United States . Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/127
September 1991
Superfund
Record of Decision:
Dorney Road, PA
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REPORT DOCUMENTATION
PAGE
1. REPORT MO.
EPA/ROD/R03-91/127
X Inupmir* ACMMion NO.
SUPERFUND RECORD OF DECISION
~-»rney Road, PA
cond Remedial Action - Final
5. Report D*ta
09/30/91
a. Performing Orgmlatfon Rept No.
9. Performing Orgjfnixrton Nun* end
10. Pro|»ctrTMk/Woffe UnH No.
11. Conome^Q or O»ntIBty Suumm
19. Scanty dua (This Report)
20. Swwtty CUw (Thta P«g«)
21. No. ofP«gt«
74
22. Prlc*
(SM ANSIZ39.18)
SM Instruction* on AVWWM
(JrTlONAL FORM 272 (4*/7)
(Formerly NT1S-3S)
OcpuuiMfil ol Comnvra
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EPA/ROD/R03-91/127
Dorney Road, PA
Second Remedial Ac~ion - :inal
~tract (Continued)
capped, and onsite waste continues to be exposed in areas. Seepage of landfill wastes
is the principal source of onsite ground water contamination. A 1988 Record of
Decision (ROD) addressed Operable Unit 1 (OU1) and provided for elimination of onsite
ponded water; regrading and multi-layer capping of the site; installing run-on/off
controls, ground water monitoring; and implementing institutional controls including
~eed restrictions and' site access restrictions including perimeter fencing. In 1991,
EPAissued an Explanation of Significant Differences (ESD) for QUl requiring
mitigation of wetlands areas affected during cap construction. This ROD addresses
onsite ground water contamination as OU2, and provides a final remedy for the si:e.,
The primary contaminants of concern affecting the ground water are VOCs including
benzene and TCE; and metals including chromium and lead.
The selected remedial action for this site includes providing wellhead treatment using
carbon adsorption for the private wells ot affected residences, and ground water
~onitoring. The esti~ated presen~ worth cost for this remedial action is S274,040,
which includes an annual 8&M c~st of S14,410.
°SP.!:"IJP_"'!ANC::: ST;'~ID~?DS OP GOALS: ARAR waivers will be issued for State standards,
specifically those requiring remediation of onsite ground water to background levels
and remediation of offsite ground water to MCLs on the basis of technical
impracticability. In addition, data indicate that ground water contamination appears
to be naturally attenuating. Ground water action clean-up levels are based on ~CLS,
risk levels, and State standards, and include benzene 5 ug/l, TCE 5 ug/l, chromium
'00 ug/l, and lead 15 ug/l. .
-J
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RECORD OF DECISION
DORNEY ROAD LANDFILL
DECLARATION
Site Name and Location
Dorney Road Landfill Site
Operable Unit 2
Upper Macungie Township, Lehigh County, Pennsylvania
Statement of Basis and Purpose
This decision document presents the selected remedial action for
operable Unit 2 of the Dorney Road Landfill Site (the Site), in
Upper Macungie Township, Lehigh County, Pennsylvania, which was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. $9601 et seq.. and,
to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300.
This decision document explains the factual and legal basis for
selecting the remedy for this Site.
The Pennsylvania Department of Environmental Resources has not
concurred with the selected remedy at this time. The information
supporting this remedial action decision is contained in the
Administrative Record for this Site.
Assessment of the Sit*
Pursuant to duly delegated authority, I hereby determine, pursuant
to Section 106 of CERCLA, 42 U.S.C. Section 9606, that actual or
threatened releases of hazardous substances from this Site, as
discussed in the .^TrnnaT^y of site Risks, if not addressed by
implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
This Operable Unit is the second of two operable units for the
Site. In September 1988, EPA issued a ROD for Operable Unit 1 (OU
1). The ROD for OU 1 documented the selected remedy for the
landfill waste, and required a low permeability cap for the
landfill in accordance with the Pennsylvania Municipal Waste
Management Regulations. Other components, such as runon/runoff
controls, perimeter fencing, ground water monitoring, and deed
restrictions were required. In September 1991, EPA issued an
Explanation of Significant Differences with respect to that ROD,
requiring mitigation of the wetlands located on top of the
landfill.
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The remedy for OU 1 addressed the relatively low, long-term threat
posed by the landfill wastes. This ROD documents the remedy for
Operable unit 2 (OU 2), which foc~ses on the ground water, and
addresses the principal exposure pathway.
Because this remedy will result in contaminated materials
remaining on-site, a 5 year review pursuant to CERCLA, will be
required to monitor the effectiveness of this remedy.
The selected remedy includes the following major components:
.
Wellhead treatment units to be provided to
residences if levels of site-related contaminants
exceed action levels
.
Ground water monitoring.
Declaration of statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action or, a waiver can be justified for any Federal and state
applicable or relevant and appropriate requirements that will not
be met, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies, to the maximum extent practicable for this site, and
it satisfies the statutory preference for remedies that employ
treatment that reduce toxicity, mobility, or volume as their
principal element.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
~~
~dwin B. Erickson
egional Administrator
Region III
?~~(Z)-?/
Date .
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DBCISION SUMMARY POR THB RBCORD OP DBCISION
1.
site Name. Location. and Descriotion
The Dorney Road Landfill Site (the Site) is located in Upper
Macungie Township, Lehigh County, Pennsylvania, approximately
eight miles southwest of the city of Allentown, as shown on Figure
1. The Site lies one mile southwest of Breinigsville and 1.4
miles north-northwest of Mertztown along the west side of Dorney
Road. Access to Dorney Road from US Route 222 is south on
Mertztown Road to east on Trexler Road to south on Dorney Road.
The site consists of approximately 27 acres. A detailed Site
layout map is included as Figure 2. Agricultural land borders the
landfill to the north, west and south. Dorney Road forms the
eastern boundary of the landfill; agriculture land is also present
east of Dorney Road. The elevation of the landfill is 15-20 feet
greater than the adjacent agricultural property along the
southwestern, southern and southeastern borders. The difference
in elevation between the landfill surface and adjacent properties
is less pronounced along the northeastern, northern and
northwestern landfill borders where it ranges from 0-5 feet.
An area of the landfill along Dorney Road, which is level
with the road surface, has been used for dumping and currently
contains a large pile of debris. A residence was located in this
area during landfilling activities. Two areas of the landfill
appear to be currently or recently used for agricultural purposes.
These areas are located in the northeast corner and southwestern
area of the landfill.
The population of Lehigh County in 1980 was 272,349 with a
population projection of 287,883 by 1990. The population of Upper
Macungie Township in Lehigh County in 1980 was 7,446 with a
population projection of 8,831 by 1990. CUrrent population within
a quarter-mile radius of the Site is estimated at 20. At present,
only one residence is located within 1,000 feet of the site and
three other residences are located within 2,000 feet of the site.
Approximately 136,815 acres (or 62 percent) of Lehigh
County's total 223,313 acres are considered undeveloped or
agricultural land based on 1986 land use figures provided by the
Joint Planning Commission of Lehigh-Northampton counties. The
remaining acreage has been developed for residential, commercial,
industrial, wholesale and warehousing, transportation,
communication and utilities, public parks and recreation. Of the
15,847 acres available in Upper Macungie Township, 10,952 acres
(or 69 percent) are considered agricultural and vacant areas. The
remaining 4,895 acres (or 31 percent) are used for other purposes.
The area immediately surrounding the Site essentially
consists of rural residences and agricultural land. The local
area is zoned for agricultural/residential use and the Site is
completely surrounded by cultivated farmland where primarily feed
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corn is grown for dairy and beef cattle along with soybeans and
wheat for human consumption. A housing development has been
recently constructed approximately one mile east-southeast of the
Site. This development currently consists of ten homes.
Precipitation data over the past 50 years recorded at the
Allentown station indicates: maximum precipitation of 67.69
inches/year; average precipitation of 42.89 inches/year; maximum
monthly precipitation (August) 12.10 inches; and, minimum monthly
precipitation (May) 0.09 inches. Approximately 60 percent of the
average annual precipitation is lost to evapotranspiration and
approximately 40 percent or 17.16 inches/year is available for
surface runoff and ground water recharge.
The surface of most of the landfill is relatively flat with
elevations ranging from 450 to 470 feet above Mean Sea Level
(MSL). A topographic high (470 feet/msl) exists in the west-
central portion of the landfill.
Numerous ponds exist on-site; the largest are located in the
southwestern area of the landfill. The total area of ponded water
is approximately 1.5 acres. Wetlands occur throughout the Site.
predominantly in the north-central and southern areas of the site.
Wetland areas account for approximately 7 acres. Also observed
on-site are several leachate seeps.
An unpaved access road is located off Dorney Road at the
southern toe of the landfill. The access road trends west along
the southern border of the fill, turns north up the landfill slope
(approximately 20 feet elevation gradient) to the landfill
surface.
An intermittent snow fence lines portions of the southern and
eastern boundaries of the landfill adjacent to the access road and
Dorney Road. The fence diverges from the roadway to the north
forming the western boundary of the cultivated field in the
northeast corner of the landfill.
Areas on-site which are not covered by vegetation, wetlands,
or ponded water show a mix of soil cover and waste. Observed waste
consists predominantly of miscellaneous municipal waste and car
battery casings. Five monitoring wells are located on the
landfill. These wells serve as methane vents as evidenced by the
presence of strong odors in the vicinity of the wells throughout
the field investigation. The venting of methane in two of the
wells also serves to bring leachate to the surface. Corrosion of
the well protective casing is allowing this leachate to flow onto
the ground surface around the well.
Stressed vegetation and the absence of vegetation is evident
over the landfill and along its borders. Most noticeable are
lines of dead trees along the northwestern border of the landfill.
This area was reported to be trenched and backfilled with waste.
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The site is underlain by two carbonate units, with the
northern half of the site mapped as Allentown Formation and the
southern half of the site mapped as Epler Formation. The Epler
Formation is an interbedded, medium-gray limestone and dolomite
and the Allentown Formation is a gray dolomite to silty dolomite
with subordinate interbedded limestone, and occasional calcareous
sandstone, shales and chert. Fractured and weathered zones
commonly contain iron minerals, clay and quartz sands.
The depth to bedrock varies greatly across the site. Bedrock
was encountered as shallow as 7.5 feet below the ground surface at
monitoring well 4 (MW-4) and is deeper than 80 feet in the
vicinity of MW-8. Borings conducted in the northern portion of
the Site, in the Upper Cambrian Allentown Formation, indicate that
the dominant lithology is dolomite. The Allentown Formation was
primarily a medium to dark gray fine to very fine grained
crystalline dolomite.
The occurrence of limestone was not observed in any of the
borings. Some occurrences, however, of dolomitized limestone were
reported. This lack of limestone locally is not unexpected given
the composition of the ground water, the high degree of fracturing
observed and the proximity of the bedrock to the water table.
In all areas of the Site, except for the northwestern portion
in the immediate vicinity of MW-7S/7DR, the water table occurs in
the bedrock near or below the bedrock/overburden interface. The
effect the ground water has had on the bedrock. of both the Epler
and Allentown Formations is apparent throughout the site. The
occurrence of dissolutioning and precipitation (fracture filling)
of carbonate material was observed in every boring conducted at
the site. The most important effect of dissolutioning was
observed in the first 15-20 feet of bedrock below the water table.
In every boring where geophysical logging was conducted (MW-2D,
MW-3D, MW-4, MW-5D, MW-6, and MW-7D) , an interval with numerous
voids of bedrock was observed immediately below the water table.
The carbonate rocks of the Epler and Allentown Formations are
extensively fractured in the vicinity of the site. The fracturing
has been caused by thrusting associated with the Taconic Orogeny.
The majority of surficial soils in the Site area have been
mapped by the United states Department of Agriculture Soil
Conservation Service as Washington silt loam. The Washington silt
loam is characterized as deep, well-drained soils with a silt loam
surface and silty clay subsoil. The infiltration capacity of the
Washington silt loam is high, averaging 1.5 inches per hour. This
high infiltration rate results in soil that is favorable to
agriculture and results in significant recharge to the water
table.
The site lies within the Toad Creek watershed. Toad Creek is
located approximately 4,200 feet south of the Site, as shown on
Figure 3. Given the surface drainage pattern at the Site,
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however, it is likely that little, if any, run-off from the site
and surrounding areas actually reaches Toad Creek. There are no
perennial streams connecting the Site area to Toad Creek. As
stated above, the area soils have a relatively high infiltration
capacity and there are some sinkholes in the area. As a result,
most of the precipitation which falls on the site area either
infiltrates directly or collects in depressions and is later lost
to evaporation and/or infiltration (i.e., "negative drainage").
Evapotranspiration limits the amount of infiltration that actually
recharges the water table, and is probably greatest in cultivated
areas surrounding the site.
Toad Creek empties into the Little Lehigh Creek approximately
one mile east of the site. Little Lehigh Creek flows northward
toward Allentown, where the creek is used as a potable water
supply. The Little Lehigh Creek is protected as a Cold Water
Fishery and a High Quality River under Chapter 93 of the
Pennsylvania Water Quality standards. The Little Lehigh Creek
drainage basin is greater than 100 square miles and includes a
number of tributaries in addition to Toad Creek. Both Toad Creek
and Little Lehigh Creek occasionally go dry near the Berks-Lehigh
county lines due to loss of flow from channel infiltration. .
Surface water flow in the immediate vicinity of the Site is
controlled by the natural topography and man-made diversion
systems. Because the landfill is elevated above surrounding
fields, drainage (or run-off) is in a radial pattern away from the
landfill. Localized surface depressions to the northeast,
southeast, south, and southwest of the site receive much of the
run-off from the landfill. Discharge from these localized
depressions is mostly due to infiltration or evapotranspiration,
except during times of unusually heavy precipitation.
within the landfill area, the most prominent surface water
features are the ponds created during the 1986 Environmental
Protection Agency (EPA) removal action and the partially-
submerged, wetland areas in the north-central and southern
portions of the Site. The ponds are apparently filled with water
year-round, and therefore are sources of infiltration. The ponds
were constructed to limit the amount of direct run-off from the
site to surrounding agricultural fields and to restrict the run-
off that does occur to rip-rap lined channels on the northern and
southern perimeters of the Site. There is no apparent discharge
from the wetland areas via surface drainage indicating that these
areas are potentially significant sources of infiltration liquids
and thus landfill leachate.
2.
site Historv and Bnforceaent Activities
The site operated as an open pit iron mine prior to landfill
activities. The time period of mining operations is unknown.
From 1959 to 1966 the landfill operated as an open dump with waste
disposal occurring in the abandoned iron mine pit. Mr. Mabry,
owner of the landfill, was also the landfill operator from 1959 to
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1966. Harold E. Oswald, ~ho had worked as a landfill employee
.from 1959 to 1966, became the primary operator in 1966 and
remained so until the landfill c19sed. The landfill was utilized
primarily as a municipal waste dump, although disposal of
industrial wastes also occurred.
In a letter dated January 8, 1970, the pennsylvania state
Health Center notified Mr. Oswald that the landfilling operation
at the Site constituted a public health threat and required him to
compact the fill and apply cover to the site. A follow-up letter
on March 9, 1970, indicated that Mr. Oswald had not complied with
this directive.
Mr. Oswald applied for a landfill permit in a submittal dated
August 27, 1970. Although the application was never approved,
landfill operations continued until December 30, 1978. On
september 28, 1979, Mr. Edward Reeser of Whitehall, pennsylvania,
applied for a landfill permit to renew disposal operations at the
site, but the permit was not granted.
In June 1970, a representative from the Pennsylvania
Department of Environmental Resources (PADER, formerly the
Pennsylvania state Health center) visited the Site and noted the
approximate location of an on-site area used for the disposal of
sludge from a General Electric plant in Allentown, Pennsylvania.
According to PADER file reports, approximately 6 cubic yards of
the sludge were being disposed each day. General Electric
disposed of waste at the site from 1960 to 1978.
A letter dated November 15, 1972 from the Pennsylvania state
Health Center to Mr. Oswald noted the existence of battery casings
on-site. Notes taken by a state soil scientist during a site
visit on October 26, 1973 indicated that "several barrels of
petroleum products" were disposed of in a trench on the site. A
State memorandum dated september 14, 1976 listed the following
four wastes that had been placed in the landfill:
o
Approximately one-half of a pickup truck of sludge from
the General Electric plant.
Approximately 25 cubic yards of sludge from Reichard-
Coulston, Inc. of Bethlehem, Pennsylvania.
o
o
Deka batteries from Deka Battery, East Penn
Manufacturing, locat~d in Lyon Station, Pennsylvania.
Approximately 400 pounds per year of asbestos waste from
Atlas Mineral.
o
The site was listed on the National Priorities List (NPL) in
september 1984. A Cooperative Agreement was signed between EPA
and the PADER, and PADER became the lead agency for work in the
Remedial Investigation/Feasibility study (RI/FS) phase.
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From June 11 to June 20, 1986, an Emergency Removal
Action was pe~~ormed by the EPA Emergency Response Contractors
(ERCs), following a request from PACER. The work was performed by
ERCs with the general objective to regrade the site to collect and
contain on-site surface runoff. The construction of on-site ponds
allowed for controlled discharge of surface runoff via two major
spillways. Although a soil cover was applied to portions of the
site, the landfill had never been graded and capped, and waste
continues to be exposed in areas.
A Remedial Investigation, consisting of two phases, was
performed from January to June 1988.
Due to difficulties encountered during Phase I activities,
additional data needs were identified and investigative activities
proposed as a Phase II RI effort. Results of the RI were
presented in the Final Remedial Investigation Report for Operable
Unit 1 (OU 1) dated August 11, 1988. A Feasibility Study for OU
1, focusing on the landfill waste, was submitted in August 1988.
A Record of Decision was issued in September 1988 for OU 1 which
specifies the following components:
.
Elimination of on-site ponded water;
Regrading;
MUlti-layer capping;
Run-on/off controls;
Ground water monitoring;
Perimeter fencing; and
Deed notice.
.
.
.
.
.
.
Special Notice Letters were issued in September 1989. In
September 1990, EPA issued a Unilateral Administrative Order
(UAO), EPA Docket No. III-90-45-DC, to seven Potentially
Responsible Parties (PRPs) after the negotiations were
unsuccessful. A second UAO, EPA Docket No. III-91-26-DC, was
issued to an eighth Respondent on January 25, 1991. The Orders
require the PRPs to implement the remedy described in the ROD for
OU 1. The PRPs have begun to implement the remedy for OU 1.
On April 10,1991, EPA requested public comment on an
Explanation of Significant Differences (ESD) for the ROD for OU 1.
This ESD proposed mitigation for the wetlands located on top of
the landfill. These wetlands would be displaced during cap
construction. On September 18, 1991, EPA issued the ESD requiring
1:1 replacement of the wetlands at the site. This decision is .
incorporated into the work required under the UAOs.
The second RI/FS, performed by PACER from March to July 1991,
is focused on the ground water and was designed to fill the data
gaps identified in the previous study. Data generated during the
RI/FS for OU 2 supplements and/or replaces data generated during
the previous investigations.
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3.
Biqhliahts of community participation
With respect to the RIfFS Report and the Proposed Plan for
the Dorney Road Landfill site were released to the public for
comment on August 8, 1991. These two documents were made
available to the public in the Administrative Record and are
maintained at two information repositories: the EPA Docket Room in
Region III and the Upper Macungie Township Building. The notice
of availability for these two documents was published in the
Allentown Morning Call on August 8, 1991. A public comment period
on the documents was held from August 8 to September 6, 1991. In
addition, a public meeting was held on August 13, 1991. At this
meeting, representatives from EPA and PACER answered questions
about problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is in the Responsiveness Summary included as an attachment
to this ROD.
4.
Scope an4 Role of ODerable Unit or Response Action Within
site strateqy
As with many Superfund sites, the problems at the site are
complex. As a result, EPA has organized the remedial work into
two OUs. The OUs are:
OU 1:
OU 2:
Landfill Waste
Ground Water
The ROD for OU 1 addressed the source of the contamination,
and selected capping of the landfill as the method to control the
source of the contamination. OU 1 addressed the relatively low,
long-term threat caused by the unlined municipal landfill.
This ROD addresses the second planned remedial action at the
site. No principal threats, such as highly toxic or highly mobile
liquids, were identified at the Site. The principal exposure
pathway for OU 2 is through ingestion of ground water.
5.
SummarY of site Characteristics
Examination of boring and geophysical logs from previous site
investigations and observations made during the present
investigation reveal no preferred occurrence to the on-site
fracturing, either aerially or vertically. Fracture spacing
varies across the site from closely spaced (inches) to widely
spaced (2-3 feet). Three types of fracture fillings have been
observed: white carbonate material, orange-brown clayey material,
and a minor amount of silicious material.
The overburden is approximately 70 feet thick at MW-1D and
thins eastward to approximately 40 feet thick at MW-10S. The
landfill waste is contained within the overburden. The water
table exists within the overburden in areas of relatively thick
overburden (MW-1D) and in the bedrock where the overburden is
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relatively thin.
material.
The water table is not in contact with the waste
Ground water at the site occurs in the carbonate bedrock and
to a lesser extent in the overburden at the site. These units are
hydraulically connected and are considered to be part of a single,
unconfined to semi-unconfined aquifer system. The depth to ground
water is variable across the site and fluctuates significantly on
a seasonal basis.
Leachate occurs as a perched zone within the landfill waste
as documented by the landfill monitoring wells installed in
February 1988. A saturated zone is present across most of the
landfill at depths ranging from at or just below the ground
surface to 30 feet. This zone discharges along the southern,
southwestern, and southeastern perimeter of the landfill as
manifested by leachate seeps in these areas.
