PB95-963906
EPA/ROD/R03-95/195
May 1995
EPA Superfund
Record of Decision:
Centre County Kepone Site
(O.I], 1), State College Borough, PA
4/21/1995
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RECORD OF DECISION
CENTRE COUNTY REPONE SITE
DECLARATION
SITE NAME AND LOCATION
Centre County Kepone Site
state College, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the first operable unit ("OU1") at the Centre County Kepone Site
located in state College, Centre County, Pennsylvania. This
document was developed in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 ("CERCLA"), 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 basis for selecting the
remedial action for this Site. The information supporting this
decision is contained in the Administrative Record for this Site.
The Commonwealth of Pennsylvania concurs with the selection of
this remedy.
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 "Summary of Site Risks", section 6.0, if not
addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE RBMEDY
The Centre County Kepone Site consists of 32.3 acres housing the
Ruetgers-Nease Corporation, which is an active chemical
manufacturing facility, and a portion of the spring Creek
watershed. This operable unit is the first of two operable units
for the site. The remedial action for OU1 will address
contaminated groundwater, surface water, soils, and sediments,
source control measures for surface water discharges, and
additional soil/sediment sampling of the lS-acre.Former Spray
Field Area and riparian areas of Spring Creek~ The groundwater
.and Thornton Spring surface water contamination represent a
significant threat. Therefore, remediation of contaminated
groundwater will be required. Soils and sediments onsite
represent a principal threat that may potentially impact
groundwater quality; therefore, an excavation and offsite
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disposal remedy for source control will be required.
The major components of the Selected Remedial Action for OUl are
as follows:
.
Extraction and treatment of contaminated groundwater with
discharge to the freshwater drainage ditch;
.
Long-term groundwater monitoring;
.
Excavation and offsite disposal of contaminated soils;
.
Surficial soil Sampling of the lS-acre Former Spray Field
Area and the calculation of environmental risks;
.
Improvements to the surface water drainage system in the
plant production area;
.
Engineering controls and hazardous materials management
practices for surface water drainage;
.
Monitoring of surface water discharge from the Site;
.
Excavation and offsite disposal of contaminated sediments;
Fish tissue and stream channel monitoring;
.
.
Onsite and offsite fencing;
.
Deed restrictions; and,
.
Riparian-area Sampling, including the drainage channel of
Thornton spring, Section B of the freshwater drainage ditch,
and downstream of Benner Fish Hatchery, and calculation of
environmental risks.
The second operable unit ("OU2") will address the soils from the
riparian-areas of Spring Creek and the lS-acre former spray field
area, and sediments from the lower portion of the freshwater
drainage ditch and Thornton Spring. EPA's decision regarding OU2
will be presented in a future ROD after the additional data has
been collected and analyzed from these areas.
It may become apparent during implementation or operation of the
groundwater extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the performance standards over
some portion of the area of attainment. If EPA, in consultation
with the Commonwealt~ of Pennsylvania, determines that
implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will be technically impracticable to achieve and maintain the
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performance standards throughout the entire area of attainment,
EPA, in consultation with the Commonwealth of Pennsylvania may
require that any or all of the following measures be taken, for
an indefinite period of time, as further modification(s) of the
existing system:
'a) long-term gradient control provided by low level pumping, as
a containment measure;
b) chemical-specific ARARs may be waived for those portions of
the aquifer for which EPA, in consultation with the Commonwealth
of Pennsylvania, determine that it is technically impracticable
to achieve such ARARs;
c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above performance standards; and
d) remedial technologies for groundwater restoration may be
reevaluated.
The decision to invoke any or all of these measures may be made
during implementation or operation of the remedy or during the 5-
year reviews of the remedial action. If such a decision is made,
EPA shall amend the ROD or issue an Explanation of Significant.
Differences, as necessary.
STATUTORY DBTERMINATIONS
The selected remedies are protective of human health and the
environment; comply with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action; and are cost-effective. These remedies utilize permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and satisfy the
s~atutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because these remedies will result in hazardous substances
remaining at the site, a review by EPA will be conducted within
five years after the initiation of the remedial action, and every
five years thereafter, as required by Section 121(c) of CERCLA,.
42 U.S.C. S 9621(c), to ensure that the remedies provide adequate
protection of human health and the environment.
irector
gement Division
l(/~1 (?S-
Date
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~R309038
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1.0
. 2.0
3.0
4.0
5.0
6.0
RECORD OF DECXSXOH
CENTRE COUNTY REPONE SXTB
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION. .
. . . .
. . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES
........
HIGHLIGHTS OF COMMUNITY PARTICIPATION
. . . .
. . . . .
SCOPE AND ROLE OF RESPONSE ACTION
.......
. . . .
5.1
SUMMARY OF SITE CHARACTERISTICS
. . . . .
5.2
. . .
. . . .
Surface Features, Geology, Soils, Hydrogeology,
Hydrology. . . . . . . . . . . . . . . . . . . . ..
Nature and Extent of Contamination . . . . .
5.2.1 Groundwater. . . . . . . . . . . . . . . .
5.2.2 Thornton Spring. . . . . . . . . . . . . .
5.2.2.1 Thornton Spring Surface Water. . .
5.2.2.2 Thornton Spring Sediment. . . . .
5.2.2.3 Thornton Spring Air. . . . . . . .
5.2.3 Onsite Soils. . . . . . . . . . . . . . . .
5.2.3.1 Onsite Surface Soils. . . . . . .
5.2.3.2 Onsite Subsurface Soils. . . . . .
5.2.4 Freshwater Drainage Ditch. . . . . . . . .
5.2.4.1 FWDD Surface Water. . . . . . . .
5.2.4.2 FWDD Sediment. . . . . . . . . . .
5.2.5 spring Creek. . . . . . . . . . . . . . . .
5.2.5.1 Spring Creek Surface Water. . . .
5.2.5.2 Spring Creek Sediment. . . .
5.2.5.3 spring Creek Fish. . . . . . . . .
5.2.5.4 Spring. creek Benthic
Macroinvertebrate Organisms. . . .
SUMMARY OF SITE RISKS
6.1
6.2
r6.3
6.4
.8 . . . . . . .
. . .
. . .
. . .
Contaminants of Concern. . . . . . . . . . .
Human Health Risk Assessment. . . . . . . . . . .
6.2.1 Exposure Assessment. . . . . . . . .
6.2.1.1 Exposure Setting. . . . . . . . .
6.2.1.2 Exposure Pathways. . . . . . . . .
6.2.1.3 Exposure Scenarios . . . . .
6.2.2 Toxicity Assessment. . . . . . . . . . . .
6.2.3 Risk Characterization. . . . . . . . . . .
6.2.3.1 CUrrent Use Scenario. . . .
6'.2.3.2 Future Use Scenario. . . . . . . .
Environmental Risk Assessment. . . . . . . . . . .
Conclusion. . . . . . . . . . . . . . . . .
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7.0
REMEDIAL OBJECTIVES
. . . .
. . . . . . . .
. . . . . .
7.1 Remedial Objectives for Groundwater and
Thornton spring Surface Water . . . . . . . . . . .
7.2 Remedial Objectives for Onsite Soil . . . . . . . .
7.3 Remedial Objectives for Freshwater Drainage
Ditch Surface Water . . . . . . . . . . . . . . . .
7.4 Remedial Objectives for Freshwater Drainage
Ditch Sediments . . . . . . . . . . . . . . . . . .
7.5 Remedial Objectives for Spring Creek Surface
Water . . . . . . . . . . . . . . . . . . . . . . .
7.6 Remedial Objectives for spring Creek Sediments
8.0
DESCRIPTION OF ALTERNATIVES
. . . . . .
. . . .
. . . .
8.1
8.2
8.3
8.4
8.5
Groundwater and Thornton Spring Surface Water. . .
Subsurface Soils. . . . . . . . . . . . . . . .. .
Freshwater Drainage Ditch Surface Water. . . . . .
Freshwater Drainage Ditch Sediments. . . . . . . .
spring Creek Sediments. . . . . . . . . . . . . .
9.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
. ~ . .
9.1
comparative Analysis of Alternatives for
Groundwater and Thornton Spring Surface Water.. . .
Comparative Analysis of Alternatives for
Subsurface Soils. . . . . . . . . . . . . . . . .
comparative Analysis of Alternatives for
Freshwater Drainage Ditch Surface Water. . . . . .
comparative Analysis of Alternatives for
Freshwater Drainage Ditch Sediments. . . . . . . .
comparative Analysis of Alternatives for
Spring Creek Sediments. . . . . . . . . . . . . .
9.2
9.3
9.4
9.5
10.0
SELECTED REMEDY: DESCRIPTION AND PERFORMANCE STANDARDS
10.1
10.2
10.3
Extraction and Treatment of Groundwater. . . . .
Long-Term Groundwater Monitoring. . . . . . . .
Excavation and Offsite Disposal of
contaminated Soils. . . . . . . . . . . . . . .
Spray Field Surficial Soil Sampling. . . . . . .
Improvements to the Surface Water
Drainage System. . . . . . . . . . . . . . . . .
Engineering Controls and Hazardous Materials
Management for Surface Water Drainage. . . . . .
Monitoring of Surface Water Discharge. . . . . .
Excavation and Offsite Disposal of
Contaminated Sediments. . . . . . . . . . . . .
Fish Tissue and Stream Channel Monitoring. . . .
Onsite and Offsite Fencing. . . . . . . . . . .
Deed Restrictions. . . . ~ . . . . . . . . . . .
Riparian-Area Sampling. . . . . . . . . . . . .
10.4
10.5
10.6
10.7
10.8
10.9
10.10
10.11
10.12
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11.0
STATUTORY DETERMINATIONS
...............
11.1
11.2
11. 3
11.4
11.5
Protection of Human Health and the Environment
compliance with Applicable or Relevant and
Appropriate Requirements. . . . . . . . . . . .
Cost-Effectiveness. . . . . . . . . . . . . . .
Utilization of Permanent Solutions and
Alternative Treatment Technologies to the
Maximum Extent Practicable. . . . . . . . . . .
Preference for Treatment as a Principal Element.
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . .
12.0
. . . .
APPENDIX A - FIGURES
Figure 1:
Figure 2:
Figure 3:
Figure 4:
Figure 5:
Figure 6:
Figure 7:
Figure 8:
Figure 9:
Figure 10:
Figure 11:
Figure 12:
Figure 13:
Figure 14:
Site and Study Area Location Map
Onsite Areas
. Monitoring Well Map
Groundwater Sampling Results - Rounds 1 and 2
Groundwater Sampling Results - Rounds 2A and 3
Thornton Spring sampling Results
Phase I and II Surface Soil Sampling Results
Phase I and II Depth Discrete Sampling Results
Phase I spring Creek Surface Water and Sediment
Sampling Results
Phase II Spring Creek Surface Water and Sediment
Sampling Results
Phase I Fish Tissue Mirex/Kepone Results
Soil Excavation Areas
Example Decision-tree for Disposition of Soils and
Sediments
Former Spray Field Area
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76
77
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Table 1:
APPENDIX B - TABLES
Table 2:
Table 3:
Table 4:
Table 5:
Table 6:
Table 7:
Table 8:
Tabl.e 9:
Table 10:
Table 11A:
Table 11B:
Table llC:
Table 11D:
Table 11E:
Summary of Groundwater sampling Results
Summary of Surface Water Sampling Results
Summary of Sediment sampling Results
Summary of Surface Soil Sampling Results
Summary of Deep Soil Sampling Results
Contaminants of Concern
Potential Exposure Pathways
Summary of Risk Scenarios and Estimates
Soil and Sediment Cleanup Levels
Remedial Alternat~ves Estimated Costs
Estimated Costs for GW/TS-3
Estimated Costs for SS-2
Estimated Costs for FWDD/SW-2A
Estimated Costs for FWDD/SED-2
Estimated Costs for SC-2
APPEND~X C - RESPONSIVENESS SUMMARY
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RECORD OF DECISION
CENTRE COUNTY REPONE SITE
DECISION SUMMARY
1.0
SITE NAME, LOCATION, AND DESCRIPTION
The Centre County Kepone Site (lithe Site") consists of an
approximate 32.3 acre property housing the Ruetgers-Nease
corporation, an active chemical manufacturing facility, and a
portion of the Spring Creek watershedl. The Ruetgers-Nease
facility is located in College Township, Centre County,
Pennsylvania. The Site is situated on Struble Road off of
Pennsylvania State Highway 26 approximately 2\ miles northeast of
the Borough of State college and 800 feet south of the
intersection of Pennsylvania State Highways 26 and 150. The
Centre County Kepone Study Area (lithe Study Area") includes
Thornton Spring and that portion of Spring Creek from the Village
of Lemont (where Thornton Spring is located) to the Pennsylvania.
Fish Commission (PFC) Benner Spring Research Station~ (See
Figure 1).
The Ruetgers-Nease facility is adjacent to the southeastern side
of a local Pennsylvania Railroad spur. A variety of facility
buildings and structures presently occupy the northern portion of
the site which is mostly covered by asphalt pavement and
concrete. These buildings and structures include processing
buildings, storage buildings, a tank farm, a groundwater
treatment facility, and an administrative building. The southern
and southwestern portions of the facility are primarily grassed
areas not currently used in the manufacturing operations. A
freshwater drainage ditch, which receives limited storm water
runoff and treated water from the groundwater treatment facility,
runs along the western boundary of the Site, crosses under PA 26,
and enters spring Creek immediately downstream from PA 26. (See
Figure 2).
~he area immediately surrounding the site is a combination of
commercial/industrial, retail, and residential properties. Just
north of the Pennsylvania Railroad spur is a lumber and
construction supply warehouse. Northwest of Route 26 are a
variety of retail stores and restaurants. Immediately southwest
of the site is a concrete manufacturer, an automobile salvage
1 - The "Site" is defined as all areas impacted by
contaminants originating from the Ruetgers-Nease plant, and
currently includes all of the plant area, the area underlain by
impacted groundwater, Thornton Spring, and Spring Creek from the
village of Lemont to the Pennsylvania Fish Commission Research
station.
. 1.
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yard, and gasoline service stations. Southeast of the Ruetgers-
Nease administration building, along Struble Road and Clyde
Avenue, is an automobile repair shop and a small manufacturing
facility. Residential dwellings are located along the southeast
side of First Avenue. Land use in the study Area is primarily
agricultural and recreational. According to the Centre County
Regional Planning Commission, the 1990 population in College
Township was 7,620, with a projected population of 8,400 by 1995.
Public water is supplied throughout the surrounding area by the
Lemont Water Company.
surface features of the Study Area include Nittany Mountain,
which rises to the southeast of the Site, and Bald Eagle Mountain
which rises across Nittany Valley to the northwest of the site.
spring Creek meanders generally northward through the Study Area
. and Nittany Valley. Nittany Valley ranges in elevation from 800
.to 1,200 feet above mean sea level (MSL), while Nittany Mountain
rises to approximately 2,070 feet, MSL.
- The primary media of concern at the site and study Area are
contaminated groundwater, surface water, soils, sediments, and
fish tissue which present both a carcinogenic and non-
carcinogenic risk to human health. Benzene, 1,2-dichloroethene,
ethylbenzene, tetrachloroethane, tetrachloroethene, toluene,
trichloroethene, vinyl chloride, xylenes, and mirex are the
chemicals which contribute most to potential future carcinogenic
and non-carcinogenic risks.
There are also potential risks to ecological receptors at the
Site and Study Area. Levels of mirex and kepone in soil of the
former spray field area, and sediments of the drainage ditch,
Thornton spring, and Spring Creek exceed the criteria that EPA
has determined are protective of ecological receptors. However,
these areas were not fully characterized during the RIfFS process
and will require further investigation to determine the extent of
contamination and potential risks to ecological receptors.
2.0. SrTE HrSTORY AND BHFORCEMBHT ACTrvrTrBs
From 1958 through 1977, the 32.2 acre Site was owned and operated
by Nease Chemical Company, Inc. (Nease Chemical or Nease). As of
December 30, 1977, Nease Chemical Company, Inc. including the
site, was acquired by and merged with Ruetgers Chemicals, Inc.
The company resulting from the merger is Ruetgers-Nease Chemical
Company, Inc. (Ruetgers-Nease). Ruetgers-Nease has owned and
operated the site continually since December 1977.
Since the beginning of operations at the Site in 1958, a variety
of organic chemicals have been produced, many with specialized
applications, including products and intermediates utilized in
the soap and detergent industry, in the manufacture of
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pharmaceutical products, in the agricultural chemical industry,
in metal plating, and in the manufacture of plastics. The
primary organic raw materials used in the production of
intermediates and products include, but are not limited to,
benzene, methanol, perchloroethylene, tetrachloroethane, toluene,
and xylene.
Two organic compounds of particuiar interest which were
manufactured as custom products at the Ruetgers-Nease facility
are kepone (chlordecone) and mirex (dodecachloropentacylodecane).
Kepone was produced at two different time periods between 1959
and 1963. Mirex was manufactured at the facility from 1973
through 1974.
In the early 1960's, Nease began onsite waste disposal by
utilizing earthen lagoons. On February 22, 1960, Nease was
notified that a chemical odor was emanating from Thornton Spring.
As a result, an inspection was conducted by the Pennsylvania
Department of Health (renamed the Pennsylvania Department of
Environmental Resources (PADER) in 1971) on June 10, 1960 which
indicated that the lagoons may be the.cause of the spring odor.
As a corrective action, a concrete lagoon was constructed in 1962
and in 1963 an earthen lagoon was macadamized with asphalt.
These lagoons served as combined neutralizing and settling
basins, where lime was added to the wastewater. The treated
water was then sprayed on an open grassy area at the southern end
of the Site identified as the Former Spray Field.
During 1969, several investigations of Site geology and dye tests
were conducted by PADER to determine if water infiltrating from
the spray field was impacting the water discharging at Thornton
Spring. Investigations revealed that the spring waters were
impacted by the spray field. PADER recommended the spray field
be discontinued and requested Nease to schedule actions to
prevent further discharges to Thornton Spring. Soon after, Nease
complied with this recommendation.
In May 1972, following a bioassay of the water in the lagoons,
PADER ordered Nease to perform in-situ treatment of the
wastewater and sludge in the concrete and earthen lagoons using a
process called Chemfix. In addition, PADER ordered that tne
contents of the asphalt impoundment be disposed of and the
asphalt and earthen impoundments backfilled. Nease complied .with
PADER's requirements for waste treatment and disposal by November
1972, and subsequently backfilled the asphalt and earthen
lagoons. Since April 1972, Nease and Ruetgers-Nease have
disposed of waste materials at offsite disposal facilities.
In November 1977, PADER issued an Administrative Order to Nease
for the preparation and submittal of a plan to investigate
potential environmental impacts at the site and to abate
discharges of industrial wastes.
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Numerous subsequent investigations were carried out at the Site
and Study area from the mid-1970's through the 1980's by various
State and Federal agencies, Nease, and Ruetgers-Nease. Based on
the findings of the investigations, PADER issued a Supplemental
Order to Ruetgers-Nease in June 1981. The Supplemental Order"
required Ruetgers-Nease to remove and dispose of contaminated
soil and solid waste material from the chemfixed lagoons and the
former drum storage area, to restore the groundwater contaminated
with organic chemicals and solvents and to conduct extensive
groundwater monitoring to determine the effectiveness of the
cleanup and the presence of any other contaminants.
In August 1981, Ruetgers-Nease submitted a plan for groundwater
rehabilitation to PADER followed by an application for approval
to construct and operate a groundwater treatment facility. PADER
granted approval for the construction of the groundwater
treatment facility in April 1982. Ruetgers-Nease initiated
construction in October 1982, and commenced operations in
November 1982.
In June 1982, Ruetgers-Nease submitted an engineering plan to
PADER for removal of Chemfix material. Excavation and removal of
the Chemfix material was initiated in October 1982. In July
1983, Ruetgers-Nease submitted a closure proposal for the former
Chemfix lagoons, which was approved by PADER in September and by
EPA in October of 1983.
EPA proposed the Site for inclusion on the National Priorities
List (NPL) on December 1, 1982 and placed it on the NPL on
September 8, 1983.
In October 1985, PADER issued a notice letter to Ruetgers-Nease
requesting a Work Plan for conducting a Remedial
Investigation/Feasibility Study ("RI/FS") at the Site. In
1986, while discussions concerning the content of the Work
were pending, oversight of cleanup activities under CERCLA
transferred from PADER to EPA.
May
Plan
were
On March 9, 1988, a Special Notice Letter was issued to Ruetgers-
Nease advising the company of their potential liability for
CERCLA response actions at the site. In November 1988, Ruetgers-
Nease entered into an Administrative Order on Consent (AOC) with
EPA whereby Ruetgers-Nease agreed to perform an RI/FS with EPA
oversight. Based on the findings of previous investigations, a
Remedial Investigation site Operations Plan (RISOP) was written
which detailed the scope of work for the RI. "Phase I of the RI
was conducted between September 1990 and July 1991, and Phase II
was conducted between October 1991 and May 1992. The Final RI
Report, which included the Baseline Risk Assessment, was
submitted to EPA in December 1992.
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The RI and FS Reports were conditionally approved on March 26,
1993 and September 27, 1994, respectively. EPA developed the
Proposed Remedial Action Plan ("Proposed Plan") for the site
based on the findings of the RI and FS Reports.
On October 3, 1994, EPA released the Proposed Plan for the Site
and provided a 30-day public comment period ending November 1,
1994. A request for 30-day extension of the comment period was
granted by EPA and public comments were accepted until December
1, 1994.
Based on comments received during the public comment period, EPA
revised the Proposed Plan to include cleanup levels for soil and
sediment. The public comment period was reopened for ,30 days
beginning on January 27, 1995 and ending on February 25, 1995.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community interest and concern about the site has been steady
throughout EPA involvement. EPA and the State cqnducted an
initial public meeting in state College, Pennsylvania on
September 11, 1990 to inform residents of the cleanup process and
activities which would take place at the Site. On September 6,
1991, a Technical Assistance Grant ("TAG") of $50,000 was issued
to a local citizens' group for the purpose of hiring an
independent technical consultant to assist the group in
understanding and commenting on technical documents for the Site.
However, the grant was terminated on August 15, 1992 because the
TAG recipient was dissolved. EPA issued a Fact Sheet which
provided the results of the Phase I Remedial Investigation and
outlined Phase II activities in May of 1992.
Pursuant to CERCLA S 113(k) (2) (B) (i)-(v), the RI/FS reports and
the Proposed Plan for the Centre County Kepone Site were released
to the public for comment on October 3, 1994. These documents
were made available to the public in the Administrative Record
located at the EPA Docket Room in Region III's' Philadelphia
office, and the Schlow Memorial Library in State College,
Pennsylvania. The notice of availability of these documents was
published in the Centre County Times on October 3 and Octob~r 17,
1994. .
A public comment period on the documents was held from October 3,
1994 to November 1, 1994. A request for a 30-day extension to
the public comment period was made on October 27, 1994. As a
result, the closing date for the public comment period was
extended to, December 1, 1994. In ~ddition, a public meeting was'
held on October 19, 1994. At this meeting, representatives from
EPA answered questions about conditions at the Site and the
remedial alternatives under consideration.
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Based on comments received during the public comment period, EPA
revised the Proposed Plan to include cleanup levels for soil and
sediment. A public comment period on the revised Proposed Plan
was held from January 27, 1995 to February 25, 1995. The notice
of availability of the revised Proposed Plan was published in the
Centre County Times on January 27 and 28, 1995. The responses to
all comments received during the public comment periods are
included in the Responsiveness Summary, which is part of this
Record of Decision ("ROD").
This decision document presents the selected remedial action for
the first operable unit ("OU1") at the Centre County Kepone site
in State College, Pennsylvania,. chosen in" accordance with CERCLA,
SARA, and, to the extent practicable, the National oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300. The selection of the remedial action for this site is
based on the Administrative Record.
4.0
SCOPE AND ROLE OF RESPONSE ACTION
The Centre County Kepone site has been divided into two operable
units (OUs) , or site components, in order to simplify and
expedite action at the Site.OU1 will. address the contaminated
groundwater and surface water, contaminated soils (excluding the
15-acre Former Spray Field Area) and sediments on the Ruetgers-
Nease property, and the sediments in spring Creek. These media
also pose some of the principal threats to human health and the
environment from the site. OU2 will consist of remedy selection
for soils from the riparian-areas of Spring Creek and the 15-acre
Former Spray Field Area, and sediments from the lower portion of
the freshwater drainage ditch and Thornton Spring. This approach
to remediation will allow for expedited action to address the
health threats while further study of soil and sediment cleanup
alternatives is completed. .
The remedy for OU1 will comprehensively address the threats posed
by the release of hazardous substances at the Site. The
principal threats posed by the Site are due to VOC contamination
in the groundwater and surface water, mirex in fish tissue, and
mirex and VOC contamination in soils and sediments. The .
groundwater aquifer is classified as a Class I aquifer - Special
Ground Water. This designation is for groundwater of
particularly high value since this aquifer is highly vulnerable
to contamination and is ecologically vital. The primary risks to
human health and the environment are from: 1) ingestion and
inhalation of, and dermal contact with groundwater from wells
that contain contaminants above the Maximum Contaminant Levels
("MCLs") established by the Safe Drinking Water Act ("SDWA"); 2)
ingestion of fish from Spring Creek containing mirex and kepone
above FDA action levels; and, 3) ingestion of and dermal contact
with soils. Soils at the Site are also highly contaminated with
6
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VOCs and therefore, represent a principal threat due to the
potential for the VOCs to migrate into the groundwater. In
addition, the levels of mirex and kepone in sediment samples in
the freshwater drainage ditch represent a potential threat to the
environment since they are greater than literature levels
indicative of ecological effects. Consequently, EPA plans to
address these threats by meeting the following goals: 1) to
restore contaminated groundwater to its beneficial use and to
background levels; 2) to mitigate or prevent leaching of
contaminants from soils and sediments to groundwater; 3) to
protect environmental receptors; and, 4) to control surface water
quality at the site.
The first goal, to restore the groundwater to its beneficial use
and to background levels, will be accomplished by extracting the
contaminated groundwater, treating it with a granular activated
carbon ("GAC") adsorption system, and discharging the treated
effluent to the onsite drainage ditch. This goal will .be further
met by the second goal which will be accomplished by excavating
contaminated sediments and soils. The purpose of this action is
twofold: 1) it will prevent the transport of soil and sediment
contaminants into the groundwater in order to protect groundwater
for its beneficial uses and meet applicable or relevant and
appropriate requirements ("ARARS") for the groundwater, and 2) it
will protect environmental receptors in those areas where
environmental risk was demonstrated.
Treatment of contaminated groundwater and removal of the
contaminated sediments and soils will assist in accomplishing the
third goal of protecting environmental receptors. OU2 will
further enhance this goal by addressing the final response
actions for soils from the riparian-areas of Spring Creek and the
15-acre Former Spray Field Area, and sediments from the lower
portion of the freshwater drainage ditch and Thornton Spring.
This decision will be made after .further studies are completed
for. these areas. .
The last goal, to control surface water quality at the Site, will
be met by source control measures. The purpose of this action is
to eliminate groundwater containing contaminants from entering
the onsite drainage ditch. This goal will be accomplished by
making improvements to the existing surface water drainage system
and implementing a surface water drainage control plan and a
hazardous materials management practices program.
5.0
SUMMARY OF SITE CHARACTERISTICS
5.1
Surface Fea~ures. Geoloav. Soils. Bydroaeoloav. Bvdroloqy
Surface Features and Resources. The Study Area lies within the
Spring Creek basin in south-central Centre County. Surface
7
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features include Nittany Mountain, which rises to the southeast
of the Site and Bald Eagle Mountain which rises across Nittany
Valley to the northwest of the Site. Spring Creek meanders
generally northward through the Study Area and Nittany Valley.
Nittany Valley ranges in elevation from 800 to 1,200 feet above
mean sea level (MSL) , while Nittany Mountain rises to
approximately 2,070 feet, MSL. In this locale, topography is
aligned in a prominent southwest to northeast direction,
reflecting the influence of underlying geologic structure and
rock types.
The site includes paved and grassed areas, and buildings and
ancillary facilities operated by Ruetgers-Nease Corporation.
The southern and southwestern portions of the Site are primarily
grassed areas not currently used in the chemical manufacturing
operations.
A freshwater drainage ditch runs along the western boundary of
the Site, crosses under PA Route 26, and enters Spring Creek
immediately downstream from PA Route 26. This ditch is
appropriately characterized as an intermittent drainageway with
minimal bankside vegetation. The banks of the ditch are
moderately-steep and the streambed itself is confined to the
central part of the ditch. Bankside vegetation is almost
entirely restricted to herbaceous plants. Sediments in .the
onsite portions of the ditch are sands and silts with very little
organic carbon, while the downstream section adjacent to PA Route
26 is alternately composed of unconsolidated cobble and sand, and
exposed bedrock. Stream flow in the freshwater drainage ditch is
dependent upon both stormwater runoff and discharges from the
site groundwater treatment facility.
Thornton Spring lies to the southwest of the site. Thornton
spring is a perennial first-order stream that originates from a
groundwater seep at the southern end of Nittany Mountain.
Thornton Spring flows approximately 300 feet before emptying into
spring Creek through a culvert ~nder Pike Street immediately
upstream from PA Route 26. The streambed of Thornton Spring is
two to four feet wide, comprised of unconsolidated sand, gravel,
and cobble, and contains relatively little organic carbon. Land
immediately adjacent to Thornton spring is forested by hardwoods
and a few shrubs, and the lawn of an adjacent private residence
borders the stream before it goes through the Pike Street culvert
and into Spring Creek.
The Spring Creek portion of the Study Area includes spring Creek
and its riparian zone (i.e., floodplain). Spring Creek is a
natural (versus channelized), approximately third-order cold
water stream with a riparian zone that is alternately forested
and maintained as residential lawns. The canopy over Spring
Creek at this location covers 30-40 percent of the stream.
Sediments in the streambed are composed primarily of sand,
8
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gravel, and cobble; a substantial amount of particulate organic
material (i.e., leaf packs, woody debris) is also found.
In addition to fish, waterfowl, and other animals closely tied to
Spring Creek and its tributaries as well as a wide variety of
terrestrial plants and animals inhabit the Spring Creek basin.
For the Spring Creek watershed upstream of Bellefonte, there are
thirty-six (36) plants and animals listed as "Species of Special
Concern" by the Pennsylvania Natural Diversity Inventory (PNDI)
The PNDI listing is inclusive of all federally listed rare,
threatened or endangered species. Of the 36 species of special
concern identified by PNDI, four (4) plants are confirmed to be
present within five (5) miles of State College. These include
the Geyer's Sedge (Carex aeveri, endangered), lupine (LuDinus
Derennis, rare), low serviceberry (Amelanchier humilis,
tentatively undetermined), and gay-feather (Liatris scariosa var.
nieuwlandii, tentatively undetermined). No rare, threatened, or
endangered animal species were identified by PNDI as residing
within five miles of State College.
with the exception of occasional transient species, there are no
federally listed or proposed threatened or endangered species
within the Study Area.
A review of the Historic Resources of Centre County (Centre
Regional Planning Commission, 1982) document was conducted to
determine if historic buildings, s~ructures, or sites were
present within a one mile radius of the Site and Study Area. No
sites are identified within a one-mile radius of the Ruetgers-
Nease manufacturing plant. Eight sites were identified along
Houserville Road or within the vicinity of spring Creek in the
Study Area.
Geology. The Site and Study Area are located in the Valley and
Ridge Physiographic Province of. the Appalachian Mountains in
Central Pennsylvania. This region is characterized by a series
of alternating elongated, high ridges and broad valleys trending
southwest to northeast. This province is characterized by
tightly folded and faulted sedimentary rocks that have been
uplifted and subsequently eroded. Limestone of the Site has
developed solution features typical of karst terrane.
The geologic units underlying the Site are represented by a
structurally duplicated sequence of carbonate rocks of Ordovican
age comprising the Loysburg Group and Bellefonte Dolomite. The
Bellefonte Dolomite, comprised in the Site vicinity by the Tea
Creek and Dale summit Members, is the lowest stratigraphic unit
observed within the limit of investigation. The Tea Creek Member
consists of a medium-light gray, cryptocrystalline dolomite that
varies from finely laminated to massive. The Dale Summit
Sandstone Member occurs below the Tea Creek Member and is
characterized as a fine to coarse grained conglomerate sandstone.
9
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The Loysburg Group overlies the Bellefonte Dolomite. The Loysburg
Group consists of interbedded dark gray limestone, dolomitic
limestone and minor dolomite.
The bedrock beneath the site lies within the northwest limb of
the Nittany Mountain syncline. Bedding planes strike northeast-
southwest, and dip approximately 25 degrees to the southeast
toward the axis of the syncline. A thrust fault, apparently
related to the later stages of the Nittany syncline folding
event, parallels the bedding strike through the site. The
faulting is responsible for the structural duplication of the
major rock units on site.
Soils. The specific soil types identified onsite are the Murrill
gravelly loam, and urban land soils. Two soils within the
Murrill channery silt loam on 3 to 8 percent slopes (MuB) and the
Murrill channery silt loam on 8 to 15 percent slopes (MuC) are
reportedly formed from sandstone colluvium and weathered residue
from underlying limestone. These soils consist of deep, well-
drained soils usually situated on level to moderately steep
slopes along the edges of the limestone valleys.
The urban land soils are soils that have been altered by
excavation, removal, and filling activities. Urban lands soils
exist within most of the fenced/developed areas of the Site.
Depth to bedrock at the Site is variable and typically more than
6 feet. Soil thickness was found to be as much as 25 feet in the
plant production area.
Hydrogeology. Groundwater movement at the site occurs as conduit
and diffuse flow. Conduit flow occurs along bedding-plane
partings and fractures enlarged by sOlutioning. Diffuse flow is
through the rock matrix. Groundwater storage in bedrock occurs
in both the primary porosity of the rock matrix and secondary
porosity, enhanced by sOlutioning. Dissolution features are more
strongly developed in the limestone of the Loysburg Group than in
the Bellefonte Dolomite. The dominant conduit flow is along the
fault which bisects the Site and brings the dolomite east of the
fault in contact with the limestone to the west. High hydraulic
conductivity, or permeability along solutioned zones, functions
'as a drain for the groundwater system; surrounding diffuse flow
zones tend to drain toward the conduit flow zone.
Residual soil overlies the bedrock at the site. Saturation
generally occurs 8 to 10 feet below ground surface. The soil is
not considered an aquifer. The bedrock, where permeable, drains
soils by vertical flow. Lateral flow at the soil-bedrock
interface occurs at competent bedrock, until flow reaches a
weathered or fractured zone. Soil permeability is too low for
soil to completely drain, creating a saturated (perched) zone in
the soil overburden.
10
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Groundwater from the site generally flows toward the southwest,
along a thrust fault which runs northeast to southwest through
the Site. Groundwater flow for the bedrock aquifer, appears to
be controlled by solution cavities and fracture systems.
Solution cavities, or a fracture system appears to be directing
shallow groundwater from the plant area and the geologic contact
into a slightly deeper groundwater zone at the center of the
Site. Groundwater conduit flow moves from the Site towards the
southwest, where it emerges as surface water at Thornton Spring.
Deeper regional groundwater flow systems have not been evaluated.
site Drainage. Site surface drainage via overland flow is
primarily directed by surface drains to the freshwater drainage
ditch along the western boundary of the Site. Surface water
leaves the Site via the freshwater drainage ditch which also
includes treated water from the groundwater treatment facility.
The freshwater drainage ditch crosses under and follows PA Route
26 in a southwesterly direction until it intersects Spring Creek.
5.2
Nature and Extent of contamination
In accordance with the Consent Order signed in 1988, Ruetgers-
Nease performed a RIfFS to assess the nature and extent of
contamination at the Site. They also performed a Risk Assessment
in order to evaluate the human health risks and the environmental
impacts associated with exposure to site contaminants.
The nature and extent of contamination at the site was
characterized by sampling surface soils, subsurface soils,
sediments, surface water, groundwater monitoring wells, ambient
air, and fish tissue.
5.2.1
Groundwater
Four separate groundwater sampling events were conducted during
the two phases of the RI. These sampling events were designated
as Rounds 1, 2, 2A, and 3. Fifteen wells and one sump were
sampled during Round 1. The groundwater samples were analyzed
for Target Compound List (TCL) volatile organics, mirex, and
kepone. During Round 2, seven wells were sampled for the same
list of analytes. Two wells were. sampled during Round 2A, and
were analyzed for TCL volatile organics. Round 3 included
sampling fifteen wells. Eight wells were sampled for TCL
volatile and seven well samples were analyzed for TCL volatile,
mirex, and kepone. Figure 3 identifies the location of existing
and new groundwater monitoring wells.
More than 20 different volatile organic compounds (VOCs),
including mirex and kepone, were detected in groundwater from the
monitoring wells, including several at concentrations that exceed
Maximum contaminant Levels (MCLs) for public drinking water
supplies. The contaminants that are of greatest concern from a
. 11
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human health perspective are benzene, 1,2-dichloroethene,
ethylbenzene, tetrachloroethene (PCE), toluene, trichloroethene
(TCE), vinyl chloride, and xylenes. Mirex and kepone were also
detected in some of the groundwater samples. Figures 4 and 5
indicate the results of sample analyses for Rounds 1/2, and 2A/3,
respectively. Table 1 provides a summary of the groundwater
sampling results.
The analytical results indicate that volatile organic compounds
are present in groundwater beneath the facility. The highest
levels of VOCs detected during the groundwater investigation were
in the two (2) wells located adjacent to the Tank Farm/Building
No.1 area (MW-21S and MW-23S). Total VOCs in MW-21S were
306,400 micrograms per liter (~g/l) during Round 1 and 222,000
~g/l during Round 2. Total VOCs in MW-23S were 409,000 ~g/l
during Round 1. Generally, total VOC concentrations in
groundwater decrease with distance from this area.
The highest concentration of benzene detected in the groundwater
was 18,000 ~g/l in MW-23S. Benzene was also detected in other
monitoring wells further downgradient of MW-23S, at lower
concentrations, but still above MCLs. The concentrations of 1,2-
dichloroethene detected in monitoring wells ranged from 19,000
~g/l in MW-21S to 3 ~g/l in MW-38D. Ethylbenzene was detected at
a maximum concentration of 16,000 ~g/l in MW-23S. PCE was
detected in 13 of 39 samples with concentrations ranging from
6,400 ~g/l in MW-21S to not detected. The highest concentration
of toluene detected in the groundwater was 190,000 ~g/l in MW-
23S. The concentration of TCE detected was the highest in MW-21S
at 78,000 ~g/l. Vinyl chloride was detected at 330 ~g/l in MW-
40D, which is located near Building 8. Xylene concentrations
detected in the monitoring wells ranged from a maximum of 92,000
~g/l in MW-23S to not detected. The contaminants and their
respective MCLs are summarized in the table on the following
page.
The highest concentrations of mirex and kepone detected during
the groundwater investigation were 0.145 ~g/l and i.41 ~g/l.
These levels were found in wells MW-22S and MW-7D, respectively~
certain VOC constituents detected in 'wells adjacent to the Tank
Farm and the Production Area were present at concentrations
greater than 10 percent of the water sOlubility of the
constituent, indicating the possibility of dense non-aqueous
phase liquids (DNAPLS). DNAPLS may be contained within the
cavities and fractures of the karstic bedrock.
5.2.2
Thornton sorina
Thornton Spring and its associated drainage channel to Spring
Creek exhibit turbulent and variable flow. The drainage channel
consists of gravel, cobbles, and boulders lying on the bedrock
12
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,~~~-=~:~.~.~.~.i,i.i.:.:.:.:.;.:.i.:.£.,.'.~.i.:.i.~.i.!.;.:.:.!.!.!.:.!.:.~.!.:.;.~.I.~.I.!.i.~.I,'.:,:.~.~.~,:.i.'...:.:.~.,.'.,.:..,'.,.!,!.!,i.~.!,!,:.'...!.!,!.;,!.i,I...1,'.;,~.!,!,~.!,i.:,~.:,!.i,i.!".:,!..,!.I.!.~
. . . .. . .. ..... .;.".:.:.: ... . .. .........' :~~tt~if:~.}?~~frt)~{f)?~~f:{r::;~:~(ft~t::~:::::i:::::::}~{::ffj/i~~}
Maxiaua
COncentration Monitorin9 SDWA
Chemical Detection Observed Well MCL
Frequency (119/1) observed- (u9/l)
VOLATILE ORGANIC COMPOUNDS
Benzene 16/39 18,000 MW-23S 5
1,2-Dichloroethane 2/39 6 MW-7D 5
1,2-Dichloroethene 17/39 19,000 MW-21S 100
Ethvlbenzene 13/39 16,000 MW-23S 700
Tetrachloroethene 13/39 6,400 MW-21S 5
Toluene 17/39 190,000 MW-23S 1,000
Trichloroethene 20/39 78,000 MW-21S 5
Vinyl Chloride 11/39 330 MW-40D 2
Xylenes 17/39 92,000 MW-23S 10,000
PESTICIDES
Kepone 7/31 1.41 MW-7D
Mirex 10/33 0.145 MW-22S
*
- Indicates where the highest contaminant concentrations were
detected.
surface at places, and small amounts of finely grained sediments.
