- .
TECHNICAL REPORT DATA
(P/etUe read InSll'llctions on the revene before completing) r
',. REPCHljT NO. Q/)P~ z-12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R03-83/005
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 02/11/83
Lehigh Electric Site, PA 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Renort
401 M Street, S .W. 14. SPONSORING AGENCY CODE
Washington, D.C. 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Lehigh Electric and Engineering Company site is located in Old Forge,
Pennsylvania and encompasses approximately 6.4 acres of property adjac~nt to the
Lackawanna River. Since the early 1960's the site has been used by Lehigh Electric
as an electrical equipment repair and storage yard. The hazardous conditions at
the site were created by indiscriminate handling and disposal of PCBs. The site
investigation found that PCBs are concentrated in the surface soil layers from un-
detectable to 110,000 ppm.
The cost-effective remedial action selected for the site includes excavation
and off-site disposal of soils with a PCB concentration of 50 ppm or greater;
additional soil excavation and removal where cost-effective; demolition of the
buildings on-site; backfilling, grading, and vegetating of the site to minimize
erosion and to control percolation and run-off. The estimated capital cost for
this remedial action is $6,401,000 and monitoring and maintenance costs for the
site over a 30-year period is $46,000.
17. KEY WORDS AND DOCUMENT ANAL VSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision:
Lehigh Electric Site, PA
contaminated media: soil
Key contaminants: PCBs
r
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (Tllis Repo,r) 21. NO. OF PAGES
20. SECURITY CLASS (Tllis page) 22. PRICE
Hazardous Waste Collection _ .. .r --.
Information Resource Cent~r ~ - --. - r:~A Report G@Up&~~ion
Information Rf5s[mU'c~ C@mJder
US EPA Region 3 ~O~ ~~~~~~~C~ O~~V US EPA Region 3
Philadelphia, PA 19107 10(» N
-------
FEe I I 9J3
RECORD OF DECISION
KEMEDL~L ~LTERNATIVE SELECTION
Site:
-
Lehigh Electric and Engineering Company, Inc. Old Forge,
Lackawanna County, Pennsylvania
Documents Reviewed
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the Lehigh Electric Site:
Study titled "Remedial Feasibility Report, Lehigh Electric and
Engineering Site, Old Forge, Pennsylvania", November, 1982.
Study titled "Remedial Field Investigation Report, Lehigh
Electric and Engineering Site, Old Forge, Pennsylvania",
September, 1982.
Staff summaries and recommendations
Recommendation by the Pennsylvania. Department of Environmental
Resources.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, and the National Oil and Hazardous Substances
Contingency Plan, I have determined that the excavation of contaminated
soils and debris and their transportation to an EPA ~pproved landfill
for secure burial provides an appropriate level of clean-up. The action
taken is a cost-effective remedy, and it effectively and reliably mitigates
and minimizes damage to, and provides adequate protection of public
health, welfare and the environment. I have also detenmined that the
action taken is appropriate when balanced against the need to use Trust
Fund money at other sites. In addition, the chosen remedy complies with
the requirements of Section 101(24) of CERCLA because off-site disposal
is more cost-effective than potential onsite remedies and necessary
to protect pub Ii c hea 1 th and t hi en~i ron~enQt. . f-
~chael ~. Brown
Acting Assistant Administrator
Offi ce of Sol i d Waste and Emergency Response
-------
REMEDI.~ IMPLEME~ITATION AL!ER~ATIVt SELECTION
LEHIGH ELECTRIC AND ENGINEERING SITE
OLD FORGE, LACKAW~~A COU~, PENNSYLVANIA
Record of Decision Summary Sheet
EPA has completed thLfollow1ng remedial Superfund activities at the Lehigh
Electric Site located tn Old Forge, Pennsylvania.
Activity
Date Compleced
Phase I Clean-up of Site
(equipment removal)
October, 19R2
Phase II Site Investigation ~eport
( so 1.1 remova 1 )
September, 1982
Phase II Feasibility Study Report
November, 1982
Public ~eeting
January 10, 19R3
Region III has reviewed the information in each report and has given careful
consideration to the comments received during the public comment period.
Based on our review, EPA'~ion III has determined that the following
actions at the site are cost-effective and effectively mitigate and minimize
damage to ~nd provide a~equate protection of public health, welfare, ~nd the
environment.
-
Action
Estimated Cost
Excavation and Off-Site Disposal
$5,761,000
Backfilling, Grading, and Vegetating
of Site
$190,000
$450,000
Demolition of Buildings
Tot~l
$6,41)1,000
Monitoring and maintenance costs for the site are estimated to be $46,noo
(present worth dollars) for a period of thirty years. ~
//
Date
) }
7~', .' /
Peter ~. B1bko
Regional Administrator
6 '-
- ,... , ,
FEB C ';. :~~~
.'
-
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NARRATIVE SUMMARY
Hi story
The Lehigh Electric ~n~ E~gine~ring Comp~ny S~:e, located just east of
the intersection ct Sou~r, "'.~ir. cHi': ~O\,.,o::~j ~~~eets, in Old Forge, ::>enns)lvania
encompassess appro, 'I~.: ,:: ':.. - c..;:-:s _7 -:-;~::.;~/'i.j adjac:nt :0 ~he LaC(dWanna
River (see Attacrm. '. ".;..",:L, ~ r,0r~~J" [}f d coaT
processing facili!'; I :'':'. ~.'I(..~ tne earl~' l:1t", ;:, .1;:.. .:.. "-".~"
Electric as an el€ctrical equipment repair and storage yard. The
hazardous condition existing at the site was created by the ind;sc~ill1inate
handling and disposal of d~e1~ctric fluid containing polychlorinated
biphenyls (PCBs).
The Environmental Protection Agency (EPA) was first notified of the site
in March of 1981 by an anonymous source. The Regional On-Scene Coordinator
found that elevated levels of PCB's were present in the soil (110,000ppm)
and determined that the site must be secured. In April of 1981, a
sixfoot high chain-link fence was erected around the perimeter of the
site. By June of 1981, the OSC had securp.d and assessed the site, determined
that PCB contamination did indeed exist, and that the contamination did
not migrate off-site to nearby ~esidentia1 areas. At that point, it was
decid~d that no further emergency activity was needed at the site, and
that remedial clean-up activity under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) should be
pursued.
Funding under CERCLA was authorized in Octob~r of 1981. Roy F. Weston,
Inc. was tasked to perform the site engineering work. The strategy was
to perform the clean-up in two phases, since we had ,to deal not only with'
contaminated medium (1n this case. soil). but also with the source of the
PCB contamination. .the thousands of pieces of electrical equipment on-si~e.