Ground water in the vicinity of the Site is the principal
source of potable water for local residents. Hand-dug overburden
wells have been used in the past but have largely been abandoned
in favor of drilled bedrock wells. All of the residential wells
currently in use in this area obtain water from the carbonate
bedrock. Completion data are not available, but most wells are
reportedly less than 200 feet deep. Because it is currently
utilized as a source of drinking water for local residents, the
bedrock-overburden aquifer at the site would be classified as a
Class II-A aquifer using the EPA Ground Water Protection Strategy.
A Class II-A Aquifer is recognized as having significant resource
value and therefore should be protected to ensure its maximum
beneficial use.
The bedrock aquifer at the site consists of fractured
dolomite that has been weathered to varying degrees by solution
processes associated with percolating infiltration liquids and
ground water. The ground water flow in this aquifer is restricted
to the enlarged fractures and void spaces (i.e., secondary
porosity) created by these solution processes; the primary
porosity (and permeability) of the bedrock is essentially
negligible. Fractures are present throughout the upper 100 feet
of bedrock at the Site with no apparent trends with regard to size
or distribution. Voids in the rock were generally more numerous
and larger in the 20-30 feet of bedrock immediately below the
water table. Voids ranged in size from a few inches to several
feet and were typically associated with relatively significant
water-producing zones. Fractures, occurring individually or in
intervals of highly fractured rock, also produced water except
where clay (i.e., weathered rock) or secondary cement had refilled
them. Estimates of yields from the fractures and voids, as noted
in the boring logs, ranged from negligible to 100 gallons per
minute (gpm), with an average yield of 15 gpm.
All of the monitoring well borings at the site encountered a
significant number of voids greater than 1 foot wide, particularly
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within the upper 50 feet of bedrock (but still within 100 feet of
land surface).
The results of the pump tests indicate that there is a high
degree of anisotropy within the aquifer. The cause of this
anisotropy may be related to the geology of the aquifer (i.e.,
Epler or Allentown Formations) but is more likely controlled by
the size, distribution and interconnection of fractures
intercepted by the wells. Because of this anisotropy, well yields
can vary significantly depending on location and completion depth.
The home wells (Figure 5) are also dominated by calcium,
magnesium and bicarbonate. In general, the ground water chemistry
is very similar between home and monitoring wells; however, the
home wells have slightly less magnesium and only one well (HW-06
located east of the Site) had elevated levels of sOdium/potassium.
Monitoring wells for OU 2 are shown on Figure 4.
The close correlation between the ionic composition of the
ground water from home wells with that obtained from the site
monitoring wells has two major implications. The first is that it
indicates all of the wells that were sampled are most likely
screened or completed in the same aquifer. A variation in the
chemical composition of water samples from these two types of
wells would have suggested separate aquifers and more importantly,
that monitoring wells were not installed so as to facilitate
detection of contaminants migrating toward the home wells.
The second implication regards the general absence of
significant impacts caused by the landfill on the ground water
geochemistry in all wells. Typical municipal waste landfill
leachate is enriched in chloride, nitrate, and sulfate. None of
these constituents are more than slightly elevated in any of the
Site monitoring wells, even in wells with elevated levels of
volatile organics and/or other site-related contaminants. The
reason for the absence of these anionic constituents is not
readily apparent but may be due to an unusual leachate composition
or to attenuation processes occurring in the soil matrix or
residuum that act to reduce the anionic concentrations (e.g.,
anion exchange, complexation, oxidation/ reduction).
The direction of regional ground water flow in the bedrock-
overburden aquifer is generally from the northwest to the
southeast. This regional gradient is disrupted beneath the site
by the presence of a prominent mound on the potentiometric
surface. The mound, most likely caused by enhanced recharge from
the landfili, is elongate with a southwest/northeast trend. This
mounding causes nearly radial flow to occur in the northern
portion of the Site, while in the southern portion of the site,
where less mounding of ground water is observed, flow generally
follows the regional trend to the southeast.
On the northwestern flank of the mound, the direction of the
ground water flow in the bedrock is to the north-northwest off the
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r
mound and then becomes more easterly north of the site. In the
vicinity of monitorinq wells MW-4, the North Well, and MW-9S/9D
qround water flow off the nose of the mound is primarily to the
northeast. Flow from the southern flank of the mound follows the
reqional trend to the southeast.
The water table occurs in the bedrock (or near the
bedrock/overburden interface) over most of the Site. In the
northwestern portion of the Site, however, near monitorinq wells
MW-7S, MW-70R, and MW-8, the water table occurs in the overburden.
Apparently, qround water flow in the overburden is not affected by
the moundinq observed in the bedrock and follows the reqional
trend to the southeast.
These results indicate that the qround water seepaqe
velocities at the site vary over a wide ranqe but are probably
close to the median ranqe of 25-100 ft/yr.
The landfill wastes are the principal sources of qround water
contamination detected at the Site. The operatinq history of the
landfill indicates that the wastes disposed of in the facility
included municipal solid waste, industrial wastewater treatment
plant sludqes, batteries, petroleum products, and solvents. The
absence of a low-permeability cap or cover on the landfill
facilitates the qeneration of an estimated 7.3 million qallons of
leachate per year due to percolation of infiltration liquids
throuqh these waste materials. This leachate is able to seep
throuqh the base of the landfill and eventually reaches the water
table because there is no impermeable liner beneath the waste.
Ground water samples from the site were collected in May
1988, May 1990, and June 1990. The followinq discussion of qround
water contamination at the site focuses on the last two rounds of
samplinq (May and June, 1990), but includes previous data
collected in 1988 as needed to discuss chanqes in conditions and
plume miqration. To enhance the contaminant interpretation,
qround water samplinq results have been qrouped accordinq to their
relative location in reqard to the landfill. The qroups consist
of the northern samplinq points which include: qround water
samples collected from monitorinq wells 4, 7S, 70R, 8, 9S, 90, the
North Well and home well 3; the eastern samplinq points which
include: qroundwater samples collected from monitorinq wells 2S,
20R, 35, 3DR, 105, 100, 11S, 110 and home wells 1, 4, 5 and 6; and
the southern samplinq points which include: qround water samples
collected from monitorinq wells 55, 50, 6S, 60, the South Well and
home well 2.
Northern Area
A summary of the analyses for the northern area wells are
presented in Table 1.
Orqanic contamination in qround water north of the 5ite is
limited to low levels of volatile orqanic compounds (VOCs) in
10
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several wells along the landfill perimeter. The largest number
and highest concentrations of VOCs were detected in samples
collected from MW-8. The contamination detected in MW-8 can be
attributed to its location on the border of the landfill.
Trenches were reportedly excavated along the landfill boundary
trending north and west from MW-8. Waste was placed in the trench
and backfilled. Evidence of this activity is noticeable in the
topography along the borders and the damage to vegetation in the
area.
Ground water quality to the north of the site has been
impacted to a greater extent by inorganic contamination. Numerous
inorganic constituents were detected above background in both
filtered and unfiltered samples from this area. Of the chemicals
of concern (COCs), only manganese and mercury were found in
concentrations above background. In the majority of northern area
wells, the bulk of the inorganic contamination was comprised of
constituents that are not chemicals of concern. These include
barium, cobalt, nickel, potassium and sodium. This latter group
of chemicals, while not relevant to the Public Health Evaluation,
is important as an indicator of landfill-related impacts on ground
water quality.
The presence of these inorganic indicators confirm the
finding based on the manganese and VOC data that landfill-related
contamination has migrated into the northern monitoring wells.
The greatest amount of contamination (dissolved) was found in the
two overburden wells, MW-8 and MW-7S. Levels of contamination
were generally lower in the North Well and MW-4 and even less but
still detectable in MW-9S/9D. Bedrock well 7D contained the least
amount of contamination of the northern monitoring wells.
contamination has not reached the residential well north of the
site.
These results indicate a decreasing concentration gradient
from west to east. Given the inferred pattern of ground water
flow, this gradient is most likely a function of source location,
in this case indicating a source of inorganic contamination near
MW-8. Inorganic, site-related contamination has not reached the
residential well north of the site (HW-03) but may eventually
reach this well because of the localized northward component of
ground water flow caused by the mounding of the potentiometric
surface beneath the landfill.
Eastern Area
A summary of the analyses for the eastern area wells are
presented in Table 2.
Both the 1988 and 1990 sampling results indicate that a plume
of volatile organic contamination is migrating eastward from the
site. Detection of 1,2-dichloroethene in monitoring wells 2S (99
~g/l), 11D (13 ~g/l), HW-01 (18 ~g/l) and HW-05 (4 ~g/l) indicate
that the plume has migrated a significant distance eastward, at
11
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1-
least as far as residential well HW-05. Well HW-05 is located a
distance of approximately 5,000 feet east of the eastern perimeter
of the landfill. Evidently, the contamination is entering the
upper part of the aquifer near MW-2S and migrating both laterally
(eastward) and vertically (downward) in response to prevailing
hydraulic gradients in this area. The plume is being attenuated
and diluted, as indicated by significant decreases in
concentrations of total VOCs with increasing distance from the
landfill/source area. In addition, concentrations have decreased
between the 1988 and 1990 sampling events (based on two rounds of
sampling in 1990), suggesting a gradual depletion of source
material (i.e., concentrations of volatile organics in the
landfill leachate are decreasing over time).
Concentrations of inorganics in the total metal sample should
be discounted due to the significant discrepancy between filtered
and unfiltered results. Consequently, only the dissolved
inorganics data are of use in evaluating inorganic contamination
in the eastern area. Dissolved inorganics above background are
generally limited to three wells on the eastern perimeter of the
landfill: MW-2S, MW-2DR and MW-3S. Of the COCs, only chromium and
mercury were detected above background. The detection of cadmium
in MW-10D (estimated at 7 ~g/l) should be considered not reliable
because it was not detected in the second round of sampling. In
addition, there were not any other dissolved inorganics above
background in MW-10D for either set of sampling results. Samples
from MW-2S, MW-2DR and MW-3S also contained elevated
concentrations of several inorganics identified as indicators of
landfill-related contamination: barium, potassium and sodiUm.
The presence of selected COCs and landfill indicators in
these wells supports the conclusion that eastward migration of
inorganic contamination is occurring in the upper 20 feet of the
aquifer (and bedrock) near MW-3S/3DR and across a deeper section
(upper 50 feet) at MW-2S/2DR. Evidently, this inorganic
contamination is being attenuated prior to its arrival at MW-
10S/10D and MW-11S/11D. This trend is consistent with conclusions
based on the past and current distribution of VOCs.
Southern Area
A summary of the analyses for the southern area wells are
presented in Table 3.
Ground water in the southern area is contaminated with
several volatile COCs. The highest concentrations of VOCs were
detected in ground water sampled from the South Well, which is
situated on the landfill border. The magnitude of contamination
was significantly lower in well cluster MW-5S/5D, which is located
50 feet west of the South Well (also on the landfill border).
This discrepancy in contaminant concentrations is a characteristic
of fractured rock aquifers and in this case illustrates the lack
of interconnection between the fracture zones intercepted by these
nearly adjacent wells. The concentration and number of
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contaminants migrating to the south decreases significantly with
horizontal distance from the landfill. contaminants appear to be
moving downward in the aquifer as demonstrated by the detection of
VOCs in MW-6D, but not MW-6S.
Inorganics data from the southern wells indicate only minimal
impacts due to migration of inorganic contamination from the
landfill. The high concentrations of inorganic constituents
detected in unfiltered samples can be attributed to suspended
sediment in the samples, as indicated by the significantly lower
concentrations in the filtered samples.
6.
Summary of site Risks
The exposure pathways that will be addressed in this pUblic
health evaluation are the ingestion of contaminants in ground
water and the inhalation of volatile organic compounds in ground
water while showering. The assumptions utilized to develop
exposure concentrations and the results of the risk evaluation are
presented below for both current use and future use exposure
scenarios. Table 4 shows a summary of the organic chemicals
detected in the ground water, and Table 5 shows the inorganic
chemicals detected in the filtered ground water. Table 6 presents
a summary of the chemical-specific Applicable or Relevant and
Appropriate Requirements (ARARs) exceeded at the Site.
The current population within a quarter mile radius of the
site is estimated at 20. At present, only one residence is
located within 1,000 feet of the site and three other residence
are located within 2,000 feet of the site. The only commercial
establishments located in the vicinity of the site are a post
office located in Breinigsville and two gas stations, one of which
is located approximately one mile north-northeast of the site and
the other is located approximately 1.5 miles north-northwest of
the site. The nearest school is Longswamp Elementary School,
which is located approximately 1.7 miles due south of the Site,
near Mertztown. The population of Upper Macungie Township in 1990
was 8,717 based on the results of the 1990 census.
The nearest residential drinking water wells are: HW-01,
located approximately 2,000 feet east of the Site, HW-02 located
approximately 1,000 feet south of the site and HW-03 located
approximately 1,000 feet north-northwest of the Site. HW-04 is
located approximately a half mile east of the Site, while HW-05
and HW-06 are located approximately one mile east of the site in
the Pheasant Meadows Development. The development consists of ten
residences with on-lot water supply wells. In June 1991 a second
round of residential well sampling was conducted. HW-01 through
HW-06 were re-sampled and two additional wells were included from
the Pheasant Meadows development, The results did not vary
significantly from the first round results." Therefore, the Risk
Assessment did not require revisions. The residential wells
sampled are identified on Figure 5.
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In order to quantitatively evaluate the risk from exposure to
chemicals detected in qround water at the Site, the population was
divided into four subgroups: children aqed 0-5 years; children
aged 6-11 years; children aged 12-17 years; and adults aged 18-30
years. Only individuals aqed 0-30 years have been considered in
this risk evaluation because 30 years represents the national
upper bound time (90th percentile) for an individual to remain at
one residence.
Excosure Assessment
The qoal of the Exposure Assessment is to determine the type
and maqnitude of human exposure to the contamination present at,
and miqratinq from, the site in the qround water. Since the site
is located in a primarily rural settinq, all residents in the
immediate vicinity of the site rely on qround water for drinking
water, cookinq, showerinq, etc. Durinq the RI, six residential
wells were sampled and analyzed for VOCs and total metals. One
monitorinq well, MW-2S, was also analyzed for semi-volatile
orqanic compounds althouqh none were detected. Both current and
future exposure scenarios were examined, and the exposures
assumptions used are shown in Table 7.
The most siqnificant of the three exposure routes is the
inqestion of the contaminants in ground water. These contaminants
upon enterinq the qastrointestinal tract are readily absorbed
throuqh the stomach and intestinal walls. The second most
siqnificant potential exposure route is the inhalation of VOCs
while showerinq. Althouqh inorqanic chemicals are not expected to
be released to the atmosphere while showerinq, the combination of
the hiqh showerinq water temperature and aqitation of the
showerinq water is expected to allow any VOCs (boilinq point less
than 145°C) to be released to the atmosphere where they may be
inhaled. Once inhaled, these compounds may directly enter the
bloodstream durinq the exchanqe of oxyqen and carbon dioxide with
blood. The dermal absorption of VOCs while bathinq or washinq is
expected to be neqliqible in comparison to exposures resultinq
from inqestion and showerinq. In addition, the lack of permeation
constants for VOCs hinders the quantitative assessment of the
dermal exposure route. Other potential exposure routes, the
dermal absorption of contaminants and the inhalation of VOCs while
cookinq, are not expected to be siqnificant and therefore were not
addressed further in this Public Health Evaluation.
Therefore, the exposure routes considered in this Public
Health Evaluation are ground water inqestion and the inhalation of
volatiles while showerinq.
The current exposure scenario was based on the results of the
residential well samplinq. HW-01 was found to contain the hiqhest
level of volatile orqanic compounds (VOCs)." Other residential
wells that were found to contain VOCs were HW-04 and HW-05. HW-04
was found to contain 5 ~q/l of chloroform which does not appear to
be Site-related since elevated levels of chloroform were not
14
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detected in on-site monitoring wells. HW-05 was found to contain
4 ~g/l of total 1,2-dichloroethene. In accordance with EPA policy
of "reasonable maximum exposure" only results from HW-01 were
utilized in the current use exposure scenario.
As stated earlier, in order to quantitatively evaluate the
risk from exposure to chemicals detected in ground water at the
Site, the exposed population was divided into four sub-groups. In
accordance with the assumption of reasonable maximum exposure, it
has been assumed that a resident will reside at the same residence
from birth to age 30. This assumption was based on the fact that
exposure levels for children are generally more significant due to
reduced body weight (among other factors) and because they
represent a sensitive segment of the population with respect to
chemical exposure.
In order to calculate exposure concentrations for use in
assessing potential risk to ingestion of ground water COCs in the
study area, (expressed in mg per kg-day), it was assumed that
children aged 0-11 ingest 1.0 liter of ground water per day
(l/day) while children aged 12-17 and adults ingest 2 l/day.
Although EPA has historically utilized a water consumption of 2
l/day for adults and 1 l/day for infants (individuals of 10 kg
body weight or less), the 1 l/day rate has been applied to all
children aged less than 12 years. This assumption of reduced
water consumption was based on studies which have shown that the
intake rate of 2 l/day represents an overestimate for adults and
grossly overestimates the intake rate for children. pennington
has estimated an average adult consumption rate of 1.2 l/day. For
children the following average water and water based foods daily
consumption rates were estimated: children 6-11 months, 0.201
liters; children 2 years, 0.499 liters; children 14-16 years,
0.746 liters. Based on this data, the estimate of a ground water
consumption rate of 1 l/day for younger children still represents
a reasonable maximum exposure level.
In determining the reasonable maximum exposure concentration,
it is assumed that children aged less than 12 years ingest 1 l/day
of water, 365 days per year, averaged over the duration of the
exposure period. For non-carcinogens, a daily exposure rate
averaged over a year for the duration of the exposure period is
assumed. For carcinogens, a daily exposure rate averaged over 30
years (90th percentile for a resident residing at the same
residence), over a lifetime of 70 years is assumed. Averaging
over a lifetime of 70 years is performed because CPFs are
developed based on a lifetime of exposure.
For deriving the reasonable maximum exposure concentration
for use in assessing risk due to inhalation of VOCs while
showering, it is assumed that adults and children aged greater
than 12 years inhale at a rate of 0.6m3/hour, and take a 12 minute
shower (90th percentile) each day. A simple model is employed to
determine the concentration of VOCs in air using contaminated
levels in ground water. All other exposure parameters remain the
15
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same as previously stated. Children less than aged 6 are assumed
not to shower. As stated previously, in accordance with EPA
policy of "reasonable maximum exposure", only results from HW-Ol
were utilized in current use exposure scenarios.
Future use exposure scenarios have been developed from ground
water concentrations detected in downgradient monitoring wells.
Based on results of the hydrogeologic study performed at the Site,
ground water appears to flow radially from the landfill along the
northern, eastern and southern boundaries, then travels in a
generally east-southeast direction. Since the installation of a
cap over the landfill precludes the use of on-site ground water
for residential usage, the monitoring wells selected for
evaluation are the downgradient perimeter wells (MW-4, North Well,
MW-9S, MW-9D, MW-3S, MW-3DR, MW-2S and MW-2DR) and the wells
located further downgradient to the south and east of the Dorney
Road landfill (MW-6S, MW-6D, MW-10S, MW-10D, MW-11S and MW-11D).
Toxicity Assessment
The Toxicity Assessment of the COCs selected for the Site was
conducted to identify relevant carcinogenic potency factors and/or
chronic reference doses against which exposure point intakes could
be compared in the risk characterization of the site. COCs are
those chemicals which are the most toxic, prevalent, persistent,
mobile, and which contribute the major risks at the site. These
COCs are identified in Tables 4 and 5.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs are upper bound numbers derived from the results
of human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation have been applied. CPFs,
which are expressed in units of (mg/kg-day)-l, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-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 CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects. RfDs are
derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for
the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur. RfDs, which are expressed in units of mg/kg-day, are
estimates of lifetime daily exposure levels for humans, including
sensitive individuals, that are not likely to be without an
appreciable risk of adverse health effects. Estimated intakes of
16
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chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the
RfD. An RfD is used as a reference point for accessing the
potential effects of exposure to a contaminant.
The toxicological criteria for the COCs at the site are shown
in Table 8.
Risk Assessment
Excess lifetime cancer risks are determined by multiplying
the intake level (the reasonable maximum exposure concentration
discussed previously), with the CPFs. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1X10-6 or 1E-6). An excess lifetime cancer risk of 1x10-6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose. By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated.
The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media.
Sample results from HW-01 were used to determine current
risks. In order to determine the lifetime cancer risk due to
exposure to chemicals detected in HW-01, the daily lifetime upper
bound exposure rate is multiplied by the CPF or slope factor.
This calculation is performed for each age group. The results for
each age group when summed are to determine a lifetime cancer risk
based on a 30-year exposure duration averaged over a 70 year
lifetime. A 70 year lifetime exposure is input into this
calculation because carcinogenic slope factors are generally
derived from long-term animal studies representing a lifetime.
Carcinogenic slope factors are presented in Tables 9, 10, 13 and
14.
Chemical concentrations used in the risk assessment were
obtained by calculating the 95th percentile Upper Confidence Level
(UCL) of the average concentrations for each chemical. A total of
14 sample results were utilized in calculating the 95th percentile
UCL. In order to evaluate non-detected results, separate
approaches were developed for organic and inorganic chemicals.
For organic chemicals, a concentration of one-half the
laboratory's reported detection limit of 3 ~g/l was utilized.
However, it should be noted that some results below the
laboratory's reported detection limit were found during the
17
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validation process. For inorganic chemicals, a result of one-half
the reported instrument detection limit (IDL) was used.
In order to evaluate potential risks to human health from
inorganic chemicals, dissolved metal results obtained from
filtered samples were utilized rather than total metal results.
This is in accordance with EPA Region III policy. Dissolved metal
results are used instead of total metal results because dissolved
metal results are expected to more accurately represent the
concentration of metals present in an active residential well.
