. Office of
Environmental Protection Emergency and
Agency Remedial Response
• EPA/ROD/R03-92/154
September 1992
SEPA Superfund
Record of Decision
C & D Recycling, PA
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.
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-i 01
.REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-92/154
3. Recipients Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
C&D Recycling, PA
First Remedial Action - Final
S. Report Date
09/30/92
7. Authors)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Projectnack/WorkUnrtNo.
11. Contrsct(C)orGrant(G)No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type of Report* Period Covered
800/000
14.
15. Supplementary Notes
PB93-963905
16. Abstract (Limit 200 words)
The 110-acre C&D Recycling site is a former metals recycling facility located along
Brickyard Road in Foster Township, Luzerne County, Pennsylvania. Land use in the area
is predominantly agricultural and residential, with fields and wooded areas to the
west and north of the site and a residential development located northeast of the
site. Mill Hopper Creek, a small stream, is located on the property and flows into a
man-made pond to the south of the site. Ground water underlying the property is used
for drinking water purposes. From 1963 to 1978, Lurgan Corporation operated a metals
reclamation business, which recovered copper and/or lead from cable or scrap metal
transported to the site. Five onsite furnaces were used to burn and process the
cable, and these activities resulted in extensive contamination of the surrounding
soil and sediment. Based on site documentation and reports by local residents,
burning also took place in onsite pits. Lurgan Corporation drawings indicate that
water used in the metals processing area was collected in a trench drain and directed
to a leach pit (dry well). In 1979, the business was conveyed to C&D Recycling, who
continued to operate the facility until 1984, when operations ceased. In 1984, the
state collected soil and ash samples, which identified elevated levels of both lead
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - C&D Recycling, PA
First Remedial Action - Final
Contaminated Media: soil, sediment, debris
Key Contaminants: Organics (PAHs, PCBs), metals (arsenic, chromium, lead)
b. loentrfiers/Open-Ended Terms
c. COSATI Reid/Group
. Availability Statement
f
19. Security Class (This Report)
None
20. Security Class (TMs Page)
None
21. No. of Pages
86
22. Price
(See ANS1-Z39.18)
See instruction* on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Devilment of Commerce
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EPA/ROD/R03-92/154
C&D Recycling, PA
First Remedial Action - Final
bstract (Continued)
and copper. In 1985, the -state and C&D Recycling arranged for the excavation and off site
recycling of 134,200 pounds of lead-contaminated ash and soil at a lead refining center.
In 1987, EPA required AT&T Nassau Metals Corporation, a potentially responsible party, to
consolidate and cover piles of ash onsite and to construct sedimentation and erosion
controls to minimize soil migration from the site in surface water runoff. Two
underground storage tanks were also removed, decontaminated, and disposed. This ROD
addresses a final remedy for the onsite contaminated soil, sediment, and debris. The
primary contaminants of concern affecting the soil, sediment, and debris are organics,
including PAHs and PCBs; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating and stabilizing
20,565 cubic yards of contaminated soil and sediment with lead levels over 500 mg/kg,
along with the onsite ash, with disposal in an offsite landfill; decontaminating and/or
demolishing contaminated buildings and structures; post-excavation/removal sampling to
confirm that clean-up levels are met; removing any casings and wire for offsite disposal
or recycling; monitoring air, ground water, and surface water; abandoning wells that
serve no useful long-term purpose; and implementing institutional controls to prevent use
of those buildings and structures onsite constructed prior to 1963, as well as underlying
soil, which demonstrates levels of lead contamination higher than 500 mg/kg. If, within
180 days of the issuance of this ROD, EPA receives information that indicates an onsite
containment cell may be designed and constructed, then the stabilized and decontaminated
materials may be disposed of onsite. The estimated present worth cost for this remedial
action is $11,985,717, which includes an annual O&M cost of $25,390.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil excavation goals and debris
decontamination goals are based on health-risk levels and include lead 500 mg/kg; copper
3,300 mg/kg; antimony 35 mg/kg; PAHs 1 mg/kg; and PCBs 2 mg/kg. Excavation goals for
sediment include lead 500 mg/kg; copper 2,900 mg/kg; antimony 35 mg/kg; and PAHs at
1 mg/kg. All soil, sediment, and ash will be stabilized to below RCRA TCLP levels prior
to disposal. Building surfaces will be decontaminated to the following levels: lead
50 ug/m3; copper 1,000 ug/m3; and antimony 500 ug/m3.
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Table of contents
for the
Decision Summary
SECTION PAGE
LIST OF FIGURES ii
LIST OF TABLES ii
I. SITE NAME, LOCATION, AND DESCRIPTION .... 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY ... 3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ... 6
IV. SCOPE AND ROLE 7
V. SUMMARY OF SITE CHARACTERISTICS 10
VI. SUMMARY OF SITE RISKS 27
VII. ALTERNATIVES 41
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES .... 53
IX. SELECTED REMEDY 61
X. STATUTORY DETERMINATIONS 67
XI. DOCUMENTATION OF SIGNIFICANT DIFFERENCES .. 72
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - ADMINISTRATIVE RECORD INDEX
APPENDIX C - CPFs, RfdS, AND RISK ASSESSMENT INFORMATION
APPENDIX D - RISK CHARACTERIZATION TABLES
APPENDIX E - DETAILED COSTS FOR SELECTED REMEDY
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STATUTORY DETERMINATIONS
This action is protective of human health and the environment
and complies with Federal and State requirements applicable or
relevant and appropriate to this action. In addition, this
action is cost-effective. It employs permanent solutions and
alternative treatment technologies to the maximum extent
practicable and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element.
Because this remedy may result in levels of hazardous substances,
pollutants or contaminants remaining on-Site above levels that
allow for unlimited use and unrestricted exposure, a review will
be conducted in accordance with Section 121(c) of CERCLA, 42
U.S.C. § 9621(c) and the NCP 40 C.P.R. § 300.430(f)(4)(ii) within
5 years after commencement of the Remedial Action to ensure that
the remedy continues to provide adequate protection of human
health and the environment.
son Date
'Regional Administrator
Region III
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List of Figures
1 CiD Recycling Site Location (depicting property boundary)
2 Area of Contamination Requiring Remediation
3 Tax Parcel Map
4 Topographic and Physical Features
5 Primary Features Associated with Site Operations
List of Tables
1 Site Specific Remedial Objectives
2 Selected Inorganic Analytical Results of Air Samples
3 Selected Inorganic Analytical Results of Ash Samples
4 Lead Analytical Results of Ash Samples (EP Toxic and TCLP)
5 Selected Inorganic Analytical Results of Soil Samples
6 Summary of Organic Contamination in Soils
7 Lead Analytical Results of Soil Samples (EP Toxic and TCLP)
8 Selected Inorganic Analytical Results of Surface Water
9 Selected Inorganic Analytical Results of Sediment Samples
10 Selected Inorganic Analytical Results of Drainage System
11 summary of Ground Water Analytical Data for Lead
12A Summary of Monitoring Well Lead Data
12B Monitoring Well Data from Reconstructed Wells (June 1989)
13 summary of Residential Well Lead Data
14 Contaminants of Potential Concern
15 Contaminants Resulting in Excess Cancer Risk Greater than
1x10*6 and/or Non-Cancer Risks with a Hazard Index > 1
16 Toxicity Equivalence Factors
17 Summary of Remedial Alternatives
18 Additional Costs Associated with Soil Cleanup to 500 ppm
19 Remedial Alternative Costs
20 Cleanup Levels
ii
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Z. Site Haae, Location, and Description
The C&D Recycling Site (C&O Site or Site) is located along
Brickyard Road in Foster Township, Luzerne County, Pennsylvania
(see Figure 1). The extent of soil contaminated with lead at the
Site is depicted on Figure 2.
The Site is located primarily on three parcels of land (Tax
Parcels 11, 11A, and 11B), totalling approximately 110 acres (see
Figure 1 and Figure 3), once owned by the Lurgan Corporation.
Prior to and apparently during ownership by the Lurgan
Corporation, portions of Parcels 11 and 11B were operated as a
dairy farm by the Sheaman family. Lurgan Corporation began metal
reclamation operations on Parcel 11, which totals approximately
45 acres including the small enclosed Parcel 11B, in 1963
although the land was not purchased by Lurgan Corporation until
1966. All Site operations occurred on Parcels 11 or 11B. The
area of soil and sediment contamination extends onto adjacent
properties (see Figure 2).
Parcel 11 is currently owned by C&O Recycling, Inc. and contains
the majority of the soil contaminated by Site operations as well
as all of the contaminated ash. A small parcel of land (11B),
which is also contaminated, is owned by the estate of Mrs. Jane
Gibson, includes an artesian well, and lies entirely within
Parcel 11. Horizons Unlimited, Inc., owns Parcel 11A, which is
an undeveloped parcel, but contains the majority of the sediment
contaminated by Site operations (Mill Hopper Pond is located on
Parcel 11A).
From southwest to northeast, the elevation of the Site decreases
(from elevation 1680 ft.) to a low area (between elevation 1630
ft. and 1650 ft.) located within an area of shale rock extraction
and a small creek, and then increases again (to elevation 1770
ft.) towards a regional topographic high point immediately
northeast of the C&D Recycling, Inc. property. A small
intermittent stream, named Mill Hopper Creek, begins in an area
of ground water seeps located near the remains of the dairy farm
structures at the Site and flows into an area from which rock was
excavated (and now acts as a man made pond) located immediately
south of the C&D Recycling, Inc. property. An artesian well,
located in an area of high ground water table, frequently
overflows into the creek bed. The pond frequently overflows an
earthen embankment at its southern limit into Mill Hopper Creek.
The topographic and physical features of the Site are depicted on
Figure 4.
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\
Noc«: Larg.r Arta Represancs Prop«rty Ovn«d By Lurgan Corpu
C&D sic* Location (Detail of White Haven,
Pennsylvania, 7.5 Minute Quadrangle, USGS
1947, Photorevised 1980)
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it.oor t»
IF. tfl t'
/*«•!••« #*•"• *"
ftiiun
OH sut 3' ofrt« *u*(r**r):
/V. r Jrflt **•*
SOIL «n*4a ANU WANTIIIES DKFIHfD
BY SCO ppm LfAD ISOCONCENTRATION UN
C * D RSCYCUNC SITS
LU2SKNS COUNTY. PA
ATJtT NASSAU METALS
ERM-Norlheast
P1CUKL 2 - Arc-u ol Soil Lead Cuntaminai ion
Kui|u iring Komudiiil ion
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requirements of Pennsylvania's residual waste management
regulation*, provide a remedial alternative equally or more
protective of human health and the environment, and be cost
effective, the stabilized and decontaminated material may be
disposed on-Site.
The major components of the selected remedy include:
1 - Confirmation, e.g., via sampling, of the areal limits of
soil and sediment with lead contamination above 500 parts
per million (ppm)(including soil beneath buildings and
concrete slabs constructed after 1963 as well as pavement
and sediment in Mill Hopper Creek and wetlands);
2 - Conduct of a Phase IB archeological survey in areas
possessing high or moderate archeological sensitivity
potentially impacted by the Remedial Action;
3 - Removal and off-Site disposal and/or recycling of
casing and wire;
4 - Excavation of all soil with lead contamination above 500
ppm resulting from Site operations (excluding soil beneath
buildings and concrete slabs constructed after 1963, or
pavement, which shall otherwise be maintained to prevent
migration of contamination from the Site);
5 - Excavation of sediment from the banks of Mill Hopper
Pond with lead levels greater than 500 pp« and excavation of
the top two feat of sediment (or an amount sufficient to
secure a new substrate) from the pond bottom to ensure that
pond water quality is not impacted.
6 - Removal of sediment within Mill Hopper Creek
contaminated with lead above 500 ppm;
7 - Removal and sampling of all sediment located within the
storm water sewer system located at the Site and evaluation
of the system's integrity (including drainage ditches) to
determine the potential for releases of hazardous substances
from the Site into the soil and ground water and any
necessary response actions;
8 - Excavation of all ash located at the Site;
9 - Post excavation/removal sampling to confirm that ash,
soil, and sediment cleanup levels are met;
10 - On-Site stabilization of the contaminated soil and
sediment, excavated and removed as described above, to
remove any characteristic of hazardous waste;
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.:. - On-Site stabilization of the contaminated ash,
excavated as described above to remove any characteristic of
ic zardous waste;
12 - Off-Site disposal of stabilized soil, sediment, and ash
into a non-hazardous (RCRA Subtitle D) waste disposal
facility;
13 - Decontamination of Site buildings with lead levels
above 500 ppm, including dismantling of non-structural
components and removal of equipment and debris which may
inhibit decontamination to required levels, or demolition of
buildings that can not be cleaned to 500 ppm lead;
14 - Dismantling of the old furnace (and other structures,
as necessary, which inhibit soil or sediment remediation and
which shall not be maintained, as necessary, to prevent
migration of contaminants from the Site);
15 - Off-Site disposal of material generated from
dismantling of Site buildings into a non-hazardous (Subtitle
D) waste disposal facility (or decontamination and recycling
of dismantled material);
16 - Performance of biota toxicity tests on remaining
soil/sediment to ensure that remediated soil (i.e., soil
with lead levels no higher than 500 ppm) does not pose a
threat to the environment (procedures to be determined
during remedial design);
17 - sitefgrading, revegetation, and related work, to ensure
that Site.topography and drainageways adequately convey
water from the Site and that soil excavation does not result
in low lying areas;
18 - Air monitoring during on-Site activity and
implementation of dust control or other necessary abatement
actions to prevent migration of contaminants to the
surrounding, community during the Remedial Action;
19 - Abandoning veils which serve no useful long-term
purpose;
20 - Periodic monitoring of ground water and surface water;
and
21 - If the soil beneath buildings and concrete slabs
constructed after 1963, or pavement is greater than 500 ppm
and these structures are not demolished institutional
controls, e.g., deed restrictions to prevent residential use
potentially affecting the protectiveness of the remedy, and
to ensure .that Site contaminants which may remain beneath
buildings and pavement are known.
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RECORD OF DECISION
C&D Recycling Site
Foster Township, Luzerne County
Pennsylvania
PART I - Declaration
PART II - Decision Stannary
PART III - Appendices
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DECLARATION FOR THE RECORD QP PECTS^Qfl
SITE NAME AND LOCATION
C&D Recycling Site
Foster Township, Luzerne County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the final selected
remedial action for the C&D Recycling Site (Site) in Foster
Township, Luzerne County, Pennsylvania, chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA or Superfund), 42
U.S.C. SS 9601 et. ssg., as amended, and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300.
This decision document explains the factual and legal bases for
selecting the remedial action for the Site and is based on the
Administrative Record for the Site.
The Commonwealth of Pennsylvania (Commonwealth) has participated
in the development of remedial alternatives and has provided
comments on the Proposed Plan in accordance with the NCP, 40
C.F.R. S 300.515(e).
The Commonwealth has not indicated that it concurs with the U.S.
Environmental Protection Agency's (EPA) selected remedial
alternative as set forth in this Record of Decision.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. S 9606, that actual
or threatened releases of hazardous substances from this Site, as
discussed in Section VI ("Summary of Site Risks") of this ROD, if
not addressed by implementing the response actions selected in
this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected remedy addresses contaminated ash, soil, sediment,
buildings and structures. The selected remedy includes
decontamination and/or demolition of contaminated buildings and
structures; stabilization of contaminated soil, ash, and
sediment, as needed; and; disposal of the stabilized and/or
decontaminated material into an off-Site landfill. However, if
within 180 days of the issuance of this ROD, EPA receives
information that indicates that an on-Site containment cell can
be designed and located to comply with the substantive
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NEW FRANKLIN
/5/ TRINKLIN COAL MINING CO.
— Figure 3 - Tax Parcel Map
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CMIWH round»Uoa oi
Fwm •y»a«> oi
Fiyurc; 'i - Toj>o«ra|>hic and I'hysicai
at ihu CM) SlLu
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The Site includes a farmhouse, barn, milkhouse, and several
outbuildings used when the property was a dairy farm; a main
facility building including four furnaces used to burn cable; and
a small isolated furnace also used to burn cable. The Site's
primary features associated with Site operations are depicted in
Figure 5.
The Site is underlain by shale and sandstone of the Mauch Chunk
Formation and a relatively thin layer of soil. The ground water
exists entirely within the Mauch Chunk Formation. Shallow ground
water generally flows within fractures in a southerly direction
towards a local discharge area near Mill Hopper Creek and Kill
Hopper Pond. The shallow ground-water system is interconnected,
via fractures, with a deeper regional ground-water system. Since
the aquifer is used for drinking water purposes, it is a Class II
aquifer according to EPA's Ground Water Classification system.
The area of contamination includes approximately 26,273 cubic
yards (yds3) of soil contaminated with lead, copper, antimony
and/or other contaminants (including low levels of polynuclear
aromatic hydrocarbons, or PAHs, e.g., benzo(a)pyrene); several
small piles of ash (approximately 165 yds3) resulting from the
burning of material at the Site contaminated with lead, copper,
and low levels of dioxins and furans; approximately 1200 linear
feet of Mill Hopper Creek containing sediment contaminated with
lead, copper, and zinc; a 0.5-acre pond (Mill Hopper Pond) with
contaminated sediment (approximately 1900 yds3); a barn and
milkhouse used when the property at the Site was a dairy farm; a
main facility building including four furnaces used to burn
cable; an underground storm water sewer system, including catch
basins, trench drains, a leach pit (drywellj, and associated
piping, which contains approximately 24 yds3 of contaminated
sediment; and a small isolated furnace once used to burn cable.
The calculated volume of contaminated soil includes soil with
lead levels greater than 500 ppm as determined during the
Remedial Investigation.
The property once owned by Lurgan Corporation (Parcels 11, 11A,
and 11B) is zoned as a C-l Conservation District in accordance
with "The Foster Township Zoning Ordinance of 1986*. This zoning
classification (C-l) is intended to protect areas which have
environmentally sensitive characteristics, e.g., mountainous
areas, aquifer recharge or discharge areas, or land whose soils
composition has been classified as hazardous, from inappropriate
or untimely development. Prior to 1986 and since 1967, the
Lurgan Corporation property was zoned for agricultural use.
The surrounding land use is agricultural and residential. A
large undeveloped, agriculturally-zoned field exists immediately
west of the Site. A wooded area which is also zoned agricultural
is located immediately north of the Site. Residentially-zoned
property/ including a densely populated "second home/retirement"
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Top of coainq 1692.*S;
I690.J9
SCALE
I
100
200
300 FEET
PRIMARY FEATURES ASSOCIATED
WITH SITE OPERATIONS
MAMASMMlf
SMALL COVtMEO ASM ffLC
FIGURE 5
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community is located northeast of the Site. A large area of
undeveloped land (Parcel 11A) is located south of the Site. The
nearest occupied dwelling is located approximately 1/8 mile
southwest from the main facility building at the Site and
approximately 275 feet from the C&D Recycling, Inc. property line
(see Figure 4). Occupied residences are also approximately 1/4
mile from the Site in every direction, except south. Abandoned
anthracite coal mines exist approximately 1/2 mile north and
south of the Site (see Figure l). The Site is only occupied by
security guards. The deed for Parcel 11 is restricted to prevent
residential and agricultural use.
IX. site History and Enforcement Activity
From 1963 to 1978, the Lurgan Corporation operated a metal
reclamation facility at the Site. In 1979, the business was
conveyed to C&D Recycling, Inc. Both Lurgan Corporation and C&D
Recycling, Inc. operations involved the reclamation of metals,
i.e., copper and/or lead, from cable and/or scrap metal
transported to the Site. Available documentation suggests that
lead was recovered from cable and wire until the mid 1970's when
burning of lead cable at the Site vas limited. Site operations
ceased in 1984.
