UNITED STATES ENVIRONMENTAL PROTECTION AGENCY · 2021. 1. 12. · UNITED STATES ENVIRONMENTAL...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

FEB 2 1988

Ms. Barbara BainesHighlandtown Multi Purpose Center3411 Bank StreetBaltimore, Maryland 21224

Dear Ms. Baines,

Enclosed is the Record of Decision (ROD) and a separateResponsiveness Summary for the Kane & Lombard Superfund Site.Please put them with the other documents regarding the site.

Ihanks for all of your cooperation. Please feel freeto contact me if you have any questions. My number is215-597-4164.

Sincerely,

Nanci L. Sinclair

Enclosure

AR30I501

DECLARATION FOR THE RECORD OF DECISION

Site Name and Location

Kane and Lombard Superfund Site - Source Control East Baltimore, Maryland.

Statement of 'Purpose

This decision document represents the selected remedial action forthis site developed in accordance with CERCLA, as amended by SARA, and tothe extent practicable, the National Contingency Plan.

' - / *

The State of Maryland has concurred on the selected remedy.

Statement of Basis

This decision is based upon the administrative record (indexattached). .The attached index identifies the items which comprise theadministrative record upon which the selection of a remedial action is based.

Description of the Selected Remedy

This remedy focuses only on the Kane and Lombard property becauseadjacent properties are in the process of being investigated by the Stateof Maryland. Ground water in the area will be deferred in this Record ofDecision until further investigations on these other potential sites areconcluded.

The selected site remedy does not attempt to ensure compliance withall ARARs, but will be consistent, to the extent practicable, with thoseaction specific ARARs.

The selected remedy consists of the following:

* Removal of drums and hot spots, contaminated soil on the site.

* Site cleaning and removal of vegetation to the extant necessaryfor construction of the necessary components.

* Construction of subsurface containment/diversion structures toboth prevent the uncontrolled lateral ..migration of presentlycontaminated shallow ground vatsr from the site, and prevent thelateral recharge flow of uncontaminated ground wa'.er into thewaste area.

* Construction of a multilayer soil cap over the area to preventthe infiltration of precipitation and surface '.vater into thewasta area.

AR30I502* Construction of a drainage system.

* Clearing of drainage ditch along the east side of the site.

* Development of necessary surface water runoff management facilities.

* Continued ground water nnonitoring of the site..»'

*

DECLARATION

The selected remedy is protective of human health and the environment,attains Federal and State requirements that are applicable or relevantand appropriate, and is cost-effective. By removing the identified hotspots, this remedy satisfies the preference for treatment that reducestoxicity, mobility, or volume as a principal element.

Regional Administrator

H30I503

DEPARTMENT OF THE ENVIRONMENT201 WEST PRESTON STPEET • 3A:_T;MGPE. MARYLAND 21201

APEA CODE :c- • 225- 5647William Donald Schaefer . Martin W. Walsh, Jr.

Governor Secretary

22. T9R7

Mr.. Thomas Voltaggio, ChiefSuperfund Branch, 3HW20U. S. Environmental Protection Agency841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

Dear Mr. Voltaggio:

The State of Maryland's Department of the Environment hasreviewed the Feasibility Study Report for the Kane and Lombardsite.

It is the Department's view that the Preferred Alternative,Alternative 2 in the document, is the best alternative for siteremediation, however, with some modification, as cited in ourprevious letter of July 28, 1987. These modifications are asfollows:

1. The addition of a statement to the effect thatfuture remediation will address the removal ofany and all drumed materials which may be foundon-site. This should include both drums remainingon the surface and the deposit of buried drumsin the northeast quadrant of the site. In addi-tion, any highly contaminated material that mayresult from this removal should also be addressedfor disposal.

2. The Feasibility Study has not fully addressed thescope of groundwater contamination at this site.The shallow wells installed by this Departmenthave yielded data indicative of organics con-tamination in a perched water table underlaying « p q n I erthe site. The Feasibility Study should provide Ht\ 0U I Da mechanism for removal of this contamination.

Mr. Thomas VoltaggioPage Two

The two above-referenced changes are items previously discussedby EPA and the Maryland Department of the Environment and should,as such, pose no problem in the drafting of a completed document.

The Maryland Department of the Environment looks forward toworking-with EPA on the final design and implementation of thisremedial project. If we may be of any assistance, please contactus.

Sincerely,

Ronald Nelson, DirectorWaste Management Administration

RN: js

cc: Mr. Steve Wassersug

AR30I505

Site Description and Summary ofRemedial Alternative Selection

for the Kane & Lombard Superfund Site

Introduction

The overall objective of the Remedial Investigation/Feasibility Study(RI/FS) was to collect information needed to evaluate actual and potentialrisks to receptors from exposure to site-related contamination in soil,surface water, or ground water. This information supported a feasibilitystudy of remedial alterjnatives for controlling sources of contamination onthe Kane and Lombard site. Because of the absence of nearby domesticsupply wells,''this investigation did not include the collection of dataneeded to,evaluate alternatives for active aquifer restoration.Furthermore, the investigation focused only on the Kane & Lombard propertybecause adjacent properties are in the process of being investigated by thestate of Maryland. Ground water in the area will be deferred in thisRecord of Decision (ROD) until further investigations on these otherpotential sites are concluded.

Site Location and Description

The Kane and Lombard site is an 8.4 acre parcel of undeveloped landlocated in the Orangeville Subdivision in the southeast quarter ofBaltimore, Maryland. The site is southwest of the intersection of Kane andLombard Streets, is directly adjacent to Patterson High School on thesite's east and south boundaries, and is within one-quarter mile of theFrancis Scott Key Medical Center. Other nearby properties are industrialand commercial. Residential properties are located within one-third of amile southeast of the site. Figure 1 is a map of greater Baltimore with anindex map of the vicinity of the Kane and Lombard property.

Between 1962 and 1971, the site war excavated and refilled with solidand hazardous wastes. Between 1971 and 1984, dvmping occurred at thesurface of the site. In 1984, surface wastes were removed and the site wasgraded, capped, and fenced under an EPA immediate removal action. This actionremoved the direct contact threat with surface contamination. Contaminantsincluding ethylbenzene, dichloroethene, vinyl chloride, and polynucleararomatics have been detected in the soil or the ground water at the site,but not in the air or surface water. Several properties adjacent to thesite were also excavated and may have been used for the disposal of solidand hazardous wastes. There are also several oiiner possible principal hazardouswaste sites located within two miles of the Kan-j and Lombard site thac mayimpact environmental conditions in the area.

The fill encountered on the site is a heterogeneous nix of construction i r n Cdebris, domestic trash, and hazardous chemical wastes. The fill increaglii 0 0 I bllbin thickness northward to over 14 feet near Lombard Street. The volume ofthe fill on-site is estimated to be approximately 57,000 cubic yards.

5A6

ft 3 -,'.,' 5 0 7

1

3ai33

1ill

33

07

-2-

There are three relatively permeable water-bearing zones underlyingthe Kane and Lombard site to a depth of 150 feet. The first water-bearingzone consists of fill, sandy silt, and silty clay between 10 and 40 feetdeep. A 25-80 foot thick layer of silty clay, clay, and sandy silty clayseparates the first and second water-bearing zones. The second water-bearing zone consists of sandy silt and silty sand between 50 and 120 feetdeep. A layer of clay to sandy silty clay approximately 20 feet thickseparates the second and third water-bearing zones. The'third water-bearing zone consists of sand and silty sand over 130 feet deep.

Site History

Prior to about 1920 the area now occupied by the Kane and Lombard sitewas undeveloped woodlands. Based on a comparison of topography between1922 and 1968, approximately ten feet of fill was distributed on the siteafter 1922. •

*

In 1962, Edward and Marietta Azrael and Albert and Cele Landayacquired the Kane and Lombard property. At that time Mr. Landay owned twoother properties in the area, purchased in 1948, both of which had beenoperated as dumps. Dumping and burning occurred on what is now known asthe Kane and Lombard site and the area north of it from 1962 until 1967when the City of Baltimore passed Ordinance No. 1062 prohibiting the openburning of refuse. Illegal dumping continued from 1967 until approximately1984 during which time many citations were issued for illegal burning.

In November 1980, Maryland State inspectors observed between 400 and500 drums on the property. The majority of the drums were rusted, damaged,and contained holes. After negotiating at length with the property ownerover site clean up, the State of Maryland issued a Complaint and Order inAugust 1983 ordering the owner to clean up the site. The owner appealed theOrder. The State was unsuccessful in forcing compliance, and in April 1984requested the assistance of EPA under the authority of CERLCA. As a resultof the request, the State and EPA performed an on-site assessment of theproperty. EPA authorized the immediate removal of 1,163 drums from thesite in June 1984. Of those, 822 drums were classified as empty. Contami-nants in the remaining 34i drums included benzene, ethylbenzene, toluene,xylene, naphthalene, and other polynuclear aromatics, PC3s, phthalates,cyanide, and several heavy metals. Approximately 6 inches of soil belowthe drums was removed and sent offsite for disposal. The site was stabilizedby regrading, capping and revegetation.

