lake-deposited or recent brook-depositedsediment, and exhibit seasonal wetness and low permeability. Theupper 5 to 15 feet of unconsolidated materials generally consistof lacustrine silty clay to clayey and sandy silt with roundedgravel and some silty sand, with variable amounts of organicmatter. Glacial till (Ashtabula Till) underlies the lacustrinedeposits; the Ashtabula till is composed of hard clayey to sandysilts with angular gravel and rock fragments. A common soil typein the FWA is the Holly silt loam. These FWA soils generallyhave a 4"-6" thick leaf litter, and are covered with nativegrasses, brush, shrubs and hardwood trees. Fragmites weedsfrequently cover the soils throughout the FWA.

The FWA area in the downstream reaches of Fields Brook (in theresidential home areas, from Route 11 down to the AshtabulaRiver) generally is surrounded by a relatively flat floodplainarea, which spreads out in variable distances from the brook tothe 100-year floodplain edge. In these downstream areas, the FWAis generally significantly lower topographically from the homes(between 15-30 feet lower than backyard areas near hojmes) and isfrequently covered with dense brush and bushes. ,

A wetland survey, which identified the size and location ofwetlands that could be affected by the Fields Brook cleanups, andan extensive wetland sampling effort, were completed in the fall1995. Data from these efforts were included in the October 1996FWA Remedial Investigation report. Baseline Ecological andBaseline Human Health Risk Assessments of the FWA were alsocompleted by the U.S. EPA in October 1996, and are provided as

L_

separate reports. The PRPs voluntarily conducted an RI/FS forthe Fields Brook FWA, and prepared an October 1996 FWAFeasibility Study under U.S. EPA oversight. The FWA FS isprovided as a separate report. These studies assess human andecological risks in these areas and form the basis for cleanupdecisions in the wetland areas.

B) FWA Exposure Units

For risk assessment purposes, reaches of the brook weresegregated into FWA exposure units (FEU). These FEUs areindicated on Figure 2. The State of Ohio, U.S. EPA and the PRPsdiscussed and agreed on the appropriate size of the FWA exposureunits. Each of the FEUs are approximately 2,000 feet in length,and correspond to areas where potential exposure to FWA soilswould occur by distinct groups of people on each side of thebrook. Various factors were considered in determining the sizeof the exposure units, including review of survey data,discussions with local citizens, inspection of all FWA areas,investigations of plants and animals along the FWA, and evidenceof use along the FWA. The U.S. EPA has reviewed these lengthsand concluded that after cleanup activities the average of theCleanup Goals (CUGs) for each FEU would be protective of humanhealth and the environment.

Land use designation for the FEUs were based upon severalconsiderations: 1) general homogeneity with respect to historicalwaste management activities, 2} differences in land use, terrain,accessibility or media type which can affect exposure scenarios,and 3} U.S. EPA Guidance documents. It is understood that someFEUs may not have floodplains or wetlands but are set up only toretain a consistent numbering system with the sediment FEUs. Thegrouping of FEUs and their associated land use designationfollows.

• Residential:FEU1 Reach 1 FEU2 Reach 2-1, 2-2, and part of 9FEU3 Reach 3

* Industrial:FEU4 Reach 4 FEUS Reach 11-1 and 11-2FEU6 Reach 5-1 and 5-2 FEU7 Reach 11-3 and 11-4FEU8 Reach 6 and 7-1 FEU9 Reach 7-2 and 8-I/FEU10 Reach 8-2, 8-3, 8A, 13-1, 13-2, and 13A

Only five of the FEUs contain floodplain soils, or containchemical concentrations above the CUGs. These are FEU2, FEU3,FEU4, FEU6 and FEUS. FEUs 2 and 3 are considered residentialbased upon the presence of homes on the property. The industrial^FEUs are upstream of the residential FEUs. There are no fencesalong the FWA, and fences do not separate the residential fromthe industrial exposure units.

FEU4, FEU6 and FEU8 are considered to have industrial usage forthe following reasons: a) the area east of Route 11 currentlydoes not have residential development; b) the properties thatfall within FEU4 and FEU6 primarily belong to the industry or theCity of Ashtabula, and do not belong to private land owners; andc) the properties can be permanently restricted from residentialdevelopment through deed restrictions and covenants.

The other five FEUs were eliminated from further considerationfor several reasons. FEUs 1, 5 and 7 do not have a floodplainarea (i.e.. Fields Brook, during a 100 year storm, stays withinthe brook channel and does not overflow the banks in theseFEU's). In FEUs 9 and 10, sampling results indicated noexceedences in the FWA above the CUGs.

C) Summary of Sampling Data•

Since 1985, sampling has been done to quantify the levels ofcontaminants in the FWA. The FWA soil analytical resultspresented in various data reports have been sent to theinformation repositories, and represent sampling effortsprimarily performed by the PRP's that have taken place in the FWAduring the past five years. Some of the soils data werecollected as part of the brook sampling programs. Additionalsurface soil samples were collected at selected locations withinthe FWA investigation area to fill data gaps. Surface soilsampling locations were selected by reviewing existing brooksediment sampling data and by locating the sampling points inareas of expected deposition. Sampling locations are shown onFigures 3 through 7 in the 10/96 U.S. EPA FWA RI Report.

Tissue samples were also collected from mice, shrews, earthworms,voles, insects, and vegetation and analyzed for 130 separatechemical parameters. Results of these efforts are discussed inU.S. EPA's October 1996 Ecological Risk Assessment. PCBs wereobserved in the FWA biota. A maximum concentration of 11 ppmtotal PCBs was detected in a single shrew composite sample.However, most concentrations were well below this level rangingfrom 0.029 to 4.8 ppm. Arsenic, cadmium, chromium, lead, andhexachlorobenzene were observed in all tissue matrices throughoutthe FWA. Barium, vanadium, and hexachlorobutadiene were observedin several but not all matrices. Various chemicals of concern,including several trace metals (lead, cadmium, chromiiAm,vanadium, and barium), were considered in the ecological riskassessment. PCBs, hexachlorobenzene, and hexachlorobutadienewere the organics that were fully assessed in the ecological riskassessment. Others were eliminated because their levels were nothigh enough in the FWA to be of concern to organisms. Summariesof the biota species collected, biota potentially present,vegetation identified, wildlife observed, and flora and faunasampling data are summarized in Tables 2 through 5 of U.S. EPA's10/96 FWA Ecological Assessment Report.

D) Soil Sampling Data Summary

A total of 211 FWA soil samples were taken. As part of thePhase I Sediment Quantification Design Investigation (SQDI)sampling, 14 sampling locations were randomly selected to providea general characterization of site conditions adjacent to thebrook. During Phase II SQDI, 55 sampling locations were locatedalong transects perpendicular to the Fields Brook channel.Transects were located near Phase I SQDI sediment samplinglocations that reported elevated concentrations of COC's. Duringthe Phase III FWA assessment, the 137 sampling locations werelocated within each FEU to represent a statistically valid numberof samples. In general, a total of 40 samples were collectedwithin each of the five exposure units with CUG exceedences:FEU2, FEU3, FEU4, FEU6 and FEU8. The sampling locations werespread fairly evenly along each length of the FWA with an equalnumber of samples (twenty) on the north and south sides of themain channel. The sampling locations also included collectingapproximately fifteen 'cross-sections1 of the FWA duringsampling. This effort located three sampling locations evenlyspaced on each side of the brook perpendicular to the brook fromthe brook to the edge of the FWA. Subsurface soil sampling(samples collected from the one foot depth below the surface tothe two foot depth below the surface) occurred along five of theFWA cross sections where the brook sediment data indicated thehighest levels of contamination in the sediment.

The Phase I and Phase II FWA soil samples, taken as part of theSQDI, were analyzed for approximately 130 different chemicals(i.e., the TCL and TAL parameters). The 137 Phase III FWA soilsamples were analyzed for eleven chemicals of concern (COCs)which exceeded cleanup goals in the brook sediment; these elevenCOCs were: arsenic, benzo(a)pyrene, beryllium, hexachlorobenzene,hexachlorobutadiene, hexachloroethane, PCBs, 1,1,2,2,-tetrachloroethane, tetrachloroethene, trichloroethene, and vinylchloride. The soil sampling locations were located by aregistered surveyor.

Soil sampling showed 95 hazardous substances which were detectedin some or all portions of the FWA. As would be expected basedon the site's history, volatile and semi-volatile organicchemicals, pesticides, PCBs, and inorganic chemicals weredetected in the FWA soils. It was found that levels'ofcontamination in the FWA soil did not exceed the level ofcontamination in the brook sediment.

The physical-chemical properties of the contaminants detected inFields Brook affect their fate in the environment. Hydrophobicorganic compounds, like PCB's, are especially persistent in theenvironment due to their low solubility in water, high octanol-water partition coefficients, and high molecular weights. Theseorganic compounds accumulate into the fatty tissue of organisms

and will be passed on through the higher orders of the foodchain.

The COC concentrations vary from background and nondetect levelsto several hundred parts per million (ppm or mg/kg). Maximumconcentrations for some of the semivolatile organics were: 610mg/kg for total PCB (FEU 6), 480 mg/kg for hexachlorobenzene {FEU8), 170 mg/kg for hexachlorobutadiene (FEU 4); for some of thevolatile organics: 56 mg/kg for trichloroethene (FEU 6), 89 mg/kgfor tetrachloroethene (FEU 6), and 8.5 mg/kg for vinyl chloride(FEU 6); and for some of the trace metals: 43 mg/kg for arsenic(FEU 8) and 57.7 mg/kg for mercury (along the Detrex Tributary toFields Brook). Average and upper confidence limit concentrationsand their frequency of detection for all of the chemicals ofconcern in FWA soils are summarized in the attached Tables 1-1through 1-5, and are also provided in Appendix A of U.S. EPA's10/96 FWA RI Report. All detected levels within FWA soils forall of the chemicals of concern are summarized in Appendix B ofU.S. EPA's 10/96 FWA RI Report.

The concentrations of all COCs except beryllium, vinyl chloride,trichloroethene and 1,1,2,2-tetrachloroethane were determined tobe generally equivalent on the north and south sides of thebrook. Beryllium concentrations were statistically different onthe north and south sides of the brook. The averageconcentration on the north was 1.86 mg/kg, with a maximumdetected concentration of 19.4 mg/kg, whereas the averageconcentration on the south was 0.7 mg/kg, with a maximum detectedconcentration of 2.3 mg/kg.

Although there appears to be somewhat more beryllium in the FWAon the north side of FEU6 and 8 than on the south side,calculated risks for beryllium are quite low and beryllium is nota determinant for remediation in either FEU. Vinyl chloride israrely detected and influences neither risks nor remediation.Similarly, trichloroethene is somewhat more prevalent on thesouth side of FEU2, and 1,1,2,2-tetrachloroethane is somewhatmore prevalent on the south side of FEU3, but calculated risksfor trichloroethene in FEU2 and 1,1,2,2-tetrachloroethane in FEU3are extremely low, on the order of 10"10. In conclusion, thestatistical tests indicate that for those COCs that influencerisks and remediation needs, there is no substantial differencein concentration levels on the north and south sides of FieldsBrook.

E) Summary of Soils Data for FEU 2

The most frequently observed organic compounds in FEU 2 werepolynuclear aromatic hydrocarbons (PAHs), PCBs (primarilyAroclor 1248), bis-2-ethylhexylphthalate, dibenzofuran,hexachlorobenzene, hexachloro-butadiene, di-n-butylphthalate,acetone, methylene chloride, tetrachloroethene and toluene. The

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highest detected concentration of total PCBs was 360 mg/kg, withthe average concentration at 24.2 mg/kg. The highest and averagedetected concentration of hexachlorobenzene were 97 and 14.3mg/kg, respectively, and the average hexachlorobutadieneconcentration was 0.81 mg/kg. The maximum detectedconcentrations of the following inorganic COCs exceeded thesediment background concentration established for the SedimentOperable Unit (SOU): arsenic, beryllium, cadmium, chromium,lead, and mercury.

Vinyl chloride was not detected in any of the 22 samplescollected on the north side of the brook and was detected in l ofthe 22 samples collected on the south side of the brook.Therefore, vinyl chloride concentrations were statisticallydifferent on the north and south sides. In addition,trichloroethene concentrations were also found to differ betweenthe north and south sides; the maximum detected concentrations onthe north and south were 0.15 mg/kg and 6.8 mg/kg, respectively.The concentrations of all other COCs were determined to begenerally equivalent on the north and south sides of the brook.

F) Summary of Soils Data for FEU 3

The most frequently observed organic compounds in FEU 3 werePAHs, PCBs (primarily Aroclor 1248), di-n-butylphthalate, bis-2-ethylhexylphthalate, methylene chloride, tetrachloroethene, andhexachloro-benzene. The highest detected concentration of totalPCBs was 530 mg/kg, with the average concentration at 29 mg/kg.The highest and average detected concentrations ofhexachlorobenzene were 99 and 6.4 mg/kg, respectively, and theaverage concentration of hexachlorobutadiene was 2.8 mg/kg. Themaximum detected concentrations of the following inorganic COCsexceeded the sediment background concentration established forthe SOU: arsenic, beryllium, cadmium, chromium, and mercury.

1,1,2,2-Tetrachloroethane concentrations were statisticallydifferent on the north and south sides of the brook. The maximumdetected concentrations on the north and south were 0.022 mg/kgand 0.22 mg/kg, respectively. The concentrations of all otherCOCs were determined to be generally equivalent on the north andsouth sides of the brook.

G) Summary of Soils Data for FEU 4 :'

The most frequently observed organic compounds in FEU 4 werePAHs, PCBs (primarily Aroclor 1248), 1,2-dichloroethene, 1,2,4-trichlorobenzene, 1,1,2,2-tetrachloroethane, acetone, 2-butanone,tetrachloroethene, trichloroethene, bis-2(ethylhexyl)phthalate,di-n-butylphthalate, hexachlorobenzene and hexachlorobutadiene.The highest detected concentration of total PCBs was 560 mg/kg,with the average concentration at 63 mg/kg. The highest andaverage detected concentrations of hexachlorobenzene were 230 and

1129 mg/kg, respectively, and the average concentration ofhexachlorobutadiene was 9.2 mg/kg. The maximum detectedconcentrations of the following inorganic COCs exceeded thesediment background concentration established for the SOU:arsenic, beryl1ium, cadmium, chromium, 1ead, and mercury.

The concentrations of all COCs were determined to be generallyequivalent on the north and south sides of the brook.

H) Summary of Soils Data for FEU 6

The most frequently observed organic compounds in FEU 6 werePAHs, PCBs (primarily Aroclor 1248), 1,1,2,2-tetrachloroethane,1,2,4 -trichlorobenzene, 1,2-dichlorobenzene, 1,2-dichloroethene,1,2-dichlorobenzene, bis-2-ethylhexylphthalate, methylenechloride, acetone, tetrachloroethene, trichloroethene, andxylenes. The highest detected concentration of total PCBs was610 mg/kg, with the average concentration at 76 mg/kg. Thehighest and average detected concentrations of hexachlorobenzenewere 320 and 33 mg/kg, respectively, and the averageconcentration of hexachlorobutadiene was 11 mg/kg. 'The maximumdetected concentrations of the following inorganic COCs exceededthe sediment background concentration established for the SOU:arsenic, beryllium, cadmium, chromium, lead, and mercury.

Beryllium concentrations were statistically different on thenorth and south sides of the brook. The average concentration onthe north was 1.36 mg/kg, with a maximum detected concentrationof 6 mg/kg, whereas the average concentration on the south was0.6 mg/kg, with a maximum detected concentration of 2.2 mg/kg.The concentrations of all other COCs were determined to begenerally equivalent on the north and south sides of the brook.

Radionuclide sampling occurred on the RMI Extrusion propertywhich lies within FEU6. In 1985, the RMI Titanium CompanyExtrusion Plant conducted an extensive baseline characterizationstudy to determine uranium levels in soil in the vicinity of theplant. As part of the 1985 sampling campaign, eleven sampleswere taken in the Fields Brook floodplain. As a result of the1985 baseline characterization, several locations, includingthree floodplain locations were selected for annual resampling.Also, additional radionuclide data were collected on the RMIExtrusion facility as part of RMI•s decommissioning efforts. 74FWA samples were taken within floodplain areas behind RMI-Extrusion for Uranium isotopes U-234 and U-235, and forTechnetium-99; 132 FWA samples were taken behind RMI-Extrusionfor U-238. The results are summarized in the 12/95 and 9/30/96RMI reports which have been provided in the Fields Brook SiteAdministrative Record. There were several individual samplingpoint detections of total uranium radionuclides in FWA areas,ranging up to 110 picocuries per gram (Pci/g).

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I) Summary of Soils Data for FEU 8

The most frequently observed organic compounds in FEU 8 werePAHs, PCBs (primarily Aroclor 1248), dimethyl-phthalate,diethylphthalate, butylbenzylphthalate, bis-2-ethylhexylphthalate, carbazole, dibenzofuran, 1, 2-dichloroethene,1,1,2,2-tetrachloroethane, 1,2,4-trichlorobenzene, 1,4-dichlorobenzene, trichloroethene, tetrachloroethene, 2-butanone,hexachlorobenzene, hexachloroethane and hexachlorobutadiene. Thehighest detected concentration of total PCBs was 270 mg/kg, withthe average concentration at 34 mg/kg. The highest and averagedetected concentrations of hexachlorobenzene were 480 and 30tng/kg, respectively, and the average concentration ofhexachlorobutadiene was 1.2 mg/kg. The maximum detectedconcentrations of the following inorganic COCs exceeded thesediment background concentrations established for the SOU:arsenic, beryllium, cadmium, chromium, lead, and mercury. Theconcentrations of all COCs were determined to be generallyequivalent on the north and south sides of the brook.

V. HUMAN HEALTH RISK ASSESSMENT

Based on analytical data collected during the FWA remedialinvestigation, a risk assessment was performed to determine thepotential risks to human health posed by the contaminantsdetected in the FWA soils and sediments. The risk assessment isa baseline risk assessment and assumes that no corrective actionwill take place in the FWA, and that no site-use restrictions orinstitutional controls such as fencing or constructionrestrictions will be imposed. The FWA human health riskassessment determines the actual or potential carcinogenic risksand/or toxic effects that chemicals detected in the FWA poseunder current and future land use assumptions.

A) Chemicals of Concern

U.S. EPA's October 1996 Fields Brook FWA Human Health RiskAssessment focused on 11 chemicals of concern (COC) which werethe 11 COCs which exceeded any of the Fields Brook sedimentoperable unit cleanup goals (CUGs) on average for any sedimentexposure unit. The Fields Brook Sediment Operable Unit CUGs areoutlined in U.S. EPA's August 3, 1993 and August 18, '1993 lettersto Mr. Joseph Heimbuch of de maximus, Inc., and the CUGexceedences are described in the February 1995 30% designdocument (these letters and the 30% design document are in theFields Brook Site Administrative Record). These COC areindicated in Table 3 and include arsenic, benzo(a)-pyrene,beryllium, 1,1,2,2,-tetrachloroethane, tetrachloroethene,trichloroethene, hexachloroethane, vinyl chloride,hexachlorobenzene, hexachlorobutadiene, and PCBs.Hexachloroethane and vinyl chloride were screened out as COCs in

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the U.S. EPA 1996 FWA human health risk assessment because theywere detected at a frequency of less than 5 percent. The FWAhuman health risk assessment focused on the 11 COC which exceededthe sediment cleanup concentration goals which were determinedduring the Fields Brook sediment remedial design. The FWA COC,their detection frequency and detected concentrations arepresented for each FEU in Tables 1-1 through 1-5.

B) Exposure Assessment

An exposure assessment was conducted as part of the human healthrisk assessment. The potential risks to people exposed to theFWA include risks from ingestion of soils in the FWA, inhalationof dusts from the area, dermal exposure to the soils, andgardening in the FWA. The greatest potential risks to people arefrom ingestion of soils in the FWA. U.S. EPA's review of theserisks indicate tihat if risks from ingestion of soil areaddressed, the other risks to humans and the environment wouldalso be addressed.

Current and future land use was divided between residential (inFEUs 2 and 3) and commercial/industrial (in FEUs 4, 6, and 8) aspart of the exposure assessment. U.S. EPA's development of theCUGs assumed that people would be exposed at certain frequenciesin the residential and industrial areas. In the residentialarea, U.S. EPA assumed that someone would ingest between 50 and200 milligrams of surface soils 61 days per year for children,110 days/year for adolescents and 37 days per year for adults,for a total of thirty years. In the industrial area, U.S. EPAassumed that someone would ingest 50 milligrams of surface soils60 days per year for a total of twenty five years.

U.S. EPA's review of the information regarding exposure to FWAsoils indicate that frequent exposure to FWA soils is not likely.There are six months or more of the year which involve coldweather in Ashtabula, which tends to inhibit outdoor exposure tosoils. The FWA does not have any buildings or structures, inpart because structures are prohibited from being built withinthe FWA because of regular flooding. This lack of buildingshould lessen the likelihood of human exposure in the FWA. Also,the FWA is generally different than the immediate backyard lawnareas of the homes along the brook. The FWA is topographicallylower than the grassy backyard areas (i.e., 10-20 feet lower inheight than the lawn areas) and is frequently separated from thebackyard lawn areas by brush, bushes with burrs and otherobstacles making it difficult to reach the FWA directly from thehomes.

U.S. EPA's research indicates that subsurface exposure below onefoot of soil depth in residential and FWA backyards generallydoes not occur unless erosion or excavation was expected in thatarea (which is not expected to occur). Also, of the 23 deep soil

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samples taken between one-to-two feet from the surface in theFWA, only two samples indicated levels of any contamination abovethe CUGs. These two locations are in the FWA soils betweenColumbus Avenue and East 16th Street. The levels ofcontamination at these locations are only slightly above theCUGs.

Plants growing in the FWA, including vegetables grown in the FWA,generally do not pick up organic contamination such as PCBs andHCBs. According to scientific studies, this is because theirroots'generally do not absorb these contaminants. Leafy treessuch as willows and poplars, and leafy vegetables such asspinach, cabbage or lettuce which might be grown in the FWA, maypick up heavy metals such as cadmium, chromium and mercury whichexist in the FWA. However, these metals are generally notprevalent in FWA^soils at elevated levels. Thus, plants were notconsidered media containing hazardous substances of concern.However, roots and vegetative materials growing in areas of FWAsoil contamination may be considered contaminated in part becausethe contaminated soil particles may be inseparable from the rootsand vegetative materials.

C) Human Health Risk Assessment

The total potential carcinogenic and noncarcinogenic hazardquotients are presented in Table 6 of the U.S. EPA 1996 FWA humanhealth risk assessment. The calculation spreadsheets, whichprovide additional detail to the individual and overallcontaminant risk profiles, are found in Appendix D of the U.S.EPA 1996 FWA human health risk assessment.

The total potential carcinogenic risk associated within each FEUis greater than the 10~6 risk which is considered the departurepoint for acceptable risk by U.S. EPA. The potential excesscancer risks ranged from 1.6 x 10~3 (at FEU 3) to 1.2 x 10"4 (atFEU 8). Exposure to PCBs and hexachlorobenzene, both Class B2carcinogens, contributed the majority of the excess cancer risk.There is not likely to be a short term risk to anyone walkingalong the brook in the FWA. However, there is a calculablecancer risk to residents, workers, and trespassers due primarilyto long-term exposures through ingestion of soils andcontaminants in the FWA soils and brook sediments.

In FEU2, FEU3, FEU4 and FEU6, the hazard indices (Hlj are greaterthari one, indicating that adverse health effects may occur fromexposure to the site. The hazard indices range from 25 in FEU 3(due primarily to potential exposures to PCBs) to 1.6 in FEU 8(due to potential exposures to the same contaminant). Thesevalues reflect addition of all the Hi's in a given FEU regardlessof the chemical-specific endpoint. Thus, these numbers arelikely to overestimate the non-carcinogenic negative impacts fromchemicals at the Site.

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A cancer survey was conducted by the Ohio Department of Health inJune 1987 to assess whether there was any evidence of increasedincidence of cancer to residents who live or lived along FieldsBrook due to potential exposures to contaminants which have beenreleased from companies along the brook. This survey was notable to detect statistically significant increases of cancer tothe population within close proximity to Fields Brook whencompared to the total cancer levels indicated for the State ofOhio and for the United States. However, within that normalcancer rate, the incidence of brain and central nervous systemcancer was higher than expected compared to both Ohio and theUnited States levels. The study also noted that it was not knownif potential exposures by these individuals to Fields Brook areacontamination played a role in these increased incidences. Adetailed follow-up investigation into these cases was conductedby the Ohio Department of Health in June 1988 and that report isalso included in the information repository. This follow-upstudy noted that the increased incidences had an unknown cause,possibly due to a misclassification of the primary disease,environmental factors, or chance alone.

The two major risk drivers at the Fields Brook site are PCBs andHCB. Risk from these two contaminants account for all of theadditive risk at the site. Beryllium and tetrachloroethenecontribute a risk in the 10"6 range in FEU's 2 and 3 and FEU6respectively. Both PCB and HCB have carcinogenic and non-carcinogenic effects. In addition, both PCB and HCB have beenshown to affect the developing fetus, indicating that the hazardindices for these two chemicals can be appropriately added.

PCBs encompass a class of chlorinated compounds which includes upto 209 variations, or congeners, with different physical andchemical characteristics. Specific combinations of PCB congenersare generally unique to each site. PCB congeners are groupedinto categories of PCBs which are known as Aroclors. CertainAroclors are commonly associated with insulation systems, othersused in hydraulic, lubricating and heat transfer fluids, andstill others as dielectric fluids in transformers. These threetypes of Aroclors were used within the Fields Brook site. It wasagreed upon by both U.S. EPA and the PRPs during meetings in 1994and 1995 to consider all of the Aroclor's and congeners togetheras total PCBs in the risk assessment. The FWA human health riskassessment has calculated the PCB risk using the cancer slopefactor of 7.7 (mg/kg-day) ~l, which was used throughout previousrisk assessment drafts and discussions between U.S. EPA and thePRPs. The human health risk assessment also calculated risksusing the recently revised and current cancer slope factor of 2.0(mg/kg-day}"1 which was entered onto the Integrated RiskInformation System (IRIS) October 1, 1996. Both of thesecalculations were reported in the human health risk assessmentbecause the timing for the slope factor revision was unknown whenthe risk assessment was drafted in the summer of 1996.

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Regarding radionuclides, U.S. EPA's October 1996 Fields Brook FWAHuman Health Risk Assessments provides the Radionuclide CUGs(RCUGs) which U.S. EPA established for both the Fields Brooksediment and the FWA soils and sediments. The RCUGconcentrations were conservatively calculated assuming both alphaand gamma emissions, and the exposure routes used in thedevelopment of the RCUGs were incidental ingestion and externalexposure to direct gamma. U.S. EPA compared all of theradionuclide data taken on the RMI Extrusion facility and FWA tothe RCUGs. Of the 74 U-234, U-235, and Technetium-99 FWAsamples, there were no U-234 and Technetium-99 RCUG exceedences,and there were two U-235 RCUG exceedences (these two U-235 RCUGexceedences were within the FWA areas behind RMI which have beenfenced-in for a number of years). Of the 132 U-238 FWA samplesbehind the RMI-Extrusion facility, there were 10 U-238 RCUGexceedences, with seven exceedences within FWA areas behind RMIwhich have been*fenced-in for a number of years, and three RCUGexceedences within FWA areas behind RMI which have been recentlyfenced-in.

U.S. EPA's review of the data indicate that radionuclides, and inparticular Uranium, are not considered a chemical of concernwithin the FWA because the levels of U-235 and U-238 indicated inthe FWA area were relatively low. The average levels indicatedon the RMI-Extrusion property, and within each residential andindustrial FEU including FEU6 which includes the RMI Extrusionfacility, were below the RCUGs established for U-235 and U-238 bythe U.S. EPA (i.e., the soil levels within the FWA are below theIxlO"6 risk levels). The Agency for Toxic Substances and DiseaseRegistry also indicated in its 4/96 health assessment for theRMI-Extrusion property (copy provided in the Fields Brook siteAdministrative Record) that the radionuclide levels indicated onthe property do not pose a significant risk to human health.

Also, to be protective, RMI-Extrusion has recently fenced-in allareas of RCUG exceedences on its property, installed silt fencesin the downgradient areas of detected radionuclides to catchsuspended silt which may run off the property during rainstorms,and is also planning to excavate/remove the contaminated soils intheir backyard, including the RCUG exceedence FWA soil areas, andship the soil to an approved storage facility in either Utah orNevada. The excavation activities are planned to occur in 1998,and will be conducted in coordination with the ongoing facilitydecontamination and decommissioning actions being conducted undersupervision of the U.S. Department of Energy. The excavationactions will also include delineation sampling in 1997 prior tothe beginning of excavation to ensure that the extent of the RCUGexceedence areas have been defined.

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VI. ECOLOGICAL RISK ASSESSMENT

U.S. EPA prepared an October 1996 Ecological Risk AssessmentReport which evaluated risks associated with doses ofcontaminants to ecological receptors by comparing receptorsagainst reference doses to calculate hazard quotients (HQs).Various chemicals of concern (COC) were identified, as indicatedin Table 3, and the ecological risk assessment focused on barium,cadmium, chromium, lead, mercury, vanadium, hexachlorobenzene,hexachlorobutadiene, and PCBs. The FWA COC, their detectionfrequency and detected concentrations are presented for each FEUin Tables 1-1 through 1-5. The HQs are presented for all speciesand zones in Tables 5-1 through 5-3 in the ecological riskassessment for exposures using: 1) mean media concentrations andarea use factors (AUFs) as presented; 2) 95 percent upperconfidence limit (UCL) concentrations and AUFs as presented; and3) 95 percent upper confidence limit on the mean (UCLM)concentrations and AUFs set equal to 1.0, respectively. Usingthis information, along with originally determined toxicityreference values (TRVs), HQs were calculated for each ecologicalreceptor, COC, and Zone {including reference or "background"locations) when sufficient information existed to do so. Resultsbased on original calculations are presented within theecological risk assessment. As indicated on these tables, anumber of different receptors of concern including mink, hawk,shrew, mouse, heron, robin and rabbit have HQs which exceed 1 formultiple contaminants of concern.