Flow rates at Thornton Spring vary greatly and have been reported
to be.as high as 3,280 gpm and as low as 38 gpm.
5.2.2.1
Thornton 8Drina surface Water
Four surface water samples were collected from Thornton spring
and the drainage channel that leads to Spring Creek at the
locations shown on Figure 6. Surface water samples TS-l, TS-2,
TS-3, and SW-4 were analyzed for TCL VOCs. In addition, SW-4 was
analyzed for mirex and kepone. VOCs were detected in all surface
water samples with the highest concentrations in the upstream
locations. The total VOCs concentration ranged from 837
micrograms per liter (~g/l) to 2,927 ~g/l. Specific VOCs
detected in surface water included 1,2-dichloroethene,
ethylbenzene, 1,1,2,2-tetrachloroethane, toluene,
13
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trichloroethene, and xylene. Mirex and kepone were detected in
SW-4 at concentrations less than 0.01 ~g/l and 1.0 ~g/l,
respectively. Table 2 provides a summary of the surface water
sampling results from Thornton Spring, and includes the
freshwater drainage ditch, and Spring Creek.
5.2.2.2
Thornton SDrina Sediment
One sediment sample (SED-4) was collected from the Thornton
Spring drainage channel immediately upstream from its confluence
with Spring Creek and analyzed for VOCs, mirex, and kepone.
Specific VOCs detected include 1,1,2,2-tetrachloroethane, 1,1,2-
trichloroethane, 1,2-dichloroethane, and trichloroethene. The
total VOC concentration was 1,807 micrograms per kilogram
(~g/kg). Mirex and kepone were also detected at concentrations
of 626 ~g/kg and 750 ~g/kg, respectively. Table 3 provides a
summary of sediment sampling results from Thornton Spring, and
includes the freshwater drainage ditch, and Spring Creek.
5.2.2.3
Thornton SDrina Air
Air samples were collected on two separate days at three
locations surrounding the Thornton Spring discharge pool and at
one location along Pike Street. See Figure 6 for the sampling
locations. Each sample was analyzed for VOCs. Levels of total
VOCs for samples closest to the mouth of Thornton Spring (A1, A2,
A3) ranged from 43.0 micrograms per cubic meter (~g/m3) to 90.8
~g/m3 during the first round of sampling, while the total VOCs
ranged from 74.3 ~g/m3 to 390.7 ~g/m3 during the second round.
Air sample A4, which was approximately 200 feet from Thornton
Spring, had significantly higher levels of total VOCs during the
first round (1,541 ~g/m3) than during the second round (247
~g/m3). The higher levels of VOCs in the first round air sample
A4 was due to construction activities upwind of the sampling
station.
5.2.3
onsite soils
A site-wide soil gas survey was implemented as a screening tool
to determine relative concentrations of volatile organic
compounds (VOCs)in the shallow subsurface soils. Information
obtained from the soil gas survey was used to establish the
surface soil sampling and discrete-depth soil boring locations.
Over 350 soil gas measurements were taken at the l8-inch depth
and approximately 120 soil gas measurements were taken at the 31-
inch depth. Readings were measured with a photoionization
detector (PID) and a flame ionization detector (FID). The
detection limits for both instruments were 0.5 parts per million
(PPM) of total volatile organic compounds. Neither instrument
had the ability to identify individual compounds in the soil gas.
14
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5.2.3.1
onsite Surface Soils
Eleven surface soil samples
investigation: two samples
kepone; seven were analyzed
analyzed for VOCs.
The highest concentration of total VOCs was detected in the
Former Drum Staging Area at a concentration of 27 micrograms per
kilogram (~g/kg). The specific compounds detected in the sample
included TCE, PCE, and toluene. Mirex was detected in all nine
samples at concentrations ranging from 32 ~g/kg in the Former
Spray Field Area to 4,770~g/kg in the Tank Farm/Building No.1
Area. Kepone was detected in eight of the nine samples
collected. Concentrations ranged from 23 ~g/kg in the Former
Spray Field Area to 1,710 ~g/kg in the Former Drum Staging Area.
near Building No.9. See Figure 7 for the locations and sampling
results for Phase I and II surface soil samples. Table 4
provides a summary of all specific compounds detected in surface
soils.
were collected during the remedial
were analyzed for VOCs, mirex, and
for mirex and kepone; and two were
5.2.3.2
Onsite Subsurface soils
sixteen soil borings were advanced to bedrock during the RI to
characterize the extent of subsurface soil impacts and to augment
the data collected during the surficial soil sampling program.
One to three samples were collected at varying depths from each
boring, and were analyzed for VOCs, mirex, and kepone.
VOCs were detected in fifteen samples, with total VOC
concentrations ranging from 2 micrograms per kilogram (~g/kg) to
2,376,110 ~g/kg. The maximum concentration of VOCs was detected
at a depth range of 222 inches to 234 inches below ground surface
in the area adjacent to the Tank Farm Area (SB-3C). Mirex was
detected in 32 of the 34 samples with concentrations ranging from
0.63 ~g/kg to 42,300 ~g/kg. The maximum concentration of mire x
was detected in the Designated Outdoor Storage Area at a depth of
42 inches to 60 inches below ground surface (SB-SB). Kepone was
detected in 12 of the 34 samples with concentrations ranging from
5.52 ~g/kg to 260,000 ~g/kg. The highest concentration of kepone
was detected in sample SB-16A located in the Former Drum Staging
Area. See Figure S for the locations and sampling results for
Phase I and II surface soil samples. Table 5 provides a summary
of all specific compounds detected in deep soils at the site.
5.2.4
Freshwater Drainaqe Ditch
The Freshwater Drainage Ditch (FWDD) consists of two distinct
sections: Section A and section B. section A includes the
portion of the FWDD from the flow control valve on Ruetgers-Nease
property, upstream to the surface water discharge points.
section B includes the portion of the FWDD from the flow control
15
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valve downstream to the confluence with Spring Creek.
Three surface water discharges from the Ruetgers-Nease facility
comprise the upstream portion of FWDD Section A and include two
surface water discharges from the facility and the treated
groundwater effluent discharge. Following the confluence of
these three discharges, the FWDD consists of an approximately 700
foot long and approximately 3 foot wide channel (the downstream
portion), which then broadens into a sedimentation" basin
(approximately 15 feet wide) immediately upstream of the flow
control valve.
section B of the FWDD is a narrow channel consisting of boulders,
cobbles, and bedrock outcrop. Shallow groundwater discharge may
occur within Section B of the FWDD during wet periods of the
year,. providing intermittent flow.
5.2.4.1
FWDD Surface Water
" " Five unfiltered surface water samples (SW-5-1, SW-5-2, SW-6,
SW-8, and SW-10) were collected from the FWDD during the two
phases of the RI. Each sample was analyzed for VOCs, mirex, and
kepone. Figures 9 and 10 present a summary of these analytical
results.
Three of the five surface water samples were collected in Section
A of the FWDD and had concentrations of total VOCs ranging from
not detected (ND) to 4,533 micrograms per liter (~g/l). Mirex
concentrations from unfiltered samples in this section of the
FWDD ranged from 0.0452 ~g/l to 0.483 ~g/l. Kepone
concentrations in unfiltered samples ranged from ND to 0.0614
~g/l. The upper forked portion of section A contained the
highest concentrations of VOCs.
The two surface water samples collected from Section B of the
FWDD had total VOC concentrations ranging from ND to 4 ~g/l.
Mirex concentrations from the unfiltered samples in section B
ranged from ND at the furthermost downstream location to 0.096
~g/l. Kepone was not detected in either sample.
5.2.4.2
FWDD sediment
Ten sediment samples were collected from eight FWDD locations.
Each sample was analyzed for VOCs, mirex, and kepone, except for
three samples which were analyzed for mirex and kepone only.
Seven of the ten sediment samples were collected in Section A of
the FWDD. VOC concentrations ranged from an estimated
concentration of 13 micrograms per kilogram (~g/kg) to 44,510
~g/kg. Mirex ranged from an estimated concentration of 5.9 ~g/kg
to 6,240 ~g/kg. Kepone concentrations ranged from not detected
(ND) to an estimated concentration of 118 ~g/kg. In general, the
16
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uppermost forked portion of section A exhibited the greatest
concentrations of VOCs, mirex, and kepone.
Three of the ten sediment samples were collected in section B of
the FWDD. VOCs were not detected in any of the samples. Mirex
ranged from an estimated concentration of 61.7 ~g/kg to 224
~g/kg. Kepone concentrations ranged from ND to an estimated
value of 8 ~g/kg.
5.2.5
SDrinq Creek
Spring Creek surface water and sediments were sampled at three
locations (SW/SED-1, SW/SED-2, and SW/SED-3). Fish tissue
samples from species representing upper and lower trophic levels
were collected from these same locations. Figure 9 depicts the
approximate locations and results of the surface water and
sediment sampling effort for Spring Creek.
5.2.5.1
SDrinq Creek Surface Water
Three surface water samples were collected from Spring Creek; one
sampling location was in the vicinity of the Benner Spring Fish
Hatchery (SW1), another in the vicinity of Houserville Park (SW2)
and the last sampling location (SW3) was upstream of Thornton
Spring, Highway 26, and the FWDD.
VOCs were not detected in either the upstream sample or the
furthest downstream sample. The sample in the vicinity of
Houserville Park had a total VOC concentration of 4 ~g/l.
Neither mirex nor kepone were detected in the surface water
samples.
5.2.5.2
SDrinq Creek Sediment
Three sediment samples were collected from Spring Creek during
the.RI at the same times and locations as the surface water
samples. All three samples were analyzed for VOCs, mirex, and
kepone.
VOCs were not detected in the upstream sample and in the sample
collected in the vicinity of Houserville Park. The sample
collected in the vicinity of the Benner Spring Fish Hatchery had
an estimated total VOC concentration of 117 micrograms per
kilogram (~g/kg). Mirex was detected in the downstream samples
at concentrations of 36.9 ~g/kg and 42.4 ~g/kg. Mirex was not
detected in the upstream sample. Kepone was detected in the
downstream samples at concentrations of 48.1 ~g/kg and 18.4
~g/kg. Kepone was not detected in the upstream sample.
Four additional sediment samples were collected during the
Sediment Toxicity Testing Program in 1992. The four sampling
locations were; upstream of Thornton Spring (Se-BACKGROUND),
17
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immediately downstream of Thornton Spring (SC-TS), in the
vicinity of Houserville Park (SC-PARK), and in the vicinity of
the Benner Spring Fish Hatchery (SC-BENNER). See Figure 9 for
approximate locations and sampling results.
The composite totals for estimated VOC concentrations for the
four samples ranged from 3 ~g/kg to 27 ~g/kg. Mirex was not
detected in the upstream sample and the sample immediately
downstream of Thornton spring. Mirex was detected at a
concentration of 72.4 ~g/kg in the vicinity of Houserville Park
and 26.9 ~g/kg in the vicinity of the Benner Spring Fish
Hatchery. No kepone was detected in any of the sediment samples.
5.2.5.3
Sorina Creek Fish
During Phase I of the RI, three Spring Creek fish tissue samples
were collected at the same locations as the surface water and
sediment locations. Fish tissue samples were collected from
upper trophic level (brown trout) and lower trophic level (slimy
sculpins) and analyzed for mirex and kepone. Figure 11 provides
an approximate location of where the fish tissue samples were
collected and their sampling results.
Mirex was detected in all the upper trophic level fish tissues at
the three sampling locations. Concentrations ranged from 15.5
~g/kg (upstream sample location) to 170 ~g/kg (downstream at
Houserville Park). Kepone was not detected in the upper trophic
level tissues.
Mirex was detected in all the lower trophic level fish at the
three sample locations. Concentrations ranged from 110 ~g/kg
(upstream sample location) to 330 ~g/kg (downstream at
Houserville Park). Kepone was detected in the lower trophic
levels at the three sampling locations. The concentrations of
kepone ranged from 330 ~g/kg (upstream sample location) to 550
~g/kg (downstream at Houserville Park).
Concentrations of mirex and kepone in fish tissues from Spring
Creek have been measured since 1976 in various historical studies
conducted prior to the RI. Fish downstream of the Route 26
bridge have exhibited levels of kepone and mirex in excess of FDA
advisory limits for edible portions (fillets). Fish tissue
levels have decreased over the years, however, mirex and kepone
levels still exceed the FDA advisory limit of 100 ~g/kg and 300
~g/kg, respectively.
5.2.5.4
Sorina Creek Benthic Macroinvertebrate Oraanisms
As stated in section 5.2.5.2, four additional sediment samples
were collected during the Sediment Toxicity Testing Program in
1992. These samples were used for a 14-day solid phase toxicity
testing on two organisms: the midge Chironomus tentans and the
18
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amphipod Hyalella azteca. The sediment samples were not toxic to
H. azteca amphipods in the 14-day sediment toxicity tests, based
on the ,survivability data in 14-day sediment toxicity tests with
the Spring Creek sediments. The sediment sample testing also did
not result in any significant mortality to c. ten tans midges,
based on the survivability results. There were statistically
significant differences in growth for c. tentans in some of the
treatment levels for the sediment samples compared to the growth
of the midges in,the reference sediments. Given the current
state of knowledge regarding sediment bioassays, the ecological
significance of this is uncertain.
6.0
SUMMARY OF SITE RISKS
A baseline Risk Assessment was prepared in order to identify and
define possible existing and future health risks and potential
environmental impacts associated with exposure to the chemicals
present in the various environmental, media at the Site if no
action were taken. The baseline Risk Assessment provides the
basis for taking action and indicates the exposure pathways that
need to be addressed by the remedial action. The baseline Risk
Assessment can be found in the Remedial Investigation Report
(Appendix K). '
6.1
contaminants of Concern
A total of twenty-nine (29) chemicals, including VOCs, mirex, and
kepone were detected in the environmental media sampled during
Phase I and II of the Remedial Investigation. Although many of
the detected substances were found not to contribute
significantly to overall public health, the risk assessment
considered risks from all detected chemicals (i.e. all chemicals
were considered of potential concern). A summary of all
chemicals of potential concern are presented in Table 6.
6.2
Human Health Risk Assessment
6.2.1
ExDosure Assessment
The objectives of the exposure assessment is to estimate the
amount of each chemical of potential concern at a site that is
actually taken into the body (i.e. the intake level or dose).
The primary components of the exposure assessment include a
characterization of the exposure setting, a pathway analysis,
identification of possible exposure conditions, and an estimation
of exposure. The results of the exposure assessment are combined
with chemical-specific toxicity information to characterize
potential risks. '
19
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6.2.1.1
ExDosure settinq
Potential exposures under both current and future land uses of
the study area were evaluated in the Baseline Risk Assessment.
The following populations have been identified as having the
potential to be exposed to chemicals of potential concern
originating from the Site under both the current and future
exposure scenarios:
.
Offsite residents within the Study Area (i.e., Thornton
Spring and Spring Creek);
Onsite workers (both episodic and daily workers);
Trespassers to the Site; and,
Recreational visitors, who are assumed to engage in
activities in and along Spring Creek.
.
.
.
In addition to the above populations, an analysis of the future
onsite residential use of the Site was considered for the Risk
Assessment.
6.2.1.2
ExDosure Pathways
A complete exposure pathway consists of the following elements:
(1) a chemical source or a mechanism for contaminants to be
released into the environment; (2) a medium through which
contaminants may be transported, such as water, soil, or air; (3)
a point of actuai or potential contact with contaminants
(exposure point); and (4) a route or mechanism of exposure, such
as ingestion, inhalation, or dermal contact at the exposure
point. Both current exposure pathways and potential future
exposure pathways were evaluated in the Risk Assessment.
As noted in Section 5.2, above, the nature and extent of
contamination at the Site was characterized by sampling surface
soils, subsurface soils, sediments, surface water, groundwater
monitoring wells, ambient air, and fish tissue.
The following potential exposure pathways were evaluated in the
Risk Assessment:
.
Use of groundwater as a drinking water source by an offsite
resident under a hypothetical future land use of the Study
Area. Potential exposure is assumed to be via ingestion of
groundwater, dermal contact with groundwater, and inhalation
of vapors from groundwater during showering. Potential
exposure of children was considered for ingestion of
groundwater and soil.
.
Direct contact with surface soil and
onsite resident under a hypothetical
Site. Potential exposure is assumed
groundwater and soil, dermal contact
groundwater by an
future land use of the
to be via ingestion of
with groundwater and
20
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.
soil, and inhalation of vapors from groundwater during
showering. Potential exposure of children was considered
for ingestion of groundwater and soil.
Direct contact with offsite surface water and sediment
during activities such as fishing and wading. During these
activities, potential exposure would be via incidental
ingestion of and dermal contact with surface water and
sediment. Populations potentially exposed via these
pathways are assumed to be recreational visitors and
residents (at Thornton Spring). These pathways are assumed
for both the current and future land use scenarios.
.
Direct contact with surface soil by offsite (floodplain)
residents along Spring Creek. Surface soil concentrations
along Spring Creek were assumed to be the same as sediment
concentrations found at Thornton Spring. Potential exposure
of children was considered for incidental ingestion of soil.
.
Direct contact with subsurface soil by onsite workers during
episodic construction/excavation activities. Potential
exposure is assumed to be via incidental ingestion of and
dermal contact with deep onsite soils. These pathways could
occur under both current and future land use scenarios.
.
Direct contact with surface soils by daily onsite
(maintenance) workers as part of their regular activities.
Potential exposure is assumed to be via incidental ingestion
and dermal contact with surface soils onsite.
.
Direct contact with surface soil, surface water, and
sediment by a trespasser at unfenced portions of the Site
(spray field area). Potential exposure is assumed to be via
incidental ingestion of and dermal contact with soil, .
surface water, and sediment. These pathways were assumed
for both the current and future land use scenarios.
.
Inhalation of airborne chemicals volatilizing from Thornton
Spring by offsite residents. This pathway was assumed for
both the current and future land use scenarios.
.
Ingestion of fish caught in Spring Creek. A fish advisory
imposed by the Pennsylvania Fish and Game Commission,
limiting local fishing to catch-and-releaseonly, has been
in effect within the Study Area since 1982. The future use
scenario assumes that the fishing advisory is no longer in
place and concentrations in fish remain at the current
levels.
.
Ingestion of beef that may have been raised in the vicinity
of Spring Creek near Houserville Park.
21
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Table 7 summarizes the pathways of exposure that exist for the
current and future uses within the Site and Study Area.
6.2.1.3
ExDosure scenarios
The exposure assessment identified potential exposure pathways.
six populations were identified as having the potential to be
exposed to chemicals originating from the Site under both current
and future land use exposure scenarios.
For current exposure scenarios, the following populations and
pathways were identified:
.
Offsite residents, assumed to be exposed to chemicals in
surface water and sediment from Thornton Spring and to
airborne vapors emanating from the spring;
.
Offsite residents in the floodplain area, assumed to be
exposed to sediments from Spring Creek and to ingestion of
locally-raised beef; . .
.
Onsite episodic worker, assumed to be exposed to chemicals
in subsurface soil during construction or excavation
activities;
.
Onsite daily worker, assumed to be exposed to surface soils
as part of maintenance activities conducted at the Site;
.
Trespassers, assumed to be exposed to chemicals in surface
soil on the unfenced spray irrigation area of the site and
to chemicals in surface water and sediment in the freshwater
drainage ditch; and
.
Recreational visitors, assumed to be exposed to chemicals in
surface water and sediment from Spring Creek.
Under the future land use scenario, all of the above exposure
pop~lations and pathways were assessed. In addition, the
following populations and pathways were considered:
.
Offsite resident, assumed to be exposed to groundwater used
as a domestic water supply (via ingestion, dermal contact,
and inhalation of vapors during showering); and.
.
Recreational visitors, assumed to consume fish caught in
spring Creek.
.
Onsite resident, assumed to be exposed to groundwater used
as a domestic water supply (via ingestion, dermal contact
and inhalation of vapors during showering). and surface soils
(via incidental ingestion).
22
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In accordance with USEPA Superfund guidance, the risks for the
above pathways were assessed for the reasonable maximum exposure
(RME) scenario; defined as the highest exposure that is
reasonably expected to occur. Exposure factors used to calculate
risks for the RME were generally based on default values'
recommended by USEPA, that are a combination of upper-bound and
average values.
6.2.2
Toxici~v Assessmen~
For all but two of the chemicals of potential concern,
toxicological values--reference doses (RfDs) for non-carcinogenic
chemicals and the non-carcinogenic effects of carcinogens, and
cancer slope factors (SFs) for known, suspected, and possible
human carcinogens--derived by USEPA were used in the risk
assessment. .
Independent evaluations of the toxicological potential of mirex
and kepone have been performed by the Weinberg Consulting Group.
Toxicological data for mirex were reviewed and an RfD of 2 x 10-4
has been accepted by USEPA for this chemical. Weinberg has
submitted a petition to the IRIS Information Submission Desk
requesting that the USEPA reconsider its cancer slope factor for
mirex. Weinberg concluded that the available data on the
potential carcinogenicity of mirex would result in calculation of
a cancer slope factor of 0.34-1 (mg/kg/day). The petition is
still under review by USEPA, but a preliminary evaluation of
USEPA concluded that an interim cancer slope factor of 0.53
(mg/kg/day)-1 should be used, since the USEPA has not yet
finalized the proposed adoption of a body weight scaling factor
to the 3/4 power instead of to the current 2/3 power. Although
the body weight scaling change will probably be made, it has not
yet been formally approved. Weinberg also submitted petitions to
the IRIS Information Submittal Desk on, the oral RfD and cancer
slope factor for kepone. USEPA Region' III toxicologists have
reviewed the Weinberg petitions and have recommended that the
Weinberg conclusions be used to calculate human risks in this RI
report. While a chronic oral RfD for kepone of 6.5 x 10-4 mg/kg-
day was derived, none of the three published studies that address
the carcinogenic potential of kepone provide adequate data for
quantitative cancer risk assessment and determination of a slope
factor. Therefore, kepone was not evaluated for carcinogenic
potential in the risk assessment.
6.2.3
Risk Characteriza~ion
The baseline risk assessment in the RI/FS'quantified the
potential carcinogenic and non-carcinogenic risks to human health
posed by contaminants in several exposure media. The
carcinogenic and non-carcinogenic risks were determined for
groundwater, surface water, sediment, soil, air, and food (beef
and fish).
23
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1----
Carcinogenic risk is presented as the incremental probability of
an individual contracting some form of cancer over a lifetime as
a result of exposure to the carcinogen. For known or suspected
carcinogens, acceptable exposure levels are generally
concentration levels that represent an excess upper bound
lifetime cancer risk to an individual of between 1.0 x 10-4 (or 1
in 10,000), and 1.0 x 10-6 (or 1 in 1,000,000) using information
on the relationship between dose and response. Risk standards
for non-carcinogenic compounds are established at acceptable
levels and criteria considered protective of human populations
from the possible adverse effects from exposure. The ratio of
the average daily doses ("ADD") to the reference dose ("RfD")
values, defined as the Hazard Quotient, provides an indication of
the potential for systemic toxicity to occur. To assess the
overall potential for a non-carcinogenic effects posed by
multiple chemicals, a Hazard Index ("HI") is derived by adding
the individual hazard quotients for each chemical of concern.
This approach assumes additivity of critical effects of multiple
chemicals. EPA considers any HI exceeding one (1.0) to be an
unacceptable risk to human health. The current risks and future
risks for each of the exposed populations are summarized in
Table 8.
6.2.3.1
CUrrent Use Scenario
The excess lifetime cancer risk for offsite residents currently
exposed to contaminants in Thornton Spring is 2 x 10-6 (or 2 in
1,000,000). The noncarcinogenic hazard index is 0.07. The
exposure pathways assume ingestion of surface water and
sediments, dermal contact with surface water, and inhalation of
vapors.
For the offsite resident who currently lives along or near to
Spring Creek, the excess lifetime cancer risk is 1 x 10-6 (or 1
in 1,000,000). The HI is 0.06. The exposure pathways assumed
are ingestion of Spring Creek sediments and the indirect pathway
of ingestion of locally-grown beef.
For the onsite episodic worker, the excess lifetime cancer risk
is 5 x 10-7 (or 5 in 10,000,000). The HI is 0.4. The exposure
pathways assume ingestion of subsurface soils.
The excess lifetime cancer risk for an onsite daily worker is
estimated at 1 x 10-6 (or 1 in 1,000,000). The non-carcinogenic
hazard index is 0.04. A daily worker is assumed to be onsite 250
days per year over a 25-year career. The exposure pathway would
be only via exposed surface soils since buildings and paved areas
constitute a majority of the manufacturing portion of the
facility.
For the trespassing scenario, the excess lifetime cancer -risk is
9 x 10-8. The HI is 0.02. The exposure pathways assume
24
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ingestion of surface water and sediment from the drainage ditch
area and soils from the spray field, and dermal contact with
surface water.
The excess lifetime cancer risk for the recreational visitor of
Spring Creek is estimated at 7 x 10-8. The non-carcinogenic
hazard index is 0.0003. The exposure pathways assume ingestion
of sediment and surface water, and dermal contact with sediments
of Spring Creek. This scenario assumes that local fisherman
return all fish caught in Spring Creek.
6.2.3.2
Future Use scenario
The excess lifetime cancer risk for a future offsite resident,
who would utilize groundwater in the area as a potable water
supply is 2. x 10-3 (or 2 in 1,000). The non-carcinogenic hazard
index is 5. The exposure pathways for this risk include
ingestion of groundwater, surface water, and sediments, dermal
contact with groundwater and surface water, and inhalation of
vapors.
The excess lifetime cancer risk for a future recreational visitor
is 4 x 10-5 (or 4 in 100,000). The HI is 1. The recreational
visitor is assumed to regularly visit Spring Creek for fishing,
wading, and other water contact activities. This scenario
assumes that the fishing advisory is no longer in effect and that
individuals regularly consume fish from Spring Creek.
For the future onsite resident, the excess lifetime cancer risk
is 1 x 10-2 (or 1 in 100). The non-carcinogenic hazard index is
1,100. The exposure pathways for this risk include ingestion and
dermal contact of groundwater and soils, and inhalation of
vapors.
The risk from potential future use of Site groundwater is
unacceptable. In addition, risk from onsite soils is .
demonstrated. Therefore, remediation of the groundwater,
Thornton Spring surface water, and soils are warranted.
6.3
Bnvironmental Risk Assessment
Potential risks to ecological resources (aquatic and terrestrial
populations) from chemical substances associated with the Site
were evaluated in the Environmental Risk Assessment (ERA) which
was included in the Remedial Investigation (RI) Report. The
Site, as defined in the assessment, includes the Ruetgers-Nease
property plus the offsite drainage areas into which the chemicals
of interest may have migrated. Previously collected data on the.
condition of benthic macro invertebrates and fish in Thornton
Spring and spring Creek were considered in the assessment, along
with a screening-level analysis of exposure and risk to receptor
species based on the results of the RI chemical analyses of
25
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surface water, sediments, soil, and fish tissues. Field
observations describing habitats and fi~h and wildlife sightings
in the area were also factored into the assessment.
Based on the RI characterization analytical data, past operations
at the chemical facility, the environmental fate characteristics,
and available ecotoxicological effects data for specific chemical
substance~, the assessment focused primarily on mirex and kepone;
however, the volatile organic compounds (VOCs) are factored in as
part of the aquatic toxicity tests conducted for the site.
Sampling, ~hemical analysis, and the evaluation of exposure and
potential risk was conducted for six distinctive zones or "Risk
Management Units" (RMUs) within the site area. The RMUs are:
RMUl -
RMU2 -
RMU3 -
RMU4 -
RMU5 -
RMU6 -
The approximately 15-acre grassy field (former spray
field area) to the southwest of the developed (fenced
in) portion of the Ruetgers-Nease property;
The drainage ditch from the point at which the
Ruetgers-Nease groundwater treatment facility effluent
is discharged, downstream to the confluence of the
ditch with Spring Creek (a distance of approximately
2,000 feet). For the risk characterization, RMU2 is
further divided into the drainage ditch on Ruetgers-
Nease property (RMU2A) and the drainage ditch beyond
the property to the point where it enters spring Creek
(RMU2B) ;
Thornton spring from the point at which it emerges from
the ground to its confluence with Spring Creek (a
distance of approximately 200 feet);
Spring Creek and its riparian zone in the vicinity of
Pike Street bridge in Lemont (upstream from both the
drainage ditch and Thornton Spring confluences);
Spring Creek and its riparian zone in the vicinity of
Houserville Park (downstream of both the drainage ditch
and Thornton Spring confluences);
Spring Creek an9 its riparian zone in the vicinity of
the Pennsylvania Fish commission Research station and
Hatchery at Benner Spring (further downstream from
RMU5) .
These RMUs were selected for sampling and analysis based upon
their geographic locations relative to potential surface and
subsurface sources of chemicals associated with the Ruetgers-
Nease facility. All RMUs, except RMU4, are in the potential
migration pathway for chemicals originating from the facility.
RMU4 is upstream from the sources and therefore it serves as a
26
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"background area" for Spring Creek.
Exposures were based on measured levels where such data were
available (i.e., soil, surface water, sediments and fish tissue)
and on estimated levels using generally accepted models of uptake
and bioaccumulation for foodchain transfer. The following
indicator receptors were carried through the assessment, although
their inclusion varies by RMU: fish and aquatic invertebrates,
piscivorous birds and mammals, insectivorous birds, and
terrestrial predators. Toxicity thresholds were identified or
derived for relevant biota based either on existing or
recommended guidelines (i.e., ambient water quality criteria or
sediment thresholds). Where published guidance was not
available, toxicity thresholds were derived. The quotient method
for characterizing potential risk was used for both mirex and
kepone in this assessment. The ratio of measured or estimated
exposure to the established or estimated toxicity threshold gives
an indication of relative risk, assuming that the receptors.
inhabit the area and are continuously exposed to the chemical of
concern. In this assessment, ratios of greater than one were
interpreted to indicate ecological risk, while ratios of less
than one indicate no or negligible ecological risk.
The ERA carried out in the RI, however, used the surrogate
approach, which involves extensive assumptions as the basis for
the models. Many of the assumptions are unjustified, resulting
in an ERA that is not protective of ecological receptors as a
whole. For example, the ERA used the assumption that the organic
carbon level of the soil is 5% an4 the lipid content of the
earthworm is 0.85%. The carbon content of the Site soil ranges
from 1% to 4% (Ref. SCS) and the lipid content of the earthworms
is 1.5% (Lawrence and Millar, 1945). Using the reasonable
assumption that the average carbon content of the soil is 2.5%
and entering the values of 2.5 and 1.5 into the calculations to
derive the bioaccumulation factor for earthworms, the results
increase nearly four-fold.
% lipid (Row)
BAF
=
--------------
% carbon (Roc)
These changes exert a change in the environmental effects
quotient from the 0.05 contained in the RI to 9.5.
The results of the quotient method analysis, indicates
exceedances of one (ratio of exposure estimate to chronic
toxicity threshold estimate) for all RHUs, except RMU1 and RMU4.
However, assumptions used in the modelled surrogate found in the
RI are linked to literature sources, but are actually postulated
toxicological estimates. They fall into the category of
estimates by virtue of the fact that they are not linked by
specific data to the Site. Since the ERA is not directly linked
21
.
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to the Site, no justification exists for any approach other than -
the conservative quotient appro~ch.
This approach takes the 95% upper confidence level and calculates
quotients from the simple division of appropriate chronic
criteria levels for all contaminants reported in all media. In
this way, the results are conservative and protective of
ecological receptors as a whole.
using this approach, ecological risk is demonstrated for all
media examined. The potential for ecological risk is very likely
demonstrable in areas not included in the Remedial Investigation
and ERA (e.g., the flood plain areas of Spring Creek and
downstream beyond the area of RMU6).
6.4
Conclusion
Actual or threatened releases of hazardous substances from this
- -Site, if not addressed by implementing the response action
- selected in this ROD, may present an-imminent and substantial
endangerment to public health, welfare, or the environment.
7.0
REMEDIAL OBJECTIVES
Remedial objectives for the Site have been developed for each
media based on the results of the Baseline Risk Assessment and
the Environmental Risk Assessment, evaluation of chemical-
specific ARARs, the Summers Model results (for natural
conditions), and EPA's initial remedial objectives developed
early in the Feasibility Study process. The final Remedial
Action Objectives and their values are discussed below for each
medium.
7.1
Remedial O~;ectives for Groundwater and Thornton SDrina
Surface Water
The Risk Assessment indicates that the carcinogenic and non-
carcinogenic risks associated with exposure to contaminated
groundwater at the site exceed acceptable levels and therefore
warrant remedial action to clean up groundwater at the Site.
MCLs and MCLGs-are currently exceeded within the area of
attainment.
The following remedial objectives were developed for the
groundwater at the Site and Thornton Spring surface water based
upon the considerations outlined above:
.
Remediate contaminants of concern onsite and mitigate
offsite migration of contaminants of concern in groundwater;
Restore groundwater quality within the attainment area; and,
.
28
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.
Reduce contaminants of concern in Thornton Spring surface
water to comply with ARARs.
7.2
Remedial Ob;ectives for onsite soil
The Risk Assessment indicates that the non-carcinogenic risks
associated with exposure to soils at the Site exceed acceptable
levels. In addition, the Environmental Risk Assessment
determined that there are potential risks to terrestrial
environmental receptors at the Site. The Summers Model results
indicated that there are impacts to groundwater associated with
the subsurface soil, which are primarily a result of potential
leaching of VOCs to groundwater.
The following remedial objectives were developed for the onsite
soils at the Site based on the considerations outlined above:
.
Mitigate leaching of contaminants of concern from subsurface
soil so as to be protective of groundwater; and,
. .
Protect environmental receptors.
7.3
Remedial Ob;ectives for Freshwater Drainaae Ditch Surface
Water
The Risk Assessment determined that there are no unacceptable
risks to human health associated with exposures to freshwater
drainage ditch surface water. However, the Environmental Risk
Assessment determined that the risk quotients exceeded toxicity
thresholds for surface water dwelling organisms in the freshwater
drainage ditch. The Pennsylvania surface water quality standards
were exceeded for several contaminants of concern.
The following remedial objective was developed for the freshwater
drainage ditch surface water based on the considerations outlined
above:
.' Control the quality of the water entering the freshwater
drainage ditch to acceptable levels based on environmental
risks and ARARs.
7.4
Remedial Ob;ectives for Freshwater Drainaae Ditch Sediments
The Risk Assessment determined that there are no unacceptable
risks to human health associated with exposures to freshwater
drainage ditch sediments. However, the Environmental Risk
Assessment determined that sediment quality in the freshwater
drainage ditch exceeded toxicity threshol4s for sediment dwelling
organisms.
As was the case for onsite subsurface soils, the leaching of
contaminants of concern from sediments in the freshwater drainage
29
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ditch can impact groundwater quality. In addition, the
freshwater drainage ditch is a conduit for contaminated runoff
draining from the Site to Spring Creek.
The following remedial objectives were developed for the
freshwater drainage ditch sediments at the Site based on the
considerations outlined above:
.
Mitigate leaching of contaminants of concern from subsurface
soil so as to be protective of groundwater; and,
.
Protect environmental receptors.
7.5
Remedial Ob;ectives for sDrina Creek Surface Water
The Risk Assessment .determined that there are no unacceptable
risks to human health associated with exposures to spring Creek
surface water. Mirex and kepone were not detected in surface
water indicating negligible to no environmental risks. The
Pennsylvania surface water quality standards were exceeded for
one contaminant of concern. .
Considering the above, the following remedial objective was
developed for Spring Creek surface water:
.
Control the contaminants of concern entering spring Creek
(Thornton Spring surface water and, groundwater discharges
from the Site) to acceptable levels based on ARARs.
7.6
Remedial Ob;ectives for SDrina Creek Sediments
The Risk Assessment determined that there are no unacceptable
carcinogenic risks to human health associated with exposures to
spring Creek sediments or from ingestion of fish. However, there
are non-carcinogenic risks from the ingestion of fish. Based on
the Environmental Risk Assessment, environmental risk is
demonstrated to biota that inhabit Spring Creek (both aquatic and
terrestrial species).
Considering the above, the following remedial objective was
developed for Spring Creek sediments:
.
To reduce the bioavailability of mirex and kepone detected
in Spring Creek sediments such ~at fish tissue levels of
mirex and kepone do not exceed FDA action levels. FDA has
established action levels for fish tissue levels of mirex
and kepone which are set at 100 ~g/kg and 300 ~g/kg,
respectively.
30
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8.0
DESCRIPTION OF ALTERNATIVES
The Feasibility study (FS) prepared by Golder Associates (June
1994) evaluated two to four alternatives for each of the five
media/locations to address risks posed by current and potential
future exposure to contaminants at the Centre County Kepone site.
Applicable remediation technologies were initially screened in
the FS based on effectiveness, implementability, and cost. The
alternatives meeting these criteria were then evaluated and
compared to nine criteria required by the National contingency
Plan ("NCP"). The NCP requires that "No Action" alternatives be
evaluated as a point of comparison for other alternatives. The
alternatives evaluated for groundwater/Thornton Spring surface
water, soils, drainage ditch surface water, drainage ditch
sediments, and Spring Creek sediments are described below.
The applicable or relevant and appropriate requirements (ARARs)
for each alternative are not included in this section. A
discussion of all ARARs for the selected remedy is contained in
section 11.2.
8.1
Groundwater and Thornton SDrina Surface Water
GW/TS-1
No Action
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual O&M Costs: $88,500
Present-Worth Costs: $1,100,000
Implementation Time: Immediate
TheoNCP requires that EPA consider a "No Action" alternative for
every site to establish a baseline for comparison to alternatives
that do require action. Under this alternative, the current
groundwater extraction and treatment system would be terminated.
This alternative provides only for routine groundwater and
surface water sampling to monitor changes in water quality at the
site and Thornton Spring.
GW/TS-2
Limited Action
Estimated
Estimated
Estimated
Estimated
capital Costs: $30,000
Annual O&M Costs: $547,000
Present-Worth Costs: $6,814,000
Implementation Time: Immediate
This alternative includes continued monitoring and operation of
the existing groundwater extraction and treatment system and
institutional controls for Thornton Spring. The groundwater
would continue to be pumped to the filter bag unit for solids
removal and then to a decanter for free product separation. The
groundwater will flow through the existing packed bed, counter-
31
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current air stripper to an equalization tank prior to
introduction into granular activated carbon (GAC) adsorbers.
Treated groundwater would continue to be discharged to the
facility's surface water system in accordance with the existing
National Pollutant Discharge Elimination System (NPDES) discharge
permit. Spent carbon will continue to be shipped offsite for
regeneration. The spent filter bags will continue to be
collected in 55-gallon drums and characterized for proper
disposal. Sampling of groundwater from monitoring wells and
Thornton Spring surface water is included. Fencing will be
constructed around the Thornton Spring area. Institutional
controls such as deed restrictions will be implemented at
Thornton Spring.
GW/TS-3
Groundwater Source and Migration Control
Estimated Capital Costs: $2,700,000
Estimated Annual O&M Costs: $491,000
Estimated Present-Worth Costs: $9,052,000
Estimated-Implementation Time: 30 years
This alternative would include a new or supplemental groundwater
source control system and a migration control system. The cost
estimates for this alternative are based upon utilizing ten (10)
source control wells (seven new) in the plant production area and
eighteen (18) migration control wells (twelve new) located near
the downgradient property boundary. However, the actual number
and location of source and migration control wells will be
determined following additional hydrogeologic characterization
that will be conducted during the remedial design phase.
The anticipated flow rate for the groundwater extraction system
will be approximately equal to the average annual discharge rate
at Thornton Spring, approximately 240 gallons per minute.
Groundwater pumped from the extraction systems will be treated in
an upgraded onsite treatment system; the existing air stripper
and _GAC system would be upgraded and sized for higher flow rates.
A free product phase separation system will be installed for.
recovery in the equalization tank. The treatment system will be
designed to reduce or remove Site-related VOCs in the extracted
groundwater, unattended, on a continuous 24 hour per day
performance basis. The ultimate objective of this alternative is
to restore the contaminated groundwater and surface water to
background levels, if technically practicable. The effluent
would be discharged to the facility's surface water system,
consistent with NPDES permit requirements. Spent carbon will be
shipped offsite for regeneration. The spent filter bags will be
collected in 55-gallon drums and will be characterized for proper
disposal. Periodic monitoring of the influent and the effluent
is included to evaluate the effectiveness of the treatment
system. In addition, the surface ~ater from Thornton spring will
32
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be monitored prior to initiating operation of the groundwater
extraction system. The purpose of the monitoring is to establish
the baseline contaminant concentrations at Thornton Spring and
evaluate the performance of the groundwater extraction system
during operation. This alternative also includes sampling of
groundwater from monitoring wells and Thornton Spring surface
water.
The final design of this alternative will undergo an analysis to
determine the projected thermal effects to Spring Creek. If
necessary, mitigation plans will be included as part of the
remedial design to maintain the existing thermal regime of Spring
Creek.
Institutional controls such as deed restrictions will be
implemented for Thornton Spring, as well as maintaining the
current zoning for the Site as industrial use. Fencing will be
constructed around the Thornton spring area. For costing
purposes, the remediation time for groundwater source and
migration control was based on 30 years (the maximum period of
performance used by EPA for costing purposes) .