In October 1984, the site was included on the Mational Priorities List(•JPL). A RI/FS began in October 19S5 and was completed in June 1987. In^pril 1987, the site was again rsjraded and hydroseede^ by EPA to minimizeerosion.

Current Site Status

Based on approximately 100 soil and ground water samples collecfiao 4yJ « 0 U Othe REM II contractor on and near the site, the most likely routes of potentialhuman exposure to contaminants are through the use of contaminated groundwater and through direct contact with contaminated soil.

-3-

Figure 2 illustrates the approximate locations of the on-site soil samples.Table 1 summarizes the numbers of samples in which organic contaminantswere detected, and the minimum, mean, and maximum concentrations of thecontaminants. Organic compounds were detected in 90 percent of theshallow soil samples (19 of 21 samples), 93 percent of the test pit samples(28 of 30 samples), and all of the 17 soil-boring samples analyzed. Themost cortmonly occurring compounds or chemical groups were phthalates, >polynuclear aromatics, toluene, mapthalene, PCBs, isophorone, carbon 'disulfide, and pesticides-, In all, 50 different organic compounds weredetected in at least one of the soil samples.

Table 2 summarizes the minimum, mean and maximum concentrations ofinorganic compounds detected in the 73 soil samples. Of the 17 inorganicconstituents analyzed for, 13 were detected in at least 85 percent of thesamples, less conroonly detected inorganics include beryllium, cadmium,mercury , and silver. ; '

Three distinct water-bearing zones were identified underlying thesite: A perched zone 10 to 40 feet deep; a semi-confined zoneapproximately 100 feet deep; and a second semi-confined zone approximately130 feet deep.

The first water-bearing zone consists of the lower portion of thefill layer and a silty layer at the top of the Arundel clay. Ground waterin this zone flows to the northeast at a rate between 0.2 and 11.8feet/day. Ground water from the site may flow through a drainage culvertand a buried stream valley toward Herring Run. The ground water in thezone is somewhat contaminated by aliphatic (up to 67 ug/1) and aromatic(up to 647 ug/1) organics. The zone has been designated as a Class IIIA aquifer because it probably does not have a sufficient areal extent toprovide an adequate yield for domestic water supplies.

The second water-bearing zone consists of a fine sand and sandy siltthat probably represents the top of the Patuxent Formation. Ground waterin this zone flows to the northeast at a rate between 0.01 and 0.1foot/day. Recharge to the zone appears to come primarily from thesoutheast and west. The zone may be hydraulically connected to the firstwater bearing zone to the north and east. The ground water in this zone issomewhat contaminated by aliphatic (up to 72 ug/1) and aromatic (up to 126ug/1) organics. The zone has been designated as a Class II S aquifer.

The third water-bearing zone consists of fine sand and silty sand ofthe Patuxent Formation. , The direction and rate of ground-water flow inthis zone were not determined as part of this RI. The third water-bearingmay be hydraulically connected to the second water-bearing zone northeastof the site. No evidence of ground-water contamination was detected in theone well screened in thi;j zone. The zone has been designated a a Class II3.

The alluvial deposits of Herring Run and other surface drainage waysdowngradient of the site Tiay be ^nore extensive than previously thought.The alluvial deposits under Herring Run intercept the outcrop zone efnisherj t c n nPatuxent Foundation and may allow contaminants to migrate to the BacVjRiver J „ ?or to other areas of the Patuxent aouifer.

LegendSoi' BoringTest Pit

• Surface Soil Sample

100 200• KMSeal* in F««(

1 incti * 130 Fe«

FIGURE '^l 4Joe;im6hls OF ON-SITE SOIL SAMPLES

OOOOOOGOOOOOOflOK»O«MOOOOf̂ f̂ ^̂ ^̂ ^̂ "̂% f̂ ^̂

1

X O«OO^^O*OOOOOO o rw o» o •« « iv IA (\JWKI2 *•« .J «*> - O * » * r K t Q« > C « « - (M .̂ ». .̂2 * > -4 >z ••• rM a.

O fUlv> >-

2O X••• O

>•

-4-

Figure 3-1 and 3-2 depict locations of on-site and off-site monitorwells.

There is no irmediate health threat to the community from ground-cratersince residents are supplied with drinking water by the City of Baltimore.Ground-water contamination may be an important issue relative to potentialfuture use of the ground water underlying the site, and the potential effectof migration of contaminated ground water beyond the site boundaries.

The proximity of Patterson High School and recreational facilitiesmakes direct contact exposures a potentially significant threat. Thisthreat is reduced by the presence of the clay silt cap that covers mostof the site and the fence which surrounds the site. Receptors related tothe Francis' Scott Key Medical Center and other nearby properties have morelimited potential for direct contact exposure to contamination at the site.

Alternative Evaluation

The remedial action objectives arising from the public healthevaluation are the following: (1) eliminate, or reduce to acceptable risk-based levels, soil contaminants which represent potential public healththreats via direct exposure to the contaminated materials and (2) eliminate,or reduce to acceptable risk based levels, ground water contaminants whichrepresent potential public health threats under the assumption of futureconsumptive use of the second water bearing zone underlying the site.Contaminants of concern include vinyl chloride, trichloroethylene, benzene,nickel, and cadmium. The first water bearing zone is not considered apotential source of drinking water. Of major importance to the second ofthese objectives is the possibility of regional ground water contamination,arising from the variety of other potential hazardous waste sites in thenear vicinity of the Kane and Lombard property. A second major considera-tion is the fact that the Kane and Lombard site encompasses only a portionof the excavation/fill known to have existed in the area. As a result ofthe potential for other contributions to ground water contamination, thisROD is limited to consideration of source control technologies to reduce oreliminate the contribution of the Kane and Lombard site to regional problems.

Based on the above objectives, numerous source control alternatives werescreened to provide a limited number of alternatives applicable for remedialactions at the site. Some of these alternatives were removed from furtherconsideration based on site-specific information and other comparativecriteria. Tnese other criteria include: effectiveness, implernentabilityand cost.

LegendMonitor Well LocationXXW-YYY xx is Well NumberXXP-YYY VYY is Approximate

Screen Depthw Indicates 4-Inch Wellp Indicates 2-Inch Well

( ) Zone Monitored(A) Indicates First

Water Beanng Zone(B) Indicates Second

Water Beanng Zone(C) Indicates Third

Water Bearing Zone(*) Indicates Sand Lens

Between First andSecond Water Bearing Zones

A£30I515

tfi£URE£~-i ROGATIONS OF ON-SJTE MONITOR WELLS

V

© Groundwater Monitor Well AR JO lib I Da.-,. 13W-032 Well Site 13; Screened f̂**̂ I ••„ to a Depth of 32 Feet TTT • ̂0_______________________^_______________________1 Mile >j[—-—-----i."" """.•"'." j J"...'. •••••Z".' --"~"' ^ ^ i—̂ 11—""°Jf'7̂ ~"" ""'-' '"[" __-... I- -•- ___ ""^ V *

OF OFF-SITE MONITOR WELLS

-5-

The alternatives that were dismissed from retention are presented belowwith the justification for elimination. A more detailed discussion of eachcan be found in the feasibility study.

Alternative Reason (s) for Elimination

- RCRA Landfill ' Higher implementation effortswithout providing increased security.Long-teen operation and maintenance.Land Disposal Regulations complicateon-site staging of excavated materialsfor redisposal. High cost.

- Soil Flushing Long term remediation is questionable.•'.*/.• Less effective and unreliable.

- Biological Land Treatment Not effective in removing metalsLand Farming from the soils nor contributing

to their immobilization in the soilmatrix. . Not effective on subsurfacecontamination.

In-Site Bioreclamation Unreliable and not effectivein removing or intnobilizing metal con-taminants .

The alternatives that have been retained for further analysis are:

Alternative 1 No action with drainageway maintenanceand long-term monitoring.

Alternative 2 ' - Containment- Multilayer cap

Alternative 3 Excavation/Incinerationa. Off-site disposalb. Off-site incinerationc. On-site incineration

Alternative 4 Excavation/Extraction

Alternative 5 In situ Vitrification

To analyze these alternatives, an evaluation was conducted thatconsidered the new requirements of the Superfund Amendments andReauthorization Act (SARA) of 1936 and the current version of the Nationa1.Contingency Plan (MCP) (50 Fed. Reg. 47912, November 20, 1985). Threebroad categories were used for the evaluation: effectiveness,implementability, and cost.

AR30I517

-6-

Within these categories there are factors that consider the short-term and long-term effects of each alternative. The evaluation is presented in detail inthe Feasibility Study. The following is a summary of the evaluation: »'»-Alternative 1. - No Further Action

The NCP requires that the no further action alternative be considered.

Implementability

Although designated as a no further action alternative, in that noremedial steps are take'n with respect to the wastes remaining on-site, thisalternative, does include maintenance of the existing fence (widen has beensubject to damage) and cap (which has been subject to erosion) in order toprevent their deterioration and subsequent re-exposure of the wastes.In addition, the remaining waste materials and debris at the surface ofthe site (in the drainageway) are to be removed.