Due to the lack of an available RfD and/or CPF for lead, the
potential future impacts on human health due to lead exposure have
been evaluated separately. In order to determine the potential
for non-carcinogenic adverse health effects at the Site, the 95th
percentile lead concentration was estimated at 9.65 ~g/l which is
below EPA's suggested action level for lead of 15 ~g/l in ground
water. Although lead was detected in one well (MW-3S) at a
concentration exceeding the EPA action level of 15 ~g/l, a second
ground water sample collected from MW-3S failed to reveal elevated
lead levels. Consequently, the potential for adverse health
effects due to lead exposure is expected to be negligible.
The only known or suspected human carcinogens detected in HW-
01 were trichloroethene and tetrachloroethene. Both these
compounds are Class B2 or probable human carcinogens. Table 9
presents a summary of the cancer risk due ~o the ingestion of
ground water from HW-01. The lifetime cancer risk from ingestion
for all age groups is 6.43x10-6 with the majority of the risk
being contributed by the 0-5 year age group and the 6-11 year
group. This is due to the reduced body weight of young children.
The lifetime cancer risk resulting from the inhalation of
trichloroethene and tetrachloroethene while showering, as shown in
Table 10, is 4.95x10-6. In this instance, the majority of the
risk is contributed by the adult age group due to the increased
length of exposure. Inhalation exposures have not been calculated
for the 0-5 year age group since they are not expected to shower.
Based on this risk evaluation, the total lifetime cancer
resulting from 30 years of exposure to contaminants detected in
ground water collected from HW-01 is 1.14x10-s or one additional
cancer related death out of a population of 88,000. This level of
risk lies within the EPA range for evaluating risk of lX10-4 to
lxlO-6. It should be noted that this risk level is based on an
assumption of reasonable maximum exposure. In other words, this
risk level is the maximum risk that is reasonably expected to
occur. Actual risks resulting from exposure to contaminants
detected in HW-Ol may be much less for the general population.
In order to evaluate risks due to exposure to non-
carcinogens, the daily exposure rate is compared to the chronic
reference dose. If the chronic reference dose is exceeded, then
the potential for adverse health effects exists. The comparison
between exposure levels and chronic reference doses is represented
18
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mathematically by dividing the pollutant intake by the reference
dose. If this ratio (known as the hazard quotient) exceeds 1.0,
the reference dose has been exceeded and the potential for adverse
health effects exists. The only two chemicals detected in HW-01
at levels above background for which non-carcinogenic toxicity
data exist are 1,2-dichloroethene and tetrachloroethene. (Note
that tetrachloroethene has been evaluated for both carcinogenic
and non-carcinogenic effects.) Hazard quotients were calculated
for each chemical in all four age groups and then were summed
within each age group to arrive at a hazard index. The highest
calculated hazard index for the ingestion of chemicals detected in
HW-01 among the various age groups was for the 0-5 year age group.
A hazard index of 9.66X10-2 was calculated. Although this hazard
index is approximately twice that of any other age group, it is
still more than an order of magnitude below the EPA guidance level
of 1.0. For the inhalation pathway the highest hazard index was
calculated for the 6-11 rear age group. The 6-11 year age group
hazard index of 2.75x10- exceeded that of the other age groups
due to an increased inhalation rate. The highest hazard index for
inhalation and ingestion combined was 0.37 for the 6-11 year age
group. This exceeded the hazard index for the other age groups
which had combined inhalation and ingestion hazard indices ranging
from 0.11-0.18. However, the combined inhalation and ingestion
results for the 6-11 year age group is still below 1.0 and thus no
adverse health effects due to non-carcinogens are expected to
occur as a result of chemicals detected in HW-01. Tables 11 and
12 present a summary of the non-carcinogenic risks.
Results for the future use consumption of ground water are
presented in Tables 13 through 16. Table 13 presents a summary of
the potential carcinogenic risks which may result from the
ingestion of downgradient ground water. Under future exposure
scenarios, the lifetime cancer risk due to ingestion based on 30
years of exposure (from birth to age 30) is estimated at 1.22X10-4
which is slightly outside the EPA range for evaluating
carcinogenic risks of 1X10-4 to 1X10-o. The majority of the risk
is being contributed by the presence of vinyl chloride. Although
the 95 percent UCL concentration of vinyl chloride is only 2.21
~g/l, it has been classified as a Class A or known human
carcinogen and has a relatively high oral carcinogenic slope
factor (the carcinogenic slope factor is a measure of a chemical's
ability to induce cancer and is derived from animal and/or
epidemiological studies). The cancer risk due to vinyl chloride
contributes 65 percent of the total cancer risk which may result
from the future use ingestion of downgradient ground water.
Another 12 percent of the total lifetime cancer risk due to ground
water ingestion is contributed by carbon tetrachloride while 1,1-
dichloroethane (9 percent) and tetrachloroethane (5 percent)
account for the remainder of the total cancer risk.
The lifetime cancer risk for future exposure due to the
inhalation of volatiles while showering is estimated to be
6.46x10-s with carbon tetrachloride contributing the majority
(approximately 30 percent) of the total cancer risk. Vinyl
19
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chloride contributes approximately 25 percent of the total risk
due to volatile inhalation while trichloroethene and 1,2-
dichloroethane contribute the majority of the remainder. Based on
future use ground water ingestion and the inhalation of volatiles
while showering, a total lifetime cancer risk of 1.65X10-4 has
been estimated, or one additional cancer related death out of an
exposed population of 6,100. This result is slightly outside
EPA's lifetime cancer risk range for evaluating carcinogens of
1x10-4 to 1X10-6. However, it should be noted that this estimate
is based on a reasonable maximum exposure scenario which is the
highest exposure concentration reasonably expected to occur.
In addition to potential risks to human health resulting from
exposure to known or suspected human carcinogens, potential non-
carcinogenic risks have also been evaluated for future use.
exposure to downgradient ground water. Although hazard indices
have been estimated for each age group, only the most sensitive
age group needs to be evaluated. For the future use ingestion of
downgradient ground water, the hazard index for the 0-5 year age
group is estimated to be 1.24. This value is approximately equal
to the EPA guidance value for evaluating non-carcinogens of 1.0.
Hazard indices for all other age groups ranged from 0.50 to 1.18. .
The majority of the total hazard index for each age group is
contributed by carbon tetrachloride (approximately 44 percent) and
cadmium (approximately 26 percent) with the remainder being
contributed almost equally by 1,2-dichloroethene,
tetrachloroethene and chromium.
For non-carcinogenic effects which may result from future use
inhalation of volatiles while showering, the 6-11 year old age
group is the most sensitive. This is due to a slightly higher
i~alation rate and an increased showering frequency for 6-11 year
olds over other age groups. The calculated hazard index for 6-11
year olds is 1.65 which is slightly higher than the EPA guidance
level for evaluating non-carcinogenic risks (1.0). The hazard
indices for the adult age group and the 12-17 year old age group
were 0.42 and 0.54 respectively, both of which are slightly below
the EPA guidance level of 1.0. Hazard indices based on a combined
exposure due to ground water ingestion and volatile inhalation
exceeded 1.0 for all age groups. Combined hazard indices ranged
from 0.92 to 2.83 with the most sensitive group being the 6-11
year age group. .
Environmental Assessment
An environmental assessment was not done for OU 2, because
there is no documented discharge of the ground water to the
surface or to any bodies of surface water. An environmental
assessment was done during OU 1.
Uncertaintv in the Risk Characterization
In order to quantitatively estimate the potential risks to
human health which may occur as a result of exposure to
20
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contaminants detected in ground water at the Site, numerous
assumptions regarding exposure parameters were required. Within
each exposure parameter there is an inherent level of uncertainty.
For example, although 71.8 kilograms of body weight was used as
the mean weight for the entire population, actual body weights
vary over a broad range. Other uncertainties include ground water
ingestion rates, inhalations rates, exposure frequencies,
showering parameters, analytic results and toxicity numbers.
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 public health, welfare, or the environment.
7.
DescriDtion of Alternatives
Alternative 1 - No Action
This alternative is considered in the detailed analysis as a
baseline to which the other remedial alternatives can be compared.
The no action alternative involves taking no further action at the
site to remove, remediate, or contain contaminated ground water.
A program of quarterly ground water monitoring would be conducted
to monitor future trends with regard to plume migration and the
effects of natural attenuation processes with time. This program
would include sampling of approximately five residential wells in
addition to the four monitoring wells to be monitored pursuant to
the 1988 ROD for OU 1. Because this alternative would result in
contaminated ground water and hazardous substances remaining on-
site, five-year reviews, pursuant to the Comprehensive,
Environmental Response, Compensation and Liability Act (CERCLA),
would be required to monitor the effectiveness of this
alternative.
Ground water monitoring samples would be analyzed for the
Target compound List (TCL) volatiles and Target Analyte List
metals. Residential well water should be analyzed by an
appropriate EPA 500 series drinking water test method, or an
equivalent method. This monitoring program may be modified by
EPA, as needed in such areas as number of wells, location of
wells, frequency of sampling, and analYtical parameters.
This alternative would not meet the Maximum contaminant
Levels (MCLs), non-zero Maximum contaminant Level Goals (MCLGs),
EPA Health Advisory levels, or risk-based action levels, based on
the RfDs and CPFs, for the ground water contaminants. There are
no action-specific ARARs associated with Alternative 1.
The estimated capital cost of this alternative is $ 0, with
Operation and Maintenance (0 & M) costs estimated to be $14,160
annually and $32,536 every five years. The present worth of this
remedy is estimated at $268,796. Implementation time is estimated
to be negligible.
21
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Alternative 2 - Alternate Water Succlv
This alternative includes the provision of bottled water
service for affected residences. Bottled water service would be
supplied to residences where exposure to contaminated ground water
of site-related contaminants exceed MCLs or would result in a
present excess cancer risk of greater than 1x10-4 or where the
H.I. is greater than 1.0. Based on sampling results from
residential wells conducted during the RI, VOCs were detected in
ground water samples from HW-01, HW-04, HW-05, HW-07 and HW-08.
Of these residential wells, only HW-01 has in the past had
contaminant concentrations at levels which would result in an
excess cancer risk of greater than 1x10-4 or are above MCLs.
since this is the only residence in the study area at risk, under
this alternative, bottled water would be supplied as an alternate
potable water supply to this residence. Ground water would
continue to be used for showering and other aesthetic purposes;
however, the risk resulting from the inhalation of VOCs while
showering is less than 1x10-4. While sampling to date has
indicated that contaminant levels have begun to decrease with
time, the contaminant plume at the site continues to migrate
primarily in the east-southeast direction. For this reason,
bottled water service may be offered to additional residences in
the future. For cost estimating purposes, however, it was assumed
that bottled water will be supplied to only one residence.
A ground water monitoring program as described in Alternative
1 would be conducted as part of this alternative.
This alternative would not meet the MCLs, non-zero MCLGs, EPA
Health Advisory levels, or risk-based action levels, based on the
RfDs and CPFs, for the ground water contaminants. There are no
action-specific ARARs associated with Alternative 2.
The estimated capital cost of this alternative is $
o & M costs estimated to be $15,469 annually and $33,845
years. The present worth is estimated to be $288,193.
Implementation time is estimated to be approximately one
Alternative 3 - Wellhead Treatment
0, with
every 5
month.
Wellhead treatment consists of providing a physical/chemical
treatment unit for the home wells of impacted residences.
Although various processes are available as home treatment units,
carbon adsorption was chosen as the best suited technology for
this application. Activated carbon is effective for removal of
organic compounds to low concentrations. If monitoring indicates
carbon adsorption units are not operating so that the site-related
contaminants remain below the action levels, EPA would require the
carbon adsorption treatment process to be repaired or replaced
with one that does. .
Of the residential wells sampled during the RI, only samples
from HW-01, HW-04, HW-05, HW-07 and HW-08 indicated the presence
22
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of contaminants at levels above background. Of these residential
wells, only HW-01 has had contamination levels above MCLs.
Activated carbon units could reduce the concentrations of ground
water contaminants to below MCLs and risk-based levels.
Periodically, the activated carbon would have to be replaced and
the residuals properly disposed of. Sampling to date has
indicated that contaminant levels will likely continue to decrease
with time. Wellhead treatment units would be offered to
residences that, through monitoring, show levels in exceedance of
the chosen action levels. For cost estimating purposes, it has
been assumed that a home treatment unit will be supplied to one
residence with a replacement rate of once per year. spent carbon
is projected to be returned to the vendor for regeneration.
A ground water monitoring program as described in Alternative
1 would be conducted as part of this alternative.
Alternative 3 would meet the contaminant-specific ARARs
(MCLs, non-zero MCLGs, EPA Health Advisory levels, or risk-based
action levels, based on the RfDs and CPFs, for the ground water
contaminants), at the point-of-use where they are relevant and
appropriate. This alternative would not comply with the
Pennsylvania Hazardous Waste Management Regulations, [25 PA Code
SS 264.90 - 264.100, specifically 25 PA Code SS 264.97(i) and (j)
and S 264.100(a) (9)], which contain a requirement to remediate to
background. There are no action-specific ARARs associated with
Alternative 3. The Federal and state Safe Drinking Water
Regulations, as they relate to drinking water standards at the tap
are relevant and appropriate for this site. (40 C.F.R. SS
141.11 - 141.16) and (25 PA Code S 109)
The estimated capital cost of this alternative is $1,400,
with 0 & M costs estimated to be $14,410 annually and $32,786
every five years. Implementation time is estimated to be one
month.
Alternative 4 - Plume Containment
This alternative was developed for plume containment by
intercepting and withdrawing contaminated ground water immediately
downgradient of the landfill boundary, treating on-site, and
reinjecting into the aquifer downgradient of the extraction wells.
This discussion assumes there is an adequate location to discharge
the treated water and that the surrounding farmland is not
negatively impacted. A series of extraction/injection wells, as
shown in Figure 6, would be installed immediately east of the
landfill to serve as a barrier to ground water flow. The intent
of the system would be to intercept contaminated ground water
flowing from beneath the landfill, effectively preventing further
migration of contaminated ground water outside the landfill
boundaries. The majority of cont~inated' ground water within the
area of attainment would not be actively remediated. continued
migration and dispersion of the plume along with natural
23
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,--
attenuation processes. and the influx of clean water via the
injection wells (dilution) would restore the aquifer in time.
Based on an estimated areal extent of contamination, a
conceptual mass balance flow model was derived in order to
calculate estimated remediation times. An estimate of 3 pore
volumes was assumed to be sufficient to remove contaminants, and
was therefore used in the calculations. The actual pumping rate
and location of the extraction and injection wells would vary
based on field data collected during a design phase.
The proposed treatment processes, depicted in Figure 7, are
ion exchange for metals and air s~ripping for VOCs. In the
proposed treatment plant, water would flow into an equalization
tank, where pH adjustment would take place, then it would be
pumped through a sand filter for solids removal. This would
prevent interference with the air stripper packing material and
the ion exchange units. Solids collected from backwash of the
filter would be dewatered on a drying bed, and periodically
disposed of off-site. The water would then flow to a air
stripper, followed by an ion exchange unit. A clearwell would
serve as a flow regulator prior to the injection of the treated
water back into the ground.
A ground water monitoring program as described in Alternative
1 would also be conducted as part of this program.
During Site work and treatment system operation, Pennsylvania
Air Pollution Control Act (25 PA Code Section 127), and OSWER
Directive 9355.0-28 air emission requirements would be met. The
Directive is a To Be Considered (TBC), and the calculated air
stripper emission rate are under the amounts necessary to require
treatment. TBCs may be criteria, guidances, advisories, or
proposed standards which, while not legally binding, provide
useful information or recommended procedures.
For Alternative 4, on-site treatment and transportation of
any treatment residuals off-site would comply with the following
Resource Conservation and Recovery Act (RCRA) regulations:
.
(40 C.F.R. Part 262) Standards Applicable to Generators
of Hazardous Waste
.
(40 C.F.R. Part 263) Standards Applicable to
Transporters of Hazardous Waste
(40 C.F.R. Part 264) Regulations and Standards for
owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities.
Transportation of any treatment residuals off-site would also
comply with the DOT Rules for Hazardous Materials Transport (49
C.F.R. Parts 107 and 171-179).
.
24
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On-site treatment would comply with the Pennsylvania Solid
Waste Management Act of 1980:
.
Pennsylvania Municipal Waste Management Rules and
Regulations (25 PA Code 273, specifically 273.281 -
273.288 relating to Water Quality Monitoring), and
Pennsylvania Hazardous Waste Management Regulations [25
PA Code SS 264.90 - 264.100, specifically 25 PA Code SS
264.97(i) and (j) and S 264.100(a) (9)], which contain a
requirement to remediate to background.
Discharge of treated ground water would comply with the
following:
.
Clean Water Act (CWA) and PA Clean Streams Law, specifically:
.
(40 C.F.R. Part 122) CWA National Pollution Discharge
Elimination System (NPDES) Regulations
(PA Code, Title 25, Chapter 92) Pennsylvania NPDES
Regulations
.
.
(PA Code, Title 25, Chapter 101) Pennsylvania Special
Water Pollution Regulations
(PA Code, Title 25, Chapter 95) Pennsylvania Wastewater
Treatment Regulations
The Federal and State Safe Drinking Water Regulations, as
they relate to drinking water standards at the tap, are relevant
and appropriate for this site. (40 C.F.R. SS 141.11 - 141.16);
(25 PA Code S 109).
.
(40 C.F.R. 144) The Underground Injection Control Regulations
relating to injection of treated ground water.
The Farmland Protection Policy Act (7 U.S.C. 4201), which
requires federal programs to minimize the extent they contribute
to unnecessary and irreversible conversion of farmland to non-
agricultural uses, is an ARAR for the site. EPA has a "statement
of Policy to Protect Environmentally Significant Agricultural
Lands (September 8, 1978), which is a TBC for the Site. The Soil
Conservation Service of the United States Department of
Agriculture has designated the lands surrounding the site as
significant agricultural lands, specifically "prime farmland".
"Prime farmland" is "land best suited for producing food, feed,
forage, fiber and oilseed crops..."
The estimated capital cost of this alternative is $3,766,945,
with a & M costs estimated to be $539,335-in the first year and
$528,535 in years 2 through 30, with $552,411 estimated every five
years. Implementation time is estimated to be 1 year, with
background cleanup levels estimated to be achieved in 88 years.
25
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Alternative 5 - Aauifer Restoration
This alternative was developed to actively treat all
contaminated ground water in the area of attainment. This
discussion assumes there is an adequate location to discharge the
treated water and that the surrounding farmland is not negatively
impacted. A total of 15 extraction wells and 14 injection wells
are proposed for this alternative. Twelve of these wells would be
located as described in Alternative 4 - Plume containment. An
additional nine extraction wells and eight injection wells would
also be installed as part of this alternative. The total flow
rate from these extraction wells is 750 gpm (50 gpm per well).
As depicted in Figure 8, the nine additional extraction wells
would be located in two areas. A line of five extraction wells
(EW-7 through EW-11) and six injection wells (IW-7 through IW-12)
would be placed parallel to each other approximately 2,000 feet
east of the plume containment wells. These extraction wells would
intercept the contaminated ground water east of injection wells
IW-1 through IW-6. The six injection wells would increase the
gradient and accelerate remediation downgradient of these wells.
Additionally, four extraction wells (EW-12 through EW-15) would be
installed near HW-04 and HW-05 to intercept the contaminated
ground water downgradient of injection wells IW-7 through IW-12.
Two additional injection wells (IW-13 and IW-14) would be
installed near injection wells IW~l through IW-6 to augment the
discharge flow rate.
An effective flow rate of 75 gpm was used. Due to the
significantly greater volume of water to be treated compared to
Alternative 4, the time needed to extract one pore volume would be
10.5 years. Assuming extraction of three pore volumes of ground
water is sufficient to remove the contaminants, approximately 31.5
years would be required to remediate the ground water once the
landfill has dewatered. Landfill dewatering would take
approximately 40 years; therefore, total remediation time is
estimated to be in excess of 70 years.
The actual pumping rate and location of extraction/injection
wells will vary based on field data and observations collected
during the desiqn phase. Water would be pumped to a treatment
facility, similar to that described in Alternative 4, through
seven inlets. Extraction wells EW-12 through EW-15 would be
connected to a main header and pumped to the treatment facility.
Extraction wells EW-1 through EW-6 would also be connected to a
main header before being" conveyed to the treatment facility.
Ground water from extraction wells EW-7 through EW-11 would be
conveyed separately to the treatment facility. As discussed in
Alternative 4, the treatment process would consist of pH
adjustment, filtration, solids handling, air stripping, and ion
exchange. To accommodate the larger flow rate, larger vessels
would be needed for each of the four processes. For the air'
stripper, a column height of 10 feet and a column diameter of 5
feet would be required to treat the ground water to remedial
26
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action levels. Following treatment, the effluent would be split
proportionately into two discharges. Fifty-seven (57) percent of
the effluent would flow to the eight western-most injection wells
while the remaining forty-three (43) percent of the effluent would
discharge to the six central injection wells.
A ground water monitoring program as described in Alternative
1 would also be conducted as part of this program.
As in Alternative 4, the off-gas from the air stripper would
not need to be treated because the predicted volatile emission
rate is less than one pound per day. A performance monitoring
plan similar to that for Alternative 4 would be conducted as part
of this alternative. Due to the increased number of extraction
wells in Alternative 5 compared to Alternative 4, a total number
of 150 samples would be collected the first year followed by 116
per year for the remaining four years.
During site work and treatment system operation, Pennsylvania
Air Pollution Control Act (25 PA Code section 127), and OSWER
Directive 9355.0-28 air emission requirements would be met. The
Directive is a To Be Considered (TBC), and the calculated air
stripper emission rates are under the amounts necessary to require
treatment. TBCs may be criteria, guidances, advisories, or
proposed standards which, while not legally binding, provide
useful information or recommended procedures.