VII. SCOPE OF THE SELECTED REMEDY

The purpose of this Record of Decision (ROD) is to select thefinal remedial action for the Fields Brook Site FWA. This finalremedy contains or removes the contaminated soils and sedimentsfrom the FWA through a combination of excavating with backfillingand landfilling, or covering the contaminated soils. Allexcavated materials will be contained on-site in a linedlandfill, and all cover and excavation areas will include removalof trees and revegetation with native vegetation. Operation andmaintenance, post closure care and future monitoring will occur,and institutional controls and access restrictions will beplaced.

The remedy addresses all exposures to media and releases tomigration pathways that are considered to present an unacceptablerisk, including incidental ingestion of soil and dermalabsorption of contaminants in soil, and releases to surfacewater, ground water, surface sediments, and wetlands.

This remedy does not include treatment of principle threat wastesin order to reduce toxicity, mobility, or volume of thecontamination. As discussed in greater detail later in this ROD,

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treatment is not practicable in part because of the significantvolume of the waste, the contaminated FWA soils will be non-mobile, the low average concentration of the materials in placeand to be excavated, and there are no residential or industrialFWA exposure units which have principle threat concentrations ofcontaminants on average greater than a 10~4 cancer risk for theFWA. However, treatment is a secondary element in that landfillleachate liquids if they are generated will be collected andtreated resulting in destruction of hazardous substances.

VIII. DESCRIPTION OP ALTERNATIVES!

A) Overview and Discussion:

The FS identified and evaluated alternatives that addressedthreats and pote'ntial threats to human health and the environmentposed by the COCs in the FWA. These remedial alternatives haveseveral common components including site preparation, placementof institutional controls, and surface controls (such as soilerosion control and revegetation of excavation and cover areasand areas of disturbance).

The cleanup objectives for contaminants in the FWA are to conducta cleanup which would be protective of human health and theenvironment. Each alternative evaluated in the FS and listed anddiscussed in this ROD other than the no action alternativeinvolves excavation and/or containment of FWA contamination. Theextent of excavation and/or cover activities varies between thedifferent alternatives. Each alternative attempts to meet thecleanup objectives by conducting a cleanup which would result inresidual FWA contamination levels which are at or below thecleanup goals (CUGs) on average in each FEU on each side of thebrook. The CUGs for each of the FWA contaminants are listed inTables 2-1 through 2-4 of this ROD, and are based in part on ahuman health risk associated with lxlO~6 range for carcinogensand a less than one hazard index. This FWA CUG list is takenfrom EPA's 10/20/94 CUG letter to the PRPs, and is also attachedto U.S. EPA's 1996 FWA Human Health Risk Assessment. The onlyexception to this CUG list are the CUGs for total PCBs in theresidential and industrial areas of the FWA, which have been to 1ppm on average in residential areas and 6 to 8 ppm on average inindustrial areas. '

<Also, each of the alternatives evaluated in the FS segregatedsections of the FWA into FWA exposure units (FEU). These FEUsare indicated on Figure 2. The State of Ohio, U.S. EPA and thePRPs discussed and agreed on the appropriate size of the FWAexposure units. Each of the FEUs are approximately 2,000 feet inlength, and correspond to areas where potential exposure to FWAsoils would occur by distinct groups of people on each side ofthe brook. Various factors were considered in determining the

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size of the exposure units, including review of survey data,discussions with local citizens, inspection of all FWA areas,investigations of plants and animals along the FWA, and evidenceof use along the FWA. The U.S. EPA has reviewed these lengthsand concluded that after cleanup activities the average of theCUGs in each FEU on each side of the brook would be protective ofhuman health and the environment.

A remedial approach which is directed at PCB and HCB wouldeffectively address the primary risk at the site and would alsoremove other COCs in the FWA. This is due to several reasons: a)the dominant risk in the FWA to both human and ecologicalreceptors is from PCB and HCB; b) the significant levels of allother COCs exist where elevated levels of PCBs and HCB exist, asindicated in part by the 12/11/96 "FWA Delineation Sampling Maps*deliverable from Woodward Clyde which has been included in theAdministrative pecord; and c) based on a review of the data, U.S.EPA has found that if a remedial cleanup to the HCB and PCB FWACUGs on average throughout each exposure unit occurs, the lowlevels of all other contamination and other COCs remaining in theFWA after cleanup is completed would be protective of humanhealth and the environment for each exposure unit.

To help demonstrate that the response areas are properly defined,all of the remedial alternatives except no action would havedelineation sampling conducted in each FWA exposure unit prior tothe beginning of construction to ensure that the response areasare properly defined to meet the remedial action objective forthat remedial alternative. Also, all of the excavation and coveralternatives include the following activities: a) long termoperation and maintenance and post closure care of the remedialaction to help ensure its effectiveness; b) long term monitoringincluding sampling of FWA surface soils and sediments, thebackfill and cover areas, and monitoring of wetland conditions atspecific locations and for various parameters to verify theeffectiveness of the remedial action; and c) compliancedeterminations to be made with floodway/floodplain regulationswith compensation for loss or damage to wetlands. All of thealternatives, including the no-action alternative, includeimposition of deed restrictions and access restrictions over theSite property.

Regarding the cover alternatives, U.S. EPA investigated severalpotential ways that contaminants could reach the surface of a sixinch soil cover. These include movement to the surface byearthworms, burrowing animals, and by other mechanisms. U.S. EPAhas reviewed these mechanisms and has determined that if thelower levels of contaminants present in the residential area arecovered, it is not likely that these contaminants would reach thesoil surface at levels of concern to humans.

Whenever excavation or cover of contaminated soils and sediments

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in the FWA is considered, backfill of all excavation or coverareas would occur using hydric-compatible soils. These are soilsthat contain seeds, organics and other properties necessary forvegetative regrowth in the wet environment. Also, removal of alltrees in excavation areas, and removal of all trees below 12"diameter at basal height (dbh) in cover areas, would occur, withroots in response areas considered contaminated, and withvegetation above ground surface considered clean if it can bedecontaminated. Revegetation of all backfill and cover areas,and revegetation of all areas disturbed during construction,would occur using erosion mats and native vegetation.

Based on sampling data available, the alternatives other than noaction consider excavation and/or covering of volumes between8,000 and 27,000 cubic yards of FWA soils. Additionalinvestigation to define the extent of PCB contamination in every2,500 square fe£t of the FWA downgradient or downstream from thefurthest upstream FWA area requiring remediation in FEUS will beconducted for each of the alternatives other than no-action, andadditional investigation to define the extent of HCBcontamination in FEU's 4 and 8 will be needed due to elevated HCBsampling results in these areas, prior to the beginning ofconstruction to help define the extent of soil excavation andcover areas.

In addition, Alternative 7 includes additional design delineationinvestigation activities and enhanced long term monitoring.

The alternatives other than no action will also involveconstruction of a temporary access road to allow access to andalong the FWA areas from the roadways during construction. Theroads will be made of crushed stone and 1/4-inch thick geonetliner. The temporary road will be removed after construction anddisposed of either in the landfill or if clean as uncontaminatedsolid waste. If the road is considered clean, the crushed stonemay be used if appropriate to assist in the construction of FWAremedy components, including construction of the landfill.

B) Alternative Listing

The alternatives evaluated in the FS are presented below:

Alternative 1 - No Action r/

• Estimated Present Worth Cost: $0• Estimated Construction Time: Immediate

The inclusion of the no action alternative is required by law andgives U.S. EPA a basis for comparison. This alternative will notreduce any potential public health or environmental riskscurrently associated with the Site. This alternative does notinclude any institutional controls over the use of ground water

21

or surface water.

Alternative 2 - Containment-Hydric-Conpatible Soil Cover

• Estimated Total Present Worth Cost: $4,600,000• Estimated Cover Cost, Present Worth: $140,000• Estimated O&M Cost, 1 year Present Worth: $244,000• Estimated Construction Time: 12 months

This alternative consists of site preparation, institutionalcontrols, revegetation, and the placement of a hydric-compatiblesoil cover and erosion mat over the Response Areas which exceed10"6 remedial risk objectives in the residential areas, and 10"sremedial risk objectives in the industrial areas. The soil coverthickness would vary from 6 to 12 inches. Physical inspectionsand chemical sampling would be part of long-term monitoring.Wetlands mitigation at off-Site locations is also considered.

Alternative 3A -Hydric-Compatible Soil Cover, Excavation,Backfill and Off-Site Disposal

• Estimated Present Worth Cost: $8,900,000• Estimated Construction Time: 12 months• Estimated Cover Cost, Present Worth: $196,000• Estimated O&M Cost, 1 year Present Worth: $244,000

This alternative consists of site preparation, institutionalcontrols, revegetation, and the placement of a hydric-compatiblesoil cover and erosion mat over the Response Areas.Specifically, this alternative would excavate, remove andbackfill soils above 30 ppm total PCBs in FEUs 2 and 3, and above250 ppm total PCBs in FEUs 4, 6 and 8, and place soil cover oversoils above 6 ppm total PCBs in FEUs 2 and 3, and above 50 ppmtotal PCBs in FEUs 4, 6 and 8. Excavation would be limited to 12inches. Excavated soil would be disposed of at an off-Sitelandfill. Physical inspections and chemical sampling would bepart of long-term monitoring. Wetlands mitigation at off-Sitelocations is also considered. Approximately 8,000 cubic yardswill be excavated and removed from the FWA under thisalternative, and brought to an off-site disposal facility.

Alternative 3B- Hydric-Compatible Soil Cover, Excavation,Backfill and Off-Site Disposal ,

• Estimated Present Worth Cost: $9,500,000• Estimated Construction Time: 12 months• Estimated Cover Cost, Present Worth: $285,000• Estimated O&M Cost, 1 year Present Worth: $244,000

This alternative is similar to Alternative 3A except the ResponseAreas were adjusted to require additional excavation nearresidential areas. Specifically, this alternative would

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excavate, remove and backfill soils above 30 ppm total PCBs inFEUs 2 and 3, and above 400 ppm total PCBs in FEUs 4, 6 and 8,and place soil cover over soils above 8 ppm total PCBs in FEUs 2and 3, and above 50 ppm total PCBs in FEUs 4, 6 and 8.Excavation would be limited to 12 inches. Excavated soil wouldbe disposed of at an off-Site landfill. Physical inspections andchemical sampling would be part of long-term monitoring.Wetlands mitigation at off-Site locations is also considered.Approximately 9,300 cubic yards will be excavated and removedfrom the FWA under this alternative, and brought to an off-sitedisposal facility.

Alternative 4 - Hydric-Compatible Soil Cover

• Estimated Present Worth Cost: $5,800,000• Estimated Construction Time: 12 monthse Estimated Cfover Cost, Present Worth: $285,000• Estimated O&M Cost, 1 year Present Worth: $244,000

This alternative is similar to Alternative 2, except the soilcover and erosion protection mat would be placed over a largerResponse Area than Alternative 2. Specifically, cover would beplaced over the Response Areas which exceed 10"6 remedial riskobjectives in both the residential and industrial FWA areas.Physical inspections and chemical sampling would be part of long-term monitoring. Wetlands mitigation at off-Site locations isalso considered.

Alternative 5 - Excavation, Backfill, and Off-Site Disposal

• Estimated Present Worth Cost: $19,000,000• Estimated Constriction Time: 12 months• Estimated Cover Cost, Present Worth: $569,000• Estimated O&M Cost, 1 year Present Worth: $73,000

This alternative consists of site preparation, institutionalcontrols, revegetation, excavating, and backfilling with hydric-compatible soils over Response Areas. Excavation would belimited to 12 inches. Specifically, this alternative wouldexcavate, remove and backfill soils from FWA Response Areas whichexceed 10"6 remedial risk objectives in both the residential andindustrial FWA areas. Physical inspection and chemical samplingwould be part of long-term monitoring. Wetlands mitigation atoff-Site locations is also considered. Approximately 28,500cubic yards will be excavated and removed from the FWA under thisalternative, and brought to an off-site disposal facility.

Alternative 6 - Excavation, Backfill, Thermal Treatment ofPCB-Contaminated Soil, and Off-Site Disposal

• Estimated Present Worth Cost: $21,300,000• Estimated Construction Time: 12 months

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• Estimated Cover Cost, Present Worth: $569,000• Estimated O&M Cost, 1 year Present Worth: $73,000

This alternative is similar to Alternative 5, except that, inlieu of off-Site landfilling, excavated material exceeding 500mg/kg PCBs would be transported off-Site for thermal treatment.Specifically, this alternative would excavate, remove andbackfill soils from FWA Response Areas which exceed 10"6 remedialrisk objectives in both the residential and industrial FWA areas.Physical inspections and chemical sampling would be part of long-term monitoring. Wetlands mitigation at off-Site locations isalso considered. Approximately 28,500 cubic yards will beexcavated and removed from the FWA under this alternative, andbrought to an off-site disposal facility.

Alternative 7 - Hydric-Compatible Soil Cover,Excavation, Backfill, and On-Site Disposal

e Estimated Present Worth Cost: $6,900,000e Estimated Construction Time: 12 monthse Estimated Cover Cost, Present Worth: $60,000e Estimated O&M Cost, 1 year Present Worth: $111,000

This alternative consists of site preparation, institutionalcontrols, revegetation, excavation and backfill, and theplacement of a hydric-compatible soil cover and erosion mat overResponse Areas. Specifically, this alternative would excavate,remove and backfill soils above 30 ppm total PCBs in FEUs 2 and3, and above 50 ppm total PCBs in FEUs 4, 6 and 8, and place soilcover over soils above 6 ppm total PCBs in FEUs 2 and 3.Excavation would be limited to 12 inches. Excavated soil wouldbe disposed of at an on-Site landfill located at a selectedindustrial facility within the Fields Brook Site. Wetlandsmitigation at off-Site locations is also considered. In additionto excavation and backfill activities, a 6-inch soil cover wouldbe placed over all soil areas with PCB contamination of 6 ppm to30 ppm in FEU2 and FEU3. Physical inspections and chemicalsampling will be conducted as a part of long-term monitoring tohelp ensure that the cleanup activities in both of these areasremain protective of human health and the environment.Approximately 15,300 cubic yards will be excavated and removedfrom the FWA under this alternative, and brought to an on-sitelandfill.

IX. SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES

The National Contingency Plan (NCP) requires that thealternatives be evaluated on the basis of the following nineevaluation criteria: (1) Overall protection of human health andthe environment; (2) Compliance with applicable or relevant andappropriate requirements (ARARs); (3) Long-term effectiveness and

24

permanence; (4) Reduction of toxicity, mobility, or volumethrough treatment; (5) Short-term effectiveness; (6)Implementability; (7) Cost; (8) State acceptance; and (9)Community acceptance. This section compares the alternativeswith regard to these nine evaluation criteria.

A) THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMANHEALTH AND THE ENVIRONMENT AND COMPLIANCE WITHAPPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS(ARARS):

Alternative 1, the No Action Alternative, would result inunacceptable risks under current conditions due to thedetrimental impacts on human and ecological receptors which maybe occurring under current conditions.

Alternatives 2, 3A, 3B, and 4 include either a cover alternativesolely involving 6 to 12 inches of soil cover, or limited FWAsoils and sediment excavation with cover alternatives involving 6to 12 inches of soil cover, which may cause a detrimental impactto the wetland ecology and ecological receptors. Thesealternatives may not be protective because they may result inunacceptable risks to humans in the event that the higherconcentration contaminants reach the cover surfaces over time.These alternatives also would not comply with the TSCA disposalregulations. Therefore, Alternatives 2, 3A, 3B, and 4 areeliminated from further consideration.

Of the remaining alternatives, all are protective of human healthand the environment. Alternatives 5, 6 and 7 all provide asimilar level of significant risk reduction and involve a greaterdegree of excavation and removal of FWA soils than the otheralternatives. Over the long term, Alternatives 5, 6 and 7 wouldbe more protective, effective and permanent.

Excavation alternatives, in general, meet the protectivenessobjectives regarding exposure to chemicals in FWA soil andsediment. While excavation completely removes chemicals from thesoil column, it generally destroys the habitat in place.Although some wetland communities (those dominated by annualgrasses or herbaceous vegetation) can be effectively restored ina relatively short time period, others (dominated by woodyspecies) cannot be restored in a relatively short period. Theecological value of the latter is generally high, and destructionof such habitats has negative impacts. Much of the Fields BrookFWA is wooded. Over much of the area, excavation techniques willresult in destruction of valuable habitat.

Clean cover reduces the potential for chemicals to be exposed tohumans and to the bioaccessible and bioavailable pools.Alternatives providing 6 inches and 12 inches of cover wouldoffer reduction in ecological exposure. Long-term reduction of

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ecological exposure depends in part on the long-term integrity ofthe cover.

As discussed previously, plants growing in the FWA, includingvegetables grown in the FWA, generally do not pick up organiccontamination such as PCBs and HCBs, and are not generallyconsidered media containing hazardous substances of concern.However, roots and vegetative materials growing in areas of FWAsoil contamination planned for remedial activity may beconsidered contaminated in part because the contaminated soilparticles may be closely associated with and inseparable from theroots and vegetative materials.

Under the 6-inch and 12-inch cover options, while potential forexposure is reduced, chemicals will remain in the potentialexposure pool. Twelve-inch covers offer greater margin of safetyfor long-term protection, but may be likely to stress most trees,and a number may be killed by reduced oxygen ration. Inaddition, the wetland character of the FWA would likely bedegraded, and substantial areas of wetland may be lost as aresult of placing a 12-inch cover. Effects from a 6-inch coverwould be less severe. Transition communities or even communitiesexpressing primarily upland character are likely to occur morereadily on a 12-inch cover, and thus the habitat may change overtime. A 6-inch cover is unlikely to stress woody vegetation.Understory, shrub and herb layer communities are likely to re-establish in largely their present configurations, although somewetland character may be lost. Such losses may be minimal,however, because the existing FWA has relatively substantialelevation differences relative to water table, and wetlandvegetation is pervasive.

Cover technologies would be most-suitable for areas withrelatively low levels of contamination, in part because of theuncertainty associated with the surfacing of COCs. With cover inplace, the biologically active surface soil and litter layerswill develop and function. In the ecosystems of the FWA, covertechnologies placed over areas with relatively low levels ofcontamination would offer adequate exposure reduction forecological receptors with less habitat destruction thanexcavation. A well designed, installed, and maintained coverwould provide long-term protection for ecological receptors.

During construction activities there is a possibility that therecould be releases of contaminants to the air above acceptablelimits which assure protection of human health and theenvironment. Air monitoring during construction activities inthe FWA and brook sediment areas will be conducted to help assurethat no unacceptable levels of air contaminants are releasedduring the cleanup. The levels will be compared to short-termindustry standards to ensure protectiveness, as well as to long-term calculated levels. If any unacceptable releases are found,

26

cleanup activities would immediately be adjusted to preventunacceptable releases of air contaminants.

The potential for recontamination of Fields Brook sediment fromreleases of any residual FWA soil contamination after FWAremediation occurs is expected to be low, particularly for theexcavation alternatives, for several reasons. Because the FWACUGs are lower than the brook pediment CUGs, the FWA soils afterremediation will have lower average residual concentrations ofcontaminants than the residual average concentrations in brooksediment, and would thus not be likely to cause recontamination.Also, the 8/94 sediment scour analysis conducted during the brooksediment remedial design indicates that floodplain soils wouldnot be expected to erode from hydraulic scour during a 100-yearrainstorm. Further, the 5/95 "FWA Field Reconnaissance and PhotoDocumentation Report* indicates that the FWA is (and would likelyremain) flat and well covered with leaves, shrubs and vegetationwhich would help prevent releases of contamination. The scourand reconnaissance reports are available for review in theinformation repositories. Lastly, post-remediation monitoringand operation and maintenance inspections will help ensure thatthe surfacing of elevated levels of FWA contamination would notoccur.

All of the alternatives except no action include a number ofcommon actions that are necessary to address site risks or toachieve ARARs, including the following:

1. Site access restrictions;

2. Institutional controls;

3. Additional investigation;

4. Long term monitoring;

5. Remediation of contaminated FWA soils and sediments;

6. Compliance with floodway/floodplain regulations; and

7. Compensation for loss or damage to wetlands.

The ARARs for these remedial actions are indicated in Tables 4-1and 4-2, and include in part the following:

surface water quality standards, including the NPDES program(Clean Water Act Section 402, 40 CFR 122, 123, 125, 131Pretreatment Regulations (40 CFR 403), The State of OhioNPDES requirements (OAC 3745-33), the State of Ohio WaterQuality Standards (OAC 3745-1); and the State of OhioPretreatment Rules (3745-3);

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actions to minimize the destruction, loss, or degradation ofwetlands in Executive Order 11988 and 40 CFR 6, Appendix ASection 6(a)(5);

air limits to be met on-site during the cleanupactivities, including limits set by OSHA (29 CFR 1910);NAAQS (40 CFR 50); various other sections of the CleanAir Act (and various federal air regulations) between40 CFR 1 to 99: and various OEPA standards, includingAmbient Air Standards (OAC 3745-17-02A,B,C); Control ofVisible Particulate Emissions (OAC 3734.02(1)); andother State of Ohio requirements;

regulations and restrictions on construction withinfloodways and floodplains, including Permits for Dischargesof Dredged or Fill Materials (33 CFR 320 to 330, Sections401 and 40^ of the CWA): and Protection of Floodplains (40CFR 6, Appendix A):

TSCA disposal regulations at 40 C.F.R. § 761.60 fit aejj., areapplicable to PCBs in concentrations of 50 pptn or greater(PCBs) when such PCBs are "taken out of service". Under theremedial actions being considered, TSCA disposal regulationscould be triggered by excavation of PCBs which may occurduring the excavation of sediments and soils. Pursuant to40 C.F.R. § 761.60(a)(4), PCBs must be disposed of: "(i) inan incinerator which complies with 761.70; or (ii) in achemical waste landfill which complies with 761.75." TheTSCA compliant chemical waste landfill disposal method isgenerally much less expensive than incineration.

Alternatives 5, 6 and 7 would all be consistent with the ARARsindicated on Tables 4-1 and 4-2, particularly the OEPArequirements for disposal of solid waste and TSCA requirementsfor'disposal of regulated PCB soils and solid waste.

B) PRIMARY BALANCING CRITERIA: LONG-TERM EFFECTIVENESSAND PERMANENCE; REDUCTION OF TOXICITY, MOBILITY ANDVOLUME THROUGH TREATMENT; SHORT-TERM EFFECTIVENESS;IMPLEMENTABILITY; AND COST.

Alternatives 5, 6 and 7 provide for increased long-termeffectiveness and permanence because they include the/ removal ofsoil from areas of highest contamination concentration in theFWA, and the covering of these areas of high contamination maynot be permanent nor effective.

None of the alternatives except Alternative 6 include treatmentof principle threat wastes in order to reduce toxicity, mobility,or volume of the contamination. Principle threats include wasteswhich can not be reliably controlled in place such as liquids,highly mobile materials, and high concentrations of toxic

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compounds. Where treatment technologies are not technicallyfeasible or available within a reasonable timeframe, theextraordinary size or complexity of a site makes implementationof treatment technologies impracticable, or implementation of atreatment-based remedy would result in a greater risk to humanhealth or the environment, treatment may not be practicable. Duein part to the significant volume and heterogeneous distributionof waste at the Site, treatment as a principle element is notconsidered practicable at the Site.

Also, the contaminated FWA soils will be essentially comprised ofnon-mobile contamination, because they will be dewatered beforedisposal and the contaminants within the soils will be non-liquidand adsorbed to soil. The FWA soils were contaminated bydeposition of contamination which was flowing in Fields Brook,and is mostly if not totally comprised of contaminated sediments ^^deposited from tlie brook during large storm events. During 1994design investigations conducted for the Fields Brook sedimentremedy, several leachate samples were taken from untreatedsediment samples taken from four sediment locations with thehighest detected sediment contamination in the brook downgradientof the major source areas of contamination. The sediment inthese areas had elevated levels of PCBs, volatile organics andother contaminants. These leachate samples did not contain anylevels which were above hazardous waste levels (i.e., the levelswere below the Toxic Characteristic Leachability Procedure (TCLP)levels established under U.S. EPA's RCRA program under 40 CFR261.24) and thus did not exhibit the characteristic of toxicity.These studies, which are in the information repositories, providesufficient information that the FWA soils would not requiretreatment through solidification because they would not beconsidered hazardous by toxicity characteristic under RCRA, andbecause the contaminated soils would not be expected to releasetoxic liquids once landfilled regardless of the volume ofleachate produced. Also, once the excavated FWA soils aredewatered and placed into the double-lined landfill withoutsolidification, even if leachate releases did occur, there are aseries of measures which will detect, stop and treat suchreleases in the landfill area before any unacceptable risk tohuman health of the environmental occurred.

In addition, principle threat wastes generally include wasteswith concentrations greater than a 10"4 cancer risk at a site,and there are no residential or industrial FWA exposure unitswhich have principle threat concentrations of contaminants onaverage greater than a 10"4 cancer risk for the FWA. The cleanupobjectives for contaminants in the FWA include to remove orappropriately contain contamination to levels which for eachcontaminant which are, on average, at or below the cleanup goals(CUGs). The CUGs for total PCBs in the residential andindustrial areas of the FWA are set at 1 ppm in the residentialarea and 6 to 8 ppm in the industrial FWA areas on each side of

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the brook in each exposure unit. There are no residential orindustrial FWA exposure units which have existing concentrationsfor any contaminant (including total PCBs) which on average wouldpresent greater than a IxlCT4 human health risk. FWA's 2, 3, 4,6, and 8 have an average total PCS concentration of approximately50-60 ppm, and the excavated soils will have a low averageconcentration of between 100-150 ppm total PCBs. Thus, for thesereasons treatment would not be practicable or required.

However, treatment is a secondary element in that landfillleachate liquids, if they are generated, will be collected andtreated resulting in destruction of hazardous substances. Thus,if contaminated liquids leach from the landfilled material, theseliquids will be collected and treated.

No significant short-term risks nor implementability problems areexpected during.construction or soon after construction ofAlternatives 5 through 7. There may be difficulty in restoringthe wetland environment to the preconstruction degree ofvegetation, in part because the removal of large trees from anyexcavation areas and smaller trees from cover areas may changethe ecosystem significantly enough that regrowth of the samespecies may not occur. Alternatives 5 through 7 would alsoprovide for short term effectiveness, in part because thesignificant areas of contamination within the FWA would becovered or excavated and removed. This would over the short termeffectively prevent exposure to significant contamination. Airmonitoring will be conducted during construction activities tohelp assure that no unacceptable levels of air contaminants arereleased during the cleanup.

Alternatives 5 and 6 are more expensive because they requireexcavation of all of the contamination present in the FWA abovethe cleanup goals and the off-Site disposal and/or treatment ofthese excavated materials. Alternative 7 is estimated to costbetween $12 and $14 million less than Alternatives 5 and 6.

C) MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE;COMMUNITY ACCEPTANCE.

The State of Ohio, through OEPA, has had a number of concernsregarding the preferred remedial alternative and itsprotectiveness of human health and the environment, cjioes notconcur with the U.S. EPA preferred alternative, and Jias statedthat substantially more contaminated FWA soils should beexcavated from the FWA in order to achieve a more protectiveremedy for the environment. Specifically, OEPA wanted U.S. EPAto select a variation to Alternative 5 which would remove 13,200additional cubic yards of lower-level contaminated soils overAlternative 7, at an increased cost of approximately $5.1 millionover the $6.9 million cost of Alternative 7. OEPA also felt thatthe exposure frequencies should have been more conservative than

30

those U.S. EPA used in the FWA human health risk assessment.OEPA wanted additional days/year for the exposure assumptionsused in developing the cleanup goals {CUGs) for the FWA. U.S.EPA's development of the CUGs assumed that people would beexposed at certain frequencies in the residential and industrialareas. In the residential area, U.S. EPA assumed that someonewould be exposed to FWA surface soils 61 days per year forchildren, 110 days/year for adolescents and 37 days per year foradults, for a total of thirty years. In the industrial area,U.S. EPA assumed that someone would be exposed to FWA surfacesoils 60 days per year for a total of twenty five years. OEPAfinds that 270 days/yr for ages 0-30 would be appropriate, inpart because contamination is located in FWA areas directlybehind residences, and in part because only three months of theyear have an average daily temperature below 32° F for theAshtabula area. .

U.S. EPA has considered the potential effect of not removingmaterials below 30 ppm total PCBs in the residential FWA area,and below 50 ppm in the industrial FWA area, and finds that theproposed remedy would be protective of both human health and theenvironment. The relatively low level of potential increasedprotectiveness provided by the increased FWA soil excavationdesired by OEPA in the above-noted variation of Alternative 5does not offset the increased costs required to implement thisalternative over the cost of Alternative 7 (i.e., $5.1 millionincreased costs). Alternative 7 offers the best balance betweenprotectiveness and cost effectiveness of all alternatives,including the variation of Alternative 5 described above.

As previously stated, U.S. EPA's review of the informationregarding human exposure to FWA soils indicate that frequentexposure to FWA soils is not likely. The cleanup in the FWAsoils provided by Alternative 7 will reduce potential cancer riskto approximately one chance in one million after cleanup. Theselevels are within the overall remedial action objective targetrisk level (10~6) which is being selected for this remedy.

The highest calculated post-remediation Hazard Quotient ("HQ",which is a term used to assess the potential effects toecological receptors of concern) was below 5 for Alternative 7,and for most receptors of concern was below 1, for eachcontaminant within the FWA, as indicated in the 10/96 FWAFeasibility Study, Attachment 1. These levels are Within anacceptable range and within an order of magnitude of theacceptable post-remediation objectives U.S. EPA strives toachieve for all ecological cleanups. U.S. EPA believes that theresponse actions to be conducted as proposed for the FWA soilswould protect the various populations of plants and animals whichexist or may exist along the floodplain area for this site.Alternative 7 will significantly reduce the short- and long-termrisks to ecological populations and reduce these population's

31

potential uptake of contamination via soil and food to acceptablelevels of exposure. Also, the additional damage to the wetlandsthat would occur under the variation to Alternative 5 describedabove also weighs against this alternative.

