United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/135
March 1991
&EPA Superfund
Record of Decision:
Eastern Diversified Metals,
PA
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56*72-101
PIEPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-91/135
3. Recipient's Accession No.
4. TMe and Subtitle
SUPERFUND RECORD OF DECISION
Eastern Diversified Metals, PA
First Remedial Action
5. Report Date
03/29/91
7. Au«hor(s)
a Performing Organization Rept No.
9. Performing Organization Name and Address
10. ProlecVTaak/Work Untt No.
11. Contract(C) or Gnnt(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street,, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit 200 words)
The 25-acre Eastern Diversified Metals (EDM) site is a former metals reclamation
facility in Rush Township, Schuylkill County, Pennsylvania. Land use in the area is
predominantly agricultural with small pockets of residential, commercial, and
undeveloped land. In addition, a small westward moving stream traverses the site's
southern border and discharges into the Little Schuylkill River, 250 feet west of the
site. Before 1966, the site was owned by an aluminum manufacturing facility. From
1966 to 1977, EDM reclaimed copper and aluminum from metal wire and cable in an
onsite processing building. Plastic insulation surrounding the metal wire and cable
was mechanically stripped and separated, and the waste insulation was disposed of
behind the processing facility. Over time, the insulation material formed a residual
pile of "plastic fluff," the most distinctive site feature. In 1974, the State
required EDM to install a leachate collection and treatment system onsite to monitor,
collect, and treat leachate emanating from the fluff pile. Because of high BOD
concentrations in the leachate, a secondary treatment was designed and installed,
channeling leachate using drainage ditches and collection trenches through an
equalization lagoon to an onsite treatment plant. In 1977, EDM terminated
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Eastern Diversified Metals
First Remedial Action
Contaminated Media: soil, sediment, debris, gw, sw
Key Contaminants: VOCs (TCE), other organics (dioxin, PCBs), and metals (lead)
b. Mentifiere/Open-Ended Terms
c. COSATI Held/Group
18. Availabilty Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
94
22. Price
(SeeANSI.Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerty NTIS-35)
Department of Commerce
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EPA/ROD/R03-91/135
Eastern Diversified Metals, PA
-First Remedial Action
Abstract (Continued)
operations, and in 1979 and 1980, residents complained of odors from the site and
expressed health concerns. Subsequent State and EPA investigations from 1983 to 1985
determined that the fluff piles, soil, sediment, leachate, and ground water were
contaminated by VOCs, other organics, and metals. This Record of Decision (ROD)
addresses two of three operable units (OUs) at the EDM site. This ROD provides a final
remedy for "hot spot" fluff and soil areas, metal-contaminated sediment and soil, and
miscellaneous debris as OU1; and provides an interim remedy for contaminated ground
water as OU2. Future RODs will address the final selected actions for ground water
(OU2), and the remainder of the fluff pile (OUS). The primary contaminants of concern
affecting the soil, sediment, .debris, ground water, and surface water are VOCs including
TCE; other organics including dioxins and PCBs; and metals including lead.
The selected remedial action for this site includes removing 480 cubic yards of soil
contaminated with lead above Federal target levels from drainage ditches; excavating and
incinerating, either onsite or offsite, 500 cubic yards of dioxin-contaminated fluff and
5,160 cubic yards of PCB-contaminated fluff and soil in excess of Federal target levels;
consolidating the onsite scattered fluff with the remainder of the fluff pile; removing
120 cubic yards of sand/silt/clay stream sediment contaminated by metals above Federal
target levels; conducting toxicity testing on incinerator residuals, miscellaneous
debris, and possibly on soil and sediment depending on type of disposal or containment;
disposing of incinerator residuals in an offsite municipal landfill or consolidating
these with the remaining fluff pile onsite, if residuals pass the toxicity test; if
residuals fail the toxicity test, treating with stabilization prior to disposal;
disposing of onsite soil and/or sediment passing the EP toxicity test in an offsite
municipal landfill; or if soil and sediment fail an EP toxicity test, stabilizing prior
to disposal; disposing of miscellaneous debris passing the toxicity test in an offsite
municipal landfill; or if miscellaneous debris fails the toxicity test, disposing of
these materials in an appropriate RCRA unit; upgrading surface water run-on/run-off
controls; installing a ground water collection trench parallel to the existing trench to
relieve overburden ground water flow; treating ground water and leachate at an onsite
treatment plant that utilizes equilization basins, clarification, discharge, and
biological treatment, with onsite discharge; upgrading the wastewater treatment facility
and existing equalization lagoon, or constructing a new lagoon to meet Federal
requirements; and further studying the practicability of deep ground water restoration.
The estimated present worth for this remedial action is $12,429,000, which includes a
present worth O&M cost of $1,428,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS; Chemical-specific goals for soil, sediment, and fluff
are based on Federal standards and include dioxin 20 ug/kg, lead 1,000 mg/kg, and
PCBs 25 mg/kg. If fate and transport modeling shows that lower values are appropriate,
those values will be used.
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RECORD OF DECISION
EASTERN DIVERSIFIED METALS SITE
DECLARATION
SITE NAME AND LOCATION
Eastern Diversified Metals Site
Hometown, Schuylkill County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the first and second Operable Units (OU1 and OU2) at the Eastern
Diversified Metals Site located in Hometown, Schuylkill County,
Pennsylvania, which was chosen in accordance with the requirements
of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 198O, as amended by the Superfund
Amendments and Reauthorizatipn Act (SARA) of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 4O C.F.R. Part 30O. This
decision document explains the factual and legal basis for
selecting the remedy for this site.
The Commonwealth of Pennsylvania concurs with the selected remedy.
The information supporting this remedial action decision is
contained in the Administrative Record for this site.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine, pursuant
to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual or
threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent and substantial
threat to public health, welfare, or the environment.
The contaminated media at the site are divided into Operable Units
as follows:
. OU1 Hotspot areas (dioxin and PCB-contaminated fluff and
soil areas contaminated above target levels)
Sediments and Soils contaminated with metals
above target levels
Miscellaneous debris
. OU2 Ground water
. OU3 . Remainder of the site, in particular the remainder of
the fluff pile
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This ROD addresses the first and second Operable Units. EPA
anticipated addressing the third Operable Unit later this year.
The selected action for the first Operable Unit is a final remedy
which provides for treating the principal threats at the site —
the dioxin and PCB-contaminated fluff and soils — through
incineration. The remedy also calls for treating the incinerator
residuals and metals-contaminated sediments and soils, if
necessary, as determined by EP Toxicity or other appropriate
toxicity testing, through stabilization. The stabilized/
unstabilized media either be disposed at an offsite landfill or
consolidated with other media onsite. The miscellaneous debris
will be disposed offsite.
The action selected for the second Operable Unit is an interim
remedy. The interim remedy will enhance shallow ground water
collection and treatment while providing for additional studies to
determine the practicability of deep ground water restoration.
The final RODs which will be issued at a later date for Operable
Units 2 and 3 will present final remedies for the ground water and
the remainder of the site, in particular, the remainder of the
fluff pile.
The selected final remedy for Operable Unit 1 and interim remedy
for Operable Unit 2 include the following major components:
Excavate and incinerate, either onsite or offsite, dioxin
contaminated fluff exceeding the target level. The target level
for dioxin will be either 20 ug/kg or a level as determined by a
recognized fate and transport model, whichever is lower. The
estimated volume of dioxin contaminated fluff is 5OO cubic yards.
Excavate and incinerate, either onsite or offsite, PCB
contaminated fluff and soils in excess of the target level. The
target level for PCB contaminated fluff and soils will be either
25 mg/kg or a level as determined by a recognized fate and
transport model, whichever is lower. The estimated volume of PCB
contaminated fluff and soil is 5,16O cubic yards.
. Remove the lead contaminated soils in the drainage ditches above
target levels. The target level for lead contaminated soils will
be either 1,OOO mg/kg or a level as determined by a recognized fate
and transport model, whichever is lower. The estimated volume of
lead contaminated soils is 48O cubic yards.
Remove the metals contaminated sand/silt/clay size stream
sediments above target levels. Target levels will determined by
a recognized fate and transport model. The estimated volume of
metals contaminated sediments is 12O cubic yards.
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Run the EP Toxicity test, or another appropriate toxicity test
as determined during RD/RA, on the incinerator residuals and
miscellaneous debris. If soils and sediments will be disposed
offsite rather than consolidated with the remainder of the fluff
pile onsite, then also test these media.
. If incinerator residuals pass the toxicity test, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite. If the residuals fail the
toxicity test, then treat through stabilization to a level which
removes the characteristic by which they failed, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite.
. If soils and/or sediments pass the toxicity test, then dispose
in an offsite municipal landfill. If soils and/or sediments fail
the toxicity test, then treat through stabilization to a level
which removes the characteristic by which they failed and dispose
in an offsite municipal landfill.
. If the miscellaneous debris passes the toxicity test, then
dispose in an offsite municipal landfill. If the miscellaneous
debris fails the test, then dispose in a RCRA landfill unit which
meets the statutory and regulatory requirements set forth below.
Install a ground water collection trench parallel to the
existing trench, down to the top of bedrock, with an estimated
inflow rate of 2O gpm. The deepened trench would extend the length
of the intermittent stream that is potentially fed by overburden
ground water flow.
. Upgrade the waste water treatment facility as necessary in order
to achieve Pennsylvania NPDES permit limits for organics and
Pennsylvania ARARs for metals in surface, waters, as set forth
below.
. Either upgrade the equalization lagoon to meet NPDES and/or RCRA
technology requirements, or construct a new equalization lagoon as
part of a new collection and treatment system which meet the
aforementioned criteria. The degree of upgrade and/or whether a
new lagoon is required will be determined during RD/RA.
Study further the practicability of deep ground water
restoration.
Upgrade surface water runon/runoff controls.
Collect and consolidate the onsite scattered fluff with the
remainder of the fluff pile.
Upgrade the existing site fence and continue site maintenance
and monitoring.
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STATUTORY DETERMINATIONS
The selected final remedy for Operable Unit 1 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, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and it satisfies
the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as their principal element.
Because the remedy for Operable Unit 1 will not result in hazardous
substances remaining onsite above health-based levels, a 5-year
review under Section 121(c) of CERCLA, 42 U.S.C. Section 9621(c),
will not apply to this action.
*
The selected interim remedy for Operable Unit 2 is protective of
human health and the environment and utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable, given the limited scope of the action. Because this
action does not constitute the final remedy for this Operable Unit,
issues such as long-term effectiveness and permanence and
compliance with applicable and relevant and appropriate
requirements will be addressed by the final response action.
Subsequent actions are planned to address fully the threats posed
by the conditions at this Operable Unit.
EdwinA/B'. "Ekickson Date
Regional Administrator
Region III!
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TART.K OF CONTENTS
DECLARATION 1
SITE NAME AND LOCATION 1
STATEMENT OF BASIS AND PURPOSE 1
ASSESSMENT OF THE SITE 1
DESCRIPTION OF THE REMEDY 1
STATUTORY DETERMINATIONS 4
DECISION SUMMARY 1
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
III. COMMUNITY PARTICIPATION 4
IV. SCOPE AND ROLE OF OPERABLE UNITS "5
V. SUMMARY OF SITE CHARACTERISTICS 7
A. Environmental Setting and Climate 7
B. Regional Geology, Hydrogeology, Hydrology ... 7
Soils 7
Geology 7
Hydrogeology 7
Hydrology 9
VI. NATURE AND EXTENT OF CONTAMINATION 9
A. Remedial Investigation 9
B. Summary of RI Findings 10
Fluff 10
Leachate 10
Soils 11
Subsurface Soils 11
Surface Water 12
Sediment 12
Ground Water 12
Air 13
Miscellaneous Debris 13
C. RI Conclusions 13
Principal Conclusions 14
VII. SUMMARY OF SITE RISKS 15
A. Exposure Assessment Summary 15
Exposure Points 15
Potentially Exposed Populations 15
Exposure Point Concentrations 16
B. Toxicity Assessment Summary 17
C. Risk Characterization Summary 18
Noncarcinogenic Risk 18
Carcinogenic Risk 19
Environmental Risk 20
D. Significant Sources of Uncertainty 21
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6
E. Risk Assessment Conclusions 22
VIII. DESCRIPTION OF ALTERNATIVES 23
Remedial Action Alternative 1 - No Action 23
Remedial Action Alternative No. 2 - Limited
Action 23
Remedial Action Alternative 3 - Incineration of
Hotspots, Stabilization, Disposal or
Consolidation, Plus Limited Action 24
ARARs 27
To Be Considered 28
Effect of Proposed Remedy 29
Remedial Action Alternative 4 - Incineration of
Hotspots, Stabilization, Disposal or
Consolidation, Shallow Ground Water
Collection/Treatment, Additional Ground Water
Studies 3O
ARARs 31
Effect of Proposed Remedy 32
Remedial Action Alternative 5 - Incineration of
Hotspots, Stabilization, Disposal or
Consolidation, Shallow and Deep Ground Water
Collection/Treatment 32
ARARs 33
Effect of Proposed Remedy . 33
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES 34
THRESHOLD CRITERIA 34
PRIMARY BALANCING CRITERIA 34
MODIFYING CRITERIA 34
1) Overall Protection of Human Health and the
Environment 35
2) Compliance with Applicable or Relevant and
Appropriate Requirements 35
3) Long-Term Effectiveness and Permanence . . 36
4) Reduction of Toxicity, Mobility, and
Volume 37
5) Short-Term Effectiveness 37
6) Implementability 38
7) Cost 39
8) Community Acceptance 39
9) State Acceptance . 39
X. SELECTED REMEDY 40
ARARS 46
Chemical-Specific ARARs 46
Action-Specific ARARs 46
Location-Specific ARARs 47
To Be Considered 47
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XI. STATUTORY DETERMINATIONS 48
Protection of Human Health and the Environment . . 48
Compliance with ARARs ..... 49
Chemical-Specific ARARs 49
Action-Specific ARARs 5O
Location-Specific ARARs 5O
To Be Considered 51
Cost-Effectiveness 51
Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent
Practicable 52
Preference for Treatment as a Principal Element . . 52
X. EXPLANATION OF SIGNIFICANT CHANGES 53
RESPONSIVENESS SUMMARY 54
OVERVIEW 54
SUMMARY OF CITIZEN'S COMMENTS RECEIVED DURING PUBLIC
COMMENT PERIOD AND EPA RESPONSES 55
Selected Remedy 55
Risk Assessment 56
Ground/Surface Water 58
RI/FS Process 59
SUMMARY OF COMMENTS RECEIVED BY POTENTIALLY RESPONSIBLE
PARTIES AND EPA RESPONSES 62
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DECISION SUMMARY
EASTERN DIVERSIFIED METALS SITE
I. SITE NAME, LOCATION, AND DESCRIPTION
The Eastern Diversified Metals Site (Site) is a former metals
reclamation facility located in Rush Township, Schuylkill County,
Pennsylvania (Figure 1) . The Site is located approximately one
mile northwest of the intersection of Routes 54 and 309 in the town
of Hometown, Schuylkill County, 1OOO feet west of Lincoln Avenue.
The Site covers approximately 25 acres of partially forested land,
in a deep east to west trending topographic valley. East-west
oriented railroad tracks border the Site on the north valley ridge.
The Little Schuylkill River flows in a south-southeasterly
direction 25O feet west of the property. A shallow stream flows
westerly along the southern border of the site in the valley
bottom, discharging into the Little Schuylkill River.
The site's most distinctive feature is a pile of "plastic fluff"
which occupies approximately 7.5 acres in a central location on
the property (Figure 2) . The fluff is composed primarily of
polyvinyl chloride (PVC) and polyethylene insulation chips, with
some fibrous material, paper, soil, and metal. The fluff is
residual material from the recycling of copper and aluminum
communication and power wire and cable. An estimated 15O million
pounds of fluff are onsite in a pile approximately 25O feet wide
by 1,5OO feet long by 4O-6O feet high.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Prior to 1966, the site property was owned by a manufacturing
company engaged in the extrusion of aluminum for the manufacture
of hospital furniture. Pre-1966 activities were confined to a
single building on the property, with the remainder of the site
left vacant. The Pennsylvania Department of Environmental
Resources (PADER) reported that the company had disposed of wooden
wire reels, wooden pallets, and similar debris and trash onsite.
Eastern Diversified Metals (EDM) operated at the present site,
reclaiming copper and aluminum from wire and cable in a processing
building on Lincoln Avenue, from 1966 until 1977. The plant
received wire from numerous suppliers, including AT&T Nassau Metals
Corporation. Plastic insulation surrounding metal cable and wire
was mechanically stripped, and separated from the metal using
mechanical (air, water) gravitational separation techniques. This
process entailed chopping the wires, stripping the plastic coating
from the copper wire with steel blades, and separating the wire
from the plastic coverings through the use of an air clarifier and
a water table. EDM used no solvents or chemicals in this process.
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Figure 1
Site Location
and Regional Topographic Map
Pennsylvania
^^LT
Source: USG3 Topographic Quaaranglts: Delano
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-•-H
Central Railroad ol New Jersey (Conrail)
I I I I I I I I I I « I I M M M I I I I I M
I I I I I I I I I
Property Line
Q Secondary
V Leachale Seep
'/ •
. / f ~-
Waslewater I V^Runoir
ilmeni Planl If Lagoon
I \ IK
to L*tle Schuylltill River
LEGEND
-*-->- Approiimale Pile Border
-— Corrugated Metal Pipe Drainage Ditch
' ••• Enisling Diversion Channel
• * — Ground Water Interceptor Trench (Approximate)
J.E. Morgan Knitting Mills Property
Tot R 53217
(Lincoln Avenue'
- — Intermittent Stream
>—»—» fence
Culvert Draining ll.iilro.id
Figure 2
SITE FEATURES
Eastern Diversified Metals
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The reclaimed metal was sold or returned to its suppliers. EDM
took the waste insulation material to the topographic swale area
behind the processing building and placed it on the ground, over
time forming the residual pile which exists now.
In 1974, pursuant to a consent order with the Pennsylvania
Department of Environmental Resources (PADER), EDM installed a
leachate collection and treatment system onsite in order to
monitor, collect, and treat leachate emanating from the fluff pile.
Due to the high BOD concentrations in the leachate at that time,
a secondary treatment system was designed and installed. This
plant utilizes aeration and microorganisms to bring the effluent
BOD within guidelines established by the NPDES permit. The
treatment plant is still operational and is part of a leachate
management system which also includes erosion control measures,
surface diversion ditches, and two shallow ground water
interception trenches which convey leachate to the leachate
treatment plant.
The leachate diversion ditches parallel the northern and southern
boundaries of the waste pile. The southern diversion ditch conveys
leachate to the treatment plant via an equalization lagoon. The
northern (interior) diversion ditch terminates at the runoff
lagoon, where runoff either evaporates or infiltrates to shallow
ground water which is intercepted by the secondary ground water
collection trench, and pumped to the treatment plant.
The main ground water interceptor trench is located along almost
the full east-west length of the pile, between the southern
leachate diversion ditch and the intermittent stream. At the
southwest end of the pile, a secondary collection trench runs
approximately north-south to collect shallow subsurface leachate
at the west toe of the pile. The trenches are approximately 6 to
1O feet deep. The leachate from the main trench discharges into
the waste water treatment plant; the leachate from the secondary
trench is conveyed to a sump just southwest of the treatment plant,
from which it is pumped directly to the plant for treatment.
The leachate treatment plant is located in the southwest corner of
the property. The equalization lagoon is located approximately 3OO
feet to the northeast, at the toe of the pile. This lagoon is
lined with 3O mil polyvinyl chloride and feeds leachate influent
to the treatment plant. The treatment process consists of
clarification and activated sludge biological treatment. The
effluent discharge enters the intermittent stream tributary to the
Little Schuylkill River. Daily flows average approximately 30OO
gallons.
EDM terminated operations in 1977 whereupon it transferred site
ownership to Theodore Sail, Inc. (Sail). In 1979 and 198O, the
Rush Township Board of Supervisors wrote letters to Diversified
Industries, Inc., Sail's parent company, on behalf of area
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residents, complaining of odors from the site and expressing health
concerns.
In 1983 and 1984, PADER conducted chemical and aquatic biological
investigations of the Little Schuylkill River (LSR) and all of its
tributaries and point source discharges. These studies included
sampling of the intermittent stream at the EDM site and the
effluent from the EDM leachate treatment plant. PADER stated that
under the acid-impacted conditions found in the LSR, "the confirmed
complete absence of any aquatic macrobenthic community is
expected." This report concluded that an evaluation of the effects
of the EDM site on the LSR could not be made due to the prevailing
acid mine drainage degradation in this section of that river.
A small fire was extinguished on the eastern end of the south face
of the pile in June, 1979. On November 2, 1979, the Hometown Fire
Co. responded to a report of a fire at the site. On November 2O,
1979, smoldering was noted in the same general area of the previous
fires and was extinguished with fire retardant and water.
Subsequently, Sail excavated the burn area to ensure that the fire
was extinguished. The area where smoldering fires were noted is
limited to a small portion of the pile in the vicinity of the
secondary leachate seep (southeast side of the fluff pile).
Temperature monitoring points were installed and have been
monitored weekly for the past twelve years. Laboratory testing has
estimated that a critical temperature of approximately 29O degrees
Fahrenheit may cause this material to smolder. The data from these
sensors indicate that smoldering fires were of a surficial origin,
possibly the result of campfires set by Site trespassers.
In 1985, Todd Giddings and Associates, Inc., completed a site
evaluation report for Sail. This evaluation included sampling and
analysis of surface water, leachate, ground water, fluff, and
sediment. These investigations determined that the fluff contains
PCBs, lead, and fails the EP Toxicity test for lead. Additionally,
various inorganics were detected in the downgradient monitoring
well. The study concluded that no contaminated ground water was
leaving the site, that fluff from the pile left the site via
erosion/sedimentation and runoff, and that the leachate treatment
plant operated within the NPDES limits with the exception of
ammonia-nitrogen.
In 1985, the EPA Field Investigation Team subcontractor, NUS
Corporation, sampled the Site's surface soil, surface water, stream
bottom sediment, leachate, leachate runoff path sediment, and
ground water, to provide data in order for EPA to determine whether
this site should be proposed for listing on the National Priorities
List (NPL). EPA placed the Site on the NPL on October 5, 1989, 54
Fed. R. 41O36 (Oct. 4, 1989).
In 1987, EPA issued a Unilateral Order to Diversified Industries,
Inc., and its subsidiary, Theodore Sail, Inc., for installation of
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a security fence around the site. The fence was subsequently
installed by those parties. On October 19, 1987, Theodore Sail,
Inc., and AT & T Nassau Metals Corporation signed an Administrative
Order on Consent with EPA for the conduct of a Remedial
Investigation/Feasibility Study for the site.
Presently, the site is unused. The waste water treatment plant
continues to be operated by Sail under a National Pollutant
Discharge Elimination System (NPDES) permit from the PADER Bureau
of Water Quality. The property is overseen by a Sail employee who
is responsible for the daily operation of the waste water treatment
plant,.general maintenance of the plant, recording of temperature
from the pile sensors and general security. The caretaker is
present on site for approximately half of the day for five days
each week. The building housing the processing equipment was sold
to Bernard Gordon.