Phase I of the dean-up (equipment removal) was "fast-tracked". Upon
completion of the Site Investigation/Feasibility Study by Weston, the
U.S. Anmy Corps of Engineers, working under an Interagency Agreement,
assisted EPA in the design review and were responsible for assembling a
bid package and procuring the clean-up contractor. In July of 1982.
CECOS International was awarded the contract for Phase I clean-up. Removal
of all surface equipment and debris (except buildings) was completed in
October of 1982.
Current Status
The Phase II Site Investigation was performed by Weston. The objective
was to determine the degree and extent of soil contamination. Generally,
it was found that PCBs are concentrated in the surface soil layers (0 to
2 feet), with concentrations decreasing with depth. Concentrations in
the soil samples ranged from undetectable (less than 0.1 ppm) to 110,000
ppm. In general, most levels were less than 500 ppm and quickly dropped
-------
-2-
off to less than 50 ppm at increa~ing depths. The highest contamination
was found in surface soil samples. The deepest levels at which PCS
concentrations of 50 ppm are found are 10 and 15 feet below the- surface.
Analytical results of samples taken from the Lackawanna River and wells
oriiied on-site indicate that the site is not medsuraLJly illl\JCll..tllI~ U1E:~
surface or ground water.
After completion of the site investigation, work on a feasibility study
began. During the initial phase of the feasibility study, remedial
options which could be utilized for the clean-up of contaminated soil at
the Lehigh Electric site were screened, and their implementability .
determined. The options considered included~
~
o Site Management
o Site Capping
o On-Site Waste Stabilization (Chemical Destruction)
o Waste Excavation with Off-Site Disposal
o On-Site Encapsulation
o On-Site Waste Incineration
o On-Site Biodegradation of Waste
Several factors used in screening the 'options were:
o Technical Feasibility
o Cost Effectiveness
o Environmental Effectiveness
o Implementation Time Frame
As a result of the scr~ening process, the following options were excluded.
from being evaluated further (alone or in combination with other options)
in the feasibility study:
Site Capping Only - Due to the high concentrations of PCBs in the soil
(up to 110,000 ppm), the estimated quantity of PCBs on-site (27.5 tons),
and the incidence of mine subsidence in the area, the long-term integrity
of d cap system is questionable. Therforp.. it was determined that site
capping alone is not an adequate remedial measure to protect .public health.
On-Site Waste Stabilization - Chemical destruction of PCB-contaminated
s011 15 1n tne experlmental stages and is unproven technology.
On-Site Waste Incineration - There are no mobile incinerators permitted
to operate 1n PennsyTvanld. Operating costs would also be excessive making
this option not cost-effective.
On-Site Biodegradation of Waste - Although this method has been shown to
be erfectlve Tor some types of hazardous waste. it is not a proven
technology for use with pca contamination at this time.
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-3-
The remaining remedial options were evaluated i~ detail (alone'or in
combination) in the feasibility study end were used to formulate
alternative site clean-up strategies. The teasl0l '1ty stuay puoiisnea
by Weston (Attachment B) identifies dlt~rnatives for remedial
action at the Lehigh Electric Site. These alternatives and their
associated costs are presented below:
Estimated Capjtal Cost
Alternative
1. No Act ion
2. Removal to 10 ppm & Site Management
3. Removal to 10 ppm ! Site Capping
4. Removal to'SO ppm & Site Management
5. Removal to 50 ppm & Site Capping
6. Removal to 50 ppm & Encapsulation
of 10 to 50 ppm On-Site
. 7. Removal to 50 ppm with additional
excavation where cost-effective and
site management (Number 4 Modified)
(O&M costs range from ~34K to $54K for all options except "No Action",
which is 5135,000.)
$10,OOP
~7,S46,OOO
~7,72S,OOO
$6,140,000
56,284,000
Sti,44R,000
$6,401,000
Each alternative except "No Action" required as a minimum the removal
from the site of all soil with PCB concentration of 50 ppm or greater.
Further, based on the resul ts of a prel imi nary endangerment assessment,
it is determined that the "No Action" option results in upper limits of
excess cancer risk and measures of reproductive risks which are in the
ranges that generally cause concern. As a result, we have determined
that the "No Action" option is not acceptable.
Pub 1 i c Input
On January 10, 1983, a public ~eeting and a press briefing were conducted
in Old Forge, Pennsylvania to describe the various alternatives (the
alternatives 1-6 above) and to discuss the Phase II portion of the site
clean-up. During the public cQmment period which followed the meeting,
we received letters and petitions from the community demanding that we
implement the alternative calling for removal to 10 ppm with capping at
an estimated cost of $7,725,000. They insisted that the lower the concentration
level of PCBs remaining on site, the lower the risk to the community will
be in future years.
. Alternative 7 was added to the feasibility study after the public
comment period, and in response to the publi( comments.
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-4-
We believe that implementation of alternative 3 would not be cost-effective.
However, as a result of public comments, we devised a modification to
alternative 4 (Alternative 7, above) which would reduce the concentration
levels of PCBs remaining on sit~ to c;lJb~tantially belnw 50 pom for a
fraction of the cost difference between alternatives 3 and 4. The
modification includes additional soil excavation below the 50 ~pm
concentration 1~e1 when it is determined to be cost-effective.
On January 31st we met with citizen leaders of the community (the PCB
Committee) to discuss this modified a1ternati~e. They reacted positively,
and we believe that their concerns will be satisfied if this cost-effective
method for site clean-up is implemented.
Recommended Alternative
Section 300.68(j) of the National Contingency Plan (NCP) (47FR 31180,
July 16, 1982] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of the r~edia1 alternative
which the agency determines is cost-effective (i.e., the lowest cost
alternative that is technologically feasible and reliable) and which
effectively mitigates and minimizes damage to and provides adequate
protection of public health, welfare, or the environment. Based on our
evaluatio~ of the cost-effectiveness of each of the proposed alternatives,
the comments received from the public, information from the Site
Investigation and Feasibility Study Reports, and information from the
State, we developed Alternative 7 above. This alternative includes:
excavation and off-site disposal of soils with a PCB concentration of 50
ppm or greater; additional soil excavation and removal where cost.-effective
(i.e., substantial PCB removal for small incremental cost increase);
demolition of the buildings on-site; backfilling, grading, and vegetating
of the site to minimize erosion and to control percolation and run-off.
We have determined that implementation of this alternative will effectively
mitigate damage to and provide adequate protection of public health,
welfare, and the environment. .