Cable burning and processing and processing of other materials at
the Site caused extensive contamination of the surrounding soil
and sediment. 2n 1984, samples of soil and ash collected by
Pennsylvania Department of Environmental Resources (PADER)
indicated elevated levels of metals, e.g., lead and copper, in
ash and in soil both near to and distant from the furnaces. In
addition, FADER'S sample results indicate that the soil and ash
at the Site is a hazardous waste pursuant to the Resource
Conservation Recovery Act (RCRA)(EPA Hazardous Haste Number DOCS)
and Pennsylvania's Hazardous Waste Management regulations [25 PA
Code § 261.3] since samples of soil and ash exhibited the
characteristic 6T toxicity [25 PA Code § 261.24].
In 1984, the Northeastern Pennsylvania Vector Control Association
completed testing of blood lead levels in children residing in
Foster Township, Pennsylvania. Nineteen of 62 children tested
had levels of lead above 5 micrograms per deciliter (ug/dL) in
blood; 8 of these children had detected levels equal to or abo-ve
10 ug/dL1. None of the children suffered from blood poisoning.
Sufficient information does not exist to conclude that the
children's elevated blood lead levels result from residing near
1 EPA draft policy currently states that Superfund remedies
should protect at least 95% of children from exposure to lead
levels which would result in their blood lead levels exceeding 10
ug/dL.
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the C&D Recycling Site. Children exhibiting blood lead levels
above 10 ug/dL lived both near to and distant from the Site. The
study by the Northeastern Pennsylvania Vector Control Association
did not evaluate lead sources (e.g., paint, soil, or water) and
differences in water quality or residence location near other
sources of lead as accounting for elevated blood lead.
In April 1985, under supervision of the Pennsylvania Department
of Environmental Resources, C&O Recycling, Inc. arranged for the
excavation and off-Site disposal of 134,200 pounds of ash and
dirt contaminated with lead. The lead-bearing material was
directed to a lead refining/reprocessing center.
A Site Inspection (SI) 'was conducted by EPA in April 1985. The
analytical data collected by PADER and EPA in 1984 and 1985 was
used to evaluate the relative hazards posed by the C&D Recycling
Site in the Hazard Ranking System (HRS) . The HRS is a procedure
through which EPA calculates a score based upon the potential and
observed hazards present at a hazardous waste site. An HRS score
of 43.92 was calculated for the C&D Recycling Site in April 1985,
based primarily upon the elevated levels of contamination in the
soil and sediment suspended within the shallow dairy farm well
existing at the Site. If the final HRS score calculated for a
Site exceeds 28.5, the Site is placed on the National Priorities
List (NPL) making it eligible to receive Superfund monies for
cleanup. In September 1985, EPA proposed the Site for inclusion
on the NPL. The Site was placed on the NPL on February 21, 1990
[55 Fed. Rea. 6154]. In April 1986, PADER requested that EPA
take the lead on the Site response action.
In 1986, EPA conducted a search for potentially responsible
parties for the Site. Several owners and operators of the Site
were identified and two sources (generators) of material sent to
the Site were issued letters noticing them of their potential
liability in regards to cleanup of the Site. EPA subsequently
entered into two administrative orders on consent (Consent
Orders) with AT&T Nassau Metals Corporation, the only potentially
responsible party (PRP) cooperating with EPA, to: 1) implement
erosion controls and security measures to stabilize the Site; and
2) investigate the nature and extent of contamination and risks
at the Site and to develop alternatives to address the
contamination at the Site.
The first Consent Order, effective September 2, 1987, required
AT&T Nassau Metals Corporation, under the direction and
supervision of EPA, to consolidate and cover the piles of ash at
the Site (see Figure 5) and to construct sedimentation and
erosion controls to minimize migration of soil from the Site in
surface water runoff. In addition, fencing was installed and
areas of the Site were seeded to prevent exposure to the highly
contaminated soil areas of the Site. AT&T Nassau Metals
Corporation, in 1988, removed the piles of cable casing from the
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Site (see Figure 5) and transported them overseas for recycling.
The sedimentation and erosion controls and ash pile covers
constructed by AT&T Nassau Metals are inspected monthly by AT&T
Nassau Metals and periodically by EPA. The requirements of the
second Consent Order will be discussed in detail at the end of
this section and in Section V of the ROD.
EPA's review of documents supplied by potentially responsible
parties, documents within PADER and EPA Site files, and
information and documents supplied by the public, indicate that
the material processed at the Site consisted primarily of
telephone and similar cable. The cable typically had a plastic
or lead outer casing and an inner insulator or sheathing of
steel, aluminum, paper, or other material. Miscellaneous
telephone scrap, e.g., splice boxes, was also sent to the Site.
Processed materials contained polyvinylchloride (PVC) based upon
1974 sample results collected by PADER. Plastic samples
collected by PADER in 1984 contained no detectable traces of PVC,
but polyethylene and polyester type resins. Certain cable also
contained a "jelly"-like substance (e.g., petroleum base,
copolymer, and polyethylene) for water-proofing. According to
1979 analytical results obtained from AT&T Nassau Metals
Corporation, the processed cable contained detectable levels of
antimony, iron, lead, nickel, silver, tin, and zinc. Available
documentation and information also indicate that other types of
electrical cable, rubber-coated cable, electrical power equipment
parts, miscellaneous metal scrap, batteries, and battery lugs
were also sent to the Site by other potentially responsible
parties.
Typical Site operations involved mechanical removal of the outer
plastic casing and burning of the inner lining, sheathing or
insulation to expose the copper cable in one of five furnaces
located at the Site. The copper was returned to the generator
and the plastic casing was stockpiled at the Site. Site
documentation indicates that the operating temperature of the
furnaces was sufficient to melt lead, but not copper, i.e.,
approximately 800 degrees Fahrenheit. Thus, lead was also
recovered and returned to the generator or shipped to other
locations. Based upon available records, it appears that lead-
cased cable was no longer burned at the Site beginning in the mid
1970s, but sorted and shipped back to the generator. Eleven
samples of cable and wire collected at the Site and analyzed by
PADER in 1974 indicate detectable levels of lead only on the
soldered connections of one wire insulator. Samples of wire
collected by PADER in 1984 detected 26% lead on the "covering" of
one type of clustered wire. According to available documentation
and local residents, burning also took place within pits located
on the Site. Proposed drawings of the Lurgan Corporation
facility indicate that water used in the metals processing area
of the Site was collected in a trench drain and directed to a
leach pit, (drywell) along with stormwater from a truck bay.
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A Remedial Investigation and Feasibility study (RI/FS) was
initiated at the Site in September 1987 by AT&T Nassau Metals
Corporation pursuant to the second Consent Order. During the
RI/FS, two underground storage tanks were removed,
decontaminated, and disposed. See Figure 5 for tank locations.
Also during the RI/FS, EPA determined that contaminated sediment
was transported through a pipe located beneath Brickyard Road to
a field located west of the C&D Recycling, Inc. property. The
RI/FS for the C&D Recycling Site was completed and the final
documents were approved by EPA in March 1992.
EPA continued the search for potentially responsible parties in
1991 and 1992. Notice letters have been sent to 14 owners or
operators of the Site, and generators of material sent to the
Site.
III. Highlights of community Participation
EPA has several public participation requirements that are
defined in Sections 113(k)(2)(B), 117, and 121(f)(1)(G) of
CERCLA, 42 U.S.C. §§ 9613(k)(2)(B), 9617, and 9621(f)(1)(G).
The documents which EPA utilized to develop, evaluate, and select
a remedial alternative for the C&D Recycling Site were sent to
the information repositories, located at the Foster Township
Building and the Freeland Public Library, in January 1992.
Additional information was sent to these locations on April 17,
1992. A copy of the Administrative Record file is located in
EPA's Region III offices. The Administrative Record, required by
Section 113(k)(l) of CERCLA, 42 U.S.C. § 9613 (k)(l), is a
compilation of documents, which EPA used to support the selection
of a remedy for the C&D Recycling Site. The Administrative
Record included the RI/FS Report, the Risk Assessment Report, and
the Ecological Assessment that were developed for the site.
A Proposed Remedial Action Plan ("Proposed Plan*), which
described EPA's preferred alternative, as well as other
alternatives, for remediating contaminated ash, soil, sediment,
structures and buildings, was released to the public on April 24,
1992. The Proposed Plan and Administrative Record were also sent
to the information repository. Also on May 6, 1992, EPA
published a notice of availability of the Proposed Plan and
Administrative Record in two newspapers of general circulation;
Standard Speaker and the Times Leader.
The public was encouraged to review the Proposed Plan and
Administrative Record file and to submit comments on any remedial
alternative and EPA's preferred remedial alternative during a 30-
day comment period from April 24, 1992 to May 25, 1992. The
public was* given an additional opportunity to comment on the
Proposed Plan and Administrative Record file at a public meeting
-------
held at the Freeland Elementary School on May 8, 1992. At this
meeting, representatives from EPA answered questions and received
comments about the Site, the remedial alternatives under
consideration, and the proposed remedy. In response to a request
from the public, the public comment period was extended an
additional 30 days to provide more opportunity for review of the
Site documents. The public comment period was then closed on
June 25, 1992.
A stenographic report of the public meeting was prepared by EPA
and will be included in the Administrative Record. A response to
the comments received during the 60-day public comment period as
well as-the May 8, 1992 public meeting is included as part of
this ROD in the Responsiveness Summary (Appendix A). Community
concerns with the selected remedy are contained within Section
Viii, (Comparative Analysis of Alternatives), of this ROD and
within the Responsiveness Summary.
The index for the Administrative Record, upon which this decision
document is based, is contained within Appendix B. This decision
document is also based upon comments contained within the
stenographic report of the public meeting on May 8, 1992 and
other comments received by EPA during the entire public comment
period, which are included in the Site file maintained at EFA's
offices in Philadelphia and which will be added to the
Administrative Record.
In June 1989, a $50,000 Technical Assistance Grant (TAG) was
awarded to the Concerned Citizens of Foster Township Task Force
(CCFTTF). The TAG provides funds to obtain technical advisors to
interpret information relating to the Site and to disseminate
information to the interested public.
IV. Scope and Role of Aotioo
The RI/FS is an investigation and evaluation process which
enables EPA to select a remedy that will be protective of human
health and the environment, that will maintain protection over
time and that will minimize untreated waste [40 C.F.R. §
300.430]. The primary purpose of the Remedial Investigation (HI)
is to collect data necessary to characterize adequately the Site
for the purpose of developing and evaluating alternatives to
effectively remediate Site contamination [40 C.F.R. §
300.430(d)]. During the RI, samples of soil, sediment, ash, air,
ground water, and surface water were collected and analyzed. The
analytical results are discussed in Section V ("Summary of Site
Characteristics") of this ROD.
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The analytical results from the RI are used to determine the
magnitude of risks posed by the contaminants at the site in the
absence of any remedial action. The baseline risk assessment
(Risk Assessment or RA) is a process wherein the current and
potential threats to human health and the environment posed by
exposure to contaminants at the Site are quantified [40 C.F.R. §
300.43 d)(4)]. The potential risks posed by the Site are
discussed in Section VI ("Summary of Site Risks1*) of this ROD.
The baseline risk assessment results are used by EPA to establish
acceptable levels of exposure for use in developing remedial
alternatives in a Feasibility study (FS). In addition, the
quality and characteristics of the flora and fauna at the Site
were evaluated in an Ecological Assessment (EA) . EPA strives to
select a remedial alternative with residual contaminant exposure
levels which do not exceed EPA's acceptable risk range of 1
excess chance of contracting cancer in 10,000 (IxlO*4) to 1
excess chance of cancer in 1,000,000 (1x10"*) for known or
suspected carcinogens [40 C.F.R. § 300.430(e)(2)(i)(A)(2)].
Additionally, EPA strives to select remedial alternatives which
reduce exposure to non-carcinogens such that there is no adverse
effect, i.e., a Hazard Index (HI) less than or equal to 1.0.
A treatability study, which is a test to determine the
effectiveness of a particular remedial alternative, was conducted
in 1990 to evaluate the effectiveness of stabilization as a
remedial technology for the Site. Based upon the RI, RA, and EA,
several remedial,A alternatives are developed within the FS along
with supporting "Information to enable EPA to select a remedial
alternative which is protective of human health and the
environment and which best satisfies the goals and expectations
of the Super fund program. Section VII ("Alternatives") of this
ROD discusses the alternatives evaluated for the C&D Recycling
Site.
The response action in this ROD addresses a remedy for
contaminated ash^soil, sediment, and buildings at the Site.
Although limited areas of soil with very high lead levels exist
at the Site, the'Site contaminants, considered in whole, are
neither highly mobile nor highly toxic at the concentrations
present at the Site. Thus, the contaminated soil and sediment
and buildings are considered to be low-level threats. Isolated
occurrences of extremely high levels of lead, e.g., ash, are
considered principal threat wastes due to high toxicity.
The NCP (40 C.F.R. § 300.430(a) (1) (i)) states that the general
goal of the remedy selection process is to select remedies that:
1) are protective of human health and the environment, 2)
maintain protection over time, and 3) minimize untreated waste.
In addition, Section 121 of CERCLA, 42 U.S.C. § 9621, includes
general goals for remedial actions at all Superfund sites. The
goals include? achieving a degree of cleanup which assures
8
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protection of human health and the environment (Section
121(d)(l)), selecting coat effective remedies (Sections 121(a)
and I21(b)(l)), preference for selecting remedial actions in
which treatment that permanently and significantly reduces the
volume, toxicity, or mobility of contaminants is a principal
element (Section 121(b)), and requiring that the selected remedy
comply with or attain the level of any applicable or relevant and
appropriate requirements of federal or state environmental laws
(Section 121(d)(2)(A)).
The primary objectives of the remedy for the C&O Recycling Site,
in addition to those stated above, are to prevent potential
exposure to the contaminated media at the Site, to control and/or
prevent the migration of contamination from the Site via wind,
ground water, and surface water transport, and to reduce residual
risk to acceptable levels.
The Site-specific remedial response objectives, which take into
consideration the level of contamination and the risks posed by
the contamination, are identified in Table 1.
TABLE 1
SITE SPECIFIC REMEDIAL OBJECTIVES
FOR THE C&D SITE
1. Protection of human health and the environment.
2. Source control and prevention of migration of
contamination from the Site via wind and surface water
transport.
3. Source control of contaminants in soil such that
leaching of contamination to ground water will not
occur in the future.
4. Source control of soil, sediment, and ash with lead
concentratins greater than 500 ppm such that the Site
no longer poses an unacceptable risk.
5. Decontaminate Site buildings.
6. Prevent exposure to contaminants.
The remedy selected in this ROD addresses each of these
objectives. To the maximum extent practicable, the remedy
selected is consistent and compatible with the prior activities
completed to stabilize or clean up the Site, e.g., cable casing
removal and sedimentation and erosion controls. The remedial
action for this Site is not separated into operable units. This
is the only response action planned for this Site.
-------
v. summary of Site characteristics
The major findings of the RI and the previous investigations
relating to contamination at the Site and response actions
conducted at the Site are discussed in this section of the ROD.
This section of the ROD primarily discusses lead, copper, zinc,
and antimony contamination. These four contaminants are Site-
related and are found in the contaminated media at the Site.
Thus, the tables in this section of the ROD depict the range of
detected concentrations of each of these "selected" contaminants
(lead, copper, zinc, and antimony) for the purpose of comparing
contamination impacts between various affected media. However,
the samples of contaminated media, e.g., soil and sediment, were
analyzed for over 100 organic and inorganic constituents and
compounds. The Remedial Investigation Report and Administrative
Record contain all of this analytical data.
UNDERGROUND STORAGE TANKS
Two underground fuel storage tanks were decontaminated and
removed from the Site in 1988 (see Figure 5). The soil
surrounding the tanJcs was sampled and analyzed in June 1988. The
larger tank (10,000 gallons capacity) stored fuel for Site
operations and the smaller tank (1,000 gallons capacity)
apparently stored gasoline for farm use. Low concentrations of
Total Petroleum Hydrocarbons (TPH) , e.g., 44 and 24 ppm, were
detected in the soil excavated from around the 10,000 gallon tank
and no TPH were detected in the other excavation. The excavated
soil was backfilled into the tank excavations and clean quarry
fill was added to bring the backfill to existing grade. In
response to two separate requests from a local resident
suspecting additional tanks at the Site, two geophysical
(magnetometer) surveys were conducted in the area depicted in
Figure 5. Mo additional tanks were identified.
CASINGS
In October 1987, cable casings stockpiled at the site (see rigor*
5) were sampled prior to their removal from the Site. Each of
several types of casing found at the Site was analyzed for RCRA
hazardous waste characteristics via the Extraction Procedure (EP)
Toxicity test. Lead and barium leached from all cable casing,
but at levels less than those established for RCRA characteristic
of toxicity [25 PA Code 261.24]. Low levels of cyanide and/or
mercury also leached from -two types of cable casings. However,
the cable is not classified as a RCRA hazardous waste. The cable
casings which were not in contact with contaminated soil were
removed from the Site in 1988 and shipped overseas for recycling.
10
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AIR
During on-Site activity associated with construction of the Site
erosion control system in 1987, the air was sampled to determine
if vehicles moving on the Site resulted in elevated contaminant
levels. Air was sampled again in 1988 during rock coring
activity. Selected inorganic analytical data from these sampling
events is presented in TABLE 2. Complete analytical results are
contained within the Remedial Investigation Report and the
Administrative Record. The data indicate that implementation of
a remedial action at the Site may cause elevated levels of
airborne contaminants.
TABLE 2
SELECTED INORGANIC ANALYTICAL RESULTS OF AIR SAMPLES
(results in ug/m3)
LEAD NO2- .03920
COPPER ND
ZINC .00307 - .00713
ANTIMONY ND
ASH
Ash, resulting primarily from the combustion of cable components
in the furnaces at the Site, is located in several piles at the
Site (see figure 5). According to analytical results, ash
samples contain elevated levels of inorganic constituents, e.g.,
lead and copper, low levels of semivolatile compounds, e.g.,
PAHs, and very low levels of chlorinated dibenzo-p-dioxins
(dioxin) and chlorinated dibenzo-p-furans (furan). Analytical
data from ash samples collected at the Site are depicted in Tafeli
3. An additional sample collected during the RI indicated that
the ash contains 7.5% lead by weight and 4.6% copper by weight.
ND = Not Detected.
•/
11
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Ash samples were also analyzed pursuant to the EP Toxicity test
or the Toxicity Characteristic Leaching Procedure (TCLP) to
determine if the ash would exhibit the characteristic of toxicity
as defined by 25 PA Code § 261.24. The results of the EP
Toxicity test and TCLP test analyses are depicted in Table 4 and
indicate that the ash exhibits the characteristic of toxicity
since the levels of lead in the extract exceed 5 mg/L (EPA
Hazardous Waste Number 0008). Complete analytical results are
contained within the Remedial Investigation Report and the
Administrative Record.
TABLE 3 :
SELECTED INORGANIC ANALYTICAL RESULTS OF ASH SAMPLES
(results in ppm)
SAMPLE LEAD COPPER ZINC ANTIMONY
PADER-843 706,666 80,169 8,362 NA
PADER-84 716,028 32,507 1,856 NA
PADER-84 606,507 105,655 7,058 NA
RI (90)4 22,000 4,900 NA 20
3 PADER-84 samples include samples f 2206 042, 047, and 051
collected by PADER in September 1984. According to the
sample location map, these samples are located in areas of
significant ash accumulation and are likely to be
representative of the ash. However, the sample sheets
identify all samples collected from the Site on September
13, 1984 as "soil" samples.
4 This sample was collected by McLaren Hart in December
1990 and analyzed by Kiber Associates, Inc., for the
stabilization Treatability study.