U.S. EPA provided a public comment period on the FWA ProposedPlan from November 13, 1996 through December 17, 1996, andconducted a public meeting on the FWA Proposed Plan on November21, 1996 in Ashtabula. Upon a request received from the U.S.Department of Interior (U.S. DOT) on behalf of the NaturalResource Trustees (i.e., U.S. DOI, the State of Ohio and theNational Oceanic and Atmospheric Administration) associated withthis site, the public comment period was extended to January 17,1997. U.S. EPA's response to the public comments received aresummarized in the attached Responsiveness Summary, which isAttachment 1 of this Record of Decision.

X. THE SELECTED REMEDY

The selected remedy is Alternative 7, which involves installationof a hydric-compatible soil cover, excavation, backfill, and on-Site disposal of excavated materials. The attached EvaluationTable (Table 5) indicates that Alternative 7 provides the overallbest tradeoffs with respect to the nine evaluation criteria.Alternative 7 is the most cost effective alternative whichreduces exposure to contaminants by removing the soil with themost elevated concentrations of contaminants from the FWAenvironment via excavation and on-Site consolidation, and bycovering areas of relatively low level contamination. Theresponse areas involving areas with FWA contamination at or abovecertain PCB and HCB concentrations discussed below are indicatedfor Alternative 7 in Figures 3 through 8. The exact dimensionsand locations of the cover and excavation limits will bedeveloped during the design of U.S. EPA!s selected remedialalternative.

Specific requirements of this selected remedy are provided below.

A) Detailed Requirements of the Selected Remedy:

1) Remedial Action Objectives and Cleanup Goals

The remedial action objectives of the selected remecjy are toreduce the potential for human health cancer risk to one chancein one million or lower after cleanup, and to reduce thepotential for human health non-cancer risks to levels that are nolonger considered toxic to humans. The remedial actionobjectives also are to reduce the potential for ecological riskto levels that would protect the various populations of plantsand animals which exist or may exist in the FWA. In addition,the remedial action objectives are to avoid or minimize

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destructive impacts to the FWA from construction activities andthe final remedy to the extent practicable in order to protectthe ecological value and existing habitats of the FWA.

The cleanup goals (CUGs) of the selected remedy are the averageconcentration per FEU for each contaminant of concern within theFWA at which the remedial action objectives noted above would bemet and at which exposure by people, plants and animals would beprotective. The CUGs are based on a human health risk associatedwith IxlO"6 range for carcinogens and hazard index of less thanone for non-carcinogens. The CUGs are also within an acceptablerange and within an order of magnitude of the acceptable post-remediation objectives U.S. EPA strives to achieve for allecological cleanups.

The CUGs for each of the FWA contaminants are listed in Tables 2-1 through 2-4 of* this ROD. Copies of U.S. EPA's 10/20/94 letterwhich includes calculations used to develop these CUGs, andcopies of U.S. EPA's 1/31/94 letter which indicates RadionuclideContamination CUGs, are included in U.S. EPA's October 1996 HumanHealth Risk Assessment report. An explanation of the developmentof the CUGs is included as an attachment to U.S. EPA's October1996 Human Health Risk Assessment report.

Regarding ecological risk reduction based on a cleanup to theCUGs, the highest calculated post-remediation Hazard Quotients("HQ", which is a term used to assess the potential effects toecological receptors of concern) are below 5 for Alternative 7,and for most receptors of concern are below 1, for eachcontaminant within the FWA, as indicated in the 10/96 FWAFeasibility Study, Attachment 1. These levels are within anacceptable range and within an order of magnitude of theacceptable post-remediation objectives U.S. EPA strives toachieve for all ecological cleanups. The response actions to beconducted under Alternative 7 would protect the variouspopulations of plants and animals which exist or may exist alongthe floodplain area for this site and will significantly reducethe short- and long-term risks to ecological populations andreducing these population's potential uptake of contamination viasoil and food to acceptable levels of exposure. It should alsobe noted that the HQ calculations were developed usingconservative assumptions which would help provide forprotectiveness to ecological receptors. 'iThe only exception to the CUGs listed in Tables 2-1 through 2-4are the CUGs for total PCBs in the residential and industrial FWAareas. The total PCS CUGs are set at an average of 1 ppm in theresidential area and an average of 6 to 8 ppm in the industrialFWA areas on each side of the brook in each exposure unit.Regarding the PCB CUGs, U.S. EPA calculated two separate humanhealth cancer risk CUGs for PCBs in the Human Health RiskAssessment, one set of CUGs based on the revised CSF and one set

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based on the former CSF. The recently revised and current CSF of2.0 results in PCB cancer risk CUGs of 1.2 ppm on average inresidential areas and 9.6 ppm on average in industrial areas.The former CSF of 7.7 results in PCB cancer risk CUGs of 0.3 ppmon average in residential areas and 2.5 ppm on average inindustrial areas. Both of these calculations were reported inthe human health risk assessment because the timing for the slopefactor revision was unknown when the risk assessment was draftedin the summer of 1996.

Upon consideration of the various issues associated with PCBrisks at the Fields Brook site, U.S. EPA has made a riskmanagement decision and has set the total PCB CUGs for thefloodplain/wetlands operable unit as follows: 1 ppm on average inresidential areas, 6 to 8 ppm on average in industrial areas.These FWA PCB CUGs are slightly lower in concentration than CUGsbased solely on,the recently revised CSF, and slightly higherthan CUGs based solely on the former CSF. These FWA PCB CUGs arebased on U.S. EPA's risk management decision to be protective ofecological receptors at the site, and to attempt to be protectiveand account for the uncertainties regarding the endocrinedisrupter health effects. Also, this decision reflects U.S.EPA's attempt to account for the potential synergistic effects ofthe multiple contaminants in the FWA which may increase healthrisks associated with the predominant chemical of concern in theFWA, which is/are PCBs.

Regarding the need to be protective of ecological receptors atthe site in developing the FWA PCB CUGs, the 1986 FWA EcologicalRisk Assessment indicated the potential for significant risks toecological populations associated with exposure to PCBs. Itshould be noted that although a FWA remedy which meets the totalPCB CUG of 1 ppm on average in residential areas and 6 to 8 ppmon average in industrial areas may still result in chronic hazardquotients (HQs) which exceed a value of 1 for several species (asdiscussed above), and that HQs above 1 may indicate a risk ofadverse effects to species, U.S. EPA believes that a FWA remedywhich meets the above noted PCB CUGS would protect the variouspopulations of ecological receptors which exist or may existwithin the floodplain area for this site. The response actionswould reduce the short- and long-term risks to ecologicalpopulations and reduce these population's potential uptake ofcontamination via soil and food to acceptable levels ,of exposure.

Regarding the need to attempt to be protective and account forthe uncertainties regarding the endocrine disrupter healtheffects in developing the FWA PCB CUGs, it should be noted thatalthough the PCB cancer risk slope factor changed based on thefinal reassessment report of September 1996 from 7.7 to 2, asnoted within the 1996 Human Health Risk Assessment, at this timethere is no agreed-upon quantitative method within U.S. EPA toincorporate the endocrine disruption data into a toxicity value.

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There is reason to believe that the endocrine, disrupter effectmay be the most sensitive health effect of PCB exposure. Also,U.S. EPA's general practice is to err on the side of cautionregarding use of uncertain data; the endocrine disruptionuncertainties provide justification for the use of a conservativePCB cleanup goal calculation. As endocrine disrupters, PCBs havethe potential to negatively impact the developing fetus, increasevulnerability to certain cancers, and possibly decreasefertility. While an RFD has not been calculated based on theseendpoints, the current evidence suggests that PCBs have thepotential to disrupt the endocrine system.

2) Excavation, Cover, and Disposal Requirement*:

a) excavate all soil in residential areas withtotal PCB contamination above 30 ppm and HCB above 80 ppm, andexcavate all sofl in industrial areas above 50 ppm total PCBs andover 200 ppm HCBs;

b) cover all soil in residential areas with totalPCB contamination between 6-30 ppm PCBs with 6 inches of hydric-compatible soil, and revegetate using erosion mats and nativevegetation;

c) transport excavated soils, construction debris,and roadways to a containment cell (landfill) to be built on oneof the industrial properties located within the Fields Brookwatershed;

d) remove all trees in excavation areas, and alltrees below 12-inch diameter in cover areas; regarding the treesto be left standing in cover areas, avoid compaction of the rootsand fill to be placed around the trees, and use constructionequipment equipped with a retractable boom if feasible so thatthe equipment stays outside the dripline of the trees; regardingroots, any roots, subsurface vegetative materials, or othervegetative materials downed before remedial activities commenced,which are in response areas or require removal to conduct theremedy will be considered contaminated; any live vegetation aboveground surface not contaminated with soils or sediments and whichcan be adequately spray washed if necessary, may be considerednot contaminated, and generally may be mulched, and used for siterestoration; and '

e) backfill all excavation areas with hydric-compatible soils and revegetate using erosion mats and nativevegetation.

3) Landfill Requirements

The on-site landfill to be constructed would be located on one ofthe industrial properties in the Fields Brook watershed. It

35

would have a bottom liner and would be covered with a plasticliner, clean soil and vegetation. It would be surrounded by afence with signs posted every 100 feet warning of the presence ofhazardous substances, and would have future monitoring andsampling to ensure it remains protective. To assure long-termeffectiveness and protectiveness, the landfill would beconstructed to meet the following minimum requirements:

a) Bottom Liner (from bottom to top, as indicatedin Figure 9)*

• choose area where underlying clay is expected to becontinuous, sand lenses not known to exist, and ground waternot known to be contaminated if possible; grade to level;

• 6-inch thick compacted in-situ clay; the bottom of the clayshall be at least 5 feet above the historical high groundwater table

• 60-mil flexible synthetic membrane liner (FML) which has apermeability equivalent or less than lxlO~14 cm/sec

• 6-inch thick sand/gravel.with leachate detection system• 60-mil FML liner• 6-inch thick sand/gravel with leachate collection system• dewatered contaminated soils/sediment (no rocks/sharp

materials near bottom)

b) Cover (from bottom to top, as indicated inFigure 9)j

grade12-inch thick clean soil/gravel (consider need for soil gascollection or vents)40-mil FML liner, keyed in1/4-inch thick geonet liner24-inch thick topsoilrevegetatedowngradient wells, one upgradient minimum, for monitoringpurposes

4) Post-Cleanup Sampling Requirements

Post-remediation sampling would be initiated in the FWA toevaluate the remedial action in both the residential andindustrial FEUs. The sampling program would involve the followingcomponents:

a) Residential FEUs (FEUs 2 and 3):

• 10 samples across both FEUs are planned to be taken eachyear, at locations in the FWA to be determined each year atU.S. EPA's discretion

• analyze for total PCBs year 1 through 4• analyze for nine chemicals of concern in year 5 (i.e.,

arsenic, benzo(a)pyrene, beryllium, hexachlorobenzene,hexachloro-butadiene, .PCBs, 1,1,2,2,-tetrachloroethane,

36

tetrachloroethene, and trichloroethene)• review results each year, evaluate data to assess the need

for further sampling and potential changes in samplinglocations, and evaluate the need for remedy repairs, inaccordance with the Superfund Program's National ContingencyPlan regulation (40 CFR Section 300)

• regarding duration of this sampling, post-remediationmonitoring will extend at least for a period of 5 years; atthe end of the 5 year period, a re-evaluation will be madeas to the appropriateness of extending the monitoring timeperiod (post-remediation monitoring will not necessarilyterminate after 5 years)

b) Industrial FKUa (FEUa 4, 6, and 8)*

• 15 samples across the three FEUs are planned to be takeneach year, £t locations in the FWA to be determined eachyear at U.S. EPA's discretion

• analyze for PCBs in year 1 through 4• analyze for nine chemicals of concern in year 5 (i.e.,

arsenic, benzo(a)pyrene, beryl1ium, hexachlorobenzene,hexachloro-butadiene, PCBs, 1,1,2,2,-tetrachloroethane,tetrachloroethene, and trichloroethene)

• review results each year, evaluate data to assess the needfor further sampling and potential changes in samplinglocations, and evaluate the need for remedy repairs, inaccordance with the Superfund Program's National ContingencyPlan regulation

• regarding duration of this sampling, post-remediationmonitoring will extend at least for a period of 5 years; atthe end of the 5 year period, a re-evaluation will be madeas to the appropriateness of extending the monitoring timeperiod (post-remediation monitoring will not necessarilyterminate after 5 years)

5) Remedial Activity Locations

Figures 3, 4, 5, 6, 7, and 8 indicate the FWA areas in theresidential areas (FEU2 and FEU3) located between East 16thStreet and Route 11, and in the industrial areas (FEU4, FEU6, andFEU8) located between Route 11 and about 2,000 feet east of StateRoad, where remedial activities would take place underAlternative 7. /

iTo implement the remedy, additional delineation sampling will beconducted prior to the beginning of remedial constructionactivities to ensure that the response areas are properlydefined. In each FWA exposure unit prior to the beginning ofconstruction, one PCS sample will be taken and analyzed in every2,500 square feet residential FWA area (i.e., one sample everyfifty feet along all north-south and east-west directions), andin all but twelve 2,500 square feet industrial FWA areas, which

37

are downgradient or downstream of the FEU8 CUG exceedence areas.The twelve industrial FWA areas which are not planned to besampled in this delineation effort are located near or along theouter edge of industrial floodplain areas where CUG exceedenceswere not previously indicated. Eight of these locations are inFEU 6 along the southern edge of the FWA in fenced-in areas ofthe RMI-Extrusion property, and four of these locations are inFEU 8 on the northeast edge of the FWA. In addition, HCBdelineation samples are required to be taken around proposedresponse areas in FEU's 4 and 8 which were developed due toelevated HCB sampling results. U.S. EPA finds it acceptable tonot do further delineation sampling in existing areas alreadyslated for response actions.

Excavation and cover of contaminated sediments and surface soilswill occur in those FWA areas designated for excavation, and willbe refined through the delineation sampling. It is anticipatedthat based on the data previously collected and to be collectedas described above, the excavation limits can be defined withoutadditional sampling to be conducted during construction.

6) Other Requirements

A temporary access road would be installed along most of thefloodplain area. This temporary road would be made of crushedstone and would have periodic access points to existing roadways.It would be removed after construction and disposed of properly.The temporary access road would allow access to and along thefloodplain areas from the roadways during construction, be madeof crushed stone and 1/4-inch thick geonet liner, and will beremoved after construction and disposed of either in the on-sitelandfill or if clean in other on-site or off-site areas.

The destruction, loss, degradation or disturbance of any FWAareas not slated for remedial response activity due to impactsfrom construction activities and the final remedy should beavoided or minimized to the extent practicable, because theecological value of the FWA is generally high and destruction ordisturbance of existing FWA habitats would have negative impacts.

Long term operation and maintenance and post closure care of theremedial action must be conducted to help ensure the remedy'seffectiveness.

Institutional controls must be placed on deeds and title forproperties where: contamination will remain in the FWA; thelandfill will be constructed; or hazardous substances, pollutantsor contaminants will remain above levels that allow for unlimiteduse and unrestricted exposure. For the landfill, the deedrestrictions must prevent residential, industrial or otherdevelopment on the landfill. For all other properties, the deedrestrictions must provide notice to any subsequent purchaser or

38

prospective developer of the presence of hazardous substances andof the requirement to conduct all development activities in sucha manner as to not release contamination towards Fields Brook,

Reviews of the selected remedy must be conducted every five yearsafter the remedial action is initiated to assure that humanhealth and the environment are being protected by the remedialaction. This is required because hazardous substances,pollutants or contaminants will remain in the FWA and in thelandfill area above levels that allow for unlimited use andunrestricted exposure.

Access restrictions must be provided to help ensure that thepublic is protected from and adequately warned of potentialexposure to the hazardous substances remaining at the site.These provisions, shall minimally include enclosure of the entirelandfill area with a fence with signs posted every 100 feetwarning of the presence of hazardous substances.

B) ARARft to b« M«tx

Section 121(d) of CERCLA requires that Superfund remedial actionsmeet ARARs. In addition to ARARs, the ARARs analysis which wasconducted considered guidelines, criteria, and standards usefulin evaluating remedial alternatives. These guidelines, criteria,and standards are known as TBCs ("to be considered") . Incontrast to ARARs, which are promulgated cleanup standards,standards of control, and other substantive environmentalprotection requirements, criteria or limitations, TBCs areguidelines and other criteria that have not been promulgated orare not directly applicable. The selected remedy will complywith the ARARs and the TBCs listed in Tables 4-1 and 4-2 whichare attached to this ROD.

Location-specific ARARs establish restrictions on the managementof waste or hazardous substances in specific protected locations,such as wetlands, floodplains, historic places, and sensitivehabitats. Table 4-1 provides a listing of location-specificARARs for the selected FWA remedy. Action-specific ARARs aretechnology-based or activity-based requirements or limitations onactions taken with respect to remediation. These requirementsare triggered by particular remedial activities that are selectedto accomplish the remedial objectives. The action-specific ARARsindicate the way in which the selected alternative must beimplemented as well as specify levels for discharge. Table 4-2provides a listing of the action-specific ARARs for the selectedFWA remedy. The action-specific ARARs listed in Table 4-2include the Ambient Water Quality Criteria and the Ohio WaterQuality Standards, which contain specific standards that would beapplicable if remediation water or treatment plant wastewater isdischarged directly to Fields Brook or the Ashtabula River.Chemical specific ARARs are incorporated into Tables 4-1 and 4-2.

39

In addition to the water quality criteria, substantiverequirements of National Pollutant Discharge Elimination System(NPDES), as implemented under Ohio regulations, would also beapplicable to wastewaters planned to be discharged to FieldsBrook which will require treatment. These wastewaters includeliquids generated during construction activities such asdewatering liquids, excavation area liquids, and liquidsgenerated during construction of the on-site consolidation area.Discharges to Publicly Owned Treatment Works (POTWs) may bepursued as an alternative discharge location. However, suchdischarges must also comply with limitations to ensure acceptabledischarge from the POTW after treatment. The specific dischargelevels will be determined during the design stage in coordinationwith OEPA.

It is expected that most of the soils and sediments to beexcavated from the FWA for disposal into the on-siteconsolidation area landfill will contain PCBs exceeding 50 ppm.Excavation of these wastes and soils and consolidation on-sitewill be considered disposal of PCBs pursuant to 40 CFR 761.Kb).In this case, 40 CFR 761.60 (a) (2) requires any non-liquid PCBs atconcentrations of 50 ppm or greater in the form of contaminatedsoil, rags, or other debris to be disposed of in an incineratorwhich complies with 761.70 or in a chemical waste landfill whichcomplies with 761.75.

The selected remedy provides for disposal of the PCBs in alandfill that does not meet the following requirements of Section761.75(b): requirement for a fifty foot distance between bottomliner and historical high water table (761.75(b)(3). Pursuant to761.75(c) (4), the Regional Administrator may determine that oneor more of the requirements in 761.75(b) is not necessary toprotect against unreasonable risk of injury to health or theenvironment from the PCBs, and may waive such requirements. TheRegional Administrator has waived the requirements in761.75(b)(3) for a fifty foot distance between bottom liner andhistorical high water table for the following reasons:

1. the landfill to be constructed which includes a lowpermeability site cover, double lined unit, leachatecollection system, leachate detection system, a bottom clayliner which shall be at least 5 feet above the historicalhigh ground water table, long term monitoring, accessrestrictions, and institutional controls will provideprotection to human health and the environment againstunreasonable risks of injury;

2. no significant reduction in the long term risks would begained from the off-site disposal of the PCBs containedwithin the sediments and soils to be excavated;

3. the costs for off-site disposal of the PCBs is

40

potentially large; and

4. the consolidation unit to be built will provide foradequate protection of the underlying groundwaterresource.

Since the remedy provides for containment of the PCBcontamination above 50 ppm, no additional protection to thepublic health or the environment would be added by off-sitetransport and disposal of the soils in an off-site incineratorcomplying with 761.70 or in an off-site chemical waste landfillcomplying with 761.75(b), or by requiring the on-site landfill tocomply with all of the requirements of Section 761.75(b). Thisfinding and waiver is established by signature to this Record ofDecision, as required in 761.75 (c) (4) .

• (The material excavated for permanent disposal into the on-siteconsolidation unit will be consolidated and temporarily stagedand stored above the 100 year flood elevation on one of theindustrial properties. The on-site landfill must meet State ofOhio requirements for construction of a solid waste managementunit including setback requirements.

Regulations related to the dewatering of the soils and sedimentsprior to consolidation must be met, including 40 CFR264.228(a)(2), which requires elimination of free liquids byremoval or solidification. Thus, it is required that dewateringof the excavated soils and sediments to be landfilled will occurin part to ensure that no free liquids will remain in the soilsand sediments prior to disposal into the landfill unit.

Treatment and air emission requirements relevant to hazardouswaste in 40 CFR 260-268 are not anticipated to be ARARs since nolisted hazardous wastes are known to have been disposed of in theFWA. Also, leachate samples collected from sediments withinFields Brook were found not to be hazardous waste bycharacteristic. Notwithstanding the above determinationregarding placement or disposal, Tables 4-1 and 4-2 identifiesthe ARARs to be followed and met during implementation of theselected FWA remedy. While several of the regulations listed inTables 4-1 and 4-2 may not be applicable due in part to the aboveplacement and disposal determination, they are consideredrelevant and appropriate and thus must be met. '

Actions must be taken to minimize the destruction, loss, ordegradation of wetlands due to construction activities and thefinal remedy, including possible compensation for wetlands thatwill be adversely affected by the selected remedial action. Adetailed wetland mitigation plan is required prior toconstruction of the remedy. An evaluation of the effects of theexcavation on the wetland hydrology will have to be conducted.

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This evaluation will be prepared based in part on input from theU.S. Army Corps of Engineers and OEPA, and actions must beimplemented to provide for compliance with thefloodplain/floodway regulations. Various ARARs apply to thisissue, including Clean Water Act Section 404 and 401; ExecutiveOrder 119990; 40 CFR 6, Appendix A; and 40 CFR 6.302(g). Actionsmust be conducted as necessary to comply with the Clean WaterAct's Section 401 and 404 regulations, potentially includinginvestigations; modeling; alternative evaluation; creation ofcompensatory storage for lost flood plain storage; use ofartificial channels combined with detention facilities or othertechnologies to maintain stream capacity without increasing theaverage velocity through the Site; excavation of soils andsediments from the FWA and consolidation on-site; actions toprevent or minimize negative impacts on the wetlands due toconstruction activities and the final remedy; actions to minimizethe destruction, loss, or degradation of wetlands, includingcompensation for wetlands that will be lost or adversely affectedby the selected remedial action; and other actions determinednecessary.

XI. EXPLANATION OF SIGNIFICANT CHANGES

There are no significant changes from the recommended alternativedescribed in the proposed plan.

XII. STATUTORY DETERMINATIONS

U.S. EPA's selected alternative provides the best balance oftrade-offs among alternatives with respect to the criteria usedto evaluate remedies. Based on the information available at thistime, therefore, U.S. EPA believes the selected alternative willprotect human health and the environment, will comply with ARARs,would be cost-effective, and will utilize permanent solutions andalternative treatment technologies or resource recoverytechnologies to the maximum extent practicable. The selectedalternative will not satisfy the preference for treatment as aprincipal element.

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ATTACHMENT 1 TO THE RECORD OF DECISION SUMMARY

RESPONSIVENESS SUMMARYFLOODPLAINS /WETLANDS AREA

RECORD OF DECISIONFIELDS BROOK SITE, ASHTABULA OHIO

PURPOSE

This responsiveness summary has been prepared to meet therequirements of Sections 113 (k) (2) (B) (iv) and 117 (b) of theComprehensive Environmental Response, Compensation, and LiabilityAct of 1986 (CERCLA) , as amended by the Superfund Amendments andReauthorization Act of 1986 (SARA) , which requires the UnitedStates Environmental Protection Agency (U.S. EPA) to respond tothe comments submitted, either written or oral presentations, onthe proposed plan for remedial action. All comments received byU.S. EPA during the public comment period were considered in theselection of the final remedial alternative for the FWA,

This document summarizes written and oral comments receivedduring the public comment period of November 17, 1996 to January17, 1997. The comments have been paraphrased to efficientlysummarize them in this document. The public meeting was held at7:00 p.m. on November 21, 1996 in the Auditorium of the AshtabulaCampus of Kent State University in Ashtabula Ohio. A fulltranscript of the public meeting, as well as all written commentsreceived during the public comment period and all site relateddocuments, are available for review at the InformationRepositories, at the following locations: 1) Ashtabula CountyDistrict Library, 335 West 44th Street, Ashtabula, OH; and 2)U.S. Environmental Protection Agency, Waste Management Division,Records Center, 7th Floor, 77 West Jackson Blvd., Chicago, IL.

I. ComBTOts to 11/96 FWA Proposed Plan;

A) Written Comment B

Comment : Implementation of the preferred alternative(Alternative 7) , nor any of the other alternatives presented inthe Proposed Plan, does not provide adequate long term protectionfor the environment, including federal and State trust naturalresources. All of the alternatives leave significant residualSite contamination in the floodplain and wetlands which willcontinue to pose an unacceptable hazard and threat of injury totrust natural resources therein, as well as to the naturalresources of Fields Brook and its receiving waters. The trusteesbelieve that the ecological risks identified in the Siteecological risk assessments can and should be further reduced bymaking significant improvements to the alternative remedial

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actions. These improvements include, but are not limited to,environmentally sensitive adjustments of the proposed cleanupgoals, depth and area of excavation, habitat replacement andmonitoring.

Response: U.S. EPA believes that the response actions to beconducted as proposed through Alternative 7 in the FWA soilswould protect the various populations of plants and animals whichexist or may exist along the flbodplain area for this site, inpart by significantly reducing the short- and long-term risks toecological populations and reducing these population's potentialuptake of contamination via soil and food to acceptable levels ofexposure. Post-remediation hazard quotients (HQ's) for mostreceptors of concern are below 1 for each contaminant regardingexposure within the FWA, as indicated in the 10/96 FWAFeasibility Study, Attachment 1. For all receptors of concern atthis site, the highest post-remediation HQ's calculated was below5, which is within an acceptable range and within an order ofmagnitude of the acceptable post-remediation objectives U.S. EPAstrives to achieve for all ecological cleanups. Further, theplanned monitoring is sufficient to determine both theeffectiveness of the selected remedy and the need for any furtheraction.

Also, Executive Orders 11988 (Floodplain Management) and 11990(Protection of Wetlands) requires federal agencies to takeactions which minimize the potential harms to floodplains andwetlands if the only practicable alternative requiresconstruction in these areas. Within the FWA FS, comparativetrade-offs between the destruction of habitat in place and thereduction in residual chemical concentrations which would resultif additional excavations occurred in the FWA were considered.Alternative 7 offers the best balance between protectiveness,cost effectiveness and minimization of harm to the environment ofall alternatives, including the variation of Alternative 5described above, and would be protective of both human health andthe environment.

Comment; We disagree with the statement on page 3 that potentialrisks to the environment would be addressed if risks to peoplefrom ingestion of soil are addressed. The proposed cleanup goalson page 4 for PCBs (6 ppm residential and 50 ppm industrial) andHCBs (80 ppm residential and 200 ppm industrial) far'exceed theecological cleanup goals (0.37 ppm PCB and 0.59 HCB) calculatedby U.S. EPA-Edison in Table 1 (column 3, page 4) of the October1996 Baseline Ecological Risk Assessment Report (BERAR). Inaddition, the Proposed Plan does not stipulate cleanup goals fornine other Site contaminants, including mercury, lead, copper andcadmium, all of which have ecological cleanup goals specified(column 3, page 4) in the BERAR. Considering the great disparityin cleanup goals presented in the BERAR and Proposed Plan, we can

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not discern how U.S. EPA used the BERAR to help "form the basisfor this proposed remediation plan" (bottom of column 2, page 2).Until the Proposed Plan cleanup goals are shown to have a firmscientific link to the BERAR, we cannot agree with or supportthem as being protective of the environment, including our trustresources.

Response: U.S. EPA's 1994 "Ecological Risk Assessment Guidancefor Superfund" specifies that risk management decisions should beconducted by considering a range of risk estimates. Thisguidance characterizes this range, with one boundary to be setbased on conservative assumptions and one to be set based on lessconservative, measured site-specific values. Exposure factorsare incorporated in the risk range development. The FWA remedyis based on a range of cleanup goals as recommended in theguidance. The Baseline Ecological Risk Assessment Report (BERAR)identifies a range of values, appropriate as potentialremediation goals, for ecological receptors at the site. Thesevalues differ primarily on the level of assumptions used tocalculate parameters such as bioavailability, home range size,etc. Values developed by U.S. EPA Edison are acknowledged to bevery conservative and in some cases are below known backgroundconcentrations. The values identified in the BERAR were used inconjunction with other information to develop clean-up goalsconsidered appropriate for the site for protection of humanhealth and the environment.

Specific clean-up goals for other contaminants such as lead,copper and cadmium, were not specifically identified in theProposed Plan. Previous data analysis conducted as part of thehuman health assessment, as well as an evaluation of residualecological risk values (HQ's), indicated that other contaminantconcentrations would be proportionally reduced as concentrationsof PCBs and HCBs are reduced through adoption of the proposedremedial action plan.

Comment: U.S. EPA (top of column 1, page 4) states that PCBs andHCBs were the two compounds causing the majority of the humanhealth risk, and that if the cleanup activities removed theelevated areas of PCS and HCB soil contamination, then thecleanup would also remove other COCs because these exist whereelevated levels of PCBs and HCBs exist. Although this finding ismade in the context of human health, the U.S. EPA later states(middle of column 2, page 4) that the cleanup actions will alsoprotect the environment. Review of the FWA data indicatesarsenic concentrations at sample points outside the proposedcleanup areas which exceed the PRPs ecological cleanup goals 38times. Clearly, this Site contaminant, and possibly others willnot be affected by implementing the preferred remedy or any ofthe alternatives, and will continue to pose ecological risk.Therefore, the proposed remediation of PCBs and HCBs will not

45

simultaneously remove or contain elevated concentrations of allof the other COCs.