The methodology for determining whether additonal SJil excavation is
cost-effective involves subdivision of certain grids (based upon data
from the Site Investigation Report) once removal tJ 50 ppm has been
achieved. Soil samples will be collected in the subgrids and analyzed
for PCB concentration. The Government's on-sitp. representative (i.e.
Corps of Engineers Inspector) will evaluate the results and decide whether
or not a significant amount of PCB-contaminated soil could be removed
from the site with little additional excavation and cost.
-------
-5-
The capital cost for this alternative ;s estimated to be 56.401.000.
monitoring and ~i~tenan~e costs are estimated to be 546.000 (present
worth value) for a period of thirty years. A breakdown of the caoital
costs appear in Attachment E.
The
State Input
After giving careful consideration to the cost-effectiveness of each
alternative and evaluating the public comments EPA had received. the
Pennsylvania Department of Environmental Resources recommended that we
implement an alternative (now designated as Alternative 7) calling for
removal of soil with PCB concentrations of 50 ppm or greater with
additional cost-effective excavation and site management. A letter
confi rmi ng the" State I s deci si on appears as Attachment D.
Proposed Acti on
We request your approval of the removal to 50 ppm with additional cost-
effective excavation and site management as the remedial implementation
option for the Phase II Lehigh Electric Site clean-up. In addition. we
request an allocation of $6.401.000 for the project. An allocation of
$300.000 for the preparation of the plans and specifications for the"
clean-up has already been made.
Tentative Schedule
Initiate
Complete
Initiate
Complete
Des 1 gn .
Design
Clean-up
Clean-up
February 1983
May 1983
August 1983
December 1983
If you have any questions. please call Anthony S. Bartolomeo at
(FTS)597-9100.
Attachments
-------
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COMMONWEALTH OF PE~NSYLV AN!A
DEPARn1ENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063 .
Harrisburg, Pennsylvania 17120
1= ~b~'.:a!"y 2. ! ~ g ~
(717) 787-9871
Mr. Anthony S. Bartolomeo
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, P A 19106
Dear Mr. Bartolomeo:
The Department of Environmental Resources, Bureau of Solid Waste
Mangement has completed its evaluation of the Phase II remedial action alternative
for the Lehigh Electric site contained in .the November, 1982 Remedial Feasibility
Report prepared by Roy F. Weston, Consulting Engineers.
It is our opinion, based upon the documentation contained in the
Feasibility Report and the additional data provided to DER by EPA on january 31,
1983, that the most applicable remedial clean-up option for this site is a.
modification of alternative 4. The Bureau believes that the environmental
effectiveness and technical feasibility of this modified alternative, coupled with
the long-term operation and maintenance responsibilities of the Commonwealth
provide a reliable, practical and implementable solution for the site.
The removal of the transformers, electrical equipment, and miscellaneous
wood and debris during the first phase of this project disturbed surface soils and
the original grid stakes. Because of this fact and the need to ensure that the
implementation of this clean-up alternative removes the PCB contaminated soils
to a level of 50 ppm or less, we believe alternative 4 should be .modified to include
the removal of a minim um of 6" of soil from the entire property (The Hot Area)
currently bounded by the fence. Moreover, consideration should be gi ven to the
removal of extra contaminated soils where it is cost effective, i.e., beyond the
depths specified in alternative 4 and the supporting documentation.
A quality assurance program approved by DER and EP A must be developed
and utilized by the selected clean-up contractor at this site to insure that the.
clean-up objective is met. In light of the physical location of this site, the issues
of flooding and mine subsidence must be specifically addressed in the design to be
approved by our agencies to ensure that the integrity of the alternative finally
selected is not compromised.
It should be further understood that once an alternative for the clean-up
of this site is finally selected by our respective agencies, the nature and extent of
operation and maintenance activities will be jointly agreed upon by DER and EPA
for this site.
-------
Anthnny ~. Bartolomeo
- 2-
February 2, 1983
If you have-any questions or comments on the recommended
alternative or other remarks contained in this correspondence, please do not
. hesitate to contaCt me.
BonCerelYI .
~ . /
AMES P. SNY ER, Assistant Director
Bureau of Solid Waste ~anagement
~
-------
~~
~
-.~~
COMMONWEALTH OF PENNSYLVANIA
OEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
January 31, 1983
Offic. of tI,. [Hputy ~c~tGl"Y -
£"";...,,,m.,, tal ","ot.Ctlo"
\t\r. Peter N. Bibko .
Regional Administrator
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, PAl 91 06
Dear Mr. Bibko:
This is to confirm the intent of the Pennsylvania Department of
Environmental Resources to provide for its 10% State Superfund match for Phase 2
remedial action activities at the Lehigh Electric site in Lackawanna County. It is
understood that the exact amount of funding is not precisely known at this time,
but will be determined more accurately after a final remedial action alternative
is chosen and jointly agreed upon by DER and EPA. Precise remedial action costs
and the associated 1096 State share will be agreed upon in a contract that we
anticipate executing with EPA prior to commencing remedial activities at the
Lehigh Electric Site.
I believe that the foregoing information is sufficient to indicate. this
Department's intent to assure State funding and enter a contract for the Lehigh
Electric site. If you have any questions or comments, please contact either
Dwight Worley, Chief, Division of Operations, at 717-787-7383 or James P. Snyder,
Assistant Director, Bureau of Solid Waste :v1anagement, at 717-787-9871.
Sincerely,
;{0,i.a.... / //l-~:,~'. ~"-('
WILLIAM B. MIDDENDORF
-------
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J.
Incluaes fill:.nq :...0 on-,..:e t:unnels.
NOt appliea :0 a:.sposal costs for so..ls II:ems l. 2 ana 51.
4.
5.
See Appena..x !::r det:a.:.l,
-------
,
PUBLIC COP'!P'!ENTS
During the public comment period of the
were received b~ EPA from the Mayor and
Forge and the Old-Forge PCB Committee.
approximately two hundred signatures of
Forge.
Feasibility Study Report, letters
Councilmen of the Borough of Old
A petition wdS also received with
residents from the Borough of Old
Basically, all correspondence addresses the level of ?CB concentrations
in the soil which will be left on-site. The alternatives evaluated in
the Feasibility Study were cased upon soil with PCB concentrations of
fifty parts per million and ten parts per million. The community insists
that the clean-up alternative selected be one which calls for the removal
from the site of all soils with a PCB concentration of ten parts per
million or greater.
The alternative that the Region is recQmmending is for removal of soils
from the site based on a fifty parts per million or greater PCR concen-
tration, and additional excavation and removal where it is determined to
be cost-effective.
