United States >
Environmental Protection--
Agency
Office of
Emergency and
: Remedial Response
E PA/ROD/R03-89/049
September 1989
®EPA
Superfund
Record of Decision
Henderson Road, PA
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50272-101
-REPOET DOCjUMENTATION 11. REPORTNO. 1 2.
~.PAGE . EPA/ROD/R03-89/049
3. RecIpient. Acc8uIon No.
..
4. lille 8nd Sub1i1I8
SUPERFUND RECORD OF DECISION
1enderson Road, PA
Second Remedial Action - Final
7. Author(.)
50 Report Date
09/29/89
8.
a. FWfonnlng Organization Rept. No.
.
9. Perfonnlng Orgalnlzation N8me 8nd Addre88
10. ProjectfTulllWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. SpoMorIng Organlutlon N8m8 8nd Addntu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . PerIod Covered
Agency
800/000
14.
15. Supplemenl8ly NoI88
1&. Ab8tract (Umlt: 200 _Ida)
The Henderson Road site is a 7.6-acre site in Upper Merion Township, Pennsylvania.
O'Hara Sanitation Company, Inc. has used the site for waste storage, waste recycling,
vehicle maintenance, and parking and office facilities since 1974. The area surrounding
the site is zoned for industrial and residential use. The site is bounded by the
Pennsylvania Turnpike, the Conrail property including train tracks, Henderson Road, and
19 Run. The Upper Merion Reservoir, located 2,000 feet upgradient of the site, serves
part of the water source for approximately 228,000 people. Prior to 1974 the site
was operated by the Ellis Concrete Company as a concrete preparation plant. During. this
operation cinders may have been placed on the western portion of the site and on
adjacent railroad property. In 1974 William J. O'Hara, Inc. began landfilling trash and
construction debris on central and eastern portions of the site until 1984. Between
1974 and 1977 William J. O'Hara, Inc. alledgedly injected industrial waste into a
160-foot onsite well. Furthermore, liquid waste, sludge, and drums may have been
disposed of in the landfill. The first operable unit for this site, as described in a
June 1988 Record of Decision, included pumping and treatment, using air strippers, of
contaminated ground water. This will be accompanied by additional characterization of
the injection well, exavation of oil pit sediment if found, removal of significant waste
within the well if feasible, institutional controls, further characterization of
~rlrl1 .. rlnn nnc::::>t-n ~ .. 'ZonF!~ nnc::c::; hl" (''Ii re>I"'t- nl1e>rI on next Dacre)
17. Document Analysia L De8criptora
Record of Decision - Henderson Road, PA
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE, PCE, toluene), organics (PARs)
b. IdentifleralOpen-EncIed Tent18
.Co COSA T1 AeId1G,GUp
vailabiUty Statement
19. SecurIty Ct... (Thla Report)
None
20. SecurIty Ct- (Thla Page)
None
21. No. of Pagea
12~
22. Price
(See ANSl-Z39.18)
See tMtructi- on ~-
-.
272 (4-77)
(FonneI1y NTlS-35)
~ntofConunerce
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. .. .
EPA/R~D/~03-89/049
Henderson Road, PA
c
'.
Abstract (continued)
treatment in the unsaturated zone, monitoring, and periodic evaluation of cleanup goals.
The second operable unit addresses all surface sources of contamination at the site. The
primary contaminants of concern affecting the soil and ground water are VOCs including
benzene, toluene, PCE, and TCE; and other organics including PAHs. The predominant
carcinogenic risk for the landfill operable unit (LOU) is based on the prediction of.
movement of leachate to groundwater. Of the 19 chemicals of concern identified for the
LOU, bis (2-chloroethyl) ether and six volatiles are considered by EPA to pose the
greatest threat to ground water. Other routes of exposure include those from ingestion
of soil and inhalation of fugative emissions.
The selected remedial action for this operable unit includes installation of erosion
controls; regrading and capping, including possibly moving the onsite watermain; .
installing a short- and long-term leachate collection system with treatment and discharge
to be determined during design; excavation and onsite consolidation of trash, soil, and
cinder currently located at the adjacent Turnpike property with appropriate remediation
of wastes left in place at the Turnpike property; further sample collection and data
evaluation in the western portion of the site leading to a determination regarding
treatment and/or capping in that area, and contingent ground water recovery; monitoring
of ground water and leachate; and. institutional controls. The estimated present worth
cost for this remedial action is $7,265,000, which includes an annual O&M cost of .
$213,260.
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REOORD OF. DECISIOO
DECIARATION .
