PROPOSED PLANORMET CORPORATION SITE

HANNIBAL, OHIO

I. STATEMENT OF PURPOSE

The United States Environmental Protection Agency (U.S. EPA) hasidentified the preferred Alternative for Remedial Action at theOrmet Corporation Superfund Site (the Site) in Hannibal, Ohio.The Proposed Plan summarizes the Site history, the RemedialInvestigation (RI) Report, the Feasibility Study (FS) Report, andthe cleanup alternatives evaluated in the FS and proposes thepreferred alternative to clean up the Site, including therationale for the preference. The RI and FS reports should beconsulted for a full description of the Site investigation andthe alternatives evaluated. A final remedy will be selected onlyafter the public comment period has ended and the oral andwritten information submitted by the public during this time hasbeen reviewed and considered.

Section 117(a) of the Comprehensive Environmental ResponseCompensation and Liability Act of 1980 (CERCLA), as amended bythe Superfund Amendments and Reauthorization Act (SARA), requiresthat notice be published and a brief analysis of the ProposedPlan for Site remediation be made available to the public. TheProposed Plan also outlines the public's role in helping U.S.EPAmake a final choice on the preferred alternatives.

II. OPPORTUNITIES FOR PUBLIC INVOLVEMENT

U.S. EPA relies on the public to ensure that the cleanup methodselected for each Superfund site meets the needs of the localcommunity, in addition to being an effective solution to theproblem. Therefore, U.S. EPA has set a public comment periodfrom April 11. 1994 through Mav 11. 1994 to encourage publicparticipation in the remedy selection process. U.S. EPA willconduct a public meeting to discuss the FS Report and theProposed Plan and to answer questions and to formally receivepublic comments. Comments are being solicited on the ProposedPlan as well as on other documents located in the informationrepository, including the RI/FS.

The RI report, FS Report and numerous other documents pertainingto the Site are available in one information repository at theUnited States Post Office in Hannibal, Ohio and anotherinformation repository at the New Martinsville Public Library inNew Martinsville, West Virginia. These documents comprise theadministrative record for the Site. U.S. EPA will respond tosignificant comments in the Responsiveness Summary Section of theRecord of Decision (ROD). The ROD is the document that presentsU.S. EPA's final alternative selection for clean up. The publiccan send written comments to or obtain further information from:

Cheryl Alien, P-19JCommunity Relations CoordinatorU.S.EPA Region 577 West Jackson BoulevardChicago, IL 60604(312) 353-6196 or Toll Free (800) 621-84319:00am-4:30pm Central Time

In order to be considered by the Agency and addressed in theResponsiveness Summary, written comments must be post marked nolater than May 11, 1994.

Information can also be obtained from:

Tinka G. Hyde Kay GossettSection Chief Site CoordinatorOffice of Superfund Ohio EPA, Southeast District OfficeU.S. EPA Region 5 2195 Front Street77 West Jackson Boulevard Logan, Ohio 43138Chicago, IL 60604 (614) 385-8501(312) 886-9296

The public meeting discussed above will be held at the followingtime and place:

DATE: April 20, 1994TIME: 7:00 p.m.LOCATION: River High School, Hannibal, Ohio

III. SITE HISTORY AND DESCRIPTION

The Ormet Corporation Site is located in Monroe County, Ohio,approximately 3 miles north of the city of Hannibal (Figure 1).The Site is located in southeastern Ohio along the Ohio River atapproximately rivermile 123, about 35 miles south of Wheeling,West Virginia. The Site is bounded on the Northwest by OhioState Route 7, on the east and southeast by the Ohio River and onthe southwest by the Consolidated Aluminum Corporation (CAC)facility.

Since the plant started operations in 1958, Ormet Corporation's(Ormet's) main process has been the reduction of alumina toproduce aluminum metal. From 1958 to 1968, approximately 85,000tons of spent potliner, a hazardous by-product of aluminumproduction, were placed in an unlined, open area in the northeastarea of the Site, identified in Figure 2 as the Former SpentPotliner Storage Area (FSPSA). From 1968 to 1981, much of thepotliner waste was removed by Ormet and transported to an on-siterecovery plant that removed a useable material called cryolitefrom the potliner. The waste from this operation was depositedin five retention/disposal ponds on Site. Since 1980, theremaining potliner material has been transported off site for

disposal.

At various times from 1958 to 1981, Ormet utilized one or more ofthe five retention disposal ponds (Ponds 1 through 5) located inthe northeastern portion of the Site and identified in Figure 2.These ponds are unlined and constructed of natural materials.

From about 1966 until mid - 1979, Ormet deposited wasteconstruction materials and other miscellaneous plant debris inthe southeastern corner of the Ormet property, adjacent to Pond 5(Figure 2). This 4 to 5 acre area is designated as theConstruction Material Scrap Dump (CMSD). An area referred to asthe Carbon Runoff and Deposition Area (CRDA) (Figure 2) containscarbon deposits, probably carried there by storm water runofffrom the Ormet plant area. Some of the carbon runoff may alsohave entered the 004 outfall stream and backwater area (Figure2).