On Monday, January 31st, a meeting with the Old Forge PCB Committee was
conduct~d to explain alternative 4 (modified). Based upon their positive
reaction, we believe "that this alternative, if chosen to be imp1emented,
will be acceptable to the PCB Committee and the community.
Copies of the correspondence are included in this attachment.
ATTACHMENT C
-------
~~ C!!mttU9 Jita!~
UND Ol8TltiCT
ROBERT J. MELLOW
300 MILLaR SUILDING
.ao SP"UC:E STREET
SC:RANTON. lOA 18503
C:O"'MITnU
A"'ItO"ItIAT10N8
IHYIItOH".NT"1. ItUOUItCU .
IN.RcaY
I.AW . ~U8T1C:. '
Ult8AN ArrA.1t8 . MOUSINca
-
~mzrl2 af Jttat9~hmnia
Janu~y 20, 1983
~. Anthonu S. B~~olomeo
Ll. S. Envi.Jtonmen:tai PJt.o.tec:.tion
Reg-<.on I II
Piu.ta.drdph.U1, PA 19106
AD p..nc. u
~ OJ
Re:
Pha.6 e T T: CleaYU.Lp
Leh-<.gh Ele~t-<.c. s-<.t:e
Old. Foltge, PA
Ve~ MJt.. 6aJLtolomeo:
A6 .th e .s.ta.te S erta.tolt Ileplle~ en,t-<.ttg La.c.,uuo:uma. Co un:ty a.nd ~ p eu -
6-i.c.a.lty the BoJt.ou.gh 06 Old. FoJt.ge a.nd a.6.teJt heaJt.-<.ng .the Jt.epo~ by my
a.6~.w.ta.nt: who a.:t:tertded the public. hea/t..{.n.g held by the EPA -Ut Old. Faltg e
an Ja.nLl.a.lud 10.th .'t.ega.'t.d.i.ng Phcwe II 05 .the c.lea.YU.Lp 06 the LeJUgh Etec.- .
.t.t-<.c. ~de. I wou.i.d we to go on ,'t.ec.OJtd a.6 ~uppoJt.t:-<.ng AUellna.te ~3 a.6
the bu.t and. po.ten:t-<.a.Uy .~a.6~.t me.thod 6 oJt. ci.eCI.YlU.p.
I agJt.ee wholehe~edly with the P.C.B. Committee a.rtd Old FOllge
BoJt.ou.gh 06 6~ that the c.on.tam.Uu:t.ted ~od ~hou.i.d be .'t.ernoved down :to
10 PP,\i Oil te.6,L In add..Uion theJte ~h.ou1..d be ,~ite c.a.pp-Utg a.i.cmg c.d:t:t
the derno.u.:t.i..on 06 on-~de bu..i..lcUngh.
I am g-<.v-<.ttg the P.C.B. Comm~tee a.nd the c.it-<.zenh06. Old FCllge
;71LJ ~~il ~ Ui=r-'a,'t.t aJ1d ~.ta;ui ,'t.ea.J.y to a.6h~6.t ,t:L~" .{.iL ,t:c.e).'/l que.~.t ~ U'~c. a
uea.ne.'t. a;1.d. env.0't.onmen:ta.ty ~a.6e c.ommu.~y.
t~
-------
BOROUGI-I OF OLD J:ORGE
TOWN ~ALL
~
3 10 SOUTH MAIN STREET
CL:i i=CRGE, ~A. - 13S18
Phon.: Ar.. Cod. 717 - 457.7441
"..._~.... -.. ....,
<.,; ""':.._-:..:
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tte !:l!:c":.-=e
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.~ f t::: =C ~Ct:.;"~ ~ t c :.::
:cr::--~ .
?~., ~:t e:- ~t ~ ~!":Ci::r
t::o ,"ublic r,e~rir'G :-.elc::' ~~: tl":~
:?:" i:-. ::~ ?or.=:e
or. ';:r.:.:.::rj" ':',
: ]23. ~e~:;.:'~~:.::~
~i:::se ':' of t::e cl:",nu'" 0: "tte :;:ost ~rossl~i cor:t~~i."'l;jteC" site on
t:: e :::a5~ ~:-::
Se~:o~r= ~o~~ ~s ~e::i~:: :lectric. ~r:c
~fter ~e~ri~~ tte
"'ro s :;r.c
cor.s 0:' t:-.e:
:;:et::ocs :"or ~uc:: cle;mu"'. :::ave cecicec that tte test ~nc "')otenti~ll? safest
,":':e't::oc:'or cle::r.u~ is ,~.:te:"!1,:te ::0. :;.
',:e -;1,0
~~r=e :h~t t::e cor.t1~i~~:~
soil si:o~:: ':e rer.:::.veC co\':r. to 10 P? ' or less.
:"0 set :le for ,:mytr.i::!!
, 0<:-
---,:)
"""'-T'!
lot , . -::... ~
ttis \':ocl,: r.ct be in t:-.e test ir.; <>rests o:t our cor.stituents.
',:e :;.re
~iv~~
"""""0 -;:'''''''~
I..r...- . .1-
~or.::7:it ~ ee
~r.c tte ~eo"'le "'~.o res::.:::e ne~r :.::e Lehi;:h
:le::.:-:.: site cur :~.:ll 5-Q.--Crt".r.~
forti: i:: tr:e er.closec letter.
"re in
co:::-lete ~~':~~~r::' :.:~t:: t~e
:""JC~5 s-:t
~-
:i~c~rel~.. .
Itf~ H 4.' p; c;, Ie.;( ~~ 1.0. i I~;: 1''('"
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--...-- -
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Just ~o there are no misunderstandinfs. we are enclosing tld s
with our Lettt:l' so you can see tor yourtielve:i that we have
el~al'ly defi ned the only method of olean up that we can acct~pt
tor thio neighborhood. .
OILY ACCEPTA.')LE CLEA~ UP 1.IETIfOIJ:
- .
ALTE1UA'fIVE jl,E1)HOO Ki. 'fHhEC: ().
ii EI.IOV AL 01-' SuI L TO 10 ppm OU LESJ Am ::.i I TE CAPP] TJ.
DEMOl.I T1 0 I Of 0 1-5l'rE IIU1 LO] ,KiS.
Clean-Up Alternatives Developed
. No Action
. Remove 5011 to 10 PPM lfc Site Managen'l' jat
'. "RemoyeS~lrt jOPPM~&~ite C~ppin{L.J
. elnove 5011 to 50 PPM & Site Managem; 11 i
. Remove 5011 to 50 PPM & Site Capping
. Remove Soli to 50 PPM & Encapsulation )t
10 to 50 PPM & Site Management. .