Current land use includes open and residential lands to the north,
west, and south/southeast, and several business/industrial
facilities to the east. Specifically, the Site is bordered by a
residence and privately owned forest land to the north. Adjacent
to the eastern border of the Site is the Lincoln Avenue building
which formerly housed the metals reclamation process. This
building is now separate from the Sail property and is known as
the Bernard Gordon property. This building is presently partially
occupied by a trailer home assembly operation. Other commercial
operations near the site along Lincoln Avenue include a shipping
facility (UPS), an auto parts/junkyard operation, a heavy freight
depot (Yellow Freight), and a pigments manufacturer (Siberline
Company) . state game lands are located to the west along the banks
of the Little Schuylkill River.
III. COMMUNITY PARTICIPATION
In accordance with Sections 113 (k) (2) and 117 of CERCLA, on
February 5, 1991, EPA placed a quarter page advertisement in the
Lehighton Times News announcing the 30-day comment period on the
Proposed Plan for the first and second operable units of the
Eastern Diversified Metals Site. Also announced was the
availability of the Proposed Plan and RI/FS reports as part of the
Administrative Record in the site information repository at the
Rush Township Board of Supervisors.
The public comment period began February 5, 1991, and ended March
6, 1991. A public meeting was conducted on February 19, 1991 in
order to facilitate receiving the public's comments and concerns
with the proposed action for the first and second operable units
at the site. Local citizens comments were chiefly related to
wanting remediation of the entire site to occur at this time; some
citizens also expressed health concerns regarding an onsite mobile
incinerator. Specific comments and concerns raised by the local
community are addressed in the Responsiveness Summary.
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IV. SCOPE AND ROLE OF OPERABLE UNITS
The Eastern Diversified Metals Site has been divided into three
operable units (OUs), or site components, in order to effectively
address the complex contamination problems present in the various
environmental media. The divisions are as follows:
OU1 - "Hotspot" areas (those areas of fluff and soils
contaminated with PCBs and dioxin above target
levels)
Sediments and Soils contaminated with metals
above target levels
Miscellaneous Debris
OU2 - Ground Water
OU3 - Remainder of the site, in particular the remainder
of the fluff pile
This ROD includes a final remedy for OU1 and an interim remedy for
OU2. The remedy for OU1 allows for expedited action on the
principal threats to human health and the environment at the site
posed by elevated levels of dioxin, PCBs, copper, lead, and zinc
in the fluff, sediments, and soils. Miscellaneous debris is
addressed as well.
The deepened trench system and further study of deep ground water
for OU2 will address the threat posed to human health and the
environment by organic and inorganic contaminants in the shallow
ground water system. OU2 is an interim remedy which provides for
expedited action to address health threats from the shallow ground
water system while allowing further study of deep ground water
cleanup alternatives.
OU3 will consist of the remedy selection for the remainder of the
site, in particular, the remainder of the fluff pile. This
approach to remediation will allow for expedited action to address
the principal threats at the site while evaluation of ground water
and fluff pile cleanup alternatives is completed. This ROD does
not address any final remedial action with respect to OU3. EPA
anticipates a subsequent, final action ROD to address OUS, once it
completes additional studies on how best to contain or treat the
enormous quantity of plastic fluff not within the "hotspots".
The remedy for OD1 will prevent future exposure, eliminate the
toxicity of dioxin and PCBs via thermal destruction, reduce the
volume of contaminated media by 8O% after incineration, and
eliminate mobility by destroying the organics and stabilizing the
metals contaminated incinerator residuals for offsite disposal or
consolidation onsite with other media.
-------
Stabilizing the incinerator residuals and metals contaminated
sediments and soils, if necessary, will reduce toxicity and
mobility by chemically and/or physically binding contaminants in
the matrix. Disposing of treated and untreated materials in either
an offsite municipal landfill or through consolidation with the
remainder of the fluff pile, if an onsite containment remedy is
selected for that OU (OU3), will prevent contact and further reduce
mobility.
Upgrading surface water runon/runoff controls by deepening existing
trenches, fortifying berms, and adding additional pumping and
piping systems as necessary will decrease fluff and contaminant
transport to the ground water and surface water thereby reducing
human and animal contact.
The interim remedy for OU2 will reduce contaminant mobility by
upgrading the shallow ground water collection and treatment system.
The enhanced system will collect any shallow ground water which
currently underflows the existing interceptor trenches and
discharges to the intermittent stream via direct discharge or
seepage. Toxicity will be reduced through enhanced treatment of
the collected leachate.
The remedial actions included in the first and second operable
units will address the principal human health and environmental
threats posed by Site conditions. The remedy for the first and
second operable units will allow for the principal threats to be
addressed while the investigations continue on the deep ground
water portion of OU2 and OU3, the remainder of the site. As part
of OU2, a limited study which may include additional analysis of
the extent of contamination, technical and cost effectiveness
estimates for a deep ground water remediation scheme, and the
potential effects of remediation on downgradient wetlands. Data
generated during the interim action will be used to determine when
and where the restoration of ground water is feasible. The interim
remedy may be incorporated into the design of the site remedy
specified in the final action ROD for OU2.
The investigations to be completed on OU2 and OU3 will identify
final remedies and cleanup levels for ground water and the
remainder of the fluff pile. The final selected actions for ground
water (OU2), both shallow and deep, and the remainder of the fluff
pile (OU3) will be presented in future RODs for those operable
units after additional information has been collected and
evaluated.
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V. SUMMARY OF SITE CHARACTERISTICS
A. Environmental Setting and Climate
The site is located in a sparsely populated rural area in Hometown,
Schuylkill County. Nearby towns include Tamaqua which is
approximately 2.5 miles to the southeast. Current land use
surrounding the site includes open and residential lands to the
north, west, and south/southeast, and several business/industrial
facilities to the east. The site is bordered by a residence and
privately owned forest land to the north. Adjacent to the eastern
border of the site is the Lincoln Avenue building which formerly
housed the metals reclamation process. State-owned game lands are
located to the west, along the banks of the Little Schuylkill
River. Surrounding land use in Schuylkill County is primarily
agricultural (82.7 percent). Approximately 5.3 percent of the area
is residential, 4.5 percent is used for manufacturing, commercial,
or mining applications, and the remaining 7.5 percent is
undeveloped.
B. Regional Geology* Hydrogeologv* Hydrology
Soils
Soils on the site have formed in colluvium, along drainage ways
and in depressed areas. The soils are deep, poor to moderately
well-drained with slow to moderately slow permeability and medium
runoff. The lower part of the subsoil layer (which begins
approximately 2O to 4O inches from ground level) contains a firm
and brittle fragipan that restricts vertical water flow and
facilitates lateral flow of shallow subsurface waters. Depth to
bedrock may be 60 to 96 inches or more.
Geology
Bedrock beneath the site is the middle member of the Mississippian
Age Mauch Chunk Formation. The Mauch Chunk is generally described
as predominantly composed of grayish-red siltstones and shales, and
grayish-red-purple sandstones. The Mauch Chunk Formation is
overlain by the Pottsville Formation, and underlain by the Pocono
Formation. Both contacts are considered to be transitional, and
both the Pottsville and Pocono are characterized by coarse-grained
yellow and gray sandstone and conglomerate lithologies.
Topographically, the Mauch Chunk tends to be a valley-former, due
to the greater resistance to erosion which typifies the more
massive Pottsville and Pocono formations.
Hvdrogeology
Water is transmitted through the Mauch Chunk primarily through
fractures, joints, and along permeable bedding zones. The
formation has low to moderate infiltration capacity and probably
low to moderate aquifer potential. In general, the Mauch Chunk is
described as yielding small to moderate supplies of good quality
-------
8
water. Mauch Chunk ground water in the Schuylkill River Basin area
is reported to have a median pH value of 7.7 and a median specific
conductance value of 120 micro mhos/cm.
Shallow ground water occurs in limited quantities under both
perched and water table conditions in the overburden. Dynamics of
ground water flow in the overburden are basically those of porous
media flow, where primary permeability dominates and the system is
assumed to be essentially homogeneous (despite the obvious presence
of certain inhomogeneities). Perched water in the fluff pile was
encountered in the eastern pile piezometer. Perched flow occurs
in some areas due to the presence of fragipans in the colluvial
soil. This flow component carries leachate from the pile, some of
which is intercepted by the existing interceptor trench system and
conveyed to the leachate treatment plant.
Underlying the perched flow zone, a local ground water system is
present in the overburden. The overburden is dry in some areas
and saturated in others, with classical porous media flow possible
only in the southwest section of the site, near the headwaters of
the intermittent stream. The ground water quality data collected
in the RI indicates that the overburden flow system recharges the
upper bedrock; thus vertical downward flow occurs, as well as
lateral flow.
Horizontally, flow in the overburden is directed southwestward
across the site at approximately O.11-O.13 feet per foot. However,
it should be noted that much of the ground water which enters the
overburden likely recharges the bedrock rather than flowing
laterally, as evidenced by the extensive dry seasonal conditions
above the bedrock. It appears that the only substantial lateral
flow in the site overburden may occur in the southwestern portion
of the site, where wells MW-3/O and MW-6/O contain water year-
around. Based on constructed piezometric surfaces, the overburden
flow system recharges the intermittent stream along its lower
length. Since the lower reach of the stream is known to flow year-
round, it is evident that this flow is sustained by the shallow
system in the southwest portion of the site. This is consistent
with the saturated conditions at MW-3/O and MW-6/O, verifying
sustained lateral flow through the overburden in the southwest
corner of the site.
Most ground water at the site occurs in joints, fractures,
permeable interbeds, and weathered zones in the bedrock. Water
was present in multiple thin zones separated by two to several tens
of feet during the monitoring well installations. Commonly, ground
water conditions in bedrock of this type are complex due to
intricate localized lithological and structural controls. Thus,
ground water may be under confined permeability, and possibly
unconfined conditions in permeable vertical fractures or extensive
near-surface weathered zones.
-------
The vertical head conditions (varying from strong downward to
slight upward) at the site verify the complexity of ground water
conditions. However, it can be observed that the water levels
measured reflect the potential for hydraulic connection among the
three aquifer zones monitored.
Flow in the shallow bedrock zone is similar in direction and
gradient to the overburden. Water level elevation contours
indicate that flow occurs below the elevation of the intermittent
stream bed, in a direction towards the Little Schuylkill River.
Thus the direct discharge point for the shallow bedrock ground
water flow appears to be the Little Schuylkill River, which is the
only regional discharge point in the area. The lateral hydraulic
gradient in the intermediate bedrock aquifer also indicates flow
toward the Little Schuylkill River.
An inventory of ground water usage was completed for the EDM site
vicinity. Figure 3 shows the locations of water wells identified
during the RI. All of the wells identified are topographically
upgradient of the site. Well depths range from 9O feet to 6OO
feet. A number of residents have reported flowing artesian
conditions, indicating a possible recharge area to the north, i.e.,
Still Creek Reservoir Area. Water quality was reported to be good
in most cases, although some wells had taste, odor, and sediment
problems unrelated to the site.
Hydrology
This part of the Schuylkill River Basin receives an annual average
rainfall of 45 inches. Basin maxima for runoff (3O inches) and
rainfall (49 inches) occur near Tamaqua and decrease from north to
south. Peak runoff occurs during the period from February to
April. The runoff low point is generally during August to October,
although at Tamaqua, low runoff typically occurs in July.
Surface runoff from the site flows predominantly in a west-
southwesterly direction, to the small unnamed intermittent stream
which flows west along the southern border of the site and drains
into the Little Schuylkill River.
VI. MATURE AND EXTENT OF CONTAMINATION
A. Remedial Investigation (RI)
EPA designed the RI field activities and analytical program to
define the extent of environmental contamination, identify
migration pathways, and provide data to support a feasibility study
of potential remedial actions. The scope of the RI included
sampling and analysis as necessary to fill data gaps in the
historical database. Leachate/seeps, surface soils, subsurface
soils, surface waters, stream bed sediments, bioassays, air, and
ground water sampling were conducted to characterize the quality
of these media (sampling locations are shown in Figures 4-9). In
-------
Figure 3
-x Ground Water Wells Map
1 Mile Radius
Eastern Diversified Metals Site
Remedial Investigation
000
•1-22 Door-to-Door Survey
o tooo 2000 .134-787 USGS & PA Well Data Base
•C5E^^Si3 (Data on Table 4-9)
Seal* in Fe«t Source: USGS Topographic Quadrangles: Delano. PA and Tamaq'ua!
mSKSe&&S^
laqua. PA -%-&%#£?'',:>/;:
-------
Figure 4
Air Sampling Locations
Eastern Diversified Metals Site
Remedial Investigation
N
LEGEND :
A AIR MONITORING
^ WSTON AIR SAMPLING LOCATIONS
(APPROXIMATE)
D« PHOPCRrr IIHC SMOON ON IWS Pl»N VIAS IAKCX fKOU
ODUR PLANS AND oocs NOI DCPCKSINI A aauNOAHt suovo
DATE Or PHOTOGRAPHY - APRIL 19. 1989
CONTOUR INTERVAL - NCVD 1929
KMl m M»(
-------
Figure 5
Soil Sampling and
Investigation Locations
Eastern Diversified Metals Site
Remedial Investigation
LEGEND :
N
SURFACE SOIL SAMPLL
SURFACE SOIL COMPOSIIE SAUHlfcS I OK Halt
SOIL PERMEABILITY IEST
TEST BORE HOLE
IES1 PI I
PILE BQHihO
(lit PflOftHtY LIM SHOWN OH IHIS PLAN HA* lAKth fRQM
ODllH PLANS AND (IOCS NUI HlWHitNl A OOuHUAHl SuRvt t
OAIE Of PHOrOCRAPHY °KIL 19. 1989
CONTOUR INItRVAL - NGVO 1929
100 100
-------
Figure 3
Surface Water, Bioassay,
Stream Bed Sediment, and
Leachate/Seep Locations
Flow Measurement Locations
Eastern Diversified Metals Site
Remedial Investigation
• N
SURFACE WATER SAMPLE
LEACHING WATER SOURCE
FOR SEDIMENT LEACHING IESI
SURFACE WATER SEDIMENT SAMPLE
BIOASSAV SAMPLE
GAUGING STATION
LEACHATE SEEP SAMPLE
WCIR
PROWRrr LINE SHOWN ON »«S PtAN WAS IANCH FROM
OIHIR PLANS AND DOCS HOI RtPIRStNl A BOUNDARY SURVO
DATE Or PHOTOGRAPHY - APRIL 19. 1989
CONTOUR INTERVAL - NGVO 1929
-------
Figure 7
Location of Little Schuylkill River Fluff Survey Stations
Eastern Diversified Metals Site
Remedial Investigation
Schuylkill
County
-------
Figure 8
Fluff Sampling
and Investigation Locations
Eastern Diversified Metals Site
Remedial Investigation
PILE BORING
SOUO WASTE SURFACE SAMPLC
TCAI PILE BORING LOCATION
1CAI RANDOM PILE SAMPLC LOCATION
(APPROXIMATE AFTER TYSON. 19651
SURFACE SAMPLE FOR 010KIN
N
me Pftopcim UNI SHOWN CN nns PIAN WAS unfN FHOU
PIANS AND DOCS HOI AfPUSlNl * BOUMDAHV iURvt
DATE or PHOTOGRAPHY - APRIL 19. 1989
CONTOUR INTERVAL - NGVO 1929
-------
N
Figure 9
Ground Water
Monitoring Well Locations
Eastern Diversified Metals Site
Remedial Investigation
MONIIOHINC WELLS
O
M-J
MMMKM
SHALLOW BEDROCK
IH1ERUCOIATC BEDROCK
ABANOOMCO OUSTING WILL
n« puwturt UM SHO«M OH IMS PIMI WAS TUCCN filox
omm n>MS AND oocs nor WMSOII « I<»MU*« su«\o.
CONTOUR INTERVAL - NGVO 1929
DATE OF PHOTOGRAPHY -
19. 1989
-------
10
addition to sampling and analyses, limited studies of the
hydrogeology and hydrology of the site were conducted through field
mapping and aquifer testing.
B. S'mn|||a.ry of RI Findings
A summary of the results from previous investigations and from the
RI sampling program are shown below.
Fluff
a) PCB concentrations ranged from 1.7 to 556O milligrams per
kilogram (mg/kg). The highest concentration was T-1O from the
vicinity of the Main Leachate Seep. In order to further delineate
this area of elevated PCB concentrations, an additional six samples
were subsequently collected in the vicinity of T-1O. The T-io
sample cluster (T-lp, T-10R, T-1OSW, T-1OSE, T-1ONE, T-1ONW, T-
1ORC) as shown on Figure 8, is defined as the PCB "hotspot" area
of the fluff pile. This area represents approximately five percent
of the pile and has an estimated volume of 4,740 cubic yards.
Slightly elevated PCB concentrations of 4O mg/kg were also found
at T-26. Mean PCB concentrations in the fluff were 15.7 mg/kg,
excluding the three highest values from the hotspot area.
b) Total lead concentrations ranged from 149O mg/kg to greater
than 4O,OOO mg/kg throughout the pile. The mean concentration was
11,45O mg/kg. Borehole results indicate that lead concentrations
are fairly consistent with depth. Lead was a probable constituent
of insulation fillers in the form of lead phthalate.
c) Concentrations of dioxin and dibenzofurans with a calculated
Toxic Equivalence (TE) to 2,3,7,8-tetrachloro-p-dibenzodioxin of
18.5 micrograms per kilogram (ug/kg) resulted from analysis of a
composite sample of fluff from the area where fires had occurred
previously. This area is on the southern rim of the pile between
the secondary leachate seep and the main leachate seep; the
sampling location is shown as SFD-1 on Figure 8. This area is
referred to as the dioxin "hotspot" area and EPA suspects that this
sample represents conditions in only a very limited area of the
pile where these fires occurred. The volume of dioxin contaminated
fluff is estimated at 5OO cubic yards.
d) Volume estimates for the hotspot areas of the fluff pile, with
the exception of two pile borings and four backhoe pits, are based
on sampling which was limited to a depth of three feet.
Leachate
a) The stream bank seeps issue from unconsolidated overburden
material. Seeps at the base of the main pile are related to the
saturated zones from within the pile, above the overburden.
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11
b) TCE was detected at 44 micrograms per liter (ug/1) at LS-1, a
seep in the north bank of the intermittent stream adjacent to the
equalization lagoon (reference Figure 6). Bis(2-ethylhexyl)
phthalate (DEHP) at 14O ug/1 and di-n-octylphthalate (DNOP) at 27
ug/1 were detected in LS-2, the main leachate seep. PCBs at 2.6
ug/1 and 6.O ug/1 were detected in LS-2 and LS-4, respectively.
c) Copper, lead, zinc, iron, and manganese were present at
elevated levels in all seeps. Maximum levels detected were 639O
ug/1 copper, 1O8O ug/1 lead, and 805O ug/1 zinc in LS-2, the main
leachate seep, 936OO ug/1 iron in LS-3, and 124OO ug/1 manganese
in LS-4. Both LS-3 and LS-4 are downgradient of the waste water
treatment facility.
soils
^^™^™^^^^^~ \
a) DEHP at 1,100-3,300 mg/kg and DNOP at 19O-72O mg/kg were
detected in surface soil samples.
b) PCBs were detected in 21 of 27 samples, with an average
concentration of 2O mg/kg. The northwestern side of the pile along
the northern drainage ways (reference Figures 2 and 5) showed the
highest concentrations at 63-24O mg/kg. The volume of soils
contaminated with PCBs above target levels is approximately 42O
cubic yards. The source of the high level PCBs may be due to
migration from the "hotspot" found in the center of the fluff pile.
c) Composite surface soil samples for dioxin and dibenzofuran
analysis had a Toxicological Equivalence (TE) of O.OO3 ug/kg for
the sample obtained adjacent to the past fire area and 7.1 ug/kg
TE for the downwind sample. The results indicated that offsite
transport of dioxins by wind-aided transport of particles is not
of concern at the site.
d) Maximum concentrations for site-related metals detected were
1O8,OOO mg/kg for copper and 1,92O mg/kg for lead. The highest
levels are associated with the northern drainage ways (reference
Figures 2 and 5) . The volume of soils contaminated with lead above
target levels is approximately 48O cubic yards. Concentrations of
zinc and cadmium at 123O mg/kg and 7 mg/kg, respectively, were
elevated above background levels of 7O mg/kg for zinc and the
detection limit for cadmium.
Subsurface Soils
a) DEHP, DNOP, and PCBs were detected at lower concentrations than
in surface soil samples with maximum concentrations of 62O mg/kg,
2OO mg/kg, and 7 mg/kg, respectively. Copper and lead were present
at 65O and 266 mg/kg, respectively, at less than 12 foot depths.
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12
Surface Water
a) Equalization lagoon samples totaled 15,7OO ug/1 of phenols,
the only semi-volatile compounds detected in surface water.
Maximum concentrations of copper at 38 ug/1, lead at 4.5 ug/1, iron
at 776 ug/1, manganese at 278O ug/1, and zinc at 369 ug/1 were
elevated above state standards of 4 ug/1 for copper, O.6 ug/1 for
lead, 3OO ug/1 for iron, 5O ug/1 for manganese, and 36 ug/1 for
manganese.
b) Samples downgradient of the junction of the intermittent stream
and the north-south drainage ditch (post-treatment), reflect iron
(776 ug/1) and manganese (1,O5O ug/1) levels which are ten times
greater than those in the intermittent stream upgradient of the
waste water treatment facility (reference Figure 6). Lead (2,.2
ug/1) and zinc (369 ug/1) at this point (SW-6) were present at
three to ten times the NPDES levels.
Sediment
a) Small quantities of fluff particles were seen in sediments 23
miles downstream of the site. DEHP at 24-4,OOO mg/kg and DNOP were
the only organic compounds detected. Highest concentrations were
in the equalization lagoon with generally diminishing results
downstream (reference Figures 2 and 5).
b) PCBs at 0.51-8.4 mg/kg were detected in the intermittent stream
but not the Little Schuylkill River.
c) Copper at 3O9O mg/kg, lead at 13OO mg/kg, zinc at 785O mg/kg,
iron at 548OO mg/kg, and aluminum at 3O5OO mg/kg concentrations
were present in sediments. The volume of metals contaminated
sediments above target levels requiring remediation is
approximately 12O cubic yards.
Ground Water
a) Specific conductance readings indicate that the main pathway
for leachate migration from the pile occurs in the western portion
of the site, where the overburden sustains a ground water flow
system.
b) The same suite of volatile compounds were identified in the
analyses from both rounds of ground water sampling. The prevalent
compounds were 1,1,1-trichloroethane and trichloroethene (TCE).
The highest individual compound concentration reported was 91 ug/1
of TCE in MW-3/O (reference Figure 9) . Total concentrations of
volatile organic compounds ranged from non-detected to 119 ug/1 in
MW-3/O. The samples with the highest levels of volatile organic
compounds were from MW-3/O, MW-2/I, MW-2/S, MW-5/S. All four wells
are located along the southern perimeter of the fluff pile, on the
downgradient edge of the site.
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13
c) Calcium, magnesium, and manganese were elevated downgradient
of the pile with respect to background. These results reflect the
leaching of major ionic species from the pile, and possibly the
mobilization of natural manganese under slight reducing conditions
in the pile leachate.
Air
a) Neither the volatile nor phenolic air analyses performed
detected any organic compounds.
Miscellaneous Debris
*
a) In general, the pile is a homogeneous mixture of the chopped
insulation. However, some debris piles outside of the main pile,
and some select areas within the pile, contain the other
miscellaneous rubble, such as unstripped wire and cable, metals,
and wooden cable spools totaling approximately 14,OOO cubic yards.