In 1972 a hydrogeologic study verified the presence ofgroundwater contamination in the Ormet Ranney well pumpingcenter. As a result of this study, two interceptor wells (#1 and#2) were installed north of the Ormet Ranney well (Figure 1) tointercept the plume before it reached this pumping center. Sitecontamination found by U.S. EPA and the State, combined with itspotential impact on drinking water supplies, prompted the U.S.EPA to place the Site on the National Priorities List (NPL) inSeptember 1985. The NPL is a list of the Nation's top priorityhazardous waste sites eligible for investigation and cleanupunder the Superfund program.

In May 1987, the U.S. EPA, OEPA and Ormet Corporation (Ormet)entered into an Administrative Order by Consent (Consent Order)providing for Ormet to conduct the Remedial Investigation/Feasibility Study (RI/FS) under the U.S. EPA and OEPAsupervision. The RI report was completed in December 1992 andthe FS was completed in December 1993.

In addition to defining the contamination found in the disposalareas described above, during the RI, seeps were discovered nearthe Plant Recreational Area ballfields and along the western edgeof the CMSD. The seeps contained cyanide ranging inconcentrations from 79 to 950 ppb.

The U.S. EPA is the lead agency responsible for managing theinvestigation of the Site which was conducted by OrmetCorporation.

IV. SUMMARY OF SITE RISKS

The areas and media investigated during the two phases of the RIincluded the following:

* Former disposal Ponds (FDPs)* Former Spent Potliner Storage Area (FSPSA)* Carbon Runoff and Deposition Area (CRDA)* Construction Material scrap Dump (CMSD)* Ballfield and CMSD Seeps (SP)* Ground Water (GW)* Surface Water (SW) ....---* Sediments (from Ohio River and Backwater Area) (SED)* Air* Environmental Evaluation

The final phase of the RI was the Baseline Risk Assessment, anassessment of potential risks to public health and theenvironment if no action is taken to clean up the Site. TheBaseline Risk Assessment was conducted by U.S. EPA and iscomprised of two reports - the Human Health Evaluation and theEnvironmental Evaluation.

At the Ormet site, potential health risks to the public and theenvironment are related to exposure to sediments, soil, andground water. Table 1 summarizes the contamination found ingroundwater and the clean up standards that the groundwater mustmeet to be protective of human health and the environment. U.S.EPA has determined that contamination at the Ormet site poses anunacceptable health risk currently to trespassers and in thefuture to potential Site residents and therefore, it is necessaryto take action to address the contamination at the Site. Asummary of the Site risks is provided in Table 2. Although afuture residential use scenario was used to calculate site risks,since this is an operating facility that is containing the plume,residents are not currently being exposed to contaminatedgroundwater.

U.S. EPA also calculated an excess lifetime cancer riskassociated with an adult/child consuming fish from the OhioRiver. Given the highly industrialized use of the Ohio River inthis area, a fishing advisory has been in place for the OhioRiver between East Liverpool, Ohio and the Greenup Locks and Damnear Portsmouth, Ohio. U.S. EPA believes that by addressing thebackwater area sediments, the source of contamination from theOrmet Site, the Ohio River will be protected from contaminationfrom the Ormet Site. A cleanup level of 1 ppm for PCBcontaminated sediments would be protective of human health andthe environment.

V. SUMMARY OF ALTERNATIVES

The Feasibility Study (FS) Report identified and evaluatedalternatives that could be used to address threats and/orpotential threats posed by the Site. All of the alternativesdescribed in the following paragraphs, except for the No ActionAlternative, include sitewide institutional controls in the form

of deed restrictions and a common perimeter fence as a commonelement. Institutional controls may also include accessrestrictions, site-specific zoning limitations and land userestrictions or easements. In addition, capping alternativesCMSD-4, CMSD-5, CMSD-7, and CMSD-8 include provisions for floodprotection measures in accordance with OAC 3745-54-18.

ALTERNATIVE li NO ACTION

CERCLA requires that a "No Action" alternative be considered as abasis upon which to compare other alternatives. This remedy wasassembled by combining the no-action remedial measures for eachof the areas and media under consideration in the FS Report. Theno-action response for ground water is considered to excludecontinued pumping of the Ormet Ranney well and interceptor wells,which currently contain the plume in the alluvial aquifer beneaththe Ormet Property. No operation and maintenance (O & M)activities are included to prevent further deterioration ofpresent Site conditions over the long-term. This alternativewould not comply with State or Federal health-based standards andwould not adequately protect human health or the environment.There is no cost for this alternative.

ALTERNATIVE 2 - ALTERNATIVE 10s These alternatives are composedof different combinations of the remedial action componentslisted below. Alternatives 2 through 10 are defined by specificcombinations of these remedial action components and aredescribed in Table 3.

Groundwater

• GW-3: Pumping of Ranney and Existing Interceptor Wells,Treatment of the Interceptor Well Water by FerrousSalt Precipitation, Clarification, and Dischargeto the Ohio River;

• GW-5: Pumping of Ranney Well and New Interceptor Wells,Treatment of Interceptor Well Water by FerrousSalt Precipitation, Clarification, Post-Treatmentby Activated Alumina Adsorption, and Discharge tothe Ohio River;

CMSD and Ballfield Seeps

• SP-4: Collection of Ballfield and CMSD Seeps usingTrench Drains, Treatment of CMSD Seeps byOil/Water Separation and/or Carbon Adsorption;

Former Spent Potliner Storage Area

• FSPSA-2: Containment by Vegetated Soil Cover;

• PSPSA-4: Containment by Single Barrier Synthetic Cap;