12
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TABLE 4
LEAD ANALYTICAL RESULTS OF ASH SAMPLES
(EP Toxicity and TCLP test analysis)
(results in ppm)
SAMPLE LEAD
PADER May 84117
PADER Sept. 84 9,117
PADER Sept. 84 10,727
PADER Sept. 84 8,372
RI (88)5
RI (90)6 458
In July and November 1989, the ash van sampled and analyzed for
dioxin and furan compounds. The analytical results indicate that
the ash contains approximately 1.5 ppb of dioxin and furan
measured as a toxicity equivalence factor equivalent to 2,3,7,8 -
tetrachloro dibenzo-p-dioxin (TCDD). TCDD is the most toxic
dioxin isomer. The potential toxicity of a mixture of dioxins
and furans was evaluated relative to the equivalent toxicity of
TCDD in accordance with EPA guidelines (EPA/625/3-89/016).
SOIL
Soil at the Site contains high concentrations of several
inorganic constituents, e.g., lead, copper, zinc, and antimony,
and low concentrations of semivolatile organic chemicals, e.g.,
polychlorinated biphenyls (PCBs) and PAHs. Although the majority
of the soil contamination is located within the upper portion of
the soil column, i.e., upper 1 to 6 inches of the soil, elevated
levels of lead were identified at deeper levels, e.g., 1 foot, in
some areas.
Initially, samples were collected by PADER and/or EPA between
1984 and 1987 in areas suspected of contamination by Site
operations. In 1988, a 100-foot-interval sampling grid was
established at the Site and samples were collected at the
5 This sample was collected in 1988. The results indicate
that the sample did not exceed EP Toxicity limits.
6 This sample was analyzed pursuant to the TCLP. Other
samples were analyzed by EP Toxicity.
13
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intersection of grid lines (nodes) in June 1988 as part of the
RI. Additional samples were collected in areas located beyond
the C&D Recycling, Inc. property in transects oriented along the
suspected directions of wind-entrained soil migration. EPA
collected split samples during the June 1988 soil sampling
activity. After the data was evaluated by EPA, additional
samples were collected in July 1989 to better define the limits
of the contamination. Additional samples were collected in
October 1989 to further define potentially impacted areas. The
majority of the samples were collected from the 0-6" interval of
soil although some of the 1989 samples were collected at depths
up to 3 feet into the soil column.
Samples of soil from residential gardens near the Site and from
vegetables grown in a garden near the Site were collected by
PADER and/or local residents in 1985. The results do not
indicate that the concentrations of lead in garden vegetables are
elevated based upon a comparison to literature values and an
evaluation of the results of lead in the garden soil.
Additionally, the levels of Site-related constituents, e.g.,
lead, detected in the garden soil did not indicate contamination
from the Site.
In November 1991, EPA collected soil samples from areas near the
then-defined limits of the soil contamination. These samples
were collected from the 0-6" interval of soil and from the 0-1"
interval of soil in response to concerns that the limit of
contaminated soil most likely available for exposure to young
children was not well defined by the 0-6* soil sampling program.
Additional 0-1" interval soil samples were collected from
properties adjacent to C&D Recycling, Inc. in June 1992 in
response to requests from Technical Assistance Grant advisors and
local citizens.
The results of sampling in the uppermost interval of the soil
column, i.e., the 0-1" interval, indicate that the areal extent
of contamination is somewhat larger than that defined by sample
results from the 0-6" interval of soil. The November 1991
sampling results further suggest that a significant proportion of
the contamination is in the 0-1" interval since samples from the
1-6H interval showed substantially lower contaminant levels. The
data support a conclusion that the total volume of soil requiring
remediation based upon consideration of the results of sampling
in the 0-1" soil interval would not likely be increased from a
volume calculation based upon sampling results of the upper six
inches of soil. The FS assumed excavation of the top 1 foot of
soil.
14
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In all, more than 250 soil samples and 55 duplicate and/or split
soil saaples were collected from the Site during and after the
RI. Selected analytical results of the soil sampling are
summarized in Table 5 and Table 6. Complete analytical results
are contained within the RI Report and the Administrative Record
file.
Soil samples were also analyzed pursuant to the EP Toxicity or
the Toxicity Characteristic Leaching Procedure (TCLP) test to
determine if the metals within the soil would exhibit the
characteristic of toxicity [25 PA Code § 261.24]. The results of
the EP Toxicity test and TCLP analyses indicate that levels of
lead in the leachate exceed regulatory levels of 5 mg/L. Thus,
the contaminated soil is a RCRA hazardous waste (EPA Hazardous
Waste Number 0008) because it exhibits the characteristic of
toxicity. The lead analytical results are depicted in Table 7.
The soil, surface water, sediment, and ash data collected during
the RI/FS is generally consistent with data collected during
previous investigations. EPA's split sample data suggest that
concentrations of compounds and constituents reported in the RI
Report are typical of the Site.
SURFACE WATER
Soil contaminated by Site operations was transported away from
the operations area behind the main facility building primarily
via the action of surface water drainage and wind. Precipitation
events over the Site generated stormwater runoff which ran
through drains and over the land surface and eventually into
nearby surface water bodies (e.g., Mill Hopper Creek).
Stormwater drainage from the operations area as well as overland
flow of stormwater runoff carried suspended contaminated soil
south towards Mill Hopper Creek from the majority of the Site and
northwest across Brickyard Road from a small portion of the
northwest corner of the Site. Stormwater from the truck loading
area and water used in Site operations were channeled to a dry
well located west of the main facility building. Stormwater in
the vicinity of the process area was channeled to the shale pit
via an underground storm water drainage system. Surface water
draining the majority of the Site (Mill Hopper Creek) was sampled
in 1984 by PADER, in 1986 and 1987 by EPA, and in 1988 during the
RI. Selected surface water inorganic analytical results are
depicted in Table a.
15
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TABLB 5
SELECTED INORGANIC ANALYTICAL RESULTS OF SOIL SAMPLES
(results in ppm)
SOIL SOURCE/
INTERVAL DATE
LEAD
CONCENTRATION RANGE
COPPER ZINC
ANTIMONY
On-Site7
0" - 6"
0" - 6"
6" - 12"
0" - 6"
0" - 6"
0" - 6"
> 6"
0" - 1"
Surface
Off-Site
0" - 6"
0" - 6"
> 6"
0" - 1"
0" - 6"
0" - 1"
PADER-84
PADER-85
PADER-85
EPA-87
RI (88/89)
RI (89)8
RI (89)
EPA-91
Other9
PADER-84
RI (88/89)
RI (89)
EPA-91
EPA-91
EPA-92
386-141,000
31-52,271
33-947
32-121,000
25-126,000
987,000
6-1690
105-1172
60-324,000
45-55
16-4190
72
37-273
17-204
2-489
225-30,303
21-6152
14-195
22-23,200
20-63,300
866
18-176
48-514
34-85,000
24-32
10-839
55
15-58
10-26
6-119
48-2526
47-735
50-243
182-2820
55-13,800
86,900
NA
47-128
38-6870
64-67
26-284
NA
45-114
29-86
15-105
NA
NA
NA
12-356
ND-646
426
NA
ND-1130
ND-2030
NA
ND-10.5
NA
ND
ND
ND
7 For the purpose of this table, on-Site is defined as soil
located on property owned by C&D Recycling, Inc.
8 This sample is a composite sample collected from 5 on-
Site locations in July 1989.
9 This row summarizes analytical results of samples
collected by AT&T in 1991 and 1992 from various locations on
the Site.
16
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TABLE 6
SUMMARY OF ORGANIC CONTAMINATION IN SOILS
AS DETECTED DURING THE REMEDIAL INVESTIGATION
CONTAMINANT f I RANGE
SAMPLES DETECTED
benzo(a)pyrene 66 ll ND-1.6
benzo(a)anthracene 66 17 ND-3
benzo(b)fluoranthene 66 23 ND-3.9
benzo (Jc) fluoranthene 66 21 ND-3.9
ideno(l,2,3cd)pyrene 66 9 ND-0.72
benzo(g,h,i)perylene 66 8 ND-0.65
bis(2-EH)phthalate 66 18 ND-4.6
PCB-12601
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TABLE 8
SELECTED INORGANIC ANALYTICAL RESULTS OP SURFACE WATER SAMPLES
(total and filtered metals analyses)
(results in parts per billion "ppb")
SAMPLE
TYPE
LEAD
CONCENTRATION RANGE
COPPER ZINC
ANTIMONY
PADER-84
EPA- 8 6
EPA- 8 6
EPA-87
RI (88)
RI (88)
TOTAL
TOTAL
FILTERED
TOTAL
TOTAL
FILTERED
ND-6.6
14-40
3-7
76-79
20-60
3-6
ND
6-10
1-6
30-35
54
ND
10
NA
NA
ND-39
17-52
18-23
NA
NA
NA
ND
ND
ND
One organic compound, bis (2-ethylhexyl) phthalate, was detected
in surface water. This phthalate, a common plasticizer and
laboratory contaminant, was detected in an unfiltared vater
sample from the outflow of Mill Hopper Pond (estimated
concentration of 7 ppb) and Mill Hopper Creek downstream of the
pond at a concentration below EPA's Contract Required Detection
Limit (CRDL)(5 ppb). Surface water was also analyzed for organic
compounds in April 1987. NO organic compounds were detected.
SEDIMENT
Sediment samples (soil and natural debris within drainage
channels, streams, and the pond) were collected on several
occasions from the Site. Mill Hopper Creek originates from small
seeps issuing from the base of a soil bank near the farmhouse on
the Site. The seeps contribute a sufficient amount of water to
form an identifiable channel. During the removal activity at the
Site in 1987, rip-rap was placed in the channel to minimize
erosion of the soil bank and subsequent transport of the eroded
material downstream in Mill Hopper Creek. Prior to placement of
rip-rap, and in 1986 and 1987, the sediment in the stream channel
was sampled by EPA. In addition to the vater from the seeps,
vater enters Mill Hopper Creek from the area of shale excavation
located in the south central portion of the Site. Water
discharges into the shale pit from a pipe draining the facility
operations area near the furnaces behind the main facility
building. The sediment within this drainage pathway was sampled
by PADER in 1984 and by EPA in 1987 prior to installation of
18
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erosion control features in 198712. The sediment in Mill Hopper
Creek channel, the pond, and in drainage ditches alongside
Brickyard Road were sampled during the Remedial Investigation.
Selected inorganic analytical results are depicted in Table 9.
Low concentrations of several organic compounds, predominantly
phthalate and polynuclear aromatic hydrocarbon (PAH) compounds,
were also detected in the sediment within the pond and creek. A
portion of the facility's drainage network discharges into a dry
well or leach pit rather than the shale pit. The drainage
system's network of pipes, catch basins, and pits is currently
clogged with sediment. Table 10 contains select inorganic
analytical results of sediment within the leaching pit (these
results were submitted to EPA in June 1992 during the public
comment period). Complete analytical results are contained
within the RI Report and the Administrative Record.
TABLB 9
SELECTED INORGANIC ANALYTICAL RESULTS OF SEDIMENT SAMPLES
(results in ppm)
SAMPLE
LOCATION
CONCENTRATION RANGE
LEAD COPPER ZINC ANTIMONY
PAOER-84
PADER-84
PADER-85
EPA- 8 6
EPA-86
EPA-87
EPA-87
RI (89)
RI (88/89)
RI (88)
Other1*
Shale Pit
MB Creek
MH Ppnd
MH C*eek
Shale Pit
Shale Pit
MH Creek
Road Ditch
MH Creek
Pond
Pond
2949-3668
1298-4032
2416-2776
772-3235
7520-13,400
3240-121,000
60-2020
51-679
14-2150
1820-3740
277-4420
1587-2101
393-1620
968-1085
273-3235
5700-9540
1250-23,200
74-748
25-179
27-380
864-1880
81-1410
391-491
158-474
NA
NA
NA
461-2820
85-250
95-342
53-141
260-675
78-256
NA
NA
NA
NA
NA
12-69
ND
6-11
ND
ND
14
12 PADER sampled soil (sediment) located in the shale pit in
September 1984. The analytical results have been included in the
range of contamination depicted in Table 5.
13 This row summarizes analytical results of 4 pond
sediment samples data collected by AT&T in March 1992.
,•
19
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TABLB 10
SELECTED INORGANIC ANALYTICAL RESULTS OF SEDIMENT
IN THE LEACH PIT (DRYWELL)
(results in ppo)
LEAD 112,000
COPPER 8,370
ZINC 3,660
ANTIMONY 834
GROUND WATER
Ground water in the Mauch Chunk Formation is used for drinking
water purposes. Thus, the aquifer is classified as a Class II
aquifer pursuant to "EPA Guidelines for Ground Water
Classification" (Final Draft, December 1986). Extensive sampling
of ground water near the Site was initiated by PADER, in 1984,
and EPA, in 1985. Samples of ground water were collected from
nearby residential wells, from a well located within the C&D
Recycling main facility building, from existing wells at the
Site, and then from monitoring wells installed by PADER at the
Site (certain wells were later converted to screened monitoring
wells during the Remedial Investigation).
Ground water monitoring wells were installed in locations at
which potential releases of hazardous substances from the Site
into the ground water could be monitored. No ground water impact
was indicated by the analytical results of sampling of these
wells.
The analytical results indicate elevated levels of inorganic
constituents, e.g., lead and copper, in residential wells. Some
of the levels detected since sampling was initiated in 1984
exceeded the existing Maximum Contaminant Level (MCL) for lead
50 ppb)(40 C.F.R. § 141.11) and the treatment level of 15 ppb
applicable to public water suppliers proposed under the Safe
Drinking Water Act, 42 U.S.C. § 300f et. aeq.. as amended. The
analytical results do not consistently indicate the presence of
contamination, thereby suggesting that a "plume" of lead- or
copper-contaminated ground water does not exist. Additionally,
both filtered and unfiltered samples were collected from many of
the monitoring wells and residential wells. Much higher levels
of inorganic constituents typically existed in unfiltered, rather
than filtered, samples. The levels of inorganic constituents
dropped significantly when the water was filtered suggesting that
the majority of the metals were suspended or attached to sediment
within .the ground water and not dissolved in the ground water.
20
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The residential well sampling results also demonstrate that a
significant amount of lead and copper is leaching from the water
distribution system within each residence. Lead and copper
levels in water samples collected as soon as the tap is opened
are significantly higher than lead and copper levels in water
samples collected after the tap was run for 30 seconds. Lead and
copper levels were lower still after the tap was opened for 3 to
5 minutes. In addition/ PADER's samples of ground water from
monitoring wells they installed in 1985 do not suggest the
presence of ground water contamination from the Site in
residential wells. •*'-•••
In 1985, EPA and PAOER collected samples of ground water from
existing wells apparently used by the dairy farm predating Site
operations. The results from these wells indicated high levels
of contamination, e.g., 11/600 micrograms of lead per liter
("ug/L") or parts per billion ("ppb") of unfirtered ground water
withdrawn from the farmhouse veil. However, the wells were not
properly sealed. In fact, the well with the highest level of
contamination was flush with the ground surface and did not have
a protective cap. When water was purged from this well the
sediment accumulated at the bottom of the well was disturbed and
suspended in the water column. Therefore/ the water sample was
extremely turbid/ contained a high level of sediment/ and would
not be representative of ground water moving through the aquifer,
but more representative of sediment that entered the well from
the surface.
The data collected during .the RI/FS is consistent with past
information and indicates that the ground water has not been
impacted by lead/ copper and other contaminants from the Site
operations. Instead/ elevated levels of lead and copper in
residential wells are most likely attributed to leaching of
metals from the water distribution systems within individual
residences caused by reaction with aggressive (corrosive) ground
water and ambient ground water quality. For example,
concentrations of lead and copper are significantly higher in
water sampled from the tap prior to purging or letting the water
run. EPA has determined that there is no difference in the
quality of ground water beneath the Site/ adjacent to the Site,
and in th« region underlain by the Mauch Chunk Formation/
attributable to Site operations.
The ground water is not contaminated as a result of Site
operations/ reiterating.previous determinations made by EPA and
FADER.
21
-------
I* I
Ground water analytical data indicate that contaminants, e.g.
lead, copper, and antimony ara not leaching from the Sita into
the ground-water system and residential wells. Ground water
analytical data for lead is summarized in TABLE 11, TABLES 12A
and 12B, and TABLI 13. Complete analytical results are contained
within the RI Report and the Administrative Record. TABLES 11,
12A, 12B, and 13 depict lead contamination since it is the
contaminant of primary concern at the Site and has caused the
most significant concern for local residents. EPA has not
identified any Site-related ground water contamination.
The analytical results in Tf-SLK 1?" indicate that only well MW-5D
has elevated level of lead. Cons, iering the concentrations of
other metals detected in th« monitoring wells f there is no
indication of Site-related ground water contamination. EPA's
analysis of analytical data indicates that metals in the ground
water do not originate from the Site. For example: 1) samples
from wells open to deep aquifer intervals tend to have poorer
water quality, 2) samples from wells upgradient to the source
areas have concentrations of metals similar to those found in
downgradient wells, and 3) wells do not have similar suites of
metals indicative of Site contamination.
Infrequent detections of organic compounds, e.g., acetone,
methylene chloride, and bis (2-«thylhexyl) phthalate, in
monitoring well samples do not indicate that the Site is a source
of these compounds. The detected organic compounds are common
laboratory contaminants and/or were frequently detected in blank
samples (i.e., control samples used to determine if contaminants
are originating from sources, e.g., laboratory, other than the
sampled media). Similar to the inorganic constituents, there was
no trend suggesting that the organic compounds originated from
the Site. Although the levels of metals in some wells are
periodically elevated, EPA has not identified the Site as a
source of ground water contamination.
During the Remedial Investigation, EPA collected split samples of
soil, sediment, surface water and ground water samples collected
on behalf of AT&T Nassau Metals Corporation. The analytical
results of EPA split samples are similar to the results of
samples collected during the RI on behalf of AT&T Nassau Metals
Corporation. The similarity between contaminant concentrations
detected by EPA and by contractors acting on behalf of AT&T
Nassau Metals Corporation, as well as the consistency between
data collected before, during, and after the Remedial
Investigation, indicates that the Site's contamination
characteristics have been well defined.
22
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TABLE 11
SUMMARY OF GROUND WATER ANALYTICAL DATA FOR LEAD
C&D Recycling Site
(total lead results in ppb)
SOURCE n MEDIAN AVERAGE RANGE
Mauch Chunk Formation14
Pottsville Formation
17
5
7
11
20
11.5
ND-24415
ND-24
Monitoring Wells (RI) 16-17
Residential
Residential
Residential
Residential
Wells
Wells
Wells
Wells
(RI)
(DER)19
(DER)20
(DER)21
41
71
22
62
44
4.2
3.8
10.9
<4
9
9.39
7
29
5
32
ND-5018
.87
.99
.56
.2
ND-41
ND-108
ND-72
ND-400
H Information on Mauch Chunk and Pottsville Formation
ground water quality obtained from: Taylor, L.E., 1984, Ground
Water Resources of the Upper Susquehanna River Basin. PADER
Bureau of Topographic and Geologic Survey Water Resources Report
158.
15 The second highest lead concentration for the Mauch Chunk
Formation is 19.4 ppb which reduces the median and average Mauch
Chunk Formation lead concentrations, to 6.7 and 6 ppb,
respectively. The second highest lead concentrations for
monitoring wells (RI) and residential wells (RI) are 44 and 36.7,
respectively, which reduces the average lead concentration to
8.37 and 7.39, respectively.
16,The analytical data reflect total concentrations of lead
in monitoring wells and residential wells in samples collected
during the Remedial Investigation.
17 Differences between construction specifics and use of
monitoring wells and residential wells are not factored into the
analytical data within this table, but were considered in
developing conclusions.
