feasibility study for floodplainavetlands area fields

F I N A L R E P O R T

FEASIBILITY STUDY FORFLOODPLAINAVETLANDS AREA

FIELDS BROOK SITEASHTABULA, OHIO

Prepared forFields Brook Action GroupAshtabula, Ohio

October 17, 1996

Woodward-Clyde

30775 Bainbridge RoadSuite 200Solon, Ohio 44139(216)349-2708(216) 349-1514 fax86C3609S

Woodward-ClydeEngineering 8 sciences applied to the earth & its environment

October 17, 1996 Submitted Via Federal Express86C3609S

United States Environmental Protection AgencyRegion V (HSRM-6J)Ohio/Minnesota Remedial Branch77 West Jackson BoulevardChicago, IL 60604-3590

Attention: Mr. Edward J. Hanlon

Subject: Final FWA Feasibility Study (FS) TextAshtabula, Ohio

Dear Mr. Hanlon:

Attached are six unbound, double-sided copies of the FWA Feasibility Study (FS). This versionincorporates the comments provided in October 11, 1996 correspondence. The following pagereferences are locations where changes have been made by FBAG that differ from USEPA requestedlanguage.

• Page 5-2, first paragraph: O&M samples, post-remediation O&M text.• Page 5-3, top paragraph: O&M samples, post-remediation O&M text.• Page 5-5, second paragraph: O&M samples, post-remediation O&M text.• Page 5-7, second paragraph: O&M samples, post-remediation O&M text.• Page 5- 10, first full paragraph: post remediation O&M text.• Page 5-13, Section 5.1.8.3: Residential FEU review criteria, fourth item.• Page 5-14, Section 5.1.8.3: Industrial FEU review criteria, fourth item.• ARARs: Since FBAG has not received comments from USEPA on 10/15/96, no changes have

been made to tables submitted on 10/1 1/96.• Detailed Cost Tables (6-2 through 6-7), Table 6-1 and text cost estimates have been revised to

consider mitigation of injured wetlands at a 1 .5 to 1 replacement at a cost of $40,000 for thepurpose of this FS. Text in Section 5.1 has been revised to reflect this assumption.

• Detailed Cost Tables for sampling O&M have been modified to reflect a sampling program of80 samples per year (40 PCB and 40 TCL/TAL) for Alternatives II, IIIA, IIIB, and IV percomments received on May 22, 1996.

If you have any questions, please do not hesitate to contact Joseph Heimbuch, de maximis, inc. at(941) 365-8444 or me at (216) 349-2708.

Sincerely,

Martin L. Schmidt, Ph.D.Senior Project Manager

MLS/kmc

cc: J. Heimbuch, de maximis, inc. Tony Wolfskill, WCCRick Mason, RMI Joe Lonardo, Vorys, Sater

Woodward-Clyde Consultants • A subsidiary of Woodward-Clyde Group, Inc.30775 Bainbridge Road, Suite 200 • Solon, Ohio 44139216-349-2708 • Fax 216-349-1514

Woodward-Clyde

DraftTABLE OF CONTENTS

1.0 INTRODUCTION...................................................................................... 1-1

1.1 PURPOSE OF REPORT................................................................. 1-11.2 ORGANIZATION OF REPORT..................................................... 1-2

2.0 SITE BACKGROUND INFORMATION...................................................2-1

2.1 DESCRIPTION OF FLOODPLAIN EXPOSUREUNITS (FEUS)............................................................................... 2-2

2.2 EXISTING CHEMICAL DATA.....................................................2-3

3.0 INTEGRATED BASELINE RISK ASSESSMENT.................................... 3-1

3.1 INTRODUCTION.......................................................................... 3-13.2 SUMMARY OF INTEGRATED BASELINE RISK ...........................

ASSESSMENT...............................................................................3-13.2.1 Human Health Risk Assessment...........................................3-13.2.2 Human Health Risk Assessment Results............................... 3-23.2.3 Ecological Risk Assessment Approach................................. 3-23.2.4 Ecological Risk Assessment Results..................................... 3-3

4. 0 IDENTIFICATION AND SCREENING OF TECHNOLOGIES ................4-1

4.1 REMEDIAL ACTION OBJECTIVES............................................. 4-14.2 POTENTIAL ARARs .....................................................................4-1

4.2.1 Location-Specific ARARs....................................................4-24.2.2 Action-Specific ARARs.......................................................4-24.2.3 Chemical-Specific ARARs ................................................... 4-3

4.3 RISK MANAGEMENT CRITERIA ...............................................4-34.3.1 Human Health Risk Management......................................... 4-34.3.2 Ecological Risk Management............................................... 4-3

4.4 POTENTIAL REMEDIAL RESPONSE AREAS............................4-44.4.1 Alternatives II, IV, V, and VI...............................................4-44.4.2 Alternatives IIIA, IIIB, and VIII ..........................................4-6

4.5 DESIGN DELINEATION SAMPLING..........................................4-6

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4.6 IDENTIFICATION OF RETAINED TECHNOLOGIES ANDPROCESS OPTIONS .....................................................................4-74.6.1 No Action............................................................................4-74.6.2 Institutional Controls...........................................................4-74.6.3 Revegetated Soil Cover........................................................4-74.6.4 Excavation and Revegetated Backfill.................................... 4-84.6.5 Thermal Treatment..............................................................4-94.6.6 Off-Site Disposal ................................................................4-94.6.7 On-Site Disposal..................................................................4.9

5. 0 DEVELOPMENT AND SCREENING OF ALTERNATIVES................... 5-1

5.1 SUMMARY OF RETAINED ALTERNATIVES............................ 5-15.1.1 Alternative I - No Action..................................................... 5-15.1.2 Alternative II-Containment #1............................................ 5-15.1.3 Alternative IIIA - Cover, Excavation, Backfill and Off-Site

Disposal............................................................................... 5-25.1.4 Alternative HIE- Cover, Excavation, Backfill and Off-Site

Disposal...............................................................................5-55.1.5 Alternative IV -Containment #2.......................................... 5-75.1.6 Alternative V - Excavation, Backfill, and Off-Site Disposal.. 5-85.1.7 Alternative VI - Excavation, Backfill, Treatment and Off-Site

Disposal............................................................................... 5-95.1.8 Alternative VII - Cover, Excavation, Backfill, Treatment, and

On-Site Disposal in Consolidation Areas.............................. 5-95.1.8.1 Fields Brook Sediment Disposal............................ 5-115.1.8.2 On-Site Consolidation Areas.................................5-115.1.8.3 Post-Remediation Samples.................................... 5-12

5.2 EVALUATION OF ENVIRONMENTAL PROTECTION FORREMEDIAL COVER AND EXCAVATION TECHNOLOGIES.. 5-145.2.1 Chemical Exposure Reduction............................................ 5-145.2.2 Ecological Impacts............................................................. 5-165.2.3 Potential Cover Issues........................................................5-175.2.4 Comparative Summary: Excavation and Cover.................. 5-20

5.3 CRITERIA FOR DETAILED ANALYSISOF ALTERNATIVES................................................................... 5-20

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6.0 DETAILED ANALYSIS OF ALTERNATIVES......................................... 6-1

6.1 ALTERNATIVE I - NO ACTION.................................................. 6-16.1.1 Overall Protection of Human Health and the Environment.... 6-16.1.2 Compliance with ARARs..................................................... 6-16.1.3 Long-Term Effectiveness and Permanence........................... 6-16.1.4 Reduction of Toxicity, Mobility or Volume through

Treatment............................................................................ 6-26.1.5 Short-Term Effectiveness.....................................................6-26.1.6 Implementability ..................................................................6-26.1.7 Cost.....................................................................................6-2

6.2 ALTERNATIVE II - CONTAINMENT #1.................................... 6-26.2.1 Overall Protection of Human Health and the Environment.... 6-26.2.2 Compliance with ARARs..................................................... 6-36.2.3 Long-Term Effectiveness and Permanence........................... 6-36.2.4 Reduction of Toxicity, Mobility or Volume through

Treatment............................................................................ 6-36.2.5 Short-Term Effectiveness..................................................... 6-46.2.6 Implementability ..................................................................6-46.2.7 Cost..................................................................................... 6-4

6.3 ALTERNATIVES IIIA & IIIB - COVER, EXCAVATION,BACKFILL AND OFF-SITE DISPOSAL....................................... 6-46.3.1 Overall Protection of Human Health and the Environment... 6-56.3.2 Compliance with ARARs..................................................... 6-66.3.3 Long-Term Effectiveness and Permanence........................... 6-66.3.4 Reduction of Toxicity, Mobility or Volume through

Treatment............................................................................ 6-76.3.5 Short-Term Effectiveness.....................................................6-76.3.6 Implementability ..................................................................6-76.3.7 Cost..................................................................................... 6-7

6.4 ALTERNATIVE IV -CONTAINMENT #2 ...................................6-86.4.1 Overall Protection of Human Health and the Environment.... 6-86.4.2 Compliance with ARARs..................................................... 6-96.4.3 Long-Term Effectiveness and Permanence ........................... 6-96.4.4 Reduction of Toxicity, Mobility or Volume through

Treatment............................................................................ 6-9iii

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6.4.5 Short-Term Effectiveness..................................................... 6-96.4.6 Implementability ................................................................6-106.4.7 Cost..................................................................................6-10

6.5 ALTERNATIVE V - EXCAVATION, BACKFILL, ANDOFF-SITE DISPOSAL.................................................................. 6-106.5.1 Overall Protection of Human Health and the Environment.. 6-116.5.2 Compliance with ARARs................................................... 6-116.5.3 Long-Term Effectiveness and Permanence......................... 6-116.5.4 Reduction of Toxicity, Mobility or Volume through

Treatment.......................................................................... 6-126.5.5 Short-Term Effectiveness................................................... 6-126.5.6 Implementability ................................................................6-126.5.7 Cost................................................................................... 6-13

6.6 ALTERNATIVE VI - EXCAVATION, BACKFILL, TREATMENTAND OFF-SITE DISPOSAL ........................................................ 6-136.6.1 Overall Protection of Human Health and the Environment.. 6-136.6.2 Compliance with ARARs................................................... 6-146.6.3 Long-Term Effectiveness and Permanence......................... 6-146.6.4 Reduction of Toxicity, Mobility or Volume through

Treatment.......................................................................... 6-146.6.5 Short-Term Effectiveness...................................................6-156.6.6 Implementability ................................................................6-156.6.7 Cost...................................................................................6-15

6.7 ALTERNATIVE VII - COVER, EXCAVATION, BACKFILL, ANDON-SITE DISPOSAL................................................................... 6-166.7.1 Overall Protection of Human Health and the Environment.. 6-176.7.2 Compliance with ARARs................................................... 6-186.7.3 Long-Term Effectiveness and Permanence......................... 6-186.7.4 Reduction of Toxicity, Mobility or Volume through

Treatment.......................................................................... 6-186.7.5 Short-Term Effectiveness................................................... 6-196.7.6 Implementability ................................................................6-196.7.7 Cost................................................... ..............................6-19

7.0 COMPARATIVE ANALYSIS OFREMEDIAL ALTERNATIVES ...........7-1

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7.1 PROTECTION OF HUMAN HEALTH ANDENVIRONMENT........................................................................... 7-1

7.2 COMPLIANCE WITH ARARs....................................................... 7-27.3 LONG-TERM EFFECTIVENESS AND PERMANENCE..............7-27.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME

THROUGH TREATMENT............................................................ 7-37.5 SHORT-TERM EFFECTIVENESS................................................7-37.6 EASE OF IMPLEMENTATION..................................................... 7-37.7 COSTS ........................................................................................... 7-4

8.0 SUMMARY OF COMPARATIVE ANALYSIS......................................... 8-1

9.0 CONSTRUCTION IMPACT ASSESSMENT............................................9-1

10.0 REFERENCES......................................................................................... 10-1

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LIST OF TABLESTABLE 4-1 POTENTIAL LOCATION-SPECMC ARARsTABLE 4-2 POTENTIAL ACTION-SPECMC ARARsTABLE 4-3 POTENTIAL ACTION-SPECIFIC ARARs, SURFACE WATER QUALITY

STANDARDSTABLE 4-4 OTHER MATERIAL TO BE CONSIDERED (TBCs)TABLE 4-5 POTENTIAL DISCHARGE LIMITATIONSTABLE 4-6 FCUGs AND CRGs FOR THE EPA DETERMINISTIC APPROACHTABLE 5- 1 ESTIMATED REMEDIAL RESPONSE AREAS AND VOLUMESTABLE 5-2 ESTIMATED SURFACE AREAS FOR COVER, EXCAVATION, AND

BACKFILL FOR ALTERNATIVES fflA AND nffiTABLE 5-3 ESTIMATED SURFACE AREAS FOR COVER, EXCAVATION, AND

BACKFILL FOR ALTERNATIVE VHTABLE 6-1 DETAILED ANALYSIS OF ALTERNATIVESTABLE 6-2 COST ESTIMATE EVALUATION FOR ALTERNATIVE HTABLE 6-3a COST ESTIMATE EVALUATION FOR ALTERNATIVE IHATABLE 6-3b COST ESTIMATE EVALUATION FOR ALTERNATIVE nffiTABLE 6-4 COST ESTIMATE EVALUATION FOR ALTERNATIVE IVTABLE 6-5 COST ESTIMATE EVALUATION FOR ALTERNATIVE VTABLE 6-6 COST ESTIMATE EVALUATION FOR ALTERNATIVE VITABLE 6-7 COST ESTIMATE EVALUATION FOR ALTERNATIVE VH

LIST OF FIGURES

FIGURE 2-1 SITE LOCATION MAPFIGURE 2-2a FEU SITE MAP (FEUs 2 AND 3)FIGURE 2-2b FEU SITE MAP (FEUs 4, 6, AND 8)FIGURE 2-3a FEU-2A TOTAL PCB CONCENTRATIONSFIGURE 2-3b FEU-2B TOTAL PCB CONCENTRATIONSFIGURE 2-4a FEU-2A HEXACHLOROBENZENE CONCENTRATIONSFIGURE 2-4b FEU-2B HEXACHLOROBENZENE CONCENTRATIONSFIGURE 2-5 FEU-3 TOTAL PCB CONCENTRATIONSFIGURE 2-6 FEU-3 HEXACHLOROBENZENE CONCENTRATIONSFIGURE 2-7 FEU-4 TOTAL PCB CONCENTRATIONSFIGURE 2-8 FEU-4 HEXACHLOROBENZENE CONCENTRATIONSFIGURE 2-9 FEU-6 TOTAL PCB CONCENTRATIONSFIGURE 2-10 FEU-6 HEXACHLOROBENZENE CONCENTRATIONSFIGURE 2- 1 1 FEU-8 TOTAL PCB CONCENTRATIONSFIGURE 2-12 FEU-8 HEXACHLOROBENZENE CONCENTRATIONS

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LIST OF FIGURES (CONTINUED)

FIGURE 4-la FEU-2A REMEDIAL RESPONSE AREAS: 10* RISKFIGURE 4-Ib FEU-2B REMEDIAL RESPONSE AREAS: 10* RISKFIGURE 4-2 FEU-3 REMEDIAL RESPONSE AREAS: 10* RISKHGURE 4-3 FEU-4 REMEDIAL RESPONSE AREAS: 10* RISKFIGURE 4-4 FEU-4 REMEDIAL RESPONSE AREAS: lO'5 RISKFIGURE 4-5 FEU-6 REMEDIAL RESPONSE AREAS: 10* RISKFIGURE 4-6 FEU-6 REMEDIAL RESPONSE AREAS: 10'5 RISKFIGURE 4-7 FEU-8 REMEDIAL RESPONSE AREAS: 10* RISKFIGURE 4-8 FEU-8 REMEDIAL RESPONSE AREAS: 10'5 RISKFIGURE 4-9 COVER ALTERNATIVE IFIGURE 5-la FEU-2A REMEDIAL RESPONSE AREAS, ALTERNATIVE IIIAFIGURE 5-lb FEU-2A REMEDIAL RESPONSE AREAS, ALTERNATIVE IIIBFIGURE 5-2a FEU-2B REMEDIAL RESPONSE AREAS, ALTERNATIVE mAFIGURE 5-2b FEU-2B REMEDIAL RESPONSE AREAS, ALTERNATIVE fflBFIGURE 5-3 FEU-3 REMEDIAL RESPONSE AREAS, ALTERNATIVES EIA & HTBFIGURE 5-4a FEU-4 REMEDIAL RESPONSE AREAS, ALTERNATIVE IIIAFIGURE 5-4b FEU-4 REMEDIAL RESPONSE AREAS, ALTERNATIVE HIEFIGURE 5-5a FEU-6 REMEDIAL RESPONSE AREAS, ALTERNATIVE fflAFIGURE 5-5b FEU-6 REMEDIAL RESPONSE AREAS, ALTERNATIVE IBSFIGURE 5-6a FEU-8 REMEDIAL RESPONSE AREAS, ALTERNATIVE ffiAFIGURE 5-6b FEU-8 REMEDIAL RESPONSE AREAS, ALTERNATIVE mBFIGURE 5-7 FEU-2A REMEDIAL RESPONSE AREA, ALTERNATIVE VHFIGURE 5-8 FEU-2B REMEDIAL RESPONSE AREA, ALTERNATIVE VDFIGURE 5-9 FEU-3 REMEDIAL RESPONSE AREA, ALTERNATIVE VHFIGURE 5-10 FEU-4 REMEDIAL RESPONSE AREA, ALTERNATIVE VHFIGURE 5-11 FEU-6 REMEDIAL RESPONSE AREA, ALTERNATIVE VHFIGURE 5-12 FEU-8 REMEDIAL RESPONSE AREA, ALTERNATIVE VH

LIST OF APPENDICES

APPENDIX A RESIDUAL ECOLOGICAL RISKSAPPENDIX B COVER ALTERNATIVE EVALUATION MEMORANDUM

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LIST OF ACRONYMS AND ABBREVIATIONSARAR Applicable or relevant and appropriate requirementsCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCOC Chemical of ConcernCRG Confidence Removal GoalCSF Cancer Slope Factorcu yds Cubic yardsECAO Environmental Criteria and Assessment OfficeEU Exposure UnitFBAG Fields Brook Action GroupFCUG Floodplain/Wetlands Area Cleanup GoalFEU Floodplain/Wetlands Area Exposure UnitFS Feasibility studyFWA Floodplain/Wetlands AreaHEAST Health Effects Assessment Summary TablesHQ Hazard quotientIRIS Integrated Risk Information Systemmg/kg Milligrams per kilogramNCP National Oil & Hazardous Substance Pollution Prevention Contingency PlanNPDES National Pollutant Discharge Elimination SystemNPL National Priorities ListOhio EPA Ohio Environmental Protection AgencyO & M Operation and maintenancePCB Polychlorinated biphenylsPOTW Publicly owned treatment worksPAH Polynuclear aromatic hydrocarbonRCRA Resource Conservation and Recovery ActRfD Reference doseRI Remedial investigationROD Record of DecisionSOU Sediment Operable UnitSQDI Sediment Quantification Design Investigationsq ft Square feetTBC To be consideredTSCA Toxic Substance Control ActUCL Upper confidence limitUSEPA United States Environmental Protection AgencyUSGS United States Geological SurveyWCC Woodward-Clyde Consultants

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1.0INTRODUCTION

1.1 PURPOSE OF REPORT

This Feasibility Study (FS) document has been prepared by Woodward-Clyde Consultants(WCC) of behalf of the Fields Brook Action Group (FBAG) to provide detailed analyses ofalternatives that are considered as permanent remedies for the floodplain/wetlands area(FWA) at the Fields Brook site. The criteria set forth in the National Oil and HazardousSubstance Pollution Prevention Contingency Plan (NCP) have been used in the preparation ofthis document. The methodology used to prepare this document is in accordance withUSEPA's Guidance for Conducting Remedial Investigations and Feasibility Studies underCERCLA (USEPA 1988a).

The remedial alternatives that are presented in this FS are intended to minimize potentialcontact with soil having concentrations that exceed risk-based cleanup standards. Theprimary objectives of this document are to:

• Identify the selected remedial technologies for locations along the FWA whereremedial action alternatives are considered.

• Summarize the remedial alternatives that were retained following initial developmentand screening.

• Present descriptions of the retained alternatives by location along the FWA andprovide a detailed analysis of each alternative.

• Present a comparative analysis of the retained alternatives.

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1.2 ORGANIZATION OF REPORT

This document is divided into nine sections. Information presented in each section issummarized as follows:

• Section 1.0 provides an introduction, which includes a description of the purpose andorganization of the report.

• Section 2.0 contains general information on the background of the site and siteconditions and summarizes chemical data from floodplain soil sampling.

• Section 3.0 presents a summary of the Integrated Baseline Risk Assessment whichincluded both human health and ecological risks.

• Section 4.0 presents the remedial action objectives, potential applicable or relevant andappropriate requirements (ARARs), risk management criteria, estimated remedialresponse areas and volumes and identification of retained technologies and processoptions.

• Section 5.0 presents the retained alternatives and describes the criteria used for thedetailed analysis of alternatives.

• Sections 6.0 and 7.0 include the detailed and comparative analysis of remedialalternatives.

• Section 8.0 presents a summary of the comparative analysis.

• Section 9.0 lists the references cited in this report.

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2.0SITE BACKGROUND INFORMATION

Fields Brook is located in the city, township, and county of Ashtabula, in northeastern Ohio.A portion of the United States Geological Survey (USGS) topographic map showing thegeneral location of the Fields Brook watershed is presented in Figure 2-1.

Fields Brook drains a 6-square-mile area. The eastern portion of the watershed drains AshtabulaTownship, and the western portion drains 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 Railroadtracks. From this point, Fields Brook flows northwest to Middle Road, then west to its confluencewith the Ashtabula River. From Cook Road downstream to State Highway 11, Fields Brook flowsthrough an industrialized area. Downstream of State Highway 11 to near its confluence with theAshtabula River, Fields Brook flows through a residential area within the city of Ashtabula. FieldsBrook empties into the Ashtabula River, approximately 8,000 feet (ft) upstream from Lake Erie.

Fields Brook was determined by the USEPA and the Ohio Environmental Protection Agency(Ohio EPA) to contain contaminated sediments resulting from industrial discharges to FieldsBrook (USEPA 1986). The Fields Brook site was included on the National Priorities List(NPL) of uncontrolled hazardous waste sites under the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) on September 8, 1983.

A remedial investigation (RI) was performed by USEPA on Fields Brook sediments and surfacewater (USEPA 1985). Detected compounds included chlorinated benzene compounds,polynuclear aromatic hydrocarbons (PAHs), hexachlorobutadiene and PCBs (USEPA 1985).

Additional investigations were performed in accordance with the Fields Brook Record of Decision(ROD) (USEPA 1986) and the Unilateral Administrative Order (UAO) (USEPA 1989).Chlorinated solvents, chlorinated benzene compounds, PAHs, hexachlorobutadiene, PCBs andmetals were identified in sediments and floodplain soils in the Sediment Quantification DesignInvestigation (SQDI) of the Fields Brook Sediment Operable Unit (SOU). The primary chemicals

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of concern in the FWA are PCBs and hexachlorobenzene. FWA soils data are discussed in Section2.2 of this FS.

2.1 DESCRIPTION OF FLOODPLAIN EXPOSURE UNITS (FEUS)

The Fields Brook FWA was divided into five (5) floodplain exposure units (FEUs) based onhuman exposure risks. The FEUs are numbered FEU-2, FEU-3, FEU-4, FEU-6 and FEU-8corresponding to the sediment exposure units (EUs) EU-2, -3, -4, -6 and -8. FEUs were notassigned to sediment EU-1, -5 and -7 because no floodplain was present at these locations. Inaddition, FEUs were not assigned to EU-9 and -10 because there were no CUG exceedancesat these locations in Phase I and Phase II SQDI floodplain data. The locations of the FEUsare shown in Figures 2-2a and 2-2b and are described below:

Residential Exposure Units (Figure 2-2a)

• FEU-2 encompasses Reaches 2-1 and 2-2 and is adjacent to a residential area. Thefloodplain width ranges from 25 to 100 ft. A steep bluff separates the floodplain fromthe residences. Access is limited by heavy brush and tree growth along the bluff.Highway bridges form the eastern and western boundaries of FEU-2. Severalresidential properties are situated adjacent to the Fields Brook FWA.

• FEU-3 is near a residential area and encompasses Reach 3. The physicalcharacteristics of FEU-3 are similar to FEU-2 including dense brush and highwaybridges at the boundaries. However, there are no developed residential properties thatextend beyond the bluff to the floodplain.

Occupational Exposure Units (Figure 2-2b^

• FEU-4 is in a transitional area and consists of Reach 4 and the portion of thefloodplain on the west side of Reach 11-1 near its confluence with Fields Brook. Thewidth of the floodplain ranges from 150 to 400 ft. The bluff near the floodplainboundary is not as steep as in the downstream FEUs. The stream channel has severalcurves and meanders. Access is limited by heavy brush, tree growth and fences along

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the bluff to the floodplain. There are no residences within 1,500 ft. of the bluff.Adjacent industrial facilities restrict access and own most of the floodplain.

• FEU-6 is in a transitional area and encompasses Reaches 5-1 and 5-2 including theportion of the floodplain on the east side of Reach 11-1 near its confluence with FieldsBrook. The floodplain width varies from 200 to 300 ft. Similar to FEU-4, the bluffnear the floodplain boundary is not as steep as in downstream FEUs. The streamchannel is braided with several islands on the eastern side of FEU-6. Assess is limitedby heavy brush, tree growth and fences along industrial properties. There are noresidences near this FEU. Adjacent industrial facilities restrict access to the floodplain.

• FEU-8 is in an occupational area and consists of Reaches 6 and 7-1. The floodplainwidth ranges from 50 to 225 ft. A moderate escarpment separates the floodplain fromindustrial properties to the north and south. Access is limited by heavy brush andfencing.

2.2 EXISTING CHEMICAL DATA

FWA soils were chemically characterized in three sampling phases of the SQDI. The nature andextent of the chemicals identified from the SQDI sampling events are discussed as part of theIntegrated Baseline Risk Assessment for the Fields Brook Floodplain/Wetlands Area(Gradient, et al. 1995). Evaluation of the results indicated that PCBs and hexachlorobenzene werethe two compounds causing the majority of the baseline risk. Average and maximum identifiedPCB concentrations are:

• Average of 24.1 mg/kg, maximum of 360 mg/kg in FEU-2• Average of 38.6 mg/kg, maximum of 530 mg/kg in FEU-3• Average of 68.1 mg/kg, maximum of 560 mg/kg in FEU-4• Average of 87.1 mg/kg, maximum of 610 mg/kg in FEU-6• Average of 38.0 mg/kg, maximum of 270 mg/kg in FEU-8

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Average and maximum identified hexachlorobenzene concentrations are:

• Average of 17.9 mg/kg, maximum of 97 mg/kg in FEU-2• Average of 10.9 mg/kg, maximum of 99 mg/kg in FEU-3• Average of 36.0 mg/kg, maximum of 300 mg/kg in FEU-4• Average of 45.6 mg/kg, maximum of 540 mg/kg in FEU-6• Average of 14.9 mg/kg, maximum of 480 mg/kg in FEU-8

Isoconcentration maps that show the distribution of PCBs and hexachlorobenzene within each ofthe five FEUs are presented in Figures 2-3a through 2-12b,

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3.0INTEGRATED BASELINE RISK ASSESSMENT

3.1 INTRODUCTION

The Integrated Baseline Risk Assessment for the FWA has two components: 1) a humanhealth risk assessment; and 2) an ecological risk assessment. The risk assessment approachand results are summarized in the following sections.

3.2 SUMMARY OF INTEGRATED BASELINE RISK ASSESSMENT

3.2.1 Human Health Risk Assessment

The human health risk assessment estimates risk by characterizing the type and magnitude ofhuman exposure to chemicals of concern (COCs) identified for human health in the FWAsoils. The 11 COCs considered for the Sediment Operable Unit (SOU) were also consideredin the human health risk assessment for the FWA. This assessment evaluates risk levels in thecontext of each COCs' toxicity, e.g., the cancer slope factor (CSF) in the case of carcinogens,or the reference dose (RfD) in the case of non-carcinogens. For carcinogens, the lifetime riskof cancer is equal to the average lifetime daily exposure multiplied by the CSF. In the case ofnon-carcinogens, exposure is thought to be without appreciable risk of an adverse effect if theaverage lifetime exposure is less than the RfD.

The exposure assessment quantifies exposure for the five FEUs: FEU-2 and FEU-3 arecharacterized by potential residential activities, whereas FEU-4, FEU-6 and FEU-8 arecharacterized by potential occupational activities.

Residential exposure is divided into three discrete time periods for which separate estimates ofchemical intake were calculated: childhood (ages 1 to 6); adolescence (ages 7 to 15); andadulthood (ages 16 to 30). Subsequently, these three estimates were summed to provide anestimate of total chemical intake by a 30-year resident. Occupational exposure wasconsidered for an adult only. For both scenarios, exposures to FWA soils were evaluated forincidental ingestion and dermal contact.

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The toxicity assessment used point estimates for all CSFs and RfDs. These values wereobtained from USEPA's Integrated Risk Information System (IRIS), Health EffectsAssessment Summary Tables (HEAST), Environmental Criteria and Assessment Office(ECAO), and from USEPA Region V. In addition to toxicity values, the toxicity assessmentalso discusses the point estimates used to describe chemical-specific absorption characteristicsused in the FWA risk assessment.

3.2.2 Human Health Risk Assessment Results

The human health risk assessment results in an estimate of risk for each COC in each FEU.Cancer risks in each FEU are driven by PCBs and hexachlorobenzene. Non-cancer risks aresecondary to cancer risks using the deterministic method of calculating risks. The followingCOCs have risks less than 10"6 for all FEUs: hexachoroethane, 1,1,2,2,-tetrachloroethane,trichloroethene, and vinyl chloride. Tetrachloroethene exceeds a 10~6 risk level only in FEU6.It contributes less than 1 % of the total cancer risk in this FEU. Hexachlorobutadiene andbenzo(a)pyrene exceed a 10~6 risk level in both FEUs 4 and 6. Similarly, these eachcontribute less than 1% of the total cancer risk in these FEUs. Additional COCs that wereevaluated for human health risks include arsenic and beryllium. Although those COCs wereestimated to have risks exceeding 10"6 in FEUs 2, 3,4, and 6 , they are minor contributors tototal risk in these FEUs. These results are described in more detail in the Baseline HumanHealth Risk Assessment for the Fields Brook Floodplain/Wetlands AreafUSEPA 1996). Therisk estimate was calculated using deterministic (point estimate) input values provided byUSEPA.

3.2.3 Ecological Risk Assessment Approach

In keeping with current guidance (USEPA 1989b, 1994), a weight of evidence approach wasemployed for evaluating ecological risks. Tissue body burdens in ecological receptors and theirfood resources were measured directly, exposure was estimated based on direct calculations andfood web modeling, toxicity thresholds were identified in the current ecotoxicology literature,


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habitats throughout the floodplain wetland were characterized, qualitative observations were madeof wildlife present in the ecosystem, and bioaccumulation and bioassay tests were undertaken.

Exposure was qualified for a suite of ecological receptors representing various trophic groups,feeding guilds, and behavioral categories. Exposure hazard quotients were quantified based on themean and 95% UCL on the mean, and area use factors based both on published foraging rangesand assumed full-time residence in ecological exposure study units of the Fields Brook FWA.These hazards quotients provide the foundation for evaluating risk reduction benefits of variousrisk management alternatives in the subsequent sections of this FS.

3.2.4 Ecological Risk Assessment Results

The baseline ecological risk assessment indicated that certain environmental receptors arepotentially at risk due to exposure to some chemicals present in the FWA system When exposuresare calculated based on mean soil concentrations, lead, cadmium, chromium and mercury are theprimary compounds associated with elevated ecological risks. When exposures are calculatedbased on 95% UCLs of soil concentrations, hexachlorobenzene, hexachlorobutadiene, and PCBsare also associated with elevated risks.

In keeping with current guidance, baseline risks were calculated based on highly conservativetoxicology and exposure assumptions. For risk management decision making, baseline risks andrisk reduction benefits of site remediation are balanced against destruction of or impact to theecosystem in place. This balance is reflected in the alternatives evaluation detailed in subsequentsections of this FS. Residual (post-remediation) risks are presented in tables with supporting textin Appendix A.

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4.0IDENTIFICATION AND SCREENING OF TECHNOLOGIES

4.1 REMEDIAL ACTION OBJECTIVES

CERCLA Section 121(d) states that any remedial action selected for a Superfund site shall attain adegree of cleanup of hazardous substances, pollutants, and contaminants released into theenvironment and of control of further releases, at a minimum, which assures protection of humanhealth and the environment. In conjunction with these requirements, remedial action objectiveshave been developed to permit a range of treatment and containment alternatives to be developed.

The remedial action objectives for the Fields Brook FWA are as follows:

• Minimize potential for human contact with soils having average chemical concentrationsthat exceed risk-based cleanup standards.

• Minimize potential for contact with soils that cause adverse effects on ecological receptors.

4.2 POTENTIAL ARARs

Section 121(d) of CERCLA requires that Superfund remedial actions attain any federalenvironmental or state environmental and facility siting standards, requirement, or criteria that aredetermined to be ARARs. The requirements of federal environmental and state environmental andfacility siting laws and regulations are identified and applied to remedial actions as ARARs usingthe approach outlined in the USEPA's CERCLA Compliance with Other Laws Manual (InterimFinal) Part I (USEPA 1988b) and Part II: Clean Air Act and Other Environmental Statutes andState Requirements (USEPA 1989).

In addition to ARARs, this FS will consider guidelines, criteria, and standards that may be useful inevaluating remedial alternatives. These guidelines, criteria, and standards are known as TBCs. Incontrast to ARARs, which are promulgated cleanup standards, standards of control, and other


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substantive environmental protection requirements, criteria or limitations; material to be considered(TBCs) are guidelines and other criteria that have not been promulgated.

4.2.1 Location-Specific ARARs

Location-specific ARARs establish restrictions on the management of waste or hazardoussubstances in specific protected locations, such as wetlands, floodplains, historic places, andsensitive habitats. Table 4-1 provides a listing of potential location-specific ARARs for the FWAat the Fields Brook site.

4.2.2 Action-Specific ARARs

Action-specific ARARs are technology-based or activity-based requirements or limitations onactions taken with respect to remediation. These requirements are triggered by particular remedialactivities that are selected to accomplish the remedial objectives. The action-specific ARARs donot determine the remedial alternative, rather they indicate the way in which the selected alternativemust be implemented as well as specify levels for discharge. Table 4-2 provides a listing ofpotential action-specific ARARs. The action-specific ARARs listed in Table 4-2 include theAmbient Water Quality Criteria and the Ohio Water Quality Standards, which contain specificstandards that would be applicable if remediation water or treatment plant wastewater is dischargeddirectly to Fields Brook or the Ashtabula River. Available standards for specific chemicals areprovided in Table 4-3. Action-specific TBC guidances are listed in Table 4-4.

In addition to the water quality criteria, substantive requirements of National Pollutant DischargeElimination System (NPDES), as implemented under Ohio regulations, would also be applicable todischarges from the FWA to Fields Brook. Discharges to Publicly Owned Treatment Works(POTWs) must also comply with limitations to ensure acceptable discharge from the POTW aftertreatment. Table 4-5 lists available limitations for discharge from a point source to: 1) surfacewater under the NPDES and 2) the City of Ashtabula POTW.

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4.2.3 Chemical-Specific ARARs

There are no chemical-specific ARARs for the FWA. Environmental requirements with numericallimits for specific chemicals, such as Ambient Water Quality Criteria and National Ambient AirQuality Standards, are considered action-specific ARARs here since their application depends onthe remedial technologies included in the alternatives. Refer to Section 4.2.2 for more details onaction-specific ARARs.

4.3 RISK MANAGEMENT CRITERIA

4.3.1 Human Health Risk Management

The results of the risk assessment were used to calculate the potential human health FWAcleanup goals (FCUGs). Based on these FCUG values, confidence removal goals (CRGs)were calculated for each FEU following the same procedure used for the Fields Brook SOU.Specific FCUG and CRG values have been chosen for use in this FS for remedial AlternativesII, IV, V, and VI. and are summarized in Table 4-6. Additional CRGs were selected fromwithin the protective range developed in the baseline risk assessment for use in AlternativesIII A , IIIB, and VII as described in Section 5.0.

4.3.2 Ecological Risk Management

Ecological exposure in the FWA is due primarily to contact with soils and sediments. Formost receptor chemical pairs, risks are due to food web transfer and in some cases by assumeddirect consumption of sediments along with preferred items of diet. Remedial alternatives thatreduce or eliminate contact and/or consumption of chemicals in soils and sediments byecological receptors will truncate the exposure route and reduce or eliminate ecological risks.This conclusion is supported by the exposure analysis, including documented body burdenmeasurements. There are apparent mechanisms that reduce the bioavailability and/orbioaccessibility of chemicals. Remedial alternatives that reduce these parameters (includingsoil covers) will reduce biotic exposure and consequent biotic risk.

Levels of environmental protection offered by each of the proposed remedial alternatives andthe parameters controlling the effectiveness are identified in Section 6.0. Appendix A

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provides a quantitative evaluation of residual ecological risks under certain remediationscenarios, as presented and discussed in Section 5.0.

4.4 POTENTIAL REMEDIAL RESPONSE AREAS

Potential remedial response areas were estimated based on the selected CRG values for eachof the proposed remedial alternatives. Review of existing FWA soil data indicate that elevatedconcentrations of chemicals are limited to the top one foot of FWA soils. Out of 23 samplescollected at a depth of below one foot, only two samples had results above the PCB CUG,both samples were below the CRG. Additionally, a review of the soil data indicate that eitherexcavation or cover for PCBs and HCB will address other COCs. Specific components of theremedial alternatives are included in Section 5.0. Details regarding development of thepotential remedial response areas for these alternatives are provided in the followingsubsections.