Under this alternative, waste materials would not be removed from thesite, destroyed, or further imnobilized. Waste would continue to contact,and presumably leach into, the first water bearing zone, and whateverdegree of rain-water infiltration exists with the present cap wouldcontinue. Based upon observed erosion of the cap, its intergrity might beexpected to diminish even with maintenance. Overall, this alternativewill not be protective. It should be noted that all alternatives includethese essential steps, although the monitoring period may vary.

Since no waste remediation measures will be implemented, technicalfeasibility and availability are not an issue.

Effectiveness

* The existing control strategies at the site do not meet RCRA Subtitle Ccriteria for containment and control of contaminants.

* The Public and the State opposed this alternative, since little, if any,reduction in environmental impacts could result. This opposition may beheightened because of the proximity of the site to housing, schools, andrecreational areas.

* Long-term maintenance and post-closure effort.

* The no further action alternative would not reduce excess healch risks.

* Implementation is not likely to result in the generation of additionalground water or air contamination, and thus should not impose anyadditional adverse public health or environmental impact. * n o n IAHoy I

* The effectiveness of the ground ,\rater -nonitoring program in evaluatingimpending changes in health risks is uncertain due to the potentialpresence of nearby off-site contaminant sources.

-7-

Cost

Capital Cost - $624,060Present Worth* - $428,450

*Assumes 30 years Tiaintenance (waste left in place).

The high cost for the disposal of debris arises from the assumptionthat these materials have been contaminated, for example, by runoff fromthe site, and therefore require disposal in a RCRA landfill. It may bethat these materials could be disposed of in a Subtitle D landfill ratherthan a RCRA landfill. Unit cost for disposal in a nonhazardous fill areestimated to be $45 per cubic yard (as opposed to $203 per cubic yard for aRCRA land fill) resulting in maximum potential savings, for disposal of2016 cubic yards, of approxiately $319,000. This would result in a totalcapital cost of approximately $225,000 rather than $624,060. This savingwould be partly offset by expense incurred in sampling and testing of thedebris and sediment which would be necessary to obtain acceptance at a •nonhazardous landfill.

Alternative 2 - Containment

This alternative \s based upon the concept of removing the remainingdrums and hot spots of contaminated soils, and isolating the wastes, inplace, from contact with ground and surface water, as a means of reducingor eliminating their contribution to water contamination. This alternativefocuses upon positive actions to reduce the hazard posed by those wastes,by preventing their contact with water. Direct contact with the wastematerials is prevented in essentially the same way as under the no actionalternative, by site security measures; however, the importance of thesecontrols is heightened by the need to maintain the integrity of the contain-ment structures. The essential elements of this alternative include thefollowing:

* Removal of drums and hot spots on site.

* Site cleaning and removal of vegetation to the extent necessary forconstruction of the necessary components.

* Construction of subsurface containment/diversion structures to bothprevent the uncontrolled lateral migration of presently contaminatedshallow ground water away from the site, and prevent the lateralrecharge flow of uncontaminated ground water into the waste area.

* Construction of a multi-layer cap over tha area to prevent theinfiltration of precipitation and surface water into the wastearea.

* Construction of a drainage system. ^ A p o n I C! f QH R U U I D I J


* Development of necessary surface water runoff management facilities.

-3-

* Continued ground water monitoring of the site.

Implementability

* Construction of a subsurface barrier along the north boundary mustconsider continuing structural intergrity and chemical compatibilityof the structure because of its construction through the wasteiFurthermore, this barrier will be located in relatively closeproximity to Lombard Street, and may be subjected to vibrationfrom traffic. The potential for differential settlement andpossible damage to the cap must also be considered. Cost forthis construction may be more difficult to estimate because of thepotential variations from ordinary barrier wall construction.

* Any of these cap options will improve the performance of theexisting single-layer cover by exhibiting substantially lowerpermeability, and greater resistance to erosion.

* Necessary depths of barrier walls will run from 20 feet on the northboundary to approximately 55 feet on the south. These depths arewithin the range of constructability for such structures.

Effectiveness

To the extent that these measures prevent the migration of waterthrough the site waste materials, this alternative can be expectedto reduce significantly the_ ground water contamination arisingfrom this source.

Removal of the drums and hot spots will reduce the toxicity,mobility and volume on the site. The new cap will also constitutean additional physical barrier. Future use scenarios for thesite are essentially obviated during the life of this action, andany such future use would have to readdress the ultimate decon-tamination and/or disposal of the fill materials.

In terms of governmental and local acceptability, this alternative mayrepresent a relatively conservative management approach, to on-sitecontamination particularly if implemented as part of a regionalinvestigation into hazardous waste contamination. It will provideadequate containment and protection, at relatively lower cost, ascompared to other alternatives (which likewise would not addres? off-site contaminant sources).

AR30I520

-9-

* Under this option, a relatively small amount of excavated wastes,from the barrier construction on the northern boundary, will remainfor reburial. If these cannot be incorporated with the rest of thefill for capping, they will be disposed of off-site. Additionaldebris from the renovation of the drainage ditch will requiredisposal. Land Disposal Requirements concerning disposal might beapplicable depending upon timeframe. If disposal occurs beforeNovember 1988, this will not be an issue.

^* Short-term impacts likely to arise from this alternative will

likely be limited to those associated with the constructionactivity itself, in terms of noise, odor, traffic and othernuisance conditions, and maybe considered minor.

• t

* Long-term, issues to consider include the need for periodic capmaintenance, management, potential ground water monitoring.

f

* Discharge of contaminated water from the first water bearing zoneto the nearest publicly-owned treatment works via the city sewersystem will require consultation with city and state agencies.The magnitude of these discharges should not be a problem, due totheir small volumes and low concentrations.

* The implementation of the containment alternative can be expectedto contribute to a reduction in the public health risk associatedwith direct contact with the wastes.

* Potential negative impact arises from the fact that the wastes arenot permanently destroyed or immobilized, nor removed from the site.

* Cleaning of wooded areas -on-site would detract from visual aestheticsof this site. However, limiting the cap to the areas ofunacceptable contamination as shown in Figure 4, minimizes thedisruption of existing vegetation, and reduces this impact.

Cost

Tables 3-1 and 3-2 summarize costs associated with this alternative.

Alternative 3 - Excavation/Thermal Treatment

The thermal treatment alternative would involve destruction of organiccontaminants and separation of metals from the soils, and would likely bebased upon rotary kiln technology. However, other configurations shouldalso be considered in the design phase. T\e primary implementation optionsunder this alternative would be (1) on-sit; incineration utilizingtransportable kiln components which would be constructed and operated on-site for the duration of the cleanup effort, and (2) transportation of |\R30 i 52 Iexcavated materials to an off-site commercial RCRA incinerator facility.- - -- • - •- ••-Included as a baseline in this overall alternative is the suboption of off-site disposal of all excavated materials. This permits comparison betweenthe cost of treatment and the cost of direct redisposal. Otheralternatives which involve treatment of excavated materials may also becomoarad to this baseline.

• VRemaining Fill Area ̂^1 * ' ~

'S/B Barrier Wall (Option)

V-' • •• :>:. ."Subsurface

S/B Barrier Wati

DewaterWater

LegendFill Thickness; 0 to 5 FeetFill Thickness; 5 to 10 FeetFill Thickness; Greater Than 1) Feet

Debris in Drainage Ditch; Repair

I Cap Area

"* Surfacery Runoff,:̂\ Gravity

J " DrainageClean Out and Dispose of ' '̂ 40 Ditch

100=•• ...

Seal* in F+»t1 Inert - 130 Feet

FIGURE ̂ ALTS?NATIVE-2 .^AP/BARRIER WALL CONTAINMENTfff i u _< ; D ̂ o

1

H ! DESCRIPTION

l^^Site Clearing^Bj grassland, brush^70 trees

2 Cap Construction

a. Asphal t :granular base - 12"asphalt - 6"

b. Concretegranular base - 12"asphalt - 6"

c. Multilayer .. •- granular base, 12"

law pereneabi 1 i ty soil, 24"(peraeabili ty < 10 cat/sec)

- synthetic liner, 320,000 s.f.- drainge layer (sand), 12"

(perneabil i ty >10 c*/«ec)- geotextile fabric, 320,000 s.f.

vegetative soil cover, 24"(18" fill, 6" top soil)

^Jfcas Ventsi

4

5

6

7

8

Subsurface Barrier

o Soil/Bentonite Slurry Wall- south side, 630 ft x 50 ft• east side, 410 ft x 35 ft- west side, 560 ft x 35 ft- north side, 750 ft x 20 f.t.

(includes clean b a c k f i l l )

o test borings- south, east, north side- west side

Dewater perched water zonerecovery sunp, with pump

Reseed, revegetate

Clear drainage ditch (as inAlternative 1)

Monitor wells (inside and outside•̂fe.

^̂ 5/B wall)

QUANTITY

6. 1 ac.1.3 ac.

35,500 s.y.

35,500 s.y.

35,500 s.y.