Response: In evaluating remedial alternatives, U.S. EPAconsidered residual risks associated with all chemicals ofpotential concern, including arsenic. Arsenic is one contaminantwhich has cleanup goals in the BERAR below background levels atthe site. Arsenic is present in the watershed as a naturalconstituent of the local geology at levels at which exposurerisks approximate those found in background areas. Since U.S.EPA generally does not require cleanup of contaminants belowbackground levels at sites, the arsenic cleanup goal for the FWAis set at the background level for the FWA, which is 27 ppm.Residual risk numbers were generated assuming area use factors of1 (100% of exposure being on-site) for a number of receptors,including the shrew, which had the highest residual arsenicexposure risks {BERAR, page 34). However, as indicated in thecomment response above, the highest post-remediation HQ'scalculated for all COCs for all receptors of concern at this sitewas below 5, which is within an acceptable range and within anorder of magnitude of the acceptable post-remediation objectivesU.S. EPA strives to achieve for all ecological cleanups.

Also, it is clear that the dominant risk in the FWA to both humanand ecological receptors is from PCB and HCB, and that thesignificant levels of all other COCs exist where elevated levelsof PCBs and HCB exist, as indicated in part by the 12/11/96 "FWADelineation Sampling Maps" deliverable from Woodward Clyde whichhas been included in the Administrative Record. Based on areview of the data, U.S. EPA has found that if a remedial cleanupto the HCB and PCB FWA CUGs on average throughout each exposureunit occurs, the low levels of all other contamination and otherCOCs remaining in the FWA after cleanup is completed would beprotective of both human health and the environment for eachexposure unit.

Comment: Page 5, Summary of Alternatives - bottom of 2ndparagraph and Page 8, item D) Remedial Activity Locations -middle of second paragraph: The PRPs are not in agreement withthe FWA delineation sampling program as described in the ProposedPlan. The PRPs described a delineation program to U.S. EPA thatinvolved further delineating existing response areas developed inthe PS. The PRPs did not propose to collect addition/al samplesat fifty-foot intervals in the entire FWA.

The text indicates that soil sampling data will be collected atfifty-foot intervals in the floodplain during delineationsampling programs. This could be interpreted to mean across theentire Floodplain/Wetland Area. The PRPs have concerns that U.S.EPA has misinterpreted the intent of the delineation samplingprogram discussed during the September 26, 1996 meeting and as

46

described in Section 4.5 of the FWA FS provided to U.S. EPA inOctober 1996. As a general comment, the PRPs do not intend tocollect soil samples in the entire FWA at fifty-foot intervalsacross the entire FWA, for the following reasons:

During earlier phases of the investigation more than 250floodplain samples have been collected in the five FEUs. Thesesampling programs were approved by U,S. EPA; in order tocharacterize the FWA, develop remedial alternatives and satisfyRemedial Investigation (RI) objectives regarding the nature andextent of the 11 COCs. The previous sampling programs were basedon systematic sampling along transects and spatially distributedso as to satisfy U.S. EPA concerns regarding definition oflocations of COC concentrations on both sides of Fields Brook.Grid sampling across the entire FWA is not necessary. It is awaste of financial resources.

If grid sampling were to be considered, it should have occurredin 1993-1994 when the RI activities were in progress and not atthe design phase of the project and would have replaced thesystematic sampling program (which was approved by U.S. EPA andimplemented by the PRPs).

Since the FS has been completed based on the approved systematicsampling program, and response areas identified, it isappropriate at this time to conduct a delineation samplingprogram to support the final FWA design. The purpose of thedelineation sampling program is to properly define the responseareas that have been developed in the FWA FS for cover andexcavation and substantially reduce the uncertainty that anysignificant contaminated areas have been missed. The FWA FSdescribed that the delineation sampling program was intended tofurther delineate current response area boundaries and sample inareas where data points are widely spread. The delineationsampling program intended to be conducted by the PRPs consistedof approximately 200 samples located within the FWA. A fifty-foot grid would be used to identify possible sampling locations,in order to better define response boundaries, fill in data gaps,and to develop cutlines for use in preparing design drawings.U.S. EPA requested that sampling maps be submitted prior to fieldwork in order to review proposed sampling locations. Thedelineation program and O&M sampling proposed by the PRPs wouldsupplement existing data and would be sufficient and protectivefor the proposed alternative.

Response: U.S. EPA has thoroughly considered this issue, andfinds that to provide better confidence in understanding theextent of contamination throughout the FWA, and to provideassurance that the response areas are properly and completelydefined, To implement the remedy, additional delineation samplingwill be conducted prior to the beginning of remedial constructionactivities to ensure that the response areas are properly

47

defined. In each FWA exposure unit prior to the beginning ofconstruction, one PCB sample must be taken and analyzed in every2,500 square feet residential FWA area (i.e., one sample everyfifty feet along all north-south and east-west directions), andin all but twelve 2,500 square feet industrial FWA areas, whichare downgradient or downstream of the FEUS CUG exceedence areas.The twelve industrial FWA areas which are not planned to besampled in this delineation effort are located near or along theouter edge of industrial floodplain areas where CUG exceedenceswere not previously indicated. Eight of these locations are inFEU 6 along the southern edge of the FWA in fenced-in areas ofthe RMI-Extrusion property, and four of these locations are inFEU 8 on the northeast edge of the FWA. In addition, HCBdelineation samples are required to be taken around proposedresponse areas in FEU's 4 and 8 which were developed due toelevated HCB sampling results. U.S. EPA finds it acceptable tonot do further delineation sampling in existing areas alreadyslated for response actions.

This degree of delineation is needed in part becausecontamination distribution is not even and consistent throughoutthe FWA. Review of the existing FWA data distribution alongvarious FWA outer edge areas, particularly in FEU4, hasdiscovered incidences of contamination at the 100 year floodplainline above the cleanup goals. In rare cases, the data along theouter edge of the FWA is higher in concentration than in FWAareas between the outer edge and the brook.

U.S. EPA is concerned that by not doing the 50' grid spacings invarious large industrial areas not currently slated for response,the results will be unacceptably biased towards a lessening ofthe response areas. Further, such sampling permits a lesseningof the degree of future O&M chemical monitoring to be conductedin part due to the expectation that the extent of contaminationwould be determined through 50' grid sampling in all FWA areas.

Comment: Page 7, item B), Landfill Requirements: Thedescription of the on-site landfill should be referred to as theon-site consolidation area, to be consistent with the FS text andlanguage used to describe this area by the PRPs.

Response: The on-site landfill may be described either as alandfill or a consolidation area, and inconsistenciep regardingthe reference to this unit would not change the components orrequirements for the installation or operation and maintenance ofthis unit. Thus, either of the two terms may be acceptably usedinterchangeably, and no text change is required.

Comment: Page 7, item B), Landfill Requirements: During theSeptember 26, 1996 meeting with the PRPs and U.S. EPA, the on-

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site consolidation area was described as a storage area thatwould contain materials from the following areas of the FieldsBrook site: a) Soil excavated from FWA response areas; b)Sediment excavated from Fields Brook as part of Sediment OperableUnit (SOU) remediation; and c) Excavated haul road material fromconstruction of FWA and SOU remedial areas.

Response: U.S. EPA would find it acceptable to place excavatedsediment from Fields Brook as part of Sediment Operable Unit(SOU) remediation and excavated haul road material fromconstruction of FWA and SOU remedial areas into the on-sitelandfill to be constructed for the disposal of FWA soils.However, these excavated materials to be placed into the landfillmust be shown not to be a "hazardous waste" as defined by U.S.EPA's RCRA program (i.e., the source area soils must not failRCRA's 'Toxic Characteristic Leaching Procedure1 testing).

Comment: U.S. EPA should consider the following variation toAlternative 5 (top of column 3f page 5): Excavation, Backfill,and On-Site Disposal. If disposal occurs in the "On-siteconsolidation area" (bottom of column 1, page 6), costs would bereduced from the $19.0 million cost of Alternative 5 by perhapsas much as $7.0 million. If this cost reduction is correct, thecost of this variation to Alternative 5 would be approximately$12.0 million. This figure is far more cost-effective thanAlternative 5 and much closer to the $6.9 million cost forAlternative 7. The main advantage to this variation toAlternative 5 is better protection for the environment throughincreased removal of contaminated soil (13,200 additional cubicyards would be excavated over Alternative 7, in accordance withthe proposed cleanup criteria and excavation depth) from the FWA.

Response: U.S. EPA agrees that on-site disposal is generallymore cost effective than off-site disposal, and agree inprinciple that the cost savings to Alternative 5 as noted abovemay be likely. However, the relatively low level of potentialincreased protectiveness provided by the increased FWA soilexcavation provided by this variation of Alternative 5 does notoffset the increased costs required to implement this alternativeover the cost of Alternative 7 (i.e., at least $5.1 millionincreased costs). Because the highest post-remediation HQ'scalculated were below 5 if Alternative 7 is implemented, andbecause the cleanup goals and remedial action objectives would bemet or exceeded for human health, Alternative 7 offers the bestbalance between protectiveness and cost effectiveness of allalternatives, including the variation of Alternative 5 describedabove. Also, the additional damage to the wetlands that wouldoccur under the variation to Alternative 5 described above alsoweighs against this alternative.

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Comment: We believe it is misleading to characterize (bottom ofcolumn 2, page 4) post-remediation residual PCB contamination asan average (1 ppm for the residential exposure units and 6 to 8ppm for the industrial exposure-units). The residual PCBcontamination should be characterized as a range of the lowestexisting concentration up to 6 ppm for residential and 50 ppm forindustrial. Since the post-remedial PCB concentrations wouldgreatly exceed U.S. EPA-Edison's BERAR ecological cleanup goal of0.37 ppm, we can not agree with U.S. EPA (middle of column 3,page 4) that the Proposed Plan cleanup goals represent acceptablelevels of exposure or will provide for the future health andviability of ecological populations.

Response: It was considered appropriate to characterize post-remediation residual concentrations as averages based on anunderstanding of most post-remediation exposure scenarios. Inmany cases, including both human and ecological receptors, post-remediation exposure is likely to occur over a certain unit areaover the site. The typical home range of many organisms is suchthat they are likely to be exposed to a range of concentrationswhich may be higher in some locations and lower in others. As aresult, exposure is expected to be represented by an averageconcentration within the exposure unit. For some species such asfield mice, however, exposure levels may represent more site-specific concentrations. For these species, however, exposure tohigher concentrations would occur to only a fraction of the totalpopulation of the species inhabiting the Fields Brook site.

Comment: We disagree with U.S. EPA's conclusion (page 4, column2, paragraph 3, and column 3, paragraph 3) that the residualcontaminant concentrations following remediation wouldnecessarily pose acceptable levels of exposure to ecologicalreceptors and thereby protect the environment. Much of thefloodplain lies within the riparian zone of Fields Brook and isclosely associated with the aquatic environment. Yet theecological risk assessments completed for the Site did notinclude a full assessment of the aquatic environment. Bioticsampling, such as fish tissue analysis for COCs, was notconducted to properly evaluate the risk to aquatic organisms andthe risk to terrestrial receptors such as the highly piscivorousmink and great blue heron. It is, therefore, imperative thatU.S. EPA require post-remedial biological monitoring of theaquatic and terrestrial environments in order to provide ascientific basis for verifying the presumed effectiveness of theproposed remedy. Until actual measurements of biotic systems areconducted, the trustees do not believe that U.S. EPA will be ableto adequately demonstrate whether the proposed remedy iseffective in protecting the environment.

The proposed post-remediation sampling (middle of column 3, page7} is currently limited to chemical sampling and analysis for a

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period of 5 years. Considering that the proposed cleanup goalsfor PCBs (6 ppm residential and 50 ppm industrial) greatly exceedthe ecological cleanup goals recommended in the BERAR (U.S.EPA-Edison 0.37 ppm and the PRPs Aroclor 1260 0.35 ppm), and thatseveral of the COCs bioconcentrate and/or biomagnify inecological food chains (e.g., PCS, HCB, cadmium, copper,mercury), we recommend that U.S. EPA require sampling andanalysis of COCs in floodplain flora and fauna as part of thepost-sampling requirements. We also strongly recommend that U.S.EPA extend the monitoring period at least 20 years in order toverify the long term environmental protectiveness of the remedy.This length of time is reasonable, considering that PCBs maypersist for 75 years or longer.

Table 1 of the BERAR (columns 2 and 3, page 4) lists ecologicalclean-up goals for the following Site contaminants that are notincluded in post*-remediation sampling (middle of column 3, page7): fluoranthene, napthalene, phenanthrene, hexachlorethane,cadmium, copper, lead, mercury and zinc. Please explain whythese contaminants are not included in post-remediation sampling.In addition, HCB should also be sampled along with PCBs in years1 through 4 because the cleanup and protectiveness of thepreferred remedy is based on the assumption (page 4) that if thecleanup activities removed the elevated areas of PCB and HCB soilcontamination, then the cleanup would also remove other COCs inthe floodplain area because this is where the other COCs exist.

Response: It is acknowledged that a full assessment of theaquatic environment of Fields Brook, which has only developedsince the brook became a continuous stream due to industrialdischarges, was not completed. To help ensure protectiveness ofthe aquatic environment, a separate focused ecological riskassessment of the brook sediment was recently prepared by U.S.EPA; this assessment estimates post-remediation risk levels toecological receptors such as mink who are or may be exposed, tothe brook. This focused assessment does recognize that the post-remediation average concentration chronic hazard quotient (HQ)calculations using the above noted cleanup goals indicate thatthere may be several species with HQ exceedences of 1, and thusthe potential still exists that there is a potential ecologicalresidual risk using the calculated cleanup goals.

However, U.S. EPA believes that the response actions/to beconducted based on cleanup of both the FWA soils and brooksediments based on the cleanup goals set for the brook sedimentand for the FWA soils would protect the various populations ofplants and animals which exist or may exist within the brook andalong the floodplain area for this site. The response actionswould reduce the short- and long-term risks to ecologicalpopulations and reduce these population's potential uptake ofcontamination via soil and food to acceptable levels of exposure.

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Regarding the brook cleanup, EPA's focused ecological riskassessment of the brook sediment indicated that post-remediationHQ's for most receptors of concern (ROC) are below 1 for eachcontaminant regarding exposure within the FWA. There were twocontaminants which had post-remediation HQ exceedences of 1 forbrook sediment for mink; for PCBs in FEU6, the HQ isapproximately 13, and for HCB, the HQ is approximately 6. U.S.EPA believes that the response actions to be conducted in FWAsoils and brook sediments would protect mink, in part because thetypical home range of mink is such that they would be exposed toan area encompassing several exposure units, and would also feedfrom areas within both the brook and FWA, as well as outside ofthis area. As a result, exposure to higher concentrations wouldoccur in only a fraction of the total food intake for mink, andthe population of the species inhabiting the Fields Brook sitewould be protected.

•Also, the surface sediments of the brook will be diluted withcleaner bedload stream sediments over time after the source area,brook and FWA remediations occur, and this will significantlyreduce the average residual sediment surface concentrations, forseveral reasons. The net average suspended sedimentconcentrations coming from source properties during storm eventsafter source remediation occurs will be well below CUGs, andsince the industrial properties comprise only approximately tenpercent of the entire brook watershed, the net suspended sedimentconcentrations from the brook watershed will likely be at or nearnon-detect levels for all contaminants of concern. Further, theupstream half of Fields Brook was never contaminated withsignificant levels of COCs, and future storms will move clean,non-contaminated sediments down from these upstream areas andcover up any residual low level contamination left in brooksediments after remediation. Thus, after brook remediation, thenet average residual concentrations in brook sediments whichcould be released during future storms are expected to be wellbelow the CUGs.

Also, as discussed in earlier comment responses, U.S. EPAbelieves that the FWA remedial response actions to be conductedwould protect the various populations of plants and animals whichexist or may exist along the FWA, in part because the FWA's post-remediation HQ's for mink are below 1 for each COC, below S forall other ROCs, which is within an acceptable range ^nd within anorder of magnitude of the acceptable post-remediation objectivesU.S. EPA strives to achieve for all ecological cleanups. Thus,U.S. EPA feels that sediments will be remediated to levelsprotective of aquatic receptors and wetland and terrestrialreceptors which might utilize the aquatic ecosystem.

Current post-remediation monitoring plans are to include samplingof soil and sediment within the Floodplain/Wetland Area. Thislevel of monitoring is appropriate to evaluate site conditions

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following clean-up. As with many baseline risk assessments,results of chemical analysis can be used in conjunction withacceptable exposure models to estimate potential risk levels toecological receptors at the site.

The range of post-remediation chemicals to be monitored do notneed to be increased at this time, because previous data analysisconducted as part of the human health assessment, as well as anevaluation of residual ecological risk values (HQ's), indicatedthat other contaminant concentrations would be proportionallyreduced as concentrations of PCBs and HCBs are reduced throughadoption of the proposed remedial action plan. The eleven keychemicals of concern, and primarily PCBs and HCB, will beanalyzed yearly for five years after cleanup, and thesecontaminants are the key indicators regarding whether the FWAremedy remains protective and whether chemical concentrations areincreasing or not in the FWA after cleanup.

Regarding duration of sampling, U.S. EPA's current recommendationis for post-remediation monitoring to extend for a period of 5years. At the end of the 5 year period, a re-evaluation will bemade as to the appropriateness of extending the monitoring timeperiod. Post-remediation monitoring will not necessarilyterminate after 5 years.

Comment: The post-remediation sampling does not provide actionlevels that will trigger additional remediation. U.S. EPA shouldestablish such action levels for both chemical and biologicalsampling in concert with the trustees.

Response: Action-levels which may trigger additional remediationhave not been identified at this time. Appropriate action levelswill be determined in the future as monitoring is conducted. Inthis way, action levels can be developed which incorporate themost recent toxicity information available for the contaminantand/or ecological receptor of concern. New data on contaminantaffects is continuously being developed, which can be applied inestablishing appropriate action levels. Establishment of actionlevels now, without the proper information, would be meaninglessand may limit application of information that may becomeavailable in the future.

Comment: The soil cover process option component of Alternative7, as well as alternatives 2 through 6, is referred to in theProposed Plan and Section 6.0 of the October 1996 FinalFeasibility Study as providing a "permanent remedy." However,this option would leave significant concentrations ofcontaminants in-place which could potentially become exposed toterrestrial receptors as well as recontaminate the streamchannel. In Alternative 7, only six inches of cover will be

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placed over PCB-contaminated soils ranging from 6 to 30 ppm.According to Table 5-1 of the Feasibility Study, the Alternative7 cover areas comprise 160,000 square feet or approximately 3.7acres. Since beaver dam induced stream re-routing has beendocumented in several exposure units at the Fields Brook Site,there is a very real potential for either beaver dam inducedstream re-routing or future meanders to cut through areas of thefloodplain containing soil that is contaminated above levels thatare considered protective of the aquatic environment. Inaddition, the COCs may be brought to the surface by fallen trees,wet periods, storm events and burrowing animals. Also, adding asix-inch soil cover may inhibit the growth of wetland vegetation.

Considering that the zone of biological activity is generallyagreed to be 12 inches, and that the Alternative 7 cover areaswould be contained in a dynamic environment subject to physicaland biological perturbations, we do not see how the U.S. EPAcould determine*with confidence that the 6-inch cover meets thecriterion for long term effectiveness and permanence. Thetrustees are doubtful that Alternative 7 fully meets theevaluation criterion for long-term effectiveness and permanencedue to the dynamic factors affecting the Site location andstability.

Response: A soil cover option for portions of the Fields BrookFloodplain Area is proposed as part of the plan for the site, andwould occur only in portions of the downstream half of the FWAremediation area. This option will be employed to areas with PCBconcentrations ranging from 6 to 30 ppm. Concentrations ofcontaminants which may exist under the clean cover layer mighteventually reach the surface, but the residual surface levelswould likely be lower than the concentrations of the soil underthe soil cover due to soil mixing which may be expected to occurdue to freeze/thaw, earthworm turnover and other phenomenon. Asa result overall soil concentrations at the surface are expectedto be lower than existing levels in the cover areas. Also, asdiscussed in the FWA FS report, there is no "general agreement"in the technical literature on a depth of a biologically activezone in environments such as the FWA.

Operation and maintenance (O&M) requirements for the site areproposed to control activities or actions which may alter streamflow routes. This is to include the riprap of stream banks tostabilize banks and reduce erosion potential. If beaveractivities threaten to alter the stream route, actioh will betaken as part of O&M to control such events. Possible streammeandering will be largely controlled by bank engineering in thepost-remedy environment.

Previous reviewers have identified the potential impact of soilcover placement on wetland hydrology within the floodplain areas.Section 404/401 of the Clean Water Act is an identified ARAR for

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the site. Issues relevant to wetland impacts are to be addressedin the Section 404/401 submittal that is a component of the 90%Design Phase. The potential for cover areas to reduce thewetland character of the floodplain vegetation has been accountedfor in the overall remedy. Wetland character will be retained tothe extent possible.

Comment: The description for Alternative 7, as well asAlternatives 2 through 6, state that wetlands mitigation will beconsidered. We request that the U.S. EPA establish wetlandsmitigation as a requirement based on ARAR compliance under theClean Water Act. There is no doubt that the activities being'discussed, i.e., vegetative clearing, excavation, filling, roadbuilding, use of heavy equipment, will harm wetlands.Consequently, we believe U.S. EPA should determine the amount,type, and location of replacement wetlands.

Table 5-1 of the October 17, 1996 Feasibility Study indicatesthat Alternative 7 affects 572,000 square feet of response area(excavation and cover area). We believe that most, if not all ofthis acreage (13.13 acres) is wetlands. However, U.S. EPA shouldconfirm the amount of wetlands being impacted by excavation andcover, and provide a breakdown of acreage by wetland types. Theamount and types of wetlands affected by the proposed access roadshould similarly be determined. We recommend that the U.S. EPArequire a minimum of 1.5 to 2.0 acre replacement for each acre ofaffected wetland. The exact amount of replacement within thisrange should be determined by the trustees and U.S. EPA based onour consideration of wetland value, scarcity and time needed torestore wetland functions. The replacement wetlands should belocated within the Fields Brook, or a nearby, watershed, andpreferably in one location.

We are concerned about the design and longevity of the proposedtemporary access road. This structure could interfere withfloodplain and wetland hydrology, become a source or cause oferosion and contamination, disrupt or interfere with wildlifemovements, and degrade or destroy adjacent wetlands. Werecommend that U.S. EPA coordinate the remedial design of thisroad with the trustees.

Response: Section 404/401 of the Clean Water Act is anidentified ARAR for the site. Issues relevant to wetland impactsincluding mitigation needs and roadway impacts will be addressedin the Section 404/401 submittal that is a component of the 90%Design Phase. The State of Ohio will be involved in this review,in part because it currently has the lead role in managing the401 program, and the State can coordinate reviews directly withthe other trustees when the 404/401 review occurs.

Also, this comment appears to assume that the remedy will

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eliminate wetlands in place. This is not true. Wetlandcharacter will be present in the post-remedy environment of theFWA, and will be encouraged by (as documented in the FS report)the use of hydric compatible soils for backfill and in thereplanting program.

Comment: Part of the plan for remediation of the FWA is to leavetrees greater than twelve inches diameter at basal height andbackfilling around them with six inches deep clean soil. Myexperience is that four inches of backfill over root zones issufficient to cause tree decline, although not necessarilyimmediately. It is my experience that whenever filling isplanned around existing trees, it is more economical to removeall existing trees prior to placing the backfill. This would beless costly to do now vs. five years from now, when installationand replacement,costs are taken into account, and in addition thereplacement tree will not have been retarded for five years.

Response: Although it is recognized that the potential for sometree death exists for the areas to receive soil cover, thereappears to be conflicting data on the level of potential risk totrees. For example, one reference (Harris, R. W., 1992,Arboriculture: Integrated Management of Landscape Trees. Shrubsand Vines. Prentice Hall) states that many species of trees arecapable of surviving burial of up to several feet of material.Eventually the root system grows up into the fill material or,depending upon the species, new roots may grow from the originalroot collar at the base of the tree or from the trunk itself.The concern is that the roots must receive adequate oxygen andnot be subjected to buildup of carbon dioxide. This referencealso recommends that compaction of the fill around the treesshould be avoided, and suggests using equipment with aretractable boom so that the equipment stays outside the driplineof the trees if feasible. This recommendation will beincorporated into the ROD for the placement of six inches ofclean soil cover in areas around all trees to be left standing inareas to be covered.

Also, potential tree deaths resulting from the cover option areto be addressed in the planned operation and maintenance (O&M)procedures for the site. The health of the large trees left inthe FWA in cover areas will be monitored on a regular basis afterthe cleanup occurs in part to determine if the trees, arestressed. If stress is indicated, steps may be taken during O&Mto modify the soil cover to protect the tree. If the treescannot be saved, the trees will be removed. Trees which diefollowing remediation are to be replaced, albeit with trees fromnurseries which have not yet reached maturity. Naturalrecruitment of trees in cover areas, as well as the planting oftrees and shrubs, will also occur following placement of thecover.

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Comment: U.S. EPA should emphasize function vs. character whenconducting replacement vegetation. Herbaceous reed, rush, sedgeand grass species thrive in hydric soils, control erosion, andenhance water infiltration, and can be first grown on 100%cocofibre mats which can then be placed down into the FWA as sodthereby providing almost instantaneous erosion control whichwould extend the planting window. If aesthetic concerns demandtree character, woody shrubs such as cornus stolonifra, treessuch as acer rubrum and/or fraxinus pennsylvanica lanceolata areriparian species that also have an attractive appearance. Thesetree species can be successfully grown in the bank zone, butshould be avoided in the splash zone.

Response: Future revegetation of areas disturbed during remedialactivities will include use of erosion mats and regrowth ofnative vegetatio'n. Additional information on revegetation of theFloodplain/Wetland Area, including which species will bereplanted to achieve the goal of revegetation of native speciesin disturbed areas, will be addressed in a separate submittalduring design of the FWA remedy.

Comment: Alternatives 5 and 6 (all excavation to 12-inch depth)seem to offer greater long term effectiveness and permanence thanAlternative 7, but even these alternatives would not provide fulllong term protection. U.S. EPA confirms (Questions and AnswersNo. 20, Fields Brook Superfund Site Information AvailabilitySession and Public Meeting, September 26, 1996) the contaminatedsoils below the 12-inch depth could be exposed by erosion duringflooding events. Further modifications of Alternatives 5 through7 would be needed to achieve a greater degree of long termeffectiveness. These changes include cleanup goals that providea greater reduction in environmental risk and excavation to depthof contamination. The extent of excavation should be driven bycompliance to the cleanup level established for the Site andshould not be limited by an arbitrary depth. By failing toexcavate the full extent of contamination exceeding cleanuplevels, the preferred and alternative remedies do not provide areasonable assurance of protectiveness. Current data gaps, withrespect to depth of contamination, should be addressed during theproposed design delineation sampling.

iResponse: Of the 23 deep soil samples taken between one-to-twofeet from the surface in the FWA, only two samples indicatedlevels of any contamination above the acceptable Cleanup Goallevels. These two locations are in the FWA soils betweenColumbus Avenue and East 16th Street. The levels ofcontamination at these locations are only slightly above thecleanup goal levels and in these two locations the surface soilswill be covered with six inches of clean soil. Since the FWA isprimarily a depositional area, contamination has been left in

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almost all areas within the top one foot of surface soils. Thus,excavations below one foot are not required to achieve aprotective remedy. Further, O&M for the remedy and the plannedmonitoring is sufficient to address these concerns and prevent orrepair the effects of significant erosion. Also, any buriedcontamination that would become exposed at the surface would notbe at its sub-surface concentration but at a lower level due todilution with clean soil.

Comment: Confining pollutants does not get rid of them. Shallowwells in our area have nitrate contents of up to 60 ppm which weattribute to the fertilizers used by the numerous nurseries inthe area. I favor Alternative #6 (incineration of wastes).

Response: Incineration of the lower-level contaminated soilswould be very expensive and would not be cost effective. U.S.EPA has considered the likelihood of direct exposure by people tocontaminated soils below the 6 inches of clean soil, and believesthat the cover activities in the residential area of the FWAcombined with the excavation activities will provide a protectiveremedy. The primary route of exposure to soils in the FWA isdirect ingestion of soils, and a soil cover will effectivelycontain the low-level contaminated soils in place and preventsurfacing of the contamination. The City of Ashtabula providesdrinking water to all residents in Ashtabula with water takendirectly from Lake Erie, and this water is tested regularly andhas not shown any exceedences of drinking water standards. Inaddition, nitrate is not one of the chemicals of concern withinthe FWA soils and incineration of nitrate contamination is notnecessary to provide for protection to human health and theenvironment.

Comment: U.S. EPA's proposed FWA remedial action involvesconstruction of an on-site landfill to be located on one of theproperties within the Fields Brook watershed. In addition toplacement of certain FWA soils into this landfill, it isrequested that U.S. EPA also allow placement of certain excavatedsoils from Source Control areas of the Fields Brook site into theon-site landfill (e.g., soils/sediment containing PCBconcentrations greater than 50 ppm originating from the ACMEproperty). The placement of this material into the dn-sitelandfill would be an alternative to transporting the'material toan off-site facility.

Response: U.S. EPA would find it acceptable to place certainexcavated soils from Source Control areas of the Fields Brooksite into the on-site landfill to be constructed for the disposalof FWA soils. However, the source control soils to be placedinto the landfill must be shown not to be a "hazardous waste" asdefined by U.S. EPA's RCRA program (i.e., the source area soils

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must not fail RCRA's 'Toxic Characteristic Leaching Procedure1testing). Also, the parties who will be constructing the FWAlandfill must agree to accept these soils.

Bi Verbal Comments to the Proposed Plan From 11/21/96 PublicMeeting

Comment: Why are we going to clean up Fields Brook and not cleanup the Ashtabula River? Fields Brook flows into the AshtabulaRiver, and the River flows into the Lake, where the Ohio WaterWorks pulls water from an outlet. Because the chemicalcontamination has been in both the brook sediments and FWA soilsfor approximately fifty years since the second world war, themajority of the contamination has already leached out of thesoils and sediments. However, when someone starts to move andchurn up the sediments and soils, there will be significantreleases of contamination, particularly during rainfall events.These releases would be unacceptable.