For Alternative 5, on-site treatment and transportation of
any treatment residuals off-site would comply with the following
Resource Conservation and Recovery Act (RCRA) regulations:
.
(40 C.F.R. Part 262) Standards Applicable to Generators
of Hazardous Waste
.
(40 C.F.R. Part 263) Standards Applicable to
Transporters of Hazardous Waste
(40 C.F.R. Part 264) Regulations and Standards for
owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities.
Transportation of any treatment residuals off-site would also
comply with the DOT Rules for Hazardous Materials Transport (49
CFR Parts 107 and 171-179).
.
On-site treatment would comply with the Pennsylvania Solid
Waste Management Act of 1980: .
.
Pennsylvania Municipal Waste Management Rules and
Regulations (25 PA Code 273, specifically 273.281
273.288 relating to Water Quality Monitoring), and
Pennsylvania Hazardous Waste Management Regulations [25
PA Code 55 264.90 - 264.100, specifically 25 PA Code SS
.
27
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I -
264.97(i) and (j) and 5 264.100(a) (9)J, which contain a
requirement to remediate to background.
Discharge of treated ground water would comply with the
following:
Clean Water Act (CWA) and PA Clean streams Law, specifically:
.
(40 C.F.R. Part 122) CWA National Pollution Discharge
Elimination System (NPDES) Regulations
(PA Code, Title 25, Chapter 92) Pennsylvania NPDES
Regulations
.
.
(PA Code, Title 25, Chapter 101) Pennsylvania Special
Water Pollution Regulations
(PA Code, Title 25, Chapter 95) Pennsylvania Wastewater
Treatment Regulations
.
The Federal and State Safe Drinking Water Regulations, as
they relate to drinking water standards at the tap, are relevant
and appropriate for this site. (40 C.F.R. 55 141.11 - 141.16);
(25 PA Code S 109).
(40 C.F.R. 144) The Underground Injection Control Regulations
relating to injection of treated ground water.
The Farmland Protection Policy Act (7 U.S.C. 5 4201), which
requires federal programs to minimize the extent they contribute
to unnecessary and irreversible conversion of farmland to non-
agricultural uses, is an ARAR for the Site. EPA has a "Statement
of Policy to Protect Environmentally Significant Agricultural
Lands (September 8, 1978) which is a TBC for the Site. The Soil
Conservation Service of the United States Department of
Agriculture has designated the lands surrounding the site as
significant agricultural lands, specifically "prime farmland".
"Prime farmland" is "land best suited for producing food, feed,
forage, fiber and oilseed crops.. .."
The estimated capital cost of this alternative is $7,785,044,
with 0 & M costs estimated to be $1,093,213 (year 1), $1,069,213
(years 2-30), and $1,093,089 (every 5 years). Implementation time
is estimated to be 1 year with background cleanup levels estimated
to be achieved in over 70 years.
8.
Summary of Comoarative Analvsis of Alternatives
The nine evaluation criteria are summarized below.
Overall Protection of Human-Health and the Environment
Alternative 1 is not protective, and is therefore dropped
from further consideration.
28
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Alternative 2 does not include any type of ground water
treatment and would not provide any additional reduction in the
risks associated with exposure to contaminated ground water other
than that offered by attenuation, dilution and other natural
processes. However, Alternative 2 would eliminate exposure, via
ingestion, to contaminated water by providing bottled water
service. Exposure via inhalation would not be reduced by this
alternative. For ground water users residing outside of the
current extent of contamination, however, Alternative 2 would help
to reduce the potential for future exposure to contaminated ground
water through the use of monitoring.
Alternative 3 would eliminate the risks associated with
exposure to contaminated ground water by treating ground water at
the well head before residential use. Alternative 3 would also
help to reduce the potential for future exposure to contaminated
ground water to residents not receiving well head treatment
through the use of monitoring.
Alternatives 2 and 3 would not actively help to prevent
increased concentration and/or volume of contaminated ground
water. These alternatives would not actively restore the
contaminated ground water to remedial action levels (background).
Alternatives 4 and 5 would both potentially prevent any
increase in concentration and/or volume of contaminated ground
water. Following start-up of the ground water
extraction/injection system, a hydraulic gradient or barrier would
be established by the pumping system. In theory, this hydraulic
barrier would help to contain the contaminant plume and therefore
reduce the potential for migration of contaminants into
uncontaminated ground water.
Upon completion, Alternative 5 would protect human health
from future exposure (ingestion, inhalation) to contaminated
ground water. Only ground water users residing outside of the
area of contamination would be protected by the
extraction/injection and treatment systems. Any ground water
users currently at risk would continue to be at risk until the
cleanup levels are achieved and therefore Alternative 2 or 3 would
have to be implemented in addition to either of these
alternatives.
Alternative 5 could also potentially restore contaminated
ground water to remedial action levels (background). However,
while the proposed cap over the landfill area would prevent
infiltration through the landfill,' the landfill would still act as
a source due to present saturated conditions and could cause
contaminant levels in the ground water to remain relatively
constant for a period of time.
29
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ComDliance with ARARs
Alternatives 2 would not meet the MCLs, non-zero MCLGs, EPA
Health Advisory levels, or risk-based action levels, based on the
RfDs and CPFs, for the ground water contaminants. Alternative 3
would meet these chemical-specific ARARs at the point-of-use where
MCLs are relevant and appropriate.
There are no action-specific ARARs associated with
Alternatives 2 and 3.
The goal of Alternative 5 is to achieve the background
cleanup levels for ground water. The ability of a ground water
extraction/injection and treatment system to attain these levels,
however, cannot be assessed at this time. Alternative 4, while
not achieving background cleanup levels, would prevent any
continued migration of ground water contaminants.
Alternative 3 would not negatively impact the significant
agricultural lands. Alternatives 4 and 5 would have negative
impacts on the significant agricultural lands.
Lona-Term Effectiveness and Permanence
since no actions would be taken to remediate the ground water
under Alternative 2, the health risks remaining after
implementation of these alternatives would be identical to those
presently associated with household use of contaminated ground
water. Alternative 2 would eliminate risks associated with
ingestion of ground water by providing bottled water service.
Alternative 3 would eliminate all risks associated with exposure
to contaminated ground water by treating it at the wellhead before
residential use. For ground water users not receiving wellhead
treatment, monitoring would be used to track plume migration and
facilitate future response actions for protection from exposure to
contaminated ground water.
with respect to environmental risks, the contaminants in the
ground water would continue to migrate over time under
Alternatives 2 and 3. Under these alternatives, natural
attenuation processes in the aquifer are expected to continue
having a positive effect on ground water quality. Because
leachate generation is expected to continue for approximately 40
years after cap construction, reduction of contaminant
concentrations in the aquifer due to remedial actions and through
natural attenuation processes may be achieved in a reasonable
time-frame (i.e., less than 100 years).
At the completion of Alternative 5 remedial action,
contaminants levels would be restored to background levels. At
the completion of Alternative 4, natural processes would still be
relied upon for some time before ~ckground levels were achieved.
Leachate generation and release from the landfill is also expected
to continue for 40 years during implementation of Alternatives 4
30
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or 5. The effect of pumpinq the qround water is not expected to
significantly affect the time-frame for leachate generation and
release from the landfill. Therefore, restoration time for
Alternatives 4 and 5 is expected to take approximately 88 and 70
years, respectively. .
Reduction of Toxicitv. Mobilitv. or Volume throuah Treatment
Alternative 2 would not reduce the toxicity, mobility, or
volume of contaminants in the ground water. Alternative 3 would
provide a reduction in toxicity by treatinq ground water at the
wellhead. Over time, contaminant levels in the present areas of
contamination may gradually decrease through natural processes,
although the current extent of ground water contamination may
spread into uncontaminated areas. . Installation of the proposed
cap over the landfill area will prevent continued infiltration
through the landfill. However, the landfill is expected to act as
a relatively lonq-term source due to presently existinq saturated
conditions and could cause contaminant levels in the ground water
to remain relatively constant for a period of time.
Alternatives 4 and 5, over the long term, could potentially
restore ground water in the zone of contamination to background
levels, assuminq all sources of contamination are controlled.
Unlike Alternative 2, Alternatives 3, 4, and 5 would provide an
irreversible treatment process that would reduce the toxicity of
the contaminated ground water by removinq the contaminants from
the extracted ground water.
Alternatives 3, 4 and 5 fully comply with one of the goals of
CERCLA to utilize treatment that permanently reduces the volume,
toxicity, or mobility of the contaminants at the Site, whereas
Alternative would not comply with this objective. Alternative 3
would reduce the toxicity of qround water contaminants by using
treatment at the point-of-use.
Short-Term Effectiveness
Alternatives 2 and 3 involve only the installation of bottled
water service and home treatment units, respectively. Protection
of workers and the community from exposure to contaminated
materials durinq remedial actions is not a major consideration for
these two alternatives. Each could be implemented in
approximately one month.
There should be no appreciable risk associated with off-gas
from the air stripper unit. Perimeter air monitorinq could be
implemented durinq start-up of the system to determine whether
actions are necessary to protect the community or workers from
adverse air emissions. Monitorinq and maintenance would also be
used to minimize risks associated with failures of the treatment
system.
31
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Implementation time for Alternatives 4 and 5 is estimated at
approximately one year. However, neither alternative will be
effective in the short-term.
ImDlementabilitv
Alternatives 2 and 3 involve widely available, vendor-
installed services and would be readily implementable. Monitoring
wells could be maintained at the Site and a ground water
monitoring program easily implemented. A ground water monitoring
program would not interfere with any future remedial actions taken
at the Site.
possible concerns associated with Alternatives 2 and 3
involve persuading residents to utilize bottled water or a
wellhead treatment unit. Any action that affects the current
ground water use scenario may be unpopular with local residents;
therefore, implementing such actions may be difficult.
with respect to alternatives 4 and 5, air strippers, ion
exchange units and ground water extraction/injection wells are all
widely used at hazardous waste sites and are highly reliable if
periodic inspections and maintenance are performed. Because
Alternatives 4 and 5 involve the extraction and treatment of
ground water, there are more implementability and operational
considerations associated with these two alternatives than with
Alternatives 2 and 3. The components of the air stripping and ion
exchange systems are readily implementable using existing
technologies. No special materials or equipment would be
required. operation and maintenance considerations include:
cleaning and replacement of wells and well pumps; maintenance of
blower units; cleaning of fouled packing; and disposal of
pretreatment sludge and spent ion exchange resins. Also,
monitoring of the effluent water and exhaust gas would be required
to ensure compliance and reliability of the systems.
It would also be desirable to create a partially closed
system using the ground water extraction and injection wells in
which most reinjected water is controlled and eventually captured
by the extraction wells. Attainment of a closed system in
fractured bedrock is be difficult, however. Reinjected water that
is transported in discrete fractures may not be captured by the
extraction wells and could potentially force contaminated ground
water into lesser contaminated areas.
No permits would be required to implement Alternatives 2 and
3, whereas various state permits may be required for Alternatives
4 and 5 to reinject treated water as well as to discharge air
stripper off-gas. However, if conducted on-site, no permit is
required and only the substantive permit requirements for
Alternatives 4 and 5 must be met.
32
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Cost
Estimated costs for the five alternatives are shown in Table
17. Costs range from a present worth of $268,796 for Alternative
2 to $24,310,746 for Alternative 5.
state AcceDtance
At this time, the Commonwealth of Pennsylvania has not
concurred with this remedy. As the Site is a state-lead project,
typically the State would prepare the Proposed Plan as well as the
ROD. In this instance, EPA at the request of PADER, prepared both
of these documents.
Public comment for the Site ran from August 8, 1991 through
September 6, 1991. PADER received a copy of the Proposed Plan
prior to issuance for public comment. PADER also presented the
Proposed Plan and the Preferred Alternative to the public at the
public meeting on August 13, 1991.
subsequent to the issuance of the Proposed Plan, PADER
provided EPA with comments which were reviewed and considered by
EPA and addressed in a draft of the ROD. PADER was provided with
a copy of the draft ROD on August 27, 1991. PADER provided
comments within several weeks. Their comments were considered and
a final draft ROD was prepared. Additional comments were received
from PADER on September 27, 1991.
Although these comments were provided after the maximum time
allowed in the NCP, EPA has considered the comments. EPA
disagrees with the conclusions set forth in the letter from PADER.
The Commonweallth raised two issues. The first issue
addressed earlier language not included in the final ROD, and is
therefore, no longer applicable. The first issue involved
expansion of the current remedy to include future use. EPA
believes its selected remedy is protective. Part of this remedy
includes ground water monitoring. If monitoring data indicates
the remedy is no longer protective, EPA is required to take
further action in a manner not inconsistent with the NCP.
The second issue involves the trigger levels for residences
which would be provided wellhead treatment. EPA believes drinking
water standards (MCLs) to be relevant and appropriate at this
Site. For Site-related contaminants that do not have MCLs, or for
cumulative risk, the trigger level shall be 1 x 10-4 for
carcinogens or greater than an HI of 1.0 for non-carcinogens. EPA
believes this is both protective and in compliance with ARARs.
Communitv Accectance
Community acceptance is assessed in the attached
Responsiveness Summary. In general the local community and the
PRPs agreed that the preferred alternative, Alternative 3, was
33
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appropriate. Concern was expressed about who would received
wellhead treatment, how the ground water monitoring program would
be implemented and how future residents would be addressed. The
Responsiveness Summary provides a thorough review of the comments
received on the RI/FFS and the Proposed Plan.
9.
selected RemedV and Performance Standards
The selected remedy is Alternative 3, Wellhead Treatment,
with approximately $1,400 capital costs and a present worth of
$274,040. This remedy consists of providing wellhead treatment
units to residences impacted by site-related contaminants above
action levels, as herein described and stated below.
Additionally, ground water monitoring is required under this
remedy.
Wellhead treatment consists of providing a physical/chemical
treatment unit for the home wells of impacted residences.
Although various processes are available as home treatment units,
carbon adsorption was chosen as the best suited technology for
this application. Activated carbon is effective for removal of
organic compounds to low concentrations. If monitoring indicates
carbon adsorption units are not operating so that the site-related
contaminants remain below the action levels, EPA will require the
carbon adsorption treatment process to be repaired or replaced
with one that does.
Home treatment units will be provided to residences whose
wells contain Site-related contaminants exceeding action levels.
The action levels are:
1.
Maximum contaminant Levels (MCLs)
If no MCL exists for a particular contaminant or if
there is a cumulative risk from the contaminants, action
will be taken if levels are greater than the 1X10-4 risk
level for carcinogens or a Hazard Index greater than 1.0
for non-carcinogens.
2.
Wellhead treatment units must be maintained according to
manufacturer's specifications so that contaminants remain below
action levels. Periodically, the activated carbon will have to be
replaced. For cost estimating purposes, it has been assumed that
a home treatment unit will be supplied to one residence with a
carbon replacement rate of once per year.
Disconnection of the treatment units may take place after six
consecutive quarterly samplings in which there have been no
exceedances of the standards in the above paragraphs. Wellhead
treatment will have to be reinstalled if monitoring indicates
contaminant levels subsequently exceed the action levels.
Since no action would be taken to actively remediate the
ground water under this alternative, the health risks associated
34
-------
with exposure to contaminated ground water at HW-01 would be the
same as those discussed in the risk assessment, namely 1.14X10-S.
However, residences with home treatment units would not be exposed
to contaminated ground water. This remedy would remain effective
provided the wellhead treatment unit was properly operated and
maintained.
For ground water users not receiving wellhead treatment
units, an effective ground water monitoring program would decrease
the likelihood of exposure to contaminated ground water. Although
monitoring is less effective in fractured bedrock than in more
homogeneous unconsolidated formations, sampling of potentially
impacted residential wells will increase confidence in the
monitoring system.
The ground water monitoring program shall be conducted as
part of this alternative. This program will consist of quarterly
sampling of five residential wells in addition to the four
monitoring wells to be monitored pursuant to the 1988 ROD. This
number of wells is approximate only, and was used for costing
purposes. Ground water monitoring samples should be analyzed for
the Target Compound List (TCL) volatiles and Target Analyte List.
metals. Residential well water should be analyzed by an
appropriate EPA 500 series drinking water test method, or an
equivalent method. This monitoring program may be modified by
EPA, in such areas as number of wells, location of wells,
frequency of sampling, and analytical parameters.
EPA does not anticipate the need for additional wellhead
treatment units in the future because the data indicates Site-
related ground water contaminant levels are declining. If data
from the ground water monitoring shows that site-related
contaminants in a residential well exceed the action levels,
further 'work to protect the residents will need to be taken
consistent with the NCP. This may include the installation of
additional wellhead treatment units or other actions, as
appropriate.
This alternative will result in contaminated ground water and
hazardous substances remaining on-site, and 5-year site reviews,
pursuant to CERCLA, will be required to monitor the effectiveness
of this remedy.
10.
statutorY Determinations
Protection of Human Health and the Environment.
The baseline risk assessment performed during the RI
identified two current and future pathways of concern: ingestion
and inhalation of ground water. As previously discussed., the
current exposure risks identified in the baseline risk assessment
fell within the EPA acceptable range of lx10-4 to 1x10-6. The
provision of wellhead treatment would control these pathways at
the nearest residence and would add additional protection over
35
-------
.
quarterly sampling, especially since this well has in the past had
slight MCL violations. No unacceptable short-term risks or cross
media impacts will be caused by implementation of the remedy.
ComDliance with ADDlicable or Relevant and ADDro~riate
Reauirements.
The remedy would not comply with the background remedial
action levels based on Pennsylvania's Hazardous Waste Management
Regulations for contaminants in the ground water at the Site,
because no action would be taken to remediate the contaminated
aquifer. This alternative would comply with the MCLs, non-zero
MCLGs and EPA Health Advisory levels at the tap. The Safe
Drinking Water Act is relevant and appropriate at the tap since
there are less than 15 service connections.
EPA is waiving the requirement in the Pennsylvania Hazardous
Waste Management Regulations [25 PA Code 55 264.90 - 264.100,
specifically 25 PA Code 55 264.97(i) and (j) and S 264.100(a) (9)],
which contain a requirement to remediate to background levels.
EPA is also waiving the reqUirement to remediate off-site ground
water to MCLs. Data indicates the ground water contamination
appears to be naturally attenuating. EPA is waiving the
requirement to remediate to background levels and to MCLs based on
technical impracticability. The authority to waive ARARs is found
in CERCLA section 121(d) (4) and in the NCP 5300.430(f) (1) (ii) (C).
These ARARs are being waived for several reasons, including: 1)
the lack of discharge areas with the necessary capacity within a
reasonable distance (less than 1 mile) from the Site and 2) the
lack of confidence in the reliability of reinjection of treated
water within the vicinity of the Site. MCLs, as relevant and
appropriate drinking water standards, will be met at the tap prior
to use of the ground water by residents.
Discharge of treated ground water to surface water or to a
Publicly Owned Treatment Works (POTW) was screened out earlier in
the feasibility analysis process due to a lack of suitable
discharge areas. No surface water bodies or POTWs of adequate
size were located within a reasonable distance from the site. The
nearest POTW with a large enough design capacity is located in
Allentown, eight miles away from the Site. The Site is located in
an area ot highly fractured bedrock. Reinjection of treated
ground water would be an unreliable process, since reinjected
water would be likely to travel along fractures and would be
difficult to control and monitor. In a worse case scenario, the
reinjected water might flow back towards the landfill and cause
higher levels of contaminants to be flushed out.
Construction of an extraction, treatment and reinjection
system would also cause the destruction of land designated as
prime farmland. EPA is required to consider the impact of its
actions on significant agricultural lands, such as the area
surrounding the site.
36
-------
There are no action-specific 'ARARs associated with this
alternative.
Cost-Effectiveness.
The selected remedy is protective and affords overall
effectiveness at a reasonable cost.
utilization of Permanent Solutions and Alternative Treatment
(or resource recovery) Technologies to the Maximum Extent
Practicable (MEP).
The selected remedy utilizes permanent solutions and
treatment technologies to the maximum extent practicable. The
selected remedy provides the best balance of tradeoffs among the
alternatives with respect to the evaluation criteria, especially
the five balancing criteria. The remedy addresses the principal
pathway for exposure to contaminants.
Preference for Treatment as a PrinciDal Element.
The preference for treatment is satisfied since treatment at
the point of use is the selected remediation for the site.
11.
Documentation of Sianificant Chanaes
A minor clarification has occurred between the Proposed Plan
and the ROD as a result of community input. The Proposed Plan
described providing treatment units to currently existing
residences only. Wellhead treatment units will be provided, as
described in the Selected Remedy section to residents whose wells
contain site-related contaminants exceeding action levels.
EPA does not anticipate the need for additional wellhead
treatment units in the future because the data indicates Site-
related ground water contaminant levels are declining. If data
from the ground water monitoring shows that site-related
contaminants in a residential well exceed the action levels,
further work to protect the residents will need to be taken
consistent with the NCP. This may include the installation of
additional wellhead treatment units or other actions, as
appropriate. '
37
-------
Scale 1:250.000
5
o
5
10
15
20 S~tut. "'iles
Commonwealth of PennS'rivonia
Deportment of Environmental Resources
Bureau of Waste Mana ement
DORNEY ROAD LANDFILL SITE
REMEDIAL INVESTIGATION/F'EASIBIUTY STIJDY
=IGURE l'
SITE LOCATlcrN MAF
SJURCE: uSGS V501 SERIES
NEWARK, N...!. QUAD.
P!'<'TO REVISED 1969.
EBASCO
EBASCO SER~CES INCORPORATED
Langhorne. Penns)'lvania
-------
o
,
AGRICUL TURAL
LAND
450
450-
ICIIMtQ t;# wAl"'f'lNCO;
'h:PCIIaAIMC CDtTQ.«S ~ ".,., "'.....D 8' .. M. amo.... . As::JOOAru DArtD 1.,,,,,,1
..,4 ftA1U8U - U 1."'1. 7 S 1lliLtJ(
-------
--
1111,.