• FSPSA-3: Containment by Dual Barrier Cap;

• FSPSA-9: Partial Excavation with Off-Site Landfilling ofthe Excavated Soils, and Containment by SingleBarrier Synthetic Cap;

• FSPSA-6: Treatment by In-situ Soil Flushing and Containmentby Vegetated Soil Cover;

• FSPSA-10: Containment by Single Barrier Clay Cap;

Former Disposal Ponds

• FDP-2: Containment by Vegetated Soil Cover;

• FDP-5: Containment by Single Barrier Synthetic Cap;

• FDP-7: Solidification and Containment by Dual BarrierCap;

• FDP-3: Treatment by Stabilization and Vegetated SoilCover;

• FDP-10: Solidification and Containment by Single BarrierClay Cap;

Construction Material Scrap Dump

• CMSD-3: Recontouring, and Vegetated Soil Cover;

• CMSD-4: Recontouring and Containment by Single BarrierSynthetic Cap, Placement of rip rap/otherengineering controls to prevent washout of CMSDmaterials;

• CMSD-5: Recontouring and Containment by Dual Barrier Cap,Placement of rip rap/other engineering controls toprevent washout of CMSD materials;

• CMSD-7: Complete Excavation, Treatment by ThermalOxidation, and Containment by Single BarrierSynthetic Capping, Placement of rip rap/otherengineering controls to prevent washout of CMSDmaterials;

• CMSD-8: Containment by Single Barrier Clay Cap, Placementof rip rap/other engineering controls to preventwashout of CMSD materials;

1Carbon Run-off and Deposition Area

• CRDA-3: Excavation and Consolidation under CMSD cover;

• CRDA-5: Excavation and Treatment by Thermal Oxidation;

• CRDA-4: Excavation with Off-Site Landfilling of theExcavated Material;

Backwater Area Sediments (Ohio River Sediments included ifindicated)

• SED-6: Sheet Piling Containment and Concrete Revetments.

• SED-8: Partial Dredging, Treatment by Solidification,Consolidation under CMSD cap.

• SED-7: Complete Dredging, Treatment by Solidification,and Consolidation under CMSD cap.

• SED-9: Complete Dredging, Treatment by SolventExtraction, and Consolidation under CMSD Cap.

• SED-4: Complete Dredging, Treatment by Solidification,and Off-Site Landfilling of the Dredged Sediments.

• SED-10: Complete Dredging (including Ohio RiverSediments), Treatment by Solidification, andConsolidation under CMSD cap.

VI. IDENTIFICATION AND RATIONALE FOR THE PREFERRED ALTERNATIVE

The preferred alternative is composed of the following remedialaction components:

• GW-3: Pumping of Ranney and Existing Interceptor Wells,Treatment of the Interceptor Well Water by FerrousSalt Precipitation, Clarification or otherappropriate treatment necessary to meet NPDESdischarge limits, and Discharge to the Ohio River;

• SP-4: Collection of Ballfield and CMSD Seeps UsingTrench Drains, Treatment of CMSD Seeps byOil/Water Separation and/or Carbon Adsorption;

• FSPSA-: Treatment by In-Situ Soil Flushing, andContainment by Single Barrier Subtitle D Cap(OAC:3745-27-ll(G)). (Capping may not benecessary if treatment eliminates the directcontact threat and renders the material in theFSPSA protective of groundwater.) This is acombination of FSPSA-6 and FSPSA-10;

£• FDP-10: Solidification (to provide engineering stability)

and Containment by Single Barrier Subtitle D Cap(OAC:3745-27-ll(G) ) . If solidification does notrender the cyanide immobile, then containmentshall be achieved with a RCRA Subtitle C CompliantCap;

• CMSD-5: Recontouring and Containment by Dual Barrier Cap(RCRA Subtitle C Compliant) placement of riprap/other engineering controls to prevent washoutof CMSD materials;

• CRDA-3: Excavate and Consolidate under CMSD cap; and

• SED-7: Complete Dredging, Treatment by Solidification,and Consolidation under CMSD cap. Any PCBcontamination found greater than 50 ppm shall bedisposed of off-site in a U.S. EPA-approvedlandfill or facility.

Capital Costs: $15,400,972 - $27,081,594O&M Costs: $ 5,400,000Present Worth Cost: $20,800,972 - $32,481,594

Based on new information or public comments, U.S. EPA, inconsultation with the State of Ohio, may later modify thepreferred alternative or select another remedial action presentedin this Proposed Plan and the RI/FS. The public, therefore, isencouraged to review and comment on all of the alternativesidentified in this Proposed Plan. The RI/FS should be consultedfor more information on these alternatives.

Each of the remedial action alternatives were evaluated using thenine criteria described in Table 4.

Threshold Criteria

1. Overall Protection of Human Health and the Environment

All alternatives under consideration except for Alternative 1(the No Action alternative) are protective of Human Health andthe Environment. Alternatives 2 through 10 would eliminate therisks associated with drinking contaminated groundwater bypumping contaminated groundwater and treating it prior todischarge to the Ohio River. In addition, Alternatives 2 through10 would eliminate the risk associated with the FSPSA, FDPs,CMSD, CRDA, and sediments through containment and/or treatment.Therefore, potential impacts to Human Health or the Environmentwill be eliminated under these alternatives.