-------
January 11, 198)
~r. Anthony S. 3artolomeo
U.S. Environmental Protection Agency
Region III
Philadelphia, Pennsylvania 19106
Dear ~~. ~artolomeo:
We, of the PCE Committee, are writing in behalf of the residents
of Cld Forge, .Pa., whose backyards are adjacent to what EPA has
termed "the most grossly contaminat:.ed site on the eastern
seaboard"
Lehigh Electric.
After meeting with the people
of this neighborhood, who have been victimized for the past
25 years due to their 24 hour-7 day week exposure to the dreaded
hazardous toxic chemical PCB.
We have banded together and are not requesting, but demandin~,
our Constitutional Rights not be violated by EFA.
We feel
that the only safe level of PCB in the soil at Lehigh Electric
should be zero to be considered environmentally safe; but being
realistic enough to realize that this soil can never be returned
to its natural state, the only level we can accept is 10 ppm
or less.
If the accepted level to be left in the soil at
Lehigh Electric after Phase II is to be anything higher, this
neighborhood will live in fear and severe mental anguish for
the rest of our natural lives.
Since no one can actually come
forward and tell us what levels are safe and how many parts per
million are acceptable, we have conferred with the residents
and have agreed to cooperate and compromise with E?A.
',Ie hav~
-------
~r. Anthony s. ~artol~weo
U.S. Enviro~~ental Protection Agency
Page 2 .
accepted the decision of the residents that the only level ~hey
can agree upon (Knowing that this may not be safe enough) i~
10 ppm or less.
l~emove Soil to 10 ppm or less a~d Site :a?pi~g)
~lternative ~ethod 10. Three ()).
Cur chilaren's lives are at stake and their children's lives,
e~c.:
rie cannot allow this
-- if we did we would feel asha~ed a~d
h~iliated that we did aot do everything i~ our ~ower to provide
the safest enviroru:lent possible for our future senerativL1s.
:.iA
cannot give us any written guarantees acout our:uture, and we
are intelligent enou~l1 not to as~c for any. oecaus e there are :10
guara.tl tel:! s
. .,. .. . ..
':';1 ~,,'U,.s ,j,,': ~ e
but there is ~uch a thing a~
prl:!vl:!!'1tive measures. and that i::i all we are aSldng for.
i?A can only specu~ate .t~at the ciean up measure they pla~ ~u
pu~ L1t.) ~ffect
:or _ehl~h ~l=ct~~c ~~ll ~e
enviro~nd:1tallj sa:e,
: ~ t t l1a ~
:..~ a.:l
~hcj'
cal1. do
-- they ca.~10t tall :.lS what
.,.,..". ,
"'OQ.,j
ha~pe~ :0, 20, 50 or 100 years
froill :law.
."e :lust look toward the
f L1 -: \..1':- e .
0u= f.)~efathers paved the way for ~s
:,;:)r ;...,;;; ":~ lea''''e
a legClcJ .)f a pota.ltial liie of sic:~.'la:s, '.:..i.=t:.. le:-c..;t.:;
.:.nli ;.... -: l..~ =:'::l
~ea~h,;;; wo~ld ~e ludicrous.
'~h.i.s we CatL1ct a.-.'j, v,i11 .10t
c:&.~_>o"J"1 .
~: :"-:A
fee7..s
that 50 ppm ~3
a safe legacy for f~ture 6enera~i:n~,
we feel that
Z-;;" 3hol.41u
~~:e th~~ creJi~:e a~d ~ut t~eir ~elie~s
Ll ",vri tine; so that this nei~hborhood can be relieved of sOwe of
the fear and mental anguish that it is now experiencing.
.:; e
~.:el
tr1a t this is
a legiti~ate request.
If EFA refuses to Q~ this,
sO!!1e"thinB is amiss.
Anything that we believe in, we are not
afraid to commit ourselves to by putting these beliefs and facts
on paper (such as this letter).
-------
~~. Ant~ony 3. =arto:omeo
U. 5. E~vir~~ental :rotection Agency
Page J
This neighborhooc has
suffered
enough.
Remove the price tag
from our heads and allow us to return to our lives on an
almost nor~al basis again
for we can never go bac~ to the
-
heppy-go-~~c~y peo~le we once were.
~nough is e~ouch.
"/hy
does ~A insist on punisni~g us, the i~~ocent victims?
:..*'- .......
- \I c:....
though we have reached the end of our rope, we are
€'Ji:1€;
to tie
a knot and hang on.
manipulative
~ames,
','{e are through being pawns in ~A' s
and refuse to be used any longer as steppi~g
stones while E?A tries to cleanse its reputation.
I t is 'ti;i'le
for them to reverse this policy a~d use this time and energy
towards cleansing all the hazardous toxic chemicals that are
slowly destroying the people of this country.
'fie will no
lOiiScr tolerata their hurry up and wait forever policy.
The
time has now ccrne for EPA to jus~iiy its ~e
-- Environ~~~enta~
irotection Agency.
\'lords wi thOl1t results are mea.ningless.
Through what =:PA quotes as being "scientific ex?ertise", they
have set sta~dards ana deemed certain conce~tr~tions as s~fe
levels.
~ut we researched enough to know that science has not
found a."1y levels that can be. considered safe.
;ive are sure that
you are fully aware that science is a practice, no~ an art.
The burden of proof does not rest with us, but with the
E~NIRO:1r>lE:iTAL ?ROTECTIO:t AGE:tCY.
Due to the ctUnmulative nature of PCB's when considered i:'1
relation to the young ages of our children, in all logic
calculates to serious health problems that can occur after a
-------
Mr. Anthony S. Jartolomeo
u. S. ~~viro~~ental Protection Agency
Page 4
lifetime of exposure.
50 you can ~~derstand why we do not
apprec~ate ~A's speculations.
These speculations may be
considered "scientific expertise" if they were to be applied to
commodities, the money market, etc.
Even then they are still
gamolinp::
b~t to ~~ole away human lives throu;h speculatio~ --
for sha..'~e.
~PA heavily emphasizes the cradle to the grave philosophy
pertai~ing to hazardous toxic waste.
We believe this EPA saying
to mean seeing such wastes from contaminated sites safely
delivered and put into approved landfills.
Because EPA spews
cost ~ffectiveness first and .human life last, we can only assume
that they interpret this philosophy as meaning putting our
~~ildren from the cradle into the grave.
