PB99-963921
EPA541-R99-086
1999
EPA Superfund
Record of Decision:
Rodale Manufacturing Co. Inc. Site OU 1
Emmaus Borough, PA
9/30/1999
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SUPERFUND PROGRAM
RECORD OF DECISION
Rodale Manufacturing Superfund Site
Emmaus, Lehigh County, Pennsylvania
Ui
SEPTEMBER 1999
PART I - DECLARATION
SITE NAME AND LOCATION
Rodale Manufacturing Superfund Site
Emmaus, Lehigh County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Rodale
Manufacturing Superfund Site (Site). The remedial action was selected in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is
based on the Administrative Record for the Site.
The Commonwealth of Pennsylvania through the Department of Environmental
Protection (PADEP) has verbally concurred on the ROD.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant to Section 106 of
CERCLA, 42 U.S.C. § 9606, that actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to the public health, welfare, or environment.
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DESCRIPTION OF SELECTED REMEDY
The selected remedy described below is the only planned action for the Site. The selected
remedy includes 1) hydraulic containment of the highest levels of contaminated ground water at
and in the vicinity o'f a portion of the aquifer at the Site which has been determined to have
Dense Non-Aqueous Phase Liquid (DNAPLs) (the area is referred to as the "Probable DNAPL
Zone"); 2) a Technical Impracticability waiver for the Applicable and Relevant and Appropriate
Requirement (ARAR) for TCE in ground water and TCE and PCE for the subsurface soil in the
Probable DNAPL Zone; and 3) passive treatment through Monitored Natural Attenuation
(MNA) for the ground water contamination that has migrated beyond the boundaries of the
Probable DNAPL Zone.
The selected remedy specifically includes the following major components:
1. Hydraulic containment of the dissolved phase VOC plume at and in the immediate
vicinity of the Probable DNAPL Zone by extraction and treatment of ground
water. This involves, but is not limited to, using an existing ground water
treatment system (GWTS) at the Site. The GWTS includes the following
components: an equalization tank, a liquid/solid separation unit and sludge
handling equipment, an air stripper, liquid phase granular activated carbon units,
and a regenerative vapor phase adsorber unit. Ground water in this part of the
plume will be remediated to the cleanup standards listed in Table 1 of Part II of
this Record of Decision.
2. Monitored Natural Attenuation to remediate contamination which has migrated
beyond the Probable DNAPL Zone. Monitored Natural Attenuation will
remediate the ground water dissolved plume in this part of the plume to cleanup
standards listed in Table 1 of Part II of this Record of Decision. If it is
demonstrated that Monitored Natural Attenuation cannot remediate this portion of
the plume in a reasonable timeframe, the GWTS will be expanded to remediate it.
3. A Technical Impracticability waiver of the ARARs for TCE in ground water and
TCE and PCE in the subsurface soils in the probable DNAPL zone.
4. Land use restrictions in the Property boundaries to prevent unauthorized access
and provide exposure control, and ground water use restrictions throughout the
entire plume to provide exposure control and prevent interference with the
groundwater remediation process.
STATUTORY DETERMINATIONS
The remedy is protective of human health and the environment and is cost effective. EPA
believes that the selected remedy will comply with all Federal and State requirements that are
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legally applicable or relevant and appropriate to the remedial action, unless they are waived. The
selected remedy utilizes a permanent solution to the maximum extent practicable and satisfies the
statutory preference for a remedy that employs treatment that reduces toxicity, mobility, or
volume.
Because this remedy will result in hazardous substances remaining on-Site above health-
based levels, a review by EPA will be conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adequate protection of human health and
the environment.
Abraham Ferdas, Director Date
Hazardous Site Cleanup Division
Region HI
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1
TABLE OF CONTENTS
PART H - DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
IV. SCOPE AND ROLE OF THE RESPONSE ACTION 3
V. SUMMARY OF SITE CHARACTERISTICS 3
A. Topography and Ground Cover 3
B. Climate 4
C. Geology and Hydrogeology 4
D. Hydrology 5
E. Land Use 5
VI. NATURE AND EXTENT OF CONTAMINATION 5
A. Air 6
B. Surface Soil 6
C. Subsurface Soil 7
D. Ground Water 8
E. Surface Water 12
F. Sediments 12
G. Springs 12
H. DNAPL Investigation 13
Vn, SUMMARY OF SITE RISKS 14
A. Human Health Risks 14
1. Identification of COPCs 14
2. Exposure Assessment 17
3. Toxicity Assessment 17
4. Risk Characterization 18
B. Ecological Risk Assessment 19
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DESCRIPTION OF REMEDIAL ALTERNATIVES CONSIDERED FOR
THE SITE
A. Dense Non-Aqueous Phase Liquids (DNAPLs) - Effect on Remedy 21
Evaluation and Selection
B. Waiver of Specific ARARs on Technical Impracticability Grounds
("TI Waiver") 22
C. Description of Alternatives 24
IX. COMPARATIVE EVALUATION OF ALTERNATIVES 26
A. Identification of ARARs 27
X. SELECTED REMEDY AND PERFORMANCE STANDARDS 31
A. General 32
B. Ground Water Extraction System 33
C. Monitored Natural Attenuation 34
D. Institutional Controls 34
XI. STATUTORY DETERMINATIONS 35
A. Overall Protection of Human Health and the Environment 35
B. Compliance with and Attainment of Applicable or Relevant
and Appropriate Requirements 35
C. Cost Effectiveness 35
D. Utilization of Permanent Solutions and Alternative Treatment
Technologies To the Maximum Extent Practicable 36
E. Preference for Treatment as a Principal Element 36
XII. DOCUMENTATION OF CHANGES FROM PROPOSED PLAN 37
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PART m - RESPONSIVENESS SUMMARY
OVERVIEW
BACKGROUND
SITE HISTORY
COMMUNITY RELATIONS HISTORY
SUMMARY OF COMMENTORS' MAJOR ISSUES AND CONCERNS
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APPENDIX A
FIGURES
Figure 1- Probable DNAPL Zone
Figure 2 - Dissolved TCE Distribution and Ground Water Flow .Direction
Figure 3 - Site Plan/Well Location Map
Figure 4 - Monitoring and Public Water Supply Well Location map
Figure 5 - Air Sampling Location Map
Figure 6 - Surface Soil Sampling Location Map and Distribution of Detected Organic
Compounds in surface Soil Samples
Figure 7 - Soil Boring Location Map and Detected Volatile Organic Compounds in
Subsurface Soil Samples
Figure 8 - Distribution of Volatile Organic Compounds in Ground Water at the Rodale
Property and Adjacent Wells
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-S
4
Table 1 -
Table 2 -
Table 3 -
Table 4 -
Table 5 -
Table 6 -
Table 7 -
Table 8 -
Table 9 -
Table 10-
Tablell-
Table 12 -
Table 13 -
Table 14 -
APPENDIX B
TABLES
Ground Water Cleanup Standards and Basis
Comparison of Surface Soil Samples with USEPA Region III RBCs
Comparison of Subsurface Soil Samples with USEPA Region III RBCs
Comparison of On-Site ( from the Rodale Manufacturing Property and Adjacent)
Monitoring Wells with USEPA Region III RBCs/ Pre-Remedial Investigation
Sampling Event
Comparison of On-Site (On the Rodale Manufacturing Property and Adjacent)
Monitoring Wells with USEPA Region III RBCs/ Remedial Investigation
Sampling Event
Comparison of Potentially Site-Related Off-Site (from the Rodale Manufacturing
Property) Ground Water Samples from private or Public Supply Wells to USEPA
Region III RBCs/ Pre-Remedial Investigation Sampling Event
Comparison of Potentially Site-Related Off-Site (from the Rodale Manufacturing
Property) Ground Water Samples from Monitoring Wells to uSEPA Region III
RBCs / Remedial Investigation Sampling Event
Comparison of Potentially Non-Site Related Off-Site (from the Rodale
Manufacturing Property ) Ground Water Samples from private or Public Supply
Wells to USEPA Region III RBCs/ Pre-Remedial Investigation Sampling Event
Comparison of Potentially Non-Site Related Off-Site (from the Rodale
Manufacturing Property) Ground Water Samples from Monitoring Wells to
USEPA Region HI RBCs / Remedial Investigation Sampling Event
Comparison of Off-Site (from the Rodale Manufacturing Property) Spring Water
Samples with USEPA Screening Values
Comparison of Off-Site (from the Rodale Manufacturing Property) Surface Water
Samples with USEPA Screening Values
Comparison of Off-Site (from the Rodale Manufacturing Property) Sediment
Samples with USEPA Screening Values
Well Categories and Analytical Parameter Summary
Exposure Scenarios for each Medium
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Table 15- Toxicity Indices - Potential Carcinogenic Effects
Table 16- Toxicity Indices - Potential Noncarcinogenic Effects
Table 17- Pennsylvania Requirements for Surface Water Discharge
Table 18- Identification of ARARs
Table 19- PA Act 2 Residential Standards for Substances detected below 15 feet
Table 20- Summary of Risk
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RECORD OF DECISION
RODALE MANUFACTURING SITE
PART II - DECISION SUMMARY
L SITE NAME, LOCATION, AND DESCRIPTION
The "Site" encompasses the approximately 1.2 acre parcel of real property designated as
the "Rodale Superfund Site," located at the intersection of Sixth and Minor Streets, in the
Borough of Emmaus, Lehigh County, Pennsylvania, (the "Property"), as well as all areas
included within the definition of "on-site" at 40 C.F.R. Section 300.5.'
Currently the only structure on the Property is a ground-water treatment system (GWTS)
building and recovery well protective enclosures. A storm water catch basin near the southwest
comer is connected to the storm sewer along Sixth Street. The Property is bounded by a 6-foot
high chain-link security fence on the south property line, and an 8-foot high red cedar security
fence on the north, east, and west sides. The Property is accessible through locking gates on the
east and west sides of the Site.
Prior to 1993, the Property included a three-story building that occupied most of the
Property (designated as three inter-connected sections: Buildings A, B, and C) which served as a
manufacturing, warehouse, and office facility. An exterior, open-space courtyard area existed on
the south side of the facility. This courtyard area was expanded in 1989 as a result of demolition
of the southern wing of Building D. Three disposal wells (Wells 1, 2, and 3) were located in the
open area, along with several other wells and cisterns (Figure 3).
Following demolition of the buildings in 1993, the Property was graded with quarry fill
and #2A modified stone. The basement under Building A, which measured approximately 170
feet in length (north-south direction) by 50 feet in width (east-west direction), was backfilled
with clean quarry fill prior to the final grade-level application of #2A modified stone. The walls
were left in place, and the floor of the basement broken up to allow for proper drainage.
1 40 CFR Section 300.5 defines "on-site" as "the area! extent of contamination and all
suitable areas in very close proximity to the contamination necessary for implementation of the
response action." As of the date of the Remedial Investigation, groundwater sampling showed
contamination had migrated off the Property approximately 700 feet, to encompass the
monitoring wells designated as "MW 3, 4 and 5". For purposes of implementation of the
remedial action as detailed in this Record of Decision, the term "Site" includes such area! extent
of contamination, as depicted on Figure 2. The area so included may be modified as further
information becomes available.
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H. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Prior to the 1930s, the Property was occupied by the D.G. Dery Silk Corporation and
later by Amalgamated Silk Corporation. Rodale Press, a publishing and printing business,
occupied portions of the building for several years beginning in 1953. From the late 1930s until
1975, the Property was operated by Rodale Manufacturing. Rodale Manufacturing manufactured
wiring devices and electrical connectors. In 1975, the Property was sold to Bell Electric, a
wholly-owned subsidiary of Square D Company. Bell Electric manufactured similar electrical
components.
Pennsylvania Department of Environmental Protection (PADEP) files indicate that under
Rodale Manufacturing's operation of the facility, several wells were used for disposal of various
wastes. PADEP files indicate that in 1962, approximately 3,000 gallons per day (gpd) of
wastewater, including rinse water from copper and zinc plating and acid brass dipping, were
discharged to a 452-foot deep borehole (Well 1) located in the former courtyard area. Discharge
of wastes into the wells continued probably until 1967 when the electroplating room was
connected to the sanitary sewer.
Past disposal practices were first identified by Square D in March 1981, when a capped
borehole was discovered during the installation of new equipment. Long-time employees of
Rodale Manufacturing indicated that two other wells were also used for disposal purposes, and
the locations of these wells were identified. During the course of the investigation at the Site,
four additional features were found. They are: a shallow cistern; a tank possibly used for fuel oil
storage; a well apparently used for makeup cooling water; and a well which is believed to have
been used for septic disposal.
In 1984, in coordination with PADEP, Square D commenced pumping contaminated
ground water from one of the disposal wells. The Volatile Organic Compounds (VOCs)
contamination in the ground water was treated by an air-stripping tower. This air stripper was
operated until 1989. In January 1989, a Site inspection was conducted at the Site on behalf of
the USEPA. On July 29, 1991, the Site was proposed for placement on the National Priorities
List (NPL) and then listed on October 4, 1991. An Administrative Order on Consent (AOC) to
conduct a Remedial Investigation and Feasibility Study (RI/FS) was executed between the
USEPA and Square D and became effective on September 21,1992.
As required by the RI/FS AOC, a Well Survey Investigation was conducted by Square D.
This investigation included, among other tasks, sampling on-site wells, off-site monitoring wells,
the Borough of Emmaus public supply wells, and several private wells, as well as sampling of
local surface water bodies (See Figure 3). The results of this investigation were included in a
September 1994 report. Based on the findings of the Well Survey Investigation, a separate AOC
for a Removal Response Action for a Site ground-water treatment system (GWTS) was executed
between the USEPA and Square D, effective September 30, 1994. The purpose of the GWTS
was to recover and treat contaminated ground water to limit further migration of contamination.
The construction of the GWTS was completed in August 1996. Remedial investigation activities
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were conducted concurrently with the construction of the GWTS. These activities included
ambient air sampling; soil sampling; sampling of ground water both on and off the Rodale
Manufacturing property; hydrologic mapping; pumping tests, and installation of eight
monitoring cluster wells beyond the boundaries of the Rodale Manufacturing property. Well
clusters consist of one shallow and one deep well except for one well cluster which consists of a
shallow, intermediate and a deep well (Figure 3). In addition to these activities, the remedial
investigation included data collection to evaluate the presence of Dense Non- Aqueous Phase
Liquids (DNAPLs) at the Site. A more detailed description of the Well Survey and Remedial
Investigation activities is included in Section VI below.
DDL HIGHLIGHTS OF COMMUNITY PARTICIPATION
Documents which EPA used to develop, evaluate, and select a remedy for the Site have
been maintained at the Emmaus Public Library, 11 East Main Street, Emmaus, PA and at the
EPA Region III Office, Philadelphia, PA.
The Proposed Plan was released to the public on June 20, 1999. The notice of
availability for the RI/FS and Proposed Plan was published in the Morning Call on June 20,
1999. A 30-day public comment period began on June 20, 1999 and concluded on July 20, 1999.
A public meeting was held during the public comment period on June 23, 1999. At the
meeting, EPA presented a summary of the alternatives in the Proposed Plan and EPA's preferred
remedy. EPA answered questions about the Site and the remedial alternatives. Approximately 8
people attended the meeting, including residents from the impacted area and potentially
responsible parties. No written comments were received during the public comment period. A
summary of the questions and EPA's responses in the public meeting are contained in Part III of
this document.
IV. SCOPE AND ROLE OF RESPONSE ACTIONS
This final selected remedy addresses the threats posed by the release of hazardous
substances at the Site. The primary objective of the remedy described in this ROD is to reduce
or eliminate the potential for human exposure to contaminated soil and ground water at the Site.
The selected remedy outlined in Section X of this ROD will comprehensively address the risks
posed by the release or threat of release of hazardous substances from the Site.
V. SUMMARY OF SITE CHARACTERISTICS
A. Topography and Ground Cover
Topography in the Borough of Emmaus varies from between 350 feet and 500 feet above
mean sea level (msl) (USGS, 1992). The most prominent topographic feature in the vicinity of
the Site is South Mountain to the south and southeast. Gentle sloping hills and stream valleys
are found to the west, north, and northwest. The peaks of South Mountain extend as high as
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1,000 feet above msl. Topographic features in the vicinity of the Site include: the Lehigh River;
Leibert, Little Lehigh, Swabia, and Cedar Creeks; Chestnut Hill; Lock Ridge; and Bauer Rock.
Elevations across the 1.2-acre Site range from 460 to 470 feet msl, with the lowest point located
within the central portion of the northern half of the Site.
B. Climate
Temperatures in the area of the Site are generally moderate, with mean monthly
temperatures ranging between 74° F in July to 27° F in January. Maximum temperatures during
most years are not excessively high and temperatures above 100°F are seldom recorded.
However, the average humidity in the area can be relatively high. Minimum temperatures during
December, January, and February are usually below freezing, but temperatures below 0° F are
seldom recorded (Wood, 1996).
Annual precipitation in the Site vicinity averages almost 44 inches per year, with July having the
highest monthly average (4.35 inches) and January having the lowest (0.13 inches) (Wood,
1996).
C. Geology and Hydrogeology
The regional geology in the area of the Site is characterized by the crystalline rock units
forming South Mountain to the east and south of the Site, and the Cambrian and Ordovician
sedimentary units of the Little Lehigh Creek Basin extending north and west of South Mountain.