18 EPA's split of the sample from MW-3 in which 50 ppb of
lead was detected by the PRP showed only 1.5 ppb of lead.
19 This row of data represents pressure tank samples
20 This row of data represents samples purged 3 to 5 man.
21 This row of data represents all other DER samples as well
as Foster/Township samples.
: 23
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TABLE 12A
SUMMARY OF MONITORING WELL22 LEAD DATA COLLECTED
DURING THE REMEDIAL INVESTIGATION
(total metals results)
(results in ppb)
SOURCE
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
n
5
1
5
7
7
7
1
5
2
MEDIAN
4
7.8
2.5
2
3.3
2.4
1.41
AVERAGE
5.82
17.66
5.78
7.77
8.37
12.77
1.41
RANGE
1.3-14
23
2.2-5023
ND -11
ND -36.224
2.S-2225
3
ND -4426
ND - 1.9
22 Data from open interval borehole wells and discrete
interval monitoring wells were included in the calculations for
each well location, e.g., MW-1 includes results from MW-1S and
MW-1D.
23 The second, highest lead concentration is 26 ug/L which
reduces the median lead concentration to 5.05 ug/L and the
average to 9.57 ug/L. After MW-3 was reconstructed, the lead
concentration was detected at 2.2 ug/L. EPA collected a split of
the sample exhibiting 50 ppb. EPA's split contained no lead.
2* The upper end of the range is from a water sample
collected from the deep well in the MW-5 well cluster.
Corresponding intermediate and shallow depth water samples
contain 1.1 ug/L and ND, respectively.
25 After MW-6 was reconstructed, water from the shallow and
deep intervals contain 2.8 ug/L and 7.7 ug/L, respectively.
26 After MW-8 was reconstructed, the deep well yields
insufficient water for sampling and the shallow well contains 8.2
ug/L.
24
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TABLE 12B
MONITORING WELL DATA FROM
RECONSTRUCTED WELLS
(JUNE 1989)
WELL I.D. LEAD CONC,
(ug/L)
MW-1S 6.5
MW-1D 3.3
MW-3 2.2
MW-4 2.5
MW-5S ND
MW-5M 3.0
MW-5D 36.2
MW-6S 2.8
MW-6D 7.7
MW-7 3 . 0
MW-8S 8.2
MW-9S ND
MW-9M 1.9
25
-------
TABLZ 13
SUMMARY OF RESIDENTIAL WELL LEAD DATA COLLECTED
DURING THE REMEDIAL INVESTIGATION*7
(total metals results)
(results in ppb)
SOURCE
n
MEDIAN
AVERAGE RANGE
Box 1636 (RI)
Box 1509C (RI)
Box 1508 (RI)
BOX 3 II28 (RI)
BOX 1506C (RI)
Box 1510A (RI)
BOX 1506AA(RI)
Box 1506 (RI)
Box 1509B (RI)
BOX 1640 (RI)
BOX 1506B (RI)
Box 1509A (RI)
Box 1509 (RI)
Box 150 6A (RI)
Box 2119 (RI)
BOX 1510 (RI)
Maple Lane(RI)
4
4
5
4
5
4
3
4
4
4
3
4
5
5
4
6
3
5.9
2.75
1.5
22.6
4.8
9.85
0.4
5.55
5.25
14.6
2.8
7.75
5.6
0.4
2.55
10.5
2.3
7.05
4.67
2.16
19.62
9.44
9.02
1
5.32
6.02
15.22
11.83
6.55
7.66
0.98
2.5
17.86
2.53
2.2-14.2
1.2-12
ND - 5.4
3 -30. 3W
ND -32.2
ND -16
ND - 2.2
ND - 9.8
3.7- 9.9
5.7-2650
1.7-3151
ND -10.3
3 -14.8
ND - 2.4
1.7- 3.3
2.7-41*
1.5- 3.8
27 Each residential well is sampled after sufficient water
is purged from the tap to evacuate 3 volumes of water from the
well or the well is dried and recharged.
28 Well locations 311, 1510, 1510A, 1640, and 1636 are
located along route 940 and in the vicinity of abandoned
anthracite mines.
29 The second highest lead concentration at this well is
27.2 ug/L. Elimination of this sample value reduces the median
concentration to 18 ug/L and the average to 16.06 ug/L.
30 Th« second highest lead concentration at this location is
18 ug/L. Elimination of this value reduces the median lead
concentration to 11.2 ug/L and the average to 11.63 ug/L.
31 The second highest lead concentration at this location is
2.8 ug/L.
32 The second highest lead concentration at this location is
36.7 ug/L. Elimination of the highest value reduces the median
lead concentration to 6.8 ug/L and the average to 13.24 ug/L.
26
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VI. Summary of site Risks
An assessment of the potential risks posed to human health and
the environment was completed in accordance with the NCP [40
C.F.R. 300.430(d)]. This section of the ROD discusses the
results of the baseline risk assessment. The results of the
baseline risk assessment are used to determine whether
remediation is necessary, to help provide justification for
performing the remedial action and to assist in determining what
exposure pathways need to be remediated.
A. HUMAN HEALTH RISK EVALUATION
The potential human health risks posed by a Superfund site if no
remedial action is taken are calculated in a baseline risk
assessment. A baseline human health risk assessment for the c&o
Recycling Site was completed in March 1992.
In general, a Site poses a potential human health risk if i) the
contaminants at the Site may cause cancer or some other health
effect at existing levels, 2) there is a route or pathway through
which a receptor may be exposed, e.g., ingestion of contaminated
soil, and 3) there is a receptor which is exposed, e.g., a child
ingesting soil. In a baseline human health risk assessment, the
contaminants are evaluated, the exposure routes are characterized
and the receptors are identified.
The Site is not currently occupied although a guard occupies the
main facility building on a temporary basis. Persons potentially
at risk include trespassers, recreational users and future
residents.
According to Foster Township zoning maps, land located north and
west of the Site is zoned for agricultural use although no
agricultural activity is ongoing. East and south of the Site is
land zoned for residential use. A trailer park (Maple Lane
Estates) and a second home/retirement community (Hickory Hills
and Hickory Hills West) exist northeast of the Site. According
to available information, the trailer park and second
home/retirement community are expected to expand. In fact,
Hickory Hills West has lots partially developed adjacent to the
northeast corner of the Site. Forested area exists north, east,
and south of the Site and acts as a buffer between the Site and
the nearest residential dwellings. C&D Recycling, Inc. has
voluntarily restricted the deed to parcel 11 (see Figure 3) to
prevent residential, recreational and agricultural use.
Nonetheless, residential occupation of the Site in the future is
possible.
27
-------
In 1984, the Northeastern Pennsylvania Vector Control Association
sampled blood from 62 children in Foster Township. Apparently
only 19 of the 62 samples were analyzed for blood lead
concentrations. The results indicate that some of the children
have elevated blood lead concentrations, but a conclusion as to
the source of the lead was not established. Some of the children
living both near to and distant from the Site had elevated blood
lead. Blood lead concentration data submitted by some of the
local residents was also considered by EPA in the assessment of
risk.
The baseline human health risk assessment for the C&D Recycling
Site evaluated the potential risks posed if an individual (e.g.,
recreational user of adjacent land) is actually exposed to Site
contamination in the absence of any remedial action. In
addition, the potential risks posed by a theoretical future
scenario of residential development on the Site were assessed.
Thus, potential risks posed by current and potential future uses
of the Site were evaluated.
In an effort to simplify the application of the results of the
risk assessment to the development of remedial alternatives, the
Site was separated into various areas, e.g., inside and outside
of the currently fenced area. This separation by area is
reasonable since the current exposure likely to occur within
these various areas is likely to be different due to access
limitations. Nonetheless, future residential use of the Site,
i.e., unrestricted access, in the absence of remediation was
evaluated in the assessment of risk.
The potential risks posed by exposure to soil, sediment, air,
surface water, and ground water were evaluated in the baseline
human health risk assessment.
EPA considers organic compounds and inorganic constituents which:
1) present a potential risk to human health and the environment
at the detected concentrations and 2) originated from the Site or
likely originated from the Site, to be contaminants of potential
concern for the Site. Inorganic constituents and organic
compounds which were not identified in at least 5% of the samples
or are essential nutrients, e.g., calcium, were not considered to
be contaminants of potential concern. The contaminants of
potential concern for the C&D Recycling Site are listed in TABLE
14. TABLB 14 also includes inorganic constituents and organic
compounds which: 1) may have been detected in only one ground
water sample or in only one sampling round and 2) may have been
detected at concentrations below EPA's contract required
detection limit for that chemical in accordance with the Contract
Laboratory Program (CLP). Thus, the comprehensive list of
inorganic constituents and organic compounds in TABLB 14 may not
be indicative of Site contamination. The contaminants listed in
TABLB 14 and marked by an asterisk (*) may contribute to the
28
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human health risk posed by exposure to soil, sediment, air,
ground water, or surface water potentially contaminated by Site-
related constituents and compounds, but are not related to the
Site. These constituents are considered in the overall risk as
background risk.
TABLB 14
CONTAMINANTS OF POTENTIAL CONCERN
C&D RECYCLING SITE
OFF-
SITE
SOIL
ON- OFF-
SITE SITE
SOIL GRND
WATR
ON- SURF SED AIR ASH
SITE WATR
GRND
WATR
Aluminum
Arsenic*
Antimony
Barium
Beryllium*
Cadmium*
Copper
Chromium
Cobalt
Cyanide
Lead
Mercury*
Manganese
Nickel*
Silver
Selenium*
Thallium*
Vanadium
Zinc
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
X
X
X X
X
X
X
X
29
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TABLE 14 (CONTINUED)
CONTAMINANTS OF POTENTIAL CONCERN
C&O RECYCLING SITE
OFF-
SITE
SOIL
Acetone
Carbon Disulfide
Methylene Chloride
Toluene
2-butanone
Xylene
Acenapthene
Acenapthylene
Anthracene
Benzo(a) anthracene
Benz o ( a ) pyrene
Benzo (b) fluoranthe.
Benzo (g,h,i,)peryl.
Benzo (k) fluoranthe.
Bis 2(EH)phthalate
Chrysene
Dibenzo ( a , h) anthra .
Dibenzofuran
Di-n-buty 1-phthala .
Di-n-octyl-phthala .
Butyl benzyl phtha.
Fluoranthene
Fluorene
Ideno(l,2,3,cd)pyr.
Naphthalene
Chloroform
Phenanthrene
Pyrene
Phenols
4 -methyl phenol
4, 4 '-DDE
4, 4 '-DDT
PCB-1260
PCB-1248
Benzoic Acid
Pentachlorophenol
Dioxin
Furan
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ON- OFF-
SITE SITE
SOIL GRND
WATR
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
ON- SURF SED AIR ASH
SITE WATR
GRND
WATR
X
X
X X
X
X
X
X
X
X
X
XXX X
X
X X
X
X
X
X
X
X
X X
X
X
X
X
X
X
X
30
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Inorganic constituents and organic compounds which were detected
at concentrations within the background range or were not solely
attributable to the Site (some compounds, e.g., PAHs, could
originate from other sources), but contribute to unacceptable
health risk were evaluated in the risk assessment. Some of these
contaminants (e.g., arsenic, beryllium, and benzo(a)pyrene) cause
a large portion of the potential risk posed by the Site.
The baseline human health risk assessment evaluated the potential
risk posed by exposure to contaminants detected at the site. The
baseline human health risk assessment considered several
plausible exposure routes. TABLE 15 lists those contaminants
which could result in an excess cancer risk greater than IxlO"6
or a non-carcinogenic risk with a Hazard Index greater than 1.
These contaminants will be addressed in the remedy selected in
this ROD.
Since the area contaminated by the elements and compounds listed
in TABLE 15 is greater than the area contaminated by other
inorganic constituents and organic compounds resulting from Site
operations (e.g., Site-related contaminants listed in TABU 14)
cleanup of the Site based upon the contaminants listed in TABLE
IS will be protective of human health and the environment, since
lead has spread the farthest from the source areas, remediation
of soil, ash, and sediment based upon lead concentrations alone
is protective and will result in the removal of all other
contaminants above health-based levels.
Exposure Assessment
Cancer potency factors (CPFs), also called slope factors, have
been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure
to potentially carcinogenic (cancer-causing) chemicals. CPFs,
which are expressed in units of (mg/kg-day)*1, are multiplied by
the estimated chronic daily intake (GDI) of a potential
carcinogen, in mg/kg-day, to provide an upper bound estimate of
the excess lifetime cancer risk associated with that intake
level. The term "upper bound" reflects the conservative nature
of the risks calculated from the CPF. It is a statistical tern
related to the degree of certainty of the data used to calculate
the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. CPFs are derived from the
results of human epidemiological studies or chronic animal
bioassays to which human-to-animal extrapolation and uncertainty
factors have been applied. CPFs for the contaminants of concern
at the Site, as well as the models from which the CPFs were
obtained are referenced in the tables within APPBHDIX C.
31
-------
TABLB 15
CONTAMINANTS RESULTING IN EXCESS CANCER RISK GREATER THAN 1X1C'6
AND NON-CANCER RISK WITH HAZARD INDEX GREATER THAN 1s
CONTAMINANT PATHWAY CONCENTRATION34 (ppm)
CURRENT35
ARSENIC SOIL INGESTION 30.52
ANTIMONY GROUND WATER INGESTION 0.03
BERYLLIUM ~ SOIL INGESTION 0.72
BERYLLIUM GROUND WATER INGESTION 0.002
BENZO(a)PYRENE56 SOIL INGESTION 0.326
LEAD SOIL INGESTION 476.62
33 This table includes lead which, according to the Lead
Uptake Biokinetic Model, may result in blood lead greater than 10
ug/dL in children exposed to contaminants at concentrations
existing at the Site. See Appendix D for risk characterization
tables for each contaminant in each pathway evaluated at the
Site.
34 This concentration represents the 95% upper confidence
level (UCL) of the mean soil contaminant concentration.
35 Current exposure scenarios include recreational exposure
to soil outside the fence ("on-site" and "off-site") surrounding
the highly contaminated areas of the Site and ingestion of tap
water in nearby residences.
36 EPA has recently evaluated the toxicity of benzo (a)
pyrene and subsequently revised the risk potentially posed by
PAHs downwards by approximately 50%. These reduced risks are not
reflected in this table, but were considered in the overall
assessment of risk posed by the Site.
32
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TABLE IS (Continued)
CONTAMINANTS RESULTING IN EXCESS CANCER RISK GREATER THAN 1X10'6
AND NON-CANCER RISK WITH HAZARD INDEX GREATER THAN 1
CONTAMINANT
PATHWAY
CONCENTRATION37 (ppm)
FUTURE38
ARSENIC
ANTIMONY
BERYLLIUM
BERYLLIUM
BENZO(a)PYRENE
COPPER
DIBENZO(A,H)ANTHRA.
LEAD
PCB
THALLIUM
DIOXIN
LEAD
SOIL INGESTION
SOIL INGESTION
SOIL INGESTION
GROUND WATER INGESTION
SOIL INGESTION
SOIL INGESTION
SOIL INGESTION
SOIL INGESTION
SOIL INGESTION
GROUND WATER INGESTION
ASH INGESTION
ASH INGESTION39
4.07
85.57
0.60
0.002
0.302
8,048.55
0.184
20,207.28
0.349
0.005
0.0015
70%
37 This concentration represents the 95% upper confidence
level of the mean contaminant concentration with the following
exceptions: 1) 0.0015 ppm for dioxin is the dioxin concentration
equivalent to 2/3,7,8 - tetrachloro dibenzo-p-dioxin (TCDD), 2)
70% lead in ash is a rounded approximation of the maximum ash
concentration including PAOER samples collected in 1984 (ash lead
concentrations detected during the RI/FS were 22,000 and 93,500
ppm). Samples collected prior to the RI are not included in
other calculations.
38 Future exposure scenarios include residential occupation
of the Site and ingestion of unremediated soil and ground water
from the monitoring wells.
39 Ash also contained elevated levels of antimony (670 ppm,
estimated), copper (33,200 ppm), and zinc (5280 ppm) detected
during the RI/FS.
33
-------
EPA represents the toxicity of individual PAHs with no known CPF
in terns of a toxicity equivalence factor (TEF) to the CPF of
benzo(a)pyrene. This is a conservative assumption since
benzo(a)pyrene is a potent carcinogen. The TEFs are multiplied
by the CPF of benzo(a)pyrene to yield a lower, individual CPF.
The TEFs used by EPA in the C&O Recycling baseline risk
assessment are identified in TABLE 16.
TABLE 16
•x ...
TOXICITY EQUIVALENCE FACTORS
Benz o(a)pyrene 1
Benzo(a)anthracene 0.145
Benzo(b)fluoranthene 0.140
Benzo(X)fluoranthene 0.066
Benzo(g,h,i)perylene 0.022
Dibenzo(a,h)anthracene 1.11
Chrysene 0.004
ideno(1,2,3-cd)pyrene 0.232
Pyrene 0.081
Potential concern for non-carcinogenic effects of a single
contaminant in a*' single medium is expressed as the ratio of the
estimated intake derived from the contaminant concentration in a
given medium to the contaminant's reference dose (Rfd). This
ratio is referred to as the hazard quotient (HQ). By addition of
the HQs for all contaminants within a medium or across all media
to which a given population may reasonably be exposed, the Hazard
Index (HI) can be generated. The HI provides a useful reference
point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
APPENDIX c contains information on CPFs and Rfds used in the
assessment of risk at the C&D Recycling Site.
If contaminants of concern in a completed exposure pathway
(individual or multiple pathway) results in the exposed
individual having 1 to 100 extra chances of contracting cancer in
1,000,000 such chances, EPA considers the risk to be acceptable
and does not necessarily recommend remedial action to address the
risk. EPA expresses the acceptable risk range in scientific
notation and in accordance with the NCP as follows: IxlO"6 to
IxlO"4 [40 C.F.R. § 300.430(e) (2) ]. EPA recommends remedial
action to address excess cancer risks greater than IxlO*4 (100 in
1,000,000). EPA may recommend remedial action to address risks
within the 1x10'* to IxlO*4 excess cancer risk range. EPA
recommends, remedial action to address non-cancer risks with a .
Hazard Index (HI) greater than 1.0. EPA considers non-
34
-------
carcinogenic risks with a HI less than 1.0 to be acceptable. The
tables within APPENDIX D depict the potential risks posed by
exposure to the contaminants at the Site in each of the media and
exposure pathways to which people could reasonably be exposed.
Risk Characterization
The majority of the Site's potential carcinogenic risk is posed
by exposure to PAH, PCB, and dioxin in the surface soil and/or
ash. The majority of the non-carcinogenic risk posed by the Site
is due to antimony and copper in the.surf ace soil and/or ash.
Lead contributes significantly to the risk posed by the Site and
was evaluated separately in the lead Uptake Biokinetic Model.
Carcinogenic risks greater than IxlO"6 and non-carcinogenic risks
with a HI greater than 1 are shown in TABLE 15. The 95% upper
confidence limit (UCL) of the mean concentration of the
contaminant at the Site causing the potential risk is also listed
in TABLE 15. The 95% UCL of the mean concentration of the
contaminant was used to calculate the chronic daily intake of the
contaminant and the resultant lifetime risk pursuant to EPA's
Reasonable Maximum Exposure Scenario (RMES) guidelines. Using
the 95% UCL of the mean concentration is reasonable since there
is only -a 1 in 20 chance that the true mean would be a higher
concentration.
The only exposure scenarios at the C&D Recycling Site which
result in potential excess cancer risk greater than IxlO*4
("unacceptable" risk) involve ingestion of ground water.
However, the majority of the risk is due to arsenic and beryllium
which EPA believes are not related to the Site, e.g., background.