Also. Separate Written Comment: During times of northeasterlywinds, there is a significant increase in raw water turbidity,total coliform bacteria, and chlorine demand in the raw waterintakes located west of the mouth of the Ashtabula River in LakeErie which supply drinking water to the City of Ashtabula. Thisdegradation in raw water quality is attributable, in whole or inpart, to the influence of the Ashtabula River. The companysupplying water to the City of Ashtabula has monitored fororganics in the raw water for over a decade. While organics suchas PCBs, PAHs and HCB have never been detected in the raw waterat the treatment plan, such monitoring is requested to beconducted at the mouth of Fields Brook and at the mouth of theAshtabula River prior to, during, and for a reasonable period oftime after completion of the Fields Brook remediation project toassure that the safety and quality of the City of Ashtabula'swater supply is maintained in an uninterrupted manner.Representatives of U.S. EPA, OEPA, the City and the Water Companyshould meet to discuss monitoring locations and frequencies.

Response: Water from Fields Brook is not considered a source ofdrinking water in the area. Contamination from the Site has notbeen found in the City of Ashtabula's drinking water. Surfacewater samples were collected from the brook, river apd harborareas in the past. As a result of this sampling, it wasdetermined that the City of Ashtabula's water supply in Lake Erieis not being contaminated by discharges from the Fields Brook.The surface water sampling conducted within the Ashtabula Riverin 1991 and in earlier years did indicate a few exceedences ofchemicals regulated as U.S. EPA drinking water standards;however, no exceedences significantly above the drinking waterstandards were indicated. Also, since at least 1972, alloperating industries which discharged a significant amount of

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water to Fields Brook or the Ashtabula River were and arerequired to test their discharge water frequently (e.g., usuallyeither monthly or weekly, sometimes daily or continuously) andtreat their discharges if necessary to ensure that the water isclean.

The City of Ashtabula receives its water from an area of LakeErie which is almost always not impacted by Fields Brook and theAshtabula River; the only potential impacts may occur duringtimes of infrequent northeasterly winds. Public water systems ofthe size of Ashtabula's are required to monitor and test forvarious contaminants including most of the contaminants found inthe sediments and soils in and around Fields Brook. This testingis done every three months. None of these monitoring sampleshave found any contamination associated with the Fields BrookSite. To help ensure protectiveness,. the PRP group conductingwork at the Site also tested the City's drinking water in 1992 atthe intake point in Lake Erie and found no contamination in thewater. Therefore, the City's drinking water was not found to beimpacted by the Fields Brook Site, and is considered safe.

The proposed cleanup alternatives for the brook sediments and FWAsoils will require collection and treatment of any wastewatergenerated during cleanup operations. The treatment requirementsof this wastewater will be based in part on Ohio EPA's surfacewater discharge permitting requirements, and discharges will beregulated to ensure that the waters have been treatedsufficiently to assure protection of human health and theenvironment. During construction activities, the soils andsediment areas of the brook and FWA which will be disturbed willbe covered every evening. Actions will be taken to help ensurethat releases of contamination will not occur, such as coveringof disturbance areas with tarps, installation of silt fences indowngradient areas of brook construction to prevent releases ofsuspended sediments, and a three day limit for any brook sedimentareas to be left exposed during stream rerouting. Also, thebrook and FWA remedies will be conducted in segregated parts ofapproximately 100-200 foot lengths, to help ensure that largeareas of .disturbed soils are not left unprotected duringrainstorms which may occur. Work will also stop if releases areindicated or if a rainstorm appears imminent. U.S. EPA believesthese activities are sufficient to confirm the continuing lack ofimpact of dischargers from the Field Brook on the drinking watersupply for the City of Ashtabula. Thus, additional sampling isnot needed.

Regarding cleanup activities in the River, contamination found inFields Brook sediment has been shown to have migrated into theriver sediment and it may be necessary and appropriate toremediate those contaminants as part of the Fields Brook siteSuperfund remediation activities. A Public/Private Partnershipknown as the Ashtabula River Partnership (ARP) involving U.S.

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EPA, U.S. Army Corps of Engineers,, the State, City, local groups,local industries, local businesses, the County, and publicofficials was formally initiated in 1/94. The overall ARP goalsare to restore beneficial uses by removing the River'scontaminated sediments. The Superfund program is monitoringprogress of the ARP, and if the ARP develops firm plans toaddress the contaminated sediments, then U.S. EPA may suspend orstop its Superfund-related studies associated with the AshtabulaRiver.

Comment: Sediment was recently taken out of the Ashtabula Riverand dumped into a landfill in the Township area. The landfill isstill there. Is there going to be a new landfill located nearthat landfill? Doctors have said that the environmental air thatwe breathe can l e coming from this particular area. The proposedlocation for the new landfill is near residences, and we don'twant the landfill in our area .or in the City of Ashtabula.Ashtabula County has become a dumping ground for toxic waste,PCB's have been dumped already on West 38th Street, and in theeast side area.

Response: It is generally most cost-effective andenvironmentally safe to treat wastes on the site where the wasteswere deposited or generated. For the Fields Brook site, thiswill be within the watershed area of Fields Brook. U.S. EPAconsidered all possible areas within the industrialized areas ofthe Fields Brook watershed as the preferred location for thelandfill, since most of the residences and schools are separatedfrom these areas. After considering all possible areas, U.S. EPAnarrowed potential landfill locations to the Detrex, ACME and RMISodium facilities. The Detrex facility has a significantgroundwater plume of contamination, and the ACME facility hassignificant amounts of debris and other contamination throughoutthe property, which would create difficulties with locating alandfill. The RMI Sodium property location would generally meetor exceed regulations for siting landfills. This location willprovide at least a 2000 foot buffer from most of the residencesin Ashtabula, and would not involve any construction in wetlands,areas of high groundwater, or surface water bodies. For thesereasons, the preferred location at this time for the on-sitelandfill for the FWA soils to be excavated is on the RMI-Sodiumfacility, which is approximately one mile west of th'e landfillfacility where the Ashtabula River sediments which were dredgedin 1994 were brought.

The transport of sediments and FWA soils will be required to beconducted in a safe and clean manner. The trucks will havecovers which will prevent dust releases or spillages duringtransport from the brook and FWA area,

Once landfilling occurs, dredged soils and sediments generally do

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not release a sufficient amount of gas to cause a human healthconcern. Once all of the dredged sediments and soils are broughtto the landfill, the landfill is closed and covered with a thicklayer of clean soil in part to prevent rainwater from enteringthe fill area. The landfill will also have a plastic layerincorporated within the cover, have a grass surface, have a fencesurrounding the facility and have a series of plastic liners forleachate detection and collection. An anaerobic environment(i.e., without oxygen) will be created within the landfill whichwill hinder the release of gases from the fill material. Thelandfill will be monitored to assure it remains protective ofhuman health and the environment. While there would be eventualrelease of gases which may build up over time within the dredgedsediments, the rate of release is very low and thus would notlikely cause a health problem to anyone who may be walking nearthe landfill. Also, the greatest chance of releases of gasesfrom the dredged sediments is during excavation andtransportation, because this is when the sediments are mostexposed to the ambient air. During the Ashtabula River dredgingof 1994, the air was tested around all construction activityareas in order to determine whether any hazardous substances werebeing released, and this testing did not indicate that any levelsof hazardous substances above allowable health based levelsoccurred.

There is a possibility that there could be releases to the airduring construction activities above acceptable limits for humanhealth and the environment. Air monitoring during constructionactivities in the FWA and brook sediment areas will be conductedto help assure that no unacceptable levels of air contaminantsare released during the cleanup. Air samples will be taken andanalyzed at an approved laboratory; the U.S. EPA and OEPA willreview the results of this sampling. The levels will be comparedto short-term industry standards to ensure protectiveness, aswell as to long-term calculated levels. If any unacceptablereleases are found, cleanup activities would immediately beadjusted to prevent unacceptable releases of air contaminants.

The companies doing the cleanup work will collect the samples andmonitor the actual operation. Government oversight will beconducted to help assure that the cleanup is operated safely andaccording to environmental regulations. Performance informationwill be made available to the public as soon as it is" developedand verified. '

Comment: Once the FWA remedy is completed, will the source ofthe contamination to the brook and FWA area be stopped? Whyspend millions of dollars on cleaning up an area if it is goingto be recontaminated in the future. I don't think there is anyreal assurance that the sources of contamination will be cleanedup.

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Response: The Fields Brook Site investigations have foundsources of potential recontamination to the brook sediments andFWA soils on several of the industrial properties surrounding theBrook. These areas of contamination are planned to be cleaned upover the next several years which will help ensure that thesurface waters and FWA soils in the Ashtabula area will notbecome recontaminated in the future. Cleanup of these potentialsource areas will occur prior to or at the same time as cleanupof the FWA soils and Brook sediments, so that the Brook would notbe recontaminated after the Brook is cleaned. Sampling will beconducted in various areas within the Brook and along the FWAsoils after cleanup activities are conducted, in part to helpassure that the Brook and FWA cleanups remain protective overtime.

•Comment t Although the backfill areas and cover areas will berevegetated over time after the cleanup occurs, before thatvegetation is established, there will be a lot of erosion. Heavyequipment will compact the FWA soils which will change the FWAdrainage patterns. Removing vegetation prior to excavation andcover activities will also leave no roots and other vegetation tohold the soil down.

Response: There is a potential for future erosion of theexcavation and cover areas after cleanup activities occur. Also,it is expected that there will be some period of time neededbefore full revegetation of native plants occurs. Revegetationsequencing after remedial construction activities occur willinclude the initial establishment of grasses soon afterconstruction activities to help prevent erosion of disturbedareas. These grasses are expected to ultimately give way to theestablishment and regrowth of native vegetation after severalyears. Operation and maintenance (O&M) activities will also beregularly conducted and will begin soon after cleanup activitiesare conducted. All cover and backfill areas will be regularlyinspected during O&M, and remedial response areas which may beeroding or not revegetating will be corrected.

Comment: Homes in the residential areas from Columbus west orState Road west may be contaminated with contamination fromFields Brook and the FWA. Cleaning up the FWA and the Brook isthus a waste of money, and these homes should be bought up andthe whole area restricted from future access.

Response: For reasons noted below, U.S. EPA believes it is notnecessary to purchase the approximately 40 residences next toFields Brook between 16th Street and Route 11 in Ashtabula, theseveral homes next to the Brook near the Ashtabula River, and theseveral apartments and townhouses along the north side of FieldsBrook between 16th Street and Route 11. There is no evidence

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that the portions of the backyards of these homes and residenceswhich lie above the 100-year floodplain area of Fields Brook havebeen contaminated by Fields Brook. Further, a spread ofcontamination from Fields Brook to these immediate backyard areasof the homes along Fields Brook is not likely to occur. The FWAis generally topographically lower (i.e., 10-20 feet lower inheight) than the immediate backyard lawn areas of the homes alongthe brook; these immediate backyard areas are significantlyhigher than the 100-year FWA and thus it is very unlikely thatany contamination from the FWA area has reached the backyardareas due to deposition of sediment from rain events.

Comment: There is a lot of money available in Superfund. U.S.EPA should use the Superfund to clean up the site and not letspecial interest get in the way.

• *Response: Superfund enforcement requirements require that, on aSite-specific basis, the potentially responsible parties (PRPs),if identified, conduct the work at the Site. The PRPs havevoluntarily conducted extensive studies for the FWA, and haveindicated that they have spent close to $25 million thus far ininvestigation and design efforts associated with the FWA, brook,source areas surrounding the brook and the Ashtabula River.Although the PRPs have not yet signed agreements and settlementdocuments for conducting the cleanup construction activities forthe FWA, brook sediments, and source areas of contamination ofthe Fields Brook site, U.S. EPA expects that these settlementagreements with the PRPs will be signed within the next year.U.S. EPA and OEPA will oversee the activities of the PRPs.During a PRP cleanup, the primary function of U.S. EPA and OEPAis to ensure PRPs comply with all applicable laws, regulations,and requirements, and meet all performance standards specified inthe Settlement Agreement.

II. Comments to U.S. EPA's 10/96 Ecological Risk Assessment

Comment: EXECUTIVE SUMMARY, Paragraph 1, last sentence: ThePRPs identified "ECUGs" only for the convenience of U.S. EPA.The PRPs believed, and continue to believe, that such goals areinappropriate objectives for risk management. Risk reductionobjectives, rather than simplistic environmental medi'a cleanupgoals, are the most appropriate risk assessment standards forrisk management.

Response: Identification of "ECUGS" does not imply that clean-upgoals are the only objectives of risk management. ECUGS are usedin combination with other risk reduction approaches to managerisk at a site. U.S. EPA normally develops remediation goals andremedial action objectives to address both human health andecological risks which are identified. This is appropriate and

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necessary as part of cleanup decisionmaking at Superfund sites.

Cpmment: Paragraph 2, sentence 4: The PRPs ecological riskassessment employed appropriately conservative assumption andapplied reasonable input values based on site-specific data.These assumptions and values were carried through appropriatelyin the conclusion of the U.S. EPA Region V baseline ecologicalrisk assessment. In contrast, U.S. EPA-Edison risk assessmentapplies values which are technically inappropriate and which arenot conservative, they are simply wrong. For example, U.S. EPA-Edison assumed that maximum contaminant levels representedexposure, that area use factors were universally 1, and thatchemicals were 100% bioavailable. Such assumptions are onlyjustifiable in a screening level risk assessment according toguidance (U.S. EPA 1994), and are not"technically sound for moresite-specific and comprehensive risk assessment. More completeand comprehensive risk assessment under the guidance is to bebased on site-specific data and reasonable assumptions. Suchdata and assumptions were employed in the PRPs ecological riskassessment as reflected in the U.S. EPA Region V baseline riskassessment.

Response: The authors of the U.S. EPA-Edison risk assessmentapplied assumptions which were considered appropriate based onavailable data for the site. It was acknowledged thatassumptions used in Edison's risk assessment were conservative.As indicated in the report, several reviewers considered the useof the conservative assumptions appropriate given thecircumstances of available data and site condition.

Comment: INTRODUCTION, Page 1, paragraph 1, first bullet: ThePRPs risk assessment is not included in this report. The PRPsdocument was revised by U.S. EPA, and U.S. EPA should beconsidered the author of the revised risk assessment.

Response: It is acknowledged that the original PRP riskassessment is not included in the final report; however, it hasbeen provided to the Administrative Record of the Fields Brooksite in its original and unrevised form. A revised ecologicalrisk assessment based on the PRP document has been provided byU.S. EPA, and U.S. EPA did consider itself the author of thisreport.

Comment;: Page 1, paragraph 1, third bullet: The PRPs did not"develop" ecological clean-up goals, and does not believe thatsuch goals are appropriate for risk management. The PRPsprovided ECUGs based on risk assessment findings at the requestand for the convenience of U.S. EPA.

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Response: Refer to the "ECUG" comment response above.

Comment: Page 2, paragraph 4, first sentence: The baselineecological risk assessment report submitted by the PRPs inOctober 1995 is NOT "provided as Attachment I". Attachment I isa report prepared by U.S. EPA, incorporating numerous revisionsto an electronic text file provided by the PRPs.

Response: It is acknowledged that the original PRP riskassessment is not included in the final report; however, it hasbeen provided to the administrative record in its original andunrevised form. A revised ecological risk assessment based onthe PRP document has been provided by U.S. EPA, and U.S. EPA didconsider itself the author of this report.

•Comment: Page 2, last paragraph, bullets ff to page 4: Thesecond bullet identifies "probabilistic statistical approach" asan "unresolved issue". In practice, and according to draftagency-wide ecological risk assessment guidance (U.S. EPA 1996),probabilistic exposure estimates are technically sound and mostappropriate.

Response: Current guidance on ecological risk assessment (U.S.EPA, 1996) acknowledges the potential application ofprobabilistic exposure estimate techniques such as Monte Carlo.Probabilistic exposure assessment may be used to estimate high-end, individual exposure at a site; this effort is needed toconduct the risk assessment. If sufficient information about thevariability in lifestyles and.other factors is available tosimulate the distribution through the use of appropriatemodeling, e.g., Monte Carlo simulation, the estimate from thedistribution may be used. If only limited information on thedistribution of the exposure or dose factors is available, therisk assessor should approach estimating the high-end byidentifying the most sensitive parameters and using maximum ornear maximum values for one or a few of these variables, leavingothers at their mean values. In risk assessments where MonteCarlo analyses have been applied a range of exposure assumptions,including exposure frequency and duration, are created. TheMonte Carlo approach then develops a distribution from each ofthese individual parameters, which may be artificial; thengenerates a final risk distribution considering all inputparameters. The value of Monte Carlo simulations in estimatingexposure or risk probability distributions diminishes sharply ifone or more parameter value distributions are poorly defined ormust be assumed. The U.S. EPA ecological risk assessmentguidance also identifies several potential concerns inapplication of such models. Use of probabilistic models are notalways "most appropriate" and were not considered appropriate forthis study. U.S. EPA's 4/18/95 letter to the PRPs responded to

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the PRP's proposal to use probabilistic techniques within the FWAecological risk assessment; this 4/18/95 letter is provided as anattachment to the U.S. EPA 10/96 Human Health Risk Assessment forthe FWA.

Comment: Page 2, last paragraph, fourth bullet: This bulletidentifies use of fish tissue from upstream locations to estimate"current" risks to mink and heron. In fact, such a use was nevermade of these data. The PRPs were committed to remediation ofthe brook sediments prior to conducting the ecological riskassessment. Therefore, species potentially exposed via brookcomponents of the overall ecosystem in the context of thefloodplain wetland would only be exposed to post remedyconcentrations. The floodplain wetland ecological riskassessment has no role in determining-cleanup criteria for brooksediments.

Response: Comments on the use of upstream fish tissue areunclear. If data on upstream fish tissue concentrations were notused to estimate current risk, than the risk assessment documentfailed to fully characterize current risks to on-site receptorswhich may consume aquatic organisms. The fish data was used inpart to calculate HQ's. U.S. EPA had previously noted that useof the upstream areas of Fields Brook {Area 4) as a referencearea for comparisons of HQ values remains questionable, in partbecause previous chemical spills may have occurred in this area,because fish swim up and down the stream and would be in contactwith downstream contamination, and also because calculated HQvalues from the originally selected reference areas at nearbystreams (Red Brook and Whitman's Creek) could have been utilizedfor comparisons.

Comment:: Page 3, first full paragraph, last sentence andelsewhere: Repeated characterization of the database employed byU.S. EPA for ecological risk assessment as "questionable" isunnecessarily vague. Throughout the report, U.S. EPA shouldidentify clearly and quantitatively the weaknesses believed toexist in the information base and state the effect of theseweaknesses on the certainty with which risk assessmentconclusions are drawn. It is important to note that,, in contrastto statements made in U.S. EPA's baseline risk, a laxge data baseon site-specific chemical concentrations including measurementsin plant tissue, mammals, and invertebrate, has been obtained toreduce assessment uncertainty.

Response: Previous comments provided by other reviewers of theoriginal risk assessment report identified areas of concernregarding data quality. In its comments to the PRPs ecologicalrisk assessment, U.S. EPA also identified weaknesses in the dataquality. For example, compositing across several different

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species in determination of small mammal tissue concentrationswere identified as an issue of potential concern in datainterpretation. Also, U.S. EPA expressed concerns regarding odddata distributions and truncations which are not justified oradequately described. U.S. EPA also expressed concerns regardinginterpretations of data presented in such a way as to downplaythe results of tests (earthworm toxicity tests) and presentationand interpretation of statistical tests (composite biotasamples).

Comment: Page 3, second full paragraph, last two sentences:Compositing of Phase II samples is not justification foremploying highly uncertain and biased conservative inputassumptions. All Phase III samples were individual organismswhere appropriate, and there are no discernible differencesbetween these samples and the Phase II composites, indicatingstrongly that concern for potential to "obscure" elevatedcontaminant concentrations is misplaced. In addition, Phase IIsamples were composited (to make analytical mass thresholdrequirements) only within species and trophic guilds. All tissuemeasurement data employed in the risk assessment arescientifically sound, and examination of these data indicatesthat nothing is "obscured" by their application.

Response: Compositing of tissue samples was identified as onesource of potential uncertainty in the U.S. EPA-Edison riskassessment. Other sources of potential uncertainty were alsoidentified within the report including the lack of speciesspecific toxicity information. U.S. EPA's general practice is toerr on the side of caution regarding use of uncertain data; theseuncertainties are justification for the use of the conservativeinput assumptions.

Comment: Attachment 1, Authorship: This attachment was preparedby U.S. EPA, not by EA Engineering, Science and Technology. U.S.EPA modified an electronic text file prepared by consultants tothe PRPs, and is the sole author of this attachment.

Response: Acknowledged.

/Comment: Page x, last sentence: It would be helpful to havecitations for this statement, rather than the generalization thatthe application is "suggested by some authors" with noidentification of the scientific sources.

Response: The 'other authors' in question are more accuratelyidentified as previous reviewers to the risk assessment document,including U.S. EPA and Ohio EPA;

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Comment: Page 36, sections 5.1.9 and 5.1.10, last sentence ofeach: As discussed in comment for Page 3, second full paragraph,last two sentences above, compositing did not affect data qualitynegatively, and in fact allowed application of high massanalytical methods for Phase II data for comparison withindividual samples analyzed by low mass methods in Phase III.Because compositing clearly had no negative effect on dataquality, there is no justification on this basis for highlyuncertain and biased input assumptions.

Response: As indicated previously, use of conservative inputassumptions was based on several uncertainty factors, includingthe use of composited samples. It is not readily apparent that"compositing clearly had no negative effect on data quality" assuggested by the. reviewer.

Comment: Attachment 2, Page 2, paragraph 1, second sentence andelsewhere: Statement that "...very little data on the extent andmagnitude of contamination in the area was available to conductthis risk assessment..." is repeated elsewhere (for example, onpage 12), and is apparently used to justify the scientificallyuntenable assumption that maximum measured chemicalconcentrations appropriately represent ecological exposure. Infact, hundreds of samples of sediments and biotic tissue havebeen taken on the floodplain wetland, and have been reported inappropriate detail in project reports. This data, rather thaninappropriate assumption of measured maximum, should have beenemployed to represent ecological exposure.

Response: The U.S. EPA-Edison risk assessment document wasprovided in its entirety as an attachment. Authors of U.S. EPA-Edison assessment evaluated the data available at that time andutilized the data as was considered appropriate. In its commentsto the PRPs ecological risk assessment, U.S. EPA identifiedseveral weaknesses in the data quality.

Comment: Page 13, section 9.0: Cleanup goals based on maximumsite chemical concentrations will clearly lead to over-remediation, with associated needless habitat destruction andimpact of remedy. Given the large data base on the /distributionof chemicals in the floodplain wetland and the detailed reportingby location provided in project documents (for example, in the RIreport), use of maximum concentrations in this calculation isinappropriate and unnecessary.

Response: Refer to the "ECUG" comment response above.

Comment: Page 14, second full sentence: It is unclear why the

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statement was made that "No site-specific data was [sic]available for levels of COCs in plants or terrestrialinvertebrates". A number of site-specific measurements of tissueconcentrations in plant tissue and earthworms were made and.reported. This data should have been used to derive site-specific BSAFs, if needed for the risk assessment, rather thanemploying the generic and inappropriate assumption that BSAFsequal 1 .

Response: It is acknowledged that site-specific tissue data didnot appear to be used to estimate contaminant concentrations atupper trophic levels in the U.S. EPA-Edison risk assessment.Authors of the original U.S. EPA-Edison assessment considered thedata inappropriate for that application, in part because the datawas not complete enough to make conclusions for the entirewetland and in part because of concerns raised regarding dataquality. .

Comment : The FWA risk assessment follows a previous riskassessment done for the Fields Brook SOU, where PCS cancer riskswere assessed with a cancer slope factor of 7.7, and PCS non-cancer risks were assessed with an RfD of 1 x 10"4. At the timeof the SOU risk assessment, IRIS listed a CSF of 7.7, while noRfD for PCBs was given. The RfD used in the Fields Brook SOUrisk assessment was recommended by U.S. EPA Region V, and wasbased on a study of Aroclor 1016 in rhesus monkeys. Many PCBstudies have been completed since the SOU risk assessment, andIRIS now lists a revised CSF of 2.0 (high end of a recommendedrange) . There remains no RfD for PCBs, however ATSDR recommendsa minimum risk level (MRL) of 2 x 10"5, based on Aroclor 1254.The change in the CSF has the effect of reducing estimated cancerrisks, while the change in the RfD has the effect of increasingestimated noncancer risks. U.S. EPA does not consider therevised CSF in calculating cleanup goals, -which would havedecreased risks and raised the cleanup goal, but they do considerthe revised RfD, which increases risks. U.S. EPA does thisdespite the fact that the new CSF is listed on IRIS, whilesignificant doubt remains about the RfD. As a result, the FWArisk assessment contains an unfair bias because U.S. EPA hasfailed to accept a valid scientific basis for a change in thetoxicological factor if it leads to a decreased risk/.

Response: This issue relates to how U.S. EPA accounted for thenew cancer slope factor of 2.0 vs. the former cancer slope factorof 7.7 to derive the cleanup goal for PCBs. As noted in the RiskAssessment, U.S. EPA calculated two separate cancer risk CUGs forPCBs, one set of CUGs based on the revised and current CSF andone set based on the former CSF. The recently revised CSF of 2 . 0results in PCB cancer risk CUGs of 1 . 2 ppm on average in

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statement was made that "No site-specific data was [sic]available for levels of COCs in plants or terrestrialinvertebrates". A number of site-specific measurements of tissueconcentrations in plant tissue and earthworms were made andreported. This data should have been used to derive site-specific BSAFs, if needed for the risk assessment, rather thanemploying the generic and inappropriate assumption that BSAFsequal 1.

Response: It is acknowledged that site-specific tissue data didnot appear to be used to estimate contaminant concentrations atupper trophic levels in the U.S. EPA-Edison risk assessment.Authors of the original U.S. EPA-Edison assessment considered thedata inappropriate for that application, in part because the datawas not complete enough to make conclusions for the entirewetland and in part because of concerns raised regarding dataquality.

III. Commanta fco-BPA'a FWA Human Health Riak AM«Mm«nt;

Comment: The FWA risk assessment follows a previous riskassessment done for the Fields Brook SOU, where PCB cancer riskswere assessed with a cancer slope factor of 7.7, and PCB non-cancer risks were assessed with an RfD of 1 x 10~4. At the timeof the SOU risk assessment, IRIS listed a CSF of 7.7, while noRfD for PCBs was given. The RfD used in the Fields Brook SOUrisk assessment was recommended by U.S. EPA Region V, and wasbased on a study of Aroclor 1016 in rhesus monkeys. Many PCBstudies have been completed since the SOU risk assessment, andIRIS now lists a revised CSF of 2.0 (high end of a recommendedrange). There remains no RfD for PCBs, however ATSDR recommendsa minimum risk level (MRL) of 2 x 10~5, based on Aroclor 1254.The change in the CSF has the effect of reducing estimated cancerrisks, while the change in the RfD has the effect of increasingestimated noncancer risks, U.S. EPA does not consider therevised CSF in calculating cleanup goals, which would havedecreased risks and raised the cleanup goal, but they do considerthe revised RfD, which increases risks. U.S. EPA does thisdespite the fact that the new CSF is listed on IRIS, whilesignificant doubt remains about the RfD. As a result, the FWArisk assessment contains an unfair bias because U.S. 'EPA hasfailed to accept a valid scientific basis for a change in thetoxicological factor if it leads to a decreased risk.

Response: This issue relates to how U.S. EPA accounted for thenew cancer slope factor of 2.0 vs. the former cancer slope factorof 7.7 to derive the cleanup goal for PCBs. As noted in the RiskAssessment, U.S. EPA calculated two separate cancer risk CUGs forPCBs, one set of CUGs based on the revised and current CSF andone set based on the former CSF. The recently revised CSF of 2.0results in PCB cancer risk CUGs of 1.2 ppm on average in

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residential areas and 9.6 ppm on average in industrial areas.The former CSF of 7.7 results in PCB cancer risk CUGs of 0.3 ppmon average in residential areas and 2.5 ppm on average inindustrial areas.

Upon consideration of the various issues associated with PCBrisks at the Fields Brook site, U.S. EPA has made a riskmanagement decision and has set the total PCB CUGs for thefloodplain/wetlands operable unit as follows: 1 ppm on average inresidential areas, 6 to 8 ppm on average in industrial areas.These FWA PCB CUGs are slightly lower in concentration than CUGsbased solely on the recently revised CSF, and slightly higherthan CUGs based solely on the former CSF. These FWA PCB CUGs arebased on U.S. EPA's risk management decision to be protective ofecological receptors at the site, and to attempt to be protectiveand account for the uncertainties regarding the endocrinedisrupter healtji effects. Also, this "decision reflects U.S.EPA's attempt to account for the potential synergistic effects ofthe multiple contaminants in the FWA which may increase healthrisks associated with the predominant chemical of concern in theFWA, which is/are PCBs.

Regarding the need to be protective of ecological receptors atthe site in developing the FWA PCB CUGs, the 1986 FWA EcologicalRisk Assessment indicated the potential for significant risks toecological populations associated with exposure to PCBs. Itshould be noted that a FWA remedy which meets the total PCB CUGof 1 ppm on average in residential areas and 6 to 8 ppm onaverage in industrial areas, may still result in chronic hazardquotients (HQs) which exceed a value of 1 for several species (asnoted in the 10/96 FWA Feasibility Study, Appendix 1), and thatHQs above 1 may indicate a risk of adverse effects to species.However, U.S. EPA believes that an FWA remedy which meets theabove noted PCB CUGS would protect the various populations ofecological receptors which exist or may exist within thefloodplain area for this site. The response actions would reducethe short- and long-term risks to ecological populations andreduce these population's potential uptake of contamination viasoil and food to acceptable levels of exposure. It should alsobe noted that the HQ calculations were developed usingconservative assumptions which would help provide forprotectiveness to ecological receptors.

