sediment being removed from the RM 10.9 Removal Area contains dioxins, the only treatment available per the LDR is incineration. 59 69 Page 8-4 However, the sediment may require disposal at a The statement that the sediment may require disposal at a RCRA Subtitle C Agree that RCRA does not require disposal in a Subtitle C RCRA Subtitle C landfill due to regulations facility “due to regulations concerning concentrations of dioxin” is not landfill, however, many Subtitle D landfill permits prohibit concerning concentrations of dioxin. supported. If the sediment does not exhibit a RCRA characteristic, then RCRA their acceptance of waste containing dioxins. The text has does not require disposal in Subtitle C. If there is another regulation – perhaps been revised accordingly. a state regulation in the state where the receiving landfill is located – then it should be identified. 60 70 Appendix A Figures - [Appendix A] Looking at Figures A-2A and A-2B, locations 0343 and 0349 have 2,3,7,8-TCDD The Removal Area runs adjacent to, but does not include, the Figures A-2a and concentrations greater than 1,000 ppt, but do not appear to be included in the federal navigation channel. Locations on the boundary line, removal area. In addition, locations 0343, 0346, 0349 are highly elevated in the such as 0343, are included in the Removal Area. However, 0.5 to 1.5 foot depth interval. All 3 of these locations are just outside of the locations 0346 and 0349 are within the federal navigation boundaries of the removal area. Please either include them, or justify why you channel and therefore not part of the Removal Area as think this is not necessary. defined in the AOC. 61 71 Appendix A, Figure [Appendix A] The data on this figure appears to be incorrect. Please revise. The wrong dataset was inadvertently presented in this figure. The figure has been corrected.
sediment being removed from the RM 10.9 Removal Area contains dioxins, the only treatment available per the LDR is incineration. 59 69 Page 8-4 However, the sediment may require disposal at a RCRA Subtitle C landfill due to regulations concerning concentrations of dioxin. The statement that the sediment may require disposal at a RCRA Subtitle C facility “due to regulations concerning concentrations of dioxin” is not supported. If the sediment does not exhibit a RCRA characteristic, then RCRA does not require disposal in Subtitle C. If there is another regulation – perhaps a state regulation in the state where the receiving landfill is located – then it should be identified. Agree that RCRA does not require disposal in a Subtitle C landfill, however, many Subtitle D landfill permits prohibit their acceptance of waste containing dioxins. The text has been revised accordingly. 60 70 Appendix A Figures - Figures A-2a and [Appendix A] Looking at Figures A-2A and A-2B, locations 0343 and 0349 have 2,3,7,8-TCDD concentrations greater than 1,000 ppt, but do not appear to be included in the removal area. In addition, locations 0343, 0346, 0349 are highly elevated in the 0.5 to 1.5 foot depth interval. All 3 of these locations are just outside of the boundaries of the removal area. Please either include them, or justify why you think this is not necessary. The Removal Area runs adjacent to, but does not include, the federal navigation channel. Locations on the boundary line, such as 0343, are included in the Removal Area. However, locations 0346 and 0349 are within the federal navigation channel and therefore not part of the Removal Area as defined in the AOC. 61 71 Appendix A, Figure [Appendix A] The data on this figure appears to be incorrect. Please revise. The wrong dataset was inadvertently presented in this figure. The figure has been corrected.
20130227%20USEPA%20RTC%20Table%20%20Pre-Final%20Design.docx