The Federal Government
spends millions of dollars to protect wildlife and animals that
they consider to oe rapidly becoming extinct.
('1'1:: ARE ALL :OOR
'rH!5) .
Yet we cannot understand their logic when they refuse
to spend an extra million dollars to keep our future generations
from becomi~g extinct.
We would be living a lie the rest of our
lives if we agreed to settle for anything more than 10 ppm or less
during Phase II of clean up at the Lehigh ~lectric Site.
~ou
can surely comprehend that we cannot, WE 'HILL JOT accept, from
an agency created to protect us, anything less than removing the
cqntaminated soil down to 10 pp~ or less.
We are justified
under the circumstances in demanding our Constitutional Rights
-------
~r. Anthony S. 3artolomeo
U.S. Environmental Protection A~ency
Page 5
and we will not allow even EPA to take these rights away
frOrt
'..ls.
Even though EPA m~J have our best interests at heart, who better
than the people that must live here the rest of our live~, shoulc
determine what is best for them.
Remember, it isn't as tho~gh
we are fortunate enough to have just visited the Lehigh Electric
Site, extend our sympat~y, and then be able to leave.
We are sure you understand the gravity of the situation, and
will do the just and proper thing by honoring our justifiable
demands.
Sincerely,
..
THE PC3 COft1!.:ITTEE
Iviarie Skutack"" ,,-... ---'- ~ \~- -:-=-'-';' ,l..,
Lucille Yager ~ ~ £
Ann !viarie Jorda v~11 ~ 4 ~
Helen Tansle "-- ~
Ruth Chipp ~ T_-(~j .
Roberta Skutack ~~ ~.jt)l)JJiI..tlLrv
r.S. Can you blame us? If you were in
fortunately you are not; wouldn't
nail to preserve human lives, and
this victimized neighborhood?
our shoes, which
you fight tooth and
echo the sentiments of
-------
~~. A~thony s. 3artolo~eo
u.s. Enviro~~ental Protection Agency
Page 6
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~:lr. Antho!'1Y s. :7.a:-tolorneo
u.s. E~vironme~tal Frotection Agency
Page 7
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U.S. ~~vironme~tal Protection Agency
Page 8
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Mr. Antho~y 3artolomeo
U.S. E~vir~~e~tal Protection Agency
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U.S. ~~vironme~tal Frotect~on Agency
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u.s. Environmental rro~ec~~on A5ency
Page 11
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'-
Oraft Risk Assessment for Lehigh ~lectric 1.0. Superfund Site
February In, 19A3
I.
I NTRODIICTI ON
-
The purpose of this document is to provide an estimate of the risk
associated with t.he pca contamination at the Lehigh Electric Co. site near
Old Forge, PA. The paper includes a discussion of the reduction in risk
likely to result from the planned remedial action.
---
The Lehigh- EI ectri c Co. ~itp. has been under study as a Sup,:arfllnd
site for more than 2 years. The- site had been used as an unshelter~d
storage location for many piecp.s of electrical equipment; e.g. transformers
and capacitors. Over a period of time, the containers were breached and
high concentrations of polychlorinat.ed biphenyls (PCRs) spilled onto the
grounti.
4'
The Agency initially erected a fence around the contaminated area
in April lq~l. Since then, action has h~en taken t.o remove pcas from
the si tee In Phase I the major pi eces of el ect.ri cal equi pnent were
removed ~nd disposed of. In Phase II the Agp.ncy obtained vertical pr.a
- concentration profiles from sample borings taken from 50' x 50' grid
sections laid out on the sit~. Further. grounr1. w.ater monitnring wells
were drilled and sampled- for pcas, and water and serliment samples from
the nearby Lackawana River were analyzerl for possible Pr,R contamination.
The Agency has now consi~ered a number of options for further remedial
work at the site. This tiocument assesses the ris~a5soc;ated with the
current situation, the "no action option", anti in a more general manner.
the risk ~ssociated with a vigorous remetiial option. -
The risk that. exists in a given situation is a function of the.
hazard(s) of the substance(s1 involved and t~e exposure to thos~ toxicants
which the target (often humans) may encounter.
Hazard
Risk
F:x posure
Therefore, this document consists of sections devoted to hazards of
pcas, likely exposure to PCBs at the Lehigh Electroc Co. site, and the
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?
anticipated riSK. While considerable information is available on the
toxicity of PCBs (i.e. hazard information), our knowledge is cer~ainly
not complete. Similarily, our knowledge of factors affecting pote~tial
exposures is also .imperfect. Consequently, it is necessary to make
certain assumctions in order to fill in these d3t~ gaps: A conscious
effort has ~een made to makp these assumptior"s ~ -: s:lch a way that t~ey
will err on the side of public safe~y. Thesp. asswl1ptions ar~ sunr.;ulZod
in tables in the s~tions that follow. NOTE: i-ny attemot tQ in't:P"r'"p::
the r~sults of thlS risk asessmp.nt witho'ij'Fd fuil anprp.t:ia~~o~ cr ~:;.~S?
assumptions would constitute a misuse of this '~fO;~2t;~t..
rT.
HAZARn rN~nRMATTON
...
Both animal expp.rimentation and human ex~erjence attest to the
toxicity of Pr,Bs~ Given the 10 different homc~ogups possibl~. many with
a large number of isomers, the problem of specifyir.g t~e t~~icity of each
cnngener is a challenge which has yet to be met, let aJon~ ~ddressing the
question of synergism which may appear in the complex mixtures we call
"PCRs". Most PC8s entp.red the environment as compo~ents of electircal
equipment coolants/dielectrics which were of generally well defined
composition; e.g. Arachlors and Kanechlors. Many of the sturlies have
been conducted with these electrical use mixtures, the most likely source
of contamination at. the Lehigh sitp.. A number of thorough reviews of
this topic hav~ been pllhlished.
A.
Human Data
The majority oi people living in the United States carry
detectable level~ of ~r.8s in their hodies. The sources Of these
substances include occupational exposure and dietary intake. The
effects of these low levels in the body are generally unknown, being
masked, if present. by exposures to a myriad of other insults and
natural processes in addition to PC~s.
In some cases, however, hig~, inadvertant exposures have resulted
i" manifest effects attrihuta~le to PCBs and/or their contaminants.
In the 19~Cs and 1970s a grou~ of Japanese and a group of Taiwanese
were independently exposed to PCRs in contaminated cooking oil. Among
the clinical symptoms which resulted were chloracne (a persistent
form of acne), eye discharges, skin discoloration. liver dysfunction,
ahdominal pain, and neurological problems. )omechildren born to
exposed mothers exhibited a temporary ski" discoloration. The exposed
populations continue to be followed to assess any chronic effects.