GW/TS-4
Groundwater Souroe Control and Thornton sprinq Surfaoe
Water Xn-situ Treatment
Estimated
Estimated
Estimated
Estimated
Capital Costs: $4,340,000
Annual O&M Costs: $832,000
Present-Worth Costs: $14,926,000
Implementation Time: 30 Years
This alternative retains the groundwater source control wells
presented in Alternative GW/TS-3. However, an in-situ treatment
system for Thornton Spring surface water would be utilized
instead of a system of onsite migration control wells. An in-
situ GAC bed would be installed at Thornton Spring to remove
organic constituents from the surface water. The cost estimates
for this alternative are based on utilizing ten (10) source
control wells (seven new) in the plant production area, in-situ
GAC treatment for Thornton Spring surface water, a clear well at
Thornton Spring to equalize flow to the GAC treatment system, and
upgrade of the existing onsite treatment system as described in
alternative GW/TS-3. However, the actual number and location of
source control wells will be determined following additional
hydrogeologic characterization that will be conducted during the
remedial design phase~
The anticipated flow rate for the groundwater extraction wells is
approximately 20 gpm to 40 gpm. The treatment plant at Thornton
'Spring must be capable of treating an average of 250 gpm and up
to 3,000 gpm. Both treatment systems will be designed to reduce
or remove the Site-related VOCs in the extracted groundwater and
33
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surface water, unattended, on a continuous, 24 hour per day
performance basis. The ultimate objective of this alternative is
to restore the contaminated groundwater and surface water to
background levels, if technically practicable. The effluent from
the extraction wells would be discharged to the facility's
surface water system, consistent with NPDES permit requirements.
Treated spring water would be released to the surface flow
system. Spent carbon will be shipped offsite for regeneration.
The spent filter bags will be collected in 55-gallon drums and
will be characterized for proper disposal. Periodic monitoring
of the influent and the effluent is included to evaluate the
effectiveness of the treatment system. This alternative also
includes sampling of groundwater from monitoring wells and
Thornton Spring surface water.
The final design of this alternative will undergo an analysis to
determine the projected thermal effects to Spring Creek. If
necessary, mitigation plans will be included as part of the
remedial design to maintain the existing thermal regime of Spring
Creek.
Institutional controls such as deed restrictions will be
implemented for Thornton Spring, as well as maintaining the
current zoning for the Site as industrial use. Fencing will be
constructed around the Thornton Spring area. For costing
purposes, the remediation time for groundwater source control and
Thornton Spring surface water in-situ treatment was based on 30
years (the maximum period of performance used by EPA for costing
purposes) .
8.2
subsurface soils
S8-1
Ho FUrther Action
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual O&M Costs: $0
Present-Worth Costs:
Implementation Time:
$0
Immediate
Interim soil remediation was performed at the Site prior to
performance of the RI. Under this alternative, no additional
soil remediation will be performed.
8S-2
Excavation/offsite Disposal
Estimated
Estimated
Estimated
Estimated
capital.Costs: $4,224,000
Annual O&M Costs: $1,500
Present-Worth Costs: $4,243,000
Implementation Time: 1 Year
Under this alternative, contaminated soils from the more isolated
34
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and unobstructed areas on the Ruetgers-Nease property would be
excavated where the concentrations of VOCs in soil exceed levels
that are protective of groundwater (see Table 9). These areas
include, but are not limited to, the Former Drum Staging Area,
the Designated Outdoor Storage Area, and the Tank Farm/Building
#1 Area (see Figure 12). Soils would be sampled and analyzed for
waste characterization prior to disposal at an offsite RCRA
permitted subtitle C hazardous waste landfill. If required,
thermal treatment of the excavated soil would be used to meet
RCRA land disposal regulations contained in 40 C.F.R. Part 268.
For cost estimating purposes, it was estimated that 6,000 cubic
yards of soil would be excavated and RCRA land disposal
restrictions would not apply.
Following removal of the contaminated soils, all areas would be.
backfilled with structural soil. The final six inches of fill
will be topsoil and the areas will be vegetated to prevent
erosion. Site regrading, with modifications to the surface
drainage system, may be performed under this alternative.
Institutional controls such as deed restrictions will be
implemented for the property, as well as maintaining the current
zoning for the Site as industrial use. Fencing will be extended
around the Site to include the former spray field and former drum
staging area. .
SS-3
soil Vapor Extraction
Estimated
Estimated
Estimated
Estimated
Capital Costs: $1,086,000
Annual O&M Costs: $151,000
Present-Worth Costs: $2,477,000
Implementation Time: 15 Years
The soil vapor extraction (SVE) alternative will be designed to
remove site-related contaminants from the unsaturated zone soils
where they exceed levels that are protective of groundwater.
Soil vapor extraction consists of a network of extraction wells
connected to the suction side of a vacuum extraction unit. Under
this alternative, two SVE systems, one in the plant production
area and one in the spray field area would be constructed with
independent treatment systems for each. The extracted vapors
will be destroyed most likely through catalytic oxidation
treatment. Because of the relatively low hydraulic conductivity
of the soils in the plant area, hydrofracturing of the soil may
be required to increase the effective radius of the SVE wells. A
performance test may be needed during the remedial design phase
to further evaluate the effectiveness of soil hydrofracturing at
the Site. A pilot test may be necessary to obtain data to
support the design of an SVE well system.
Institutional controls such as deed restrictions will be
35
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-
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implemented for the property, as well as maintaining the current
zoning for the Site as industrial use. Fencing will be extended
around Site to include the former spray field and former drum
staging area.
SS-4
Capping
Estimated
Estimated
Estimated
Estimated
capital Costs: $1,896,000
Annual O&M Costs: $11,500
Present-Worth Costs: $2,039,000
Implementation Time: 1 Year*
This alternative would involve capping all the areas of
contaminated surface and subsurface soils on the Ruetgers-Nease
property to reduce infiltration and associated leaching of
contaminants of concern to the groundwater. The cap would be
made of structural concrete in the areas near the operating
facilities and cover approximately 85,500 square feet. In more
isolated areas, such as the former spray field area and former
drum storage area, approximately 24,500 square feet of cap would
be made of a 20-mil to 60-mil synthetic geomembrane, covered with
geotextile, and then covered with approximately 2 feet of soil
with vegetative cover. The areas to be capped would include the
same areas depicted on Figure 12. Some surface regrading may be
necessary to redirect surface water from low lying areas.
Institutional controls such as deed restrictions will be
implemented for the property, as well as maintaining the current
zoning for the site as industrial use. Fencing will be extended
around the Site to include the former spray field and former drum
staging area.
8.3
Freshwater Drainaae Ditch Surface Water
FWDD/SW-l
No Action
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual O&M Costs: $48,000
Present-Worth Costs: $596,000
Implementation Time: Immediate
No remedial activities will be undertaken for the surface water
in the Fresh Water Drainage Ditch (FWDD) under the No Action
alternative. However, surface water discharge monitoring will
continue in accordance with. the NPDES permit under this
alternative.
Common Components for Alternatives FWDD/SW-2A and 2B
Upgrading physical facilities for control of surface water and
the utilization of the Site's hazardous materials management
36
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programs to protect surface water discharge will be common to
alternatives FWDD/SW-2A and 2B. Measures will include
improvements to the surface water discharge systems to reduce
potential groundwater infiltration into underground piping and,
eventually, discharging into the FWDD. Specifically, stormwater
collected from the active tank farm secondary containment system
and roof drains from production buildings will be channeled to
the groundwater treatment plant for treatment prior to discharge
to the FWDD. Secondary containment systems will be provided to
areas around the plant such as the outdoor material substance
container storage, tank storage, and tank/trailer
loading/unloading areas and coating these systems with an
impermeable/wear resistant material. The discharge system to the
FWDD from the treatment plant and stormwater catch basins will be
improved. Also included will be the use of hazardous material
management practices developed at the Site to reduce the
potential for releases. Site regrading may be performed to
enhance this alternative. Stormwater runoff from the Ruetgers-
Nease facility would continue to be discharged to the surface
water system through the FWDD and monitored monthly in accordance
with the NPDES permits. Quarterly sampling and analysis of the
ditch discharge for VOCs and select inorganic parameters will be
performed as well as biannual sampling and analysis for mirex,
kepone, and photomirex. '
FWDD/SW-2A
Source Control Measures; Reconstruct Existing Surface
Water Drainage Pipes
Estimated
Estimated
Estimated
Estimated
capital Costs: $663,000
Annual O&M Costs: $71,500
Present-Worth Costs: $1,550,000
Implementation Time: 6 Months
Under this alternative, approximately 920 linear feet of the
existing underground surface water discharge lines will be
repaired or replaced to eliminate contaminants of concern from
entering the surface water of the FWDD. All of the common
components stated above are included.
FWDD/SW-2B
Source Control Measures; Plug Existing Surface Water
Drainage Pipes and Replace with Aboveground Pipes
Estimated
Estimated
Estimated
Estimated
Capital Costs: $544,000
Annual O&M Costs: $55,500
Present-Worth Costs: $1,233,000
Implementation Time: 6 Months
Under this alternative, the existing underground surface water
discharge lines will be plugged and replaced with an aboveground
system to eliminate contaminants of concern from entering the
37
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surface water of the FWDD. The aboveground system will be
approximately 920 linear feet in total length. All common
components stated above are included.
8.4
Freshwater Drainaae Ditch Sediments
PWDD/SED-l
No Further Action
Estimated
Estimated
Estimated
Estimated
capital Costs: $0
Annual O&M Costs: $0
Present-Worth Costs:
Implementation Time:
$0
Immediate
FWDD sediment remediation was performed at the Ruetgers-Nease
facility prior to performance of the RI. Therefore, the No
Further Action alternative consists of no additional FWDD
sediment remediation.
FWDD/SED-2
Excavation and Soil Lined Ditcb
. Estimated
Estimated
Estimated
Estimated
Capital Costs: $351,000
Annual O&M Costs: $14,900
Present-Worth Costs: $536,000
Implementation Time: 6 Months
This alternative will involve excavation of approximately 500
linear feet of contaminated sediments in the upper forked portion
of Section A of the FWDD to levels that are protective of
groundwater and environmental receptors (see Table 9).
Conventional excavation equipment (backhoe, etc.) would be used
to remove the sediments to a depth of approximately 4 feet deep.
The FS estimated that approximately 400 cubic yards of sediments
are contaminated in the upper forked. section of the FWDD. The
excavated areas would be backfilled with clean fill and seeded
with a vegetative cover to prevent erosion. Excavated sediments
would be disposed of at an offsite RCRA permitted subtitle C
hazardous waste landfill. If required, thermal treatment of the
excavated soils would be used to meet applicable RCRA land
disposal regulations contained in 40 C.F.R. Part 268. . However,
for costing purposes, it was assumed that RCRA land disposal
regulations would not apply and that soil could be disposed of at
a hazardous waste landfill.
FWDD/SED-3
Concrete Lined Ditcb witb Limited Excavation
Estimated
Estimated
Estimated
Estimated
Capital Costs: $200,000
Annual O&M Costs: $20,500
Present-Worth Costs: $454,000
Implementation Time: 6 Months
38
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This alternative would excavate the top 6 inches to 1 foot of
sediments in the upper forked portion of Section A of the FWDD
(approximately 500 linear feet). The amount of excavation
required (140 cubic yards) is estimated to be that which is
necessary to shape and grade the ditch for concrete liner
placement. The excavated sediments would be disposed ,of at an
offsite RCRA permitted subtitle C hazardous waste landfill. If
required, thermal treatment of the excavated sediments would be
used to meet applicable RCRA land disposal regulations contained
in 40 C.F.R. Part 268. However, for costing purposes, it was
assumed that RCRA land disposal regulations would not apply and
that sediments could be disposed of at a hazardous waste
landfill.
8.5
Sorina Creek sediments
Common Comoonents
.Limited data was available for riparian-area soils of Spring
Creek during the RI. A common component to all alternatives for
Spring Creek sediments is a phased sampling program for Spring
Creek riparian-area soils, including the lower portion of the
FWDD, Thornton Spring outlet and drainage channel, and
depositional areas beyond the Benner Fish Hatchery. The first
phase would involve mapping the depositional areas and sampling
the most likely places where contamination may be found. If
concentrations of mirex or kepone are found in excess of
a trigger level which will be established during remedial design,
an intensive grid sampling and analysis effort will be required.
The sampling results from both phases will be summarized and
environmental risks calculated. The riparian-area soils will be
addressed as part of the ROD for OU2. The precise scope of this
sampling program will be determined during the remedial design
phase. Therefore, cost estimates are not included in the FS.
SC-l
No Action
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual O&M Costs: $0
Present-Worth Costs:
Implementation Time:
$0 .
Immediate
The NCP requires that EPA consider a "No Action" alternative for
every site to establish a baseline for comparison to alternatives
that do require action. Under this alternative, no remedial
activities would be performed for sedime~ts in Spring Creek.
This alternative assumes that the current "catch and release"
fishing advisory is not in effect for Spring Creek and source
control remediation of FWDD sediments and groundwater/Thornton
Spring water will not be implemented.
39
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SC-2
Institutional Controls and Monitoring
Estimated
Estimated
Estimated
Estimated
capital Costs: $0
Annual O&M Costs: $39,000
Present-Worth Costs: $482,000
Implementation Time: Immediate
Under this alternative, the present "catch and release" fishing
advisory on Spring Creek would be temporarily maintained as an
institutional control. Continued monitoring of Spring Creek fish
tissue and stream channel sediments would be conducted for up to
30 years to support cancelling the advisory in the future.
No intrusive remedial "activities in spring Creek would be
conducted in this alternative and therefore, adverse impacts to
the Spring Creek ecological systems are avoided.
SC-~
Hydraulic/vacuum Dredging
Estimated
Estimated
Estimated
Estimated
Capital Costs: $19,400,000
Annual O&M Costs: $48,500
Present-Worth Costs: $20,000,000
Implementation Time: 2 Years
This alternative~ould involve the use of a hydraulic or vacuum
dredger to remove sediments with mirex and kepone concentrations
in excess of 10 ~g/kg from depositional areas of Spring Creek.
Approximately 15,100 cubic yards of sediments would be dredged
from Thornton Spring to the Benner Fish Hatchery (approximately a
5 mile stretch). Direct access through and along" the floodplain
and riparian zones to the spring Creek stream channel is required
for equipment operation. The hydraulic and/or vacuum dredging
equipment would remove significant quantities of water along with
the sediment. The removed sediments would be dewatered and
subsequently transported offsite to a RCRA permitted subtitle C
hazardous waste landfill for disposal. water, removed along with
the sediments, would be treated and returned to the stream.
Areas where sediments are removed will be backfilled with a
substrate similar to and compatible with the natural substrate in
the stream. Implementation of this alternative may have a
detrimental impact on the environmental quality of the area.
In addition, continued monitoring of spring Creek fish tissue and
stream channel sediments would be conducted for up to 30 years to
support cancelling the advisory in the future.
40
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I -
SC-4
Line stream Channel
Estimated
Estimated
Estimated
Estimated
Capital Costs: $11,416,000
Annual O&M Costs: $58,100
Present-Worth Costs: $12,136,000
Implementation Time: 2 Years
This alternative would provide containment of sediments with
mirex andkepone concentrations in excess of 10 ~g/kg from
depositional areas of Spring Creek from Thornton Spring to the
Benner Fish Hatchery (approximately 5 miles). Pervious
geotextile material will be laid on top of the existing sediment
depositional areas. Following the placement of the geotextile,
rip-rap and/or gravel will be placed on top of the geotextile
liner as ballast, erosion protection, and to provide a more
ecologically compatible substrate for lower trophic organisms.
The rip-rap/gravel layer would be approximately 16 inches in
thickness. Large debris and boulders will have to be removed
prior to placing the geotextile to avoid damage. Direct access
through and along the floodplain and riparian zones to the Spring
Creek stream channel is required for equipment operation.
Hydraulic controls, such as flood control walls or levees would
be constructed along the riparian zone, to mitigate the increased
potential for scouring, erosion, and flooding of the stream
banks.
In addition, continued monitoring of Spring Creek fish tissue and
stream channel sediments would be conducted for up to 30 years to
support cancelling the advisory in the future.
9.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial action alternatives for the groundwater/Thornton.
Spring surface water, soils, drainage ditch surface water,
drainage ditch sediments, and Spring Creek sediments described in
the previous section were evaluated using the nine evaluation
criteria as described below. The resulting strengths and
.weaknesses of the alternatives were then weighed to identify the
alternative providing the best balance among the nine criteria.
Summary of Hine criteria
In selecting EPA's preferred alternative, EPA evaluated each
proposed remedy against the nine criteria specified in the
National Contingency Plan. The alternative must first satisfy
the threshold criteria. The Primary Balancing criteria are used
to weigh the tradeoffs or advantages and disadvantages of the
alternatives. Finally, after public comment has been obtained,
the modifying criteria are considered. Below is a summary of the
nine criteria used to evaluate the remedial alternatives.
41
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Threshold criteria
.
Overall protection of human health and the environment:
Whether the remedy provides adequate protection and how
posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
risks
.
Compliance with ARARs: Whether or not a remedy will meet all
applicable or relevant and appropriate requirements ("ARARs")
of Federal and State environmental statutes and/or whether
there are grounds for invoking a waiver.
Primary Balancing Criteria
.
Lona-term effectiveness and permanence: The ability of the
remedy to afford long term, effective and permanent
protection to human health and the environment along with the
degree of uncertainty that the alternative will prove
successful. . .
.
Reduction of toxicitv. mobilitv. or volume throuah treatment:
The extent to which the alternative will reduce the toxicity,
mobility, or volume of the contaminants causing the site
risks.
.
Short-term effectiveness: The time until protection is
achieved and the short term risk or impact to the community,
onsite workers, and the environment that may be posed during
construction and implementation of the alternative.
Implementability: The technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement that remedy.
.
.
Cost: Includes estimated capital, operation and maintenance,
and net present worth costs.
Modifying criteria
.
state Acceptance: Whether the Commonwealth concurs
opposes, or has no comment on the selected remedy.
Commonwealth concurs with the remedy and therefore
criteria will not be discussed further.
with,
The
this
.
Communitv Acceptance: Whether the public agrees with the
selected remedy. A public meeting was held October 19, 1994
in state College, pennsylvania. Comments received from the
public meeting and comments received in writing during the
public comment periods are referenced in the Responsiveness
Summary attached to this Record of Decision. The community
favors the selected remedy and therefore, this criteria will
42
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not be discussed further.
9.1
ComDarative Analvsis of Alternatives for Groundwater and
Thornton SDrina Surface Water
OVerall Protection. . Since GW/TS-1 (No Action) and GW/TS-2
(Limited Action) would neither eliminate nor reduce to acceptable
levels the threats to human health or the environment presented
by contamination at the Site, they are not protective and
therefore, will not be discussed in the remainder of this
analysis. Alternatives GW/TS-3 and GW/TS-4 will comply with
PADER's groundwater ARARs which require that groundwater
containing hazardous substances be remediated to background
quality, or MCLs, whichever is more stringent, and would protect
human health because they significantly reduce the risk
associated with the ingestion and inhalation of contaminated
groundwater by treating the plume. However, GW/TS-3 is
considered to provide greater protection since groundwater
containing contaminants of concern would not migrate through the
attainment area to Thornton Spring.
compliance with ARARs. ARARs will be met by all the remedial
alternatives with the exception of the No Action and the Limited
Action alternative. Alternatives GW/TS-3 and GW/TS-4 will comply
with the Commonwealth of Pennsylvania's standards requiring that
groundwater containing hazardous substances be remediated to
"background" quality as set forth in 25 PA Code SS 264.97(i),
(j), and 264.100(a) (9), or MCLs, whichever are more stringent.
, Any surface water discharge of'treated effluent will comply with
the substantive requirements of the National Pollutant Discharge
Elimination System ("NPDES") discharge regulations set forth in
25 PA Code S 92.31, and the Pennsylvania Water Quality Standards
(25 PA Code S 93.1-93.9).
With respect to location-specific ARARs, Alternatives GW/TS-3 and
GW/TS-4 would comply with the EPA's Ground Water Protection
Strategy Policy for a Class I aquifer, which is a TBC standard.
Alternatives GW/TS-3 and GW/TS-4 would protect current and
potential sources of drinking water and waters having other
beneficial uses.
Alternatives GW/TS-3 and GW/TS-4 which include groundwater and
surface water remediation, would meet the performance standards
as set forth in section 10.1 of this ROD relating to groundwater
remediation and treatment. .
Alternatives GW/TS-3 and GW/TS-4 would meet all location and
action-specific ARARs relating to activities performed as part of
the remedy, including Federal and State air emission requirements
.and treatment, storage, and disposal requirements for any
hazardous and solid wastes generated during the groundwater
treatment process.
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Long-term Effectiveness and Permanence. Once clean-up goals have
been met, contaminant concentrations in the groundwater aquifer
will be permanently reduced to acceptable levels by Alternatives
GW/TS-3 and GW/TS-4. The time for implementation is estimated to
be the most rapid for GW/TS-3.
Reduction of Toxicity, Mobility, or volume through Treatment.
Alternatives GW/TS-3 and GW/TS-4 include recovery and treatment
of the contaminated groundwater and will therefore significantly
reduce the toxicity, mobility, and volume of the contaminants of
concern by removing them. GW/TS-3 will collect and treat the
contaminants of concern, more effectively and at the source
before migration into the attainment areas, thereby reducing the
toxicity, mobility, and volume of the contaminants of concern at
the Site.
Short-term. Effectiveness. Alternative GW/TS-4 will have larger
potential exposure ri.sks associated with the construction and
operation of the in-situ treatment system at Thornton spring.
In-situ treatment, if successful, will potentially have short-
term reductions in exposure risks at Thornton spring, similar to
those achieved by GW/TS-3, but it may also have contaminants of
concern in the groundwater in some of the attainment area during
the period of implementation. GW/TS-3 has a low potential risk
of remedial worker exposure to contaminants of concern associated
with the installation of the extraction well systems. The time
for implementation of the remedial actions and attaining RAOs is
shorter for GW/TS-3 than for GW/TS-4. Further, mitigation of
contaminants of concern in the attainment area will be
accomplished earlier in the impiementation period.
Implementability. GW/TS-3 and GW/TS-4 use established
technologies which are readily implementable. Enhancement of the
migration control wells under GW/TS-3 is less common and may
require a pre-design study. GW/TS-4 involves a relatively unique
application which will be difficult to design and implement,
especially with the large flow variations observed at Thornton
spring.
Cost. capital and operation and maintenance costs are summarized
in Table 10. The estimated present-worth costs of the selected
Alternative (GW/TS-3) is estimated at $9,052,000. Alternative
GW/TS-3 is less costly than Alternative GW/TS-4 and provides the
same degree of risk reduction.
9.2
Comoarative Analvsis of Alternatives for Subsurface Soils
OVerall Protection. EPA has developed cleanup levels for all
contaminants of concern with the objective of removing
contaminated soil that has the potential to migrate to
groundwater. Alternatives SS-1 (No Further Action) and SS-4
(Capping) will neither eliminate nor reduce the soil
44
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contamination to acceptable levels, except by natural
attenuation. Therefore, they will not be discussed further.
Alternatives SS-2 (Excavation) and SS-3 (Soil Vapor Extraction)
provides the highest level of overall protectiveness because it
will result in the permanent removal of all VOC contaminants of
concern for the soils at the Site. However, the use of SVE has
limited application at the Site.
compliance with ARARs. There are no ARARs that are pertinent for
the development of clean-up levels for the contaminated soil at
the Site. The equations used to develop soil clean-up criteria
for contaminants of concern in soil for the site require the use
of an acceptable standard for groundwater. The groundwater
criteria are used to back calculate the soil criteria. Section
264.97(i), (j) and 264.100(a) (9) of Title 25 of the Pennsylvania
Code sets forth standards that are ARARs for groundwater. The
Commonwealth of Pennsylvania maintains that this requirement to
remediate to background is found in other legal sources.
In addition, the Pennsylvania Department of Environmental
Resources document entitled "Cleanup Standards for Contaminated
Soils", dated December 1993, is a "To Be Considered" (TBC)
requirement that establishes soil cleanup standards deemed to be
acceptable under the residual waste regulations. The .regulation
and the guidance document were used in the development of the
soil clean-up criteria. Alternatives SS-2 and SS-3 will meet the
soil clean-up criteria.
Kepone is an origin RCRA listed waste as discarded material U142
and is addressed under RCRA in 40 C.F.R. Part 268 which describes
the prohibitions on land disposal of various hazardous wastes.
Since contaminants will exist in the soil excavated under
Alternative SS-2, the soil will first be tested to determine if
kepone concentrations are above the risk-based concentration of
160 ppb. If kepone concentrations are below 160 ppb, the soil
will be tested to determine if it is a RCRA characteristic waste
in accordance with 40 C.F.R. S 261.24 by the Toxic Characteristic
Leaching Procedure ("TCLP"). If it is determined to be hazardous
waste or kepone concentrations are above 160 ppb, the remedy will
be implemented consistent with the substantive requirements,
which are relevant and appropriate, of PA Code SS 262.11 and
262.12 (relating to hazardous waste determination and.
identification numbers), 25 PA Code 262.20-262.23 (relating to
manifesting requirements. for offsite shipments of spent carbon or
other hazardous wastes), and 25 PA Code SS 262.30 - 262.34
(relating to pretransport requirements); 25 PA Code SS 263.10 -
263.31 (relating to transporters of hazardous wastes); and with
respect to the operations at the Site generally, with the
substantive requirements of PA Code SS 264.10 - .264.56 and
264.170 - 264.178 (in the event that hazardous waste generated as
part of the remedy is managed in containers), 25 PA Code SS
264.190 - 264.199 (in the event that hazardous waste is managed,
treated, or stored in tanks); and if prohibited by land disposal
4-5
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restrictions, 40 CFR Part 268. EPA does not presently have
sufficient information to determine whether the constituents are
hazardous wastes; however, as noted above, EPA shall require the
performance of kepone and TCLP testing to address this and 40 CFR
S 268.50 (prohibitions on storage of hazardous waste) which are
relevant and appropriate.
Long-term Effectiveness and Permanence. Alternative 55-2
provides a high level of long-term effectiveness and permanence
because it will result in the permanent removal of the
contaminants of concern in the soils at the 5ite. However, 55-2
may not be feasible in some locations since the facility must
remain operational. Alternative 55-3 may be effective for
meeting clean-up goals in specific areas. The degree of
effectiveness attained by 55-3, however, must be verified by a
post-treatment soil sampling method which is less reliable than
the post-excavation soil sampling method associated with 55-2.
. _Reduction of Toxicity, MObility, or Volume through Treatment.
Alternatives S5-2 and 5S-3 will result in permanent reduction in
the toxicity, mobility, and volume of the contaminants of concern
at the site because the contaminants will either be permanently
destroyed or removed from the 5ite. However, SS-2 cannot be
performed in the plant area and 5S-3 has very limited application
at the 5ite. -
Short-term Effectiveness. Alternative 55-3 will have fewer
short-term impacts associated with 5ite disturbance. 5hort-term
impacts associated with Alternative 55-2 include the disruption
of the Site associated with removing and replacing soil, and
physical risks involved in any activities where heavy equipment
is used. Implementation of SS-2 would require less time than
55-3, because excavation requires less time to implement than
soil vapor extraction. 55-2 has limited risks associated with
the excavation and hauling of soils with contaminants of concern.
5S-3 has greater potential exposure risks associated with
implementation, due to the drilling and removal of VOCs from the
soil. The off-gas from the SVE system will require monitoring to
ensure that it complies with relevant health-based standards.
Implementability. The excavation alternative (S5-2) does not
require specialized equipment and uses routine construction
procedures so it is easily implemented. 55-2 will require
personnel experienced in hazardous materials handling and
transport. Soil Vapor Extraction (55-3) requires experienced
personnel and specialized equipment. Furthermore, SVE may not
be feasible at-the 5ite and can only be used in specific areas.
The low hydraulic conductivity of the soils (about 10-7 cm/s) and
the perched water table conditions make this alternative
potentially infeasible. Difficulties may also be encountered by
the expected need for hydrofracturing near an active plant
building, and p~acement of the 5VE piping through the plant area.
46
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A pilot study should be performed to provide data to support the
design of an SVE well system.
Cost. Capital and operation and maintenance costs are summarized
in Table 10. The Soil Vapor Extraction alternative (SS-3) would
have the lower net present-worth costs at $2,477,000 when
compared to SS-2.
9.3
ComDarative Analvsis of Alternatives for Freshwater Drainaqe
Ditch Surface Water
OVerall Protection. with Alternative FWDD/SW-1, contaminants of
concern will continue to exceed chemical-specific ARARs and
potentially migrate in the surface water. Therefore, it will not
be discussed in the remainder of this analysis. FWDD/SW-2A and
2B (Source Control) is to reduce loading of contaminants of
co~cern to the freshwater drainage ditch surface water. Both of
these alternatives will accomplish this by a combination of .
improvements to the surface water collection and discharge
systems at the Site and continued material management at the
plant. Material management programs implemented at the Site
include: a waste minimization program, a spill prevention and
contingency plan, strict hazardous material handling protocols,
and a best management practices program. FWDD/SW-2A and 2B both
include changes to the physical surface water system by diverting
drain discharges to the treatment plant for collection, replacing
the underground lines discharging to the freshwater drainage
ditch, and upgrading the surface water management plan.
compliance with AHARs. Both alternatives FWDD/SW-2A and 2B will
reduce loading of contaminants of concern to the freshwater
drainage ditch surface water. Improvements to the existing storm
water drainage system, or redesign of the system will meet the
action-specific requirements of the county's stormwater
management plan under the Pennsylvania Storm Water Management Act
(32 P.S. SS 680.1 - 680.5 and S 680.13, and 25 PA Code 111.14). .
Construction of the improvements and regrading will be performed
in accordance with Soil and Water Conservation Regulations (Title
25, PA Code Chapter 102.1 - 102.32) to meet the requirements of
the control of soil erosion and sedimentation resulting from
earthmoving activities. The discharge of storm water will meet
the requirements of the Pennsylvania NPDES Regulations (25 PA
Code SS 92~1, 92.3 - 92.11, 92.17, and 92.41).
Long-term Effectiveness and Permanence. Alternatives FWDD/SW-2A
and 2B will both be effective in the long-term. However,
FWDD-2A will provide additional permanence since the existing
surface water drainage pipes will be reconstructed and not
plugged as in FWDD/SW-2B.
. Reduction of Toxicity, MObility, or Volume through Treatment.
Neither alternative FWDD/SW-2A nor FWDD/SW-2B actively reduces
47
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the toxicity, mObility, or volume of contaminants of concern at
the Site. These alternatives are designed to keep contaminants
of concern out of the freshwater drainage ditch surface water.
Short-term Effectiveness. The implementation of Alternative
FWDD/SW-2A may have potential short-term impacts. Reconstruction
of the underground discharge lines to the freshwater drainage
ditch could have some risks associated with encountering
contaminants of concern in ~he excavations, potential release of
VOCs, potential release of contaminants of concern to the surface
or freshwater drainage ditch surface water, confined work space,
encountering buried utilities during excavation, and
excavation/shoring collapse. Both Alternatives FWDD/SW-2A and 2B
have a short implementation period.
Implementability. Both Alternatives FWDD/SW-2A and 2B are easily
implementable since operational practices and/or procedures are.
already developed. Reconstruction of the discharge lines under
either alternative will entail disruption of operations to
access, plug, and/or reconstruct the lines.
Cost. Capital and operation and maintenance costs are summarized
in Table 10. The Source Control Alternative which replaces the
surface water drainage pipes with an aboveground system (FWDD/SW-
2B) would have lower net present-worth cost of $1,223,000 when
compared to FWDD/SW-2A.
com~arative Analvsis of Alternatives for Preshwater Drainaae
Ditch sediments
9.4
Overall Protection. EPA has developed cleanup levels for all
contaminants of concern with the objective of removing
contaminated soil that has the potential to migrate to
groundwater. In addition, soil cleanup levels for mirex and
kepone .that are protective of environmental receptors have been
established by EPA and are set at 10 #g/kg. Alternative
FWDD/SED-1 (No Further Action) will neither eliminate nor reduce
the sediment contamination to acceptable levels, except by
natural attenuation. Therefore, it will not be discussed
further. Alternative FWDD/SED-2 (Excavation and Soil Lined
Ditch) will provide the highest level of protectiveness because
it will result in permanent removal of all contaminants of
concern from the sediments in the freshwater drainage ditch at
the Site. Alternative FWDD/SED-3 (Limited Excavation and
Concrete Lined Ditch) is less protective since some sediments
containing contaminants of concern would remain in the ditch.
Compliance with ARARs. There are no ARARs that are pertinent for
the development of clean-up levels for the contaminated sediments
at the Site. The equations used to develop soil clean-up
criteria for contaminants of concern in soil for the site require
the use of an acceptable standard for groundwater. The
48
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groundwater criteria are used to back calculate the soil
criteria. Section 264.97(i), (j) and 264.100(a) (9) of Title 25
of the. Pennsylvania Code sets forth standards that are ARARs for
groundwater. The Commonwealth of Pennsylvania maintains that
this requirement to remediate to background is found in other
legal sources. In addition, the Pennsylvania Department of
Environmental Resources document entitled "Cleanup Standards for
Contaminated Soils", dated December 1993, is a "To Be Considered"
(TBC) requirement that establishes soil cleanup standards deemed
to be acceptable under the residual waste regulations. The
regulation and the guidance document were used in the development
of the sediment clean-up criteria. Alternatives FWDD/SED-2 and
FWDD/SED-3 will meet the sediment clean-up criteria. However,
Alternative FWDD/SED-3 is a limit~d excavation and the drainage
ditch will be lined with concrete to reduce leaching of
contaminants of concern into groundwater.
Kepone is an origin RCRA listed waste as discarded material U142
and is addressed under RCRA in 40 C.F.R. Part 268 which describes
the prohibitions on land disposal of various hazardous wastes.
.Since contaminants will exist in the sediment excavated under
Alternatives FWDD/SED-2 and FWDD/SED-3, the sediment will be
first be tested to determine if kepone levels are above the
health-based risk concentration of 160 ppb. If kepone
concentrations are below 160 ppb, the sediment will be tested to
determine if it is a RCRA characteristic waste in accordance with
40 C.F.R. S 261.24 by the Toxic Characteristic Leaching Procedure
("TCLP"). If it is determined to be hazardous waste or kepone
concentrations are above 160 ppb, the remedy will be implemented
consistently with the substantive requirements, which are
relevant and appropriate, of PA Code SS 262.11 and 262.12
(relating to hazardous waste determination and identification
numbers), 25 PA Code 262.20-262.23 (relating to manifesting
requirements for offsite shipments of spent carbon or other
hazardous wastes), and 25 PA Code SS 262.30 - 262.34 (relating to
pretransport requirements); 25 PA Code SS 263.10 - 263.31
(relating to transporters of hazardous wastes); and with respect
to the operations at the site generally, with the substantive
requirements of PA Code SS 264.10 - 264.56 and 264.170 - 264.178
(in the event that hazardous waste generated as part of the
remedy is managed in containers), 25 PA Code SS 264.190 - 264.199
(in the event that hazardous waste is managed, treated, or stored
in tanks); and if prohibited by land disposal restrictions, 40
CFR SS 268.1 - 268.6, 268.8 - 268.9, 268.30 - 268.37, 268.40 -
268.43, and 268.50. EPA does not presently have sufficient
information to determine whether the constituents are hazardous
wastes; however, as noted above, EPA shall require the
. performance of TCLP testing to determine whether the constituents
fail TCLP.
Long-term Effectiveness and Permanence. Alternative FWDD/SED-2
provides a high level of long-term effectiveness and permanence
49
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1- -----------
because it will result in the permanent removal of the
contaminants of concern in the sediments at the Site.
Alternative FWDD/SED-3 will also be effective but will leave
sediments containing contaminants of concern in the drainage
ditch since excavation is limited to the top 6 to 12 inches.
Reduction of Toxicity, Mobility, or Volume through Treatment.
Alternative FWDD/SED-2 will result in a permanent reduction in
the toxicity, mobility, and volume of the contaminants of concern
at the Site because the contaminants will be permanently removed
from the freshwater drainage ditch. Alternative FWDD/SED-3 will
reduce the mobility relative to sediment transport and leaching
of contaminants of concern.
some
Short-term Effectiveness. Alternative FWDD/SED-2 will have the
less short-term risks due to the quick reduction in contaminants
of concern in the sediments. Short-term impacts associated with
Alternatives FWDD/SED-2 and FWDD/SED-3 include the disruption of
the freshwater drainage ditch associated with removing sediments
and "replacing them with soil or concrete and the physical risks
involved where heavy equipment is used.
rmplementability.
are implementable
Both alternatives
material handling
Both Alternatives FWDD/SED~2 and FWDD/SED-3
and utilize standard construction technologies.
will require personnel experienced in hazardous
and transport.
Cost. capital and operation and maintenance costs are summarized
in Table 10. The Limited Excavation and Concrete Lined Ditch
alternative (FWDD/SED-3) would have the lowest net present-worth
costs at $454,000.
9.5
ComDarative Analvsis of Alternatives for sDrina creek
Sediments
OVerall Prot.ction. EPA has developed soil cleanup levels for
mirex and kepone in sediments (10 ~g/kg) that are protective of
environmental receptors. The Food and Drug Administration (FDA)
has established action levels for mirex and kepone in edible
portions of fish set at 100 ~g/kg and 300 ~g/kg, respectively.
Since SC-1 (No Action) assumes that the current "catch and
"release" advisory is no longer in effect for Spring Creek and the
other alternatives selected in this interim ROD would not be
implemented, it would neither eliminate nor reduce to acceptable
levels the threats to human health or the environment presented
by contamination at the Site and will not be discussed in the
remainder of this analysis. Alternatives SC-2 (Institutional
Controls), SC-3 (Dredging), and SC-4 (Lining stream Channel)
would all protect human health because they maintain the "catch
and release" fishing advisory. The potential short-term
environmental impacts resulting from Alternatives SC-3 and SC-4
would be significant; floodplain, riparian zone, and possibly
50
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wetland habitats would be impacted through the construction of
access roads, work stations, and stream channel access points.
Dredging operations under SC-3 and lining the stream channel
under SC-4 would destroy benthic habitats. There may also be
some long-term adverse impacts from alternatives SC-3 and SC-4 as
a result of resuspension of contaminated sediments.
Compliance with ARARs. There are no chemical-specific ARARs that
are pertinent for the development of clean-up levels for the
contaminated sediments in spring Creek. However, EPA has
determined that mirex or kepone concentrations of 10 ~g/kg is the
cleanup level that would be protective of ecological receptors.
The technical basis for the cleanup level is based on the
toxicity (both for aquatic and terrestrial species),
bioaccumulation, and biodegradation of the pesticides.
Alternatives SC-1 and SC-2 do not have any location-specific or
action-specific requirements. Since Alternative SC-3 will result
in removal of mirex and kepone contaminated sediments, offsite
disposal will be in compliance with the requirements contained in
40 CFR SS 268.1 - 268.6, 268.8 - 268.9, 268.30 - 268.37, 268.40 -
268.43, and 268.50. The remedy will be implemented consistently
with the substantive requirements, which are relevant and
appropriate, of PA Code SS 262.11 and 262.12 (relating to
hazardous waste determination and identification numbers), 25 PA
Code 262.20 - 262.23 (relating to manifesting requirements for
offsite shipments of spent carbon or other hazardous wastes), and
25 PA Code SS 262.30 - 262.34 (relating to pretransport
requirements); 25 PA Code SS 263.10 - 263.31 (relating to
transporters of hazardous wastes); and with respect to the
operations at the Site generally, with the substantive
requirements of PA Code SS 264.10 - 264.56 and 264.170 - 264.178
(in the event that hazardous waste generated as part of the
remedy is managed in containers), 25 PA Code SS 264.190 - 264..199
(in the event that hazardous waste is managed, treated, or stored
in tanks).
Both Alternatives SC-3 and SC-4 will comply with erosion and
. sedimentation control measures contained in 25 PA Code Chapter
102.1 - 102.32; wetland regulations in 25 PA Code SS 105.1 -
105.3, 105.12, and 105.19; Pennsylvania water resource
regulations in 25 PA Code S 91. Activities which may impact the
100-year floodplain are subject to the technical requirements of
the Pennsylvania Flood Plain Management Act of 1978 and the Dam
Safety and Encroachment Act of 1978 contained in 25 PA Code SS
105 and 106. In addition, spring Creek is considered a water of
the Commonwealth and requirements contained in 25 PA Code S 105
and Federal Executive Order 11988 may apply.
Long-term Effectiveness and Permanence. Alternative SC-2 relies
on the natural attenuation process; the other alternatives
attempt to reduce fish tissue levels to levels where the fishing
51
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----- -
i
!
advisory can be lifted. Alternatives SC-3 and SC-4 may provide a
higher degree of long-term effectiveness and permanence as a
result of their removal and containment components, respectively.
However, due to morphological considerations in Spring Creek,
there are concerns regarding the effectiveness of these
alternatives to achieve remediation goals. Both SC-3 and SC-4
may leave some impacted sediments in place and both alternatives
will cause sediment resuspension.