~"'''---
\%
\%!
TREXLERTOWN )
r1}
....
~ "
"'\ ~RUH ..' 1.'
~ .:~ \ ~(f.~~+.r - -=- \
I ("Ii '
BREINIGSVILLE ftir
-"~
"\
\
UPPER
MACUNGIE
TOWNSHIP
"
ANCIENT OAKS
..
,
...." .. .!CHA£FER
-...~'
..
,
MAXATAWNY "
"
.~~
.~,+...+
...~.c
lQ~
. .
'.. APPROXIMATE
''', cf SITE LOCATION
".. . WEILERSVILLE
, ~ ~
'_'NGTON . "-, )"""~..
~.kW:P . """'- :-ta;r
:~.~
j\...~' '-'.. ~.j"
~"~; '>~
: MERTZTOWN M' ,
/J1 "
r"
CRE-E-It /
'r~
,-~
CREEK
N
SCALE
o
4000
2000
INDICATES DIRECTION OF SURFACE WATER
FLOW
SOURCE: U.5.G.5. TOPOGRAPHIC MAPS,
TOP TON AND ALLENTOWN-WEST
PENNSYLVANIA QUADRANGLES
,<~
6i-~G'1-
+J" Co
c~
o ..
"
Commonwealth o' Penns~vania
Deportment 01 Environmental Resources
Bureau 01 Was Ie "'onaqemenl
DORNEY ROAD LAND ILL 51 E
ROIEOIAL IN II£STICA TlON/f[ASIBILlT'r STUDY
fiGURE 3
SURFACE WATER DRAINAGE MAP
[BASCO
(SA SCD S£R \/ICE S INCOHPOR A I ED
lonqh()(ne. Penn::'~1fon1a
-------
.
...-1D$
. ..,.-10;)
'$
M~lIf~
~ HW-OI
o .
HW-~ \J
SCIUItC( rs ..~G:
YOPOQIIJAIMC CDHTOURS - MAP PREPAH(D By" N. K[OOAl . ASSOOAF[S OAnD 2-14-81
SUltfAQ: nAf\JfI(.S - US C.S. 1 ~ MiHU1'[ C).JAOft.-CU - IOPTOI'f p" AHD
A(RIAl PtiQJOCHAPH DAII.O """11-88
IoIOttITOR wELLS - SUR\II(y lOCATED 8' L 11108(1111 Ka*8AU. . ASsoa...Tt.S
NOTE'
~"IC a(SULTS A.[ fllOM U"'llU.iII(O S"'''''L(.S nOTAL M['ALU
L..E.W!O
..w- 'D ..
HW-06
J"' 450-----
...
-.-----
-------
~C( c:I WAPI"..c
1()P()CJ1~ co.tlOUltS - ""AI' ~IitL;ONl:£t) 3' II. .. ..roo"," II "-S$oc...rts DAna }-14-87
S\Htf'A.Ct fiAI\IRU - u S-C So 1.) IoMhVT( OJAOA."c:...r - 10000ICH ~. AHD
A(thAI. Pt1Ol()I;;:toAPH OAit.:) -')-11
460
Mo..ti~ tll(l'-S - S),J1t'-'C'r lOC..Tt.J 8Y L 1I08(U I(IMB..u II ..~oc..T[S
~
HW-06
./' 450"'-
...
tOoI( 1II{L.L
CQNJOMII - w(NI S£..,t. L('t.IQ.
-++--+-
'8O\..NC»
111'( 8ClJNC)AltT
-...-
WA rur 80DT
'8U I
HW-~
0 . \\
0
:8
<
...
.
SCALI IN ,c-rr
>00 '000
COIAIONWEAl TH OF PENSYl VAN&A,
()(PARTUEH1 Of" ENVR)N.IENfAl RfSOURCES
DORNEY ROAD lANDFill SITE
REMEDIAl "I/£STIGAT~EASI8I..rTY STUDY'
FIGURE '\
RESIDENTIAL WELL SAMPL~ LOCATION MA
E8ASCO SERvICES INOORPOfV.I EO
l»tGHOAHE. Pf~sY\ v...~
-------
LEGEND
HW-OJ
.
HW
MW
Residential Wells
Monitoring Wells
Injection Wells
.
A
Extraction Wells
WW-.,NORTH MW-9S,9D
~
Treatment Facility
LandI/II boundry
SCALE: 1. . 660'
Comm~nwenllh of Pennsylvania
Uupsrtmcnt of ~nvlronmental Reaources
nOIlNF.Y HOAD LANUf'ILL SIT~ - FFS
AEJEDW. 1lVU11GA~ J£A88LIf't tJ\IJr .
-- Figure' 6
Alternative + . Extraction/Injection
I'lel1 Locations
EBASCO SF.RVICES INCORPORATED
Lan horne. Penns 1 vania
HW-O~
.
-------
Extracted Groundwater
Blower
To
Atmosphere
r - - - - SandFihe~
I r-'
I
I
I
EquUlzation Tank
Pump
Air Stripper
-
Filter
Backwash
Pump
Effluent
Clearwell
Air Stripper
Blower
Effluent
Transfer
Pump
Pump
Ion Exchange
To Refnjeclion
Wells
Commonwealth 01 Pennsylvania
Department 01 Environmental Resources
DORNEY ROAD LANDFILL SITE. FFS
REMEDIAL INVESTIGATION I FEASIBILITY STUDY
FIGURE' 7
PROCESS flOW DIAGRAM
EBASCO SERVICES INCOHPOHA" U1
Lan!Ihorne, Ponnsylvaflld
-------
HW-OJ
.
LEGEND
HW
MW
.
~
Residential Wells
Monitoring Wells
Injection Wells
Extraction Wells
MW-4 NORtH
~7.D
MW.38,3DR
W.1
~
Treatment Facility
-
Landfill boundry
SCALE: 1. . 660'
ESTIMATED
/ AREA OF ATTANoENT
Commonwealth of Pennsylvania
De artment of Environmental Resources
DORNEY ROAD LANDFILL SITE - FFS
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
Figure 8
Alternative 5 - CONCEPTUAL DESIGN
EBASCO SERVICES INCORPORATED
Lan horne. Penns lvania
.4EW.'3
JE.W-14
IIW-O~
.
81W-12
.
-------
TABLE 1
PENNSYLVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
OORNET ROAO LANDFILL SITE
CHEMICALS OF COMCE8M IM CaOUNOMATER • NORTH WELLS
(1)
Contaminant
frequency
Range of Detection
Median
Location of
Maximtjn
Date
Volatile Organies
Vinyl Chloride
CM orome thane
Total 1,2-Oichloroethene
1.2-Oichloroethane
1,1,1•Trieh Ioro«thane
Carbon Tetrachloride
Trichloroethene
Tetrachloroethene
Benzene
1,1-Dichloroethane
1,2-0ichIoropropane
Total Metals
2/15
NO
2/15
2/15
2/15
NO
2/15
2/15
2/15
•/IS
2/15
4-9
4 *
18-56
4-9
1.5-3
--
9-18
8-13
3-7
3-32
1.2-6
6.5
--
37
6.5
2.3
• •
13.5
10.5
5
5
3.6
MW-8
--
MVI-8
MU-8
MU-8
--
MU-8
MW-8
MU-8
MU-8
MU-8
6/21/90
--
6/21/90
6/21/90
6/21/90
--
6/21/90
6/21/90
6/21/90
6/21/90
6/21.90
• Ban* in
* Beryl lie*
• Cadniin
* Chromiu*
* Mercury
• Lead
• Manganese
* Nickel
• Thai lien
• Vanadiin
• Zinc
15/15
11/15
4/15
10/15
6/15
14/15
15/15
9/15
2/15
7/15
14/15
16.7-3010
1.1-344
3.1-57.5
4.1-213
0.27-54.3
1.5-244
119-24,200
8.4-1910
3.2-42.1
4.7-516
9.5-5620
199 MW-
5.9 MW-
12 MW-
14.5 MW-
3.9 MU-
11.2 MW-
996 MU-
42.6 MU-
22.7 MU-
81.8 MU-
87.4 MU-
5/18/90
5/18/90
5/18/90
5/18/90
rs 5/15/90
5/18/90
5/18/90
5/18/90
5/18/90
5/18/90
5/18/90
Dissolved Metals
CadMiui
Chromium
Mercury
Manganese
Lead
* Cobalt
* Nickel
• Zinc
• Bartvia
2/H
1/U
2/14
14/14
1/14
7/14
4/14
11/14
14/14
3.5-6.2
6.3
1.1-23.6
2.1-9000
6.1
4.0-49.4
8.2-148
5. 1-56.0
4.1-1400
4.9
6.3
12.4
227.5
6.1
8
72
10.1
161.4
MU-8
MU-70R
MU-7S
MW-8
MU
MU-8
MW-8
MU-9S
MW-8
6/21/90
6/20/90
6/20/90
6/21/90
6/21/90
6/21/90
5/18/90
6/20/90
5/18/90
Notes:
All Concentrations in ug/l.
<1) - North wells include eanitoring wells 4.7S.70«.8,9S,90. North Well (NW) and HOM well «.
NO - Not Detected.
• - Not potential chemicals of concern for Public Health Evaluation.
-------
TABLE... 2
PENNSYLVANIA OEPART"ENT OF ENVIRONMENTAL ~ESaJRCES
DORNEY ROAD LANDFILL SITE
,
CHE"ICALS OF CONCERN IN GRaJNDWATER . EAST WELLS
Location of
Contaminant F "e<:I\Jencv Ranqe of Oetection ~ fi4aJti- ~
Volatile O,.ganics
Vinyl Chlor-ide 2/20 6-7 6.5 fi4W-2S 6119/90
Chloromethane 2/20 10-14 12 fi4W"'0 6/'8/90
Total 1,Z-Oichloroethene "/20 ,.99 10.5 ~-Z5 6119/90
1,2-0ichloroethane 3/20 1.3-3 1.3 fi4W-Z5 5/17/90
1,1,1-Trichloroethane 5/20 1.0-2.5 1.3 14\1-115 5/16/90
Carbon Tetrachloride 2/20 15-31 23 14\I'11S 6/18/90
Tr~chloroetllene 13/20 2.0-31 5 ~-25 6/19/90
Tetrachloroetllene 13/20 1.6-210 3 14\1-25 6/19/90
Benzene 2/20 1. 9.4 3 14\1-25 5/17/90
1,1'0ichloroethane 12/20 1.5- 19 3 ~-25 5/17190
1,2'Dichloropropene 2/20 1.5.3 2.2 ~-25 5/17/90
Total Metals
. SariUl 20/20 21.8-190 100.5 ~-3S 5115/90
. SerylL iua 9/20 1.5-3.2 1.6 ~-2$ 5/17/90
. c.ani UI 1/20 2.9 2.9 ~-10S 5/1'/90
. Chromi UII 11/20 10.2-29.7 10.2 ~'3S 5/15/90
. Mercury 2/20 7.7'13.4 10.6 14\1'2$ 5/17/90
. Leed 18/20 1.3-119 2.9 14\1-3$ 5/15/90
. Mansanese 18/20 2.1-656 52.7 14\1-25 5/17190
. Nickel 3/20 6.5-43.2 7.1 14\1-25 5/17190
. TllalL iUII 1/20 4.5 4.5 14\1-35 6/20/90
. VanediUl 8/20 3.1-19.4 4.6 14\1-2$ 5/11190
. Zinc 16/20 11.5-130 28.9 ""-2$ 5/17/90
Dissolved Metals
Cach f UtI 3/16 2.5-7.0 3.3 MW-1(1O 5/110190
C1Ir08iUl 10/16 3.6-21.3 8.0 MW-3$ 6/20/90
Mercury 2116 0.62-0.66 0.64 MW-ZS 6/19/90
MMganeSe 15116 2.2-44.4 7.4 MW-3DR 5/15/90
Leed 7/16 1.5-63.6 2.0 ""-3$ 5/15/90
. C0b81t 4/16 4.8-9.0 5 ""-35 5/15/90
. Nickel lID
. Zinc 12/16 4.4-24.8 11.1 ""-25 6/19/90
. SariUl 18/18 19.2.165 38.1 14\1-lOR 5/11190
!!2!D:
All concentrations in UIIl.
GrcuQlater saa.,les frcn "".lOR and ""-3DR were ffltered ..ith a 0.2 UI
filter. All other s.-ples an.lyzed for dissolved ..tals were filtered
..ith a 0.45 UI filter.
(1) - East wells include monitoring ...lls 2S,lOI,3S.3DI,1OS,1OD,11S,11D and Home Well
lID - Not Detected.
. - lIot potential cll_lcals of concern for PWlfc HeaUh Evaluation.
lIos. 1,10,5, and 6.
-------
TABLE 3
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDFILL SITE
( 1)
CHEMICALS OF CONCERN IN GROUNDYATER - SOUTH YELLS
Location of
Contaminant Frequency Range of Detection Median Maxinun Date
Volatile Organics
Vinyl Chloride 2/10 2-8 5 SY 6/20/90
Chloromethane NO
Total 1,2-0ichloroethene 6/10 1.1-12 4.5 S\.J 6/20/90
1,2-0ichloroethane NO
1,1,1-Trichloroethane NO
Carbon Tetrachloride NO
Trichloroethene 4/10 1. 1-6 1.5 S\.J 6/20/90
Tetrachloroethene 6/10 1.8-2.8 2.3 MW-5S 5/15/90
Benzene 1/10 I, I, S\.J 6/20/90
1,1-0ichloroethane 3/10 1.3-4 1.3 S\.J 6/20/90
1,2-Dichloropropane 1/10 1.2 1.2 S\.J 6/20/90
Total Metals
* Bariun 10/10 61.2-333 94.4 S\.J 6/20/90
* Beryll iun 6/10 1.3-3.7 2.0 M\.J-6S 6/19/90
* Cad'niun 1/10 3.7 3.7 M\.J-6S 5/14/90
* Chromiun 7/10 5.9-28.5 9.8 M\.J-50 5/15/90
* Mercury NO
* Lead 10/10 1.1-17.2 10.6 M\.J-5S 5/15/90
* Manganese 9/10 14.4-2410 160 S\.J 6/20/90
* Nickel 1/10 22.8 22.8 S\.J 6/20/90
* Thall iun 1/10 6.3 6.3 S\.J 6/20/90
* Vanadiun 2/10 4-4.4 4.2 MW-6S 6/19/90
* Zinc 9/10 17-74.6 27.9 MW-6S 6/19/90
Oissolved Metals
Cad'niun 1/9 3.5 3.5 MW-5S 5/15/90
Chromiun 4/9 5.8-29.8 10.5 MW-5D 5/15/90
Mercury ND
Manganese 8/9 2.3-2390 15.5 SW 6/20/90
Lead 1/9 1.8 1.8 MW-6S 5/14/90
* Cobalt 1/9 27.5 27.5 SW 6/20/90
* Nickel 1/9 24.1 24.1 SW 6/20/90
* Zinc 9/9 8.4-32.9 11.2 MW-6S 6/19/90
* BariUII 9/9 13.9-352 75.6 SW 6/20/90
~:
All concentrations in ug/l.
(1) - South wells include monitoring wells 5S,50,6S,6O, South Well (SW) and Home \.Jell #2.
ND - Not Detected.
* - Not potential chemicals of concern for Public Health Evaluation.
-------
TABLE 4
. PENNSTlVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNET ROAD lANDFill SITE
OReANIC CHEMICALS DETECTED IN GROUNDWATER SAMPLES
--Background Results (ug/l)..--
Frequency of Concef'ltrat ion Median
Chemical Oetection Range (uq/l) ~ RW-S.6
.Vinyl Chloride 6/1.5 2-9 <10 <2
.Chloromethane 2/1.5 10- 11. <10 <10
Chloroethane 2/1.5 8-9 <10 <10
.1,t-Oichloroethane 24/45 1.3-32 <5 <5
-Total 1,Z~Oichloroethene 22/45 1. 1 -99 <5 <5
Chloroform 3145 5-t5 <5 <5
.',Z-Ofchloroethane 5/45 1.3-9 <5 <5
.',','-Trichloroethane 1/45 1.0-3 <5 <5
.Carbon Tetrachloride Z/45 15-31 <5 <5
.',2-0ichloroprop8ne 5/45 1.2-6 <5 <5
.Trichloroethene 19/45 1. 1- 31 <5 <5
.Benzene 5/45 1 .9- 7 <5 <5
.TetrachI oroethene 21/45 1.6-Z4 <5 <5
Ch I orotlenzene 2/45 7-10 <5 <5
Total Xyl.".. 2/45 44-52 <5 <5
~:
. Potential Ch_fcal. of Concern
.. Baled on Results fr- IU/SIV.1988
-------
TABLE 5
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDFILL SITE
INORGANIC CHEMICALS DETECTED IN FILTERED GROUNDWATER SAMPLES
Background Results (ug/l)..
Frequency of Concentration Median
Chefll;cal Detection !ranqe (1JI!:I/l) 14\1-'5 RW-S.6.7
Aluninun 9/39 14.6-301 20
-------
TABLE 6
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD lANDFill SITE - FfS
EXCEEDANCES OF POTENTIAL HEAlTH-BASEP AAARs
Maxl8U8 Detected .
loc:.tlon Cont_lnant V.tue
"'.8 lar". 1,010
"'.8 18I\I8nt 1
"'-8 C..tUl 51.5
..,. US C.rbon 'etrachlorlde 11
"'-8 Cltr.tUl 211
"'-8 CCIfIP8r 510
"'-8 ',2-DtchlorOlthene 9
"'-201 .. 'ot.t ',2-DlchtorOlthene 99
"'-8 l.ad 244
"'-8 It..,..... 81,100
..,- 75 Mercury. 54.1
"'-8 Nickel 1,910
"'.25 'etrachtorethene 24
III- 25 TrtchiorOlthene 11
"'-8 That t h. 42.1
111-8 Vlnvt Chi or I. 9
. 111-8 Zinc 5,620
111-8 1,2-Dlchtoropropene 6
potentiat ARAR, Exceeded
Exceeds PMCl (2,000).
Exceeds MCl (5), MCLG (0), PA ~ater Quatity Standards (1). and
AWDC for Drinking Yater (0.67).
Exceeds MCl (5), MClG (5) end AWDC for Drinking Yater (10).
Exceeds MCl (5), MClG (0), end AWDC for Drinking Wlter (0.4).
Exceeds MCl (100), MClG (100), PA Ylter Quatlty Standards (50),
and AWOC for Drinking Yater (50).
PA water Quat ItV Standards (100)
Exceeds MCL (5), MCLG (0), AWDC for Drinking ~ater (0.94) and PA ~ater
Quatlty Standards (0.4).
Exceeds MCl (70) and MClG (70) for Cis I saner.
Exceed8 EPA Action levet (15), PMCl (5), PMCLG (0). AWDC for Drinking Water
(50) and PA Yater Quatity Standards (50).
Exceeds SMCl (50) and AWDC for Prinking Uater (50)
Exceeds MCl (2), MClG (2), AWDC for Drinking Water (10) and PA
Yater QuatitV Standards (0.144).
Exceeds PMCl (100), PMClG (100) AWDC for Drinking ~ater (15.4) and PA Water
Quatlty Standards (632).
Exceeds MCl (5), MClG (0),
PA Water Quality Standards
Exceeds MCl (5), MCLG (0),
Quatlty Standards (3).
Exceeds PMCL (2/1), PMClG(0.5) AWDC for Drinking ~ater (13) and PA Water
Quatity Standards (13).
Exceeds MCl (2), MCLG (0), AWDC for Drinking Water (2.0) and PA Water
Quatlty Stendards (0.2).
Exceeds AWDC for Drinking Water (5,000) and PA Water Quality
Standards (5,000).
Exceeds MCL(S), MCLG (0).
PMClG (0). AWDC for Drinking Water (0.8) and
(0.7).
AWDC for drinking water (2.7) and PA Water
!t21S1 :
Att Concentrations in ug/I.
. Includes unfiltered sempte resuttl.
.. Jrans-1.2-Dichloroethene and Cis-1,2-Dichtorethene have been
reported as Total 1.2-Dichloroelhene.
-------
TABLE 7
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDFILL SITE
EXPOSURE ASSUMPTIONS UTILIZED IN RISK CALCULATIONS
CI1i ldren CI'1 i ldren CI1ildren Adul ts
0-5 Yrs. 6-11 Yrs. 12-17 Yrs. 18-30 Yrs.