The first bedrock unit encountered at the Site consists of carbonate rocks of the Leithsville
Formation. Deep sections of weathered bedrock (saprolite) occur above the competent bedrock
of the carbonate units of the Little Lehigh Creek Basin, overlain in some areas in the vicinity of
the Site by glacial drift deposits, and generally capped with a soil loam horizon. The saprolite
varies in thickness from 50 feet to more than 250 feet in the Site vicinity.
Abundant evidence and literature describes the area as extensively faulted. Detailed
hydrogeological characterization of the overburden and bedrock units at the Site indicate that
these units are highly heterogeneous and complex at a small scale. The information obtained
during the investigations conducted at the Site suggest that the bedrock is highly fractured and
faulted in the vicinity of the Site, with the predominant fracture orientations aligned generally in
a north-northeast/south-southwest directions, and faults trending northwest-southeast. A linear
ground water depression has been consistently observed for both the shallow and deeper bedrock
extending from an area immediately west of the Site towards the north-northwest. This feature
appears to act as a preferential pathway for the migration of ground water and may be related to
the northwest trending dissolution enhanced fault feature.
A bedrock aquifer underlies the Site and is recharged by local precipitation. Ground
water beneath the Site flows to the north-northeast, in the direction of the Little Lehigh Creek.
Ground water at the Site flows through extensive joints and fractures, and in the case of the
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carbonates, the solution enhancement of these secondary openings. The depth to ground water at
the Site and in the immediate Site vicinity has been observed to range from 105 to 115 feet
below ground surface (bgs).
Bedrock ground water provides the Borough of Emmaus and the Little Lehigh Creek
Basin with approximately 60% of its potable water supply. The Liethsville Formation and the
Allentown Dolomite are locally the most important water-bearing units . Four of the six public
water supply wells for the Borough of Emmaus are located in the Liethsville Formation. The
other two are located in the Allentown Dolomite and the Hardyston Quartzite.
D. Hydrology
Little Lehigh Creek is the primary drainage feature in the area. Little Lehigh Creek is
located in northwest Borough of Emmaus (about 1.5 miles northwest of the Site) and flows
generally from southwest to northeast towards the City of Allentown where it discharges to the
Lehigh River. Leibert Creek is a tributary to Little Lehigh Creek approximately one mile west
of the Site. Leibert Creek flows generally from south to north and discharges to Little Lehigh
Creek northwest of the Borough of Emmaus.
Based on the topography of the Site and the fact that the entire Property surface is
covered with crushed stone, nearly 100% of the precipitation to the Site would be expected to
infiltrate into the subsurface during most rain events. No significant runoff would be expected.
E. Land Use
The Site includes approximately 1.2 acre of land at Sixth and Minor Streets in the
Borough of Emmaus, Lehigh County, Pennsylvania, approximately five miles south of the City
of Allentown. The Property land use is industrial and the land use in the area comprising and
surrounding the Site includes residential as well as industrial and commercial facilities.
VI. NATURE AND EXTENT OF CONTAMINATION
This section discusses the nature and extent of contamination in the air, soil (surface and
subsurface), ground water, surface water, sediment, and springs at and around the Site. The data
included for discussion were generated during the Well Survey Investigation, during the
response action for the ground water treatment system (GWTS), and during the Remedial
Investigation (RI).
The Well Survey Investigation was conducted at the Site from January to October 1993
to characterize water and sediment quality in and around the Site. This investigation also
included, sampling of on-site wells (both monitoring and disposal wells), the Borough of
Emmaus public supply wells, and several private wells, as well as sampling of local surface
water bodies.
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The response action for the GWTS was completed in August 1996. This activity
included, rehabilitation of an on-site disposal well (Well 7), installation of a ground water
recovery well (RW-3), ground water sampling of Well 7 and RW-3, and collection of subsurface
soil samples.
The RI activities were conducted concurrently with the construction of the GWTS.
These activities included, ambient air sampling, soil sampling, sampling of ground water both on
and off the Rodale Manufacturing property, hydrologic mapping, performance of a pump test,
and the installation of eight monitoring well clusters beyond the boundaries of the Rodale
Manufacturing property. In addition to these activities, the RI included the collection of data to
evaluate the presence of DNAPLs at the Site.
A. Air
Air sampling was conducted during the RI to assess air quality at the Site. Samples were
collected during two separate sampling events in the fall of 1995 from two background locations
(AS-1 and AS-2), two areas suspected to be source areas based on historical Site information
(AS-3 and AS-4), and two downwind locations (AS-5 and AS-6) and analyzed for Volatile
Organic Compounds (VOCs) (Figure 5). The sampling results revealed that toluene was the only
VOC detected. Toluene was detected in all six air samples during the second sampling event at
low concentrations ranging up to 3.7 parts per billion(ppb). The detected concentrations of
toluene in samples collected upwind, mid-site, and downwind were consistent, indicating the
source of toluene detected was located upwind of the Site and is not Site-related.
B. Surface Soil
Surface soil samples were collected at the Site during the RI to evaluate the extent of
shallow soil contamination on the Property (Figure 6). Analytical results for VOCs, metals, and
pesticides/PCBs are summarized below.
VOCs
TCE was detected at low levels in seven surface soil samples, ranging from 2 ppb to 63
ppb. Additionally, total 1,2-DCE and PCE were detected in one sample at 8 ppb and 6 ppb,
respectively. Figure 7 shows the sampling locations and distribution of VOCs detected.
Pesticides/PCBs
Detectable levels of heptachlor (1.5 ppb), endosulfan I (1.7 ppb), 4,4'-DDE (2.3 ppb),
Aroclor-1242 (28 ppb), Aroclor-1248 (30 ppb), and Aroclor-1254 (22 ppb) were observed in soil
collected from one sample location. Another sample showed 4,4'-DDE at a concentration of 1.9
ppb.
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Inorganics
All concentrations of dete'cted inorganic constituents were low and no significantly
elevated values were present in the soil samples analyzed.
C. Subsurface Soil
Subsurface soil samples were collected during the GWTS investigation and the RI.
Although part of the RI investigation, a total of 19 soil borings were completed in late summer
and early fall of 1994 during the GWTS investigation. The purpose of conducting this soil
sampling at this time was to characterize soil quality in selected portions of the Site identified as
potential source areas, and to help in selecting the location of the GWTS building. Seven
additional soil borings were completed during the RI in March 1996 to supplement the soil
characterization data generated during the GWTS investigation (Figure 7). Summaries of the
analytical results for VOCs, Semi-Volatile Organic Compounds (SVOCs) and inorganics are
provided respectively, as follows.
VOCs
Detected levels of VOCs were low in most borings, except one located near former
disposal Well 2. Samples in this location displayed the highest TCE concentrations (up to
1,400,000 ppb). Elevated TCE concentrations were detected in this location at depths greater
than 40 feet, corresponding to the base of the cased portion of Well 2, with concentrations
decreasing with depth below 67 feet. Elevated TCE concentrations were also detected at other
boring locations at various intervals at concentrations up to 8,300 ppb. PCE was detected at
110,000 ppb in the same sample location near Well 2 in the 65- to 67-foot interval.
The VOC detections are situated in the immediate vicinity of disposal Well 2. The
depths at which the elevated concentrations are found correspond with the construction of this
well. It is most likely that historical disposal practices account for the VOC detected in soil
found in this area at these depths.
Other VOCS detected in one or more soil samples at low concentrations include 1,1,1-
TCA (1 ppb), 1,1,2-TCA (2 to 51 ppb), 1,2-DCA (4 ppb), total 1,2-DCE (1 to 630 ppb), 2-
butanone (6 to 140 ppb), 2-hexanone (3 ppb), 4-methyl-2-pentanone (12 to 18 ppb), carbon
disulfide (2 to 6 ppb), ethylbenzene (11 to 710 ppb), toluene (2 to 880 ppb), and total xylenes (3
to 5,700 ppb).
Semi-Volatile Organic Compounds (SVOCs)
Several SVOCs were detected infrequently in the subsurface soil samples collected at the
Site, as indicted on Table 3-6. The following SVOCs were detected in at least one sample: 2-
methylnaphthalene (670 to 11,000 ppb); bis(2-ethylhexyl)phthalate (84 to 140 ppb); di-n-octyl-
phthalate (78 to 110 ppb); fluorene (83 to 640 ppb);-naphthalene (1,200 to 16,000 ppb), and
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phenanthrene (250 to 700 ppb).
Inorganics
Inorganic concentrations were low and no significantly elevated or anomalous values
were present in the soil samples analyzed.
D. Ground Water
Ground water samples were collected as part of the Well Survey Investigation, the
removal response action, and the RI. The Well Survey Investigation included sampling of on-
site wells, six Borough of Emmaus Public supply wells, and several private wells. Two
additional on-site wells were sampled during the GWTS response action. The RI included
sampling of the existing on-site wells and 16 newly installed off-site wells.
On-Property and Adjacent Wells
Ten on-site wells (Wells 1 through 6 and MW-1 through MW-4) were sampled and
analyzed for TCL VOCs, SVOCs, PCBs, and Metals and cyanide (total and dissolved) during the
Well Survey Investigation. Two additional wells, RW-3 and Well 7, were sampled during the
GWTS response action during the fall of 1994 and analyzed for TCL VOCs, SVOCs (Well 7
only), and metals and cyanide (total and dissolved). During the RI, nine previously installed
wells (MW-1 through MW-3, RW-3, Well 1 through Well 4, and Well 6) were sampled and
analyzed for TCL VOCs in January 1997 and TCL SVOCs and six Metals (arsenic, beryllium,
copper, chromium, lead, and manganese) and cyanide (total and dissolved) in October 1996.
On-site well MW-4 was not sampled during the RI due to its well-head configuration and low
productivity. Summaries of the analytical results obtained during the investigations for VOCs,
SVOCs, and metals/cyanide are presented below respectively. PCBs were not detected in any
ground water samples collected from the on-site wells during the Well Survey Investigation.
VOCs
Several VOCs were detected in the ground water samples collected from the on-site wells
during the Well Survey Investigation and the GWTS response action (Figure 9). Six primary
VOCs were identified from the sampling results, including TCE, 1,2-DCE, vinyl chloride, PCE,
1,1-DCE, and 1,1,2-TCA. TCE was detected in all 12 on-site wells at concentrations ranging
from 21 to 400,000 ppb. The VOC 1,2-DCE was detected in nine wells with concentrations
ranging from 68 to 43,000 ppb. Vinyl chloride was detected in seven wells at concentrations
ranging from 71 to 3,200 ppb. PCE was detected in several injection wells at concentrations
ranging from 10 to 3,900 ppb. The VOCs 1,1-DCE and 1,1,2-TCA were detected less frequently
at concentrations ranging up to 27 ppb and 350 ppb, respectively. Other VOCS detected in one
or more wells at elevated levels include 2-butanone (13 ppb), acetone (2 to 37 ppb), benzene (13
ppb), ethylbenzene (9 to 540 ppb), toluene (1 to 530 ppb), and total xylenes (11 to 4,600 ppb).
8
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1
VOCs were detected in each of the samples collected from the nine on-site wells sampled
during the RI. TCE was detected in all on-site wells at concentrations ranging from 20 to
570,000 ppb. Other VOCs detected in one or more of the well samples include total 1,2-DCE
(190 to 23,000 ppb); vinyl chloride (680 to 1,300 ppb); PCE (4 to 5 ppb); chloromethane (2,900
ppb); toluene (15 to 220 ppb); ethylbenzene (21 ppb); and total xylenes (100 ppb).
SVOCs
Several SVOCs were detected in several on-site wells at concentrations up to 6,000 ppb
during the Well Survey Investigation and the GWTS response action. Although the greatest
number of SVOCs were found in Well 5 (shallow cistern), the concentrations of the SVOCs
detected ranged from 1 to 84 ppb. Due to the shallow depth of the cistern (8 feet), the SVOCs
are likely attributable to localized soil contamination. SVOCs were not found above
quantification limits at wells MW-1 through MW-4.
SVOCs were detected in ground water samples collected from four of the previously
installed monitoring wells during the RI. The following SVOCs were detected, naphthalene (17
to 66 ppb); 2-methylnaphthalene (5 ppb and 14 ppb); phenol (9 ppb and 16 ppb); 4-methylphenol
(9 ppb and 58 ppb); 2,3,5-trichlorophenol (6 ppb and 8 ppb); pentachlorophenol (2 ppb and 5
ppb); phenanthrene (2 ppb); bis(2-ethylhexyl)phthalate (23 ppb); 2-methyl phenol (3 ppb); and
1,4-dichlorobenzene (1 ppb).
Inorganics
Samples were collected during the Well Survey Investigation and GWTS response action
and analyzed for total and dissolved inorganics. Elevated total concentrations of beryllium,
cadmium, lead, nickel, and cyanide were detected in some on-site wells. Total beryllium was
detected in five well samples at concentrations ranging from 0.72 to 6 ppb. Total cadmium was
detected in eight well samples at concentrations ranging from 2.6 to 35.8 ppb. Total lead was
detected in several samples at concentrations ranging.from 2.3 to 555 ppb. Total nickel was
detected in several wells at concentrations ranging from 5.1 ppb to 115 ppb. Total cyanide was
detected in several wells at concentrations ranging from 2.8 to 402 ppb.
During the RI, both total and dissolved ground water samples were analyzed for arsenic,
beryllium, chromium, copper, iron, lead, manganese, and cyanide. Manganese was detected in
samples from all nine previously installed wells for both total manganese (60.7 to 4,120 ppb) and
dissolved manganese (14 to 3,100 ppb). Total iron was detected in samples from all nine wells
(291 to 49,800 ppb), and dissolved iron was detected in samples from seven wells (120 to 21,300
ppb). Total chromium was detected in samples from eight wells (except Well 4) at
concentrations ranging from 3.4 ppb to 129 ppb. Dissolved chromium was not detected in any of
the samples collected. Total copper was detected in samples from six wells at concentrations
ranging from 10.5 ppb to 238 ppb. Dissolved copper was not detected hi any of the samples
collected. Total lead was detected in samples from six wells at concentrations ranging from 2.8
ppb to 70.6 ppb. No dissolved lead data is available for any of the samples collected due to the
AR3G0932
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rejection of these data during data validation. Total arsenic was detected in two samples (5.4
ppb and 5.7 ppb), and dissolved arsenic was detected in one sample (7.2 ppb). Total cyanide
was detected in samples from three wells (10.3 to 62.2 ppb). Dissolved cyanide was detected in
one sample (26.5 ppb).
Off-Property Upgradient/Sidegradicnt Wells
During the RI, seven off-Property upgradient/sidegradient monitoring wells (MW-6,
MW-7S, MW-7D, MW-8S, MW-8D, MW-12S, and MW-12D) were installed (Figure 4).
Samples were collected from the wells and analyzed for TCL VOCs.
Chloromethane and TCE were detected in one sample at 1 ppb and 0.9 ppb, respectively.
Acetone was detected in one sample at a concentration of 6 ppb. No other VOCs were detected
in any of the well samples.
Off-Property Downgradient Wells
During the RI, nine off-Property downgradient monitoring wells (MW-5S, MW-5D,
MW-9S, MW-9D, MW-10S, MW-10I, MW-10D, MW-1 IS, and MW-11D) were installed
(Figure 4). Samples were collected from the wells and analyzed for TCL VOCs.
Based on laboratory results, detected levels of VOCs were low in most samples, except
notably MW-9D. TCE was detected in six wells, with concentrations ranging from 2 to 1,000
ppb (detected in MW-9D). Contaminants detected in MW-9D and not in any other downgradient
well included 1,1-DCA (4 ppb), 1,1-DCE (3 ppb), and PCE (51 ppb). Acetone (5 to 100 ppb),
carbon tetrachloride (2 to 130 ppb), chloroform (2 to 190 ppb), cis-l,2-DCE (2 to 38 ppb), and
toluene (0.6 ppb) were also detected in a few of the wells.
Borough of Emmaus Public Supply Wells
During the Well Survey Investigation, six public supply wells (PSW-1 through PSW-4,
PSW-6, and PSW-7) for the Borough of Emmaus were sampled and analyzed for VOCs, SVOCs,
PCBs, and Metals. PCBs were not detected in any ground water samples collected from the
Borough public supply wells. Results of the sampling are summarized below.
VOCs
Results of the sampling showed TCE in five Borough supply wells, with concentrations
ranging from 4.4 ppb to 14 ppb. PCE was detected in two Borough supply wells at 1.4 ppb to 21
ppb. Other VOCs detected at levels less than 4 ppb included 1,1,1-TCA, carbon tetrachloride,
cis-l,2-DCE, ethylbenzene, toluene, and total xylenes.
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1
SVOCs
The only SVOC detected in any of the ground water samples collected from the supply
wells was bis(2-ethylhexyl)phthalate, which was detected at 4 ppb in sample PSW-4, however,
this compound was also detected in the associated method blank.
Inorganics
The ground water data generated in connection with the Well Survey Investigation
appears to have identified an area-wide issue with regard to sodium in ground water.
Concentrations of both total and dissolved sodium were observed to range from 4,620 ppb to
more than 18,000 ppb. Total barium was also detected in one sample at an elevated
concentration of 23,100 ppb. However, a duplicate sample collected at the same time indicated
that total barium was detected at a concentration of 27.9 ppb.
OfT-Propertv Private WcHs
Thirty-one private wells were sampled and analyzed for VOCs and Metals, and the
results are summarized below.