/Regarding the need to attempt to be protective and account forthe uncertainties regarding the endocrine disrupter healtheffects in developing the FWA PCB CUGs, it should be noted thatalthough the PCB cancer risk slope factor changed based on thefinal reassessment report of September 1996 from 7.7 to 2, asnoted within the 1996 Human Health Risk Assessment, at this timethere is no agreed-upon quantitative method within U.S. EPA toincorporate the endocrine disruption data into a toxicity value.There is reason to believe that the endocrine disrupter effect

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may be the most sensitive health effect of PCB exposure. Also,U.S. EPA's general practice is to err on the side of cautionregarding use of uncertain data; the endocrine disruptionuncertainties provide justification for the use of a conservativePCB cleanup goal calculation.

This decision is also supported by the 12/96 "Public HealthImplications of PCB Exposures" article prepared by the Agency forToxic Substances and Disease Registry and U.S. EPA. This studyindicates that exposure to PCBs in the Great Lakes area appearsto cause disrupt reproductive functions, cause neurobehavioraland developmental deficits occur in newborns which continuethrough school age in children, and result in developmentalproblems such as abnormally weak reflexes, greater motorimmaturity and less responsiveness to stimulation.

Also, as indicated in U.S. EPA's 10/22/96 article entitled "PCBs:Cancer-Dose Response Assessment and Application to EnvironmentalMixtures", there are a number "of uncertainties associated withthe effects of how environmental processes alter PCB mixturesafter release into the environment, and the resultantuncertainties associated with assessing risks posed by differentenvironmental mixtures once released. The report indicates thatamong the exposures associated with greatest toxicity andpersistence after release into the environment include ingestionof contaminated sediment or soil, which is the primary humanexposure route associated with the FWA.

Comment: Pages 4-3 and 5-3: Section 4.3.1 concerning toxicityvalues for PCBs states that the cancer slope factor is 2.0.While this is a true statement, it is misleading because U.S. EPAused the old cancer slope factor of 7.7 to derive the cleanupgoals.

PCB cancer risks were inappropriately calculated using the formercancer slope factor of 7.7 (mg/kg-day) . It was acknowledged inthe risk assessment that a new range of cancer slope factors hasrecently been established for PCBs, but these new values were notused. No scientific justification was provided to explain whythe former cancer slope factor was chosen instead of the recentlyreassessed value.

/In the risk assessment report, it is noted that the/former cancerslope factor of 7.7 (mg/kg-day)"1 was based on studies usingAroclor 1260. The recent PCB reassessment was described as a"joint consideration of cancer studies and environmentalprocesses [...] supported by several complimentary sources,"perhaps implying that the reassessed values are less valid. Infact, the upper bound slope of 2.2 (mg/kg-day)"1 calculated inthe recent PCB reassessment is based on the same rat study(Norback and Weltman, 1985) as the former value of 7.7 (mg/kg-

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day}"1; the reassessment simply corrected three errors that hadbeen made in the development of the 7.7 value. Specifically, therevised value took into account a 1991 reevaluation of the tumorhistopathology data, a new U.S. EPA cross-species scaling factor,and initial instead of time-weighted doses.

The statement "There is some evidence that mixtures containingmore highly chlorinated biphenyls are more potent inducers ofhepatocellular carcinomas in rats than mixtures containing lesschlorine by weight," (pg. 5-3 of the risk assessment) was anearly hypothesis, but has not been supported by more recent data.Based on information summarized in U.S. EPA'a 1996 PCBreassessment report, there is little if any evidence of aconsistent relationship between chlorination levels and cancerpotency. Aroclor 1016 (41% chlorinated) is much less potent thanAroclor 1242 (42% chlorinated), and analytical methods cannotreliably distinguish the two mixtures in environmental samples.Also, Aroclor 1254 (54% chlorinated) is more potent that Aroclor1260 (60% chlorinated) in female rats in the recentcarcinogenicity study sponsored by General Electric. It islikely that the cancer potency is far more dependent on theconcentrations of particular congeners. Unfortunately, therelative importance of each congener is only beginning to becharacterized.

Response: Cancer risks were calculated using both the 7.7 and2.0 cancer slope factors, and for risk management reasons(discussed in the previous comment response) U.S. EPA has decidedto use a more conservative PCB CUG than would be calculated basedsolely on the recently revised cancer slope factor of 2.0. Weare in agreement with Woodward-Clyde that the new cancer slopefactors reflect considerable effort by individuals in U.S. EPAand has resulted in an improved interpretation of data on theability of PCBs to cause cancer. As regards to relative toxicityof variously chlorinated PCB congeners, the comment is accepted.It was agreed upon by both U.S. EPA and the PRPs during meetingsin 1994 and 1995 to consider all of the Aroclor!s and congenerstogether as total PCBs in the risk assessment.

Comment: Page 4-4: The text (pgs. 4-4 and 6-5) notes thatendocrine disrupter effects "may be best modeled as linear andnon-threshold," and that they "could theoretically be'calculatedin a manner similar to the cancer slope factor." We 'disagree.Although the precise mechanisms of endocrine disruption are notwell known at the present time, the dose-response relationshipfor PCB endocrine disrupter effects is likely to have athreshold, similar to developmental and systemic effects inducedvia other mechanisms. Linear, non-threshold models are onlyappropriate for compounds that are thought to induce cancer bydirectly causing DNA mutations; endocrine disruption is notbelieved to involve mutagenesis.

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Response: The concept of how best to model toxicity mediated viaendocrine disruption is controversial and the scientific data areincomplete. It is therefore unclear whether these effects willultimately be modeled by assuming a threshold or by assuming alinear, non-threshold model. There are reasons to believe,however, that perturbations of a complex system such as theendocrine system (or the interacting endocrine, immunological andneurological systems) will be non-threshold and incremental.

Comment:: Page 6-4: There are several problems with thediscussion of uncertainty associated with the PCB cancer slopefactor on page 6-4 of the risk assessment. A significant problemis that only the draft PCB reassessment (January, 1996) isdiscussed. Since several changes were made in the finalreassessment report (September, 1996)",- this discussion should beupdated to reflect U.S. EPA's final recommendations. Forexample, while the draft reassessment recommended a specificadjustment to the exposure duration to reflect the persistence ofPCBs in the body, the final reassessment recognized potentialconcerns about persistent PCB congeners but did not recommend aquantitative adjustment. Also, it is incorrectly noted on page6-4 that "the new document describes PCB cancer potency using tworanges ..." [emphasis added]. In fact, while the draftreassessment recommended two ranges, the new, final reassessmentrecommended a total of six values - both a central and upper-bound slope value for three reference points (" high risk," " lowrisk," and " lowest risk" ) . Lastly, it is incorrectly noted inthe risk assessment report that the draft document includedguidance on the application of a cross-species scaling factor.While both the draft and final reassessment reports incorporateda cross-species scaling factor when modeling slope estimates, itwas not recommended that risk assessors apply an additionalcross-species scaling factor when assessing PCB cancer risks.

Responsei Comment accepted; since the results and summary of therisk assessment will not substantially change as a result of thiscomment, in part for reasons noted above in the comment responsesto the cancer slope issue, the FWA Human Health Risk Assessment,does not require change.

/Comment: Page 6-5: In the risk assessment, it was/ stated that"It is likely that the risk calculated from either of the cancerslope factor underestimates actual risk from the sit.e". Westrongly disagree with this statement. While there are numeroussources of uncertainty in PCB risk estimates (including endocrinedisrupter effects), numerous conservative assumptions are used sothat the results represent upper bound risk estimates. Forexample, it is noted in the Risk Assessment Guidance forSuperfund (RAGS) (U.S. EPA, 1989) that cancer risk estimatesbased on linear cancer models and an upper 95th percentile

74

confidence limit "will generally be an upper bound estimate.This means that U.S. EPA is reasonably confident that the truerisk will not exceed the risk estimate derived through use ofthis model and is likely to be less than that predicted." Thisfact is even noted in Table 7 of the U.S. EPA Fields Brook riskassessment.

Response: The cancer risk is an upper bound estimate of risk andtherefore likely overestimates calculated cancer risk. However,the statement in question was meant to reflect the entire scopeof PCB toxicity including endocrine disruption effects. Inaddition, the statement was intended to represent the limitationsin the risk assessment due to an inability to calculate a riskfor these more subtle endpoints.

Comment: Table»7: We have several concerns with the discussionof general uncertainty factors in Table 7. It is misleading torepresent many of these uncertainty factors as "over- orunderestimating risks," implying that each possibility is equallylikely, when in fact, they are far more likely to overestimaterisks. By definition, toxicity factors (slope factors andreference doses) are designed to err on the side ofoverestimating risks. For example, even though it istheoretically possible that humans could be more sensitive toPCBs than animals, an uncertainty factor is incorporated intotoxicity values to specifically account for this possibility.Furthermore, despite large numbers of PCB-exposed workers, PCBshave not been causally associated with cancer in humans based onepidemiology data. Another example is linear extrapolation fromhigh doses to low doses. This approach will only underestimaterisks if the dose-response relationship is superlinear (which hasnever to our knowledge been suggested for PCB carcinogenicity).

Response: U.S. EPA partially agrees with this comment. Safetyfactors are intended to overestimate risk and should be stated assuch. High dose to low dose extrapolations tend to overestimaterisk and should be noted as such. U.S. EPA disagrees about theanimal to human extrapolation. There is a great deal ofuncertainty in such an extrapolation and that uncertainty mayover- or underestimate risk.

tComment: Page 3-5: The U.S. EPA risk assessment is overly-critical of the exposure survey conducted by the PRPs, and statesthat "...the survey did not focus upon those individuals whoreside along Fields Brook and thus does not accurately representthe population whose exposure to the brook is most of concern."This is not the case. The survey area is bounded by portions ofEast 14th Street, Columbus, East 15th Street, Route 11, East 23rdStreet, and East 21st Street. Of the 100 households that weresurveyed within this area, 40 of them are on property directly

75

adjoining Fields Brook. The other 60 households, while notadjoining Fields Brook itself, include those across the streetfrom the brook, and within this small defined area. U.S. EPA'sassertion, that the survey did not focus on households likely tobe exposed to the brook, is false.

Response: U.S. EPA does not believe it was overly critical ofthe PRPs survey; the several significant concerns regarding thesurvey are summarized in the FWA Human Health Risk Assessment.In addition to concerns noted in the Risk Assessment, U.S. EPA isconcerned that the PRPfs survey inappropriately disregardedhunting and fishing as a frequent activity along Fields Brook.During 1993 and 1994 discussions with the PRPs, U.S. EPAexpressed concern that this conclusion did not consider thatthese other streams are not in close proximity to their residence(i.e., in their»backyards), and disregarded the circumstantialevidence of frequent use discussed above (e.g., hiking,campfires, play). Further, the survey did not address the issueof children's exposure.

Comment: Page 6-3: The text incorrectly states that "The [PRPs]proposed that the size of the FWA exposure units be larger thanthose used in this risk assessment; that is, they proposed that asmaller number of exposure units be demarcated within the FWA forevaluation." This statement is false. The PRPs initiallyproposed that the FWA exposure units correspond to the SOUexposure units, and U.S. EPA accepted this proposal.

Response: The PRPs raised concerns regarding the length andtotal area of the FWA exposure units being considered by U.S. EPAin its 9/19/94 comments to U.S. EPA, including whether separateFWA exposure units existed on both sides of Fields Brook. U.S.EPA's 10/20/94 letter to the PRPs noted that it was appropriateto divide the FWA into the same ten exposure units that werepreviously used for Fields Brook sediment. U.S. EPA also notedthat because separate populations exist on each side of FieldsBrook, separate exposure units must be considered on each side ofthe ten exposure units. The PRPs continued to disagree with U.S.EPA's designation of separate FWA exposure units on each side ofFields Brook into early 1995.

fi

Comment: Page 4-5: Section 4.3.8 concerning arsenic toxicitycites a cancer slope factor of 1.75. This value is out-of-date.The correct value of 1.5 is given in Table 5. It is unclear whichvalue was used in the risk calculations.

Response: As shown in Appendix D, the calculation spreadsheets,the updated value of 1.5 was used in the risk calculations. Thevalue of 1.75 given in section 4.3.8 was inadvertently in error.

76

Comment: : Table 3: This table contains typographical errors; itis not clear to what extent, if any, these errors affect the riskcalculations. The errors include:

Comment : FEU2 . maximum concentration of PCE should be 2500jig/kg

Response; Acknowledged. As the exposure point concentration isthe lower of the maximum and the 95% UCL the risk calculationsare not affected.

Comment : FEU2 . maximum concentration of 1,1,2,2-Tetrachloroethane should be 580

Response : Acknowledged. As the exposure point concentration isthe lower of thtf maximum and the 95% UCL the risk calculationsare not affected.

Comment : FEU2 . basis for exposure point concentration forP.CBs should be listed as 95% UCL

Response: Acknowledged. The 95% UCL value was used in the riskcalculation.

Comment : FEUS . maximum concentration of hexachlorobenzeneshould be 480,000 /ig/kg

Response : Acknowledged. As the exposure point concentration isthe lower of the maximum and the 95% UCL the risk calculationsare not affected.

Comment : FEUS . 95% UCL on mean and exposure pointconcentration for hexachlorobutadiene should be 1900 /xg/kg.

Response : Acknowledged . This revision lowers the calculatedhexachlorobutadiene carcinogenic risk of 3.6 E-08 to 8.66 E-09,and the hazard index from 0.0046 to 0.001. The revision does notchange the overall FEU8 carcinogenic risk of 1. IE-04, and hazardindex of 1.4.

IV* CfrBHllditB to the "Development of the Clftflnuy Qoa.1 (CTTGa) *Section of the EP.JV' s FWA

Comment : Page 3 bottom through page 4 top: This text statesthat the CUGs were developed for the FWA by considering only thesoil ingestion exposure route; that dermal exposure was notconsidered in developing CUGs. This statement is false. Boththe PRPs and the U.S. EPA risk assessments considered both soilingestion and dermal exposure, and both were used in U.S. EPA'sdevelopment of the CUGs.

77

Response: Comment accepted. The CUG and risk calculations wereproperly conducted and considered both soil ingestion and dermalexposure, and thus no change to the risk assessment text isrequired.

Comment: page 5 top: This section appears to state that CUGswere developed for the FWA in 1993. However, the risk assessmentwas not done until 1995 (PRPs risk assessment) and 1996 (U.S. EPArisk assessment), and this 1996 U.S. EPA risk assessment is thefirst document that contains CUGs.

ReRponae: U.S. EPA submitted a list of FWA CUGs to the PRPs on10/20/94, and this list is provided as an attachment to the 1996EPA Human Health Risk Assessment. These 10/94 CUGs are thecurrent CUGS for* the FWA.

Comment: The Remedial Investigation Report for the FWA providesa general overview of the site chronology, activities completedand analytical data collected. There are some minorinconsistencies that should be noted regarding the following:use of the term operable unit for the FWA, description of FEUs(Floodplain Exposure Units) vs. EUs (Sediment Exposure Units),and analytical parameters obtained during FWA studies. Overall,the report references and summaries information provided indeliverables prepared by Gradient, EA Engineering and Woodward-Clyde .

Response: U.S. EPA considers the FWA a separate operable unit ofthe Fields Brook site. Regarding use of the terms FEU's vs. EU'swithin this report, unless otherwise noted within the report,both of these terms refer to the floodplain area exposure unitsunder discussion.

Comment; Page 1-1: The text notes that U.S. EPA has divided thesite into four areas of concern, three of which are considered"operable units" associated with the Fields Brook Superfund Site.The text incorrectly describes the operable units. The 1986 SOWoriginally described two operable units, the Sediment OperableUnit (SOU) and the Source Control Operable Unit (SCOU). TheFloodplain and Wetland Area (FWA) has never been officiallydesignated or referred to as an operable unit by the PRPs. ThePRPs voluntarily proceeded with FWA sampling, risk assessmentsand feasibility study alternatives beginning in 1994.

Response: U.S. EPA considers the FWA a separate operable unit ofthe Fields Brook site, and no separate formal designation isrequired by U.S. EPA in order to refer to the FWA as such.

78

Comment: Figure 1 does not accurately depict the SOU and FWAinvestigation areas. The Source Control Operable Unit is notshown.

Response: The figure provides the reader with the general areasinvolved in the SOU, FWA and Source Control investigations.However, due in part to photocopying losses in clarity, thereader may have difficulty in deciphering and segregating thesedifferent areas.

Comment: Page 2-3: Section 2.1.2 discusses SCOU activities andindicates that all field work was completed in the Fall of 1995.The text does not reference the completion of a Feasibility Study(FS) that identified remedial alternatives that were developedfor the remaining source control areas that represented potentialrecontamination sources to Fields Brook.

Response: Comment accepted; since this paragraph is intended toprovide the reader with an overview of progress at anotheroperable unit, the text does not require change.

Comment: Page 2-4: Section 2.1.4 refers to theFloodplain/Wetlands Area Operable Unit. This reference isincorrect.

Response: U.S. EPA considers'the FWA a separate operable unit ofthe Fields Brook site.

Comment: Page 3-2: The text describes groupings of FEUs forresidential and industrial land use areas. There appears to besome confusion regarding actual designation of FEUs (floodplainexposure units) and Bus (sediment exposure units). The listingprovided describes exposure units (Eus) for the sediment operableunit and incorrectly describes the residential and industrialEus. The designation break for residential and industrial FEUsin the FWA was Route 11 and in the SOU was State Road. In theSOU, residential Eus included: Reach 1, 2-1, 2-2, 3, 4, 11-1,11-2, 5-1, and 5-2. and in industrial Eus included 11-3, 1-4, 6,7-1, 8-1, 8-3, 8A, 13-1, 13-2, and 13A. ,

Response: The above statement is correct regarding designationsof reaches of Fields Brook into FWA vs. brook sediment exposureunits. However, regarding use of the terms FEU's vs. EU's inthis report, unless otherwise noted within the report, both ofthese terms refer to the floodplain area exposure units underdiscussion, and the reaches identified on pages 3-2 and 3-3 ofthe FWA RI report correctly designate which reaches of the FWAare considered residential vs. industrial use.

79

Comment: Page 3-2: It should be noted that the FWA project onlyconsidered response areas in residential areas (FEU 2 and 3) andindustrial areas (FEU4, 6, and 8).

Response: This .report is an RI report which discusses the natureand extent of contamination and history of the site; responsearea discussions are provided within the FWA FS report.

Comment: Page 3, section 3.3, Figures: The figures provided inthe RI (Figure 3 through 7) that identify Phase I, II, and IIIFloodplain Sample Locations depict the proposed locations asshown in the Work Plan. They do not show actual surveyedlocations and minor sample numbering modifications that occurredduring field sampling. Figures showing final sampling locationsthat were surveyed to exact locations were provided in theOctober 1996 Feasibility Study.

Response: Comment accepted; since these figures are intended toprovide the reader with a general overview of sampling locations,the report does not require change.

Comment: Page 3-4: In the second full paragraph, the textindicates that all samples were analyze for the 130 chemicals.This is not "correct. The 137 samples collected during Phase IIIwere only analyzed for the 11 COCs identified for the FWA(1,1,2,2 tetrachloroethanej etrachloroethene, trichloroethene,vinyl chloride, benzo(a)pyrene, hexachloroethane,hexachlorobenzene, hexachlorobutadiene, arsenic, beryllium, andPCBs).

ResporiRe: Comment accepted; sinceTthe results and summary of thedata__ summary writeups do not substantially change as a result ofthis comment, the report tioes not require change.

Comment: Table 2: The source of the summary analytical-datatables included in this appendix was not referenced. The PRPsprovided U.S. EPA with electronic files. It is assumed that dataprovided in these summary tables is consistent with the PRPsdatabase. '/Response: This comment makes a correct assumption; the reportdoes not require change.

Approximate Currentatershed Boundary

ApproximateScale in Feet

Legend

Sediment Operable Unit andFloodplain/Wetlands AreaOperable Unit

Source Control Operable Unit

"IH-•H«a

n8arco

Ashtabula River InvestigationFigure 1

Location Map

Legend

1

i

Exposure Unit Number

Reach Number

Comi

Woodward-Clyde ConsultantsFeet

2000 4000Figure 2

Exposure UnitsProperty Ownership Along Fields Brook

Sediment Operable Unit/Floodplain-Wetlands Area Proposed Remedial Response Area

I

H•ftj

Otr

ft•o

oo

24A50CQ

0!

ce

B*

ALTERNATIVE VII

MATCH LINE - SEE FEU2B FIGURES

Figure 3Eipos«raUnHI2A

Rtmfdlil Rtsponst Areas Alttrnalrw VIIFloodplaln-Wetlands Area Proposed Remedial Response Area

s

CQi

1MATCH LINE - SEE FEU2A FIGURES•-err"—

Figure 4EipowflUnltlZB

RBmedlal Rasptmsa Anas Alttrnatto VIIFloodplain-Wetland Area Proposed Remedial Response Area

in•li

FiguresExpowreUnltia

Rtnwdlal Rtsaonsa Art at Altarnattvt VIRoodplain-Wettand Area Proposed Remedial Response Area

C 246VOOO

gb•*

vo

M

FEU4ALTERNATIVE VII

Figure 6Floodplaln Ex^onra Unit f 4

Rtmtdlil Rnpons* Artat Altarnattvt VIIFloodplaln-Wetland Area Proposed Remedial Response Area

•4

doPi

g

Figure 7FlfXMlpliln Eiposvn Unit 16

Rtmfdlil Response Artas Alttmallv* VtlFloodplain-Wettand Area Proposed Remedial Response Area

d&•*

g00

ALTERNATIVE VII

Figure 8Flootf plain Eipoture Unit 18

Ramtdlal Reiponsa Art is Mtornatlva VIIFloodplaln-Wetlaix) Area Proposed Remedial Response Area

FIELDS BROOKPROPOSED ON-SITE CONSOLIDATION AREA

CROSS-SECTIONAL VIEW

ao

6-inch Top Soil Layer24-inch Soil Layer

On-site Consolidation Area

12-inch Sand/Gravel Layer

Soil/Scdimcnt/Dcbris

6-inch Sand/Gravel Layer with"^ Leachate Detection System

60-mil Liner

In-situ Soils with Rccompactcd 6-inch Top Layer

Tablo 1-1:Summary of Soils Data for FKU 2Summary of Phase I, n, and m Dau For

Fields Brook FWA Surface SousFlood Plain Exposure Uait 2

Parameter1, 1,2,2 -Tetrachloroethane1, 1,2-Tnchloroethaae1,2,4-TricalorobeazeaeI 7 -Rich lorofr**1**"*1,2-Dichlorottheae (tool)I 3 -THrhiorflfrf nMty1 . 4-Dichlonbeazcae2-Buanone2-Hexaaoae •? -ILhtfhyliuphf h*Urw»

2-Methyipheaol4,4'-DDTArmjnhfhfTVfA f*M«nhthvlM*

AcetoaeAataraceaeAjodor-1248Aroclor-1254Aiodor-1260Beazo(a)aBthnceaeBeazot a jpyicaeBeazo(b)fluoraBiheaeBenzod,h4)peryleneBeazoOOfluoraatheaeBurylbe&zylphthalateCarbaxoteCaiboa Bisulfide_.. ^nh^ColofoiDnBCaiywePi'B-butytphrtMlitcDi'Q^OCtYlpQttttUttDibeaz^a,h)aatlmceacvi&eazOuffaaDieldnaDiethytphihalateninwitlvyinl^ h * 1 •?»

FitrtrrPilfan TPnrtftf^itfm nFlMt'fnlftn flj 'ft**

EadhaEadriaketane

rtamocrDetecu

1321459129

21I

2917613232136

•sJ1

3133381721371523714I213865101546

NumberSamples

393939393939393939393939393939393939393939393939393739393939393939393839393939393939

rerceat nDetected

f%fci\v*t33.335.1335.9012.8223.0130.7723.0853.852.56- -74.362.5617.9515 JS33.3358.9753.8592.317.692J679.4984.6297.4443.595.1333.3318.922.5612.825.1394.8735.902.565.1333.3321.0515.3812.8225.642.5612.8210.2615.38

tattBBB^Detect

(M t»*\•fnci)OJS

0.00601.1

0.380.213.20.360.0540.0020

1.20.0260.120.0700.138.1

0.153600.220.210.820.601.7

0.640.670.140.120.0100.023

1.70.610.19

0.00600.180.460.0670.0240.0900.0380.100.0430.0650.027

kntbBeocMeaa/_ , (i, u\(•fAtf)0.0250.031OJ10.240.0140.320.250.0340.0320.160.270.110.250.210.240.1724

2.032.030.220.210.47OJZO0.290.210.240.0320.0320.0510.210-210.270.230.200.120.240.250.060.110.110.110.11

SuadardDeviatioa

0.0920.150.260.0750.0340.500.160.150.150.210.150.370.170.191.3

0.20603.83.80.160.130.360.110.160.190.170.150.150.270.150.190.15

' 0.0550.120.380.170.160.190.37OJ7OJ70.37

95% -UCLMfM«Af«\\vyKKy

0.0190.0150.420.280.0140.4S0.340.0200.0150.290420.250.460.590.0970.355651215

0.300.330.880.280.310.470,420.0150.0190.018OJ30.370.380.280.490.280.630.360.15OJ20.210.250.20

9501900

Table) 1-1: Summary of Soils Data for FEU 2 (continued)

Flood Plain, Exposure Uoit 2

Parameter••••l H^MH i MH

Ethyl BenzeneFluoraatheneFluorene•flf-fftfMt*

HeptyhiAr eporidejic3cacnj*j> tm» • M<fc»FrHexachlorobutadieneHexachloroethaneIndeno(lvX3<.d)pyitneMethoxychlorMethylene ChlorideHtnhthi**"*PhenanthrenePhenolPyreneStyreneTetrachloroetheneTolueneTotal PCBsTrichloroetheneVinyl ChlorideXylenes (total)alpha-BHCalpha-Chlordanebea-BHCbis(2-Ethylhcxyl)phthalatedelta-BHCpmma-BHC (Lindane)cunma-Chlordane^^HBBBB^AluminumAntimonyArsenicBariumBerylliumCyJT"""*

CakramChromiumCobaltCopperCyanideIronLead __________ __

950S900SURfSOtLJCLS

TTesioerDetects

53873733268

2432127371

381124 .3238181

22331937131412391

2539262839393939133939

Number PerceetSamples Detected

393939393939393939393839393939393939393939393939393939393939393939393939393939173939

<*)12.8297.4417.937.6917.9584.6266.6720.5161.547.695576697394.872.56

" -97.44287161.5482.0597.4446.152.5656.417.697.6948.7294.8733.3335.9030.771002.56

64.10100

66.6771.79100100100100

76.47100100

fe»2oO

Detect Meaa(eiffAD0.0030

170.076

1.50.015

976.30OJO0.760.0797.1

0.741.1

0.0511.1

0.0622.5

0.283606.8

0.00500.62

0.0610.0059

4.4162.8

0.470.15

238001.240

165001.811

59300517361030.58

65600147

(anflu)0.031OJ20740.160.14

140.810750.200.570700.140750.280.30

0.00700.0773.027

240.190.0320.0210.0600.0570.271.5

0.130.0900.1314562

5.413

38770.673.8

163681041750

0.2337608

66

Deviation•MM^Mi

0.150730.17OJ30.652217

0.160.141.91.1

0.150740.150760.0100.40

0.051601.1

0.150.100.190.190.952.7

0.450700.3539651.610

51790.473.3

147641116.620

0.148198

26

TJCLM(•«*i)

0.0170.500.431.70.193031.4

0.290.300.980.0440.280.420.310.48

0.0120.0530.088284

0.0680.0150.0150.140.0970.534.0

0.530.560.4215928

6.719

192151.484

243571501957

0.4039695

75

Table 1-1: Summary of Soils Data for PBTJ 2 (continued)

Flood Plain Exposure Unit 2

ParameterMagnesiumManganeseMercuryNickelPotassiumSeleniumSilverSodiumThallium

VanadiumZinc

———— NymEeFDetects

39393939398

222463939

NumberSamples

3939393939393939393939

Percent"Detected

(%)100100100100100

20.3156.4161.5415.31100100

Manmum ArithmeticDetect Meaa

(Bf/kf) (mf/kf)162002630

11157

31709.613

13501.3902297

510686*3.267

18464.33J3203.5149182

StandardDeviation

23375303.3365503.33.42542.718966

35%UCLM(mf/kij

56101004

1782

2029125.53988.5226206

950*900SURFSOIL-XL3

Tabl* 1-2: S ry of Soils Data for FEU 3

Summary of Phase I, n and m Data ForFields Brook FWA Surface Soils

Floodpiain Exposure Unit 3

Parameter1,1,1 -Tnchioroethanei, 1,24-Tetrachloroethane *1, l,2*Tnchloroethane1,2,4-Trichlorobenzene1,2-DichlorobenzeneIt2-Dichloroethene (total)1,3-Dichlorobenzene1 4-Pirh lor "***"?»•**2-Butanone2-MethylnaphThaime4.4'-DDT4-Methyi-2-pentanoneAcenaphthyleneAcetoneA tttkwwm*

Aroclor-1248Aroclor-i254BenzeneBenzofatanthraceneBenzo(a)pyTeneBenzo(b)fluoraniheneBenzo(frh,i)peryleneBucylbenzylphthalateCarbon DisulfidcCartxm TetnchlorideChlorobenzeneChloroformChryxneDi-n-bwtylphthalateDibenzofuxanEthyl BenzeneFluonntbeneFluorene

HexachlorabutadieneHoachloroethaneIndeno(l,2.3<,d)pyrcncMethylene ChlorideNinhfhaiftPhenanthrenePyreneStyrene

930S900SURFSOOJOS

NumberDetects

210291

1132234121

281

31125

22279631415131817

321

2414411353

233010

NumberSamples

41414141414141414141641414141414141414141414141414141414141414141414141414141414141