Groundwater Intake
Rate (l/day) 1.0 1.0 2.0 2.0
Exposure Fr~ency (days/year)
Groundwater Ingestion 365 365 365 365
Showering NIA 365 365 365
Groundwater Absorption Factor
Stomach 1.0 1.0 1.0 1.0
Lung NIA 1.0 1.0 1.0
YeirS Exposed (yelrs) 6 6 6 12
Averlge LIfetime (years) 70 70 70 70
Body Weight (kg) 14.5 30.5 55.9 71.8
3 12
Bathroom Volume (m ) NIA 12 12
Water Used Per Shower (l/min) MIA 30 30 30
Shower Duration (minutes) NIl. 12 12 12
Inhalation Rate (.'/hour) MIA 1.0 0.6 0.6
-------
TABLE 8
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DOlNEY ROAD LANDFILL SITE
TOXICOLOGICAL CRITERIA FOR POTENTIAL CHEMICALS OF CONCERN
Oral Inhalation
IMalation Carcinogenic: Carcinogenic:
Oral ato ato Slope Fac:to~1 Slope Fac:tor
Chemic:al (mg/kg-day) (mg/kg-day) (mg/kg-day) (mg/kg-day)
Ca
-------
TABlE-9
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDRll .TE
UfETIME CANCER"8I( DUE TO CURRENT USE GROUNDWATER INGESnON
CURAfNT USE - HW-1 ADULTS 11-30
GROUNOWATfRINGflDON - CARCINOGENS
GW INTME ABSORPll ON BODY OAYSEXP YEARS EXP CANCER UfETlME
CONC. RATE fACTOR waOHT OAYS/YEAA YEARS LT. C[) POTENCY CANCER
COMPOUND JMi& JLtDm fUIITLESS) JU1 fUNTLESS) /UNITLESS, /MO/l(O - DAY) ~ ftm1
TIiCHlOROETHENE 0.007 2.00 1.00 71.80 1.00 0.11 3.34E-0~ 1.IE-02 3.eeE - 01
TEJRACHlOROETHENE 0.001 2.00 1.00 71.80 1.00 0.11 :1.38E - O~ ~.IE-02 1.22E-06
1.59E - 06
CURRENT USE - HW-1 CHILDREN 0-1
GROUNOWATERINGE8110N - CARCINOGEN I
GW INTME AB80RPllON BODY DAYS EXP YEARS EXP CANCER UffTIME
CONC. RATE fACTOR waOHT DAYS/YEAR YEARS l.T. C[) POTENCY CANCER
COMPOUND JMJW JLQUl fUIITLEI. JU1 fUHlTlEIS) ,UNlTLfSS, fM 0/1( 0 - OA Y) ill.IQ..!! ~
TIICHLOROETHENE 0.007 1.00 1.00 14.50 1.00 0.08 4.14E-05 IIE-02 4.5~E-Ol
TETRACHLOROEJHENE 0.001 1.00 1.00 14.50 1.00 0.08 2.80E-05 ~.IE-02 '.5'E-06
1.86E - 06
CUAAfNT USE - HW-1 CHILDREN 1-11
OROUNOWATfRINOflll0N - CARCINOGENS
GW INTAKE ABSOAPTlON BODY DAYS EXP YEARS EXP CANCER LJfETlME
CONC. RATE FACTOR WaGHT DAYS/YEAR YEARS L.T. C[) POTENCY CANCER
COMPOUND !Mi4t .cL.tlM:tl fUHlTlESS' JU1 .UHlTLESS, /UNITLESS, ,MO/l(O - DAY) fACTOR ftmS
TIiCHlOROETHENE 0.007 2.00 1.00 30.50 1.00 0.09 3113E -O~ I.IE -02 4 JJE - 01
TETRACHLOAOETHENE 0.005 2.00 1.00 30.50 1.00 0.09 2.8tE-O~ ~.IE -02 1.43E - 06
t 81E-06
-------
TABLE 9 (Coni..
PENNSYlVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDRU SIIT£
UfE11ME CANCER RISK DUE TO CURRENT USE GROUNDWATER INOEsnON
cURRENT USE - HW-1 CttLDREN 12-17
GROUNOWATERINGEB1\ON - CAAaNOGENI
OW INTAKE ABSORP1\ON BODY DAYS EXP YEARS EXP CANCER
CONC. RATE FACTOR waOHT DAVSlVEAR YEARS L.T. CD POTENCY
COMPOUND JMI& aan IUNTLUm JUl IUNTLESSI IUNlTLESSI IMQJt(Q- DAY) fACTOR
TIICHLOROETHENE 0.007 2.00 1.00 55.80 1.00 0.09 2.I~E-0~ 1.IE-02
TETRACHLOROETHENE 0.001 1.00 1.00 55.80 1.00 0.08 1.~3E-05 5.IE-02
TOTAL UFmYE CANCER IIIK REIUL1\NG fROY GROUNDWATERINGEITION (CURRENT USE)
i
I '
:
UFETlME
CANCER
~
2.3&E-07
1.82E-07
1.02E - 06
8.43E-06"
-------
TAaE 10
PENNSYlVAN~ DEPARrMEI« Of OMAD"'ENr Ai fESOURCES
DORIIEY ROAD tANOR.I. SITE
UfEflME CANCER RISK WE TO CURRENr USE IteWATION Of VOtATlLfS
CURRfNl' USE - HW-1 ADUlTS 11-30
INtWRION Of VOtATI.fS WHI.f &HOWERINB - CARQNOQENS
VOC IHOWEA INHAlATION A8SORPrION BODY ~YS EXP YEARS EXP CANCER lIfEllME
CONe. DUM'IOH fWE fACrOR WEIGHT ~YSlVEAR YEARS LT. CDI POTENCY CANCE R
COMPOUND JIHIoIUl BIB A&3MOlIRIi IUNIIUss\ JW) IUNITL£S$ IUHIIL£S$ II.4G/KG-~'r'} fAa.Q8 BIZ
TRICHlOROffHEHE 0.210 0.3» 0.80 1.00 71.80 1.00 0.11 802f -O~ 1.1£ -02 1112£-06
TElIWH.OROEJHENE 0.150 0.3» 0.80 1.00 71.80 1.00 0.11 4.:J)f-0~ 3:£-03 U2E-01
1.1610-06
CURREHr U8E - HW-1 CHLDREHI-11
NWRION OF VOtATI.fS WHI..E &HOWEfWG - CARaNOOENI
VOC &HOWER IHtWAJIOH A880RPrION BODY ~YS EXP YEARS EXP CANCE R lIfEllME
CONe. DURATION IWE FlaOR WEIOtfI' ~YWYEAR YEARS LT. CDI POJENCY CANCER
COUPOUND ~ tIQUJI ~ ANl'Lf'8Sa 0 IUNfL£SS'I /UNIT 1.£ S$) IMQ/KG-DAVI fAk[Q8 WiK
TIICHLOROffHEHE 0.210 0.3) 1.CIO 1.00 ~50 1.00 o.m \.lee - 04 11£-02 201E-06
TElMCHLOAOErHENE 0.150 0.3» 1.00 1.00 ~IIO 1.00 o.m 8.431:-05 3:£ -03 2.1IIf - 01
2 4!8E-06
CURRENI' USE - HW-1 CHIlDREN 12-17
NWRIOH OF IIOiATI.f8 WHI.f 8HOWEfWG - CARQNOGEN8
VOC &HOWER INHAlATION A890RPrION BODY ~YS EXP YEARS EXP CANCER
CONe. DURATION fWE FlaOR WEIGHT ~YSIVEAR YEARS LT. CDI POJENCY
COMJIIOUtiD .CImIUl taB II&3MOUII IUNfL.Esm «m /UHIIL£S$ /UNIT 1.£ SS1 II.4O/KG - DA VI fAWlli
TIICHLOROE1HfHE 0.210 0.3) 0.80 1.00 ~80 1.00 0.11 1.13E-0~ 1.1£-02
TEIMCHLOROEJHENE 0.150 0.3) 0.. 1.00 MIO 1.00 0.11 ~52E-05 3:£-03
TOTAL UfErIMf CANCER flSIC RESULTING FfOMINHAI.ATION OF WtATLE8lMiLE SHOWERING CCURRfNr USE)
TOTAL UfErIMf CANCER fI8( RESULTING FfI)M GROUNDWATER USAGE CCURRfNr USE INOfSTIOH AND SHOWERNG)
LIfETIME
CANCER
WiK
1.31E -06
1.82E -01
15Qf-06
4 ~E - 06
1. 14E - O~
-------
TABlE ,.11
PEtMM.VNIA DEPAltU8EHJ OF ENVIH0188ENr Al 1£9OURCf'S
OOIlfEY ROAD LANDFU 8I1'E
NOH-CAItCINOOENIC .... DUE TO CURl£JG' USE GROUNJWATER MlESJION
CUfUIENI' USE - HW-1 ADUlTS 18-30
GROUNIIWUEA 1NOE.8OH -NONCARaN0GfN8
OW NME A880API'ION IIOO't' MY8 EXP
CONe, MrE fAaOR WEIGHT MV8IVEAA COI RFD HAZARD
COUfIOtH) JIIUl .... AJMrI FIUf & IUNlIl.Ed IUBlKO- M'l) IUO/I{Q-M't') IHW
1.2-OCHLOROETHENE 0.011 2.OD l.OD 71.10 1.00 6.01E-04 21£-02 251E-02
TElIWH.OROETHENE 0.- 1.8 1.8 71.. 1.00 USE -04 1.1£-02 1.38£-02
3110E -02
CURIE'" USE - HW-1 CHI.DIEN 0-1
GROUNIIWUER 1NOE.8OH -NON:ARCINOGENI
O/IN N'ME ABmRPl'8OH IIOO't' MYS EXP
CONe. ME fAaOR WEIOtfI' MY'IWEAA COI RFD HAZARD
COMPOUND -.u A.5Im ANrIE.. & AJNII'lESSI IUG/KQ-MY'I IUO/I{Q - DA YI IWJf!
1.2-OICHLOROETHENE 0.011 1.00 1.00 14.50 1.00 U4E -03 2.1£-02 8.21E-02
TETMCHLOROETHENE 0.005 1.00 1.00 14.50 1.00 3.451;-04 1.1£-02 3.451;-02
8_-02
CURIE'" USE - HW-1 CHlLDAENI-tt
OROUNDWUEA INOE.ION -N0NCARC8N0QfN8
OW IHT ME A880RPI'ION BODY MYS EXP
CONe. ME fACl'OR WEIGHT MYWVEAA COI RFD HAZARD
COMPOUND 08fW A.5Im AJMrlE8m & lUNlfl.Esm IUBlKQ-DAY'I IMGJKO-DA't') IWJf!
t,2-OCHLOROETHENE 0.011 2.00 1.00 30.50 1.00 1. 88E-03 2.1£-02 500(-02
TETIWHOROETHENE 0.005 2.00 1.00 30.60 1.00 U8E -04 1.1£-02 3 2IIIf - 02
9. 18E-02
I .
I
-------
T AaE. 11 f:Gnlt
PEI88YlVANIA DEPARUIENT OF EIMAOMIENrAl RESOURCES
OO"'EY ROAD LNCJFU 8fl'E
NON-CAIIC8M)GfJIC .... DUE TO CURRENr USE GROUNDWATER INOfSHON
CUAAEHr USE - HW-1 CHI.DAfN 12-17
GROUNOMQER INOEsrlON -NONCAACItOOENI
ow INI'M£ ABSORPfION 801W Do\VS DP
CONe. MIl fAaOR WEJOHI' Do\YS/YEAR CO! RFD HAZARD
COMPOUND AtQ4l UU A"'lE~ U IU..ln£ss BlQJl(O-Do\'t'.) IYOJI(Q-~YI JNW
U-IIQtlOROETHENE 0.011 2.1D 1.00 65.80 1.00 U4E-04 2.1£-02 3.22£-02
TETMQtLOROETHENE 0.001 2.1D 1.00 UtO 1.00 nIlE - 04 1.1£-02 U9E-02
~.O'E -0'2
-------
T AIIl£ 12
PEI8tnl.VAIM DEPAfI'MfNJ Of fN\IIROI8IENT At. 1ESOUta:8
DOftNEY IIQM) _E
IION-c-.MCIIIOOOIC ... OUETOCURRENr U8EINtW..AT8OII Of WlATI.£8
CURIEHI' use - HW-1 ADUlT811-3O
IlWATION Of VOI.ATU81M11£ 8HOWEfINO - NONCAACINOOfNS
VOC ...... INHAU.TION A880IRION BOD\' MVS EXP
OOHC. DUMJIOII RATE FACfOA WEIGHT MYSJWEAA CO! AI) HAZAR>
OOUPOUtol) MYQ1 "" ADMOUft AJNIf. FSS' d AJNII'LE~, IMQMQ-(}AV) "QMQ-(}A'{\ taX
1.2-DCHLOROErHENE 0.540 0.8 0.. 1.00 71.80 1.00 !I.OJE -04 2.11:-02 451E-02
TETIWKOROErHENE 0. I. 0.8 0.. 1.00 71.80 1.00 2.51E -04 1.11: -02 2.51E-02
702f-02
CUAIENI' UIE - HW- 1 aaDAEH 1-11
IlWATIOII Of VOtATU81M11£ IHOIAEMIG - NONCAACINOGENI
VOC ~A IlWATION A88OIRION BOD\' MVS EXP
OOHC. OUIWIOII RATE FACfOA WEIGHT MWM:AA CO! AI) HAZAR)
00UP0Ut0I) MYQ1 jDIfI AIMtOUft .... FSS' - ....-. FSS'I f.lQMQ-(}A'{\ &lQMQ-(}A'{\ !taX
1.2-DCHLOROETHENE 0.540 0.20 1.00 1.00 30.50 tOO 3.~-03 2.11:-02 07£-01
TETfWH.OROSHENE 0. I. 0.8 1.01 1.00 30.60 1.00 U4E -04 1.11: -02 !l1ME-02
2.75f-OI
CUAIENI' UIE - HW-1 CHI.OfIEN 12-17
NWATION Of VOI.ATU81M1L£ 8ttOIM:fINO - NOHCARCINOGENI
VOC SHOWER INHAU.TION ABSOIRION BOD\' MVS EXP
OOHC. DUMTION RATE FACfOA WEIGHT MWM:AA CO! AI) HAZAR)
OOWOUND MUW JJQWI AIMtOUR AN'.FS!U 81 .... FSS' &lQMQ-(}A'{\ "QMQ-(}A'{\ WW
1,2-DCHLOROErHENE 0.540 0.20 0.10 1.00 55.110 1.00 1.1f1f-03 2.11:-02 5.1111: - 02
TElIWH.ORDETHENE 0. I. 0.8 0.. 1.00 115.110 1.00 3.22£ -04 1.11: -02 322£-02
802f-02
-------
TABLE.,13
PENNSYlVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
DORNEY ROAD lANDRll SITE
UFE11ME CANCER RISK DUE TO FUTURE USE GROUNDWATER INGESnON
fUTURE USE - ADULTS \1-30
GROUNDWATEIiINGf8110N - CARCINOGENS
GW INTAKE ABSORPlION BODY DAYSEXP YEARS EXP CANCER UfETIME
CONC. RATE FACTOR WaGHT DAYSlYEAR YEARS L.T. CD POTENCY CANCE"
COMPOUND 1!494l aan IUNlTLESSt m..g} IUNlTLfSSt IUNlTLfSSI /MGJI(Q- PAY) fACTOR !ti!S
VINYl CHLOfiDE 0.002 2.00 1.00 71.80 1.00 0.17 1.06E -os 1.9E t 00 2 0 I E - OS
t,2-DlCHLOIiOETHANE 0.002 2.00 1.00 71.80 1.00 0.11 1.83E-06 9.IE-02 1.I3E-Ol
CHLOROMETHANE 0.003 2.00 1.00 71.80 1.00 0.17 U9E-OS 1.3E - 02 2 01E-Ol
CARlON TETRACHLOIllDE 0.001 2.00 1.00 71.80 1.00 0.17 2.S1E - OS 1.3E-01 3.3SE - 06
TIICHLOROETHENE 0.001 1.00 1.00 71.80 1.00 0.17 4.44E-OS I.IE - 02 488E - 01
BENZENE 0.002 1.00 1.00 11.80 1.00 0.17 8.19E-06 2 9E - 02 2.SSE-Ol '
TETRACHlOROETHENE 0.007 2.00 1.00 71.80 1.00 0.11 3.31E-05 5.1E-02 I .12E - 06
t,2-DlCHLOROPROPANE 0002 2.00 1.00 71.80 1.00 0.17 8.02E - 06 6 8E - 02 5.46E-Ol
1. I - DlCHLOROETHANE 0.001 2.00 1.00 71.80 1.00 0.11 3.09E -os 9.IE-02 2.82E-06
3.01E - 05
FUTURE USE - CHLDREN 0-5
GROUNDWATERINGE8110N - CARCINOGENS
GW INTAKE ABSORPlION BODY DAYS EXP YEARS EXP CANCER UFf11ME
CONC. RATE FACTOR WaGHT DAYs/yEAR YEARS L.T. CD POTENCY CANCER
COMPOUND JU41 &Am IUNlTLESSt m..g} IUNlTLfSSt /UNITLESSI /MQJI(Q - PAY) fACTOR Jtl!S
VINYl CHLOfiDE 0.002 1.00 1.00 14.~ 1.00 0.09 1.31E-05 1.9E .00 2.48E-os
t,2- DlCHLOROETHANE 0.002 1.00 1.00 14.50 1.00 0.09 8.69E - 06 9.IE - 02 882E-01
CHLOROMETHANE 0.003 1.00 1.00 14.50 1.00 0.09 1.91E -OS I JE - 02 2.S1E-01
CARBON TETRACHLOIllDE 0.005 1.00 1.00 14.50 1.00 0.09 3.19E-OS I JE -01 4 \4E-06
TIICHLOROETHENE 0.008 1.00 1.00 14.~ 1.00 0.09 S.49E-05 1.IE-02 6 04E - 01
BENZENE 0.002 1.00 1.00 14.50 1.00 0.09 1.09E - OS 2 9E - 02 3.ISE-01
TETRACHLOROETHENE 0.007 1.00 1.00 14.50 1.00 0.09 4.I1E-05 S1E-02 2 I3E - 06
t,2- DlCHLOROPROPANE 0.002 1.00 1.00 14.50 1.00 0.09 993E-06 6 8E - 02 61SE-01
1.1-DlCHLOROETHANE 0.001 1.00 1.00 14.50 1.00 0.09 3.83E - 05 91E-02 349E-06
3 13E - OS
-------
TABLE 13 (Coni.)
PENNSYLVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
DORNEY ROAD I.ANDRlL SITE
UfE11ME CANCER RISK DUE TO fUTURE USE GROUNDWATERINGESnON
fUTURf USE - CttLOREN I-I I
GROUNDWATfRINGUnON'- CARCINOGEN'
GW INTAKE ABSORP110N BODY DAYS EXP VEARS EXP CANCER UfEllME
CONC. RATE fACTOR WBGHT DAYSlYEAR YEARS l.T. CD POTENCY CANCER
COMPOUND lMi& A&m 'UNITLESSA 4UD ,UNlTLESSI ,UNlTLESSI IMOJl(O - DAVI lli.IQfi ~
VINYL CHLOfiDE 0.002 2.00 1.00 30.50 1.00 0.09 1.24E-05 1.9EtOO 2 36E - 05
1.1- OICHLOROETHANE 0.002 2.00 1.00 30.50 1.00 0.09 922E - oe 9.IE -02 839E-01
CHLOROMETHANE 0.003 1.00 1.00 30.50 1.00 0.09 1.88E-05 1.3E-02 2.44E-01
CARBON TETRACHLORIDE 0.005 2.00 1.00 30.50 1.00 0.09 3.03E-05 1.3E-OI 3.94E-06
TfiCHLORO£THENE 0.001 2.00 1.00 30.50 1.00 0.09 5.22E - 05 1.1E - 02 514E-01'
BENZENE 0.002 1.00 1.00 30.50 1.00 0.09 1.03E - 05 2.1IE-02 300E - 01
TETRACHLOROETHENE 0.007 1.00 1.00 30.50 1.00 0.09 391E-05 5.1E-02 2 02E - 06
u- OICHLOROPROPANE 0.002 2.00 1.00 30.50 1.00 0.09 944E-06 6 IE - 02 6.42E-01
1.1- OICHLOROETHANE 0.001 2.00 1.00 30.50 1.00 0.09 3.64E - 05 9.1E-02 3.31E-06
3.55E-05
fUTURf USE - CttLOREN 12-17
GROUNDWATERINGESlION - CARCINOGENS
GW INTAKE ABSORPnON BODY DAYS EXP YEARS EXP CANCER UfEnME
CONC. RATE fACTOR WBGHT DAYS/YEAR YEARS l.T. CD POUNCY CANCER
COMPOUND 1d4l A&m 'UNlTlE8SI 4UD 'UNlTlESSI ,UNlTlESSI 'MOJl(G-PAVI fACTOR "S~
VINYl CHLOfiDE 0.002 2.00 1.00 55.90 1.00 0.09 8.18E-06 1.9EtOO I.29E-05
u- OICHLORETHANE 0.002 2.00 1.00 55.80 1.00 0.09 5.03E - 08 9.IE-02 4 58E - 01
CHLOROMETHANE 0.003 2.00 1.00 55.80 1.00 0.09 I.02E-05 1 3E - 02 I.33E-01
CARlON TETRACHLORIDE 0.005 2.00 1.00 55.80 1.00 0.09 1.65E - 05 1.3E-OI 2.15E-06
TfiCHLOROETHENE 0.001 2.00 1.00 55.80 1.00 0.09 285E-05 I.IE-02 313E-01
BENZENE 0.002 2.00 1.00 55.80 1.00 0.09 5.64E - 06 2.9E-02 1 64E -01
TETRACHLOROETHENE 0.007 2.00 1.00 55.80 1.00 0.09 211E-05 5 IE - 02 UOE-06
u- OICHLOROPROPANE 0.002 2.00 1.00 55.80 1.00 0.09 5.15E-06 6 8E - 02 3 50E - 01
1.1-IICHLOROETHAHE 0.001 2.00 1.00 55.80 1.00 0.09 1.99E-05 8.1E-02 I.81E-06
1 94E - 05
~TAL UfEnME CANCER fiSK RESUlnNO fROM OROUNDWATERINOESTION (FUTURE USEI 1 2<>[ - 04
-------
TABl£ 14
PENNSVlVNM DEPARI'MENr Of ElMRONUENJAL RE80URCES
OO"'EY ROAD LAHDfU IfI'E
UfBlME CANCER ... DUE TO RlrURE .. I18WATION Of WOlAlIl£S
fil'UAE USf - ADUlTS "-30
NWATION Of YOtAJUI WHI.£ SHOWERINCI - CARCIN00EH8
\IOC IHOWER INtWATION AB90RPrION BODV' MYS EXP YEARS EXP CANCER lIf ETIME
OOHC. DUMTION IWE fACI'OR WEIGHT MVWVEAR YEARS LT. CO! POTENCY CANCE R
CQUPOtN) ~ .. IU:IMOUII plll'L£SS\ ti1 AJNITL£~ ~L£SS\ lUG/KG - DAY! UQ.Q8 BIZ
WM. QtLOIIDf 0.C154 UD 0.111 UIO 11.80 UIO 0.11 I !WE -o~ 3.1£-01 4.S.E - 08
'~OICHlOROfTHANE 0.088 0.. 0.111 UIO 11.80 UIO 011 1 JIIE -O~ 81E-02 UtiE - 06
QtLORDIIEfHANE 0." UD 0.111 UIO 11.80 1.110 0.11 2 59E-0~ 8:£-03 16JE-01
. CAfIIONTEJfW:HlOllDf 0.1a 0.. 0.111 1.110 11.80 1.00 0.11 4.10E-0~ 1:£-01 ~.:oe - 08
TIICHlOROflHEHE 0.213 UD 0.111 UIO 11.80 1.00 0.11 8.1OE-05 OE - 02 100E-oe
ENlENE 0.. 0.. 0.111 1.110 11.80 1.110 0.11 1.48E - 05 2.1£-02 429E-Ol
TEJIW:HLOROETHEtE 0.. 0.. 0.111 1.110 11.80 1.110 0.17 . 64E-05 3:£-03 1.~-07
t~OICHLOROPROPANE 0.081 0.. 0.111 1.110 11.80 1.00 0.17 1.:&E-05 61£-02 9 41E -01
t. t-DICHlOROEfHANE 0. 157 0.. 0.111 1.110 11.80 1.00 0.11 4.48E-05 81E-02 UIBE-oeo
1.79E - O~
fil'UREUSf - CHaDRENe-1t
NWATION Of YOtAJU8 WHU SHOWERINCI - CARCINOGENS
\IOC SHOWER INtWATION ABSORPrION BODV' MYS EXP YEARS EXP CANCER LIfETIME
CONe. DURATION IWE fAcrOR WEIGHT ~YSM:AR YEARS LT. CO! POTENCY CANCER
COMPOUND ~ tmU8 a&.1MOUll /UNlfL£SS\ U) (JJNlTL£SS) IUNITL£SSI IMG/KG-DAYI fl&I.Qfj WK
WM. CHlORDE o.~ 0.20 1.00 1.110 30.50 1.00 0111 3112E -O~ 3(£-01 8~-06
t.2-DICHlOAOfTHAHE o.eMe 0.20 1.00 1.00 30.50 1.00 000 2.11E-05 91E-02 241E-06
CHLOROMETHANE 0.080 0.20 1.00 1.00 30.50 1.00 000 508E-0~ 6 :»;-03 3:.DE - 01
CARIIONTEJMCHLORDE 0.143 0.20 1.00 1.00 30. 50 1.00 0.00 804E-05 1 :£-01 I04E-05
TIICHlOROEntENE 0.213 0.. 1.00 1.110 30.50 1.00 000 1 :.DE - 04 1.11:-02 2 O4E-06
IIfNZENE 0.052 UD 1.00 1.00 30.50 1.00 000 2~-0~ 2 !£ - 02 841E-01
TEJfW:HLOROETHENE 0.112 0.20 1.00 1.00 30.50 1.00 0.00 911E-05 3 :E - 03 3 OOE -0'
1.2-OICHlOROPROPANE o.eMe 0.3» 1.00 1.110 30.50 1.00 0.00 213E-05 6 1£ - 02 186£-06
I. t-OICHlORDErHANE 0.157 0.3» 1.00 1.00 30.50 1.00 000 86OE-05 91E-02 80IE-06
3 ~E-O~
-------
TABU: 1 4 ~I..