Reduction of Toxicity, Kobility, or Volume throuqh Treatment.
Alternative SC-2 utilizes natural attenuation processes, and
Alternatives SC-3 and SC-4 utilize removal and containment
actions, respectively, to reduce constituent mObility. None of
the alternatives provide treatment for reduction of the toxicity
and/or volume of mirex and kepone.
Short-term Effectiveness. Alternative SC-2 does not include any
remedial actions which would cause adverse effects to human
health or the environment. Alternatives SC-3 and SC-4 will
potentially cause several severe adverse impacts to the
environment: increased erosion; resuspension and increased
transport and bioavailability of buried impacted sediments;
destruction of aquatic, riparian zone, and flood plain habitats;
increased siltation within wild trout spawning grounds; and, the
overall reduction in quality of the wild trout fishery. Both
Alternatives SC-3 and SC-4 will result in a similarly high degree
of these adverse environmental impacts primarily from the
construction of access roads and work stations within the flood
plain, riparian zones, and possibly wetlands; construction
activities conducted within the stream channel (dredging,
backfilling, and containment); and construction of flood control
structures along the riparian zone.
Implementability. Both Alternatives SC-3 and SC-4 will be
difficult to implement from both a technical and administrative
standpoint. The cobbles, boulders, and deep pools in some
depositional areas will interfere with effective implementation
of both of these alternatives. These alternatives will be
further complicated by the requirement for access to creek areas
and construction on both sides of Spring Creek. Alternative SC-2
can be easily implemented.
Cost. Alternative SC-2 has the lowest net present-worth cost of
$500,000. The estimated present-worth costs of Alternatives SC-3
and SC-4 increase substantially and are summarized in Table 10.
52
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10.0
SELECTED REMEDY: DESCRIPTION AND PERFORMANCE STANDARDS
EPA has selected the following alternatives as the remedy for OUl
at the Centre County Kepone site: GW/TS-3 (extraction and
treatment of groundw~ter), 55-2 (soil excavation/disposal),
FWDD/SW-2A (source c.ontrol measures), FWDD/SED-2 (sediment
excavation/disposal), and SC-2 (institutional controls and
monitoring).
The remedy will restore the groundwater in the area of attainment
to background levels as established by EPA, in consultation with
the Commonwealth of Pennsylvania or to the appropriate MCLs or
non-zero MCLGs, whichever is more stringent. The remedy also
includes excavation and offsite disposal of contaminated soils
and sediments, source control measures for surface water from the
site, and long-term monitoring. This remedy is protective of
human health and the environment, is cost-effective, shall meet
ARARs, and utilizes treatment technologies to the maximum extent
practicable. The remedy includes the following components:
.
Extraction and treatment of groundwater with discharge to
the freshwater drainage ditch;
.
Long-term groundwater monitoring;
.
Excavation and offsite disposal of contaminated soils;
.
Surficial Soil Sampling of the 15-acre Former Spray Field
Area;
.
Improvements to the. surface water drainage system in the
plant production area;
.
Engineering controls and hazardous materials management
practices for surface water drainage;
.
Monitoring of surface water discharge from the Site;
.
Excavation and offsite disposal of contaminated sediments;
.
Fish tissue and stream channel monitoring;
.
Onsite and off site fencing;
.
Deed restrictions;
Riparian-area Sampling, including the drainage channel of
Thornton Spring, Section B of the freshwater drainage
ditch, and downstream of Benner Fish Hatchery.
Each component of the selected remedy and its performance
standards are described below.
.
53
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10.1
Extraction and Treatment of Groundwater
Description of the component of the Remedy
The groundwater shall be remediated through extraction and
treatment of contaminated groundwater throughout the area of
attainment which will be determined during the remedial design
phase. The extraction shall create groundwater zones where the
contaminated groundwater is hydraulically contained and shall
prevent migration beyond the area of attainment. Groundwater
shall be treated using an onsite treatment system. Thetreatment
system will be designed to reduce the site-related contaminants
in the extracted groundwater, unattended, on a continuous, 24-
hour-per-day performance basis. The exact location, size, and
number of wells (both source control and migration control) shall
be determined during the design by EPA, in consultation with the
Commonwealth of Pennsylvania. At least one round of samples
shall be collected from existing Site monitoring wells during-the
predesign phase, and analyzed for volatile organic compounds, in
order to determine the extent of the groundwater contaminant
plume at that time. Aquifer tests shall be performed during the
predesign phase in order to define aquifer characteristics, if
such tests are determined to be necessary by EPA, in consultation
with the Commonwealth of Pennsylvania.
The treated groundwater effluent will be discharged to the onsite
freshwater drainage ditch through a new outfall pipe that shall
be constructed as part of the remedial action. A system to treat
contaminated groundwater with GAC shall include water
conditioning, solids filtration and handling, and GAC adsorption.
The groundwater will be pumped to filters for solids removal, to
a decanter for free product separation, and then to GAC columns
for adsorption of VOCs. Spent solids from the solids filtration
system will be characterized in accordance with the TCLP test set
forth at 40 C.F.R. S 261.24. The treatment system will be
designed to achieve 98 percent removal of VOCs in compliance with
the substantive requirements of PADER's NPDES regulations. Final
flow rates and GAC system dimensions will be determined by EPA
during remedial design. The final combined pumping rate and the
exact location,- size, and number of wells shall be based on the
ability to hydraulically control the contaminated groundwater
plume as determined by EPA.
An operation and maintenance plan shall be developed for the
groundwater extraction system and submitted to EPA for approval
during the remedial design phase. At a minimum, the influent and
effluent from the treatment facility shall be sampled monthly for
volatile organic compounds, and the effluent sampled biannually
for mirex, kepone, and photomirex. Operation and maintenance of
the groundwater extraction system shall continue for an estimated
30 years or such other time period as EPA, in consultation with
the Commonwealth of Pennsylvania, determines to be necessary,
54
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based on the statutory reviews of the remedial action which shall
be conducted no less often than every five years from the
initiation of the remedial action in accordance with the EPA
guidance document, structure and Components of Five-Year Reviews
(OSWER Directive 9355.7-02, May 23, 1991). statutory reviews
will be conducted as long as hazardous substances remain onsite
and prevent unlimited use and unrestricted access to the site.
The operation and maintenance plan shall be revised after
construction of the collection system has been completed if it is
determined to be necessary by EPA. The revised operation and
maintenance plan shall be submitted to EPA for approval.
In addition, a Baseline Monitoring Plan shall be developed to
establish baseline contaminant concentrations for Thornton Spring
surface water. The baseline contaminant concentrations for each
contaminant of concern will be established prior to commencement
of the groundwater extraction system and will be used to evaluate
the effectiveness of the system. The Plan shall include, as a
minimum, monthly sampling of Thornton Spring surface water with
25% of the samples taken within 12 hours after a storm event and
include flow measurements to ensure a quantitative evaluation of
the spring's water quality. The exact frequency and duration of
sampling and the analytical parameters and methods to be used
will be determined by EPA, in consultation with the Commonwealth
of Pennsylvania, during the remedial design phase.
A comprehensive analysis of the groundwater extraction system
shall be made to determine the thermal effects on Spring Creek.
The analysis shall include establishment of Spring Creek
background conditions, and modeling of the background data to
demonstrate the thermal effects of the dewatering Thornton Spring
and discharging treated effluent to spring Creek via the
freshwater drainage ditch. The establishment of background
conditions for Spring Creek shall include, at a minimum,
temperature and flow readings from three locations: .
1) Spring Creek upstream from the confluence of Thornton Spring,
2) Thornton Spring, and 3) spring Creek at a location 40 meters
downstream from the confluence of the'£reshwater drainage ditch.
The exact frequency and duration of measurements. and methods to
be used will be determined by EPA, in consultation with the
Commonwealth of Pennsylvania, during the remedial design phase.
The analysis shall be submitted for EPA acceptance and include,
if necessary, mitigation plans for maintaining the background
thermal regime of Spring Creek.
In addition, existing pumping and monitoring wells which serve no
purpose shall be properly plugged and abandoned consistent with
PADER's Public Water Supply Manual, Part II, section 3.3.5.11, in
order to eliminate the possibility of these wells acting as a
conduit for future groundwater contamination. Wells which may be
plugged and abandoned include the pumping wells on the Ruetgers-
Nease Corporation property and any well not used or co~sidered by
55
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EPA for practical use as part of a long-term groundwater
monitoring network. Periodic monitoring of groundwater and
Thornton Spring surface water will occur to determine the
performance of the pump and treat system and the effectiveness of
the selected remedy in meeting the performance standards.
Performan~e standards
The performance standard for each contaminant of concern in
the groundwater in the area of attainment shall be the MCL
or the non-zero MCLG for that contaminant [40 C.F.R. Part
141] or the background concentration of that contaminant,
whichever is more stringent. The background concentrations
for each contaminant of concern shall be established in
accordance with the procedures for groundwater monitoring
outlined in 25 PA Code S 264.97(i), (j), and 264.100(a) (9),
subject to the approval of EPA in consultation with the
Commonwealth of Pennsylvania. Establishment of background'
concentrations. shall not delay groundwater extraction and
treatment. In the event that a contaminant of concern is
not detected in samples taken for the establishment of
background concentrations, the detection limit for the
method of analysis utilized with respect to that
contaminant shall constitute the "background" concentration
of the contaminant. The area of attainment (the area in
which these performance standards are to be met) will
include, as a minimum, the downgradient property boundary
of Ruetgers-Nease Corporation, the groundwater
contamination beyond the Ruetgers-Nease corporation
property, and Thornton Spring. However, MCLs and MCLGs for
these contaminants of concern are listed below.
1.
contaminant
Benzene
Chloroform
1,2-Dichlorobenzene
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene
1,2-Dichloropropane
Ethylbenzene
Tetrachloroethene
Toluene
1, 1, 1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
Xylenes
MCL (I.£a/l)
MCLG (ua/l)
5
100
600
810*
5
7
70
5
700
5
1,000
200
5
5
2
10,000
o
o
600
o
7
70
o
700
o
1,000
200
3
o
o
10,000
* Non-carcinogenic health-based concentration
56
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.
2.
The number and location of recovery wells will be
determined by EPA, in consultation with the Commonwealth of
Pennsylvania, during the design phase and shall be
sufficient to control the migration of contaminants and to
achieve the groundwater cleanup levels throughout the area
of attainment. The area of attainment for the cleanup will
be the area where the more stringent standard, as discussed
in the preceding performance standard, for the contaminants
are exceeded and will include, as a minimum, the
downgradient property boundary of Ruetgers-Nease
corporation, the groundwater contamination beyond the
Ruetgers-Nease Corporation property, and Thornton Spring.
The exact area of attainment will be determined during the
remedial design and shall be subject to EPA approval in
consultation with the Commonwealth of Pennsylvania.
3.
The performance standard for the treated groundwater prior
to discharge to the onsite freshwater drainage ditch shall
be compliance with the substantive requirements of the
NPDES discharge regulations set forth in 25 PA Code
S 92.31, and the Pennsylvania Water Quality Standards (25
PA Code SS 93.1 - 93.9). Pursuant to the Pennsylvania
Department of Environmental Resources' determination,
monitoring for all the contaminants of concern shall be
required.
A Baseline Monitoring Plan shall be developed to establish
the baseline contaminant concentrations for Thornton Spring
surface water. The baseline contaminant concentrations for
each contaminant of concern will be established prior to
commencement of the groundwater extraction system and shall
be subject to EPA approval, in consultation with the
Commonwealth of pennsylvania. The baseline contaminant
concentrations will be used to evaluate the effectiveness
of the groundwater extraction system. The Plan shall
include, as a minimum, monthly sampling of Thornton Spring.
surface water with 25% of the samples taken within 12 hours
after a storm event and include flow measurements to ensure
a qualitative evaluation of the spring's water quality.
The exact frequency and duration of sampling and the
analytical parameters and methods to be used will be
determined by EPA, in consultation with the Commonwealth of
Pennsylvania, during the remedial design phase.
4.
5.
The performance standard for the surface water at Thornton
Spring shall be no less than a 20% reduction per year of
the baseline contaminant concentrations established during
the design of this component of the remedy over a five year
period or compliance with the substantive requirements of
the NPDES discharge regulations set forth in 25 PA Code S
92.31, and the Pennsylvania Water Quality Standards (25 PA
Code SS 93.1 - 93.9). Pursuant to the Pennsylvania
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7.
Department of Environmental Resources' determination,
monitoring for all the contaminants of concern shall be
required.
6.
Operation and maintenance of the groundwater extraction
system shall continue until such time as EPA, in
consultation with the Commonwealth of Pennsylvania,
determines that the performance standard for each
contaminant of concern has .been achieved throughout the
area of attainment. If EPA and the Commonwealth make such
a determination, the monitoring wells shall be sampled for
twelve consecutive quarters throughout the area of
attainment and if contaminants remain at or below the
performance standards, the operation of the extraction
system may be discontinued. Semi-annual monitoring of the
groundwater shall continue for five years after the system
is shut down. Semi-annual monitoring shall continue until'
EPA, in consultation with the Commonwealth of Pennsylvania,
determines that the performance standard for each
contaminant of concern can be achieved on a continuing
basis.. If subsequent to an extraction system shutdown,
. monitoring shows that groundwater concentrations of any
contaminant of concern are above the performance standard,
the system shall be restarted and continued until the
performance standards have once more been attained for
twelve consecutive quarters.
8.
The management and ultimate disposition of the spent carbon
and the associated hazardous substances from the granular
activated carbon units shall not degrade air quality nor
contribute to ground-level ozone formation and will be
determined, subject to EPA approval, during the remedial
design. Such management will entail treatment and/or
disposal of the carbon filters.. In the event that these
units are a hazardous waste, the following ARARs will apply
as the Performance Standard for onsite activities: 25 PA
Code SS 262.11 - 262.13 (relating to hazardous waste
determination and identification numbers), 25 PA Code SS
262.20 - 262.23 (relating to manifesting requirements for
offsite shipments of spent carbon or other hazardous
wastes); and with respect to the operations at the Site
generally; with the substantive requirements of 25 PA Code
SS 264.190 - 264.199 (in the event that hazardous waste is
managed, treated, or stored in tanks).
The background thermal regime of Spring Creek shall be
maintained during the operation of the groundwater pump and
treat system. The background temperatures and flow.
conditions for Spring Creek shall be established during the
remedial design subject to approval of EPA in consultation
with the Commonwealth of Pennsylvania.
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Groundwater Remedy Implementation
Because the selected remedy will result in contaminants remaining
onsite, 5-year reviews under Section 121(c) of CERCLA will be
required.
An operation and maintenance plan for the groundwater extraction
and treatment system, including long-term groundwater and
Thornton Spring surface water monitoring, shall also be required.
The performance of the groundwater extraction and treatment
system shall be carefully monitored on a regular basis, as
described in the long-term groundwater and Thornton Spring
surface water monitoring component below, and the system may be
modified, as warranted by the performance data collected during
operation. These modifications may include, for example,
alternate pumping of extraction wells and the addition or
elimination of certain extraction wells. In addition, the
extraction/treatment alternatives GW/TS-3 and GW/TS-4 rated
relatively even against all of the criteria except the cost
.criterion. Consequently, if, based on the more detailed
information gathered during remedy implementation or operation,
variations occur (such as a change in the contaminant
concentration or flow rate), EPA may consider the utilization of
a combination of the groundwater treatment technologies under
Alternatives GW/TS-3 and GW/TS-4.
It may become apparent during implementation or operation of the
groundwater extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the performance standards over
some portion of the area of attainment. If EPA, in consultation
with the Commonwealth of Pennsylvania, determines that
implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will be technically impracticable to achieve and maintain the
performance standards throughout the entire area of attainment,
EPA, in consultation with the Commonwealth of Pennsylvania may
require that any or all of the following measures be taken, for
an indefinite period of time, as further modification(s) of the
existing. system:
a) long-term gradient control provided by low level pumping, as
a containment measure;
b) chemical-specific ARARs may be waived for those portions of
the aquifer for which EPA, in consultation with the Commonwealth
of Pennsylvania, determine that it is technically impracticable
to achieve such ARARs;
c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above performance standards; and
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d) remedial technologies for groundwater restoration may be
reevaluated. .
EPA, in consultation with the Commonwealth of Pennsylvania, may
make the decision to invoke any or all of these measures during
implementation or operation of the remedy or during the 5-year
reviews of the remedial action. If such a decision is made, EPA
shall amend the ROD or issue an Explanation of Significant
Differences.
10.2
Description of the Component of the Remedy
Lona-Term Groundwater Monitorina
A long-term groundwater monitoring program, which includes
Thornton spring surface water, shall be implemented to evaluate
the effectiveness of the groundwater pumping and treatment
system. A plan for the long-term groundwater monitoring program
sha~l be included in the operation and maintenance plan for the
groundwater extraction and treatment system. The number and
locations of monitoring wells, including any additional wells to
those already in existence, which are necessary to verify the
performance of the remedial action will be determined during the
remedial design and shall be subject to EPA approval, in
consultation with the Commonwealth of Pennsylvania.
Groundwater from the monitoring wells and Thornton Spring surface
water shall be sampled quarterly for volatile organic compounds,
annually for mirex and kepone, and biannually for photomirex.
sampling shall continue until such time as EPA, in consultation
with the Commonwealth of pennsylvania, determine that the
performance standard for each contaminant of concern has been
achieved throughout the area of groundwater contamination.
Performance ,Standards
1.
. .
2.
The performance standard for this component of the remedy
is the preparation and EPA acceptance of a Long-Term
Groundwater Monitoring Program. The Program must include,
but not be limited to, monitoring of groundwater from
monitoring wells and Thornton Spring surface water on a
quarterly basis for VOCs, annually for mirex and kepone,
and biannually for photomirex. The specific monitoring
wells to be sampled will be provided in the Long-Term
Groundwater Monitoring Program and subject to EPA review
and approval in consultation with the Commonwealth of
Pennsylvania.
In the event EPA and the Commonwealth of Pennsylvania
determine that the performance standard for each
contaminant of concern has been achieved throughout the
area of attainment, as discussed' in the performance
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standards contained in Section 10.1, the monitoring wells
shall continue to be sampled for twelve consecutive
quarters. If contaminants remain at or below the
performance standards, the operation of the extraction
system may be discontinued.
3.
Semi-annual monitoring of the groundwater shall continue
for five years after the system is shut down. Semi-annual
monitoring shall continue until EPA, in consultation with
the Commonwealth of Pennsylvania, determines that the
performance standard for each contaminant of concern can be
achieved on a continuing basis.
10.3
Excavation and Offsite DisDosal of contaminated Soils
Description of the component of the Remedy
This portion of the remedy consists of excavation and offsite
disposal of an estimated 6,000 cubic yards of contaminated soil
from a minimum of three areas: the Former Drum Staging Area, the
Designated Outdoor Storage Area, and the Tank Farm/Building #1
Area.' All excavated soils containing kepone above 160 ppb for
offsite disposal will be considered a RCRA listed waste as .
discarded material U142. Soils requiring removal shall also be
subjected to the Toxicity Characteristic Leaching Procedure
(TCLP) as described in 40 C.F.R. Part 261, Appendix II, prior to
disposal at an offsite RCRA permitted subtitle C hazardous waste
landfill. If required, offsite thermal treatment of the
excavated soil would be used to meet RCRA land disposal
regulations. Excavation will continue until the soil left in
place meets the soil clean-up levels that are protective of
groundwater as shown in Table 9.
Any asphalt and subbase in the excavation area described above'
will be removed and staged for offsite disposal as construction
debris. Excavation will then begin using a backhoe, and the
sides of the excavation area will be cut back to a minimum 2 to 1
slope to prevent side wall failure. Temporary ,shoring or
,engineering measures may be required in areas near existing
structures to maintain structural stability. Excavation will
continue to a depth of 8 feet or ,shallower if bedrock is ,
encountered. Soil removed during this phase of the excavation
will be stockpiled at a location approved by EPA pending sample
analyses and, if analyses show that this soil has concentrations
of VOCs, mirex, and kepone that are protective of groundwater, it
will be utilized for replacement material after excavation
activities are complete.
All soil from the 8 to 12 foot depth interval, and any additional
soil containing concentrations of VOCs, 'mirex, and kepone that
are not protective of groundwater, will be removed in lifts and
loaded onto vehicles for transport to an offsite RCRA permitted
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subtitle C hazardous waste landfill. Sediment and erosion
controls and temporary covers will be installed to protect
exposed soil from the effects of weather consistent with PADER's
Bureau of soil and Water Conservation Erosion and Sediment
Pollution Control Manual.
Post-excavation sampling will be performed after the excavation
has progressed to 12 feet. Post-excavation samples will be
obtained from the base and the sidewalls of the excavation to
ensure that contamination is not present above the clean-up
level. The location of the post-excavation samples will be
selected based on visual observation of lithology and screening
for VOCs using an appropriate organic vapor detector. The
samples will be analyzed for VOCs on a quick turnaround basis
using a method approved by EPA. If the post-excavation sample
concentrations are below the clean-up level, the excavation will
be backfilled using the stockpiled clean soil. Additional clean
borrow material will be brought in to restore the excavation to
original grade, and the asphalt surface will be repaired. "
Backfilling will be performed in 6-to-12 inch lifts, and the
material will be compacted to minimize the potential for
subsidence.
If VOCs are detected at levels above being protective of
groundwater in the post-excavation samples, additional material
will be removed from the excavation area and new samples obtained
for analysis as discussed above. Excavation and sampling
activities will continue until the results indicate that the
soils do not contain contaminants of concern above the clean-up
level. The excavation area will then be restored as described in
the preceding paragraph.
In addition, surficial and deep soil samples shall be collected
in the inactive or unobstructed areas of the Tank Farm/Building
#1 Area, including the upgradient of the freshwater drainage
ditch and the unoccupied portions of the tank farm. These areas
were not fully characterized in the Remedial Investigation and
were determined in " the Feasibility Study to be disruptive of
plant operations should excavations occur. The purpose of the
sampling will be to fully characterize the soils and assess the
need for additional excavation. The number and location of the
soil samples, and the analytical parameters and methods to be
used will be determined by EPA, in consultation with" the
Commonwealth of Pennsylvania, during the remedial design phase.
Performance standards
1.
The performance standard for this component of the remedy
is to remove all soils with concentrations of contaminants
of concern that are above levels" protective of groundwater
from a minimum of three areas: the Former Drum Staging
Area, the Designated Outdoor storage Area, and the Tank
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3.
4.
10.4
2.
Farm/Building #1 Area. Figure 12 illustrates the general
location of these areas. The exact areas targeted for soil
removal shall be determined during the remedial design and
shall be subject to approval of EPA in consultation with
the Commonwealth of pennsylvania. Table 9 provides the
listing of the contaminants of concern at the Site and the
appropriate soil clean-up level.
Excavated soils containing kepone above the risk based
concentration of 160 ~g/kg will be considered a RCRA listed
waste as discarded material U142. Soils requiring removal
shall also be subjected to the Toxicity Characteristic
Leaching Procedure (TCLP) as described in 40 C.F.R. Part
261, Appendix II, prior to disposal at an offsite RCRA
permitted. subtitle C hazardous waste landfill. The federal
land disposal restrictions contained in 40 C.F.R. SS 268.1
- 268.6, 268.8 - 268.9, 268.30 - 268.37, and 268.40 -
268.43 shall apply to the offsite disposal of any soils
found to exhibit the characteristic of a hazardous waste.
Figure 13 provides an example of a decision tree type
approach for the ultimate disposition of soils removed from
the site. A plan for the disposition of soils shall be
determined during remedial design and shall be subject to
approval of EPA in consultation with the Commonwealth of
Pennsylvania.
Exposed soil from the Site shall be protected from the
effects of weather and comply with the PADER's Bureau of
Soil and Water Conservation Erosion and Sediment Pollution
Control Manual.
The performance standard for this component of the remedy
shall include preparation and EPA acceptance of a surficial
and deep soil sampling program in the Tank Farm/Building #1
Area. The sampling program must include, but not be
limited to, sampling of the soils in the inactive or
unobstructed areas of the Tank Farm/Building #1 area. The
specific number and location of soil samples, and the
analytical parameters and methods to be used shall be
provided in the sampling program and shall be subject to
EPA review and approval in consultation with the
Commonwealth of Pennsylvania.
Description of the Component of the Remedy
SDrav Pield Surficial Soil Samolinq
During the Remedial Investigation, levels of mirex and kepone
were detected in the surficial soil samples from the 1S-acre
spray field area that may be capable of causing adverse
ecological effects. However, the extent of these compounds in
surface soils were not well characterized during the Remedial
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Investigation. A surficial soil sampling program for the 1S-acre
spray field area shall be implemented in order to: (1) evaluate
the environmental risks from the surficial soils; and (2) assess
the need for additional biological studies or remedial action.
Figure 14 illustrates the area defined as the 1S-acre former
spray field area. .
1.
Performance Standards
2. .
10.5
A minimum of 4S surface soil samples, excluding QA/QC
samples shall be collected from the 1S-acre spray field
area and analyzed for mirex, photomirex, and kepone. The
exact number and location of samples for the surficial soil
sampling program for the 1S-acre spray field area shall be
determined during the remedial design phase and shall be
subject to EPA approval in consultation with the
Commonwealth of Pennsylvania.
EPA acceptance of a report summarizing the data generated
from the surficial soil sampling program including
calculation of environmental risks and the need for
additional biological studies or remedial action.
XmDrovements to the Surface Water Drainaae Svstem
Description of the component of the Remedy
Stormwater runoff from the Site is discharged to the surface
water drainage system through the freshwater drainage ditch.
Improvements shall be made to the existing surface water drainage
system to eliminate potential groundwater infiltration into the
underground piping.
Performance Standards
1.
2.
The engineering method to eliminate groundwater
infiltration shall be determined during the remedial design
and shall be subject to approval by EPA, in consultation
with the Commonwealth of Pennsylvania.
The performance standard for this component of the remedy
is as follows: upon completion of the engineering method
to eliminate groundwater infiltration, all underground
piping will be evaluated using video cameras or similar
investigative equipment. The purpose of the evaluation is
to insure that groundwater is not infiltrating into the
underground piping. A report detailing the evaluation
shall be submitted to EPA and the Commonwealth of
Pennsylvania. Repairs will be performed as EPA in
consultation with the Commonwealth of Pennsylvania
determines necessary to eliminate any leakage of
groundwater into the underground pipes. The evaluation
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will be repeated every three (3) years as part of the
operation and maintenance until the groundwater meets the
Performance Standards described in Section 10.1.
10.6
Enaineerina Controls and Hazardous Materials Manaaement for
Surface water Drainaae
Description of the Component of the Remedy
Engineering controls to reduce the potential for any inadvertent
release of hazardous substances from entering the freshwater
drainage ditch shall be implemented at the Site. These
engineering controls shall include, but are not limited to: (1)
stormwater collected from the active tank farm secondary
containment system and/roof drains from production buildings will
be channeled to the groundwater treatment plant for treatment.
prior to discharge to the freshwater drainage ditch; (2)
secondary containment systems will be provided for various areas
in the production area (such as the outdoor material substance
container storage, tank storage, and trailer loading/unloading
areas) and these systems will be coated with an impermeable/wear
resistant material; (3) the discharge system to the freshwater
drainage ditch from the treatment plant and stormwater catch
basins will be improved; (4) the use of stormwater catch basin
covers, which are employed in the event of a spill, will be
maintained; and (5) regrading of unpaved surfaces in the plant
production area will be performed to enhance storm water runoff.
In addition, a Hazardous Materials Management Practices Program
will be developed for the site to reduce the potential for
releases. The hazardous materials management practices program
will include a waste minimization program, and a spill
contingency program.
Performance Standards
1.
The performance standard for this component of the remedy
shall be the preparation of a Surface Water Drainage
Control Plan which addresses at a minimum, items 1 through
5 described above. The exact engineering controls to be
implemented shall be determined during the remedial design
and shall be subject to EPA approval, in consultation with
the Commonwealth of. Pennsylvania.
The performance standard shall include the preparation of a
Hazardous Materials Management Practices Program. The
Program shall be developed during the remedial design and
shal~ be subject to EPA approval, in consultation with the.
Commonwealth of Pennsylvania.
2.
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10.7
Monitorina of Surface Water Discharae
Description of the Component of the Remedy
A long-term surface water monitoring program for the freshwater
drainage ditch shall be implemented to evaluate the effectiveness
of the improvements made to the surface water discharge system
and NPDES Tequirements. A plan for the long-term surface water
monitoring program shall be included in the operation and
maintenance plan for the groundwater extraction and treatment
system. EPA will determine the number of monitoring points
necessary to verify the performance of the remedial action. At a
minimum, the freshwater drainage ditch discharge will be sampled
quarterly for VOCs and select inorganics, and biannually for
mirex, kepone, and photomirex. Numbers and locations of these
monitoring points shall be subject to EPA approval during the
remedial design, in consultation with the Commonwealth of
Pennsylvania.
Performance standards
1.
The performance standard for this component of the remedy
is the preparation and EPA acceptance of a Surface Water
Monitoring Program. The Program must. include, but not be
limited to, monitoring of the groundwater extraction and
treatment system in compliance with the NPDES requirements,
quarterly sampling of the freshwater drainage ditch
discharge for VOCs and select inorganics, and biannual
sampling for mirex, kepone, and photomirex. The specific
location of the monitoring points will be provided in the
Surface Water Monitoring Program and subject to EPA review
and approval in consultation with the Commonwealth of
Pennsylvania.
Excavation and Off site Disoosal of contaminated Sediments
10.8
Description of the component of the Remedy
This portion of the remedy consists of excavation and offsite
disposal of impacted sediments/soils from the freshwater drainage
ditch on the Ruetgers-Nease property (Section A) to a RCRA
permitted subtitle C hazardous waste landfill. To be protective
of environmental receptors, the sediments/soils from the upper
24" of the drainage ditch will be removed. Excavation of
sediments/soils will continue until the sediments/soils left in
place meet the soil and sediment clean-up levels that EPA has
determined are protective of groundwater as set forth in Table 9.
The depth of excavation may be limited by the occurrence of
bedrock.
sediment samples shall be collected and analyzed for VOCs, mirex,
and kepone during the remedial design in order to determine the
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exact area and volume of soils requiring removal. Sediments
requiring removal shall undergo a TCLP test as described in 40
C.F.R. Part 261, Appendix II, prior to offsite disposal in order
to determine whether those sediments exhibit the characteristic
of toxicity. All excavated sediments containing kepone above 160
ppb for offsite disposal will be considered a RCRA listed waste
as discarded material U142. If required, thermal treatment of
the excavated sediment would be used to meet RCRA land disposal
regulations.
Post-excavation sampling will be performed after the excavation
is completed. Post-excavation samples will be obtained from the
base and the sidewalls of the ditch to ensure that contamination
is not present above the clean-up level. The location of the
post-excavation samples will be selected based on visual
observation of lithology and screening for VOCs using an
appropriate organic vapor detector. The samples will be analyzed
for VOCs on a quick turnaround basis using a method approved by
EPA. If the post-excavation sample concentrations are below the
clean-up level, the excavated area will be backfilled using clean
soil. Additional clean borrow material will be brought in to
restore the excavation to original grade.
If VOCs are detected at levels above being protective of
groundwater in the post-excavation samples, additional material
will be removed from the excavation area, and new samples
obtained for analysis as discussed above. Excavation and
sampling activities will continue until the results indicate that
the sediments/soils do not contain contaminants of concern above
the clean-up levels. The excavation area will then be restored
as described in the preceding paragraph.
Performance standards
1.
The performance standard for this component of the remedy
is to remove all sediments/soils from the upper 24" of
section A of the freshwater drainage ditch to be protective
of environmental receptors. Excavation of sediments/soils
shall continue until the sediments/soils left in place meet
the soil and sediment clean-up levels that EPA has
determined are protective of groundwater as set forth in
Table 9. The depth of excavation may be limited by the
occurrence of bedrock. The exact areas targeted for removal
shall be determined during the remedial design and shall be
subject to approval of EPA in consultation with the
Commonwealth of Pennsylvania.
Excavated soils containing kepone above the risk based
concentration of 160 ~g/kg will be considered a RCRA listed
waste as discarded materialU142. Soils requiring removal
shall also be subjected to the Toxicity Characteristic
Leaching Procedure (TCLP) as described in 40 C.F.R. Part
2.
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261, Appendix II, prior to disposal at an offsite RCRA
permitted subtitle C hazardous waste landfill. The federal
land disposal restrictions contained in 40 C.F.R. Part 268
shall apply to the offsite disposal of any soils found to
exhibit the characteristic of a hazardous waste. Figure 13
provides a decision tree type approach for the ultimate
disposition of soils removed from the Site.
3.
Exposed sediments from the freshwater drainage ditch shall
be protected from the effects of weather and comply with
the PADER's Bureau of Soil and Water Conservation Erosion
and Sediment Pollution Control Manual.
4.
The performance standard shall include preparation and EPA
acceptance of a monitoring plan for the sediments in
section A of the drainage ditch after the remedial action
is complete to assure that the residual contamination
remains in place and does not migrate. The exact number
and location of samples from Section A of the drainage
ditch shall be determined during the remedial design phase
and shall be subject to EPA approval in consultation with
the Commonwealth of Pennsylvania.
Fish Tissue and S~ream Channel Moni~orina
10.9
Descrip~ion of ~he componen~ of ~he Remedy
A spring Creek fish tissue and sediment monitoring program shall
be implemented during the remediation phase. The program will
provide data to evaluate the contamination trends of spring Creek
to determine whether the fishing advisory may be lifted in the
future. Stream channel sediment monitoring will provide data to
assess the progress of the natural attenuation and sediment
deposition processes. EPA, in consultation with the Commonwealth
of Pennsylvania, will determine the number and location of
sediment samples and fish tissue analyses to be included in the
monitoring program during the remedial design phase. The
frequency and duration of sampling and the analytical parameters
and methods to be used will be determined by EPA, in consultation
with the Commonwealth of Pennsylvania, during the remedial design
phase.
In the event that fish tissue levels decrease to below the
established FDA action levels of 100 ~g/kg for mirex and
300 ~g/kg for kepone, an intensive Short-Term Fish Tissue Survey
will be required to support cancelling the "No-Kill Zone" on
Spring Creek. The Survey will be petitioned by the PRP(s) and
EPA, in consultation with the State of Pennsylvania and will
determine number of species, location, and sampling frequency to
be included in the Survey.
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Performance standards
1.
The performance standard for this component of the remedy
is the preparation and EPA acceptance of a Spring Creek
Fish Tissue and Sediment Monitoring Program. The
Monitoring Program must include, but not be limited to,
annual monitoring of the Spring Creek sediments and fish
tissue for mirex and kepone. No less than six (6) sediment
samples and 6 biota (3 upper trophic and 3 lower trophic)
samples shall be taken from Spring Creek during preferred
seasons of March/April or August/October. The specific
location of the monitoring points and the sampling season
shall be provided in the Monitoring Program and is subject
to EPA review and approval in consultation with the
. commonwealth of Pennsylvania.
The performance standard for fish tissue sampling is that
it be done according to Pennsylvania Department of
Environmental Resources protocol (PADER publication #33).
2.
3.
Monitoring of fish tissue and Spring Creek sediments shall
continue for an estimated 30 years or such other time
period as EPA, in consultation with the Commonwealth of
Pennsylvania, determine to be necessary based on the
statutory review of the remedial action which shall be
conducted no less often than every five years from
initiation of the remedial action in. accordance with the
EPA guidance document, structure and Components of Five-
Year Reviews (OSWER Directive 9355.7-02, May 23, 1991).
4.
In the event that fish tissue levels decrease to below the
established FDA Action Levels for mirex and kepone of 100
~g/kg and 300 ~g/kg, respectively, the PRP(s) may petition
to conduct an intensive Short-Term Fish Tissue Survey to
support cancelling the "No-Kill Zone" on Spring Creek. The
performance standard for this component of the remedy, is
the preparation and EPA acceptance of a Short-Term Fish
Tissue Survey. The Survey must include fish tissue
sampling from a minimum of two (2) biota (brown trout and
white suckers) during the March/April and August/October
seasons from a minimum of five (5) locations. The specific
location of the monitoring points will be provided in the
Survey and subject to EPA review and approval in
consultation with the Commonwealth of Pennsylvania.
10.10
onsite and Offsite pencina
Description of the Component of the Reme4y
The chain-link fence on the Ruetgers-Nease Corporation's property
shall be extended to include the former spray field and the
former drum staging areas in order to prevent unauthorized access
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to the Site. In addition, a chain-link fence shall be
constructed around Thornton spring and its' drainageway channel.
1.
Performance standards
2.
3.
10.11
A chain-link fence shall be extended on the Ruetgers-Nease
Corporation's property to include the former spray field
and the former drum storage areas. In addition, a chain-
link fence shall be constructed around Thornton Spring and
it's drainageway channel. The fence shall have a minimum
height of six feet and shall be equipped with a locking
gate(s). The exact location and specifications of the
fence shall be determined during remedial design and is
subject to EPA approval in consultation with the
Commonwealth of Pennsylvania.
A plan for the 'maintenance of the fenced areas shall be
submitted to EPA and the Commonwealth of Pennsylvania for
approval during the remedial design phase.
The fence shall be maintained until such time as EPA, in
consultation with the Commonwealth of Pennsylvania,
determines that access restrictions are no longer required.
Deed Restrictions
Description and Performance Standard for the Component of the
Remedy
Within 30 days after the lodging of Consent Decree, restrictions
shall be placed on the deed of the site (Ruetgers-Nease
Corporation) to prohibit: (1) use of the property for
residential, commercial, or agricultural purposes; and, (2) the
use of on site groundwater for domestic purposes, including
drinking water. The deed restrictions shall remain in effect
until EPA, in consultation with the Commonwealth of Pennsylvania,
determines that they are no longer required to protect human
health and welfare, and the environment.
10.12
Description of the Component of the Remedy
RiDarian-Area SamDlina
Limited data was available from riparian-area soils of spring
Creek during the Remedial Investigation. A sampling program for
riparian-area soils shall be implemented in order to: (1)
evaluate Site impacts on the riparian-area soils of spring Creek,
including the lower portion of the freshwater drainage ditch
(Section B), the Thornton Spring outlet and drainage channel, and
the depositional area of beyond the Benner Fish Hatchery; (2)
assess environmental risk from the floodplain sediments; and (3)
determine the need for additional remedial action.
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Soils and sediment samples shall be collected from the riparian-
areas of Spring Creek, the lower portion of the freshwater
drainage ditch, the Thornton Spring outlet and drainage channel,
and the depositional areas of beyond the Benner Fish Hatchery.
The exact number and location of samples will be determined by
EPA, in consultation with the Commonwealth of Pennsylvania,
during the remedial design phase. These samples shall be
analyzed for mirex, photomirex, and kepone.
Performance Standards
1.
A work plan for the sampling of the riparian-area soils of
Spring Creek, including the lower portion of the freshwater
drainage ditch (Section B), the Thornton Spring outlet and
drainage channel, and the depositional areas beyond the
Benner Fish Hatchery shall be prepared. The exact number
and location of samples and the analytical parameters and
methods to be used will be determined by EPA, in
consultation with the Commonwealth of Pennsylvania during
the remedial design phase.
2.
"EPA acceptance of a report summarizing the data generated
from the riparian-area sampling program including
calculation of environmental risks from the floodplain
sediments and the need for additional biological studies or
remedial action.
11.0
STATUTORY DETERXIRATIOHS
EPA's primary responsibility at Superfund sites is to undertake
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C. S
9621, establishes several other statutory requirements and
preferences. These requirements specify that when complete, the
selected remedial action for each site must comply with
applicable or relevant and appropriate environmental' standards
established under federal and state environmental laws (ARARs)
. unless a statutory waiver is invoked. The selected remedy also
must be cost effective and utilize treatment technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that permanently and significantly reduce
the volume, toxicity or mobility of hazardous substances. The
following sections discuss how the selected remedy for this Site
meets these statutory requirements.
11.1
Protection of Human Health and the Environment
Based on the Baseline Human Health Risk Assessment for the Site,
measures should be considered to reduce potential risk from four
sources: (1) VOCs in groundwater, (2) VOCs in Thornton Spring
surface water, (3) mirex in onsite soils, and (4) mirex in
71
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recreational fish. These media and contaminants were selected
because potential health hazards for some exposure scenarios
exceeded a lifetime cancer risk of 10-6 or a non-cancer hazard
index of 1. The results of the Environmental Risk Assessment
show a potential for risk to ecological receptors for all media
examined.
The selected remedy protects human health and the environment by
reducing levels of contaminants in the groundwater and Thornton
Spring surface water to those required by ARARs through
extraction and treatment and by instituting deed restrictions for
the site. The groundwater extraction and treatment system shall
reduce the levels of contaminants of concern in the groundwater
to achieve MCLs as required by the S~fe Drinking Water Act, 42
U.S.C. SS 300(f) - 300(j) and 40 C.F.R. SS 141.61 or the
background concentrations (the Pennsylvania ARAR under 25 PA Code
SS 264.90 - 262.100, SS 264.97(i), (j), and 264.100(a) (9»,
whichever is more stringent.