4.4.1 Alternatives II, IV, V, and VI

Potential remedial response areas for Remedial Alternatives II, IV, V, and VI were estimatedbased on the CRGs calculated using the deterministic risk assessment method with USEPAinput values. The area estimates for residential FEU-2 and FEU-3 were calculated using theCRGs developed for the 10"6 risk targets. Estimates for the occupational FEUs (FEU-4,FEU-6, and FEU-8) considered both the 10"5 and 10'6 risk targets. No response areas wererequired for chemicals other than PCBs and hexachlorobenzene. The estimated areas areshown in Figures 4-la through 4-8 and are summarized as follows:

FEU-2

• 10'6 Risk Target [Figure 4-1 (a, b)]0 PCB CRG = 5.9 mg/kg, Est. Area = 216,000 sq. ft.0 Hexachlorobenzene CRG = 5.6 mg/kg, Est. Area = 138,000 sq. ft.0 Net Area = 216,000 sq. ft.

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FEU-3

• 10"6 Risk Target [Figure 4-2]0 PCB CRG = 8.1 mg/kg, Est. Area = 115,000 sq. ft.0 Hexachiorobenzene CRG = 5.9 mg/kg, Est. Area = 18,000 sq. ft.0 Net Area = 115,000 sq. ft.

FEU-4

• 10"6 Risk Target [Figure 4-3]0 PCB CRG = 17.1 mg/kg, Est. Area = 121,000 sq. ft.0 Hexachiorobenzene CRG = 50.1 mg/kg, Est. Area = 62,000 sq. ft.0 Net Area = 134,000 sq. ft.

• 10"5 Risk Target [Figure 4-4]0 PCB CRG = 257 mg/kg, Est. Area = 10,000 sq. ft.0 Hexachiorobenzene CRG = 1874 mg/kg, Est. Area = 00 Net Area = 10,000 sq. ft.

FEU-6

• 10'6 Risk Target [Figure 4-5]0 PCB CRG = 15.5 mg/kg, Est. Area = 150,000 sq. ft.0 Hexachiorobenzene CRG = 43.5 mg/kg, Est. Area = 14,000 sq. ft.0 Net Area = 150,000 sq. ft.

• 10"5 Risk Target [Figure 4-6]0 PCB CRG = 204 mg/kg, Est. Area = 32,000 sq. ft.0 Hexachiorobenzene CRG = 1336 mg/kg, Est. Area = 00 Net Area = 32,000 sq. ft.


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FEU-8

• 10'6 Risk Target [Figure 4-7]0 PCB CRG = 14.1 mg/kg, Est. Area = 132,000 sq. ft.0 Hexachlorobenzene CRG = 58.5 mg/kg, Est. Area = 26,000 sq. ft.0 Net Area = 158,000 sq. ft.

• 10'5 Risk Target [Figure 4-8]0 PCB CRG = 225 mg/kg, Est. Area = 6,000 sq. ft.0 Hexachlorobenzene CRG = 4900 mg/kg, Est. Area = 00 Net Area = 6,000 sq. ft.

4.4.2 Alternatives IIIA, IIIB, and VII

Potential remedial response areas were also developed for Alternatives IIIA IIIB, and VIIbased on the response levels agreed to during the 1995 and 1996 meetings with USEPA andFBAG representatives. The response areas associated with these alternatives are less than orequal to the 10"6 risk target for FEUs 2 and 3. Response areas for FEUs 4, 6, and 8 weredeveloped based on target levels of 50 mg/kg for PCBs and 200 mg/kg hexachlorobenzene.The target levels for FEUs 4, 6, and 8 correlate with an approximate industrial risk target of 3x 10"6. Specific response areas for Alternatives IIIA, IIIB, and VII are discussed further inSection 5.0.

4.5 DESIGN DELINEATION SAMPLING

The isoconcentration lines that have been drawn based on currently available data have beenused to develop the potential remedial response areas presented in this FS. Figures 2-3athrough 2-12 illustrate the isoconcentration mapping for PCBs and hexachlorobenzene. Inorder to establish cutlines that can be used during integration of the FWA remediation withthe SOU activities, a design delineation program is planned to be implemented. Thedelineation sampling will involve collection of additional soil samples in both residential andindustrial FEUs to further delineate current response area boundaries and sample in areaswhere data points are widely spread. A sampling grid in these areas consisting of


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approximately 50 foot grid lines will be used to establish sampling locations. Samples will beselected to refine existing response areas and fill in data needs. Soil samples will be analyzedfor PCBs in all five FEUs and hexachlorobenzene in selected response areas in FEUs 4 and 8.

4.6 IDENTIFICATION OF RETAINED TECHNOLOGIES AND PROCESSOPTIONS

Remedial technologies and process options that were retained for the Fields Brook FWA aresummarized in the following subsections. The remedial alternatives discussed in Section 5.0were developed based on the retained remedial technologies and process options presentedherein.

4.6.1 No Action

In accordance with the NCP, a no action alternative is required for consideration and serves asa baseline against which other alternatives can be compared. No institutional controls,containment, excavation, or treatment would be included as part of no action.

4.6.2 Institutional Controls

The use of institutional controls would involve restriction of present and future land use in theindustrial and residential areas, such that human exposure to contaminated soils does notincrease above that which is predicted for a remedy. Institutional controls would include deedrestrictions or permanent covenants to prevent residential use or development in FEUs 4, 6,and 8. Deed restrictions or permanent covenants to prevent or restrict construction ordevelopment of all five FEUs (2, 3, 4, 6, and 8) would also be included as institutionalcontrols.

4.6.3 Revegetated Soil Cover

Four cover alternatives that were considered for the FWA are presented in the CoverAlternative Evaluation Memorandum, Fields Brook site, Floodplain/Wetlands Areapresented in Appendix B. Each alternative was developed to provide a competent barrier for


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the protection of human health and the environment. Detailed analysis of the four coveralternatives was performed in accordance with RI/FS Guidance (USEPA 1988a). Detailedanalysis of the four cover alternatives indicates that Cover Alternative I, as shown inFigure 4-9, provides the most cost-effective cover for meeting the remedial action objectives.In general, Cover Alternative I consists of two elements (from bottom top):

• a minimum 6-inch thick soil layer

• a vegetation layer

The selected soil type would be supportive of plant growth. To help ensure protectivenessand regrowth of hydrophytic vegetation, the selected soil type is anticipated to be compatiblewith hydric conditions. This soil type is understood to be the same as what is understood byprofessional ecologists to produce hydric soils. Revegetation would be done by hydroseeding,selective planting, or other appropriate techniques. A soil erosion mat would be installed ontop of the cover for erosion control during re-establishment of vegetation. Cover thicknessmay be increased to a maximum 12-inch thickness (Cover Alternative II), if deemed necessaryto help ensure protectiveness of human health and the environment. The hydric-compatiblesoils to be used as cover material will be capable of supporting a native vegetation wetlandecosystem which will develop in place.

4.6.4 Excavation and Revegetated Backfill

Excavation of soils in the FWA would be done to a depth of 12-inches. The excavated areaswould be backfilled with soil supportive of plant growth. To help ensure protectiveness andregrowth of hydrophytic vegetation, the selected type is anticipated to be compatible withhydric conditions. This soil is understood to be the same as what is understood byprofessional ecologists to produce hydric soils. Revegetation would be done by hydroseeding,selective planting, or other appropriate techniques. A soil erosion mat would be installed ontop of the backfill for erosion control during re-establishment of vegetation. Thehydric-compatible soils will be capable of supporting a native vegetation wetland ecosystemwhich will develop in place.


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4.6.5 Thermal Treatment

Use of this technology would involve transporting the excavated soil to a thermal treatment facility.This technology would only be considered for soils with PCB concentrations greater than500 mg/kg.

4.6.6 Off-Site Disposal

Use of off-site disposal refers to transporting excavated soil to an off-site landfill for disposal.The selected landfill would be appropriately permitted to receive the excavated soils.

4.6.7 On-Site Disposal

Use of on-site disposal refers to transporting excavated soil to selected on-site consolidationarea for land disposal. The selected disposal area would be designed to meet the substantiverequirements for an appropriately permitted landfill.

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5.0DEVELOPMENT AND SCREENING OF ALTERNATIVES

The remedial technologies and process options have been developed into eight (8) remedialalternatives for the FWA. Descriptions of the eight remedial alternatives are presented herein.

5.1 SUMMARY OF REMEDIAL ALTERNATIVES

Estimated remedial response areas and volumes to be included in each alternative aresummarized in Table 5-1. A description of each remedial alternative and the technologies tobe employed under each alternative, are presented in separate subsections below.

5.1.1 Alternative I - No Action

Alternative I consists of no additional remedial actions to be implemented in the Fields BrookFWA. No institutional controls, containment, excavation treatment technologies or processoptions would be used under this alternative.

5.1.2 Alternative II - Containment #1

Alternative II consists of containing the existing COCs on-site by placing a hydric compatiblesoil cover and erosion protection mat over areas within each FEU which have exceeded 10"5

and 10"6 risk based target concentrations. Areas with potential residual ecological risks, asdiscussed in section 4.3.2, would also have a protective cover installed under this alternative.Vegetation would be re-established with native plant species immediately following coverplacement activities. Revegetation would be accomplished using hydroseeding, selectiveplanting or other appropriate techniques. Mitigation of injured wetlands would be includedand is assumed for purposes of this FS to consist of a 1.5 to 1 replacement of the remedialresponse areas. This replacement ratio may change during the design process.

Institutional controls (including deed restrictions and permanent covenants preventingresidential use or development in FEUs 4, 6, and 8) and an operations and maintenance(O&M) program would also be implemented to maintain the protection provided by thisalternative. Design delineation sampling would also be performed to verify or modify response

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area boundaries. O&M of the remedial response areas would include physical inspection andpost-remediation chemical sampling. Since this alternative involves relatively extensive coverareas, the requirements for post-remediation sampling are estimated to include 80 samples peryear. Of these 80 samples, 40 would be analyzed for PCBs and 40 would be analyzed fortarget compound list/target analyte list (TCL/TAL) parameters. The post-remediation O&Mreport would be reviewed and evaluated each year to assess the need for further monitoringand potential changes in sampling locations, and to evaluate the need for remedy repairs, inaccordance with the Superfund Program's National Contingency Plan regulations. Forpurposes of this FS, non of the cost estimates developed for the FWA alternatives considerssampling beyond the first five years; however, evaluations of the sampling program wouldoccur each year for the purposes noted above.

The estimated cover areas for Alternative II may increase or decrease based on the results ofthe design delineation sampling. Areas that are considered for cover placement underAlternative II are as follows:

• Cover placement over soil exceeding CRGs based on 10"6 FCUGs in FEUs 2 and 3(See Figures 4-la, 4-lb and 4-2)

• Cover placement over soil exceeding CRGs based on 10"5 FCUGs in FEUs 4, 6 and 8(See Figures 4-4, 4-6, and 4-8)

• Cover placement for residual ecological risks

5.1.3 Alternative IIIA - Cover, Excavation, Backfill and Off-Site Disposal

Alternative IIIA consists of the excavation and subsequent backfilling of selected FEU areasand providing hydric-compatible soil cover as containment over additional areas. Excavationdepth would be limited to 12 inches. However, deeper excavations would occur if pureproduct or drums are identified during the excavation efforts. Additionally, 6 inches ofhydric-compatible soil cover would be placed over areas not excavated with potential residualecological risks. Table 5-2 provides an estimate of the surface areas for each area to becovered and backfilled under this alternative. Vegetation would be re-established immediatelyfollowing excavation, backfilling and cover placement activities for Alternative IIIA.

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Revegetation would be accomplished using hydroseeding, selective planting with nativespecies or other appropriate techniques. Mitigation of injured wetlands would also be includedand is assumed for purposes of this FS to consist of a 1.5 to 1 replacement of the remedialresponse areas. This replacement ratio may change during the design process. All excavatedsoil would be transported off-site for landfill disposal.

Institutional controls (including deed restrictions and permanent covenants preventingresidential use or development in industrial FEUs 4, 6, and 8) and an O&M program wouldalso be implemented to maintain the protection provided by this alternative. Design delineationsampling would also be performed to verify or modify response area boundaries. O&M of theremedial response areas would include physical inspection and post-remediation chemicalsampling. Since this alternative involves relatively extensive cover areas, the requirements forpost-remediation sampling are estimated to include 80 samples per year. Of these 80 samples,40 would be analyzed for PCBs and 40 would be analyzed for target compound list/targetanalyte list (TCL/TAL) parameters. The post-remediation O&M report would be reviewedand evaluated each year to assess the need for further monitoring and potential changes insampling locations, and to evaluate the need for remedy repairs, in accordance with theSuperfund Program's National Contingency Plan regulations. For purposes of this FS, non ofthe cost estimates developed for the FWA alternatives considers sampling beyond the first fiveyears; however, evaluations of the sampling program would occur each year for the purposesnoted above.

The estimated excavation and cover areas for Alternative IIIA may increase or decrease basedon the results of the design delineation sampling. Areas where excavation and coverplacement have been selected under this alternative are as follows:

• FEU 2:Excavate the top 12 inches of soil in areas with PCB concentrations greater than 30 mg/kg,except in areas with trees larger than 5-inch diameter breast high (dbh). If a decision ismade not to excavate in order to preserve trees, a 6-inch cover would be placed over thecontaminated area. A 6-inch cover would also be placed over soil with PCBconcentrations between 6 and 30 mg/kg and any remaining areas with hexachlorobenzeneconcentrations greater than 6 mg/kg (See Figures 5-la and 5-2a).

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FEU3Excavate the top 12 inches of soil in areas with PCB concentrations greater than 30 mg/kg.A 6-inch cover would also be placed over soil with PCB concentrations between 8 and 30mg/kg and any remaining areas with hexachlorobenzene concentrations greater than 6mg/kg (See Figure 5-3).

FEU4Excavate the top 12 inches of soil near sample location H4N15S (west section of FEU 4)with PCB concentrations greater than 50 mg/kg. For the remainder of FEU 4, excavatethe top 12 inches of soil with PCB concentrations exceeding 250 mg/kg. A 12-inch coverwould be placed over soil with PCB concentrations between 100 and 250 mg/kg. A 6-inchcover would be placed over soil with 50 to 100 mg/kg of PCBs and any remaining areaswith hexachlorobenzene concentrations exceeding 200 mg/kg (See Figure 5-4a).

FEU6andFEU8Excavate the top 12 inches of soil with PCB concentrations exceeding 250 mg/kg. A 12-inch cover would be placed over soil with PCB concentrations between 100 and 250mg/kg. A 6-inch cover would be placed over soil with 50 to 100 mg/kg of PCBs and anyremaining areas with hexachlorobenzene concentrations exceeding 200 mg/kg (See Figures5-5a and 5-6a).

Place additional backfill (6 inches or 12 inches) over excavation areas as necessary to adjustfor topography of adjacent cover areas. Include revegetation and erosion protection mat inall cover areas.

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5.1.4 Alternative IIIB- Cover, Excavation, Backfill and Off-Site Disposal

Alternative IIIB consists of the excavation and subsequent backfilling of selected FEU areasand providing soil cover as containment over additional areas. Excavation on depth would belimited to 12 inches. However, deeper excavations would occur if pure product or wastematerials are encountered during the excavation efforts. Additionally, 6 inches of hydriccompatible soil cover would be placed over areas not excavated with potential residualecological risks. Table 5-2 provides an estimate of the surface areas for each area to becovered and backfilled under this alternative. Vegetation would be re-established immediatelyfollowing excavation, backfilling and cover placement activities for Alternative IIIB.Revegetation would be accomplished using hydroseeding, selective planting with nativespecies or other appropriate techniques. Mitigation of injured wetlands would also beincluded and is assumed for purposes of this FS to consist of a 1.5 to 1 replacement of theremedial response areas. This replacement ratio may change during the design process. Allexcavated soil would be transported off-site for landfill disposal.

Institutional controls (including deed restrictions and permanent covenants preventingresidential use or development in industrial FEUs 4, 6, and 8), and an operations andmaintenance (O&M) program would be implemented to maintain the protection provided bythis alternative. Design delineation sampling would also be performed to verify or modifyresponse area boundaries. O&M of the remedial response areas would include physicalinspection and post-remediation chemical sampling. Since this alternative involves relativelyextensive cover areas, the requirements for post-remediation sampling are estimated to include80 samples per year. Of these 80 samples, 40 would be analyzed for PCBs and 40 would beanalyzed for target compound list/target analyte list (TCL/TAL) parameters. Thepost-remediation O&M report would be reviewed and evaluated each year to assess the needfor further monitoring and potential changes in sampling locations, and to evaluate the needfor remedy repairs, in accordance with the Superfund Program's National Contingency Planregulations. For purposes of this FS, non of the cost estimates developed for the FWAalternatives considers sampling beyond the first five years; however, evaluations of thesampling program would occur each year for the purposes noted above.

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The estimated excavation and cover areas for Alternative IIIB may increase or decrease basedon the results of the design delineation sampling. Areas where excavation and coverplacement have been selected under this alternative are as follows:

• FEU 2:Excavate the top 12 inches of soil in areas with PCB concentrations greater than 30 mg/kg,except in areas with trees larger than 5-inch dbh. If a decision is made not to excavate inorder to preserve trees, a 6-inch cover would be placed over the contaminated area. A 6-inch cover would also be placed over soil with PCB concentrations between 6 and 30mg/kg except for an area on the west side of Fields Brook, north from sample locationH2S05S to the west end of FEU 2 (including the island with sampling location H2S04S).In this area, soil with more than 6 mg/kg of PCBs would be excavated to a depth of 12inches. Any remaining areas with hexachlorobenzene concentrations greater than 6 mg/kgwould be addressed using a 6-inch cover (See Figures 5-lb and 5-2b).

• FEU3Excavate the top 12 inches of soil in areas with PCB concentrations greater than 30 mg/kg,except in areas with trees larger than 5-inch DBH. If a decision is made not to excavate inorder to preserve trees, a 6-inch cover would be placed over the contaminated area. A 6-inch cover would also be placed over soil with PCB concentrations between 8 and 30mg/kg and any remaining areas with hexachlorobenzene concentrations greater than 6mg/kg (See Figure 5-3).

• FEU4Excavate the top 12 inches of soil near sample location H4N15S (west section of FEU 4)with PCB concentrations greater than 50 mg/kg. For the remainder of FEU-4, excavatethe top 12 inches of soil with PCB concentrations exceeding 400 mg/kg. A 12-inch coverwould be placed over soil with PCB concentrations between 100 and 400 mg/kg. A 6-inchcover would be placed over soil with 50 to 100 mg/kg of PCBs and any remaining areaswith hexachlorobenzene concentrations exceeding 200 mg/kg (See Figure 5-4b).

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• FEU6andFEU8Excavate the top 12 inches of soil with PCB concentrations exceeding 400 mg/kg. A 12-inch cover would be placed over soil with PCB concentrations between 100 and 400mg/kg. A 6-inch cover would be placed over soil with 50 to 100 mg/kg of PCBs and anyremaining areas with hexachlorobenzene concentrations exceeding 200 mg/kg (See Figures5-5band5-6b).

• Place additional backfill (6 inches or 12 inches) over excavation areas as necessary to adjustfor topography of adjacent cover areas. Include revegetation and erosion protection mat inall cover areas.

5.1.5 Alternative IV • Containment #2

Alternative IV consists of containing the existing contaminants on-site by placing a soil coverand erosion protection mat over areas within each FEU which have exceeded 10"6 risk basedtarget concentrations. Areas with potential residual ecological risks, as discussed inSection 4.3.2, would also have a protective cover installed under this alternative. Vegetationwould be re-established with native plant species immediately following cover placementactivities. Revegetation would be accomplished using hydroseeding, selective planting orother appropriate techniques. Mitigation of injured wetlands would be included and isassumed for purposes of this FS to consist of a 1.5 to 1 replacement of the remedial responseareas. This replacement ratio may change during the design process.

Institutional controls (including deed restrictions and permanent covenants preventingresidential use or development in industrial FEUs 4,6, and 8) and an operations andmaintenance (O&M) program would be implemented to maintain the protection provided bythis alternative. Design delineation sampling would also be performed to verify or modifyresponse area boundaries. O&M of the remedial response areas would include physicalinspection and post-remediation chemical sampling. Since this alternative involves relativelyextensive cover areas, the requirements for post-remediation sampling are estimated to include80 samples per year. Of these 80 samples, 40 would be analyzed for PCBs and 40 would beanalyzed for target compound list/target analyte list (TCL/TAL) parameters. The


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post-remediation O&M report would be reviewed and evaluated each year to assess the needfor further monitoring and potential changes in sampling locations, and to evaluate the needfor remedy repairs, in accordance with the Superfund Program's National Contingency Planregulations. For purposes of this FS, non of the cost estimates developed for the FWAalternatives considers sampling beyond the first five years; however, evaluations of thesampling program would occur each year for the purposes noted above.

The estimated cover areas for Alternative IV may increase or decrease based on the results ofthe design delineation sampling. Areas which are considered for cover placement underAlternative IV are as follows:

• Cover placement over soil exceeding CRGs based on 10~6 FCUGs in FEUs 2, 3, 4, 6and 8 (See Figures 4-1, 4-2, 4-3, 4-5, and 4-7)

• Cover placement for residual ecological risks

5.1.6 Alternative V - Excavation, Backfill, and Off-Site Disposal

Alternative V consists of excavating and backfilling areas within each FEU which haveexceeded 10"6 risk based target concentrations. The excavated materials would be transportedoff-site for landfill disposal in this alternative. Areas with potential residual ecological risks,as discussed in section 4.3.2, would also be excavated and backfilled under this alternative.Replacement backfill materials would consist of clean, hydric-compatible and soil materials.Vegetation would be re-established with native plant species immediately followingexcavation and backfilling activities. Revegetation would be accomplished usinghydroseeding, selective planting or other appropriate techniques. Mitigation of injuredwetlands would be included and is assumed for the purposes of this FS to consist of a 1.5 to 1replacement of the remedial response areas. This replacement ratio may change during thedesign process.

Institutional controls (including deed restrictions and permanent covenants preventingresidential use or development in industrial FEUs 4, 6, and 8) and an operations andmaintenance (O&M) program would be implemented to maintain the protection provided bythis alternative. Design delineation sampling would also be performed to verify or modify


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response area boundaries. O&M of the remedial response areas would include physicalinspection and post-remediation chemical sampling of cover and excavation backfill areas.Since this alternative involves excavation, the sampling program would be similar to thatdescribed in Section 5.1.8.3 for Alternative VII. The post-remediation O&M report would bereviewed and evaluated each year to assess the need for further monitoring and potentialchanges in sampling locations, and to evaluate the need for remedy repairs, in accordance withthe Superfund Program's National Contingency Plan regulations. For purposes of this FS,non of the cost estimates developed for the FWA alternatives considers sampling beyond thefirst five years; however, evaluations of the sampling program would occur each year for thepurposes noted above.

The estimated excavation areas for Alternative V may increase or decrease based on theresults of the design delineation sampling. Areas which are considered for cover placementunder Alternative V are as follows:

• Excavation of top 12 inches of soil exceeding CRGs based on 10"6 FCUGs in FEUs 2,3,4, 6 and 8, backfill to original grade, and revegetate (See Figures 4-la, 4-lb, 4-2, 4-3, 4-5, and 4-7).

• Excavation of top 12 inches of soil for residual ecological risks, backfill to originalgrade, and revegetate.

• Off-site landfilling of excavated materials.

5.1.7 Alternative VI - Excavation, Backfill, Treatment and Off-Site Disposal

Alternative VI is identical to Alternative V except that, in lieu of off-site landfilling, excavatedmaterials exceeding 500 mg/kg of PCBs would be transported off-site for thermal treatment.

5.1.8 Alternative VII - Cover, Excavation, Backfill, and On-Site Disposal inConsolidation Area

Alternative VII consists of the excavation and backfilling of selected areas in FEUs 2, 3, 4, 6,and 8, and placement of a soil cover over additional areas in FEUs 2 and 3. Excavation ondepth would be limited to 12 inches. However, deeper excavation would occur if pure


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produce or waste materials are encountered during excavation efforts. Additionally, 6 inchesof hydric compatible soil cover would be placed over areas not excavated and with potentialresidual ecological risks, as discussed in Section 4.3.2. Table 5-3 provides an estimate of thesurface areas for each area to be covered and backfilled under this alternative. Vegetationwould be re-established with native plant species immediately following excavation, cover andbackfill activities. Revegetation with native species would be accomplished using hydro-seeding, selective planting with native species or other appropriate techniques. Mitigation ofinjured wetlands would be included and is assumed for purposes of this FS to consist of a 1.5to 1 replacement of the remedial response areas. This ratio may change during the design ^process. All excavated material would be transported to an on-site consolidation area fordisposal.

Institutional controls (including deed restrictions and permanent convents preventingresidential use or development in industrial FEUs 4, 6, and 8) and an operations andmaintenance (O&M) program would be implemented to maintain protection provided by thisalternative. Design delineation sampling would be performed to verify or modify responsearea boundaries. O&M of the remedial response areas would include physical inspection andpost-remediation chemical sampling of cover and backfill areas. Post-remediation samplingand chemical analysis would be implemented to maintain protection provided by thisalternative. The post-remediation O&M report would be reviewed and evaluated each year to ^ Jassess the need for further monitoring and potential changes in sampling locations, and toevaluate the need for remedy repairs, in accordance with the Superfund Program's NationalContingency Plan regulations. For purposes of this FS, non of the cost estimates developedfor the FWA alternatives considers sampling beyond the first five years; however, evaluationsof the sampling program would occur each year for the purposes noted above. Detailsregarding the post-remediation sampling are presented in Section 5.1.8.3. Areas whereexcavation and cover placement have been selected under this alternative are as follows:

• FEU 2 and FEU 3

Excavate the top 12 inches of soil over areas with concentrations PCBs greater than30mg/kg and hexachlorobenzene (HCB) concentrations greater than 80 mg/kg.Excavated soil would be dewatered and disposed in the on-site consolidation area.


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Trees would be removed from the excavation areas. Tree roots and trees that havefallen prior to excavation would be disposed in the on-site consolidation area. Anyresidual soil adhering to the wood, rocks, or non-vegetative debris located aboveground surface would be removed. If removal is not feasible, place materials into on-site consolidation area. The above ground wood would be considered asuncontaminated debris and used as mulch or disposed in the on-site consolidation area.A 6-inch cover would be placed over areas with PCB concentrations between 6 and 30mg/kg. Trees in the cover areas with dbh below 12 inches would be removed. Treeroots would be disposed in the on-site consolidation area. Excavated areas would bebackfilled with 12 inches of hydric-compatible soil. Additional backfill soil would beplaced as required to transition to the elevation of adjacent 6-inch cover areas (SeeFigures 5-7, 5-8, and 5-9).

• FEU 4, 6 and 8

Excavate the top 12 inches of soil over areas with concentrations of PCBs greater than50 mg/kg and hexachlorobenzene concentrations greater than 200 mg/kg. Excavatedsoil would be dewatered and disposed in the on-site consolidation area. Trees wouldbe removed from the excavation areas. Tree roots and trees that have fallen prior toexcavation would be disposed in the on-site consolidation area. Any soil from wood,rock, or non-vegetative debris located above ground surface would be removed. Ifremoval is not feasible, place materials into on-site consolidation area. The aboveground wood would be considered as uncontaminated debris and used as mulch ordisposed in the on-site consolidation area. Excavated areas would be backfilled with12 inches of hydric-compatible soil, plus additional backfill soil as required totransition to the elevation of adjacent 6-inch cover (See Figures 5-10, 5-11, and 5-12).

Additional features for Alternative VII have been for implementation of this remedy whichinclude co-disposal of FWA and SOU excavation material and construction of on-siteconsolidation area. The following section describe the aspects.

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5.1.8.1 Fields Brook Sediment Disposal

Alternative VII addresses certain aspects of the sediment to be excavated from the FieldsBrook SOU. The on-site consolidation area to be constructed for the FWA soiHs to bedesigned to include space for the Fields Brook sediment. For comparison with the otherFWA alternatives, the costs that have been developed for Alternative VII do not address theadditional space requirements. Details regarding the remedial activities and recentmodifications for the Fields Brook sediment remedy will be in the Explanation of SignificantDifferences (ESD) to be provided by USEPA for the SOU.

5.1.8.2 On-Site Consolidation Area

The on-site consolidation area would be placed in an area where underlying clay is expectedto be continuous and sand lenses are not known to exist. The bottom of 4he consolidationarea is to be located at least 5 feet above the groundwater table. If possible, the consolidationarea would be located in an area where groundwater contamination is not known to bepresent. Detailed requirements for the proposed on-site consolidation area are as follows:

• Bottom Liner (from bottom to top) - ---0 6-inch recompacted in-situ soil0 60-mil liner0 6-inch sand/gravel layer with leachate detection system0 60-mil liner0 6-inch sand/gravel layer with leachate detection system0 Dewatered FWA soil/Fields Brook sediment (no rocks or sharp materials near

bottom)

• Cover (from bottom to top)0 Compacted FWA soil/Fields Brook sediment0 12-inch clean sand/gravel layer (consider the need for passive gas collection or

vents)0 40-mil liner with trench tie-in

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0 1/4-inch geonet (with attached geofabric)0 24-inch soil layer0 6-inch topsoil layer0 vegetative cover

• Other/Operations & Maintenance (O&M)0 Perimeter fencing0 Groundwater monitoring well installation (minimum one upgradient, three

downgradient)0 Semiannual groundwater sampling with analysis for TCL/TAL parameters0 Quarterly maintenance

The estimated area assumes that the soil would be placed to a maximum height of 25 feet with3:1 horizontal to vertical sideslopes. The integrated design will describe details of theconsolidation area.

5.1.8.3 Post-Remediation Sampling

A post-remediation chemical sampling program would be initiated in the FWA forAlternative VII to evaluate remedial action in both the residential and industrial FEUs. Thesampling program would involve the following components:

• Residential FEUs (FEU2 and 3)0 10 samples are planned to be taken each year.0 Analyze for PCBs years 1 through 4.0 Analyze for 11 COCs year 5 (i.e., arsenic, benzo(a)pyrene, beryllium,

hexachlorobenzene, hexachlorobutadiene, hexachloroethane, PCBs, 1,1,2,2,-tetrachloroethane, tetrachloroethene, trichloroethene, and vinyl chloride).

0 Review and evaluate sampling results each year during the 5 years of sampling.The sampling program would be evaluated to assess further monitoring needs.Remedy evaluations and repairs would be performed as needed in accordance withthe National Contingency Plan (NCP).

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• Industrial FEUs (FEU4, 6, and 8)0 15 samples are planned to be taken each year.0 Analyze for PCBs years 1 through 4.0 Analyze for 11 COCs year 5 (i.e., arsenic, benzo(a)pyrene, beryllium,

hexachlorobenzene, hexachlorobutadiene, hexachloroethane, PCBs, 1,1,2,2,-tetrachloroethane, tetrachloroethene, trichloroethene, and vinyl chloride).

0 Review and evaluate sampling results each year during the 5 years of sampling.The sampling program would be evaluated to assess further monitoring needs. ^Remedy evaluations and repairs would be performed as needed in accordance withthe National Contingency Plan (NCP).

5.2 EVALUATION OF ENVIRONMENTAL PROTECTION FOR REMEDIALCOVER AND EXCAVATION TECHNOLOGIES

5.2.1 Chemical Exposure Reduction

Excavation and cover technologies, in general, meet the objective of reducing short-term andlong-term exposure of ecological receptors to chemicals in FWA soil and sediment.Excavation completely removes chemicals from the soil column. Clean cover reduces thepotential for chemicals to be exposed to humans and to the bioaccessible and bioavailable Jpools. Cover technologies would be most-suitable for areas with relatively low levels ofbecause potential exposure of chemicals to human and ecological receptors is expected to bebelow acceptable risk levels. With cover in place, the biologically active surface soil and litterlayers will develop and function. As summarized in Section 5.2.4, in the ecosystems of theFWA, cover technologies placed over areas with relatively low levels of contamination couldoffer adequate exposure reduction for ecological receptors with less habitat destruction thanexcavation.

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Alternatives providing 6 inches and 12 inches of cover could offer reduction in ecologicalexposure. Few true borrowing organisms (see discussion below) are present in the FWA.Most species dwelling in proximity to the substrate (and associated with elevated exposurerisks) utilize the ground surface or runs in the interface between the soil and litter layers.Those active at the soil/litter interface would be exposed, through daily activities, to surfacesoil chemicals at levels well below those in the baseline case. Long-term reduction ofecological exposure depends on the long-term integrity of the cover. A well designed,installed, and maintained cover should provide long-term protection for ecological receptors.Crucial issues for evaluation include:

• biological turnover of soils below the cover system;• transport through the cover via plant uptake;• potential local or catastrophic loss of the cover, and• documentation of long-term exposure control.

Biological turnover is primarily a function of burrowing animals. Invertebrates such ascrayfish and earthworms and vertebrates such as moles, muskrats, beavers, and woodchucksinvert components of the soil column as a function of their daily activities during the warmseason. Consideration of such activities will be important in cover design, maintenance, andmonitoring. Beavers and muskrats are present in the system, but generally utilize burrowsystems adjacent to the aquatic ecosystem. Stream banks and bottom sediments are beingremediated under the Fields Brook SOU. Where these organisms burrow in the floodplainsystem, some turnover of cover soil may be expected.

Woodchucks dig comparatively deep and extensive burrows. However, woodchucks cannotconstruct deep burrows in the shallow soils overlying rocky glacial till in the FWA.Woodchuck activity in the Fields Brook vicinity is confined largely to the upland slopes at theouter edge of the FWA. Some penetration of burrow systems off the slopes into FWAsubstrate may be expected.

Mammals common in the FWA include mice (Peromyscus, Zapus, Napezapus, and Mus), rats(Rattus), shrews (primarily Blarina) and voles (Microtus). These species are not burrowers.

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Voles and shrews utilize runs at the soil/litter interface. Often mice and rats are surfacedwellers, and the species recorded in trap surveys in the Fields Brook FWA are partiallyarboreal. Mole tunnels were not recorded during extensive site ecological investigations, butmoles are expected to be present. While moles are not abundant, and may be limited byshallow soils and high water tables, some mole turnover of soils may be expected.

Aquatic invertebrates (primarily crayfish), like aquatic mammals, will construct burrowsystems at the streambanks. Some burrows will likely occur beyond the Fields Brook SOU,but the distance to water and till deposits combine to limit the number, extent, and frequencyof such burrows.

Earthworms occur throughout the FWA. While a quantitative survey was not undertaken,observationally most individuals recovered or recorded in site surveys are subsurface dwellers,but individuals of species utilizing the surface of the litter layer (lumbricus) were found.Surface-using earthworms were not abundant in the system, and their activities may be limitedby clays and till underlying surface soils. Some limited turnover of soils may be expected fromearthworms.

Transport of chemicals through the clean cover layers to biologically active strata of thesurface ecosystem is a potential concern. Under baseline conditions, few compounds werepresent at measurable concentrations in vegetation. All cover alternatives would reduce thisexposure route further, because surface-spreading roots (which likely comprise the majority ofroot biomass in this shallow-soil system) will function in an uncontaminated stratum.

There is a margin-of-safety provided in the baseline risk assessment for the FWA and thismargin will help assure the protectiveness a cover alternative, as discussed in Appendix A.

5.2.2 Ecological Impacts

Active remediation in wetland ecosystems has substantial environmental impacts. Suchimpacts can be controlled by implementing risk management alternatives which balance theneed for exposure reduction with the need to sustain the health of the habitat in place. For

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evaluating ecological impacts, the remediation techniques can be grouped into two categories:excavation and cover. Excavation techniques remove chemicals from the potential exposurepool. However, in doing so they destroy the habitat in place. While some wetlandcommunities (those dominated by annual grasses or herbaceous vegetation) can be effectivelyrestored in a relatively short time period, others (dominated by woody species) cannot berestored in a relatively short period. The ecological value of the latter is particularly high, anddestruction of such habitats has negative impacts. Much of the Fields Brook FWA is wooded.Over much of the area, excavation techniques will result in destruction of valuable habitat.

Both 6-inch and 12-inch cover designs offer effective exposure reduction. However, thechemicals will remain in the potential exposure pool beneath the cover. Twelve-inch designswill not provide substantially greater exposure reduction if the cover is maintained effectively,but do offer greater margin of safety for long-term protection. Deep cover designs (12 inchesof soil, relative to grade or water elevation) are also likely to cause relatively severe ecologicaleffects. Cover layers this deep are likely to stress most trees, and a number may be killed byreduced oxygen ration. In addition, the wetland character of the floodplain would bedegraded, and substantial areas of wetland may be lost as a result of placing a 12-inch cover.Effects from a 6-inch cover would be less severe.. Transition communities or evencommunities expressing primarily upland character are likely to occur more readily on a12-inch cover. While a 12-inch cover does result in a greater exposure reduction for animals,the lack of substantial populations of true burrowing species means there is a little riskreduction benefit relative to environmental impacts of cover at this depth.

A 6-inch cover offers the fewest ecological consequences. Soil addition of this depth isunlikely to stress woody vegetation. Understory, shrub and herb layer communities are likelyto re-establish in largely their present configurations, although some wetland character may belost. Such losses may be minimal, however, because the existing floodplain has relativelysubstantial elevation differences relative to water table, and wetland vegetation is pervasive.Given the nature of the present faunal community as primarily associated with ground surfaceor the soil/litter interface, a 6-inch cover will likely provide exposure reduction at minimalenvironmental impact.


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5.2.3 Potential Cover Issues Identified by USEPA

As described in preceding sections, appropriate cover techniques may meet the objectives ofreducing short-term and long-term exposure to chemicals in the FWA. However, since theproposed cover systems would be limited to 6 to 12 inches of hydric-compatible soil to beplaced on the ground surface of the FWA, there are several potential long-term effectivenessand permanence issues that demonstrate USEPA's concerns related to the cover. USEPAprovided this list of cover issues to FBAG on February 8, 1996. A response to theapplicability and degree to which these potential issues are operative within the FWA wasprovided to the USEPA by the FBAG on March 21, 1996. USEPA commented on theMarch 21, 1996 submittal on May 22, 1996. FBAG provided additional responses andtechnical discussion supporting the use of a cover to USEPA on August 13, 1996. Copies ofthese reports are provided in the administrative records. The specific issues described byUSEPA consisted of the following:

• "Earthworms may move COCs to the surface."

• "Burrowing animals and other organisms would be expected to continue to have directcontact with the COCs and also bring COCs to surface."