PENNSVlVAIM DEPARrMENr Of BMAOI8IENT Ai. RESOURCES
DOIII8EV ROAD I.AMJfI.l 8IfE
UmlME CANCeR ... OOE TO fUrURE USE DeW.ATION OF \IOlATIlE8
fWUfIE USE - CHIlDREN 12- 17
NWATION OF VCKATU8 WHI..E &HOWEfINB - CARCINOGEH8
VOC IHOWER INHAlATION ABSORPI'ION 800V MYS EXP YEARS EXP CANCER
CONe. IJUlWION fWE FACfOR WEIOHI' MYSlYEAR YEARS LT. CO! POTENCY
COMPOUND lMGI1a MIll ~" AJNII'I ~5.1 d 1UN1(L£SS\ IUNIH£SS' IMGlKG-DAY\ fAC[QB
\11M. CHlOIIDE 0." 0.. 0.. UD 55.80 1.00 0.00 IlIIIIE - 06 31£-01
1.I-DICHlOROErHAHE 0.CM8 0.. 0.. 1.00 55.110 1.00 0.00 I IIIIf - 06 1I.IE-02
CHlOAOMB'tWIE O.CIIO 0.. 0.. 1.00 5&80 1.00 0.00 UIIE -05 8:1;-03
CARIOMTEJMCHlORDE 0.143 ... 0.. 1.00 55.80 1.00 om 2.83E-05 1:1; - 01
TIICHLOROE'lHENE 0.213 UD ... 1.00 55.80 1.00 om 311Zf-05 11£-02
BENZENE UU ... ... 1.00 55.110 1.00 o.m 1I.48E-0I 211E-02
TEJIWH.OROErHEHE ..- ... 0.. 1.00 55.80 1.00 0.00 2.9IIE-05 3 :1;-03
1.I-DICHlOROPROPANE ..... 0.. 0.. 1.00 55.80 1.00 o.m I !ME-De 811:-02
1. t-DICHlOROErtWIE 0.157 UD 0.. 1.00 55.80 1.00 o.m 2111E -05 1I.IE-02
TOTAL. UFETIMf CANCER". flESUlTINO flOM NW.ATION Of VOI.ATILf81Mi1..E SHOWERING
TOTAL. UFETIME CANCER II8IC flE8UlTINO flOM AU.. QROUtOVATER USAGE CfUI' UfE UtE INOEsrlON AND &HOWEIING)
UfETIME
CANCER
~
2111E -06
109E-01
1.06f-01
342E-06
I 8tiE -01
2~-01
984E-08
10IE-01.
2.82£ - 06
1.1~-05
8.4tiE-05
Ul6f - 04
-------
TABL5- 15
PENNSYLVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
DORNEY ROAD LAHDAll SITE
NON-CARQHOOEHIC IISKS DUE TO fUTURE USE GROUNDWATER INGESlION
fUTURE USE - ADULTS 11-30
OROUHDWATERINOUDOH -HONCARQHOOEHI
OW INTAKE ABSORPDON BODY DAYS EXP
COHC. RATE fACTOR wa OHT DA YSIYEAR CD RFD HAZARD
COMPOUND tM.9& JIam ,UHlTLESS) J!.S.21 ,UNITlESS) 'MOJKO-PAY) 'MOJKO-DAY} lli!!t!
CARBON TETRACHLORIDE 0.005 2.00 1.00 11.80 1.00 1.50E - 04 7.0E - 04 2.14E-01
1.1.1- TfiCHLOROETHANE 0.002 2.00 1.00 11.10 1.00 4.40E-05 9.0E - 02 4.89E - 04
U- DlCHLOROETHENE 0.021 2.00 1.00 11.10 1.00 1.35E-04 2.0E-02 367E-02
TETRACHLOROETHENE 0.007 2.00 1.00 71.10 1.00 1.81E-04 1.0E-02 1.91E-02
1.1- DlCHLOROETttANE 0.001 2.00 1.00 11.80 1.00 1.1IE-04 1.0E-01 1.81E-03
CADMIUM 0.002 2.00 1.00 11.80 1.00 6.18E-05 5.0E - 04 1.24E - 01
CHR08IUM 0.001 2.00 1.00 11.80 1.00 2.62E-04 50E - 03 5.24E -02
MANGANESE 0.114 2.00 1.00 11.10 1.00 3.18E-03 10E-01 3.18E-02
MERCURY 2.20E-04 2.00 1.00 11.80 1.00 6.13E-06 3.0E - 04 2.04E -02
~ 02E - 01
fUTURE USE - CHLDREN 0-5
OROUHDWATERINOE8DOH -NOHCARQHOOEHS
OW INTAKE AB80RPl1ON BODY DAY8 EXP
CONC. RATE FACTOR waOHT DAYSlYEAR CD RFD IIAlAHD
COMPOUND tY2LU. JIJD6n ,UHlTLESS) J!ID 'UNITLESS) 'MOJKO- DAY} (MGJKG - DAY} lli!!Q
CARBON TETRACHLORIDE 0.005 1.00 1.00 14.50 1.00 3.12E-04 7.0E - 04 ~ JIE-OI
1,1,1- TIICHLOROETHAHE 0.002 1.00 1.00 14.50 1.00 1.09E-04 9.0E - 02 12IE-OJ
u- DlCHLOROETHEHE 0.028 1.00 1.00 14.50 1.00 1.82E-03 2.0E - 02 9 09E - 02
TETRACHLOROETHEHE 0.001 1.00 1.00 14.50 1.00 4.81E-04 10E - 02 481E-02
1.1- DlCHLOROETHANE 0.008 1.00 1.00 14.50 1.00 4.41E-04 1.0E-01 441E-03
CADMIUM 0.002 1.00 1.00 14.50 1.00 1.53E -04 5.0E-04 J06E-01
CHRO"UM 0.008 1.00 1.00 14.50 1.00 8.49E-04 5 OE - 03 1 30E -01
MANGANESE 0.114 1.00 1.00 14.50 1.00 1.88E-03 1.0E-01 1.88E - 02
MERCURY 2.2OE-04 1.00 1.00 14.50 1.00 1.52E-05 3 OE - 04 5.06E - 02
1 24E . 00
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TABlE'15 (Coni.)
PENNSYLVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDRll SITE
NON-CARQNOGENIC flSKS DUE TO fUTURE USE GROUNDWATER INGESTION
fUTURE USE - CHLDREN 8- ..
OROUNOWATERINOfS110N -NONCARQNOOENS
OW INTAKE ABSORPl1ON BODY DAYS EXP
CONC. RATE fACTOR waOHT DAYS/YEAR CD RFO HAZARD
COMPOUND t!!9.lLl ~ fUNITLESSl J!S.ID fUNITLESSI fMGJI(Q-DAY) fMGJI(G- OAY} lli.QQ
CARBON TETRACHLORIDE 0.005 2.00 1.00 30.50 1.00 3.53E-04 1.0E-04 5.05E - 01
'.1.1- TRCHLOROETHANE 0.002 2.00 '.00 30.50 1.00 1.04E-04 9.0E - 02 1.15E - 03
u- PlCHlOROETHENE 0.028 2.00 1.00 30.50 1.00 t.13E-03 2.0E-02 8 65E -02
TETRACHlOROETHENE 0.007 2.00 1.00 30.50 1.00 4.83E-04 1.0E-02 4 63E -02
eo e -PICHLOROETHANE 0.008 2.00 1.00 30.50 1.00 4.25E-04 '.OE-OI 4.25E - 03
CADAIUM 0.002 2.00 1.00 30.50 1.00 1.46E-04 5.0E - 04 2.91E -01
CHRO"UM 0.008 2.00 1.00 30.50 1.00 6.17E-04 5.0E-03 1.23E-01
MANGANesE 0.114 2.00 1.00 30.50 1.00 7.5OE-03 10E-01 7.50E-02
MERCURY 2.2OE-04 2.00 1.00 30.50 1.00 1.44E -05 3.0E-04 4.8IE-02
I. 18E t 00
fUTURE uaE - CHLDREN 12-17
OROUNOWATERINOfS110N -NONCARQNOOEN8
OW INTAKE ABSORP110N BODY OAYSEXP
CONC. RATE fACTOR waOHT OA YS/yEAR CD RFO "AlARD
COMPOUND JM!Ui1 n.mm fUNlTLfSSI J!UU fUNlTLESSl fMGJI(Q-OAY) fMGJI(G-OAY) l!illE!
CARBON TETRACHLORIDE 0.005 2.00 '.00 55.90 1.00 0.00 7.0E - 04 2 75E -01
e. e. e - TRCHlOROETHANE 0.002 2.00 1.00 55.80 '.00 0.00 9 OE - 02 6 28E - 04
u- PlCHlOROETHENE 0.028 2.00 1.00 55.80 1.00 0.00 2.0E-02 4 12E - 02
TETRACHLOROETHENE 0.007 2.00 1.00 55.80 1.00 0.00 1.0E-02 2 53E - 02
e.e-PICHLOROETHANE 0.008 2.00 1.00 55.80 1.00 0.00 1.0E-01 2.32E - OJ
CADAIUM 0.002 2.00 1.00 55.80 1.00 0.00 50E-04 1.59E -01
CHRO"UM 0.00i 2.00 1.00 55.80 '.00 000 5 OE -03 6 73E -02
MANGANesE 0.114 2.00 1.00 55.80 '.00 000 1.0E-01 4.09E - 02
I8fRCURY 2.20E-04 2.00 1.00 55.80 1.00 0.00 3.0E - 04 262E-02
8.44E-01
i .
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TABLE 16
PENNSYlVANIA DEPARTMENT Of EN~RONM(NTAL RESOURCES
DORNEY ROAD LANDRLL flTE
NON-CARQNOGENIC Rl8K8 DUE TO fUTURE U8E INHALAnON OF VOLAnLES
fUTURE USE - ADULTS 18-30
INHAlATION Of VOLATILES WHILE 8HOWERlNCt - NONCARCINOGEN8
VDC '"OWER INHALATION ABSORPTION BODY DAYS EXP
CONC. DURATION RATE fACTOR WBGHT DAYS/YEAR CD AID HAZARD
COMPOUND 'M0IU8 JWHI.ID 'M3IHOUm 'UIITlESS. 01 'UNTlESSI 'MGJt(G-DAYI 'MOJt(G-DAYI lliW
CARBON TETRACHLORIDE 0.143 0.20 0.10 1.00 11.80 1.00 239E - 04 7.0E-04 341E-OI
',1. . - ,"CHlOROETHANE 0.047 0.20 0.10 1.00 11.80 1.00 7.11E-05 3.0E-OI 2.59E-04
U-DICHLOROETHENE 0.17' 0.20 0.10 1.00 1'.80 1.00 '.86E-04 2.0E-02 4.83E - 02
'ETRACHLOROETHENE 0.182 '.20 0.10 1.00 11.80 1.00 2.11(-04 I.OE-02 211E-02
'.' -DICHLOROETHANE 0. 117 0.20 0.10 1.00 71.80 1.00 2.62E - 04 I.OE-OI 2.62E - 03
4.20E-0'
fUTURE USE - CttLDREN .- II
INHAlATION Of VOLATlLE8 WtllE SHOWERING - NONCARCINOGENS
VDC SHOWER INHALATION ABSORP11ON 80DY DAYS EXP
CONC. DURATION RATE fACTOR WBGHT DAYSlYEAR CD RIO "AZARD
COMPOUND JIWIU1 JWWm 'M3IHOUm 'UNlTlESS. 01 'UNTLESSI 'MGJt(G-DAYI 'MGJ)(G-OAYI UtW
CARlON TETRACHLORIDE 0.'43 0.20 1.00 1.00 30.50 1.00 '.38E-04 1 of - 04 1.34E.00
1.',1 - T"CHlOROETHANE 0.047 0.20 1.00 1.00 30.50 1.00 3.05E - 04 3 OE - o' '02£-03
1.1- DlCHLOROETHENE 0.57' 0.20 1.00 1.00 30.50 1.00 3.18E-03 2.0E - 02 I. toE - o.
TETRACHLOROETHENE 0.112 0.20 1.00 1.00 30.50 1.00 I.06E-03 10f-02 '.06E-O.
1,1 - DlCHlOROE1HANE 0.151 0.20 1.00 1.00 30.50 1.00 I.03E-03 1.0E-01 I.03E-02
1.8SE .00
-------
TABLE 16 . ,Coni.)
PENNSYLVANIA DEPARTMENT Of ENVIRONMENTAL RESOURCES
DORNEY ROAD LANDRLL SITE
NON-CARQNOOENIC 1181(8 DUE TO fUTURE USE INHAunON OF VOLAnlES
fUTURE USE - CttlDREN 12- 17
INHALAlION Of VOLAlIlES WHILE SHOIM:RlNG - NONCARCINOOEN8
voe IHOWER INHALAlION ABSORPIIOH BODY DAYS EXP
CONC. DURAnON RATE fACTOR WBOHT DAYS/YEAR CD RIO HAZARD
COMPOUND CMG/Ma JWWm CM3IHOUm CUNITLESS' Ul IUNITlESS' /MOII(O - DA Y} /MOIKO - DAY} uwn
CARBON TETRACHLORIDE 0.143 0.20 0.80 1.00 55.80 100 3.01E-04 1.0E-04 4.38£ - 01
'.',' - TIIC...OROETHANE 0.047 0.20 0.80 1.00 55.80 1.00 8.88E-0~ 30E-OI 3.33£ -04
1.2- DlCHlOROETHENE 0.57' 0.20 0.80 1.00 55.80 1.00 1.24E -03 2 OE - 02 0.20£ - 02
TETRACHLOROETHENE 0."2 0.20 0.80 1.00 55.80 1.00 3.48E-04 I.OE - 02 348£ - 02
1.1-DlCHlOROETHAHE 0.'.7 0.20 0.80 1.00 55.80 1.00 3.36E-04 I.OE-O\ 3.38£-03
II 38£-01
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T*0£ 17
PENN9VIVAMA OEPARTUaff OF BMRONMENTAi. RESOURCES
OOHNEYRQADailE-FFB
SUMMARY MATRIX FOR DETMLED EVALUATION OF ALTERNATIVES
Alternative 1
Mo Action
COSTS
Capital
to
0 ft N
(14,160 (annually)
(32.S36 (every 5 y««r»>
Prtttnt Worth
$268.796
AUtrratlM 2
ktlt
Uater SLVW!V
Capital
U
Oft N
»1S.4A9 (annually)
$33,MS (every 5 yaara)
Prttcnt Worth
>2M.19J
Alternative 3
Meilhead Trtatment
Capital
U.400
0 t N
tU.410 (annually)
$32,786 (tvary 5 yaara)
Pretent Worth
•274.040
Alternative 4
Piune Containment
Capital
(3,766,945
0 I N
SS39.33S (year 1)
»528.5J5 (years 2-30)
i552,411 (every S years)
Present Uorth
$11,966,534
Alternative S
Aquifer Restoration
Capital
t7,78S,OU
0 I H
»t,09J.2U (ye«r 1)
11,069.21) (years 2-30)
(1,093,089 (every S years)
Present Worth
(24,310,746
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a.
,eNNSYLVANIA
~
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL ReSOURCES
Northeast Regional Office
90 East Union Street - 2nd Floor
W;lkes.8arre, Pennsylvania 18701-3296
(717) 826-2511
September 30, 1991
Mr. Edwin B. Erickson, Regional Administrator
U.S. Environmental Protection Agency
Reg; on 1 II
841 Chestnut Building
Philadelphia, PAl 19107
RE: Record of Decision (ROO)
Dorney Road Landfi" NPL
Operable Unit II
Upper Macungfe Township,
Non-Concurrence
Site
Lehigh County
Dear Mr. Erickson:
The Record of Decision received September 27, 1991 for ~erable Unit II which
addresses groundwater contamination at the Dorney Road Landfill NPL site in
Upper Mlcungie Township, Lehigh County, has been reviewed by the Department.
The major cOMPonents of the selected remedy include:
- Provision of treatment systems for residential well water supplies that
contain site-related contaminants in levels that exceed maximum
contaminant levels (MCLs) or exceed a lX10-4 cancer risk level or a
Hazard Index greater than 1.
- Establishment of a quarterly groundwater monitoring system for the site
that includes both monitoring wells and residential wells.
The Commonwealth of Pennsylvania does not concur with this Record of Decision
for the following reasons. We request that the comments contained in this
letter be made part of the Administrative Record for the Dorney Road Landfil'
site. Furthermore, we expect that the final ROD will reflect that the
Commonwealth does not concur with EPA's selected remedy.
EPA's selected remedy provides for no action with regard to treatment of the
contaminated aquifer. I~ order to justify this action v;s-a.vis
Pennsylvania's background ARAR for contaminated aquifer remedies. EPA intends
to waiva the State ARAR ftUrsuant to Section 121 (d)(4)(C) of CERCLA as
technically impracticable from an engineering perspective. The Department
agrees with EPA that there i5 a sufficient technical basis to justify a lawful
waiver under this statutory provision. In addition, EPA intends to waive its
asserted federal ARAR of MCLs as the cleanup standard for groundwater using
the same Justification. EPA's selected remedy does not. however, waive the
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[---..-
SEP-30-1991
16:27 FROM
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TO
82155979890
P.03
Mr. Edwin 8. Erickson,
Regional Administrator
..2-
September 30) 1991
MCL requirement as to the point of use for the aquifer. That is, while EPA
does waive the MCL requirement as a cleanup standard for the contaminated
groundwater, EPA nevertheless requires MCL treatment for all current users
whose well water demonstrates contaminant levels above MCLs. Hence, EPA does
not waive the MeL as a drinking water standard for point of use consumption.
EPA also proposes to provide well head treatment systems for all current
residential users whose wells demonstrate contaminant levels above MCLs or
above a lXlO-4 cancer risk level either now or in the future, as determined
by a monitoring program (Alternative 3). EPA's position, however, is that
EPA wiTl not provide such well-head treatment systems for all potential users
of the contaminated aquifer. That is, the treatment requirement in the ROD
applies to residential property owners and does not automatically apply to any
individual who may wish at some later time to make use of the aquifer .
resource. The Department's position on this issue is that EPAls ROD 1s
illegal in that it: 1) fails to comply with federal ARARs as required by
Section 121(d)(2)(A)(i) of CERCLA; 2) fa11s to comply with state ARARs as
required by Section 121(d)(2)(A)(ii) of CERCLA; and 3) is not protective of
human health and the environment as required by Section 121(d)(1) of CERCLA.