12

31,500 s.f.14,350 s.f.19,600 s.f.14,800 s.f.

3611

^

1

35,500 s.y.

2,016 c.y.

20

UNIT COST, $

i

1,500/ac.2,000/ac.

18/s.y.

22.70/sy

36/s.y.

500/ea.

8/sf8/sf8/sf11/sf

1,100 ea.1,100 ea.

3,500

1.80/s.y.

203/c.y.

5,000 ea.

TOTAL COST, S

$9,150 (a.$2,600 (a,

i i -

$639,000 (b)

$816,500

$1,278,000 (a:

$6,000

$252,000 (a"$114,800

ALTERNATIVE 2 - PRELIMINARY ESTIMATE, CAPITAL COST -- CONTAINMENT

TEM

9

10

11

12

13

14

'"

DESCRIPTION

Engineering oversite personnelthrough implementation Phase (2persons, 1 year)

'

Suboptions

Suboption a - Site clearing,multilayer cap, S/B wall on south,east, north sides, gas vents,dewatering of perched zone,revegetation, clear drainage ditch,monitor wells, engineer/oversight.

Suboption b - Site clearing,asphalt cap, S/B' wall on south,east, north sides, gas vents,dewatering of perched zone,revegetation,' clear drainage ditch,monitor wells, engineer/oversight.

Note: 1) For concrete cap, add$177,500 to suboption b. 2) For S/Bwell on west site, add $156,800 toeither suboption.

Mobilization/Demobilization (22V.)Construction management, siteservicesa. suboption ab. suboption b

Technology lapl ementati on ,designs, plans, specifications,regulatory approval, insurancebonds, permits (22X)a, suboption ab. suboption b

Overhead and profit (10%)a. suboption ab. suboption b

Contingency (25X)a. suboption ab. suboption b

Total (rounded)a. suboption ab. suboption b

QUANTITY

4,000(

•

AR30

UNIT COST, $

45/hr.

TOTAL COŜ $

$180,000

> i'

$2,621,600

$1,976,600

•

$576.750$434,850

$576,750$434,850

_$262,160"$197,600

$655,400$494,150

$4.692,660$3,538,100

4 - item included in suboption a3 - item included in suboption b

ALTERNATIVE 2 - PRELIMINARY ESTIMATE OF OPERATING AND MAINTENANCE COSTS — CONTAINMENT

1

2

3

4

i5

6

7

B

9

10

( D E S C R I P T I O N

Security inspection, quarterly, 8hr/cycle

Monitoring - 5 wells analytical15 wells, water level only

o Labor: sampling 5 wills annually30 hours per cycle

o Analytical: VOA/BNA/mtals5 wells plus blank/duplicate

o Expenses, annual

Maintenance

o Fence repairo Vegetation control

Reporting/documentation

o Labor: quarterly inspection2 hr/cycle

o Labor - annual ground watermonitoring 24 hr/cycle

Operating power, removal ofperched ground water

o electric usage rateo service connection

Subtotal

Adaini strati ve (15X)

Contingency (257.)

ANNUAL TOTAL (rounded)

Present worth*

iQUANTITY

32 hr.

30 hr.

7

Lunp sun

250 ft/yr35,500/s.y.

* 8 hr.

24 hr.

1600 kw-hr

•

UNIT COST, $

35/hr.

35/hr.

950/ea

500

6/ft0.24/s.y.

35/hr.

35/hr.

0.063/kw-hr8. 50/month

TOTAL COST, $

$1,120

•

Si, 050

$6,650

$500

$1,500$8,520

$280

$840

$101$102

$20,6o3

$3,100

$5,170

$28,930

$247,930

ssumes 30 years maintenance (wastes left in place...Remediation takes 1 year,

HR301525TABLE 3>-A

-10-

The thermal treatment technology would be expected to exceed sourcecontrol cleanup criteria for the identified contaminants. However,depending upon the configuration of the kiln and accessory equipment,concern may arise over air emissions of volatile materials, including heavymetals. To some extent, such emissions will be controlled by flue-gasdevices such as wet precipitators or baghouse filters. ''

As an alternative, one of the kiln-based innovative technologies, suchas roasting, 'or chloride volatilization may be pursued further. The formerwould not separate metals from soils, but would immobilize them within.Since these are based upon rotary kiln technologies, their costs may, at aconceptual level, be expected to be only slightly higher than conventionalincineration processes, due to the additional chemical or material handlingequipment. However, substantial investigatory/pi lot work would benecessary before selecting these alternatives.

All waste materials would be excavated under this alternative. Sinceexcavation along Lombard Street will expose the face of the remainder ofthe fill which continues to the north, stabilization and capping of thisface would be required, both as an interim protective measure duringexcavation, and to prevent future interaction between those wastes and thetreated areas on-site. Temporary structural support of the exposed facemay be required to prevent collapse of the road base.

The general outline to a thermal treatment for the Kane and Lombardsite would include the following operations:

* Removal of the clean portion of existing cap, to be saved for re-burial.

* Excavation of fill, plus contaminated subsoils.

* Stabilization and capping of exposed fill along Lombard Street.

* Manual sorting (using construction equipment) of large debrisfrom the fill (cement culverts', auto bodies) for separatelandfill disposal. The materials must be removed prior to in-cineration to prevent damage to the kiln.

* Staging of excavated, pre-sorted material for processing.

* Mechanical shredding of materials (to

-11-

While this evaluation is based primarily upon rotary kiln technology,there are other incineration processes under development which may warrantconsideration in the implementation phase. One such process is the infraredincineration process which may present the capability for substantiallyhigher throughput rates. Compatibility of this equipment with the wastespresent at the Kane and Lombard site would require investigation.

Implenentability

The ability of incineration to destroy organics identified at the Kaneand Lombard site is reasonably certain. Of somewhat greater concern is theability to recapture metals from the flue gas and prevent or minimize airemissions. The presence of chlorinated organics may also require the useof wet neutralization'-equipment (caustic scrubber) to minimize emissions.In sum, the. basic incinerator would likely be supplemented by the incorpora-tion of a secondary combustion chamber, caustic scrubber precipitation/baghousefilter and other appropriate devices. A trial burn would likely be neededto determine the nature of the off-gas, and obtain necessary air permits.

A major consideration in determining the feasibility and costeffectiveness of incineration is the material throughput rate of thesystem, and the BTU content of the material being burned. The on-site soilmaterials are likely to have a negligible BTU and high ash content andtherefore may be a costly material to incinerate. Truly mobile (i.e.,trailer mounted) systems are limited by the size of the incinerator itselfand have limited capacity, on the order of tons of solid waste per hour.For this reason, a fairly large scale incineration project like the Kaneand Lombard site would involve the erection on-site of transportableincinerator components; at the end of the project, the system would bedisassembled and removed. Throughput rates in such a system may be in thearea of five.tons per hour. Permanent installation such as would exist atan off-site TSD facility would have substantially larger capacities.However, off-site incinerators may not accept bulk solids and repacking ofmaterials in drums may be required. Furthermore, available capacity atsome installations may be limited.

Excavation of the fill materials at the Kane and Lombard site will becomplicated by the presence of large objects, such as concrete sections,known to have been buried. Such objects will not only make the actualexcavation more difficult than would be the case with relativelyhomogeneous soils, but will also require pre-sorting and separate disposal.This factor will affect all alternatives which require excavation.

Due to the presence of the first water bearing zone, dewatering of theexcavation nay be required. Based on system throughput rates and prein-cineration materials handling requirements, actual implementation of thistechnology is expected to last approximately 3 years (post-construction).

-12-

Effectiveness

This alternative might be expected to exceed the applicable SARAbased source control criteria and result in permanent siteremediation requiring relatively minimal post-remediation main-tenance.

Long-term involvement with the site after closure would berelatively limited.

Short-term impacts are likely to arise from the incinerationprocess itself, with respect to potential air emissions.The ability of the incinerator off-gas cleaning devices to meetapplicable aiRemission standards should be addressed duringthe design and trial burn phases.

Even with the probability of meeting air pollution standards,this alternative could meet with some degree of local or communityopposition during the actual implementation. This opposition maybe largely overcome by effective public education effort concerningthe air emissions, and by demonstrating the permanent nature of thecleanup effort.

Since this alternative results in the off-site disposal of at leastsome materials (the pre-sorted debris which cannot be incinerated),all such materials must go to a facility which is permitted andoperated in accordance with Federal and State hazardous waste dis-posal regulations. Furthermore, the shipment of materials to thosefacilities must be performed in accordance with State and FederalDepartment of Transportation (DOT) regulations for shipment,handling, and tracking of hazardous wastes.

This alternative is likely to result in localized, short-ternimpacts typical of a heavy construction project, with respectto odors, noise, and traffic. The excavation will cause short-term impacts with respect to dust, and water collection.

This alternative should be expected to provide adequate protectionof public health from hazards associated with direct contact withsite materials. It can also be expected to effectively eliminatethe contribution of this site to further ground watercontamination; however, because of the presence of additionalfill areas in the immediate vicinity, and the potential contri-bution of other hazardous waste sites in the area, the degree ofi nprovement in ground water quality cannot be predicted att li ' time.