VOCs
Only two VOCs were detected at elevated levels in two private wells. TCE was detected
in PW-LM20 at a concentration of 5.2 ppb and PCE was detected in PW-SA08 at a concentration
of 5.3 ppb.
Inorganics
The analytical results for total and dissolved metals and cyanide in private wells are
summarized below.
Total antimony was detected at in several residential wells at concentrations ranging up
to 21.8 ppb. Ground water samples of the residential wells analyzed for dissolved antimony
revealed no detectable concentrations.
Thallium was detected in samples collected from some residential wells (both total and
dissolved) at elevated levels at concentrations ranging up to 4 ppb of total thallium and 4.8 ppb
of dissolved thallium.
Manganese (total and dissolved) was detected in a few samples at concentrations ranging
up to 281 ppb and 269 ppb, respectively.
Total lead was detected in several samples at concentrations ranging up to 231 ppb.
Dissolved lead was detected in samples at concentrations ranging up to 10.1 ppb.
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Total iron was detected in a few ground water samples at levels ranging up to 775 ppb.
E. Surface Water
Thirteen surface water samples (SW-1 through SW-3, SW-5 through SW-12, SW-15, and
SW-16) were collected during the Weil Survey Investigation and analyzed for VOCs and Metals.
The samples were collected from the primary water courses in the study area at locations both
upgradient, downgradient, and near the confluence of streams. A summary of the analytical
results for VOCs and metals is provided below.
Results of the sampling showed VOCs, including carbon disulfide, cis-1,2-
dichloroethene, benzene, TCE, toluene, and PCE, in three surface water samples at low
concentrations (less than or equal to 1 ppb). Acetone was detected in one sample at a
concentration of 10 ppb. TAL total and dissolved metals and cyanide in surface water samples
indicted that no samples contained elevated metal concentrations.
F. Sediment
Fourteen stream sediment samples were collected during the Well Survey Investigation
and analyzed for VOCs and Metals. The sediment samples were collected from the primary
water courses in the study area at locations both upgradient, downgradient, and near the
confluence of streams. A summary of the analytical results for VOCs and metals is provided
below.
Results of the sampling indicated the presence of acetone, methylene chloride and 2-
butanone in several samples at low concentrations, however, these compounds were also
detected in the associated method blanks. Toluene was detected in a duplicate sample, SD-9, at
8 ppb. Results for metals and cyanide in stream sediment samples indicated low concentrations
(0.76 ppm to 10.5 ppm) of arsenic in all samples. Chromium, lead, nickel, and zinc
concentrations in one sample were high relative to the other sample results.
G. Springs
Four spring samples were collected during the Well Survey Investigation from four
springs located in the vicinity of the Site. All the samples collected were analyzed for metals;
only two samples were analyzed for VOCs. A summary of the analytical results for VOCs and
metals is provided below.
Results of sample SP-03 found PCE and TCE at 8.7 ppb and 14 ppb, respectively. The
VOCs 1,1,1-TCA, benzene, carbon tetrachloride, and cis-l,2-dichloroethene were detected in
one spring at levels less than 1 ppb.
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H. DNAPL Investigation
An assessment of the presence of Dense Nonaqueous Phase Liquids (DNAPL) was
conducted as part of the RI. DNAPLs, denser than water, are particularly difficult to locate and
remove from the subsurface; their ability to sink through the water table and penetrate deeper
portions of aquifers is one of the properties that makes them very difficult to remediate. See
Guidance for Evaluating the Technical Impracticability of Ground-Water Restoration OSWER
Directive 9234.2-25, 1993 (TI Guidance).
The evaluation was performed in accordance with the TI Guidance and EPA's DNAPL
Site Characterization Fact Sheet (1994)(DNAPL Fact Sheet) and included consideration of
historical Site use (i.e., industry type, historical process and waste disposal practices, potential
for DNAPL-related chemical usage), and Site characterization-data (including ground water and
soil quality data, physical observations of DNAPL, geologic structure, hydrogeological
information, and structural geology).
As part of the assessment, field screening for DNAPLs was conducted during the RI soil
boring activity.
Results of the DNAPL evaluation indicate the presence of DNAPLs in the subsurface soil
and aquifer at the Site, based on the following:
• Information regarding historical operations and waste disposal practices at the Site
suggest the use and disposal of DNAPL-related chemicals (specifically, TCE) into
several on-site bedrock wells.
• Observations made during a downhole video of Well 3 indicated an accumulation of dense
black material at the bottom of the well.
• Concentration of DNAPL chemicals (e.g., TCE) in groundwater at greater than 1% of the
single-component solubility is a strong indicator of the presence of DNAPLs. See
DNAPL Fact Sheet. At the Site, dissolved TCE concentrations were observed up to
44.5% of TCE's single-component solubility in six wells including RW-3, Well 2, Well 3,
Well 4, MW-4, and MW-1, indicating the presence of DNAPL in the immediate vicinity
of these wells.
• Calculations of pore-water concentrations in soil samples obtained at the Site indicates the
presence of DNAPL in the overburden soil in the immediate vicinity of on-site soil boring
SB-7 (adjacent to Well 2).
• Information regarding the initial cleanup of selected disposal wells following their
discovery by Square D included analytical data indicating the presence of materials
containing high concentrations of TCE
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Based on the above factors it is likely that DNAPLs exist at the Site.
VO. SUMMARY OF SITE RISKS
Following the RI, analyses were conducted to estimate the human health and
environmental hazards that could result if contamination at the Site is not cleaned up. These
analyses are commonly referred to as risk assessments, and identify existing and future risks that
could occur if conditions at the Site do not change. The Baseline Human Health Risk
Assessment(BLRA) evaluated human health risks and the Ecological Risk Assessment (ERA)
evaluated environmental impacts from the Site.
A. Human Health Risks
The BLRA assesses the toxicity, or degree of hazard, posed by contaminants related to the
Site, and involves describing the routes by which humans could come into contact with these
substances. Separate calculations are made for those substances that can cause cancer
(carcinogenic) and for those that can cause non-carcinogenic, but adverse, health effects.
The primary objective of the risk assessment conducted was to assess the health risks to
individuals who may have current and future exposure to contamination present at and migrating
from the Site under existing Site conditions. The risk assessment is comprised of the following
components:
• Identification of Chemicals of Potential Concern (COPCs) - identify and characterize the
distribution of COPCs found at or near the Site.
• Exposure Assessment- identify potential pathways of human exposure, and estimate the
magnitude, frequency, and duration of these exposures.
• Toxicity Assessment- assess the potential adverse effects of the COPCs.
• Risk Characterization -characterize the potential health risks associated with exposure to
Site-related contamination.
Each of these steps is explained further below:
1. Identification of COPCs
The identification of COPCs includes data collection, data evaluation, and data screening
steps. The data collection and evaluation steps involve gathering and reviewing the available Site
data and developing a set of data that is of acceptable quality for risk assessment. This data set is
then further screened to determine those chemicals and media of potential concern. The data used
for the quantitative risk analysis were all validated prior to use in the risk assessment.
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Soil
Soil data collected by Geo Environmental Consultants, Inc. between August and September
1994 and in March 1996 was used for the risk analysis. A total of 26 borings were completed in
these two sampling activities. Samples were taken at different intervals from 0 to up to 92 feet
below ground surface (bgs). Results from samples taken from 0 to 2 feet bgs were considered
surface samples in the risk analysis. Samples from 2 feet bgs and below were considered
subsurface samples. However, a risk analysis was conducted only for surface samples, 0 to 2
feet; and for subsurface samples taken up to 15 feet.
Ground water
Ground water sampling was conducted during the Well Survey Investigation and during
the RI. The Well Survey Investigation ground water sampling included private wells, on-site
disposal and monitoring wells, and six Borough of Emmaus Public Supply wells. The RI
sampling included on-site disposal and monitoring wells, and the new monitoring wells installed
beyond the Rodale Manufacturing property boundaries. The risk analysis included evaluation of
the data collected during these two sampling events.
Springy
The data used in the risk analysis for springs was collected from four springs along the
Little Lehigh Creek during the Well Survey Investigation.
Surface and Sediments
The risk analysis included the evaluation of the data collected during the Well Survey
Investigation for surface and sediment samples which were collected from the Little Lehigh
Creek, Leibert Run, and the unnamed tributary.
Selection of Chemicals of Potential Concern
The COPC selection process was conservative, to ensure selection of the most
constituents. Selection of COPCs was based on the criteria presented in EPA Region III
guidelines. The maximum concentration of each detected constituent in each media was
compared to the following Health-Based Screening Level (HBSL) criteria developed by EPA to
select the COPCs. If the maximum concentration of a constituent exceeded each of the criteria,
the constituent was selected as a COPC.
• Soil- April 1998 USEPA Region ffl Risk-Based Concentrations (RBCs)
for residential and industrial exposure;
• Ground Water April 1998 USEPA Region III RBCs for residential tap water;
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• Surface Water - Ten times (1 OX) the April 1998 Region III residential tap water
RBCs;and
• Sediment - 10X the April 1998 USEPA Region III residential soil ingestion
RBCs.
The surface water and the sediment criteria are 10X higher because surface water and
sediment exposure is expected to be at least ten times less than ground water and soil.
Chemicals of Potential Concern
Tables 2 through 12 identify the chemicals that were selected as COPCs for each media
based on the above screening methodology.
In the ground water risk analyses, the wells sampled were divided into three categories:
on-site monitoring wells; off-site potentially site-related wells, which include public and private
supply wells, monitoring wells, and springs; and off-site non-Site related wells, which include
public and private supply wells and monitoring wells. It is important to note that on-site wells,
within the context of this categorization of wells, means wells on and adjacent to the Rodale
Manufacturing Property. Off-site wells are wells located up, side and down gradient from the
Rodale Manufacturing Property. The off-site potentially site-related wells were placed in this
category because they were located within an arc downgradient of the Site such that constituents
entering the ground water at the Site could potentially be transported to and be intercepted by
each of these wells. The off-site potentially non-site related were located in this category because
their location was either upgradient or sidegradient of the Site at a distance which is not
considered to be within an area potentially impacted by the Site. Although potentially non-Site
related, a risk analysis was also conducted for the off-site potentially non-site related wells. This
approach was developed for the risk assessment based on current data available for the Site.
However, due to the likely presence of DNAPLs at the Site, and since DNAPLs are not governed
by flow direction, the breakdown of wells may need to be modified if further information
collected in the future shows that contamination from the Site may be impacting any of the wells
located in the potentially non-site related category. Table 13 includes the wells for each category.
The risk analysis for ground water samples collected in wells on the Rodale
Manufacturing property boundaries includes only those constituents from the RI sampling that
were present at concentrations greater than the HBSLs. PCOCs identified in the Well Survey
Investigation sampling activity but either not detected or detected at concentrations less than
HBSLs in the more recent RI sampling, were not included in the risk analysis but are considered
PCOCs and will be included in future ground water sampling to ensure their continued absence or
presence at concentrations less than HBSLs.
An evaluation of background concentrations of inorganic constituents in soil, ground
water, surface water, and sediment was not included in the risk assessment. Therefore, some of
16
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1
the inorganics identified as PCOCs may not be Site-related.
A detailed evaluation of all chemicals exceeding risk screening criteria is presented in the
BLRA which can be found in the Site Administrative Record.
2. Exposure Assessment
An exposure assessment involves three basic steps: I) identifying the potentially exposed
populations, both current and future; 2) determining the pathways by which these populations
could be exposed; and 3) quantifying the exposure. Under current Site conditions, the BLRA
identified potential populations as having the potential for exposure to Site-related contaminants
either currently and/or in the future.
The Site land use is industrial and the area surrounding the Site includes residential as
well as industrial and commercial facilities. The Site is located within an area which is currently
zoned as Residential-High Density & Office with an adjacent area immediately south of Furnance
Street zoned as Residential-Low Density. A light industrial facility is located across Sixth Street
to the west of the Site and a railroad right-of-way border the Site immediately to the south, but
most of the property within the neighborhood surrounding the Site is used for residential housing.
Residential populations are present to the north and east of the Site.
The future land use for the Site and surrounding area is expected to be similar to the
current land use. However, the Site could possibly be converted to a residential area in the future.
Also, construction activities may take place at the Site.
Table 14 summarizes the exposure scenarios considered in the risk assessment.
3. Toxicity Assessment
The purpose of the toxicity assessment is to weigh available evidence regarding the
potential for particular contaminants to cause adverse effects in exposed individuals. Where
possible, the assessment provides a quantitative estimate of the relationship between the extent of
exposure to a contaminant and the increased likelihood and/or severity of adverse effects.
A toxicity assessment for contaminants found at a Superfund site is generally
accomplished in two steps: 1) hazard identification; and 2) dose-response assessment. Hazard
identification is the process of determining whether exposure to an agent can cause an increase in
the incidence of a particular adverse health effect (e.g., cancer or birth defects) and whether the
adverse health effect is likely to occur in humans. It involves characterizing the nature and
strength of the evidence of causation.
Dose-response evaluation is the process of quantitatively evaluating the toxicity
information and characterizing the relationship between the dose of the contaminant administered
or received and the incidence of adverse health effects in the administered population. From this
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quantitative dose-response relationship, toxicity values (e.g., reference doses and slope factors)
are derived that can be used to estimate the incidence or potential for adverse effects as a function
of human exposure to the agent. These toxicity values are used in the risk characterization step to
estimate the likelihood of adverse effects occurring in humans at different exposure levels.
For the purpose of the risk assessment, contaminants were classified into two groups:
potential carcinogens and noncarcinogens. The risks posed by these two types of compounds are
assessed differently because noncarcinogens generally exhibit a threshold dose below which no
adverse effects occur, while no such threshold can be proven to exist for carcinogens. As used
here, the term carcinogen means any chemical for which there is sufficient evidence that exposure
may result in continuing uncontrolled cell division (cancer) in humans and/or animals.
Conversely, the term noncarcinogen means any chemical for which the carcinogenic evidence is
negative or insufficient.
Slope factors have been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic
contaminants of concern. Slope factors, which are expressed in units of (mg/kg-day)-l are
multiplied by the estimated intake of a potential carcinogen, in ppm/day, to provide an upper-
bound estimate of the excess lifetime cancer risk associated with exposure at that intake level.
The term "upper-bound" reflects the conservative estimate of the risks calculated from the slope
factor. Use of this approach make underestimation of the actual cancer risk highly unlikely.
Slope factors are derived from the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty factors have been applied to
account for the use of animal data to predict effects on humans. Slope factors used in the BLRA
are presented in Table 15.
Reference doses (RfDs) have been developed by EPA for indicating the potential for
adverse health effects from exposure to contaminants of concern exhibiting noncarcinogenic
effects. RfDs, which are expressed in units of mg/kg-day, are estimates of acceptable lifetime
daily exposure levels for humans, including sensitive individuals. Estimated intakes of chemicals
from environmental media (e.g. the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur. Reference doses used in the BLRA are
presented in Table 16.
4. Risk Characterization
The risk characterization process integrates the toxicity and exposure assessments into a
quantitative expression of risk. For carcinogens, the exposure point concentrations and exposure
factors discussed earlier are mathematically combined to generate a chronic daily intake value
that is averaged over a lifetime (i.e., 70 years). This intake value is then multiplied by the toxicity
value for the contaminant (i.e., the slope factor) to generate the incremental probability of an
individual developing cancer over a lifetime as a result of exposure to the contaminant. The
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National Oil and Hazardous Substances Pollution Contingency Plan (NCP) established acceptable
levels of carcinogenic risk for Superfund sites ranging from one excess cancer case per 10,000
people exposed to one excess cancer case per one million people exposed. This translates to a
risk range of between one in 10,000 and one in one million additional cancer cases. Expressed as
scientific notation, this risk range is between l.OE-04 and l.OE-06. Remedial action is warranted
at a site when the calculated cancer risk level exceeds l.OE-04. However, since EPA's clean up
goal is generally to reduce the risk to l.OE-06 or less, EPA also may take action where the risk is
within the range between 1 .OE-04 and 1 .OE-06.
The potential for noncarcinogenic effects is evaluated by comparing an exposure level
over a specified time period (i.e., the chronic daily intake) with the toxicity of the contaminant for
a similar time period (i.e., the reference dose). The ratio of exposure to toxicity is called a hazard
quotient. A Hazard Index (HI) is generated by adding the appropriate hazard quotients for
contaminants to which a given population may reasonably be exposed. The NCP also states that
sites should not pose a health threat due to a non-carcinogenic, but otherwise hazardous,
chemical. If the HI exceeds one (1.0), there may be concern for the potential non-carcinogenic
health effects associated with exposure to the chemicals. The HI identifies the potential for the
most sensitive individuals to be adversely affected by the noncarcinogenic effects of chemicals.
As a rule, the greater, the value of the HI above 1.0, the greater the level of concern.
Table 20 summarizes the total risks for the Site by media. The detailed results of the risks
for each well is in the BLRA which can be found in the Site Administrative Record.
B. Ecological Risk Assessment
The ecological risk assessment (ERA) was conducted to evaluate the potential threats to
ecological receptors from exposure to Site contaminants. The following activities were
conducted:
• Evaluation of potential for off-site migration of site-related PCOCs. This evaluation
included surface water runoff from the Site, ground water flow direction, and potential
ground water to surface water discharge areas.
• Description of the type and proximity of wetlands or other habitats found in and near the
unnamed tributary, Liebert Run, and little Lehigh Creek.