*•

Percent Maximum Arithmetic StandardDetected

(%)4.8824.394.88

21.952.4426.837.324.88

56,109.7616.674.882.4468.292.44

75.612.4448812JO53.6665.8521.9514.637.322.449.7636.5931.7143.902.4417.0778.052.4458.5434.159.7626.8385.377.32

56.1073.1724.39

• I r f2

Detect(mt/kf)0.0030

0.220.0060

0.980.19

0.0414.2

0.870.0660.080O.OSO0.00200.0050

2.50.0060

5300.0480.0020

0.17OJ30.670.14

0.0410.0370.0030

0.100.0230.24

0.0710.00400.011OJO

0.003099472.0

0.16OJ70.0550.240.25

0.0030

Mean(mf/kf)0.00760.0130.0069

0.410.40

0.00940.490.41

0.00800.380.0250.0075

0.400.120.40292.2

0.00680.390.320.370.360.37

0.00820.00770.00920.0072

0.360.320.40

0.00700.300.406.42.8

0.430.350.060.390.310.29

0.0055

Deviation

0.00470.034

0.00141.11.1

0.00791.21.1

0.0101.1

0.0340.0047

1.10.401.1926.5

0.00161.1l.l1.11.11.1

0.00660.00460.0140.0056

1.11.11.1

0.00511.11.1189.5LI1.1

0.0791.11.11.1

0.0026

95%UCLM(mf/kc)0.00820.013

0.00770.430.35

0.0110.450.37

0.00870.404.1

0.00880.430.110.425396.2

0.00840.360.320.380.340.43

0.00900.00820.00930.0085

0.43OJ40.44

0.0110.360.46

141.9

0.400.340.0940.430.340.29

0.0088

Table 1-2: Summary of Soili Data for FEU 3 (continued)FioodpUin Eipomre Uah 3

ParaateterTetiachJofoctDciicTolueneTotal PCBiTrichiocoethcneXytene* (total)bett-BHCbis(2-Etbyihexyl)phthalateAlumilHIffl.ArsenicBariumBerylliumCadmiumCalcinifChfonuoni ,CobaltCopperCyanideIronLadMafnrtnrnManganeseMercuryNickelPotassomSilverSodiumThallium

VanadiumZinc

Defects

28333120323

314123413211414141415

4141414140414111351

4139

NamaerSample*

41404141416414141414141414141416414141414141414141414141

Perceat 1Detected

<%)6L2917 JO75.614S.787S.0550.0075.61100.0060.91100.0071.0526.83100.00100.00100.00100.0083.33100.00100.00100.00100.0097.56100.00100.0026.8385.372.44

100.0095.12

^•liBMBI

Detect(»*kf>

0.640.0475300.190.0500.249.6*

2420024

215001.79.7

233004704079

0.3250400

9786209519.2147

304012

4840.62842621

lAritaaMtkMet*

(-•*•>0.0320.0047

290.0280.0060.0450.6013231

1312340.641.7

49S3611427

0.1831098

4439775461.142

17972.22004.792135

StaadardDcviatMM

0.120.0079

920.047

0.008390.101.6

37587.1

3433OJ32.4

5311904.614

0.0855439

1910801951.831

5272.7811.9134105

93%UCLM(•tfAf)0.0920.0060

4730.0430.0080

9.31.2

1639216

18550.952.3

7677711431

0.3332450

4942396302.148

19762.82228.7106152

930tMOSURFSOILXLS

Table 1-3: Summary of Soil* Data for FEU 4

Summary of Phase I, n, and m Dau ForFields Brook FWA Surface Sous

Flood Plain Exposure Unit 4

Parameter1, 1,2,2-Tetnchloroethane1 1 2 -Trichf ony* ******1,1-DtdUoroetheneU2,4-Trichiorobenzenc1,2-Dtchlofobenzene1,2-Dichloroethene (total)1,3-Dichlorobenzene1 , 4-Dichlorobenzene2-Butanone .2-Hexanone2-Methyinaphthalcne2-Methylphenol4,4'-DDT4-MetliylphenolAcenaphtbyleneAcetoneAnrhrarrnfArodor-1248Arodor-1254Ajockw-1260BenzeneR^Ti/ofi )a nt hnmvfBenzo(a)pyreneBen2o(b)fluoraitthencBenzo(f.h,i)peryteneBen2oOc)fluoranibeDeButylbenzylphthalateCarbazoleCarbon DisulfideCaiboa TeuacnlondeChlorobenaeaeQxtoratfbnaOuysenent.n_>«ifyl|th*h* l*ff»

Dibenz(a,A)anthnceneDibenzoAiranDiethylphthalateDimethylphthalatcEthyl BenzeneFluonmheneFluoreae

NumberDetects

1962171

22136231

17 •11310201734311

262431179655171028171565I

337

29

NumberSamples

36363636363636363636363673636363636363636363636363636353536363636363636363636363636

PercentDetected

53176

473

613617643

473148

28564794833

726786472517141431928784731417143

921981

Maw^BM^a TUBVOi

Detect(mf/Vf)

150.00400.113.5

0.049.13.0

0.362.4

0.00200.0450.0310.0110.210.0332.70.115600.270.530.0410.310.371.6

0.220.380.0940.0840.01

0.00100.0322.1

0.33l.l

0.0380.0130.0900.23

0.00101.1

0.061230

ArithmeticMeaa

(mf/kf)0.670.180.160.961.0

0.400.880.990.240.180.891.0

0.0481.0

0.950.300.90634.54.50.160.900.930.630.940.980.981.0

0.190.180.180.23 ,0.901.01.0

0.980.980.990.180.690.9629

StandardDeviation

2.50.360.342.02.31.51.92.3

0.530.362.32.3

0.0942.32J

0.612J1339.29.2

0.34222.31.42.32J2J2J0.360.360.360.542J2.32.32.32.32.3

0.361.92.346

95%UCLM(mf/kf)

1.50.520.321.71.1

0.721.01.2

0.540.412.41.11.01.14.8

0.742.8

31683545

0261.21.1

0.9112121.82.0

0.580.440.510.551.12.01.12.42212

0.440.7522565

950S900

Table 1-3: Summary of Soil* Data for FEXJ 4 (continued)Flood Plato Exposure Unit 4

ParameterHfTtlf hi' H ff*******"rwWTf^h"**Iadeoo(U>c,d)ayMKMethykne ChlorideNaphthalenePhenanthrenePyreneStyreneTetrachloroetheneTolueneTotal PCBsTrichloroetheneXyknes (total)kj W-J .CfliylW^vynntlil^lpt*

AluminumArsenicBariumBerylliumCadmiumCalciumChromiumCobaltCopperCyanideIronLeadMagnesiumManganeseMercuryNickelPotasnuDSeleniumSilverSodiumThalliumVanadiumZinc

9501900smtnou-XLS

NumberDetects

27717271432308

262334262236361636202433363636333363336323632216272

3631

MemberSamples

3636363636363636363636363636363636363633363636733363336333633363633363636

P*

Percent Maximmm Arithmetic StandardDetected

/(k£\\rwf

75194775398983227264947261100100441005667100100100100431001001001009710097644826

10086

• 2ott

Detect(mg/kt)

1905.9

OO62.2

0.0310.721.1

0.1038

0.225608.63.915

4340038

110006.4

20.6040600620692901.5

62300161

74202720

19199

32202.79.48950.98949621

Mean(mfflci)

9.20.950.940.230.920.600.670.131.5

0.07263

0.460.181.6

1856513

24520.9$3.8

135541231851

0.29388S2

6040708253.965

18646.32.63766.3192158

Deviation

322.12.3

OJ32J1.81.9

0.306.30,201331.5

0.683.0

68799.1

26661.04.3

116681441047

0.548859279494934,3485953.22.41754.9

f 23197

95%UCLM(mg/Vfj

251.0l.l

0.453.8

0.650.720.317.9o.u21881.6

0.215.0

2036816

69831.18.0

2333018620603.3

4168569

436010011582

2103153.944214

306191

Table 1-4: Summary of Soils Data for PKU 6

Fields Brook FWA Surface SoilsFlood Plain Exposure Unit 6

Parameter1,1,24-Tetnchloroethane1 lJ?-Trifhk)iTf?*thf*M|

1,1-Dichloroethene1.2.4-Thchlocobenzene1 (2-Dichlofobenzene1,2-Dichloroethene (tool)1 ,3 -Dichlorobenzenel,4-DichlofOben2e&e2-Butanone7 -Met hrlittp nt h^frtif2-McthyiphenoJ4,4'-DDE4,4'-DDTA r*fim|if )}f«e

Acffnjphthyl****AcetoneAnthrjfffl*

Aroclor-1242Aroclor-1248Arodor-1254Benzo(a)amhnceneBenao(a)pyteneBcnzo(b)fluoTajttheneBenzo(frh.i)peryleneP^fl7^/)f}f|tt«mntpu»fM»

ButyfeenzyiphfhalafrCariMzoteCarbon DisulfideCaiboa TeuadikMridef**_ « ^ » _ . _ _ _ _ _uuoroocBicncChlorafocmChiTKneDiHi^NiiyipothalateDibenzdJOanthxmceneDtbenzoflinnDicthytphthalatenifiMWbvlnkth* 1 *t»WIIIMIIMJ||»||IIMIB1«

Fwtftiulfsn TTFndoif11"5^* fif'^frEndhnketoaeEthyl BenzeneFluonmhene

NumberDetects

23129

2415271615122212128

30131

331

1729361817331662713671414211734

NumberSamples

404040404040404040404014144040404040404040404040404036404040404040404040401414144040

PercentDetected

(%)5830236038684038305531475

2075333

833

43739045318883151568331518353514771885

™fl S^IIBTIIHDetect

(mt/kf)12

0.130.844.3

0.521100.730.528.7

0.610.0150.47

0.00500.130.037

1.90.3422

6100.271.81.4U1.1

0.0320.62

0.0510.0450.19

110.553.2

0.230.390.100.671.7

0.430.190.0340.015

1.8

ArithmeticMean

(«***)0.480.130.131.31.14.1

0.941.0

0.401.01.1

0.860.681.11.1

0.261.16.7746.61.2

0.941.11.11.11.1

0.760.140.130.510.141.11.1M1.11.01.0

0.600.580.570.140.95

StandardDeviation

1.30.300.272.92.9182.82.91.42.92.81.4U

2.852.860.502.911131112.92.8182.92.82.91.4

OJ3OJ21.9

0.332.92.92.92.92.82.81.31J1.3

OJ32.8

95%UCLM(nif/kc)

2.10.230.251.81.463

0.911.1

0.592.31.33341101.22.6

0.601.861

1940531.71.21.91.21.22.01.3

0.220.180.530.211.41.61J2.11.92.7897558

0.241.2

930000

Table 1-4: Summary of Soil* Data for PBTJ 6 (continued)

Flood Plain Exposure Unit 6

ParameterFluoreneTT-L Lli-ill.^

HeachkmbeozeoeTTr ujjK 1 ___i_nlu. it -«-rli mnm

HexachloroethaneIndeno(l,2,3<,d)pyreneMetfaytene ChlorideMairh^haliT*PhenanthxenePyreneStyreneTenchloroetheneTolueneTocalPCBsTrichloroetheneVinyl ChlorideXylenes (total)aipha-BHCalpha-Chlordanebeta-HRCbwO-PtlrvlhrT1)!1******1***delia-BHCgamma-BHC (Lindane)gamma-QUordaneAluminumArsenicBariumBerylliumCadmiumCalciumChromiumCobaltCopperCyanideIronLeadV4iF**fiiifnManpneaeMercuryNfckdPotassiumSelenium

95Qf*»SUKFSOILXLS

NvmberDetect!

61

393215182915322712342534312

23115

30111

40234033314040384010404040403940365

Samples

401440404040404040404040404040404014141440141414404040404040404040144040404040404040

I

*epceatDetected<%)

15798803845733880683085638578558773675777

100581008378100100951007110010010010098100

13

**2of3

Detect(attAf)

0.421.03201704.3

0.470.450033J4.3

0.1589

0.10610568.5

0.440.19

0.0184.511

0.0720.250.02726300

3396206.0

12.10128000

108029116

0.77130000

23185503070224*4

31003.4

Aritametie St*ad*rd wv.Mean

(Bff/kt)

1.1

0.4133111.21.1

0.121.01.01.0

0.127.0

0.11764.4

0.350.090.300.290.652.3

0.300.300.3814465

1320531.14.0

261931471448

0.2236593

5635569474.274

13854.8

Deviation

2.90.7472312.92.9

0.262.92.82.9

0.3118

0.30131111.4

0.260.690.691.33.6

0.690.690.7651058.0

24221.33.4

3062S2135.625

0.2319619

39)1636684.584meIJQ

3.1

UCLM(mf/ki)

1.3250220461.81.3

0.222.31.41.4

0.346480,231633172

0.450.164831

2047.13648101

1645215

44162.17.8

593312211657

0.3840425

67394312241690

177313

Table 1-4: Summary of Soil* Data for FBTJ 6 (continued)

Flood Plaia Exposure Unit 6NoBber ttmmbtr Percent MiTJnrna Arithmetic Standard 95%Detectt Saanks Detected Detect Mean Deviation UCLMParuDeter

SodiumThallium

VanadiumZinc

2ft5

4040

40404040

<*>

7013

100100

(•fftf)

14105.6

1710339

2.33424.1237146

2.82442.635465

3.14238.7390168

950000SUIFSOILJCLS

Tablo 1-5: Suanary of Soil* Data for FSU 8Summary of Phase I, U, and HI Data For

Fields Brook FWA Surface SoflsFlood Plaia Exposure TJnh S

M.__U«^ MiMh»r P^ITfBt

ParaaMteri t i, i • i ncBiofOdMiici 1 1 i.TtfracbloToethaiicI, I,***"!****"1"" •**••"•l,U-TricfakxoethaaeU-DicfalaroethaneU-Dicbioroetnene1^4-Trich)orabe&zene1,2-Dicalonbeazeae1.2-Dicaloroetbeae (total)1,3-Dtchlorobantne1,4-Dichlorobenzen*2-Butanone2 Mrtlr/lnap11*11*1*11*4,4'-DDE4,4'-DDTi-Chloro-3-methylphenoi4-NitnjphenolA/vnftphtbeneAcenaDh^hvlen£r

AcetoneAnthraceneAiodor-1242An>dor-124SAiodor-1234Aredor-1260BenzoU^nthn**"*Beaza(a)pyreneBeazo(b)fluoKaatheneBcnzo(j.b,i)peryleneBenzo(k)fluocamheneBromofbnnButylbeniylphthalJteCaiteoleCaiboaDisuifideCaiboaTetncfalorideCUofobc&xsaaChlofotenOtfyseaBD « L. —— • __ • ifc !>•••i-a-botytpbt&alateDJbcnz(aJt)titfiirarrnrpibenzofltfanOibromochlonxnethaDeDietbytptutulateDimetbytphthalaieEthyl BenzeneFlttorantheneFluoreneHexachlorobenzeneHexacbtofobaadieaeHpiacnioroethane _____

Detects Staipka Detected(*)— r —

17231IS12188171531111i172020221

3145

28323815111

211773743115320I

262993720352213

-TT— '424242424242424242424224244242424242424242424242424242424242394242424242424242424242424242424242

4057243294319403674442240a48522741012677690362625044177171074367a2

626921U48S35231

MAZIBMIBI ADetect

(mf/kf)u.uuu^u

120.0340.00300.0020

1.30.1947

0.320.339.0

0.760.34

0.00470.0070.0220.0920.061120.210.462703.69.4

0.850.791.4

0.280.56

0.000300.0360.17OJ20.010.98121.0

OJ10.0370.10

0.000300.661.9

0.122.1

0.17480172.4

kritaawtic !SuadsrdMesa Deviation

(Bffef)U.UV40.660.0950.0940.0940.300.46U

0.480.430.380.370.710.670.31U

0.410.380.320.405.7305.86.00.470.440.380.450.480.0940.380.440.0830.0940.100.110.470.46OJO0.400.0940.430.340.0320.490.41301.2

0.48

U.^B12

0.280080.2S1.0

0.997.2

0.991.01.61.02.12.1

0.982.41.01.0121.0163316161.01.0

0.320.990.990.281.01.0

0.260.28OJ9OJ21.0

' 0.990.981.0

0.281.01.0

0.190.331.0952.8

0.99

95%UCLM(a|/kf)

UJJ/J0.670.0680.0760.0660.720.350.801.1

0.630.160.414.23.6

0.621.6

0.750.680.230.48203991723

0.330.360.520.480.360.0770.390.360.0620.0710.0780.0890.360.450.380.640.0770.630.900.0490.660.491321.9

0.69

Table 1-5: Summary of Soils Data for FEU 8 (continued)

Flood Plain Ezposare Uoit 8

Parameterindeno(i^J<.d)pyRneMethykM ChlorideNHutraeodiphenyiamineNaphthalenePhenanthfenePyreneTetnchJonetheneTomeneTotal PCBsTrichloroetheneXyknes (total)beta-BHCbisa-EthyU>exyI)phthalatetrani- 1,3-DichloropropeneAliimimim

AntimonyArsenicBariumBerylliumCadmiumCalciumChromiumCobaltCopperCyanideIronLeadMagnesiumManganeseMercuryNickelPotassiumSeleniumSilverSodiumThalliumVanadiumZinc

NumberDetect!

20186

29363823253326187

311

411

28423225424242422142424242414240162719124239

NumberSample*

4242424242424242424242244242414242424242424242422442424242424242424242424242

Fereest .Detected

<*)4V4314698690556079624329742

1002

6710076601001001001008810010010010098100953864452910093

M«V«MM

Detect(-8*0

0.420.740.120.0564.61.98.2

0.1727011

OJO2.467

0.0004031500

2143

1370199.7

741001580291470.66

58400263547012900

5890

39301.817

79816

2280420

ArithmeticMeaa(•g*t)

0.450.0570.480.340.630.470.490.033

340.780.0360.315.7

0.094170535.815

2971.3V

152252661449

0.2336702

62351314181344

17963.83.82743.5430194

StandardDeviation

u.yy0.15O oo.yv1.0

0.870.521.8

0.09582.4

0.10l.i11

0.2849333.211

2793.02.0

152613454.930

0.1310364

39947

20001517

7423.94.31673.858495

95%UCLM(mg/kg)

0.500.0600.610.440.920.640.460.0562381.6

0.0441414

0.074186867.819

3752.22.5

22286 '4661659

0.2940274

713839179712851

21278.47.13427.8764235

9501900SURFSOILXLS

Fid* Brook FloodpUln* »»d WctUadi

Ckeawp Goei CamcealfmOoa* Fee Carctacfeaa \m PUodpftaaval O« lagietlin And Dervuri Abwrpiioe, By A *

I—1— __.

(latefratod Expewm DuraAioa Of 3* Yem)

Chemical

Arsenic (i)BerylliumbeiaBHCgamma BHC (Lindaae)bis(2-Ewylhcxyl)priihalateCarbazokChloroform4.4' DDE4.4'-DDT1 ,4 DichlorobenzeneI.l-DichloroetheneHexachlorobenzeneHcxachlorobutftdieneHexachloroethaaeMcthylene chloridePCBsPAH - Benio(a)anihracfnePAH - Benzo^)flotirMilhenePAH - Benio(a)pyrenePAH - ChryaeaePAH - Dibenz(ath)anthracenePAH - lndeno(1.2,3-cd)pyreae1 . 1 ,2.2-TetrachloroethattTeuachloroetheneU^TricMoroethaneTrichloroetheaeVinyl chloride

U.S.BPACarcinogen

Clau

AB2CCB2B2B2B2B2B2CB2CCB2B2B2B2B2B2B2B2CB2CB2A

SlopeFactor

(mt/kt-day)

1.754.3181.3

00140.02

000610.340.34

0.0240.616

0.0780.014

0.00757.7

0.730.737.3

0.00737.3

11 0.730.2

0.0510.0570.011

1.9

Source<•)

IRISIRISIRIS

HEASTdIRIS

HEASTdIRISIRISIRIS

HEASTdIRISIRISIRISIRISIRIS

IRISbcccccc

IRISECAOc

IRISECAOc

HEASTd

Ruk Specific a»Concentration at £

Oral Dermal Cancer Risk Level of •Absorption Absorption IE-06 "

Fraction Fraction (anc/kt) t-»

0.950.010.50.5

0.25

0

0.980.950.50.50.50.50.50.50.7

10.810.98

1

0.0010.0010100100.250.250.050.100.100.250.050.250.250.250050.060.030.030.030.030.030.030,050.030.05

0.0050.05

2.60.50.91.3

43.575.7

411.66.36.3

63.14.20.8

194108.1333.6

0.33.33.30.3

33300.33.3

11.752.742.4

267.813

2ftao**90•H-

8ftH-

H*

nnnH-pooP

Pan* lot 2 FWAMCKLt

Table 2-1: PWA CTJQe: Residential Carcinogen (continued)

1

TJo*

•o v +1 w.c --

Table 2 - 2 : FWA CUO«: RMid«nti*l Men-CarcinogenFttfe Bnot - noodptabft ud Wctteds

forBated O« !•*«*» «* Dcnml Abeorptfo* By A

(iBtefrvtod ExpoMR Dwtto* of 30 Y

Chanicii

AnthraceneArwbcOO

BcfyunnBHC (Lttdaoe)

BvtytbeazyiphdiaUte

CMboadinlfideCUOfObeOBBOeChloroformChromium mChromiuaVl

Cymfe4,4'-DDTDibenzofotn1.2-Dichlorobeoieael,3~Dtcfalocobeaxefle1,1-DtchkvoetaDe1 , 1 -DicuoroemeoetraBS*l,2*DichkifoeiheiieDicayt phthabteDimethyl ptomaine

rraonodieneFbonneHexAchlocobeoaeoe

Mercvry (iaocfaoic)Mohyteoediloride4-Memytpbeool

NtckeL sohibte saltsPyicooSckmumSUvtrTetnchloroetheoeThallium

Health Hazard -Specific Coocentraooo

to^ Onl Derail for Hazard Quotient.(Rff» So«ce Abtorpdon Abtocpaon SetEqnaltolr.Avi (a) Faction ggcjgn ———— <°*ff*j?

0.06 RIS0.1 RIS0.3 RIS

0.0003 RIS0.07 RIS

0.005 RIS0.0003 RIS

0.02 RIS0.6 RIS0.2 RIS

0.001 RIS fo.i RIS

0.02 RIS0.01 RIS

i nus1 IHU

0.005 RIS0.037 HEAST d0.02 RIS 8

0.0005 RIS0.004 ECAO

f t fM IRISV.U7 m^t^f

0.09 DWHA0.1 HEAST

0.009 RBbnoi RISU.w* t^t^tf

oi RISu.o *••••*10 HEAST b

0.1 DUSb0.0003 RIS j

0.04 RIS0.04 RIS

0.0008 RIS0.002 RIS0.001 RIS0 14 RIS iW« «~ m^*^^

0.0003 HEAST c0.06 RIS

0.005 HEAST0.04 HEAST b0.02 RIS e0.03 RIS

0.005 RIS h0005 RIS\J.\J\fJ mnmmr

0.01 RIS0.00008 HEAST

mmmmi^^^^

10.5

0.95ao60.010.5

005I

0.90.05

111

0.050.10.6 '

0.720.5

11I11I

0.90.950.9

10.5

I0.8

11

0.030.150.98

11

0.030.6

0.950.3

11

0.030.050.03

0.0010.0010.001

0.10OO50.05005

0.0010.050.050.05

0.0010.0010.0010.0010.100.03OO5OO50.050.050.05005OO5OO50.100.030.03005005

i 0050.0010.001

0.05005OO5

0.0010.03

0.0010.001

0.030.001

6.5E+049.7E+043.0E+055.9E+028.6E+04S.OE+032.0E4025.4E+035.8E+059.6E+041.2E+039.7E+041.9E+049.7E+0310E4066OE+034.7E+042.6E4043JE>02A lB+/)3+^JCiT\IJ

4.4E4044.4E-MM9.7E-f048.8E+031.9E4043.8E4054.9E+O64.8E+042JE4024.0E+044JE4043.7E+029.9E+024.9E+021.6E+053.8E*025.8E+04•j <FjJTlA«JbWJ

2.0E+042.3E+043.1E+046.4E+036.4E+031.1E+04l.OE-^02

Tabl« 2-2: FWA CUGs: Residential Non-Carcinogen (continued)Clamp Goal CottemCraHoav for Noncarefaiofeas la Floodplain* aod Wetlands Soi

Baaed OB Intartlsn and Darnel Absorption By A BieifVarial Receptar(laaagratad Expoean Daratioa of 30 Yaen)

Chemical

Reference

Dose (RID)(mg/kg-day)

SourceOral

AbsorptionFraction

DermalAbsorption

Fnctton

HeakhHazard-Specirk Coocemnboo. for Hazard Quotient

Set Equal to 1(mg/tg)

Toluene1 4-Tridilorobenzene1 , 1, 1-Trichloroedtane1 , 1 ,2-TrichloroeihaneTrichloroeiheneVanadiumXyknesZinc

0.20.010.09

0.0040.0060.007

20.3

IRISRIS

IRIS eIRIS

ECAOHEAST

IRISIRIS

I0.85

10.810.98OJ

1OJ

0.050.250.050.05

0.0050.0010.05

0.001

1.96*454.7E+038.8E+443.8E+037.5E+038.9E+431.96*463.8E+05

EXPOSURE ASSUMPTIONS:ial

Receptor (child adotoirrnt. adult) IntegratedChild body weight (kg)Child tnrtimrnt iagestioa rate (mgttay)Child exposare frequency (days/year)Child exposare duration (years)Child surface area expoaed (cm2/event) (g)Adolasocnt body weight (kg)Adolescent •«•«•••••« ingestioa rate (ing/day)Artnkaani exposure frequency (days/year)Adolescent exposare durationAdolescent surface area exposed (cm2/event) (h)Adult body weight (kg)Adah sediment ingestioa rase (ms/dny)Adult exposure frequency (days/year)Adult exposure durationAdult surface ana expoaed (cm2/event) (i)Soil to skin afcflnmr factor (ma/a&2)Target hazard quotientAveragmg Tima (yean)

15200616

187235

100110

93328

701003715

34920.20

130

a. Sources of ToxidnrViIRIS - InasMsd Rink Inronnaaoa System. U.S. EPAHEAST- riatkhEflneB Aaseaameot Summary Tables, U.S. EPA

DWHA * DraMMWatar Heal* Advisory, U.S. EPAb. Under review by BPA workijoapc Verified by wotkgroapvd. TbeRfDwsse. The oral RID is beingt Rfl) for caamtum in food.g. Percent exposed (26% * arms, hands A feet) x 50 peroeatiie surface area of child (age I dm 6

d drinking water sandard of 1.3 mg/1 asaoming 2 liten consumed per day for 70 years.leWDWoitgroap.

rVcett exposed (26% » anas, bands* feet )x 50 pPercent exposed (18% -am. hands A feet)x 50 pRfD for endrin used as lurrogase toxkarjr valna.

7200).t 15-12800).akfnrtaceire«of sduit(sge 16thr» 30- 19400).

j.k. A bioavatlabtliry factor of 65% it used to aojast for the matrix effect of soil on ganmimminal sbsorpaoo of anenic.