• "Root uptake of COCs (mostly the heavy metals, but also low levels of organics)would result in surfacing of the COCs into leaf litter. Further, roots from trees andplants which would eventually come back to the area would be expected to grow onlythrough the surface soils due to the wetland environment, and would create conduitsto the lower contamination and enhance bulking/mixing with covered contaminants."

• 'Trees would be killed by a 6 to 12 inches cover due to compaction and prevention ofair interchange; dead trees would uproot and fall and cause cover integrity problems."

• "While storm-event scour models indicate that the FWA would remain mostly adeposition zone during 100-year storms, with reduced floodplain due to cover height,

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the velocity may be expected to increase in the entire FWA area which may enhancescour of the side of cover areas and other flatter FWA areas."

• "Compaction (to prevent direct exposure) may be difficult during construction in partbecause the area has several rolling hill areas and in part because the soil cover will beplaced directly over leaves, trees, and stumps (this may not ensure integrity due todifferential settlement expected from degradation)."

• "Since the area is in its entirety considered a "wetland" (according to USAGEdefinition), water would be expected to regularly move up and down through the 6 to12 inches cover during rainy and wet periods, which would be expected to affectstructural integrity and increase likelihood of circuiting of COCs upward and crackingof the cover."

• "Since the site is in northern Ohio, a 42-inch frost line exists, and freeze/thaw effectsof the weather could negatively affect structural integrity, and increase likelihood ofcircuiting of COCs upward and cracking of the cover."

• "A regrowth of hydrophytic vegetation within the FWA after remediation would beneeded to help prevent surface erosion and help coalesce soils. While all backfill forcover areas would consist of hydric-compatible soils (contains seeds, organics, andother properties necessary to regrowth in the wet environment), raising the surface 6to 12 inches could desiccate surface soils and wetland vegetative growth would beinhibited. Alternative revegetation plans to offset this effect may be cost-prohibitive."

• "Rigorous and costly O&M may be needed to ensure long-term integrity and preventunwanted trees and shrubs, frequent maintenance of the cover andmonitoring/sampling would be needed to help ensure that COCs are not surfacing,"

• "Since backfill raises surface elevations and changes area hydrology, wetlandrestoration may not occur, mitigation may be required, and mitigation costs foreliminated wetlands may be significant."


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• "PCB volatilization"

5.2.4 Comparative Summary: Excavation and Cover

Given the biotic communities inhabiting the floodplain wetland, exposure reduction can beaccomplished either by excavation or cover (presuming the cover is maintained andmonitored). Habitats in place over much of the remediation area are high quality, slowgrowing, not easily replaceable wooded wetland systems. In this case, a 6-inch cover willprovide effective risk reduction with minimal habitat destruction. However, use of a coverwould be most suitable for areas with relatively low levels of contamination since thechemicals will remain in the soil column beneath the cover. In balancing destructiveremediation with risks of residual contamination, for ecological protection the most effectiveand protective remedy could incorporate both cover and excavation depending on the level ofcontamination that is present in the particular area of the FWA to be addressed.

5.3 CRITERIA FOR DETAILED ANALYSIS OF ALTERNATIVES

The purpose of the detailed evaluation of potential remedial alternatives is to provide asufficient amount of relevant information for each alternative for the selection of thecost-effective remediation measure for a particular site or facility. Each alternative isevaluated initially against the CERCLA criteria and then the alternatives are compared againsteach other to identify the key advantages and disadvantages of each.

Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA(USEPA 1988a) provides nine evaluation criteria to address the CERCLA statutoryrequirements and considerations:

1. Overall protection of human health and the environment,2. Compliance with ARARs,3. Long-term effectiveness and permanence,4. Reduction of toxicity, mobility or volume through treatment,5. Short-term effectiveness,6. Implementability,

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7. Cost,8. State acceptance, and9. Community acceptance.

The nine criteria are grouped into three categories: threshold, balancing and modifying. Thethreshold criteria (Nos. 1 and 2) focus on how risks posed through each exposure pathway arereduced, controlled, or eliminated. Balancing criteria (Nos. 3 through 7) are used to furtherevaluate the alternatives that satisfy the threshold criteria. The modifying criteria (Nos. 8 and9) include community and state acceptance. These criteria will not be evaluated in thisdocument.

The main aspects of the seven criteria to be evaluated during the detailed evaluation of thealternatives are discussed below:

1. Overall Protection of Human Health and the Environment: This criterion is used toprovide an overall assessment of the degree to which each alternative protects humanhealth and the environment. The overall protectiveness focuses on whether thealternative would achieve adequate protection and how existing site risks would beeliminated, reduced or controlled through treatment, engineering, or institutionalcontrols. Because this criterion is considered a threshold criterion, overall protectionmust be provided for an alternative to be considered a remedy for the site.

2. Compliance with ARARs: This criterion is used to assess whether an alternativewould meet all federal and state ARARs. This criterion is also a threshold criterion.

3. Long-Term Effectiveness and Permanence: This criterion is used to assess the riskthat would remain at the site after the remedial action objectives are achieved. Theextent and effectiveness of the controls needed to manage any treatment residuals oruntreated wastes are assessed by determining the magnitude of any residual riskremaining at the site at the conclusion of the remedial activities. The adequacy andreliability of the controls used to manage treatment residuals or untreated wastes, ifany, are assessed.


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4. Reduction of Toxicity. Mobility or Volume through Treatment: This criterion allowsfor an assessment of the degree to which treatment of hazardous substances wouldpermanently and significantly reduce toxicity, mobility, or volume of the hazardoussubstance (i.e., contaminants). This assessment would be completed by analyzing thedestruction of toxic contaminants, the reduction of total mass of toxic contaminants,the irreversible reduction of contaminant mobility, and the reduction of total volume ofcontaminated material.

5. Short-Term Effectiveness: This criterion is used to address the effects of analternative during the construction and implementation of remedial activities until theremedial action objectives would be achieved. The issues considered includeprotection of workers and the community during construction and implementation, anyenvironmental impacts that might result, and the length of time until the remedialaction objectives would be achieved.

6. Implementability: The implementability criterion is used to assess the technical andadministrative feasibility of implementing an alternative, availability of thetechnologies, and the availability of various services and materials required duringimplementation. Technical feasibility refers to the technical difficulties and variablesassociated with the alternatives, the reliability of the technologies, and monitoringrequirements. Administrative feasibility includes the activities which requirecoordination with regulatory offices or agencies.

7. Cost: The cost evaluation includes capital costs, annual operation and maintenance(O&M) costs, and a present worth analysis. The cost estimates are order-of-magnitude level estimates, as defined by the American Association of Cost Engineers,and are approximate estimates made without engineering data. Typically, an estimateof this type is expected to be accurate to +50% and -30% for unit quantities. Theactual cost would depend on the final scope of the remedial action, the implementationschedule, actual labor and material costs, competitive market conditions, and othervariables that may affect project cost. Based on USEPA guidance, cost-effectivenessrequires the cost of the remedy to be proportional to its overall effectiveness. Overallproject costs (both capital costs and annual O&M costs) can be compared on a


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common basis by using present worth calculations. The present worth calculationspresented in this FS were calculated using an average interest rate of 5% over timeperiods of 1, 5, 10, 30 years. All of the cost estimates are based on implementation ofthe FWA remedy concurrent with the SOU remedy and represent incremental costs tothe estimates for the SOU remedy.

Each alternative will be evaluated using these seven criteria. On a case-by-case basis, thecriteria are balanced in a risk management judgment as to which alternative provides the mostappropriate solution for the site problem. The detailed analysis of each alternative is providedin Section 6.0.


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6.0DETAILED ANALYSIS OF ALTERNATIVES

The individual analysis of alternatives presented in this section consists of a summarydescription of the primary components of the alternative followed by an evaluation withrespect to the seven CERCLA criteria described in Section 5.0. The results of the evaluationare summarized in Table 6-1. Detailed breakdowns of the costs of the alternatives arepresented in Tables 6-2 through 6-7.

6.1 ALTERNATIVE I - NO ACTION

This alternative would not involve any action and would allow the entire FWA to remain as itcurrently exists. The no-action alternative is required for consideration by the NCP and serves as abaseline for comparison with other alternatives.

6.1.1 Overall Protection of Human Health and the Environment

Since Alternative I does not involve any remediation of the FWA soils, there would be noreduction in potential for adverse effects to human or ecological receptors. Unlike all the otheralternatives, there would be no impacts on the existing ecosystem by destruction of habitat throughremediation.

6.1.2 Compliance with ARARs

No potential chemical-specific or action-specific ARARs have been identified for the no actionalternative. There would be no adverse impacts to wetlands from no action.

6.1.3 Long-Term Effectiveness and Permanence

Since no action is taken, there is no reduction in risk to human receptors in any FEUs. However,this is the only alternative that would allow the existing ecosystem to be preserved in its presentstate. There would be no adverse impact to the site hydrology from no action.


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6.1.4 Reduction of Toxicity, Mobility or Volume through Treatment

Since no action is taken, there is no reduction of toxicity, mobility or volume of contaminantsthrough treatment.

6.1.5 Short-Term Effectiveness

Since no action is taken, there would be no increase in risk to the community, workers, or theexisting ecosystem in the short term. No time would be required to complete the no actionalternative

6.1.6 Implementability

This alternative would be the easiest to implement since no action would be required.

6.1.7 Cost

There are no costs associated with the no action alternative.

6.2 ALTERNATIVE II - CONTAINMENT #1

Alternative n involves constructing a 6-inch cover using hydric compatible soils in designatedremedial response areas for all five FEUs. The total area to be covered through implementation ofAlternative II is estimated at 370,000 sq. ft (8 acres). The human health risk targets for thisalternative would be 10"6 for residential FEUs 2 and 3 and 10"5 for industrial FEUs 4, 6, and 8.Institutional controls are also included in Alternative II. The institutional controls, as described inSection 5.0, include deed restrictions or permanent covenants to restrict construction ordevelopment in all five FEUs and to prevent residential land use in industrial FEUs 4, 6, and 8.Long-term maintenance and post-remediation chemical sampling would be required for the cover.Wetland mitigation would be performed as required to comply with ARARs.


Alternative II provides reduction in risk to human receptors using a 10"6 risk target forresidential FEUs 2 and 3, and a 10"5 risk target for industrial FEUs 4, 6, and 8. Thisalternative provides minimal adverse risk to ecological receptors due to construction impacts.

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The ecological risk of exposure to residual concentrations following implementation of thisalternative is expected to be acceptable. Cover placement in FEUs 2 and 3 would result in amoderate adverse impact to the existing ecosystem. The ecosystem impacts in FEUs 4, 6, and 8would be relatively low due to the limited cover areas. The exclusive use of a cover would allowall chemicals to remain in the FWA soil column, which may reduce the protectiveness of thisalternative in areas of relatively high chemical concentrations.


The cover placement included in Alternative n is expected to comply with most potential ARARs.However, this alternative may not comply with the TSCA disposal regulations. Since the coverplacement would change the site topography, the response areas would require wetland mitigationand/or demonstration of no adverse impacts under the Clean Water Act and E.O. 11990(Protection of Wetlands). This alternative does not involve off-site disposal of contaminated soils.There are no potential chemical-specific ARARs.


Alternative II would result in a moderate reduction in risk to human receptors in all five FEUs. Thecover may be reliable and provide for long-term effectiveness and permanence with propermaintenance. The exclusive use of a cover would allow all chemicals to remain in the FWA soilcolumn, which may reduce the long-term effectiveness and permanence in areas of relatively highchemical concentrations. The long-term ecological risk from implementing the remedy isacceptable since the soil cover material would be supportive of vegetative growth and thevegetation would recover in the long term. Interim erosion control methods would be used duringthe revegetation period. The relatively extensive cover areas may be expected to have a relativelymoderate to high impact to the site hydrology.


Placement of the soil cover is a permanent remedy, but does not involve a reduction in toxicity,mobility, or volume through treatment.


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Alternative n would involve a minimal risk to the community from airborne particulates andvehicular traffic during cover construction. Workers would need protection against dermal contactand dust inhalation during construction activities. Low to moderate environmental impacts areanticipated during cover placement and while re-establishing native vegetation. The coverconstruction and initial planting of replacement native vegetation is expected to be completedwithin a 1 year time period.


Standard construction equipment and techniques would be utilized during implementation of thisalternative. Hydric-compatible soils may not be readily available for the cover, and may have to beobtained through on-site or off-site mixing of available materials, such as clay and organiccompost. Specifications for hydric-compatible soil would be developed so that the soil type isappropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialcover failure. Implementation is expected to require coordination with USEPA, Ohio EPA, andthe U.S. Army Corps of Engineers.

6.2.7 Cost

Details regarding the costs associated with this alternative are presented Table 6-2. A summary ofthe costs is as follows:

• Alternative II - Direct Costs = $ 2,850,000- Annual O&M= $ 243,500- 30-year Present Worth = $ 4,991,000

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6.3 ALTERNATIVES IIIA & IIIB - COVER, EXCAVATION, BACKFILL ANDOFF-SITE DISPOSAL

Alternatives IIIA and IIIB involve a combination of : 1) containment using 6-inch or 12-inchhydric compatible soil cover; and 2) excavation, hydric-compatible soil backfill, and off-sitedisposal. The total estimated containment areas and excavation volumes are as follows:

• Alternative IIIA - Containment Area = 351,000 sq ft (8 acres)- Excavation Volume = 8,300 cu yd

• Alternative IIIB - Containment Area = 319,000 sq ft (7 acres)- Excavation Volume = 9,300 cu yd

The containment areas and excavation volumes are based on the PCB target concentration valuesdescribed in Section 5.0. The total remedial response area (including both the containment andexcavation areas) is the same for the two alternatives and is estimated at 572,000 sq ft (13 acres).The primary differences are that Alternative IIIB includes approximately 2,200 cu yd of additionalexcavation in FEU 2, while Alternative IIIA includes 1,200 cu yd of additional excavation in FEUs4, 6, and 8. Institutional controls are also included in Alternatives IIIA and IIIB. The institutionalcontrols, as described in Section 5.0, include deed restrictions or permanent covenants to restrictconstruction or development in all five FEUs and to prevent residential land use in industrial FEUs4, 6, and 8. Excavation would be limited to a depth of 12 inches. Long-term maintenance andpost-remediation chemical sampling would be required for both cover and excavation areas.Wetland mitigation would be performed as required to comply with ARARs.


Alternatives IIIA and IIIB provide reduction in risk to human receptors using a 10"6 risk targetfor residential FEUs 2 and 3 and a 50 mg/kg target response level for PCBs in FEUs 4, 6, and8. The 50 mg/kg PCB concentration correlates with an average residual PCB concentrationof approximately 6 to 9 mg/kg and an approximate industrial risk target of 3xlO"6. Thesealternatives provide minimal adverse risk to ecological receptors due to construction impacts.The ecological risk of exposure to residual concentrations following implementation of thisalternative is expected to be acceptable. Specific post-remediation residual ecological risks that


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have been calculated for Alternatives niA and Ilffi are discussed in Appendix A. The use of acover would allow all chemicals to remain in the FWA soil column, which may reduce theprotectiveness of this alternative in areas of relatively high chemical concentrations.

Adverse impacts to the existing ecosystem within each FEU would vary from low to highdepending the total amount of cover or excavation associated with Alternatives IRA and fflB. Ingeneral, the excavation areas would involve greater ecological impacts due to total destruction ofthe existing habitat. However, excavation would result in less potential for long term ecologicalimpacts than a cover since the contaminants are not left in place.


The excavation and cover placement included Alternatives niA and HIE are expected to complywith most potential ARARs. However, this alternative may not comply with the TSCA disposalregulations. Since both the excavation backfilling and cover placement would change the sitetopography, the response areas would require wetland mitigation and/or demonstration of noadverse impacts under the Clean Water Act and E.G. 11990 (Protection of Wetlands). There areno potential chemical-specific ARARs.


Alternatives IHA and fflB would result in a high reduction in human health risk in FEUs 2 and 3and a moderate reduction in human health risk in FEUs 4, 6, and 8. The cover may be reliable andprovide for long-term effectiveness and permanence with proper maintenance. The use of a coverwould allow all chemicals to remain in the FWA soil column, which may reduce the long-termeffectiveness and permanence in areas of relatively high chemical concentrations. The use of soilexcavation is highly reliable, and is being considered for areas with relatively high PCBconcentrations. The long-term ecological risk from implementing the remedy is acceptable sincethe excavation backfill and soil cover material would be supportive of vegetative growth.Regrowth of native vegetation would be expected to recover in the long term, although therecovery time is expected to be the shortest for the 6-inch cover areas. The recovery times for the12-inch cover and excavation areas would be approximately the same. Interim erosion control


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methods would be used during the revegetation period. The excavation and cover areas may beexpected to have a relatively moderate impact to the site hydrology.


Containment and excavation are both permanent remedies, but do not involve a reduction intoxicity, mobility, or volume through treatment. Excavation and backfilling with clean materials isirreversible.


Alternatives IIIA and IIIB would involve a minimal risk to the community from airborneparticulates and vehicular traffic during cover construction and excavation. Increased risk to thecommunity would be associated with the off-site transport of contaminated soils. Workers wouldneed protection against dermal contact and dust inhalation during construction and excavationactivities. Moderate environmental impacts are anticipated during cover placement, limitedexcavation and backfilling, and while re-establishing vegetation. Implementation of AlternativesDIA and mB, through the initial planting of replacement vegetation, is expected to be completedwithin a 1 year time period.


Standard construction equipment and techniques would be utilized during implementation of thesealternatives. Hydric compatible soils to be used for cover and backfill may not be readily available,and may have to be obtained through on-site or off-site mixing of available materials, such as clayand organic compost. Specifications for hydric-compatible soil would be developed so that the soiltype is appropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialerosion of cover or excavation backfill areas. Implementation is expected to require coordinationwith USEPA, Ohio EPA, and the U.S. Army Corps of Engineers.

6.3.7 Cost

Although Alternatives IIIA and IIIB include the same overall response areas, the estimated costsassociated with these alternatives vary depending on the size of the excavation and cover areas.


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Higher costs are associated with Alternative IIIB, since it includes approximately 1,400 cu yds ofadditional excavation. Details regarding the estimated costs for Alternatives IHA and HIE arepresented Tables 6-3a and 6-3b. A summary of the costs is as follows:

• Alternative fflA - Direct Costs = $7,563,000- Annual O&M= $ 243,500- 30-year Present Worth = $ 9,700,000

• Alternative IIIB - Direct Costs = $ 8,144,000- Annual O&M= $ 243,500- 30-year Present Worth = $10,281,000

6.4 ALTERNATIVE IV - CONTAINMENT #2

The components of Alternative IV are essentially the same as those described for Alternative HBoth of these alternatives involve constructing a 6-inch cover using hydric compatible soils indesignated remedial response areas. However, the human health risk target for this alternativewould be 10^ for all five FEUs (2, 3, 4, 6, and 8). The total area to be covered throughimplementation of Alternative IV is estimated at 764,000 sq ft (18 acres). Institutional controls arealso included in Alternative IV. The institutional controls, as described in Section 5.0, include deedrestrictions or permanent covenants to restrict construction or development in all five FEUs and toprevent residential land use in industrial FEUs 4, 6, and 8. Long-term maintenance andpost-remediation chemical sampling would be required for the cover. Wetland mitigation would beperformed as required to comply with ARARs.


Alternative IV provides reduction in risk to human receptors using a 10"6 risk target. Thisalternative also provides a minimal adverse risk to ecological receptors due to constructionimpacts. The ecological risk of exposure to residual concentrations following implementation ofthis alternative is expected to be acceptable. Cover placement would result in a moderate adverseimpact to the existing ecosystem. The exclusive use of a cover would allow all chemicals to remainin the FWA soil column. The use of a cover would allow all chemicals to remain in the FWA soil


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column, which may reduce the protectiveness of this alternative in areas of relatively high chemicalconcentrations.


The cover placement included in Alternative IV is expected to comply with most potential ARARs.However, this alternative may not comply with the TSCA disposal regulations. Since the coverplacement would change the site topography, the response areas would require wetland mitigationand/or demonstration of no adverse impacts under the Clean Water Act and E.G. 11990(Protection of Wetlands). This alternative does not involve off-site disposal of contaminated soils.There are no potential chemical-specific ARARs.


Alternative IV would result in a moderate reduction in risk to human receptors in all five FEUs.The cover may be reliable and provide for long-term effectiveness and permanence with propermaintenance. The exclusive use of a cover would allow all chemicals to remain in the FWA soilcolumn, which may reduce the long-term effectiveness and permanence in areas of relatively highchemical concentrations. The long-term ecological risk from implementing the remedy isacceptable since the soil cover material would be supportive of vegetative growth and thevegetation would recover in the long term. Interim erosion control methods would be used duringthe revegetation period. The relatively extensive cover areas may be expected to have a relativelymoderate to high impact to the site hydrology.


Placement of the soil cover is a permanent remedy, but does not involve a reduction in toxicity,mobility, or volume through treatment.


Alternative IV would involve a minimal risk to the community from airborne particulates andvehicular traffic during cover construction. Workers would need protection against dermal contactand dust inhalation during construction activities. Low to moderate environmental impacts areanticipated during cover placement and while re-establishing native vegetation. The cover

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construction and initial planting of replacement native vegetation is expected to be completedwithin a 1 year time period.


Standard construction equipment and techniques would be utilized during implementation of thisalternative. Hydric compatible soils may not be readily available for the cover, but could beobtained through on-site or off-site mixing of available materials, such as clay and organiccompost. Specifications for hydric-compatible soil would be developed so that the soil type isappropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialcover failure. Implementation is expected to require coordination with USEPA, Ohio EPA, andthe U.S. Army Corps of Engineers.

6.4.7 Cost


• Alternative IV - Direct Costs = $ 3,743,000- Annual O&M= $ 243,500- 30-year Present Worth = $ 5,879,000

6.5 ALTERNATIVE V • EXCAVATION, BACKFILL, AND OFF-SITE DISPOSAL

Alternative V involves excavation of all soil with chemical concentrations that exceed the CRGs inFEUs 2, 3, 4, 6, and 8 to a depth of 12 inches, backfilling to original grade using hydric compatiblesoils, and placing a vegetative cover over the backfill areas. Excavated soil would be disposed inan off-site landfill. A human health risk target of 10"6 would be used for all five

The total remedial response area for Alternative V is estimated at 764,000 sq ft (18 acres), which isthe same as the area to be covered in Alternative IV. The total volume of soil to be excavated to adepth of 12 inches in this area is estimated at 28,500 cu yds. Institutional controls, long-termmaintenance, and post-remediation chemical sampling would also be included in Alternative Vsince the excavation depth would be limited to the upper 12 inches. The institutional controls, as


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described in Section 5.0, include deed restrictions or permanent covenants to restrict constructionor development in all five FEUs and to prevent residential land use in industrial FEUs 4, 6, and 8.Wetland mitigation would be performed as required to comply with ARARs.


Alternative V provides reduction in risk to human receptors using a 10~6 risk target forresidential FEUs 2 and 3 and for industrial FEUs 4, 6, and 8. This alternative providesminimal adverse risk to ecological receptors. The ecological risk of exposure to residualconcentrations following implementation of this alternative is expected to be acceptable. The useof excavation to remove relatively high chemical concentrations from the soil column, wouldincrease the protectiveness of this alternative.

Adverse impacts to the existing ecosystem would be high due to the relatively extensive excavationareas that are included in Alternative V. In general, excavation would result in a greater degree ofecological impact than a 6-inch or 12-inch cover due to total destruction of the existing habitat.However, this alternative would result in less potential for long term ecological impacts caused byleaving the contaminants in place.


The excavation and backfilling included in Alternative V would comply with potentialARARs. The response areas would require wetland mitigation and/or demonstration of noadverse impacts under the Clean Water Act and E.G. 11990 (Protection of Wetlands). Thereare no potential chemical-specific ARARs.


Alternative V would result in a high reduction in human health risk. Soil excavation and backfillingare highly reliable controls. O&M of the selected off-site landfill would be required to insure thereliability of this alternative. The long-term ecological risk from implementing the remedy isacceptable since the excavation backfill material would be supportive of vegetative growth. Thevegetation would recover in the long term, although the recovery time is expected to be greaterthan for the cover areas specified in other alternatives. Interim erosion control methods would be

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used during the revegetation period. The excavation and backfilling to original grade may beexpected to have a low impact to the site hydrology. The use of excavation to remove relativelyhigh chemical concentrations from the soil column, would increase the long-term effectiveness andpermanence of this alternative.


Excavation and backfilling with clean material is an irreversible, permanent remedy, but does notinvolve a reduction in toxicity, mobility, or volume through treatment.


Alternative V would involve a minimal risk to the community from airborne particulates andvehicular traffic during excavation and backfilling. Increased risk to the community would beassociated with the off-site transport of contaminated soils. Workers would need protectionagainst dermal contact and dust inhalation during excavation and backfilling activities. Moderate tohigh environmental impacts are anticipated from excavation, backfilling, and re-establishing nativevegetation. Implementation of Alternative V, through the initial planting of replacement nativevegetation, is expected to be completed within a 1 year time period.


Standard construction equipment and techniques would be utilized during implementation of thisalternative. Hydric-compatible soils to be used for backfill may not be readily available, but couldbe obtained through on-site or off-site mixing of available materials, such as clay and organiccompost. Specifications for hydric-compatible soil would be developed so that the soil type isappropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialerosion of excavation backfill areas. Implementation is expected to require coordination withUSEPA, Ohio EPA, and the U.S. Army Corps of Engineers.

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6.5.7 Cost


• Alternative V - Direct Costs = $19,671,000- Annual O&M= $ 73,000- 30-year Present Worth = $20,491,000

6.6 ALTERNATIVE VI - EXCAVATION, BACKFILL, TREATMENT ANDOFF-SITE DISPOSAL

Alternative VI is the same as Alternative V except that the excavated soil with total PCBconcentrations exceeding 500 mg/kg would be thermally treated prior to off-site landfilling. Thetotal remedial response area for Alternative V is estimated at 764,000 sq ft (18 acres), which is thesame as the area to be covered in Alternative IV. The total volume of soil to be excavated to adepth of 12 inches in this area is estimated at 28,500 cu yds. An estimated total of 2,000 cu yds ofthe excavated soil would require thermal treatment. Institutional controls, long-term maintenanceand post-remediation chemical sampling would also be included in Alternative VI since theexcavation depth would be limited to the upper 12 inches. The institutional controls, as describedin Section 5.0, include deed restrictions or permanent covenants to restrict construction ordevelopment in all five FEUs and to prevent residential land use in industrial FEUs 4, 6, and 8.Wetland mitigation would be performed as required to comply with ARARs.


Alternative VI provides reduction in risk to human receptors using a 10"6 risk target forresidential FEUs 2 and 3 and for industrial FEUs 4, 6, and 8. This alternative providesminimal adverse risk to ecological receptors. The ecological risk of exposure to residualconcentrations following implementation of this alternative is expected to be acceptable. The useof excavation to remove relatively high chemical concentrations from the soil column, wouldincrease the protectiveness of this alternative.

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Adverse impacts to the existing ecosystem would be high due to the relatively extensive excavationareas that are included in Alternative VT. In general, excavation would result in a greater degree ofecological impact than a 6-inch or 12-inch cover due to total destruction of the existing habitat.This alternative would result in less potential for long term ecological impacts caused by leaving thecontaminants in place.


The excavation and backfilling included in Alternative VI would comply with potential ARARs.The response areas would require wetland mitigation and/or demonstration of no adverse impactsunder the Clean Water Act and E.O. 11990 (Protection of Wetlands). These alternatives areexpected to comply with all other potential location-specific and action-specific ARARs. There areno potential chemical-specific ARARs.


Alternative VI would result in a high reduction in human health risk. Soil excavation andbackfilling are highly reliable controls. O&M of the selected off-site landfill would be required toinsure the reliability of this alternative. The long-term ecological risk from implementing theremedy is acceptable since the excavation backfill material would be supportive of vegetativegrowth. The ecological system would recover in the long term, although the recovery time isexpected to be greater than for the cover areas specified in other alternatives. Interim erosioncontrol methods would be used during the revegetation period. The excavation and backfilling tooriginal grade would may be expected to have a relatively low impact to the site hydrology. Theuse of excavation to remove relatively high chemical concentrations from the soil column, wouldincrease the long-term effectiveness and permanence of this alternative.


Excavation and backfilling with clean material is an irreversible, permanent remedy, but off-sitedisposal without treatment would be reversible. Thermal treatment would result in a reduction intoxicity, mobility, and volume of contaminants in soil with PCB concentrations greater than 500mg/kg.


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Alternative VI would involve a minimal risk to the community from airborne particulates andvehicular traffic during excavation and backfilling. Increased risk to the community would beassociated with the off-site transport of contaminated soils. Workers would need protectionagainst dermal contact and dust inhalation during excavation and backfilling activities. Moderate tohigh environmental impacts are anticipated from excavation, backfilling, and re-establishingvegetation. Implementation of Alternative VI, through the initial planting of replacementvegetation, is expected to be completed within a 1 year time period.


Standard construction equipment and techniques would be utilized during implementation of thisalternative. Hydric compatible soils to be used for backfill may not be readily available, but couldbe obtained through on-site or off-site mixing of available materials, such as clay and organiccompost. Specifications for hydric-compatible soil would be developed so that the soil type isappropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialerosion of excavation backfill areas. Implementation is expected to require coordination withUSEPA, Ohio EPA, and the U.S. Army Corps of Engineers.

6.6.7 Cost

Details regarding the costs associated with this alternative are presented Table 6-6 A summary ofthe costs is as follows:

• Alternative VI - Direct Costs = $22,093,000- Annual O&M = $ 73,000- 30-year Present Worth = $22,913,000


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6.7 ALTERNATIVES VII - COVER, EXCAVATION, BACKFILL AND ON-SITEDISPOSAL

Alternative VH involves a combination of: 1) containment using 6-inch hydric compatible soilcover; and 2) excavation, hydric-compatible soil backfill, and on-site disposal. The total estimatedcontainment areas and excavation volumes are as follows:

• Alternative VH - Containment Area = 160,000 sq ft (4 acres)- Excavation Volume = 15,300 cu yd

The containment areas and excavation volumes are based on the PCB target concentration valuesdescribed in Section 5.0. The total remedial response area (including both the containment andexcavation areas) is estimated at 572,000 sq ft (13 acres). Institutional controls are also included inAlternative VII. The institutional controls, as described in Section 5.0, include deed restrictions orpermanent covenants to restrict construction or development in all five FEUs and to preventresidential land use in industrial FEUs 4, 6, and 8. Excavation would be limited to a depth of 12inches. Long-term maintenance and post-remediation chemical sampling would be required forboth the cover and excavation areas, wetland mitigation would be performed as required to complywith ARARs.


Alternative VII provides a reduction in risk to human receptors using a risk target at or below10 xlO"6 for residential FEUs 2 and 3 and a risk target of 3 x 10"6 for industrial FEUs 4, 6,and 8. A 30 mg/kg target PCB response level for excavation in residential FEUs 2 and 3 anda 50 mg/kg PCB target response level for excavation in industrial FEUs 4, 6, and 8 are used inthis alternative. In addition, this alternative provides a reduction in risk to human receptorsusing an 80 mg/kg hexachlorobenzene target response level for excavation in FEUs 2 and 3and a 200 mg/kg hexachlorobenzene response level for excavation in FEUs 4, 6, and 8. Areduction in risk is also provided by the cover in FEUs 2 and 3 which will be placed overresponse areas having PCB concentrations ranging from 6 to 30 mg/kg. This alternativeprovides minimal adverse risk to ecological receptors. The ecological risk of exposure toresidual concentrations following implementation of this alternative is expected to be acceptable.Specific post-remediation residual ecological risks that have been calculated for Alternative VII are


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maintenance activities and inspections (and repairs if necessary) to be conducted each year for thisalternative will help ensure that the remedy will remain protective, long-term effective andpermanent.


Containment and excavation are both permanent remedies, but do not involve a reduction intoxicity, mobility, or volume through treatment. Excavation and backfilling with clean materials isirreversible.


Alternative VII would involve a minimal risk to the community from airborne particulates andvehicular traffic during cover construction and excavation. Increased risk to the community wouldbe associated with the on-site transport and disposal of contaminated soils. Workers would needprotection against dermal contact and dust inhalation during construction and excavation activities.Moderate environmental impacts are anticipated during cover placement, limited excavation andbackfilling, and while re-establishing native vegetation. Implementation of Alternative VIIincluding construction of an on-site landfill, is expected to be completed within a 2 year timeperiod.


Standard construction equipment and techniques would be utilized during implementation of thisalternative. Hydric compatible soils to be used for cover and backfill may not be readily available,and may have to be obtained through on-site or off-site mixing of available materials, such as clayand organic compost. Specifications for hydric-compatible soil would be developed so that the soiltype is appropriate to support wetland vegetation. The specified mix would be verified duringimplementation of the remedial alternative. Routine inspections would provide notice of potentialerosion of cover or excavation backfill areas. Implementation is expected to require coordinationwith USEPA, Ohio EPA, and the U.S. Army Corps of Engineers.

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discussed in Appendix A. The use of excavation to remove relatively high chemical concentrationsfrom the soil column, would increase the protectiveness of this alternative. The post-remediationchemical sampling, evaluations of sampling results, and operation and maintenance activities andinspections (and repairs if necessary) to be conducted each year for this alternative will help ensurethat the remedy will remain protective, long-term effective and permanent.

Adverse impacts to the existing ecosystem within each FEU would be moderate considering thetotal amount of excavation and cover associated with Alternative VII. In general, the excavationareas would involve greater ecological impacts due to total destruction of the existing habitat.However, excavation would result in less potential for long term ecological impacts than a coversince the contaminants are not left in place.


The excavation and cover placement included Alternative Vn are expected to comply withpotential ARARs, and result in moderate adverse impacts to wetlands. Since both the excavationbackfilling and cover placement would change the site topography, the response areas wouldrequire wetland mitigation and/or demonstration of no adverse impacts under the Clean Water Actand E.O. 11990 (Protection of Wetlands). There are no potential chemical-specific ARARs.


Alternative VII would result in a high reduction in human health risk in FEUs 2 and 3 and a highreduction in human health risk in FEUs 4, 6, and 8. The cover would be reliable and protective ofhuman health and the environment with proper maintenance. The use of soil excavation is highlyreliable, and is being considered for areas with relatively high PCB concentrations. The long-termecological risk from implementing the remedy is acceptable since the excavation backfill and soilcover material would be supportive of vegetative growth. The ecological system would beexpected to recover in the long terra The recovery time is expected to be the shortest for the6-inch cover areas. Interim erosion control methods would be used during the revegetation period.The excavation and cover areas may be expected to have a relatively moderate impact to the sitehydrology. The use of excavation to remove relatively high chemical concentrations from the soilcolumn, would increase the long-term effectiveness and permanence of this alternative. Thepost-remediation chemical sampling, evaluations of sampling results, and operation and


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6.7.7 Cost


• Alternative VH - Direct Costs = $ 4,629,000- Annual O&M= $ 111,000- 30-year Present Worth = $ 5,896,000


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7.0COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES

7.1 PROTECTION OF HUMAN HEALTH AND ENVIRONMENT

All of the alternatives, except the no-action alternative, are protective of human health. However,the use of a cover to be placed in areas of relatively high chemical concentrations may reduce theprotectiveness of Alternatives II, IIIA, IIIB, and W. The use of excavation to remove relativelyhigh chemical concentrations in Alternatives V, VI, and VH, may increase the protectiveness ofthese alternatives. A 10* risk target is used in the alternatives for protection of human health in theresidential FEUs (FEU 2 and FEU 3). Alternatives IV, V, and VI also use the 10* risk target inthe industrial FEUs (FEU 4, FEU 6, and FEU 8). A 10"5 risk target is used in the industrial FEUsfor Alternative II. Alternatives HIA and IIIB use a USEPA-designated target responseconcentration for PCBs of 50 mg/kg in the industrial FEUs. The 50 mg/kg PCB concentrationcorrelates with an average residual PCB concentration of approximately 6 to 9 mg/kg and anapproximate industrial risk target of 3 x 10"6. Alternative VII uses various USEPA-designatedtarget concentrations. The excavation target concentrations used in Alternative VII were 30 mg/kgPCBs and 80 mg/kg hexachlorobenzene in residential FEUs 2 and 3, and 50 mg/kg PCBs and 200mg/kg hexachlorobenzene in industrial FEUs 4, 6, and 8.

Alternative VII also used a 6 to 30 mg/kg target concentration range for cover areas with PCBs inresidential FEUs 2 and 3. This PCB concentration is at or below the 10-6 risk target based onUSEPA's deterministic approach. Each alternative, except no action, provides reduction in risk toecological receptors. The alternatives that include cover (Alternatives II, IHA, HIB, IV, and VII)provide less adverse impact to the environment than the total excavation and backfill alternatives(Alternatives V and VI). Long term ecological risks would be associated with contaminants thatremain in-place following either cover or excavation. However, the alternatives that involveexcavation (IIIA, DIB, V, VT, and VII) would result in less potential for ecological impacts thanthe complete cover alternatives (II and IV) since the areas with relatively high chemicalconcentrations are not left in place.

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7.2 COMPLIANCE WITH ARARs

All alternatives, that involve removal of FWA soils with PCB concentrations at or above 50mg/kg (Alternatives V, VI, and VII) would comply with potential ARARs. The alternativesthat involve cover placement over FWA soils with PCB concentrations at or above 50 mg/kg(Alternatives II, IIIA, IIIB, and IV) may not comply with TSCA disposal regulations.

All remedial response areas would require wetland mitigation and/or demonstration of noadverse impacts under the Clean Water Act and E.G. 11990 (Protection of Wetlands). Thealternatives that do not include soil covers (Alternatives V and VI) would have greateradverse impacts to wetlands since they involve more excavation and backfilling No chemical-specific ARARs have been identified for the Fields Brook FWA.