This total is roughly estimated to be comprised of 3O% fluff, 3O%
wire and cable, 3O% wood, soil and miscellaneous materials, and 1O%
fine-grained iron. Locations of the miscellaneous debris piles are
shown on Figure 1O.
C. RI Conclusions
A number of elements and compounds related to the presence of the
fluff pile were detected in each of the site media, including:
. Bis-(2-ethylhexyl) phthalate (DEHP) - present in surface soils,
subsurface soils, stream bed sediment and leachate, but not in
ground water or surface water.
Polychlorinated biphenyls (PCBs or Aroclors) - detected in the
fluff, surface soils, subsurface soils, and sediments, but
virtually absent from aqueous media.
Trichloroethene (TCE) - in ground water monitoring wells and
one ground water seep from the site overburden.
Dioxin and dibenzofurans - detected at low levels in fluff and
soils adjacent to the former burn area of the pile.
Copper, lead, zinc, iron and calcium were elevated above
background concentrations in all solid and aqueous media.
Manganese in ground water monitoring wells.
-------
Figure 10
Miscellaneous Waste Pile
Locations
Eastern Diversified Metals Site
Remedial Investigation
fo in swi;
—- IftCOlN -UtN,.
LEGEND :
HUttWiH HtU
Huff PUC
Ml AND (.Ami
CA0U AMU SPOOLS
SPOOLS AMU DCBftiS
SPOOLS ANO MHC
MHC AND fluFT
MM AMD SOUP
0 IHUH i>rt
I UCIAI <-*••
2 AON AM) >•
) CAHtt CAV
4 M(!*I tint-
& TfUfr.Of.l
• tlUfl
N
(H( PAOPlHIt llllt ^tlOHN OH II.IS PIAM MAS lAKfN fOOU
olhtH PLAMS ANO UCKS HOI KCPfMSCNI A •OuNOANI SONvti
DAfC Ot PHOIOCKAPMY - APRIL 19. !989
CONIOUK INltRVAL - ftCVD
SCALC « HIT
200 100
-------
14
Principal Conclusions
Due to the low solubility of the phthalate compound it is
possible that the detection of these compounds is a result of the
inclusion of fluff particles in soil samples rather than phthalates
transported from the pile to the soil in water. This conclusion
is supported by the fact that phthalates were found only in solid,
not aqueous, media.
PCBs, like phthalates, are also low solubility compounds which
would be expected to adhere to soil particles or remain in the
plastic matrix. It is suspected that PCBs were used as
plasticizers or additives to plastics in the past. The inclusion
of fluff particles in soil samples also likely explains the
presence of lower level PCBs detected in surface and subsurface
soils and sediments but their virtual absence in aqueous media.
Like phthalates and PCBs, lead is probably bound in large part
in the fluff material. Lead was a probable constituent of
insulation fillers in the form of lead phthalate.
The principal conclusions regarding the dynamics and extent of
migration of site-related constituents are as follows:
The main mechanism of migration at the site is physical
transport by runoff and erosion. Particulate fluff material is
eroded from the pile, and deposited in onsite surface soils and
offsite in stream bed sediments.
Metals accumulated in the intermittent stream sediments may
dissolve in the stream water to levels which are toxic to aquatic
life.
A secondary mechanism of migration at the site is seepage and
overland runoff of leachate during wet periods, where the leachate
diversion ditches may be insufficient to carry all of the flow.
These leachate discharges enter the stream directly by overland
runoff.
. Transport of contaminated ground water is a potential migration
route.
Another secondary mechanism of migration at the site is wind
erosion, as the finer particulates are carried during strong winds
and deposited in onsite and offsite surface soils.
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15
VII. SUMMARY OF SITE RISKS
A. Exposure Assessment- gMmmayy
The goal of the exposure assessment is to determine the type and
magnitude of human exposure to the contaminants present at, and
migrating from, the Eastern Diversified Metals Site. The exposure
assessment was conducted to estimate the risk imposed by the Site
if no remedial action was taken.
To determine if human and environmental exposure to the
contaminants of concern might occur in the absence of remedial
action, an exposure pathway analysis was performed. An exposure
pathway is comprised of four necessary elements: 1) a source and
mechanism of chemical release; 2) an environmental transport
medium; 3) a human or environmental exposure point, and; 4) "a
feasible human or environmental exposure route at the point of
exposure. The potential for completion of exposure pathways at
the Eastern Diversified Metals Site is described in the following
sections.
1. Exposure Points
The potential points of exposure to compounds associated with the
EDM site are shown below:
Air exposure to fugitive dust from the fluff pile in the
site vicinity (no volatile compounds were found in air
testing done at the site);
Ground water exposure from a hypothetical potable well
near the site boundary;
Sediment exposure in the intermittent stream;
Surface water exposure at the leachate seeps on site, the
intermittent stream, and/or the Little Schuylkill River;
Exposure to the fluff in the pile and to the soils around
the pile on the site
Exposure to contaminants in edible fish tissue.
2. Potentially Exposed Populations
The potential populations which may be exposed at the exposure
points are children ages 2-6, children ages 6-12, and adults
including onsite maintenance workers, offsite residents, offsite
workers, and hunters and fishermen. It is important to note that
the dermal contact and ingestion exposures with leachate, fluff
and soil for children are calculated according to a "fence down"
scenario which assumes that there is no fence to restrict site
access. It is also important to point out that risk estimates were
based on continuous (or chronic) lifetime exposure to the site.
The calculated risk for each population was based on contact with
the exposure point concentrations in the various media during the
entire time an individual within an age group falls within that age
range (i.e. 4 years for Age 2-6, 6 years for Age 6-12, and 58 years
-------
16
for Adults - total lifetime assumed to be 7O years) . It is
unlikely that any one individual will be exposed to the site in all
of the ways that are assumed here for his or her entire lifetime.
A summary of the potential site-related exposures to affected
populations analyzed in this assessment is shown in Table 1.
3. Exposure Point Concentrations
The site-related exposure point concentrations were determined once
the exposure scenarios and potentially affected populations were
identified. If the transport of compounds associated with a site
is under steady-state conditions, monitoring data are adequate to
determine potential exposure concentrations. If no data are
available or if conditions are transient (such as fugitive dust in
air or a migrating plume in ground water) , models are used to
predict concentrations. In lieu of an established trend in
historical data indicating the contrary, the EDM site was
considered to be in steady-state with its surroundings.
The only pathway for which modeling was considered appropriate was
the fugitive dust pathway. Receptors for the surface water and
sediment contact pathways were either expected to be present,
although infrequently, in the area in which samples were taken or
the concentrations found during the RI were used as a deliberately
conservative estimate of potential concentrations downstream.
Thus, all exposures, except via the air pathway, were expected to
be represented by the concentrations found in the samples taken on
the site.
To describe the air pathway, average and maximum concentrations of
the indicators for which the fluff had been analyzed were used as
input for a fugitive dust screening model. The models used were
EPA's Industrial Source Complex Short Term (ISCST) and Industrial
Source Complex Long Term (ISCLT) Dispersion Models. This was a
conservative approach, as the airborne dust particles are likely
to contain much lower levels of lead and PCBs than the larger size
plastic fraction which makes up most of the pile. Assumptions were
made regarding meteorological and site conditions based on
established screening criteria and first-hand observation of site
conditions.
Exposures were estimated for the maximum and average concentrations
for each indicator chemical in each medium at the site. The air
screening model output was used to develop similar data for the air
exposure points. Dioxin toxicological equivalents (DTEs) were used
to describe the dioxin content of soil and fluff. When calculating
the average concentration, half of the detection limit was used as
the concentration in a given sample for indicators which were not
detected in that sample. For ground water, only downgradient wells
were used for the calculations, i.e., upgradient well MW-.1 was
omitted from the calculations. The measured and calculated values
are presented in Table 2. The lead concentrations were omitted
since these intakes were considered separately due to the absence
-------
Tahl* 1 KDMaite
T mijIU'MTH^Tl t A0S4flWB4&t
Route* of Expora*** U*«d to Calculate Potential latak**
Route* of Kxpora*
Potentially
Petcadal Routes of Ezpocim
Adult* Fugitive Dust Surface Water Contact Incidental Surfece Water
Incidental Soil/Fluff Contact Incidental Soil/Fluff
Btoaccumulaaon (FUh Ingestlon)
Children age 6-12 Fugitive Oust Surface Water Contact Incidental Surface Water
Incidental Soil/Fluff Contact Incidental Soil/Fluff
Btoaccuxnulatton (Fish Ingestlon)
Children age 2-6 Fugitive Dust Bloaccumuladon (Fish IngesOon)
Rovtea of XxpocoTM Ralatoii to Hypothetical V«fl
PoteatiaOr
Potential Route*
Population Inhalation D*«mal Ing«*tion
Adults Bathing Bathing Drinking Water
Children age 6-12 Bathing Bathing Drinking Water
Children age 2-6 Bathing Bathing Drinking Water
-------
TaMa 2
BOM Sit* EaatatgaraMat Aaaaaaouat
•cpoMira Ratal CaawaaUatloM
PoiaaUa! Foi.aUal
MaaiaBi lowea Mat
Aar rtaaT On-alte
Off-alte realdenla
Huntera and Flahermen
Off-alte workera
(Warehouae)
Oro«a4 Water tlnflrtta Hypothetical well
• alte boundary for
Potable water
ttalarmt Mutf Off-alle (atream)
(aUca* vita aeaUaaat)
Bxpoaura
Baate
Inhalation
mg/m3
Inhalation
mg/m3
Inhalation
rng/rnS
IngcaUon
Dermal contact
(Bathing)
Inhalation While
Bathing
Dermal contact
Incidental IngeaUon
Indicator
PCBa
Dkwdn
Zinc
PCBa
Dtoidn
Zinc
PCBa
Dkudn
Zinc
Manganeae
Trtchloroelhene
Copper
Zinc
Manganeae
Trtchlorocthene
Copper
Zinc
Manganeae
Trtchloroelhene
Copper
Zinc
Manganeae
PCBa
Copper
Zinc
DEHP
Manganeae
l>CBa
Copper
Zinc
DEHP
Avaraga
Coaa.
(pom)
I.27E-06
I.I8E-1O
I.3IE-08
3.63E-07
3.20E-U
3.66B-06
2.07E-07
2.77E-II
3.08E-06
4.I8E+00
2.4IE-O2
800E-O3
4.26E-02
4.IBE*00
2.4IE-O2
B.OOE-O3
4.26E-02
4.I8E«00
2.4IE-02
800E03
4.26E-O2
8.I7E«O2
2.67E«00
5.O7E*O2
I.60E«02
2.26E»O2
8.17E«02
2.67E*OO
S.07E»02
I.S9E«02
2.26E«02
Coaa.
(ppml
3.6SEO6
11 BE- tO
I.48E-OB
I.02E-OB
3.29E-II
4.I4B-08
8.66B-O6
2.77E-II
3.4BE-O8
I.07E«OI
O.IOE-02
4.00E02
I.60E-O1
I.07E«OI
O.IOE-O2
4.00E-02
1.68E-OI
I.07E*OI
O.IOE-O2
4.OOE-O2
I.60E-OI
3.32E*O3
8.40E*00
2.22E«03
3.0IE*02
7.60E+02
3.32E«03
8.4OE*OO
2.22E*03
3.01 E*02
7.50E«02
Data
TOAI-0/84*
ERM. 108O*
TOAI-0/84*
TOAI-O/84*
ERM. IO80*
TOAI-0/84*
TOAI-0/84*
ERM IO80*
TCAJ-O/84*
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. IO80
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
EHM. 1080
ERM. 1080
ERM. 1080
EHM. 1080
ERM. 1080
ERM. 1080
ERM. IO80
ERM. 1080
ERM. 1080
*• -Data used aa Input lo screening model; modeling Infbnnallon Is Included as an apuendlx (Append!* C|.
-------
Tabla 2 (coatlaiMd)
BDM Ml* BaAaafaraMBt AaaaaaoMat
i Mat Ca«o««tratlo»a
rotaatlaH PotaaUal rotaatlal
ItoaVMB Source Mat Bonte
•avfaca watar taaaaala On-alle Dennal Contact
OrotuU watar IntermUtent atream Dennal contact
Inddenlal Ingeatlon
Little SchuyUdU tL Dennal contact
Inddenlal IngeaUon
BloaocumulaUon
(Ftah IngeaUon)
•oil fluff On-alle Dennal Contact
Inddenlal IngeaUon
aadtoator
PCBa
Tnchlorocthene
Copper
Zinc
DEIIP
Copper
Zinc
Manganeae
Copper
Zinc
Manganeae
Copper
Zinc
Manganeae
Copper
Zinc
Manganeae
Copper
Zinc
PCBa
Dkudn
Zinc
Lead
PCBa
DfcuUn
Zinc
Avaraga
COM.
(ppm)
6.23E*00
2.72E-O3
1.26E-02
I.79E«OO
4.I6E«OO
I.40E-OI
9.55E-OI
I.60E-O2
9.65E-OI
I.60E-O2
I.66&OI
9.6SE-OI
I.60E-02
1.86E-OI
9.66E-OI
I.60E-02
I.86E-OI
9.66E-OI
I.60E-02
I.66E-OI
I.93E«02
I.85E-02
2.00E*03
I.I8E«04
I.85E-02
2.0OE*O3
li«M«
Coma.
(ppm)
I.24B«OI
6.00E-O3
4.40E02
6.38E«OO
8.05E«00
I.40E-OI
2.78E«00
3.80E-02
3.69E-OI
2.78E«OO
3.80E02
3.69E-OI
2.78E«00
3.80E-02
3.69E-OI
2.78E«OO
3.80E-02
3.69E-OI
2.78E*OO
3.80E-02
3.69E-OI
5.56E«O3
I.8SE02
2.26E*03
4.O8E«O4
5.56E*03
I.85E-02
2.26E«03
Data
ERM. 1989
ERM. 1989
ERM. 1989 ,
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM, 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
ERM. 1989
TGAI--9/84
ERM. 1989
TGAI-9/84
TCAI--9/B4
TGAI-9/84
ERM. 1989
TGAI-9/84
-------
TaMa 2 (eoatlauad)
BDM Site Ba«aa(araM»t AM*
Expoaura Mat Coawaatiatlaaa
rotaaUal . muatlal raUatUI
Itaaapatt BBpoMU* Bxpoama hiMeatot
IMHiMt Source Wat Route CoMpraad
•oil tMifMaMU On-Hlc Dermal contact Manganeae
loonllnuedl PCBa
DkHdn
Copper
Zinc
DEHP
Incldenlal IngeaUon Manganeae
PCBa
Dtoxtn
Copper
Zinc
DEHP
Avataga
COMO.
(ppm)
3.67E«02
3.76E«OI
3.B7E-03
l.aOE«OI
3.77E*Oa
I.47E+O3
3.67E«O3
3.76E«OI
3.57E-03
l.aOE*O4
3.77E*O3
I.47E«O3
MaalBum
Come.
(pprn)
a.eaE«o2
2.40E«O2
7.I4E-03
I.08E«O5
I.23E«O3
3.30E«O3
8.eaE«oa
2.40E«O2
7.I4E-03
I.08E«O5
I.23E*O3
3.30E«03
DaU
ERM. 1089
ERM, 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
ERM. 1080
-------
17
of a Reference Dose (RfD). The major assumptions about exposure
frequency and duration that were included in the exposure
assessment are shown on Table 3.
B. Toxicitv Assess*"**^ nummary
The toxicity evaluation of the indicator chemicals selected for
the EDM site was conducted to identify relevant carcinogenic
potency slopes and/or chronic reference doses against which
exposure point intakes could be compared in the risk
characterization of the site. Indicator compounds are those which
are the most toxic, prevalent, persistent, mobile, and which
contribute the major potential risks at the site. Indicator
compounds selected for this site classified as noncarcinogens are
lead, copper, zinc, and manganese. Potentially carcinogenic
indicator compounds selected for this site are PCBs,
trichloroethylene, bis (2-ethylhexyl) phthalate, and
polychlorodibenzo-p-dioxin. A summary of toxicological information
for the indicator chemicals is shown in Table 4. Important fate
and transport processes for the indicator compounds are shown in
Table 5.
In a CERCLA risk assessment, the potential exposure point
concentrations are expressed only in terms of the indicator
compound concentrations during the exposure assessment. However,
a more comprehensive and conservative approach is to use the
concentrations of similar compounds to represent the effect of the
entire chemical group, i.e., the total mass of a chemical group is
used as the mass of the indicator compound representing that group.
This conservative assumption allows for exposures to entire
chemical families to be incorporated in the risk calculations. In
the risk assessment, this approach was considered necessary only
for dioxins because of the high toxicity attributed to this group
of compounds. Multiple related cogeners of dioxins and the
chemically similar furans were grouped together for evaluation.
The concentration of each isomer was multiplied by a toxicological
equivalency factor (TEF) which converts the concentration of the
isomer to a concentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(2,3,7,8-TCDD) that is toxicologically equivalent. The total of
all the concentration-TEF products was then used as if it were the
concentration of 2,3,7,8-TCDD in intake and carcinogenic risk
calculations.
Carcinogenic Potency Slopes (CPSs) have been developed by EPA's
Carcinogen Risk Assessment Verification Endeavor (CRAVE) for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic chemicals. CPSs, which are expressed
in units of (mg/kg-day)-1, 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 CPS.
-------
TABLE 3
zsic anx spconc PARAMCTCRS FOR CALCDLATIOK or DOSAGE AND INTAKE
PHYSICAL CHAKA^i I MTiff TV "T
Average Body Weight
Average Skin Surface Area
Average Lifetime
Average Number of Yean Exposure In Lifetime
ACTIVITY CHARACTERISTIC*
Inhalation Rate
Retention Rate of Inhaled Atr
Absorption Rate of Inhaled Air
Frequency of Fugitive Dust Inhalation
- On-stte maintenance workers
- Off-site residents
- Off-site workers
- Hunters and Fisherman
- Casual Trespassers
Duration of Fugitive Dust Inhalation
- On-slte maintenance workers
- Off-site residents
- Off-site workers
- Hunters and Fisherman
- Casual Trespassers
Amount of Water Ingested Daily
Percent of Drinking Water From Home Source
Length of Time Spent Showering/Bathing
Percentage of Skin Surface Area
Immersed While Showering/ Bathing
Volume of Water Used While
Showering/ Bathing
Volume of SbowentaO
Length of Time Spent in Bathroom After
Showering/ Bathing
Volume of Bathroom
Amount of Sediment Ingested Incidentally
Frequency of Sediment Contact
-Casual trespassers
-Casual trespassers
Percentage of Skin Area Contacted by *>•*•*••* .
Skin Absorption Rats of Compounds
in Sediment
Amount of Water Ingested Incidentally
. Hunters and Fisherman
- Children Playing
Frequency of Surface Water Contact
• Hunters and Fisherman
- Children Playing
Duration of g^TfiT Water Contact
- Hunters and Fisherman
• Children Playing
Percentage of Skin Surface Area
IB^fe^MH^KduJ
U11UCIVCQ
- Hunters and Fisherman
- Children Playing
(a)
(a)
W
Id)
(f.d)
(0
(d)
(d)
(d)
(d)
(d)
(d)
(d)
(d)
Id)
(d)
(dl
(0
(d)
(bl
(0
(bl
(bl
(bl
• (bl
(0
(dl
(d)
(d)
(O
(0
10
(d)
(d)
(d)
(d)
(d)
(d)
Adult
70kg
18.150 cm2
TOyrs
SByrs
0.83m3/hr
75%
100%
156days/yr
365days/yr
260 days/yr
14 days /yr
2hn/day
24hrs/day
Shrs/day
4hrs/day
2iiters
75%
20 mm.
100%
200 liters
3m3
10 mm.
10 m3
—
~
20%
0.06
0.2 liters
14 days/yr
4hn/day
18%
Chiia Aae b- 12
29kg
10.470 cm2
6yrs
0.46 m3/hr
75%
100%
365 days/yr
26 days/yr
24hrs/day
1 hr/day
2 liters
75%
20 nan.
100%
200 liters
3m3
10 tan.
10 m3
100 mg
26 days/yr
1 hr/day
20%
0.12
0.05 liters
26 days/yr
1 hr/day
16%
Child Aec 2-o
16kg
6980 cm2
4yrs
0.25 m3/hr
75%
100%
365 days/yr
*
24 hrs/day
2 liters
75%
20 mln.
100%
200 liters
3 m3
10 mtn.
10 m3
...
—
...
—
...
...
...
...
-------
TABLC 3 (Continued)
EDM am spianc PARAMETERS FOR CALCULATION or DOSAGE AND DTTAKZ
ACTTVTTY CHARA£TOUsT!c4 (Continued
Amount of Fish Consumed Dally
Amount of Soil Ingested Incidentally
Amount or Huff Ingested Incidentally
Frequency of Soil/Fluff Contact
•On-sue maintenance workers
•Casual trespassers
Duration of Soil/Fluff Contact
-On-site maintenance workers
•Casual trespassers
Percentage of svi" Area Contacted by Soil/Fluff
Skin Absorption Rate of Compounds
in Soil/Fluff
MATERIAL CHARACTERISTICS
Dust Adherence. Soil
Dust Adherence. Fluff
Soil Matrix Effect
Mass Flux Rate (water-based)
BIG-CONCENTRATION FACTORS
Lead
Manganese
Capper
Zinc
CHEMICAL SPECIFIC ABSORPTION FACTORS
Dtoxln (in fluff and soil: tngesaon only)
PCBs (in sediment, fluff, and soil', tngesdon only)
Lead (in sediment and soil: tngesaon only)
<4
in
in
(d)
(d)
(d)
(d)
(d)
(c)
(e)
(D
(c)
<«)
in
(k)
(0
(0
(hi
(hi
U)
Lead (in fluff, based on absorbable fraction: (App. I)
inhalation of fugitive dust and ingesaon only)
(All other absorption rates are assumed to be 100 %).
Adult Child Aaeb- 12 Child Ase 2-6
6.5 g/day 6.5 g/day 6.5 g/day
50 mg 50 mg
50 mg SO mg
156 days/yr
— 26 days/yr
2 hrs/day
— 1 hr/day
20% 20%
0.08 0.12
O.S1 mg/cm2 •
l.4Smg/cm2 ••
15%
O.S mg/cm2/hr
49 L/kg
100 L/kg
200 L/kg
47L/ltg
0.3
0.3 "•
0.3
0.27 (moat probable Intake)
0.55 (maximum intake)
a • Anderson. E.. Browne. N.. Duletsky. S-. Warn. T.. *Development of Statistical Distributions or Ranges of Standard Factors Used in
Exposure Assessments'. PB 8S-242667/AS. US EPA. Office of Health and Environmental Assessment. 1984.
b - K.G. Symms. "An approximation of the Inhalation exposure to volatile sythedc organic chemicals from showering with
contaminated household water.* paper presented at the symposium of the American College of Toxteologlsts. IS November 1986.
c - J.K. Hawley. "Assessment of Health Risk from Exposure to Contaminated Soli". Risk Analysts. Vol. 5. No. 4. 1985
d • ERM Staff Professional Judgement
e - Lepow. M.L.. Bruckman. L.. Gillette. M.. Markowttz. S.. Roblno, R.. Kaplsh. J.. Investigations into Sources of Lead in the
Environment of Urban Children". Pr"Vi""ir"tjl Research 10:415-426. 1975. and
Lepow. M.L.. Bruckman. M.. Robtno. U. Markowttz. S.. Gillette. R.. Kaplsh. J.. "Role of Airborne Lead In Increased Body Burden of
Lead in Hartford Children". Environmental Health Pospecdvu 6:99-101. 1974
f - Superfund Public Health Evaluation Manual
g - Superfund Exposure Mar imn nl Manual
h - Kimbrough R. Falk H. Stemr P. Fries G. 1984. "Health Implications of 2.3.7.8-tetrachlorodlbenio-p-dtoxln (TCDD)
contamination of residential soil". Journal of Toxicology and Environmental Health 14:47-93.
i - Upsky. D. 1989. Health Hazards ftwmfl with PCDD and PCDF Emission*. Found in: The Risk Assessment of Environmental
Hazards. D. J. Paustenbach. ed.. New Yoric John Wiley and Son. pp. 631 - 686.