P**2of 2 FWA-RNCJCL5

Table 2-3: FNX CUQ0: Industrial Carcinogen

w

I

1

o £

*1 I*\tu a

111US

MlI

< &2] ii2 "8°U

38b 6

— — 04 M O — — Clp<Nr4<Nppppppppppppp

00

oob

O O O O

ul • ur x

ee o CM•5

Table 2 - 3 , FWA CUO. : Indu.^ri.lCarcinogen (continued,

I

if * 3 9 f £ 9 5 ? ?12 *J > f f S > ? 3 . J r <

-*if s"s• iS* 3 8 3

t»i !t

3i

Table 2 -4 : FWX CUGa: Industrial Non-Carcinogen

FWdi Broot - FloodpldM an* Wetkndfl

VfHMMIP WM ^VMHlu m**umm «•« *-W«MM»IMH^«BV^«MV *M • WMM|V^MBBV MBMB «* VV^^BW v

Daaiid Oa lajulhia and Hrnnal fthsnrntlon By b a TTrrapntiimal ftfirqrtnr(Expocare Frequency of 60 Dny> par Year for 25 Years)

CbfiP^*1

AceaaphtheneAcetoneAnthraceneArsenic (i)BariamBeryfliom•aana BHC (Liodane)bis(2-£mylhexyl)pntbalate2-Bataaone *BatyihenzytphmalateCaiBmaimCarbon disalfideCynrobenzeneChloroformChromium EDChroauam VICopperCyanide4.4T-DDTDtanzofunnlO-Dichlorobenzene1.3-Dtchiorobenzene1.1-Dichloroetnaoe1,1-Dkhloroetbeoe•ans-lO-DtchloroemeneDietfayl phdialateDiaanayt phdulaieDi-a-bntytpbdialaieEndna ketonennorantaenerfcmmiHtKacblorobenzeneHeuchlorobatadieneHsxacbloroetnaneMaasjsneseMnrcory (iaorfank)Memytene cblorkk44lemyiphenolNapnmakneNkfcel soluble saltsPya«neSekniumSaferTeanchlorDetheneTaatlium

ReferenceDose (RID)

(mi/kg-day)0.060.10.3

0.00030.07

0.0050.0003

0.020.60.2

0.0010.1

0.020.01

10.0050.037

0.020.00050.004

0.090.090.1

0.0090.020.810

0.10.0003

0.040.04

0.00080.0020.001

0.140.0003

0.060.005

0.040.020.03

0.0050.005

0.010.00008

Source<»)

IRISIRISIRISIRISIRISIRISmismismisous

IRIS fousmismismismis

HEAST dmis f

DOSECAO

misDWHAHEASTmis b

mismis

HEAST bnusbmis b

mismismismismis

mis iHEAST c

misHEAST

HEAST bmis e

misIRIS b

ER1S[RIS

HEAST

OralAbsorption

Fraction1I

OJ0.950.060.010.5

0.251

0.90.05

111

0.050.10.6

0.720.5

111I1I

0.90.950.9

10.5

10.8

11

0.030.150.98

11

0.030.6

0.950.3

11

DermalAbsorpoott

Fraction0.030.050.03

0.0010.0010.001

0.100-250.050.25

0.0010.050.050.05

0.0010.0010.0010.001

0.100.030050050.050.050.050050.250050.100.030.03005OO5

( OO50.0010.001

0.05005OO5

0.0010.03

0.0010.001

0.030.001

Health Hazard -Specific Conceotraaonfar Hazard Quotient

Set Equal to 1(mi/kg)4.6E+Q57.1E+052.1E+G63.9E4035.6E+053.1E+041.4E+033.5E+044.3E+068OE+057.9E+037.1E+051.4E+057.1E+047.9E4064.1E-HM3.1E+05l.TE+0514E+033.1E-MH3.9E4053.9E+057.1E-f056.4E+O41.4E+053.3EX)64.2E+074.1E4051.8E+0318E4053.1E4053.1E+038.6E+034.3E4031.1E4062.5E4034.3E+05Z2E4O4l.7E-»051.5E+052.lE-*^)54.2E+O44.2E+O47.6E>O46.8E-M32

Pue I FWA-ONC X1.S

Table 2-4 : FWA CUG« Industrial Non-Carcinogen (continued)

BcarcBBOfen* In Ftodnlain* and Wetlands SoiOeanup Goal Cotnacrationa for NOBBased On Ingutton and Dtraal Absorption By An Occupational Receptor

(Exposure Frequency of *0 Days per Year for 25 Years)

Chemical

ReferenceDoae(RfD)

(mi/kg-diy)Source

00

OralAbsorption

Fraction

DermalAbsorption

Fnctioo

Health Hazard-Specific Cooceocncioo

for Hazard QuotientSet Equal to 1

(mgVki)Tow)1 4-Tricfalocobeozeoe1.1,1 -TricUoroemsoe1,1,2-TrichloroeduDCTrichkMoeiheoeVaoadiuiiiXyteneeZinc

0.20.010.09

0.0040.0060.007

20.3

DUSDOS

IRIS eBIS

ECAOHEAST

IRISQUS

I0.85

I0.810.9803

10.3

0.050.250.050.05

0.0050.001

0.050.001

1.4E+064.0E+046.4E+052.7E-MH5.0E+045.9E+041.4E+072.5E+06

EXPOSURE ASSUMPTIONS:Expoaarc setboiReceptor

OccupaiiooalAdnlt

Chikl body wdgnt (kg)Child mdimrnr infestioQ rate (mf/day)Child exposure frequency (days/year)Quid exposure duration (yean)Child surface area exposed (cm2/event)Adokacant body weitat (kg)Adolescent •~tiifr*f inaesnon rate (mg/day)Adnkaffrnr exposure frequency (days/year)Adolescent exposure durationAdolescent surbce area exposed (cm2/evem)Adah body wagbt (kg)Aduh sediment msjestion rate (nc/day)Adah exposure fieanency (days/year)Adult exposure durationAdalt surtee area exnoaed (cm2/event) (f)Soil to skin adherence fiKtor <na/cm2)Target hazard quotientAverexmt Tune (years)

150000

350000

70506025

9700.20

125

L Sources of Toxiory VaJIRIS - latefxieed Risk lafonnsbon System. U^. EPAHEAST - Hnatt Eflecai Asaesament Sunnnary Tables, U.S. EPAECAO- Provisional WD: Memo from loan Doflarnide ECAO, April 1992DWHA - DriatonfWaiBr Hsallh Advisory. U.S. EPA

b. Under review by &A vorkpoupVerified by woikgfonp,Tae RID was calcalasBd fl

UDUt nenoiucdrinkum water standard of 1.3

e. The oral RiD is being recoaaidered by the RID Workgroup.i prop assuming 2 liters consumed per day for 70 yean.

RID for cannsam in food.Percent exposed (5% MikRfD for endna used as sunogaie touciry value.

i of adult (age 16 thru 30 • 19400).

of soil on gasaxMntestinal absorption of srsenic.

FWA-ONC-XL5

Tabla- 3: FWA Human Health and Ecological COCsj

Fields Brook FWAContaminants of Coneeni for the Fields Brook FWA Risk Assessment

Chemical"——— Human Health Ecological——————'—5T xArsenic /v

Barium XBenzo(a)Dyrene XBeryllium XCadmium * XChromium XHexachlorobenzene X XHexachiorobutadiene X XHexachloroethane XLead XMercury XPolychloriiuted Biphenyls X X1,1,2^-Tetrachloroethane XTetrachloroethene X*Trichloroethene XVanadium XVinyl Chloride X

Table 4-1: Location-»p«cific ARARs

Requirement Requirement

Location-Specific Laws/Requirements

FEDERAL REGULATIONS

E.O. 11988 Protection of Floodolains

1. Limits activities in floodplains. Floodplain is defined as "thelowland and relatively flat areas adjoining inland and coastalwaters including flood prone areas of off-shore islands,including at a minimum, that are* subject to a one percent orgreater chance of flooding in any given year.** Federal agenciesmust evaluate the potential effects of actions taken in afloodplain and avoid adverse impacts from remedial activities[40 CFR 6.302 and Appendix A]

E.O. 11990 Protection of Wetlands

2. Minimizes adverse impacts on areas designated as wetlands.[40 CFR 6.302{a) and Appendix A]

Clean Water Act Section 404

3. Requires Federal agencies to avoid, to the extent possible,adverse impacts associated with destruction or loss of wetlands.[40 CFR 230-231; 33 CFR 320-330]

National Historic Preservation Act (NHPA)

8. Requires the preservation of historic properties included in oreligible for the National Register of Historic Places and tominimize harm to National Historic Landmarks. [16 USC 47(et seg.; 40 CFR 6.30l(b); 36 CFR Part 63, Part 65, Part 800|

Wilderness Act

9. Limits activities within areas designed as wilderness areas orNational Wildlife Refuge Systems. [16 USC 1311.16 USC 668; 50 CFR 53, 50 CFR 27]

Wild A Scenic Rivers Act

10. Protects rivers that are designated as wild, scenic, orrecreational. [16 USC 1271; 40 CFR 6.302(c)]

Clean Air Act (CAA1

Non Attainment Area Requirements

11. Requires the use of reasonably available control technology(RACT) for sources located in non-attainment areas.(CAA Title I, Subpart 2]

~4. Prohibits discharge of dredged or filled material into waters olthe U.S. without a permit. [40 CFR 230, 33 CFR 320-330)

Rivers and Harbors Act of 1899: Section 10

5. Section 10 permit required for structures or work in oraffecting navigable waters. [33 USC 403, 33 CFR 320-330]

Endangered Species Act

6. Protects endangered species and threatened species andpreserves their habitat Requires coordination with federalagencies for mitigation of impacts. [16 USC 1531 et sea:50 CFR 200, 50 CFR 402]

Fish and Wildlife Coordination Act

7. Requires coordination with federal and state agencies onactivities affecting/modifying streams or rivers if the activityhas a negative impact on fish or wildlife. [16 USC 661 et seg.;40 CFR 6.302(g)]

12. Any activity modifying a stream or river, which wi l l have adiversion, channeling, or other action and which affects fishwildlife must be implemented with action to protect fish orwildlife [16 U.S.C 661 et seq.)

Resource Conservation and Recovery Act (RCRA)

13. A treatment/storage/disposal (TSD) facility within a 100-yearfloodplain must be designed, constructed, operated, andmaintained to avoid washout

14. Landfills may not be located within vulnerable h>drogeologyareas. [RCRA 3004

Tabl« 4-1: Location-specific ARARs (continued)

Requirement Requirement

Toxic Substances Control Act (TSCA1

15. Requires that TSCA landfills meet specified siting, design,handling, and monitoring requirements [40 CFR 761.60 and761.75(8)].

STATE STATUTES AND REGULATIONS

Ohio H«*"*«""« Waste Siting Criteria •

1, A hazardous waste facility installation and operation permitshall not be approved unless it proves that the facilityrepresents the minimum risk of all of the following:

(it Contamination of Ground and Surface Water(ih Fires or Explosions from Treatment Storage or Disposal

Methods(iii) Accident during Transportationfiv> Impact on Public Health and Safety(vl Air Pollution(vj> Soil ContaminationfORC 3734-06 (D> (6)

Ohio HararHnu* Waste Management Regulations

1. Facilities where treatment, storage, or disposal of hazardouswaste will be conducted is prohibited within the 100-yearfloodplain. [OAC, Title 3745, Chapter 54, Section 18]

2. New RCRA treatment, storage, or disposal of hazardous wasteis prohibited within 61 meters of a fault displaced in Holocenetime. [OAC, Title 3745. Chapter 54, Section 18]

3. Placement of noncontainerized or bulk liquid hazardous win salt domes, salt bed formations, underground mines,is prohibited. [OAC, Title 3745, Chapter 54, Section 18]

Prohibits the following locations for treatment, storage, anddisposal of acute hazardous waste: (H within 2.000 feet of an-residence, school, hospital. Jail, or prison: (21 anv naturallyoccurring wetlandi (3) any flood hazard area* (41 within anystate park or national park or recreation area.fORC 3734.05 (D*6VgVhH

Ohio Solid Waste Regulations

Specifies locations in which solid waste landfills are not to besited. fOAC 3745-27-07 (A> (BH

Ohio Groundwater Well Regulations

Mandates that groundwater wells be: (U located andmaintained so as to prevent contaminants from entering a welland (2> located to be accessible for cleaning and maintenance[OAC 3745-9-04 (A) and (Bll

Table 4-2 : Action-apecific ARARi

FEDERAL REGULATIONS

Toxic Substances Control Act (TSCA)

! Establishes regulations to govern the storage and disposalof PCBs including PCB-contaminated soil. [40 CFR 761]

National Pollutant Discharge Elimination System (NPDES)

9. Requires dischargers of pollutants from any point sourceinto surface waters of the United States to meet certainrequirements and obtain a NPDES permit.[40 CFR 122.435 123. and 125 are involved!

The PCB Spill Cleanup Policy, Subpart G of §40 CFR 761, applies tospills thai occurred after May 4, 1987, the effective date of the policy.Subpart G is not an ARAR at the Fields Brook Site, since PCBcontamination occurred before the effective date of the policy. Subpart Gis instead identified as "to be considered" (TBC) guidance.

3. Specifies requirements for disposal of materials containingPCBs. [40 CFR 761.60]

4^ Dredged materials that contain 50 ppra of PCBs or greatermust be disposed of in an incinerator or chemical wastelandfill, as specified in the regulations. [40 CFR761.60UX5)]

5. Prescribes design, construction, and operation standardsfor TSCA landfills. [40 CFR 761.75]

Clean Air Ad

National Ambient Air Quality Standards (NAAQS)6. Establishes ambient air quality standards to protect public

health and welfare. Includes Rational P"1^ "**Om^«v Ambient ^ ft»*litv Starf^ far PaniculateMatter. [40 CFR 50]

Ambient Air Monitoring7. Specifies methods for conducting ambient air monitoring.

[40 CFR 53]

Water Act

8 Prohibits discharge of dredged or fill material into watersof the U.S. without a penmt. [40 CFR 230, 33 CFR 320-330]

Ambient Water Quality Criteria

10. Requires EPA to publish water quality criteria for specificpollutants for the protection of human health and theprotection of aquatic life. [40 CFR 131]

National Pretreatment Standards

11. Establishes general and specific standards for pollutantsthat are discharged to a POTW. [40 CFR 403]

Storm Water Discharge Regulations

12. Establishes permitting, sampling and analysis requirementsfor industries in certain categories which discharge stormwater to waters of the United States. Includes stormwater discharge from construction activities. [40 CFR 122]

RCRA Corrective Action Management Unit Rule

13. Provides for designation of a Corrective ActionManagement Unit and eases regulatory requirements forremedial actions conducted within unit boundaries. [40CFR 260 et al]

RCRA Hazardous Waste Treatment Storage and DisposalRegulation

14. Provides regulations for the notification of hazardouswaste activities, identification and listing of hazardouswastes and management of hazardous wastes bygenerators, transporters and operators of treatmentstorage and disposal faculties. [40 CFR 260 et al]. SpecificRCRA TSD regulations that mav need to be evaluated aspotential ARARa on a case-bv-caac basis include:a) 40 CFR 268 (movement of excavated materials)b) 40 CFR 6. Appendix Ac) RCRA 3003d) 40 CFR 262 and 263e) 40 CFR 170-1790 5PA flaynrdous Waste Permit Program (oromul gated

in part as 40 CFR 300.440(9/22/93)).g) RCRA Section 3005h) 40 CFR 270 and 124i) 50 FR 45933(11/5/85)

Table 4*2: Action-specific ARARa (continued)

Requirement Requirement

15. Specifies requiremenu for closure of hazardous wastemanagement units, [40 CFR 264.117(c).228<a) and (b).and 3lO(a) and <b)]

16. These regulations establish standards for designinstallation and maintenance of dikes around a unit inorder to ensure the unit does not fail or overtop, and toremedy problems and any contamination. [40 CFR 264,221(g)and (h), and 261.277]

RCRA Land Disposal Restrictions

17. Establishes a timetable for restriction of land disposal ofhazardous wastes and treatment criteria of hazardouswaste prior to land disposal. [40 CFR 268]

RCRA Solid Waste Treatment Storage and Disposal (TSD)Regulations

18. Establishes requirements for owners and operators of solidwaste disposal facilities [40 CFR 258]

STATE STATUTES (OHIO REVISED CODE)

Ohio Air Emission Standards. General

1. Air emissions must be in compliance with Sec. 3704 andanv rules, permits, orders, and variance issued pursuant tothat section. fORC Sec. 3704.05fAimi. (Ol

Prohibits the emission of paniculate matter, dust, fumes.gas, mist, smoke, vapor, or odorous substances thatinterfere with the comfortable enjoyment of life orproperty or i| injurious to public health. IORC Sec.3734.02ml

in* nlans for sanitarvRCQUJTM cxplosiv? MS. BlBBlMfill _ __— -UnHfill* MtH flwnwute* fltffttfwiiv tn the PJIBCtOC Of OtlKEPA to order an owner or opetaMC of « faciliBJQimplement an explosive MS monitorirni and repottingfORC Sec. y34.q4.UAl.ro. (Dl. (G\\

Ohio Water Pollution Statutes

I. Pollution of waters of the state is prohibited. [QRC Sec.6III .J

2. Sites with point source discharges must comply withnational effluent standards. fORC Sec. 61111.04.21

3. prohibits failure to comply with requirements of Sections6111.01 to 6lll.08or anv rules, permit or order issuedunder those sections. fORC Sec. 6111.071

Ohio Nuisance Statutes

1. Prohibits noxious exhalations or smells and the obstructionof waterways. fQAC 3767.13**check with Ohio EPA recites**]

2. Prohibition against throwing refuse, oil, or filth into lakes.streams, or drains. fOAC 3767.14**check with Ohio EPAre. cites**!

STATE REGULATIONS rOHIO ADMINISTRATIVE CODE)

Ohio Non-Point Source Regulations

1. Regulations call for the use of conservation practices 10 *"control sediment pollution of water resources.[OAC, Title 1501.Chapters 1,3, 5]

Ohio Water Quality Standards

I- Specifics analytical methods and collection procedures forsurface water discharges. fOAC 3745-1-031.

2. All surface waters of the state shall be free from:(a> Objectionable suspended soils.fb) Floating debris, oil, or scum(c) Materials that create a

°r(e) Nutrients that create nuisance growth

fOAC 3745-1-041

3. Prevents degradation of surface water Quality bclov. water oualitv.

[QAC 3745~l-05fA>

Criteria for establishing thermal and non-iherrnal mmzones for point source discharges.fOAC 3745-I-06JA1

Tabla 4-2: Action-ep«cific ARARa (continued)Requirement Requirement

Establishes w«er gyajjry 7fiT7p* for po|lutants that do nothave specific numerical or narrative criteriafOAC 3745-1-071

Establishes water use designations for stream segmentswithin the Ashtabula River Basin.fOAC 3745-1-14]

Establishes water use designations for stream segmentswithin the Lake Erie Basin,fOAC 3745-1-311

)hio Air Quality Regulations

Prohibition of air pollution nuisances fOAC 3745-15-07

' Tibient air quality standards for total suspendedarticulates fOAC 374S-17-02(A) (B) (Ol

Specifies the allowable opacity for paniculate emissionsfrom stationary sources. (OAC 3745-17-07 (A through D)]

Restrictions for control of fugitive dust emissions fOAC3745-l7-08(Ah (A2) (Bl (Oil

Air quality standards for carbon monoxide, ozone, andnon-methane hydrocarbons. fOAC 3745-21-02(A) (B)(01.

Measurement methods to determine ambient air qualityfor carbon monoxide, ozone, and non-methanehydrocarbons.OAC 3745-21 -03 (to (O (DM

Prohibition of significant and avoidable deterioration of airquality ffQAC 3745-21 -061

Control reouiremen^ for emissions of organic materialsfrom stationary sources fOAC 3745*21-07 (A) (B) (El (DilllRequirements for carbon monoxide emissions fromstationary sources fOAC 3745-2i-OftfA-EU

10. Emission control programfor air ooilutioa alerts.

is for orenaratkHiCTrfflfflWf

fOAC 3745-25-031

Dhio Solid Waste Regulations

• Defines exemptions: to solid waste feyu|afjon| anflestablishes limitations on temporary storage of nutresciblewaste or any solid waste which causes a nuisance or health

Establishes allowable methods of solid waste disposal.fOAC 3745-27-06 (A> fBl fOl

Specifies the minimum technical information required as asolid waste permit to install. fOAC 3745-27-06(8) (Ol

4.

5.

6.

7.

Additional siting requirements with respect to geology.water supplies, occupied properties, oarklands and minesubsidence areas. fOAC 3745-27-07 (D) (R (G) (H)1

Construction specifications for sanitary landfills. [OAC3745-27-08(0 (D-H)l

Final closure of sanitary landfill facilities fOAC 3745-27-1 1(B)

Established when an explosive eas monitoring plan isrequired for solid waste landfills. fOAC 3745-27-1 i (A>(B) (D) (E) (M>

8.

9.

10.

Identified parameters and schedule for explosive gasmonitoring. 1OAC 3745-27-12(1) (.HI

Requires that a detailed plan be provided to describe howany proposed filling, grading, excavating, building, drillingor mining on land where a hazardous waste facility or solidwaste facility was operated will be accomplished.Specifics the required post-closure care for solid wastefacilities. fOAC 3745-27-14(A)l

11. ^pecifjes Official operational requirements for solid wastelandfills. fQAC 374S-27-i9fEM

12. Requires the ownen/ooeraijof '9 jmplcment measures toattain compliance with requirements of these rules.fQAC 3745-27-19(0)

13.

14.

15.

Includes requirements for daily cover and intermediatecover for temporarily inactive areas. fOAC 3745-27-19(F)(GilIncludes requirements for the final cap system for areas atfinal elevations. fOAC 3745-27- 19 (rDl

Requires owners/operations to conduct a program todetect PCB waste and hazardous watte prior todisposal. fQAC 374S-27-19fUl

16. Surface water requires to be diverted from areas wheresolid waste is being, or fry* hecn. deposited. fOAC 3745-

17. Requires repair of leachatc outbreaks: collections andtreatment of leacnaic on the surface of the landfill. [OAC3745-27-19(101

18. Specifies certain operational and location standards forlandfills accepting waste after June 1.1994.IOAC 3745-27-201

Table 4-2: Action-ipecific ARAR« (continued)

Requirement Requirement

Ohio Air and Water Pollution

I. Requires that a permit to install (FTP or plans_jruJJldemonstrate best availafrje technology (BAT) and shall notinterfere with or prevent the attainment or maintcnance_ofapplicable ambient air auaJitv standards. fOAC 3745-31-06]

Ohio Section 401 Regulations

t. Specifics substantive criteria for Section 401 water qualitycriteria for dredging. Tilling.obstructing, or altering watersof the state. [OAC 3745-32-06]

Ohio Hazardous Waste Management Reflations

rovides regulations for the notification of hazardous wasteactivities, identification and listing oMiazardous wastes andmanagement of hazardous wastes by generators, transportersand operators of treatment storage and disposal facilities.Specific regulations are as follows:

1. Specifies permit information required for all hazardouswaste facilities. fOAC 3745-50-44(A)l

2. Specifies permit information required for all hazardouswaste land disposal facilities. fOAC 3745-50-44(8)1

3. Establishes substantive permit requirements for containerstorage. fOAC 3745-50-44(0 ml

Establishes substantive permit requirements for surface~" impoundments fOAC 3745-50-44(0 (4)

5. Establishes substantive permit requirements for hazardouswaste surface impoundments, wane piles, land treatmentunits, landfills, and underground injection wells. fOAC3745-5(M4(O(6H

6. Establishes substantive permit requirements for hazardouswaste landfills. fOAC T745-5CM4/CVTH

7. Establishes substantiyghjnffdoys waste permitreouirementi for miacdl«ieout unto.

8. Exempts the residues of hazardous wastes from emptycontainers. fOAC 3745-Sl-07fA> (Bll

9- Requires that waste generators determine whether thewaste is hazardous. fOAC 3745-52-1UA1 throuch (D)l

10. Requires the use of the manifest system for hazardouswaste transportation. IOAC 3745-52-201

11. Specifies the number of manifest copies to be prepared.fOAC 3745-52-221

12. Specifies procedures for the use of manifests.fOAC 3745-52-231

13. Requires a generator to package waste inaccordance with U.S. DOT regulations for transportationoff-site. fOAC 3745-52-301

14. Specifies labeling requirements for h«arrim« waste to betransported off-site. fOAC 3745-52-311

15. Specifics marking requirements for hazardous waste to betransported off-site. fOAC 3745-52-321

16. Requires that generators placard hazardous waste prior tooff-site transportation. IOAC 3745-52-331

17. Specifies security requirements for wastefacilities. IOAC 3745-54- 14(A) through (C)l

18. Specifies inspection requirements for hazardous wastefacilities. fOAC 3745-54- ISfAUQ!

19. Restricts the siting of hazardous waste facilities in areas ofseismic activity or floodolains.

20. Specifies design and operation standards for hazardouswaste facilities. fOAC 3745-54-311

21. Requires that waste facilities be equipped withemergency equipment. fOAC 3745-54-32(A) through f D ) l

22. Requires testing of emergency equipment.fOAC 3745-54-331

23. Requires thai personnel handling hazardous waste haveimmediate access to an internal alarm or emergencycommunication device. fOAC 3745-54-341

I24. Requires that adequate aisle space be maintained at

facilities. fOAC 3745-54-351

25. Requires arrangements with local authorities. fOAC 3745-54-37(A> and

26. Requires ih*t ha|*rdous waste facilities have a contingencyplan, fOAC 3745-54-52fA) through fFH

27. Requires that contingency plans be maintained at thefacility and submitted to local authorities and the OhioEPA. fOAC 3745-54-53(A) and fB)l

Table 4 -2 : Action-specific ARARfl (continued)

Requirement Requirement

29.

30.

31.

32.

33.

Requires an emergency coordinator. fQAC 3745-54-551

Specifies the procedures to be followed in the event of anemergency. fQAC 3745-54-561

Establishes circumstances »«fer whicfr an operator of ahazardous waste facility must implement a iipjinoLyJigxmnnitonnff program.

46. Requires that notice be given to local land authoritiesconcerning the disposal of hiaffdous waste _ai_yie_sueJ_anclrequires a notation to the deed Co the facility property.

3745-55- 19(A> and (B)l

47. Containers holding Mtirdoyy waste must bc_n>ajnuinedgood condition (po rust or structural defects).fOAC 3745-55-74]

Presents ground waier monitoring and response programs.required for hnfpJous land-baaed units. fOAC 3745-54-9UA11

R«niire* compliance with permit conditions that address.ground water QAC 3745-54-921

35.

48. Hazardous waste placed in container must not react withthe container material or liner material. fOAC 3745-55-721

49. Containers holding hazardous waste must be closed exceptto add or remove wastes and must not be handled in amanner that mav nnxure the cootjincT or cause it to leak.

———————————————— fQAC 3745-55-731team res that permit specify hazardous consiiruenis_jo_vhich the ground vMer PfTffitiffB standard of 3746-54-92 50. Requires at least weekly inspections of container storage

in "———~ areas. IOAC 3745-55-741

51. Requires that container storage areas have a containmentand specifies thaf nUlJUW requirements of such a

i [OAC 3745-75 (A-DH

applies. fQAC 374^-54-93 fA> (BH

Presents the methodology for fletermining concentrationlimits and alternative concentration limits.

3745-54-94 (A) (B)l

36 Establishes point of compliance at vertical surface located.at the hvdraulicaHv downgradient litnjt of the waste

area tltajjauenjadowq into the .uppermost

37.

nnderlvin. the untrfrt. 1QAC 3745-54-95 (A> (BH

A compliance period durint which the ground waterprotection standards apply will be required in the permit.fOAC 3745-54-96 (A) (Bl (Ol

PreKSI»_!^fluiienwuj_fQr the ground water monitoringprogram. fQAC 3745-54-97(A) through (HM

52. Prgfflis_gsaejil_ precautions to be taken to preventaccidental ignition or reaction of jgnitable or reactivewastes that will be stored in container. fOAC 3745-55-761

53. Presents general precautions to be taken when dealingwith incompatible wastes.

54. Specifies closure requirements for containers andcontainment system. fOAC 3745-55-781

55. Requires that each existing tank used to store or treathazarous wnm? that dots pot Imvctoo

39.

40-

41.

42.

43.

44.

Presents requirements of ground water detection program.fOAC 3745-54-98 fA-H

Presents requirements of around water compliancemonitoring program.

Specifies closure standards for hazardous waste facilities.fOAC 3745-55- 1UA> through (Ol

Presents the required content of closure plans.fOAC 3745-55- 1 2(BH

fOAC 3743-55-9HA. B. DM

56. Requires a secondary containment system for tanks and

rOAC 3745-55-92 fA-Gl

57. Specified general operating requirements for tank systems.fOAC 3745-55-94 (A. Bf' Ol

Requires proper decontamination or disposal ofcontaminated equipment, structures, and soils. fOAC3745-55-141

58. Requires inspections at least once each operating dayfOAC 3745-55-95 (A-frll

59. Requires thai unfit tanks be removed from use and fun her

rOAC 3745-55-96 ( A. B. C. RlSpecifies post-closure care reouirementa.fOAC 3745-55-171

45. Presents the requirements of an adequate post-closureplan.fOAC 3745-55-18(8))

Ttblc 4-2: Action-•pacific AJtAfta (continued)Rtquirtmcfit

60. damn iod aott- loninfOAC 3743-33-97 f A. Bll

iremanti for uak

61 Presents audopi be taken

62. Presents general precautions to be taken when dealingbit wastes that are stored or

63. S

in tanks. fOAC 3743-53-99CA. B>l

fies the desitn and ooerauoo for waste

64.

1743.56-Sl <A-FU

MI* niles rmut he mooitorad durinc construction Ofinstallation apj yj^fflkma. fOAC 3745-56-54 f A. B»

65. Specifics closure and POtt-clotufe care pMuiremenu forPiles. fOAC-3745-S6-3i (A.B.OI

66. Allowi Ohio EPA the opportunity to inspect waste filesduring construction. fOAC 3743-56-33 fA>l

67. Specifies environmental performance standards for land-baaed unin. IQAC 3743-37-OKA) through

6S. Preienti deutn and ooenfi i reauiimieiiii foe landfilli.fQAC 3745-37^03<A) throuth (Dl

69.>an fl]||, [

uiorinc and in«f>*ft"M> reouiretncmi for

70. Specifics closure and oost-ciomft for

Ikmids. in landfilla. fQAC 1749.57-141 A> ihiwuh

72.

1. Specifies minimum ooMtruaioti pcouirememi for newgroundwMcf wcilt. fQAC 3743-9-06* AKBMPv ind 'E)1

2.

3.

fOAC 3745.9-05/ A) through (GM

Eatabliihea i r f e deaim rcauiretnenu for newgfoundwaief welli fQAC 3745*9^03-07^1 through

4. Reauifes the disinfection of new wells and the use ofDoable water for priming pumos. fOAC 3745-9-08(A) and

S. Establishes maimcnj madifieitft

fCV (DM I ME) through (Gl.

6. Reouires that foil

wtfU. fOAC 3745-9-09 fA> through

itull he nuintuiMd in conottilled widi trout or similar matenai or

with all n«ul»iorufOAC 3745-9. 10 fA^ through fOI

Ohio National Poll'Mant Pischaftf E|iniipMk>n Sviiem

1 . Requires permits for the discharge of pollutants from anypoint source into waters of the United States. Must meettechnology-based effluent limttalions and standards (either"best conventional pollutant control technology "or 'bestavailable technology economically achievable"), determinedon a case-by-case basis. (OAC. Title 3745. Chapter 33]

O Pre-Treatment Reouir*>g>*nts

2. Regulates (be discharge of pollutants to POTWs.[OAC Title 3745. Chapter 3]

73. bits the al i of FO20. FO2I.FQ22.FQ23.

74. EaiaMiiha location. deai«B. consnuetion. operation.

iiniu uied to imt. oc Ait of

75. Pfojyhjts the use of dilution as a lubninuc for treatmentof restricted wastca or restricted waste residues.

Table 5i FH* Alternative Evaluation

£vafttttfon Crttoi* Aft 1. Alt I Alt 3A Alt 38 Alt. 4 Alt 3 Alt 8 Alt 7

Overall Protectionof Health and Environment

Compliance with ARARs

Long-term Effectivenessand Permanence

Reduction of Toxicity, Mobility.or Volume through Treatment

Short-term Effectiveness

[mplemeruabtlity

Present Worth Cost (millions)

3 ft

NA ft«

3 ft

3 3

3 •

NA •

0 46

ft

ft

ft

ft

•

•

89

» ft . • • •

» ft • • •

ft » • • •

ft 3 ft • ft

• • • • •

• • • • *)

9.5 5.8 19.0 21.3 69

State Agency Acceptance

Community Acceptance Community acceptance of thethe public comment peaod.

recommended alternative will be evaluated after

Fully meets catena ft Partially meets catena 3 Does not meet catena NA Not applicable