In addition to the uncertain effectiveness with respect to ground .*water remediation, the potential exists for sone negative i.-npacts 2-§to arise if problems ara encountered with air emissions. - n q n I stfml

The contaminant levels and leachability characteristics of the ashproduced from the incinerator 'Tiust be considered in their disoosal.

-13-

Cost

An evaluation of costs associated with this alternative is containedin Table 4-1 and 4-2.

Alternative 4. - Excavation/Extraction» r >

This alternative involves excavation of contaminated fill materialsfollowed by an extraction (soil washing) process to separate contaminantsfrom the soil, leaving a product sufficiently decontaminated to permit on-site reburial. Implementation of this alternative would involve thefollowing major operations:

* Removal of the clean portion of the existing cap, to be saved forreburial. :" *

* Excavation of contaminated fill and subsoils.

* Staging of excavated materials in a cleared area of the site.

* Stabilization/capping of exposed fill face along Lombard Street.

* Presorting for removal of large debris and off-site disposal ofdebris. Debris removal is required to avoid damage to equipment.

* Screening/mechanical shredding to achieve uniform small fragments.

* Processing of shredded wastes in soil wash equipment.

* Treatment of wash streams by appropriate technology (such asreverse osmosis or carbon absorption). Wash water will be recycledto the wash process, with concentrate/regenerant stream to disposal

* Sampling of washed materials to verify adequacy of treatment.

* On-site reburial of clean materials. Necessary makeup fill to beobtained off-site.

* Reburial of clean cap materials.

* Clearing of the drainage ditch along the east side of the site.

* Grading/Revegetation.

Ii?nl 'nentabi li ty

* Should the sampling program indicate that contamination in somefractions has not been sufficiently reduced, off-site disposalmay be required. Should the volume of such materials prove to besubstantial, any potential advantage of this approach o

'. [excavation and disposal would likely be lost.

ALTERNATIVE 3 - PRELIMINARY ESTIMATE, CAPITAL COST -- EXCAVATION/INCINERATION

FF"

1

2

3

j

6

DESCRIPTION

Excavation

Clean overburden (cap) (save forreburial )

Contaminated fill and subsoil

Presort debrisDisposal in RCRA fill

Fill disposal options(89,900 c.y. « 121,400 to'*)

SUBOPTION A - 'OFF-SITE DISPOSAL

o disposal in off-site RCRA l a n d f i l lo backfill , clean fill

Subtotal Subption A

SUBOPTION B - OFF-SITE INCINERATION

o transport and incinerationo backfill, clean fill

Subtotal Option B

SUBOPTION C - ON-SITE INCINERATION

o Mechanical shredder, 15 t/hr.o Incineration in transportable

incinerator unito Off-site ash disposal (RCRA)o Testing of incinerated waste

for reburial, one sample per500 c.y. (VOA/BNA/Metals)

o Reburial on-site of incineratedmaterial (assumes 302 volumereduction on incineration)

o Clean makeup fill

Subtotal Option C

Cap/containment along LombardStreet fill face

Concrete or asphalt capC* %

Grading/Vegetation


QUANT; TY

6050 c.y.

94,630 c.y.

4,730 c.y.4,730 c.y.

121,400 tons100,680 c.y.

121,400 tons100,680 c.y.

121,400 tons121,400 tons

160 ton200

62,900 c.y

37,780 c.y.

8,000 s.y.

6 ac.

2,016 c. y.

t \j >j i

UNIT COST, $

4/c.y.

5/c. y.

15/c.y.230/c.y.

173/ton12/c.y.

306/ton12/c.y.

15/ton200/ton

173/ton1 ,000 ea.

5.00/c.y.

12/c.y.

W3Q ! 58,700/ac

203/c.y.

TOTAL COST^fc

$24,200i

$473,150

$70,950$1,087,900

$21,002,200$1,208,160

$22,210,360

'!1;£'M$38,356,560

$1,821,000$24,280,000

$27,680$*» (* A * * *

• '• v t - - >

$314,500

$453,360

$27,096,540

30 "i0'°

ALTERNATIVE 3 - PRELIMINARY ESTIMATE, CAPITAL COST ~ EXCAVATION/INCINERATION

^̂ ^

7

8

10

^

9

12

13

14

.

DESCRIPTION

Monitor wells

Engineering oversite personnelthrough implementation phase (2persons, 3 years each

Subtotal (rounded) based upon filldisposal options (all other itemscommon) .v

Suboption A - Off-site disposalSuboption B - Off-site incinerationSuboption C - On-site incineration

Mobil iz at ion/Demobilization (22%)Construction management, siteservices

a. Off-site disposalb. Off-site incinerationc. On-site incineration

Technology Implementation,designs, plans, specifications,regulatory approval, insurancebonds, permits (22Z)


Overhead and Profit (10X)


Contingency (25X)


TOTAL (rounded)


QUANTITY

5

12,000 hr.

HR3_,

'UNIT COST, *

5,000 ea.

45/hr.

01531

TOTAL COST,

$25,00

$540,00'

-

'

$24,982,10(*41,199,20($29,939,20C

$5,496,05C$9,063,82C$6,586,620

$5,496,050$9,063,820$6,536,620

$2,498,210$4,119,920$2,993,920

$6,245,520$10,299,800$7,484,800

$44,718,000$73,747,000$53,591,000

—• i~v O"~, ̂ /_

^('continued)

IVE 3 - PRELIMINARY ESTIMATE OF OPERATING AND MAINTENANCE COSTS -- EXCAVATION/INC;rW

TEM

1

2

3

4

5

6

DESCRIPTION

Security inspection, quarterly 8 hr/

Monitoring - 5 wells annually

o Labor: sampling 30 hours per cycle

o Analytical : •VOA/9NA/attals5 wells plus blank/duplicate

o Expenses

Maintenance


Reporting/Documentation




Present worth*

QUANTITY

32 hr.

30 hr.

7

Lump sum

250 ft/yr29,000 s.y.

8 hr.

24 hr.

UNIT COST, $

35/hr.

-

35/hr.

9SO/ea

500

6/ft0.24/s.y.

35/hr.

35/hr.

'TOTAL COST, $

$1,120

$1,050

$6,65C

$500

$1,500$6,970

•$280

$C40

$18,910

$33,8(90

'Assumes 5 yr maintenance, post-remediation; remedial phase takes 3 years.

J TABLE

AR30I532

-14-

The process will likely result in relatively small weight and volumereductions in the washed materials (on the order of 10% forcontaminated soils washing) that would help to minimize the volumeof makeup fill required; however, the total reduction in volume forfill may be somewhat larger due to the removal of debris duringscreening. .•'•

The process will result in a volume of final discharge wash waterfor disposal. This water may be suitable for discharge to sewers.Remaining technical uncertainties with respect to necessaryextraction solutions and effectiveness must be addressed in a pilottest program.

Based on material processing rate and pre-wash materials handlingrequirements, the implementation phase of this technology isexpected to last 2.5 to 3 years.

Implementation of this process involves several relatively com-plex unit operations, including presorting and shredding, thewash process itself, the recovery and treatment of the washsolutions, and the need for testing of residual materials priorto reburial. The applicability of all of these steps to the typesof wastes at the Kane and Lombard site should also be examinedin the pilot program.

Effectiveness

Soil washing/extraction has the potential for at least meeting, andpossibly exceeding., soil cleanup criteria. It can also be expectedto substantially reduce the contribution of the Kane and Lombard siteto ground water concentrations of most of the identifiedcontaminants; however, the possibility of achieving ground watercleanup goals by this action cannot be addressed.

Treated soils may retain some low concentrations of contaminants andthe wash solutions (solvents) may leach out in' the future.

IThile off-site reburial of some treated materials could conceivablybe required, this treatment should approach the stated goal of re-ducing toxicity and/or volume of wastes considered for off-sitedisposal.

The potential for relatively high process throughput rates may,depending upon the rates of other components (such as excavationand post-treatment sampling) help to reduce the overall length ofthe remediation effort and minimize impacts arising from that effort.These (short-terra) impacts would primarily be those associated withthe heavy construction of the work, with respect to noise, odor andtraffic.

AR30I533

-15-

As this technology results in permanent separation of wastes from thesite, long-term impacts and issues are likely to be limited to anypost-remediation monitoring required to assess ground waterimprovement and, detect recontamination by,penetration ofthe barrier along the north boundary of the site.

,''Off-site disposal of presorted debris, treatment processconcentrate streams, and any unsuccessfully decontaminated wasteswill require compliance with U.S. and State DOT requirements forhandling, transport, and tracking of hazardous wastes. With conven-tional wash water treatment systems such as reverse osmosis or deioni-zation, both the volumes and the concentrations of the concentrate/regenerant streams can be quite high, and disposal of these volumescan add to the...cost and complexity of the project.

Local discharge of final, treated, wash waters will require an NPDESor.local sewer discharge approval.