J - Beck. BD. S. Hala aL. Murphy. 1989. Evaluation of Soil IngesOon Rates. Cambridge. MA: Gradient Corp.
k - U.S. EPA. "Health Assessment Document for Manganese". EPA 600/8-83-013F. 1984.
1-Human Health Evaluation Manual. July 1989.
•O.S1 mg/cm2 was used to calculate dermal contact in sofl. because the soil at the EDM site is the same general
soil type as in the Lepow. el al research study (reference e). This dust adherence value was derived from the recovery rates and
area of the skin dust collector used in the study.
•• 1.43 mg/cm2 was used to calculate dermal contact in the fluff due to lack of more specific results for dust adherence of fluff.
•••30% intestinal absorption used as best estimate of exposure to PCBs and dioxin for most probable scenarios: 100% absorption
usod for r^loitoBon of exposure T^yt***^
-------
Table 4
Summary of Toxlcologlcal Information
For the Indicator Chemicals
EDM Site
Indicator Chemical
Oral RID*
mg/kg/day
Inhalation RID*
mg/kg/day
Oral CPF**
1 /mg/kg/day
Inhalation CPF**
1 /mg/kg/day
EPA Carcinogen
Classification
Reference
Copper 3.70E-02 l.OOE-02 NA NA
Lead withdrawn withdrawn NA NA
Manganese 2.00E-01 3.00E-04 NA NA
Zinc 2.10E-01 l.OOE-02 NA NA
Dloxlns NA NA 1.5GE+05 1.56E+05
Bls(2-ethylhexyl)phthalate 2.00E-02 NA 1.40E-02 NA +
Polychlortnated Blphenyls (PCBs) NA NA 7.70E+00 7.70E+00
Trtchlorethene NA NA 1.10E-02 1.30E-02
D
B2
D
D
B2
B2
B2
B2
SPHEM
IRIS
SPHEM
SPHEM
SPHEM
IRIS
IRIS
IRIS
•Noncarclnogenlc effects
••Carcinogenic effects
+No Inhalation pathway; therefore, use of Oral CPF for Inhalation CPF is not needed.
RfD - Reference Dose
CPF - Carcinogenic Potency Factor
NA - Not Available
IRIS - EPA's On-Llne Integrated Risk Information System accessed 7/89.
SPHEM - Superfund Public Health Evaluation Manual 10/86.
-------
Table 5 EDM Site
Endangennent Assessment
Important Fate and Transport Processes for
Indicator Compounds
Compound
ICajorPate and
Transport Proc
Lead
Sorption
Bioaccumulation
Chemical spedation
Biotransfonnatlon
Manga
Sorption
Complexation
Coddatlon
Potychloxlnated Biphenyls (PCBs)
Bi
Photolysis
Hydrolysis
Sorption
Biotransfonnatlon (<4 chlorine per molecule)
Volatilization
Oioxlns
Sorption
transfonnation
Tnchloroethene (TCE)
Biotransformation/degradatlon
Volatilization
Bloaccumulation
Oiddatlon
Copper
Sorption
Bloaccumulation
Complex formation
Zinc
Sorption
Bioaccumulation
Bi3-{2-EtbyihocyDphthaJate (DEHP)
Sorption
Biodegradation
-------
18
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Cancer potency slopes are derived from the
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals that are likely to be
without.an appreciable risk of adverse health effects. Estimated
intakes of chemicals from environmental media (e.g., the amount of
a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors 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
noncarcinogenic effects to occur.
When reviewing the quantitative information presented in the tables
in this section, the following threshold levels should be used.
For noncarcinogenic risks, a chronic hazard index value above a
value of l.O indicates the potential for an adverse health impact.
For the carcinogenic risks, a value greater than 1E-O4 to 1E-O6 is
generally recognized as indicating a risk beyond the acceptable
level.
1. Noncarcinogenic Risk
The Hazard Index (HI) Method is used for assessing the overall
potential for noncarcinogenic effects posed by the indicator
compounds. Potential concern for noncarcinogenic 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 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.
Tables 6-8 present the calculated hazard indices for each age group
evaluated. These tables calculate the hazard indices associated
with each of the exposure points, exposed populations, and routes
of exposure identified previously. Host probable and maximum
hazard indices have been calculated, using the most probable and
maximum intakes calculated previously. Most probable intakes are
calculated using average exposure point concentrations of the
-------
Takia e
Calralalloaj of
•••carclajog*
(Adult Popuht
•kUaaardladlcea
don)
Patel
Calculated
UM! Pnkakla
Hf»*llMtlcal
Doao
Host rrokaklo
Haaard Ud«i
Haaard lodoa
Wtmtt
On-slte
Workers
OtoMdWattt
FlBflPlte
Off-aile rcatdenU
OC-aUewarkcra
fWarehouM}
Hunters and
•ahcnntn
HypolheUcal
dowi«radlcnl wcl
PCB*
Dtojitn
Zinc
FCB*
Dkaln
Zinc
FCB>
Otoxln
Zinc
PCBa
Okuiln
Zktc
Manganese
Irfchloroelhene
Copper
Zinc
Manganese
Irfchloroclhene
Copper
Zinc
Inhalation While Mangancaf
Bathing Trfchloroclhenc
(Volatile coranounds
only)
Inhalation
Inhablton
Inhalation
Inhalation
IngeMkm
Dermal conucl
Oi«M4vatcf Ullk SchuyUUU R
(»/«r C^UMcal k*ckU«) llunlera and Ptahennan
Duma) contact
Manganese
Copper
Ztoc
NA • Not Applicable
Incidental IngesUon Manganese
Copper
Zinc
96SE09 2.77E07 NA
8.B7E-I3 897EI3 NA
8.96E08 I.I3E07 I.OOE02
Total kaaard. tkkt «po*wr« a*hrt:
7.53E-08 2I8E06 NA
702EI2 7.02E 12 NA
7.8IE07 6.84E-07 IOOE 02
Total kaaaid. tkls oxpoawo sofaiti
I.8IE-08 4.34E07 NA
I.40E 12 I.40E 12 NA
I.S6E07 I.76E07 I.OOE-02
Total kaaaid. tkla oza«aaro awlatt
4.82E-IO I.38E-08 NA
4.4BE-I4 4.49E-I4 NA
4.99E09 665E09 I ODE 02
Total kaaard. tkta •xpo«u« awkiti
8.95E02 4.22EOI 2.00E 01
S.I6E04 I.9SE03 NA
I.7IE-04 856E04 3.70E-02
9.I2E04 3.62E03 2 IOE 01
I.79E04 8.43E-04 200EOI
I.03E08 3.89E-06 NA
3.42E07 1.7IE 06 3.70E 02
1.82E06 7.23E06 2. IOE 01
NA
4 IOE 03 I.SSE-02 NA
NA
NA
Total kaaard. tkla azpoawo pobtt:
3.47E-06
S.8IE08
6 (HE 07
101 EOS
I.38E07
I.34E06
2.00E-OI
370E02
2.IOEOI
I.OSE-04 3.05E04 2.00E-OI
I.7SE06 4.I6E-06 3.70E-02
I.82E-OS 4.04E-05 2.IOE-OI
ToUl kasard. thb cxpoiuic point:
NA
NA
9.06E06
NA
NA
7.8 IE-OS
NA
NA
I.66EOS
I.
NA
NA
4.99E-07
4.47EOI
NA
4.63E03
4.34E-03
8.9SE-04
NA
9.25E06
8.6BE08
NA
NA
NA
NA
4.07B-OI
I.73E-OS
I.67E06
268E06
6.23E04
4.74EOS
8.68E-O5
6.70E-04
NA
NA
I.I3EOS
1.13E-48
NA
NA
8.B4E-OS
•.MB-08
NA
NA
I.76E-05
1.7611-08
NA
NA
S.6SE-07
8.88B-«7
2.IIE«00
NA
2.3IE-02
I.72E02
4.22E-03
NA
4.63EOS
3.44EOS
NA
NA
NA
NA
a.lBB*00
S.OSE-OS
3.73E08
638E06
I.S2E-03
I.I3E-04
I.93E04
I.80E-03
POOR QUALITY
ORIGINAL
-------
Tafcb 6 (coBt
BOM §IU KmUMganMBl Aaaaamtat
Calculation of IU«c*fcta«t«alc Hasard ladlcea
*>t*allal Fataallal
Tnuuoort Bcpoaiira
Madhua •owe* Fotat
•wflMo walar OroMd valor UtOe SchuyUdil R
«•• (ft/or lidtatml loaoktaf)
lAdull Popublkml
PoUatlal I
Bapoaiuo 1 ladlealor
•OHIO I Coaipoud
BtoacciiffMilattffn Mtntfunt^r
Iflah In0cadon| Copper
Calcmhtt«d
Moot hokaklo
8.87E03
7136E04
Ma>tai«H
btako
2.68E-02
L6IE-O3
..far^o.
2.0OE-OI
2 JOE 01
Total kaaard. tkU oBpoawo ootat:
•all VhUI On-aUe
Maintenance Workers
Dennal Contact PCBa
Dtailn
Ztae
Incidental Infeadon PCBa
Dtaitn
Zinc
I.I2E-04
I.07E-08
I.I6E-O3
I.76E-OS
I.60E09
A.IOEO4
3.22E-03
I.07E08
I.30E-03
I.O2E-O3
3.38EOB
4.I3E-04
NA
NA
2.IOE-OI
NA
NA
2.IOE-OI
MM! PreUbU
Haaard ladu
4.43EOa
A fVl V.A4
o.ujc*m
3.46E-O3
•.asc-oa
NA
NA
6.S2E-03
NA
NA
2.90E-03
Total kaaaid. tkU oxyoaaro a*tat: •.42E-O3
•wfcoa ooH On-aMe
Maintenance Workera
Dermal contact Manguieoc
PCBa
Dtaxm
Copper
Zbk
DEHP
Incidental Ingeatton Manfuieae
PCBa
Dtoxln
Copper
Zktc
DEHP
7.48E-OS
766E08
7.28E-IO
2.4SE-06
7.60E-OS
2.99E-O4
I.I2E04
3.44EO8
3.26E 10
3.66E-03
I.I5E04
4.47E-O4
Total ki
I.B3E04
4.88E05
I.46E-OB
2.20E-O2
3 SI E 04
8.73E04
5.47E04
I.46E04
4.3SEOO
6.68E-02
7.60E04
2.OIE-03
sard. Ikla up
2.00E-OI
NA
NA
3.70E-O2
2.IOEOI
2.00E-O2
2.OOE-OI
NA
NA
3.70E-02
2.IOEOI
2.OOE-02
oaaro potal:
3.74E-O4
NA
NA
6.61 E-OS
3.66E-04
I.SOE-02
6.S9E-O4
NA
NA
B.88E-02
S.47E04
2.24E-O2
1.98B-O1
M^l...
I.29E-OI
7167E-03
1.B6C-OI
NA
NA
6.IBE-03
NA
NA
I.97E-03
•.16B-09
9.I6E-04
NA
NA
5.9SE-OI
J.19E03
3.36E02
2.74E03
NA
NA
I.78E*00
3.S7E03
I.OIEOI
2 •<|B*OO
NA-Not applicable
•atatcaanc* workara)
Total kaaard lar oa-atto •atatCBaac* workcra: 1.46B-01
Total kaaard far off*lto raaldoata (bMtadaa k«atla« ft fkhlaj aoaMrio): •. 14B-01
Total kaaard far off-alta workara: 1.86IVOS
Total kacard for k«alera ft tbkcraiaa: 8.6SB-O2
2.S2&v»OO
2.91B*OO
LSW-Ol
Note: 100 ml/day waa uacd In calculallnj Ingcalkm of Surface aoll and Fluff for maxtmuro exposure; only the wont of the two waa uaed In the total maximum hazard calculation.
POOR QUALITY
ORIGINAL
-------
Tabla 7
EOM 8IU BMlsngsnseal A>Mu«cat
Calculation of N«BC*rclB«g«B.le Haaard Indict*
(Child 6-12 Population)
Potential Potential Potential
Medium Source Point Rout*
Air Fluff Onslle Inhalation
Indicator
PCBs
Dtoxln
Zinc
Calculated
Most Prokskk
Intake
I.08E-09
I.OOEI3
I.IIE06
Calculated
Uaxlniunt
Intake
3.09E-08
I.OOE-13
I.2SE08
Reference
NA
NA
I.OOE02
Most Probable
Hasard Indes
NA
NA
I.I IE 06
Total kacard. Ikls «iposurs polnl: 1.1 IE-O4)
Off-site rcsklenls bihalalion
PCBs
Dtoxln
Zinc
I01E07
939E 12
8.79E 07
2.9IE-06
9.30E-I2
994E07
NA
NA
IOOE-O2
NA
NA
8.79E-OS
Total kasard. Ikls exposure potato 6.79E-O6
around Wstsr VtuffPUa Hypothetical Ingestton
downgradtcni well
Dermal contact
(Bathing)
Inhalation White
Bathing
(Volatile compounds
only)
Manganese
lYtdMoraelhcne
Copper
Zinc
Manganese
IVkhloroelhene
Copper
Zinc
Manganese
Ittchloroe thene
Copper
Zinc
3I7EX)I
I.2SE-O3
4I6E04
223E03
2.SIE04
I.4SE06
4 80E 07
2.S6E06
...
5.64E-03
...
...
LOaEtOO
4.73E03
208E03
8.79E03
I.I8E-03
546E06
2.40E06
I.OIEOS
...
a.ooE-oa
...
...
aooEoi
NA
3.70E-02
2.IOE-OI
aOOEOI
NA
3.70E-02
2.IOE-OI
NA
NA
NA
NA
Total kasard. Ikls exposure point:
I.09E«00
NA
I.I2E02
LOSE 02
I.2SE-03
NA
I30E05
I.22E-OS
NA
NA
NA
NA
l.llfeOO
Uulnnuu
Hasard Indss
NA
NA
I.25E-06
1.28sVO«
NA
NA
9.94E-OS
9.941VOB
S.iaE«OO
NA
6.62E02
4.I8E02
6.9IE-03
NA
649E05
4.83E05
NA
NA
NA
NA
0.23E*00
(residential us* of gvowd umtsi)
•sdbnsnl fluff Off-site (slreaml Dermal contact
(•tied wtlk ssdlmsat)
Incidental Ingeslton
Manganese
PCBs
Copper
Zinc
DEHP
Manganese
PCBs
Copper
Zinc
DEHP
3.82EOS
I.2SE07
2.79E-OS
7.44E06
I.06E05
2.0IE04
I.96E07
I.47E04
3.91 E-OS
554E05
I.55E-04
3.93E07
I.04E04
I.4IE05
3.6IE-OS
8.ISE04
6.I9E-07
S.4SE04
7.39EOS
I.84E-04
2.00E-OI
NA
3.70E-O2
2.IOE-OI
2.00E-02
2.00EOI
NA
3.70E-02
2.IOEOI
2.00E02
Total kasard. eedlment. Ikls exposure point:
Surface voter Leackats On- site Dermal Contact
Manganese
PCBs
TVtchloroelhene
Copper
Zinc
DEHP
I.28E-05
S.60E09
257E08
3.68E-06
8.S4E06
2.88E07
255E05
I.23E08
9.0SE08
I.SIEOS
I.66E-OS
2.88E-07
2.00E-OI
NA
NA
3.70E02
a tote oi
2.00E02
Total kaiard. Icackafc. IhU cxpocurc point:
I.9IE-04
NA
7.SSE-04
3.54E-05
6.28E-04
I.OOE-03
NA
3.96E-03
I.86E04
2.77E03
0.43kVOa
6.4 IE-OS
NA
NA
9.9SEOS
4.07EOS
I.44EOS
2.10B-04
7.77E04
NA
2.8 IE-OS
6. 7 IE-OS
I.76E03
4.08E03
NA
I.47E02
3.53E-04
9.2IE-03
s.satvoa
I.28E04
NA
NA
3.SSE04
7.B9EOS
I.44E05
S.76EO4
NA - Not Applicable
POOR QUALITY
ORIGINAL
-------
*l« 7 (continue*)
EDM Bile Endangcrment Aaeceement
Calculation of Noncorclnof ante Hasard Indices
(Child 6-12 Population)
Potential
Tranapott
Uedliua
Source
Potential
Evpoeurc
Point
Potential
bpoanre
Roiil*
Indicator
Compound
Calculated
Meat ProbahU
Hypothetical
Intake
CnlculnUd
Mudniuni
Hypothetical
Utah*
Reference
Dote
Host Probable
Haiard Indci
MaBleaua*
Hawrd Index
ffwrfcco Wat*
« on tinned...
Oronnd vntai IntermllUnl alrcam
(«/ot Sedlmant kacnlng)
UllkSchuylktUR
Ftafl
UlUeSchuytUlla
On-alte
••rfccoaoll
Onalle
Dermal contact
Incidental Ingtalkm
Dermal contact
Incidental Infection
Wi>HT»"wil»tV»n
inah Injection)
Dermal Contact
Incidental Ingealkm
Dermal contact
Incidental Ingealton
Manganeae
Coooer
n — •
Zinc
I.96E-06 6.73E-06
329E08 7.82B-OB
9.42E07 7.60E-0?
, 2.00E-OI
3.70E02
2IOEOI
Manganeae I.I7E04 34IE04 2OOEOI
Copper I.07E06 4.67E 06 370E(«
Zinc 2.ME05 4 (BE 06 a.lOE-OI
Total naiard. atranm vntat. tnla axpoanio notat:
Manganeae
*%?
Manganeae
Copper
Zinc
Total
Manganeae
Copper
Zinc
Total kama
PCBa
Dtojdn
Zinc
PCBa
Dtodn
Zinc
Manganeae
PCBa
DtoHn
Copper
Zinc
DEHP
Manganeae
PCBa
Dkudn
Copper
Zinc
DEHP
l.eeE-06 B.72E-08
S.29E-M 7.82E 08
S.42E07 7.GOC-07
I.I7E-04 3.4 IE 04
I.07E06 4.67E06
2.04E05 4.&3E05
1 bauid. rivar •ntor. thla oz|
2.I4E02 e.23E-Oa
7.I7E04 I.70E03
I.76E03 3.80E-03
2.S7E-06 7.40E-04
2.46E 08 2.46E-00
2.66EO4 9.0IE04
2.00EOI
3.70E02
2.IOEOI
2.00E-OI
3.70E02
a.lOEOI
•oanro ootnti
200EOI
370E02
a.lOE-01
•oaoro ootat:
NA
NA
a. IDE oi
7.1 IE 06 I.37E03 NA
6.82E-IO 4.54E-00 NA
246E04 5.6SE-04 2.IOEOI
Total nnMtd. fhrfl thla OBpoawro potati
I.72E-05 4.20E05
I.76E-06- I.I2E05
I.67E-IO 3.34E-IO
5.62E-07 6.05E03
I.76E-06 5.76E-OS
6.67E-05 I.64E-04
2.00E-OI
NA
NA
3.70E02
2.IOEOI
2 ODE 02
4.5IE-OS 2.2 IE 04 2.00E-OI
I.38E06 5.80E-OS NA
I.32E 10 l.76EOa NA
I.47E-03 2.6SE-02 3.70E-O2
4.63E-05 3.02E-04 2.IOE-OI
I.BOE04 8. HE 04 200E02
Total haaard. aolt Ihla axooenre oolnt:
0.82E-06
800E-07
I.A3E-06
5.86E-04
&.3IE05
0.73EOS
7.40E-04
0.82E-06
fl.eOE-07
I.63E06
S.86E-04
53IE05
0.73EOS
7.4AE-04
I07EOI
I04E02
8.3SE03
l.MaVOI
NA
NA
I.27E03
NA
NA
I.I7E03
a.44kVOS
8.S9E-OS
NA
NA
I.S2EOS
8.40EOS
3.43E03
2.2SE-04
NA
NA
3.9HE-02
2.20E-04
B.OIEO3
B.annvoa
POOR QUALITY
ORIGINAL
2.06E-05
2 I IE 06
3.62E06
1 .7 IE 03
I.26E 04
2.I6C04
286E05
2. 1 IE 06
362E06
I.7IE-03
I.26E-04
2.I6E04
3.I2E-OI
4.60E02
I.8SE02
9.76aV01
NA
NA
I.43E-03
NA
NA
2.64E-03
4.O8S-03
2.IOE-04
NA
NA
I.37E-OI
2.74E-04
7.72E03
I.IOE03
NA
NA
7.I7EOI
I.44E-Q3
4.0SEO2
9.0BB-O1
Total bacard.'all expocure point*: 1.31B«OO
Nolt: UK) ing/day was used In i:ab iibll
i u< Stulai i; still unit Hull lor maximum exposure; only Ilic worst of Hie I wo was usctl In Ilic lulul iiuxliiiiuii ha^iiil cakiilallun.
-------
TaM* 8
BOM III* BadM»J*MM*» I
CalctdalloB ol NaawaiclMg**!* Baaai* ladle**
(Child a-6 Population)
B>pa**M
fetal
IMIcalM
blak*
•*f*N*)**
HaMrt !•«••
Alt
Ora>»dWaUr
Of *ne reakknl*
Hypothetical
djownfradteni we!
Inhatollon
KB*
Dtodn
Zhic
TitehfcmeihcM
0.93E06
a.87E06
Dermal contact
Titchlaraelhene
NA
NA
I.03E06 I.I6E06 1.00*02
Tatal haiard. thl* *Bf**iar* ••tali
1.868*00 2.00B4I
NA
3.70E-oa
l.60E-Oa a.lOE-OI
I.42B-O3 2.0QEOI
6.BSE08 NA
288E06 9.70E-O3
I.22B06 a.lOB-01
2.27E03
7.62E44
4.00E-O3
3.OIE04
I74E06
6.76E07
3.07BOB
Inhalation Whlk u^^^^.
Balhlng TitchtooethtM
(VoUllfe compound* Copper
on*) Zbtc
6.30E03
2.00E-O2
HA
NA
HA
NA
Tatal hasard. thl* ••*•*•>• palat:
Surface Water
OrautdWaUt
(*/«* fcttlMHt iMCklH)
Uilk SchuyNUII R
Bloaccuroulallon
CFUh Ingeallonl
•Mana>ne*c
Copper
Zhic
a.ooE.oi
I.30E03 309E03 3.70E-02
3.I8E03 7.06E03 2.IOB4>I
Tatal haaard. thfc* *ipa*«i* paUt:
NA
NA
I.09E4M
I.03B-04
I.06E*OO
NA
X03E-Oa
I.0IB-02
I.60E-O3
NA
I.G6E-OS
I.46E-OS
NA
NA
NA
NA
a.oiB+oo
I.04E-OI
3.SIB02
l.5IE-Oa
3.44B-O1
NA
NA
I.I6E-04
I.I«B-04
e.26B«00
NA
I.O2E-OI
7.66E01
7.09E03
NA
7.78E-OS
6.79EOS
NA
NA
NA
NA
A44B400
6.6SE-OI
8.70E02
4.66E-OI
i.iactoo
NA • Not applicable
. aM «ip*MV* f*lat*i
I.00B40I
POOR QUALITY
ORIGINAL
-------
19
indicator chemical; maximum intakes are calculated using maximum
exposure point concentrations. All other exposure parameters are
identical in the calculation of the types of intakes.