• Analytical results for ground water, and for spring/seeps, surface water and sediments
from Little Lehigh Creek used in the ecological risk assessment were from the sampling
conducted during the Well Survey Investigation. The wells adjacent next to the Little
Lehigh Creek were selected because Site ground water and spring/seep discharge to Little
Lehigh Creek is the primary transport mechanism for Site ground water which could affect
surface water quality.
• Analytical results for surface soil are from the sampling conducted by GEC during the
time-critical investigation and the Remedial Investigation activities.
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• All the analytical results were screened against the EPA Region III ecologically-based
screening levels (EBSLs).
The results of the ERA are the following:
• Several wetlands were identified in the areas proximal to the Liebert Run and Little
Lehigh Creek, however, they have no potential for Site contamination impacts.
• A Site visit and a review of Pennsylvania Natural Diversity Inventory (PNDI) and U. S.
Fish and Wildlife files showed that no documented species of threatened/endangered rare
plant or animal species are located within a 2-mile radius of the Site, except for two
plants: a lettuce saxifrage (Saxifraga micranthidifolia) and western hairy rockcress
(Arabis hirsuta). However, these two plants are located upgradient of the Site and can not
be affect by Site contamination. The possible presence of habitat for bog turtles was also
investigated. The PNFI files noted an unverified observation of bog turtles near the
unnamed tributary. However, the potential bog turtle habitat is also located upgradient of
the Site.
• All VOCs detected in surface soil, ground water, springs/seeps, surface water, and
sediment samples were below the EBSLs.
• Several inorganic constituents were detected above the EBSLs in surface soil, ground
water, surface water, and sediments. Only two inorganic constituents were detected in
spring/seeps samples. •
• Surface soil samples showed levels of some inorganics above EBSLs, however, the
presence of 6 to 24 inches of gravel mitigates direct exposure of any wildlife scavenging
on the surface for food.
• Only one detection of aluminum was detected in a spring in the south bank of Little
Lehigh Creek. Lead was detected in a spring on the north bank of Little Lehigh Creek,
however, the north bank does not receive ground water flow from the Site.
• Although some inorganic constituents were detected in surface water and sediment
samples above the EBSLs, some of these inorganics were detected in both upstream and
downstream samples.
» Inorganic constituents detected in ground water samples showed certain detections above
the EBSLs, however, only about one half of these detections were for dissolved
concentrations, which is recognized as the fraction that may be bioavailable and
transportable.
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RECOMMENDATIONS
Some inorganics were detected above the EBSLs in some surface water and sediment
samples collected in Little Lehigh Creek, and in some ground water samples collected from wells
near Little Lehigh Creek, however, these contaminants can not be attributed to the Site based on
available data. Although Little Lehigh Creek serves as a discharge for ground water in the area, it
is 1.5 miles down gradient from the Site and there are other industries or factors between the Site
and the creek which may be contributing to the levels of inorganics detected in those samples.
Additional monitoring will be needed to determine whether these inorganics are Site-related.
DESCRIPTION OF REMEDIAL ALTERNATIVES CONSIDERED FOR THE
SITE
In accordance with Section 300.430(e)(9) of the National Oil and Hazardous Substances
Contingency Plan (NCP), 40 C.F.R. § 300.430 (e)(9), remedial response actions were identified
and screened for effectiveness, implementability and cost during the Feasibility Study to meet
remedial action objectives at the Site. The technologies that passed the screening were developed
into remedial alternatives. EPA assessed these alternatives against the nine criteria specified in
the NCP at 40 C.F.R. Section 300.430(e)(9)(iii). In addition, EPA evaluated the No Action
Alternative as required by the NCP. These alternatives are presented and discussed below. All
projected costs provided for the alternatives below are estimates.
A. Dense Nonaqueous Phase Liquids (DNAPL) - Effect on Remedy Evaluation and
Selection
The following information is relevant to all of the remedial alternatives evaluated:
As indicated in Section VI, data collected during the RJ revealed concentrations of
TCEdetected in ground water samples from six wells that are indicative of the presence of
DNAPLs.2 The distribution of the wells that meet or exceed the standard indicates the extent of
the "Probable DNAPL Zone".
DNAPLs tend to adhere to soil and aquifer material and are very difficult to remove.
DNAPL remedial technologies currently are limited, and none are able to recover all trapped
DNAPL (TI Guidance). The presence of DNAPLs poses a long-term source of contaminants to
soil and groundwater. Most DNAPLs persist for long periods while slowly releasing soluble
2 Chemical concentrations that exceed 1 percent of the chemical's single component
solubility are an indication of the presence of DNAPLs. Concentrations of TCE in ground water
samples collected from six wells at the Site revealed concentrations of up to 45% of TCE's
single component solubility. Figure 1 shows the locations of the wells indicating the likelihood
of proximal DNAPLs.
21
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organic constituents to ground water through dissolution. Even with a moderate release,
dissolution may continue for hundreds of years or longer under natural conditions before all the
DNAPL is dissipated and concentrations of soluble organics in ground water return to
background levels. The presence of DNAPLs generally does not allow the restoration of the
groundwater to cleanup standards.
Similarly, the presence of DNAPLs in subsurface soils makes remediation of the
contaminated soils in the Probable DNAPL Zone impracticable. Where DNAPLs remain in the
groundwater, they will continue to act as a source of contamination to the groundwater for the
foreseeable future. Therefore, any remedial action that requires removal of the DNAPLs in the
subsurface soils in the Probable DNAPL Zone would have a negligible beneficial effect on the
groundwater, since the groundwater would remain subject to the source contamination caused by
the DNAPLs.
B. Waiver of Specific Arars on Technical Impracticability Grounds ("Ti Waiver")
In this section, EPA, by signature on this ROD, is issuing a waiver of certain ARARs on
the basis of technical impracticability.
Generally, a remedy must meet applicable or relevant and appropriate standards,
requirements, criteria, and limitations (collectively referred to as "ARARs")3 or provide grounds
for invoking a waiver under the NCP at 40 C.F.R. Section 300.430(f)(l)(ii)(C) and CERCLA,
Section 121(d)(4), 42 U.S.C. § 9621(d)(4). Under CERCLA Section 121(d), remedial actions
must attain ARARs under federal environmental laws and promulgated State environmental or
facility siting laws, unless such ARARs are waived pursuant to Section 121(d)(4) of CERCLA
(For a detailed discussion of ARARs applicable to remediation of the Site, please see Section IX.)
ARARs may be waived by EPA for any of the six reasons specified by CERCLA Section
121(d)(4) and the National Contingency Plan. One of the bases for an ARAR waiver is technical
impracticability from an engineering perspective.
3 Applicable requirements are those substantive environmental standards, requirements,
criteria, or limitations promulgated under Federal or State law that are legally applicable to the
remedial action to be completed at the Site. A "legally applicable" requirement is one which
would legally apply to the response action if that action were not taken pursuant to Sections 104,
106, or 122 of CERCLA. Relevant and appropriate requirements are those substantive
environmental protection standards, requirements, criteria, or limitations promulgated under
Federal or State law which, while not being legally applicable to the remedial action, do pertain
to problems or situations sufficiently similar to those encountered at the Site that their use is well
suited to the Site. ARARs may relate to the substances addressed by the remedial action, to the
location of the Site, or to the manner in which the remedial action is implemented.
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After the RI indicated the likely presence of DNAPLs at the Site, Square D Company
submitted to EPA a Technical Impracticability Evaluation Report (August 1999), which evaluated
the practicability ofrestoring the groundwater in the Probable DNAPL Zone to its beneficial use
within a reasonable time frame given the conditions of the Site. This Report is in the
Administrative Record for the Site. EPA's TI Guidance requires that the following components
be incorporated into a TI Evaluation document:
(1) The specific ARARs for which TI determinations are sought.
(2) Spatial area over which the TI decision will apply.
(3) Conceptual model that describes site geology, hydrology, groundwater
contamination sources, transport and fate.
(4) An evaluation of the restoration potential of the site, including data and analyses
that support any assertion that attainment of ARARs is technically impracticable
from an engineering perspective.
The TI Evaluation Report incorporates all of these components. In addition, the TI
Evaluation describes Site geology, hydrology, ground water contamination sources, transport, and
fate, and evaluates the restoration potential of the Site. The TI Evaluation Report identifies the
DNAPL sources, and demonstrates that no other remedial technologies could attain the cleanup
levels at the Site for TCE within a reasonable time frame.
EPA has determined that the TI Evaluation fully and adequately identifies and evaluates
existing on-site conditions that support the issuance of a TI waiver, pursuant to the TI Guidance.
The TI Evaluation Report demonstrates the need for a waiver of ARARs because it is technically
impracticable from an engineering perspective to meet TCE groundwater and subsurface soils
ARARs in the Probable DNAPL Zone. Complete restoration of these areas is unlikely, because
currently known remedial technologies cannot eliminate the DNAPLs. Hence, it is appropriate to
waive the following ARARs by signature of this ROD:
(1) the MCL for TCE in the Probable DNAPL Zone depicted on Figure 1.
(2) the soil standards established pursuant to Pennsylvania Act 2, Section 303 (25 PA
Code § 250.305(b) and Appendix A, Table 3b) for TCE and perchloroethene for
subsurface soil below 15 feet. Soil contamination exceeding cleanup standards is present
in a small area directly above or close to the aquifer within the Probable DNAPL Zone.
Since the concentration of contaminants in ground water below these soils is very high
(due to the presence of DNAPLs), contamination contribution from soils into the ground
water is not significant. Further, since DNAPLs will remain in the groundwater in the
Probable DNAPL Zone for the foreseeable future, any remedial actions addressing
subsurface soil would have a negligible benefit of protecting the DNAPL-contaminated
groundwater.
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These waivers are collectively referred to as the "TI Waiver".
C. Descriptions of the Alternatives
Below are the description of the remedial alternatives evaluated
Alternative 1: No Action.
Capital Cost: $ 0
Operation and Maintenance $ 0
Total Cost: $ 0
The no action alternative is required by the National Contingency Plan, 40 C.F.R. Part
300, as a baseline alternative against which other alternatives can be compared. Under this
alternative, no control or remediation would occur. A review of Site conditions would be
required every five years, since under this alternative, waste would be left in place.
Alternative 2: Natural Attenuation with a Technical Impracticability
Waiver in the Probable DNAPL Zone
Capital Cost: $ 30,000
Operation and Maintenance - estimated annual cost: $ 90,000
Present Worth of O&M (30 years, 5%)- $1,383,525
Total Cost: $1,410,000
This alternative includes natural attenuation for the dissolved phase ground water
contamination and the issuance of a TI Waiver for the groundwater and subsurface soils ARARs
in the Probable DNAPL Zone. Natural attenuation relies on natural processes to decontaminate
contaminated ground water. These processes include dilution, biodegradation, volatilization,
adsorption, and chemical reactions with subsurface materials. During natural attenuation,
monitoring of the contaminants of concern in the monitoring wells is conducted to determine if
natural attenuation is decreasing the concentrations of the contaminants at an acceptable rate,
while providing sufficient protection to human health and the environment. Specifically, ground
water samples are collected and analyzed for biological and chemical indicators to confirm that
contaminant biodegradation is reducing contaminant mass, mobility, and risk at an acceptable
rate.
Data collected during the RI showed that natural attenuation activities are occurring at the
Site, however, a natural attenuation demonstration needs to be conducted to evaluate current
available data and to determine any additional data that needs to be collected. Based on this, EPA
will determine if natural attenuation will reduce the levels of contamination at the Site at an
acceptable rate.
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Alternative 3; Ground Water Extraction with Conventional Treatment
with a Technical Impracticability Waiver in the
Probable DNAPL Zone.
Capital Cost: $ 90,000
Operation and Maintenance - annual estimated cost $ 225,000
Present Worth of O&M (30 years, 5%) $ 4,150,575
Total Cost: $ 4,240,000
This alternative includes extraction and treatment of the dissolved phase ground water
contamination and the issuance of the TI Waiver for the groundwater and subsurface soils
ARARs in the Probable DNAPL Zone. This alternative would involve extracting ground water
from a series of extraction wells, treating the extracted ground water using conventional treatment
processes and discharging the treated ground water to surface water. The GWTS is currently
operating on-site since it was constructed as part of the removal response action. This alternative
assumes that the existing ground-water extraction and treatment system would continue to be
operated.
The GWTS uses conventional treatment processes including: flow equalization;
liquid/solid separation; sludge handling; air stripping; liquid phase granular activated carbon
adsorption; and a vapor phase regenerative off-gas treatment unit. The ground-water treatment
system has been in operation since August 1996 and, based on operational data, effectively treats
ground water to meet current PADEP discharge limitations.
The GWTS was designed and installed to extract ground water from four monitoring
wells. One of the wells proved marginally effective (flow rate of less than 1 gallon per minute)
and ground water extraction from that well was eliminated. Because of the discontinued use of
one of the wells and the highly fractured and heterogenous nature of the bedrock, the current
ground water extraction system may not be providing complete hydraulic containment of the
highest levels of the dissolved phase VOC plume. Therefore, further investigation needs to be
conducted to determine the number of additional wells that may need to be installed to contain
contamination from the Probable DNAPL Zone.
Preferred Alternative:
EPA's preferred alternative for remediating the dissolved ground water contamination is a
combination of Alternatives 2 and 3:
• Containment by extraction of ground water with conventional treatment in the
Probable DNAPL Zone.
• Monitored natural attenuation of contaminants which have migrated beyond the
Probable DNAPL Zone.
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• . TI Waiver for ground water and subsurface soils in the Probable DNAPL Zone.
The GWTS will provide hydraulic containment of the dissolved phase VOC plume in the
immediate vicinity of the Probable DNAPL Zone. Natural attenuation will remediate the ground
water dissolved plume beyond the Probable DNAPL Zone. Together, these two aspects of the
remedy will be used to achieve the cleanup levels listed in Table 1.
DC. COMPARATIVE EVALUATION OF ALTERNATIVES
The alternatives discussed above were compared on the basis of the nine criteria set forth
in the NCP at 40 C.F.R. Section 300.430(e)(9)(iii) in order to select a remedy for the Site. These
nine criteria are categorized according to three groups: threshold criteria; primary balancing
criteria: and modifying criteria. These evaluation criteria relate directly to the requirements in
Section 121 of CERCLA, 42 U.S.C. § 9621, which determine the overall feasibility and
acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy to be eligible for selection.
Primary balancing criteria are used to weigh major trade-offs among remedies. State and
community acceptance are modifying criteria formally taken into account after public comment is
received on the Proposed Plan. A summary of each of the criteria is presented below, followed
by a summary of the relative performance of the alternatives with respect to each of the nine
criteria. These summaries provide the basis for determining which alternative provides the "best
balance" of trade-offs with respect to the nine criteria.
Overall Protection of Human Health and the Environment
CERCLA requires that the selected remedial action be protective of human health and the
environment. A remedy is protective if it reduces current and potential risks to acceptable levels
within the established risk range posed by each exposure pathway to the contamination.
Compliance With ARARs
This criterion addresses whether a remedy will meet applicable or relevant and
appropriate standards, requirements, criteria and limitations (collectively referred to as "ARARs")
or provide grounds for invoking a waiver under CERCLA Section 121(d)(4), 42 U.S.C. §
9621(d)(4), and the NCP at 40 C.F.R. § 300.430(f)(l)(ii)(C). Applicable requirements are those
substantive environmental standards, requirements, criteria, or limitations promulgated under
Federal or State law that are legally applicable to the remedial action to be completed at the Site.
A "legally applicable" requirement is one which would legally apply to the response action if that
action were not taken pursuant to Sections 104, 106, or 122 of CERCLA. Relevant and
appropriate requirements are those substantive environmental protection standards, requirements,
criteria, or limitations promulgated under Federal or State law which, while not being legally
applicable to the remedial action, do pertain to problems or situations sufficiently similar to those
encountered at a specific site that their use is well suited to the site. ARARs may relate to the
26
AR3009U9
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substances addressed by the remedial action, to the location of the site, or to the manner in which
the remedial action is implemented.
In addition, Section 121(d)(2)(A) of CERCLA requires a level of cleanup "which at least
attains Maximum Contaminant Level Goals (MCLG) established under the Safe Drinking Water
Act (42 U.S.C. § 300f et seq.) and Water Quality Criteria (WQC) established under section 304 or
303 of the Clean Water Act (33 U.S.C. § 1314 or 1313), where such goals or criteria are relevant
and appropriate under the circumstances of the release...." 42 U.S.C. § 121(d)(2)(A) The NCP
expands upon this provision of CERCLA, specifying that at Superfund sites whose ground or
surface waters are current or potential sources of drinking waters, all non-zero MCLGs must be
met to the extent they are relevant and appropriate; and that to the extent a non-zero MCLG is not
relevant and appropriate for a given contaminant, the MCL for that contaminant must be met in
the surface and ground water to the extent relevant and appropriate. -The NCP also provides that
where an MCLG for a contaminant has been set at a level of zero, the MCL promulgated for the
contaminant under the SDWA must be attained by remedial actions for ground or surface waters
that are current or potential sources of drinking water, where the MCL is relevant and appropriate
under the circumstances of the release.
As indicated above, EPA has reviewed a Technical Impracticability Evaluation Report for
the Site which documents the likely presence of DNAPLs at the Site, and has determined that it is
impracticable to remediate the ground water to its beneficial use for TCE within the designated
Probable DNAPL Zone depicted on Figure 1.