In addition, the current risk posed by ingestion of ground water
is not due to the C&D Recycling Site since EPA believe* Site-
related contaminants have not migrated to residential wells
through the ground water system. The only exposure scenario
which does not involve ingestion of ground water and which
results in a non-cancer risk with a HI greater than 1 involves
ingestion of soil under future residential use of the Site.
Several exposure scenarios result in potential excess cancer risk
between IxlO*4 and IxlO*6 ("acceptable1* risk). However, the
majority of these scenarios assume future residential development
of the Site. At least three current exposure scenarios pose an
excess cancer risk greater than IxlO*6 due to contaminants which
may be related to the Site. Each of these three scenarios
involves ingestion of surface soil contaminated with PAHs,
specifically benzo(a)pyrene. Since PAH contamination is the
result of the incomplete combustion of organic matter and the
Site operations involved various burning processes, it is
reasonable to assume that PAHs will be found on the Site. It is
also probable that PAH contamination originated, in part, from
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other sources. EPA has recently revised the potency slope for
benzo (a) pyrene, thereby reducing the estimate of risks posed by
PAHs by approximately 50%. TABLE 15 does not reflect these
reduced risk calculations.
Ingested arsenic is a known human carcinogen which results in an
increased incidence of skin cancers. Only a fraction of the
arsenic-induced skin cancers are fatal, although the non-fatal
skin cancers remain of some concern. Furthermore, the assumption
of a linear relationship between arsenic dose and cancer risk may
overestimate the risk. EPA believes that the uncertainties
associated with ingested inorganic arsenic a ire-such that risk
estimates could be modified downwards as much as tenfold relative
to risk estimates associated with other carcinogens.
Most of the exposure scenarios which result in potential non-
carcinogenic risk with a hazard index greater than 1.0
("unacceptable1* risk) involve ingestion of ground water. The
risk is due mainly to antimony (current off-Site ingestion) and
thallium (future on-Site ingestion). As discussed previously,
the Site data do not suggest that Site-related contaminants have
migrated to residential wells. Ingestion of soil by a toddler
residing on the Site in the future would result in a hazard index
of 2.87.
Summation of the potential risks posed by several pathways over a
30 year time period reasonably estimates the total potential risk
posed by contaminants detected during the RI. The calculations
suggest that the current risks posed to off-Site residents and
future risks potentially posed to on-Site residents are greater
than IxlO"4. The majority of the risk results from ingestion of
beryllium in ground water, which EPA believes is not related to
Site operations.
Lead
Although EPA considers lead to be a possible human carcinogen, it
has not yet developed the necessary factors, e.g., Cancer Potency
Factor (CPF), to evaluate risks posed by lead similar to other
carcinogenic compounds. Therefore, it is not possible to
calculate a cancer risk number as is done for other contaminants.
EPA believes, however, that levels of lead equal to or greater
than 10 ug/dL of blood may cause adverse effects on nervous
system development in children. Therefore, the assessment of
potential risks posed by the C&D Recycling Site would be
incomplete without considering the risk posed by lead.
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Lead cleanup levels were evaluated based upon the Lead Uptake
BioJcinetic (UBK) Model which considers all probable lead exposure
routes and allows EPA to evaluate soil lead cleanup levels
necessary to protect children from adverse affects of lead in the
bloodstream. EPA uses the model to predict the percentage of
children which could have blood lead levels above 10 ug/dL if
exposed to lead from various sources including soil. EPA
currently endeavors to reduce soil lead levels such that at least
95% of the children exposed to lead contaminated soil would have
blood lead levels below 10 ug/dL.
Using the calculated maximum concentration of lead in air (0.0226
ug/nr) and the 95% UCL (UCL-) of the mean concentration of lead
in residential wall water (9.29 ug/L) and soil located beyond the
C&D Recycling, Inc. property line (476.6 mg/kg), blood lead
information for exposed children was modelled with the Lead UBK
Model. The modelled output indicates that a minimum of 94% of
exposed children would exhibit blood lead levels below 10 ug/dL.
A Geometric standard Deviation of 1.42 was used in the model.
This GSD reflects exposure to a very small number of children,
and was selected on the basis of the limited extent of off-Site
lead contamination. Had lead contamination been more widespread,
a higher 6SD would have been used. In addition, the model
assumed a condition wherein indoor dust lead concentrations are
equal to outdoor soil lead concentrations. Since the affected
land immediately adjacent to the Site is not characterized by
active residential use and soil lead values near the homes are
less than 476 ppm, this modelled output is an over-estimate of
the elevated blood lead risk posed to children playing on
property adjacent to the Site. Use of the UCL^ value in the
model provided a slightly protective estimate of the average soil
lead concentration.
Using the calculated maximum concentration of lead in air (0.0226
ug/mf) and the UCL~ of the mean concentration of lead in on-Site
monitoring wells (12.72 ug/L) and soil located on the Site
(20,207 mg/kg), blood lead information for exposed children
residing at the Site in the future was modelled with the Lead UBK
Model. The modelled output indicates that exposed children would
exhibit blood lead levels above 10 ug/dL.
The baseline human health risk estimate was conducted using
various reasonably conservative assumptions about the likelihood
of exposure, the amount of exposure, and the toxicity of the
chemicals. For example, the C&D Recycling Site baseline risk
assessment assumed that the exposed child would ingest 200 mg/day
of soil with levels of contaminants present at the UCL^ of the
mean concentration level. Additional exposure assumptions
include ingestion by adults of 2 liters of water and 100 mg of
soil per day. EPA believes that incorporation of these
assumptions will lead to calculation of a Reasonable Maximum
Exposure,Scenario (RMES) and a risk value which is unlikely to
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underestimate the actual risk.
The excess cancer risk posed by ground water, which is unrelated
to the Site, is greater than 10"4. The non-cancer risk posed by
ground water is greater than 1.0. The excess cancer risk posed
by surface soil contaminants other than lead at the C&D Recycling
Site (including Site-related contaminants) is within EPA's
acceptable risk range. In addition, the HZ is less than 1 for
all, but one, exposure scenarios involving ingestion of soil or
sediment contaminated by the Site. The only exposure scenario
resulting in a HI greater than 1 and involving ingestion of soil
or sediment contaminated by the Site is based upon future
residential land use.
The Lead Uptake Biokinetic Model and existing EPA policy indicate
that soil lead levels should be reduced to provide protection of
human health. Although ground water is presently not
demonstrably impacted by contaminants from the C&D Recycling
Site, remedial action for soil, sediment, and ash to ensure
future protection of ground water is warranted. In addition,
migration of contaminants from the Site has impacted surface
water bodies near the Site. Thus, remedial action to address the
contaminated ash, soil and sediment at the Site is justified.
B. ENVIRONML
An ecological assessment was performed at the Site in 1990. The
assessment included evaluation of the plant and animal species
living at or using the Site surroundings. Terrestrial and
aquatic animals and plants were observed and identified. An
aquatic benthic survey was performed and species diversity for
aquatic and terrestrial plants and animals was characterized.
Surface water and sediment samples were collected and analyzed
during the Remedial Investigation.
Based upon consultation with State and Federal agencies
knowledgeable about threatened and/or endangered species in the
Commonwealth of Pennsylvania, EPA has determined that no
threatened and/or endangered species are located within or near
the C&O Recycling Sit*.
According to PAOER, the Sandy Run basin is a High Quality Cold
Water Fishery. An evaluation of migration pathways from the
contaminant source areas, e.g., furnaces and ash piles, to Mill
Hopper Creek suggests that Site contaminants have impacted Mill
Hopper Creek and the pond which lie within the Sandy Run Basin.
The lack of aquatic vegetation in the pond is likely the result,
in part, of the high levels of sediment and contaminants flowing
into the pond. Unfiltered water samples exceeded Pennsylvania
Water Quality Standards for lead, cadmium, beryllium, copper, and
silver. Filtered water samples exceeded Hater Quality Standards
for lead/'
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Wetland areas were identified at the Site. The wetland areas
within the area of contamination are primarily limited to the
Mill Hopper Creek channel and the immediate surroundings of the
channel. Downstream of the Site, Mill Hopper Creek flows through
larger wetland areas.
An archeological survey was conducted on the Site in 1991. The
Phase 1A survey was completed due to the existence of an
abandoned (and ruined) frame farmhouse and its associated
structures located in tha center of the Site. The farmhouse
dates to the middle of the 19th century. There are no properties
listed on the National Register of Historic Places within 1 mile
of the Site.
Although the buildings on the Site are not historically
significant, the area near the headwaters of Mill Hopper Creek
may have prehistoric archaeologic significance and should be
further investigated before disturbed by any remedial activity.
In addition, the area immediately adjacent to the farmhouse ruins
and associated structures may have historic significance since it
may provide insight into human occupation in the area in the
1800 's and 1900's.
TJgVgT.fi
In addition to the remedial objectives stated in the Feasibility
Study, EPA seeks^to eliminate, reduce, or control risks to human
health and the environment. EPA expects to include both
treatment to minimize the threat posed by highly mobile wastes
and containment to control low-level threats. Additionally, EPA
expects to minimize the amount of untreated waste. To achieve
the necessary level of protection, EPA establishes remediation
goals, i.e., cleanup levels based upon levels of exposure
protective of human health and the environment. For known or
suspected carcinogens, EPA has established acceptable exposure
levels as those which may result in 1 to 100 extra chances of
contracting cancer among 1,000,000 such chances, i.e., excess
cancer risk between IxlO"4 and IxlO"6.
Based upon the results of the Lead Uptake Biokinetic Model and
the baseline risk assessment, the concentrations of contaminants
in the soil within the fenced area of the Site would pose a
health risk if the Site were developed as residential property.
Additionally, the level of lead in soil within adjacent
properties may not provide the necessary level of protection
suitable for active residential use. Finally, the levels of
toxic metals in the sediment may inhibit healthy growth in Mill
Hopper Pond.
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The Lead UBK Model shoved that an average level of approximately
450 ppm lead in the soil on residential property (2-acre lot)
would not result in blood lead concentrations exceeding 10 ug/dL
in greater than 95% of the exposed children. Reducing the
average soil lead level to approximately 300 ppm on individual
residential lots (2-acre lot) would increase the level of
protection to greater than 99%. These model runs include
assumptions that indoor dust concentration is equal to outdoor
soil lead concentrations and ground water and soil lead
concentrations equal the UCL~ mean concentration of lead in
these media beyond C&D Recycling, Inc. property line. A
geometric standard deviation (GSD) of 1.42 was used consistent
with the assumption that the exposure occurs to a single
theoretical family on their 2-acre property. Two acres is
consistent with Foster Township zoning requirements and nearby
properties.
Based upon this information and EPA's existing policy on soil
lead cleanup levels [OSWER Directive 19355.4-02], EPA proposes a
soil cleanup level of a maximum of 500 ppm lead, i.e., no
confirmatory sample collected shall exceed 500 ppm. EPA believes
that 500 ppm lead would be protective of human health
(residential exposure) and would not impact the environment,
e.g., leach to the ground water. EPA believes and expects that a
cleanup .level of 500 ppm would ensure that the average soil lead
level remaining on any two-acre plot would be less than
approximately 235 ppm, including theoretical residential plots
located on the Site. Thus, residual soil lead levels would be
protective.
Since property west and north of the C&D Recycling Site is zoned
for agricultural use, and many residents near the Site grow
garden vegetables, the soil lead cleanup maximum level of 500 ppm
was considered in evaluating possible impacts to future
agricultural activity. Existing information suggests that the
soil cleanup level of 500 ppm (the average level expected to be
less than 235 ppm on any 2-acre lot after the cleanup) would not
result in elevated risfc to individuals ingesting vegetables grown
in this soil.
Lead contamination spread the farthest from the source areas,
e.g., furnaces and ash piles. Thus, the area of lead
contamination represents the largest contaminated area and
encompasses areas of soil and sediment contaminated by other
compounds and constituents, e.g., PAHs, copper, and antimony.
The area of remediation delineated by lead satisfactorily
addresses unacceptable levels of other Site-related contaminants
in the soil.
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since the evaluation in the ecological assessment of the cause of
the poor conditions in the pond was not conclusive, but includes
impact froa the Site, EPA assumes that Site contaminants in Mill
Hopper Pond sediment have resulted in poor growth of aquatic
vegetation. Thus, EPA proposes removal of 2 feet of pond
sediment and placement of a protective layer of rock/soil to
support vegetative growth. Removal of contaminated pond sediment
will also ensure that this sediment is not released downstream.
Since Mill Hopper Creek and portions of Mill Hopper Pond
periodically run dry making exposure to contaminated sediment a
possibility, EPA proposes that all sediment available for
recreational or future residential exposure (i.e., bank of pond
and dry stream bed) exceeding 500 ppm lead be removed. This
level should be equally protective of the environment.
Considering Pennsylvania's Co-occurrence database, only lead
levels of approximately 300 ~o 500 ppm in the sediment may cause
benthic toxicity in the remediated creek bed. Since the Co-
occurrence database may not apply to the Site and the majority of
the creek to be remediated is periodically dry, the 500 ppm
cleanup level is deemed to be adequate for environmental
protection. Consideration of the significant stresses likely
caused by periodic dryness suggests that lover cleanup levels may
not provide improved habitat for benthic organisms in the creek.
Air sampling and sampling of decontaminated building surfaces
would be implemented to ensure that residual contaminant levels
do not exceed appropriate levels. Ambient air should not exceed
50 micrograms lead per cubic meter (ug/m3) and 1000 ug/m3 copper
to protect future occupational inhabitants. Building surfaces
should not exceed soil cleanup levels to protect human health and
the environment.
VIZ. Alternatives
The Feasibility Study report developed alternatives to meet the
remedial objectives of the Site cleanup. TABLB 17 lists the
remedial alternatives developed in the Feasibility Study and
provides information on estimated costs, including present worth
costs which include the cost of operation and maintenance (OiM)
and estimated implementation time for each alternative. T&BLB 17
provides estimated cost data for a cleanup level of 1000 ppm as
presented in the FS and 500 ppm as preferred by EPA. The
documentation for the costs can be found in Appendix I. Each
alternative considered is also briefly described in this section
of the ROD. Each alternative, except Alternative 1, includes
implementation of the common actions described in this section.
i
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TABLE 17
SUMMARY OF REMEDIAL ALTERNATIVES
C&O Recycling Site
ALTBRNATXVB 1 - HO FURTHER ACTION
1000 ppm
Estimated Capital Cost : $ 0
Estimated Annual O&M Cost : $ 70,500
Estimated Present Worth Cost : $ 831,020
Estimated Implementation Time: N/A
500 ppm
$ 831,020
ALTERNATIVE 2 - ACCESS RESTRICTIONS and CONSOLIDATION
1000 Pom 500 ppm
Estimated Capital Cost :
Estimated Annual O&M Cost
Estimated Present Worth Cost :
Estimated Implementation Time:
$ 1,296,100
$ 82,090
$ 2,263,740
12 months
$ 2,270,531
ALTERNATIVE 3 - BOIL/VEGETATIVE COVES
loop
Estimated Capital Cost
Estimated Annual O&M Cost
Estimated Present Worth Cost
$ 2,903,560
$ 33,820
$ 3,302,210
Estimated Implementation Time: 20 months
ALTERNATIVE 4 - RCRA COVES
Estimated Capital Cost
Estimated Annual O&M Cost
Estimated Present Worth Cost
1000 ppm
$ 3,465,460
$ 33,820
$ 3,864,110
Estimated Implementation Time: 22 months
500 ppm
$ 3,863,586
500 ppn
$ 4,830,138
ALTERNATIVE 5 - STABILIZATION AND 07F-8XTB DISPOSAL
1000 ppm 500 ppm
Estimated Capital Cost : $ 8,645,275
Estimated Annual O&M Cost : $ 25,390
Estimated Present Worth Cost : $ 8,944,565
Estimated Implementation Time: 18 months
$11,985,717
ALTERNATIVB « - STABILIZATION AND ON-8ITB DISPOSAL
Estimated Capital Cost
Estimated Annual O&M Cost
Estimated Present Worth Cost
1000 ppm
$ 5,258,185
$ 38,020
$ 5,706,345
500 ppm
$ 7,361,185
Estimated Implementation Time: 18 months
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The remedial alternatives are described in this section of the
ROD as they are described in Feasibility Study and the Proposed
Plan for the purpose of consistency (the FS draft was reviewed by
the public and the FS alternatives were described in the Proposed
Plan). EPA's modifications to the alternatives are described as
modified common actions and new common actions in this ROD (as
veil as in the Proposed Plan). Modifications are also described
in Section XI ("Explanation of Significant Differences") and in
Section IX ("Selected Remedy) of this ROD. Differences between
the remedy preferred by EPA in the Proposed Plan and selected in
this ROD are detailed in Section XI ("Explanation of Significant
Differences") and in Section IX ("Selected Remedy) of this ROD.
ALTERNATIVE 1 - HO FURTHER ACTION
1000 ppm 500 ppm
Estimated Capital Cost : $ 0
Estimated Annual O&M Cost : $ 70,500
Estimated Present Worth Cost : $ 831,020 $ 831,020
Estimated Implementation Time: N/A
The NCP [40 C.F.R. Section 300.430(e)(6)] requires that EPA
consider a "No Action" or "No Further Action" alternative for
each site. This alternative provides only for continued
maintenance of the sedimentation and erosion control systems, ash
pile covers, and fencing. In the No Further Action Alternative,
the contaminants in the soil and sediment at the site would be
left in place. The Site would continue to pose a potential risk
to trespassers and would pose a risk to nearby residents if their
land were to be used in a different manner, e.g., occupation of
land immediately adjacent to the Site. In addition, continued
migration of contaminants in the surface water may further impact
the environment. Alternative 1 is not protective of human health
and the environment.
COMMON ACTIONS
Alternatives 2 through 6 include several common actions, common
actions which were developed in the FS ("FS COMMON ACTIONS"), and
described in th© Proposed Plan, are also described below for
consistency purposes. EPA also considered modifications to the
common actions developed in the FS ("USEPA MODIFIED COMMON
ACTIONS"). EPA's modified common actions were also described in
the Proposed Plan and are described below. EPA also considered
newly developed common actions, i.e., not developed within the FS
("USEPA COMMON ACTIONS"). The new common actions were described
in the Proposed Plan and are described below. Each of the common
actions was considered in the comparative evaluation of remedial
alternatives and in the development of the Proposed Plan. The
estimated costs for Common Actions are contained in APPENDIX B.
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FS COMMON ACTION 11) - flxcavatipn and Stabilization of Pond
Sediment
The top two feet of sediment within the pond shall be excavated
from the pond. Since EPA expects that sediment will fail the
TCLP (similar to Site soils), the sediment shall be stabilized,
e.g., with a mixture of port land cement and water, to remove any
hazardous characteristic and to comply with Land Disposal
Restrictions of the Resource Conservation and Recovery Act
(RCRA)[40 C.F.R. Part 268]. According to the results of a
Treatability Test conducted in 1990, stabilization is an
effective treatment technology for the site contaminants. The
pond bottom would than be covered with uncontaminated soil and
crushed stone to support vegetative growth. The stabilized
sediment would be disposed as described in Alternatives 2 through
6 (Subtitle 0 waste disposal facility) and may be combined with
other soil or sediment. During activity in the pond, Mill Hopper
Creek would be diverted around the pond subject to Dam Safety and
Waterway Management Regulations [25 PA Code § 105.1 fi£. sag.").
Additionally, activity in the pond shall not result in a release
of contaminants to Mill Hopper Creek in excess of Pennsylvania
Ambient Water Quality Standards [25 PA Code § 93.1 et. sea.].
The estimated volume of sediment is 1900 yards3 based upon a
sediment depth of 2 feet.