Exposures to multiple sources of contamination through several
routes of exposure may occur. Therefore, the sum of all hazard
indices for each single age group and exposed population is given.
Hazard indices were calculated separately for the three age groups.
Both most probable and maximum lifetime hazard indices were
calculated and are presented in Table 9.
Manganese in the ground water is the compound responsible for
driving the hypothetical downgradient well exposure point over the
hazard index of one. Onsite worker exposure to copper in surface
soils also exceeds the hazard index of one.
Since the RfD for lead has been withdrawn, the hazard or risk
associated with lead could not be estimated by standard risk
assessment methods. For this reason, alternate methods were chosen
and lead was not included on the tables showing the noncarcinogenic
hazard estimates for the site. The Superfund removal action level
of 15 ppb for lead was used to screen site data for ground and
surface water for evidence of potential hazard due to lead. The
action level was used directly as a guideline to assess ground
water as a hypothetical source of drinking water while it was
adjusted for intake volume for the surface water incidental
ingestion scenario. Since the standard drinking water scenario
assumes two liters of water is ingested daily but the incidental
ingestion scenario assumes only O.O5 liters per hour of exposure,
the action level was adjusted by the relative volume associated
with each specific exposure scenario for incidental ingestion of
surface water.
For soil and fluff, the potential for hazard due to lead was
assessed by comparing detected concentrations to the interim
guidelines for soil lead cleanup levels established by EPA (OSWER
Directive #9355.4-02). The range given in the referenced guidance
is 5OO to 10OO ppm total lead for soil in residential areas. The
level of 1OOO ppm was used for this site.
2. Carcinooenic Risk
For potential carcinogens, risks are estimated as probabilities.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency slope and expressing the
result in scientific notation. An excess lifetime cancer risk of
1E-O6 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.
Tables 1O-12 present the calculated potential carcinogenic risks
for each age group of the potentially exposed populations. Both
-------
Table 9
EDM Site Eadaagermeat Assessment
Theoretical Noacarcinogenic Hazard Indices
Most Probable Maxima
Adults, off-site residents
Children, age 6-12
Children, age 2-6
Noncarcinogenic
Hazard
Index
5.14C-01
1.31E+00
2.25E+00
Noncarcinogenic
Hazard
Index
2.31E+00
6.55E+00
1.06E+OA
Note:
Note:
The exposure pathways Included In these calculations are listed below.
All ages: off-site fugitive dust (predicted by air model)
Ssh Ingestlon (theoretical bloaccumulatlon)
residential use of hypothetical downgradient well water
Adults: additional off-site fugitive dust exposure as hunters and fishermen
Adults.
Children 6-12: off-site recreational exposure to river water
Children 6-12: off-site recreational exposure to intermittent stream water and sediment
on-site recreational exposure to surface soil, fluff, and leachate (fence-
down scenario)
It should be noted that some of these pathways are hypothetical and do not represent actual
exposures under etui cut conditions.
-------
Alt
OtaMeicafcknla
O**tt« worker*
HimlcnMMl
KB*
Dtoda
Ztac
PC8«
Okudn
Ztac
KB*
DtoidN
Zinc
7.53E-Oa 2.I8E-06 7.70E«OO
6.8IB-I2 5.BIB-I2 I.MB«06
8.S7B-O7 7.43EO7 NA
Total fie*, thfe
I.SIE-08 4.34E-07 7.7OE*OO
I.4OB 12 I.40B-I2 l.6fiE*O6
I.MB 07 1.768-07 NA
Total rtafc. tMa ««»im
&.8OEO7
9.22B-07
NA
I.BOK-M
I.I6E-07
2.IBE07
NA
4.82E IO
3.78EI4
4.20300
I.30B-M
3.7ae-l4
4.7BE-08
7.70E«00
l.5fi£«O5
NA
•xpooaro point:
3.7IE08
5.9oeoa
NA
2.I4BO6
I.4OEO7
NA
3.38B-0*
I.68E-06
8.22807
NA
I.77B-O8
3.34B-08
2.I8B-07
NA
8.88B-4M
I.07E-07
S.80E-08
NA
I.I3B-07
VtaMMto
Hypo4hrtk»l
Dermal contact
•.ase-oa
6.I6E04
I.7IE04
8.I2E06
I.THE 04
I.03E08
3.42E07
I83B07
4.22EOI
I.86E-O3
•.B6E-04
3.e2B-O3
B.43E-O4
3.80E-Oa
I.7IB-00
7.23B06
Inhalation While
Balhlnf TitaMomtnoM 4.IOE-O3 I.B5E-O2
(Volatile OMpouixto Copper
Zinc
Total rUk. noMontlal wo
••rfaaavmtot
!•/••
Ullk Schu
•< UarfcUg) llunlcra and
Dcimal contact
IncklcnUj ln§>r«llon
3.47E06
5.81 EOS
0.04E07
1.01 EOS
I.3BE-07
I.34E06
NA
I.IOEO2
NA
NA
NA
I.IOE-02
NA
I.30E-02
NA
NA
NA
NA
NA
NA
6.67E06
NA
NA
NA
I.I3E-O8
NA
NA
NA
6.33E-05
NA
NA
8.1
NA
NA
NA
NA
2.I4EOS
NA
NA
4.28E-O8
NA
NA
NA
2.0IEO4
NA
NA
a.aas-04
NA
NA
NA
Mangfuie
Copper
Zinc
LOSE 04 3.06E04 NA NA NA
I.7&EOB 4.I6E-06 NA NA NA
I.82E05 4 (ME 05 NA NA NA
Total rUb. laU •ipoiura polat: No c*Blrikulloa No coaulamloa
POOR QUALITY
ORIGINAL
-------
TaMa 1O «
BOH Ml* gaa»»g«n
C«l«i4»lU« a* Catata ««!•!• Mik
CatclMgaala
Catc
la«g«a
Oa-iM*
BtaacciMuiitlliM
OcnMlConUct
•.07E09
9.07BO4
7.21B-04
.I3B04
.07B00
.10*09
7.08K04
NA
Derail oooUct
KB*
3.XIE03
I.07E00
I.3IBO3
7.70B*OO
70B06 I.OQE03 7.70E*OO
09B00 3.a0B09 1.568*06
0.IOB04 i.aaeoa NA
T*«al riafc. Ula *«>timt futut
ftlMBtfflMCtM
DBHP
Mai^HHicaa
7.40B-00
7.06B-O0
7.30BIO
a.4BB00
7.0BE06
l.iaB-04
3.44E00
S.20EIO
OBHP
I.IBB 04
4.47E04
I.03B-04
4.0BB-05
I.46E-00
a.aoB-oa
a.5IB04
0.73B04
5.47B-04
I.40E04
4.36B00
0.5BE-Oa
7.50E-04
a.OIBOS
TMal dak. Ikli
NA
7.70E«00
I.S0E«06
NA
NA
I.40B02
NA
7.70B*00
I.50E«06
NA
NA
I.40E03
»a.MaraUl:
S.0IB-O4
I.07B-03
I.36E04
a.04B-04
NA
S.MB-O3
NA
6.80EOS
I.I4B-04
4.I9B00
a.0SE-OS
soaeos
NA
NA
•.aeeoe
S.004VO4
a.40B-oa
I.07BOS
ft.aae-04
NA
3.77E04
a.a7E04
NA
NA
D42B06
NA
I.I3E03
0.78G-O4
NA
NA
a.02E-05
a.40B-0*
Tat
>^A.B .&ut^_
igaalariakt***
•.40B-04
NA • Not
t*
T«Ul •MclMgtak ikk I* hwiton «a
S.MB-07
0.00B-0*
I.I9B-O7
Note:
WM uaed In calcuUtli^ Infection of Surface will and Fluff far mulniMi eipa«uc: only Ihe woral of the two WM uacd In the total maximum rtah cakulaUon.
POOR QUALITY
ORIGINAL
-------
T.M. 11
UUk«
HF>*tlM«lMl
latak*
On-aMc
CMMlc
HyprthHlMl
InhaUOon
Inhalation
PCBs
Dhudn
Zinc
PCBs
Dfcudn
Zinc
Manganese
IMcblemiheiK
I.OaC-00
LOOK-IS
I.IIK-Oa
I.OIE-O7
7.BIE 13
a.TMC-07
3.I7E-OI
I.26E03
4.I6E4M
3 ME -08 7.70C*00
I.OOE 13 I.60C*06
I.2SC-06 NA
T*Ul (Uk. IkJ* MfMM* f*UI:
a.9ie7 NA
T«U1 itek. UU «ipM«ra fttmi:
0.29C-00
I.66C-OB
NA
lOQEtOO
4.73E-03
a.OBE-03
8.70E-OS
contact
(BMhfc^ Irfchloralhene
IMdilQcoclhcnc
2.BIE-04
I.46E-M
4.60E4)7
35AE-06
6.64E-09
T«4alrUk.
6.46E-OS
340E46
I.OIC-OS
a.o0E-oa
i.ioeoa
NA
NA
NA
I.IOEOa
NA
NA
NA
i.aoeoa
NA
NA
7.76E07
l.a3E-06
NA
xois-oe
NA
I.36COS
NA
NA
NA
i.&«eoa
NA
NA
NA
7 2 IE 05
NA
NA
3J0EO7
I.66B06
NA
a.»4B-07
a.24E-OS'
I.33E00
NA
2.S7B-0*
NA
6.aiE06
NA
NA
NA
6 01E 06
NA
NA
NA
X72EO4
NA
NA
S.34B-04
Of-aUcktticaot Dennal coolart Manganese
DEHP
Incidental Infection
S.8aE-OS
I.26E-07
I.6SE4M
7.44E4W
I.06E4I5
3.0IE44
I.06E4)7
I.47E4M
DEI IP
On-atte Dermal Contact Manganeae
IVtehloroclhene
Copper
Zinc
DEIIP
I.3BE-OS
S.60EOB
S.68E-0«
8.54E06
3.6BE-07
I.04E-04
I.4IE-OS
3.6IE45
8ISE4M
3.06E4M
5.45E44
730E4S
I.04E-O4
Taialrbk.
3.6SE4)S
I.33E08
0.0SE08
I.3IE4S
I.66EOS
a.B8E07
NA
7.70C»00
NA
NA
l.40EOa
NA
7.70E*00
NA
NA
I40E02
NA
770E.OO
I.IOE03
NA
NA
I 40EOa
ToUl lUh. IhU cB|KMHra polal:
NA
9.60E07
NA
NA
I.48E07
NA
IS IE 06
NA
NA
7.76E07
S.40BXW
NA
4.3IE-OB
3.83E 10
NA
NA
4.03E09
4.74B08
NA
3.03E08
NA
NA
4.91 E-O7
NA
i .see os
NA
NA
2S8E06
a.aoB-00
NA
9.SIEOH
9.96E 10
NA
NA
4O3EO9
i.ooe-07
NA Nut Applicable
POOR QUALITY
ORIGINAL
-------
rsfzaa
Takte 11 |c«*U«a»4)
BOM Mta BvdaaganMmt AM*
CaknJaHaai WCanbagtalB Rlak
HaPmtufcrtlaol
T . YjedUW i CJeaGuT
huh*
Hy»»«fc«llMl
laUk*
ICWI
MMKHBWB
CaMtoMMto
•artiea WaUi
McnnNlcnl alreaoi
Dermal contact Mangantae
Intldmtal ImraMon
aST
9.20E4M
9.42E-07
I.ME-06
I.07E4M
2.04E4S
I.ME 48
9.20E-O8
3.43147
I.96E-06
I07E46
9.04E4S
6.73E-O6
7.UE-OB
7.60E47
6.72E46
4.67E-06
4.BSE4NI
Ta4alrtak.
B.73E4M
7A2C-08
7.60E47
6.72E-O6
4.67E-06
4.59E-05
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Ctacr
••23C-O2 NA
7.I7E44 I.70E-09 NA
I.76E-O9 9.ME-O9 NA
T*tal ifak. tfcla aaaaama •*!•(:
NA
NA
NA
NA
NA
NA
NA
NA
NA
Ob^Mc
DenmlCortad
PCBa
Dtaxtn
Zinc
Incidental IngnOon PCBa
Dtaxto
Zinc
••ifctiaaH
On-aMe
ktanflancac
POOR QUALITY
ORIGINAL
Dermal contact
DEI IP
Incidental IngeaUon Manurae
Dfcudn
Capper
3.67E-05
9.46E4W
9.66E-04
7.IIE-06
6UE 10
9.46E04
I.72E-OS
I76E4M
I67E 10
7.40E-04
3.46E4M
9.0IE-04
20SE-04
6B2E 10
T*talrlak.
7.70E«00
I.66E«06
NA
770£»00
I66E«06
NA
•pa«wata4«tt
l.a0E04
9.S4E-04
NA
B.48EOS
I.06E04
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ft* OMOrltatlM
6.70E-03
9.84E-O4
NA
I.58E-03
I06E04
NA
4.20E-OS
I.I2E4S
3.94EIO
6.B7E-OS
4.5IE4)S
I.99E46
I.92E-IO
6.76C-OS
I.64E4M
I75C4K)
2.6SE42
I.80E4M
8 HE 04
NA
7.70E«00
I.S6E«O6
NA
NA
I.40E02
NA
7.7OE«00
I.66B«OS
NA
NA
I.4OEO2
T«4al Hak. tkla aapaMM patet:
' ToUl H»k. a
NA
I.3SE-OS
2.61 EOS
NA
NA
8.6IE 07
NA
I.07EOS
2.0SE-OS
NA
NA
2.S2E-06
7.4SB-06
9.O6B-O4
NA
ease os
6.21 EOS
NA
NA
2.I6E-OS
NA
4.S4E 04
3.74E04
NA
NA
I.I3EOS
•.•OB-04
S.ISE-03
Note: !<•" o^/day waa uacd In eakulalliig liiKcsliun u( Sui(ace noil and Hud for maximum enpuoure: only Ihe wont of the Iwu was used In UK lolal maxlmuin risk calculation.
-------
•DM Ml* B»fe»J«raMBl Mn
KB*
DfcMta
Ztoc
WaUt
ft.93£O0
7.79B-I2
• 66B07
a.sae-oi
3.37E09
763E04
4.00B03
9.0IEO4
I.74BOB
5.76B07
9.07E-OB
TrtcMoroc«kcnc K.30EO3
7.7SBI2
0.78B4I7
7.70B«00
I.66E«06
HA
7.04B-07
I.22E46
NA
I.I
l.aiK-06
i.aaB4
NA
TrtclitomrtlncM
Canpcr
Zinc
i.a&e«oo
assess
3.76B419
i.eaeoa
I.42KO3
6.66E-OS
9 ME 08
2.00248
I.IOE-02
NA
NA
NA
I.IOEO3
NA
NA
NA
i.aoE-oa
NA
NA
NA
2.40K06
NA
NA
NA
i.»ie-oa
NA
NA
NA
NA
NA
• WaUt
ItlMMM^
UutefldMiytklllt
saaeoa
I.SOEOS
S.ia809
soae^u NA
7.0CB4» NA
T«Ul iMu Ikte «»»»«»« petal:
NA
NA
NA
0.4IB-O6
NA
NA
NA
7.2 IB-OS
NA
NA
NA
2.60C-04
NA
NA
3.MB-O4
NA
NA
NA
TMol ftok. •• •CTMBIM:
3.7W-O4
NA
POOR QUALI
ORIGINAL
-------
20
most probable and maximum carcinogenic risks (using most probable
and maximum intakes) have been calculated for each carcinogen found
at the identified points of exposure.
The indicators responsible for the potential risk levels associated
with the fluff and the onsite soil are PCBs and dioxin. PCBs may
be bound within the fluff materials, and therefore, their
bioavailability may be limited. The assumptions in the intake
calculations, however, assume a bioavailability equal to that found
with similar compounds in soil.
The indicator responsible for the risk associated with the
hypothetical scenario for residential use of ground water is
trichloroethylene, which may be ingested and also volatilized
during bathing and subsequently inhaled.
Total maximum and most probable case risks associated with actual
and hypothetically applicable exposure points were calculated.
These total worst case and most probable case risks are shown in
Tables 1O-12. Lifetime estimates of risk are presented in Table
13. These have been calculated for offsite residents, following
the same procedure used to calculate lifetime hazard indices.
3. Environmental Risk
The major ecosystem of the EDM site and surrounding ridges is the
eastern deciduous forest. The wetland community is limited to the
small flood plain of the intermittent stream and the LSR and
several small emergent wetlands. All of these wetland areas,
except one small emergent wetland, are located outside of the
fenced site area. No rare or endangered species have been reported
or observed on or near the site. Although an intensive ecological
risk assessment was not conducted, some indication of potential
risk to wildlife and the environment can be assessed from the
toxicity testing (bioassays), field assessment, and human health
risk analysis and site conditions.
The lack of suitable habitat on or near the site and the site fence
discourages wildlife utilization of the site. Large mammals are
prevented from easily entering the site due to the fence. Small
animals, birds, and soil invertebrates are limited due to lack of
habitat.
The intermittent stream, most likely due to elevated contaminant
levels, has limited ability to support aquatic life. Direct
discharge of contaminated overburden ground water and contaminated
seeps into the intermittent stream have resulted in contaminated
sediments and surface water in the stream. Federal and state
surface water standards are exceeded for copper, lead, zinc,
manganese, and iron in this stream. The results of the
intermittent stream bioassays indicate possible site-related
toxicity to aquatic life in the intermittent stream due to metals.
-------
Table 13
EDM Site Endangerment Assessment
Calculation of Theoretical Total Lifetime Carcinogenic Rick
Contribution to Contribution to
Most Probable Ma***»nim
Lifetime Risk ; Lifetime Risk
Adults, off-site residents 5.16E-05 2.05E-04
Children, age 6-12 8.01E-05 7.17E-04
*
Children, age 2-6 5.64E-06 2.22E-05
THEORETICAL TOTAL MOST PROBABLE
LIFETIME CANCER RISK: 1.37E-O4
THEORETICAL TOTAL MAXIMUM
LIFETIME CANCER RISK: 9.44E-O4
Note:
The hypothetical exposure assumptions included in these calculations are listed below.
All ages: off-site fugitive dust at residence (predicted by air model)
residential use of hypothetical downgradient well water
Adults: additional off-site fugitive dust exposure as hunters and fishermen
Children 6-12: off-site recreational exposure to intermittent stream sediment
on-slte recreational exposure to surface soil, fluff, and leachate (fence-
down scenario)
Most Probable Maximum
Lifetime Rlak Lifetime Risk
Other Populations
Total carcinogenic risk.
on-slte maintenance workers 1.4E-03 1.6E-02
(30 yrs. exposure)
Total carcinogenic risk,
off-site workers 1.5E-07 1.6E-06
(30 yrs. exposure)
Total carcinogenic risk.
hunters and fishermen 8.2E-09 9.6E-08
(58 yrs. exposure)
-------
21
The Little Schuylkill River does not support resident aquatic life
for approximately 5 miles downstream due to its acid mine degraded
condition. Transport of sediment does not seem to have a
significant effect on metals concentrations because sediment
samples collected from the Little Schuylkill River both upstream
and downstream of the tributary, did not significantly differ for
metals.
Discussion of general limitations inherent in the risk assessment
process as well as the uncertainty related to some of the major
assumptions made in this assessment are included below.
1. The Risk Assessment is based upon the data collected during
the RI and uses RI sampling results and predictive modeling to
represent environmental concentrations over large areas. This
extrapolation contributes to the uncertainty of the Risk
Assessment. Also, air and emissions modeling is used rather than
actual sampling to predict the exposure concentrations due to
fugitive dust emissions from the site.
2. The potential human exposure to ground water is probably not
very substantial. No existing ground water users are present in
areas hydraulically downgradient of the site. Also, no downstream
use of the Little Schuylkill River water (which is the discharge
point for ground water from the site) for residential water
supplies has been identified in the vicinity of the site at this
time. However, aquatic life is exposed to contaminated ground
water via direct discharge and seepage to the intermittent stream.
3. The onsite exposures for children ages 6-12 are based on the
assumptions that the fence around the site is not in place and that
no remediation has occurred.
4. Lead, phthalates, and PCBs may be chemically bound in the
plastic matrix of the fluff and, therefore, fluff (and soil) may
not be as bioavailable as assumed in the risk assessment.
5. Due to the limitations of the risk assessment process itself
and to conservative assumptions made specific to the EDM site, the
risk levels calculated are considered to be estimates of worst-case
risk.
6. The CPSs and reference doses contain uncertainties resulting
from extrapolating from high to low doses and from animals to
humans. Protective assumptions were made to cover these
uncertainties.
-------
22
E. Risk Assessment Conclusions
Exposure of adult onsite maintenance workers to copper in the
surface soil and exposure to a hypothetical downgradient well (on
the site or state game lands) for all age groups were significant
noncarcinogenic hazards for individual pathways and populations at
the site. The maximum noncarcinogenic hazard index for actual
exposures for children age 2-6 was also greater than one.
Exposure to the fluff and onsite surface soil by onsite
maintenance workers, and (for fluff only) children age 6-12
trespassing on the EDM site presented significant carcinogenic
risks greater than 1E-O4. The potential risks associated with
these exposures are related to PCBs and dioxin in fluff material
and site soils.
. Residential use of ground water from a hypothetical well located
downgradient of the site presented exceeded 1E-O4 for maximum
estimates of carcinogenic risk. The risk is driven by the presence
of trichloroethylene in the ground water.
The estimated "most probable" lifetime carcinogenic risk for
off site residents is above the potentially acceptable range. Under
the "maximum" lifetime carcinogenic risk scenario, the risk to
offsite residents also exceeds 1E-O4.
. The intermittent stream, most likely due to elevated contaminant
levels, has limited ability to support aguatic life. Direct
discharge of contaminated overburden ground water and contaminated
seeps into the intermittent stream have resulted in contaminated
sediments and surface water in the stream. The results of the
intermittent stream bioassays indicate possible site-related
toxicity to aquatic life in the intermittent stream due to metals.
Federal and state surface water standards are exceeded for copper,
lead, zinc, manganese, and iron. Due to acid mine degradation in
the Little Schuylkill River, it is extremely difficult to measure
site impacts on that river.
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.
-------
23
VIII. DESCRIPTION OF ALTERNATIVES
In accordance with 4O C.F.R. § 3OO.43O, a list of remedial response
actions and representative technologies were identified and
screened to meet the remedial action objectives at the site. The
technologies that passed the screening were assembled to form
remedial alternatives. The PS evaluated a variety of technologies
used in the development of alternatives for addressing the
contaminated fluff, sediments, soils, and ground water. Upon
further analysis, the technologies and approaches contained in the
following alternatives were determined to be the most applicable
for OU1 and OU2 at this site.