By signature on this Record of Decision, EPA therefore approves the TI Waiver detailed
in Section VIII.B. for the Probable DNAPL Zone. Aside from the TI Waiver, all other
components of the remedy selected for the remediation of the Site must meet ARARs.
A. Identification of ARARs
Based on the requirements of CERCLA, the NCP, the Pennsylvania's remediation
standards, the potential chemical-specific "relevant and appropriate" requirements are:
(1) the MCLs promulgated under the Safe Drinking Water Act ("SDWA"), 42
U.S.C. §§ 300f-300j-26, at 40 CFR §§ 141.11-.12 and 141.61-.62;
(2) non-zero MCLGs, promulgated under the SDWA, § 300g-l, at 40 CFR §§
141.5-. 51 and any more stringent requirements of the Pennsylvania Safe Drinking
Water Act, 35 PS. §§ 721 fiLsfiQ., and set forth at 25 Pa. Code §§ 109.202-.203;
and/or
(3) Pennsylvania's statewide standards promulgated under Section 303 (a) and (b)
of Act 2, P.S. § 6026.303(a), and set forth at 25 Pa. Code § 250.301(a) and
Appendix A, Table 1 Medium-Specific Concentrations for Organic Regulated
Substances in Groundwater, Used Aquifers, TDS< 2500) and Table 2 (Medium-
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Specific concentrations for Inorganic Regulated Substance in Groundwater, Used
Aquifers, TDS< 2500 and Secondary Contaminants).
(4) All other requirements cited on Table 18 .
The selected ground water cleanup standards were derived in accordance with the above
discussed requirements, including the requirement that remedial actions "at least" attain ARARs
(including MCLs and non-zero MCLGs) and be protective of human health and the environment.
As reflected in the selected ground water cleanup standards (Table 1), the cleanup standard for a
number of the COCs was based on a risk-based concentration which has been determined
specifically for this Site. Consistent with CERCLA and the NCP, RBCs were used when ARARs
were not sufficiently protective because of the presence of multiple contaminants and exposure
pathways.
Long Term Effectiveness/Permanence
This evaluation criterion addresses the long-term protection of human health and the
environment after remedial action cleanup goals have been achieved, and focuses on residual
risks that will remain after completion of the remedial action.
Reduction of Contaminant Toxicity. Mobility, and Volume Through Treatment
This evaluation criterion addresses the degree to which a technology or remedial
alternative reduces the toxicity, mobility, or volume of a hazardous substance. Section 121(b) of
CERCLA, 42 U.S.C. § 9621(b), establishes a preference for remedial actions that permanently
and significantly reduce the toxicity, mobility, or volume of hazardous substances. A
combination of treatment and engineering controls may be used, as appropriate, to achieve
protection of human health and the environment, as set forth in the NCP at 40 C.F.R. Section
300.430(a)(iii). Treatment should be utilized to address the principal threats (such as liquids, high
concentrations of toxic compounds, and highly mobile materials) presented by a Site, and
engineering controls such as containment will be considered for wastes that pose a relatively low,
long term threat or where treatment is impracticable. See 40 C.F.R. § 300.430(a)(iii).
Short-term Effectiveness
This evaluation criterion addresses the period of time needed to achieve protection of
human health and the environment, and any adverse impacts that may be posed by construction
and implementation of a remedy.
Implementabi tity
This evaluation criterion addresses the technical and administrative feasibility of each
remedy, including the availability of materials arid services needed to implement the chosen
remedy.
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The cost of each of the alternatives is evaluated, and compared to the no action alternative.
State Acceptance
The EPA, as lead agency for this Site, selects the remedy in consultation with the State.
EPA has provided the information on which this Record of Decision is based to the Pennsylvania
Department of Environmental Protection (PADEP), and has had discussions on this matter with
PADEP representatives.
Community Acceptance
The comments and concerns expressed by the public during the public meeting and during
the comment period are considered. This criterion includes a determination of which components
of the alternatives interested persons in the community support, have reservations about, or
oppose based on public comments.
A summary of the relative performance of the Alternatives with respect to each of the
nine criteria follows:
Overall Protection of Human Health and the Environment
Alternative 1 does not provide exposure control for the human exposure to contaminated
subsurface soils and ground water. Under Alternative 2, natural processes would continue to
mineralize constituents but the time frame to restore the area outside the Probable DNAPL Zone
can not be predicted due to the continued discharge of contaminants from the Site due to the
presence of DNAPLs. Site land and ground water use restrictions would be required to provide
exposure control for Alternatives 2 and 3. Alternative 3 ranks higher in terms of overall
protection of human health and the environment because it includes treatment of the areas with
the highest levels of contamination. It would result in restoring the area outside the Probable
DNAPL Zone to beneficial use more quickly than would Alternative 2. However, the GWTS
alone will not address the portion outside the hydraulic containment area.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
As indicated above, EPA approved a Technical Impracticability(TI) Evaluation Report for
the Site which documents the likely presence of DNAPLs at the Site, and based on information in
the TI report, EPA has determined that it is impracticable to remediate the ground water to its
beneficial use for TCE within the designated Probable DNAPL Zone as depicted on Figure 1.
By signature on this ROD, EPA is therefore approving the TI Waiver for the Probable
DNAPL Zone. Aside from the TI Waiver, all other components of the remedy selected for the
remediation of the Site must meet ARARs.
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Alternatives 1 and 2 would not achieve the ARARs throughout the plume because of the
continued discharge of contaminants from the DNAPL zone. Under Alternative 3, the GWTS
will contain the levels of contamination emanating from the Probable DNAPL Zone and prevent
this contamination from continuing to spread to the dissolved phase ground water area. However,
the current GWTS does not capture the contaminated ground water in the entire plume.
Therefore, alternative 3 will not meet the ARARs beyond the GWTS hydraulic containment area.
Alternative 3 would also require that the surface water discharge of the treated ground water meet
ARARs for such a discharge.
Long-Term Effectiveness and Permanence
Alternative 1 will not be effective and permanent since it does not include any action.
Alternative 2 would be effective and permanent once the natural processes reduce the levels of
contamination in the ground water, which will take many years, and provided the institutional
controls are enforced. Data collected during the remedial investigation indicated that some •
natural attenuation processes are occurring. However, since DNAPLs exist at the Site, natural
attenuation alone will not be effective in restoring the ground water in the entire plume to its
beneficial use in a reasonable time frame. Alternative 3 controls the continued down gradient
migration of contaminants in the aquifer, and is therefore considered a more effective remedy.
However, Alternative 3 alone would not address contamination outside the hydraulic containment
area. Alternative 3 like alternative 2, rely on enforcement of the institutional controls to be
effective.
Reduction of Toxicitv. Mobility, or Volume Through Treatment
Alternatives 1 and 2 will not reduce the toxicity, mobility and volume through treatment.
Therefore, alternatives 1 and 2 will not meet the statutory preference for treatment. Natural
attenuation will reduce the toxicity, mobility and volume, but it will take many years. Alternative
3 does use treatment to reduce toxicity, mobility and volume of contaminants. Although a
component of these alternatives is a technical impracticability waiver for TCE in the Probable
DNAPL Zone, there is a reduction of contaminant mobility and volume through pumping and
treating the highest levels of contamination and, therefore, this alternative rank highest in terms of
this factor.
Short-Term Effectiveness
For Alternatives 1 and 2, the exposure levels will gradually decrease over time, which
could take many years. For alternative 3, the exposure to contaminated ground water will be
reduced more quickly since most of the contaminated ground water at and near the Probable
DNAPL Zone will be contained with the existing GWTS.
Implementability
Alternative 1 requires no action to implement. Alternative 2 would be easy to implement,
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since it involves only installation of additional monitoring wells, conducting standard sampling
procedures, and implementing land and ground water use restrictions. Alternative 3 is also easy
to implement because the GWTS is already in place. Only minor modifications will be needed
such as the installation of additional extraction and monitoring wells will need to be installed.
Land use restrictions to restrict the future usage of the Site and use of Site ground water will need
to be implemented as part of alternative 3 as well.
Cost
The alternatives range from $0 for the no action Alternative 1 to $4,240,000 for
Alternative 3. This cost assumes that at least one additional extraction well and one additional
monitoring well will be installed as part of alternative 3. The cost for alternative 3 would be
slightly higher if it is determined during the remedial design that more monitoring and extraction
wells need to be installed. However, the cost is not expected to be significantly higher.
State Acceptance
The Commonwealth of Pennsylvania has had the opportunity to review and comment on
all the documents in the Administrative Record and has participated in selecting the remedy for
this Site. The Commonwealth has had the opportunity to comment on the draft ROD and, has
verbally concurred on the ROD.
Community Acceptance
A public meeting on the Proposed Plan was held on June 23, 1999 at the Emmaus Public
Library. Oral comments were received during the meeting. No written comments were received.
No comments were made in opposition to the preferred alternative at the public meeting. See Part
III of the ROD document (Responsiveness Summary) for a summary of the oral comments
received during the public meeting.
X. SELECTED REMEDY AND PERFORMANCE STANDARDS
Based upon considerations of the requirements of CERCLA and the detailed analysis of
the alternatives using the nine criteria, EPA has determined the most appropriate remedy for the
Site is a combination of Alternatives 2 and 3. The remedy will specifically include the following
components:
1. Hydraulic containment of the dissolved phase VOC plume in the Probable DNAPL Zone.
This involves extraction of ground water with conventional treatment using the existing
ground water treatment system (GWTS) at the Site. The GWTS includes the following
components: an equalization tank, a liquid/solid separation unit and sludge handling
equipment, an air stripper, liquid phase granular activated carbon units, and a regenerative
vapor phase adsorber unit. The GWTS system will provide hydraulic containment of the
dissolved phase VOC plume in the Probable DNAPL Zone. The extraction and treatment
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of the dissolved phase plume will continue until the cleanup standards listed on Table 1
are met. Full implementation of the hydraulic containment may require installation and
operation of additional wells and/or equipment, to supplement the GWTS.
2. Decontamination of ground water through Monitored Natural Attenuation (MNA) outside
the ground water extraction system capture zone until the cleanup standards in Table 1 are
met. Natural attenuation relies on natural processes to decontaminate contaminated
ground water. These processes include dilution, biodegradation, volatilization,
adsorption, and chemical reactions with subsurface materials. During natural attenuation
monitoring of the contaminants of concern in the monitoring wells is conducted to
determine if natural attenuation is decreasing the concentrations of the contaminants at an
acceptable rate, while providing sufficient protection to human health and the
environment. Specifically, ground water samples are collected and analyzed for
biological and chemical indicators to confirm that contaminant biodegradation is reducing
contaminant mass, mobility, and risk at an acceptable rate. Natural attenuation will
remediate the ground water dissolved plume beyond the GWTS capture zone to cleanup
standards in Table 1. Results of the monitoring will be used to determine if natural
attenuation is decreasing the concentrations of the contaminants at an acceptable rate
while providing sufficient protection to human health and the environment. The
evaluation of the monitoring will be conducted during the 5-year review of the remedy
conducted by EPA. If it is demonstrated that natural attenuation can not remediate this
portion of the plume, the GWTS will be expanded to remediate it.
3. The TI Waiver in the Probable DNAPL Zone, as set forth in Section VIII of this ROD.
4. Institutional controls, in the form of land use restrictions in the Property boundaries to
prevent or reduce exposure to contaminated soils, and ground water use restrictions
throughout the entire Site to prevent or reduce exposure to contaminated ground water.
Detailed requirements and further performance standards associated with the selected
remedy are presented below.
A. General
1. A background analysis shall be conducted during the remedial design phase to determine
if any of the inorganic contaminants of concern are background or site-related.
2. Five year statutory reviews under Section 121 (c) of CERCLA will be required, as long as
hazardous substances remain on the Site and prevent unlimited use and unrestricted access
to the Site. Five year reviews shall be conducted at the initiation of the remedial action in
accordance with applicable EPA guidance.
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B. Ground Water Extraction System
1 The ground water contamination associated with and in the vicinity of the Probable
DNAPL Zone as outlined in Figure 1 shall be contained through extraction and treatment.
The GWTS shall be used for this purpose, but since the GWTS may not be capturing all of
the contamination migrating from the Probable DNAPL Zone, additional extraction wells
will be required to be designed and installed to prevent the continued migration of the
contamination from this zone. The exact number and location of extraction wells shall be
subject to approval by EPA during the remedial design phase.
2. The treated ground water effluent shall be discharged to the unnamed tributary to Liebert
Creek and shall meet the discharge requirement limits. These discharge requirements
limits are listed on Table 17. This list shall also include other inorganic contaminants of
concern if EPA later concludes that they should be added to the list.
3. Management of waste from operation of the GWTS shall comply with the requirements
of: 25 Pa. Code Chapter 262 Subparts A (relating to hazardous waste determination and
identification numbers); B (relating to manifesting requirements for off-site shipments of
hazardous wastes); and C (relating to pretransport requirements); 25 Pa. Code Chapter 263
(relating to transporters of hazardous wastes); and with respect to the operations at the Site
generally, with the substantive requirements of 25 Pa. Code Chapter 264, Subparts B-D, I
(in the event that hazardous waste generated as part of the remedy is managed in
containers); 25 Pa. Code Chapter 264, Subpart J (in the event that hazardous waste is
managed, treated or stored in tanks); and 40 C.F.R. 268 Subpart C, Section 268.30, and
Subpart E (regarding prohibitions on land disposal and prohibitions on storage of
hazardous waste).
4. The existing Operations and Maintenance Manual(O&M) dated October 31, 1996 for the
GWTS shall be used. However, any modifications made during the remedial design
phase, such as the addition of extraction wells, shall be incorporated in the O&M plan.
Any modifications shall be subject to approval by EPA.
5. A long-term ground water monitoring program, as well as analyses of flow and
contaminant levels, shall be implemented to evaluate the effectiveness of the GWTS. The
installation of additional monitoring wells will be required. Numbers and locations of
these monitoring wells may be subject to change, with EPA approval, during the remedial
design. The installation of the monitoring wells to evaluate the effectiveness of the
GWTS shall be coordinated with the installation of monitoring wells to be installed as part
of the MNA demonstration and implementation. Installation of additional wells may be
necessary and must be in accordance with 25 Pa. Code Chapter 107. These regulations
are established pursuant to the Water Well Drillers License Act, 32 P.S. § 645.1 et seq.
7. If the MNA demonstration shows that natural attenuation will not reduce the levels of
contaminants in the portion of the plume beyond the Probable DNAPL Zone to the
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cleanup standards in Table 1, the GWTS shall be expanded to cleanup the ground water in
this area.
C. Monitored Natural Attenuation
1 . A MNA demonstration shall be provided to EPA to determine whether MNA is effective
in remediating the plume which has migrated beyond the Probable DNAPL Zone to
cleanup standards in Table 1 in a reasonable time frame.
2. Monitoring shall be conducted until the cleanup standards for all the contaminants of
concern in Table 1 are achieved. The necessary monitoring shall be determined during
remedial design phase and shall be provided in a Natural Attenuation Monitoring Plan
approved by EPA. A sufficient number of wells shall be installed as part of the MNA.
The number, location of wells, and monitoring parameters necessary to verify the
performance of the remedial action will be subject to approval by EPA. Installation of
additional wells will be necessary and must be in accordance with 25 Pa. Code Chapter
107. These regulations are established pursuant to the Water Well Drillers License Act,
32 P.S. § 645.1
3. Monitoring shall continue until such time as EPA determines that the performance
standard for each contaminant of concern has been achieved.
D. Institutional Controls
1 . Throughout the course of the cleanup, all persons conducting the cleanup shall refrain
from using the Property in any manner that would interfere with or adversely affect the
integrity or protectiveness of the remedial measures.
2. The Site shall not be used:
(a) in any manner that would interfere with or adversely affect the integrity or
protectiveness of the remedial measures;
(b) in any way as to implement newly commenced or expanded groundwater
pumping in the aquifer, not identified in this ROD, which will adversely affect the
plume migration;
3. Human consumption of contaminated groundwater shall be prevented (drinking water
supply wells shall not be installed in the area of the contaminated plume at and/or
emanating from the Site).
4. Any new development at or near the Site that will adversely affect the hydraulic
containment and plume migration shall be prohibited.
34
AR300957
-------
5. The Site shall be identified as property underlain by contaminated ground water.
6. Easements, restrictive covenants, and/or local governmental controls, along with other
appropriate means as determined by EPA, shall be used to implement the requirements
above.
XI. STATUTORY DETERMINATIONS
The following sections discuss how the selected remedy for the Rodale Manufacturing
Site meets these statutory requirements.
A. Overall Protection of Human Health and the Environment
Based on the Baseline Human Health Risk Assessment for the Site, measures should be
considered to reduce potential risk from contaminants in ground water. This media and
contaminants were selected because potential health hazards for some exposure scenarios
exceeded the EPA target range of l.OE-04 (or 1 in 10, 000) and l.OE-06 91 in 1,000,000) for
lifetime cancer risk or a non-cancer hazard of one (1). The results of the Ecological Risk
Assessment does not show the potential for risk to ecological receptors.
The selected remedy protects human health and the environment by containing ground
water contamination associated with the Probable DNAPL Zone through extraction and treatment
using the existing GWTS. In addition to the GWTS, Monitored Natural Attenuation will
remediate the plume which has migrated beyond the Probable DNAPL Zone to cleanup standards
in Table 1. Also, institutional controls to prevent the future usage of the Site and the use. of
ground water, will be employed to provide exposure control.