Alternative 1 would not provide or enhance protection of HumanHealth or the Environment because it does not contain or treat

icontamination sources at the Site.

2. Compliance with ARARs

Below is an analysis of the ability of the components of eachalternative to achieve key ARARs. For a detailed breakdown ofall ARARs, please see Table 7-2 in Attachment 3 to the Addendumin the FS report.

40 CFR 141: Federal Drinking Water Standards promulgated underthe Safe Drinking Water Act ("SDWA") include both MaximumContaminant Levels {"MCLs") and non-zero Maximum ContaminantLevel Goals ("MCLGs"), that are applicable to municipal drinkingwater supplies servicing 25 or more people. At the Site, MCLsand MCLGs are not applicable, but are relevant and appropriate,because the aquifer underlying the Site is used as a source ofpotable water. Both GW-3 and GW-5 will meet this ARAR.

OAC:3745-33-01 through OAC:3745-33-10: Section 402 of the CleanWater Act establishes the National Pollutant DischargeElimination System ("NPDES") program. This program has beendelegated to the State of Ohio and the cited regulations setforth the requirements for the discharge of the treated groundwater into the Ohio River. Both GW-3 and GW-5 will meet theseARARs.

40 CFR 260.18(b) / OAC: 3745-54-18: Siting regulationspromulgated under the Solid Waste Disposal Act, as amended by theResource Conservation and Recovery Act, as amended ("RCRA")provide that hazardous waste facilities operating within a 100-year floodplain must be maintained so as to prevent washout ofhazardous substances. These requirements are ARARs because theCMSD lies within a 100-year floodplain. Alternatives whichinclude CMSD-4, CMSD-5, CMSD-7 or CMSD-8 provide engineeringcontrols to meet this ARAR. Alternatives which include CMSD-3 donot provide such controls to prevent washout and, therefore, willnot satisfy this ARAR.

RCRA Closure Requirements:

RCRA closure requirements govern the closure/capping of solidwaste (Subtitle D) and hazardous waste (Subtitle C) landfills,surface impoundments and waste piles. The State's hazardouswaste management program, as administered by Ohio EPA, wasapproved by U.S. EPA pursuant to 42 U.S.C. 6926(b) and 40 CFRPart 271 and became effective on June 30, 1989. The State'ssolid waste management program, as administered by Ohio EPA hasnot yet been finally approved by U.S. EPA, but because theState's solid waste caps are at least equivalent to the FederalSubtitle D requirements set forth in 40 CFR Part 258, the State'ssolid waste closure requirements are potential ARARs.

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FDP, FSPSA, and CMSD areas received waste which is similar tocurrently regulated hazardous waste (i.e., potliner). However,as discussed below, the Subtitle C hazardous waste closurerequirements may not be appropriate for all of these areas. TheCRDA contains carbon material and levels of arsenic, PCBs andPAHs which pose a future residential risk. Because this materialwill be excavated and disposed of, it is considered a solidwaste.

RCRA Subtitle C: Spent potliners were deposited in the FSPSA,the FDPs and the CMSD. Spent potliners from primary aluminumreduction are listed hazardous wastes under Subtitle C, at 40 CFR261.32. Because these materials were deposited prior to 1980,the effective date of RCRA, the RCRA Subtitle C (hazardous wasteprovisions) are not applicable. Cyanide is the hazardousconstituent for which spent potliners are listed. 40 CFR Part261, App. VII. Because cyanide is present in the spent potlinersat the Site, RCRA Subtitle C is relevant. RCRA Subtitle C isappropriate for the CMSD due to the presence of the cyanide seepsemanating from the western boundary of the CMSD and because spentpotliner was disposed of there. These seeps indicate that thecyanide is mobile within the CMSD. RCRA Subtitle C is notappropriate, however, for the FSPSA and the FDP because: 1) thebaseline risk assessment found no direct contact threat posed bythe cyanide; 2) the greatest concentrations of cyanide is in theFSPSA, which will be treated by soil flushing, thus transferringthe cyanide to ground water which will be treated to meet NPDESrequirements prior to discharge to the Ohio River; 3)solidification in the FDP is expected to render the cyanideimmobile; 4} following completion of the soil flushing, thesingle-barrier cap, if necessary, will provide sufficientprotection from exposure to the spent potliner materials in thislocation, and will similarly provide adequate protection in theFDP area. Despite the determination that Subtitle C requirementsare not ARARs for the FDP and FSPSA, alternatives which includecomponents FSPSA-3, FDP-7, and CMSD-5, the dual barrier cap,would meet the Subtitle C requirements.

RCRA Subtitle D: OAC:3745-27-11(G) regulates closure of areascontaining solid wastes. Alternatives which employ the soilcover, FSPSA-2, FDP-2, CMSD-3, and CRDA-3 will not meet thisARAR. Alternatives which include a single-barrier clay cap(FSPSA-10, FDP-10, and CMSD-8) will meet this ARAR. Alternativeswhich include a single-barrier FML cap (FSPSA-4, FDP-5, CMSD-7and CMSD-4) will have to demonstrate "equivalency" to thematerials set forth in this regulation, but can be designed tomeet this ARAR.