FS COMMON ACTION f2) - Excavation and Stabilization of Storm
Water Sewer System Sediment
All (approximately 24 yards5) sediment within pipes, drains,
basins, and pits which constitute the subsurface storm water
sewer system shall be removed, sampled (via TCLP) to determine if
the sediment exhibits the RCRA characteristic of toxicity, and
stabilized, as necessary, e.g., with a mixture of portland cement
and water to remove any RCRA hazardous characteristic. The
stabilized sediment would be disposed as described in
Alternatives 2 through 6 (Subtitle D waste disposal facility) and
may be combined with other soil or sediment on the Site if
sampling demonstrates that the sediment within the storm sewer
system is compatible with other soil or sediment, e.g., suitable
for co-disposal.
FS COMMON ACTION 13) - Decontamination of Site Buildings
The main facility building, barn, and milkhouse shall be
decontaminated. The interior space of the buildings,
approximately 83,000 square feet, shall be vacuumed to remove
contaminated surface material. Interior smooth surfaces would be
wiped down with damp cloths. Surfaces which cannot be cleaned by
vacuum or .wet cloth shall be encapsulated. Vacuum filters,
water, cloths, and contaminated debris shall be treated, as
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necessary, to meet RCRA Land Disposal Restrictions (40 C.F.R Part
258) and disposed in a RCRA Subtitle C hazardous waste landfill
if determined to be a RCRA hazardous Haste. The small furnace
structure shall be dismantled since it is not structurally sound
and would interfere with soil removal. The dismantled material
would be disposed as described in Alternatives 2 through 6.
FS COMMON ACTION |4) - Removal of Casing and Wire
The remaining casing cable and wire shall be baled and disposed
off-Site in a non-hazardous facility. If feasible, the material
shall be cleaned and recycled rather than disposed. The remedial
alternatives* wliich include this common action (i.e., Alternatives
2 through 6) assume, for cost estimating purposes, that the
material shall be disposed into a permitted off-Site landfill.
FS COMMON ACTION #5) - Deed Restriction
A restriction of the deed shall be filed to prohibit residential,
agricultural and recreational activity on any portion of the Site
on which hazardous substances above cleanup levels shall remain.
Available information indicates that such a deed restriction for
Tax Parcel 11 has been filed.
USEPA'8 MODIFIED COMMON ACTIOHS
USEPA MODIFIED COMMON ACTION I1) - Removal of Pond/Creek
Sediment
All sediment within the pond with levels of lead above 500 ppm
shall be removed. A 500 ppm cleanup level is consistent with the
cleanup level applied to surface soil and would not adversely
affect the pond environment since the remaining sediment would
subsequently be covered. At minimum, a maximum of 2 feet of
sediment shall be removed from the bottom of the pond regardless
of the degree of contamination to allow for placement of
rock/sediment on the pond bottom intended to support new growth
of aquatic vegetation. This action is necessary to minimize
further release of suspended contaminated sediment from the site
and to prevent future exposure to contaminated sediment when the
pond is dry. Remediation of the pond has the added benefit of
significantly improving the habitat within the pond.
Additionally, sediment in the bed of Mill Hopper Creek with lead
levels above 500 ppm shall be removed. A 500 ppm cleanup level
is necessary to both minimize further release of contaminated
suspended sediment and potential risk to individuals ingesting
sediment during recreational activity when Mill Hopper Creek runs
dry. Remedial activities shall not result in migration of
surface water from the Site with contaminant levels in excess of
federal or state water quality criteria or standards [25 PA Code
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§§ 93.1 et. sfisu, Pennsylvania Clean Streams Lav 35 P.S. §§
691.1-691.1001][Clean Water Act, Federal Water Quality Criteria,
33 U.S.C. § 1251] and shall be completed in accordance with State
requirements regulating activity in streams [25 PA Code §§ lOS.l
et. secr.1. This modification affects each alternative discussed
within the FS and was evaluated in regard to the alternative
evaluation criteria in the Proposed Plan and this ROD.
USEPA MODIFIED COMMON ACTION #3) - Decontamination of Site
Buildings
On-Site buildings with dust lead levels above 500 ppm lead
remaining after soiJ,: reliediation shall b« decontaminated by
washing/vacuuming/sealing exposed surfaces. Air monitoring shall
be implemented. After decontamination, the dust lead level in
any on-Site building shall not exceed the soil lead cleanup level
of 500 ppm. In addition, non-structural components and equipment
within the buildings which would interfere with proper
decontamination of the buildings shall be removed and disposed or
cleaned and recycled in compliance with the requirements of 40
C.F.R. Part 268. The debris, water, cloths, filters, etc.
generated during decontamination of the buildings, shall be
treated, as necessary, to meet Land Disposal Restrictions (40
C.F.R. Part 268) and disposed in a RCRA Subtitle C facilty.
Building components may be disposed into a Subtitle D facility.
This modification affects each alternative discussed within the
FS and was evaluated in regard to the alternative evaluation
criteria in the Proposed Plan and this ROD.
USEPA MODIFIED COMMON ACTION |4) - Removal of Casing and Wire
Remaining cable casing and wire shall be either (1) recycled, if
feasible, and if the recycling process does not result in
additional debris requiring disposal, or (2) disposed into a non-
hazardous (Subtitle D) off-Site waste disposal facility. Cable
casing and wire which has come to be located on adjacent
properties shall also be removed. This modification affects each
alternative discussed within the FS and was evaluated in regard
to the alternative evaluation criteria in the Proposed Plan and
this ROD.
USBPA NBW COMMOM ACTIONS
USEPA COMMON ACTION 16) - Abandon Wells
Several wells located at the Site, e.g., farmhouse well, serve no
useful purpose and should be properly plugged and abandoned in
order to eliminate the possibility of these wells acting as a
conduit for future ground water contamination. Any well not used
or considered for practical use as part of a long-term ground
water monitoring network should be properly plugged and abandoned
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in accordance with minimum requirements of 25 PA Code 109.602(c)
and consistent with PADER's Public Water Supply Manual, Part II,
Section 3.3.5.11. This new common action affects each
alternative discussed within the FS and was evaluated in regard
to the alternative evaluation criteria in the Proposed Plan and
this ROD. The expected additional cost is very low and the
potential for additional protection is significant.
USEPA COMMON ACTION #7) - Stream Monitoring
The flowing water within Mill Hopper Creek and/or pond shall be
periodically sampled to aasuyv- that the remedy is protective of
the aquatic environment.- In addition, stream biota shall be
periodically inspected to ensure that no impact is resulting from
the remedy. The additional cost of this common action is low and
necessary to ensure compliance with regulations protecting fresh
water streams. This new common action affects each alternative
discussed within the FS and was evaluated in regard to the
alternative evaluation criteria in the Proposed Plan and this
ROD. The anticipated additional cost is very low and the
potential for additional protection is significant.
USEPA COMMON ACTION #8) - Phase IB Archeolocrical Survey
Prior to any soil excavation, shovel test pits shall be conducted
to determine if archaeologically significant artifacts exist at
the Site. A Phase IB Archeological Survey shall be conducted in
accordance with Pennsylvania Bureau of Historic Preservation
guidelines in areas of moderate or high archaeologic or historic
significance potentially impacted by the Site remediation. This
new common action affects each alternative discussed within the
FS and was evaluated in regard to the alternative evaluation
criteria in the Proposed Plan and this ROD. The expected
additional cost is moderately low and necessary to ensure that
potential cultural resources are not impacted. This Common
Action is necessary to comply with the requirements of the
National Historic Preservation Act (Chapters 106 and ILO(f) and
36 C.F.R. Part 800) and Archeological and Historic Preservation
Act (16 U.S.C. § 469a-l).
USEPA COMMON ACTION 19) - Toxieitv Testing
After soil excavation and regrading is completed, or as early as
reasonably practicable, samples of soil shall be tested to ensure
that remaining concentrations of Site contaminants do not pose a
threat to human health and the environment. The test protocol
and standards shall be develoed during the remedial design. This
new common action affects each alternative discussed within the
FS and was evaluated in regard to the alternative evaluation
criteria in the Proposed Plan and this ROD. The expected
additional cost is moderately low and necessary to ensure that
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the residual soil contaminant levels do not impact human health
and the environment.
Each of the remaining remedial alternatives, i.e., Alternative 2
through Alternative 6 is described in this ROD as they were
presented in the Feasibility Study and Proposed Plan. The common
actions referenced in each alternative and figured into the
estimated cost are the common actions developed in the FS.
However, EPA's evaluation of the remedial alternatives was
performed with consideration for the modified common actions and
new common actions described above. Additionally, EPA
comparatively evaluated each remedial alternative with a cleanup
level of 500 ppm lead as well as It/00 ppm lead. Alternatives 2
through 6 are discussed below.
ALTERNATIVE 2 - ACCESS RESTRICTIONS (and CONSOLIDATION)
1000 ppm 500 ppm
Estimated Capital Cost : $ 1,296,100
Estimated Annual O6M Cost : $ 82,090
Estimated OiM Present Worth Cost: $ 967,640
Estimated Present Worth Cost : $ 2,263,740 $ 2,270,531
Estimated Implementation Time : 12 months
In addition to the FS Common Actions described above and the
continued maintenance described in Alternative 1, Alternative 2
involves consolidating soil with lead at concentrations exceeding
500 ppm and not located on C&O Recycling, Inc. property, i.e.,
adjacent residential and agricultural land, and soil above 1000
ppm lead located in areas readily accessible to trespassing
recreational users into a main area to be enclosed by a 6-foot
high chain link fence. Excavated soil would be consolidated
within the 1000 ppm lead isoconcentration line. The existing
fence at the Site would be extended to include additional area
generally located east and south of the existing fence. The
fence in Alternative 2 would enclose all areas of soil with lead
exceeding 500 ppm to minimize accidental exposure to contaminated
soil. The volume of soil to be addressed is 3550 cubic yards
from areas located on adjacent property and 650 cubic yards from
other areas for a total volume of 4200 cubic yards (assuming a
conservative depth of remediation of 1 foot). The excavated soil
would be replaced by soil containing lead levels at or below the
mean soil lead background level (approximately 44 ppm).
Consolidation of soil would comply with the erosion control
requirements of the Pennsylvania Erosion Control regulations (25
PA Code § 102.1 et. afifl.) and would include investigation, e.g.,
search for archeological artifacts, in soil near Mill Hopper
Creek affected by the remediation.
48
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Additionally, Alternative 2 includes excavation of approximately
24 yd3 of contaminated sediment from the storm sever system and
1900 yd3 of sediment from the pond, sampling storm sever system
sediment, stabilization of the excavated sediment, as necessary,
to remove any RCRA hazardous waste characteristic and to comply
with the Land Disposal Restrictions [40 C.F.R. Part 268], and
disposal of all sediment into a permitted non-hazardous vaste
disposal facility. Off-Site disposal vould comply vith EPA's
Off-Site Policy (OSWER 9330.2-07). Non-hazardous vaste resulting
from building decontamination disposed in Pennsylvania vould be
disposed into a landfill regulated by residual vaste regulations
[25 PA Code Chapters 287, 288, and 289].
T j r ow*- •
The treatment, i.e., stabilization, of SCRA characteristic
hazardous vaste at the site vould comply vith the substantive
requirements of hazardous vaste treatment facilities, 25 PA Code
Chapter 264. Transportation and handling of hazardous vaste,
i.e., soil, sediment, and ash prior to stabilization, vould
comply vith the substantive hazardous vaste handling and
transportation requirements of 25 PA Code Chapters 262 and 263.
Alternative 2 includes continued maintenance of the storm vater
control system, sedimentation and erosion controls, fencing, and
ash pile covers, i.e., continued implementation of the ongoing
maintenance .
Since soil is to be consolidated vithin a single unit or Area of
Contamination, placement, as defined by RCRA (40 C.F.R. § 268.1),
vould not occur. Since this remedial alternative is not
generating contaminated soil, the soil is not classified as a
vaste. Since placement of a hazardous vaste is not occurring,
Land Disposal Restrictions (LDRs) under RCRA are not Applicable
or Relevant and Appropriate Requirements ("ARARs") relating to
soil consolidation. Thus, EPA believes the hazardous vaste
regulations under RCRA and Pennsylvania's hazardous, municipal,
or residual vaste regulations are neither applicable nor relevant
and appropriate requirements for soil consolidation in
Alternative 2. Post excavation sampling, e.g., sampling vith X-
Ray Fluorescence (XRF) and confirmatory laboratory sampling,
vould be implemented to ensure that cleanup levels are met.
During the Remedial Action, release of particulate matter (dust)
from the Site vould be monitored and shall comply vith applicable
or relevant and appropriate regulations [Clean Air Act § 109,
National Ambient Air Quality Standards, regulations at 40 C.F.R.
Fart 50] [25 PA Code §§ 123.1 fi&. sea, and 131.1 fi£.
EPA estimates that Alternative 2 could be fully implemented
vithin 1 year from the date field activity is started. If all
soil above 500 ppm vere consolidated into a fenced area of the
Site, the estimated present vorth cost vould increase to
2, 270, 531 r.
49
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ALTERttTXVB 3 - 8OXL/VBGBTATXVB COVBR
1000 ppn 500 ppa
Estimated Capital Cost : $ 2,903,560
Estimated Annual O&M Cost : $ 33,820
Estimated O&M Present Worth Cost: $ 348,650
Estimated Present Worth Cost : $ 3,302,210 $ 3,863,586
Estimated Implementation Time : 20 months
Alternative 3 includes the elements of Alternative 2, including
common actions, and a soil cover to prevent direct contact with
contaminated soil and ash. The soil cover would be at least 3
feet thick and include a topsoil layer to promote grcerch of a
stabilizing vegetative layer. Alternative 3 also includes some
grading to establish suitable slopes for cover placement and
consolidation of additional soil located on steep slopes into
areas of the Site with gentler slopes. In addition, soil would
be removed from existing paved areas and a new pavement cover
emplaced, as needed. The soil cover would be placed over all
soil with lead levels exceeding 1000 ppm. The cover would
include storm water control features to protect the integrity of
the cover and minimize erosion. Alternative 3 includes a ground
water monitoring program, consistent with Pennsylvania's waste
management regulations.
Since soil is to be consolidated within a single unit, placement,
as defined by RCRA (40 C.F.R. § 268.1), would not occur. Since
this remedial alternative is not generating contaminated soil,
the soil is notClassified as a waste. Since placement of a
waste is not occurring, Land Disposal Restrictions (LDRs) under
RCRA are not ARARs for soil consolidation activities. Thus, EPA
believes the hazardous waste regulations under RCRA and
Pennsylvania's hazardous or residual waste regulations are not
applicable or relevant and appropriate to consolidation and
covering of soil in Alternative 3.
The continued maintenance of ash pile covers would no longer be
necessary under Alternative 3. Instead, the soil/vegetative
cover would be maintained.
EPA estimates that Alternative 3 could be fully implemented
within 20 months from the date field activity is started. If all
soil above 500 ppm were addressed in Alternative 3, the estimated
present worth cost would increase to $3,863,586.
50
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ALTSBATXVB 4 - RCRA COVER
1000 POP 500 ppm
Estimated Capital Cost : $ 3,465,460
Estimated Annual O&M Cost : $ 33,820
Estimated O&M Present Worth Cost: $ 398,650
Estimated Present Worth Cost : $ 3,919,220 $ 4,830,138
Estimated Implementation Time : 22 months
Alternative 4 includes all aspects of Alternative 3 although a
drainage layer and a low permeability liner shall be installed
within the soil cover. The drainage layer will minimize the
amount of water infiltrating through the underlying contaminated
soil and the liner further ensures that infiltration into the
underlying soil is minimized. The multilayer cap in Alternative
4 complies with cover requirements of RCRA [25 PA Code §
264.310], although compliance is neither an applicable nor
relevant and appropriate requirement. Since soil is to be
consolidated within a single unit, placement, as defined by RCRA,
would not occur. Since the Remedial Action is not generating
contaminated soil, the soil is not classified as a waste. Since
placement of a hazardous waste does not occur in Alternative 4,
the Land Disposal Restrictions of RCRA are not applicable [40
C.F.R. § 268]
The continued maintenance of the ash pile covers would no longer
be necessary under Alternative 4. Instead, the RCRA cover would
be periodically maintained.
EPA estimates that Alternative 4 could be fully implemented
within 22 months from the date field activity is started. If all
soil above 500 ppm lead were addressed in Alternative 4, the
estimated present worth cost of the remedy would increase to
$4,830,138.
ALTERNATIVE 5 - STABILISATION AMD OFF-8ZTB DISPOSAL
1000 ppm 500 PPm
Estimated Capital Cost : $ 8,645,275
Estimated Annual O&M Cost : $ 25,390
Estimated O&M Present Worth Cost: $ 299,290
Estimated Present Worth Cost : $ 8,944,565 $11,985,717
Estimated Implementation Time : 18 month*
Alternative 5 includes all common actions and elements described
in Alternative 2 including excavation of soil and sediment as
described in Alternative 2. In addition, Alternative 5 includes
excavation of all soil with lead above 1000 ppm and all ash
located at the Site. Approximately 20,565 cubic yards of
excavated .soil, sediment and ash would be stabilized, e.g., mixed
with portland cement and water, to remove any hazardous
51
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characteristic and transported off-Site to a permitted non-
hazardous disposal facility. The ash vill either be stabilized
and disposed at a non-hazardous facility, or transported to a
hazardous waste facility for treatment, as needed, and disposal.
With the addition of stabilizing mixture, over 22,600 cubic yards
of stabilized soil, sediment and ash would be removed from the
Site. A cleanup level of 500 ppm increases the amount of soil,
sediment, and ash to be stabilized to approximately 28,362 cubic
yards and the amount requiring disposal to approximately 31,000
cubic yards. Stabilization removes the hazardous characteristic
of toxicity from the ash, soil, and sediment to be disposed and
meets the treatment requirements of RCRA Land Disposal
Restrictions [40 C.F.R. § 268]. Stabilization would meet the
general handling, treatment, and transportation requirements of
25 PA Code Chapters 262, 263 and 264.
The Site would be closed and monitored considering monitoring
requirements of Pennsylvania's residual waste regulations (25 PA
Code § 288.152)
EPA estimates that Alternative 5 could be fully implemented
within 1 and one half years from the date field activity is
started.
If all soil above 500 ppm were disposed off-Site, the estimated
present worth cost of Alternative 5 will increase to $11,985,717.
ALTERNATIVE * - 8TABILI2ATIOM AMD OM-8ITB DISPOSAL
1000 ppm 500 ppm
Estimated Capital Cost : $ 5,258,185
Estimated Annual O&M Cost : $ 38,020
Estimated O&M Present Worth Cost: $ 444,160
Estimated Present Worth Cost : $ 5,706,345 $ 7,361,185
Estimated Implementation Time : 18 months
Alternative 6 includes all the common actions and excavation and
stabilization of approximately 20,565 cubic yards of soil and
sediment with lead above 1000 ppm and ash discussed within
Alternative 5 with the exceptions discussed herein. The
excavated and stabilized soil and sediment would be disposed into
a containment cell constructed.on-Site. The Feasibility Study
provided an evaluation of two possible locations; the on-Site
depression known as the "shale pit" and the northeast corner of
the Site. Prior to disposal an impermeable liner system would be
constructed in the base of the containment cell. After all the
material is placed within the containment cell, including over
22,600 cubic yards of stabilized soil, sediment, and ash as well
as any non-degradable rubble from dismantling of any on-Site
building, a multilayer cover would be placed on top. According
to the Feasibility Study, the liner and cover would be designed
in accordance with the RCRA standards [25 PA Code § 264.310]
52
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although these requirements are neither applicable nor both
relevant and appropriate, since the stabilized material is not
hazardous. The residual waste regulations of PAOER are relevant
and appropriate for disposal. Thus, the on-Site containment cell
would meet siting and design standards of Pennsylvania's residual
waste management regulations (25 PA Code §§ 287 and 288).