The excavation of soil and sediments onsite will protect human
health and the environment by removing the contaminated soil,
thereby eliminating the potential for contaminant migration to
the groundwater and preventing exposure through inhalation,
ingestion, and dermal contact. Excavation of drainage ditch
sediments will also reduce aquatic toxicity and bioconcentration
of mirex and kepone through exposure to contaminated sediment to
both aquatic and terrestrial populations. .
Implementation of the selected remedy will not pose any
unacceptable short-term risks or cross-media impacts to the Site
or the community.
11.2
comDliance with ADDlicable or Relevant and ADDroDriate
Reauirements
The selected remedy will comply with all applicable or relevant
and appropriate chemical-specific, location-specific and action-
specific ARARs. Those ARARs are:
Chemical-Specific ARARs
The selected remedy will be designed to achieve compliance with
chemical-specific ARARs related to groundwater and ambient air
quality at the Site. The contaminants from the Centre County
Kepone site and their respective MCLs which are listed under the
performance standards of section 10.1 of this ROD are relevant
and appropriate for this remedial action. If a non-zero Maximum
Contaminant Level Goal ("MCLG") has been established, the MCLG
shall be attained by the remedy~ .
The Commonwealth of Pennsylvania standards specify that all
groundwater containing hazardous substances must be remediated to
72
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L
"background" quality as set forth in 25 PA Code SS 264.90 -
264.100, and in particular, 25 PA Code SS 264.97(i), (j)r and
264.100(a) (9). The requirement that all groundwater be
remediated to background levels is an ARAR if background levels
are determined to be more stringent than the appropriate.MCLs or
non-zero MCLGs. The methodes) by which background levels will be
determined are set forth under the description of the selected
remedial alternative contained in Section 10. These background
levels, if more stringent than the appropriate MCLs or non-zero
MCLGs, shall be attained as part of the remedial action.
However, if EPA and the Commonwealth of Pennsylvania determine
that attaining such levels is technically impracticable, EPA may
amend the ROD or issue and Explanation of Significant Differences
to address this situation.
Location-specific ARARS.
The Pennsylvania Erosion Control Regulations, 25 PA Code SS 102.1
- 102.5, 102.11 - 102.13, and 102.21 - 102.24, regulate erosion'
and sedimentation control. These regulations are applicable to
the regrading and excavation activities associated with the
selected remedial alternative.
The Dam Safety
105.3, 105.12,
the freshwater
Commonwealth.
and waterway Management Act, 25 PA Code SS 105.1 -
and 105.19 are location-specific regulations for
drainage ditch as it is considered a water of the
40 CFR S 6.302(a), (b), and (g) addressing wetlands, floodplain,
and fish and wildlife apply to the groundwater, freshwater
drainage ditch, and Thornton Spring selected remedial
alternatives.
Action-specific ARARs
Any surface water discharge of treated effluent will comply with
the substantive requirements of. the NPDES discharge regulations
set forth in 25 PA Code SS 92.1 and 92.31, the applicable
Pennsylvania Water Quality Standards set forth in 25 PA Code
Chapter 93, and the Pennsylvania Water Treatment Regulations (25
PA Code SS 95.1 - 95.3 and 97).
VOC emissions from any air stripping tower will be governed by
the PADER air pollution regulations. Air Emissions will also
comply with 40 C.F.R. SS 264.1030 - 264.1034 (Air Emission
Standards for Process Vents), and with 40 C.F.R. SS 264.1050 -
264.1063 (Air Emissions Standards for Equipment Leaks). Air
emissions of. Vinyl Chloride will comply with 40C.F.R. Parts
61.60 - 61.69, National Emission Standards for Hazardous Air
'Pollutants (NESHAPS).
73
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Air permitting and emissions ARARs are outlined in 25 PA Code SS
121.1 - 121.3,121.7,123.1,123.2,123.31,123.41,127.1,
127.11, 127.12, and 131.1 - 131.4; 25 PA Code S 127.12 requires
all new air emission sources to achieve minimum attainable
emissions using the best available technology ("BAT"). In
addition, the PADER air permitting guidelines for remediation
projects require all air stripping and vapor extraction units to
include emission control equipment. However, the permitting
regulations allow for exemptions if a source is considered to be
of "minor significance," or if emission controls are not
economically or technically feasible. During design of the air
stripping unit, PADER shall determine from actual design flow
rates and VOC loading rates whether emission controls need to be
installed.
The groundwater collection and treatment operations will
constitute treatment of hazardous waste (i.e., the groundwater
containing hazardous waste), and will result in the generation of
hazardous wastes derived from the treatment of the contaminated
groundwater (i.e. spent carbon filters and filter bags).
Treatment of groundwater will be implemented consistently with
the requirements of 25 PA Code SS 262.11 - 262.13 (relating to
hazardous waste determination and identification numbers), and
25 PA Code S 262.34 (relating to pretransport requirements).
Fugitive ~ust emissions generated during remedial activities will
be controlled in order to comply with fugitive dust regulations
in the federally-approved state Implementation Plan ("SIP") for
the Commonwealth of Pennsylvania, 25 PA Code SS 123.1 - 123.2.
25 PA Code SS 123.31 and 123.41 which prohibits malodors
detectable beyond the Ruetgers-Nease Corporation property line is
applicable to the selected remedial alternative.
25 PA Code SS 264.90 - 264.100 (Subchapter F), regarding
groundwater monitoring is applicable to the selected remedial
alternative.
25 PA Code SS 16.23, 16.101, 16.102, and Appendix A (Tables 1 and
2), Water Quality Toxics strategy, will apply for water quality
guidance at Thornton Spring and the freshwater drainage ditch.
Since residuals will be generated in the soilds filtration
portion' of the treatment system and the spent GAC carbon filters
and contaminants will exist in the excavated soil and sediments,
these will first be tested to determine if kepone levels are
above the health-based risk concentration of '160 ppb. If kepone
concentrations are below 160 ppb, these will be tested to
determine if they are RCRA characteristic wastes in accordance
with 40 C.F.R. S 261.24 by the Toxic Characteristic Leaching
Procedure ("TCLP"). If any of these are determined to be
hazardous waste or if kepone concentrations are above 160 ppb,
the remedy will be implemented consistent with the substantive
74
-------
/
requirements, which are relevant and appropriate, of PA Code SS
262.11 - 262.13 (relating to hazardous waste determination and
identification numbers), 25 PA Code S 262.34 (relating to
pretransport requirements); and if prohibited by land disposal
restrictions~ 40 CFR SS 268.1 - 268.6, 268.8 - 268.9, 268.30 -
268.37, and 268.40 - 268.43. EPA does not presently.have
sufficient information to determine whether the constituents are
hazarqous wastes; however, as noted above, EPA shall require the
performance of kepone and TCLP testing to address this and 40 CFR
S 268.50 (prohibitions on storage of hazardous waste) which are
relevant and appropriate to this action. Waste "residuals"
generated from the solids filtration portion of the treatment
system and the spent GAC carbon filters that are TCLP
characteristic wastes will be considered as hazardous waste and
will be treated and/or disposed in compliance with the applicable
regulations~ .
Modifications to the onsite storm water drainage system will be
required to meet the requirements under Pennsylvania's storm
Water Management Act, 32 P.S. SS 680.1 - 680.5, and S 680.13, and
25 PA Code 111.14 (Scope of Study).
To Be Considered ("TBC") Standards
Pennsylvania's Ground Water Quality Protection strategy, dated
February 1992 and EPA's Ground Water Protection Strategy, dated
July 1991 are TBCs.
Existing pumping and monitoring wells which serve no useful
purpose will be properly plugged and abandoned consistent with
PADER's Public Water Supply Manual, Part II, section 3.3.5.11.
aWSER Directive #9355.0-28, Control of Air Emissions from
Superfund Air strippers at Superfund Ground Water Sites, is a "to
be considered" (TBC) requirement. .
The PADER document entitled "Cleanup Standards for Contaminated
Soils", dated December 1993, is a TBC requirement that
establishes soil cleanup standards deemed to be acceptable under
the residual waste regulations.
Sediment and erosion controls and temporary covers will be
installed to protect exposed soil from the effects of weather in
accordance with PADER, Bureau of Soil and Water Conservation's
Erosion and Sediment Pollution Control Manual.
1.1..3
Cost-Effectiveness
The selected remedy for aU1 is cost-effective in providing
overall protection in proportion to cost, and meets all other
requirements of CERCLA. Section 300.430(f) (ii) (D) of the NCP
requires EPA to evaluate cost-effectiveness by comparing all the
75
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alternatives which meet the threshold criteria - protection of
human health and the environment and compliance with ARARs -
against three additional balancing criteria: long-term
effectiveness and permanence; reduction of toxicity, mobility or
volume through treatment; and short-term effectiveness. The
selected remedy meets these criteria and provides for overall
effectiven~ss in proportion to its cost. The combined estimated
present worth cost for the selected remedy is $15,863,000.
Detailed capital and O&M cost estimates for the alternatives
included in the selected remedy are shown in Tables 1LA through
11E.
11.4
utilization of Permanent solutions and Alternative
Treatment Technoloaies to the MAyimum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized while providing the best balance
among the other evaluation criteria. Of those alternatives
evaluated that are protective of human health and the environment
and meet ARARs, the selected remedy provides the best balance of
tradeoffs in terms of long-term and short-term effectiveness and
permanence, cost, implementability, reduction in toxicity,
mObility, or volume through treatment, state and community
acceptance, and preference for treatment as a principal element.
Under the selected remedy, groundwater extraction through source
and migration control wells and treatment of groundwater using
GAC (GW/TS-3) is more cost-effective than the other alternatives
evaluated. In addition, the area of attainment is increased
under this alternative. Alternative GW/TS-3 will" reduce
contaminant levels in the Class I aquifer, a special source of
groundwater, and reduce the risks associated with direct contact
and ingestion of the groundwater to the maximum extent
practicable, as well as provide long-term effectiveness.
The selection of SS-2, excavation and offsite disposal of
contaminated soils, is consistent with Superfund program policy.
The remedy provides the highest degree of long-term effectiveness
and permanence, reduces mObility and reduces risk to human health
and the environment.
Source control measures for the Site surface water (FWDD/SW-2A)
provides the highest degree of long-term effectiveness among the
alternatives considered and it is cost-effective. Alternative
FWDD/SW-2A will eliminate groundwater infiltration into the
surface water drainage system and provide engineering controls to
reduce the potential for any inadvertent releases of hazardous
substances from entering the freshwater drainage ditch.
Excavation and offsite disposal of contaminated sediments
(FWDD/SED-2) is consistent with Superfund program policy.
The
76
-------
remedy provides the highest degree of long-term effectiveness and
permanence, reduces mobility and reduces risk to human health and
the environment.
Institutional controls and monitoring of Spring Creek (SC-2)
provides the best balance of trade-offs in terms of long-term
effectiveness and permanence, short-term effectiveness, and
implementability to support lifting the fishing advisory on
spring Creek. It is also more cost effective than the other
alternatives since it is unknown what the combined effects will
be from implementing the other alternatives selected in this ROD.
11.5
Preference for Treatment as a princiDal Element
The selected remedy satisfies, in part, the statutory preference
for treatment as a principal element. The contaminated
groundwater alternative addresses the primary threat of future
direct contact, inhalation, and ingestion of contaminated
groundwater through treatment using a GAC system. If required,
the treatment of soil/sediments that pose principal threats to
human health or the environment will satisfy the statutory
preference for treatment as a principal element.
12.0
DOCUMENTATION OP SIGNIPICANT CRAHGES
The Revised Proposed Plan for the Centre County Kepone Site was
released for public comment on January 27, 1995. EPA reviewed
all written and verbal comments submitted during the public
comment periods on the original and revised proposed plans. The
following changes have been made to the Selected Remedies from
the preferred alternative described in the Revised Proposed Plan.
1.
2.
3.
The selected alternatives for subsurface soils and
sediments at the Site identify kepone as an origin RCRA
listed waste (U142) at concentrations above the health-
based risk concentration of 160 ppb. Soils and sediments
with concentrations above that level destined for offsite
disposal will be subject to the LOR treatment standard of
0.13 mg/kg total.
The disposition of contaminated soils and sediments, even
if treatment is necessary, has been clarified to be a "RCRA
permitted subtitle C hazardous waste landfill" rather than
a "permitted treatment, storage, and disposal (TSD)
facility".
The selected alternative for remediation of subsurface
soils at the Site has been clarified to indicate that a
surficial and deep soil sampling program be performed in
the Tank Farm/Building #1 Area. This area was not fully
characterized during the RI/FS due to the presence of
77
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4.
5.
storage tanks which have since been removed. In addition,
construction of a rail tank car loading/unloading facility
is planned for the area. The purpose of the sampling
program will be to fully characterize the soils and assess
the need for additional excavation. The cost of
remediation for this area was not factored in the FS cost
estimate. However, the size of the area is approximately
500 feet by 200 feet. This change was made in response to
several comments received by the Agency.
The selected remedial alternative for remediation of
freshwater drainage ditch sediments has been clarified to
include all of section A of the drainage ditch and not be
limited to the upper forked portion. The cost estimate in
the RQD reflects remediation of only the upper forked
portion. The cost of remediation for the lower portion of
the drainage ditch is estimated at $120,000 (an additional.
260 cubic yards). This change was made in response to
several comments received by the Agency.
6.
The Proposed Plan included a 10 ppb cleanup standard for
mirex and kepone for protection of environmental receptors
in the onsite freshwater drainage ditch sediments and
soils. Since there are analytical concerns regarding the
ability to assess this low level of contamination,. EPA has
included a standard of performance which is equivalent to
the 10 ppb cleanup standard. This performance standard
will require the upper 24 inches of sediment/soil be
removed from the freshwater drainage ditch (regardless of
kepone and mirex concentrations). This change was made in
response to comments received by the Agency.
The Proposed Plan addressed EPA's intention to divide the
site into two operable units (QUs). QUI will remediate the
groundwater, surface water, sediment and soils at the Site
(excluding the IS-acre former spray field area) QU2 will
address the spray field area and the riparian-areas of
Spring Creek. It has become apparent to the Agency that
the terminology contained in the Environmental Risk
Assessment could be interpreted to exclude the Former Drum
Staging Area from QUI. Based on comments received by the
Agency, the Former Drum Staging area will be remediated as
part of QUI.
78
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APPENDIX A - FIGURES
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FIGURE 2
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. RUETGEAS-NEASE CORPORAl1ON
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LOCATION MAP
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KEPONE
MlR£)(
CL VOl AVENUE
~
MW-36D RND. 3
ACETONE 23
2-BUTANONE 28
2-H~:xANONE 3 J
METIffiDIE CHLORID~ 2 J
PeE 2J
TOlUENE 2 J
1.1.I-TCEa II J
JM.ENES (TOTAl) 1 J
KEPONE NO 0.132
MIREX ND 0.00544
---
1IW-35S
AU \/DC.
KEPONE
MlREX
OW-D 1/"-'"
II'1r 100 "
-55 "
\ jl.::.::=: == ==-- ---'
. '- -- ---==-==---::::- ..- -
IW-3S
r-4S
1IW-335A
ET1M.BD12ENE
PCE
TOlUEHE
XYLENES
K£POHE
MIREX
IIW-JOS
ACETOHE
KEI'OIff
WREX
IIND.3
:5 J
HA
HA
AND. 3
1500
54J
800
OTAL 4800
0.58
0.0088 J
1IW-2eD RND.
IIOIZDIE :5J
CItt.OII08DIZfHE ND
1,1-0C£a 2 J
1.2-0C£a NO
EnM.II£HZENE :5 J
TOlUENE 21
TCf 14
xn.EN£S (TarAL) 18
KEfIONE HA
YIIEX HA
AND. 3
1400
20
OTAl 80
NO 0.132
NO 0.00544
RHO. J
II J
4 J
NO
J
NO
NO
NO
NO
HA
HA
1IW-1
BENZENE
1,1-O<:Ea
1,2-0CE (TOTAL)
MEnfrLEN£ CHLORIDE
1,I,1-TCEa
1,1.2-TCEa
TCE
K£f'OI\E
MIREX
1IW-400 RHO. 3
BENZENE 120 J
CHLOR08EIfZENE 240
1,2-DC[. (TarN..) 1400
EnMBENZENE 280
UE1IM£HE CHLORIDE 14 J
PCEo 23 J
TOWENE 07 J
1,I,I-TCfo 13 J
TCE 81 J
VINYl CHlDRlDE JJD
~ trOTAL\
IIJRD(
lsr~ lIWii240
'CNUt ~
I
/r'--~
----
1IW-25S/D
o
RND.3
7 J
1 J
2 J
HA
HA
1IW-310
=--
~---
----
1IW-301D
8£HZENE '
1,2-DeE
mm..BENZENE
PC£a
TOLUENE
1,1,1-TCEa
TCE
VINYl CHLORIDE
01
IIND.3
2 J . I
2 J
4 J I
1 J 0
34
1 J
2 J
NA I
~
IIND.3
J50 J
1700
1700
03 J
8500
40 J
50 J
180 J
LEGEND
MW-20
o
MONITORING WElL NUMBER
(5) SHAI.LOW
(D) DEEP
(5/0) IIONITORS 2 ZONES
GROUNOWAn:R
COu.EcnDN SUUP
...
CYCLONE fENCE
IWlJI(W) lRACKS
~Ea 1,1,2,2- n:1RACHLORO~
1,2 OCE (TOTAL) 1,2-DICHLOROETHENE .
1,1,1 TCEa 1,1,1- TRtCHLORO£lHANE
1,1,2 TCEa 1,I,2-1R~E
TCE TRlCHlDROETHENE .
PCE . TElRACHLOROET'HENE
1,1OCEa 1,1-0ICHLOROEnWIE
1.2 OCEa 1,2-OICHLOIIOf:DWjE
AU VALUES REPORTED IN PPB
J - QUANmATlON IS APPROXlIlATE
OUE TO UIotITATIONS ID£HI1fIED OURIIM .
THE QUAU1Y ASSURNa R£VIEW .'/'
(DATA VAUDAfI!IH) . ~ .
ND - COMPOUND WAS NOT DETECTED . ' !
HA - NOT ANAl. VZED
ND xx. - NOT Dmcn:o WITH
DETEcnON UMIT
* - ANAl. YSlS PERFORMED AT
SECONOAR'( DIlunON
~ .
COMPOUNDS NOT omCTEO IN BOTH
ROUNDS ARE NOT USTED. .
ww..s WITHOUT II RESULTS BLOCK 1,-
WERE NOT SAMPLED. /
RUETGERS-NEASE
CHEMICAL CO., INC.
STATE COLLEGE, PA.
REMEDIAL INVESTIGATION REPORT
FIGURE 5
ROUNDS 2A & 3
GROUND WATER SAMPLING VOC
AND MIREX KEPONE RESULTS
~ sue ENVIRONMENTAl.
IIijJJ SERVIGES- GROUP
Engk1_.. lIanag... SclanU.I. .. PI...n..
.w.a "'1111. PoL
SI;AlE: 1. -200'
DAn::
7/24/02
-------
"ROUTE 26
SW-4/SED-4
TS-1 TS-2
DATE' 6/26/91 7/15/91
TOTAl.. VOlA11L£S 8Y1 1822
THORNTON SPRING
:~~I~:C WlA1n£S16'::T,':f'1
~~ WLA11L£S16/=' 17/~911
/~
LEGEND
RUETGERS- NEASE
CHEMICAL CO., INC.
STATE COLLEGE, PA
RGURE 6
THORNTON SPRING
AIR & SURFACE WATER
VOC SAMPLING RESULTS
~ SMC ENVIRONMENTAL
II!lP SERVICES- GROUP
- RESULTS OBTAINED FROM
DILUTION ANALYSIS
. - SURFACE WATER SAMPLING
AA4 - AIR MONITORING STATION
o
POINT
V~ rom&. P.I.
SCAI.£: ,. ..40'
DATE:
7/1/92
-------
1-----;
/'
/
//
/1
.'" ~ ;..,/
/
....... .
I "---
/~~
LEGEND
CYClONE fLNCE
.
RAILROAD TRACKS
PHASE I SURACIAL SOIL
SAMPUNG lOCAnON
.
PHASE II SURFICIAL SOIL
SAMPUNG lOCAnON .
All VAlIlES REPORTFO IN PPB
NA - NOT ANAl. YlED FOR
. - RESULTS REPORTED moM A
SECONDARY DllunON ANAlYSIS.
J - QUANnTAnON IS APPROXIMAtED
DUE TO UNITAnONS IDEtmAED DURING
lHE QUAIJTY ASSURANCE REVIEW
(II4TA VAUlI4nDN)
B -
QUAUTAlML Y SUSPECT SINCE
COIotPOUND WAS rOUND IN FI£l.D
AND/Oll lAB BlANK.
NO xxx -
NOT DElECTEO WITH
DETECTION UNIT
.tI.QI£S:
COIotPOUNDS WHICH WERE NOT DElEClED
ARE NOT USTED.
S$-4 RESULTS ON AGURE 4-8
SS-4 IS ACTUAlLY"
SEDIIiENT SAMPLE
/~
RUETGERS- NEASE
CHEMICAL CO., INC.
STATE COLLEGE. PA.
REMEDIAL INVESTIGATION REPORT
FIGURE 7
PHASE I & II
SURfACE SOIL SAMPLING
VOC MIREX/KEPONE RESULTS
~ sue ENVIRONMENTAL
IIUP SERVlC;ES. GROUP
Engln_.. Nanog.... Sclenllsts " Plann...
'WEt rom.. fA.
SCAlE: t" - 200'
1141E:
7/1/92
-------
DIPIII< .4-4
~ :'-:11
-- 181 11.5
11-48 - 80-8
IDIAL WllAIUS I8J I
IClPOC .. ".0
- 1871
101M. WllA1US )nlO J
KUI-VOtAntD (fen) 180 J
k[fOII[ I'" J
111110 n.I
-- sa
1.081£
'-3
I
lOW. WllAIIUS PMO I
8t(POH£ ItD ".0
IIIIIIJC UII
38 - 1"-1
IDW. WU1US 14M!)'"
~ ~I~'"
S8-X - m-'
- WlAIUI U1I1I0
- )5.41
- 11.3
, -
-----,
, ,
, I
, I
, I
,
-
UlJ .
3.811 --
7t-J
III 18.0
1-" J
II
'710
NO ".0
'UI
101M. WilAIUS 'J
- ""II..
U8pC III
SIi-. 101-12
101M. WllAIUS 3 I
- NO"..
.... .....
IU70
...-
I8IIU.Jo
a
~
--
-
-
IVIM. WllAIUS 145.
- III ".0.
.... ..., ,
- so:
lMU:
4-3
ur-'~
) =---
'/ r--~
LEGEND
.. .
! .
-- CYCLONE ftHCE
- fWLRIWI TRACkS
PHASE I DEPIH - DISCRETE
SOIL BORING lOCAUON
PHASE H OEPIH-DISCIIETE
SOIL BORING lOCA1IOIIS
AlL VAlUES REPORIDI IN PPR
~
.
.
UL - ntlS COYPOUND WAS NOT DE1tC1tO !
BUr THE QUAN1ITA11ON UIoIIf IS
PROIIA8t.Y HIGHER DUE TO A lIAS
'OEHIIflED DURING THE QUAU1Y
ASSURANCE RE'JI[w. . I
J - QUNfmA1ION IS APPROXlMA1tO . I
DUE TO UIIITA1IOHS 1OEHIIf1D) ~ i
'!HE QUAUIY ASSURANCE R£\'IIW '.
(DATA VAUDA11OIt) ~
. - RESULTS REPOR'ltO F1IOII A
DlLunON ANAlYSIS.
.;: I
NOTES: ~ .
COMPOUNDS WHICH WER£ NOT DETEGItD ".
ARE NOT LImO WTIIt tHE DCfPI10N Of . :,
TCl SOII-\/OLAtIlE ANALYS£8 AND T,\L ~~.
IHOROAtIIC ANALYSES. " ,
.!
~~~LEs~~ :.~~o:: .
1N0RlW«C ANAlYSES WDI£ f'IJIf'ORMm ~..
SAt.lPlES S82-,,- 81M-A NCO m-A, , :!
NO "". - NOT D£TEatm WITH
DmcnON UUIf.
(0) -DillY LOW lLVt\.S ATRl8111m TO
BlANk CONJAUlNA1ION WEllE F'QUND.
/~
RUETGERS-NEASE
CHEMICAL CO., INC.
STATE COLLEGE, PA.
REMEDIAL INVESTIGATION REPORT
FIGURE 8
PHASE I &: II
DEPTH-DISCRETE SOil
SAMPLING RESULTS
~ SYC ENVIRONMENTAL
IIUP SERVICES- OROUP
Engln- I. Nanoger.. So,..UlI, . Plonn.,
'WD rollll. 'A.
SCAlE: 1".200.
I DATE:
0/10/112
-------
----
I
- ~--- -=-. - -~=-----=-=-:::..:....;----==--=._.=--~.-._~_.,..--~ ------"'-'""=""-----=
LEGEND
$ SWI/SEDI
SURFACE .AltR/SEDlYEIIt
SAMPLING L0CA1IoN
NO - NOT DETEC1m
NO """ - HOT DETECTED WIIH
DETEC'IION UIIIT
NOTE: ALL RESUlTS ARE IN ppb
B - THIS RESULT 15 QUALlTATMLY
SUSPECT SINCE THIS COIIPOUHO
WAS DETEC1m IN f1£I.D ='=
lAIIORATORY BlANKS AT
L£VELS .
J - QUNffiTATION IS APPROXIIoIATE
DUE TO UWITATIONS IDOfTIfIfD
DURING THE QUAUTY ~
REVIEW (QATA VAUOATlON)
..~
~
J.
I
,.
."
~
t
I~ j
SCALL:
Y 1000 2000 (fUT)
I I
RUETGERS-NEASE
CHEMICAL CO.. INC.
STATE COLLEGE, PA.
REMEDIAL INVESTIGATION REPORT
. AGURE 9
PHASE 1
SURFACE WATER / SEDIMENT
VOC, MIREX AND KEPONE
SAMPLING RESULTS
~ sue ENVlRONYENT At
IQ1JJ SERVICES GROUP
£no~_.. "''''0'''''' Scl8n1181. .. Plonn..
yw.a "'811. ,4.
SCAl£: AS SHOWN
QAT[:
8/24'11
- -- --~
-- -. ----
- - - ----
-------
\
I. I'
,.
\
'.
r
LEGEND
.
SURf ACt WI\1[ft / 3EDIMENT
SANPUNG LOCATION
DATA QUAUnERS
J - OUNItnATIOtI IS APPROXIL\ATE
DUE TO UUII'A11ONS IO£NJIfIEO
DURING THE QUAlIIV ASSURANCE
REVIEW (DATA VAUDA11ON)
. - REPORttD fROM A DILUTION NW.'I5tS
B - THIS RESULT IS QUAUTA1IVEL Y
SUSPECT SINCE THIS COMPOUHD
WAS DETECTED IN FIElD AHD/DR
lABORATORY IIlAAKS AT SIMIlAR
l£VElS
UL - THIS COI.IPOUNO WAS HOT OETECTtD,
. BUT THE QUAHTITATIOH UMIT 15
PROIIAIIlY HIGHER DUE 10 A lOW
BIAS IOEHTlnED DURIHO THE
QUALnY ASSUIWICE REVIEW
HaTE: All VAlUES IN ppb
COI.IPOUHDS WHICH WERE HOT DETECTtD
IN Nf'( Of THE SANPl£S COU£CTED AT
A SANPlING LOCATION ARE NOT usrm
HO ... - NOT OETECTtD WIn!
OETECTION UMIT
N
SCALE: ~
a &yo 1000 (fEET)
I ,
RUETGERS-NEASE
CHEMICAL CO., INC,
STATE COLLEGE, PA.
PEMEDIAL INVESTIGATION REPORT
FIGURE 10
PHASE II SURfACE
WATER / SEDIMENT
VCr., KEPONE AND MIREX
SAMPLING RESULTS
~ sue ENVlRONYENTAL
IIUJ' SERVICES GROUP
£"0"'.".. Mana...., Wantl.l. . Ptann...
,oWn PO.I. ,...
SCALE: AS SHOWN
7/1/02
DATE:
-------
----- ~-- - --:~------=.=-_-:-_-
--- - -----=-=-- ...:
-- -~-_.~ --~ ~'.---==---c-__--:-_----=-.;..._-------- ----
~-~-
---------~..--
- - -- -----
LEGEND
o F1
.
FISH SAIoIPUNO U)(:"nON
SAIoIPlES WERE fROZEN
NOTE: ALl RESULTS ARE IN UO/!
-------
.1
------
/~
, ,
, ,
, ,
, ,
, ,
, ,
,
., '
, '
I I
, ,
I I
I I
,
~
I
I
//
1/
....-",//
../
fORM£R AMlS(fE
tMOOH
fORMER SPRAY
fIELD NI£A
AREA EAST Of PAOOUC11ON IIUIJIING '2
~
i
~
SCAlr:
GA.:
. LEGEND
-
APPROXIW,n: PROP£R1Y UME
OIWNAG£ DITCH
~~
CYCLONE f'E~
RAII.R(W) tRACt
-------
DISPOSE OF
SOIL/SEDIMENTS
AT RCRA PERMITTED NO
SUBTITLE D LANDFILL
INON-HAZARDOUSI
420ISFLOW.DWG
EXCAVATED
SOil/SEDIMENT
SAMPLE RESULTS
WASTE
CLASSIFICA TION
OF U142
YES
YES
TREA T TO REGULA TORY
ST ANDARD8 FOR TCLP
CON8TITUENT8
TREA T TO REGULA TORY
8T ANDARD8 FOR TCLP
CON8TITUENTS PLU8
UNDERL YING HAZARDOUS
CONSTITUENTS
DISPOSE OF
SOIL/SEDIMENTS
AT RCRA PERMITTED
SUBTITLE D LANDFilL
INON-HAZARDOUSI
DISPOSE OF
SOIL/SEDIMENTS
AT RCRA PERMITTED
SUBTITLE C
LANDFILL
IHAZARDOUSI
FIGURE 13
EXAMPLE DECISION TREE FOR DISPOSITION OF SOILS AND SEDIMENTS
NO
TREAT FOR KEPONE
TO MEET LAND
DISPOSAL
RESTRICTION
STANDARDS
DISPOSE OF
SOIL/SEDIMENTS
AT RCRA PERMITTED
SUBTITLE C
LANDFILL
(HAZARDOUSI
-------
, ,
, ,
, I
, ,
I I
, ,
I I
I I
J I
I ,
I I
I I
I
/.
FRESH WAtER DRHtW:( DITCH
I
I
//
1/
..--///
./
FORIIER ANlSIJE
lAGOON
~
FORWER SPRAY
FIElD AREA
AREA £AST or PIIOOIJcnoN BUUIING '2
..... ,
GA.:
... ..:
.. ...u.
LEGEND
-
N'P!IOXIlotA1E PROf'£R1Y LINE
DfIAIWi[ DITCH
CYCLONE f'ENC[
RAUOAD TRAClCS
[ii-~]
BUIlDING
BlDC.
~ OESCRIPfIOH
B-1 WAIN PROCESSING AREA
B-2 WNIEHOUSt:.. PROCESSINC
B-3 WAR£HOUS(
B- 4 IIISIUATION IIUIlDING
B-5 WAIN1fJWtCE IIUUINC
B-1 IIOUA HOUSE
8-1 PROCESSING AREA
8-8 [QUFUENf sroRIa
8-1 CROUNIIWAtER TR£ATUENT FACILITY
8- 10 WAAtHOUSt:
8-11 HAlNIDOUS WAStE S10RACE SHELTER
8-12 ORUM S1ORAOE SHELTER
8- 13 UECIWICAI. $f0llAG[
8-14 0fJIC[ .. SfOIWI[
8-15 WNCHEON IlUIUIINO
FIGURE 14
200
............
Icole
o
200
.
teet
EXTENT OF FORMER
SPAAYFIELD AREA
RUETGERS-NEASE CORPORA "ON
-------
APPENDIX B - TABLES
-------
TABLE 1
Su.aamuy 0' GI'OUIId Walei' Sam.... ResUIta
.. 1M Rueeaen-N- Si8e
State C"', PAl
Ruae ., Reported Raaae 01 Decetled
DI88diM '....-, Delee... I..iIDiU Cl&afL) Coaceolraatiou CItIIL)
CIM8JuI ......,...... N88er ., Saa", Mi8i8- Muia.. MiIUa... Muia-
VOUDU ORGANIC Coa8'OUND8
AclloM ' 39 10 10 3 13000
8cnzeae 16 39 S 10 I 18000
2-ButaOOM 1 24 10 10 28 28
Cblorobenz- S JI S 10 2 250
CbIOIOfonn 3 39 S 10 2 4
r ,1-DichIOlOCllhIM S. 39 S 10 2 3
1 .2. Dlchluruodllne 2 39 S 10 3 6
1 ,I . Dio:hlUN8lhlnl 2 40 S 10 2 4
1,2-Dichlol'08CheM (1...1) 17 39 S 10 3 19000
Edlylbeaune 13 J9 S 10 I 16000
2-HI"oone 1 39 10 10 3 3
Mllbya- cIIIoridl S J9 10 10 1 61
1,I,2,2-T8Ir8cb10108lbaM U 39 S 10 1 200,000
T8Ir8cb101081bene U 39 S 10 I 6400 .
Toa- 11 39 S 10 1 190,000
1,1,2- Trichloroedt8D1 2 . 39 S 10 I 3
I ,1,1- Trichloro8lhlne 6 39 S 10 2 73
Trichloro8lh- 20 39 S .10 11.6 78000
-------
.
TABLE 1 (continued)
s-.UJ 01 G....... W... S8mpli8c RIIUIU
8' die lbIetaen-Neue8I8
SIa8e C"". .,,1
Ruae 01 Reported Raqe or Deletled
....... """"'" ~ u.iII CIlIIL} COKt'JIlratioaa filii'"
CII88icaI ...... .,..... ....... ., s..... MIIIiIII- MuJa... M.i8i8... Mui8-
Vin,l CbIorid8 II J9 10 10 I ]]0
X,I81118 11 J9 5 10 I 92000
nsncma
K.- 7 JI 0.1 0.132 0.0904 1.41
Ni... 10 JJ 0.00544 0.01 0.0015 0.145
I Alllllllplilll _ka ableined from RI (IMC 1991).
Nota: 118. ..lytic.1 p~ure U88d lor mirellpbotomiru/bpone .II8I,Ii. it a OC-NS iuop. dilulion method which reprcun18 die bell .vailable loch.\oloIY for die qualllilelive
.nelyli. of Ih- COIIIfIOUnd.. 1'ba III8IbocI adju818 lor the recovary obIained GO a aampl"8p8Cific baIi.. The culTOlll EPA procedure for mirea and kcpone (Medlod aOBO) i.
limpl, a OC method and do88 not con8CIlor reco¥8IJ. R8IIt8 from Iha OC-NS iaor.op. dilulion medlod would, on .vora,e, be 20 10 25" hilher dldn rewll. from die EPA
OC 1II8IbocI.
-------
TABLE 2
s..m.UJ 01 Surface Water Sampliaa Results
at ... R..,_Neue SiIe
Slate C"'. ..4'
"",e of Reported RaBae of Detected
De8..ti08 F.......y Delee... Liaib I/&8/LI COlltf.lltra,ioas «PaiL'
C~ ........ "....... H..beI' of SuI'" Miaia... Muiaaum Miai8 Muia-
. WD
VOUDU ORGANIC COMI'OIINDS
AcItOII8 2 12 10 10 23 1100
......... '5 12 5 10 2 29
Cblorob8azeII8 S 12 S 10 6 2500
Chloroform 1 6 10 10 4 4
1,1""D8-DicbI0~ 1 6 S S 160 160
1,2-Dic:bIolU8th8II8 (IOUI) 3 6 10 10 300 530
Ethylbellull8 4 12 S 10 4 230
4-Mldlyl-2-hnla- 1 6 10 10 2 2
-
1,I,2.2-T.rachlolOltllallll 6 12 5 10 3 410
T~ 1 12 5 10 26 49
ToIuaae 6 12 S 10 I 840
1,I,2-TrichloIOIthall8 3 6 10 10 1 13
Tricblol'Ollb- 4 11 S 10 66 230
Vill,l QIorid8 4 11 10 10 30 n
Xy""" S 12 S 10 60 140
nsnCIDES
KtpOIl8 2 9 0.132 0.132 0.818 0.939
-------
TABLE 2 (continued)
SwulUJ 01 Surf.. Waler Sam.... RIlUlLi
at die ....,...Neue!ite
SUte C"", PAl
a.u,. 01 Repon'" RU¥I! o' De8ee1ed
....... r.......-, Dtutliell Li8i8a \IIaIL) Coate1.r.tiMI \IIaIL)
CIM8k8I .....,..... N..w 01 Sea.. ...-.... Mui8... MiIWa... I Muia-
1
Miru 5 9 O.OOSt O.OOS4 0.0082 i O.S
I All -.Iq .-I8a .... ... .. (IMC 1_).
Mole: The ~ ptOC*IuI8 ..... b ~x/Up0a8 .....,Iia il . OC-MS ilOtOp. dillllion medaod which rap-nil lb. beea IVlillbl. lochnolo,y for thl 1ulnlitlliv.
.....,Iia of"'" ~II". ............... for 1M NCOvery obcaiaed 08. """"lp8IIific basil. The curnnI ErA proceduf8 for mire. .011 tCf)one (Mediad 8080) il
....., I OC IIII8bod ad d08I8118 CQII8CI8 b .-very. .... rr- die OC-MS iIotAJpe ditution IDIdIod would, OR Iven,., be 20 10 2SS hi,her Win ruul18 from lb. EPA
OC ..-.....
-------
TABLE 3
Sulllaa8IJ 01 SediaeDl SulpIiaa Results
AI die Rudpn-N- Site
SI8Ie CoIIe8., PAl
Delee... Frequea&:y Rua. 01 Reponed Delectioa I..iaaiU CI&I/ql Rqe 01 Detected C'IIXIIIII""" CI&I/IIa)
C"''' .... ., Deteda N_- 01 SImples Mi8i8.... Mu.b8.... Miaiaauaa MuiII-
VOUDU ORGANIC COMI'OIJNDS
Ac8lone 2 15 10 10 110 6700
2-Buta- 1 15 10 10 3 3
C.rtIoo Di..lfide 1 10 5 5 16 16
Chlorobe~ 1 15 5 10 42000 42000
Chloroform 1 10 5 10 6 6
1.2-tr1118-DicblOIOIdMne I 10 5 5 200 200
Edlylbenune I 15 5 10 5 5
1.1.2.2.Y8Ir.cblbro8lhlll8 1 10 5 5 ISOO ISOO
T elncblol'll8lhene 2 16 5 10 2 140
Toluene 7 15 5 10 I 810
1,1,2- Yricbloroelba- I 10 5 5 24 24
Tricbloroelh- I 10 5 5 67 67
YiDJI CIIIoride I 10 10 10 16 16
Xyleoel 4 15 5 10 4 1700
nsnCIDIS
K8pone 7 16 35.6 68 8 -1 7SO
Mirex 13 16 6.5 18.5 5.9 ! 6240
-------
TABLE 3 (continued)
I'
s....a.., .r SedP-tIIt SuIt... ReIuIIa
.. die a....en-N_.
SI88e Collp. ,AI
DlUcdoa ".....-, ..... 0' aepo"" DetacIio8 LiIIiI8 ~ Rap 0' Dewtt!d c........... ~
CM8iuI ..... "DIIIda I ....... 01 ..... MiMI.... T Mui8.. Mi8ia.... I MuiII..
I 'All .....,1iDI ...... .... ... II (1Me 1_).
N0t8: TII8 8ll8lJ1ic81 pnI08IIuN ..... .. ~ _Iyul il I OC-MS ilOlOpl dilulion lIIIIhod which 1'If_lIIIlbe bill IVlillble lec:hnolollY for Ibe qUlnlilllive
""".0'''' all8l,n".. .............. for tile dCCW8IJ oIItaiaed Oft . 18mpl"'lpICific balil. The CUmni EPA procedure for mire. Ind tel'0ne (Medlod 1010) il
limply. OC ....... ... dOlI......... for 18OOY8IJ. ....... from tbe OC-MS ieotope dilution lDIthod would. on IV"". be 20 10 25. hiahllr Iblln NMlI18 from Ibl EPA
OC lDIChod.
-------
-:-
TABLE 4
Summary 01 Surface Soil SampliDa Results
.t die Rueqen-N- Site
State C"e, PAl
'--
ltaqe 01 Repomd Raaae 01 Detected
...... .........., DetectiOll LiaitI ."..,... Coaceatr.tiuDS CI&I/IIat
CIM8iuI ..... .. ....... ...... .1 Sam.. Miaim- MuilaIllD Miaimum Mui8-
VOUDU ORGANIC COIIPOIJND8
MIIb,..... Chloride 2 6 5 10 7 .
1,I,1,1-TltnchI0l'0ltbaM 1 1 5 5 6 6
TItnchiCllQlthena 1 .. 10 10 . .
Tolueae 2 .. 10 10 2 2
Trichloroecb- 1 6 5 10 3 17
PES'I1CIDU
Kepone 1 9 68 68 23 1710
Mir.. 9 9 11.5 18.5 32 42000
I All IIn.,liIIa _ha oIIcaiD811 from RI (&MC 1991).