Implementation of the selected remedy will not pose any unacceptable short term risks or
cross media impacts to the Site, or the community.
B. Compliance with and Attainment of Applicable or Relevant and appropriate
Requirements ("ARARs")
The selected remedy will comply with all applicable or relevant and appropriate chemical
specific, location-specific and action-specific ARARs to the extent discussed in Section IX of this
ROD, and summarized in Table 18.
C. Cost Effectiveness
The selected remedy is cost-effective in providing overall protection in proportion to cost
and meets all other requirements of CERCLA. Section 300.430(f)(ii)(D) of the NCP requires
EPA to evaluate cost-effectiveness by comparing all the alternatives which meet the threshold
criteria - protection of human health and the environment and compliance with ARARs - against
three additional balancing criteria: long-term effectiveness and permanence; reduction of toxicity,
35
AR300958
-------
mobility or vqlume through treatment; and short-term effectiveness. The selected remedy meets
these criteria and provides for overall effectiveness in proportion to its cost.
The cost estimated present worth cost for the selected remedy presented in this ROD is
$4,240,000.
D. Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized while providing the best balance
among the other evaluation criteria. Of those alternatives evaluated that are protective of human
health and the environment and meet ARARs, the selected remedy provides the best balance of
tradeoffs in terms of long-term and short-term effectiveness and permanence, cost effectiveness,
implementability, reduction in toxicity, mobility, or volume through treatment, State and
community acceptance, and preference for treatment as a principal element.
Under the selected remedy, extraction and treatment of ground water, as well as
Monitored Natural Attenuation, reduces the risk associated with exposure to the ground water to
the extent practicable.
E. Preference for Treatment as a Principal Element
The selected remedy satisfies, in part, the statutory preference for treatment as a principal
element. The GWTS will provide treatment for the highest levels of contamination and will
prevent the migration of contamination due to continue dissolution of DNAPLs in ground water.
The selected remedy, which includes a natural attenuation component, provides the best overall
protection of human health and the environment. In addition, Site land and ground water use will
be restricted to prevent exposure to contaminated soil and ground water.
XH. DOCUMENTATION OF CHANGES FROM PROPOSED PLAN
The Proposed Plan identifying EPA's preferred alternative was released for comment on
June 20, 1999. No written comments were received during the public comment period. EPA's
preferred alternative outlined in the Proposed Plan included a TI waiver for all of the
contaminants of concern in the ground water in the Probable DNAPL Zone. Based on further
review of the TI Guidance, EPA has approved a waiver for ground water in the Probable DNAPL
Zone for TCE standard only. The cleanup standards for the rest of the COCs in the groundwater
will be met in the entire contamination plume.
36
AR300959
-------
APPENDIX A
AR300960
-------
-------
WSPOS»l wtll
GROUND -WMCR MONltORlNC
C«OUNO-SU«tr»Ct tlCVAIIOM CON10UB
IN Fftl »HO MtAM
or romitR
pt"»ccNt or tct
units Of pRoe»a.t OM»PI ?ONC
i «A« «•» uonno raw *ic n»"
vtMraMHC ^u. VM. MMC MO wirwt vi
suou icunwt ctxruno " cowccnm wn.
•II 01«» IOCOOIK »( »H01«I«H
or Kt muMin v*m CMOIOIO
we wwm •->«.
t» c«ct" •»-« rw ••o- went
vnum.m mi c«cut>itD fiiw wont n IIM
RODAU
CMUAUS. PENNSYLVANIA
TECHMICAl IMPRACTICABtLllY EVALOATIOM
PROBABLE ONAPL ZONE
»*»!•. WO » in. "t
-------
-------
LtCtND
IORUCR nwoSAi *(ii
W*UR M(RflIORif«; wftl
PHWIHIl B»'.|
? UONIIOHINC Will.. '.(HI KllttlNf.. AND Sum Ai.l Mm
SAUI'll KM AIIIINS (OUI'll III) IN ( IHINI ( ll|»l Mill
THIS Kl Ml DlAI INVtSHOlKW HAV< III I H >JWv1 vl It
All Ollim HK'AIIOH'. «H| Al'lliH.IUAII
KIli'AII UAMIII Al Illlmil. Mil
IMUAII'. l-INM'.rt VAUIA
REMEDIAL INVtSIIGAIION
SITE PLAN/WELL LOCATION MAP
BBT.-
BR300963
>«iwi. tain » in w
-------
Figure, 4
cn
o
o
co
ca
EMMAUS
JUNCTION
PSW-J
ROOAIC
MANUFACTURING
SITE
SUAMMC CAMP ''.
® PUBLIC SDHI'IT Mil
@ UONIIOWlNC v«l| CI
IORW[R rHM)UCHIttl
RtCOVlBY «ti
UASI MAP »OCl«*ll I SOU CtO INWUMMMUI IIMSUlWI
WC IWAWNti IMnlltD 'UKUMIWAMH ItlVAtKM CQMtUUH
u*p scpTciecu tt*r ntr NIMOTM tuw AIUIIM. ii*iti>
2 MOMIOMI; mil, so* HUMMI; ADD MM
-------
Figure 5
MS
1O
0>
o
o
00
cc
V
LEGENC
m"* « GROUND- WATI.R MOMIIORINC Will
WE" ' (ORMfR PRODUCTlOM/tHSPOSAl Wl I
"^ ' • RECOVtRY will
U" °8 n CISTIRN
PROPERTY BOUNDARY
AS-2 ft PASSIVF AIR SAMPIINC IGCATION
(APPROXIMATE)
NOT[
1 BASE MAP MOPlflfl) fROM BARRY ISI It AND
ASSOCIAICS. PC 5UR\*Y. DAI(0 IO.-JI/96
2 AIR SAMPKS COlltniO (1Y Clf ON (K IIXII H
5 It 17. 1995
J MONirORINC MM. M» HnRlNi;. ANII MIRIACI Mil,
RtMpAl INVlSllGAtlON MA«I B| f N"wIHi Yll) "'!' ""
OTHER IOCA1IONS ARf AI'PHOHIUAII
M.AIl
0
RODAU MANUIACHIRINC SHI "' '
IUMAUS. PINNSYI VANIA
REMEDIAL INVESTIGATION
AIR SAMPLING LOCATION MAP
•-CUT »>5UW. KUCI I Ul. MC , 5
J -»• Fi y -•«••"-1 * ......••«•. |
-------
Figure 6
en
o
o
CO
cc
|llKMpM*»nlt« I
NO
(OUP)
\ \ ^
-WT| \ \ \ X /
ulii j Iv \ \ ^ \ /
LECEHD
PROPERTY BOUNDARY
SURfACt SAUPtINC IOCAIION
BACKGROUND SDK. SAUPIINC IOCA1IUN
THE COMPOUND WAS POStllvCtr iDlNliriCO.
HOWCVtR THE ASSOCIATED HUUfRICAl VAlUt I'j AN
ESIIUArtO CONCtNlRAIION ONlt
IHE COMPOUND HAS BEEN FOUND IN IHl
AS VKlL AS IIS ASSOCIATED BLANK. ITS
IN IHE SAMPLE MAY BE SUSP! CI
NOI DETECTED
DUPLICATE SAMPLE
NJ - IHl ANALYSIS INDICATED IHE PR(SINI( (.» A
COMPOUND FOR MUCH iHtRE IS PRf Sl'UPtlvf
EVIDENCE 10 MAKE A lENTAllvE IW NllfIC AIICIN III!
ASSOCIA1EO NUMERICAL VALUl IS AN ISHMATfh
CONCENTRAIION ONLY
NOIt
I BASE MAP MODiriEO fROM BAHKl ISLIT AND
ASSOCIAIES. PC SURVCf. OAUU IO/JI/S6
2 SAMPUS COUECIED BT CtC AND ANAl ,tUt Hi
LANCASTER LABORAIORItS
1 ALL CONCENIRATIONS ARE REPORIEO AS u^/kg li'pbl
4 DETECTED CONSIIIOENTS RfPORITl) VIIIM H OIIAIIIIIHS
NOI H.IUSTRAIED
& MOMTORINC «tll. SOU BUhlNl,. ANFi SuKIAtt v«l
SAMPLE I W AHONS COMPlEirn
-------
N'» (» > I»n *>]
' / Dt.Mu-o.lt.,-. l«lrtUO
1*l>frM4>f*,•. „
•• "-•• '••"[• . f..
-""• / • f«.
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h F"
111 "*«•• ">ii«-> ")('•"•• *"•»«
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: <
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[""•••""•••" P nwj
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f 9 14 - 'I
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>
r-.
UD
cr»
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o
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«
\
---- _ ...... ______
iL.&'H1-; '" "•* I N,
•• - — — ^.— -_ j— — . 1 1 i
/ | «~M — ---- V
/. K'M") |('ii •))» iiiMik. n , rm anil
IN Illl ',An/I'll MAT III VIM'll'l
not in iii in
v (niii%) • imi'iii AH ',A
IKHMill IBflU lUUMi >SI II «Htt
». \
'""«*•
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\
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/ Pf^- (" ) l« ••')>« ••') V»* I
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1 S*t»1IS lUtlM HI) H*
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f
r"';;.1,".', _,, r; '•*'•; "•""»•!
t;
i » •.
(:";:,::.!.(;;
\
\
^
V
/
I1AIA mil lliuMWollll
l/nli*l I IJAMU! AI IIIMIII MM
IUMAH'. I'llllr,/! yAlIK
REMEDIAL INVESTIGATION
SOIL BORING LOCATION MAP AND
DETECTED VOLATILE ORGANIC
COMPOUNDS IN SUBSURFACE SOW. SAMPl(S
HBL
• Atu«. MUCH « III K | /
^ ""' " « ••••
-------
FIGURE 8
cr>
o
o
CO
OC
LEGEND
GROUND-WATER MONITORING «€Ll
TORMER PROOUCTION/OISPOSAl WELL
RECOVERY WELL
CISTERN
• PROPERTY BOUNDARY
DUPLICATE SAMPLE
ESTIMATED VALUE. COUPOUNO WAS DOEl Till.
BUI RESULTS ARE BEIOW OAIANTIHCATIOM HUH
COMPOUND WAS ANALYZE!! AT SECONDARY
DILUTION
1 BAS£ M* HODtW FHOU lAMY ISC II AW)
A550Cr«T!5. PC VJKfl. 0«HO 10/JI/M
ALL CONCCHTRAnOHS Ml
AS wfA t
3 CHOUMO-WAItfl OUALITr DATA IKPflflltD <&> '
UW-* WAS COU.CCTIO ON AUQUSI 20. IMt
THC (ttyAMOCN Or QtOUHO-VAItK OUAUfT DATA
WAS COUtCTCD MWA» t-14. l»7
4 IMMIOIMC WEU. SOI M»IC. AW SUHTAa SOt
SAimt IOCAINHS COMUJEltO « COMCKON MIH MS
MCUCDIM N^SIlCAmN HAVC fCCN SURVCIfD All
OTXR IOCADOHS AM APMOtifclATt
) SHAOCD CONCtHmATIOHS AJ«( AVOVl IX USCPA WO AW
PA ACI 2 CftOUNO-WATtM S1AWARDS
RUOAIE MANUF AC TURING SITI
EUMAUS. PENNS'IVANIA
REUttHAL INVESTIGATION
~DtSTR(BUTK)N OF VOLATILE ORGANIC
COMPOUNDS M GROUND WATER
AT ON SITE AND ADJACENT WELLS
BBT
r, MUCK I Ul. MC
-
8
-------
Figure 9
LECENp
sumv *u
•CU ClUSHK
SHALLOW UOMTOKMC vcit
rOHtf NSPOSAl WIU
WCOVCK WRCTtD GtaOGIC CONUCT OH r*Ut
. COWOOMO WAS HltCtb
Mat is MS esioo ou«anncAix» IMI
CCMTOUNO WAS WAt>nU »1 StCWDMK Murnn
-« C
"NO tMlllUO -OmUNOWAItH Elf V.IKX
*' 'wy- r
2 iKMtomxc «eu_ SM Km«. wo SUDTACC sm.
A LOCAIWMS COMUCKO M COMCDON -IH n«
*'' M"* KC" S""*"" AU own
3 ALL coHctNiKAiioNS AW wmiitD AS ^A («*)
• SAItfUS OIA«(0 JAKUADT I IM7
5 SHADCO CONCENnAIMHS A*( AMVC M ustM ya ,
PA ACT J OBOONO-W.ItR SIAWAWS
HtmglKTt
noi>
BASH. LtHKH COUir». PA . U S C. S
/* J\V.r. '-.c" woa) " • c«ii. «AH»
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«SOU«Cts. WAItB BfsOUKCI «P«I 31
•*.
r- '' *
\>-
«isoutas w imu
M Or C«v«ONy(MI>l
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IA»«« SCAlt UAPS ANO AW CONSCdKD APMO»UI| .w
SCAll
0
ROOAU MANufAcnmiNG SITE
tUMAUS. PEMNSTIVANIA
REMEDIAL INVESTIGATION
DISTRIBUTION OF VOLATILE
COMPOUNDS M GROUND \ „
AT OPF-8ITE MONITORING WELLS
HBL
OJ^MV, tOUC» t U(, K
-------
-------
APPENDIX B
AR300970
-------
-------
Table 1
Ground water Cleanup Standards and Basis
Chemical
Cloroform
1 , 1 -Dichloroethene
Carbon Tetrachloride
Perchloroethene
Trichloroethene
1 , 1 ,2-Trichloroethane
Chloromethane
Vinyl Chloride
1 ,4-Dichlorobenzene
Bis(2-ethylhexyl)phathalate
Pentachlorophenol
Arsenic
Ammonia
Antimony
Copper
Iron
Thallium
Lead
Chromium
Benzene
3enzo[k]fluoranthene
Dibenzo[a,h]anthracene
3enzo[b]fluoranthene
^-nitrosodiphenylamine
Cleanup Standard
Micrograms/ Liter
(UG/L)
0.15
4
0.16
1.1
1.6
0.19
2
0.019
0.47
4.8
0.56
0.045
200
6
150
300
0.5
5
100
0.4
0.55
0.0092
0.0092
14
Basis
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
RBC
Federal MCL
RBC
RBC
PA Act 2
(SMCL)
MCLG
PA Act 2
(MCL)
Federal MCL
RBC
PA Act 2 (S)
RBC
RBC
RBC
AR30097I
-------
Phenanthrene
Ethylbenzene
2-methylnaphthalene
Benzo[a]anthracene
Barium
Cadmium
Cyanide
Nickel
Vanadium
Zinc
Aluminum
Indenofl ,2,3-cd]pyrene
Naphthalene
Pyrene
Xylenes, total
Benzo[a]pyrene
Di-n-octyl phthalate
Manganese
cis 1,2-dichloroethene
trans 1,2-dichloroethene
4-methylphenol
Toluene
no
700
120
0.0092
2,000
5
200
100
2.1
2,000
200
0.092
6.5
13
4,000
0.0092
730
50
40
50
60
380
RBC
Federal MCL
RBC
RBC
Federal MCL
Federal MCL
Federal MCL
PA Act 2 (H)
PA Act 2 (G)
PA Act 2 (H)
PAAct2(SMCL)
RBC
RBC
PA Act 2 (S)
Federal MCL
RBC
RBC
PA Act 2 (SMCL)
RBC
RBC
RBC
RBC
RBC Risk-Based Concentration
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
SMCL Secondary Maximum Contaminant Level
H Lifetime Health Advisory Level
G Ingestion
S Aqueous Solubility Cap
AR300972
-------
ezeooeav
csi in
i
U
v
I
11
8883888
MI
" *J *
38888
>i
*§
51
5 "
i§
388
388
u
6
833
•i
Ii§
e
^
x
i
-------
Table 2 continued
COMPARISON Or SURFACE SOUS WITH USEPA REGION M RISK BASED CONCENtRAllONS
ROOAIE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
CT»
O
O
CO
oc.
III |KM*M» d MC vilw to ordn^tm: «BM«m« «( HK-IMh •« NK nk» tat«
111 (MM* KMM ImktMMMil fiMtclton A*«cy WSWAJ KtMrinf «*- far to* ki Ml IrMMnM MtUnfl. US!PA ItM.OSWCHOkw^* nN|4.fi
IMIwMWnuMM.
• - T—rifrn if ItT tit V^inlin titanic filliili
1...
J . *•— i -- ' "i ..... *i" 1-*i«fi-t-r f-Tliri'm HK KI: nlu* itawn to vAn *mM^ In UMPA MHIM W WC I«W>
Mfe« M. tultoci: UMM< Ntok««H« C
. Mefton a.PM^tehta. tanqtmte, M«««A»,<«rtO««* »7. It9».
». ff mn,m. P»,,^,,<,, M»m»r»nHtot tt me T«
W9..W6XLR , 9/|6/9g
-------
Tab^s 3
COMPARISON OF SUBSURFACE SOIL SAMFtES WITH USEPA REGION HI HBCs
NOOAIE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
C*M*M«I
«•••*
Mum
Cdchim in
Chnrnwn
CoMI
COMW
Mill
••dlft
fafmkimHt
•MftflMM
MtfCWV
•CM
OlMtfum •"
fine
1.2-OkMMOtthww. T*Mrf
IMIMMatMltWW
litfcl^wvvM^^
•L.."