Stabilization removes the hazardous characteristic of toxicity
from the material to be disposed and meets the treatment
requirements of RCRA Land Disposal Restrictions [40 C.F.R. §
268]. A cleanup level of 500 ppm increases the amount of soil,
sediment, and ash to be stabilized to approximately 28,362 cubic
yards and the amount requiring disposal to approximately 31,000
cubic yards.
The maintenance of ash pile covers under Alternative 6 is no
longer necessary. Maintenance of the on-Site disposal cell and
associated features is included. The O&M period is cost
estimated for 30 years.
EPA estimates that Alternative 6 could be fully implemented
within 1 and one half years from the date field activity is
started. If all soil above 500 ppm were disposed off-site, the
estimated present worth cost of Alternative 6 will increase to
$7,361,345.
Till. Comparative Evaluation of Alternatives
As required in the NCP [40 C.F.R. §. 300.430(e) (9) (iii) ] , each of
the alternatives is evaluated against nine remedy evaluation
criteria. The comparative: evaluation of alternatives enables EPA
to select the option which most appropriately meets the remedial
objectives. The nine evaluation criteria are defined as follows:
A) THRESHOLD CRITERIA [relates to statutory requirements that
each alternative must satisfy in order to be eligible for
selection]
1) Overall Protection of HUPfln Health and the
whether each alternative provides adequate protection of
human health and the environment in the long and short term
and describes how risks posed through each exposure pathway
are eliminated, reduced or controlled through treatment,
engineering controls, or institutional controls.
2) Compliance with ARARat whether each alternative will meet
all of the Applicable or Relevant and Appropriate
Requirements (ARARs) of Federal and State environmental laws
and/or provides a basis for invoking a waiver; whether a
remedy complies with advisories, criteria and guidance that
EPA and PADER have agreed to follow.
53
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B) PRIMARY BALANCING CRITERIA [technical criteria upon which
the detailed analysis is primarily based]
3) Long-term Effectiveness and Permanence: refers to
expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time, once clean-up goals have been met.
This criterion includes consideration of residual risk and
the adequacy and reliability of controls.
Treatment ; addresses the statutory preference for selecting
remedial actions that employ treatment technologies that
permanently and significantly reduce the toxicity, mobility
or volume of hazardous substances.
5) Short-term Effectiveness: relates to adverse impacts on
human health and the environment that may be posed during
the construction and implementation period, until clean-up
levels are achieved.
6) Implementability ; the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
remedy.
7) £QS£: estimated capital, operation & maintenance (O&M),
and net present worth costs.
C) MODIFYING CRITERIA [criteria considered throughout the
development of the preferred alternative and formally assessed
after the public comment period which may modify the preferred
alternative]
8) State/Support Agency Acceptance; whether the state
concurs with, opposes, or has no comment regarding the RI/FS
and the preferred alternative.
9) c/Mmmn-itv Acceptance; the public's general response to
the alternatives which will be assessed in the Record of
Decision following a review of the public comments received
on the administrative record and the proposed plan.
Each alternative considered was compared and evaluated against
each of the nine evaluation criteria in this section of the ROD.
EPA's comparative evaluation of remedial alternatives in the
Feasibility Study and this ROD was completed with consideration
of several modifications to some of the common actions described
in the Feasibility Study. EPA's modified common actions are
described, in this section of the ROD.
. 7
54
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Overall Protection of Human Health and the Environment:
Each alternative, except Alternative 1, is protective of human
health and the environment by eliminating, reducing, or
controlling risk through treatment of soil, sediment, and ash,
engineering controls, and or institutional controls. Since
Alternative 1 does not eliminate, reduce, or control some of the
exposure pathways, it is not protective of human health and the
environment. Therefore, Alternative 1 will no longer be
considered as a remedial alternative.
Institutional controls, e.g., access restrictions specified in
Alternatives 2, 3, 4, 5, and 6, minimize direct contact with
contaminated media posing a potentially unacceptable health risk.
Engineering controls such as consolidation (Alternative 2) reduce
the chance for exposure to the contaminated soil, ash, and
sediment. Implementation of multiple engineering controls such
as a combination of consolidation and on-Site containment
(Alternatives 3, 4, and 6) or a combination of consolidation and
disposal into an off-Site landfill (Alternative 5), eliminates
exposure to contaminated soil, ash, and sediment. Thus,
accidental ingestion and inhalation of the contaminated soil,
ash, and sediment is minimized or prevented.
Treatment of contaminated soil, ash, and sediment (Alternatives 5
and 6), combined with engineering controls and institutional
controls, provides a higher degree of protection since the
toxicity and mobility of the contaminants is significantly
reduced. Thus, Alternatives 5 and 6 provide the highest degree
of protection of human health and the environment.
r
Each alternative provides different degrees of protection of
human health. Since the contaminated soil will not be covered in
Alternative 2, Alternative 2 provides the lowest degree of
protection of human health. Trespassers will contact the
contaminated soil. Alternatives 3 and 4 provide an increased
degree of protection since the contaminated soil will be covered.
Alternatives 5 and 6 provide the highest degree of protection of
human health since the toxicity and mobility of the contaminants
is reduced. Alternative 5 includes stabilization of the soil and
sediment and transportation of the soil, ash, and sediment to an
off-Site disposal facility. In Alternative 5, the ash will
either be stabilized and disposed at a non-hazardous facility, or
transported to a hazardous waste facility for treatment, as
needed, and disposal. Alternative 6 includes stabilization and
on-Site disposal of the soil, ash, and sediment.
Each alternative provides different degrees of protection of the
environment. However, off-Site migration of contaminated
particulate matter suspended in surface water runoff is probable
under Alternative 2 (Alternative 2 relies upon maintenance of
existing, silt fencing to prevent off-Site migration).
55
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Additionally/ Alternative 2 may not provide sufficient protection
of ground vater in th« future although no ground water impact is
evident or reasonably foreseeable. Alternatives 3, 4, 5, and 6
significantly reduce or eliminate potential environmental impacts
by preventing migration of contaminated material from the Site.
EPA Common Actions #6, 7, 8, and 9 also provide for assurance
that the selected remedial alternative vill not result in
environmental damage.
Compliance with ARARs
Alternatives 2, 3, 4, 5, and 6 comply with applicable or relevant
and appropriate federal environmental regulations.
Long-term Effectiveness and Permanence
Stabilization significantly reduces the threat posed by the
contaminated material by reducing the mobility of the
contaminants. A treatability study performed in 1990
demonstrated that stabilization effectively reduced the mobility
of the contaminants in the affected media.
Stabilization of sediment is included in Alternatives 2 through
6. Stabilization of sediment and soil above 500 ppm and ash is
included in Alternatives 5 and 6. Alternatives 5 and 6 provide
the greatest reduction of the overall risk posed by residual
contamination since soil, ash, and sediment would be stabilized.
Stabilization is a proven technology. Although little data exist
to demonstrate the effectiveness of stabilization over decades,
existing experience indicates that stabilized material would
remain immobile given proper maintenance.
56
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The reliability of covers and liners, assuming proper design,
construction and adequate maintenance, and the relatively
homogenous nature of the stabilized waste ensures that
Alternatives 3, 4, and 6 are effective over the long tern.
However, there is no liner in Alternative 3 and no bottom liner
in Alternative 4. An off-Site disposal facility (Alternative 5)
should have a liner both above and beneath the waste to be as
effective as the on-Site containment cell (Alternative 6),
although this is not a liner requirement of all non-hazardous
waste landfills. The liners above and beneath the waste in the
on-Site containment cell (Alternative 6) best minimizes
infiltration through the contaminated material. Construction of
a proper l/.ntr system is ensured in Alternative 6.
The reliability of Alternative 5 is similar to Alternative 6
provided that the operator of the off-site disposal facility
properly maintains the facility, separates wastes by type to
ensure that co-disposal of stabilized soil, sediment, and ash
with waste which may affect the stabilized material does not
occur, and the integrity of the stabilized material is not
compromised prior to final capping of the facility. In
Alternative 6, the disposal cell would contain similar wastes and
would be immediately capped. Additionally, the off-Site landfill
utilized in Alternative 5 would need to be constructed in a
similar manner as the containment cell in Alternative 6 to be
equally or more effective over the long term.
Alternative 2 cannot reliably prevent exposure to contaminated
materials. The RCRA cover in Alternative 4 and soil cover in
Alternative 3, in addition to the institutional controls
specified in each alternative, would adequately prevent direct
contact with the contaminated material. Since the material would
remain untreated, continued maintenance of the these covers is
critical to prevent future exposure. The absence of a liner
beneath the contaminated material in Alternative 4 and the lack
of a bottom liner and low permeability layer in the cap in
Alternative 3, provide less future protection of ground water
from untreated contaminants than Alternatives 5 and 6. However,
no ground water impact is evident or reasonably foreseeable.
Reduction of Toxicitv. Mobility and Volume through Treatment
Alternatives 2, 3, and 4 do not reduce the toxicity, mobility, or
volume of hazardous substances via treatment, although
Alternatives 3 and 4 utilize containment technologies to reduce
the contaminant mobility.
The primary contaminants of concern at the Site are metallic
elements which cannot be destroyed. However, stabilization of
the contaminated material effectively immobilizes the metals
within the stabilized soil structure thereby reducing the
57
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mobility of the contaminants, stabilization is also an effective
means of immobilizing low level organic contamination. However,
stabilization results in an increase in the volume of material to
be addressed in any remedial alternative. Stabilization vill
also reduce the toxicity of the contaminants as demonstrated by
EP Toxicity and TCLP testing. The Stabilization Treatability
Study indicates that this technology is effective at reducing the
mobility of the contaminants.
Alternatives 5 and 6 each include stabilization of approximately
28,362 cubic yards of contaminated soil, sediment, and ash. Once
stabilized, the results of Toxicity Characteristic Leaching
Procedure testing performed during a treatability study indicate
that contaminants of concern do not leach from the stabilized
soil at levels of concern. Additional testing during
implementation of Alternatives 5 and 6 would ensure that
contaminants of concern do not leach above regulatory levels.
Although reversible, it is not expected that conditions promoting
destabilization would occur once the stabilized material is
disposed, especially in Alternative 6 where potential co-disposal
with potentially harmful waste is easily prevented. Although
some elements within the contaminated soil, sediment, and ash
have economic value, e.g., copper and lead, recycling of the
material is not a feasible alternative.
Short-term Effectiveness
Each alternative, except Alternative 1, involves earth moving
activity which would result in generation of dust. Thus, dust
control measures must be implemented and air monitoring may need
to be performed to reduce the chance of off-Site migration of
contaminants above ambient air quality standards. Personnel
protective apparatus to prevent exposure via inhalation of
contaminants is available and reliable. Alternatives 5 and 6
would result in the greatest levels of potentially contaminated
dust generated due to the stabilization procedure, although off-
Site contaminated emissions are not expected with implementation
of reliable dust abatement measures.
The only alternative which may causa additional short term
impacts during implementation is Alternative 5. Over 2000 trucks
of stabilized soil, sediment, and ash would leave the site and
travel to a disposal facility thereby increasing the chance of
accident and subsequent contact with stabilized material. In
addition, the large number of heavy trucks travelling on the
highway during implementation of the off-Site disposal
alternative (Alternative 5) would generate a significantly higher
level of air pollutants than on-Site disposal (Alternative 6).
58
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Each Alternative, except Alternative 1, may result in temporary
impact to Mill Hopper Creek as the creek is diverted to
facilitate remediation of the pond and the creek itself.
However, Mill Hopper Creek periodically dries up, thus
significantly reducing potential impacts to flowing stream
segments and minimizing disturbance of aquatic communities in the
creek bed providing activity is scheduled to occur while the
Creek is dry. After remediation of the creek and pond is
complete, a significantly more improved substrate will exist to
promote a healthier environment in the pond and creek.
Implementability
The Stabilization Treatability Study results indicate that this
technology would be effective and implementable at the C&D
Recycling Site.
Each alternative is implementable and utilizes readily available
and reliable technologies. Stabilization (Alternatives 5 and 6)
requires use of crushing machinery, but can be implemented
without difficulty based upon the results of the stabilization
treatability study. Alternatives 3, 4, 5, and 6 include some
off-Site actions which would require administrative coordination.
Alternative 5 relies heavily upon administrative coordination to
provide a level of protection equivalent to Alternative 6, i.e.,
coordination is necessary to ensure disposal into a facility with
appropriate liners, to prevent co-disposal of waste, and to
ensure prompt construction of the protective cap. Alternative 6
includes construction of a complex containment cell requiring
significant technical design and review prior to implementation.
Off-Site disposal of dioxin-contaminated ash in Alternative 5 may
not be easily implementable. Currently, EPA has no knowledge of
a permitted operational dioxin treatment facility. Capacity at
long-term dioxin waste storage facilities is limited and
potentially unavailable. However, EPA believes that the
stabilized ash can be disposed in a RCRA Subtitle D facility.
Cost
Considering a soil cleanup level of 1000 ppm, the costs of
Alternatives 2, 3, and 4 range from an estimated $ 2.2 to $ 3.9
million; the estimated cost of Alternative 6 is $ 5.7 million;
and, the estimated cost of Alternative 5 is $ 8.9 million. The
estimated capital cost, annual operation and maintenance costs
and present worth costs for each alternative are depicted in
TABLE 17.
59
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TABLE 17 includes costs based upon a cleanup level of 1000 ppm
lead in the soil as discussed in the Feasibility Study. EPA
evaluated excavation of all soil contaminated with lead above 500
ppm. Excavation and disposition of additional soil results in
additional costs. The estimated additional costs associated with
excavation of soil contaminated above 500 ppm lead are depicted
in TABLE 18.
TABLE 18
ADDITIONAL COSTS ASSOCIATED WITH
SOIL CLEANUP LEVEL OF 500 ppm
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
2
3
4
5
6
+ $
+ $
+ $
+ $
+ $
3,
1,
6
561
966
041
654
,791
,376
,028
,152
,840
Thus, considering a cleanup level of 500 ppm, the present worth
costs for the Remedial Alternatives are depicted in TABLE 19 as
follows:
TABLE 19
REMEDIAL ALTERNATIVE COSTS
ALTERNATIVE 2 $ 2,270,531
ALTERNATIVE 3 $ 3,863,586
ALTERNATIVE 4 $ 4,830,138
ALTERNATIVE 5 $11,985,717
ALTERNATIVE 6 $ 7,361,185
State Acceptance
The Commonwealth of Pennsylvania Department of Environmental
Resources has not indicated whether it concurs with EPA's
selection of Alternative 5.
<7
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The Concerned Citizens of Foster Township Task Force (CCFTTF)
received a Technical Assistance Grant (TAG) in 1989. The CCFTTF
and the TAG advisors are opposed to on-Site disposal of
stabilized waste, a 500 ppm cleanup level, and decontamination of
buildings. CCFTTF and the TAG advisors advocate off-Site
disposal, a cleanup level less than 200 ppn, demolition of on-
Site buildings, and compliance with all Foster Township zoning
ordinances. CCFTTF, TAG advisors, and community members request
additional sampling and more comprehensive testing of soil at the
Site and neighboring land. CCFTTF also requests that the remedy
address ground water.
Several local, State, and Federal elected officials have
supported the requests of the CCFTTF, TAG advisors and local
residents.
Based upon the public comments, EPA believes that the community
agrees with off-Site disposal of the stabilized material as
selected in this ROD.
EPA has responded to each of the public comments in the
Responsiveness Summary appended to this ROD (APPENDIX A). EPA
believes that this ROD addresses and includes technically
important comments relating to the remedial alternatives
evaluated in this ROD.
IX. TBX SELECTED REMEDY
EPA received numerous comments during the public comment period.
After consideration of the public comments and an analysis of all
of the proposed remedial alternatives, utilizing the nine
criteria listed in 40 C.F.R § 300.430(e)(9)(iii), EPA has
determined that Alternative 5 is the most appropriate remedy for
the C&D Recycling Site.
Specifically, the selected remedy for the C&D Recycling Site
includes:
1 - Confirmation, e.g., via sampling, of the areal limits of
soil and sediment with lead contamination above 500 parts
per million (ppm) (including soil beneath buildings and
concrete slabs constructed after 1963 as well as pavement
and sediment in Mill Hopper Creek and wetlands);
2 - Conduct of a Phase IB archeological survey in areas
possessing high or moderate archeological sensitivity
potentially impacted by the Remedial Action;
3 - Removal and off-Site disposal and/or recycling of
casing and wire;
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4 - Excavation of all soil with lead contamination above 500
ppm resulting from Site operations (excluding soil beneath
buildings and concrete slabs constructed after 1963, or
pavement, which shall otherwise be maintained to prevent
migration of contamination from the Site);
5 - Excavation of sediment from the banks of Mill Hopper
Pond with lead levels greater than 500 ppm and excavation of
the top two feet of sediment (or an amount sufficient to
secure a new substrate) from the pond bottom to ensure that
pond water quality is not impacted.
. . 1 . c; .'
6 - Removal of sediment within Mill Hopper Creek
contaminated with lead above 500 ppm;
7 - Removal and sampling of all sediment located within the
storm water sewer system located at the Site and evaluation
of the system's integrity (including drainage ditches) to
determine the potential for releases of hazardous substances
from the Site into the soil and ground water and any
necessary response actions;
8 - Excavation of all ash located at the Site;
9 - Post excavation/removal sampling to confirm that ash,
soil/ and sediment cleanup levels are met;
10 - On-Site stabilization of the contaminated soil and
sediment, excavated and removed as described above, to
remove any characteristic of hazardous waste;
11 - On-site stabilization of the contaminated ash,
excavated as described above to remove any characteristic of
hazardous waste;
12 - Off-Site disposal of stabilized soil, sediment, and ash
into a non-hazardous (RCRA Subtitle D) waste disposal
facility;
13 - Decontamination of Site buildings with lead levels
above 500 ppm, including dismantling of non-structural
components and removal of equipment and debris which may
inhibit decontamination to required levels, or demolition of
buildings that can not be cleaned to 500 ppm lead;
14 - Dismantling of the old furnace (and other structures,
as necessary, which inhibit soil or sediment remediation and
which shall not be maintained, as necessary, to prevent
migration of contaminants from the Site);
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15 - Off-Site disposal of material generated from
dismantling of Site buildings into a non-hazardous (Subtitle
D) waste disposal facility (or decontamination and recycling
of dismantled material);
16 - Performance of biota toxicity tests on remaining
soil/sediment to ensure that remediated soil (i.e., soil
with lead levels no higher than 500 ppm) does not pose a
threat to the environment (procedures to be determined
during remedial design);
17 - Site grading/ revegetation, and related work, to ensure
that Site topography and drainageways adequately convey
water from the Site and that soil excavation does not result
in low lying areas;
18 - Air monitoring during on-Site activity and
implementation of dust control or other necessary abatement
actions to prevent migration of contaminants to the
surrounding community during the Remedial Action;
19 - Abandoning wells which serve no useful long-term
purpose;
20 - Periodic monitoring of ground water and surface water;
and
21 - If the soil beneath buildings and concrete slabs
constructed after 1963, or pavement is greater than 500 ppm
and these structures are not demolished institutional
controls, e.g., deed restrictions to prevent residential use
potentially affecting the protectiveness of the remedy, and
to ensure that Site contaminants which may remain beneath
buildings and pavement are known.
EPA has selected off-Site disposal of stabilized soil, sediment,
and ash. Within 180 days of issuance of this ROD, EPA may modify
its selection of Alternative 5, pending a demonstration that the
on-Site containment cell (Alternative 6), can provide an equally
or more protective remedy which is cost effective and complies
with all ARARs. If EPA preliminarily determines that an on-Site
remedy is equally or more protective than the remedy selected in
this ROD and that an on-Site remedy is cost effective and
complies with all ARARs, EPA will solicit public comment before
making a decision to modify the remedy.