HOle: no 8II8lyticai procedure uled for miJu/pbotomirex/bpoGe .lI8Iyai. i. . OC-Ma ilOCqlo dilution mMhod which npJ'8181118 lb. beat ayailable loc:hllolollY for Ibe quanlilaliye
.ulyai. of.... compouDd.. Tho meIbocI ecIjU118 for dI. I'8COYIIY obtained on . 1IIRp1..~ific baai.. Tho curreRI EPA pl'OC*lure for mire. and kOf'one (Melhod 8080) i.
liuIpIy. OC IIIIIbod oDd.. DOt cornet for 18GOY0IJ. R"'" from lb. OC-MS i8oIapo dilution Jn8IbucI would. OR ovNqe. be 20 10 2S" hiahor 1ht;1n reaull. from Ibo EPA
OC metbod.
-------
TABLE 5
I .
Summary 01 Deep Soil Sutplina RIIIUIts'
at die Ruetpn-Neue SiIe
State CoUeae. PA.
..... 01 Reported Raage 0' Detected
...tioa """"" ....... Liait8 N/II8) COIICstratiuaa CI&I/IIa)
CIIe8iuI ...... ....... N_ber .1 s..,.. Mi8i8... Muiaua Miaiaua ~-
VOIA11U ORGANIC
COMftMJNDS
Ac:etaa8 9 ]1 10 10 18 22000
a.- J 15 5 5 15 920
2-~ 4 34 10 10 9 70
C8rt1oq Dilulftde 4 19 5 10 5 190
~ 5 31 5 10 5 71000
ChlorofonD 1 14 5 5 3 19
1,2.Dichloroetb- (10181) 9 34 5 10 1 1900
1,2-Diclaloroprop8. I 16 5 5 2000 2000
EAhylbaazaM 13 34 5 10 6 210,000
1,1.1,1-T....dtI~ 11 31 5 10 2 )5000
T~ 15 31 5 10 ] 6100
T"""Y"'" I 19 5 5 . 810 810
ToIuaee 14 34 S 10 2 760,000
1,1.1-Tric:blor08tbane 3 30 S 10 2 210
Trichloroalll.- 24 34 5 10 I 22000
Vinyl Chloride I 14 10 10 17 17
Xyl.... II 34 S 10 9 1,300,000
-------
TABLE 5 (continued)
-
Sum8uy 01 Deep Soil Su8p1iq Resuita
at 8M R...,en-Neue Site
State CoIIt8e, PAl
Ruae 01 Reported Ra:lge "I Detected
Delet8i08 F.....-y ~da8 LiaiU 11&.,..1 C08CtSI'rlitiOlll CI&I/IIII
CIae8kaI ..... ., Delee.. N88ber of SuI'" Mi_- Muimum Miaia- Mui8-
nsnCIDU
K8p0.. 12 J4 61 68 S.S2 260,000
Mire. '29 J4 11.5 II.S 0.6) 42)00
I AlI....1i11l -ka obtala8d 110m RI (IMe 1992).
NOla: 'Ib8 analytical procedure U88d for mil'8JllpbolomiruJtfllOM analYlil II a OC-MS ilOlope dilution method which repreacnll Ibe beal availlble lechnology lor Ibe qUlnlilAlive
_I,.. of"'" CClqlouada. Th. med80d edjulla for 8be recovery obCala8d 00 a ....I....-ific ba... The CUrl8nl EPA procedure for mire. and kCfone (Melhod 8080) il
81....1,. OC ID8Ibod and cIoea 1108 correcI b 18COV8I). ....... from lb. aC-MS ilOlOpa dilulioa lMIhod would, on aver.,., b. 20 to 2S" hi,hcr IbJln rcaulll frum Ibe EPA
OC 1II8Ihod.
-------
TABLE 6
Summary 01 Mella-Specific CIM8k81 D«eelioos
at die aue.,en-Nase Site
suae C"'e.'A
...- Surf8CC! W.ter
GI'8U8II W"'" Surf.. Soils
CII88iuI AIw Creel! Di.dl s,riIIa Deep Soils C'" Dild- StrieI IWI
I. AC8OII8 X X X X X X X
1. ....... X X X X X
J. 2-1u&eAo. X X X X
4. C8dIoa Dilulfide . X X
.5.~ X X X X X X
6. as-form X X X X
7. 1.1-~ X
t. 1 ;1-DidaIOlO8lb8ne X
9. 1.2-Di,bI0fll8lban8 X
10. I.I-Dicb~ X
II. 1.1-DicIIIora."- X X X X X
11. 1.1-DidIIoIop...,... X
I'. Edt,...... X X X X
14. 2-""""" X
15. K8pone X X X X X X X X X
16. "8111,... aaIoride X X
17. 4-......,1-1-""... X
II. Mirea X X X X X X X X X
19. 1.1.1.1-Tdr8da10r0ech.. X X X X X X X. X
20. Tecr8,hloroelh8ne X X X X X X
. .
-------
TABLE 6 (continued)
s..88I'J 01 Media-Sped& C~" Dele&:1i0lU
at die .......Neue Si8e
S&M8 C"., PA.
Sedi8- Surf.e W .ta-
G"'" W8&eI' Surf.. Soils
CIM8k81 A.Ir Creek Diklla Spri8a Deep Soils Creek Dikb S.... IIWI
11. Tetnhydrofunn X
11. TollI- X X X X X X X X X x
13. 1.2.4-Trichl~' X
24. 1,I,I-TricblolO8tbu8 X X
25. 1,I,1-Trichlol'Ollha... X X X x
26. TrichlolOldwM X X X .X x X
11. TrichloroftllOrometbl... X
28. Vinyl Chloride X X X X X
2" X.,...... X X X X X X X
-------
~-
TABLE 7
....... Eqggre Pldaways at die
D.qes....Ne8se sate CoIIe8e Site
POC8IdaIIy EqIaIed Popal8Doa
WorUr
uposure MedimDJ F100cIpIIiD Off... RecnatiaaaJ OD-Site
Eq:oSw-e Route !teIidaIC Rsid8t Epi&QcIic I DaiI)' I '!'=-es~ V"1Iitor 1ReRc.hc
Ground Waler
InpaQOG "" x
Denna1 COIIUCt "" x
1nhalacioa of Vapon "" x
Surface W atei'
lncicIenuJ lnpIIioa I: I: I:
Dermal ColII8Ct I: I: I:
SedimaItI
lncideataJ m,aaoa I: I: X
Dermal ColII8Ct I: I: x
Soil
lncideataJ IaaaUoa 1:. c
I: I: X I:
Dermal CoatKC x x I: X I:
fUr
Vapor r
Food
1apC0G of Beef I:
iJIpIcioa of filii x'
I An olHit8 lpi8adic worker ia .-.III8d CD 118 apcII8II to d8Ip aabIurI8I:8 aoiIa cIuriar periodic COIIIINc:IioaI-vatioa activi1ia.
An 00-- daily .,orter is .-.III8d CD COIDCC IUdciaI aoiIa wIIiI8 ~ -~- 8CIiYiti8 at Ib8 Sir8.
% A ~ ia .-.III8d to 118 ..... CD ~1Ia ill IOi1. IUIf8ce .,.... 8Dll1Idim8I8 ill lb. ..-y iJripIioD field _.
3 An off-lite reIid8a& is 8I8IID8d CD be upoIId CD pouDd W8t8r UDder . ftIIUN 1188 -no oaIy.
. EJqI08Uft CD ftoodpIaiD aoiI8 will be ....... .... ~~ ill 11Ion8ae Spriaf...t; .....
, ,An off... I'8IIid8a& ia ....... CD be upoIId CD Y8pOft ..,.a......, hili 11Iontroa Spriaf.
6 There ia . ~ baa OG Ir88pic fiIb caup& ill Ipriq C~ Ib8 ftaan filii ~ ...no - .... baa ia lifted.
-------
TABl£ 8
Sunmary of Centre CoU1ty Kepone $Ie
Risk Scela ios and Es6..1a1e!t
[[[~:::::: ,'.',',',',','.',','."'.',',',",',",'.',',',',',',','.'""""",""""""",,,. ',',',','.'.'.'.',',',',',',','.'.'.',',','.',',".',',','.'.',",',",'.'.'.".','.',' lillill!lllllllli':~.!illlliJ:liilllil 11111811/11
"","'..........."..................... ..."',-"""""""""""""'.......
,"".,......,...........,.......,........" 1.llliilli!llilllllllll.IIIIIIIII!I'11
11.1!!,I.!:.ill!I!!II!!i!:II'!I_!!!!i!IIII!.i!.II!!!11!.11Ii' lili.II!.~.il!illll!
Current Offsite 2 x 10~ Surface Water Ingestion
Resident HI = 0.07 Sediment Dermal
Air Inhalation
Current Offsite 1 10~ Sediment. Ingestion.
x
Floodplain Resident HI = 0.06 Beef
Current Onsite 5 x 10"7 Subsurface Ingestion
Worker (episodic) HI = 0.4 Soil
Current Onsite 1 1 0-6 Surface Soil. Ingestion .
x
Worker (daily) HI = 0.04
Current Trespasser 9 x 1 O~ Surface Water Ingestion
HI = 0.02 Sediment Dermal
Soil
Current Recreational 7 x 10~ Surface Water Ingestion
Visitor HI = 0.0003 Sediment Dermal
Future Offsite 2 10" Groundwater. Benzene Ingestion .
x
Resident HI = 5 Surface Water Dichloroethene (1 ,2-cis-) Dermal.
Sediment Tetrachloroethane Inhalation .
Air Tetrachloroethene (pCE)
Trichloroethene (TCE)
Vinyl chloride
Future Recreational 4 1W Surface Water Mirex Ingestion .
x
VISitor HI = 1 Sediment Dermal
Fish.
Future Onsite 1 1q-2 Groundwater. Benzene Ingestion .
x
Resident HI = 1100 Soil" Dichloroethene (1 ,2-cis-) Dermal.
Ethylbenzene Inhalation.
Tetrachloroethane
Tetrachloroethene (PCE)
Toluene
Trichloroethene (TCE)
Vinyl chloride
Xylenes (mixed)
Mirex
Notes:
-------
TABLE 9
Soil and Sediment Clean-up levels
for the Centre County Kepone Site
-
463
25
1. Acetone
2. Benzene
3. 2-Butanone
-. .-. 4. Carbon Disulfide
5. Chlorobenzene
6. Chloroform
7. 1,2-Dichloroethene
8. 1,2-Dichloropropane
9. Ethylbenzene
10. Kepone
11. Methylene Chloride
12. Mirex
13. 1,1,2,2-Tetrachloroethane
14. Tetrachloroethene
15. T etrahyd rofu ran
16. Toluene
17. 1,1,2- Trichloroethane
18. Trichloroethene
473
13,003
1,984
264
210
15
46,287
72,737
200(2)
33,062
. 14
109
70(2)
15,028
17
38
19. Vinyl Chloride
20. Xylenes
Notes:
(1) - Summers Model calculations for subsurface soils with foe = 4% and natural soil
cover as contained in the Feasibility Study dated October 1993.
(2)- Level 2 protection standards taken from "PA Guidance for Cleanup Standards
for Contaminated Soils dated December 1993".
1
161,104
-------
. , . ... ...,
!illlljlll~!ll8ii!ill!il!~1
GWITS-1
GWITS-2
GWITS-3
GWITS-4
SS-1
SS-2
SS-3
SS-4
FWDD/SW-1
FWDD/SW-2A
FWDD/SW-2B
FWDD/SED-1
FWDD/SED-2
FWDD/SED-3
SC-1
SC-2
SC-3
SC-4
TABLE 10
REMEDIAL ALTERNA11VE ESl1MATED COSTS
Remediation of Groundwater and Thornton Spring
No Action
No Further Action
Groundwater Source and Migration Control
Groundwater Source Control and Thornton Spring In-Sltu Treatment
Remediation of Subsurface Solis
No Further Action
Excavation
Soli Vapor Extraction
Capping
Remediation of FWDD Surface Water
No Action
Source Control - Reconstruct Existing Pipes
Source Control - Plug existing Pipes & Replace with Aboveground Pipes
Remediation of FWDD Sediments
No Further Action
excavation' and Soli Lined Ditch
Concrete Lined Ditch with excavation
Remediation of Spring Creek Sediments
No Action
Institutional Controls and Monitoring
HydraulicNacuum Dredging
Line Stream Channel
Notes:
I" - Present worth was calculated using a seven (7) percent discount rate over a thirty year period.
Z - Excludes monitoring coSts for years 1 and 2 totaling $266,400.
ji!III!llllilllllilR.lllllllillll!III!lillllllllllllllll"11!1..I!ill!!!II!I!I::!I!I!I!!III:i!II!!III!:llill
$0 $88,548 $1,099,000
$30,000 $546,708 $6,814,000
$2,694,318 $490,87(f $9,052,000
$4,339,343 $831,6a(f $14,926,000
$0 $0 $0
$4,224,285 $1,500 $4,243,000
$1,085,600 $150,700 $2,477,000
$1,896,238 $11,500 $2,039,000
$0 $48,000 $596,000
$662,582 $71,500 $1,550,000
$544,157 $55,500 $1,233,000
$0 $0 $0
$350,857 $14,900 $536,000
$199,665 $20,500 $454,000
$0 $0 $0
$0 $38,800 $482,000
$19,399,017 $48,480 $20,001,000
$11,416,766 $58,080 $12,136,000
-------
TABLE 11A
Colt estimate
For Remedial Alternative
OWnB-3: Oroundwat. Bourc. and Uigranon Control
Activity Unit CG888 UnIt8 QuantllY &81II1II111 8i8I8 of
Colt Estimate.
EST1UA1B) IIRECT CAPITAL COSTS
MoblllzatlonlDemobllizlllon $75,000 lump sum 1 $75,000
Oroundwater extraction:
-Wells:
-8.-dla., 150' deep $14,000 per well 4 $56,000 Drllllnll contractor
-8. -dl.., 300' deep $28,000 per well 8 $224,000 Drllnng contractor
-12. .dla., 85' deep $10,000 per wen 7 $70,000 Drilling contractor
-hydrofracturlng 10 wells $85,000 lump sum 1 $85,000 Oolder, Seattle experience
-Pumps (4., 113 Hp) $450 each 10 $4,500 Tom, Morris Industry
.Pumps (4., 112 Hp) $500 each 3 $1,500 Tom, Morris Industry
-Pumps~. , 314 Hp) $5SO each 5 $2,750 Tom, Morrl"OOustry
-Pumps (4., 1 Hp) $600 each 1 $600 Tom, Morris Industry
-Housing $2,000 each 20 $40,000 Whitehouse, fL Cost Est.
-Instrumenlallon $1.500 each 20 $30,000 Whitehouse, FL Cost Est.
. Piping, 11ft
. 1.25. ID Sch. 40 Carbon Sleel $3 FT 2600 $7.800 pansten Supply, St Cotl
. 1.0. 'D Sch. 40 Carbon Steer $2 FT 2000 $3,000 Pansten Supply, Sf Coff
-Piping, transmission system
. 4. SDR-17188 SDR-17 Plexco HOPE $20 FT 6000 $120,000 J.P. McElvenny, Exton
-Trench, backfill, compact $10 FT 6000 $60,000 Double waffed pipe
.Pump Installallon $700 each 20 $14,000
-Electrical supply, control wiring, and conduit 86 FT 6000 $36,000
.Install electrical/mechanical/controls $100,000 lump sum 1 $100,000
Subtotal $930,150
Fencing (Access Restriction) $20 FT 1~iIIIi ~I~t..): Fence contractor
Deed Restrictions $10,000 Lump sum :~~;1r. II~-
~...:t~;....... ,:. :......l
Subtotal \!!\%t-
page 1 o. 5
-------
TABLE 11 A (continued)
ColI Estlm8te
For RemedI8l All.......,.
GWIt'S-3: Groundwater Soun:e and MIgr8l1on Qlntrol
..
. .'-" ..
Cost
.:.~
Un" Co8Is 'U.:
Groundwater Treatment System Upgrade
to 250 gpm ClPaclly with air treatment
-llr 8I~ng lower $45,000 each 2 890.000 Cafbonllr, MN
-GAC Column (10000 Iba carbon Wiler cells) $110,000 each 2 $220,000 Projecl8lCP8rlence
-Carbon (Water), IIr" charge $2 per lb. 20000 $40,000
-GAC column (AIr V8SI4IIsIblowerslcondensers $32,000 each 2 864,000
. -Carbon (Air), first charge $2.50 per lb. 6000 $15,000
-bag IllIers $1,500 each 6 $9,000
-pipes, valves, fillings, pretreatmenl $40,000 Lump sum 1 $40,000
-electrical and Instrumentallon . $150,000 Lump sum 1 $150,000
-pumps $5,000 each 2 $10,000
-equallzallon lank (20,000 gal) $25,000 Lump sum 1 $25,000
.R:~:lf;:ftqij!ti~t1~!fmtll~![:!mmtli:[:[::; ':~r;::[:i;::igi~" .::::::::;r:::i:;;::':I ::W[\]@lt::: ::i;~mIiSi:jj~.::: IJj_::ml1IHm:::~i;':;;':::m::
-Inslallallon $100,000 Lump sum 1 $100.000
-Faclilly building $40 sq.'1. 2000 $80.000
Subtotal
{::$:LH:': .;(JOO;
TOTAL DIRECT CAPITAL COST
Jilf~.arq:;
ESTIMATED INDIRECT CAPITAL COSTS
Gen. Engineering Servlces(154Mt)
PermllllnglRegulalory Coordlnallon(5~)
Implemenl Heallh & Salety Plan(5~)
Conllnoency(20.)
Lump sum
Lump sum
Lump sum
lump sum
TOTAl INDIRECT CAPITAl COSTS
TOTAL CAPITAl COSTS
page 2 01 5
-------
TABLE .11 A (continued)
Cost Estimate
For Remedial Alternative
GWfTS-3: Groundwater Source and Migration Control
Activity Unit Costs Units Quantity . Estimated 8- of .
Cost &tlmati
O&MCOSTS
Groundwater Extraction & Treatment
Operation Cost ..
-Operating Labor 840 man hour 4160 $166.400
-Maintenance & Repair $30.000 year 1 $30,000
-Electrical Power 845.000 year 1 $45.000
-Chemical Cost $15.000 year 1 $15,000
-Carbon Replacement (water) $0.60 per lb. 40000 $24,000 Assumes that carbon can be
-Carbon Replacement (air) $0.80 per lb. 24000 $19,200 regenerated
- TranaportaUon 'or carbon $0.15 per lb. 84000 $9.600
-Sludge Disposal $20.000 year 1 $20,000
Subtotal Annual Operating Coet $329.200
Groundwater Monitoring
(Quarterly - year, 1 '0 2)
..
analytical cost - VOCI $350 per sample 132 $46.200 Assumes Groundwater
analytical cost - MlrexrKepone, and . sampling/monitoring
Photomlrex $1.100 per sample 132 $145.200 12 wells quarterly plus
Sample Collection - labor $70 man hour 260 $18.200 4 QAlQC samples per we,,'
$ample Collection - expenses ".500 lump sum 8 $12.000 'or two years and 1 sampl..
Reporting $5.600 each 8 ""'.800 'or Thornton Spring per event
Total Monltortng Coets Vears 1 - 2 8266.400
page 3 0' 5
-------
TABLE 11A (continued)
ColI Estimate
For Remedial Alternative
GWITS-3: Groundwater Source and MlgraJlon Control
I"
I
I
" Activity Unit Co8t8 . Unlll Quantity EatIril8ted BiiII of. . . .
ColI .E8tliNd.< ...
Groundwater Monitoring
(Semiannual - years 3 through 30)
analVileal cost - VOCs $350 per sample 34 $11.900 Assumes Groundwater
analVileal cost - Mlrex. Kepone. and sampling/monitoring
Photomlrex '1.100 J* sample 34 $37.400 12 w8lls semllllnually ptus
Sample Collection - Llbor 870 mill hour 64 "'.480 4 QAIQC samples per event
Sample Collection - expenl8l '1.500 Lump sum 2 $3,000 lor 28 year, and 1 sample
Reporting 85.800 each 2 811.200 for Thornton Spring per event
Annual Monltortng Colli 867,980
Tr.ialment System Monitoring Assumes monthly Influ.,.,t
and emuent IImples Ind
analytical cost - VOCI $350 per lample 36 '12,600 one NPDES dlecharge pt.
analytical cost - Mlrex. Kepone, and sample per month
Pholomlrex 81.100. per sample 36 839.600
Sample Collection: Labor 170 man hour 50 83.500
Reporting $2.000 each 12 824.000
Annual Trealment System MOnitoring Costs 879.700
Fence Maintenance $1.500 per year 1 $1,500
J
Subtotal 81,500
Annual Data Review and Report 810.000 per year 1 $10.000 See Table 6-6
Subtotal '10.000
page.. 0' 5
-------
TABLE 11 A (continued)
CGII EII'mII8
For RemedI8l Aft.......
GW1I'8-3: GroundwaI. Soun:e .... __Ion Control
" ,
nllC0i88 ,Un"', ~8IjE.8t...,.
" : COif'
n,
, '
.... '..
five V..r Data RevIew a~ Report
812.450 each
6
874.700 See Table 6-6
, Annual Subtotal
82.480
TOTAl ANMIAl 0 & M COST
(excluding years 1 and 2)
8480.870
~WORIH(30YEARS" N)
Tota' Monitoring Costs Vears 1 - 2
88.091.206
8266.400
SublOIaI
86.357,606
PRESENT WORTH ALTERNAT1VE GWtrS-3
Capllal Cost
o & M Cost (Present Worth)
.:'W::If.EIJI:::
'8.357.606
TOTAl PRESENT WORTH FOR ALTERNAT1VE GWtrS-3
iM:u." '~~';
.-..:-..'" .:J.~..
page 5 01 5
-------
TABLE 11B
Cost Estimate
For Remedial Alternative
89-2: ~cavatlon
. ACtivity .. Unit Costs Un'" Quantity &lImited. . B~of :
Cost £sIlmate' . .
ES~ATED DIRECT CAPITAL COSTS
EXCAVAnONlREMOVAL
MoblDemob 850.000 Lump sum 1 850.000 '93 Means Building Constructlon'Cost Data
Conventional excavation 830 C.Y. 6000 '180,000 '93 Means Building Construction Cost Data
Shoring 'or excavations 815 SF 1500 $22,500 '93 Means Building Construction Cost Data
01l-511e disposal $240 ton 9720 $2,332,800 Model Clt, (1.82 tonsiCY @) 120 pet)
Imported clean backfill $20 C.Y. 6000 $120,000 Mat.(Contractor) + Haullng('93 Means 022-266-0550)
Place/compact backtlll $15 C.Y. 6000 $90.000 Conlraclor
Fine gra~lng $5.000 acre 2 $10,000 '93 Means 025-100-0010
Pavement Replacemenl $40 LF 1000 $40.000 Pavemenl Conlractor
laboralory Analytical Services:
ClP - VOCs. TClP $2.000 sample' 30 $60.000 laboratory
P.,manent Fencing (Access Restriction) $20 lF 2400 $48.000 Fence Contraclor
Deed Restrlcll.ons $10.000 lump sum 1 $10.001
TOTAL DIRECT CAPITAL COST 82,913,300
ESTIMATED INDIRECT CAPITAL COSTS
'.
Gen. Engineering Services (15~) lump sum $436.995
P8ImlllingIRegulatory Coordlnallon (5CM1) lump sum $145.665
Implemenl Health' Safet, Ptan (5CM1) lump sum $145.665
Contlngenc, (20%) lump sum '582,660
TOTAL INDIRECT CAPITAL COSTS 81,310.985
TOTALCAPlTALCosrs "',224,285
page 1 o' 2
-------
T ABLE 11 B (continued)
Colt Estimate
For Remedial AIt.nat1v8
99-2: Excavation
I '
ActIVIty , .. , Unit Costs Units QuantItY Elttmeled "", ....~. "
,
Cost , Ettlmat8"
O&MCOSTS
Annual Fence Maintenance $1,500 Yea' 1 '1.500
TOTAL ANNUAL 0 & M COST '1.500
PRESENT WORTH (30 YEARS. nil) 818.814
PRESENTWORnt ALTERNA11VE SS-2
Capitol COlt "'.224.285
0 & M Cost (Present Worth) 818.614
TOTAL PRESENT WORTH FOR ALTERNATIVE SS-2 "'.242,899
page 2 0' 2
-------
TABLE 11C
Cost Estimate
For Ren,edlal Alternative
fWDDISW-2A: Source Control - ExCavat8lReplac8 existing PIpes
, ActIVIty Unit Costi Units Quantity ,Estimated . ,(p.' ..','\ '. ."'" .BMI8Of"
'Cost &IImaae
ESTIMATED DIRECT CAPITAL COSTS
MoblllzallonlDemoblllzalion $10.000 lump sum 1 $10.000
Conventional excavatiOn $30 CY 300 $9.000
Orr-slte disposal $240 Ton 486 $116.640 Model Clty/1.621on1CY. 120pcf
Imported clean backfill $20 CY 300 $8.000 Material + Haullng('93 Means 022-266-0550)
Place/compact backfill $15 CY 300 $4.500
Bituminous pavement removal $7 SY as $595 '93 Means 020-55-4-1750
Pavement off-site disposal $11 CY 11 $121 '93 Means 020-55-4-5600
Patch Pavement(3" wearing & 1.5" . $13 SY as $1.105 '93 Means 02S-104-04601OOOO; 022-308-0050/8900
binder course. 3" gravel base)
Topsoil. lime. fertilizer & seed $3 SY 600 $1.800 '93 Means 029-304-031Q(022-~86-02S0
HOPE pipe (12" OIa. Plexco SDR 32.S) $7 FT 920 $6.440 J.P. McElvenny(lncl. mat.,dellv., fus:on, tech.) ,
Temporary reroute waler, HOPE Pipe $6 FT 920 $S.S2O
Sile Grading $10,000 Acre 2 $20,000
Secondary containment structures(concrete) $5,000 Each 10 $50.000
Plant operallon Interference '30,000 Day 7 $210,000
TOTAL DIRECT CAPITAL COST 8441,721
ESTIMATED INDIRECT CAPITAL COSTS
Gen. Engineering Services (1S"') lump sum $66,258
PermlttlngIRegulatory Coordlnatlon(SCMI) lump sum $22.086
Implement Heallh & Safet, Plan(54M1) lump sum 822,086
Contlngency(25"') lump sUm $110.430
TOTAL INDIRECT CAPITAL COSTS $m.861
TOTAL CAPITAL COSTS $662,S82
page 1 0' 2
I .
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,TABLE 11 C (continued)
Colt Estlm.t.
For Remedial Alternallve
FWDOISW-2A: Source Control - ExcavatelReplace existing Pipes
A.ct1vl11 Unit CostS UnIta Quantity &tlmated . Baile Of
Cost ., . Eitlinatt
O&MCOSTS
Roadway maintenance 88,000 Year 1 $8,000 2 people, 3 days/quarter @ $401hr
Vegetallonllawn Maintenance $8,500 Year 1 $8,500 26 days @ S4OIhr.
Inspecllon & Reporting $7,000 Year 1 $7,000 1 person, 5 days/quarter @ $401hr
NPDES SUrface Water Sampling $4,000 Month 12 $48,000 Laboratory + Reporting
TOTAl ANNUAL 0 & M COST $71,500
PRESENT WORTN(30 VEARS . N) . $881,244
PRESENT WORTH AlTERNATIVE
FWOOfSED-2
Capital Cost $662,582
0 & M Cost (Present Worth) $887,244
TOTAL PRESENT WORTH FOR'Al1£RNATIVE FWDCiSED-2 $1,549,825
page 2 0' 2
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TABLE 11D
Cost Esllmate
. . For Remedial Ahernatlve
FWDDISED-2: excavation and SoIl LIned DItch
Activity. . q Unit Costs Unit. auantliy EiiIm8ted "Of
Cost Estimate.
EsnMATED DIRECT CAPITAL COSTS
MoblllzatlonJDemoblllzatlon . 810,000 Lump sum 1 $10,000
Conventional excavation 830 CY 400 812,000 See Appendix F
O"-slte disposal 8240 Ton 648 $155,520
tmported clean backfill 820 CY 400 88,000
Plac8lcompact backfill $15 CY 400 $6,000
68 Topsoil, lime, fertilizer & seed 83.00 SY 1250 83,750 '93 Means 029-304-03101022-288-025(
Temporary reroute water, HDPE Pipe 86.00 FT 1000 88,000 Envlrocon Materlal(mat. & delivery)
'93 Means 027-11 0-3240(1abor & equip)
Grade channel $5.00 SY 140 $700
Lab Servlces(2O VOCs,.TCLP SED Sam pi $2,000 Sample 20 $40,000 Laboratory
TOTAL DIRECT CAPITAL COST $241,970.
ESTIMATED INDIRECT CAPITAL COSTS
Gen. Engineering ServIces (15%) Lump sum $36,296
PermlltlngIRegulatory Coordlnatlon(5~) Lump sum $12,099
Implement Health & Safety Plan(5~) Lump sum $12,099
Contlngencw(2O%) Lump sum $48,394
TOTAL INDIRECT CAPITAL COSTS 8108,887
TOTAL CAPITAL COSTS 1350,857
page 1012
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TABLE 11 D (continued)
Cost Estimate
. For Remedial AII.natlve
FWDOISED-2: excavation and SoIl LIned DItch
I'
ACtivity OnlC0st8 Units QUantltJ Estimated Bti8I8 0"
.. ..
, Cost . .' E8tlinate'. ..
O&MCO~S
Inspection & reporting 86,400 Year 1 $6,400 5 days/quarter @I $tORlr
Vegetallonllawn malnlenance 88,500 Year 1 $8,500 26 days II $tORlr
TOTAl ANNUAl 0 & II COST '14,900
PRESENT WORTH(30 YEARS .~) '184,894
PRESENT WORTH ALTERNATIVE
FWDDISED-2
Capllal Cost 8350,857
0 & M Cost (Present Worth) 81&4,894
TOTAL PRESENT WORTH FOR Al TERNAT1VE FWDOISED-2 $535,751
page 2 0' 2
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TABLE 11E
Cost Estimate
For Remedial Alternative
SC-2: No Action with. Temporary Inslltutlonal Controls and Monitoring
Activity Unit Costs UnIts Quantity Estimated . .. 8IIIi of
Cost . £ttlmate
CAPITAl COSTS
No Capital Costs $0
O&MCOSTS
Laboratory Analytical Services:
Mlrex and Kepone $1,200 Sample 12 $14,400 Assumes 6 sediment samples and 6 biota (3 lower trophic and 3 upper
trophic IIsh tissue samples) samples - Annual Sampling Event
QAlQC Samples $1,200 Sample 5 $6,000
Annual Analytical SeMces Subtotal $20,400
Sample Collection $4,000 Per Year 1 $4,000 Labor and expenses per annual sampling event.
Reporting 01 oala $8,000 Per Year 1 $8,000 Engfneerlng services lor annual report which also Includes data validation.
Annual 0 & M Subtotal $32,400
Contingency (20%) $6,480
TOTAL ANNUAL 0 & M COST $38,880
PRESENT WORTH (30 YEARS II 'AIt) $482.462 PIA (7,30) - 12.4090
TOTAL PRESENT WORTH FOR AL TERNAT1VE SC-2: NO AcnON WITH TEMPORARY $482,462
INS11TUTIONAL CONTROLS AND MONITORING
NOTES:
QAlQC samples Include:
Duplicates, Field blanks, Matrix Spike, Matrix Spike Duplicate, and Method blanks.
Page 1 ~, ,
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APPENDIX C - RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION PLAN
AT THE
CENTRE COUNTY KEPOHE StJPERPUND SITE
STATE COLLEGE, PBHHSYLVAHI~
Public Comment Period:
October 3, 1994 thru December 1, 1994
Note: This Responsiveness Summary plus the attached
Responsiveness Summary Supplement which addresses the public
comment period from January 27, 1995 thru February 25, 1995
constitute the complete summary of significant comments received
from the public on the original and revised Proposed Remedial
Action Plan for the Centre County Kepone Site.
-------
overview
Background
Part I:
A.
B.
C.
D.
Part II:
A.
B.
C.
D.
E.
CENTRE COUNTY KEPONE SITE
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLE OF CONTENTS
. . . . . . . .
. . .
...........
.......
. . . . . . . . . . . . . . . . .
Summary of Commentors' Major Issues and Concerns
c
. . 1
. . 4
Implementation of the Remedy. . . . . . . . . . . . 5
Air contamination Issues. . . . . . . . . . . . . . 7.
Heal th Conc.erns . . . . . . . . . . . . . . . . . . . 9
Miscellaneous. . . . . . . . . . . . . . . . . . . . 9
Comprehensive, Technical, and Legal Response to Comments
Comments of Golder Associates. . . . . . . . . . .
Comments of U.S. Fish and Wildlife Service,
Pennsylvania Fish and Boat commission, and the
U.S. Department of Interior Office of Policy
and compliance. . . . . . . . . . . . . . . . . .
Comments of Spring Creek Chapter Trout Unlimited
Comments of Pennsylvania Department of
Environmental Resources. . . . . . . . . . . . . .
Comments of Various Citizens. . . . . . . . . . .
10
12
14
14
17
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RESPONSIVENESS SUMMARY
CENTRE COUNTY REPONE SITE
STATE COLLEGE, PENNSYLVANIA
This community relations responsiveness summary is divided
into the following sections:
overview:
This section discusses EPA's preferred alternative
for remedial action.
Background:
This section provides a brief history of community
interest and concerns raised during remedial
planning at the Centre County Kepone Site.
Part I:
This section provides a summary of commentors'
major issues and concerns, and expressly
acknowledges and responds to those raised by the
local community. "Local community" may include
local homeowners, businesses, the municipality,
and potentially responsible parties (PRPs).
Part II:
This section provides a comprehensive response to
all significant comments and is comprised
primarily of the specific legal and technical
questions raised during the public comment period.
If necessary, this section will provide technical
detail to answers responded to in Part I.
Any points of conflict or ambiguity between information provided
in Parts I and II of this responsiveness summary will be resolved
in favor of the detailed technical and legal presentation
contained in Part II.
OVERVIEW
In October 1994, EPA announced the opening of the pUblic
comment period and published its preferred alternative for the
Centre County Kepone Site, located in state College, Centre
County, Pennsylvania. EPA divided the Site into five areas,
based on eithe~ the location or the media involved:
.
Ground water and Thornton Spring surface water;
Subsurface soils;
Fresh water drainage ditch (FWDD) surface water;
FWDD sediments;
Spring Creek sediments.
.
.
.
.
For each of the five areas, EPA screened several possible
alternatives to remediate the Site contamination, giving
consideration to nine key evaluation criteria:
1
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.
Threshold criteria, including;
--Overall protection of human health and the environment;
--Compliance with Federal, state, and local environmental
and health laws;
.
Balancing criteria, including;
--Long-term effectiveness and permanence;
--Reduction of mobility, toxicity, or volume of
contaminants;
--Short-term effectiveness;
--Ability to implement;
--Cost; and
.
MOdifying criteria, including;
--state acceptance; and
--Community acceptance.
EPA carefully considered state and community acceptance of the
remedy prior to reaching the final decision regarding the remedy.
The Agency's preferred remedy for each of the five areas is
outlined below. A full description can be found in Section V,
Evaluation of Alternatives, in the Proposed Plan.
Groundwater and Thornton Sprinq Surface Water
The preferred alternative is Alternative GW/TS-3.
alternative includes:
This
.
Installing a new or supplemental groundwater source control
system;
.
Installing a migration control system to restore the
contaminated groundwater and surface water to background
levels, if technically practical;
.
Sampling the onsite groundwater, Thornton spring surface
water, and the treatment system influent and effluent
periodically to evaluate the effectiveness of the system;
Implementing institutional controls for the Site and
Thornton spring;
.
Constructing fencing around the Thornton Spring area.
Subsurface Soils
.
The preferred alternative is Alternative SS-2. The goal of this
remediation is to protect potential environmental receptors by
removing those soils where the concentrations of volatile organic
carbons (VOCs) may contaminate the qroundwater. This alternative
includes: .
2
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.
Excavating contaminated soils from the more isolated areas
on the Ruetgers-Nease property;
Disposing of excavated contaminated soils offsite;
..
.
Implementing institutional controls, such as deed
restrictions;
.
Extending the fencing around the Site.
PWDD Surface Water
The preferred alternative is Alternative FWDD/SW-2A.
alternative includes:
This
.
Implementing source control measures;
.
Repairing or replacing the existing underground surface
water discharge lines to reduce the potentiai groundwater
infiltration from entering the FWDD surface water.
PWDD Sediments
The preferred alternative is Alternative FWDD/SED-2.
alternative includes:
This
.
Excavating contaminated sediments in the upper forked
portion of the FWDD where the concentrations of VOCs in the
sediments exceed levels that are protective of groundwater
and environmental receptors.
.
Disposing of excavated sediments offsite.
spring Creek sediments
The preferred interim alternative is Alternative SC-2.
alternative includes:
This
.
Monitoring of spring Creek fish tissue and stream channel
sediments for up to 30 years to support canceling the
present "catch and release" fishing advisory.
Conducting a phased sampling program for spring Creek bank
area soils.
.
These alternatives satisfy the key criteria for remedy selection
and minimize the need for long-term treatment and management.
3
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BACKGROUND
Community interest and concern about the Site has been
steady throughout EPA involvement. EPA and the State conducted
an initial public meeting in State College, Pennsylvania on
September 11, 1990 to inform residents of the cleanup process and
activities which would take place at the Site. On September 6,
1991, a Technical Assistance Grant ("TAG") of $50,000 was issued
to a local citizens' group for the purpose of hiring an
independent technical consultant to assist the group in
understanding and commenting on technical documents for the Site.
However, the grant was terminated on August 15, 1992 because the
TAG recipient was dissolved. EPA issued a Fact Sheet which
provided the results of the Phase I Remedial Investigation and
outlined Phase II activities in May of 1992.
To obtain public input on the Proposed Remedial Action Plan
(Proposed Plan or PRAP), EPA held a public comment period from
October 3, 1994 to December 1, 1994. In addition, EPA held a
public meeting on October 19, .1994 at the State College Area High
School, State College, Pennsylvania, to discuss issues related to
the Proposed Plan. Local area residents, state, county, and
local officials, news media representatives, EPA representatives,
and representatives from companies interested in the site
activities and clean-up decisions attended the meeting.
EPA issued public notification of the October 19, 1994 .
meeting to local media, area residents, and Federal, state and
local officials on EPA's Site mailing list. EPA also announced
the opening of the public comment period in a newspaper display
ad placed in the Centre Daily Times.
In addition, EPA established a Site information repository
at the Schlow Memorial Library. The repositories contain the
community relations plan, the Remedial Investigation/Feasibility
Study (RI/FS) report, the Proposed Plan, and other relevant
documents. EPA also houses its Administrative Record,
encompassing the key documents the Agency uses in selecting the
Site remedy, at the Schlow Memorial Library.
PART I:
SUMMARY OP COIOlmrI'ORS' KAJOR ISSUBS AND CONCBIUlS
This section provides a summary of commentors' major issues
and concerns, and expressly acknowledges and responds to those
raised by the local community. The major issues and concerns
about the proposed remedy for the Centre Coun~y Kepone site
received at the public meeting on October 19, 1994, and during
the public comment period, can be grouped into four categories:
A.
B.
Implementation of the Remedy
Air contamination Issues
4
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C.
D.
Health Concerns
Miscellaneous
The questions, comments, and responses are summarized below.
A.
Implementation of the Remedy
1.
A citizen requested clarification of the groundwater
treatment process.
EPA ReSDonse: The contaminants in the soil at the Site are
leaching into the groundwater and contaminating it. To
remediate the groundwater contamination at the Site, EPA
must meet two objectives: removing the soil which is
causing the groundwater contamination to prevent future
contamination; and removing the contaminants that currently
exist in the groundwater. The preferred alternative
addressing the Subsurface Soils area will accomplish the
first objective. The soils will be excavated where the VOC
concentrations exceed levels that are determined to be
protective of groundwater and environmental receptors, and
the so"ils disposed of offsite. The existing groundwater
contamination will be addressed through the preferred
alternative for the Groundwater and Thornton Spring Surface
Water area. Groundwater will be removed through extraction
wells, processed in a treatment plant to remove the
contaminants, and discharged to the facility's surface water
system.
2.
A citizen expressed concern that the contaminated soil will
be disposed near the Site, on Ruetgers-Nease property.
3.
EPA ReSDonse: The contaminated soil will not be treated or
disposed at the Ruetgers Nease facility. An appropriate
landfill to accept the contaminated soil will be researched
and located during the Remedial Design. The landfill must
be a permitted facility which meets the requirements
necessary to handle the contaminants in the soil and may be
located anywhere in the United States.
A citizen asked what would happen to the buildings on
Ruetgers-Nease property while the soil is being excavated.
EPA ReSDonse: The areas of high contamination include the
tank farm/building #1 area, the area east of production
building #2, the former spray field, the former drum staging
area, and the designated outdoor storage area. The
accessible contaminated areas will be excavated. The
Proposed Plan provides for excavation of the former spray
field, the former drum staging area, and the designated
outdoor storage area.