7.3 LONG-TERM EFFECTIVENESS AND PERMANENCE

The soil cover used in Alternatives H, IIIA, IHB, IV, and VII is an effective and accepted approachto reduce risk. The reliability of a cover in the long term is high with proper maintenance.Appropriate cover and backfill materials would be used in all alternatives to promote growth ofdesired types of vegetation and control erosion. Interim erosion control methods would be usedduring revegetation. However, the use of a cover over areas of relatively high chemicalconcentrations may reduce the long-term effectiveness and permanence of Alternatives II, IIIA,niB, and IV. The use of excavation to remove relatively high chemical concentrations inAlternatives V, VI, and VTI, may increase the long-term effectiveness and permanence of thesealternatives.

Alternatives V , VI, and VQ afford the highest degree of long-term effectiveness and permanencebecause these alternatives use primarily excavation and backfilling to reduce risk posed by inplacesoils. The excavation and backfilling included in Alternatives niA or mB would also result in amoderate degree of long-term effectiveness and permanence.


Woodward-Clyde

Draft

7.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGHTREATMENT

Alternative VI is the only alternative that reduces the toxicity, mobility, or volume ofcontaminants through treatment. This alternative involves thermal treatment of an estimated2,000 cubic yards of soil with PCB concentrations greater than 500 mg/kg. Some residualwaste would remain following the thermal treatment. For Alternative VII, the mass of COCsin soils to be removed is lower than for any other excavation/cover alternative. This mayreduce the potential principal threat of the excavated soil relative to the other excavationalternatives.

7.5 SHORT-TERM EFFECTIVENESS

Low to moderate short-term adverse environmental impacts are expected to be associatedwith Alternatives II, IIIA, IIIB, and IV. The adverse environmental impacts for AlternativesV , VI, and VII are expected to increase and range from moderate to high due primarily to theincreased time requirement for vegetative regrowth. Minimal risk to the community isexpected from airborne particulates and vehicular traffic during cover construction. Increasedcommunity risk is associated with excavation and off-site transport of contaminated materialsin Alternatives IIIA, IIIB, V, and VI because of the unexpected potential for spills or releasesto the environment. Increased community risk is also associated with the excavation andon-site disposal of contaminated material in Alternative VII because of the unexpectedpotential for spills or releases to the environment.

Workers would require protection against dermal contact and dust inhalation duringimplementation of all alternatives except for no action. Time required to implement theAlternatives II, IIIA, IIIB, IV, V, VI, and VII is estimated at approximately 1 year, excludingthe long-term O&M.

7.6 EASE OF IMPLEMENTATION

All of the alternatives are readily implementable. Standard construction equipment,techniques, and materials are readily available. Hydric-compatible soils may not be readilyavailable and may have to be obtained through on-site or off-site mixing of available materials,

7-3L:\333FB\86C3609S\[S:\BROOKFS\FWA_FS\] ANNOUT2.DOC 10/17/96

Woodward-Clyde

Draft

such as clay and organic compost. Specifications for hydric-compatible soil would be developedso that the soil type is appropriate to support wetland vegetation. The specified mix would beverified during implementation of the remedial alternative. Routine inspections would providenotice of any cover or backfill erosion problems.

7.7 COSTS

Preliminary estimates of direct costs, annual O & M, and 30-year present worth are included inTable 6-1. There is no cost associated with the no action alternative (Alternative I). Other than noaction, the lowest 30-year present worth costs have been estimated for each alternative and areranked as follows:

• Alternative n $ 4,991,000• Alternatively $ 5,879,000• Alternative mA $ 9,700,000« Alternative mB $ 10,281,000• Alternative VII $ 5,896,000• Alternative V $ 20,491,000. Alternative VI $ 22,913,000

The costs for alternative V and VI are significantly higher than the other alternatives. EPAguidance and policy states that containment (Alternatives n, ffiA, fflB, and IV), rather thantreatment of low threat wastes, is protective of human health and the environment. Overall,Alternative VII is more cost-effective than the other Alternatives since it provides adequateprotection of human health and environment, and has a relatively low cost.

7-4L:\333FB\86C3609S\ISABRCJOKFS\FWA_FS\1ANNOUT2.DOC 10/17/96

Woodward-Clyde

Draft

8.0SUMMARY OF COMPARATIVE ANALYSIS

Comparative analysis of the remedial alternatives indicates that all of the alternatives, exceptno action, are generally protective of human health and provide reduction in risk to ecologicalreceptors. However, the use of a cover in areas of relatively high chemical concentrationsmay reduce the protectiveness of Alternatives II, IIIA, IIIB, and IV. The alternatives thatinclude soil covers (Alternatives II, IIIA, IIIB, IV, and VII) have less adverse impact towetlands than the total excavation and backfilling alternatives (Alternatives V and VI). Theadverse environmental impact of excavation and backfilling must be considered whenevaluating the potential benefit. The primary benefits of excavation and backfilling versuscover alternatives appears to be the increased level of protectiveness, long-term effectiveness,and permanence. These benefits may be outweighed by short-term adverse environmentalimpacts to the floodplain/wetland areas and appears to be most warranted for areas withrelatively high PCB concentrations, such as the areas outlined for Alternatives IIIA, IIIB, andVII. Wetland damage through either excavation or cover can be mitigated with properreconstruction of the wetland. Thus, the adverse environmental impacts caused beimplementation of any of the alternatives are short-term and would be reversible. Detailedanalysis of the alternatives indicate that Alternative VII provides the most cost-effectivemethod of disposal for soil to be excavated from the FWA.


Woodward-Clyde

Draft

9.0SUMMARY OF COMPARATIVE ANALYSIS

9.1 CONSTRUCTION IMPACT ASSESSMENT

Assessment of impacts on biological resources from construction activities associated withremediation measures identified in Alternative VII will be presented in conjunction with theintegrated SOU and FWA Design. The Construction Impact Assessment will combine theSOU remedial activities and potential remedial FWA activities so as to integrate the twoprojects and provide a foundation for future Contingency Design Studies. The assessmentwill include a description of existing biological resources; assessment of the impact of coverplacement; excavation and backfilling; and potential mitigation measures.

L:\333FB\86C3609S\fSABRCOKFS\FWA_FS\JANNOUT2.DOC 10/17/96

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10.0REFERENCES

Gradient Corporation, EA Engineering, Science, and Technology, Inc., and Woodward-ClydeConsultants 1995. Integrated Baseline Risk Assessment for the Fields BrookFloodplain/Wetlands Area. October.

USEPA, 1985, Final Remedial Investigation Report, Fields Brook Site, Ashtabula, Ohio.WA19.5L45.0,W65246.C.

USEPA. 1986. Record of Decision, Remedial Alternative Selection, Fields Brook SedimentOperable Unit, Ashtabula, Ohio.

USEPA. 1988a. Guidance for Conducting Remedial Investigations and Feasibility Studies UnderCERCLA. EPA/540/G-89/005. OSWER Directive 9355.3-01, Interim Final. October.

USEPA. 1988b. CERCLA Compliance With Other Laws Manual, Draft Guidance.EPA/540/G89/006. August.

USEPA. 1989. Part II: Clean Air Act and Other Environmental Statues and State Requirements.EPA/540/G-89/009. August.

USEPA. 1989b. Risk Assessment Guidance for Superfimd, Volume II. EnvironmentalEvaluation Manual. EPA/540/189/001. March.

USEPA. 1994. Ecological Risk Assessment Guidance for Superfund: Process for Designing andConducting Ecological Risk Assessments. USEPA, Environmental Response Team.Edison, NJ, September 26, Review Draft.


Woodward-Clyde

TABLES

TABLE 4-1POTENTIAL LOCATION-SPECIFIC ARARSFIELDS BROOK SITE - FLOODPLABV/WETLAND AREASASHTABULA, OHIO

DRAFT

Requirement PotentiallyApplicable

PotentiallyRelevant andAppropriate

Comments

Location-Specific Laws/Requirements

FEDERAL REGULATIONS

E.O. 11988 Protection of Floodplains

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 area 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]

Yes The FWA is located within a 100-yearfloodplain. If remedial activities are conductedwithin the floodplain, or adversely affect naturalfloodplain values, this regulation will beapplicable.

E.O. 11990 Protection of Wetlands

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

Clean Water Act Section 404

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

Wetlands are present along portions of FieldsBrook. Regulations are applicable only ifremedial activities impact the wetlands areas.

Wetlands occur along Fields Brook; regulationswould be applicable only if the remedialactivities impact the wetlands areas and/or otherwaters of the United States.

L:\333FB\86C3609S\2TABLE.4-1 Page 1 of 7 10-03-96

TABLE 4-1 (Continued)POTENTIAL LOCATION-SPECIFIC ARARSFIELDS BROOK SITE - FLOODPLAIN/WETLAND AREASASHTABULA, OHIO

DRAFT



Comments

4. Prohibits discharge of dredged or filled material into waters of Yesthe 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 or Yesaffecting navigable waters. [33 USC 403, 33 CFR 320-330]

Endangered Species Act

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

Fish and Wildlife Coordination Act

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

No Regulations would be applicable if the remedialaction involves dredge and/or fill activities inFields Brook

If the remedial activity affects navigable waters,these regulations are applicable.

If there are threatened/endangered (T/E) speciesor critical habitats within the areas impacted bythe remedial activities, this regulation would beapplicable. No such endangered species areknown within the area.

If Fields Brook will be impacted by remedialactivities, this regulation would be applicable.



DRAFT



Comments

National Historic Preservation Act (NHPA)

8. Requires the preservation of historic properties included in or Noeligible for the National Register of Historic Places and tominimize harm to National Historic Landmarks. [16 USC 470et seg.; 40 CFR 6.301(b); 36 CFR Part 63, Part 65, Part 800]

Wilderness Act

9. Limits activities within areas designed as wilderness areas or NoNational Wildlife Refuge Systems. [16 USC 1311,16 USC 668; 50 CFR 53, 50 CFR 27]

Wild & Scenic Rivers Act

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

No This Act would only be applicable if culturalresources at the site are eligible for inclusion onthe National Register of historic places. Noneare known.

No The site is not within a federally owned areadesignated as a wilderness area or a NationalWildlife Refuge System.

No Neither Fields Brook nor its receiving stream islisted as a Wild and Scenic River.

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]

No No

Does not apply to normal construction activity,just industrial sources.



DRAFT



Comments

Fish and Wildlife Coordination^ Act

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

Yes No This Act would only be applicable if:(1) pollutants or dredge and fill are dischargedinto a body of water or wetlands, and/or (2)dams, levees, impoundments, stream relocation,rip-rap or channeling jctivitv. and/or waterdiversion structures are constructed, and/or anyother construction activity within or in thevicinity oj" the stream which affects fish orwildlife.

Resource Conservation and Recovery Act fRCRA)

13.

14.

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

Yes No

Landfills may not be located within vulnerable hydrogeologyareas. [RCRA 3004 (o)(7)].

Yes No

Potentially-applicable This requirement wouldonly appJY to permanent hazardous wastelandfill located within the site and locatedwithin a 100-year floodplain. Interim storagedoes not need to attain ARARs. if theappropriate interim storage requirements aremet.

This requirement eewW would only apply, if alandfill is proposed to be placed within avulnerable hydrogeology area.

L:\333FB\86C3609S\2TABLE.4-] Page 4 of 7 10-03-96


DRAFT



Comments

Toxic Substances Control Act (TSCA1

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

Yes No

STATE STATUTES AND REGULATIONS

Ohio Hazardous Waste Siting Criteria

1. A hazardous waste facility installationTand operation permitshall not be approved unless it provesrthatrthe facilityrepresents the minimum risk of all of the following:

(i) Contamination of Ground and Surface Water(ii) Fires or ExplosionsjTQm Treatment. Storage or Disposal

Methods(iii) Accident during Transportation(iv) Impact on Public Health and Safetyfv) Air Pollution(yj) Soil ContaminationfORC 3734-06 fD) (6) (d)1

Yes Yes

These regulations would apply if a remedyincludes construction of a TSCA landfill or if aremedy^ncliides disposal rof material thatcontains PCB concentrations at or greater than50 me/kg. Interim storage does not need toattain ARARs if appropriate interim storagerequ i rements are met

Would be an ARAR if the remedy involvedtreatment, storage ror disposal of hazardouswaste.



DRAFT



Comments

2. Prohibits the following locations for treatment, storage, and Yesdisposal of acute hazardous waste: (U within 2.000 feet of anyresidence, schoolT hospita^ jail, or prison: (2) any naturallyoccurring wetland: (3) any flood hazard area: (4) within anystate park or national park or recreation area.fORC 3734.05 (DX6)fcyh)1

Ohio Solid Waste Regulations

I. Specifies locations in which solid waste landfills are not to be Yessited. rOAC 3745-27-07 (A) (B)l

Qhio^Groundwater Well Regulations

1. Mandates that groundwater wells be: (1) located and Yes

Yes Would be an ARAR if the remedy involvedtreatmentLstorage. or disposal of acutehazardous waste.

Yes

Mandates that groundwater wells be: (H located andmaintained so as to prevent contaminants from entering a welland (2) located to be accessible for cleaning and maintenancefOAC 3745-9-04 (A) and (B)1

No

Applicable if remedy involves the establishmentof solid waste landfill. Also mav prohibitleaving waste in place in certain unfavorablelocations.

Applies if remedy chosen includes theinstallation of groundwater monitoring wells.



DRAFT



Comments

Ohio Hazardous• _Waste_Management Regulations

I. Facilities where treatment, storage, or disposal of hazardous Yeswaste 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 waste Nois 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 waste Noin salt domes, salt bed formations, underground mines, or cavesis prohibited. [OAC, Title 3745, Chapter 54, Section 18]

No

No

Potentially applicable to permanent hazardouswaste landfill located within the site, andlocated within a floodplain. Interim storagedoes not need to attain ARARs if appropriateinterim storage requirements are.met.

No treatment, storage, or disposal takes placewithin 61 meters of a fault.

No actions involve the placement of hazardouswaste in any of these units.


TABLE 4-2POTENTIAL ACTION-SPECIFIC ARARSFIELDS BROOK SITE - FLOODPLAIN/WETLAND AREASASHTABULA,OHIO

DRAFT



To BeConsidered

(TBC) Comments

FEDERAL REGULATIONS

Toxic Substances Control Act (TSCA)

1. Establishes regulations to govern the storage and disposal Yesof PCBs including PCB-contaminated soil. [40CFR761]

2. TSCA Spill Cleanup Policy [40 CFR 761, Subpart G] No

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

4. Dredged materials that contain 50 ppm of PCBs or greater Yesmust be disposed of in an incinerator or chemical wastelandfill, as specified in the regulations. [40 CFR761.60(a)(5)]

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

No

No

No

No

No

No

Yes

No

No

No

TSCA regulations for storage and disposal couldbe applicable to disposal of PCB contaminatedsoils.

The TSCA PCB Spill Cleanup Policy is not apotentially applicable or relevant and appropriaterequirement for Superfund response actions (see59 FR 62793-94).

These regulations would apply if materialscontaining PCBs are disposed.

Applicable if dredged materials containing at least50 ppm of PCBs are disposed.

Only applicable for alternatives that includedisposal of TSCA materials.

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TABLE 4-2 (Continued)POTENTIAL ACTION-SPECIFIC ARARSFIELDS BROOK SITE - FLOODPLAIN/WETLAND AREASASHTABULA,OHIO

DRAFT



To BeConsidered

(TBC) Comments

Clean Air Act

National Ambient Air Quality Standards (NAAQS)

6. Establishes ambient air quality standards to protect public Yeshealth and welfare. Includes National Primary andSecondary Ambient Air Quality Standards for ParticulateMatter. [40 CFR 50]

Ambient Air Monitoring

7. Specifies methods for conducting ambient air monitoring. Yes[40 CFR 53]

Clean Water Act

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

Yes

No

No

No Only applicable if criteria pollutants aredischarged to the atmosphere during wastehandling or a treatment process. NAAQS wouldbe used to compare ambient air quality during theremedial action.

No Would only be applicable to actions resulting inemission of criteria.

No Regulations would be applicable if the remedialaction involves dredge and/or fill activities inFields Brook.

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DRAFT



To BeConsidered

(TBC) Comments

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.[40CFR 122.435l23,apdl25are involved!

Yes No No permit would be required for an on-siteCERCLA remedial action that involves adischarge, but the substantive requirements of theNPDES program would apply if the remedialaction involves surface water discharge. Theremedial actions at the Fields Brook FWA willlikely include point source discharges. This ARARis expected to be applicable to all of the FWAremedial alternatives.

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. [40CFR 131]

National Pretreatment Standards11. Establishes general and specific standards for pollutants

that 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]

No Yes No

Yes

Yes No

Relevant and appropriate if contaminants arereleased to surface waters.

No If the remedial action involves discharging to aPOTW, these standards would be an ARAR.

No No storm water permit would be required for anon-site CERCLA remedial action that involves adischarge. Substantive requirements (e.g.,StormWater Pollution Prevention Plans) could beapplicable, e.g. for construction activities.

L:\2I lFB\86C3609S\TABLE4-2. WPS 3 of 24 October 9. 1996


DRAFT



To BeConsidered

(TBC) Comments

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 DisposalRegulations

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 facilities. [40 CFR 260 et al]. SpecificRCRA TSD regulations that may need to be evaluated aspotential ARARs on a case-bv-case basis include:a) 40 CFR 268 (movement of excavated materials)

40 CFR 6. Appendix ARCRA 3003

No Yes No

Yes No No

b)c)d)e)0

g)h)

40 CFR 262 and 26340 CFR 170-179EPA Hazardous Waste Permit Program (promulgatedin part as 40 CFR 300.440(9/22/93)).RCRA Section 300540 CFR 270 and 124

Would be potentially relevant and appropriaterequirement for management of hazardous wasteat the sites

Would apply if hazardous wastes are generated atthe site. Contaminated soils in the FWA are notknown to be hazardous wastes pursuant to RCRAor the Ohio solid waste disposal statute. Even ifcontaminated soil were considered solid orhazardous waste, designation of a correctiveaction management unit would allow movement ofsoil without triggering the Land DisposalRestriction regulations.

<) 50 FR 45933 (11/5/85)



DRAFT



To BeConsidered

(TBC) Comments

15. Specifies requirements for closure of hazardous waste Yesmanagement units. [40CFR 264.117(c),228(a) and (b),and 310(a) and (b)]

16. These regulations establish standards for design Yesinstallation 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 of Yeshazardous 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 solid Yeswaste disposal facilities [40 CFR 258]

No

No

No

No

No No

No No

Some of these requirements would apply ifcontainment or other on-site disposal of RCRAregulated waste is a chosen alternative.These regulations would apply if remediesselected include installation of a dike around awaste management unit.

Substantive requirements would be potentiallyapplicable if hazardous wastes are generatedduring remedial activities and disposal is off site.However, only applicable if no equally or morestringent state regulation exists.

Substantive requirements would be potentiallyapplicable if solid wastes are generated duringremedial activities. However, only applicable if noequally or more stringent state regulation exists.

L:VZ 11FB\86C3609S\TABLE4-2.WPS 5 of 24 October 9, 1996


DRAFT



To BeConsidered

(TBC) Comments

STATE STATUTES (OHIO REVISED CODE)

Ohio Air Emission Standards. General

1. Air emissions must be in compliance with_SecJ_37Q4_andany rules^ permits, orders, and varianceJssued pursuant to Yesthat section. [QRC Sec. 3704.05fA).(B). (C)1

2. Prohibits the emission of paniculate matter, dust, fumes.gas. mist. smoke, vaporôr odorous substances that Yesinterfere rwiththecornfortable^cniovment ofÎjfejn;property or is injurious to public health. fORC Sec.3734.02(1)1

3. Requires explosive gas monitoring plans for sanitary Yeslandfills and provides authority to the Director of OhioEPA to order an owner or operator of a facility toimpjementân explosive easjônitoring^jind^reporting plan.fORC Sec. 3734.04.UA).(C). (D). (G>1

No

No

No

No Applies to any air emissions resulting fromremedial activities.

No May be applicable if the remedial action choseninvolves air emissions, (e.g. from constructionactivities during remedial action).

No May be applicable if the remedy selected includesconstruction of a landfill on-site.

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DRAFT

RequirementPotentially To Be

Potentially Relevant and ConsideredApplicable Appropriate (TBC) Comments

Ohio Water Pollution Statutes

1. Pollution of waters of the state is prohibited. FORC Sec. Yes6111.041

2. Sites with point source discharges must comply with Yesnational effluent standards. TORC Sec. 61111.04.21

3. Prohibits failure to comply with requirements of Sections6111.01to 6111.08or any rules, permit or order issued Yesunder those sections. fORC Sec. 6111.071

Ohio Nuisance Statutes

1. Prohibits noxious exhalations or smells and the obstruction Yesof waterways. TOAC 3767.13**check with Ohio EPA re.cites* *1

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

No

No

No

No

No

No

No

No

No

No

Would apply if remedial activities include La pointsource discharge, such^ of waste watersgenerated during dewaterine or decontaminationactivities.

Would apply if remedial activities could impactwaters of the state.

Would apply if remedial ctivities could impactwaters of the state.

Applies if remedial activities involve noxiousexhalations or smells or the obstruction ofwaterways.

Potentially applicable if remedial activities involvedischarge of waters.



DRAFT



To BeConsidered

(TBC) Comments

STATE REGULATIONS (OHIO ADMINISTRATIVE CODE)

Ohio Non-Point Source Regulations

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

Yes No No

Ohio Water Quality Standards

1. Specifies analytical methods and collection procedures forsurface water discharges. [QAC 3745-1-031.

2. Alljurface waters of the state shall be free from:(aj Objectionablg^suspended soils,fb) Floating debris, oil, or scum(c) Materials that create a nuisance.(d) Toxic, harmful oriilethali substances,(e) Nutrients that create nuisance growth

TOAC 3745-1-041

3. Prevents degradation of surface v/ater qua!ity, belowdesignated use or existing water quality.fOAC 3745-1-05 (A) fB) (C)l

4. Criteria for establishing thermal and^non^thermal mixingzones for point source discharges.fOAC 3745-1-06 (A) (B)1

Yes

Yes

No

No

No

No

Yes

Yes

No

No

No

No

These regulations could be applicable for anymajor earth-disturbing activities.

Would be applicable to discharge to surface wateras a result of remediation and any on-site surfacewaters affected by site conditions^

Would be applicable to discharge to surface wateras a result of remediation and any on-site surfacewaters affected by site conditions.

Requires that best available technology (BAT) beused to trcata surface water discharges.

Applies if remedy involves point source discharge.

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DRAFT



To BeConsidered

(TBC) Comments

5. Establishes water quality criteria for pollutants that do nothave specific numerical or narrative criteriaTOAC 3745-1-071

6. Establishes water use designations for stream segmentswithin the Ashtabula River Basin.[QAC 3745-1-141

7. Establishes water use designations for stream segmentswithin the Lake Erie Basin.FOAC 3745-1-311

Ohio Air Quality Regulations

1. Prohibition of air pollution nuisances fOAC 3745-15-07

2- Ambient air quality standards for total suspendedparticulates fOAC 3745-17-02 fA) fB) (C)1

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

4. Restrictions for control of fugitive dust emissions fOAC3745-17-08 (AH (A2) fB) (D)1

5. Air quality standards for carbon monoxide, ozone, andnon-methane hydrocarbons. TOAC 3745-21-02(A) fB)

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

Ng

No

No

No

No

No

No

No

No

No

Would be applicablejtoLdischarge.rto..rsur_face_wat_eras a result of remediation and any on-site surfacewaters affected bv site conditions.

Applies if a stream or stream segment is on siteand is either affected by site conditions or if aremedy includes a direct discharge.

Applies if a stream or stream segment is on siteand is either affected bv site conditions or if aremedy includes a direct discharge.

Applies to remedial activities that may cause airpollution nuisances.

Applies to air emissions that result from remedialactivities (e.g..excavation and cover placement).

Applies to paniculate emissions from a stacks andfugitive emissions sources. Construction activitiesduring remedial work must comply with theserequirements.

Applies to air emissions as a result of remedialactivities, (e.g..excavation and cover placement).

Applies if remedy involves emission of carbonoxides or non-methane hydrocarbons.

LA211FB\86C3609S\TABLE4-2.WP5 9 Of 24 October 9, 1996


DRAFT

Requirement

Potentially To BePotentially Relevant and ConsideredApplicable Appropriate (TBC) Comments

6.

7.

8.

9.

Measurement methods to determine ambient air qualityfor carbon monoxide, ozone, and non-methanehydrocarbons.TOAC 3745-21 -03 (B) (O (D)1

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

Control requirements for emissions of organic materialsfrom stationary sources fOAC 3745-21-07 (A) (B) (E) (I)

Requirements for carbon monoxide emissions fromstationary sources fQAC 3745-21 -08 (A-E)l

10. Emis.sJQn_c_QntrQl program requirements for preparationfor air pollution alerts warnings and emergencies^[QAC 3745-25-031

Ohio Solid Waste Regulations

1. Defines exemptions to solid waste regulations andestablishes limitations on temporary storage^of putresciblewaste or any solid waste which causesi__a nuisance or healthhazard [QAC 3745-27-03 CB)1

2. Establishes allowable methods of solid waste disposal.TOAC 3745-27-06 (A) (B) (CH

3. Specifies the minimum technical information required as^asolid waste permit to install. TOAC 3745-27-06(6) (C)1

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

Applies if remedy involves emission of carbonoxides or non-methane hydrocarbons.

Applicable if remedy^ involves emission of carbonoxides and non-methane hydrocarbons.

Applies if remedy involves emission of organicmaterials.

Applies if remedy involves emission of carbonmgnoxide^

Applies to remedial activities that may emit aircontaminants.

Applies to any solid waste that will be managedduring.the remedial activities.

Applies to any solid waste that will be managedduringjhe remedial activities.

Applies to any new solid waste disposal facilitycreated on site.

L:\211FB\S6C3609S\TABLE4-2.WP5 10 of 24 October 9, 1996


DRAFT

4.

Potentially_, . . Potentially Relevant andRequirement . . . . .Applicable Appropriate

Additional sitine requirements with respect to ecology. Yes Nowater supplies, occupied properties, parklands and minesubsidence areas. TOAC 3745-27-07 (D) (F) (G) (H)l

To BeConsidered _

/rnm Comments(1BC)

No Applies to anv new sanitary landfills for solidwaste disposal.

5. Construction specifications for sanitary landfills. FOAC Yes3745-27-08 fC) (D-HM

6. Final closure of sanitary landfill facilities fOAC 3745-27-11 Yes

7. Established when an explosive ^as monitoring plan is Yesrequired for solid waste landfills. fOAC 3745-27-11 fA>(E) (D) (E) (M) (Nil

8. Identified parameters and schedule for explosive gas Yesmonitorine. fOAC 3745-27-12 fn mi

9. Requires that a detailed plan be provided to describe how Yesanv proposed filling, grading, excavating, building, drillingor mining on land where a hazardous waste facility.or^solidwaste facility was operated will be accomplished.

10. Specifies the required^ post-closure care for solid waste Yesfacilities. fOAC 3745-27-14 (A)1

11. Specifies general operational requirements for solid waste Yeslandfills. [QAC 3745-27-19fE)l

No

No

No

No

No

No

No

No

No

No

No

No

No

No

Applies to any new^ solid waste disposal facilitycreated on_site.

Substantive requirements apply to anv new solidwaste landfills created on site.

Applies to anv site which has had or will haveputrescible solid wastes placed on site and whichhas a residence or other occupied structurelocated jvitfain 1000 feet of the emplaced solidwaste.Applies to anv disposal site where explosive gasgeneration and migration may be threat.

Applies to any site at which hazardous or solidwaste has been managed.

Substantive requirements apply to any newlycreated solid waste landfill on site.

AppIiesjQ anv new solid waste disposal facilitiescreated on site.

L:\2I IFB\86C3609S\TABLE4-2.WP5 11 of 24 October 9, 1996


DRAFT

12.

13.

14.

15.

16.

17.

18.

Requirement

Requires the owners/operator to implement measures toattain compliance with requirements of these rules.rOAC 3745-27-19 (D) (2)1

Includes requirements for daily cover and intermediatecover for temporarily inactive areas. fOAC 3745-27-19 (F)MLIncludes requirements for the final cap system for areas atfinal elevations. [OAC 3745-27-19(H)l

Requires owners/operations to conduct a program todetect PCB waste and hazardous waste prior todisposal. fOAC 3745-27-19 CD1

Surface water requires to be diverted from areas wheresolid waste is being, or has been, deposited. FOAC 3745-27- 19 mi

Requires repair of leachate outbreaks: collections andtreatment of leachate on the surface of the landfill. [OAC3745-27- 19 (K)l

Specifies certain operational and location standards forlandfills accepting waste after June 1. 1994.[OAC 3745-27-201

PotentiallyApplicable

Yes

Yes

Yes

Yes

Yes

Yes

Yes


No

No

No

No

No

No

No

To BeConsidered

(TBC)

No

No

No

Yes

No

No

No

Comments

Applies to any new solid waste disposalcreated on site.




Applies to anv new solid waste disposalcreated on site.



facilities

facilities

facilities

facilities

facilities

Jacilities

facilities



DRAFT



To BeConsidered

(TBC) Comments

Ohio Air and Water Pollution

1. Requires that a permit to install (PTO or plans must Yesdemonstrate best available technology (BAT)_and shall notinterfere with or prevent the attainment or maintenance ofapplicable ambient air quality standards. [QAC 3745-31-06]

Ohio Section 401 Regulations

1. Specifies substantive criteria for Section 401 water quality Yescriteria for dredging, filling, obstructing, or altering watersof the state. [OAC 3745-32-06]

Ohio Hazardous Waste Management Regulations

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

Yes

No

Yes

No Applies if waste water is discharged via a pointsource to surface-waters. Wastewater maybegenerated from soil dewatering or fromdecontamination activities. It is not anticipatedthat air pollution equipment will be used.

No Would apply if remedial activities includedredging, filling, obstructing, or altering waters ofthe state.

No Substantive requirements are potentiallyapplicable if remedial actions involve generation,transportation, treatment, storage, or disposalactivities that are identified in the specificregulations listed. Substantive requirements arepotentially relevant and appropriate if remedialactions involve management of material as ahazardous waste.



DRAFT

1.

2.

3.

4.

5.

6.

7.

8.

9.

Requirement

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

Specifies permit information required for all hazardouswaste land disposal facilities. fOAC 3745-50-44(6)1

Establishes substantive permit requirements for containerstorage. [OAC 3745-50-44(0 (1)1

Establishes substantive permit requirements for surfaceimpoundments [OAC 3745-50-44(0 (4)

Establishes substantive permit requirements for hazardouswaste surface impoundments, waste piles, land treatmentunits, landfills, and underground iniection wells. FOAC3745-50-44(0(6)1

Establishes substantive permit requirements for hazardouswaste landfills. [OAC 3745-50-44(0(7)1

Establishes substantive hazardous waste permitrequirements for miscellaneous units.

Exempts the residues of hazardous wastes from emptycontainers. rOAC 3745-5 1-07 (A) (B)1

Requires that waste generators determine whether thewaste is hazardous. FOAC 3745-52-1 HA) through (D)l


Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes


Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

To BeConsidered _

(TBC) Comments

No

No

No Applies if container storage occurs on site for asignificant length of time.

No Applies if surface impoundment is used as part ofdewatering system during remedial action.

No Applies if unit is built as part of remedial action.

No Applies if unit is built as part of remedial action.

No

No

No Applies if hazardous waste is transported off-sitefor disposal.



DRAFT



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

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

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

13. Requires a generator to package hazardous wasteinaccordance with U.S. DOT regulations for transportationoff-site. [QAC 3745-52-301

14. SpecifiesJabelinjg requirements for hazardous waste to betransported off-site. fOAC 3745-52-311

15. Specifies marking requirements for hazard^usjwaste jo betransported off-site. TOAC 3745-52-321

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

17. Specifies security requirements for hazardous wastefacilities. TOAC 374S-54-14(A) through (C)1

18. Specifies inspection requirements for hazardous wastefacilities. fOAC 3745-54-15fA).(C)1

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

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

No

Applies if hazardous waste is transported off-sitefor disposal.

Applies ifJiazardQus_waste. is transported off-sitefor disposal.

Applies if hazardous waste is transported_T off-sitefor disposal.

Applies if hazardous waste^isjransported off-sitefor disposal.

Applies if hazardous waste is transported off-sitefor disposal.

Applies if^hazardous waste is transported off-sitefor disposal.

L:\2I IFB\86C3609S\TABLE4-2.WP5 15 of 24 October 9, 1996


DRAFT

20.

21.

22.

23.

24.

25.

26.

27.

28.

Requirement

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

Requires that hazardous waste facilities be equipped withemergency equipment. fOAC 3745 -54-3 2( A) through (D)l

Requires testing of emergency equipment.(OAC 3745-54-331

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

Requires that adequate aisle space _ be maintained athazardous waste facilities. TOAC 3745-54-351

Requires arrangements with local authorities. fOAC 3745-54-37(A) and (B)l

Requires that hazardous waste facilities have a contingencyplan. fOAC 3745-54-52(A) through (F)l

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

Specifies situations requiring that the contingency plan beamended. fOAC 3745-54-54fA)1


Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Potentially To BeRelevant and Considered _. . . /Tn^.-, CommentsAppropriate (TBC)

Yes No

Yes No

Yes No

Yes No

Yes No

Yes No

Yes No

Yes_ No

Yes No

L:\21IFB\86C3609S\TABLE4-2.WP5 16 of 24 October 9, 1996


DRAFT

Requirement

29. Requires an emergency coordinator. [OAC 3745-54-551

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

31. Establishes circumstances under which an operator of ahazardous waste facility must implement a ground watermonitoring program. fOAC 3745-54-901

32. Presents ground^ water monitoring and response programsrequired for hazardous land-based units. [OAC 3745-54-9UA11

33. Requires compliance with permit conditions that addressground water. fOAC 3745-54-921

34. Requires that permit specify hazardous constituents towhich the ground water protection standard of 3746-54-92applies. fOAC 3745-54-93 (A) fB)1

35. Presents the methodology for determining concentrationlimits and alternative concentration limits.[QAC 3745-54-94 ( A) fB)l

36. Establishes point of compliance at vertical surface locatedat the hvdraulicallv downgradicnt limit of the wastemanagement area that extends down into the uppermostaquifer underlying the unit(s). fOAC 3745-54-95 (A) (B)l

L:\2IIFB\86C3609S\TABLE4-2.WP5

PotentiallyPotentially Relevant andApplicable Appropriate

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

17 of 24

To BeConsidered _rrnn Comments(1BC)

No

No

No

No

No

No

No

No

No

No

October 9, 1996


DRAFT

Requirement


37. A compliance period during which the ground waterprotection standards apply will be required in the permit.[QAC 3745-54-96 (A) (B) (C)l

38. Presents requirements for_the_ ground water monitoringprogram. [OAC 3745-54-97(A) through (H)1

39. Presents requirements of ground jwater detection program.rOAC 3745-54-98 (A-I)

40. Presents requirements of ground_water_compliancemonitoring program.

41. SpecifiesLclosure^standardjLjfor hazardous waste facilities^[OAC 3745-55-1KA) through (C)1

42. Presents the required content of closure plans.[QAC 3745-55-12(6)1

43. Requires proper decontamination or disposal ofcontaminated equipment, structures, and soils. JOAC3745-55-141

44. Specifies post-closure care requirements.[QAC 3745-55-171

Yes

Yes

Yes

Yes

Yes

Yes

Yes

45. Presents the requirements of an adequate post-closureplan.fOAC 3745-55-18(6)1

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

Yes



DRAFT

Requirement


46. Requires that notice be given Jo local land authoritiesconcerning the disposaLofhazardous waste at the site, andrequires a notation to the deedjq the facility property.TOAC 3745-55-19(A) and (B)1

47. Containers holding hazardous waste musLJie maintained ingood condition (no rust or structural defects).rOAC 3745-55-741

48. Hazardous waste placed in react withthe container material or liner material. fOAC 3745-55-721

49. Containers holding hazardous waste must be closed exceptto add or remove wasteland must:__notbe'handled_jn_a_manner that may rupture the container or cause it tojeak.TOAC 3745-55-731

50. Requires at least weekly inspections of container storageareas. [OAC 3745-55-741

51. Requires that container storage areas have a containmentsystem and specifies that minimum requirements of such asystem. fOAC 3745-75 (A-D)1

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No Applies if hazardous waste will be stored incontainers.

No Applies if hazardous _waste will be^stgredjncontainers.

No Applies if hazardous waste will hectored incontainers.


No Applies if hazardous^waste will be stored mcontainers.


L:\211FB\86C3609S\TABLI:4-2.WP5 19 of 24 October 9, 1996


DRAFT

Requirement


52. Presents general precautions to be taken to preventaccidental ignition or reaction of linkable or reactivewastes that will be stored in container. [QAC 3745-55-761

Yes Yes No Applies if potentially reactive or ienitable wasteswill be stored in containers.

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 treathazardous waste that does not havejsecpndarv containmentbe tested to assure tank integrity.rOAC 3745-55-91 (A. B. D)1

56. Requires a secondary containment system for tanksassessment to determine tank integrity.[QAC 3745-55-92 (A-G)

Yes

Yes

Yes

Yes

Yes

Yes

Yes Yes

No Applies if potentially incompatible waste will bestored in container.

No Applies if hazardous waste will be stored incontajneji^

No Applies if hazardous waste will be either stored ortreated in tanks.


57. Specified general operating requirements for tank systems. Yes[QAC 3745-55-94 (A. B. C)l

58. Requires inspections at least once each operating day. YesTOAC 3745-55-95 fA-D)1

59. Requires that unfit tanks be removed from use and further Yesreleases be prevented.rOAC 3745-55-96(A. B. C. F)1

Yes

Yes

Yes


No Applies if hazardous waste will be with stored ortreated in tanks.

No Applies if hazardous waste will be with stored ortreated in tanks.

L:\2l lFB\86C3609S\TABLii4-2.WP5 20 of 24 October 9, 1996


DRAFT



60. Sg_eciFies_closu_re and postglpsure•_Requirements for tank Yessystems. fOAC 3745-55-97 (A. B)1

61. Presents general precautions to be taken to prevent Yesaccidental ignition or reaction of ignitabie or reactivewastes that are treated or stored in tanks. [OAC 3745-55-

Yes

Yes

No Applies if hazardous waste will bc_with stored ortreated in tanks.