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Including excavation of all soil contaminated with lead above 500
ppm, the estimated present worth cost of Alternative 5 rises to
$11,985,717. Thus, the estimated present worth cost of EPA's
modification of Alternative 5, i.e., the selected remedial
alternative, is $11,985,717 plus costs of addressing debris,
equipment in buildings, well abandonment, stream sampling, and
removal of cable from adjacent properties which are common to all
alternatives evaluated by EPA. The estimated costs associated
with the selected remedy are detailed in APPENDIX B.
Performance Standards
Performance standards applicable to the selected remedy are:
1. The Phase IB Archeological Survey shall comply with
Guidelines on Archaeology and Historic Preservation, 48 Fed. Recr.
44716-42 (September 29, 1983), 36 C.F.R. Parts 65 and 800.
2. Site activity shall not cause exceedance of Pennsylvania
Water Quality Standards in Mill Hopper Creek, 25 PA Code §§ 93.3
through 93.8, or exceedance of background water quality in Mill
Hopper Creek should background quality exceed Pennsylvania Water
Quality Standards, 25 PA Code § 93.5 and water quality criteria
for toxic substances of 25 PA Code Chapter 16. However,
compliance with Chapter 16 regulations will consider the ambient
background water quality of Mill Hopper Creek and Mill Hopper
Pond.
3. The stabilization process and/or earth moving shall not
generate dust exceeding National Ambient Air Quality Standards
within 100 feet of the Area of Contamination [Clean Air Act §
109, National Primary and Secondary Ambient Air Quality Standards
for lead, 40 C.F.R. § 50.12, and particulate matter, 40 C.F.R. §
50.6 and 40 C.F.R. Part 52 Subpart NN] [Pennsylvania's Air
Pollution Control Act, 25 PA Code if 123.1 fi£. fifig. and 131.1 e£.
SSfl.]. Dust suppression methods, e.g., wind screens, water
spray, or chemical agents, shall be utilized to minimize dust.
Air monitoring shall be performed in accordance with 40 C.F.R.
Part 50 Appendix 6 [25 PA Code §§ 123.1 fi£. Sfifl- and 131.1 e£.
sgg.].
4. Excavation and consolidation of the soil, sediment and ash
shall comply with the Pennsylvania Erosion Control Regulations,
25 PA Code § 102.1 fi£. sea.. Pennsylvania's Air Pollution Control
Act, 25 PA Code §§ 123.1 e£. sea, and 131.1 £&. sea.
5. Diversion of Mill Hopper Creek during implementation of
selected remedy shall comply with Pennsylvania Dam Safety and
Waterway Management Regulations, 25 PA Code § 105.1 fi£.
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6. Disposal of hazardous waste debris generated fron the
decontamination, dismantling and/or demolition of site buildings,
the old furnace and any other structures, shall comply with the
Land Disposal Restriction requirements of 40 C.F.R. Part 268.
7. The stabilized soil, sediment, and ash shall be analyzed
using the Toxic Characteristic Leaching Procedure. No sample of
leachate from tested stabilized material shall exceed the levels
specified in TABLE 20.
8. Cleanup levels for contaminants of concern in soil and
sediment (TABLE 20) shall not be exceeded in any soil or sediment
sample, excluding areas not impacted by the Site, remaining after
Site remediation.
Compliance Points
The point of compliance for soil and sediment shall be determined
during the remedial design to consist of a representative
sampling of the soil and sediment areas from which contaminated
material was removed. For example, to ensure that soil lead
levels do not exceed 500 ppm, a representative number of samples
will be collected and analyzed for lead.
The point of compliance for building dust shall be determined
during remedial design and shall consist of sampling from
representative surface area within the remediated buildings.
During remediation of sediment and soil in the vicinity of Mill
Hopper Creek and pond, Pennsylvania Water Quality Standards shall
be maintained in downstream Mill Hopper Creek. The point of
compliance shall be in flowing water of Mill Hopper Creek
downstream of the Site.
During stabilization and earth-moving activities, the air shall
be monitored. The National Ambient Air Quality Standards shall
not be exceeded within 100 feet of the Site boundary which shall
be the point of air compliance.
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TABLE 20
CLEANUP LEVELS
FOR CONTAMINANTS OF POTENTIAL CONCERN CONTRIBUTING
EXCESS CANCER RISK GREATER THAN 1X10'6
OR HAZARD INDEX GREATER THAN 1
MEDIA CONTAMINANT CLEANUP LEVELS
Soil
Lead 500 ppm
Copper 3300 ppm
Antimony 35 ppn
PAHs 1 ppm40
PCBs 2 ppm
Sediment
Lead 500 ppm
Copper 2900 ppm
Antimony 35 ppm
PAHs 1 ppm
Stabilized Ash. Sediment and Soil (extract)
Jursenic 5 mg/L
Barium 100 mg/L
Cadmium . 1 mg/L
Chromium 5 mg/L
Lead 5 mg/L
Mercury 0.2 mg/L
Selenium 1 mg/L
Silver 5 mg/L
Buildn
Lead 50 ug/m3, 500 ppm
Copper 1000 ug/m3, 3300 ppm
Antimony 500 ug/m3, 35 ppm
40 Cleanup levels for PCB and PAH contamination relate to
Site-related contamination.
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X. statutory Determinations
The selected remedy which was outlined in Section IX satisfies
the remedy selection requirements of Section 121 of CERCLA (42
U.S.C. section 9621) and the NCP (40 C.F.R. Section 300.430(e)).
The remedy provides protection of human health and the
environment, achieves compliance with ARARs, utilizes permanent
solutions to the maximum extent practicable, contains treatment
as a principal element, and is cost effective.
A. Protection Qf. flyman Health and the Environment
The selected remedy is protective of human health and the
environment. Engineering, treatment and institutional controls
are utilized to protect public health and the environment.
Excavation of soil and sediment with lead levels above 500 ppm
would encompass the area of soil, sediment, and ash contaminated
with Site-related constituents and compounds at levels of concern
and is the level necessary to be protective of human health and
the environment. Excavation and subsequent treatment and
disposal of this material would eliminate potential exposure to
the hazardous substances released from the Site.
Decontamination, dismantling and/or demolition of Site buildings
with lead levels above 500 ppa, the old furnace, and other
structures, is necessary to protect human health and the
environment. The residual level of excess cancer risk is
expected to be less than IxlO*6 and the residual risk resulting
from Site-related non-carcinogenic constituents and compounds
will have a Hazard Index less than 1. There would be no long-
term impacts on the environment although short-term impacts are
necessary to effect off-Site transportation and disposal and to
improve the pond and stream. No unacceptable cross-media impacts
are expected to occur.
Once remediation is completed, the levels of contaminants of
concern remaining in the soil and sediment exposed at the Site,
i.e., less than 500 ppm lead, will be below risk levels, i.e.,
IxlO*6 excess cancer risk or HI equal to 1 or blood lead level of
10 ug/dL. The amount of contaminants in the treated soil,
sediment, and ash will not be reduced, but potential exposure is
virtually eliminated. Thus, residual risk at the Site will be
acceptable in accordance with the NCP. According to the Lead
Uptake Biokinetic Model, the levels of lead remaining in the soil
and sediment would not result in blood lead levels above 10 ug/dL
in exposed children consistent with EPA policy.
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B. Compliance with Applicable or Relevant and Appropriate
Requirements f ARARs ^ of environmental laws
It is expected that the selected remedy will comply with all
ARARs identified in this ROD. Major ARARs and other non-
promulgated advisories or guidances issued by federal or state
governments that are to-be-considered ("TBC") include:
1) The Pennsylvania Water Quality Standards, 25 PA Code §§ 93.1
et. sag, designate the use of Mill Hopper Creek as a High Quality
(HQ) stream supporting Cold Water Fishes (CWF) . Several
standards relating to this designation are provided. The
standards are relevant and appropriate to the extent that the
Site contributes concentrations of listed contaminants above
ambient background levels.
2) 25 PA Code Chapter 16 establishes limits for concentrations
of Site contaminants which may enter Mill Hopper Creek to the
extent that the Site causes the short- or long-term release of
listed contaminants above ambient background levels.
3) Fish and Wildlife Coordination Act (16 U.S.C. 661
seg.) — requires action to protect fish and wildlife from
actions modifying streams or areas affecting streams. This
statute is relevant and appropriate to Mill Hopper Creek and Pond
sediment remediation.
4) The Clean Water Act, 33 D.S.C. § 1344 and 40 C.F.R. Part
330, establishes requirements for discharge of fill material into
Mill Hopper Creek and wetlands.
5) Archaeological and Historic Preservation Act, 16 U.S.C.
469a-l and 36 C.F.R. Part 65, provides for preservation of
historical and archaeological data that might otherwise be lost
as a result of alterations of the terrain. The National
Histroical Preservation Act, 16 U.S.C. §§ 470 et. sea. 36 C.F.R.
Part 800 provides for the protection of places which may be
eligible for listing on the National Register of Historic Places
(NHRP) . The Phase IB Archeological Survey will determine if
historic or cultural features at the Site exist and may be
impacted by the remedy.
6) Fugitive dust emissions of lead and particulate matter
generated during implementation of the selected remedy comply
with National Primary and Secondary Ambient Air Quality
Standards, 40 C.F.R. Part 50. These standards are applicable
requirements. EPA expects that the Remedial Action will not be a
"major" source of emissions, i.e., greater than 250 tons/year.
Measures shall be taken to prevent fugitive emissions. The
Commonwealth of Pennsylvania implements regulation of air quality
pursuant to Sections 107 and 110 (a) (2) of the Clean Air Act.
Fugitive dust emissions generated during remedial activities will
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comply with regulations in the Commonwealth of Pennsylvania, 40
C.F.R. Part 52, Subpart HN.
7) Pennsylvania's Air Pollution Control Act, 25 PA Code §§
123.1 et. sea, and §§ 131.1 et. seg., limit fugitive emissions
from the Site and establishes standards for particulate matter
and lead.
8) Treatment, i.e., stabilization of contaminated sediment,
soil, and ash shall comply with the regulations in 25 PA Code
264, Subchapters A-E, Subchapter I, and Subchapter J.
9) The diversion of Mill Hopper Creek during implementation
shall comply with the Pennsylvania Bureau of Dam Safety and
Waterways Encroachments Act of 1978, P.L. 1375, as amended. 32
P.S. §§ 693.1 et. seq. and the Pennsylvania Dam Safety and
Waterway Management Regulations, 25 PA Code § 105.1 et. sea.
10) Any storage and/or transportation of hazardous wastes from
the Site shall be performed in accordance with 25 PA Code
Chapters 262 and 263.
11) Consolidation or excavation of soil would comply with
erosion control requirements of Pennsylvania's Erosion Control
Regulations, 25 PA Code § 102.1 et. sea.
12) To the extent that material must, be excavated or mined to
replace soil removed from the Site, the borrow activity would
consider the requirements of the Pennsylvania Bureau of Mining
and Reclamation, 25 PA Code § 77.1 et. seq.
13) Potential discharges of water during remedial activity in
Mill Hopper Creek and Pond shall comply with the Pennsylvania's
Water Quality Standards, 25 PA Code §§ 93.1 fit,. 553. The
selected remedy shall not impair the ability of the stream to
maintain or propagate cold water habitat fishes pursuant to 25 FA
Code §§ 93.3 through 93.8, considering the ambient background
water quality of Mill Hopper Creek and pond pursuant to 25 PA
Code § 93.5.
14) Potential discharges of water during remedial activity in
Mill Hopper Creek and Pond shall comply with the water quality
criteria for toxic substances of 25 PA Code Chapter 16,
considering the ambient background water quality of Mill Hopper
Creek and Pond.
15) The selected remedy 'shall include ground water monitoring
pursuant to substantive requirements of 25 PA Code §§ 288.251
through 288.258.
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16) Any on-Site discharge of water generated from the
stabilization or decontamination activities shall comply with the
substantive requirements of the Clean Water Act NPDES
regulations, 40 C.F.R. §§ 122.41-122.50, Pennsylvania NPDES
regulations, 25 PA Code §§ 92.31, and the Pennsylvania Wastewater
Treatment Regulations, 25 PA Code §§ 93.1-93.9.
17) The Occupational Health and Safety Act (OSHA), 29 C.F.R.
Parts 1904, 1910, and 1926, provides occupational safety and
health requirements for workers involved in field construction or
operation and maintenance activities.
TBC : .*" "--• -
1) EPA OSWER Directive 19355.4-02 — Recommends a soil cleanup
of 500 to 1000 ppm for soil in residential setting.
2) Executive Order 11593 "Protection of and Enhancement of the
Cultural Environment* — Requires that historic and cultural
properties are not substantially altered. The results of the
Phase B Archeological Survey will ensure that potentially
significant cultural resources are not substantially altered or
destroyed.
3) DOI Criteria for Inclusion in the National Register of
Historic Places (36 C.F.R. § 60.4) — The Phase IB
Archeological Survey will identify if cultural or historic
resources at the Site exist and will recommend additional study,
as needed, to determined if these resources are eligible for
inclusion on the National Register of Historic Places.
4) Rivers and Harbors Act (33 U.S.C. 403) — applies to
dredging from navigable waters. Removal of contaminated sediment
from Mill Hopper Creek shall consider the requirements of the
River and Harbors Act.
5) Determinations about the effectiveness of soil remediation
at the Site will be based on EPA 230/02-89-042, Methods for
Evaluating Cleanup Standards. Vol. It Soils and Soil Media.
6) Section 121(d)(3) of CERCZA, 42 U.S.C. § 9621(d)(3) and EPA
OSWER Directive I 9330.2-07 ("Off-Site Policy") concerning the
off-Site disposal of hazardous substances from Superfund Sites.
7) Abandoning wells shall be completed in accordance with
minimum requirements of 25 PA Code 109.602(c) and consistent with
PADER's Public Water Supply Manual, Part II, Section 3.3.5.11.
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C. goafc Effectiveness
The selected remedy is cost effective. The estimated present
worth cost of the selected remedy is $11,985,717 plus the costs
of toxicity testing, well abandonment, stream monitoring and
Phase IB Archeological Survey (common to all alternatives except
Alternative 1) . The elements in the soil, sediment, and ash can
not be destroyed. Off -Site disposal does not provide a reduction
in risk beyond that provided by Alternative 5, but rather
transfers minimal risk to a new location for an additional cost
of approximately $ 4.6 million. EPA believes that the selected
remedy will eliminate the risks to human health and the
environment at the Site, therefore the selected remedy provides
an overall benefit proportionate to its costs such that it
represents a reasonable value for the money that will be spent.
D. Utilization of Permanent Solutions and Alternative Ty?atB?n.t
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost effective manner to
control contamination at the Site. Of those alternatives
evaluated that are protective of human health and the environment
and meet ARARs, the selected remedy provides the best balance
with regard to long-term and short-term effectiveness and
permanence, cost., implementability, reduction in toxicity,
mobility, or votume through treatment, also considering the
statutory preference for treatment as a principal element and
considering State and community acceptance.
The selected remedy utilizes permanent solutions to the
extent practicable. The elements contaminating the soil,
sediment, and ash can not be destroyed to totally eliminate the
potential risk posed. However, stabilization of the soil,
sediment, and ash. eliminates the risk associated with ingest ion.
stabilization permanently reduces mobility of the contaminants
and the toxicity of the contaminants as demonstrated by the TCLP
testing. The remedy also relies on containment and long-term
management of the treated material.
E. Preference for Treatment as a Principal Element
By stabilizing the soil, sediment, and ash, the selected remedy
satisfies the statutory preference for treatment as a principal
element. The selected remedy addresses the principal threat
posed by the Site through the use of treatment technologies.
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XX. Documentation of significant Differences
This section of the ROD discusses the changes made to the
preferred remedy. In certain instances, this section simply
clarifies intended components of the preferred remedy described
in the Proposed Plan.
The Proposed Plan, released for public comment on April 24, 1992,
identified Alternative 6 as EPA's preferred alternative. EPA, in
consultation with PADEH, decided to select a remedy that requires
off-Site disposal of the stabilized soil, sediment, and ash
(Alternative 5) rather than disposal into an on-Site containment
cell (Alternative 6}.
During the public comment period, EPA was able to evaluate the
two modifying criteria, state and public acceptance. The
comments reviewed from the community in which the Site is located
were strongly in favor of off-Site disposal of the stabilized
material. The Commonwealth of Pennsylvania has stated that it
cannot concur with the construction of an on-Site containment
cell until more information concerning the design of the on-Site
containment cell is available to ensure compliance with
Pennsylvania's residual waste management regulations, although no
current information prevented the location of a containment cell
at the Site. EPA believes that Alternative 6 (on-Site
containment cell), if implemented in accordance with State ARARs,
will satisfy the requirements of Section 121 of CERCLA, 42 U.S.C.
S 9621.
EPA has selected off-Site disposal of stabilized soil, sediment,
and ash. Within 180 days of issuance of this ROD, the PRPs may
submit to EPA information demonstrating that the on-Site
containment cell (Alternative 6), can provide an equally or more
protective remedy which is cost effective and complies with all
ARARs. If EPA preliminarily determines that an on-Site remedy is
equally or more protective than the remedy selected in this ROD
and that an on-Site remedy is cost effective and complies with
all ARARs, EPA will solicit public comment before making a
decision to modify the remedy.
Section VIII ("Comparative Analysis of Alternatives11) of this ROD
presents the full evaluation of all alternatives based upon the
nine criteria identified in the NCP and provides the basis for
the selection of Alternative 5.
Additional changes from the remedial alternative contained in the
Proposed Plan are:
1. Dust control measures will be required. This ROD specifies
a point of compliance for ambient air quality standards.
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2. Post excavation sampling must confirm that all Site-related
contaminants have been addressed.
c
3. Soil sampling shall be required under pavement and buildings
constructed after 1963 (when EPA believes the Site first
operated). The soil need not be excavated if the structures are
maintained such that contaminants within these soils do not
migrate from the Site and do not become available for exposure.
As such, re-paving may be required in some areas and the deed for
Tax Parcel 11 may be restricted.
4. The Phase IB Archeological Survey shall only be conducted in
areas of high or moderate archeological or historical sensitivity
potentially impacted by the remedy, i.e., areas to be excavated
or subject to excessive traffic.
5. The Proposed Plan incorrectly specified the contaminated
soil volume. The volume of contaminated soil to be addressed is
approximately 26,273 yd3 due to a 500 ppm soil lead cleanup
level. This volume of soil was considered in the evaluation of
alternatives, but was mistakenly left out of the Site
description.
6. 2PA expects that any structure or debris inhibiting Site
remediation would be dismantled.
7. Only building surfaces with lead exceeding 500 ppm shall be
remediated. The building surfaces shall be cleaned such that the
remaining concentrations of contaminants are consistent with the
soil cleanup levels, i.e., less than 500 ppm lead.
8. Two feet of pond sediment shall be removed and then a new
pond substrate shall be added. The selected remedy does not
consider removal of all pond sediment above 500 ppm since
exposure to pond sediment beneath the nev pond bottom will be
unlikely (i.e., residential exposure is unreasonable). However,
the remedy specifies a cleanup level of 500 ppm -for all sediment
available for exposure.
9. A fence is not necessary at the Site except to limit access
to any exposed areas where hazardous substances above the cleanup
levels are located.
10. Final Site grading was not included in the FS. Site grading
was considered in the Proposed Plan and was comparatively
evaluated in this ROD. Site grading will ensure that storm water
can be properly managed at the Site and that final slopes do not
promote erosion. Minor Site specific changes may be made to the
remedy as a result of the remedial design and construction
processes.
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