R.
Animal Data
Animal studies hav@ the advantage of cnntrolled exposures whic~i
permit the determination of dose-exposure relationships. A disadvantage
is that the reslJl ts obtai ned from the non-human must be extrapol ated
to the human situation.
Many PCB studi@s have been conducted using several animals species.
The effects noted are similar to those observed with a side variety
of chlorinated polycyclic aromatic substances: particularly.
-------
4
currently working with Canada to extend these studi~s, using a
colony of some AO monkeys.
The lowest on served effect level (LO~l) in these studips
is approximately 1 p~ in the dip.t or, roughly, .n5 J1Ig/kg-d.
Oua~Hative risk extrapolation is not usually performed
with data on reproductive effects. Rather, a measure of the
risk involved is presented as a ratio between the LOEL (in this
case) and the estimated exposure.
I I!. EXPOSURE
No matt~r how hazardous a substance might be, if it never comes into
contact with people, the human health risk will he zero. Thprefore, the
extent of the health risk posed by the PCBs at the Lehigh F.lectric Ce.
site depends on tMe extent to which people come into contact with them;
i.e. the exposure.
Because it is not possible to foresee all possible eventualities
that might result in exposure to the Lehigh Flectric P~~s, two separate
scenarios will be presented to indicate reasonable levp.15 of exposure
for the "no action" option. The first of these scenarios is built on
relatively high exposure, low probability assumptions. This scenario
might be ~eferred to as "plausible, worst case". A second senario is
hased on more modn.rate exposures and is ~ore likely to reprpsent a real
situation at the site. . .
Both scenarios make use of the dat.a collected at the site hy EPA
and/or its contractor.
The section closes with a discussion of anticipat.ed exposure after
remedial work.
A.
The Oata
After removal of the electrical equi~ment from the site during
Phase I of the cleanup, the Agency ohtained bore samplings from each
grid. Bore samples were ta~en down to a depth at which the PCB
concentration fell below 10 ppm. A conscious effort was marle to
drill at points on the sections which arp most visually contaminated.
Positive values of pca residues were found in the sediment.s of
the nearby Lackawana River. This contamination could have resulted
from erosion of contaminated soil from the elpvated site.
Calculations based upon these data suggest that t.he magnitude
of PCBs in the contaminated area is 2S,nor~g.
The point of highest concentration of pr.Ss in the soil on the
surface was measured at 11("1,11011 ppm (or ll~, PC~s). The averaqe
concentration of prRs on the surface of the sp.ctions which wer~ found
to bp contam;nated at levels in excess of ~n ppm was calculated to
be approximately ~700 ppm.
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5
B.
Exposure Scenarios Under "No Action" t1ption
Although the area is :urrently fencp.d, the boundary clearlY has
been breached on more than onp. occasion. In the following sc~~arios
~:-:~ ..~:);;:::;;ti~r: i~"~~~~ that people can contact r"~ co"t:a!"!;"a't:~~ :0il
for 1 hr/d for 180d/yr (to account for ice and snow cover in winter,
aperiodic ac,=eys to the site, etc.).
The possible routes of exposure which mllst be considered ar~
ingestive, dermal absorntion, anli inhalation. Tables I & II layout
the "assumptions uset1 in t~e two scenarios. Table III lays out
additional assumptions which are common "to both scenarios.
TAf\LF I
Assumptions for P1ausi~le Worst Case
Ingestion ~ssumptions
, 9 soil daily for
.5g so; 1 da i 1 y for
.1g soil daily for
in the ~rp.a)
10n~ of pr,Ss on soil are bio10qica11y
3 years (child'
7 years (youngster)
10 years (adult -- less likely to be
available
Oe~a1 Assumptions
19 soil on skin daily for ?O years in a lifetime
1nr, of PC~s penetrate skin
Inhalation Assumptions
"Rrp.athing rate wnile in the area 2Om3/d
~ust level in the ~ir is 100 micrograms/m3; at ambient air standard
of 75 micrograms/m3
All particles can be inhaled
All partic1es inhaled are retained
All PCBs on retained particles hecomp. biologically availa~le
TARLE I I
Assumptions for More Likely 5cenario
Ingestion Assumptions
.1g dany for 20 years in a lifetime
lOO~ of PCSs on soil are biologically available
Dermal A~sumptions
.1g soil on skin daily for 20 years in a lifetime
l~ of PCBs penetrate skin
Inhalation Assumption
Same as Table I
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"
TABU: III
Other Assumptions i.ommon to Both Scenarios
70kg per person ("Fine tuning" the wf!ight over! lifetime is assumed to
have a negligible effect on the significance of the data)
Ihr exposure per day-for 182 days per year
In adc1ition to ti'tese dirF'ct p.xposures to ~umans, t:~ere p.xists the
possihility of indirect exposurf!s vi~ conta~inatp.d wild ga~p., fish,
vegetation, etc. The extent 0' this exposure cannot be evaluated at this
point due t~ lack of information on fish harvesting from the river, PCB
levels in game, the potential for the site to serve as a current or
future source of vegetation that would eventually reach humans, ~tc.
The reader should be aware that. a potential for ac1ditional exposure may
exist via t.hesp. inc!l;rect rOlltes. although they are not expect.ed tn be
as large as that from direct routes.
-------
7
CALCULATIONS
Plausible Worst Case
Ingestion
Lifetime Daily Dose = 19 soil x (Cone. PCB in soil) x (182/365) 1yrs/7~yrs
da1 ly
- -
+ .5g soil x (Cone. PCB in soil) x (181' nli~) 7yrs!7nyrs
rlay
+ .1g soil x (Cone. PC:8 in so i 1) x (lA?/l" 5) lOyrs/?nyrs
day
.
70kg
.
(1000 mg soil x 1 x 3) + (500 mg soil x 1 x 1) + (100 mg soil x 1 x 1~1
d 2- 70- d 2- 10- .d ?- 7-_1
.
Cone. PCR ~ 70kg
= 21 mg soil + 25 mg soil + 7 mg soil J (Cone.' PCB)/70kg
d d d
. .