No Applies if potentially reactive or ienitable wastesare stored or treated in tanks.

62. Presents general precautions to be taken when dealingwith potentially incompatible wastes that are stored ortreated in tanks. [QAC 3745-55-99 (A. B)1

63. Specifies thea design and^operjttion^^ requirements for wastepiles, includes liner system, leachate collection andremoval system, wind dispersal prevention and run-on/run-off control.FOAC 3745-56-51(A-F)1

64. Waste piles must rje^monitored during construction orinstallation and operations. fOAC 3745-56-54 (A. B)1

65. Specifies closure and post-closure care requirements forwaste piles. FO AC-3745-56;5 8 (A.B.C)I

66. Allows Ohio EPA the opportunitv^to inspect waste filesduring construction. TOAC 3745-56-55 (A)1

67. Specifies environmental performance standards for land-based units. [QAC 3745-57-QUA) through (D)1

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No Applies if potentially incompatible wastes arestored or treated in tanks.

No Applies if hazardous waste will be either stored ortreated in waste piles.

No

No

No

No

Applies if hazardous waste will be either stored ortreated in waste piles.

Applies if hazardous waste will be either stored ortreated in waste piles.

Applies if hazardous waste will be either storedtreated in waste piles.



DRAFT

Requirement


68. Presents design and operating requirements for landfills.fOAC 3745-57-03(A) through (1)1

69. Presents monitoring and inspection requirements forlandfills. fOAC 3745-57-05(A) and (B)l

70- Specifies closure and post-closure requirements forlandfills. fOAC 3745-57- 10(A) and (B)1

71. Prohibits the... placement_p_fbulk or non-containerizedliquid hazardous .waste, or hazardous waste containing freeliquids, in landfills. FOAC 3745-57-14(A) through (D)1

72. Allowsphio EPA opportunity^jo inspect landfill duringconstruction. [QAC 3745-57-17(A)1

73. Prohibits the placement of hazardous wastes FO20. FO21.FO22. FO23. FQ26 and FO27 in landfills.

74. Establishes location, design, construction.operation^maintenance and closure requirements for miscellaneousunits used to treat, storeL.and_dispQse:._of hazardous wastes.

75. Prohibits the use of dilution as a substitute for treatmentof restricted wastes or restricted waste residues.rOAC 3745-59-03f A) and (B)1

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

Applies if hazardous waste landfilLwill be locatedon-sitc.

Applies if a hazardous waste landfill will belocated on-site.

Applies to alternative that incorporates treatment,storage or disposaLof hazardous wastes inmiscellaneous units.

Applies to any alternative that incorporates on-site disposal of hazardous waste.

L:\211FB\86C3609S\TABLE4-2.WP5 22 of 24 October 9. 1996

TABLE 4-2 (Continued)POTENTIAL ACTION-SPECIFIC ARARSFIELDS BROOK SITE - FLOODPLAIN/WETLAND AREASASHTABULA,OH1O

DRAFT



To BeConsidered

(TBC) Comments

Ohio Groundwaler Wells Regulations

1. Specifies minimum construction requirements for new Yeseroundwater wells. fOAC 3745-9-06fA)(BKD). and fE)1

2. Establishes casing requirements for groundwater wells YesTOAC 3745-9-05(A) through (G)l

3. Establishes surface design requirements for new Yesgroundwatcr wells fOAC 3745-9-05 -07(A) through (F)1

4. Requires the disinfection of newjwells andLthc use of Yespotable water for priming pumos. fOAC 3745-9-08(A) and (C)1

5- Establ i shes maintenance ....and modificationjrequiTements Yesfor casing, pump, and wells. [QAC 3745-9-09 (A) throughfC). (DKIXE) through fG).

6. Requires that following completion of use, wells and test Yesholes be completely filled with grout or similar material orshall be maintained in compliance: with all regulationsfOAC 3745-9-10 (A) through (Ql

Ohio National Pollutant Discharge Elimination System

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

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

Yes No

Applies jfremedj^chosen includes the installationof groundwater monitoring wells.

Applies if remedy chosen includes the mstallationwells.

Applies if remedy chosen includes the installationof groundwater monitoring wells.

AppHesuf remedy chosen includes the installationof groundwaieTLjnonitoringj wells.

Applies jfremedyjchosen includes the installationof groundwater monitoring wells.

AppHesJf remedy chosen includes the installationof groundwater monitoring wells.

Applicable if the remedial action involvesdischarge to surface water located off-site orrelevant and appropriate for discharges to on-sitesurface water. Substantive requirements must bemet, but no permit will be required for on-sitedischarges.



DRAFT



To BeConsidered

(TBC) Comments

Ohio Pre-Treatment Requirements

2. Regulates the discharge of pollutants to POTWs.[OAC Title 3745, Chapter 3]

Yes No No Applicable if waste/treatment water from the siteis discharged to the POTW.


Woodward-ClydeDRAFT

TABLE 5-1ESTIMATED REMEDIAL RESPONSE AREAS AND VOLUMESFIELDS BROOK FLOODPLAINAVETLAND AREA, ASHTABULA, OHIO

RemedialAlternative

(No.)

I

n

III A

1MB

IV

V

VI

VII

ResponseArea

(sq. ft.)

0

370,000

572,000

572,000

764,000

764,000

764,000

572,000

Total EstimatedCover Area

(sq. ft.)

0

370,000

351,000

319,000

764,000

0

0

160,000

(acre)

0

9

8

7

18

0

0

4

Total EstimatedExcavation Volume

(cu. yd.)

0

0

8,300

9,300

0

28,500

28,500

15,300

CoverFEU Area(No). (sq. ft.)

2,3,4,6,8 0

2 216,0003 106,0004 10,0006 32,0008 6,000

2 108,0003 52,0004 41,0006 85,0008 65,000

2 48,0003 52,0004 46,0006 105,0008 68,000

2 216,0003 106,0004 134,0006 150,0008 158,000

2 03 04 06 08 0

2 03 04 06 08 0

2 108,0003 52,0004 06 08 0

ExcavationArea

(sq. ft.)

00000

108,00054,00024,00028,0007,000

168,00054,00019,0008,0004,000

00000

216,000106,000134,000150,000158,000

216,000106,000134,000150,000158,000

108,00054,00065,000

113,00072,000

ExcavationVolume(cu. yd.)

0

00000

4,0002,000

9001.100

300

6,2002,000

700300100

00000

8,0004,0005,0005,6005,900

8,0004,0005,0005,6005,900

4,0002,0002,4004,2002,700

NOTE: Alternative VI requires thermal treatment of estimated total of2000 cubic yards with PCB concentrations exceeding 500 mg/kg.

L:\31IFB\86C3609S\TABLE5 I.XLS 10/10/96, 9:49 AM

Woodward-Clyde

TABLE 5-2REMEDIAL ALTERNATIVES IIIA AND IIIBESTIMATED SURFACE AREAS FOR SOIL COVER AND BACKFILLFIELDS BROOK FLOODPLAINAVETLAND AREA, ASHTABULA, OHIO

DRAFT

REMEDIAL ALTERNATIVE IIIA

FEU

23468

EstimatedSoil Cover Area (sq. ft.)

6" 12"108,00052,00025,00044,00048,000

00

16,00041,00017,000

Estimated Backfill Area (sq. ft.)12" 18" 24"

Exc. Only 6" Cover 12" Cover0

37,00016,000

00

108,00017,000

000

00

8,00028,0007,000

REMEDIAL ALTERNATIVE IIIB

FEU

23468

EstimatedSoil Cover Area (sq. ft.)

6" 12"48,00052,00025,00044,00048,000

00

21,00061,00020,000

Estimated Backfill Area (sq. ft.)12" 18" 24"

Exc. Only 6" Cover 12" Cover122,00037,00016,000

00

46,00017,000

000

00

3,0008,0004,000

L:\31 IFB\86C3609S\TABLE 5_2.XLS 10/10/96,9:51 AM

TABLE 5-3RESPONSE AREA AND VOLUME BREAKDOWN

REMEDIAL ALTERNATIVE VHFIELDS BROOK FLOODPLAINAVETLAND AREA

ASHTABULA, OHIO

FEU2

3

4

6

8

DescriptionExcavate 12" where PCBs>30ppmand HCB > SO ppm; matchelevation at 6" cover over PCBbetween 6 and 30 ppm

Excavate 12" where PCBs>30pproand HCB > 80 ppm; Backfill 12",plus 6" cover over 17,000 SF tomatch elevation of 6" cover overPCBs between 6 and 30 ppm.37,000 SF backfill only.

Excavate 12" where PCBs>50 ppmor HCB > 200 ppm. Backfill 17".

Excavate 12" where PCBs>50ppmor HCBs > 200 ppm. Backfill 12".

Excavate 12" where PCBs>50ppmor HCBs>200 ppm. Backfill 12".

Total

Cover Area (3F)6"

108,000

52,000

0

0

0

160,000

12"0

0

0

0

0

0

Cover Volume (CY)6"2,000

900

0

0

0

2,900

12"0

0

0

0

0

0

ExcavationArea (SF)

108,000

54,000

65,000

113,000

72,000

412,000

ExcavationVolume (CY)

4,000

2,000

2,400

4,200

2,700

15300

BackfillVolume (CY)

4.000

2.000

2,400

4,200

2,700

15300

Cover over Backfill Area (SF)6"

108,000

17,000

0

0

0

125,000

12"0

0

0

0

0

0

Cover over Backfill Volume (CY)6"

2,000

300

0

0

0

2300

12"0

0

0

0

0

0

L:\333FB\B6C3609S\ALTRNTVS.XLS(ALTERNATIVEVII) 10/10/96, 9:52 AM

TABLE 6-1EVALUATION OF REMEDIAL ALTERNATIVESFLOODPLAIN/WETLAND AREAFIELD BROOK SUPERFUND SITE

No.

1

Criteria

OverallProtectiveness• Human Health

• EnvironmentalProtection

Alternative I:No Action

No reductionin potentialfor adversehuman healtheffects.

No reductionin risk toecologicalreceptors

Alternative IIContainment#1

;l|piifl S| Sftplilllf

Providesreduction in riskto humanreceptors using10'6 risk targetin FEUs 2 and 3and 10 5 risktarget in FEUs4,6 and 8.

Providesminimal adverserisk toecologicalreceptors; long-term risks wouldbe associatedwithcontaminantsremaining inplace.

AlternativeIHACover,Excavation,Backfill andOff-SiteDisposal

Providesreduction in riskto humanreceptors using10 6 risk targetin FEUs 2 and 3and targetresponse valueof 50 mg/kgPCBs in FEUs4, 6 and 8.Providesminimal adverserisk toecologicalreceptors; long-term risks wouldbe associatedwithcontaminantsremaining inplace.

AlternativeIIIBCover,Excavation,Backfill andOff-SiteDisposal

Providesreduction in riskto humanreceptors using10"6 risk targetin FEUs 2 and 3and targetresponse valueof 50 mg/kgPCBs in FEUs4, 6 and 8.Providesminimal adverserisk toecologicalreceptors; long-term risks wouldbe associatedwithcontaminantsremaining inplace.

Alternative IVContainment#2

s; ||;>||| | |||pil|||

Providesreduction in riskto humanreceptors using10'6 risk targetin FEUs 2, 3, 4,6 and 8.


Alternative VExcavation,Backfill andEx-SituOff-SiteDisposal

Providesreduction in riskto humanreceptors using10'6 risk targetin FEUs 2, 3, 4,6 and 8.


Alternative VIExcavation,Backfill,Treatment andOff-SiteDisposal

Providesreduction in riskto humanreceptors using10"6 risk targetin FEUs 2, 3, 4,6 and 8.


Alternative VIILimited Cover,Excavation,Backfill, andOn-SiteDisposal

Providesreduction in riskto humanreceptors using10"6 risk targetin FEUs 2 and 3and targetresponse valueof 50 mg/kgPCBs in FEUs4, 6 and 8.Providesminimal adverserisk toecologicalreceptors; long-term risks wouldbe associatedwithcontaminantsremaining inplace.

L:\2l IFB\86C3609S\TABLE6-1-DOC KV17/96

TABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVESFLOODPLAIN/WETLAND AREAFIELD BROOK SUPERFUND SITE

No.

1(con't)

2

Criteria

• EnvironmentalProtection(con't)

Compliance withARARs• Location

SpecificARARs

• ActionSpecificARARs

• ChemicalSpecificARARs

Alternative I:

No impacts onexistingecosystem.

Alternative II

Provides low tomoderateadverse impactsto environmentdue to coverplacement, (lowin FEUs 4,6 and8: moderate in(FEUs 2 and 3).

AlternativemAProves low tohigh adverseimpacts toenvironmentdue to coverplacement andexcavation (lowin FEUS;moderate inFEUs 3, 4 and6; high inFEU2).

AlternativeIIIBProves low tohigh adverseimpacts toenvironmentdue to coverplacement andexcavation (lowin FEU, 6 and8; moderate inFEUs 3 and 4;high in FEU2).

Alternative IV

Providesmoderateadverse impactsto environmentdue to coverplacement.

Alternative V

Provides highadverse impactsto environmentdue toexcavation.

Alternative VI

Provides highadverse impactstoenvironmentaldue toexcavation.

Alternative VII

Proves moderateadverse impactsto environmentdue toexcavation;lower adverseimpact to theenvironment incover areas inFEU2 and 3.

No adverseimpacts towetlands.

Not relevant forthe no actionalternative.

Complies withARARs; lowadverse impactsto wetlands dueto cover in allfive FEUs.

Complies withARARs; highadverse impactto wetlands inFEU 2;moderateadverse impactto wetlands inFEUs 3 and 6;low adverseimpact towetlands inFEUs 4 and 8.

Complies withARARs; highadverse impactto wetlands inFEU 2;moderateadverse impactto wetlands inFEUs 3 and 6;low adverseimpact towetlands inFEUs 4 and 8.

Complies withARARs; lowadverse impactto wetlands dueto cover in allfive FEUs.

Complies withARARs; highadverse impactsto wetlands dueto extensiveexcavation.

Complies withARARs; highadverse impactsto wetlands dueto extensiveexcavation.

Complies withARARs;moderateadverse impactsto wetlands dueto excavationand limitedcover.

Complies with action specific ARARs

Not relevant; no chemical specific ARARs are identified for site

L:\211FB\86C3609S\TABLE6-l.DOC lO/n/96

FABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVES?LOODPLAINAVETLAND AREA

BROOK SUPERFUND SITE

Mo.

J

Criteria

Lone-TermEffectivenessand Permanence• Relative

Magnitudeof ResidualRisk

0 HumanReceptors

• AdequacyandReliability ofControls

Alternative I:

-'.'- - i -: f ;^.;.-i i ! > 3 ;?ll£

: -I; : * elN: ^ r U^ ^~; ! *! '-' -•! £ r T-

: H: ^ '4 1-1 £ WNo reduction ofrisk for humanreceptors in anyFEUs.

Not Relevant

Alternative II

f^:-;.K ££;;;•;:-• :j

lh > i|| $'• - Js.:. •"

H l i * <l '1 1 1' f I;

1 1s !• 11 & -= ^ ; I f f jH%

•I-;: 's i ;i i: a . i i°K J

Moderatereduction of riskfor humanreceptors in allFEUs.

Cover isadequate andreliable withpropermaintenance.

Alternative niA

^•^\:^:7.^-::-//-^ -;io

"|;§lg :•;;:-:;-;; ^t !;ySftlll^M^^ ^£: HlliyiMijf ;y| |i||li|!lli -§ •!

;H!i§pi:$y il

High reduction ofrisk for humanreceptors in FEUs2 and 3.Moderatereduction inFEUs 4, 6 and 8.

Cover is adequateand reliable withpropermaintenance.Soil excavation ishighly reliable.

O&M of off-sitelandfill wouldensure reliability.

Alternative IIIB

. ;"-%;S3fp! i^^'^Wf H"S

tl Bililii HI iiSiiin1 ill 1 j|t1 |i[ ! H

High reduction ofrisk for humanreceptors in FEUs2 and 3.Moderatereduction inFEUs 4, 6 and 8.Cover is adequateand reliable withpropermaintenance.Soil excavation ishighly reliable.

O&M of off-sitelandfill wouldensure reliability.

Alternative IV

iiilt!!; ::i: :;:j;tiili>l!

|p§||pS|%;pi:}||

Moderatereduction ofrisk for humanreceptors in allFEUs.

Cover isadequate andreliable withpropermaintenance.

Alternative V

;^?4^^i- SH?S 9-P||£p|pl|fg;gla;U|sol

sliffi!^fi!Si§; y^M!

High reductionof risk forhumanreceptors in allFEUs.

Soil excavationis highlyreliable

O&M of off-sitelandfill wouldensurereliability.

Alternative VI

;ig i;;;;;.;: |:g ||||

g|||£:Si;:: i||ip^Sp^^Sliiir^P


Soil excavationis highlyreliable

O&M of off-sitelandfill wouldensurereliability.

Alternativevn

f||t |g!Sfp§H


Soil excavationis highlyreliable. Coveris adequate andreliable withpropermaintenance.O&M of on-sitelandfill wouldensurereliability.

.:\211 FB\86C3609S\TABLE6-1 .DOC

FABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVESFLOODPLAIN/WETLAND AREAFIELD BROOK SUPERFUND SITE

No.

3(con't)

Criteria

0 Revegetation

0 Erosion

RelativeHydrologicalImpact

Alternative I:

No action wouldpreserveecosystem in itspresent state.

No action wouldpreserveecosystem in itspresent state.

No hydrologicalimpact

Alternative II

Cover materialsis expected topromote desiredtypes ofvegetation.

Establishednativevegetation isexpected toprovideadequate andreliable erosioncontrol.

Interim erosioncontrol methodswould be usedduringrevegetationperiod.

Moderate tohigh impact dueto cover

AlternativemACover andbackfillmaterials areexpected topromote desiredtypes ofvegetation.



Moderateimpact due tocover

AlternativeIIIB

Cover andbackfillmaterials areexpected topromote desiredtypes ofvegetation.



Moderateimpact due tocover

Alternative IV

Cover materialis expected topromote desiredtypes ofvegetation.



Moderate tohigh impact dueto cover

Alternative V

Backfillmaterial isexpected topromote desiredtypes ofvegetation.



Low impact

Alternative VI

Backfillmaterial isexpected topromote desiredtypes ofvegetation.



Low impact

Alternative VII

Cover andbackfillmaterials areexpected topromote desiredtypes ofvegetation.


Interim erosioncontrol methodswould be usedduringrevegetationperiod.Low tomoderate impactdue to limitedcover

,:\211 FB\86C3609S\TABLE6-1 .DOC

TABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVESFLOODPLAINAVETLAND AREAFIELD BROOK SUPERFUND SITE

No.

4

Criteria

Reduction ofToxicitv, Mobilityor Volumethrough treatmentIrreversibleTreatment

Type and Quantityof ResidualsRemaining AfterTreatment

StatutoryPreference forTreatment

Alternative I:

/:-;-;v"~;::?,iSvA-:-:;":-;..:

:r^4v£p: "PS. £:^;;;^/=:=:C^ '$&&&$None

Not applicable

Does not satisfy

Alternative II

',:•••.?-,•:>:• .• - : • . ' ' ' , : " •,.:'£*

:; :^0;;.-;;--^;^

Cover ispermanent butdoes not provideirreversibletreatment.

Not applicable

Does not satisfy

AlternativefflA

i:.:";^'-fer;^?H^?P~rExcavation andbackfill withclean soil isirreversible, butoff-site disposalwithouttreatment wouldbe reversible.

Cover materialis permanent.

Not applicable

Does not satisfy

AlternativeIIIB

'-.'.-: -.'- -;''^~^-^Vo-- f--";- " ;.-

•22?. ;'i;:=%«{;--;^-^'' ::::Jij=-°ikM;.:^v?>:;'. :;

Excavation andbackfill withclean soil isirreversible, butoff-site disposalwithouttreatment wouldbe reversible.Cover materialis permanent.

Not applicable

Does not satisfy

Alternative IV

".:!-^'^'".;^: ••?•!! ^V^-.'-^K:.^

k^B-i r- -€\fe«'•:% J ; :^fl|lCover ispermanent butdoes not provideirreversibletreatment.

Not applicable

Does not satisfy

Alternative V

^:-:^Vrf;=; &<1 ; ;=;& -'•\^-M & ff j Ij; "•

|;S;';:0ii V?& ?Kl?L HS.* 1 1 S > °^: J"

Excavation andbackfill withclean soil isirreversible, butoff-site disposalwithouttreatment wouldbe reversible.

Not applicable

Does not satisfy

Alternative VI

'''.<•.- ::fv:^l:i?i::i>p;:^*"; '].-' ~-/;^.---.^ ^'-ol^;||-^-^-^:'^

sr-'L^s^-^-^feii^:i^^P§l;i^lliiExcavation andbackfill withclean soil isirreversible, butoff-site disposalwithouttreatment wouldbe reversible.

Thermaltreatment isirreversible.

Residualsremain afterthermaltreatment of soilwith PCBconcentrationsgreater than 500mg/kg.

Satisfies

Alternative VII

LI/^;^^!^ |!,&&§= ipsSlfilii?t;iExcavation andbackfill withclean soil isirreversible, buton-site disposalwithouttreatment wouldbe reversible.Cover materialis permanent.

Not applicable

Does not satisfy

L:\21IFB\R6C3609S\TABLE6-I.DOC

TABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVESFLOODPLAIN/WETLAND AREAFIELD BROOK SUPERFUND SITE

No.

5

Criteria

Short-termEffectiveness

CommunityProtection

WorkerProtection

Alternative I: Alternative II AlternativeniA

AlternativeIIIB

Alternative IV Alternative V Alternative VI Alternative VII

No increase inrisk isanticipated

None

Minimal risk tocommunityexpected fromairborneparticulates andvehicular trafficduring coverconstruction.

Minimal risk tocommunityexpected fromairborneparticulates andvehicular trafficduring coverconstruction andexcavation.

Increased riskdue to off-sitetransport ofcontaminatedmaterials.

Minimal risk tocommunityexpected fromairborneparticulates andvehicular trafficduring coverconstruction andexcavation


Minimal risk tocommunityexpected fromairborneparticulates andvehicular trafficduring coverconstruction.

Minimal risk tocommunityexpected fromairborneparticulate andvehicular trafficduringexcavation.


Minimal risk tocommunityexpected fromairborneparticulate andvehicular trafficduringexcavation.


Minimal risk tocommunityexpected fromairborneparticulates andvehicular trafficduring coverconstruction andexcavation.Increased riskdue to transportand on-sitecontainment ofcontaminatedmaterials.

Protection required against dermal contact and dust inhalation during construction activities.

L:\211 FB\86C36WS\TABLE6- 1.DOC

'ABLE 6-1 (Concluded)VALUATION OF REMEDIAL ALTERNATIVES'LOODPLAIN/WETLAND AREATELD BROOK SUPERFUND SITE

Jo.

i

Criteria

Ecological Impacts

Time Until Actionis Complete

ImolementabilitvAbility to Controland Operate

Alternative !:

No change inecologicalimpacts

No time.

Alternative II

Low tomoderateenvironmentalimpactsanticipatedduringplacement ofcover onexisting surfacesand re-establishment ofnativevegetation.

AlternativeIIIAModerateenvironmentalimpactsanticipatedduringplacement ofcover onexistingsurfaces, limitedexcavation andbackfilling, andre-establishmentof nativevegetation.

AlternativenreModerateenvironmentalimpactsanticipatedduringplacement ofcover onexistingsurfaces, limitedexcavation andbackfilling, andre-establishmentof nativevegetation.

Alternative IV

Low tomoderateenvironmentalimpactsanticipatedduringplacement ofcover onexisting surfacesand re-establishment ofnativevegetation.

Alternative V

Moderate tohighenvironmentalimpactsanticipated fromexcavation,backfilling, andre-establishmentof nativevegetation.

Alternative VI

Moderate tohighenvironmentalimpactsanticipated fromexcavation,backfilling, andre-establishmentof nativevegetation.

Alternative VII

Moderate tohighenvironmentalimpactsanticipated fromexcavation,backfilling, andre-establishmentof vegetation.Moderateenvironmentalimpactsanticipatedduringplacement ofcover onexistingsurfaces, andre-establishmentof nativevegetation

Construction estimated to be completed in approximately one (1) year.

No action iseasy toimplement

Readilyimplementedusingconventionaltechnologies.







:U 11 FB\86C3609S\TABLE*-1 .DOC

PABLE 6-1 (Concluded)EVALUATION OF REMEDIAL ALTERNATIVESi'LOODPLAINAVETLAND AREA1ELD BROOK SUPERFUND SITE

Mo. Criteria

Ability toMonitorEffectiveness

Ability to ObtainApprovals andCoordinate withOther Agencies

Alternative I:

Monitoring isnot included inthis alternative.

No approvalsnecessary

Alternative II

Routineinspectionswould providenotice of erosionof cover areas.

Approvalprocess wouldrequirecoordinationwith USEPA,Ohio EPA andU.S. AimyCorps ofEngineersrepresentatives.

AlternativemARoutineinspectionswould providenotice of erosionof cover andbackfill areas.

Approvalprocess wouldrequirecoordinationwith USEPA,Ohio EPA andU.S. ArmyCorps ofEngineersrepresentatives.

AlternativeIHBRoutineinspectionswould providenotice of erosionof cover andbackfill areas.


Alternative IV

Routineinspectionswould providenotice of erosionof cover areas.


Alternative V

Routineinspectionswould providenotice of erosionof backfill areas.


Alternative VI

Routineinspectionswould providenotice of erosionof backfill areas.


Off-site thermaltreatmentpermits are notexpected to bedifficult.

Alternative VII

Routineinspectionswould providenotice of erosionof cover andbackfill areas.


2IIFBV86C3609S\TABLE6-1.DOC

ABLE 6-1 (Concluded)VALUATION OF REMEDIAL ALTERNATIVESLOODPLAIN/WETLAND AREA[ELD BROOK SUPERFUND SITE

o. Criteria

Availability OfServices,Materials andTechnologies

CostsDirect Costs

Annual O&M

30 Year PresentWorth

Alternative I:

Not applicable

$0

$0

$0

Alternative II

Hydric-compatible soilmay not bereadilyavailable.Mixing ofavailablematerial may berequired.

$2,850,000

$243,500

$4,991,000

AlternativenuHydric-compatible soilmay not bereadilyavailable.Mixing ofavailablematerial may berequired.

$7,563,000

$243,500

$9,700,000

AlternativeIIIBHydric-compatible soilmay not bereadilyavailable.Mixing ofavailablematerial may berequired.

$8,144,000

$243,500

$10,281,000

Alternative IV


$3,743,000

$243,500

$5,879,000

Alternative V


$19,671,000

$73,000

$20,491,000

Alternative VI

Hydric-compatible soilmay not bereadilyavailable.Mixing ofavailablematerial may berequired.Thermaltreatmentfacilities areavailable.

$22,093,000

$73,000

$22,913,000

Alternative VII


$4,629,000

$111,000

$5,896,000

Note: Refer to Table 6-2 through 6-7 for detailed cost breakdowns.O&M annual cost of $874,000 includes analytical sampling for year 1-5. Future O&M sampling subject to trend analysis.

\2MFB\86C3609S\TABLE6-1.DOC

TABLE 6-2 COST ESTIMATE EVALUATION FOR ALTERNATIVE IIFLOODPLAIN/WETLANDS AREAS (FWA)FIELDS BROOK SUPERFUND SITE, ASHTABULA OHIO

ALTERNATIVE: II PREPARED BY: BECHTEL ENVIRONMENTAL INC.

DRAFT

GENERAL RESPONSE: CONTAINMENT #1

CONSTRUCTION ITEMS: QUANTITY UNITS UNITPRICE

RAWCOST

LEVEL OFSAFETY

COSTFACTOR

TOTALCOST

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal of soil at offsite TSCA landfill, (w/transport'n)Place 6 inch thick cover, hydric compatible soils=ine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areaIncineration of soil at offsite TSCA landfill, (w/transprtn)Removal/offsite disposal of road mat'l, w/restoration

Establish Offsile Wetlands to Offset FWA Wflt'flnds LossPurchase replacement wetlands (FWA response area x 2)

8.58,000

00

7,01941.111

00

8,000

acreslinft

cu ydton

cu ydsqydcu ydtonlinft

19.6 acres

$16,000.00$13.00$13.00

$176.00$19.00$4.00$5.00

$800.00$16.00

$40,000.00

$135,904$104,000

$0$0

$133,361$164,444

$0$0

$128,000

$784,000

1.051.001.051.001.051.001.801.001.00

1.00

$142,700$104,000

$0$0

$140,029$164,444

$0$0

$128,000

$784,000CONSTRUCTION ITEMS COST (INCLUDING PROTECTION) $1,463,173

ADDITIONAL CONSTRUCTION AND CONTINGENCY COSTS PERCENTAGE OF CONSTRUCTION COST COST

CONSTRUCTION ITEMS COST (INCLUDING PROTECTION)

ADDITIONAL CONSTRUCTION COST:HEALTH AND SAFETY CONTINGENCYCONSTRUCTION CONTINGENCYCONSTRUCTION OVERSIGHT

SUPPORT COSTS:DESIGN AND PROCUREMENT SERVICESDELINEATION SAMPLINGPERMITTING AND LEGAL SERVICESSERVICES DURING CONSTRUCTION

CONSTRUCTION TOTAL

3.6%35.0%28.5%

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

$1,463,173

$52,674$512,111$417,004

$2,444,962

$139,001$200,000$17,558$52,674

$409,234

TOTAL TECHNOLOGY CAPITAL COST $2,854,196OPERATION AND MAINTENANCE (O&M) ITEMS:

Post-RA Sampling tor FWA Exposure Units fS Yearsl1) Sampling/analysis of soil, 80 samples per event

O&M for FWA Exposure Units f3Q Yearsl2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Mainlenance_and repairs (1% cover & fill loss/year)

QUANTITY

80

2229

205

UNITS

samples

per yearper yearper yearper yearcuyd

UNITPRICE

$2,500.00

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$200,000

$6,135$2,045$2,045$1,769

$21,525

LEVEL OFSAFETY

COSTFACTOR

1.05

1.001.001.001.001.00

YEARLYCOST

$210,000

$6,135$2,045$2,045$1,769

$21,525TOTAL TECHNOLOGY O&M YEARLY COST $243,519

REMEDIAL ALTERNATIVE SUBTOTAL (YEAR1)- $3,097,715TOTAL TECHNOLOGY O&M PRESENT WORTH

5.0% YEARS 04.32900 | $1,054,195REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) • $3,908,391

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% 10 YEARS 07.72200 $1,167,925

REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 10) - $4,022,121TOTAL TECHNOLOGY O&M PRESENT WORTH

5.0% 30 YEARS 15.37200 $2,136,877REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $4,991,073

Note: Post remediation sampling will be evaluated after first 5 years.

DRAFTTABLE 6-3a COST ESTIMATE EVALUATION FOR ALTERNATIVE Ilia

FLOODPLAIN/WETLANDS AREAS (FWA)FIELDS BROOK SUPERFUND SITE, ASHTABULA OHIO

ALTERNATIVE: Ilia PREPARED BY: BECHTEL ENVIRONMENTAL INC.GENERAL RESPONSE: COVER, EXCAVATION, BACKFILL, AND EX-S1TU DISPOSAL


RAWCOST

LEVEL OFSAFETY

COSTFACTOR

TOTALCOST

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal of soil at offsite TSCA landfill, (w/transport'n)Place 6 inch thick cover, hydric compatible soilsPlace 12 inch thick cover, hydric compatible soilsPlace 6 to 12 inch thick backfill, hydric compatible soilsFine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areaIncineration of soil at offsite TSCA landfill, (w/transprtn)Removal/offsite disposal of road mat'l, w/restoration

Establish Offsite Wetlands to Offset FWA Wetlands LOSSPurchase replacement wetlands (FWA response area x 2)

8.18,0008,300

13,4465,1304,7043,790

39,00000

8,000

19.6

acreslinft

cuydton

cu ydcuydcu ydsqydcuydtonlinft

acres

$16,000.00$13.00$13.00

$176.00$19.00$19.00$19.00$4.00$5.00

$800.00$16.00

$40,000.00

$128,926$104,000$107,900

$2,366,496$97,470$89,376$72,010

$156,000$0$0

$128,000

$784,000

1.051.001.051.001.051.051.051.001.801.001.00

1.00

$135,372$104,000$113,295

$2,366,496$102,344$93,845$75,611

$156,000$0$0

$128,000



lONSTRUCTION ITEMS COST (INCLUDING PROTECTION)



CONSTRUCTION TOTAL

3.6%35.0%28.5%

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

$4,058,962

$146,123$1,420,637$1,156.804$6,782.525

$385,601$200,000$48,708

$146,123$780,432

TOTAL TECHNOLOGY CAPITAL COST $7,562,957OPERATION AND MAINTENANCE (0&M) ITEMS:

Post-RA Sampling for FWA Exposure Units (5 YearsJ1) Sampling/analysis of soil, 80 samples per event

Q&M for FWA Exposure_Ujlits. (30 Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5} Mowing, monthly except winter months6) Maintenance and repairs (1% cover & fill loss/year)

QUANTITY UNITS

80

2229

205

samples

per yearper yearper yearper year

cuyd

UNITPRICE

$2,500.00

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$200,000

$6.135$2.045$2.045$1.769

$21.525

LEVEL OFSAFETY

COSTFACTOR

1.05

1.001.001.001.001.00

YEARLYCOST

$210,000

$6,135$2,045$2,045$1,769

$21.525TOTAL TECHNOLOGY O&M YEARLY COST ^243.519


5.0% YEARS 04.32900 | $1,054,195REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) - $8,617,151

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% JO_____YEARS 07.72200 | $1,167,925


5.0% 30 YEARS 15.372001 $2.136,877REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $9,699,834


DRAFTTABLE 6-3b COST ESTIMATE EVALUATION FOR ALTERNATIVE Illb


ALTERNATIVE: Illb PREPARED BY: BECHTEL ENVIRONMENTAL INC.GENERAL RESPONSE: COVER, EXCAVATION, BACKFILL, AND EX-SITU DISPOSAL

CONSTRUCTION ITEMS:

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal ot soil at offsite TSCA landfill, (w/transport'n)Place 6 inch thick cover, hydric compatible soilsPlace 12 Inch thick cover, hydric compatible soilsPlace 6 to 12 inch thick backfill, hydric compatible soilsrine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areaIncineration of soil at offsite TSCA landfill, (w/transprtn)^emoval/offsite disposal of road mat'l, w/restoration

Establish Offsite Wetlands tn Offset FWA Wetlands LossPurchase replacement wetlands (FWA response area x 2)

QUANTITY

7.38,0009,300

15,0664,019

10,2591,792

35,33200

8,000

19.6

UNITS

acreslinft

cu ydton

cuydcuydcuydsqydcu ydtonlinft

acres

UNITPRICE

$16,000.00$13.00$13.00

$176.00$19.00$19.00$19.00$4.00$5.00

$800.00$16.00

$40,000.00

RAWCOST$1 16,800$104.000$120,900

$2,651,616$76,361

$194,921$34,048

$141,328$0$0

$128,000

$784,000

LEVEL OFSAFETY

DEDEDDDECEE

E

COSTFACTOR

1.051.001.051.001.051.051.051.001.801.001.00

1.00CONSTRUCTION ITEMS COST (INCLUDING PROTECTION)

ADDITIONAL CONSTRUCTION AND CONTINGENCY COSTS




PERCENTAGE OF CONSTRUCTION COST

3.6%35.0%28.5%

CONSTRUCTION TOTAL

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

TOTAL TECHNOLOGY CAPITAL COSTOPERATION AND MAINTENANCE (OSM) ITEMS:

Post-RA Samolino for FWA Fxoosure Units if, Years)1) Sampling/analysis of soil, 80 samples per event

O&M for FWA Exoosure Unjt? (30 Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Maintenance and repairs (1% cover & fill loss/year)

QUANTITY

80

2229

205

UNITS

samples


cuyd

UNITPRICE

$2,500.00

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$200,000

$6,135$2,045$2,045$1,769

$21,525

LEVEL OFSAFETY

D

EEEEE

COSTFACTOR

1.05

1.001.001.001.001.X

TOTAL TECHNOLOGY O&M YEARLY COST

TOTALCOST

$122,640$104,000$126,945

$2,651,616$80,179

$204,667$35,750

$141,323$0$0

$128,000

$784,000$4,379,126

COST

$4,379,126

$157,649$1,532,694$1,248,051$7,317,519

$416,017$200,000$52,550

$157,649$826,215

$8,143,734YEARLYCOST

$210,000

$6,135$2,045$2,045$1,769

$21,525$243,519

REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 1} - $8,387,253TOTAL TECHNOLOGY O&M PRESENT WORTH

5.0% & 5 YEARS 04.32900 $1,054,195REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) - $9,197,928

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% & 10 YEARS 07.72200 $1,167,925


5.0% & 30 YEARS 1 5.37200 $2,136,877REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $10,260,611


DRAFTTABLE 6-4 COST ESTIMATE EVALUATION FOR ALTERNATIVE IV


ALTERNATIVE: IV PREPARED BY: BECHTEL ENVIRONMENTAL INC.GENERAL RESPONSE: CONTAINMENT #2


RAWCOST

LEVEL OFSAFETY

COSTFACTOR

TOTALCOST

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal of soil at offsite TSCA landfill, (w/transport'n)Place 6 inch thick cover, hydric compatible soilsFine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areancineration of soil at offsite TSCA landfill, (w/transprtn)

Removal/offsite disposal of road mat'l, w/restorationEstablish Offsile Wetlands_to Offset FWA Wetlands Loss

Purchase replacement wetlands (FWA response. arg_a_x_2)____

17.58,000

00

14,32084,889

00

8,000

19.6

acreslinft

cu ydton

cu ydsq ydcu ydtonlinft

acres

$16,000.00$13.00$13.00

$176.00$19.00$4.00$5.00

$800.00$16.00

$280,624$104,000

$0$0

$272,080$339,556

$0$0

$128,000

$40,000.00 $784,000

1.051.001.051.001.051.051.001.801.00

1.00

$294,656$104,000

$0$0

$285,684$356,533

$0SO

$128,000

$784,000CONSTRUCTION ITEMS COST (INCLUDING PROTECTION) $1,952.873





CONSTRUCTION TOTAL

3.6%35.0%28.5%

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

$1,952,873

$70,303$683,506$556,569

$3,263,251

$185,523$200,000$23,434$70,303$479,261


Posl-RA Sampling for FWA Exposure UnilsIS Years!1) Sampling/analysis of soil, 80 samples per event

Q&Mfor FWA Exposure Units (30 Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Maintenance and repairs (1% cover & fill loss/year)

QUANTITY

80

2229

205

UNITS

samples

per yearper yearper yearper yearcuyd

UNITPRICE

$2,500.00

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$200,000

$6,135$2,045$2,045$1,769

$21,525

LEVEL OFSAFETY

COSTFACTOR

1.05

1.001.001.001.001.00

YEARLYCOST

$210,000

$6,135$2,045$2,045$1,769

$21,525TOTAL TECHNOLOGY O&M YEARLY COST $243.519


5.0% YEARS 04.32900 . j]054~195REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) - $4,796,706

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% JO_____YEARS 07.72200 [ $1,167,925


5.0% 30 YEARS 15.37200 $2,136,877REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $5,879,389


].«11 mtfC *NNS\FWreRA10.Xl.W

TABLE 6-5 COST ESTIMATE EVALUATION FOR ALTERNATIVE VFLOODPLAIN/WETLANDS AREAS (FWA)FIELDS BROOK SUPERFUND SITE, ASHTABULA OHIO

ALTERNATIVE: V PREPARED BY: BECHTEL ENVIRONMENTAL INC.