5
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Because the facility is active, the areas under or near the
buildings (the tank farm/building #1 and the production
building number #2) will not be excavated. This means that
a major source of contamination will remain on the Site.
The remedy calls for curbing this contamination source by
using migration control wells to prevent the ground water
from migrating down to spring Creek. Should monitoring of
the ground water indicate that the remedy is not meeting
cleanup objectives, further action addressing the onsite
soil may be implemented in the future.
A citizen asked whether Route 26 would be moved during the
excavation.
4.
EPA ReS'DODse: The remedy will not affect Route 26. The
amount of contaminated soil under the road is minimal and
will not be disturbed as part of the cleanup.
5.
A citizen asked how much of the Thornton spring area would
be fenced.
EPA ReS'DODse: The exact locations and specifications for
the areas to be fenced at Thornton Spring will be decided
during the Remedial Design phase of the project.
A citizen expressed dismay that the Site, which has existed
for 20 years, has taken so long to reach the clean-up stage.
6.
EPA ReS'DODse: Congress enacted CERCLA in 1980. The Site
was included on the National Priorities List in 1983, when
the Superfund program was in its infancy. Congress passed
the Superfund Amendments.and Reauthorization Act in 1986
which gave the Act additional enforcement capability to aid.
in the cleanup process. Since the amendments were enacted,
the cleanup process has become more uniform. However, even
now, it generally takes eight to ten years to clean up a
si te. One of the reasons is the wide range of complicated
. technical issues which must be investigated and addressed.
A citizen requested a time frame for the cleanup.
7.
EPA ReS'DODse: Once the Record of Decision has been issued,
the Remedial Design, or the plan for accomplishing the Site
cleanup will begin. The Remedial Design could take six
months to a year to develop. The Remedial Action, which is
the actual cleanup, can begin as soon as the Remedial Design
is complete. At this point in time, EPA cannot anticipate
how long the Remedial Action will take. However, a schedule
for cleanup activities will be developed during the Remedial
Design.
6
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B.
Air contamination Issues
1.
A citizen asked whether air had been considered as an
exposure pathway in the risk assessment.
BPA Resoonse: (Note that the response provided by EPA at
the public meeting was not entirely complete. The response
that follows is considered more complete based on further'
review of the site documents) Yes. Air samples were
collected from the Thornton Spring area and EPA used these
data to estimate the inhalation exposures of the residents
living near Thornton Spring. The current and future risk
associated with the inhalation pathway only, based on the
air sample data is 6 x 10-7, or six in ten million. This
value indicates an acceptable exposure level, given that the
NCP states that "...acceptable exposure levels are generally
concentration levels that represent an excess upper bound
lifetime cancer risk to an individual of between 10-4 (one
in ten thousand) and 10-6 (one in one million) ..."
2 .
The same citizen expressed concern that the threat from air
exposure was based on estimated concentrations of the
contaminants in the air rather than actual concentrations.
BPA Resoonse: The threat from air exposure was calculated
based on actua.l air data collected directly from the
Thornton Spring area during two sampling events - one fair
weather event and one foul weather event in the Summer of
1991. No estimated or modeled concentrations were used to
assess the risk to residents from the inhalation of vapors
in the vicinity of Thornton spring. Modeled or estimated
air concentrations were only used to assess the risk
associated with the inhalation of vapors during showering as
part of the offsite resident future groundwater risk'
evaluation.
3.
The same citizen asked whether the concentrations proposed
by the model were the same as the actual measured
concentrations.
BPA Resoonse:
Comment #2.
See previous response, Part I, section B,
4.
The same citizen commented that the air samples from
Thornton Spring ranged from 74.3 micrograms per cubic meter
to 390.7 micrograms per cubic meter and asked whether 390.7
micrograms per cubic meter could be considered a potential
risk.
BPA Resoonse: In order to assess the risk of exposure to
chemicals of potential concern, it is necessary to determine
the chemical concentrations in the media of concern. Air
7
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samples were collected in the Thornton Spring area to
determine what chemicals and concentrations were present in
the air. sixteen chemicals of potential concern were
detected in the various air samples at a variety of
concentrations.
Reasonable maximum exposure (RME) concentrations were
developed for each chemical detected, which is the basis for
the risk calculations. The RME of each chemical of concern
is represented by either the highest observed (detected)
concentration or the 95 percent upper confidence limit on
the mean concentration (a statistical analysis), whichever
is lower. A RME was determined for each of the 16 chemicals
detected in the Thornton Spring air samples, and these
values were used to calculate the risk associated with the
air in the vicinity of the spring. Based on these risk
calculations, there is no unacceptable risk associated with
air exposure in the vicinity of Thornton Spring.
5.
The same citizen asked why risk from air exposure was
calculated for offsite residents but not potential future
onsite residents.
EPA ReSDonse: EPA calculated air exposure risk for offsite
residents because of their proximity to Thornton Spring.
Potential future onsite residents are unlikely to be exposed
to volatilized contaminants from Site soils or surface.
water. The site is currently zoned industrial and will
likely remain so. The ROD requires deed restrictions be
placed on the property to maintain the current zoning and
assure it is not rezoned residential. Therefore, there will
be no risk to onsite residents drinking contaminated ground
water, which is the main risk any future onsite resident
would encounter.
6.
A citizen expressed concern about possible exposure to
contaminants through the air during the excavation process.
EPA ReSDonse: Air monitoring will be conducted during the
excavation process. The health and safety plan will address
possible exposure as a result of the excavation process, as
well as identify contingency measures to mitigate any
airborne contaminant problems encountered during
construction. The Commonweal th of pennsylvania ARARs
require airborne contaminants remain inside the property
line which will greatly reduce any potential risk to offsite
residents. In addition, community members will be informed
or excavation activities at the Site before they occur.
8
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C.
Health Concerns
1.
A citizen asked for a description of the harmful effects of
mirex and kepone.
2.
EPA ResDonse:Kepone affects the reproductive system and
mirex affects the liver and adrenal glands. Exposure causes
tissue death and necrosis. Presently it is unknown if
kepone is a carcinogen (weight of evidence Class D), but
mirex has been classified as a possible human carcinogen
(weight of evidence Class C).
A citizen asked whether residents of state College should be
drinking bottled water because of the Site's contamination
of the groundwater.
EPA ReSDonse: The plume of contamination from the Site is
located entirely between the plant and the stream and has
not affected the drinking water supply. Based on EPA's
investigations and site files, the Site has never had an
impact on the water consumed by.nearby residents. Their
drinking water is supplied by the Lemont Water Company and
does not come from groundwater under the site. Further,
EPA's actions at the site will prevent any future
contamination from occurring. .
D.
Miscellaneous
1.
A citizen asked for a definition of onsite.
2.
EPA ResDonse: In EPA documents, onsite refers to the.
Ruetgers-Nease property (including the operating facility,
former spray fields, etc.) area only, and offsite refers to
areas outside of the plant area. However, the entire Centre
County Kepone Superfund Site is defined as all areas
impacted by contaminants originating from the Ruetgers-Nease
plant site, and currently includes all of the plant area,
the area underlain by impacted ground water, Thornton
spring, and spring Creek from the Village of Lemont to the
Pennsylvania Fish Commission Research Station. All of these
areas are addressed in the Proposed Plan.
A citizen asked whether chemicals were ever disposed on the
upper side of the mountain or near the fire pond.
EPA ReSDonse: Ruetgers-Nease files indicate that all
disposal occurred on the site property.
9
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3.
4.
A local official asked whether the contamination extends
outside of the Ruetgers-Nease property boundary.
EPA ReSDODse: Yes. Groundwater contamination extends from
the plant site to Thornton spring, and can be found under
several properties located "downgradient" from the Ruetgers
Nease. property. Traces of VOCs were detected in two wells
located offsite and downgradient from the Ruetgers-Nease
property, although at much lower levels than onsite.
The same local official commented
considering rezoning the Abramson
the area would be considered part
involved in the cleanup.
that College Township is
property and asked whether
of the site or become
EPA ResDoDse: No. The direct cleanup covers the Ruetgers-
Nease property only and other limited. offsite areas
including the FWDD and Thornton Spring. The official was.
advised, however, to be aware of the environmental concerns
in the area, and to consider these concerns thoroughly as
part of any rezoning activities.
PART :I:I:
COHPREBENS:IVE, TECJIJf:ICAL, AND LEGAL RBSPONSB TO
COMMENTS
This section provides technical detail in response to
comments or questions on the Centre County Kepone sit~. These
comments or questions were received at the October 19, 1994
public meeting or by mail or telephone during the pUblic comment
period, and may have been covered in a more general fashion in
Part I of this Responsiveness Summary. The following specific
comments are addressed:
A.
B.
C.
D.
A.
E.
Comments of Golder Associates
Comments of u.s. Fish and wildlife Service, Pennsylvania
Fish and Boat commission, and the u.S. Department of
Interior Office of Policy and Compliance .
Comments of Spring Creek Chapter Trout Unlimited
Comments of Pennsylvania Department of Environmental
Resources
Comments of various citizens
Golder Associates Comments
In an a-page document dated November 30, 1994, Golder Associates
(Golder) commented on the Proposed Plan on behalf of Ruetgers-
Nease Corporation. The document included numerous editorial and
clarification comments (which are acknowledged by EPA) , as well
as several specific technical comments regarding the Proposed
Plan. These specific technical comments follow:
10
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1.
PRP Comment #11: Additional sampling should be limited to
riparian area soils of spring Creek within the original
study Area, and sediments in the lower portion of the FWDD
and Thornton Spring. Additional sampling beyond the Benner
Fish Hatchery is unwarranted based upon the data previously
collected by PaDER. The PaDER data includes sample points
in Blanchard Lake which were non-detect for both mirex and
kepone.
SPA ResDonse: The actual scope of the supplemental Spring
Creek sampling program is yet to be determined. However,
given that both kepone (36.9 ug/kg) and mirex (36.9 and 26.9
ug/kg) were detected at the Benner Spring sediment sampling
station during the RI, the extent of kepone and mirex in the
Spring Creek sediment below Benner Spring is currently
unknown. Consequently, additional sediment sampling
stations downstream of Benner spring are being considered.
2.
PRP Comment #14: EPA's stated objective for the selected
alternative amounts to removal of VOCs in soil to protect
groundwater from impacts due to leaching. This objective
can be equally satisfied by capping or soil vapor extraction
(SVE). We believe EPA should reconsider its preferred
alternative for soils and at least permit pilot testing of
SVE at RNC's option to establish its effectiveness at the
site.
SPA ReSDonse: As stated in the feasibility study for the
Site, effective implementation of SVE will be difficult
because of the low hydraulic conductivity of the soils
(about lxlO-7 em/see) and the perched water table
conditions. Difficulties may also be encountered by the
potential need for hydrofracturing near active plant
facility buildings, and the placement of piping through the
plant area. - Given these uncertainties regarding.
implementation and effectiveness, SVE was not selected for
further evaluation.
However, SVE may be reconsidered if the selected remedies
demonstrate limited success in the objectives of containment
of VOC contamination and ground-water treatment. .
Consequently, BFA does not object to pilot testing of the
SVB technology concurrent with the implementation of the
preferred alternative provided it does not interfere with
the schedule for remedial design/remedial action, although
SVE testing will not be specifically addressed in the ROD.
Capping was not selected for further evaluation since
contaminants would remain in soils at levels above
acceptable levels and would not satisfy the threshold
criteria for overall protection of human health and the
environment as established in the NCP.
11
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B.
u.s. Fish and Wildlife, Office of Environmental Policy and
compliance, and pennsylvania Fish and Boat Commission
Comments
Comments prepared and submitted by various federal and state
agencies indicated similar concerns which are summarized and
addressed in the following section. Similar comments were
received from the following agencies:
.
In a prepared statement presented at the October 19, 1994
public meeting and in a subsequent 2-page written submission
of this statement, the united States Department of Interior
Fish and Wildlife Service (F&WS) commented on the Proposed
Plan for the Site.
.
In another prepared statement presented at the October 19,
1994 public meeting and in a subsequent 4-page written
submission of this statement, The Pennsylvania Fish and Boat
commission (PFBC) commented on the Proposed Plan for the
Site.
.
In a 6-page letter dated October 31, 1994, the United States
Department of Interior, Office of the Secretary, Office of
Environmental Policy and Compliance (OEPC) commented on the
Proposed Plan for the Site.
The F&WS and PFBC statements and OEPC letter raised the following
general concerns, which are summarized as follows:
1.
F&WS/OEPC Summary Comment #1: The F&WS and OEPC believe
that wildlife is at risk from contaminants present in the
soil of the 1S-acre grassy field adjacent to the plant Site,
and that this area should be addressed further.
EPA ReSDonse: EPA acknowledges that there cis some
uncertainty regarding the ecological risks associated with
the 15-acre grassy field adjacent to the plant Site.
Consequently, additional sampling and a subsequent
reassessment of the ecological risks posed by the
contaminants in this area are currently planned to resolve
the uncertainty. Any further action required for this area
will be addressed at a later date as part of the Proposed
Plan and subsequent Record of Decision (ROD) for OU2.
However, it should be noted that the Former Drum staging
Area, which considered part of 15-acre grassy field, will be
addressed under OU1.
2.
F&WS/PFBC/OEPC Summary Comment #2: The F&WS, PFBC, and OEPC
are concerned that the preferred. alternative may adversely
affect both Thornton Spring and Spring Creek, with respect
to altering the integrity of Thornton Spring (as related to
flow and contaminant flux), and increase thermal loading to
12
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spring Creek. Consequently, they request that the preferred
alternative be re-evaluated further to assess these
concerns. Further, the OEPC indicates that the preferred
alternative for the ground-water/Thornton Spring should be
the most protective alternative (GW/TS-4), or at least a
combination between GW/TS-4 and the Proposed Plan
alternative GW/TS-3. In addition, the PFBC also indicates
that Thornton Spring should be treated for contaminants of
concern at its source.
EPA ReSDODse: EPA recognizes the importance of thermal
loading on the resources of spring Creek. A study is
currently underway which is further evaluating the thermal
effects of Thornton spring flow on the Spring Creek
watershed. Based on the results of this study, EPA proposes
to develop a thermal loading performance standard for any
action implemented which potentially effects flow at
Thornton Spring. This performance standard, which will" be
further developed during the Remedial Design phase, is
intended to prevent unacceptable thermal loading of the
Spring Creek cold water resource.
with respect to the treatment of contaminants at Thornton
Spring, this alternative has several limitations. First,
this alternative provides limited overall protection as it
would continue to allow contaminants to migrate from the
Site to Thornton spring. Further, it has been demonstrated
in the FS that this alternative would be difficult (although
not impossible) and most costly to implement because of
various technical complications. The system evaluated in
alternative GW/TS-4 would be extensive, and would initially
require acquisi tion of and rezoning of property in the
vicinity of Thornton Spring, followed by the development of
considerable spring flow control structures, the
construction of a treatment plant capable of treating an
average of 250 gpm and up to 3000 gpm, and the construction"
of a 500,000 gallon clear well to equalize flow to the
treatment system. Such a system constructed in the vicinity
of Thornton Spring could have numerous adverse social and
environmental impacts.
3.
F&WS/PFBC/OEPC Summary Comment #3: The F&WS, PFBC, and OEPC
indicate that the contaminated sediments in Thornton Spring
and the lower portion of the FWDD should be addressed given
the environmental receptor risks posed by the sediments in
these areas.
EPA ReSDODse: Further assessment of the contaminated
sediments of Thornton Spring and the lower portion of the
FWDD is currently planned. Any further action required for
these areas will be addressed at a later date as part of the
final Proposed Plan and subsequent final Record of Decision
13
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(ROD) .
4.
F&WS/OEPC summary Comment #4: The F&WS and OEPC concur that
additional characterization of Spring Creek riparian-area
soil and sediments is required prior to a final
determination of remedial action for this portion of the
site.
EPA ReSDonse:
No response is necessary.
C.
spring Creek Chapter Trout Unl~ited Comments
In a 4-page letter dated October 28, 1994, the Spring Creek
Chapter of Trout Unlimited (SCCTU) commented on the Proposed
Plan for the Site. The SCCTU letter raised concerns that
the potential for thermal degradation of Spring Creek as a
result of the actions described in the Proposed Plan has not
been adequately addressed. The SCCTU requested that
. "...some other treatment and discharge alternative be
considered ~o prevent any further thermal degradation to
Spr ing Creek. II . .
1.
EPA ReSDonse: See EPA response presented in Part II,
Section B, Response #2.
D.
pennsylvania Department of Environmental Resources Comments
In a 3-page document dated October 25, 1994, the Commonwealth of
Pennsylvania Department of Environmental Resources commented on
the Proposed Plan. The specific comments of this letter follow:
1.
with regard to groundwater contamination, PADER is concerned
that the preferred alternative GW/TS-3 will not provide
adequate control to prevent the migration of contaminants
from the Site to Thornton Spring and ultimately Spring
Creek. This basis for this concern is related to the Site's
karst geology where subsurface flows follow fractures and
solution channels. The interception of all of these
pathways to prevent any offsite migration by the series of
wells is a hit or miss solution.
Given these concerns, PADER prefers alternative GW/TS-4,
which includes source control wells and treatment at
Thornton spring in lieu of the migration control wells.
This would ensure that the source of the contaminants
entering spring Creek via Thornton Spring would be
eliminated, as well as eliminating the ~irect contact threat
the spring discharge presents. PADER would, however, like
to remove the in-situ portion of the remedy solution because
an adequate treatment system would most likely require
external units.
14
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Realizing that alternative GW/TS-3 does have the potential
to achieve the remediation goals relative to the protection
of Thornton Spring and spring Creek, PADER will agree with
the selection of this alternative only if it includes a
provision for implementation of a collection and treatment
system at Thornton Spring if statistically significant
reductions of contaminant levels are not attained within
five years of remedy implementation.
EPA ReSDonse: The ROD will include a performance standard
for the surface water at Thornton Spring which requires no
less than a 20% reduction per year in the baseline
contaminant concentrations established during the remedial
design over a five year period or compliance with the
substantive requirements of the NPDES discharge regulations
set forth in 25 PA Code S 92.31, and the Pennsylvania Water
Quality Standards (25 PA Code SS 93.1-93.9). Should this
performance standard not be attained, the ROD will require
supplements or modifications to alternative GW/TS-3, which
could incorporate elements of alternative GW/TS-4, which
includes the collection and treatment of surface water at
Thornton spring.
2.
with regard to soil remediation, PADER concurs with the
selection of alternative 55-2 (excavation and offsite
disposal of contaminated soils), however, it is not
convinced that this activity should be limited to those
areas which are easily accessible. PADER has been involved
with remediations at other facilities where structures have
been relocated in order to provide access to contamination.
We have not been provided sufficient information in this
case to indicate that relocation of the tank farm, whether
on a temporary or permanent basis, is not a viable option to
allow access to the contaminated soils in this area. The
highest levels of soil and ground-water contamination on the
site have been documented in the tank farm area. If this
contamination is left in place in its current state,
contaminants will continue to leach into the groundwater
precluding the ground-water pump and treat system from
achieving its remediation goal. In addition, while
alternative SS-2 includes a series of source control wells
in this vicinity, the absence of an aquitard layer at a
reasonable depth beneath the tank farm eliminates any
assurances that contaminants will not simply migrate
downward and elude the capture zones of these wells.
EPA ReSDonse: Given that the Ruetgers Nease plant site is
an active on-going operation, the relocation of major plant
facilities could be highly disruptive and costly to plant
operations. Although it is acknowledged that residual
contamination will remain in areas inaccessible to
excavation, the combination of remedies selected for the
15
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site is expected to meet the overall remedial objectives for
the site. However, the overall effectiveness of the entire
preferred remedy (including soil, sediment, and ground-water
elements) will be evaluated after implementation and during
scheduled 5-year reviews in accordance with Section 121(c)
of CERCLA. Should the selected remedies not be successful
in meeting the remedial objectives, additional measures may
be identified and implemented (such as SVE) to further
address the subsurface soil in the main plant area.
3 .
with regard to the Freshwater Drainage Ditch surface water
and sediments, PADER concurs with the preference of
alternative FWDD/SW-2A and FWDD/SED-2. However, PADER
specifies that all contaminated soil that is encountered be
remediated according to the Departments December, 1993,
guidance document "Cleanup Standards for contaminated
Soils." .
4.
EPA ResDoDse: EPA has incorporated, where appropriate, the
PADER guidance into the soil/sediment cleanup criteria being
developed for the site, although these guidelines are "To Be
Considered (TBCs)" rather than ARARs. Only two compounds,
methylene chloride and tetrahydrofuran, are affected by the
State's TBC standards. These two compounds were detected
during the Remedial Investigation and were not considered in
the Summers Model presented in the Feasibility Study.
with regard to spring Creek sediments, PADER concurs with
the rationale behind the preferred alternative SC-2, but has
several qualifications. with regard to the fish tissue
sampling, PADER specifies that it be done according to DER
protocol (PADER Publication #33), during the Department's
preferred seasons (August and September) and finally that
the three stream sites that have been historically sampled
by the Department and the Fish Commission be utilized. In
addition, should fish tissue body burdens ever decrease to
the point that the Department and the PennsYlvania Fish and
Boat Commission consider opening up the Spring Creek
fishery, a more intensive short-term survey would be .
required. This would include more stream locations to be
sampled, additional fish species to be collected, and more
seasons to be sampled before the final decision to open the
fishery be made. .
PADER believes that the proposed plan should retain
alternative SC-3 (or a hybrid version) for future
consideration. The trigger mechanism for initiation of this
alternative would rely upon kepone and mirex concentrations
in Spring Creek sediment and fish tissue. These levels
would be evaluated during the five-year review mandated by
CERCLA section 121(c). If kepone and mirex levels exceed
the 10 ppb cleanup standard,. remediation of spring Creek
16
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sediments, as well as Thornton Spring sediments, should be
required.
EPA Response: The specific details regarding the proposed
fish monitoring program will be developed during the
Remedial Design phase of the project. All relevant
recommendations regarding the frequency and scope of fish
tissue sampling activities program will be evaluated and
incorporated into the final monitoring program.
E.
with regard to retaining alternative SC-3 for future
consideration, additional sampling and further evaluation of
Spring Creek sediments are proposed. Based on the results
of this additional study, additional remedial alternatives
addressing Spring Creek sediments, including
hydraulic/vacuum dredging (i.e. alternative SC-3), may be
considered during the 5-year review process. If any further
action is required for spring Creek sediments, it would be
addressed in a ROD amendment or in an Explanation of
signifi cant Differences (" ESD") .
Additional Various Citizen Comments
Various other written comments were received from several
citizens regarding the Proposed Plan. The detailed comments,
including a 3-page letter from one citizen are presented first,
followed by other comments submitted by various other citizens.
Comments presented in a 3-page letter submitted by one citizen
include:
1.
Given the citizens' observations regarding the general
improvement in apparent stream quality and the expected
effectiveness of alternatives GW/TS-3 and 55-2 to further"
reduce contamination, this citizen indicated that fencing
the spring and its tributary is not necessary. Although
fencing would potentially restrict direct access to the
spring and stream and subsequently direct "contact with
contaminated water and sediments, it would do little to
prevent the inhalation of VOCs in the air unless the "fenced
in area" included a large portion of the citizens'. property
and that of their neighbor. As an alternative, this citizen
recommends that the water from the spring be diverted into a
drainage pipe from the upwelling to spring Creek. Such
action would greatly reduce the potential for inhalation of
VOCs and direct contact with contaminated water and
sediment. Although probably more expensive than fencing,
future maintenance costs would be greatly reduced and
potential access virtually eliminated. . Although the
Pennsylvania Fish and Boat Commission may object to burying
the stream on the basis of a significant loss of habitat,
the entire tributary represents approximately 300 feet of
17
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channel and in terms of the entire Spring Creek drainage a
very small percentage of available habitat.
EPA ReSDODse: The exact locations and specifications for
the areas to be fenced will be decided during the Remedial
Design phase of the project.
with regard to the recommendation of "piping" Thornton
Spring from its upwelling to spring Creek, this alternative
was considered, but rejected during the early phases of the
FS. This alternative was eliminated from further review
because of problems associated with technical
implementability related to highly variable flows, and major
administrative issues related to limited property access and
the constraints that are associated with the spring being a
regulated water body.
2.
What are the specific VOC's in the air near Thornton Spring
and its tributary? How were these data used to calculate
potential health risks to current and future residents
living near the spring and its tributary? Since the VOC
concentrations were considerably lower in 1990 and 1992 when
air sampling was conducted, what are the potential health
risks to current residents associated with concentrations
that may have been many times greater?
EPA ResDoDse: A total of ~6 different chemicals were
detected in the air during the two phases of air sampling at
Thornton Spring, including: acetone, benzene, 2-butanone,
chlorobenzene, cis-~,2-dichloroethene,
trans-~,2-dichloroethene, ~,2-dichlorobenzene, ethylbenzene,
~,~,2,2-tetrachloroethane, toluene, ~,2,4-trichlorobenzene,
~,~,~-trichloroethane, tri chI oroethene,
trichlorofluoromethane, vinyl chloride, and xylene. It
should be noted that only a few of these compounds were
detected in any given air sample.
with regard to how the air data are used to calculate
potential health risks, see the EPA Response to Part I,
section B, Comments #~, 2, 3, 4, and 5.
with regard to the portion of the question about potential
health risks associated with exposures prior to ~990 and
~992, the Superfund risk assessment process is generally
concerned with current or future exposures. Consequently,
historical exposures are not typically addressed.
3.
What is meant by "institutional controls such as deed
restrictions at Thornton Spring?" This statement appears in
several places in the proposed plan but is never defined.
Does this statement apply to the tributary that flows from
the spring to spring Creek? The area is currently zoned
18
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residential, although it is indicated on page 12 that it is
industrial. Does the above statement infer that zoning
would be changed or that nearby property owners would be
restricted in selling their property? Such restrictions
could have a negative impact on the value' of adjacent
properties and on the property owners' ability to sell it.
If such restrictions are to be implemented, EPA, DER, or
Ruetgers-Nease should consider buying the properties
adjacent to the spring.
EPA ReSDonse: The scope of any deed restrictions that may
be considered necessary to meet the institutional control
objective will be determined during the Remedial Design
phase. Extensive deed restrictions will only be necessary
if additional measures beyond those proposed are required to
limit future exposure to residual contaminated surface water
and sediments in the vicinity of Thornton Spring. possible
deed restrictions could include the prohibition of the use
of spring water for potable or non-potable uses, future
building or improvement setback/encroachment requirements at
the spring site, limitations on future land uses at the
spring site, etc. Any deed restriction proposed will be
carefully analyzed to ensure that any potential impact on
nearby property values or land use are minimized.
4.
It is stated on page 17 that periodic sampling of
groundwater, Thornton spring surface water, and the
treatment system influent and effluent will be conducted.
Does EPA infer by this statement that air quality and
sediments will not be monitored in the future? Furthermore,
how frequent is "periodic sampling?" Once per year? Once
every three years? Future sampling of all contaminated
resources needs to be conducted on a routine basis and
should be precisely defined in the Proposed Plan.
EPA Response: The appropriate monitoring frequency of
groundwater, Thornton Spring surface water, and the
treatment system influent and effluent will be formally
established during the upcoming Remedial Design phase of the
project. However, for the purposes of developing cost
estimates for the FS, monitoring wells and surface water
from Thornton spring were proposed to be sampled quarterly
for VOCs, annually for mirex and kepone, and biannually for
photomirex. Further, treatment plant effluent and influent
were proposed to be sampled monthly for VOCs and sampled
biannually for mirex, kepone, and photomirex (effluent
only) . '
with respect to air sampling, none is currently proposed to
be routinely conducted given that the baseline risk
assessment identified no unacceptable exposures to air.
However, air monitoring will be performed, as necessary, to
19
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ensure that the proposed action will meet the appropriate
emission limitations and health and safety concerns.
with respect to additional sediment testing, the
contamination of sediments in Thornton Spring and Spring
Creek will be further evaluated. Any further action required
for this media, including sediment quality monitoring
freqUency, will be addressed at a later date as part of the
final Proposed Plan and subsequent final Record of Decision
(ROD) .
5.
Onsite and offsite references need to be clearly defined,
particularly in reference to Table 1 and the potential risk
scenarios. It appears that "onsite" refers to the Ruetgers-
Nease facility and ~ot Thornton Spring. However, in several
instances in the report, references to the spring and onsite
, are used together giving the impression that the spring is
considered "onsite." Obviously, anyone living near Thornton
Spring is subject to a greater risk than someone living
further from the spring. Consequently, the "current
offsite" and "future offsite" populations listed in Table 1
should be clearly defined and perhaps stratified to include
those located relatively close to the spring and the onsite
facility and those that live at a greater distance from
either the spring or Ruetgers-Nease.
EPA ResDonse: For the Centre county Kepone Site, the site
is defined as all areas impacted by contaminants originating
from the Ruetgers Nease plant site, including but not
limited to, areas underlain by contaminated ground water,
Thornton Spring, and portions of Spring Creek. With regard
to the risk scenarios, "onsite" is defined as the area
within the property boundaries of the Ruetgers-Nease
Chemical plant proper. Consequently, "offsite" is defined
as those areas outside of the Ruetgers Nease property
boundaries, and directly includes such areas as Thornton
spring and spring Creek, as well as other areas outside of
the property boundaries.
During the human health risk assessment, certain assumptions
are made regarding realistic and complete exposure pathways
(i.e. potential contact ,with contaminated soil, sediment,
surface water, ground water, and air) with respect to a
targeted population, including workers, trespassers,
residents, and visitors. These conservative assumptions are
employed to ensure those populations with the greatest
potential ,risk are identified and assessed in the risk
assessment. All reasonable populations with some potential
for risk are assessed, whereas populations with no potential
for risk are excluded from the assessment.
For this Site, there were three current or future "offsite"
20
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target populations that were assessed to be potentially at
risk. The "offsite resident" was defined as those people
who live directly adjacent to Thornton spring (the
population with the most likely potential for risk); the
"offsite floodplain resident" was defined as those people
who live directly along the floodplain of Spring Creek, and;
the "recreational visitor" was defined as those people who
occasionally frequent spring Creek for fishing, wading, or
other water contact activities. No other offsite
populations were determined to be potentially at risk.
No unacceptable risks were identified for any current or
future offsite populations investigated during this study.
other comments submitted by citizens are:
6.
A citizen expressed concern that soil remediation also
consider mirex and kepone concentrations in addition to the
volatile organic compounds (VQCs), as mirex and kepone are
also present at very high concentrations. Further, a
concern was expressed that the remedial alternatives chosen
be properly implemented on the full extent of the C
contamination as demonstrated by a sufficient and convincing
sample network.
EPA ReSDonse: The actions proposed for this site are
intended to address the mirex and kepone (as well as the
VOC) contamination in the soil, sediment, ground water and
surface water. Appropriate cleanup criteria for mirex,
kepone, and VOCs are currently being developed.
7.
EPA's preferred remedial alternative for the site is
intended to provide protection of human health and the
environment. While it is recognized that not all of the
contamination will be completely removed by the preferred
alternative, the unacceptable risks associated with any
residual contamination will be adequately mitigated by the
proposed action to ensure human health and environmental
protection.
A citizen expressed concern that the Site report was
extremely difficult to follow, and raised the point that the
document be made clearer so that every citizen could
understand it. Further, this citizen asked if there was any
way to speed up the process of cleaning up this
environmental site.
EPA ReSDonse: EPA recognizes that the RI/FS report for this
project is a very complex document, but this level of
technical detail is required to present the scientific
information necessary to evaluate and determine the most
appropriate cleanup approach for the Site. Realizing that
21
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these complex technical reports can be difficult to
understand, EPA has developed several non-technical general
information fact sheets and other background documents which
summarize the cleanup program and complex Site issues.
These easy-to-read summary documents are included in the
Administrative Record, which is available for review from
information repositories located at the Schlow Library and
EPA Region III in Philadelphia.
with regard to the duration of the cleanup process, see the
EPA response provided for Part I, Section A, comment #6.
22
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RESPONSIVENESS SUMMARY SUPPLEMERT
FOR THE REVISED PROPOSED REMEDIAL ACTION
AT THE
CENTRE COUNTY REPONE SUPERFUND SITE
CENTRE COUNTY, PENNSYLVANIA
PLAN.
Public Comment Period:
January 27, 1995 thru February 25, 1995
-------
Overview
Part I:
A.
B.
C.
D.
CENTRE COUNTY REPONE SITE
RESPONSIVENESS SUMMARY SUPPLEMENT
POR THE
REVISED PROPOSED REMEDIAL ACTION PLAN
TABLE OP CONTENTS
. . . . . . . . . . . . . . .
. . . . . 1
.......
Comprehensive, Technical, and Legal Response to Comments
Comments of Golder Associates. . . . . . . . . . . . 3
Comments of ~ennsylvania Fish and Boat Commission. . 7
Comments of the u.s. Department of Interior Office
of Pol-icy and Compliance. . . . . . . . . . . . . . 8
Comments of Pennsylvania Department of
Environmental Resources. . . . . . . . . . . . . . 10
Attachment 1
Attachment 2
Supporting Technical Data for Mirex and Kepone
supporting Technical Data for Development of 10 ppb
Cleanup Criteria
.
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RESPONSIVENESS SUMMARY SUPPLEMENT - REVISED PROPOSED PLAN
CENTRE COUNTY KEPONE SITE
STATE COLLEGE, PBNHSYLVANIA
This responsiveness summary supplement is divided into the
following sections:
Overview:
This section discusses the revisions to EPA's
preferred alternative for remedial action.
Part I:
This section provides a comprehensive response to
all significant comments and is comprised
primarily of the specific legal and technical
questions received during the public comment
period for the revised proposed plan.
This portion of the responsiveness summary is intended to
address the comments raised for the revised proposed plan
only, but is also intended to supplement the comprehensive
responsiveness summary completed for the original proposed
plan. .
OVERVIEW
In October 1994, EPA announced the opening of the public
comment period and published its preferred alternative for the
Centre County Kepone Site, located in State College, Centre
County, Pennsylvania. However, based on further evaluation and
comments received during that public comment period, EPA issued a
revised Proposed Plan in January 1995 for the site. The revised
Proposed Plan addressed and clarified a number of issues raised
during the initial public comment period. A summary of the major
Proposed Plan revisions are as follows:
.
Operable unit Designations - EPA has divided the planned
remedial action into two operable units (OUs) to simplify
and expedite action at the site.
OU1 will remediate the principal threats at the Site which
are VOC contamination in the ground water and surface water,
mirex and VOC contamination in on-site soils and sediments
(excluding the Former Spray Field Area), and mirex in fish
tissue.
OU2 will address the final response actions for soils in the
riparian-areas of spring Creek and the 15-acre Former Spray
Field Area, and sediments from the lower portion of the
freshwater drainage ditch and Thornton spring. These areas
were not fully characterized during theRI/FS and sampling
efforts will be required for these areas prior to the
development of final response actions.
1
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.
Together, OU1 and OU2 will remediate the Site by addressing
the principal threats posed by the site. The final response
actions for OU1 are addressed in the revised proposed plan.
Cleanup criteria - EPA has developed cleanup levels for
contaminated soil and sediment at the Site. Neither state
nor federal applicable or relevant and appropriate
requirements (ARARs) exist for the chemicals of concern at
the Site, and consequently, cleanup levels for VOCs, mirex,
and kepone were developed to reflect levels of contaminants
that will be protective of ground water, environmental
receptors, and to meet the ground-water ARARs. These
cleanup levels are included in the revised proposed plan.
.
Miscellaneous Technical Clarifications - Several additional
technical clarifications were presented in the revised
proposed plan, and are summarized as follows:
Thermal Loadina for Sprina Creek: A common component for
the ground-water extraction systems described in the revised
proposed plan includes an analysis of the final design and
the projected thermal effects to Spring Creek. If
necessary, mitigation plans will be included as part of the
remedial design to maintain the existing thermal regime of
Spring Creek.
Thornton Sprina Monitorina: The surface water from Thornton
Spring will be monitored prior to initiating operation of
the ground-water extraction system. The purpose of the
monitoring is to establish the baseline contaminant
concentrations at Thornton Spring and evaluate the
performance of the ground-water extraction system during
operation.
Desianation of Excavation Areas: Under alternative SS-2,
contaminated soils from the more isolated and unobstructed
areas on the Ruetgers-Nease property would be excavated
where concentrations of VOCs exceed levels that are
protective of ground water. These areas include, but are
not limited to, the Former Drum staging Area, the Designated
Outdoor storage Area, and the Tank Farm/Building #1 Area.
Cleanup levels for the soils in these areas are provided in
the revised proposed plan.
with the exception of the above changes and other minor
editorial and clarification revisions throughout the revised
proposed plan, there were no other changes to the original
proposed plan.
2
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PART I:
COMPREHENSIVE, TECHNICAL, AND LEGAL RESPONSE TO COMMENTS
This section provides technical detail in response to
comments or questions on the revised Proposed Plan for the Centre
County Kepone Site. These comments or questions were received
via mail during the public comment period from January 27 through
February 25, 1995. The following specific comments are
addressed:
A.
B.
C.
Comments of Golder Associates
Comments of Pennsylvania Fish and Boat Commission
Comments of the u.S. Department of Interior Office of Policy
and Compliance
Comments of Pennsylvania Department of Environmental
Resources
D.
A.
Golder Associates Comments
In an large document dated February 24, 1995, Golder Associates
. (Golder) commented on the revised Proposed Plan on behalf of
Ruetgers Nease corporation. The document included a 7-page
summary letter with 6 additional attachments of other
correspondence regarding the Site dated November 30, 1994 through
February 8, 1995. The following major comments were presented:
1.
The 10 ppb soil cleanup levels for mirex and kepone are
unnecessary to achieve the remediation sought by EPA, and
moreover, are without scientific justification and
inconsistent with the National Contingency Plan (NCP).
EPA ResDonse: The 10 ppb soil cleanup levels developed for
the Site are intended to be protective of environmental
receptors. Because of their chemical properties, these
compounds require that their residual levels in soil be
allowed only at very low concentrations for the following
reasons:
. They are very resistant to degradation, with very long
residual half-lives;
. They bioaccumulate in the food chain;
. They bioconcentrate in ecological receptors;
. They adversely impact members of both the plant and
animal kingdoms; and
. Despite their adsorptive properties, both contaminants
have been transported some distance from the original
source, the RNC plant site, and, in fact, the certain
extent of contamination is as yet unknown.
3
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Both compounds strongly adhere to soil and sediment and are
made potentially more available to soil microorganisms found
in soils with elevated concentrations of organic carbon.
Mirex inhibits photosynthesis in plankton at levels as low
as 1. ppb. Some fish are adversely impacted by levels as low
as 7 ~g/l. Reports indicate that some soil microflora are
sensitive to levels as low as 0.01. ~g/kg. Consequently, the
10 ppb criteria are considered protective. A detailed
technical description of the effects of mirex and kepone on
environmental receptors, with supporting bibliography, is
presented in Attachment 1 of this responsiveness summary.
The general technical basis for the development of the
assumptions used to develop the 1.0 ppb criteria for mirex
and kepone are included in the Region III Interim Bcological
Risk Assessment Guidance. The Interim Guidance clearly
states that the conservative approach is preferred in cases
where a complement of information is not available (e.g., .
bioaccumulation studies, body burden of contamination, study
of endpoints of impacts specific to mirex and kepone, i.e.
endocrine system), as the situation regarding the Site. EPA
Region III assesses risk on a habitat basis rather than by
specific ecological receptors, in most cases, since remedial
investigations are not set up to carry out the kinds of
detailed surveys needed to identify and assess potential
impacts to all ecological receptors in a given area.
Therefore, sensitive species that may be found in or using a
given area have not been individually considered. This is
the case with the Centre County Kepone RI, therefore the
conservative approach in determining protective cleanup
targets is preferred. Specific details regarding the
assumptions used by EFA to calculate the reasonable worst
case scenario are included in Attachment 2 of this
responsiveness summary.
In summary, risk assessment is the basis for determining the
target cleanup level for risk management and based upon the
EPA Region III screening level risk assessment approach, the
cleanup level could be extremely low. EPA's rationale for
selecting the 1.0 ppb number was based on information from.
the RI coupled with a revised toxicological evaluation
originally presented in. the risk assessment and some
compromises dictated by technology and economics. The
screening results are as follows:
. A screening level risk assessment shows a potential for
risk a~ 1. ppb and if the uncertainty factor of 1.00
(applied to protect unrelated species) were to be
factored in, we would recommend a cleanup target of 0.001.
ppb.
4
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. The reasonable worst-case scenario shows
risk at about a factor of 10 which would
case for recommending less than 1 ppb as
number.
a potential for
still make a
a target cleanup
Despite the evidence justifying the 10 ppb (or less) cleanup
criteria, EPA recognizes that there are analytical concerns
regarding the ability to assess this low level of kepone and
mirex contamination in the soil and sediments. To address
this concern, EPA is proposing a standard of performance
that is equivalent to the 10 ppb cleanup criteria for the
FWDD sediments which will attain the remedial objectives for
protection of environmental receptors. This performance
standard will require that the upper 24 inches of
sediment/soil be removed from the FWDD (regardless of kepone
and mirex concentrations). The upper two feet of
sediment/soil is where the greatest biological activity is
found and includes the topsoil and A horizon. In addition,
the two foot depth harbors the food organisms for a wide
variety of predators ranging from insects through mammals
and birds. Should volatile organic contamination be
detected below the 24-inch depth in excess of the soil
cleanup criteria for protection of groundwater, additional
excavation will be required. Once all of the contaminated
sediment/soil has been removed, the area will be backfilled
to grade.