SITE. NAME AND LOCATION
Hemerson Road NPL site
362-372 SOUth Hemerson Road
Upper Merion Township, pennsylvania
STATEMENT OF BASIS AND PURFCSE
'tt1is . decision document presents the selected remedial action for the
HemersonRoad NPL Site ("the site") Larrlfill ~rable Unit in Upper Merion
Township. 'tt1e selected remedial act ion has been developed in accordanCe with
the Canprehensive Environnental Response an::i Liability Act of 1980, as cmemed
by the superfurXi Amen::iments am Reauthorizatior ~ct of 1976, arxi, to the
extent pract icable, the National Contin;;Jency Plan. 'tt1e attached iooex (Exhibit
1) identifies the items which comprise the administrative record upon which
the selection of the remedial action is based.
'tt1e Carmonwealth of pennsylvania has concurred on the selected remedy.
ASSESSMENr OF 'mE SITE
Actual or threatened releases of hazardoos substances fran this cperable
unit, if oot addressed by implementin;;J the response action selected in this
IDD, may present an iltminent arxi substantial eman;;Jennent to public health,
welfare, or the environnent.. ..
DESCRIPrION OF THE SELECTED REMEDY
'tt1is cperable unit is the secord of two cperable units that address,
contcmination at the site. 'l1'1is cperable unit, the Lamfill ~erable unit,
addresses soils, surface water, air, arxi groum water potentially impacted by
previoos lan::ifillin;;J, surface placanent, am pcssible trenchin;;J on-site, in
addition to potential leakage fran on-site umergrouoo storage tanks. 'the
first Operable unit, the Injection Well ~erable unit, addresses grouoo water
contamination caused by injection of hazardous substances into an on-site
well prior to 1977 an:i the risks associated with exposure to groum water
contaninated fran that well.
,
'l1'1e major canponents of the selected remedy for the Lan:lfill ~rable
unit include: .
run-on, run-off, arxi erosion controls
short arxi lorq-tenn leachate collection
cappin;;J CNer the lamfill, includin;;J roovin;;J the on-site water main
unless. a means of maint~ininJ the water line on-site arxi ajdressin;;J
remedial oojectives arxi State ARARs is designed
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. groom water recovery am treatment if, after two years of pumpiOJ
groom water beneath the site for the Injection Well cperable Unit,
site-related groom water contamination is detected or" near at t."1e
property line am groord water is still leaviOJ the site .
rrovanent to the Hemerson Road site of trash, shallow soils ard shallow
cirder fill fran the Pennsylvania. Turnpike prcperty c:wjjacent to the
site, c:wjditional characterization of the Turnpike prcperty, ard appr<>-
priate remediation to address wastes, contaminated soil am bedrock
left in place, if any, ani leachate .
monitoring in coordination with the Injection Well Operable unit
institutional controls on-site am on adjacent properties to restrict
activities that woold interfere with remediation at the site
further sample collection am data evaluation in the western pOrtion
of the site, in coordination with the Injection Well Operable unit,
leading to a determination whether to pilot test for, am possibly,
carmence in-situ volatilization or other treatment ani/or cappiOJ in
that area .
pericdic reevaluation of clean-up goals throughoot cperation ard main-
tenance, in coordination with the Injection Well cper-able unit.
STATUroRY DETERMINATIOOS
'!he selected remedy is protective of human health am the envirorment,
complies with Federal am State requirements that are legally applicable or
relevant ani apprq>riate to this remedial action, ani is cost-effective.
'!his remedy satisfies the statutory preference for medies that anploy
treatment that reduces toxicity ,md:>i1ity or volume as a principal elanent.
ani utilizes permanent solutions am alternative treatment technologies to
the maximlln extent practicable. However, treatment of larxifilled wastes ard
contaminated soils in the central an::l eastern portions ~f the site was oot
foom to be practicable, so that this remedy does oot satisfy the statutory
preference for treatment as a principal elanent of the remedy.
'!he selected remedy may result in hazardous .substances remaining on-site
above health-based levels. '!herefore, a review will be corducted within five
years after carmencement of the remedial action an::l every five years thereafter,
thI"CAJghoot cperation an::l maintenance. '!his review will be coroucted in
consonance with the five-year review for the Injection Well cperable unit to
evaluate whether technologies implemented provide c:wjequate protection of
human health an::l the envirorment, whether additional treatment is apprq>riate,
whether prcqress is. being made in meeting clean-up goals, an::l whether clean-up
goals shoold be rev ised.
~30~-~
n 8. Erlckson
Regional Administrator
4/aCJ/tj..