DRAFT

GENERAL RESPONSE: EXCAVATION, BACKFILL, AND EX-SITU DISPOSAL


RAWCOST

LEVEL OFSAFETY

COSTFACTOR

TOTALCOST

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal of soil at offsite TSCA landfill, (w/transport'n)Place 12 inch thick backfill, hydric compatible soils=ine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areancineration of soil at offsite TSCA landfill, (w/transprtn)Removal/offsite disposal of road mat'l, w/restoration

Establish Qfisite Wetlands to Offset FWA Wetlands LQ$S.Purchase replacement wetlands (FWA response area x 2)

17.58,00026,50046,170

28.50084,869

00

6,000

19.6

acreslinft

cuydton

cuydsqydcu ydtonlinft

acres

$16,000,00$13.00$13.00

$176.00$19.00$4.00$5.00

$800.00$16.00

$280,624$104,000$370,500

$8,125,920$541,500$339.556

$0$0

$128,000

$40,000.00 $764,000

1.051.001.051.001.051.001.801.001.00

1.00

$294,656$104,000$389,025

$8,125,920$568,575$339,556

$0$0

$128,000

$784,000CONSTRUCTION ITEMS COST (INCLUDING PROTECTION) $10,733.731





CONSTRUCTION TOTAL

3.6%35.0%28.5%

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

$10,733,731

$386,414$3,756,806$3,059,113

$17,936,065

$1,019,704$200,000$128,805$386,414

$1,734,924


Post-RA Sampling for FWA Exposure Units fS Years!1) Sampling/analysis of soil, 25 samples per event

Q&M for FWA Exposure Units f3Q Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Maintenance and repairs (1% cover & fill loss/year)

QUANTITY

25

2229

205

UNITS

samples

peryearper yearper yearper year

cu yd

UNITPRICE

$1.503.60

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$37,590

$6,135$2,045$2,045$1,769

$21,525

LEVEL OFSAFETY

COSTFACTOR

YEARLYCOST

1.05

1.001.001.001.001.00

$39,470

$6,135$2,045$2,045$1,769


REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 1) $19,743,978TOTAL TECHNOLOGY O&M PRESENT WORTH

5.0% YEARS 04.32900 \ $315,970REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) • $19,986,959

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% 10 YEARS 07.72200 \ $429,701


5.0% 3 0 Y E A R S 15.37200 $820,044REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $20,491,033

Note: Post remediation sampling will be evaluated after first 5 years.1 ,\2 II HUSfiC MWSU-WS H> JO XLW

TABLE 6-6 COST ESTIMATE EVALUATION FOR ALTERNATIVE VIFLOODPLAIN/WETLANDS AREAS (FWA)FIELDS BROOK SUPERFUND SITE, ASHTABULA OHIO

ALTERNATIVE: VI PREPARED BY: BECHTEL ENVIRONMENTAL INC.

DRAFT

GENERAL RESPONSE: EXCAVATION, BACKFILL, TREATMENT, AND EX-SITU DISPOSAL


RAWCOST

LEVEL OFSAFETY

COSTFACTOR

TOTALCOST

Selective clearing, incl. TSCA disposal of stumpsConstruct access/haul roadsExcavate contaminated soil and haul to staging areaDisposal of soil at offsite TSCA landfill, (w/iransport'n)Place 12 inch thick backfill, hydric compatible soilsFine grade, place erosion mat, seed and mulchDewater and screen contaminated soil at staging areancineration of soil at offsite TSCA landfill, (w/lransprtn)Removal/offsite disposal of road mat'l, w/restoration

Establish Qffsite Wetlands to Offset FWA Wetlands LossPurchase replacement wetlands (FWA response area x 2)

17.58,00028,50042,930

28,50084,8692,5003,2408,000

19.6

acreslinft

cuydton

cuydsqydcuydtonlinft

acres

$16,000.00$13.00$13.00

$176.00$19.00$4.00$5.00

$800.00$16.00

$40.000.00

$280,624$104,000$370,500

$7,555,680$541,500$339,556$12,500

$2,592,000$128,000

$784,000

1.051.001.051.051.051.001.801.001.00

1.00

$294,656$104,000$389,025

$7,933,464$568,575$339,556$22,500

$2,592.000$128.000






CONSTRUCTION TOTAL

3.6%35.0%28.5%

9.5%5.1%1.2%3.6%

SUPPORT COST TOTAL

$13,155,775

$386,414$3,756,806$3.059,113

$20.356,109

$1,019,704$200,000$128,805$386,414

$1,734,924


Post-RA Sampling for FWA Exposure Units (5 Years!1) Sampling/analysis of soil, 25 samples per event

O&M for FWA Exposure Units (30 Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Maintenance and repairs (1% cover & till loss/year)

QUANTITY

25

2229

205

UNITS

samples


cu yd

UNITPRICE

$1,503.60

$3,067.56$1,022.52$1,022.52

$196.50$105.00

RAWCOST

$37,590

$6,135$2,045$2,045$1,769

$21,525

LEVEL OFSAFETY

COSTFACTOR

1.05

1.001.001.001.001.00

YEARLYCOST

$39,470

$6,135$2,045$2,045$1.769



5.0% YEARS 04.32900 | $315.970REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 5) - $22,409,003

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% 10 YEARS 07.72200 $429.701


5.0% 30 YEARS 15.37200 $820,044REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $22,913,077


L>211HNMCMOWWWSRAJO XLW

DRAFTTABLE 6-7 COST ESTIMATE EVALUATION FOR ALTERNATIVE VII


ALTERNATIVE: VII PREPARED BY: Bechtel Environmental Inc.GENERAL RESPONSE: EXCAVATION, BACKFILL, AND EX-SITU DISPOSAL ONSITE

CONSTRUCTION ITEMS:

Excavation/Cover/Backfill in FWA EU'sSelective clearing, incl. offsite disposal of stumpsConstruct access/haul roads, (w/clearing)Excavate contaminated soil & haul to onsite disposal areaPlace 6" thick cover, hydric compatible soil (allow $15/cy purchPlace 12" thick backfill, hydric compatible soil (allow $15/cy purPlace 6" thick fill, hydric compatible soil (allow $15/cy purch.)Fine grade, place erosion mat, seed and mulchRemoval/offsite disposal of road mat'l, w/restoratiort

Construct/Fili/Cao Onsite Disoosal FacilitvRough grading/strip topsoil 6"Compact insitu soilInstall 60 mil flexible membrane liner, HDPEPurchase/dump 6" sand/gravelSpread/compact 6" sand/gravelInstall leachate detection sumpsConstruct 3' x 1 .5' anchor trenchInstall 60 mil flexible membrane liner, HDPEPurchase/dump 6" sand/gravelSpread/compact 6" sand/gravelInstall leachate collection systemConstruct access/perimeter roadsInstall security fencing, 7' galvanized chain linkInstall gates, 7' galvanized chain link, 12' double-swingCondition contaminated soil from FWASpread & compact contam'd soil from FWAGrading of disposal volumesPurchase/dump 1 2" sand/gravelSpread/compact 12" sand/gravelInstall 40 mil flexible membrane liner, HDPEInstall geonet, 1/4' thick w/geotextile both sidesPurchase/dump 24" clean soilSpread/compact 24" clean soilSpread/compact 6" topsoilConstruct perimeter runoff collection swaleFine grade, place erosion mat, seed and mulchInstall 2" PVC groundwater monitoring wells, 4 each x 25'

Establish Offsite Wetlands to Offset FWA Wetlands LossPurchase replacement wetlands (FWA response area x 2)

QUANTITY

13.18,000

15,2592,963

15,2592,315

63,5568,000

5,6254,669

42,025778778

8820

42,025778778820900900

215,25915,2594,6691,5561,556

42,0254,6693,1133,113

778820

4,669100

19.6

UNITS

acreslinftcu ydcu ydcu ydcu ydsq ydlinft

sqydsq ydsqftcu ydcu ydeachlinftsqftcu ydcu ydlinftlinftlinfteachcu ydcu ydsqydcu ydcu ydsqftsqydcu ydcu ydcu ydlinftsqydlinft

acres

UNITPRICE

$6,959.00$15.00$13.00$19.20$19.20$19.20$1.40

$24.00

$0.43$0.30$1.46$8.75$3.19

$1,000.00$0.52$1.46$8.75$0.52

$20.00$13.36$15.68

$415.42$0.18$0.52$0.43$8.75$3.19$1.06$5.89$4.71$0.52$0.52$3.63$1.40

$94.72

$40,000.00

RAWCOST

$91,381$120,000$198,367$56,890

$292,973$44,448$88,978

$192,000

$2,419$1,401

$61,357$6,808$2,482$8,000

$426$61,357$6,808

$405$16,400$12,024$14,112

$831$2,747$7,935$2,008

$13,615$4,964

$44,547$27,500$14,662$1,619

$405$2,977$6,537$9,472

$784,000

LEVEL OFSAFETY

DEDDDDEE

EEEEEEEEEEEEEEDDDEDEEEEEEEE

E

COSTFACTOR

1.081.001.051.051.051.051.001.00

1.001.001.001.001.001.001.001.001.001.001.001.001.001.001.051.051.051.001.051.001.001.001.001.001.001.001.00

1.00CONSTRUCTION ITEMS COST (INCLUDING PROTECTION)

ADDITIONAL CONSTRUCTION AND CONTINGENCY COSTS




PERCENTAGE OF CONSTRUCTION COST

4.8%35.0%38.6%

CONSTRUCTION TOTAL

12.9%8.9%1.6%4.8%

SUPPORT COST TOTAL

TOTAL TECHNOLOGY CAPITAL COST

TOTALCOST

$98,691$120,000$208,285$59,734

$307,621$46,670$88,978

$192,000$1,121,979

$2,419$1,401

$61,357$6,808$2,482$8,000

$426$61,357$6,808

$405$16,400$12,024$14,112

$831$2,884$8,331$2,108

$13,615$5,212

$44,547$27,500$14,662$1,619

$405$2,977$6,537$9,472

$334,699$784,000

$2,240,678COST

$2,240,678

$108,000$784,237$864,000

$3,996,915

$288,000$200,000$36,000

$108,000$632,000

$4,628,915

I FB\*JCMOlS\FV*FSFt«« XLW

DRAFTTABLE 6-7

ALTERNATIVE:

COST ESTIMATE EVALUATION FOR ALTERNATIVE VIIFLOODPLAIN/WETLANDS AREAS (FWA)FIELDS BROOK SUPERFUND SITE, ASHTABULA OHIOVII PREPARED BY: Bechtel Environmental Inc.

GENERAL RESPONSE: EXCAVATION, BACKFILL, AND EX-SITU DISPOSAL ONSITE

OPERATION AND MAINTENANCE (O&M) ITEMS:

Post-RA Sampling for FWA Exposure Units f5 Years)1) Sampling/analysis of cover soil, 25 samples per event

O&M for FWA Exposure Units (30 Years)2) Cover inspections3) Inspection report preparation4) Management and coordination5) Mowing, monthly except winter months6) Maintenance and repairs (1% cover & fill loss/year)

O&M for Onsite Disposal Facility (30 years)7) Disposal area inspections8) Inspection report preparation9) Management and coordination10) Mowing, twice monthly except winter months11) Maintenance and repairs (1% cover loss/year)12) Groundwater sampling/analysis13) Leachate collection/transfer to Detrex treatment facility

O&M for Offsite Wetlands to Offset FWA Wetlands Loss f30 years)

QUANTITY

14) Wetlands inspections - by others15) Inspection report preparation - by others16) Management and coordination - by others17) Wetlands maintenance/repairs - by others

25

2229

205

444

1831

44

000

0.0

UNITS

samples


cuyd


cuydper yearper year

per yearper yearper year

acres

UNITPRICE

$1,503.60

$3,067.56$1,022.52$1,022.52

$196.50$105.00

$1,363.36$1,022.52$1,022.52

$72.36$105.00

$3,704.20$1,200.00

$8,521.00$3,408.40$1,704.20

$10,000.00

RAWCOST

$37,590

$6,135$2,045$2,045$1,769

$21,525

$5,453$4,090$4,090$1,302$3,255

$14,817$4,800

$0$0$0$0

LEVEL OFSAFETY

COSTFACTOR

1.05

1.001.001.001.001.00

1.001.001.001.001.001.001.00

1.001.001.001.00

YEARLYCOST

$39,470

$6,135$2,045$2,045$1,769

$21,525

$5,453$4,090$4,090$1,302$3,255$14,817$4,800

$0$0$0$0

TOTAL TECHNOLOGY O&M YEARLY COST $110.796REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 1) - $4,739,711

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% YEARS 04.32900 $479,636


5.0% 10 YEARS 07.72200 $721,645REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 10) - $5,350,560

TOTAL TECHNOLOGY O&M PRESENT WORTH5.0% 30 YEARS 15.37200 $1,267,289

REMEDIAL ALTERNATIVE SUBTOTAL (YEAR 30) - $5,896,204


A P P E N D I X A

RESIDUAL ECOLOGICAL RISKS


October 17, 1996

Woodward-Clyde

30775 Bainbridge RoadSuite 200Solon.Ohio 44139(216)349-2708(216} 349-1514 fax86C3609S

RESIDUAL ECOLOGICAL RISKS

Levels of environmental protection offered by each alternative and the parameters'

controlling effectiveness are identified in Section 6. This appendix provides quantitativeevaluation of a range of residual risks under certain active remediation scenarios as

presented in Section 5.

As documented in the Remedial Investigation (RJ) reports, the risk management process

for the floodplain wetland proceeds from human health evaluation/control to ecologicalexposure/control. In keeping with appropriate guidance, baseline risks were evaluated

conservatively to present a range of residual risks. Toxicity thresholds representedexposure in the very low No Observed Adverse Effects Level (NOAEL) range, andincluded values based on chemical species and exposure routes far more severe tluui thoseexpected under Held conditions. Specifically, for risk management consideration, us

detailed in current ecological risk assessment guidance (t)SEPA 1994, chapter R)

toxicological thresholds above very conservative NOALLs but below Lowest Observed

Adverse Effects Levels (LOAELs) arc employed. Table 1 illustrates a range of potentialecological exposure risks in keeping with the 1994 draft guidance. Residual risks arc;

calculated as proportional to changes in environmental media concentrations. For thesetables, exposure was assumed ut post-remediation concentrations for alternatives in group

III using exposure point concentrations at the 95 percent upper confidence limit (UG1.).All receptors except the hawk and heron arc assumed to spend full lime in the Holds

Brooks floodpluin wetland. As detailed in the baseline risk assessment. Hit- hawk isassumed to feed in the FWA 52 percent of the time and the heron 50 percent. For lead,

arsenic, and mercury, the TRV was multiplied by 2 to 4 because exposure in the FWA is

primarily to sediment-related inorganic species, and toxicity studies were conducted withorganic species, und biomarkcr endpoints were employed in some toxicity studies from

which TRVs were derived.

Two cases are presented in Table 1 to represent a range of post-remediation riskassumptions. l?or case I, TRVs were multiplied by 5, because a multiplier of 10 is used toestimate NOAEL from LOAEL. This places hazard quotients mid-point on the range

between NOAULs and LOAliLs. For case II, TKVs are not modified, so this caserepresents a conservative exposure scenario.

When residual risks arc quantified in the NOAliL/LOARL range of Case I, all ecologicalhazard quotients fall to below 1,0. This indicates the effectiveness of the remedy in

reducing exposure and associated potential hazard to ecological receptors in the FieldsBrook floodplain wetland. When residual risks are quantified in the low NOAEL rangeof Case 11, some hazard quotients exceed 1.0. Note thut in a few cases, for example

arsenic in xonc 3, residual risk assuming a low NOAUL TRY increases slightly from thebaseline case. This is due to residual soil concentrations, estimated at background levelsassumed to be used as backfill, for the remedy having a slightly higher concentration than

baseline soils. In /one 3, under the conservative assumptions in case II, there is lessoverall reduction in ecological risk. This is because the compounds driving potential

risks (metals, chlorinated hydrocarbons) are not precisely co-located with those driving

the remedy (e.g., PCDs). In general, there is risk reduction benefit under both the realistic

assumptions of case I and the conservative assumptions of case II.

TABLE 1. FLOODPLAIN/WETLANDS AREAS FIELDS BROOK SUPERFUND SITE,ASHTABULA, OHIO RESIDUAL HAZARD QUOTIENTS

CompoundZono 1Aroclor 1248

Cadmium

Chromium

Hexch lo ro benzeneHexachlorobutadiene

Lead

Mercury

Zone 2Aroclor 1248

Aroclor 1290

Arsenic

Barium

Cadmium

Chromium

Hexchlorobenzene

BaselineSpecies Hazard Quotient

robinrabbitshrewrobin

shrewmouserobinrabbit

robin

shrewmouserabbit

shrewmouserobinshrewmouserobin

shrewmouserobinrabbitmink

shrew

mink

shrewrobinshrewmouserobinrabbitrobinrabbit

1.111.04

1.122.01

2.631.931.181.65

1.54

1.351.364.10

2.291.253.27

6.802.39263

1.031.132.502.33

1.49

1.01

2.56

1.78299

3.482.881.732.33

4.812.35

ResidualHazard Quotient 1

0.0050.005

0.070.13

0.190.140.090.12

0.01

0.020.020.06

0.330.180.47

0.060.020-02

0,030.030.060.06

0.08

0.29

0.32

0.220.36

0.300.240.150.20

0.410-20

ResidualHazard Quotient II

0.0250.025

0.035065

0.050.7

0.450.6

0.05

0.10.10.3

1.650.9

2.35

0.30.10.1

0.150.150.30.3

0,4

1.45

1.6

1.11.8

1.61.2

0751

2.051

CompoundHexachlorobutadiene

Lead

Mercury

VanadiumZone 3Aroclor 1248

Arsenic

Cadmium

Chromium

Hexachlorobenzene

Hexachlorobutadiene

Lead

Mercury

Vanadium

BaselineSpecies Hazard Quotientshrewmouserabbitshrewmouserobin

hawkshrewmouserobinmink

robin

shrew

robin

minkshrewmouserobinrabbit

minkrobinrabbitshrewmouserabbit

shrewrobin

hawkshrewmouserobinrabbit

mink

1.631.985.06

5.101.614.57

2.965.713,343,47

2.66

1.00

1.26

1.49

1.175.425.113.114.26

1.055.062.51

1.281.253.90

2.841,36

3.3814.658.769321.31

6.24

ResidualHazard Quotient I

0.040,050.12

0.650.200.58

0.080.140.080.09

0.27

0.07

0.31

0.26

0,180,820.770.470.64

0.200.950.47

0.250.240.75

0.370.18

0.160.700.420.450.63

0.89

ResidualHazard Quotient II

0.?025

0.6

3.251

2.9

0.40.70.4

0.45

1.35

035

1.55

1.3

0.94.1

3.S52,3532

14752.35

1.251.2

3.75

1.850.9

0.83.52.1

2.25315

4.45

A P P E N D I X BD R A F T

COVER ALTERNATIVEEVALUATION MEMORANDUM

FIELDS BROOK SITEFLOODPLAINAVETLANDS AREA


October 1996

Woodward-Clyde

30775 Bainbridge RoadSuite 200Solon, Ohio 44139(216)349-2708(216) 349-1514 fax86C3609S

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1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

2.0 BACKGROUND INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1 SITE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12.2 SITE HISTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12.3 FLOODPLAIN EXPOSURE UNITS (FEUs) . . . . . . . . . . . . . . . . 2-22.4 CHEMICALS OF CONCERN . . . . . . . . . . . . . . . . . . . . . . . . . 2-32.5 PHYSICAL CHARACTERISTICS OF FLOODPLAIN/WETLANDS

AREA (FWA) SOILS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

3.0 CRITERIA FOR DEVELOPMENT OF COVER ALTERNATIVES . . . . . . 3-1

3.1 REMEDIAL ACTION OBJECTIVES FOR FWA . . . . . . . . . . . . . 3-13.2 POTENTIAL ARARS FOR THE FLOODPLAIN/WETLANDS

AREA, COVER ALTERNATIVE . . . . . . . . . . . . . . . . . . . . . . 3-2

3.2.1 Location-Specific ARARs . . . . . . . . . . . . . . . . . . . . . . . 3-33.2.2 Action-Specific ARARs . . . . . . . . . . . . . . . . . . . . . . . . 3-33.3.3 Chemical-Specific ARARs . . . . . . . . . . . . . . . . . . . . . . . 3-33.3.4 ARARs Evaluation for FWA Cover Alternatives . . . . . . . . . 3-4

4.0 DESCRIPTION OF POTENTIAL COVER ALTERNATIVES . . . . . . . . . . 4-1

4.1 COVER ALTERNATIVE I . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24.2 COVER ALTERNATIVE II . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24.3 COVER ALTERNATIVE III . . . . . . . . . . . . . . . . . . . . . . . . . 4-34.4 COVER ALTERNATIVE IV . . . . . . . . . . . . . . . . . . . . . . . . . 4-34.5 COVER ALTERNATIVE V (SPECIAL CONDITIONS) . . . . . . . . . 4-4

5.0 EVALUATION AND COMPARISON OF COVER ALTERNATIVESUSING CERCLA EVALUATION CRITERIA . . . . . . . . . . . . . . . . . . . 5-1

5.1 CERCLA CRITERIA FOR EVALUATION OF ALTERNATIVES . . 5-15.2 COMPARATIVE ANALYSIS OF COVER ALTERNATIVES . . . . . 5-3

5.2.1 Overall Protection of Human Health and the Environment . . . . 5-35.2.2 Compliance With ARARs . . . . . . . . . . . . . . . . . . . . . . . 5-45.2.3 Long-Term Effectiveness and Permanence . . . . . . . . . . . . . 5-4

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Section Page

5.2.4 Reduction of Toxicity, Mobility, and/or Volume ThroughTreatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

5.2.5 Short-Term Effectiveness . . . . . . . . . . . . . . . . . . . . . . . 5-65.2.6 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-65.2.7 Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

6.0 SELECTED COVER ALTERNATIVE ........................ 6-1

7.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

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DRAFTTABLE OF CONTENTS (Continued)

LIST OF TABLES

Section 3.0

Table 3-1 Potential Location-Specific ARARs for Cover AlternativesTable 3-2 Potential Action-Specific ARARs for Cover Alternatives

Section 4.0

Table 4-1 Cover Alternatives for Floodplain/Wetlands Area

Section 5.0

Table 5-1 Evaluation of Cover Alternatives

LIST OF FIGURES

Section 2.0

Figure 2-1 Site MapFigure 2-2 Floodplain Exposure Units (FEUs)

Section 4.0

Figure 4-1 Cover Alternative IFigure 4-2 Cover Alternative IIFigure 4-3 Cover Alternative IIIFigure 4-4 Cover Alternative IVFigure 4-5 Cover Alternative V

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1.0INTRODUCTION

Woodward-Clyde Consultants (WCC) has been contracted by the Fields Brook PRP RemedialAction Group (FBPRPRAG) to conduct a Cover Alternatives Evaluation in support of theFloodplain/Wetland Areas (FWA) Feasibility Study (FS) at the Fields Brook Superfund sitein Ashtabula, Ohio. This investigation is being conducted to meet the requirements of theFWA FS as discussed in the April 21, 1995 meeting between the U.S. EnvironmentalProtection Agency (USEPA) and the Fields Brook PRP Organization (FBPRPO), and assummarized in the April 28, 1995 letter to USEPA.

The purpose of this Cover Alternatives Evaluation Memorandum is to perform a preliminaryassessment of the feasibility of using a cover for containment of FWA soils in order to meethuman health and environmental remedial action objectives. Four cover alternatives arepresented and evaluated using the criteria described in USEPA's Guidance for ConductingRemedial Investigations and Feasibility Studies under CERCLA (USEPA 1988a). A fifthcover alternative has been presented for special conditions that may exist in select areas asa result of submerged conditions. A recommended cover design is selected based on theresults of this evaluation. Based on a request from USEPA during the November 2, 1995meeting, the cover design used in the FWA FS was modified to provide a higher degree ofprotectiveness for related alternatives in FEUs having PCBs in excess of 100 ppm. In theseareas, the same cover was selected, however, the thickness was increased to 12 inches.

This memorandum is organized in a feasibility study report format to facilitate evaluation ofthe alternatives that include covers in the FWA FS Report. The recommended coveralternative will be considered for use in FWA FS alternatives that include containmenttechnologies.

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2.0BACKGROUND INFORMATION

2.1 SITE DESCRIPTION

Fields Brook is located in the city, township, and county of Ashtabula, in northeastern Ohio.A portion of the United States Geological Survey (USGS) topographic map showing thegeneral location of the Fields Brook watershed is presented in Figure 2-1.Fields Brook drains a 6-square-mile area. The eastern portion of the watershed drainsAshtabula Township, and the western portion drains the eastern portion of the city ofAshtabula. The main channel is 3.9 miles in length and begins at Cook Road, just south ofthe Penn Central Railroad tracks. From this point, Fields Brook flows northwest to MiddleRoad, then west to its confluence with the Ashtabula River. From Cook Road downstreamto State Highway 11, Fields Brook flows through an industrialized area. Downstream ofState Highway 11 to near its confluence with the Ashtabula River, Fields Brook flowsthrough a residential area within the city of Ashtabula. Fields Brook empties into theAshtabula River, approximately 8,000 feet (ft) upstream from Lake Erie.

To facilitate locating features along Fields Brook and its tributaries, the stream has beendivided into segments identified by a unique numbering system involving stream reaches.Figure 2-2 shows the identification of these reach segments and industrial propertyboundaries within the Fields Brook watershed.

2.2 SITE HISTORY

Fields Brook was determined by the USEPA and the Ohio Environmental Protection Agency(Ohio EPA) to contain contaminated sediments resulting from industrial discharges to FieldsBrook (USEPA 1986). The Fields Brook site was included on the National Priorities List(NPL) of uncontrolled hazardous sites under the Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA) on September 8, 1983.

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Chlorinated solvents, chlorinated benzene compounds, PNAs, PCBs and metals wereidentified in sediments and floodplain soils in the Sediment Quantification DesignInvestigation (SQDI) of the Fields Brook Sediment Operable Unit (SOU).

In order to evaluate control effects of remedial alternatives, a procedure was implementedthat incorporates residual ecological risk and human health clean up goals has beenconceptualized.

2.3 FLOODPLAIN EXPOSURE UNITS (FEUs)

The Fields Brook FWA was divided into five (5) floodplain exposure units (FEUs) based onhuman exposure risks. The FEUs are numbered FEU-2, FEU-3, FEU-4, FEU-6 and FEU-8corresponding to the sediment exposure units (EUs) EU-2, -3, -4, -6 and -8. FEUs were notassigned to sediment EU-1, -5 and -7 because no floodplain was present at these locations.In addition, FEUs were not assigned to EU-9 and -10 because there were no CUGexceedances at these locations in Phase I and Phase II SQDI floodplain data. The locationsof the FEUs are depicted on Figure 2-2 and are described below (WCC 1995):

• FEU 2 encompasses Reaches 2-1 and 2-2 and is a residential area. Thefloodplain width ranges from 25 to 100 ft. A steep bluff separates thefloodplain from the residences. Access is limited by heavy brush and treegrowth along the bluff. Highway bridges form the eastern and westernboundaries of FEU-2. Several residential properties are situated adjacent toFields Brook.

• FEU 3 is in a residential area and encompasses Reach 3. The physicalcharacteristics of FEU-3 are similar to FEU-2 including dense brush andhighway bridges at the boundaries. However, there are no residentialproperties that extend beyond the bluff to the floodplain.

• FEU 4 is in a transitional area and consists of Reach 4 and the portion of thefloodplain on the west side of Reach 11-1 near its confluence with FieldsBrook. The width of the floodplain ranges from 150 to 400 ft. The bluff is


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not as steep as in the downstream FEUs. The stream channel has severalcurves and meanders. Access is limited by heavy brush, tree growth andfences along the bluff. There are no residences within 1,500 ft. of the bluff.Adjacent industrial facilities restrict access and own most of the floodplain.

• FEU 6 is in a transitional area and encompasses Reaches 5-1 and 5-2 includingthe portion of the floodplain on the east side of Reach 11-1 near its confluencewith Fields Brook. The floodplain width varies from 200 to 300 ft. Similarto FEU-4, the bluff is not as steep as in downstream FEUs. The streamchannel is braided with several islands on the eastern side of FEU-6. Accessis limited by heavy brush, tree growth and fences along industrial properties.There are no residences in this FEU. Adjacent industrial facilities restrictaccess and own the ponded area in the floodplain.

• FEU 8 is in an occupational area and consists of Reaches 6 and 7-1. Thefloodplain width ranges from 50 to 225 ft. A moderate escarpment separatesthe floodplain from industrial properties to the north and south. Access islimited by heavy brush and fencing.

• Ecological exposure zones were established as a function of differential habitatfeatures. Zone 1 is in the lower reaches of the floodplain/wetland area alongFields Brook. Zones 2, 3, and 4 are successively upstream to the lower areaof the floodplain/wetland area.

2.4 CHEMICALS OF CONCERN

FWA soils were chemically characterized in three sampling phases of the SQDI. PCBs andhexachlorobenzene were the compounds causing the preponderances of the baseline risk.Maximum PCB (Aroclor 1248) concentrations were 360 ppm in FEU-2, 530 ppm in FEU-3,560 ppm in FEU-4, 610 ppm in FEU-6 and 270 ppm in FEU-8. Maximumhexachlorobenzene concentrations were 97 ppm in FEU-2, 99 ppm in FEU-3, 300 ppm inFEU-4, 540 ppm in FEU-6 and 480 ppm in FEU-8.


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2.5 PHYSICAL CHARACTERISTICS OF FLOODPLAIN/WETLANDS AREA(FWA) SOILS

Field reconnaissance of the five FEUs was performed in May 1995 (WCC 1995). Thereconnaissance was performed by walking the length of each floodplain exposure unit. Fieldobservations were made at selected former SQDI Phase III floodplain sample locations. Atthese locations small test pits were dug for observation of the root, humus, and soil zones andthe surface surrounding the sampling locations. Vegetation and approximately 3 inches ofleaves predominantly covered the ground surface in each floodplain. The top 1 to 2 inchesof soil consisted of roots and humus. Soil moisture conditions at the ground surface wereobserved from photographs taken at each test pit and are described below:

• FEU-2 was moist to saturated at ground surface; submerged areas wereobserved in the area of an existing beaver dam.

• FEU-3 was moist to saturated at ground surface.• FEU-4 was moist to saturated at the ground surface. Submerged areas were

observed in the area of a former beaver dam.• FEU-6 was moist to saturated at the ground surface.• FEU-8 was moist to submerged at the ground surface.


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3.0CRITERIA FOR DEVELOPMENT OF COVER ALTERNATIVES

The development of remedial action alternatives is a multi-step process. First, remedialaction objectives are developed. Second, general response actions, representing a wide rangeof remedial technologies and process options, are developed to satisfy the remedial actionobjectives. Specific remedial technologies and process options are then evaluated based onsite-specific conditions. Finally, potential remedial action alternatives are assembled.

This cover alternatives evaluation memorandum focuses on the evaluation of one generalresponse action: containment. This general response action will be evaluated and comparedwith other general response actions (e.g no action, excavation) in the FWA FS Report. Thepurpose of the cover alternatives evaluation is to recommend a containment remedialtechnology (i.e. a cover) and cover process options (e.g. cover materials) that will beincluded in the FWA FS array of remedial alternatives.

This section presents the criteria for the development of cover alternatives for the FWA.Two main criteria have been considered for development of the cover alternatives presentedin Section 4.0. These criteria are as follows:

• Remedial action objectives for the FWA• Applicable or relevant and appropriate requirements (ARARs)

These criteria are discussed in the following section.

3.1 REMEDIAL ACTION OBJECTIVES FOR FWA

CERCLA Section 121(d) states that any remedial action selected for a Superfund site shallattain a degree of cleanup of hazardous substances, pollutants, and contaminants released intothe environment and of control of further releases, at a minimum, which assures protectionof human health and the environment. In conjunction with these requirements, remedial


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action objectives have been developed to permit a range of treatment and containmentalternatives to be developed.

The remedial action objectives for the Fields Brook FWA are as follows:

• Minimize potential for human contact with soils having average chemicalconcentrations that exceed risk-based cleanup standards.

• Minimize potential for contact with soil that causes adverse effects onecological receptors,

• Minimize ecological harm from the remedy.

The FS for the FWA will evaluate the degree that each assembled alternative will providein meeting the remedial action objectives for the FWA. The cover alternatives evaluationincludes an assessment of each cover alternative in meeting these objectives.

3.2 POTENTIAL ARARS FOR THE FLOODPLAIN/WETLANDS AREA, COVERALTERNATIVE

Section 121(d) of CERCLA requires that Superfund remedial actions attain any federalenvironmental or state environmental and facility siting standards, requirement, or criteriathat are determined to be ARARs or obtain a waiver. The requirements of federalenvironmental and state environmental and facility siting laws and regulations are identifiedand applied to remedial actions as ARARs using the approach outlined in the USEPA'sCERCLA Compliance with Other Laws Manual (Interim Final) Part I (USEPA 1988b) andPart II: Clean Air Act and Other Environmental Statutes and State Requirements (USEPA1989b).

In addition to ARARs, the FS will consider guidelines, criteria, and standards that may beuseful in evaluating remedial alternatives. These guidelines, criteria, and standards areknown as TBCs. In contrast to ARARs, which are promulgated standards, standards ofcontrol, and other substantive environmental protection requirements, criteria or limitations;


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Materials to be considered (TBCs) are guidelines and other criteria that have not beenpromulgated. A listing of TBCs is provided in the FS in Section 4.0. TBCs will supplementARARs when the use of the TBCs is deemed necessary to meet FWA remedial actionobjectives.

3.2.1 Location-Specific ARARs

Location-specific ARARs establish restrictions on the management of waste or hazardoussubstances in specific protected locations, such as wetlands, floodplains, historic places, andsensitive habitats. Table 3-1 provides a listing of potential location-specific ARARs for theFloodplain/Wetlands Area at the Fields Brook site.

3.2.2 Action-Specific ARARs

Action-specific ARARs are technology-based or activity-based requirements or limitationson actions taken with respect to remediation. These requirements are triggered by particularremedial activities that are selected to accomplish the remedial objective. The action-specificARARs do not determine the remedial alternative, rather they indicate the way in which theselected alternative must be implemented as well as specify levels for discharge, if required.Table 3-2 provides a listing of potential action-specific ARARs for the Floodplain/WetlandsArea. The action-specific ARARs listed in Table 3-2 include the Ambient Water QualityCriteria and the Ohio Water Quality Standards, which contain specific standards that wouldbe applicable if contaminants are discharged directly to Fields Brook or the Ashtabula Riverduring cover construction.

3.3.3 Chemical-Specific ARARs

Chemical-specific ARARs, as defined by the USEPA (1988a), are usually health- orrisk-based numerical values or methodologies which, when applied to site-specific conditions,result in the establishment of numerical values. These promulgated values establish theacceptable concentration of a chemical that may be found in the ambient environment.There are no chemical-specific ARARs for the FWA.


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Environmental requirements that provide numerical limits for chemicals, such as AmbientWater Quality Criteria and National Ambient Air Quality Standards, are consideredaction-specific ARARs since their application depends on the remedy selected for the FWA.

3.3.4 ARARs Evaluation for FWA Cover Alternatives

Potential location-specific and action-specific ARARs are listed in Tables 3-1 and 3-2. TheARARs that are most likely to drive the selection of a remedy for the Floodplain/WetlandsArea are the floodplain and wetland protection standards of Executive Orders 11988 and11990 and Section 404 of the Clean Water Act.

Executive Orders 11988 and 11990 limit activities in floodplains and wetlands. Theregulations promulgated pursuant to these Executive Orders require that, where a practicablealternative exists to an action that would result in adverse impacts to floodplains or wetlands,the action may not proceed. If no practicable alternative to the action exists, adverse impactsmust be minimized. Under Clean Water Act Section 404, adverse impacts associated withthe destruction or loss of wetlands must be avoided to the extent possible. Should cappingbe shown to be an effective method for containing the contaminants located in the FWA,avoiding post-capping adverse impacts from contaminants, and preserving floodplain andwetland functions, the capping alternative may be seen as a positive impact in the long term.


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4.0DESCRIPTION OF POTENTIAL COVER ALTERNATIVES

Five cover alternatives have been selected for evaluation. Each cover alternative is intendedto provide a competent barrier for the protection of human health by preventing dermalcontact with the underlying soils and to protect potential ecological receptors. Fill materials(e.g., soil or stone) will be borrowed from an offsite source. Specifications for the borrowmaterials, compactive effort and similar design issues are beyond the scope of thismemorandum and are not presented.