40 CFR Part 761: Regulations promulgated pursuant to the ToxicSubstances Control Act regulate the disposal of PCBs inconcentrations of 50 ppm or greater. PCBs were found in twolocations at the Site; in sediments in the Outfall 004 backwater

11area (at concentrations of up to 97 ppm) and in a singlecomposite soil sample taken at the CRDA (56 ppm). Alternativeswhich incorporate SED-7, SED-8, SED-9, SED-10 and CRDA-3 willmeet 40 CFR Part 761.60. PCB-contaminated soils greater lessthan 50 ppm shall be excavated and disposed of in a TSCAcompliant facility as set forth in these regulations. Thecomponents referred to above involve consolidation of arelatively small volume of PCB-contaminated sediments{approximately 2,000 - 4,000 cu. yds.) and soils (at most, 5,700cu. yds.) in relatively low concentrations (less than 50 ppm)into the CMSD, which will be capped and protected from washoutthrough the use of rip rap, concrete revetments, and/or otherengineering controls necessary to prevent washout.

Implementation of the No Action alternative would not achieveFederal and State health-based standards. Since the No Actionalternative does not provide protection of human health and theenvironment, this alternative will not be carried through forfurther evaluation against the remaining seven criteria.

Balancing Criteria

The comparative analysis for the balancing criteria will be doneby comparing the alternative remedial action componentsconsidered for each area/media at the site against each other.Areas/media proposed to be remediated are: groundwater (GW);Ballfield and CMSD Seeps (SP); Former Spent Potliner Storage Area(FSPSA); Former Disposal Ponds (FDP); Construction Material ScrapDump (CMSD); Carbon Runoff Deposition Area (CRDA); and BackwaterArea Sediments (SED) . There is only one alternative for theBallfield and CMSD seeps, therefore, no comparative analysis isprovided for remediation of this remedial action component.

3. Long-Term Effectiveness and Permanence

GW-3 and GW-5 would both provide long-term effectiveness andpermanence. In fact, GW-3 has been containing the groundwatercontamination plume for approximately 20 years and it has beenestimated that the plume will be remediated, if the pumpingcontinues over the next 30 years. GW-5, which calls forreplacing the existing intercepter wells with wells located inthe center of the plume is expected to remediate the groundwaterwithin similar timeframes as those estimated for GW-3.

CRDA-3, CRDA-4, and CRDA-5 would all provide long-termeffectiveness; however, only CRDA-5 would provide for a permanentsolution through excavation, treatment and off-site disposal.Since all of these options require disposal in a landfill, long-term maintenance of these landfills would be required.

SED-7, SED-9, SED-4, and SED-10 would all be effective over thelong-term; however, SED-9 would provide for a more permanent

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solution by treating the contaminated sediments via solventextraction prior to consolidation under a cap. SED-6 would beless effective in that this alternative allows for containment inthe backwater area, leaving the contained sediments vulnerable toflood events. In addition, SED-6 would eliminate a benthichabitat. SED-8 would not be effective in the long-term sincethis alternative allows for PCB contaminated sediment to remainin the backwater area above the cleanup level of l ppm.CMSD-4, CMSD-5, CMSD-7, and CMSD-8 all call for containment undereither a single or dual barrier cap which would be effective overthe long-term given proper O&M. Therefore, all alternativeswould require long-term maintenance.

FDP-7, FDP-3, and FDP-10 would provide treatment throughsolidification prior to capping. FDP-5, FDP-7, FDP-3, and FDP-10all call for containment under either a single or dual barriercap which would be effective over the long-term. However, FDP-5would not provide for treatment prior to capping. Therefore, itwould not be as effective as the other FDP alternatives. Allalternatives would require long-term maintenance.

FSPSA-9, FSPSA-4, FSPSA-3, FSPSA-10 all call for containmentunder either a single or dual barrier cap which would beeffective over the long-term. FSPSA-6 includes a vegetativecover which would not reduce infiltration through the fill. Allalternatives would require long-term maintenance. In addition,FSPSA-6 calls for soil flushing which provides for permanenttreatment of this source by flushing out contaminants which couldthen be captured by a groundwater pumping system.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment

Both of the groundwater alternatives (GW-3 and GW-5) will reducethe toxicity, mobility and volume (TMV) of contaminants throughtreatment by pumping out contaminated groundwater and treating itprior to discharge to the Ohio River.

CRDA-5 would reduce TMV through treatment prior to off-sitedisposal. CRDA-3 and CRDA-4 would not reduce TMV throughtreatment; however, by consolidating the excavated material underthe CMSD cap, mobility would be reduced.

SED-9 would reduce TMV through treatment; however, treatment willresult in an additional waste stream which would require furthertreatment prior to disposal. SED-7, SED-4, and SED-10 wouldreduce mobility of contaminants through solidification prior todisposal under the CMSD cap. SED-6 and SED-8 would not reduceTMV through treatment.

CMSD-7 would reduce TMV through treatment by thermal oxidation.CMSD-4, CMSD-5, and CMSD-8 would not reduce TMV throughtreatment; however, capping will reduce the mobility of

contaminants by placing an impermeable barrier over the waste.

FDP-7, FDP-3, and FDP-10 would reduce the mobility ofcontaminants through solidification prior to the waste beingcontained under an impermeable barrier. However, solidificationwould increase the volume in the FDPs. FDP-5 would not reduceTMV through treatment; however, capping will reduce the mobilityof contaminants by placing an impermeable barrier over the waste.