2.
The soil cleanup levels for organic compounds are
inappropriate: (a) as to the PADER interim cleanup standards
because PADER no longer supports the use of these standards
made by EPA in the revised PRAP, and their use is
inconsistent with the NCPi and (b) as to the Summers Model
because the effects of existing controls have not been
considered.
EPA Resoonse: The soil cleanup standards presented in
revised proposed plan was a combination of the results
the Summers Model presented in the feasibility study
prepared for the site and PADER cleanup guidance.
with regard to the PADER cleanup guidance, it is .
acknowledged that some technical concerns have been raised
regarding the general applicability of these criteria.
However, these criteria continue to be used by PADER
presently t;hrougbout the Commonwealth pending the
development of new guidelines, which are expected to be
issued within the next 18 months to 36 months. Consequently
as a result of the current status, this cleanup guidance is
currently being used to support feasibility studies at other
Region III sites in Pennsylvania, including the AIW Frank
and Middletown sites. Therefore, the criteria are
considered appropriate for the Site. As a result, only two
the
from
5
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compounds, methylene chloride and tetrahydrofuran, are
influenced by the criteria. These two compounds were
detected during the Remedial Investigation and were not
considered in the Summers Model presented in the Feasibility
Study.
with regard to the applicability of the results from the
Summers Model presented in the Feasibility Study, EPA's
intent is to develop one set of cleanup criteria to be
applied to all soil and sediment addressed under OU1,
including subsurface soil located under paved areas in the
plant area, soil located in the Former Drum Staging Area,
and sediments in the FWDD. It is acknowledged that
inclusion of the effects of pavement in the Summers Model
would produce a less conservative set of criteria than those
selected. However, preference was given to a single
conservative set of criteria for soils and sediments since.
lateral infiltration of groundwater through adjoining
unpaved areas or subsurface drainage is possible at the Site
which would result in the release of contaminants to
groundwater. In addition, there are no assurances that the
paved surfaces would remain paved for an infinite time
period.
3.
Soil Vapor Extraction (SVE) has not been given appropriate
consideration, which is inconsistent both with the
requirements of the NCP and EPA Region III's consistent
practice at all other sites.
EPA ReSOODse: EPA has considered SVE extensively as part of
the remedial alternative evaluation process, and this review
is consistent with the Threshold and Primary Balancing
criteria set by the NCP (40 CFR 300.430(f)). As stated in
the feasibility study for the Site, effective implementation
of SVE will be difficult because of the low hydraulic
conductivity of the soils (about lX10-7 em/see) and the
perched water table conditions. Difficulties may also be
encountered by the potential need for hydrofracturing near
active plant facility buildings, and the. placement of piping
through the plant area. Given these uncertainties regarding
implementation and effectiveness, SVE was not selected for
further consideration as part of the preferred remedy for
the Site.
However, SVE may be reconsidered if the selected remedies
demonstrate limited success in the objectives of containment
of VOC contamination and ground-water treatment.
Consequently, EPA does not object to pilot testing of the
SVE technology concurrent with the implementation of the
preferred alternative provided it does not interfere with
the schedule for the. remedial design/remedial action.
However, SVE testing will not be specifically addressed in
6
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the ROD.
B.
pennsylvania Fish and Boat Commission Comments
In a 3-page document dated February 24, 1995, the Pennsylvania
Fish & Boat Commission commented on the revised Proposed Plan.
The following comments were presented:
1.
The PFBC recognizes spring Creek as an outstanding aquatic
resource, and agrees that a component of any system removing
or discharging additional water to Spring Creek must include
monitoring and design to maintain the existing thermal
regime of spring Creek. In addition, the PFBC views
Thornton Spring as a stream capable of supporting a
significant aquatic community, and are concerned that this
stream will not be returned to a condition that could
support aquatic life in the near future. Consequently, the
PFBC prefers alternative GW/TS-4, an expansion of the .
existing ground water extraction and treatment system with a
surface discharge plus in-situ treatment of Thornton Spring.
However, if GW/TS-3 is the alternative that is designed and
implemented, the PFBC supports rapid reduction in
contaminant levels at Thornton Spring, establishment of
performance standards to achieve contaminant reduction, and
regular monitoring to determine if standards are met.
Failure to effectively reduce contaminant levels should lead
to system redesign or supplementation.
2.
EPA ReSDonse: The ROD will include a performance standard
for the surface water at Thornton Spring which requires no
less than a 20% reduction per year in the baseline
contaminant concentrations established during the remedial
design over a five year period or compliance with the
substantive requirements of the NPDES discharge regulations
. set forth in 25 PA Code S 92.3~, and the Pennsylvania Water
Quality Standards (25 PA Code SS 93.~-93.9). Should this
performance standard not be attained, the ROD will require
supplements or modifications to alternative GWjTS-3
(including the expansion of the extraction well network).
These modifications could incorporate elements of
alternative GWjTS-4, which includes the collection and
treatment of surface water at Thornton Spring.
Thornton spring sediments are not addressed in any remedial
action alternatives. Understanding one objective of EPA's
remedy is to reduce bioavailability of contaminants in
spring Creek sediments, it follows that highly contaminated
sediments in Thornton Spring should be removed. It is the
experience of the PFBC in dealing with recent sediment
removal projects in the Spring Creek watershed that Thornton
Spring sediments can be readily removed. The PFBC agrees
7
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C.
with EPA's proposal of a 10 ppb cleanup level for the
Freshwater Drainage Ditch, and feel it should be applied to
Thornton spring sediments.
EPA ResDonse: The sediments of Thornton Spring will be
addressed as part of OU2 activities. Removal of Thornton
Spring sediments or the application of cleanup criteria will
be considered during the remedial alternative evaluation
phase of OU2.
3 .
soil excavation is planned for isolated and "unobstructed"
areas. Given the extent of contamination and potential for
continuing release of contaminants via ground water, it is
important that "unobstructed". be further defined so it does
not simply mean inconvenient for plant operations in areas
such as Tank Fa.rm/Building #1.
EPA Response: Unobstructed areas are defined as locations
. in the main plant area where remedial activities can be
conducted without the major disruption of plant activities.
No major facility relocation is proposed to facilitate
remedial action at the Site. However, the overall
effectiveness of the entire preferred remedy (including
soil, sediment, and ground-water elements) will be evaluated
after implementation and during scheduled 5-year reviews in
accordance with Section 121(c) of CERCLA, and should the
selected remedies not be successful in meeting the remedial
objectives, additional measures may be identified and
implemented (such as SVE) to further address the subsurface
soil in the main plant area.
United states Department of Interior, Office of the
Secretary, Office of Environmental Policy and Compliance
Comments
In a 3-page document dated February 27, 1995, the United states
Department of Interior, Office of the Secretary, Office of
Environmental Policy and Compliance commented on the revised
Proposed Plan. The following comments were presented:
1.
The DOI stated that the decision to study the lower FWDD and
Thornton Creek sediments further under OU-2 work is
unfortunate and will result in continued exposure and
unnecessary delay of protection for the environment,
including DOI trust resources. The DOI is concerned by the
delay, since the revised Proposed Plan does not indicate the
timing of the remedial action development for OU-2. The DOI
recommends that the additional studies of these areas be
conducted quickly so that an effective remedy can be
selected and a ROD for OU-2 can be written as soon as
possib.le.
8
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EPA ResDonSe: OU2 investigative activities are expected to
be conducted concurrently with the remedial design phase of
OUl to accelerate the overall decision schedule for OU2.
These activities are expected to begin shortly after the
completion of the ROD.
2.
The bifurcation of the site into two operable units has
created a remedial sequencing concern. Remediation of
upland areas should logically occur first, and the FWDD
sediments should be removed before treated ground water is
discharged. Otherwise, contaminated soil from the field
will continue to move downgradient to the FWDD, and the
treated ground water discharged to the FWDD will accelerate
movement of contaminated sediment to Spring Creek. The
development of two OU's is particularly problematic with
regard to the 15-acre spray field, since this will not be
addressed until OU-2. The lower FWDD should have sediments
removed before the discharge of treated ground water. Once
the ground water treatment system is operating, Thornton
spring will experience lower flows, easing the removal of
contaminated sediments.
EPA ReSDonse: Although it is acknowledged that upland areas
are typically addressed before downgradient areas in some
remediation scenarios, the upland areas of the site are
considered relatively stable from the perspective of
sediment transport. For example, the Former Spray Field
area is a thickly vegetated and maintained grassy field at
present, and there is little to no sediment transport from
this area occurring under current conditions. Further, any
future remediation of this area, if necessary, would require
strict sediment and erosion control measures to prevent the
migration of sediments during any type of construction
activities.
with regard to the sediment mobility in the lower portion of
the FWDD, sediment transport in this ditch is typically
limited to storm events given that this ditch drains a large
area beyond that of the Ruetgers Nease plant site. There is
usually little to no surface water flow in the lower portion
of the FWDD under non-storm conditions, and much of the
ditch is vegetated. The discharge of treated ground water
is not expected to promote sediment transport in the FWDD,
as most of the discharge is expected to disappear into the
subsurface along the FWDD. However, the potential for
increased sediment transport as a result of the ground-water
discharge will be evaluated and addressed during the
remedial design phase. to ensure that, minimal additional
sediment is transported to Spring Creek via the FWDD.
with regard to removal of sediment from Thornton spring, the
feasibility and necessity of this remedial alternative will
9
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4.
D.
3 .
be addressed as part of OU2 activities.
The DO I supports the revision that includes protection of
the existing thermal regime of Spring Creek. The DOI
requests that the FWS be consulted via the BTAG group to
help determine if mitigation plans are necessary, because
their cursory examination of data indicates that the
existing thermal regime cannot be maintained without
mitigation.
BPA Res~onse: All remedial design and action plans which
potentially affect environmental receptors at the plant
site, Thornton Spring, FWDD, and Spring Creek will undergo
review by the BTAG group directly and through the FWS and
PFBC as part of EPA's overall technical review of all RD/RA
activities.
The DOI does not agree that remediation of any Spring Creek
sediments would cause more environmental damage than it
would alleviate. The DOI requests that EPA determine the
net benefits of stream sediment remediation on a site-
specific basis via coordination with the BTAG.
BPA ReSDonse: Further consideration for the remediation of
Spring Creek sediments may be conducted as part of OU2
activities, based on the results of the riparian monitoring
program, or will be reevaluated as part of the 5-year review
process for the site.
Pennsylvania Department of Bnvironmental Resources Comments
In a 4-page document dated February 23, 1995, the Commonwealth of
Pennsylvania Department of Environmental Resources commented on
the revised Proposed Plan. Most of the comments provided on the
revised plan were identical to those provided for the original
plan, with the following exceptions:
1.
The Department would agree with the selection 'of alternative
GW/TS-3 only if it included a requirement that all ,
contaminate levels in Thornton Spring be reduced 20-25% per
year from an established baseline. If GW/TS-3 cannot
achieve this yearly reduction in Thornton Spring
contamination, then modifications to GW/TS-3, which could
include the construction of additional recovery wells, or
collection and treatment at Thornton Spring should be
mandated. In addition, the PRP should be given the
opportunity to implement collection and treatment at
Thornton Spring (GW/TS-4) if the PRP believes it cannot meet
these yearly reductions, at the outset ,of remedial
activities. .
BPA ReSDonse:
The ,ROD includes performance standards which
10
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require no less than a 20% reduction per year in the
baseline contaminant levels in Thornton Spring. Should this
performance standard not be attained, the ROD will require
supplements or modifications to alternative GW/TS-3, which
could incorporate elements of alternative GW/TS-4, which
includes the collection and treatment of surface water at
Thornton Spring.
Should it become apparent during the RD phase (based on
additional field data) that GW/TS-3 may not meet the
performance criteria, additional consideration will be given
to incorporating GW/TS-4 design elements into the final RD,
and modifying the Record of Decision as appropriate.
2.
The Department commented that in the event that large
amounts of contaminated soils remain in the tank
farm/building #1 area following the excavation of all
contamination which can be feasibly addressed, subsequent
implementation of other remedial alternatives, such as a
modified soil vapor extraction system, should be considered
or included as an integral part of SS-2. .
EPA ReSDonse: Although it is acknowledged that residual
contamination will likely remain in areas inaccessible to
excavation as part of SS-2, the combination of remedies
selected for the site is expected to meet the overall
remedial objectives for the Site. However, the overall
effectiveness of the entire preferred remedy (including
soil, sediment, and ground-water elements) will be evaluated
after implementation and during scheduled 5-year reviews in
accordance with section 121(c) of CERCLA. Should the
selected remedies not be successful in meeting the remedial
objectives, additional measures may be identified and
implemented (such as SVE) to further address the subsurface
soil in the main plant area.
3.
The Department clarified that the PADER level 2 cleanup
standards for 2-butanone and 2-hexanone are 50 ug/kg and 210
ug/kg, respectively.
EPA ReSDonse: EPA has revised the cleanup criteria for the
Site as appropriate.
11
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I
ATTACHMENT 1
SUPPORTING TB~CAL DATA POR KIREX AND REPONE
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MIREX
General Information: Mirex is a fully chlorinated, cage-
structured compound. It is resistant to heat (decomposition at
650°C) and has low reactivity with acids, bases and other
chemical agents such as ozone and lithium. It is one of the most
stable of the organochlorine pesticides known and has been used
widely in the southern United states for the control of the
imported fire ant. An estimated 74% of the mirex used in the
united states for nearly 20 years, however, has been used for
nonagricultural uses, i.e., as a fire retardant in plastics.
Environmental TranS~ort and Fate: The release of mirex in the
environment has occurred via effluents from manufacturing plants
and sites where mirex was utilized as a flame retardant additive
to polymers and at points of application where it was used as an
insecticide. Mirex is expected to persist in the environment
despite the 1978 ban on its use in the United states. For the
most part, mirex is resistant to biological and chemical'
degradation. Photolysis of mirex may occur, however sorption is
likely to be a more important fate process, but sorption does not
dominate. Evidence is available from the literature that mirex
can degrade into kepone in the environment. Persistent compounds
such as kepone and monohydro- and dihydro- derivatives of mirex
have been identified as products of extremely slow transformation
of mirex. Mirex bioconcentrates in aquatic organisms. It will
also adsorb to organic materials in soils and sediments and is
immobile.
Like kepone, mirex is mobile by virtue of its aliphatic
properties. Because of its solubility characteristics, it is not
readily transported as a dissolved substance in water and
probably moves through the environment dissolved in aliphatic
materials and/or adsorbed to particulate matter. Because of its
mode of application, atmospheric contamination and dissemination
are unlikely. Extensive residue surveys indicate that various
factors are instrumental in the distribution of mirex, including:
proximity to treated area, rate of decomposition, rainfall
patterns, surface runoff, duration of exposure, seasonal
population movements, avoidance behavior, trophic relationships
and other habitat considerations. Like kepone, mirex thus'
possesses chemical characteristics that lead to concentration in
nontarget terrestrial and aquatic organisms.
Mirex residues are quite persistent in various species. The
resistance to mirex degradation and metabolism leads to
environmental stability and biomagnification through terrestrial.
(including the human web) and aquatic systems. However, the fate
of mirex in the environment and the associated transfer
mechanisms have not been well defined. This situation is further
complicated by an inability to account for almost half the mirex
sold from 1962 to 1973 and in some cases, the mixing of usage
A1-1
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data for flame retardant and fire ant control programs.
Biodearadation:
Generally, mirex is resistant to attack by bacteria and fungi and
can inhibit the growth of actinomycetes, a common soil fungus.
Although mirex is taken up by microorganisms, plants and higher
animals including fish and rats, it is not metabolized. Yet
analysis of soils from spills from sites 5 and 12 years after the
accidents suggests that dechlorination takes place very slowly
and kepone is a biotransformation product of mirex. Both mirex
and kepone are highly persistent in the environment and have high
lipid:water partition coefficients so that they bioconcentrate
several thousand fold in the food chain.
Ecotoxicoloaical Profiles:
Aauatic Toxicitv: Mirex can be concentrated in fishes directly
from sediments, water or food. While photodecomposition products
(enhanced by interaction with aliphatic amines) can occur and are
presently being used to enhance decomposition in field use, the
toxicity of the resulting monohydro, dihydro and trihydro
degradation products remains unknown. In addition, certain
photodecomposition products accumulated on bait particles leached
to seawater and the organisms i~ a simulated marsh concentrated
one of the compounds in a manner similar to mirex itself.
Decompositiqn products must, therefore, be included in any
evaluation of the "disappearance" of the parent compound.
The biological significance of mirex is related to its chemical
characteristics. Modes of transfer into living systems are
important to an understanding of the impact of this insecticide
on aquatic organisms. Mirex reduces productivity of green algae.
Various species of phytoplankton can concentrate the pesticide
and thus may serve as passive agents of transfer to other
organisms. Mirex does not appear to have pronounced acute
effects on fishes in a range of concentrations found in treated
areas. However, dose-dependent secondary effects such as
bacterial infection (goldfish) and growth inhibition (bluegills,
catfish) appear to be related to mirex accumulation.
Various forms of freshwater and estuarine arthropods are
extremely sensitive to mirex, with high mortality at
concentrations as low as 0.1 ppb. Juvenile forms are often more
susceptible and larval stages of some species show adverse
sublethal reactions at concentrations as low as 0.01 ppb.
Irritability and mortality have often occurred after exposure.
This is the so-called delayed effect which is a distinctive
characteristic of mirex in a variety of aquatic species.
Although certain factors (age, size, species, physicochemical
factors, etc.) influence the form and degree of response
(including irritability, loss of equilibrium, paralysis and
Al-2
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death), mirex evidently is an effective biocide for various forms
of aquatic invertebrates. This is an important consideration in
any evaluation of the environment impact of mirex.
Bioaccumulation: Routine applications of mirex can kill various
nontarget species including oil-loving ants, spiders, beetles and
crickets. Uptake and accumulation of mirex can cause reductions
in seed germination, seedling emergence and growth in several
plant species. This would indicate more pervasive effects than
toxicity studies or residue surveys would show. Bioconcentration
factors (BCFs) are as follows: algae 12200; fish 2580; snails
4900; crayfish 16860-71400; daphnids 14650. Bioconcentration
factors after 70 days exposure to 0.038 ~g/l; grass shrimp 13100-
17400; sheepshead minnows: 28900-5000; mud crabs: 15000-18700;
hermit crabs: 44800-71100; ribbed mussels (soft tissue): 42000-
52600; American oysters, Crassostrea virainica. (soft tissue)
34200-73700.
Terrestrial Toxicitv
Mammals: Mirex is lethal as a single dose to rats. It appears
not to require metabolism in order to exert its toxicity and, in
keeping with this, toxicity does not differ significantly between
sexes. Thus it is likely that it would be similar in toxicity to
all mammals.
The subacute toxic effects most commonly observed in mammals have
included weight loss, hepatomegaly, and reproductive failure. An
important feature of its effect on the liver is the induction of
mixed function oxidase.
These effects have been observed at rather low levels of
exposure. In rats, 1.0 ppm in the diet caused induction of
cytochrome P-450 within 14 days. This is very high in comparison
to chronicity factors of 5.4 for.DDT and 12.8 for dieldrin,
indicating a highly cumulative effect.
Birds: Birds are not extremely sensitive to the acute toxic
effects of mirex. However, the relatively high levels of
residues in wild birds in the treated areas and the lack of data
about the possibility of reproductive effects of mirex on natural
populations remains a potential problem. Signs of intoxication
in mallards and pheasants from acute oral administration were
mild ataxia. withdrawal signs appeared as soon as 40 minutes
after treatment. Mirex fed to captive American kestrels, Falco
sDarverius, produced a marked decline in sperm concentration with
a slight compensatory increase in semen volume resulting in a 70%
decrease in sperm numbers. No effect on sperm motility was
observed. The survival of Hvalella azteca was reduced relative
to that of Cranaonvx Dseudocracilis during exposure to mirex in
water for a 13-day period. This was correlated to greater
bioaccumulation of mirex by Hvalella azteca than by cranaonvx
Al-3
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pseudoqracilis.
Plants: The photosynthesis of plankton is inhibited by 16, 10,
33 and 19% after exposure to 1 ppb after 5, 10, 15 and 20 days,
respectively.
KEPONE
General Properties: Kepone is the ketone analog of mirex. Like
mirex, it has easily defined physical and chemical properties and
saturated, symmetrical molecules. It does not occur in nature.
It is released into the atmosphere as a result of its manufacture
and use as an insecticide. However, its use as an insecticide
has been banned in the United states. Kepone also occurs as a
degradation product .of mixer. The presence in Kepone of a
carbonyl group in place of 2 chlorine atoms in mirex greatly
affects Kepone's solubility in water which is 2,000 times that of
mirex. It is also more reactive and volatile than mirex. Its
thermal decomposition point is about 400°C, compared to about
600°C for mirex. Technical preparations of Kepone contain 94.4%
Kepone, which 0.1% hexachlorocyclopentadiene as a minor
contaminant.
Environmental Transport and Fate: Kepone released to soil
adsorbs to the soil; however, some leaching to the groundwater
may occur especially in sandy soils with a low organic content.
Biodegradation and hydrolysis are not important fate processes,
but some evaporation may be observed from the soil surface.
Kepone released to water adsorbs to sediment and bioconcentrates
in fish but may not bioconcentrate in crustaceans or other
aquatic organisms. It does not hydrolyze or biodegrade and
direct photodegradation is not significant compared to other
processes. Evaporation from water is also not significant with
half-life of 3.8 to 46 years predicted for evaporation from a
river 1 m deep flowing at 1 m/sec with a wind velocity of 3
m/sec. Kepone released to the atmosphere will not react with
photochemically produced hydroxyl radicals or ozone and will be
subject to direct photodegradation. Kepone is sorbed to
particulate matter in the atmosphere and is subject to
gravitational settling. Exposure to kepone will occur through
the consumption of contaminated food especially contaminated fish
and seafood. Exposure may also occur in countries where its
manufacture and use as an insecticide are still permitted.
Biodeqradation: No evidence of any degradation was detected for
Kepone exposed to hydrosoils from a reservoir (not previously
exposed to kepone) and a creek (contaminated with Kepone) under
anaerobic and aerobic conditions for 56 days. No degradation'of
Kepone exposed to sewage sludge was observed under anaerobic
conditions for 120 hr. No degradation was reported for kepone
exposed to contaminated James River sediments with added
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autoclaved silty clay loam soil for 52 days at a pH of 7.0.
Biotic. Dearadation: Kepone is very stable in the environment and
is not significantly hydrolyzed. Photolysis of Kepone in the
presence of oxygen results in the formation of carbon dioxide and
hydrogen chloride. Irradiation of Kepone dihydrate with UV
light, including wave lengths less than 290 nm, caused the
formation of 2 compounds which were identical to those formed by
the irradiation of mirex.
Bioaccumulation: Kepone is relatively insoluble in freshwater
and in seawater. It leaches readily through few soils (highly
porous sands), but is adsorbed by clays and loams, especially
those with high organic content. Aquatic plant and animal
species can be highly efficient in accumulating Kepone, and it is
known that a large Kepone reserve can be found in the flesh of
fish. The ability of different species to concentrate Kepone
varies considerably, however, as a consequence of differences in
depuration rates, which can be high in such organisms as oysters
and low in some fishes. In general, Kepone is susceptible to
transfer from particulate. or food-web processes to higher trophic
levels with relatively efficient mechanisms for biological
magnification, including concentration in humans. The
bioconcentration Factors (BCFs) are as follows: PimeDhales
Dromelas (fathead minnow) 1100-2200; CVDrinodon varieaatus 1548;
Leiostomus xanthrus 1221; Palaemonetes Duaio 698; Callinectess
saDidus 8. Brevoortia tyrannus (atlantic menhaden) 2300-9750;
Menidia mendia (Atlantic silverside) 21700-60200.
soil AdsorDtion/Mobility: The percent leached through soil
cylinders 80 cm deep is: clay loam, 1.2% clay, 17.2% sandy clay
loam, 36.8%. Using a reported range of water solubility an
estimated range of Koc of 2400 to 2600 was calculated. A Koc of
this magnitude is indicative of slight chemical mobility and
leaching potential in soil.
Toxicity in Sediment: Suspended sediment includes mineral
grains, various kinds of plankton and detritus. Each phase
concentrates kepone to a different degree. Kepone concentrations
in zooplankton sometimes reach levels of 16 ~g/g (dry weight)
while phytoplankton range form nondetectable to 2.1 ~g/g. Kepone
associates with the organic portion of the bottom sediments and
inorganic grains are relatively clean. Therefore, a change in
the ratio of inorganic to organic particles has the potential to
change kepone concentrations. Benthic animals may take up kepone
directly from the sediments and pass it on to organisms that prey
on them.
Al-5
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CENTRE COUNTY KEPONE
BIBLIOGRAPHY
The abstract is based upon a search showing that kepone
(chlordecone) and mirex (dodecachloropentacylodecane) impact
several phyla. Citations also show a wide range in biological
concentrating factors (BCF) among phyla. These factors
complicate the ecological risk potential by adversely affecting
normal life stage processes. In addition, the BCF values coupled
with the longevity of the compounds (resistance to breakdown in
the environment) broaden impacts from the physiological and food
chain perspective. That is, small quantities of the biostatic
compounds carry wide-ranging implications.
citations:
Abston, A. A. & J.D. Yarbrough. 1976. The in vivo effects of
mirex on-selected hepatic enzymes in the rat. Pest. Biochem.
Phvsiol. 6:192-199.
Baker et al. 1972 Induction of hepatitis mixed function
oxidases by the insecticide, mirex. Environ. Res. 5:418-424.
Bahner, C.H. et al. 1977. Kepone bioconcentration,
accumulation, loss, and transfer through estuarine food chains.
ChesaDeake Science. 10(3): 297-303.
Bender, M.E. et al. 1977. Kepone residues in Chesapeake Bay
biota, Kepone Seminar II, Sept. 20 & 21, Easton, MD.
Boetcke, K.P. et al. 1972. Mirex and DDT residues in wildlife
and miscellaneous samples in Mice. Pesticide Moni. Jnl. 8:14-
22.
Bookhart, C.G. et al. 1979. Kepone effects on development of
Callineates saDidus and RhithoDonoDeus. USEPA 600/3-79-104.
Brewerton, H.V. & D.A. Slade. 1964.
New Zealand ~ ~ Res. 7:647ff.
Buckler, D.R. et al. 1981. Acute and chronic effects of kepone
and mirex on the fat head minnow. Trans Amer. Fish. ~
110:270-280.
Kepone residues on apples.
Butler, P.A. 1953. Pesticide-Wildlife Studies- A review of FWS
investigations during 1951-'62. U.S. FWS Circ. 1617: 11-25.
Byard et al. 1975. Biochemical changes in the lives of rats fed
mirex. Toxicol. ADD1. Pharmacal. 33:70-77.
Al-6
-------
Carlson, D.A. et al. 1976. Mirex in the environment:
degradation to Kepone and related compounds. Science.
939-941.
Its
194:
Chernoff, N. et al. 1974. Feto toxicity and cataracts genecity
of mirex in rats and mice with notes on Kepone. Env. Res. 15:
257-267.
Collins, H.L. et aI, 1973. Residues of mirex in channel catfish
and other aquatic organisms. Bull Environm. Contam. k Toxic.
10:73-7.
Commonwealth of VA., Div. of Consolo Lab. Services. 1979.
Chlordecone (Kepone) mirex in metabolites in fish and shellfish.
Tech. Proa. 3-122. Richmond, VA.
Connolly, J.P. & R. Tonelli. 1985. Modelling of Kepone in the
striped bass food chain of the James River Estuary. East. Coast.
Shelf. Sci. 20:349-356.
de la Cruz, A.A. & K.Y. Lue. 1978. General: Mirex
incorporation in estuaries animals, sediment, and water,
Mississippi Gulf Coast. Pestic. Monit. Jnl. 12(1): 4ff.
Dewitt, J.B. et al. 1961. Effects on wildlife. in: Effects of
Pesticides on fish and wildlife in 1960. U.S. FWS Circ.143:4-15.
Drifmeyer, J.E. et al 1980. Chlordecone (Kepone) accumulation on
estuarine plant detritus. Bull. Environ. Contarn. Toxica. 24:
364-368.
Eroschenko, U.P. &
gonads, liver, and
by the insecticide
504.
w.o. Wilson. 1975. Cellular changes in the
adrenal glands of Japanese quail as affected
Kepone. Toxicol. ADDI. Pharmacol. 31: 491-
Fabacher, D.C. & E. Hedgson. 1976. Induction of hepatic mixed-
function oxidase enzymes in adult and neonatal .mice by kepone and
.mirex. Toxical. ADDI. Pharmacol. 38: 71-77.
Garnas, R.L. et al. 1978. The fate and degradation of 14c -
Kepone in estuarine microorganisms. In: Kepone Proceedings II,
EPA-903/9-78-011. U.S. EPA Phila., PA. 330-362.
Good, E.E. et al. 1965.
in the laboratory mouse:
754-757.
Effects of pesticides on reproduction
I. Kepone. ~ Econ. Entomol. 58(4):
Hallet, D.J. et al. 1978. Photo mirex - synthetic assessment of
acute toxicity, tissue distribution, and mutagenicity. ~ Aaric.
Food Chern. 26(2): 388-391.
A1-7
-------
Hallister, T.A. et ale 1975. Mirex and marine unicellular
algae: accumulation, population growth, and oxygen evolution.
Bull Environm. Contam. & Toxicol. 14(6)
Hansen, D.J., et aI, 1976.
Science 193: 528.
Kepone:
hazard to aquatic organisms.
Hansen, D.J. et ale 1977. Kepone: Chronic Effects on embryo,
fry, juvenile, and adult sheep shead minnow, Cvproniton
varieaatus. Chesaoeake Science. 18:(2) 227ff.
Holcomb, C.M. & W.S. Parker. 1979. Mirex residues in eggs and
livers of the long-lived reptiles (Chrvsemvs scriota ~ Terraoene
carolina) in Miss. Bull Environ. Toxicol. 23:309-371.
Kaiser, K.L.E. 1974. Mirex: an unrecognized contaminant of
fishes from Lake ontario. Science 185: 523-525.
Kendall, R.J. et ale 1977. Residues in fish, wildlife and
estuaries. Pestic. Monit. Jnl. 11(4) 64ff.
Khera, K.E. 1975. Mirex: A Teratogenicity, dominant lethal
and tissue distribution study in rats. Food Cosmet. Toxical.
14: 25-27.
Kobylinsky, G.J. & R.J. Livingston. 1975. Movement of mirex
from sediment and uptake by hogchocker. Trinectes Maculatus Bull
of Environm. Contam. & Toxicol. 14(6)
Legget, T.A., Jr. 1979. The development of blue crabs,
Callineates sapidus, from Kepone contaminated eggs. M.S. Thesis,
College of William and Mary, Williamsburg, VA.
Lowe, J.C. et ale 1971. Effects of mirex on selected estuarine
organisms. Trans. 36th No. Amer. wildl. Nat. Res. Corp. 171-
186.
Ludke, L.J. et ale 1971. Toxicity of Mirex to crayfish,
Procambrue blandina. Bull Environ. Contam. Toxicol. 6(1): 89-
96. .
Lue, K.Y. & A.A. de la Cruz. 1978. Mirex incorporation in the
environment: toxicity in Hvdra. Bull. Environm. contamination &
Toxicoloav. 007-4861/78/0019-0412.
MacFarland, L.Z. & P.O. Lacy. 1969. Physiologic and
endocrinologic effects of the insecticide Kepone in the Japanese
Quail. Toxicol. Aool. Pharmacol. 15: 441-450.
Markin, G.P. 1981. Translocation and fate of the insecticide
mirex within a bahia grass pasture ecosystem. ~ Poll.
(Series A) 26: 227-241.
A1-8
-------
Mehendale, H.M. et ale 1973. Fate of 14c-Mirex in the rat and
plants. Bull. Environ. Contam. Toxicol. 8:200-207.
Minchew, C.D. et ale 1980. Tissue distribution of mirex in
adult crayfish (Procambarus Clerki). Bull Environm. Centam.
Toxicol. 24: 522-526.
Moseman, R.F. et al 1977. Electron capture for chromatographic
determination of kepone residues in Env. samples. Arch.
Environm. Contam. Toxicol. 6: 221-231.
Naqui, S.M. & A.A. de la Cruz. 1973. Mirex incorporation in the
environment: Residues in nontarget organisms. Pestic. Momt.
Jnl. 7: 104-111.
Nichols, F.H. 1974.
polychaete. Liminol.
Sediment turnover by a deposit-feeding
Oceano. 19: 945-950.
Ohlendorf, H.M. et ale 1981. Orgono chlorine residues 'and
mortality of herons. Pesticides Monitorinq Jnl. 14 (4) 1259.
Ordnoff, S.A. & R.R. Colwell.
estuarine microbiol. activity.
1980. Effect of Kepone on
Microb. Ecol. 6:357-368.
Provenzano, A.J. 1978. Survival, duration of larval stages and
size of post larval of grass shrimp (Palaemonetes Duqio) reared
from kepone contaminated and uncontaminated populations in
Chesapeake Bay. Estuaries: 1:239ff.
Roberts, M.H., Jr. & R.E. Bendl. 1982. Acute toxicity of Kepone
to selected freshwater fishes. Estuaries: Vol. 5 (No.3): 158-
164. .
RObinson, A.M. & J.D. Yarbrough.
administration of mirex in rats.
72.
1976. Liver responses to oral
Pest. Biochem. Phvs. 8: 65-
Schimmel, S.C. et ale Kepone Toxicity and Bioaccumulation in
Blue Crabs (Contribution No. 349. Env. Res. Lab., Gulf Breeze,
Fla.) 1979. Estuaries: Vol. 2, No.1. (Mar. 1979).
Shea, J.C. et ale 1981. Accumulation and retention of mirex by
brook trout. Bull Environm. Contam. Toxicol. 27:79-83.
smith, J.C. & F.S. Arant. 1967. Residues of kepone in milk of
cows receiving treated feed. ~ Econ. Entimol. 600(4): 925-
927.
strik, J.J.T.W.A. et ale 1980. Toxicity of photo mirex with
.special reference to porphyria, hepatic P-40, and glutathione
levels, serum enzYmes, histology, and residues in quail and rat.
Bull. Environm. Contam. Toxicol. 24: 350-355.
Al-9
-------
Togatz, M.E. et al. 1975.
selected estuarine animals..
3: 371-383.
Seasonal effects of leached mirex on
Arch. of Environ. Contam. and Tox.
u.s. EPA. 1975. Fact sheet on kepone levels found in
environmental samples from the Hopewell, VA area. Health
Effects Lab., RTP, No. Carolina.
Van Valin, C.C. et al. 1968. Some effects of mirex on two warm
water fishes. Amer. Fish Coco Trans. 97: 185-196.
Villeneuve, D.C. et al. 1979. Short-term toxicity of photo
mirex in the rat. Toxicol. Annl. Pharmacol. 47: 105-114.
Walsh, G.E. et al. 1977. Toxicity and uptake of kepone in
Marine Unicellular algae. Chesaneake Science. 18:222-223.
Walsh, G.E. et al. 1982. Toxicity and uptake of kepone in
marine unicellular algae. Chesaneake Bav Sci: 16:222-223.
Ware, G.E. & E.E. Good. 1967. Effects of insecticides on
reproduction in the laboratory mouse. II. Mirex, Telodrin, and
DDT. Toxicol. Annl. Pharmacol. 10:54-61.
Wheeler, N.B. et al. 1977. Mirex residues in non-target
organisms after application of 10-5 bait for fire ant control,
northeast Fla. 1972-74. Pestic. Monit. Jnl. 11:146-156.
Wolfe, J.C. & B.R. Narment. 1973. Accumulation of mirex
residues in selected organisms after an aerial treatment,
Mississippi 1971-72. Pesticides Monitorina Jnl. 7:112-116.
Yarbrough, J.D. et al. 1981.
monohydromirex in male rats.
58:105-117.
Comparative study of 8-
Toxicoloav and Annlied Pharmacoloav
A1-I0 .
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ATTACHMENT 2
SUPPORTING TBCBHJ:CAL DATA FOR DBVELOPKEHT
OF A 10 PPB CLEANUP CRITERIA
-------
EPA selected the following general assumptions in developing the
cleanup criteria: .
.
Reasonable assumptions for such considerations as lipid
content of worms and soil total carbon values were developed
to support the conservative approach rather than factored in
ways to give less conservative answers.
.
Endpoints were developed from tissue level studies when
available rather than gross studies that cannot be used in
developing NOAELS OR LOAELS.
.
The maximum or the 95% UCL of data was assumed, especially
when a relatively low number of samples is involved.
The conservative risk assessment approach uses additive
effects based upon the assumption that the habitat reacts as
a whole to contamination, with some receptors more'
susceptible than others, but all comprising whole.
.
.
In screening level risk assessments, a factor of 10 is used
in developing potential for risk to related species (e.g.,
bird-to-bird) and a factor of 100 for unrelated species
(e.g., fish-to-bird).
.
Levels of mirex as low as 1 ppb inhibit photosynthesis of
some phytoplankton; some soil microorganisms are adversely
affected at 0.01 mg/kg. Chronic toxicity manifested by
irritability, loss of equilibrium, hepatomegaly,
reproductive failure, paralysis, induction of mixed function
oxidase, and mortality may occur after long exposure.
An example of the application of these conservative assumptions
to the kepone exposure model for the American Robin is presented
on Table 1. The assessment demonstrates that the reasonable
worst case indicates serious potential for risk.
The risk assessment is the basis for determining the target
cleanup level for risk management and based upon the EPA Region
III screening level risk assessment approach, the cleanup level
could be extremely low. The recommended target cleanup level of
10 ppb is based on information from the RI coupled with a revised
toxicological evaluation originally presented in the risk
assessment and some compromises dictated by technology and
economics. The screening results are as follows:
. A screening level risk assessment shows a potential for
risk at 1 ppb and if the uncertainty factor of 100
(applied to protect unrelated species) were to be
factored in, a cleanup target of 0.001 ppb would be
recommended.
A2-1
-------
. The reasonable worst-case scenario shows
risk at about a factor of 10 which would
case for recommending less than 1 ppb as
number.
a potential for
still make a
a target cleanup
The above values are unreasonable from a technological and
economic perspective. The target cleanup level of 10 ppb is
based upon the judgement that the greatest amount of cleanup will
be achieved for a reasonable investment and still yield an
acceptable degree of protection. It is preferable to cleanup to
a level protective of the most sensitive receptors, but the
appropriate level of information was not provided. In such
cases, the most protective cleanup numbers that are economically
and technically feasible are recommended.
A2-2
-------
TABLE 1
KEPONE EXPOSURE MODEL FOR AMERICAN ROBIN
(KepoN! in soil JJB/1cg)(daily intake) + (upoN! in soil JJB/1cg)(soil ingestion rate) = JJB/kg/dy
(body Wt. 01 robin)
Environ's factors: 0.0087 kg/dy = daily intake
0.0008 kg/dy = incidental soil ingestion
0.078 kg = body Wt. of robin
BAP = 8.82 (eanhworm kepone BAP)
RISK TO AMERICAN ROBIN
FACTOR ENVIRON REASONABLE
WORST CASE .
Diet (LOAEL) 50 ppm 1 10 ppm2
LOAEL to NOAEL 0.2 = 10 ppm x 0.2 = 2 ppm
Uncenainty Facior (UF)
LOAEL
UP for inter-species uncertainty none 0.1
Toxicity Threshold3 1000 fJ.g/kg/dy 20 fJ.g/kg/dy
Kepone in soils (fJ.g/kg) 53 53
Eanhworm Lipid Level 0.85 1.5
(% Wet Wt.)
Soil Organic Carbon (%) 5 2.5
Eanhworm BAP 8.82 31.1
Avg. Oral Exp. (fJ.g/kg/dy) 52.7 189.3
Ratio Exposure to Threshold 0.05 9.5
Notes on assumptions:
. Lipid Content: A citation from the Environ ERA, Lawrence and Miller (1945), states the average lipid
content of earthworms is about 1.5%, a much more conservative (but not unreasonable) value.
. BAF: site-specific soil organic carbon average is reasonably estimated to be 25%, changing the BAF
from 8.82 to 31.1.
. Average oral dose: this is based upon the higher BAF.
2
From DeWitt et a1. 1962 (as used in Environ's March '94 ERA).
From McCall & Eroschenko. 1988. (Cited in Environ's Dee. 12, 1994 letter to EPA)
March 1994 ERA cited information that ring-necked pheasant fngested food equal to 10% of body
Wt. on a daily basis. Worst case assumes same for Japanese quail. study organisms used by the
McCall & Eroschenko (1988). This may be a good estimate for the American Robin as well.
3
A2-3
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~ :TITLE: Superfund record of decision: Centre County Kepone Site (0.U.1),
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