Remedial Action Alternative l - No Action
The National Contingency Plan (NCP) requires that EPA consider a
"No Action" alternative for every site to establish a baseline for
comparison to alternatives that do require action. The No Action
alternative consists of taking no remedial action to cleanup
contamination or to address risks posed by the site. The existing
shallow ground water collection and treatment system would cease
operation and the existing surface water diversion ditch system and
the fence surrounding the site would cease to be maintained.
This alternative would present a threat to human health and the
environment at the site because it does not meet the ARARs
discussed below and would not meet the remedial objective of
cleaning up contaminated onsite areas and reducing the toxicity,
mobility, and volume of contaminants. This alternative serves only
as a baseline for comparison to other alternatives.
Capital Cost: $ O
Annual O&M. Present Worth: $ O
TOTAL COST $ O
Remedial Action Alternative No. 2 - Limited Action
This alternative provides for continued shallow ground water
collection using the existing interceptor trenches, continued
treatment at the existing waste water treatment facility, and
continued maintenance of the equalization lagoon, surface water
diversion ditches, and existing fence. Site inspections, surface
water, and ground water monitoring would also be conducted on a
semi-annual basis. The monitoring program would consist of
sampling approximately 1O existing monitoring wells and four
surface water samples at seep locations for halogenated
hydrocarbons, phenolics, and select metals (Pb, Cu, Al, Mn, Fe,
and Zn) with appropriate quality assurance protocol.
Remediation of the hotspot fluff and soil areas, metals
contaminated soils and sediments, and miscellaneous debris is not
addressed with this alternative. Additionally, the shallow ground
-------
24
water, some of which currently underflows the existing ground water
interceptor trench system and enters the deeper aquifer and
intermittent stream via seeps and normal discharge, would not be
addressed. Deep ground water also would not be addressed.
The Limited Action alternative would provide no remediation of the
contaminated media at the site and, therefore, would not meet the
potential chemical-specific ARARs discussed below. There would be
no potential location-specific or action-specific ARARs applicable
to this alternative.
This alternative does not meet the remedial objectives for the
site. It is not protective of human health and the environment.
There is no long-term effectiveness because wastes remain onsite
and exposed. Although the existing trench system collects and
treats some shallow ground water, there is an insufficient
reduction in toxicity, mobility, and volume for ground water and
other media. State and community acceptance of this alternative
would be very unlikely.
Capital Cost: O
Annual O&M. Present Worth; $ 966.OOP
TOTAL COST $ 966,OOO
Remedial Action Alternative 3 - Incineration of Hotspots,
Stabilization, Disposal or Consolidation/ Plus Limited Action
In addition to the Limited Action (Alternative 2) activities,
Alternative 3 provides for treatment and disposal of approximately
5,6OO cubic yards of hotspot fluff and soils, 60O cubic yards of
metals contaminated sediments and soils, and 14,OOO cubic yards of
miscellaneous debris as follows:
Excavate and incinerate, either onsite or offsite, dioxin
contaminated fluff exceeding the target level. The target level
for dioxin will be either 20 ug/kg or a level as determined by a
recognized fate and transport model, whichever is lower. The
estimated volume of dioxin contaminated fluff is 5OO cubic yards.
Excavate and incinerate, either onsite or offsite, PCS
contaminated fluff and soils in excess of the target level. The
target level for PCB contaminated fluff and soils will be either
25 mg/kg or a level as determined by a recognized fate and
transport model, whichever is lower. The estimated volume of PCB
contaminated fluff and soil is 5,16O cubic yards.
. Remove the lead contaminated soils in the drainage ditches above
target levels. The target level for lead contaminated soils will
be either 1,OOO mg/kg or a level as determined by a recognized fate
and transport model, whichever is lower. The estimated volume of
lead contaminated soils is 48O cubic yards.
-------
25
Remove the metals contaminated sand/silt/clay size stream
sediments above target levels. Target levels will determined by
a recognized fate and transport model. The estimated volume of
metals contaminated sediments is 120 cubic yards.
Run the EP Toxicity test, or another appropriate toxicity test
as determined during RD/RA, on the incinerator residuals and
miscellaneous debris. If soils and sediments will be disposed
offsite rather than consolidated with the remainder of the fluff
pile onsite, then also test these media.
. If incinerator residuals pass the toxicity test, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite. If the residuals fail the
toxicity test, then treat through stabilization to a level which
removes the characteristic by which they failed, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite.
. If soils and/or sediments pass the toxicity test, then dispose
in an offsite municipal landfill. If soils and/or sediments fail
the toxicity test, then treat through stabilization to a level
which removes the characteristic by which they* failed and dispose
in an offsite municipal landfill.
. If the miscellaneous debris passes the toxicity test, then
dispose in an offsite municipal landfill. If the miscellaneous
debris fails the test, then dispose in a RCRA landfill unit which
meets the statutory and regulatory requirements set forth below.
Upgrade surface water runon/runoff controls.
Collect and consolidate the onsite scattered fluff with the main
fluff pile.
Upgrade the existing site fence and continue site maintenance
and monitoring.
Although many other remedial options were evaluated during the
initial screening of technologies in the FS as shown in Table 14,
incineration of the hotspot areas was determined to be the best
treatment option for these media because it would destroy the
greatest amount of organic constituents (phthalates, PCBs, and
dioxin) in the fluff and soils. Additionally, incineration would
not only reduce the volume of contaminated media by 8O%, but would
also eliminate its mobility.
The incinerator would have to meet all hazardous waste (RCRA) and
PCB (TSCA) performance standards. Due to the presence of dioxins
and PCBs, the incinerator would be required to achieve 99.9999%
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TABLE 14
Olil
Screening of Technologies and Process Options
GENERAL
RESPONSE
ACTION
TECHNOLOGY PROCESS
TYPE OPTIONS
EFFECTIVENESS
IMPtEMENMSlLITY
COST
RETAIN
TREATMENT
- FLUFF. SOIL.
SEDINENf,
DEBRIS
SOIL
ONLY
Physical/ Contaminant
Chemical Extract Ion
(Washing)
St obi lint ion/
Solidification
Thermal Thermoplastic
Solidification
Onsite
Incineration
Offsite
Incineration
Physical/ Physical
Chemical Separation
In-SItu
Soil
Flushing
Vitrification
Doei not reduce (oxictty - transfers
contaminants to uaiteuater
Effectiveness questionable as lead and PCS
contaminant* may be bound in plastics
• unable to remove through washing
Nay b* difficult to remove washing
solution fro* treated Mterlal
Reduce* volume of contaminated Bed IB
Requires bringing potentially hazardous
washing solutions onsite
Concentrated wastewater requires treatment
Limited availability of services, equipment
Pilot study required to determine
effectiveness and reliability
Decrease* mobility of contaminants Equipment and services available
Chemlcilly/physically binds both organic and Readily implementable
Inorganic contaminants in the matrix pilot study required to determine
Increase* volume reagent mixture
Will effectively stabllite plastics
and adsorbed contaminant*
Sow solvents and greases can cause matrix
to soften and never become rigid
Increases volume
Destroy* dtoxins, PCBs and other organic*
Reduce* toxiclty and voluw
Ineffective on metals
Requires removal of contaminated media
from (Ite
Destroy* dioxins, PCflt and other organics
Reduce* toxiclty and volume
Ineffective on metals
Reduces volume of soil/sediment requiring
treatment
Remove* only fluff particles, not
potentially adsorped contaminant*
Effectiveness questionable as
contaminant* my be bound in plastics
Potential Increase In ground water
contamination
Contaminated wastewater requires treatment
Destroy* PCBs and other organic*
Immobilizes Inorganic*
Reduces volume
Not routinely demonstrated on remedial
scale
Requires drying and heating of waste
Requires highly skilled labor
and specialty equipment
Solidified product requires packaging
limited availability of mobile incinerators
Off-gas controls and ash stabilization
and disposal required
No offsite facilities will accept
dioxin contaminated waste at this time
Few facilities will accept waste with a
high lead content
Ash stabilization and disposal required
Equipment and services available
Pilot study required to assess
effectiveness and reliability
Would not treat waste*
Require* recovery of contaminated flushing
solution, which will be difficult due to
*ite geology/hydrogeology
Limited availability of service* and equipment
Pilot study required to verify effectiveness
Off-gas hood required to collect gases formed
during treatment
Equipment availability and services limited
Very expensive
High Capital
High 0 i M
tow to Moderate Capital
Low 0 1 M
High Capital
Low 0 t M
(Effectiveness limited to adsorbed
contaminants) '
res
Binds contaminants making'ironobile
No
(other solidification methods more
implementable and cost effective)
Moderate Capital Ves
Very High 0 t M Effective and implementable for
dioxin and PCB destruction
Moderate to Yes
Very High Capital Some facilities may be permitted to accept
No 0 I M dioxin contaminated waste in the future
High Capital No
low DIM (Not appropriate for removal of
adsorped contaminants)
Moderate Capital No
Moderate 0 I M (not appropriate for site conditions)
Very High Capital No
Very High 0 » H (excessive cost)
DISPOSAL
• FLUFF, SOU,
SEDIMENT,
DEBRIS
Offsite
Onsite
landfill
landfill
Consolidation with
Other Media
effective and reliable using
conventional techniques
Meets remedial action objectives
in combination with treatment/
disposal options
Effective and reliable using
conventional techniques
Meets remedial action objectives
In combination with treatment/
disposal options
Simplifies renediation by bringing site
media together
Effective and reliable using
conventional techniques
Meets remedial action objectives
in combination with treatment/
disposal options
Equipment and labor available Moderate Capital
Performed by typical excavation and Low 0 & M
hauling equipment
Triggers land disposal restrictions
• treatment required
RCRA facility not required after treatment
to pass toxicity test
Equipment and labor available
Performed by typical excavation and hauling
equipment
Yes
For select treated and untreated
media passing toxicity test
Moderate to High Capital No
High 0 t M (site not suitable for onsite landfill)
Equipment and labor readily available Low Capital
Performed by typical excavation and hauling, low O t M
equipment
Treatment required only for incinerator
residuals if fail toxicity test
Ves
For select treated and untreated
media passing toxicity test
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26
destruction of all organic hazardous constituents pursuant to 4O
C.F.R. § 264.343 (a) (2) . During the Remedial Design/Remedial Action
(RD/RA) phase, a test burn of the fluff and other treatability
studies as necessary would be performed to determine optimal
incinerator operating conditions and to quantify emissions for
control device selection and risk analysis. Throughout actual
operation, incinerator feed rates and operating conditions must be
continuously monitored and controlled to ensure compliance with the
performance standards. Incinerator emission estimates would also
have to be evaluated to ensure that they would not adversely affect
attainment of any National Ambient Air Quality Standards (NAAQS)
promulgated under the Clean Air Act, particularly the NAAQS for
lead, 4O C.F.R. Part 50, Appendix G.
An onsite mobile incinerator would be the most practical
incinerator choice because of the availability of mobile units and
the fact that the contaminated media would not need to be moved
offsite for treatment. Approximately one year would be required
to retain a mobile incinerator for the site. EPA's current best
estimate of incineration time for the hotspot areas is 288 days.
This estimate will be refined during RD/RA.
Offsite incineration facilities would most likely be unavailable
because no facilities are currently permitted to accept dioxin
contaminated waste and most will not burn a waste with the lead
concentrations which are present in the fluff. However, this could
change by the time the remedy is ready to be implemented.
Because the plastic fluff primarily consists of oxidizable organic
constituents, the quantity by weight of ash after incineration is
estimated to be approximately 20 percent of the original feed. The
ash remaining after incineration of soil is estimated to be
approximately 7O percent of the original soil weight. For the
purposes of this ROD, 1,342 cubic yards of incinerator ash are
estimated. A more accurate estimate of the ash quantity will be
determined during a pilot test burn.
Stabilization is an effective and proven technology for
immobilizing contaminants such as the metals which will remain in
the ash and residuals after incineration. If these residuals fail
the EP Toxicity or other appropriate toxicity test as determined
during RD/RA, the residuals will be stabilized with a cementitious
or pozzolanic reagent mixture which will increase the residual
volume to approximately 1,61O cubic yards.
The metals contaminated soils and sediments would have to undergo
toxicity testing if they will be disposed offsite. After either
passing the test without treatment, or being stabilized to a point
at which they pass the test, the soils and/or sediments would be
disposed in an offsite municipal landfill.
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The miscellaneous debris would undergo toxicity testing and, if it
passes the test, then it will be disposed in an offsite municipal
landfill. If the debris fails the test, then it will be disposed
in a RCRA landfill unit which meets minimum technology requirements
(MTRs). The small fluff pile located offsite to the south,
identified as Wl-16 on Figure 1O, is considered miscellaneous
debris. Offsite debris disposal would need to be accomplished
prior to May 8, 1992 in order to meet the requirements of the
National Capacity Variance.
If an onsite containment remedy is selected for OU3 - the remainder
of the fluff pile - then treated/untreated (depending on the
results of toxicity testing) incinerator residuals, and untreated
sediments, soils, and debris would be consolidated onsite with the
remainder of the fluff pile rather than being disposed offsite.
In this case, it would be unnecessary to perform toxicity testing
on the soils, sediments, and debris.
Although the small onsite emergent wetland is not in the direct
path of proposed excavation activities, care would need to be taken
when conducting any construction/excavation activities near this
area. Care would also need to be exercised when excavating
sediments from the intermittent stream so as to not unnecessarily
disturb surrounding wetlands areas.
Upgrading the surface water runon/runoff controls may include
deepening diversion ditches, fortifying berms, and providing
additional pumping facilities and piping - as described with regard
to the waste water treatment facility above - to insure that all
runoff is delivered to the waste water treatment facility.
ARARS
Major ARARs under this alternative include:
Chemical-Specific ARARs
(a) RCRA Subtitle C, 4O C.F.R. Part 261 and PA Code, Chapter
261 for identification of characteristic hazardous wastes;
(b) the National Ambient Air Quality Standards (NAAQS) set
forth at 40 C.F.R. Part 5O;
(c) the Pennsylvania Air Pollution Control Act, Title 25, PA
Code Chapter 127;
(d) the Pennsylvania ARAR for ground water for hazardous
substances, which is that all ground water must be remediated to
background quality as specified by 25 PA Code Sections 264.90 -
264.1OO, and in particular, by 25 PA Code Sections 264.97(i), (j),
and 264.1OO(a)(9).
(e) 4O C.F.R. Part 761.125, which requires removal of
contaminated soils to 25 mg/kg in areas of restricted public use
under the Toxic Substances and Control Act (TSCA). If fate and
transport modeling shows that a lower value is more appropriate,
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28
that value will be used.
Action-Specific ARARs
(f) if waste is to be conveyed off site to a landfill, then RCRA
and Department of Transportation regulations governing the
transportation of hazardous wastes, 40 C.F.R. Parts 262 and 263,
and 4O C.F.R. Parts 1O7 and 171-179, respectively;
(g) LDRs for disposal of incinerator residuals and for disposal
of sediments, soils, and debris if these are disposed offsite, as
provided in 40 C.F.R. Part 268;
(h) -PA Code, Title 25, Chapter 264, subchapter 0 - Pennsylvania
regulations for hazardous waste incineration.
(i) the EPA TSCA regulations for incineration of PCS materials,
4O C.F.R. § 761.7O;
(j) RCRA incineration standards set forth at 4O C.F.R. Part
264, subpart O, except to the extent federal regulations provide
more stringent standards;
(k) if the wastes are nonhazardous, then onsite landfilling
must comply with RCRA landfill standards, 4O C.F.R. Part 264,
subpart N;
(1) if the wastes are fixated using a cement or pozzolan-based
process, or another similar fixation process that provides
equivalent protection, EPA will require compliance with RCRA
standards for miscellaneous treatment units, 4O C.F.R. Part 264,
subpart X, and the operation, mobilization and closure requirements
set forth at 4O C.F.R. §§ 264.6OO, et sea.
(m) OSHA standards for worker's protection, 29 C.F.R. Parts
19O4, 191O, and 1926;
(n) RCRA landfill standards, 40 C.F.R. Part 264, subpart N, and
PA Code Title 25, Chapters 271, 273, 275, 277, 279, 281, 283, and
285, which regulate solid waste landfills, should EPA select
offsite disposal of nonhazardous materials;
(o) RCRA requirements for fixation of ash residues, if
necessary, 4O C.F.R. Part 264, subpart X;
Location-Specific ARARs
(p) PA Code, Title 25, Chapter 1O2, which pertains to erosion
control requirements related to excavation activities.
(q) the National Capacity Variance for off site debris disposal,
if it is determined to be hazardous, 40 C.F.R. Part 268, Appendix
VIII (there is a RCRA land disposal restriction capacity extension
until May 8, 1992, per 55 Fed. R. 2252O);
(r) The Clean Water Act, 33 U.S.C. §§ 1251 et seq.. which
regulates activity in the vicinity of wetlands;
To Be Considered
(a) the EPA Guidance on Metals and Hydrogen Chloride Controls
for Hazardous Waste Incinerators (EPA Office of Solid Waste, August
1989) ;
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29
(b) Lead in limited areas of site soils in excess of 1,000
mg/kg (OSWER Directive #9355.4-02) . If fate and transport modeling
shows that a lower value is more appropriate, that value will be
used.
(c) Dioxin in plastic fluff and soil exceeding 2O ug/kg.
Previous dioxin remediation by the EPA at Times Beach, Missouri has
required cleanup to the 20 ug/kg level in non-residential areas at
which future use is to be as a green area, such as a park or open
space. Although cleanup levels have varied at different sites, the
20 ug/kg level has also been used in some industrialized areas as
well. In the time since those levels were applied, EPA has changed
its methods of calculating 2,3,7,8-TCDD equivalence for the dioxin
and dibenzofuran compounds. At the EDM site, the new equivalence
value is twice that calculated using the old method. Therefore,
the number 20 ug/kg at the EDM site will provide protectipn
equivalent to 10 ug/kg, as applied at some other sites before the
calculation method was changed. If fate and transport modeling
shows that a lower value is more appropriate, that value will be
used.
(d) Executive Order 11988, 4O C.F.R. § 6, Appendix A,
concerning federal wetlands policies;
Effect of Proposed Remedy;
Incineration would eliminate the toxicity and mobility of organic
hotspot contaminants and reduce the total volume of contaminated
media. Stabilization of the incinerator residuals, soils, and
sediments, if necessary, would reduce the toxicity and mobility of
inorganic contaminants in these media by chemically and/or
physically binding them in the stabilization matrix. Volume would
increase slightly. Disposal of the stabilized/unstabilized
material either offsite or consolidation with the remainder of the
fluff pile, if an onsite containment remedy is selected for that
OU (OU3), would prevent contact. Offsite disposal of miscellaneous
debris will prevent contact. Removal of sediment from the
intermittent stream would remove the hazard posed to aquatic life
by metal concentrations in sediment and surface water - surface
water is impacted by sediment contamination through leaching of
contaminants in sediment to surface water. Toxicity and long-term
effectiveness would be addressed by completely removing and
disposing of contaminated sediments.
The remedial objectives for OU1 media are met through this
alternative, however, as described in Alternative 2, the remedial
objectives for OU2, ground water, are not met under this
alternative. Although the existing trench system collects and
treats some shallow ground water, there is an insufficient
reduction in toxicity, mobility, and volume for ground water
through this alternative. Therefore, this alternative is not
protective of human health and the environment.
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30
Capital Cost: $ 10,6O1,8OO
Annual O&M. Present Worth: $ 966.OOP
TOTAL COST $ 11,567,8OO
Remedial Action Alternative 4 - Incineration of Hotspots,
Stabilization, Disposal or Consolidation, Shallow Ground Water
Collection/Treatment, Additional Ground Water Studies.
In addition to the incineration/stabilization/disposal/
consolidation activities of Alternative 3, Alternative 4 provides
for an interim remedy for OU2, ground water, of enhanced collection
and treatment of shallow ground water and further studies regarding
the practicability of deep ground water restoration. The ground
water activities for this alternative would include the following:
Install a ground water collection trench parallel to the
existing trench, down to the top of bedrock, with an estimated
inflow rate of 2O gpm. The deepened trench would extend the length
of the intermittent stream that is potentially fed by overburden
ground water flow.
Upgrade the waste water treatment facility as necessary in
order to achieve Pennsylvania NPDES permit limits for organics and
Pennsylvania ARARs for metals in surface waters, as described in
the Pennsylvania Ambient Water Quality Criteria (AWQC) values (PA
Code 25, Chapter 93) and PA secondary drinking water standards.
Either upgrade the equalization lagoon to meet NPDES
requirements and/or RCRA requirements, or construct a new
equalization lagoon as part of a new collection and treatment
system which meet the aforementioned criteria. The degree of
upgrade and/or whether a new lagoon is required will be determined
during RD/RA.
This alternative includes deepened interceptor trenches to remove
all contaminated ground water from the overburden flow system.
The existing interceptor trenches would be supplemented by a deeper
trench to the bedrock surface which would collect the overburden
ground water leaving the site as underflow beneath the exiting
shallow trenches. This would require reconstruction from
approximately the area of MW-3/O westward and along the southwest
border of the site. That is, the stretch along which deeper
overburden flow occurs in the local water table system. The
trenches would extend to bedrock, which is approximately 2O feet
below the ground surface. The deepened trench is estimated to
recover about 2O gpm of both perched flow and lateral flow from the
local system. Due to the limited thickness and variable hydraulic
conductivity of the overburden soil, a pumping well system is not
considered to be technically applicable for this component of
ground water collection.
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31
The waste water treatment facility (WWTF) will be upgraded as
necessary in order to achieve Pennsylvania NPDES permit limits for
organics and Pennsylvania ARARs for metals in surface waters as
described above. The WWTF will treat collected leachate, ground
water, and scrubber waste water . Required upgrades may include,
but would not be limited to, a filtration system for metals removal
and additional pumping facilities and piping to ensure that all
runoff is being delivered to the waste water treatment facility.
The designs and specifications for the upgrade including the type
and extent of additional accessory pumps and piping apparatus will
occur during RD/RA and be refined via pilot scale testing onsite.
The equalization lagoon will be upgraded either to meet NPDES
and/or RCRA requirements, or a new lagoon will be constructed as
part of a new collection and treatment system. RCRA would require,
at a minimum, a double liner and leak detection system. The degree
of upgrade and/or whether a new lagoon is required will be
determined during RD/RA.
The practicability of restoring the deep ground water system would
be evaluated as part of this alternative. Implementation of an
effective recovery well system in the bedrock is expected to be
difficult, due to the fractured nature of the aquifer at the site
which results in anisotropic flow conditions. The collected ground
water could have much lower constituent concentration levels than
those observed at the site monitoring wells due to dilution by
uncontaminated ground water from offsite. Additionally, wetlands
downgradient of the site adjacent to the Little Schuylkill River
could be negatively impacted by a deep ground water recovery system
because they would likely be deprived of sufficient water to
maintain the ecosystem.
To better assess the practicability of deep ground water
restoration, further information may be collected on the extent of
contamination, technical and cost effectiveness estimates for a
deep ground water remediation scheme, and the potential effects of
remediation on downgradient wetlands. Data generated during the
interim action will be used to determine when and where the
restoration of ground water is feasible. The interim remedy may
be incorporated into the design of the site remedy specified in
the final action ROD.
ARARa
The ARARs for OU1 of this Alternative are the same as for
Alternative 3. ARARs which address OU2 are shown below. Because
the remedy proposed for OU2, ground water, is interim in nature,
EPA need not address all of the ARARs for OU2 at this time; the
additional ARARs will be delineated when EPA prepares the final
action ROD, per 4O C.F.R. § 3O0.43O(f)(1)(ii) (C)(1).