FSPSA-9, FSPSA-4, FSPSA-3, and FSPSA-10 would not reduce TMVthrough treatment. Although FSPSA-9 calls for partial excavationof the FSPSA, this alternative simply transfers this material toan off-site disposal facility, therefore there would be no netvolume reduction to the environment. FSPSA-6 would increasemobility of contaminants to the groundwater through soilflushing; however, the groundwater pumping system would capturethe contaminants and treat the groundwater prior to discharge tothe Ohio River.

5. Short-Term Effectiveness

Both GW-3 and GW-5 are estimated to achieve cleanup levels inapproximately 30 years. Currently the intercepter wells andRanney called for in GW-3 are containing the contaminatedgroundwater. GW-5 calls for relocating the intercepter wellsfrom the edge of the plume to the center of the plume, closer tothe FSPSA. Relocating the current intercepter wells would not beeffective in the short-term because it would not capturecontaminated groundwater located between the FSPSA and the Ranneywell.

CRDA-3 and CRDA-5 would be equally effective in the short-term.CRDA-4 may pose some short-term exposures since the materialwould need to be transported off-site for disposal. All of thesealternatives require complete excavation of contamination in theCRDA which would result in habitat alteration.

All of the sediment alternatives (SED-4, 7, 6, 8, 9, and 10)would present short-term impacts to the benthic habitat in thebackwater area during dredging and/or containment. However,since this area is connected to the Ohio River, resedimentationis expected to occur rapidly, except for SED-6 which wouldeliminate the backwater area. SED-6 eliminates the backwaterarea by cutting this area off from the Ohio River and capping thesediments in place. SED-8 would allow concentration of PCBsabove the cleanup level (1 ppm) to remain in the backwater area.

CMSD-4, CMSD-5, and CMSD-8 would provide more short-termeffectiveness through capping than CMSD-7, which calls forexcavation of the CMSD prior to treatment and capping.Excavation of the CMSD could cause fugitive dust emissions whichwould require engineering controls during implementation.

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FDP-7, FDP-3, FDP-10 require solidification prior to cappingwhich may generate fugitive dust emissions during the mixingprocess. Although FDP-5 does not call for solidification priorto capping there is a concern that the surface of the ponds couldnot support the heavy equipment needed to construct the cap.However, the dust emissions could be controlled during thesolidification process. FDP-7, 3, and 10 are considered to bemore effective in the short-term than FDP-5 becausesolidification would improve the geotechnical properties of theponds prior to capping.

FSPSA-4, FSPSA-3, and FSPSA-10 would provide more short-termeffectiveness through capping than FSPSA-9, which calls forexcavation of the FSPSA prior to treatment and capping.Excavation of this area could cause fugitive dust emissions whichwould require engineering controls during implementation. FSPSA-6, which calls for soil flushing is expected to take ten years toreduce the contaminant concentrations prior to capping.

6. Implementability

GW-3 has been operating for approximately 20 years and issuccessfully containing the groundwater plume on-site. GW-5would be implementable, but less so than GW-3 since GW-3 isalready in existence and GW-5 would require the placement ofadditional wells. In addition, there are concerns that thetreatment plant which is currently planned and permitted underGS-3 may not be able to handle the higher concentration ofcontaminated groundwater which would be produced by placing newwells closer to the FSPSA (GW-5). The new well locations underGW-5 could be accommodated with an additional treatment componentadded to the treatment system.

CRDA-3, CRDA-4, and CRDA-5 are readily implementable. Given therelatively small volume of material, off-site landfill capacityshould not pose a problem for CRDA-4.

All of the sediment alternatives will require at least temporaryisolation of the backwater area from the Ohio River which can beachieved by placing sheet piling along the entrance to the river.All of the sediment alternatives appear to be readilyimplementable; however, SED-9 may require a treatability studyprior to solvent extraction treatment. Given the relativelysmall volume of material, off-site landfill capacity should notpose a problem for SED-4.

CMSD-4, CMSD-5, and CMSD-8 would be readily implementable. CMSD-7 would be implementable; however, given its proximity to theOhio River, excavation and treatment of such a large volume ofmaterial may pose some construction problems.

FDP-5 would be less implementable than FDP-7, FDP-3, and FDP-10

since the unsolidified pond material may not be able to supportthe use of heavy equipment needed for capping. Given the limitedspace surrounding Pond 5, solidification may need to proceed instages across the pond.

FSPSA-4, FSPSA-3, FSPSA-6, and FSPSA-10 are expected to bereadily implementable. FSPSA-9 implementability would bedependent on the availability of off-site landfill space fordisposal of the excavated material. A treatability study wouldbe needed prior to implementation of FSPSA-6.

7 . Cost

The currently operating groundwater system (GW-3) is estimated tocost $1.8 million, whereas GW-5 is estimated to cost $3.3million. In addition, the O&M costs are expected to be higherfor GW-5 than for GW-3.

CRDA-3 would cost $100,000 for excavation and consolidation withthe CMSD. The costs increase by an order of magnitude to $1.6million under both CRDA-4 and CRDA-5 when this small volume ofmaterial is excavated and treated/disposed off-site.