Section 121(d) of CERCLA (SARA) requires that whenever any hazardous substance
remains on-site (as in the case at Dorney). then the remedial action selected
under Section 104 or secured under Section 106 of CERCLA must attain a
standard of control for such hazardous substance "which at least attains (any
federal or stateJ legally applicable or relevant and appropriate standard.
requirement. criteria or 1imitation.- Section 300.430(e)(2)(1)(B) states that
IIMCLGs, established under the Safe Drinking Water Act, that are set at levels
above zero, shall be attained by remedial actions for ground or surface waters
that are current or potential sources of drinking water, (where relevant and
appropriate] ..." In the explanation for this provision in the preamble, EPA
states that "[p]roposed Section 3oo.430(e)(2)(1)(8) reflected EPA's
determination that HeLs generally shall be considered relevant and appropriate
standards when determining acceptable exposure for groundwater and surface
water that is a current or potential source of drinking water." Moreover, in
its discussion on the location of points of compliance. the preamble states:
"EPA's po11cy is to attain ARARs so as to ensure protection at all poi nts of
potential exposure." F1na11y, EPA concludes that since MCLs are generally
applicable under the Safe Drinking Water Act to the quality of drinking water,
"MeLs are generally considered relevant and appropriate to groundwater that is
or m~ be used for drinking.-
Thus, EPA has unambiguously asserted its poSition that both CERCLA and the NCP
as clarified by the preamble, require NeLs (or MCLGs in some circumstances) as
ARARs for both existing and potential users of the aquifer resource. Since
EPA has waived the MCL only as a cleanup standard for the entire aquifer at
Dorney but not waived such ARAR as a point of use standard for drinking water
from the aquifer. EPAls arbitrary determination in the ROD not to cover all
potential users of the Dorney aquifer clearly violates Section 121 of CERCLA.
Moreover, since well.head treatment systems are readily available, EPA would
have no basis for waiving the MeL drinking water ARAR under Section
121.~(J;1 ,~:1," II" ;,;;;[' .,'
-------
Mr. Edwin B. Erickson,
Regional Administrator
-3-
September 30, 1991
Section 121(d)(2)(A)(ii) requires that selected remedial actions attain any
promulgated requirement under a State environmental law. Moreover, "EPA
believes that remedial actions should be required to comply with ARARs
identified by the (support agency] before the ROD is signed. II Section 1303(b)
of the Storage Tank and Spill Prevention Act, 35 P.S. Section 6021.1203(b),
requires that:
[a]ny owner or operator of a storage tank who affects or
dimin; shes a water supply as a result of a release shall
restore or replace the affected supply with an alternative
source of water adequate in quantity and quality for the
purposes served by the supply, at no cost to the owner of
the affected water supply.
This unambiguous provision of Pennsylvania law requires replacement water
supplies (e.g. well-head treatment systems) to all owners of the water supply
resource. There is absolutely no basis under this law for distinguishing
between a current user of the groundwater or one who wishes to make 'use of the
contaminated aquifer resource in the future. Moreover, this law, while legally
appli~able to owners of storage tanks, is certainly relevant and appropriate,
utilizing the criteria found at Section 300.400(g)(2) of the NCP as clarified
by EPA in the preamble, to a situation where hazardous constituents in a
landfill have affected the water supply. EPA has made no determination to
waive this state ARAR, and compliance with this ARAR by means of well-head
treatment systems 1s readily available. Consequently, by drawing an arbitrary
distinction between current and potential users of the aquifer resource in the
ROO for Dorney Road, EPA has violated section 121(d)(2)(A)(1i) of CERCLA.
Finally, and perhaps most importantly, EPA's artificial distinction between
current and potentia' users of the aquifer resource at Dorney does not provide
for a protective remedy. Section 121(d)(1) states: remedial actions selected
under this section or otherwise required or agreed to by the President under
this Act shall attain a degree of cleanup of hazardous substances, pollutants,
and contaminants released into the environment and of control of further
release at I mrtnimum which assures protection of human health and the
environment.
In its ROD, EPA has arbitrarily determined that current users of the Dorney
Road aquifer shall be protected through point 0' use treatment systems but
that any person who wishes to drill a well in the future and use the aquifer
as a drinking water SOurce ~ not be protected. One can scarcely imagine a
more arbitrary distinction between those who are entitled to the protections
afforded by CERCLA and those who are not. The assertion that such a remedy
"assures protection of human health-, when EPA proposes that certain users
of the contaminated aquifer are not to be protected, 1$ clearly unfounded
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SEP-30-1991
16:30 FROM
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TO
82155979890
P.05
Mr. Edwin B. Erickson,
Regional Administrator
-4-
September 30, 1991
in law. Many of the would be users of the Dorney contaminated aquifer are
farmers without the wherewithal to initiate private causes of action to
assure protection of their water supply. They rely on their government to
provide them with the required protections of law. Consequently, EPA's
determination to exclude certain potential users of the contaminated water
supply at Dorney from adequate protection of human health violates both
Section 121(d)(1) of CERClA and the greater requirements of governmental
responsibility.
The second issue which has arisen over the ROD for Dorney Road concerns the
level of protection to be afforded against contamination from constituents
which do no~ have promulgated MCL values. EPA asserts that the action level
for well-head treatment systems shall be MCLs for constituents which have such
values, or the lXlO-4 cancer risk level for those constituents that do not.
Aside from the fact that there is a tremendous differential of magnitude
between protection to a one in ten-thousand degree and protection to a one in
one-million degree, this requirement violates the NCP. Section 300.430 (e)(2)
(i)(A)(Z) of the NCP states:
For known or suspected carcinogens, acceptable exposure levels
are generally concentration levels that represent an excess
upper bound lifetime cancer risk to an individual of between
10-4 and 10-6 using information on the relationship between
dose and response. The 10-6 risk level shall be used as a
point of departure for determining remediation goals for
alternatives when ARARs are not available.....
This provision clearly expresses a preference for a risk level of lXlO-6 in
determining exposure levels to potential carcinogens. While this risk level
may, under the NCP be altered due to factors related to exposure, uncertainty
or technical limitations, nowhere in the Dorney ROD does EPA indicate why "the
10-6 point of departure was not required or what factors led EPA to make a
determination to move off of the point of departure. Consequent.1Yt EPA IS
unexplained adherence to a lXl0-4 standard for non-MCL constituents violates
the Section 300. 430(e)(2)(1 )(A)(2) of the NCP and authorizes a risk. exposure
one hundred .times greater than its preferred protection level.
For these reasons, the Department cannot agree that EPA has met its statutory
obligations with regard to the choice of remedy and the decision set forth in
the ROD. ConsequentlYt the Department cannot concur with the ROD for this
site.
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I.
Mr. Edw1n B. Erickson.
Regional Administrator
-5.
September 30. 1991
The Pennsylvania Department of Environmental Resources non-concurrence with
this Record of Decision does not wa1ve the following rights of the
Department:
- EPA will assure that the Department is provided an opportunity to
fully participate in any negotiations with the responsible parties.
- The Department will be given the opportunity to concur with
decisions related to the design of the remedial action to assure
compliance with OER design speciffc ARARs.
- The Department's position is that its design standards are ARARs
pursuant to SARA. Section 121. and we will reserve our right to
enforce those design standards.
- The Department will reserve its rights and responsibilities to
take independent enforcement actions pursuant to state and
federal law.
11 you have any questions regarding thfs non-concurrence letter. please do not
hesitate to contact me.
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DORNEY ROAD OPBRABLB UNIT #2
RESPONSIVENESS SUMMARY
A.
OVERVIEW
At the time of the public meeting, EPA had announced its
preferred alternative for the site and had requested input from
. the public. Alternative 3 was the preferred alternative. This
alternative involved installation of wellhead treatment units to
residences whose well water was contaminated by site-related
contaminants over MCLs and health-based action levels. Ground
water monitoring was also proposed to monitor the effectiveness
of the proposed remedy.
Judging by the response generated during the public comment
period, the local citizens and township officials did not have
major opposition to the preferred alternative, but did express
concerns over the details of who would be provided wellhead
treatment units, and the criteria for inclusion in the future.
Representatives of the group .of PRPs who had previously
received Unilateral Administrative Orders ("UAOs") to implement
the remedy described in the first ROD stated they believed the
preferred alternative to be appropriate. However, they expressed
concern regarding the implementation of the ground water
monitoring portion of the preferred alternative.
As documented in the Declaration and Decision Summary
portions of the ROD, the selected remedy is Alternative.3,
Wellhead Treatment. EPA has attempted to clarify answers to the
questions raised during the public comment period regarding long-
term protectiveness and ground water monitoring.
These sections follow:
.
Background on Community Involvement
Summary of Comments Received during Public Comment
Period and Agency Response
.
.
Remaining Concerns
.
Attachment:
site.
Community Relations Activities at the
B.
BACKGROUND 011 COMMUNITY IIIVOLVBMDI'l'
Community interest was probably highest back in the 1970's
when the Site was an operating landfill. At that time, citizens
circulated a petition to close the landfill. Interest was also
shown during the public comment period for Operable Unit 1 ("OU")
after which capping the landfill was selected as the remedy.
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PADER, the lead agency during the Remedial Investigation/
Feasibility study ("RI/FS") phase, and EPA have had contact with
contiguous and other nearby property owners while the study for
OU 2 proceeded and distributed a fact sheet to these residents in
February, 1990. This fact sheet described the upcoming RI field
activities.
C.
SUMMARY OP COMMENTS RECBIVED "DURING PUBLIC COMMENT PERIOD
Comments raised during the public comment period for OU 2
are summarized briefly below. The comment period was held from
August 8 to September 6, 1991.
This summary is divided into two parts. Part I is a
response to a summary of the commento~s' major issues and
concerns, particularly comments expressed by the local community.
Part II is intended to be a comprehensive response to significant
comments of a technical and legal nature. The comments are
categorized by relevant topics.
Part I
Concerns Reaardina Remedial Action Alternatives
1.
Comment: Several commentors had questions concerning the
planned ground water monitoring and future development
relative to the CERCLA five year review process.
EPA Response: As outlined in the Decision Summary of the
ROD, the selected remedy includes quarterly ground water
monitoring of nine wells. EPA may modify the monitoring
program in such areas as: number of wells, location of
wells, frequency of sampling, and analYtical parameters.
EPA believes this will provide the flexibility to ensure the
selected remedy remains protective. Where hazardous
substances, pollutants or contaminants remain on-site, EPA
is required to review a remedial action no less otten than
every five years. If quarterly monitoring indicates the
selected remedy is no longer protective, EPA is required to
re-examine the selected remedy in a manner consistent with
the NCP. If the required quarterly sampling indicates there
is a problem with the effectiveness of the remedy; a review
will be done sooner than the five year maximum review
period. Additional work may then be required, including
installation of additional wellhead treatment units or other
actions, as appropriate.
The cost estimates for the ground water monitoring
process assume a thirty year limit. The actual monitoring
time frame will be extended, if necessary, to provide for
the protectiveness of the remedy.
2
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2.
Comment: Several commentors suggested the addition of deed
restrictions to the landfill property, the contaminated
ground water, or both.
EPA Response: The deed for the landfill property includes a
duly recorded deed notification as described in the ROD for
OU 1 and ordered in the UAOs.
Deed restrictions are of questionable value, because of
the difficulty of monitoring and enforcing them.
Nonetheless, in the present instance, the following notice
has been placed of record on the landfill property deed:
"Which land above-described contains the 27 acres of
the Dorney Road Landfill site which is the subject of a
proceeding under section 106(a) of the Comprehensive
Environmental Response, Compensation, and Liability Act
of 1980, as amended, 42 U.S.C. Sec. 9606(a) at Docket
Number III-90-45-DC."
Part II
Technical Questions/Ground Water Information
1.
Comment: The commentor expressed concern regarding the
cause of the "stressed vegetation along the northern
boundary of the landfill", suggesting the cause was ground
water contamination.
EPA Response: EPA disagrees. Considering that the depth to
ground water in the northwest corner of the site is
approximately 50 feet below the surface, it is unlikely that
the root systems of these trees encounter ground water. In
addition, the extent of radial flow to the west is
upgradient and not likely to extend a significant distance
from the property boundary.
2.
Comment: The comment or expressed concern over reported deep
trenching and landfilling in the northern edge of the site
near MW-8 alleging that the drilling crews retrieved pieces
of battery casings from a depth of 160'feet in the vicinity
of MW-8. The comment or suggested this area had not been
thoroughly characterized and that waste in the rumored deep
trenches would be in contact with the ground water table.
EPA Response: EPA disagrees. Records do not indicate
installation of monitoring wells to 160 feet at the Site,
nor is there evidence of trenches at that depth at the Site.
Bedrock was encountered at approximately 76 feet below grade
at MW-8. Due to the extreme hardness of the bedrock, it is
unlikely that waste disposal occurred below this depth.
3
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3.
4.
5.
Comment: The commentor stated that the influence on ground
water flow of surface drainage and surface topography to the
north of the site does not appear to have been addressed or
adequately described.
EPA Response: An investigation of surface features,
including surface water is outside the scope of this Ground
Water Remedial Investigation/Focused Feasibility study
(RI/FFS). Surface water was addressed in the first QU. It
is unlikely, however, that the ground water will contaminant
surface water or surface soils since the water table is 50
feet below the surface and confined ground water conditions
do not exist at the Site.
Comment: The commentor had several related questions
regarding the possibility of contamination migration into
the bedrock and suggested further investigation be done in
this area.
EPA Response: Contamination of the ground water in the
bedrock has been documented in the RI report. All
monitoring wells except MW-7S are installed in the bedrock. .
The deep monitoring wells are screened at elevation
intervals similar to neighboring residential wells.
Analytical data results indicate that contaminant levels
decrease with distance from the landfill. The low
concentration of contaminants found at depth in the aquifer
does not warrant additional investigation of deeper flow
zones within the aquifer.
Comment: The commentor expressed concerns over the
completeness of the ground water investigation in the north
and northwest area of the site.
EPA Response: The information regarding ground water flow
in the northwest corner has been defined. This area has a
significant thickness of overburden (approximately 76 feet),
which causes recharge from the overburden to the bedrock.
Recharge is indicated by the downward vertical gradient
between MW-7S and MW-7DR. Horizontal ground water flow is
from the MW-7 cluster towards the landfill. Ground water in
the area of the MW-7 cluster may be somewhat mounded due to
ground water recharge thus resulting in radial ground water
flow. However, since groundwater in this area is not
contaminated, the impacts of radial flow from MW-7 cluster
area are inconsequential.
6.
Comment: The commentor expressed concern that the water
table in the soil overburden has not been investigated or
explained in detail, particularly for the adjoining
properties.
4
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EPA Response: The occurrence of perched water was
investigated during the RI. Two piezometers were installed
to a depth of approximately 40 feet in the northwest corner
of the site. Perched water was not encountered in these
piezometers during the investigation. Perched water zones
are generally caused by significant precipitation events.
Health Concerns
2.
1.
Comment: Comment or expressed concern over the rumored cause
of death of the resident who lived in the house located on
the landfill boundary. (The house has since been
demolished.) The commentor suggests that the resident died
from lead poisoning due to drinking ground water
contaminated by the Site.
EPA Response: Records indicate that residents of the former
on-site house used a cistern for potable water. A cistern
collects rainwater, therefore ground water was not ingested.
EPA has no information regarding the cause of death of the
residents of the former house.
Comment: The comment or expressed concern about the uptake
of contaminated ground water into surface soils and
particularly by farm crops.
EPA Response: As ground water is not. under confined
conditions at the Site, there is no discharge of ground
water (which is generally 50 'feet below grade) to the
surface. Therefore, the uptake of contaminated ground water
by farm crops is not a significant concern at the Site.
Remediation Alternatives
1.
Comment: The commentor had questions regarding the
screening out of a public water supply in the FS process.
EPA Response: Data collected during the RI did not indicate
that an extensive ground water contamination situation
exists at the site. Only results from one residence has
previously indicated site-related contaminant levels over
acceptable values, and the most recent sampling has shown
contaminants are currently at acceptable levels. The water
line alternative was screened out since wellhead treatment
would provide at least the same level of protection and is
more cost-effective for the small number of potentially
affected residences. As stated previously, the data
indicates contaminant levels to be declining in the area,
but ground water monitoring is included in the selected
remedy to observe the effectiveness of the remedy. The
remedy will be examined if sampling results indicate the
remedy is no longer protective.
5
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.
I '
.
It should be noted that in water line remedies EPA only
provides for maximum instantaneous demand. These demand
estimates do not provide for future growth because Superfund
does not provide for expansion of a community and will only
correct current problems within an existing system.
2.
comment: Several commentors questioned any effect the site
may have on development in the area.
EPA Response: EPA does not encourage or discourage future
development. EPA mandated to ensure the selected remedy
remains protective; ground water monitoring is included to
help monitor the effectiveness of the remedy.
Cost/Fundina Issues
1.
Comment: The commentor expressed concern regarding the site
owner's obligations relating to contribution to the costs of
any remedial actions, and the provision of access to the
Site, especially in consideration of recent subdivision
approvals.
EPA Response: Mr. R. Emory Mabry was included as a
Respondent in the UAOs issued by EPA to implement the ROD
for OU 1. These UAOS require, among other things, a deed
notification on the site property, access to the Site, and
the implementation by Respondents of OU 1. Additionally, a
lien was placed on the site property.
2.
Comment: Several commentors had questions relating to how
the remedy would be funded or who would pay.
EPA Response: It is EPA's policy to use enforcement first.
This means EPA will attempt to get the PRPs to agree to
implement the remedy, typically under a Consent Decree or
Unilateral Order. CERCLA states that responsible parties
bear joint and several liability; anyone party can be held
responsible for 100 percent of the cost. If there ar no
viable PRPs (such as with an abandoned site or bankrupt
parties), the PRPs do not have the means to implement the
remedy, or the PRPs do not cooperate, EPA and the State may
use the Superfund to pay for the necessary remedial actions.
In the case of recalcitrant parties, EPA has the option of
implementing the remedy with Fund money and then recovering
the costs through a cost recovery action filed in federal
district court. An agreement is often reached with the PRPs
to conduct the remedial activities. Local residents are not
billed for the cleanup.
The issue of who will be implementing the remedy for OU
2 at the site has yet to be resolved.
6
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Miscellaneous Concerns
2.
D.
1.
CommeD~: The commentor questioned the hunters' use of the
Site and the fees allegedly charged to hunters by the site
owner for use of the land.
EPA RespoDse: EPA and the pennsylvania Game Commission have
been assured by Mr. Mabry that he is not charging and
encouraging hunters to use the property. The Remedy
selected for OU 1 includes a perimeter fence which will
limit access of humans and wildlife to the Site and protect
the landfill cap that is to be constructed.
CommeD~: The commentor stated he believes a commitment was
broken because of an alleged agreement to remove a well
installed during site investigations.
EPA RespoDse: The site RIfFS phase was conducted as a
State-lead project. PACER had the responsibility to arrange
for any access agreements. These agreements required the
property owner(s) to allow PACER to drill wells on the
property. EPA was not a party to these access agreements
and therefore, not responsible for the removal of any wells.
REMAINING CONCERNS
Issues and concerns that EPA was unable to address during
remedial planning activities include the following:
1.
2.
CommeD~: The commentor expressed concern over which
residences would be receiving wellhead treatment units.
EPA RespoDse: Wellhead treatment units will be provided to
residences based on sampling results. Results that exceed
the action levels for site-related contaminants, as
described in the ROD, will trigger wellhead treatment units
to be offered to residents. The exact residences are not
delineated at this time.
CommeD~: The commentor questioned whether this remedy will
continue to be effective in the future.
EPA ...poDse: Based on the data collected, EPA believes
this remedy will remain effective. Due to the uncertainties
surrounding ground water movement, particularly in fractured
bedrock, EPA has included as part of this Alternative,
ground water monitoring. In this manner, EPA may observe
the effectiveness of the remedy by providing a system which
will indicate if the remedy ceases to be protective. -
7
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..
~.
ATTACBMBItT
COXMUHITY RBLATIONS ACTIVITIBS
AT DB DORHBY ROAD LAHDI'ILL SITB
Community Relations activities conducted at the Dorney Road
Landfill site to date have included:
.
.
An EPA press release announced the addition of the site
to the Superfund list. (September 1984)
An information repository was established at the Upper
Macungie Township Building. Copies of both the
Remedial Action Master Plan (RAMP) and the RIfFS Work
Plan were distributed to local and county officials and
included in the repository. (February 1985)
.
.
PACER conducted a public meeting in the community to
inform residents of upcoming events and the Superfund
process, and to request input to the Work Plan. (March
1985)
.
The RIfFS Report and Proposed Plan for OU 1 were
released to the public. (August 1988)
.
A public meeting was held in the community to present
the RIfFS and the Proposed Plan for OU 1, and to
solicit community input. (August 1988)
The public comment period for OU 1 opened on August 16,
1988, and closed on September 14, 1988.
.
.
A Responsiveness Summary was prepared for. inclusion in
the ROD for OU 1. (September 1988)
A Fact Sheet was distributed to local residents
describing the upcoming RIfFS activities for OU 2.
(February 1990)
.
.
A public notice announced the availability of the RIfFS
Report and Proposed Plan for OU 2 and requested public
comment. (August 1991)
A public meeting was held in the community on August
13, 1991 to answered questions and solicit community
input. PADER presented the RIfFS Reports and Proposed
Plan, and PADER and EPA responded to citizens'
concerns.
.
.
The pUblic comment period for OU 2 was held from August
8, 1991, to September 6, 1991.
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