Since this alternative will result in removal of contaminants fromthe site, it may prove effective in minimizing future threats topublic health and welfare arising from the Kane and Lombard sire.However, the performance of the system in meeting clean-up goalsshould be demonstrated prior to implementation.

Depending upon the contaminants and the solvents used, air (vapor)emissions from the process may have to be examined.

The primary negative public health or environmental impacts whichmay arise from this alternative concern the redisposal of the con-taminated wash solutions from the process.

Cost

Cost evaluation for implementation of this alternative is presented inTables 5-1 and 5-2. While the soil wash process has been used at a limitednumber of installations, the technique is relatively new, and the costof implementation at the Kane and Lombrad site may therefore be speculative.

Alternative 5. - In-Situ Treatment (Vitrification)

This alternative employs an innovative soil treatment technology,vitrification, in an attempt to achieve adequate containment or treatmentof contaminants without the requirement for excavation of the waste andsubsequent reburial/disposal and associated operations. Potential savingsin time and expense, and reductions in operating hazards to be gained byeliminating these operations must be evaluated against potential totalimplementation/operating costs and uncertainties associated with thevitrification process. Since the process is still in an early stage ofdevelopment, projected costs are somewhat uncertain. Furthermore, „application of the process to the highly heterogeneous fill materials ,^ f{ 3 0 I 5would require investigatory and pilot studies, and the cost and tine requirerdfor this development work should he considered.

ALTERNATIVE 4 - PRELIMINARY ESTIMATE, CAPITAL COST — EXCAVATION/EXTRACTION

^P DESCRIPTION

Excavation

o .Clean overburden (cap)(save for reburial)

o Contaminated fill and subsoil

Preosort debrisDi'spose in RCRA f i l l

• t '

Soil Wash(89,900 cy » 12400 tons)

Laboratory evaluation andprocess development

- Laboratory scale- Pilot scale

o mechanical shredding, IS ton/hr(to avoid equipment damage and

^̂ jcrease contact between solventil̂ Bd contaminants)

Soil wash process, 89,900 cy

o includes, treatment/recycle ofwash solution and disposal ofconcentrate/regenerant solution.Approximately 100 cy/day

Disposal of treated material

o testing of washed material, onesample per 500 c.y. Sample andanalyse for VQA/BNA/metal s (incl.blanks)

Backfillo reburial of washed soil (assumes

10X volume reduction)o reburial of capo clean makeup fill

Cap/containment along Lombard«eet:fill face

oncrete or asphalt cap

Grading/Vegetation

Clear drainage ditch (as in nAlternative 1) •'* i

QUANTITY-

6,050 c.y.

94,630 c.y.

4,730 c.y.4,730 c.y.

Lump sumLump sun

Lump Sum121,400 tons

89,900 c.y.

200

80,900 c.y.

6,050 c.y.13,370 c.y.

8,000 s. y.

6 ac.

-> o 2, 016, -Cry.i o u i •:• ,; o

UNIT COS', $

4.00/c.y.

5.00/c.y.

15.00/c.y,.230/c.y.

15/tons

95/c.y.

1,000 ea,

5/c.y.

5/c.y.12/c.y.

A,R308,700/ac.

203/c.y.

TOTAL COST, $

.,'

$24,200

$473,150

$70,950$1,104,690

$150,000$150,000

$1,821,000

$8,540,500

$200,000

$404,500

$30,250$164,760

535$160,000

$52,200

$409,250

1

1

{t

i

i.i!F

ft

*|

***

rK

t*H-

W

r>r .

V-V*

tai

Of

t-^r-Mi

U.

fj

ALTERNATIVE 4 - PRELIMINARY--.ESTIMATE,. CAPITAL COST — EXCAVATION/EXTRACTION

1'101J

r123

13

33i*. *^16

DESCRIPTION

Monitor wells

Engineer i ng/over^i te personnelthrough implementation in phase (2persons, 3 years each)

Subtotal

Mobilization/Demobilization (22%)Construction management, siteservices

Technology Implementation,designs, plans, specifications,regulatory approval, insurancebonds, permits (22%)

Overhead and Profit (10%)

Contingency (25%)

TOTAL (rounded)

QUANTITY

5

12,000 hr

UNIT COST, $

5,000 ea.

45/hr

! ^TOTAL COST, $

$25,000

$540,000

$14,320,450

$3,150,500

$3,150,500

$1,432,450

$3,580,10

$25,634,000

TABLE 5=1 (continued)

AR30I536

.TFPNATIVE 4 - PRELIMINARY ESTIMATE OF OPERATING AND MAINTENANCE COSTS — EXCAVATION/EXTRACT

EM

2

3

4

DESCRIPTION

Security inspection, quarterly, 8 hr


o Labor: sampling, 30 hours per cycl

o Analytical: VOA/BNA/metals5 wells plus, blank/duplicate

o Expenses, annual

Maintenance


'

Reporting/Documentationto Labor: quarterly inspection2 hr/cycle


5 ANNUAL TOTAL (rounded)

6 .Present worth*

ssumes 5 yr maintenance, post remediation

QUANTITY

32 hr

30 hr

7

Lump sum

250 ft/yr29,000 s..y.

8 hr.

24 hr.

UNIT COST, $

35/hr

••

35/hr

950/»a

500

6/ft0.24/sy

35/hr.

35/hr.

TOTAL COST, $

$1,120

$1,050

$6,650

$500

' $1,500$6,970

$280

-

$840 ,

$18,910 It

$53,960

remedial phase takes 3 years. '

TABLE S-3 ?

l\

AR3QI537

-16

The treatment to be achieved by in-situ vitrification consists ofimmobilization of metals within a crystalline matrix, and volatilization,followed by combustion/oxidation, of organics. The actual performance ofthe process in capture/destruction of organics must be demonstrated priorto implementation.

\t

Implementation of this alternative involves the following steps:

* Removal of clean portion of existing cap, saved for replacement.

* In-situ vitrification of contaminated fill area, extending intosubsoil layer.

* Replacement of'.clean cap materials, plus makeup fill and coversoil as required.

* Grading/vegetation.

Implementability

Literature reports indicate that vitrification of contaminated soilsresults in the formation of a stable glasslike and crystalline mass whichis quite resistant to leaching and weathering (Oma, et al, 1983). Itshould therefore, in such applications, result in an essentially permanentremedial technology, as long as no future use of the property would requireexcavation.

Testing has demonstrated that the ISV process is effective at depthsup to 10-13 meters (33 to 43 feet) (Oma et al, 1983) which is adequate forthe wastes at the Kane and Lombard site. A major uncertainty in theapplication of ISV or any in-situ process to material like that at theKane and Lombard site involves the heterogeneity of the materials and thecapability of the technology to deal with void spaces and discontinuities.Literature reports indicate that in-situ vitrification is not significantlyaffected by metal inclusions unless a full electrical short circuit occurs,and metal fractions as high as 5% of the total weight may be accommodated.Cement and concrete inclusions are reported to dissolve in the melt.Vitrification of soil containing sealed containers (e.g., drums) resultedin breaching of the container and release of gas to be captured in the ISVoffgas hood (Oma et al, ^983; Fitzpatrick, 1987a). More recent resultsindicate that large void spaces may be accommodated, apparently by coales-cence of the melt zone into the void (Fitzpatrick, 1987b).

The existence of the shallow water table in the base of the fill mayaffect ISV operations. Energy requirements ?.nd cost will increase due tothe necessity for evaporating this moisture. If an electrical shortcircuit is achieved the process will be compromised.

The equipment for ISV has apparently functioned well during testing-p on IHowever, operations on the scale necessary at the Kane and Lombard site H i v O Uhave apparently'not been demonstrated.

-17-

Operational cautions which should be considered in the implementationof ISV may include potential for accidental gas release due to hoodfailure/ and precautions associated with high temperature and high voltageequipment.

Current information on the processing rate for vitrification indicatesthat complete vitrification of the Kane and Lombard site, assuming 24hours/day of operation, would take 4.5 years.

While research and pilot testing of this process indicates promise forapplication in heterogeneous materials it has not been demonstrated forhighly heterogeneous landfill materials such as are present at the Kane andLombard site. Substantial development work will be required prior to thisselection of this option.

Effectiveness

* This alternative is likely to achieve or exceed cleanup levels fororganics in soil, and will substantially reduce contribution of allcontaminants (organics and metals) to ground water; as with otheroptions, the degree of ground water remediation to be achieved isdifficult to quantify. The inmobilization of metals in the crystallinematrix will reduce incidental exposure to these contaminants, butany future use such as construction which requires excavation ofthe material may result in some hazard. The native of the solidifiedmass may itself obviate such future use.

* Government and local opposition to this alternative as a long termsolution would likely be limited to concern over long-termprohibition of future land use, as with certain other options.Long-term impact in terms-of maintenance monitoring or surveillanceshould be relatively low.

* Short term impacts on the surrounding community would be thoserelated to construction activities at the site (noise, odor,traffic).

* Materials likely to be transported off-site under this alternativewould be limited to the debris removal to clean out the existingdrainage ditch. These materials.would, unless sampling could establishotherwise, be handled as hazardous and therefore be subject tofederal and state DOT regulations.