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32
Chemical-Specific ARAR
(a) the Pennsylvania Ambient Water Quality Criteria (AWQC)
values (PA Code 25, Chapter 93) for copper (4.O ug/1), lead (O.6
ug/1) , zinc (36 ug/1) , and secondary drinking water standards under
the Pennsylvania Safe Drinking Water Act (PA Code, Title 25,
Chapter 1O9) for iron (3OO ug/1) and manganese (5O ug/1) in surface
water. EPA will also require compliance with the terms of the
NPDES permit for the waste water treatment facility.
Action-Specific ARAR
(b) PADER Hazardous Waste Regulations (PA Code, Title 25,
Chapters 26O-27O) for the equalization lagoon upgrades/new lagoon.
Effect of Proposed Remedy:
The remedial objectives for both OU1 and OU2 are met through this
alternative. The hotspot areas, contaminated soils, sediments, and
debris will be remediated and the objectives will be met as
described in Alternative 3. In addition, upgrading the shallow
ground water collection/treatment system will reduce mobility by
collecting any contaminated overburden and shallow ground water
that currently underflows the existing interceptor trenches and
discharges to the intermittent stream through seeps or direct
ground water discharge. Thereby, toxicity to aquatic life in the
stream will be reduced and toxicity of the collected waste water
will be eliminated through treatment. Additionally, a provision
is included which allows deep ground water remediation if it is
found to be practicable.
Capital Cost: $ 11,OO1,OOO
Annual O&M. Present Worth: $ 1.428.OOP
TOTAL COST $ 12,429,OOO
Remedial Action Alternative 5 - Incineration of Hotspots,
Stabilization/ Disposal or Consolidation, Shallow and Deep
Ground Water Collection/Treatment.
This alternative is identical to Alternative 4, except that deep
ground water would be remediated without further consideration as
to practicability. This alternative would include the following
actions for deep ground water:
Install two or more ground water recovery wells
Upgrade or construct a new waste water treatment facility.
Recover and treat the deep ground water for TCE and manganese
removal.
This alternative consists of the use of pumping wells and
interceptor trenches to remove all contaminated ground water from
both the overburden and bedrock flow systems. This recovery system
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33
would operate until either the ground water cleanup potential ARARs
were achieved or practical limits of constituent recovery were
reached. A system of two or more wells would be used. The actual
number of wells and pumping rates would depend on a detailed system
design which would be conducted during RD/RA.
Design of an effective ground water recovery system for the bedrock
would be difficult due to the anisotropic nature of flow.
The recovered ground water would be treated if necessary using a
chemical-oxidation-filtration type system. If ground water
treatment was needed, determination of the most appropriate
treatment option would be made during the RD/RA phase.
ARARS
The ARARs for OU1 of this Alternative are the same as for
Alternatives 3 and 4. The ARARs for OU2 are the same as for OU2
of Alternative 4, with the following additions:
Chemical-Specific ARARs
(a) the Pennsylvania standards for TCE and manganese in ground
water (25 PA Code §§ 264.9O - 264.1OO);
Location-Specific ARARs
(b) RCRA Location Standards for treatment, storage, or
disposal facilities located in a 100-year floodplain, 4O C.F.R.
Part 264;
(c) the Clean Water Act (CWA) and the Fish and Wildlife
Coordination Act, both of which regulate activity in the vicinity
of wetlands, 33 U.S.C. §§ 1251 et sea.;
(d) The PA Hazardous Waste Facility Siting regulations, Title
25, Chapter 269, Subchapter A), except to the extent permits are
not required, per § 121(e) of CERCLA, 42 U;S.C. § 9621(e). This
requires that no portion of a new facility may be located within
a wetland or bordering a vegetated wetland, unless approved by the
State. Chapter 1O5 (25 PA Code Sections 105.1 et seq.) if EPA
determines that construction within the wetland area is necessary;
(e) Executive Order 11988, the Federal Floodplains Management
Executive Order, 40 C.F.R. § 6, Appendix A.
Effect of Proposed Remedy;
This alternative meets the remedial objectives of OU1 and OU2.
Hotspot areas, contaminated soils, sediments, debris, and shallow
ground water would be remediated and objectives met as described
for Alternative 4. While this Alternative attempts to treat deep
ground water, the necessity of such an action, the technical and
cost effectiveness, and the potentially serious negative
consequences to downgradient wetlands provide substantial doubt as
to whether such action is acceptable. In particular, the location-
specific ARARs for protection of wetlands likely would not be met,
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34
including Executive Order 1199O (4O C.F.R. § 6, Appendix A), which
sets forth a policy designed to minimize or prevent any adverse
impacts to wetland areas; the pumping and treating of contaminated
ground water would likely dewater the wetland areas.
Capital Cost: $ 12,915,8OO
Annual O&M. Present Worth: S 2.928.OOP
TOTAL COST $ 15,843,800
IX. COMPARATIVE ANALYSIS OF ALTERNATIVES
The five remedial action alternatives described above were
evaluated under the nine evaluation criteria as set forth in the
NCP 4O C.F.R. § 3OO.43O(e)(9). These nine criteria are organized
according to the groups below and can be categorized into three
groups: threshold criteria, primary balancing criteria, and
modifying criteria.
THRESHOLD CRITERIA
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate
requirements (ARARs)
PRIMARY BALANCING CRITERIA
Long-term effectiveness
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
MODIFYING CRITERIA
Community acceptance
State acceptance
These evaluation criteria relate directly to requirements in
Section 121 of CERCLA, 42 U.S.C. Section 9621, which determine the
overall feasibility and acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy to be
eligible for selection. Primary balancing criteria are used to
weigh major trade-offs between remedies. State and community
acceptance are modifying criteria formally taken into account after
public comment is received on the Proposed Plan. The evaluations
are as follows:
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35
1) Overall
A primary requirement of CERCLA is that the selected remedial
action be protective of human health and the environment. A remedy
is protective if it reduces current and potential risks to
acceptable levels under the established risk range posed by each
exposure pathway at the site.
A. Fluff. Soils. Sediments. Debris
The incineration, stabilization, and disposal options of
Alternatives 3, 4, and 5 would provide protection of human health
and the environment by eliminating, reducing, and controlling risk
through treatment and engineering controls. Exposure to the
principal threats at the site and all other contaminated solid
media would be eliminated through incineration, stabilization, and
disposal. Incineration would be required to completely destroy all
organics. Residuals and soils/sediments with metals exceeding
target levels would be stabilized, if necessary, and disposed to
minimize the potential for future migration. Removal of sediment
from the intermittent stream would remove the hazard posed by metal
concentrations to aquatic life. Disposal of treated and untreated
materials, including miscellaneous debris, will prevent contact and
further reduce mobility.
B. Ground Water
By upgrading surface water runon/runoff controls, Alternatives 3,
4, and 5 decrease contaminant migration via fluff and contaminant
transport to the ground water and surface water. Alternatives 2
and 3 allow continued operation of the existing ground water
collection and treatment system, without modification, which allows
some shallow ground water to underflow the existing trench system
without treatment. Alternative 4 is more protective than
Alternatives 2 and 3 because it includes upgraded surface water
runon/runoff controls and also enhances shallow ground water
collection and treatment while further studying the practicability
of deep ground water restoration. Alternative 5, although it
addresses the shallow and deep ground water, may likely dewater
downgradient wetlands through pumping, thereby being unprotective.
Alternative 1, No Action, accomplishes none of the above and,
therefore, is not protective of human health and the environment.
No action would occur at the site and the risks to human health and
the environment would remain unchanged.
2J Compliance with Applicable or Relevant and Appropriate
Requirements
This criterion addresses whether or not a remedy will meet all of
the applicable or relevant and appropriate requirements of other
environmental statutes and/or provide grounds for invoking a
waiver.
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A. Fluff. Soils. Sediments. Debris
Alternatives 3, 4, and 5 would comply with all applicable Federal
and State environmental laws. Incineration would result in the
destruction of organic contaminants to below Federal and state
standards. Federal and state regulations/ guidelines regarding the
incineration of hazardous wastes would be complied with as would
air emissions requirements. Federal transportation and land
disposal ARARs would also be met. Alternatives 1 and 2 would not
meet ARARs for the solid media and would not comply with the CERCLA
preference for treatment.
B. Ground Water
Alternatives 4 and 5 address the issue of contaminated ground water
while Alternatives 1, 2, and 3 do not. ARARs for the interim
ground water action under Alternative 4 will be met with respect
to discharges from the waste water treatment facility and,
subsequent target levels to be achieved for surface water. Since
the selected remedy, Alternative 4, is an interim remedy for OU2,
ground water, further compliance with ground water ARARs will be
addressed in the ROD for the final remedy. Alternative 5 complies
with chemical-specific ground water ARARs, however, location- and
action-specific ARARs may not be met, especially with regard to
wetlands.
3) Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses the long-term
protection of human health and the environment once remedial action
cleanup goals have been achieved, and focuses on residual risks
that will remain after completion of the remedial action.
A. Fluff. Soils. Sediments. Debris
Alternatives 3, 4, and 5 would permanently and completely eliminate
the hotspot areas which present the principal threat at the site.
Incinerator residuals and metals contaminated soils and sediments
would be stabilized, if necessary, and disposed to minimize the
potential for any future migration from these residuals.
Miscellaneous debris would be safely disposed. The removal of the
contaminated sediment from the stream would eliminate the impact
on aquatic life in the intermittent stream.
B. Ground Water
The selected interim remedy, Alternative 4, remedy provides for
treatment of shallow ground water, with a final analysis of long-
term effectiveness and permanence for ground water to be addressed
in the final action ROD. Alternative 5 might be effective in the
long-term by attempting to treat both shallow and deep ground water
contamination. Contaminant concentrations might be permanently
reduced to near or below potential ARARs, and manganese might
continually be reduced at a slower rate. Whether this would be
possible or effective and permanent in the long-term will be
addressed in the final action ROD for this OU.
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37
Alternatives 1 and 2 provide no long-term effectiveness or
permanence for solid or ground water media. Alternative 3 provides
no long-term effectiveness or permanence for ground water.
4) Reduction of Toxicity, Mobility* an<* voinm*
This evaluation criterion addresses the degree to which a
technology or remedial alternative reduces the toxicity, mobility,
or volume of a hazardous substance. Section 121(b) of CERCLA, 42
U.S.C. Section 9621(b), establishes a preference for remedial
actions that permanently and significantly reduce the toxicity,
mobility, or volume of hazardous substances over remedial actions
which will not result in such reduction.
A. Fluff. Soils. Sediments. Debris
Alternatives 3, 4, and 5 will eliminate the toxicity of dioxin,
PCBs, and other organics via thermal destruction. The volume of
contaminated media will be reduced by 80% after incineration,
however, a corresponding 15-2O% volume increase is expected after
stabilization of the residuals. An overall 67% volume reduction
is expected to be achieved. Metals concentrations in the residuals
would increase, which increases toxicity, however, this effect
would be overcome through stabilizing the residuals, if toxicity
testing shows that this is necessary. Stabilization of the
residuals, sediments and soils, if necessary, would reduce toxicity
and mobility by chemically and/or physically binding the inorganic
contaminants in the matrix. Therefore, toxicity and mobility will
be greatly reduced for these alternatives by destroying the
organics and stabilizing the inorganically contaminated
residuals/soils/sediments.
Alternatives 1 and 2 provide no reduction in toxicity, mobility,
and volume of the solid media.
B. Ground Water
Alternatives 4 and 5 address the toxicity, mobility, and volume of
contaminated ground water by collecting and treating shallow ground
water. Alternative 5 also would attempt to reduce toxicity and
mobility with subsequent volume reductions of contaminated deep
ground water. Alternatives 2 and 3 currently reduce the toxicity
of some shallow ground water which is collected and treated under
the existing system, however, some shallow ground water underflows
the existing system without treatment and deep ground water
contamination is not addressed.
5) Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed to
achieve protection of human health and the environment, and any
adverse impacts that may be posed during the construction and
operation period until cleanup goals are achieved.
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A. Fluff. Soils, Sediments. Debris
EPA estimates approximately 288 days will be needed under
Alternatives 3, 4, and 5 to achieve reductions in toxicity,
mobility, and volume for the solid media. Risks to human health
and the environment would be mitigated through the use of advanced
air emissions control systems for the incinerator. Drainage
controls would prevent continued erosion and end transport of
contaminated soils to the intermittent stream. Removal of the
intermittent stream sediments would mitigate adverse impacts to
aquatic life quickly.
B. Ground Water
Reductions in shallow ground water contamination would be achieved
as soon as the deepened trench and improved treatment system were
implemented under Alternatives 4 or 5. Alternative 2 would have
no short term effectiveness for the solid media or ground water
since site risks are not reduced from existing conditions.
6) Implementability
This is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to
implement the chosen solution.
A. Fluff. Soils. Sediments. Debris
Alternatives 3, 4, and 5 are implementable. Equipment required,
including a mobile incinerator if onsite incineration is
implemented, and typical earth moving equipment is commercially
available. However, advance scheduling would be necessary to
attain a mobile incinerator. Offsite incineration is currently not
implementable due to the lack of permitted facilities. The
incinerator would be fitted with advanced emissions control systems
to reduce potential short-term risks to within an acceptable range.
There would be no implementation issues associated with
Alternatives 1, 2, and 3.
B. Ground Water
Only Alternatives 4 and 5 provide for additional measures to remedy
ground water. To better assess the practicability (and
implementability) of deep ground water restoration, further
information may be collected under Alternative 4 on the extent of
contamination, technical and cost effectiveness estimates for a
deep ground water remediation scheme, and the potential effects of
remediation on downgradient wetlands. Data generated during the
interim action would be used to determine when and where the
restoration of ground water is feasible. The interim remedy might
be incorporated into the design of the site remedy specified in the
final action ROD. The implementability of Alternative 5 is
questionable because of wetlands ARARs issues and the technical
limits of achieving ground water cleanup goals in a fractured
bedrock aquifer. There are no implementability issues concerning
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ground water associated with Alternatives 1, 2 and 3 since no
additional actions are taken to remedy ground water.
7) Cost
CERCLA requires selection of a cost-effective remedy that protects
human health and the environment and meets the other requirements
of the Statute. Project costs include all construction and
operation and maintenance costs incurred over the life of the
project. Capital costs include those expenditures necessary to
implement a remedial action.
The costs of the five alternatives range from $ O to
$ 15,852,820. The degree of protection provided by the
alternatives also varies. Comparison of different levels of costs
for different levels of protectiveness and permanence of treatment
is a primary decision criterion in the cost-effectiveness
evaluation.
Alternatives 3, 4, and 5 are the highest in cost, but offer a
higher level of protection by providing permanent relief from
exposure to the principal contaminants at the site. A breakdown
of the costs associated with Alternative 4, the selected
alternative, is provided in Table 15.
8) coBH|>upi.ty Acceptance
A public meeting on the Proposed Plan was held on February 19, 1991
in Hometown, Pennsylvania. Most comments received at that meeting
centered on health concerns related to onsite incineration.
Comments received during the meeting and comment period are
discussed in the Responsiveness Summary attached to this ROD.
9) State Acceptance
The Commonwealth of Pennsylvania has concurred with this selected
Remedial Action.
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TABLE 15
Breakdown of Costs
Selected Remedy
INSTALLED COST
Site Preparation
Consolidation of
Scattered Debris
Handling of Media
Exceeding Target Levels
. Excavation and Removal
. Onsite Incineration
. Analytical Work - TCLP
. Stabilization/Transport/Disposal
Surface Water Runon/Runoff Controls
Enhanced Shallow
Ground Water Collection
and Treatment
. Holding Basin Upgrade
. Interceptor Trench
. Upgrade to Runoff Lagoon
. Upgrade to UWTF
$ 500.000
$ 140,000
-
TDCC
Indirect Cost
Contingency at 30X TDCC
TOTAL CAPITAL COST
30 Year PU 08* at 5X GU Monitoring
30 Year PU O&M at 5X GU Monitoring
TOTAL COST
$ 56,700
$ 2,630,000
$ 100,000
$ 3,516,100
$ 58,600
% 7,001,400
$ 97,500
$ 160,000
S 28,900
S 20,700
$ 307,100
S 7,308,500
S 1,500,000
$ 2,192,500
* 11,001,000
$ 428,000
$ 1,000,000
S 12,429,000
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X. SELECTED REMEDY
Alternative 4; Incineration of Hotspots, Stabilization, Disposal
or Consolidation, Shallow Ground Water Collection/Treatment,
Additional Ground Water Studies.
Based on the findings in the RI/FS and the nine criteria listed
above, the US EPA has selected Alternative 4. Alternative 4
represents the best balance among the evaluation criteria. The
remedy for OU1 of that Alternative satisfies the statutory
requirements of protectiveness, compliance with ARARs, cost
effectiveness, and the utilization of permanent solutions and
treatment to the maximum extent practicable. The extent to which
OU2 satisfies statutory requirements will be determined in the
final action ROD for that OU. Alternative 4 is selected as the
most appropriate remedy for meeting the goals of Operable Units 1
and 2 at the Eastern Diversified Metals Site. While Alternative
5 provides for remediation of deep ground water, EPA remains
seriously concerned that the pumping and treating of this aquifer
will adversely affect the nearby wetlands area by depriving it of
a substantial amount of water.
As discussed in Section VIII, Alternative 4 provides for a final
remedy for OU1 media consisting principally of treatment and
disposal of approximately 5,6OO cubic yards of hotspot fluff and
soils, 6OO cubic yards of metals contaminated sediments and soils,
and 14,000 cubic yards of miscellaneous debris, and an interim
remedy for OU2, ground water, which includes enhancing shallow
ground water collection and treatment and further study on the
practicability of deep ground water restoration. The major
components of this alternative include the following:
Excavate and incinerate, either onsite or offsite, dioxin
contaminated fluff exceeding the target level. The target level
for dioxin will be either 2O ug/kg or a level as determined by a
recognized fate and transport model, whichever is lower. The
estimated volume of dioxin contaminated fluff is 5OO cubic yards.
Excavate and incinerate, either onsite or offsite, PCB
contaminated fluff and soils in excess of the target level. The
target level for PCB contaminated fluff and soils will be either
25 mg/kg or a level as determined by a recognized fate and
transport model, whichever is lower. The estimated volume of PCB
contaminated fluff and soil is 5,160 cubic yards.
. Remove the lead contaminated soils in the drainage ditches above
target levels. The target level for lead contaminated soils will
be either 1,OOO mg/kg or a level as determined by a recognized fate
and transport model, whichever is lower. The estimated volume of
lead contaminated soils is 48O cubic yards.
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Remove the metals contaminated sand/silt/clay size stream
sediments above target levels. Target levels will determined by
a recognized fate and transport model. The estimated volume of
metals contaminated sediments is 12O cubic yards.
Run the EP Toxicity test, or another appropriate toxicity test
as determined during RD/RA, on the incinerator residuals and
miscellaneous debris. If soils and sediments will be disposed
offsite rather than consolidated with the remainder of the fluff
pile onsite, then also test these media.
. If incinerator residuals pass the toxicity test, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite. If the residuals fail the
toxicity test, then treat through stabilization to a level which
removes the characteristic by which they failed, then either
dispose in an offsite municipal landfill or consolidate with the
remainder of the fluff pile onsite.
. If soils and/or sediments pass the toxicity test, then dispose
in an offsite municipal landfill. If soils and/or sediments fail
the toxicity test, then treat through stabilization to a level
which removes the characteristic by which they failed and dispose
in an offsite municipal landfill.
. If the miscellaneous debris passes the toxicity test, then
dispose in an offsite municipal landfill. If the miscellaneous
debris fails the test, then dispose in a RCRA landfill unit which
meets the statutory and regulatory requirements set forth below.
Install a ground water collection trench parallel to the
existing trench, down to the top of bedrock, with an estimated
inflow rate of 2O gpm. The deepened trench would extend the length
of the intermittent stream that is potentially fed by overburden
ground water flow.
. Upgrade the waste water treatment facility as necessary in order
to achieve Pennsylvania NPDES permit limits for organics and
Pennsylvania ARARs for metals in surface waters, as set forth
below.
. Either upgrade the equalization lagoon to meet NPDES and/or RCRA
technology requirements, or construct a new equalization lagoon as
part of a new collection and treatment system which meets the
aforementioned criteria. The degree of upgrade and/or whether a
new lagoon is required will be determined during RD/RA.
Study further the practicability of deep ground water
restoration.
Upgrade surface water runon/runoff controls.
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Collect and consolidate the onsite scattered fluff with the
remainder of the fluff pile.
Upgrade the existing site fence and continue site maintenance
and monitoring.
Major objectives of the incinerator operation would be to assure
compliance with the RCRA, TSCA, and Clean Air Act performance
standards, as set forth in the ARARs section below, prevent
slagging of minerals, and minimize volatilization of metals while
achieving complete destruction of organics in the incinerator feed
stream. This could be accomplished by either a rotary kiln or an
infrared primary combustion chamber each followed by an
afterburner. To minimize slagging and metals volatilization, the
primary chamber would be operated at a moderate temperature (160O-
2OOO degrees F). To insure thorough destruction of organics, the
afterburner would be operated above 22OO degrees Fahrenheit.
Material will be fed into the primary chamber, heated to the
desired temperature, and maintained at that temperature for a
sufficient period of time to ensure that the target destruction
levels set forth at 40 C.F.R. § 264.343 are achieved. Soils would
be screened to obtain a reasonably uniform particle size
distribution. Fragments larger than 6 inches in diameter would be
crushed prior to incineration.
The secondary combustion chamber (afterburner) will provide
additional retention time to insure thorough destruction of
organics. It will be operated at conditions designed to completely
oxidize all organics, including PCBs, dioxins, and products of
incomplete combustion (PICs), leaving the primary combustion
chamber.
The secondary combustion chamber will be followed by one or more
air pollution control devices that will remove fly ash, acid gases,
and metals from the exhaust gas. The exact components of the air
pollution control system will not be known until pilot test results
are obtained using actual wastes from the site. It is likely that
the system will include a high energy alkaline scrubber for acid
gas and some particulate control (a standard component on most
mobile incinerators) followed by a high efficiency particulate
control device such as a bag filter or electrostatic precipitator
to control fine particulates (i.e. metals). It is anticipated that
a fine particulate control device would have to be retrofitted to
an existing incinerator unit. It is important to note that the
discussion above regarding incinerator types, design, and operating
parameters is only an estimate; final design and optimum operating
conditions for the incinerator and emissions control devices will
be determined by EPA during RD/RA.
Compliance with the relevant performance standards will be verified
by conducting a trial burn. The trial burn will include tests to
determine the actual organic destruction efficiency and the metals,
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43
particulate, and HC1 emission rates. Key incinerator and air
pollution control device operating parameters will also be
recorded. These conditions will form the operating "envelope" for
the remainder of the incinerator's operation. The trial burn will
begin no more than fifteen days after commencing incinerator
operation.
Analysis of incinerator wastes would be required prior to disposal
or consolidation. Because the fluff contains lead, which is not
destroyed through incineration, the ash and other incinerator
residuals would likely require treatment. Land Disposal
Restrictions (LDRs) require treatment for lead to a leachability
of less than 5 mg/1, by the Extraction Procedure (EP) Toxicity
test. Since the wastes are "characteristic" wastes, the wastes
would not have to be delisted. Following treatment (stabilization
in this case) which eliminates the characteristic by which it was
classified as hazardous (lead), the residuals would be reclassified
as non-hazardous.