The least expensive sediment alternatives are SED-6 and SED-8which are estimated to cost $228,000 and $224,000, respectively.Both of these alternatives contain at least a portion ofcontamination in-situ and do not provide any form of treatment.SED-7 is the most cost effective at $270,000 by removing thematerial and solidifying prior to placement under the CMSD cap.SED-4 is the least cost-effective in that is provides the samelevel of treatment as SED-7 but is estimated to cost $1.3million. SED-9 provides a higher level of treatment than SED-7but still requires containment under the CMSD cap. SED-9 isestimated to cost $1 million. SED-10 is estimated to cost$400,000 for excavation, solidification and consolidation underthe CMSD cap. The additional cost for SED-10 compared to SED-7is the result of excavating river sediments. Given the highlyindustrialized use of the Ohio River in this area, a fishingadvisory has been in place for the Ohio River between EastLiverpool, Ohio and the Greenup Locks and Dam near Portsmouth,Ohio. U.S. EPA believes that by addressing the backwater areasediments, the source of contamination from the Ormet Site, theOhio River will be protected from contamination from the OrmetSite. Therefore, remediation of the Ohio River sediments is notconsidered necessary.

CMSD-7 is the least cost-effective alternative in that it isestimated to cost $68 million and will still require somecontainment after treatment. CMSD-4, CMSD-5, and CMSD-8 aresimilar in cost at $1.3 million, $1.8 million, and $1.6 million,respectively. CMSD-5 has a higher cost because the dual barriercap provides an additional layer of protection.

FDP-7, FDP-3, and FDP-10 are similar in cost at $10.6 million,$8.3 million, and $10.8 million, respectively. The difference incost is associated with the difference in cost between avegetative soil cover, dual barrier cap and a single barrier cap.FDP-5 is the least expensive alternative at an estimated cost of$1.8 million; however, this alternative does not call forsolidification of the pond material prior to capping.

The least expensive alternatives for the FSPSA are FSPSA-4 andFSPSA-10 which are estimated to cost $1.4 million for a singlebarrier cap. FSPSA-9 is the most expensive alternative at anestimated cost of $2.6 million for partial excavation and bothoff-site disposal and an on-site single barrier cap. FSPSA-3has an estimated cost of $1.8 million. FSPSA-6 is the mosteffective of the FSPSA alternatives because it provides fortreatment of the Site's principal threat via soil flushing at anestimated cost of $520,000. The preferred alternative employsthe soil flushing component of FSPSA-6 and the single barrier capcomponent of FSPSA-10 at an estimated cost of $950,000.

Modifying Criteria

8. State/Support Agency Acceptance

The State of Ohio is currently reviewing this Proposed Plan.

9. Community Acceptance

Community acceptance of the alternatives will be evaluated afterthe public comment period ends and will be described in theRecord of Decision (ROD) for the Site. Responses to all publiccomments will be contained in a responsiveness summary in theROD.

VII. PREFERRED ALTERNATIVE

The recommended alternative is believed to provide the bestprotection for the affected area. Based on the informationavailable at this time, U.S. EPA believes the recommendedalternative would protect human health, would comply with Stateand Federal laws, would be cost-effective, and would utilizepermanent solutions and alternative treatment technologies orresource recovery technologies to the maximum extent practicable.The recommended alternative will satisfy the preference fortreatment as a principal element in the following areas:collection and treatment of groundwater and seeps; soil flushingof the FSPSA; solidification of the FDPs and backwater sediments.It will not however, satisfy the preference for treatment as aprincipal element in the remaining areas, including the CMSD andCRDA.

17

Table 4. Nine Evaluation Criteria

Threshold Criteria:

1. Overall Protection of Human Health and the Environment:Addresses whether a remedy provides adequate protection anddescribes how risks posed through each exposure pathway areeliminated, reduced, or controlled through treatment,engineering controls, or institutional controls.

2. Compliance with ARARs: Addresses whether a remedy will meetall requirements of other federal and state environmentallaws and regulations and/or provides grounds for invoking awaiver.

Primary Balancing Criteria:

3. Long-Term Effectiveness and Permanence: Refers to expectedresidual risk and the ability of a remedy to maintainreliable protection of human health and the environment overtime, once cleanup levels have been met.

4. Reduction of Toxicity. Mobility, or Volume ThroughTreatment: Assesses the degree to which a remedy utilizestreatment to address the principle threats at the Site.

5. Short-Term Effectiveness: Addresses the potential adverseeffects that implementation of a remedy may have on humanhealth and the environment, i.e. during construction andbefore cleanup levels are achieved.

6. Implementabilitv: Addresses the technical andadministrative feasibility of a remedy, including theavailability of services and materials.

7. Cost: Includes the estimated capital and operation andmaintenance costs for a remedy, also expressed in netpresent worth costs.

Modifying Criteria:

8. State Acceptance: Indicates whether the State of Ohiosupports the alternative.

9. Community Acceptance: Addresses the acceptability of thealternative to the local community based on commentsreceived during the public comment period.