* This alternative would appear to provide adequate long-term pro-tection of public health and the environment, so long as tnesolidified mass is left inta :t and in place.

* As long as air amissions from the off-gas hood are effectivelyand consistently controlled, the degree of short-tern(implementation phase) hazard to public health and the envî cf|q|i0: | 539should not be excessive.

-18-

Cost

Cost evaluation for implementation of this alternative is contained inTables 6-1 and 6-2. Cost for the actual vitrification process have beendeveloped from vendor contact, and .should be considered speculative in theabsence of testing and detailed treatability analysis.

Recommended Alternative

Section 121 of the Superfund Amendments and Reauthorization Act (SARA)of 1986 and the current version of the National Contingency Plan (NCP) (50Fed Reg. 47912, November 20, 1985) establishes a variety of requirementsrelating to the level of cleanup for remedial actions under CERLCA.Applying the current evaluation criteria (implenentability, effectiveness,and cost that was previously described under each of the fivealternatives), we recommend that Alternative 2 be implemented at the Kaneand Lombard Superfund Site.

This remedy is a source control action.for the site. Ground water inthe area will be deferred in this Record of Decision until furtherinvestigations on other potential sites in the nearby area are concluded.This remedy does not attempt to ensure compliance with all ARARs for theentire site, but will be consistant, to the extent practicable, with thoseaction specific ARARs. CERCLA i 121 provides that under certaincircumstances an otherwise applicable or relevant and appropriaterequirement can be waived. These waivers apply only to the attainment ofthe ARAR, other statutory requirements, such as that remedies be protectiveof human health and the environment, cannot be waived. CERCLA $ 121 (d)(4)provides waivers which were considered in recommending this alternative.The following waivers are applicable to this site: 1) interim remedy; 2)greater risk to health or the environment, 3) technical impracability and4) fund balancing.

Alternative 2 is a source control remedy and can be viewed as an interimremedy because ground water in the second and third water-bearing zones arenot addressed. As stated previously, the ground water in this area will beaddressed at the conclusion of the investigation of other potential sources.

Alternatives 3,4 and 5 possibly provide permanent solutions to thesite; however, the risk associated with the implementation of thesealternatives provides a greater risk to the health and the environment viaair emissions than the implementation of Alternative 2.

Due to the enomous amount of construction material and debris buriedon-site, total excavation required under Alternatives 3,4 and 5 would betechnically impracticable and costly. Alternative 2 will !ocus on removingselected hot spots identified in the geophysical survey and samplinganalyses, versus tha entire site and is less costly.

Table 3 lists statutory requirevents and \RARs applicable toAlternative 2.

ALTERNATIVE 5 - PRELIMINARY ESTIMATE, CAPITAL COST — IN SITU VITRIFICATION

TEM

1

2

3

•5

6

7

8

9

10

11

«13

15

DESCRIPTION

Site preparationi

Remove clean overburden (cap)(Save for reburial)

Vitrification process

Laboaratory Evaluation and' ProcessDevelopment

• laboratory scale

- pilot scale

Vitrification processing

Reburial of overburden (cap)

Makeup f i l l , plus soil cover, 2 ft.1 total

Grading/vegetation


Monitor wells

Engi neer ing/oversi te personnel,through iapl eaentation phase, (2persons, 5 years ea.)

Subtotal

M o b i l i z a t i o n / D e m o b i l i z a t i o n (22 X)Construction aanagenent, siteservi ces

Technology Impl ementat i an ,designs, plans, specifications,regulatory approval, insurancebonds, peraits (22%)

^Overhead and profit (10%)

Contingency (25X)

TOTAL (rounded) - - •-, }

QUANTITY

6,050 c.y.

Luap Su«

Lump sun

Lump su«

94,630 c.y.

6,050 c.y.

19,400 c.y.

6 ac.

2,016 c.y.

5

20,000 hr.

fl

UNIT COST, $

4/c.y.

270/c.y.

5.00/c.y.

15/c.y.

8,700/ac.

203/c.y.

5, 000/ea.

45/hr.

R30 I5fc|

TOTAL COST, $

$24,200

$150,000

$150,000

$25,550,100

$30,250

$291,000

$52,200

$409,250

$25,000

$900,000

$27,592,000

$6,070,240

$6,070,240

$2,759,200

$6,898,000

$49,389,700

lERNATIVE : - PRELIMINARY ESTIMATE OF OPERATING AND MAINTENANCE COSTS — IN SITU VITRlFlC

1EM3'

2

33

z3UjJkr•""I

3553>

DESCRIPTION

Security inspection, quarterly, 8 hr


o Labor: sampling, 30 hours per cycl

o Analytic*!: VOA/BNA/aetals5 wells plus blank/duplicate

o Expenses, annual

Mai ntenance

a Fence repairo Vegetation control

Reporting/Documentation


o Labor - annual ground water•onitoring, 24 hr/cycle


Present worth*

QUANTITY

32 hr.

30 hr.

7

Lump sum

250 ft/yr29,000 s.y.

8 hr.

24 hr.

UNIT COST, $

35/hr.

35/hr.

950/ea

500

6/ft0.24/sy

35/hr.

35/hr.

11 t

'TOTAL COST, $

$1,120

$1,050

$6,650

$500

$1,500•"•$280

$840

$18,910

$44,olO

TABLE fa-

1

1T

3

1

»Assuaes 5 yr *ai ntenance, post-re«edi at i on , remedial phase takes 5 years.

-J

RR30I5I42

-19-

This alternative consists of the following:

* Removal of drums and hot spots contaminated soil on the site.

* Site cleaning and removal of vegetation to the extent necessary forconstruction of the necessary components.

i

* Construction of subsurface containment/diversion structures to bothprevent the uncontrolled lateral migration of presently contaminatedshallow ground water from the site, and prevent the lateral rechargeflow of uncontaminated ground water into the waste area.

* Construction of a multilayer soil cap over the area to prevent theinfiltration of precipitation and surface water into the waste area.

, /

* Construction of a drainage system.


* Development of necessay surface water runoff management facilities.

* Continued ground water monitoring of the site.

The conceptual development of this alternative is presented in Figure4. This configuration has been developed to provide, to the extentpossible, complete on-site management of surface water.

Along the eastern boundary of the fill, ground water containment isprovided by the subsurface slurry wall. Along the north boundary (LombardStreet) a similar subsurface barrier is used.

In this region, however, the wall must be constructed through fillmaterials, which complicates the construction process itself, involvesuncertainites regarding wall continuity, and raises concerns over its long-term physical and chemical intergrity. However, there are a variety ofcomplications and unknowns which should be considered. These include theincreased amount of excavation required to work around buried objects, theunknown additional slurry which may be needed to achieve an effective sealin the porous fill, and the requirement for disposal of wastes excavatedfrom the trench and their replacement with imported fill (as opposed to themore common reuse of trench excavated as backfill). These complicationsintroduce additional uncertainties into the cost estimates. While othersubsurface structures (diaphram or piling walls) may provide greater structu-ral rigidity in this area, they may also involve significantly higherpermeabilities.

Along the south side, the subsurface contaiament structure has beenextended to the southwest in such a way as to tie into the topography inin the Southwestern corner and divert all ground water, entering fromthe southwest, to the northeast, generally similar to its natural flow.jDQQ I 5 b 3

-20-

Following construction of the subsurface containment/diversion system,the site will be capped to prevent infiltration of precipitation. Capconstruction will include the construction of drainage channels andappropriate grading to direct runoff to the east for discharge in theexisting drainage ditch along the eastern boundary.

The first water bearing zone contained within the site will bedewatered by the placement of a shallow sump in the northeast area of theconfined zone, to intercept this water as it flows naturally to thenortheast. A new cap system and subsurface barrier/wall will minimizeentry into the site and the shallow sump will withdraw existing water fromthe shallow zone. Current evidence indicates that this zone will drain,over a period of years at a declining rate. Since this water iscontaminated it will ngt be discharged directly to the surface or stormsewers. The preferential disposition for this relatively small flow wouldbe discharge to the sanitary sewer system and hence to the municipal wastewater treatment plant, under an agreement with the city. This proposal hasbeen discussed with the state and the city.

Comparison of Remedial Alternative

Table 7 provides a comparison of the five remedial alternativesdescribed in the ROD.

Schedule

Concurrence of ROD September 1987

Negotiations with PRPs October 1937 - December 1987

Initiate Design Phase January 1988

Complete Design June 1988

Initiate Construction August 1988

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Table 8Selected Action - Specific Probable ARAR Requirements

for Alternative 2 - Recommended Alternativefor the Kane and Lombard Site

Action Requirements Citation

Capping Placement of a cap over waste 40 CFR 264.310 (a)requires a cover designed and

264.228 (a) constructed to:

0 Provide long-term minimizationmigration of liquids throughthe capped area;

0 Function with minimum maintenance;

0 Promote drainage and minimizeerosion or abrasion of the cover;

0 Accomodate settling and subsidenceso that the cover's integrity ismaintained; and

° Have a permeability less than orequal to the permeability of anybottom liner system or naturalsub-soils present.