H
H
VMQMP>Y
— T77 —
• /•
m
t/*
tit
7/7
«/•
7/7
• /•
1 1 1
tit
T/f
• /•
571
• /*
*/»
:/«
i/i
77i
1 JTJ
• /iT
i/i*
i/i*
1/1*
i/ii
i/i*
411*
unnfin
ft.M-U.4 —
11.* • 1*7
ft I* • i.i
iS
ilo i.i*o
3.* • 17.*
Ill -16*
no • **.«
ll.*00 • 77.JOO
4.1 • 4*.l
MI-N7
r iilt'-UII6T~'~
0.017 • 0.1*0
ii.i-N.7
43* - M7
0 » 1.1
t J-J.I
I4~J.|*.0
' O.M1-7.I
i* * • ii i
•*i-MO
0001 o.oot
0.00*
0.001
0.004
o.ooi
0.001. OO47
iMMtMtt
5TF
•»ioii»iit
*»llll
5/4
'Mew**
,>^*«7;
.ffl
1317 —
' i*ON ' '
1*ON
"" 'i*N
NC
MON
47ON
$10 N
I.IOON
4OO
NC
1*ON
UN
ICON
NC
MON
MOM
NC
OMN
WON
" i.iooN
TOON
4. TOON
1 1*0 H
ilM
"'ilboN
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tUMtttttf
ti ••'•
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' «•••
•"- ii
in
r»*.
en
o
CO
cc
11981176X1R
I of 2
9/15/98
-------
Tnhlp 3 Contlnuot'
COMPARISON OF SUBSUflf ACE SOW.S WITH USEPA WEGKJN W TOSK BASED CONCENTRATIONS
nOOAlE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
UD
r--.
en
— g
MC -«tok«MWC«K««Mtoni, CO
.-.! ....... . ...i....^_.^^.u-»^^nVrlnr|f|:|nt|||L| Q£
-H. «I
^'
I - f miilinei «t MC M Injinliii *<»iililil Crfrtri«
N -
•-C^a^hM^^rtc..^!*.***!^*^^
"J ** AnvirvitbiwCMM ttw vfMMKt •• • C^MPWMB WH w^tickiKcrv!• •^•••nMltfAMIAMWM •• •••&• * t*i^»yna "—**™—•-- Tl^ ^^^^.^^^«^^»^j*rf^^^^^
i»^ ^^^^E^K^ f^pnvncv vWM V
«W
N - NMCBdWfMlC *«MN
NG • Ite tiNut*
Cl . MC M M •! O. I to IM* «hw> MC Kl: nlM itawn to VikM *>nM^ to UUfA H^ton M MC «•*!•
«M«M SUM* Emk
. Irwi Hn I
K.tom. tVmt^trt.. M»mnn»i»i tnm *~»m Hn»^. t»rfc*tottol. n MC UMi
t«M»
1398I126XIH «-.,«,, 9/15/98
-------
I
Table 4
COMPARISON OF ON-SITE GROUNOWATER SAMPLES FROM MONITORING WELLS WITH USEPA REGION HI RBC.
PRE-REMEOUL INVESTIGATION SAMPLING EVENT
ROOALE MANUFACTURING SITE
EMMAUS, PENNSYLVANIA
199t112tXlfl
P»g« 1 Of 2
AR300977
9/15/98
-------
Table 4 Continued
COMPARISON OF ON-Srrt GBOUNOWATW SAMPLES RTOM MOMTTOMNO WtUS WITH USEPA URSION III H8C*
PRE-MMKMAL INVtSTKSATION SAMPUNQ 8VWT
HODAUEMANUFACTUHING SITi
EMMAUS. PENNSYLVANIA
c—*_
1 — 73713—
— m —
1 — «Ti3 —
ii/ii "
J7i3 —
— u/ii "
— i37TF—
— 10/iA "
12 Hi
11 Ml
5773 —
— 5713 —
— rrnr~
— rra —
1 t/u —
ii/a -•
[ — irssn —
S3
— rsK —
i3j
is — —
3S53
ni
— eras —
1 I3»j
i.6U
nn —
m
533H
m
— irr» —
— ran —
«K(U»«MM
| TSTB
rrs
5T5 '
iB«
I 5SffS
I 5T!
J3TB
5333
n.o N
55
OJ.K
S3*
WOOTi
| »Mi
4/4 1
"" i/i
" l/il
"" — F7T
i/t
i/.A
"" — T77
" »/ii
o/io
i/ii
" ' 0<3
o7!
— — rrr
""••• \m —
| i4Ji.UJoo'-
iTTHS 1
fa.ii.i.W
— mm —
t.M-H4.Uo
— nrro —
iTTH
— nns —
— arms —
O.U-W —
1 a4.i^6
0.6i-1.0M
— lit. lit
— rrrs —
— I.i • ii.6H
" i.l«. 74.000
iiH-.U "
B3-J
55T7
~ — B5i :
5ST
"vg'l •" "
•t «
.'.. • '. V.
•» -• * ,
"*• .*
(a Ulff* 1»»4 M. OiMn WMT Mt
c -
Not*
ci • we «N* o.i <
IP: «
I MMl 17. INT. Htm Kn, I. *M», NkO..
1. ttNMnJm
19981128XLR
9/1S/96
AR300978
-------
6Z600CHV
16'5 1.6
I 10 I l
i
-------
Table 6
COMPARISON OF POTENTIALLY SITE-RELATEO OFf-Sm GROUNDWATER SAMPLES FROM PRIVATE OR PUiUC SUPPLY WILLS TO USEPA REGION III RIC.
PRE-REMEDIAL INVESTIGATION SAMPLING EVENT
ROOALE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
15"
TTT
-5TT
"oTT
TT"
NC
M.O N
O.It C
""•.I M
•871
TTi
TTST
•nrr
133-
T7T
"5TT
2*O M
17ll112eXLR
1 at 3
flR300980
9/1S/9*
-------
Table 6 Continued
COMPARISON OF POTENTIALLY SITE-I
"ELATED OFMITE GBOUNDWATEB SAMPLES FROM WWVATE O" PUSUC SUWLY w»is TO US«* D^ «
ME-BEM1DIAL INVESTIGATION SAMSUNG EVENT ^^ ^^ " BEG'ON '" WC<
ROOALE MANUFACTURINfi SITE
EMMAUS. PENNSYLVANIA
9H5/95
AR30098I
-------
Table 6 Continued
COMPARISON OF POT!NTIALLY SITE-RELATEO OFF-SITE GROUNOWATE* SAMPUS FROM PRIVATE OR PUBLIC SUPPLY WELLS TO US6PA REGION III ROC.
PRE-REMEDIAL INVESTIGATION SAMPLING EVENT
ROOALE MANUFACTURING SITE
EMMAUS, PENNSYLVANIA
-
nwMOT
•MM
•UMUMIHMni
innmtBtjni
_
i / 1
1/1
1 ; 1
M.3M
iitio
' " i-ili
i.*7i
i.«i
. o.ii
».§
3*.i
*.*•
O.I J
Q.I J
•.7
t4.0
Men*«MM
29O N
H.O
MC --
1*0 N
MC
O.M C
i.1 N
1.1 C
1.CC
^~^
0 / 1
oTT
01 1
57i
j-
-Ti
1 -V;
01
01
•y,
01
ffT
"T/
01
Of —
01
01
01
V!
01
01
01
0 1
1 / 1
1 / 1
T
*•
V"«
l78i11JBXUl
P*g«3al3
9/15/9*
AR300982
-------
COMPARISON Of POTENTIALLY
Table 7
S.TE-«LATED OFMm «WUNBWAT» SAMPLES fflOM MONITOrtNG WELLS TO USEPA REGION Ml MC.
REMEDIAL INVESTIGATION SAMPLING EVENT
ROOALE MANUFACTURING SITS
EMMAUS, PENNSYLVANIA
H3S3
— rra —
j-5
iT338
— Sons —
— ens —
!3
£S
TB5
• — rsia —
— JL!
T5
57j
ns
— nss —
— jnoo —
iT3
ERo
HK5
— HC
" HE
L.'d
' 55
i.ii
"' ii4
u 5c
~ — oiTTi
~TiT5
_ .j^
~ TTE
," ^~ : •"•»• •* *
o~i
n
— 5-5
n
3Ti
am
oTi
oTi
OM
oTi
571
l •« WC
189i1126XUI
9/15(91.
AR300983
-------
\
Table 8
COMPARISON OF NON-SITE RELATED OFF-SITE GROUNOWATER SAMPLES FROM PWVATE OR PUiUC SUPPLY WELLS WTTH USEPA REGION III R8C»
PRE-REMEOIAL INVESTIGATION SAMPUNG EVENT
RODALE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
MOMI
$4t^M0A
S4*W
2/1
T7T—
— TT3! —
— in? —
— TTai —
— rrs —
— TT« —
— rrn —
1 — TTzi — 1
27/2*
— rrs —
— 373—
— r/n —
— inn—
lt/2«
23/24
3 / 3i
3 /2B
2S/2I
7/21
1/21
21 1 29
4/ 2§
22 /2t
1 37j
F!T
04J
_
531
5U '
1 *" 1
zTTi
J3TI
sTSB
53i
iS
n
12».4
2B1
o.n •
•-1
S.2tO
M$.22t
2l.f K
•t.TQO
4.2V
4.S7D
""sr**
5ioS
STJ
m
\r*
MOM
TT»
JISM
ito
73.0 H
1.1 M
73.0 N
NC
11.0 M
IC.OH
NC
O^t N
1.100H
1 o/i
— -m
oTl
57i
— m —
ori
TV 4
4,i
871
TTTiS
i/if
-T7T
oTS
77T1
TTi
rrs
0/2*
2/23
0/3
O/3
0/tt
1/7
1/1
0/2*
4/4
1 J22
[ BT^oT
— 12.0 • ii.4 —
1 j - M '
STTo!
0.31 • ti.li
0.3 • 20.6
oTToli
6.4.10.0 —
S3TTi
1 14.1 . 1*3 1
— rrrj —
4».11Hi»-
TTT3
ui-Ujoo
— TSTTSi —
4.H.1M
— rm —
i.o.i.U6 —
413-»A>B
1 .2 • 2S1
O.OTf -0.11
4.1 • I.I
312 • I.2W
0.77» -MI.22I
21.1 • 11,1
3.0*0 - M.700
1.1-441
t.l • 4,t70
r~ — fsffi
PW-OMW
MMM40
pw.UAt
Swl
SwH 1
Sw3
Sw3
rsw-i
Sw3
1 Rrnjj 1
m£u»MO
H04JMM
_ -g—
tw-wwi
" HEtBii
nw3
FwSSB
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— «r35i —
m«-MM
PW-SAoi
WW4JB11
«*4*411
r*n&Tl
PW-UUI
PW-UM17
mv-uMM
nv-mii
•^L-r -
'• - * -C-.
-..^ , j
N*
TM
y«
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Mf
VM
w
Ma
VH
VM
131 UtW* 1»M
(Jl
15tiiizaxLft
1 of I
9/15/98
AR30098U
-------
Tble 9
COMPARISON OF NON-SITE RELATED OFF-SITE GROUNOWATER SAMPLES FROM MONITORING WELLS TO USEPA REGION III R8C4
REMEDIAL INVESTIGATION SAMPUNG EVENT
RODALE MANUFACTURING SITE
EMMAUS. PENNSYLVANIA
JTTJ3
TB
•tJoTT
PT5B
5TB
iio.U.6
ti.o-ii.0
MW-tO
ssrss
5535
13.IH
M.to
MW.Tt
•STW
ls
1 - Th.
J - Tht
K
L
Ci - WC• HI •» o.i • ttm mn MC (
T.inium. • MK TMH iwoni M.
ToBOMfM. W WC TOM IKMtof toL SlMpeC MM-
I Mn*l IT. 1N7. MM) tav U IMII. HO..
(April. ItMIn
lE9t1126XLR
I 1 of 1
9/15/3*
AR300985
-------
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AR300986
-------
ill!
jfji
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2 =
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1 1 ' 1 ! • ill
»ii I I » 5=55====i:=
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flR3:0'0987
-------
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AR300988
-------
Table 13
MM
HW-1
ueo
SAOT
.100
IMM1I
SOI
UD11
L01J
1*411
man
LM10
UHT
VOC. SVOC. PCI.
VOC. SVOC. PCS.
voc.cvoc.
voc. svoc. PCI.
VOC. SVOC. PC*, li
voc. svoc. PC*, i
voc.ivoc.pcai
voc. svoc. pea i
voc. svoc. pea i
voc.*voc.pca>
voc.
»•*••_
VOC. IVOC. M^BK
VOC. SVOC. MfHB
voc. svoc. i
voc.svoc.il
voc. svoc. i
VOC. SVOC. I
voc. ivoc. i
voe.svoc.ii
VOC. IVOC. I
oai«M
11*
SVOC. Mi«nc. owm Ctamicy
SVOC. M*nc. Omn CMmny
voc.
VOC.
svoc. «•»••. a«
SVOC. mipia. a«
svoc. »••«. a.
svoc. »•>••. o«
SVOC. MnMC O«
svoe.t
VOC
VOC
VOC
VOC
voc
voc
voc
voc
VOC
voc
voc
voc
voc
voc
VOC
voc
voc
15-S«
01M1126OUH
ion
AR300989
-------
Table 14
Summary of Potential Exposuro Pathways
Rodato Manufacturing SMe
Emmaus. Pennsylvania
30
CO
O
CD
VO
VD
O
Source Medium
Soil
Ground Water
Surface WaUr
Sediment
Migration/Release Mechanism
Direct Contact
Partlculale Emissions
Direct Volatilization (VOCs only)
Leaching of PCOCs
Surface Runoff
Potable Use
Discharge to Surface Water
Direct Contact
Direct Volatilization (VOCs only)
Btoaccumulatton by aquatic organisms
Direct Contact
Leaching of PCOCs
Btoaccumulalkm by aquatic organisms
Route of Potential
Human Exposure
Incidental Ingostlon, dermal contact
Inhalation
Inhalation
Ground-water exposures
Dermal contact
Ingestion, dermal contact. Inhalation
of VOCS
nddental Ingestion, dermal contact
nhalatton
ngestion
nddental Ingestion, dermal contact
Surface water exposures
ngestion
VOCs - Volatile Organic Compounds
PCOCs - Potential Constituents of Concern
02981126'
15-Sep-98
-------
Table 15
Toxicity Indices - Potent* Carc.nog.nK: Effects
Rodin Manufactunng Site
Error;..-. Pennsylvania
VOCs
Carbon tetrachtoride
Chloroform
Chloromethane
1.1-Oichtoroethene
Tetrachloroemene
Trichloroethene
Vinyl chloride
SVOCs
l.'^-Oichlorobenzene
yinwyOphthalate
Penacntorophenol
METALS
Arsenic
i
0*1
.19
0.013
I nn
1 v.O
5.206-02
1.10E-02
1.906*00
2.406-02
1.406-02
1.206-01
1.506*00
i
82
82
C
C
A
C
82
82
A
i
IRIS
IRIS
HEAST
IRIS
NCEA
NCEA
HEAST
HEAST
IRIS
IRIS
IRIS i
/n/Mtotfon/toute • T ~1 • 1 1
VOCe
Carbon tetrachtoride
(Chloroform
j Chloromethane
11.1-Oichioreetnene
Tetrachloroethene
Trichtoroethene
Vinyl chloride
SVOCe
8<*<2-e»ylhexyOphmalate
METALS
Arsenic
Cadmium
Chromium VJ >
5.306-02
8.106-02
6.006-03
1.756-01
2.006-03
6.006-03
3.006-01
2.206-02
1.406-02
1.516*01
6.306*00
82
82
C
C
A
1
1
A I
81 1
IRIS
IRIS
HEAST
IRIS
NCEA
NCEA
HEAST
4CEA
4CEA
RIS
IIS
r\lw
RIS
WWght^f-Evidenoe Classifications:
A • human carcinogen
82 - probable human carcinogen
C - possible human carcinogen
IRIS «integrated Risk Infoimation System (USEPA, 1998)
06981126QUJ
Page 1 of 1
AR30099I
i4-Sep-98
-------
Table 16
Toxicfty indices • Potential Noncaronogenic ERects
Rodale Manufacturing Site
Emmaus. Pennsylvania
Ofa/fioute
VOCa
Camon tetrachlonds
Chloroform
1.1-Ofchforoethene
ca-l,2-Olchtoreethene
Tatrachtoroethene
Toluene
TricnJocoethene
svoce
1.4-Oichlorobenzene
4-Methylpheool
Bls(2-«thylr)exynprt11ialata
Pemachtorophenol
MTTALS
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium III
Chromium VI
Copper
Iroo
Manganeee
Selenium
Silvtr
THiKium
line
/fl/ia/atfon ftoutt
VOCa
Carbon tatnchioride
tftikMOform
Tetrachioroelhene
Toluene
SVOCe
1.4-Dichlorobenzerw
METALS
Aluminum
Banum
Chromium VI
Manganeee
Ammonii
RID
(mg/Vg-d)
0.0007
0.01
9.006-03
1.00E-02
1.00E-02
2.00E-01
0.006
0.03
0.005
0.02
0.03
1 .006*00
4.00E-04
3.00E-04
7.006-02
1. 006-03
1.006*00
5.006-03
4.006-02
3.00E-01
2.006-02
5.00E-03
5.00E-03
7.00E-05
3.00E-01
0.000671
e.ee-06
0.14
1. 146-01
2.2*6-01
1.006-03
1.406-04
1.006-07
1.43E-05
2.ME-02
Confidanci
Lavrt
MMlium
Medium
Medium
Medium
Medium
.