Figure 1Location of theOrmet CorporationPlant

OHIO

Hannibal

CAC RanneyWell

Ormet SuperfundSite Boundary

OnnetRanney Well

ORMET PROPERTYBOUNDARY

Proctor

WEST VIRGINIA

HannibalLocks and Dam

Toll Bridge kNot To Scale

Ormet SuperfundSite BoundaryFigure 2 Ormet Site

PlantRecreation

Area

Former PotlinerStorage Area

004OutfallStream

ConstructionMaterial

ScrapDumpCarbon Runoff and

Deposition Area

Backwater Area

TABLE 1 Range of Groundwater Contamination at Ormet

Chemicals of concern (COG)in Groundwater

Tetrachloroethylene ( PCE)Arsenic (As)Beryllium (Be)Cyanide (CN-)Fluoride (F)Manganese (Mn)Vanadium (V)

Range of DetectedConcentration (ug/1)

5.0 - 40

1.8 - 394

0.25 - 35

11.0 - 18600

100.0 - 710,000

10.0 - 15,400

2.6 - 369

Clean upLevel(ug/1)5.0

101

4.0

200.0 P

4000.0

3802

542

P - Proposed2 - Health based clean up level; HQ< 11 « Detection Limit

Table 2 Smnmarv of Potential Excess Lifetime Cancer Risks and Non - Carcinogenic Hazards, from theOrmet, Hannibal. Ohio

Hypothetical Current Scenarios

Media

Backwater Area Sediments

ELCR

2 X 10"4

HI

—

SCOC

PCB, PAH

Hypothetical Future Resident Scenarios

Mediapond 5 soilspond 1-4 soilsFSPSA soilsCRDA soilsCMSD soils

Backwater Area Sedimentsground water

ELCR

3 x 10"41 x 10"37 x 10*31 x 10"35 x 10"3

3 x 10"4

2 x 10'3

MI

1.03.00.83.01.0

—

600

SCOC

As, Be, PAHAs, Be, PAH, VAs, Be, PAHAs, PAH, PCBAs, Be, PAH, PCB

PCB, PAH

As , Be , CN' , F , Mn , PCE , V

Hypothetical Future Worker Scenarios

Mediaground water

ELCR

1 x 10"3HI30

SCOC

As,Be,CN",F,Mn,PCE,V

ELCR = Excess lifetime cancer risk - (U.S.EPA's acceptable risk range is 10"4 10"6)HI = Hazard index - (HI < 1.0 is protective)SCOC = Chemicals of concern significant to risksPCB = Polychlorinated biphenylPAH = Polynuclear aromatic hydrocarbon

TABLE 3. REMEDIAL ALTERNATIVES AND CORRESPONDING REMEDIAL ACTION COMl'ONEMS

SnewidcRemedialXllcrnanvc

Number

1

2

3

4

5

6

7

89

10

RemedialAlternative

Category

NI» Aclum

Containment

Containment

Containment

Contammcnl/Off Site Disposal

Treatment 'Con tain men!

Tt cut rncnt /Contain me nl

E *c a vat inn /Treatment /Containment

E»cavftlionTiealment/O(f Sile Disposal

Treatment /Containment

Remedial Measures

Ground Water

GW 1

GW 3

GW 3

GW 3

GW 3

GW 3

GW-3

GW-3

GW 5

GW-5

Sccpt

SP-I

SP-4

SP-4

SP-I

SP-l

SP-4

SP-*

SP4

SP-1

SP4

Former SpentPotlincr

Storage Area

FSPSA-I

FSPSA2

FSPSA4

FSPSA-3

FSPSA 9

FSPSA 9

FSPSA 6

FSPSA 6

FSPSA9

FSPSA 10

FormerDisp^isal

Ponds

1 -[)!' 1

FDP 1

I-DP 5

FOP 7

FDP 5

FDP-3

rni' 7

FDP 5

FDP 7

FDP 10

ConstructionMaterial

Scrap Dump

CMSD 1

CMSD 3

CMSD-I

CMSD 5

CMSD-4

CMSD 7

CMSD 7

CMSD4

CMSD 7

CMSD-I

Carbon Run -offand Deposition

Area

CRDA 1

CRDV)

CRDA 3

CRDA 3

CRDA 3

CRD\ 5

CRDA 5

CRDA 3

CRDA4

CRDA 3

Ohio Ri

Sedimc

sr.D

SED

SI:DsrnsrD

StD

sunSED

SED-

SCO 1

Table 4. Nine Evaluation Criteria

Threshold Criteria:

1. Overall Protection of Human Health and the Environment:Addresses whether a remedy provides adequate protection anddescribes how risks posed through each exposure pathway areeliminated, reduced, or controlled through treatment,engineering controls, or institutional controls.

2. Compliance with ARARs: Addresses whether a remedy will meetall requirements of other federal and state environmentallaws and regulations and/or provides grounds for invoking awaiver.

Primary Balancing Criteria:

3. Long-Term Effectiveness and Permanence: Refers to expectedresidual risk and the ability of a remedy to maintainreliable protection of human health and the environment overtime, once cleanup levels have been met,

4. Reduction of Toxicity. Mobility, or Volume ThroughTreatment: Assesses the degree to which a remedy utilizestreatment to address the principle threats at the Site.

5. Short-Term Effectiveness: Addresses the potential adverseeffects that implementation of a remedy may have on humanhealth and the environment, i.e. during construction andbefore cleanup levels are achieved.

6. Implementability: Addresses the technical andadministrative feasibility of a remedy, including theavailability of services and materials.

7. Cost: Includes the estimated capital and operation andmaintenance costs for a remedy, also expressed in netpresent worth costs.

Modifying Criteria:

8. State Acceptance: Indicates whether the State of Ohiosupports the alternative.

9. Community Acceptance: Addresses the acceptability of thealternative to the local community based on commentsreceived during the public comment period.