0 Restrict post-closure use of 40 CFR 2^4.117 (c>property as necessary to preventdamage Ma the cover.

0 Prevent run-on and run-off from 40 CFR 264.228 (b)damaging cover. 40 CFR 264.310 (b)

Closure with Removal of contaminated materials. 52 FR 8712waste in place (March 19, 1987)(Hybrid Closure)

Application of cover and post-closure 52 FR 8712monitorin.2 based en exposure pathway(s) (March 19, 1987)of concern.

Table 8 Continued

Action Requirements Citation

Consolidation Placement on or 'in land outside unit 40 CFR 268;boundary or area of contamination will (Subpart D)trigger land disposal requirements andrestrictions.

Removal of drums * Land Disposal Restrictionand contaminated"hot spot" areas. Tfye selected remedy involves placement and treatment of

soils and debris wastes. Placement of wastes or treatedresiduals is prohibited under RCRA Land DisposalRestrictions (LDR) unless certain treatment standards aremet. LDR standards have not been promulgated for soiland debris wastes, but.when published, the standards maybe applicable or relevant and appropriate. Despite theabsence of specific treatment standards, the treatmentmethod employed as part of this remedial action satisfiesthe statutory requirement to, "... substantially diminishthe toxicity of the waste or substantially reduce.thelikelihood of migration of hazardous constituents fromthe waste so that short-term and long-term threats tohuman health and the environment are minimized."[sec. 3004 (m) H.S.W.A.]

Discharge to POTW Pollutants that pass-through the POTW 40 CFR 403.5without treatment, interfere with POTWoperation, or contaminate POTW sludgeare prohibited.

Specific prohibitions preclude thedischarge of pollutants to POTWs that:

0 Create a fire or explosion hazard in thePOTW;

0 Are corrosive (pH < 5.0);

0 Obstruct flow resulting in interference;

0 Are discharged at a flow rate and/orconcentration that will result ininterference, and

0 Increase the temperature of wastawaterentering the treatnent plant chat would

Table 8 Continued

Action Requirements Citation'

result in interference, but in nocase raise the POTW influent temper-ature above 104° F (40°C).

0 Discharge must comply with local 4(J CFR 403.5 andPOTW pretreatment program, including local POTW regu-POTW-specific pollutants, spill lations.prevention program requirements, andreporting and monitoring requirements.

0 RCRA permit-by-rule requirements must 40 CFR 268be compiled with for discharges of (Subpart D)RCRA hazardous wastes to POTWs by truck,rail, or dedicted pipe.

Ground-water Excavation of soil for construction of 40 CFR 268Diversion slurry wall may trigger cleanup or land (Subpart D)(Slurry Wall) disposal restrictions.

Operation and Post-closure care to ensure that the site 40 CFR 264.1maintenance is maintained and monitored.(0 & M)

AR301550

FINAL RESPONSIVENESS SUMMARY

KANE AND LOMBARD SITE

BALTIMORE, MARYLAND

From August 30, 1987 through September 28, 1987, the U.S. EnvironmentalProtection Agency (EPA) held a public comment period on the Feasibility Study(FS) for the Kane and Lpmbard site in Baltimore, Maryland. The purpose ofthis document is to summarize comments on the FS expressed by residents, localofficials, and other interested parties during thepublic comment period andto provide EPA responses to those comments.

This responsiveness summary is divided .into the following sections:

Section I Site Background. This section provides a brief sitehistory and discusses EPA's preferred alternative forremedial action.

Section II Summary of Major Comments and EPA Responses. Allcomments are categorized by relevant topics. EPAresponses to these comments also are provided.

I. SITE BACKGROUND

The Kane and Lombard site is an 8.4 acre parcel of undeveloped landlocated in Baltimore, Maryland. The site is bounded on the north by LombardStreet, on the south by Patterson High School, on the east by recreationalfields, and to the west by a trucking company. Located in the Orangevillesection of the city, the site is situated less than 1/2 mile from aresidential area and the Francis Scott Key Medical Center.

According to site records, the Kane and Lombard site was used to disposeof construction and demolition debris, household trash, and industrial wastes.The site came to the attention of the State of Maryland in 1980 when severalhundred drums were discovered on site. Following unsuccessful efforts by theState to force the owner to clean up the site, EPA removed approximately 1200drums and the surface soil layer from the site. EPA than stabilized the siteby regrading, covering the site with a clay cap, and r^vegetating the sitearea. In 1984, the Kane and Lombard site was added tc EPA's NationalPriorities List (NPL) and in October 1985, contractors to EPA began a RemedialInvestigation/Feasibility Study (RI/FS) of the site.

Remedial investigation activities at the site included examination of||tRe3Q I bb isite's history and current conditions with respect to surface characteristics,subsurface soil and geologic characteristics, and surface and subsurface watercharacteristics. The RI then characterized the chemical contaminationremaining at the site by sampling site soils and ground water and assessed thepublic health threat posed by the.;sit.e. , ... . .

Using information collected during the RI, EPA developed an FS thatdescribes and evaluates alternatives for addressing contamination at the site.These alternatives — known as remedial alternatives — were evaluated on thebasis of how easily they could be implemented, how successfully they couldprotect public health and.the environment, and how much they were likelv tocost. As part of the FS, a variety of technologies for controlling sources ofcontaminants were screened and applied to the alternatives proposed foraddressing contamination at the Kane and Lombard site. Because of thepresence of other, off-site sources of contamination, the FS was limited inscope to considering the contaminated soil sources at the site. Described indetail in the FS report, these alternatives are summarized in the ProposedRemedial Action Plan (PRAP). The PRAP presents a brief summary of theremedial alternatives developed in the FS report, identifies an alternativepreferred by EPA, and provides the basis for the Agency's preference.

After careful consideration of the proposed remedial alternatives, EPA'spreferred alternative for addressing contamination at the Kane and Lombardsite is Alternative 2: Containment. This alternative would involve:

« Clearing the site;

• Removing drums on the site;

• Constructing a slurry wall below the surface of the siteto contain contaminated ground water within the site anddivert uncontaminated ground water away from the site;

« Constructing a cap and drainage channels to preventprecipitation from seeping through contaminated materials;and

a Installing facilities to remove the ground water fromwithin the contained area.

While no reduction or other modification of site contamination takes place,this alternative focuses on isolating the wastes, in place, from contact withground or surface waters, as a means of reducing or eliminating theircontribution to water contamination. By implementing site security measures,direct contact with waste materials will be prevented.

If. SUMMARY OF MAJOR COMMENTS AND EPA RESPONSES

EPA held a public comment period on the Kane and Lombard FS report fromAugust 30, 1987 to September 28, 1987. A public meeting was held at thePatterson High School on September 10, 1987 at 7:00 p.m. Those attending themeeting included representatives from EPA, the Maryland Departmentand Mental Hygiene (MDHMH) Waste Management Administration, area newsreporters, and approximately 30 community residents. During the meeting, EPAstaff presented an overview of the events that had occurred at the site,described hew the Superfund cleanup program works, described the proposedremedial alternatives.1 fcn4 explained why EPA had chosen Alternative 2 as the

preferred alternative. Following thi5 presentation, EPA answered questionsfrom the citizens about the proposed remedies and the cleanup of the site.

EPA participated in a follow-up meeting on September 21, 1987 at 0:00a.m. in the offices of Congressman Benjamin Cardin (Maryland - District 3) tobrief the congressman and his staff on the proposed and preferred remedialalternatives. The meeting was attended by representatives from EPA; stafffrom the MDHMH Waste Management Administration, Public Information, andCommunity Relations offices; and citizen representatives from the EastwoodCivic Association and the BEDCO association.

Questions, comments, and concerns received during both meetings andthroughout the comment period are summarized below and are categorized byrelevant topics. Each comment i* followed by EPA's response.

ON-SITE CONTAMINATION

Question; Many residents asked what chemicals EPA found at the site.

Response: EPA stated that no contamination was found in either the air or thesurface water at the site; however, the soil at the site was contaminated withboth organic and inorganic chemicals. The primary contaminant found insurface and subsurface soils was lead. Other contaminants found in the soilincluded polynuclear aroraatics (PNAs), phthaltates, toluene, inorganiccompounds, and polychlorinated biphenyls (PCBs). The first ground water zone,which extends to a depth of approximately 10 feet, was shown to becontaminated with cadmium, chromium, nickel, vinyl chloride, dichoroethelene,and trichloroethene.

Question: Several residents asked what chemicals continue to remain on site.

Response: EPA stated that four to five barrels remained on site after the1984 emergency removal action. These drums were found to contain non-toxicinert chemical residues and do not present a health threat.

Question: Many residents expressed concern that the fence surrounding thesite' was inadequate and that area children easily could gain access to thesite. In addition, several residents cited a recent Baltimore Sun articlethat referred to breaks in the fence.

Response: EPA responded that no holes had been found in the fence and thatrepresentatives of MDHMH checked the fence monthly and also had found nobreaks or holes. EPA iterated the importance

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