Stabilization would require treatment with a cementitious or
pozzolanic reagent mixture developed specifically to bind the metal
constituents within the stabilizer and residual matrix.
Stabilization/Solidification contractors have developed proprietary
additives to serve as chelates or chemical precipitants. These
additives would assist in chemically binding constituents in the
final matrix. Treatability testing of the residuals would be
performed to determine the stabilizing mixture needed to pass the
toxicity testing for less than 5 mg/1 of lead. It is estimated
that stabilization would increase the residual amount by 15-2O
percent so that the volume of hotspot residuals would total
approximately 1,61O cubic yards. The quantity of hotspot wastes
after stabilization would be reduced to about 33 percent of the
original amount. After either passing the toxicity testing without
treatment or being treated to a point at which they pass the test,
the residuals would be disposed either in an offsite municipal
landfill or consolidated with the remainder of the fluff pile
onsite.
The metals contaminated soils and sediments would have to undergo
toxicity testing if they will be disposed offsite. After either
passing the test without treatment, or being stabilized to a point
at which they pass the test, the soils and/or sediments would be
disposed in an offsite municipal landfill.
The miscellaneous debris would undergo toxicity testing and, if it
passes the test, then it will be disposed in an offsite municipal
landfill. If the debris fails the test, then it will be disposed
in a RCRA landfill unit which meets minimum technology requirements
(MTRs). The small fluff pile located offsite to the south,
identified as Wl-16 on Figure 1O, is considered miscellaneous
debris. Offsite debris disposal would need to be accomplished
prior to May 8, 1992 in order to meet the requirements of the
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National Capacity Variance.
If an onsite containment remedy is selected for OU3 - the remainder
of the fluff pile - then treated/untreated (depending on the
results of toxicity testing) incinerator residuals, and untreated
sediments and soils would be consolidated onsite with the remainder
of the fluff pile rather than being disposed offsite. In this
case, it would be unnecessary to perform toxicity testing on the
soils and sediments.
With regard to target levels for the dioxin, PCB, and lead
contaminated media, the Federal standards of 2O ug/kg, 25 mg/kg,
and l,OOO mg/kg, respectively, will be used or a level as
determined by a recognized fate and transport model, whichever is
lower. A model will be run to determine soil contaminant levels
which will produce ground water concentrations at background
levels, pursuant to the Pennsylvania ARAR for ground water, 25 PA
Code Chapter 264, as more specifically delineated in the ARAR
Section below. This determination will be made during the remedial
design, and in the event that EPA and PADER do not agree on a
recognized model, then the Summers Model will be used.
If the model projects contaminant concentrations for dioxin, PCBs,
and lead which are less than the Federal standards, then the target
level will be these lower concentrations. With regard to the
phthalates, copper, zinc, and cadmium contaminants, the soil target
level will be identical to the concentration value projected by the
model, as no Federal ARAR values have been identified for these
contaminants in soil.
Excavation and removal will be accomplished with conventional heavy
construction equipment, such as backhoes, bulldozers, loaders, and
cranes. Stream sediments would be removed by hand excavation or
by using hydraulic vacuums. Although the small onsite emergent
wetland is not in the direct path of proposed excavation
activities, care would need to be taken when conducting any
construction/excavation activities near this area. Care would also
need to be exercised when excavating sediments from the
intermittent stream so as to not unnecessarily disturb surrounding
wetlands areas.
The interim ground water remedy under this alternative includes
enhanced shallow ground water collection and treatment by
installing an interceptor trench system in the overburden to the
top of bedrock which will extend from the origin of ground water
flow in the perennial section of the intermittent stream parallel
to the existing trench, both south and west of the fluff pile.
This trench system will collect approximately 1O gpm of lateral
flow from the local system and perched flow which is estimated to
average about 5-10 gpm. Thus, the overburden total is estimated
to be approximately 15-2O gpm. The interim remedy may be
incorporated into the design of the site remedy specified in the
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final action ROD.
The waste water treatment facility (WWTF) will be upgraded as
necessary in order to achieve Pennsylvania NPDES permit limits for
organics and Pennsylvania ARARs for metals in surface waters as
delineated below. The WWTF will treat collected leachate, ground
water, and scrubber waste water . Required upgrades may include,
but would not be limited to, a filtration system for metals removal
and additional pumping facilities and piping to ensure that all
runoff is being delivered to the waste water treatment facility.
The designs and specifications for the upgrade including the type
and extent of additional accessory pumps and piping apparatus will
occur during RD/RA and be refined via pilot scale testing onsite.
The equalization lagoon will be upgraded either to meet NPDES
and/or RCRA requirements, or a new lagoon will be constructed as
part of a new collection and treatment system. RCRA MTRs would
require, at a minimum, a double liner and leak detection system.
The degree of upgrade and/or whether a new lagoon is required will
be determined by EPA during RD/RA.
Additional studies on the ground water aquifer will be conducted
to better assess the practicability of deep ground water
restoration. Implementation of an effective recovery well system
in the bedrock is expected to be difficult, due to the fractured
nature of the aquifer at the site which results in anisotropic flow
conditions. Further information may be collected on the extent of
contamination, technical and cost effectiveness estimates for a
deep ground water remediation scheme, and the potential effects of
remediation on downgradient wetlands. Data generated during the
interim action will be used to determine when and where the
restoration of ground water is feasible. The interim remedy may
be incorporated into the design of the site remedy specified in the
final action ROD.
Other activities associated with this remedy include upgrading
surface water runon/runoff controls, consolidating onsite scattered
fluff with the main fluff pile, upgrading the existing site fence,
and continuing site maintenance and monitoring. Upgrading the
surface water runon/runoff controls may include deepening diversion
ditches, fortifying berms, and providing additional pumping
facilities and piping - as described with regard to the waste water
treatment facility above - to insure that all runoff is delivered
to the waste water treatment facility.
Some changes may be made to the remedy as a result of the remedial
design and construction process. Such changes, in general, reflect
modifications resulting from the engineering design process.
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ARARS
Major ARARs for the selected remedy are shown below. Because the
remedy proposed for OU2, ground water, is interim in nature, EPA
need not address all of the ARARs for OU2 at this time; the
additional ARARs will be delineated when EPA prepares the final
action ROD, per 4O C.F.R. § 30O.43O(f)(1)(ii) (C)(1).
Chemical-Specific ARARs
(a) RCRA Subtitle C, 4O C.F.R. Part 261 and PA Code, Chapter
261 for identification of characteristic hazardous wastes;
(b) the National Ambient Air Quality Standards (NAAQS) set
forth at 4O C.F.R. Part 5p;
(c) the Pennsylvania Air Pollution Control Act, Title 25, PA
Code Chapter 127;
(d) the Pennsylvania ARAR for ground water for hazardous
substances, which is that all ground water must be remediated to
background quality as specified by 25 PA Code Sections 264.90 -
264.10O, and in particular, by 25 PA Code Sections 264.97(i), (j),
and 264.100(a)(9).
(e) 4O C.F.R. Part 761.125, which requires removal of
contaminated soils to 25 mg/kg in areas of restricted public use
under the Toxic Substances and Control Act (TSCA). If fate and
transport modeling shows that a lower value is more appropriate,
that value will be used.
(f) the Pennsylvania Ambient Water Quality Criteria (AWQC)
values (PA Code 25, Chapter 93) for copper (4.O ug/1), lead (0.6
ug/1), zinc (36 ug/1), and secondary drinking water standards under
the Pennsylvania Safe Drinking Water Act (PA Code, Title 25,
Chapter 1O9) for iron (30O ug/1) and manganese (5O ug/1) in surface
water. EPA will also require compliance with the terms of the
NPDES permit for the waste water treatment facility.
Action-Specific ARARs
(g) if waste is to be conveyed off site to a landfill, then RCRA
and Department of Transportation regulations governing the
transportation of hazardous wastes, 4O C.F.R. Parts 262 and 263,
and 4O C.F.R. Parts 1O7 and 171-179, respectively;
(h) LDRs for disposal of incinerator residuals and for disposal
of sediments, soils, and debris if these are disposed offsite, as
provided in 40 C.F.R. Part 268;
(i) PA Code, Title 25, Chapter 264, subchapter o - Pennsylvania
regulations for hazardous waste incineration, expect to the extent
federal regulations provide more stringent standards;
(j) the EPA TSCA regulations for incineration of PCB materials,
4O C.F.R. § 761.7O;
(k) RCRA incineration standards set forth at 4O C.F.R.. Part
264, subpart 0;
(1) if the wastes are nonhazardous, then onsite landfilling
must comply with RCRA landfill standards, 4O C.F.R. Part 264,
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subpart N;
(m) if the wastes are fixated using a cement or pozzolan-based
process, or another similar fixation process that provides
equivalent protection, EPA will require compliance with RCRA
standards for miscellaneous treatment units, 4O C.F.R. Part 264,
subpart X, and the operation, mobilization and closure requirements
set forth at 4O C.F.R. §§ 264.60O, et sea.
(n) OSHA standards for worker's protection, 29 C.F.R. Parts
1904, 1910, and 1926;
(o) RCRA landfill standards, 40 C.F.R. Part 264, subpart N, and
PA Code Title 25, Chapters 271, 273, 275, 277, 279, 281, 283, and
285, which regulate solid waste landfills, should EPA select
offsite disposal of nonhazardous materials;
(p) RCRA requirements for fixation of ash residues, if
necessary, 4O C.F.R. Part 264, subpart X;
(q) PADER Hazardous Waste Regulations (PA Code, Title 25,
Chapters 26O-27O) for the equalization lagoon upgrades/new lagoon.
Location-Specific ARARs
(r) PA Code, Title 25, Chapter 1O2, which pertains to erosion
control requirements related to excavation activities.
(s) the National Capacity Variance for off site debris disposal,
if it is determined to be hazardous, 4O C.F.R. Part 268, Appendix
VIII (there is a RCRA land disposal restriction capacity extension
until May 8, 1992, per 55 Fed. R. 2252O);
(t) The Clean Water Act, 33 U.S.C. §§ 1251 et sea.. which
regulates activity in the vicinity of wetlands;
To Be Considered
(a) the EPA Guidance on Metals and Hydrogen Chloride Controls
for Hazardous Waste Incinerators (EPA Office of Solid Waste, August
1989) ;
(b) Lead in limited areas of site soils in excess of 1,000
mg/kg (OSWER Directive #9355.4-02) . If fate and transport modeling
shows that a lower value is more appropriate, that value will be
used.
(c) Dioxin in plastic fluff and soil exceeding 2O ug/kg.
Previous dioxin remediation by the EPA at Times Beach, Missouri has
required cleanup to the 2O ug/kg level in non-residential areas at
which future use is to be as a green area, such as a park or open
space. Although cleanup levels have varied at different sites, the
2O ug/kg level has also been used in some industrialized areas as
well. In the time since those levels were applied, EPA has changed
its methods of calculating 2,3,7,8-TCDD equivalence for the dioxin
and dibenzofuran compounds. At the EDM site, the new equivalence
value is twice that calculated using the old method. Therefore,
the number 2O ug/kg at the EDM site will provide protection
equivalent to 1O ug/kg, as applied at some other sites before the
calculation method was changed. If fate and transport modeling
shows that a lower value is more appropriate, that value will be
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used.
(d) Executive Order 11988, 4O C.F.R. § 6, Appendix A,
concerning federal wetlands policies;
ZZ. STATUTORY DETERMINATIONS
Section 121 of CERCLA requires that the selected remedy:
. be protective of human health and the environment;
..comply with ARARs;
. be cost-effective;
*
. utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and
. address whether the preference for treatment as a
principal element is satisfied.
A description of how the selected remedies satisfy each of the
above statutory requirements is provided below.
Protection of Human Health and the Environment.
The selected remedy for OU1 will be protective of human health and
the environment by reducing the principal threats posed by the
current site situation. Based on the risk assessment, the threats
posed by the site are the areas of the fluff pile contaminated with
dioxin, and fluff and soil areas contaminated with high levels of
PCBs, lead contaminated soils, copper, lead, and zinc contaminated
sediments and surface water in the intermittent stream, and TCE and
metals contaminated leachate from the intermittent stream bank
seeps.
The incineration, stabilization, disposal, and upgrade actions of
the selected remedy would provide protection of human health and
the environment by eliminating, reducing, and controlling risk
through treatment and engineering controls. Exposure to the
principal threats at the site and all other contaminated solid
media would be eliminated. Incineration would completely destroy
all organics. Residuals and soils/sediments with metals exceeding
target levels would be stabilized, if necessary, and disposed to
minimize the potential for future migration. Removal of sediment
from the intermittent stream would remove the hazard posed by metal
concentrations to aquatic life. Disposal of treated and untreated
materials will prevent contact and further reduce mobility.
Upgrading surface water runon/runoff controls would decrease
contaminant migration via fluff and contaminant transport to the
ground water and surface water.
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Exposure levels will be reduced to within or below the 1E-O4 to
1E-O6 acceptable risk range and the hazard indices for non-
carcinogens will be reduced to less than one. Implementation of
the selected remedy will not pose unacceptable short-term risks or
cross-media impacts to the site, the workers, or the community.
While there are risks associated with lead volatilization during
incineration, these risks would be reduced to acceptable levels
through the use of specialized air pollution control equipment.
Since metals are not destroyed through incineration, there will be
some long-term risks associated with the metals (predominately
lead) .contamination, however, the inorganic contaminated residuals
will be treated prior to disposal if they fail toxicity testing to
reduce the mobility of the metals. Soils and sediments will be
treated if necessary. Treated and untreated materials will be
placed into either an offsite landfill or consolidated onsite with
the remainder of the fluff pile if an onsite containment remedy is
selected for that OU (OU3) for proper long-term management.
Miscellaneous debris will be disposed offsite.
The selected remedy for OU2 reduces risk by initiating further
shallow ground water cleanup and reducing the potential for
degradation while additional ground water analysis is being
conducted. Since OU2 is an interim remedy, further discussion of
compliance with the statutory requirement of overall protection
will be addressed at the time of the final remedy selection.
Compliance with ARARs.
All applicable or relevant and appropriate requirements (ARARs)
pertaining to the selected remedy will be attained. Because the
remedy proposed for OU2, ground water, is interim in nature, EPA
need not address all of the ARARs for OU2 at this time; the
additional ARARs will be delineated when EPA prepares the final
action ROD, per 4O C.F.R. § 30O.43O(f)(1)(ii) (C)(1).
Chemical-Specific ARARs
(a) RCRA Subtitle C, 4O C.F.R. Part 261 and PA Code, Chapter
261 for identification of characteristic hazardous wastes;
(b) the National Ambient Air Quality Standards (NAAQS) set
forth at 4O C.F.R. Part 50;
(c) the Pennsylvania Air Pollution Control Act, Title 25, PA
Code Chapter 127;
(d) the Pennsylvania ARAR for ground water for hazardous
substances, which is that all ground water must be remediated to
background quality as specified by 25 PA Code Sections 264.90 -
264.1OO, and in particular, by 25 PA Code Sections 264.97(i), (j),
and 264.100(a)(9);
(e) 4O C.F.R. Part 761.125, which requires removal of
contaminated soils to 25 mg/kg in areas of restricted public use
under the Toxic Substances and Control Act (TSCA) . If fate and
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transport modeling shows that a lower value is more appropriate,
that value will be used;
(f) the Pennsylvania Ambient Water Quality Criteria (AWQC)
values (PA Code 25, Chapter 93) for copper (4.O ug/1), lead (O.6
ug/1) , zinc (36 ug/1) , and secondary drinking water standards under
the Pennsylvania Safe Drinking Water Act (PA Code, Title 25,
Chapter 109) for iron (3OO ug/1) and manganese (5O ug/1) in surface
water. EPA will also require compliance with the terms of the
NPDES permit for the waste water treatment facility;
Action-Specific ARARs
(g) if waste is to be conveyed off site to a landfill, then RCRA
and Department of Transportation regulations governing the
transportation of hazardous wastes, 4O C.F.R. Parts 262 and 263,
and 4O C.F.R. Parts 1O7 and 171-179, respectively;
(h) LDRs for disposal of incinerator residuals and for disposal
of sediments, soils, and debris if these are disposed offsite, as
provided in 40 C.F.R. Part 268;
(i) PA Code, Title 25, Chapter 264, subchapter O - Pennsylvania
regulations for hazardous waste incineration, except to the extent
federal regulations provide more stringent standards;
(j) the EPA TSCA regulations for incineration of PCB materials,
40 C.F.R. § 761.70;
(k) RCRA incineration standards set forth at 4O C.F.R. Part
264, subpart O;
(1) if the wastes are nonhazardous, then onsite landfilling
must comply with RCRA landfill standards, 4O C.F.R. Part 264,
subpart N;
(m) if the wastes are fixated using a cement or pozzolan-based
process, or another similar fixation process that provides
equivalent protection, EPA will require compliance with RCRA
standards for miscellaneous treatment units, 4O C.F.R. Part 264,
subpart X, and the operation, mobilization and closure requirements
set forth at 4O C.F.R. §§ 264.6OO, et sea.;
(n) OSHA standards for worker's protection, 29 C.F.R. Parts
1904, 1910, and 1926;
(o) RCRA landfill standards, 40 C.F.R. Part 264, subpart N, and
PA Code Title 25, Chapters 271, 273, 275, 277, 279, 281, 283, and
285, which regulate solid waste landfills, should EPA select
offsite disposal of nonhazardous materials;
(p) RCRA requirements for fixation of ash residues, if
necessary, 4O C.F.R. Part 264, subpart X;
(q) PADER Hazardous Waste Regulations (PA Code, Title 25,
Chapters 26O-270) for the equalization lagoon upgrades/new lagoon;
Location-Specific ARARs
(r) PA Code, Title 25, Chapter 1O2, which pertains to erosion
control requirements related to excavation activities;
(s) the National Capacity Variance for off site debris disposal,
if it is determined to be hazardous, 4O C.F.R. Part 268, Appendix
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VIII (there is a RCRA land disposal restriction capacity extension
until May 8, 1992, per 55 Fed. R. 2252O);
(t) The Clean Water Act, 33 U.S.C. §§ 1251 et sea. . which
regulates activity in the vicinity of wetlands;
To Be Considered
(a) the EPA Guidance on Metals and Hydrogen Chloride Controls
for Hazardous Waste Incinerators (EPA Office of Solid Waste, August
1989) ;
(b) Lead in limited areas of site soils in excess of 1,OOO
mg/kg-(OSWER Directive #9355.4-02) . If fate and transport modeling
shows that a lower value is more appropriate, that value will be
used;
(c) Dioxin in plastic fluff and soil exceeding 2O ug/kg.
Previous dioxin remediation by the EPA at Times Beach, Missouri has
required cleanup to the 2O ug/kg level in non-residential areas at
which future use is to be as a green area, such as a park or open
space. Although cleanup levels have varied at different sites, the
2O ug/kg level has also been used in some industrialized areas as
well. In the time since those levels were applied, EPA has changed
its methods of calculating 2,3,7,8-TCDD equivalence for the dioxin
and dibenzofuran compounds. At the EDM site, the new equivalence
value is twice that calculated using the old method. Therefore,
the number 2O ug/kg at the EDM site will provide protection
equivalent to 1O ug/kg, as applied at some other sites before the
calculation method was changed. If fate and transport modeling
shows that a lower value is more appropriate, that value will be
used;
(d) Executive Order 11988, 40 C.F.R. § 6, Appendix A,
concerning federal wetlands policies;
Cost-Effectiveness.
The estimated present worth cost for the selected remedy is
$ 12,429,OOO. The remedy is cost-effective in mitigating the risks
posed by the principal threats at the site in a reasonable period
of time and meets all other requirements of CERCLA. Organic
contaminants present in OU1 media will be destroyed and inorganic
contaminants will be treated if necessary to reduce toxicity and
mobility, and the treated and untreated nonhazardous wastes will
be disposed in an appropriate landfill or consolidated onsite;
therefore, the selected remedy affords a high degree of long-term
effectiveness and permanence. Although Alternatives 1, 2, and 3
can be implemented at lower costs, these alternatives are not as
effective in protecting human health and the environment.
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Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable.
The selected remedy for OU1 utilizes permanent solutions and
treatment technologies to the maximum extent practicable while
providing the best balance among the other evaluation criteria.
Of all alternatives evaluated, the selected remedy provides the
best balance in terms of long-term effectiveness and permanence,
short-term effectiveness, cost, implementability, and state and
community acceptance. Since OU2 is an interim remedy, the
utilization of permanent solutions and alternative treatment
technologies to the maximum extent practicable will be addressed
at the time of the final remedy selection for that OU.
The major tradeoffs that provide the basis for the selection
decision are overall protection, implementability, and cost.
Because of the uncertainties regarding technical and cost
effectiveness, implementability, and additional benefits vs. costs
derived from Alternative 5, the selected remedy (Alternative 4) is
more appropriate. This is particularly so in light of the
potential harm that could befall the nearby wetlands should EPA
require pumping and treating of deep ground water, as
aforementioned. Alternative 4 provides treatment to the maximum
extent practicable for OU1 media and initiates treatment for the
shallow ground water component of OU2. This reduces risk and the
potential for further degradation in the ground water system, while
allowing additional study on the practicability of deep ground
water restoration. Alternatives 1, 2, and 3 do not meet all of
the remedial objectives for the site and, therefore, do not
thoroughly address overall protection of human health and the
environment.
Preference for Treatment as a Principal Element.
The selected remedy uses treatment to address the principal threats
at the site posed by OU1. Treatment is employed through
incineration of the hotspot areas of the fluff and soils which
present the principal threats at the site and stabilizing the
residuals if they fail toxicity testing. Treatment is also
employed in stabilizing the metals contaminated sediments and soils
which fail toxicity testing, if being disposed offsite.
Treatment is initiated for OU2 through additional shallow ground
water collection and treatment which will reduce risk and the
potential for further degradation. Further discussion on the
preference for treatment for OU2 will be presented in the final
action ROD for OU2.
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Z. EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan identifying EPA's preferred alternative for the
Eastern Diversified Metals Site was released for comment in
February, 1991. The selected remedy described in this ROD differs
from the remedy in the Proposed Plan with regard to the following:
1) The EP Toxicity test or another appropriate toxicity test
such as the Toxicity Characteristic Leaching Procedure (TCLP) will
be used to determine whether the incinerator residuals, sediments,
soils (if offsite disposal is selected for the sediments and
soils), and miscellaneous debris are characteristic hazardous
wastes". The EP Toxicity test may be used in certain circumstances
under the RCRA exemption for lead and arsenic wastes as stated in
55 Fed.R. 3868, Section P. Appropriate tests for each media will
be determined during RD/RA.
2) The miscellaneous debris will not be stabilized, even if it
fails toxicity testing. Stabilizing the debris would require, in
many cases, increasing the risk to human health and the environment
by grinding whole wire and cable into small pieces which would make
hazardous constituents, including lead and particulates, more
mobile and bioavailable, as well as potentially increasing volume.
If the debris fails toxicity testing, it will be disposed in a
landfill which complies with all applicable and appropriate RCRA
requirements, as delineated in the ARAR sections of this ROD.
3) The sediments and soils will not be treated if they are to
be consolidated with the remainder of the fluff pile (OU3) onsite.
Contaminant concentrations in sediments and soils are less than in
the fluff material; consequently, there is no benefit to treating
these media before consolidation with the rest of the OU3 media.
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