I .,
Date
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groorrl water recCNerj anj treatment if, after two years. of pumpi~
grouoo water beneath the site for the Injection Well q>erable unit,
sit~related groorrl water contamination is detected or near at the
property line anj groond water is still leavi.~ the site
rrovement to the Henderson Road site of trash, shallow soils anj shallow
cinder fill fran the Pennsylvania 1\Jrnpike property crljacent to the
site, additional characterization of the 1\Jrnpike property, anj appro-
priate remediation to addreSs wastes, contaminated soil an::i bedrock
left in place, if any, and leachate
monitori~ in coordination with the Injection Well q>erable Unit
institutional controls on-site an::i on adjacent properties to restrict
activities that woold interfere with remediation at the site
further sample collection and data evaluation in the western portion
of the site, in coordination with the Injection Well .cperable Unit,
leadi~ to a detetmination whether to pilot test for, anj possibly,
carmence in-situ volatilization or other treatment an::i/or cappi~ in
that area .
pericrlic reevaluation of clean-up goals throoghOlt q;>eration ard main-
tenance, in coordination with the Injection Well q>erable Unit.
STA'IUI'ORY DE'I'ERMINATIOOS
'!he selected remedy is protective of human health an::i the environnent,
canplies with Federal and State requirements that are legally applicable or
relevant and appropriate to this remedial action, and is cost-effective.
'!his remedy satisfies the statutorj preference for remedies that enploy
treatment that reduces toxicity, rnct>ility or volume as a principal element
anj utilizes petmanent solutions arrl alternative treatment technolo;ies to
the maximl.Jn extent practicable. However, treatment of laoofilled wastes arrl
contaminated soils in the central am eastern portions of the site was rot
foorrl to be practicable, so that this remedy does oot satisfy the statutory
preference for treatment as a principal elenent of the -.nedy.
'!he selected remedy may result in hazardous substances remainirQ on-site
above health-based levels. Therefore, a review will be corrlucted within five
years. after o:mnencenent of the ranedial action anj everj five years thereafter,
throoghoot operation am maintenance. 1his review will be conducted in
consonaoce with the five-year review for the Injection Well cperable Unit to
evaluate whether technologies implenented provide adequate protection of
human health arrl the environnent., whether additional treatment is appropriate,
whether prO"Jress is beirg made in meeti~ clean-up goals, am whether clean-up
goals shoold be revised. .
e:1win 8. Erickson
Regional Administrator
Date
CONCURUHCES
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TABrE OF CDN1'ENI'S
HENDERSOO roAb tANDFILL OPERABLE UNIT
DECI.SICN. SUr-t1ARY
I. SITE NAME, LOCATION, AND DESCRIPTICN
II. SITE HISTORY AND ENFORCEMENT AC!IVITIES
III. m1MUNITY RELATIONS HISTORY
rv. SCOPE AND roLE m" OPERABrE UNIT AND RESPaJSE ACTION
V.. SITE CHARACI'ERISTICS
A. Fill Material ~ Tanks, aOO Leachate in LOu
B. Data Collected in WJ Remedial Investigation
C. potential Routes of Migration fran Ia.J Sources anj
Groooo Water Fate-am-Transport Assessment .
D. Results aoo Conclusions fran IvnJ Remedial Investigation
VI.
LOO RISKS
A. Human Exposure pathways
B. I.aJ Human Health Risk Assessment
C. I.aJ ard :M:U: Canparison of Human Heal th Risk Assessments
D. Envirormental Risks
VII.
DESCRIPTION OF 'mE ALTERNATNES
A. Remedial Cbjectives
B. Surrmary of Alternatives
VI II. SUr+1ARY OF miPARATIVE ANALYSIS OF ALTERNATNES
IX. THE SELEC!ED REMEDY .
A. Sumnary of Major Factors aOO Criteria Associated with
Selected Remedy
B. Anticipated ChcmJes am Decisions to be Made D..1rinJ lID/FA
C. Risk Level to be Attai ned
D. Point of Canpliaoce
,
X.
STA1Ul'ORY DETERMINATIONS
A. oetennination of ErdanJerment
B. Protection of Human Health ard the Envirorment
C. Attainnent of ARARs
D. Cost Effectiveness
E. utilization of Pennanent Solutions FmployinJ Alternative
Technologies to the Maxim1.lY\ Extent Practicable
F. Preference for Treatment as a principal Element
XI.