Three moisture conditions must be considered for the application of these alternatives. Theconditions are as follows:

• "Moist" condition - the water table is below the existing leaf pack within theexisting soil layer. Note that this condition considers that the leaf pack maybe dry at the surface, and soils are generally moist to saturated at depth.

• "Saturated" condition - the water table is above the soil layer but within theleaf pack layer.

• "Submerged" condition - the water table is above the leaf pack and the soillayer and the area is typically inundated with ponded water. The typicalponded depth is approximately 3 inches. Less than 10% of the remedialresponse area is characterized by these conditions.

As discussed in Section 2.5, the soil surface in all five FEUs is covered by approximately3 inches of leaves. The vegetation in each FEU consists of grasses, shrubs, and trees thatare typical of wetland areas. The following cover alternatives are assumed to be placed ontop of the leaf pack and with minimal clearing of mature trees. The cover alternatives aresummarized in Table 4-1.


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4.1 COVER ALTERNATIVE I

Cover alternative I is depicted in Figure 4-1. This alternative consist of three elements (frombottom to top):

1. a minimum 6-inch thick soil layer,2. a re-vegetation layer, and3. an erosion protection mat.

Alternative I is intended for moist or saturated conditions (i.e., water table is below thesurface of the existing soil layer or within the leaf pack). Soil fill is placed to the watersurface and is covered with an additional 6-inch layer. The soil used for cover will consistof hydric compatible soils. This soil type was selected to be supportive of plant growth andsimilar to existing wetland soils. Re-vegetation utilizing hydroseeding, selective planting,or other techniques will be required. A soil erosion mat will be installed on top of the coverfor erosion control during re-establishment of vegetation. The vegetation layer will protectthe soil cover from erosion. Re-vegetated growth will re-established with native plantspecies immediately following cover placement.

4.2 COVER ALTERNATIVE II

Cover Alternative II is similar to I but consists of a 12-inch minimum soil layer. AlternativeII is depicted in Figure 4-2. The two elements of this cover design include (from bottom totop):

1. a minimum 12-inch thick soil layer,2. a re-vegetation layer, and3. an erosion protection mat.

Alternative II is intended for moist or saturated conditions. Soil fill is placed to the watersurface and is covered with an additional 12-inch layer. The soil used for cover will consistof hydric compatible soils. This soil type was selected to be supportive of plant growth andsimilar to existing wetland soils. Re-vegetation utilizing hydroseeding, selective planting,

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or other techniques will be required. A soil erosion mat will be installed on top of the coverfor erosion control during re-establishment of vegetation. The vegetation layer will protectthe soil cover from erosion. Re-vegetated growth will re-established with native plantspecies immediately following cover placement.

4.3 COVER ALTERNATIVE III

Cover alternative III is depicted in Figure 4-3 and consists of four elements (from bottomto top):

1. a minimum 3-inch thick layer of small stone,2. a minimum 3-inch thick layer of soil,3. a re-vegetation layer, and4. an erosion protection mat.

Alternative III is intended for moist or saturated conditions. It can also be used insubmerged areas. The stone layer will facilitate placing the soil layer in submergedconditions and will provide additional protection against penetration by humans or burrowinganimals. The soil used for cover will consist of hydric compatible soils. This soil type wasselected to be supportive of plant growth and similar to existing wetland soils. Re-vegetationutilizing hydroseeding, selective planting, or other techniques will be required. A soilerosion mat will be installed on top of the cover for erosion control during re-establishmentof vegetation. The vegetation layer will protect the soil cover from erosion. Re-vegetatedgrowth will re-established with native plant species immediately following cover placement.

4.4 COVER ALTERNATIVE IV

Cover alternative IV is depicted in Figure 4-4 and consists of three elements (from bottomto top):

1. a minimum 3-inch thick layer of soil,2. a re-vegetation layer, and3. an erosion protection mat.


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Alternative IV is applicable for only the moist or saturated moisture conditions. The soilused for cover will consist of hydric compatible soils. This soil type was selected to besupportive of plant growth and similar to existing wetland soils. Re-vegetation utilizinghydroseeding, selective planting, or other techniques will be required. A soil erosion matwill be installed on top of the cover for erosion control during re-establishment of vegetation.The vegetation layer will protect the soil cover from erosion. Re-vegetated growth will bere-established with native plant species immediately following cover placement.

4.5 COVER ALTERNATIVE V (SPECIAL CONDITIONS)

Cover alternative V is depicted in Figure 4-5 and consists of two elements (from bottom totop):

1. a non-woven geotextile, and2. a minimum 3-inch thick layer of small stone.

Alternative V is applicable for only submerged conditions. If submerged conditions areidentified in remedial response areas that use cover alternatives I, II, III, or IV, than coveralternative V will be used. The geotextile and the stone layer will facilitate placing thematerials in submerged conditions and will provide additional protection against penetrationby humans or burrowing animals. Re-vegetation is not a necessary part of this design butcould be integrated using fabricated vegetative matting or other techniques. Since the surfacewill consist of small stone, special techniques will need to be employed to re-establish asurface vegetation layer.


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5.0EVALUATION AND COMPARISON OF COVER ALTERNATIVES USING

CERCLA EVALUATION CRITERIA

This section presents an evaluation of the five cover alternatives identified in Section 4 usingthe seven CERCLA evaluation criteria presented in USEPA guidance (USEPA, 1988a). Theresults of the criteria evaluation are summarized in Table 5-1.

5.1 CERCLA CRITERIA FOR EVALUATION OF ALTERNATIVES

The Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA(USEPA 1988a) provides nine evaluation criteria to address the CERCLA statutoryrequirements and considerations:

1. Overall protection of human health and the environment,2. Compliance with ARARs,3. Long-term effectiveness and permanence,4. Reduction of toxicity, mobility, or volume through treatment,5. Short-term effectiveness,6. Implementability,7. Cost,8. State acceptance, and9. Community acceptance.

The nine criteria are grouped into three categories: threshold, balancing and modifying.The threshold criteria (Nos. 1 and 2) focus on how risks posed through each exposurepathway are reduced, controlled, or eliminated. Balancing criteria (Nos. 3 through 7) areused to further evaluate the alternatives that satisfy the threshold criteria. The modifyingcriteria (Nos. 8 and 9) include community and state acceptance and are evaluated by theUSEPA following a review of the public comments on the RI/FS documents. Modifyingcriteria are not evaluated in this document.

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The main aspects of the seven criteria to be evaluated during the detailed evaluation of thealternatives are discussed below.

1. Overall Protection of Human Health and the Environment: This criterion isused to provide an overall assessment of the degree to which each alternativeprotects human health and the environment. The overall protectivenessfocuses on whether the alternative would achieve adequate protection and howexisting site risks would be eliminated, reduced or controlled throughtreatment, engineering, or institutional controls. Because this criterion isconsidered a threshold criterion, overall protection must be provided for analternative to be considered a remedy for the site.

2. Compliance with ARARs: This criterion is used to assess whether analternative would meet all federal and state ARARs. This criterion is also athreshold criterion.

3. Long Term Effectiveness and Permanence: This criterion is used to assessthe risk that would remain at the site after the remedial action objectives areachieved. The extent and effectiveness of the controls needed to manage anytreatment residuals or untreated wastes are assessed by determining themagnitude of any residual risk remaining at the site at the conclusion of theremedial activities. The adequacy and reliability of the controls used tomanage treatment residuals or untreated wastes, if any, are assessed.

4. Reduction of Toxicitv. Mobility, or Volume through Treatment: Thiscriterion allows for an assessment of the degree to which treatment ofhazardous substances would permanently and significantly reduce toxicity,mobility, or volume of the hazardous substance (i.e., contaminants). Thiscriteria is not applicable for evaluation of the cover alternatives, becausetreatment technologies are not part of the cover alternatives.

5. Short-Term Effectiveness: This criterion is used to address the effects of analternative during the construction and implementation of remedial activitiesuntil the remedial action objectives would be achieved. The issues consideredinclude protection of workers and the community during construction andimplementation, any environmental impacts that might result, and the lengthof time until the remedial action objectives would be achieved.

6. Implementabilitv: The implementability criterion is used to assess thetechnical and administrative feasibility of implementing an alternative,availability of the technologies, and the availability of various services and


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materials required during implementation. Technical feasibility refers to thetechnical difficulties and variables associated with the alternatives, thereliability of the technologies, and monitoring requirements. Administrativefeasibility includes the activities which require coordination with regulatoryoffices or agencies.

7. Cost: The cost evaluation includes capital costs, and annual operation andmaintenance (O&M) costs. The cost estimates are order-of-magnitude levelestimates, as defined by the American Association of Cost Engineers, and areapproximate estimates made without complete engineering data. Typically,an estimate of this type is expected to be accurate to +50% and -30% forunit quantities. The actual cost would depend on the final scope of theremedial action, the implementation schedule, actual labor and material costs,competitive market conditions, and other variables that may affect projectcost. EPA guidance requires the cost of the remedy to be proportional to itsoverall effectiveness.

5.2 COMPARATIVE ANALYSIS OF COVER ALTERNATIVES

In this section and in Table 5-1, the alternatives are evaluated in relation to one another foreach of the seven evaluation criteria. The objective of this analysis is to identify the relativeadvantages and disadvantages of each alternative and to provide a basis for selecting therecommended alternative that is presented in Section 6.


Each of the FWA cover alternatives provides protection of human and ecological receptorsfrom exposure by capping impacted floodplain and wetland soils. Cover alternatives I, II,and IV provide overall protection by the placement of a soil cover that will also promotereestablishment of vegetation in the wetland. The degree of protection for these threealternatives generally is relative to the thickness of the cover (i.e. the thicker the cover, themore protective the cover although the thickest cover may reduce future wetland conditionsat some locations). Therefore, cover alternative II is most protective, followed by coveralternative I with cover alternative IV being the least protective.

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Cover alternatives III and V provide overall protection by the placement of multimediacovers on the FWA. The multimedia covers are more effective at protecting human andecological receptor from exposure to chemicals of concern than comparable thicknesses ofsoil cover; however, reestablishment of vegetation and benthic communities on multimediacovers may be more difficult or less effective than on soil covers.

5.2.2 Compliance With ARARs

The ARARs that are most likely to affect construction of capping alternatives for theFloodplain/Wetlands Area are the floodplain and wetland protection standards of ExecutiveOrders 11988 and 11990 and Section 404 of the Clean Water Act.

The regulations promulgated pursuant to the Executive Orders and the Clean Water Actrequire that, where a practicable alternative exists to an action that would result in adverseimpacts to floodplains or wetlands, the action may not proceed. If no practicable alternativeto the action exists, adverse impacts must be minimized. The only practical alternative withthe lowest impact to floodplain wetland areas is the no action alternative. An excavationalternative would have the highest adverse impact than any of the cover alternatives. Thishigh adverse impact is based on the complete removal of natural occurring organic bioticmaterial from excavation areas which will be replaced with fill. This new material wouldbe less likely to re-establish existing root and woody vegetation. However, the use of hydriccompatible soils would likely promote regrowth of existing and revegetated plant species.Cover Alternatives 1 and IV comply with low adverse impact to wetlands. As a result ofdeeper burial of the naturally occurring vegetation, Cover Alternatives II and IV comply witha moderate adverse impact to wetlands.


The long-term magnitude of residual risk to human health and the environment is expectedto be lowest for the thickest cover alternatives and those utilizing stone (Cover AlternativesII and III). The long-term magnitude of residual risk to human health and the environmentis expected to be highest for the thinnest cover (Cover Alternative IV).


Woodward-Clyde

Draft

Each cover alternative will require O&M (i.e. inspection and repairs, if necessary) tomaintain the integrity of the cover and to minimize risks of exposure to human andecological receptors to COCs over the long-term. Items that will be assessed during routineinspection of the covers include erosion and re-vegetation. Erosion control andreestablishment of appropriate wetland vegetation are key control measures that will impactthe long-term effectiveness of each cover alternative. Each of the cover alternatives thatutilize soil may require erosion control measures for protection during flood events;however, cover alternatives that utilize hydric compatible soils are expected to promote thedesired vegetation.

Each cover is expected to impact the existing hydrology of the Fields Brook channel andfloodplain. The cover alternatives may change storage capacity and roughness coefficients(due to changes in vegetation) of the FWA that would potentially impact stream velocity andupstream/downstream water levels during flood events. Cover Alternative II would createthe highest impact to the existing hydrology, because it is the thickest cover. The loss in thestream cross-sectional area for a 100-year flood using Cover Alternative II would likely begreater than 10% at locations where the cover will be installed across the entire floodplain.Cover alternative IV would create the least impact to the existing hydrology, because it isthe thinnest cover and vegetation is expected to be easily reestablished on this cover.

Environmental impacts are expected to be highest for Cover Alternative III because of thesoil and stone layers on the existing ecology. The stone layers will reduce the ability of theecosystem to support the growth of new woody vegetation to a greater extent than the otheralternatives, and would likely alter the community structure of annual shrubs, grasses, andlarger herbaceous species. The deep cover design (Cover Alternative II) is likely to causesevere ecological impacts, including stress to existing trees and substantial loss of wetlandareas. The addition of 12-inches of soil on top of the existing leaf pack material is likelyto severely limit the ability of vegetation to regrow in these areas, which involves existingroot mat beneath cleared areas and seed stock. The 3-in. and 6-in. soil covers (CoverAlternatives I and IV) provide the lowest ecological impact of the cover alternatives. Soiladdition of less then 6 inches is unlikely to stress woody vegetation. The use of a hydriccompatible soil is expected to be supportive of plant growth and provide a replacement soiltype that is similar to existing wetland soils. Understory shrub and herb layer communities


Woodward-Clyde

Draft

are likely to re-establish in their present configurations under Cover Alternatives I and IV,although some wetland character may be lost.

5.2.4 Reduction of Toxicity, Mobility, and/or Volume Through Treatment

None of the cover alternatives would result in any reduction of toxicity, mobility, or volumeof COCs through treatment. This criterion is not applicable for evaluating differencesbetween cover alternatives.


Each of the cover alternatives is expected to be similar in short-term impacts on thecommunity, workers, and the environment during construction. Primary worker hazards willinclude physical hazards associated with conventional construction activities. Constructionof each of the cover alternatives and achievement of the Remedial Action Objectives isexpected to take less than one year, following completion of design and award of thecontract.

5.2.6 Implement ability

Cover alternatives I and II are easily constructed using conventional construction techniques.The thin (3-in.) layers included in Cover Alternatives III and IV may be difficult to placeand control thickness. Cover Alternative III will be more labor intensive during constructionthan the other alternatives due to placement of two layers of material. The materials,services, equipment, and specialists required for construction of each of the coveralternatives are readily available. Standard methods of inspection will be utilized to monitorthe effectiveness of each cover alternative.

S:\BROOKFS\FWA_COVE\COVERQ05 5-6 12-14-95

Woodward-Clyde

Draft

5.2.7 Cost

The estimated cost for each alternative is divided into capital costs and annual O&M costs.The lowest estimated capital cost is for Cover Alternative IV ($18,400 per acre) and thehighest estimated capital cost is for Cover Alternative III ($31,500 per acre). The capitalcosts do not include clearing and grubbing because these costs are expected to be similar foreach cover alternative. The annual operation and maintenance (O&M) costs are based onarea to be maintained and do not vary by cross-section of cover options. O&M costs willbe evaluated in the FWA FS.


Woodward-Clyde

Draft

6.0SELECTED COVER ALTERNATIVE

The results of the cover alternative evaluation presented in Section 5.0 suggest that CoverAlternative I provides the optimal balance among the CERCLA evaluation criteria.Alternative I includes a 6 inch hydric compatible soil cover, re-vegetation and placement ofan erosion protection mat for application on moist or saturated soil areas. If submergedconditions are encountered, Alternative V (Special Conditions) will be considered.

In response to requests from USEPA during the November 2, 1995 meeting, the coverdesign used in the FWA FS was modified to provide a higher degree of protectiveness inareas of the floodplain having PCBs in excess of 100 ppm. As a result, two additionalalternatives were developed to include a twelve inch cover in areas requiring moreprotectiveness. In areas requiring a 12 inch cover, Cover II was selected.

The evaluation criteria with the biggest impact on the selection of cover alternatives includeoverall protectiveness, long-term effectiveness and permanence, short-term effectiveness,implementability, and cost. Compliance with ARARs, and reduction of toxicity, mobility,and volume through treatment criteria are similar for each of the cover alternatives, and donot influence selection of a recommended cover alternative.

Cover Alternative I provides adequate overall protectiveness of human health and theenvironment compared to the other cover alternatives. Cover Alternative I also providesmoderate reduction of residual risk to human and ecological receptors, and are expected tohave moderate impacts on the existing floodplain hydrology and continuation of wetlandconditions compared to other cover alternatives. Cover Alternative I will be easilyconstructed and is expected to have lower environmental impacts during construction thanthe other cover alternatives. In particular, Cover Alternative I will provide a cover materialthat allows for regrowth of woody vegetation, grasses, herbaceous plant species, and issimilar to existing wetland soils.


Woodward-Clyde

Draft

The capital costs of Cover Alternative I is the second lowest of the cover alternatives. Thelow cost, low to moderate environmental impacts expected during and after construction, andthe adequate overall protection of risk to human and ecological receptors make CoverAlternative I the most cost-effective alternative for meeting remedial action objectives forthe Fields Brook FWA, Balancing of the protectiveness and adverse impact of remediationfor the size and location of the remedial response areas will be developed in the feasibilitystudy.


Woodward-Clyde

Draft

7.0REFERENCES

Fields Brook Potentially Responsible Parties Organization. 1994. Phase I Report, SedimentQuantification Design Investigation.

Fields Brook Potentially Responsible Parties Organization. 1995. Phase II Report, SedimentQuantification Design Investigation.

U.S. Environmental Protection Agency. 1986. Record of Decision, Fields Brook SuperfundSite, Ashtabula, Ohio.

Woodward-Clyde Consultants (WCC). 1995. FWA Field Reconnaissance and PhotoDocumentation, Fields Brook Site, Ashtabula, Ohio.

S:\BROOKFS\FWA_COVE\COVER.007 7-1 12-14-95

Tables

DRAFTTABLE 3-1

POTENTIAL LOCATION-SPECIFIC ARARS FOR COVER ALTERNATIVESFIELDS BROOK SITE - FLOODPLAIN/WETLANDS AREA

ASHTABULA, OHIO



Comments

Location-Specific Laws/Requirements

FEDERAL REGULATIONS

E.O. 11988 Protection of Floodplains

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 area subject to a one percent orgreater chance of flooding in any given year." Federalagencies must evaluate the potential effects of actions takenin a floodplain and avoid adverse impacts from remedialactivities, if a practicable alternative to the action exists.Where no practicable alternatives exist, adverse impactsmust be minimized. [40 CFR 6.302B and Appendix A]

Yes No The site lies within the 100-year floodplain. Ifremedial activities are conducted within thefloodplain, or adversely affect natural floodplainvalues, this regulation will be applicable.

E.O. 11990 - Protection of Wetlands

2. Requires that adverse impacts to areas designated as Yeswetlands be avoided where there is a practicable alternativeto the activity. Where no practicable alternative exists,adverse impacts must be minimized. [40 CFR 6.302(a) andAppendix A]

Clean Water Act Section 404

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

S:\BROOKFS\FWA_COVE\TAB1.E3-' DOC

No

No

Wetlands occur along Fields Brook. Regulationsare applicable to remedial activities that wouldimpact the wetlands areas.

Wetlands occur along Fields Brook; regulationswould be applicable to remedial activities thatwould impact the wetlands areas.

a.6I

TABLE 3-1 (Continued)POTENTIAL LOCATION-SPECIFIC ARARS FOR COVER ALTERNATIVES

FIELDS BROOK SITE - FLOODPLAIN/WETLANDS AREAASHTABULA, OHIO



Comments

4. Prohibits discharge of dredged or filled material into waters Yesof the 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 or Yesaffecting navigable waters. [33 USC 403, 33 CFR 320-330]

Endangered Species Act

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

National Historic Preservation Act (NHPA)

7. Requires the preservation of historic properties included in Noor eligible for the National Register of Historic Places and tominimize harm to National Historic Landmarks.[16 USC 470 et seg.; 40 CFR 6.301(b); 36 CFR Part 63,Part 65, Part 800]

Wilderness Act

8. Limits activities within areas designed as wilderness areas or NoNational Wildlife Refuge Systems. [16 USC 1311,

No Regulations would be applicable if the remedialaction involves dredge and/or fill activities inFields Brook.

No If the remedial activity affects navigable waters,the substantive requirements of these regulationswill be applicable. No permit would be requiredfor an on-site action.

No If there are threatened/endangered (T/E) speciesor critical habitats within the areas impacted bythe remedial activities, this regulation would beapplicable. No such endangered species areknown within the area.

No This Act would only be applicable if culturalresources at the site are eligible for inclusion onthe National Register of historic places. None isknown.

No The site is not within a federally owned areadesignated as a wilderness area or a National

S:\BROOKFS\FWA_COVRTABLEM .DOC Draft

AFTTABLE 3-1 (Continued)

POTENTIAL LOCATION-SPECIFIC ARARS FOR COVER ALTERNATIVESFIELDS BROOK SITE - FLOODPLAINAVETLANDS AREA

ASHTABULA, OHIO



Comments

16 USC 668; 50 CFR 53, 50 CFR 27]

Wild & Scenic Rivers Act

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

No No

Wildlife Refuge System.

Neither Fields Brook nor its receiving stream islisted as a Wild or Scenic River.

Fish and Wildlife Coordination Act

10. Requires coordination with federal and state agencies on Yesactivities affecting/modifying streams or rivers if the activityhas a negative impact on fish or wildlife. [16 USC 661 etseg.;40CFR6.302(g)]

11. Any activity modifying a stream or river, which will have a Yesdiversion, channeling, or other action and which affects fishor wildlife must be implemented with action to protect fishor wildlife [16 U.S.C 661 et seq.]

No If Fields Brook will be impacted by remedialactivities, this regulation would be applicable.

No This Act would only be applicable if:(1) pollutants or dredge and fill are dischargedinto a body of water or wetlands, and/or (2) dams,levees, impoundments, stream relocation, and/orwater diversion structures are constructed.

ft

S:\BROOKFfflFWA_COVEVTABLEl 1.DOC

a.6

Draft(D

TABLE 3-2POTENTIAL ACTION-SPECIFIC ARARS FOR COVER ALTERNATIVES

FIELDS BROOK SITE - FLOODPLAINAVETLANDS AREAASHTABULA, OHIO


PotentiallyRelevant

andAppropriate

To BeConsidered

(TBC)Comments

FEDERAL REGULATIONS

Toxic Substances Control Act (TSCA>

1. Contaminated soil, rags, or other debriscontaining 50 ppm or greater PCBs must bedisposed of in an incinerator or chemical wastelandfill, as specified in the regulations. [40 CFR76l.60(a)(4)]

Clean Air Act

National Ambient Air Quality Standards (NAAQS)

2. Establishes ambient air quality standards toprotect public health and welfare. [40 CFR 50]

Yes No No

Yes Unknown No

Clean Water Act

Ambient Water Quality Criteria

3. Requires EPA to publish water quality criteriafor specific pollutants for the protection ofhuman health and the protection of aquatic life.[40 CFR 131]

No Yes No

Applicable if soil, rags, or other debriscontaining at least 50 ppm of PCBs aregenerated during remediation.

Only applicable if criteria pollutants aredischarged to the atmosphere during wastehandling, a treatment process, and/orconstruction activities. NAAQS would be usedto compare ambient air quality during theremedial action.

Relevant and appropriate if contaminants arereleased to surface waters or if treatedgroundwater is collected and discharged tosurface waters.

S:\BROOKFS\FWA_COV\TABLE3-ZCAP 12-15-95

TABLE 3-2 (Continued)POTENTIAL ACTION-SPECIFIC ARARS FOR COVER ALTERNATIVES

FIELDS BROOK SITE - FLOODPLAINAVETLANDS AREAASHTABULA, OHIO


PotentiallyRelevant

andAppropriate

To BeConsidered

(TBC)Comments

Storu Water Discharge Regulations

4. Establishes permitting, sampling and analysisrequirements for industries in certain categorieswhich discharge storm water to waters of theUnited States. Includes storm water dischargefrom construction activities., [40 CFR 122]

Yes No No No storm water permit would be required foran on-site CERCLA remedial action thatinvolves a discharge. Substantiverequirements (e.g., Storm Water PollutionPrevention Plans) could be applicable, forexample to construction activities associatedwith remediation.

Resource Conservation and Recovery Act (RCRA)

RCRA Corrective Action Management Unit Rule

5. Provides for designation of a Corrective ActionManagement Unit and eases regulatoryrequirements for remedial actions conductedwithin unit boundaries. [40 CFR 260 et al]

No Yes No Would be potentially relevant and appropriatefor management of hazardous waste within aunit boundary.

S:\BROOKFS\FW A_^JOV\TABLE3-2.CAP 12-15-95

TABLE 3-2 (Continued)POTENTIAL ACTION-SPECIFIC ARARS FOR COVER ALTERNATIVES

FIELDS BROOK SITE - FLOODPLAIN/WETLANDS AREAASHTABULA, OHIO


PotentiallyRelevant

andAppropriate

To BeConsidered

(TBC)Comments

RCRA Hazardous Waste Treatment Storage andDisposal Regulations

6. Provides regulations for the notification of Yeshazardous waste activities, identification andlisting of hazardous wastes and management ofhazardous wastes by generators, transporters andoperators of treatment storage and disposalfacilities. [40 CFR 260 et al]

7. Specifies requirements for closure of hazardous Nowaste management units. [40 CFR Part 264,Subpart G, and 40 CFR 228(a) and (b)]

8. These regulations establish standards for design, Noinstallation, and maintenance of dikes around aunit, to ensure the unit does not fail or overtop,and to remedy problems and any contamination.[40 CFR 264. 221(g) and (h), and 264.228(a)and (b)]

RCRA Solid Waste Treatment Storage andDisposal (TSD) Regulations

9. Establishes requirements for owners and Yesoperators of solid waste disposal facilities [40CFR 258]

Yes No

Yes

Yes

No

No

Yes No

Substantive requirements would be potentiallyapplicable or relevant and appropriate shouldany hazardous wastes be generated duringremediation. If contaminated soil wereconsidered solid or hazardous waste,designation of a corrective action managementunit would allow certain movement of soilwithout triggering the Land DisposalRestriction regulations

These regulations would not apply, but may berelevant and appropriate to in-placecontainment

These regulations would be relevant andappropriate if remedies selected includeinstallation of a dike around a wastemanagement unit.

Substantive requirements would be potentially applicif solid wastes are generated during constructionactivities. However, only applicable if no equally or istringent state regulation exists (see below).

S:\BROOKFS\FWA_COV\TABLE3-2.CAP 12-15-95

DRAFTTABLE 3-2 (Continued)

POTENTIAL ACTION-SPECIFIC ARARS FOR COVER ALTERNATIVESFIELDS BROOK SITE - FLOODPLAINAVETLANDS AREA

ASHTABULA, OHIO


PotentiallyRelevant

andAppropriate

To BeConsidered

(TBC)Comments

STATE REGULATIONS

Ohio Non-Point Source Regulations

1. Regulations call for the use of conservation Yespractices to control sediment pollution of waterresources. [OAC, Title 1501, Chapters 1, 3, 5]

Ohio Water Quality Standards

2. Establishes minimum water quality requirements Yesfor al! surface waters of the state. Establishesstream use designations and water qualitycriteria protective of such uses. See Table 4-3.[OAC, Title 3745, Chapter 1]

Ohio Ambient Air Quality Standards and Guidelines

3. Establishes ambient air quality standards for Yescriteria pollutants applicable in Ohio. Requiresattainment of the standards through applicationof pollution control techniques. [OAC, Title3745, Chapter 21]

No

No

No No

These regulations could be applicable for anymajor earth-disturbing activities.

Applicable if contaminated water is dischargedinto surface waters. Could be triggered byconstruction activities.

May be applicable if the remedial actionchosen involves air emissions of any criteriapollutants. Construction activities may triggerambient air quality standards due to emissionsof particulates.

S:\BROOKFS\FWA_COV\TABLE3-2.CAP 12-15-95

oaIa6f0

Woodward-Clyde

DRAFT

TABLE 4-1COVER ALTERNATIVES FOR FLOODPLAINAVETLANDS AREA

FIELDS BROOK SUPERFUND SITE

Cover Alternative

Six inches of hydric compatible soil withhydroseeding

~6"

ConfigurationHvdroseedina

Application

__ Erosion Protection

Soil Cover

. |Existing Leaf Pack Saturated

II.Twelve inches of hydric compatible soilwith hydroseeding

Hydroseeding

Existing ileaf Pack '

Erosion ProtectionMat

Three inches of stone overlain by threeIII. inches of hydric compatible soil with

hydroseeding

Hydroseeding4OOOOOOOOOOO0QOOQOQOQOQMQOOQ0OQOQQQ90P90QQQ9909O09OOQOC

Soil Cover

T- . ,, . .Erosion Protection, -Mat

SubmergedSaturated

IV. Three inches of hydric compatible soil withhydroseeding

^ ~—— Hydroseedingf******?*?!?*??**?^^*********^

3" : i : : t . - -?, : Son Cover

Erosion ProtectionMatSaturated

V. Three inches of stone underlain by a non-woven geotextile (Special Conditions)

-3-~3"

Non-Woven Geotextile

Exist in a Leaf Pack ^~*

Submerged

TABLE 5-1EVALUATION OF COVER ALTERNATIVESFLOODPLAINAVETLAND AREA, FIELDS BROOK SITE

DRAFT

No.

1

2

Criteria

Soil Condition:

Overall Prolectiveness

• Protection of humanhealth and theenvironment

Compliance with ARARs

• Location-SpecificARARs

• Action -SpecificARARs

• Chemical-SpecificARARs

I

6 in. of clayeyorganic soil withrevegetation and

erosion protectionmat

Moist/Saturated

II



Moist/Saturated

AlternativesIII

3 in. of stoneoverlain by 3 in. ofclayey organic soilwith revegetation

and erosionprotection mat

Moist/Saturated/Submerged

Cover will provideadequate protectionagainst humanexposure throughdermal contact andagainst exposure byecological receptors

Thickest cover of thealternatives provideshighest protectionagainst humandermal contact andagainst exposure byecological receptors

Cover will provideadequate protectionagainst humanexposure throughdermal contact andagainst exposure byecological receptors

IV



Moist/Saturated

V

3 in. of stoneunderlain by

geotextile

(Special Conditions)

Submerged

Thinnest cover of thealternatives provideslowest protectionagainst humandermal contact andagainst exposure byecological receptors

Geotextile willprovide highprotection againsthuman exposurethrough dermalcontact and againstexposure byecological receptors

Complies with lowadverse impact to

wetlands

Complies withmoderate adverse

impact to wetlands


impact to wetlands

Complies with lowadverse impact to

wetlands


impact to wetlands

Controls would comply with action-specific ARARs.

Not relevant. No chemical -specific ARARs are identified for the FWA. w&

S:\BROOKFS\FWA_COVE\311FB\86C3609S\TABLE5-1.DOCPage I of6

a6I

TABLE 5-1, CONTINUEDEVALUATION OF COVER ALTERNATIVESFLOODPLAIN/WETLAND AREA, FIELDS BROOK SITE

DRAFT

No. Criteria

Alternatives

I



II



HI

3 in. of stoneoverlain by 3 in. ofclayey orgnaic soilwith revegetation


IV




geotextile


Soil Condition: Moist/Saturated Moist/Saturated Moist/Saturated/Submerged

Moist/Saturated Submerged

Long-Term Effectivenessand Permanence

Relative Magnitude ofResidual Risk

0 HumanReceptors

0 EcologicalReceptors

Adequacy andReliability ofControls

0 Revegetation

Moderate reductionof risk for dermalcontact

Moderate reductionof exposure

High reduction ofrisk for dermalcontact

Moderate reductionof exposure


High reduction ofexposure

Low reduction of riskfor dermal contact

Low reduction ofexposure


High reduction ofexposure

Cover materialexpected to promotedesired plant growth.Clayey organic soilsexpected to providesimilar wetland soiltype and promoterevegetation.

Cover materialexpected to promoteplant growth. Clayeyorganic soilsexpected to providesimilar wetland soiltype and promoterevegetation.

Cover materialexpected to promoteplant growth. Clayeyorganic soilsexpected to providesimilar wetland soiltype and promoterevegetation.

Cover materialexpected to promotedesired plant growth.Clayey organic soilsexpected to providesimilar wetland soiltype and promoterevegetation.

Wetland vegetationmay not be re-established on stoneand geotextile media.

S:\BROOKFS\FWA_COVE\311 FB\86C3609S\TABLE5-1 .DOCPage 2 of6


DRAFT

No.

4

Criteria

Soil Condition:

0 Erosion

• O&MRequirements

• RelativeHydrologicalImpact (e.g.storage capacity,stream velocity,floodingupstream/downs tream)

Reduction or Toxicitv.Mobility, or VolumeThroueh Treatment

Alternatives

I



Moist/Saturated

II



MoistfSaturated

Ill

3 in. of stoneoverlain by 3 in. ofclayey organic soilwith ri'vegetation



IV



Moist/Saturated

Revegetation expected to provide erosion protection during flood events.

V


geotextile


Submerged

Higher erosionresistance than soil

covers; erosionresistance will

depend upon stoneparticle size.

Routine inspection of cover and vegetation required; repairs and/or revegetation must be made as necessary.

Low impact duringflood events due tothickness of cover.

Moderate impact,thickness of capl ikely to changestorage capacity andstream flowcharacteristicssignificantly duringflood events.

Low impact, f i l l ingof submerged areaswith stone will haveless impact onstorage capacity thanf i l l ing with soil.

Least impact onhydrology of floodplain.

Low impact, storagecapacity may bereduced and flowvelocity increased ifexisting vegetationcannot bereestablished on thiscover.

This criterion will be considered in the FWA Feasibility Study.

S:\BROOKFS\FWA_COVE\3IIFB\86C3609S\TABLE5-I.DOCPage 3 of 6

£oaa6Ift

TABLE 5-1, CONTINUEDEVALUATION OF COVER ALTERNATIVESFLOODPLAINAVETLAND AREA, FIELDS BROOK SITE

DRAFT

No.

5

Criteria

Soil Condition:

Short-Term Effectiveness

• Community Protection

• Worker Protection

• EnvironmentalImpacts

• Time Until Action isComplete

Alternatives

I



Moist/Saturated

II



Moist/Saturated

Ill




IV



Moist/Saturated

V


geotextile


Submerged

Risks to community only expected from non -con laminated airborne dust and vehicular traffic during constuction.

Primary worker hazards will be associated with conventional construction activities; risks of exposure to FWAcontaminants will be minimal.

Low environmentalimpact. Minimalclearing andgrubbing required,soil to be placed onexisting surfaces.

Moderate to highenvironmentalimpact. Minimalclearing andgrubbing required,soil lobe placed onexisting surfaces.Highest quantity ofmaterial to bebrought in on haulroads of all coveralternatives.

Moderate to highenvironmentalimpact. Minimalclearing andgrubbing required;filling of submergedareas will impactwetland flora, fauna,and water quality.

Low environmentalimpact. Minimalclearing andgrubbing required,soil to be placed onexisting surfaces.

High environmentalimpact. Placementof geotextile andfilling of submergedareas will impactwetland flora, fauna,and water quality.

Construction estimated to be completed in less than one year for each alternative.

S:\BROOKFS\FWA_COVE\311 FB\86C3609S\TABLE5-1 .DOCPage 4 of 6


DRAFT

No.

6

Criteria

Soil Condition:

Imnlemen (ability

• Ability to Constructand Operate

0 Cover

0 Revegetation

• Ability to MonitorEffectiveness

Alternatives

I



Moist/Saturated

II



Moist/Saturated

Ill

3 in. of stoneoverlain by 3 in. ofclayey organic soilwitb revegetation



IV



Moist/Saturated

V


geotextile


Submerged

'• • •:• \ •••••£* •••••. .*• : A!-. •.;;•:: ; ^'^Y'>:^:v'v.: -k-^01^ ô-H1^ \ .:AVs i;^? <» I's ; -1.-1 ^îix'^^'^^s'&^^^fî^:^ •i.'1:' &A-t:•'•'.. • ' ' . .. ,;/';S|C;W Xi IS ' " 4":c-;.V^.v; "/' :: ^ <>•.- '•'.••" "••.••• $ ^tr «>• "^:?;> '•& Sfe'l;1'0^ :; J:&>^|«l ii^^'^tf^p^ ^.-spf •>; sixî'!-'^

Easy to constructusing conventionalconstructiontechniques. Clayeyorganic soils may notbe available. Mixingof clay and compostmay be donedifficult.

Easy to constructusing conventionalconstructiontechniques. Clayeyorganic soils may notbe available. Mixingof clay and compostmay be donedifficult.

Thin layers may bedifficult to place andto control thickness.Clayey organic soilsmay not be available.Mixing of clay andcompost may be donedifficult.

Thin layers may bedifficult to place andto control thickness.Clayey organic soilsmay not be available.Mixing of clay andcompost may be donedifficult.

Vegetation easily reestablished by hydroseeding and/or selective planting.

More labor intensiveto install geotextilethan otheralternatives; thinlayers may be moredifficult to place andcontrol thickness

Revegetation onstone will require

special techniques,vegetation existing

prior to contstructionmay be difficult to

reestablish.

Standard, readily available methods will be utilized to monitor effectiveness.

OaI5.6

S:\BROOKFS\FW A_COVE\31IFB\86C3609S\TABLE5-I.DOCPage J of 6

TABLE 5-1, CONTINUEDEVALUATION OF COVER ALTERNATIVESFLOODPLAINAVETLAND AREA, FIELDS BROOK SITE

DRAFT

No.

7

Criteria

Soil Condition:

• Ability to ObtainApprovals andCoordinate with OtherAgencies

• Availability ofServices andMaterials

Cost

• Estimated CapitalCost (per acre)

• Annual O&M Cost(per acre)

Alternatives

I

6 in. of clayeyorganic soil withre vegetal! on and


Moist/Saturated

II

12 in. or clayeyorganic soil withrevegetation and


Moist/Saturated

III




IV


erosion protect! mmat

Moist/Saturated

V


geotextile


Submerged

Approval process and agency coordination are expected to be equivalent for each alternative.