Medium
Medium
Low
.ow
Medium
MeMfUfH
Hgh
Low
Low
-
HioJl
Medium
Medium
Medium
-
tedium
•
.
Medium
Medium
.
-
.
Medium
Medium
Critical
6fTeet
Liver (leaiona)
Liver (lector*)
UvwOeaiorn)
fieTMVl fti^f fleinwilnhiinl
^**""* \w«*c. n«*iTBwylOO*n|
Liver (hepatotoMdty)
Uver/Kidney (weight)
^
I~*J1J ml f«_
t<*rwii n4vvoo* tyttem (nypoactMty)
Uver(wetgtK)
Fetotoxidty
^eurotosdctty
•ongevKy (dec blood otiirnia)
SWn (Myperpiomentation. keretoeto,)
Incruaed BJood Preaaura
Kidney (proMnurta)
Noeflectaobeefved
No effects observed
G.I. Trad (irrtttoon)
No eflactt obaerved (dietary req.)
Central nervoua system
Salanoila
SWn(afByrte)
1
li^/M< li^^ ^ntvn^ ajJIuMul
'H^MI \O^^> •vtCjfmv 9KUWff
^
.
Neurotogicel
Liver (weight)
.
'etotoxictty
.
IAI imhaliBiHnrBl ttnmnfimmimm\
leuraoenavwraj (rnangatiiam)
Pulmonary (no lung •ffect* observed)
RrtVRfC Basis/
RfD'RtC Source
LOAEUIRIS
LOAEUIRIS
LOAEUIRIS
NOAEUHEAST
LOAEUIRIS
NOAEUIRIS
NCEA
NCEA
NOAEUHEAST
LOAEUIRIS
NOAEUIRIS
LOAEUUSEPA Region III
1 nAd ABIC
n VirnfTL/im j
NOAEUIRIS
NOAEUIR1S
NOAEUIRIS
NOEL/IRIS
NOEL/IRIS
LOAEUHEAST
NOAEUUSEPA Region III
NOAEUIRIS
NOAEUIRIS
LOAEUIRIS
EPA-6CAO
met note
.' wri fiKio
NCEA
NCEA
NCEA
LOAEUIRIS
NOAEUIRIS
NCEA
NOEUHEAST
EPA-6CAO
OAEUIRIS
NOAEUIRIS
Uncertainty
PBGfAT
* eW»*Wt
1000
1000
1.000
1.000
1.000
100
100
1000
100
100
1.000
3
3
10
100
100
100
1
1
3
3
.
^
.
300
1000
.
1,000
-
1000
30
Modifying^
CMJ-»/L»
^•CtOf
1
1
1
3
1
1
1
^
1
1
1
1
,
i A
10 •[
5*P
1 I
1
3
1
1
.
1
;
.
1
1
.
i
-
1
1
LOAEL - lowest observed advene effect level
NOAEL • no observed adverse affect level
NOEL - no observed affect level
IRIS - integrated Rick Information System (USEPA. 1B96)
05981128QUJ
Pag* 1 of 1
AR300992
14-SCP-98
-------
Table 17
GWTS PERMITTED EFFLUENT LIMITS'
RODALE MANUFACTURING SITE
EMMAUS, PENNSYLVANIA
FEASIBILITY STUDY
Monthly
Average
(my'L)
Tetrachloroethylene
1,2-Trans-Dichloroethylene
1,1 J-Trichloroethane
Trichloroehtylene
^^-^—^——«^»_
Vinyl Chloride
N-Nitrosodi-Phenylamine
PMMB^MBM
Pyrere
Dissolved Iron
As per January 31, 1995 letter from Dino R. Agustim, Sanaury Engineer. Nonhean Regional Oflfiee PA DER,
to Jahan Tavagjr, Principal, GEC, regarding Industrial Waste, Rodaie Manufacturing Superfimd Site.
Page 1 of I
AR300993
-------
Plug and abandon existing pumping monitoring wells
which serve no useftil purpose
(Pa.)
Hazardous waste management as part of the operation of
the Ground Water Treatment System (Pa.)
Comply with the discharge requirements in surface
waters (Pa.)
Soil Cleanup requirements listed on Table 19- Waived bv
TI Waiver (Pa.)
Air Emissions from GWTS (Pa.)
The ground water shall be restored in the entire
contaminated plume to the cleanup standards in Table 1
of the ROD, except for TCE in the Probable DNAPL
Zone. (Pa. and Federal)
Action
Action
Chemical
•—^^
Chemical
Action
Chemical
I0?' ^^ re8Ulat}°nS m cstablished P«™ant to the Water Well Drillers Act, 32 P.S.§
""^^^^"•^^^•™*-^^™™™™^^^B
PADEP's Public Water Supply Manual, Part II, Section 3.3.5.11
US WaStC detcnnmatio» ™<« identification numbers), B
25 Pa. Code Chapter 263 (relating to transporters of hazardous wastes)-
?? Ae "P"8'™ at *« site generally,, with the substantive requirements of 25 Pa. Code
eVCnt ^ haZmlOUS WatW 8CneratCd " P8rt °f *C remedy is managed ta
25 Pa. Code Chapter 264, Subpart J (hazardous waste managed in containers)
^^ E (regardln8 pr°hibitions on *"* of
Pennsylvania Discharge Permit Regulations (25 Pa. Code, Chapter 92 and 93)
Pennsylvania land Recycling and Environmental Remediation Standards Act (Act2 of 1995), Title 25, Chapter
Pennsylvania Air Permitting Regulations 25 PA Code §§123 and 127.
CTRm,
CFR §§ 141 50,5II; 40 CFR §300.430 (eX2XIXAX2) and (eXD(D); or PA Statewide Standards for ground
water promulgated under Act 2 § 303 (a) and (b), at 25 Pa. Code § 250.301 Appendix A, TabS I
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Table 19
PA Act 2 Residential Standards for Substances detected below 15 feet which have been waived
Chemical
Trichloroethene
Perchloroethene
Standard (Micrograms/KHogram)
MG/KG
500
500
Basis
PA Act 2
PA Act 2
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Table 20 -Summary of Risks
Non- Cancer Hazard Index
Adult
Industrial
Worker
Child Resident
Adult Resident
Trespasser
Soil
0.2
5.6
1.1
0.59
Ground Water
119,666
76,057
Spring (SP-03)
0.4
0.1
. Incremental Cancer Risk
Adult
Industrial
Worker
Child Resident
Adult Resident
Trespasser
Soil
4E-06
IE-OS
IE-OS
2E-05
Ground Water
0.8
3.0
Spring {SP-03}
6E-06
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RECORD OF DECISION
PART III - RESPONSIVENESS SUMMARY
RODALE MANUFACTURING SUPERFUND SITE
EMMAUS, LEHIGH COUNTY, PENNSYLVANIA
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RODALE MANUFACTURING SUPERFUND SITE
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
Overview 4
Background
5
Site History (5)
Community Relations History (7)
Summary of Commentors* Major Issues and Concerns
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Responsiveness Summary
Rodale Manufacturing Superfund Site
Borough of Emmaus, Lehigh County, Pennsylvania
The Responsiveness Summary is divided into the following sections:
1
Overview;
This section discusses evaluation criteria that the U.S. Environmental Protection
Agency (EPA) uses for determining the preferred remedial action alternative for a
Superfund site.
Background;
This section provides a brief history of community relations activities conducted
during remedial planning at the Rodale Manufacturing Superfund site.
Summary;
This section provides a summary of commentors' major issues and concerns and
EPA's responses to those issues and concerns during the public meeting.
"Commentors" may include local homeowners, businesses, the municipality and
potentially responsible parties (PRPs).
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1
Overview
Oh June 21,1999, EPA published the Proposed Remedial Action Plan (Proposed Plan) for the
Rodale Manufacturing Superfund Site (the site), located in the Borough of Emmaus, Lehigh County,
Pennsylvania. The Proposed Plan outlines EPA's preferred remedial alternative for the site, giving
consideration to the following nine evaluation criteria:
Threshold Criteria
• Overall protection of human health and the environment
• Compliance with federal, state and local environmental and health laws
Balancing Criteria
• Long-term effectiveness and permanence
• Reduction of mobility, toxicity or volume of contaminants
• Short-term effectiveness
• Ability to implement
Cost
Modifying Criteria
• State acceptance
• Community acceptance
After considering several alternatives, EPA's preferred alternative is 1) hydraulic containment of
the highest levels of contaminated ground water at and in the vicinity of a portion of the aquifer at the
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Site which has been determined to have Dense Non-Aqueous Liquids (DNAPLs) (the area referred to as
the "Probable DNAPL Zone") by extraction and treatment using initially an existing Ground Water
Treatment System (GWTS) at the Site: 2) a Technical Impracticability waiver for the Applicable and
Relevant and Appropriate Requirement (ARAR) for TCE in ground water in the Probable DNAPL Zone:
and 3) passive treatment through Monitored Natural Attenuation (MNA) for the contamination which
has migrated beyond the boundaries of the Probable DNAPL Zone.
Background
Site History
Prior to the 1930s, the Property (as defined in Part II, Section I) was occupied by the D.G. Dery
Silk Corporation and later by Amalgamated Silk Corporation. Rodale Press, a publishing and printing
business, occupied portions of the building for several years beginning in 1953. From the late 1930s
until 1975, the Property was operated by Rodale Manufacturing. Rodale Manufacturing manufactured
wiring devices and electrical connectors. In 1975, the Property was sold to Bell Electric, a wholly-
owned subsidiary of Square D Company. Bell Electric manufactured similar electrical components.
Pennsylvania Department of Environmental Protection (PADEP) files indicate that under Rodale
Manufacturing's operation of the facility, several wells were used for disposal of various wastes.
PADEP files indicate that in 1962, approximately 3,000 gallons per day (gpd) of wastewater, including
rinse water from copper and zinc plating and acid brass dipping, were discharged to a 452-foot deep
borehole (Well 1) located hi the former courtyard area. Discharge of wastes into the wells continued
probably until 1967 when the electroplating room was connected to the sanitary sewer.
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\
Past disposal practices were first identified by Square D in March 1981, when a capped borehole
was discovered during the installation of new equipment. Long-time employees of Rodale
Manufacturing indicated that two other wells were also used for disposal purposes, and the locations of
these wells were identified. During the course of the investigation at the Site, four additional features
were found. They are: a shallow cistern; a tank possibly used for fuel oil storage; a well apparently used
for makeup cooling water; and a well which is believed to have been used for septic disposal.
In 1984, in coordination with PADEP, Square D commenced pumping contaminated ground
water from one of the disposal wells. The Volatile Organic Compounds (VOCs) contamination in the
ground water was treated by an air-stripping tower. This air stripper was operated until 1989. In January
•
1989, a Site inspection was conducted at the Site on behalf of the USEPA. On July 29,1991, the Site
was proposed for placement on the National Priorities List (NPL) and then listed on October 4,1991.
An Administrative Order on Consent (AOC) to conduct a Remedial Investigation and Feasibility Study
(RI/FS) was executed between the USEPA and Square D and became effective on September 21,1992.
In September of 1992, EPA and Square D signed an Administrative Order by Consent (AOC).
Under this AOC, Square D was required to conduct remedial investigation and feasibility study (RI/FS)
activities. Before starting RI/FS activities, Square D was required to conduct a Well Survey
Investigation which included groundwater, soil and nearby stream sediment sampling. A Well Survey
report stated that ground water at the site was contaminated with VOCs that were moving off the
property. Under a second AOC signed in September 1994, Square D conducted a removal action at the
site and installed a GWTS. The system has been in full operation since August 1996.
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1
Community Relations History
EPA representatives traveled to the Site and conducted community interviews on June 3 and 4,
1997. The purpose of these interviews was to gauge residents' knowledge and concerns about the
Rodale Site. The findings from these interviews were released as part of the site Community Relations
Plan in January 1998, a document that describes EPA's strategy for addressing the community's site-
related concerns.
EPA distributed its first site fact sheet to the community in September 1997, providing
descriptions of the Superfund process, how the Site became a Superfund site, and how the ongoing
cleanup activities were progressing. To facilitate the continuing availability of site-related information
to the community, EPA announced the establishment of a site information repository in January 1998,
through a public notice that appeared in the January 19,1998 edition of the Allentown Morning Call. A
second fact sheet was distributed to the community in March 1998 to further advertise the new
information repository.
In November 1998, EPA distributed a third fact sheet and published a second public notice in the
Allentown Morning Call, inviting residents to a November 24,1998, public availability session. The
purpose of this availability session was to provide community members with an update on site cleanup
activities.
To maintain community involvement in the project and obtain public input on the newly released
Proposed Plan, EPA established a public comment period from June 20 to July 20,1999. On June 23,
1999, EPA held a public meeting on the Proposed Plan to provide residents with information on
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proposed cleanup alternatives. The meeting also provided residents with an opportunity to ask questions**
about or comment on the Site and EPA's proposed cleanup alternative.
Summary of Commentors' Major Issues and Concerns
This section provides a summary of commentors' major issues and concerns raised during the
public meeting and EPA's responses to those issues and concerns. Commentors may include local
homeowners, businesses, the municipality and PRPs. Major issues and concerns about the Proposed
Plan for the Site received during the public meeting on June 23,1999 and EPA's responses are presented
below:
1. How deep is the groundwater below the ground surface?
EPA Response: The depth of the aquifer extends hundreds of feet. The top of the water table is
approximately 60 feet below the ground surface.
2. At what depths is the groundwater most contaminated?
EPA Response; The site was contaminated by 4 injection wells, drilled to different depths. The deepest
injection well is approximately 400 feet. The shallowest area of contamination is probably in the
deepest part of the overburden, which is considered subsurface soil. The deepest area of contamination
is in the bedrock where the groundwater is, from approximately 60 feet below ground surface to 450
feet, and possibly deeper, due to the deeply fractured nature of the bedrock..
3. Was a groundwater flow model created for the design of the groundwater pump and treat
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1
system?
EPA Response: No, the system was modeled on water level elevation information from shallow,
intermediate and deep Wells. EPA drew a potentiometric surface for each of those levels and based the
range for the pumping system on the inward gradient at about 400 feet deep.
4. What is the nature of the hydrology at the site?
EPA Response: The bedrock is fractured, karstic limestone. There are some major, deep solution
channels - we believe there are some faults in the area. Consequently, there are some areas where
monitoring well yields exceed 300 gallons per minute and some which yield much less. There's a broad
spectrum of yields, indicating complex hydrogeology. EPA did not attempt to model the hydrogeology
because of this complexity.
5. Did EPA consider doing in situ, biological treatment?
EPA Response: Yes, in situ biological treatment was considered as part of the feasibility study.
However, because there are areas of pure, undissolved contaminant which tend to kill the organisms
used in biological treatment, EPA was not confident that this type of remedy would be successful.
6. Is there any concern for volatilization into basements?
EPA Response: No. The aquifer is deep and, more importantly, there is a 40-60 foot layer of clay-rich
overburden that prevents the VOCs from migrating upward through soil and into the air. This was
confirmed by ambient air monitoring in the vicinity of the Site which did not reveal any airborne
volatiles.
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1
7. When did EPA first find out about the contaminants onsite? Vv
EPA Response:' When Square D was operating the site, they uncovered a contaminated well in 1981. f
However, there is some documentation in PADEP files that indicates that Rodale Manufacturing was
disposing of some of their electroplating waste years earlier in onsite wells. Arrangements for Rodale to
begin disposal directly into the Borough of Emmaus sanitary sewer occurred between PADEP, the
Borough of Emmaus and Rodale from as early as 1967.
8. In what year did the Borough of Emmaus install air strippers on some of Rodale's wells?
EpA Response: EPA does not know exactly. PADEP representatives indicated that their information
reflects that this occurred in the 1970s and 1980s.
9. Have the onsite contaminant concentrations dropped considerably?
SPA Response: The onsite wells have shown high levels of contamination that have not dropped
considerably.
10. Will EPA conduct quarterly sampling?
EPA Response: EPA will determine the sampling schedule during the Remedial Design. The schedule
may start quarterly and then go down to semi annually. EPA will determine the schedule based on what
is necessary to ensure that levels are reducing as expected.
11. Is EPA conducting all the work?
SPA Response; No. To date, the owner of the Property, Square D Company, has conducted the response
activities at the Site. In addition, EPA clarifies this response by adding that EPA anticipates that Square
10
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1
D will enter into a judicially-enforceable Consent Decree, obligating it to fully develop and implement
all aspects of the proposed remedy.
12. How soon will EPA implement the Proposed Plan?
EPA Response: EPA responded to this question by explaining that after all the public comments have
been reviewed, EPA will prepare its Record of Decision, a legal document describing the cleanup
decision and responding to the public comments. Once the Record of Decision is issued, EPA and
Square D will begin the remedial design activities which are expected to take one year. During that
time, Square D will continue to operate the groundwater treatment system. By way of further
clarification, EPA modifies this response by adding that, it anticipates that it will enter into a judicially.
enforceable Consent Decree with Square D, which will obligate Square D to implement the proposed
remedy. Also, EPA typically enters into an Administrative Consent Order to commence Site remedial
design work immediately, while the Consent Decree for Remedial Action is lodged with the court for the
mandatory public comment period.
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