= .75 (Cone. PCB) mg PCB'
kg-d
Where r.one. PCB is expressed in units of mg PCB
mg. s011
Denna 1
Lifetime naily Dose. Ion mg soil x (Cone. prR in soil) x 182d x 2nvr x 10~
3m 7'OYr
70kg
. .2 (r.one. PCB) mg PCB
kg-d
Where Cone. PCB is expressed in units of mg PCB
mg 5011
Inha lat ion
Lifetime naily Dose. 2n m3 x Ihr x d x 182d x 20yrs x 100mg soil x Cone. PCB
d d' 24hr md 7nyrs mJ
70\l:g
= .0002 (Cone. PCR) mg PCB/k-d
Where cone. PCB is expressed in units of mg PCR
mg soi 1
-------
8
Note that the inhalation dose is negligible compared to th~ ingestion or
dermal routes. Therefore, thp eombin~d dose is essenti~lly:
Total Lifetime Dose = .9~ (Cone. of PCB' mg PCB
1""" ,..
I'~-'"
(1)
-
Where i.onc. PCB is expresed in units of mg Pi.B
mg so i 1
More likely scenario
Ingestion
Lifetimp Daily nose = lon mg soil x (Cone. Pr.H in soil) x l82d x 20yrs/70kg
d --~ 70yrs
= .7. (Cone. pi.a) mg PCB
kg-d
[1enna 1
Lifetime n~ily nose = lon mg soil x Cone. PCB in soi~ x l82d x 2nyrs x l~
d -md 70yrs
7nkg
= .n? (Conc. rCB) m, PCB
g-d .
Inhalation
Same as plausible worst case: still negligible.
rherefore, the total lifetime daily rlose = .?? (ronc. prB) mg Pi.R
kg-d
(2)
Where Conc. PCB is expressed a~ mg PCB
mg so 1 1
C.
Exposure After Remedial Work
The planned remedial option involves excavating down to a level of
from one to 14 feet until the PCR concentration in the rp.maininq
contaminated soil is somewhere between 10 and ~O ppm. The estimated
amount of PCBs whi ch wi 11 be removed is ?7 tons. Thi s impl i es that about
9A~ of the original amount will remain.
The excavation will then he backfilled with PCR free dirt.
Subsequently, the entire lot (excavated and non-excavated) will be covered
with 6~ of fresh soil and seeded.
Once this remedial work is completed, the surface concentrations of
PC~s from the site will be essentially zero, and hence the risk from
rlirect. exposure will also be essentially zero. .
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9
Tne possibility of movement of any remaining PC8s through the ground
water is not considered likely, given the relatively strong binding
properties of PCBs to soil, in relation to their rp.latively low solubilities
in wat er .
It is conc~ivable that over time, PCBs could co-vaporize with water
in thp. soil and ri~e to thp. surface. This;s likely to he a very slow
process and, given tne low ~mount of PCBs remai~ing in thp. soil at the
excavated rleoths and the fact that PCBs would vaporize and ~ove off-site
at very low concentrations, it is ~ot thought that PCRs would ~ver again
be present at the surface in conce<1::rations that w01Jl1 he of concern.
IV.
RISK
As mp.ntionea above, the CAG of ~PA has detpnminerl an upper limit to
thp. excess risk from cancer due to PCBs to be the lifetime Daily Dose.
IIpper 1 im;t of Cancp.r Ri sic = 4.35 (mg/kq-d) -1 (ti fet ime Daily
Dose) . ~
( 3 )
Where Lifetime nailv Dose is expressed in limits of mg/kg-d.
This relationship holds at low doses. At higher doses where the
dose-response function is suhlinp.ar, the p.quation over-estimates the
upper limit of the risk. Given the coarseness in the rest of the riSK
assessmp.nt presented here, however, the non-linear corrp.ction has not
-' been marle in .this paper.. The effect of this is to introduce another
conservative assumption.
Figure I illustratp.s the upper limit of the excess cancer riSK of
- both the plausible worst cas~ scenario anrl the more likely scenario ~s a
function of concentrations of PCBs in the soil. The vertic1p. lines at
1111,000 ppn and 3700 ppm represent., respectively, the dose at the "hottest"
spot found and the average of the dosp.s at p.ach of the .grid sections
which showed concentrat.ions of Pr.Rs in excess of snppm.
Note that the ordinatp. also displays values for the rat.io (CR)
of the LOEL to the anticipated dose. The greater the value of the ratio,
the greater is one's confidence that the exposures are not significant
from a direct human health perspectiv~.
For the plausible worst case scenario, therefore, we have [using eg
(1) i n eg (3) J
!tpper limit of excess cancer risk = 4.3~ x .Q5 x ronc. PCB (4)
. 4.1 x Conc. pcr
in
Similarly, for the more liKely scenario, we have [using eQ. (2)
eg (3)J:
Upper limit of excess e~ncp.r risk. 4.35 x .22 x Conc. PCB
= .9~ x Cone. peR
(5)
-------
(10)
v.
DISCUSSION
Figure I illustrates that, within the hounds of the approximations
us@d in this paper, eAjjOS\.ii"e~ :"'a:w1~~r.; f~~ t~e "~1~:':$~b1e wa~51; ':!5!"
and the "more like1y stenario" give upper 1imits of ~xcess cancer risk
and measures of r~production risks which are in the ranges that generally
ca'Jse 'oncer"'. "'hrs"'is true for both the highest points of cot1tamination
(11n,Ono p~~) ar.d t~e averag@dconcentration (3,700 ppm).
~~~" I th~t ~he :ancer estimat~s have not been correc!ea :or non.
.,,;,,,._,, -'. .' . "..,.,j fokQ"l!for~, are overestimates to some
der;r~e. "'hesp. corr~ctiC)ns ar"~ no: : I <..e:;J '.w ,-..;":'.,;:," ~k,? uDper limit
estimates to levels which will no longer be 0' concern. Thus, is
oarticularly true of the llO,OOo.ppm contiimination level.
In any event, t.he measures of reproduction risk, the C~ values,
do not need to be corrected and, quite independently, they convey the
same information: the "no action" option results in exposures which
~re of some concern. Generally, one would like to see CR values in
excess 0' IOn or 1,000. The "no action" option results in CR values
in the less than 1 to 100 range.
In sum, if t~e direct exposure scenario assumptions summarized in
Tables I . tIt are accepted, the "no action" option is associated with
'risks of concern. '
As stated above, the proposed rp.medial action will reduce surface
concentrations to effectively zero. Hence, the risk from direct exposure
will also be effectively zero. We have noted that there is some possibility
for indirect exposures and, possibly, finite direct exposurp.s over.time.
For reasons cited in Section III C, however, these exposures (and hence
the risks) are not likely to be significant.
vt.
CONCLUSION
The proposed remedial action will markedly reduce most (perhaps
all) of the risk, which is of likely concern at the Lehig~ Elp.ctric Sitp..
-------
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