Standard, readily available construction techniques, equipment, and materials will be utilized.

$34,800 $50,300 $33,300 $27,100 $18,300

Annual O&M costs vary based on area to be maintained and do not vary by cross-section of cover options. Thesecosts will be included in the FWA Feasibility Study.

S:\BROOKFS\FWA COVE\31!FB\86C3609S\TABLE5-1 DOCPage 6 of 6

Figures

REVEQETATION

HYDRIC-COMPATiBLE SOIL COVER

EROSIONPROTECTION MAT

(SATURATEDCONDITION)

(MOIST CONDITION)

COVER ALTERNATIVE I (MOIST OR SATURATED CONDITION)FIELDS BROOK SUPERFUND SITE - ASHTABULA. OHIO

DRAWN BY: MV | CHECKED BY; PO | PROJECT NUMBER; B6C5609S | DATE: 12-13-95 | FIGURE NO: 4-1u i\»ic Jio»s\covEiui.p\ FIGURE -1

Woodward-ClydeConsultants

REVEQETATION

HYDRIC-COMPATIBLE SOIL COVER

EXISTING LEAF PACK



(MOIST CONDITION)

COVER ALTERNATIVE II (MOIST OR SATURATED CONDITION)FIELDS BROOK SUPERFUND SITE - ASHTABULA, OHIO

DRAWN BY: MMSJ CHECKED BY: PO | PROJECT NUMBER; B6C3609S | DATE: 12-13-95 | FIGURE NO: 4-2


-REVEGETATION

HYDRIC COMPATIBLE SOIL COVER

EXISTING LEAF PACK


(SUBMERGED CONDITION)

(SATURATED CONDITION)

(MOIST CONDITION)

COVER ALTERNATIVE III (MOIST, SATURATED OR SUBMERGED CONDITION)FIELDS BROOK SUPERFUND SITE - ASHTABULA. OHIO

DRAWN BY: MMS | CHECKED BY: PO | PROJECT NUMBER: 86C3609S | DATE: 12-13-95 | FIGURE NO: 4-3


-REVEGETATION

HYDRIC-COMPATIBLE SOL COVER

EXISTING LEAF PACKf


r*r (SATURATED CONDITION)

±- (MOIST CONDITION)

COVER ALTERNATIVE IV MOIST OR SATURATED CONDITION)FIELDS BROOK SUPERFUND SITE - ASHTABULA. OHIO

DRAWN BY: MMS I CHECKED BY: PO | PROJECT NUMBER: 86C3609S | DATE: 12-13-95 | FIGURE NO: 4-4U:\6KJKWS\COVCTAL1\nOUK4


\- SMALL- ' • ' • • • ' • • ' • • " / : ' • • /o " STONE " *o " * "o" ' 'o

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EXISTING SOIL

±- (SUBMERGED CONDITION)

NON-WOVENGEOTEXTILE

COVER ALTERNATIVE V (SUBMERGED CONDITION)FIELDS BROOK SUPERFUND SITE - ASHTABULA. OHIO

DRAWN BYi MMS | CHECKED BY: PO | PROJECT NUMBER: B6C3609S | DATE; 12-05-95 | FIGURE NO: 4-5


FINAL

DRAWINGS FORFEASIBILITY STUDY

FLOODPLAIN / WETLAND AREASFIELDS BROOK SITE, ASHTABULA, OHIO

OCTOBER, 1996

PREPARED FOR:FIELDS BROOKACTION GROUP

PREPARED BY:Woodward-ClydeConsultantsEngineering & sciences applied to the earth & its environment

30775 Baiabridge Road, Suite 200Solon, Ohio 44139

TABLE OF CONTENTS

FEASIBILITY STUDY REPORT

FigureNo. Title2-1 General Location Map

2-2a FEU Site Map (FEUs 2&3)2-2b FEU Site Map (FEUs 4,6&8)2-3a FEU-2A Total PCBs2-3b FEU-2B Total PCBs2-4a FEU-2A Hexachlorobenzene2-4b FEU-2B Hexachlorobenzene2-5 FEU-3 Total PCBs2—6 FEU-3 Hexachlorobenzene2-7 FEU-4 Total PCBs2—8 FEU-4 Hexachlorobenzene2-9 FEU-6 Total PCBs2-10 FEU-6 Hexachlorobenzene2-11 FEU-8 Total PCBs2-12 FEU-8 Hexachlorobenzene4-1 a FEU-2A Remedial Response Areas;4-1 b FEU-2B Remedial Response Areas;4-2 FEU-3 Remedial Response Areas;4-3 FEU-4 Remedial Response Areas;4-4 FEU-4 Remedial Response Areas;4-5 FEU-6 Remedial Response Areas;4-6 FEU-6 Remedial Response Areas;4-7 FEU-8 Remedial Response Areas;4-8 FEU-8 Remedial Response Areas;4-9 Cover Alternative I

10T1 Risk1(T* Risk

10~* Risk10"' Risk1CT5 Risk1<T*Risk10* Risk1CT6 Risk10* Risk

FiaureNo.

5-1a5-1b5-2a5-2b5-35-4a5-4b5-5a5-5b5-6a5-6b5-75-85-95-105-115-12

TitleFEU-:FEU-:FEU-;FEU-:FEU-;FEU-FEU-FEU-iFEU-iFEU-iFEU-iFEU-:FEU-FEU-FEU-FEU-FEU-i

2A Remedial Response Areas, Alternative IIIA2A Remedial Response Areas, Alternative 1MB2B Remedial Response Areas, Alternative IIIA2B Remedial Response Areas, Alternative 1MB3 Remedial Response Areas, Alternative IDA & IIIB4 Remedial Response Areas, Alternative IIIA4 Remedial Response Areas, Alternative IIIB6 Remedial Response Areas, Alternative IIIA6 Remedial Response Areas, Alternative IIIB8 Remedial Response Areas, Alternative IIIA8 Remedial Response Areas, Alternative IIIB2A Remedial Response Areas, Alternative VII2B Remedial Response Areas, Alternative VII3 Remedial Response Areas, Alternative VII4 Remedial Response Areas, Alternative VII6 Remedial Response Areas, Alternative VII8 Remedial Response Areas, Alternative VII


APPROXIMATE_CURRENT«*WATERSHED BOUNDARY -

1000 2000 3000 4000 5000 6000 7000 FEET

CONTOUR INTERVAL 10 FEET

UNITED STATESDEPARTMENT OF THE INTERIOR

GEOLOGICAL SURVEY

ASHTABULA NORTH, OHIONEM ASHTABULA 15' QUADRANGLE

N4152.5—W8045/7.5

NORTH KINGSVILLE, OHIO

N 4152.5—W8037.5/7.5

ASHTABULA SOUTH, OHIOSE/4 ASHTABULA 15' QUADRANGLE

N4145—W8045/7.5

GAGEVILLE, OHIO

N4145—W8037.5/7.5

GENERAL LOCATION MAP

FIELDS BROOK - ASHTABULA, OHIO

Woodward-Clyde ConsultantsDRAWN: REM

CHECKED: WECJOB NUMBER

86C3609D FIGURE NO: 2-1

FLOODPUM EXPOSURE UNIT Z

FIELDS BROOK

100-YEAR FLOODPUUN BOUNDARY

GEND

PHRAGUrTES WETLAND

300 150 0

SHRUB COVER

FOREST COVER

POTENTIAL EROSION AREAS

DATE

10-09-96PROJECT NO.

86C3609SFILE NAME

B48-2AWOODWARD-CLYDE CONSULTANTS FIELDS BROOK SUPERFUND SITE -FLOODPLAIN EXPOSURE UNITS SITE MAPPROJECT MGR.

MLSSCALE

AS SHOWN

LEGEND

PtfflAGUfTES WOUND

FLOODPLAIN EXPOSURE UNIT 8FIELDS BROOK

FLOODPLAIN EXPOSUREUNFT 6aOODPLAIN EXPOSURE UNIT 4

100-YEAR FLOODPLAIN BOUNDARYFLOODPLAIN EXPOSURE

UNIT 8

FIELDS BROOK

FLOODPLAIN EXPOSUREUNIT 3 ODPLAIN BOUNDARY100-YEAR FL

DESIGNED enGLR

DATE

10-09-96PROJECT NO.

86C8609SFILE NAME

B918-2ACLYDE CONSULTANTS FIELS BROOK SUPERFUND SITE - aOODPLAIN EXPOSURE UNITS SITE MAPWOODWARD CHECKED EfT

MJM

SCA1£

AS SHOWN

MATCH LINE - SEE FEU2B FIGURES

—————————— LEGEND ———————————~^ 100 YEAR FLOODPLAIN BOUNDARY

FL07102S-11 A SAMPLE: PHASE I FLOOOPLAJN SOILFL1BS6 + SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE III FLOCOPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

NOTE: BASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY 4-18-87

Wood ward-ClydeConsultantsEngineering 4 sciences applied to the earth & Hs environment

30775 Bainbridge Road, Suite 200Soton, Ohio 44139

CLIENT: FIELDS BROOK

LOCATION: ASHTABULA. OHIO

FLOODPLAIN EXPOSURE UNIT 2ATOTAL PCB

CONCENTRATIONSDRAWN BY:

BGKCHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-3a

t 746500O MATCH LINE - SEE FEU2A FIGURES £ 2^65000

LEGEND

FLQ7102S-11 *FUBS6*

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE tl SURFACE SOILSAMPLE: PHASE III FLOODPLAJN SOILSAMPLE: PHASE 1 SURFACE SOIL SOURCE CONTROL


Woodward—ClydeConsultantsEngineering & sciences applied to the earth & its environment

30775 Bainbridge Road. Suite 200Solon. Ohio 44-139


LOCATION: ASHTABULA, OHIO

FLOODPLAIN EXPOSURE UNIT 2BTOTAL PCB


BGKCHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-3b

£ 2465000

ooo'


——————————— LEGEND ————————————.r -'—^ 100 YEAR FIOODPLAIN BCXJNOARY

F107I02S-11 A SAMPLE: PHASE I FLOOOPLAJN SOILFL1BSC* SAMPLE: PHASE R SURFACE SOIL

• SAMPLE: PHASE W FLOOOPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE COMTROL

NOTE: BASE UAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY 4-18-87

Woodward—ClydeConsultantsEngineered ft sciences "applied to the earth & fts environment

30775 Bainbridge Road. Suite 200Solon, Ohio 44139

CUENT: FIELDS BROOK


FLOODPLAIN EXPOSURE UNIT 2AHEXACHLOROBENZENE


BGK

CHECKED BY:

MLSPROJECT HO:

66C3609SDATE:

10-09-96FIGURE NO:

2-4o

E 7465000 MATCH LINE - SEE FEU2A FIGURES E 2-JSSOOO

-^"—" 100 YEAR FLOOOPLAW BOUNDARYFU>7i02S-il * SAMPLE: PHASE I FLOODPLAIN SOIL

FL1BS6+ SAMPLE: PHASE II SURFACE SOIL• SAMPLE; PHASE iB FLOOOPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL


Woodward—ClydeConsultantsEngneering ft sciences applied to the earth ft its environment



FLOODPUIN EXPOSURE UNIT 2BHEXACHLOROBENZENE

CONCENTRATIONSCHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2~4b

———————————— LEGEND —————————————

~~""~-* 100 YEAR FLOOOPLAIN BOUNDARY

no7i<tts-ii * SAMPLE: PHASE I FLOOOPLAIN SOILFLIBSB* SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE 111 FUOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOI SOURCE CONTROL


Woodward-Clyde wConsultantsEngneering & sciences appGed b the evth ft its environment


FIELDS BROOK

LOCATION: ASHTABU LA, OHIO

FLOODPLAIN EXPOSURE UNITTOTAL PCB


MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-5

FL07102S-11 *

FLiasa *

—————— LEGEND —————————————

100 YEAR FLOODPLAIN BOUNDARY

SAMPLE: PHASE 1 FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOIL

SAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL


Woodward-Clyde vrConsultantsEngflKering & sciences appfied to the earth ft Hs environment


FIELDS BROOK

LOCATION: AS HT ABU LA, OHIO

FLOODPLAIN EXPOSURE UNIT 3HEXACHLOROBENZENE


MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-6

————— LEGEND —————————————

"* 100 YEAR FLOODPLA1N BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOIL

FUB98* SAMPLE: PHASE it SURFACE SOIL• SAMPLE: PHASE III FLOODPLAIN SOL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

NOTE: BASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY +-18-87

FLOODPLAINEXPOSUREUNIT 6


MITCHELLTRANSPORT RMI EXTRUSION

Woodward—Clyde rConsultantsEngineering ft sciences emptied to the earth A Hs environment30775 Bainbridge Road. Suite 200Solon, Ohio 44139

CUENT: FIELDS BROOK

LOCATION: ASH TABU LA, OHIO

FLOODPLAIN EXPOSURE UNIT 4TOTAL PCB


BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:10-09-96

FIGURE NO:

2-7

FL071O3S-11 •

FUBSB +

———— LEGEND —————————————

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE t FLOODPLAIN SOIL

SAMPLE: PHASE II SURFACE SOU.

SAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE COfJTROL

NOTE: BASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY +-IB-87




1*0=1rra

Woodward-Clyde ConsultantsEhgheering ft scfcnca appfod to the earth It fts enwonment






BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE HO:

2-8

1 2469000


RMI EXTRUSION*

——————————— LEGEND —————————————

*-—'——*• 1OO YEAR FLOOOPUIN BOUNDARYfu>7iozs-ti * SAMPLE: PHASE I FLOODPLAIN SOIL

R.1BS* * SAMPLE: PHASE II SURFACE SOIL• SAMPLE: PHASE II FLOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL


et

<CM£

Woodward—ClydeConsultantsEngineering ft sciences applied to the earth & Hs environment

30775 Bainbridge Road, Suite 200Solon. Ohio 44139





BGK

CHECKED BY:

MLS

PROJECT HO:

86C3609SDATE:10-09-96

FIGURE NO:

2-9

L 2470000


RMI EXTRUSIONS

LEGEND —————————————

"• 100 YEAR FLOODPLAIN BOUNDARY

SAMPLE: PHASE I FLOODPUUN SOtt.F11BM+ SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE 18 FLOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

NOTE: 8ASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY 4—1&-87

ot

ICM£

inHFEET

Woodward—ClydeConsultantsEngineerhg ft sciences oppfied to the earth ft its environment

30775 Bainbridge Road, Suite 200Solon, Ohio 44139

CUENT: FIELDS BROOK




BGKCHECKED BY:

HLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-10

100 YEAR FLOODPLAiN BOUNDARYFU)7i02S-H * SAMPLE: RUSE I FLOODPLAIN SOL

FLiBS* * SAMPLE: PHASE II SURFACE SOIL



Woodward—Clyde wConsultantsEngineering i sciences applied to the earth ft Hs environment


CLIENT: FIELD BROOK




BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-11

LEGEND—^——" 100 YEAR FLOODPLAIN BOUNDARY

RB7102S-11 A SAMPLE: PHASE I FLOODPLAIN SOU.FUBS«* SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE ft) FLOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

NOTE: BASE MAP PREPARED BY KUCERA INTERNAT10NALDATE OF AERIAL PHOTOGRAPHY 4-18-87

Wood ward-ClydeConsultantsEngheemg ft sciences "eppfied to the earth A Ks environment


CUENT: FIELD BROOK

LOCATION: AS HT ABU LA, OHIO



BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

2-12

£ 2465000

TOTAL PCBsEPA DETERMINISTIC 10~6 CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 233,000 SQ. FT.

HEXACHLOROBENZENEEPA DETERMINISTIC 10"6 CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 138,000 SQ. FT.


——— LEGEND —————REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASWSED ON H£ tCWHOBBDCOe OK

OVERLAP OF PCB ANDHBMQUMHHZENE RESPONSE «M

1OO YEAR FLOODPLAIN BOUNDARYH07102S-M A SAMPLE: PHASE t FLOODPLAIN SOIL

FU*» • SAMPLE: PHASE a SURFACE SOILKMMS • SAMPLE: PHASE HI FLOODPLAIN SOIL

NOTES: TOTAL REMEDIAL RESPONSE AREA = 233,000 SQ. FT.(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCB AND HEXACHLOROBENZENE AREAS)

BASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY 4-18-87

oc

too=lran

Woodward-ClydeConsultantsEngineering A sciences appfed to the earth A its environment

30775 Bainbridge Rood, Suite 200Solon, Ohio 44139


LOCATION: ASH TABU LA. OHIO

FLOODRLAIN EXPOSURE UNIT 2AREMEDIAL RESPONSE AREAS

EPA DETERMINISTIC, 10"* RISKDRAWN BY:

BGKCHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-1 a

MATCH LINE - SEE FEU2A FIGURES

DUD

TOTAL PCBsEPA DETERMINISTIC 10~s CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 233,000 SQ. FT

HEXACHLOROBENZENEEPA DETERMINISTIC 10"6 CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 138,000 SO. FT

LEGENDREMEDIAL RESPONSE AREASBASED ON THE PCS CRG

REMEDIAL RESPONSE AREASBffiED OH THE tfWOlflRDBEHZDC CRG

OVERLAP OF PCB ANDHEXMHJWOBENZQC RESPONSE AREAS

100 YEAR FLOODPLA1N BOUNDARY

FUI7102S-11 A SAMPLE: PHASE I FLOODPLAIN SOIL

FL1BS>* SAMPLE: PHASE II SURFACE SOIL

H2NWS • SAMPLE: PHASE III FLOODPLAIN SOIL

NOTES: TOTAL REMEDIAL RESPONSE AREA = 233,000 SQ. FT(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCB AND HEXACHLOROBENZENE AREAS)


Woodward-Clyde rConsultantsEngineering A sciences appfad to the earth & its environment

30775 Boinbridge Road. Suite 200Solon, Ohio 44139

FIELDS BROOK


FLOODPLAIN EXPOSURE UNIT 2BREMEDIAL RESPONSE AREAS

EPA DETERMINISTIC, 10~6 RISKDRAWN BY:

BGKCHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96

FIGURE NO:

4-1b

LEGEND

NOTES: TOTAL REMEDIAL RESPONSE AREA = 115,000 SQ. FT.(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCS AND HEXACHLOROBENZENE AREAS)

BASE MAP PREPARED BY KUCERA INTERNATIONAL__ DATE OF AERIAL PHOTOGRAPHY 4-18-87

turn

FUI7102S-11 A

FL18SB *

H2N00S •

REMEDIAL RESPONSE AREASBASED ON THE PCS CRG

REMEDIAL RESPONSE AREASUSED ON THE WXttHUKieEHZDC C8G

OVERLAP OF PCB ANDtOttJUROeOCM RESPONSE «*S

100 YEAR FLOODPLAJN BOUNDARY

SAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE 11 SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOIL

AlLJLlg

, \

TOTAL PCBsEPA DETERMINISTIC 10~e CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 115.000 SQ. FT.

HEXACHLOROBENZENEEPA DETERMINISTIC 10~* CUG = 1.0 mg/kgREMEDIAL RESPONSE AREA = 18,000 SQ. FT.

\'0\

y

Woodward-Clyde rConsultantsEngineering ft sciences appSed to the earth ft its environment




FLOODPLAIN EXPOSURE UNIT 3REMEDIAL RESPONSE AREAS

EPA DETERMINISTIC, 10~6RISKDRAWN BY:

BGKCHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-2

REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASUSD ON THE fEMDtflWtttCDC CRG

OVERLAP OF PCB ANDHEXKX0RGGENZDC HE5POKSE AREAS

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE 1 ROODPLAIN SOILSAMPLE: PHASE II SURFACE SOIL

H2NQBS • SAMPLE: PHASE III FLOODPLAIN SOIL



TOTAL PCBsEPA DETERMINISTIC 10~6 CUG = 2.5 mg/kgREMEDIAL RESPONSE AREA = 121,000 SQ. FT

HEXACHLQRABENZENEEPA DETERMINISTIC 10~6 CUG = 6.7 mg/kgREMEDIAL RESPONSE AREA = 62,000 SQ. FT.




160

HFHT

Woodward—ClydeConsultantsEngineering ft sciences, applied to the earth A its environment




FLOODRLAIN EXPOSURE UNIT 4REMEDIAL RESPONSE AREAS

EPA DETERMINISTIC, 10"6 RISKDRAWN BY:

BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-3

LEGEND

firm REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASBASED OH 1HE HEXACtUROeEHZDC C«G

OVERLAP OF PCB ANDHBUOUSOBDBENE RESPONSE «BS


A SAMPLE: PHASE I FLOOOPLAIN SOIL

FL1BS6 * SAMPLE: PHASE II SURFACE SOIL

H2M095 • SAMPLE: PHASE 111 FLOODPLAIN SOIL



TOTAL PCBsEPA DETERMINISTIC 10'5 CUG = 25.0 mg/kgREMEDIAL RESPONSE AREA = 10,000 SQ. FT.

HTXACHLQROBENZENEEPA DETERMINISTIC 10~5 CUG = 67.0 mg/kgREMEDIAL RESPONSE AREA = 0


NOTES: TOTAL REMEDIAL RESPONSE AREA = 10.000 SQ. FT.(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCB AND HEXACHLOROBENZENE AREAS)


1M

Hnn

Woodward-Clyde ConsultantsEngineering A sciences .oppfied to the earth ft its environment






BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-4

NOTES: TOTAL REMEDIAL RESPONSE AREA - 150.000 SQ. FT.(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCB AND HEXACHLOROBENZENE AREAS)




TOTAL PCBsERA DETERMINISTIC 10~6 CUG = 2.5 mg/kgREMEDIAL RESPONSE AREA = 150,000 SQ. FT

HEXACHLQRQBENZENEERA DETERMINISTIC 10~6 CUG = 6.7 mg/kgREMEDIAL RESPONSE AREA = 14,000 SQ. FT.

RMI EXTRUSION^J<

nrrn———— LEGEND —————REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASBUSED ON THE tOKHUWMOGENE CfiG

OVERLAP OF PCB ANDHEttCHOflCONZBe RESPONSE MBS

100 YEAR FLOOOPLAIN BOUNDARYFL07102S-H A SAMPLE: PHASE I FLOODPLAIN SOIL

FLIBS6+ SAMPLE: PHASE 11 SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOIL

1*0=!TfCt

Woodward-ClydeConsultantsEngineering ft sciences oppied to the earth & its environment





-6EPA DETERMINISTIC, 10"6 RISKDRAWN BY:

BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-5

2470000

TOTAL PCBsEPA DETERMINISTIC 1CT5 CUG = 25.0 mg/kgREMEDIAL RESPONSE AREA = 32,000 SQ, FT.

HEXACHLQROBENZENEEPA DETERMINISTIC 10~5 CUG = 67.0 mg/kgREMEDIAL RESPONSE AREA = 0

FLOODPLA1NEXPOSURE

4

FLOOD PLAINEXPOSUREUNIT 4



RMI EXTRUSION*^

tHED

FU7i<ns-H *

———— LEGEND ————————REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASBASED ON THE HEXKHLUUeOQDC CRG

OVERLAP OF PCB ANDHEXKHLDH080KME BESPOKE «£AS


SAMPLE: PHASE I FLOOOPLAIN SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE HI FLOODPLAIN SOIL

t*eHFEET

Wood ward-ClydeConsultantsEngineering ft sciences .oppfed to the earth & rts environment


FIELDS BROOK


FLOODP.LAIN EXPOSURE UNIT 6REMEDIAL RESPONSE AREAS

EPA DETERMINISTIC, 10~5 RISKCHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96

FIGURE NO:

4-6

TOTAL PCBsERA DETERMINISTIC 10"* CUG = 2.5 mg/kgREMEDIAL RESPONSE AREA = 132,000 SQ. FT.

HEXACHLOROBENZENEEPA DETERMINISTIC 10"* CUG = 6.7 mg/kgREMEDIAL RESPONSE AREA = 26.000 SQ. FT.

LEGEND

firm REMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASUSED ON 1* HEXKtUflOBDCDE CRG

OVERLAP OF PCS ANDtEWOUKBENZBC PESOS AREAS


FU>7io2S-ii * SAMPLE: PHASE I FLOOOPLAIN SOIL

fLiesa * SAMPLE: PHASE H SURFACE SOIL

H2H09S • SAMPLE: PHASE HI FLOODPLAIN SOIL



Woodward—ClydeConsultantsEngineering ft sciences appfad to the earth & its environment


CLIENT: FIELD BROOK




BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-7

TOTAL PCBsERA DETERMINISTIC 10~5 CUG = 25.0 mg/kgREMEDIAL RESPONSE AREA = 6,000 SQ. FT.

HEXACHLOROBENZENEEPA DETERMINISTIC 10"5 CUG = 67.0 mg/kgREMEDIAL RESPONSE AREA = 0

LEGENDREMEDIAL RESPONSE AREASBASED ON THE PCB CRG

REMEDIAL RESPONSE AREASBASED OH HE KXMHJ3ROGEHZEME CRG

OVERLAP OF PCB ANDHEXMH0R06EHZEIC RESPONSE «EAS


FIB7102S-11 * SAMPLE: PHASE I FLOODPLAIN SOILFLiasa * SAMPLE: PHASE II SURFACE SOILWN09S • SAMPLE: PHASE III FLOODPLAIN SOIL

NOTES: TOTAL REMEDIAL RESPONSE AREA = 6.000 SQ. FT.(AREA HAS BEEN ADJUSTED FOR OVERLAP OFPCB AND HEXACHLOROBENZENE AREAS)


Wood ward-ClydeConsultantsEngineering ft sciences, oppfcd to the earth & its environment


CLIENT: FIELD BROOK



L-5EPA DETERMINISTIC, 10~3 RISKDRAWN BY:

BGKCHECKED BY:

ML5PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

4-8

3"

L

REVEGETATION

HYDRIC-COMPATIBLE SOIL COVER

EXISTING LEAF PACK

x/ s EXISTING SOIL



<MOIST CONDITION)

DRAWING NOT TO SCALE

COVER ALTERNATIVE IFIELDS BROOK SUPERFUND SITE - ASHTABULA, OHIO

DRAWN BY: MMSJ CHECKED BY: PO | PROJECT NUMBER: 86C3609S | DATE:: 10-09-96 | FIGURE NO: 4-9

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E 2465000

ALTERNATIVE IIIA

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——— LEGEND ———————————100 YEAR FLOOOPLAIN BOUNDARYSAMPLE: PHASE t FLOOOPLAIN SOILSAMPLE: PHASE I SURFACE SOU.SAMPLE: PHASE • FLOOOPLAM SOILSAMPLE: PHASE I SURFACE SON. SOURCE CONTROL

12" EXCAVATION AREAPCS CONCENTRATION > 30

6" COVER AREAPCB CONCENTRATION 6-30 mg/kgHC8 CONCENTRATION > 6 mg/kg

NOTE: BASE MAP PREPARED BT KUCERA INTERNATIONALDATE OF AERW. PHOTOGRAPHY 4-18-87

Wood ward-ClydeConsultantsEngineering ft sciences appCed to the ewth It its enwonment




FLOODPLAIN EXPOSURE UNIT 2AREMEDIAL RESPONSE AREAS

ALTERNATIVE IIIADRAWN BY:

BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-1 a

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FEU2AALTERNATIVE 1MB

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R07102S-11 *

FL1BS6 +

———— LEGEND —————————————

100 YEAR FLOOOPLAIN BOUNDARY

SAMPLE: PHASE I FLOODPLA1N SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOODPLAJN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

12" EXCAVATION AREAPCB CONCENTRATION > 30 mg/kg

IT EXCAVATION AREAPCB CONCENTRATION > 6 mg/kg

6T COVER AREAPCB CONCENTRATION 6-30 mg/kgHCB CONCENTRATION > 6 mg/kg


Wood ward-ClydeConsultantsEngineering ft sciences applied to the earth ft its environment





ALTERNATIVE 1MBDRAWN BY:

BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:10-09-96

FIGURE NO:

5-1 b

E 2*65000 MATCH LINE - SEE FEU2A FIGUREScir

£ 2466000

ALTERNATIVE IIIA

RJ37102S-11

H.1BSO

100 YEAR FLOOOPLAIN BOUNDARY

SAMPLE: PHASE I FLOOOPLAIN SOIL

SAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOOOPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE COMTROL

SAMPLE: PROPOSED FLOOOPLAIN DELINEATION

ir EXCAVATION AREAPCB CONCENTRATION > 30 mg/kg

Woodward—ClydeConsultantsEngineering ft sciences applied to the earth ft its environment



COVER AREA. B CONCENTWHCB CONCENTRATION > 6 mgPCB CONCENTRATION 6-30 mg/kg.__.. . „ __^kg


ALTERNATIVE IIIANOTE: BASE MAP PREPARED BY KUCERA INTERNATIONAL

DATE OF AERIAL PHOTOGRAPHY 4-18-B7CHECKED BY:

MLSPROJECT HO:

86C3G09SDATE:

10-09-96FIGURE NO:

5-2a


ALTERNATIVE 1MB

Wood ward-ClydeConsultantsEngineering ft sciences applied to the earth ft its environment

100 YEAR FLOOOPLAIN BOUNDARYSAMPLE: PHASE t FLOOOPLAIN SOIL 30775 Bainbridge Road, Suite 200

Solon. Ohio 44139FL1BS6* SAMPLE: PHASESAMPLE: PHASE HI FLOOOPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

EXCAVATION AREAPCB CONCENTRATION > JO mg/kg LOCATION: ASHTA8ULA. OHIO



PCB CONCENTRATION 6-50 mg/kg7kg ALTERNATIVE 1MBHCB CONCENTRATION > 6 mg



SAMPLE: PHASE I FLOODPLAIN SOIL

SAMPLE: PHASE II SURFACE SOIL



6 COVER AREAPCB CONCENTRATION 8-30 mq/kq

I! IP -1 i

ALTERNATIVE IIIA AND

Woodward—ClydeConsultantsEngineering & sciences applied to the earth 4 its environment

30775 Bambridge Road, Suite 200Solon, Ohio 44139

FIELDS BROOK



ALTERNATIVE IIIA AND 1MB

FU07102S-11 *FL1BS6*

———— LEGEND ————————————

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE HI FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

\T EXCAVATION AREAPCB CONCENTRATION > 50 mg/kg

1? EXCAVATION AREAPCB CONCENTRATION > 250 mg/kg

12" COVER AREAPCB CONCENTRATION 100-250 mq/kg

6" COVER AREAPCB CONCENTRATION 50-100 mg/kgHCB CONCENTRATION > 200 mg/kg


Li 2469000

ALTERNATIVE IIIA

Woodward-ClydeConsultantsEngineering & sciences applied to the earth It its environment






BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-4a

FL07102S-11*FL1BS6*

*

———— LEGEND ————————————

1OO YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

1? EXCAVATION AREAPCB CONCENTRATION > 50 mg/kg


12" COVER AREAPCB CONCENTRATION 1OO-4OO mg/kg

6T COVER AREAPCB CONCENTRATION 50-100 mg/kgHCB CONCENTRATION > 200 mg/kg


2469000

ALTERNATIVE 1MB

Wood ward-ClydeConsultantsEngineering & sciences appied to the earth it its environment






BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-4b

ALTERNATIVE IIIA

FL07102S-11 *FUBS6*

———— LEGEND ————————————

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL


12" COVER AREAPCB CONCENTRATION 100-250 mg/kg

6" COVER AREAPCB CONCENTRATION 50-100 mg/kgHCB CONCENTRATION > 200 mg/kg


Woodward-ClydeConsultantsEngineering & sciences qppied to the earth & its environment






BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-5a

ALTERNATIVE 1MB

FL07102S-11 *FL1BS6 +

———— LEGEND —————————————

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOIL



12" COVER AREAPCB CONCENTRATION 100-4OO mg/kg

€T COVER AREAPCB CONCENTRATION 50-tOO mg/kgHCB CONCENTRATION > 200 mg/kg


Wood ward—ClydeConsultantsEngineering A sciences applied to the earth A its environment






BGKCHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-5b

FEUSALTERNATIVE IIIA

LEGEND

FL07102S-11 *FL1BS6 +

100 YEAR FLOODPLAIN BOUNDARYSAMPLE: PHASE I FLOODPLAIN SOILSAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL



ff COVER AREAPCB CONCENTRATION 50-100 mg/kgHCB CONCENTRATION > 2OO

NOTEi BASE MAP PREPARED BY KUCERA INTERNATIONALDATE OF AERIAL PHOTOGRAPHY 4-18-87

Wood ward-ClydeConsultantsEngineering A sciences oppSed to the earth ft its environment


CLIENT: FIELD BROOK


EXPOSURE UNIT 8REMEDIAL RESPONSE AREAS


BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-6a

ALTERNATIVE 1MB

LEGEND"•**"—"» 100 YEAR FLOODPLAIN BOUNDARY

FL07102S-11 A SAMPLE: PHASE I FLOODPLAIN SOILFL1BS6* SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE III FLOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL



G" COVER AREAPCB CONCENTRATION 50-100 mg/kgHCB CONCENTRATION > 200 mg/kg


Wood ward-ClydeConsultantsEngineering ft sciences applied to the earth & fts environment


CLIENT: FIELD BROOK



ALTERNATIVE IIIBDRAWN BY:

BGK

CHECKED BY:

MLSPROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-6b

£ 2465000

I! D^ ^~

FEU 2AALTERNATIVE VII

i—i

oco


FL07102S-11 *FUBS6*

——— LEGEND ———————————100 YEAR FLOOOPLAIN BOUNDARYSAMPLE: PHASE I FLOOOPLAIN SOILSAMPLE: PHASE H SURFACE SOILSAMPLE: PHASE HI FLOOOPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

1ST EXCAVATION AREAPCB CONCENTRATION > 30 mg/kgHCB CONCENTRATION > BO mg/kg

er COVER AREAPCB CONCENTRATION 6-30 mg/kgHC8 CONCENTRATION > 6 mg/kg

NOTE: BASE UAP PREPARED BY KUCERA INTERNAT!ONALDATE OF AERIAL PHOTOGRAPHY 4-18-87

Wood ward-ClydeConsultantsEngineering ft sciences appEed to the earth & its environment





ALTERNATIVE VIIDRAWN BY:

BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-7


ALTERNATIVE VI

*•—"-""** 100 YEAR FLOOOPLAIN BOUNDARY

FUJT102S-11 * SAMPLE: PHASE I FLOOOPLAIN SOIL

FLIBSO* SAMPLE: PHASE II SURFACE SOIL


_ EXCAVATION AREAPCB CONCENTRATION > 30 mg/kqHCB CONCENTRATION > 80 mg/kq

COVER AREAPCB CONCENTRATION 6-30 mg/kgHCB CONCENTRATION > 6 mg/kq


Woodward-Clyde ConsultantsEngineering & sciences applied to the earth t its environment


FIELDS BROOK




BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:10-09-96

FIGURE NO:

5-8

FL07102S-11 *FL1BS6*

—————— LEGEND —————————————

100 YEAR FLOODPLAJN BOUNDARY

SAMPLE; PHASE I FLOODPLAIN SOIL

SAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE III FLOODPLAIN SOILSAMPLE: PHASE t SURFACE SOIL SOURCE CONTROL

12" EXCAVATION AREAPCB CONCENTRATION > 30 mg/kgHCB CONCENTRATION > 80 mg/kg

6T COVER AREAPCB CONCENTRATION 6-30 mq/kq

ALTERNATIVE VII

Woodward—ClydeConsultantsEngineering ft sciences appfied to the earth ft its environment




ALTERNATIVE VIICHECKED BY:

MLSPROJECT NO:

86C3609PDATE:

10-09-96FIGURE NO:

5-9

FL071025-11 *FL1BS6*

———— LEGEND —————————————


SAMPLE: PHASE I FLOODPLAIN SOIL

SAMPLE: PHASE II SURFACE SOILSAMPLE: PHASE HI FLOODPLAIN SOILSAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

12" EXCAVATION AREAPCB CONCENTRATION > 50 rug/kgHCB CONCENTRATION > 200 mg/kg

ALTERNATIVE VIINOTE: BASE MAP PREPARED BY KUCERA INTERNATIONAL

DATC OF AERIAL PHOTOGRAPHY 4-18-87

H4H08S H4N07S

HCB > 20O mg/kgNO PCB > 50 mg/kg

Woodward—ClydeConsultantsEngineering ft sciences applied to the earth & its environment

30775 Boinbridge Road, Suite 200Solon, Ohio 44139





BGKCHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-10

ALTERNATIVE VII

———————————— LEGEND —————————————

-^——^ 100 YEAR FLOODPLA1N BOUNDARY

FL07102S-11* SAMPLE: PHASE I FLOODPLAIN SOILFL1BS6* SAMPLE: PHASE II SURFACE SOIL

• SAMPLE: PHASE III FLOODPLAIN SOIL

• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

l/yyj 12" EXCAVATION AREAX/7/\ PCS CONCENTRATION > 50 mg/kg

HCB CONCENTRATION > 200 mg/kg


Woodward-Clyde wConsultantsEngineering ft sciences appfied to the earth 4 its environment

30775 Bainbridqe Road, Suite 200Solon, Ohio 44139





BGK

CHECKED SY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-11

ALTERNATIVE VII

HC8 > 200 mg/kgNO PCB > 50 mg/kc

LEGEND

*--'——"* 1OO YEAR FLQODPLAIN BOUNDARYFL07102S-11* SAMPLE: PHASE ! FLOODPLAIN SOIL

FL1BS6* SAMPLE: PHASE It SURFACE SOIL• SAMPLE: PHASE III FLOODPLAIN SOIL• SAMPLE: PHASE I SURFACE SOIL SOURCE CONTROL

V'/.'/.X 12" EXCAVATION AREArZ^Zl PCB CONCENTRATION > 50 mg/kg

HCB CONCENTRATION > 200 mg/kg


Wood ward-ClydeConsultantsEngineering & sciences applied to the earth & its environment

30775 Boinbridge Road, Suite 200Soton, Ohio 44139

CUENT: FIELD BROOK




BGK

CHECKED BY:

MLS

PROJECT NO:

86C3609SDATE:

10-09-96FIGURE NO:

5-12

feasibility study for floodplainavetlands area fields

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