OOCUMENTATION OF SIGNIFICANT ~ES
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RECORD OF D~ISION
. DEX::ISION SlM-1ARY
I. SITE NAME, LOCATICN, AND DESCRIPI'ION
!he Hen:lerson Road NPL Site ("the site") consists of 7.6 acres located
at 362-372 South Hen:lerson Road in Upper Merion Township, in sootheastern
Pennsylvania (see Exhibit 2). O'Hara Sanitation Canpany, Inc. occupies the
site with several small businesses. O'Hara Sanitation Canpany presently.
uses the site for waste storage, waste recycling, vehicle maintenance arrl
parking, am office facilities.. .
!he site is boumed on the oorth by the Pennsylvania Turnpike ("the
Turnpike"), to the east by the Southeastern Pennsylvania Transportation
Authority Norristown High-Speed Line right-of-way am including a stream
bed, on the sooth by property owned by Consolidated. Rail Corporation
("Conrail") am including railroad tracks, to the west by South Heooerson
Road, am on the oorthwest by Chester Valley Railroad tracks, owned by .
Conrail. Prq;>erty directly oorthwest of the Chester Val.ley Railroad tracks
also is owned by the Pennsylvania Turnpike Camlission. Lam in the vicin-
ity of the site is zoned for light in:lustrial, heavy imustrial, aoo
residential use (see Exhibit 3).
'l11e site is approximately 2000 feet sooth am upgradient of the Upper.
Merion Reservoir ("UMR"), a fomer limestone quarry. Philadelphia Suburban
Water Canpany ~ ("P5\'l:II) groom water in UMR at a rate of 7.5 million
gallons a ciay.as one of several sources of water serving PSWC' s 228,000
custaners. !his pumping has lowered the grourrl water at the site to about
120 to 160 feet below the surface.
!he population within 1,500 feet of the site consists mainly of an-
ployees of businesses that surroorrl the site. Within o~ mile of the site
the total estimated residential population is 5,000. '!he nearest residen-
tial dwelling is 560 feet soothwest of site. '!he nearest school is 3,000
feet sooth of the site.
!he site is located in the Chester Valley, an east-west trerrling sut>-
division of the Piedmont Uplarrls. '!he Chester Valley contains highly folded
dolanite am limestone rocks which dip to the sooth-soothwest. Bedrock is
encountered on-site at depths of 34 am 46 feet. Sinkholes are carmon in the
Chester Valley, including the area of the site, due to dissolution an:} subse-
quent collapse of the dolanite a.rrl limestone bedrock.
'!he piedmont Uplar:rls is dlaracterized by mature, dissected rolling hills.
On-site tq>ography has changed extensively since the 1970' s, due to gradi~
aoo regradi~ associated with c.perations. At present, the higheSt on-site
elevation is in the oorthwest corner, approximately 190 feet above sea level.
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2
The stream bed located at the eciSt eoo of the site is the lowest on-site
point of elevation, at approximately 126 feet above sea level. Lard surfaces
slope toward the central portion of the site fran the north, sooth, west,
aoo east., at slopes of approximately two percent. At the extreme east of
the. site, lard surfaces slope at approximately eight percent and increase to
40 percent toward the stream bed. A level area at an elevation of approx-
imately 160 feet lies in the northern and western portions of the site (see
Exhibit 4). A corrugated metal storm sewer line presently runs through the
sooth erd of the site am empties into the stream bed. A 36-inch water
transmission main, owned by PS\VC, is situated alorg the eastern portion of
the site parallel to the stream bed~ A ponded area used to occupy the sooth
central portion of the site. Much of the western portion of the site is
paved at present.
. UMR is one of two primary surface water bcxHes in the vicinity of the
site. However, no surface water bcdy empties into UMR. 'Ibe second major
surface water body associated with the site is the adjacent stream, Frog Run,
which is intermittent. 'Ibis stream receives ruooff fran the entire site
sooth and east of the railroad spur in the northwest corner of the site and
a small area west of the site alorg Harderson Road (see Exhibit S). '!he
stream alternates between gainirg and losirg reaches until it ultimately
discharges to the Schuylkill River.
Frog Run is dry except durirg ard iITmediately after stormwat~r run-
off events. 'Ibe stream has no Carmonwealth of pennsylvania classification.
Since the Schuylkill River is classified as a cold water fisheries stream,
Fr~ Run woold be classified as a cold water fisheries stream. The stream
bed is class if ied as oots ide the SOO-year floOO bourrlary.
No species of special concern or exemplary natural carmunities exist in
in the vicinity of the site as detecnined by the Pennsylvania Natural Diversity
Inventory. No erdargered reptiles or am~tdbians are expected to inhabit the
area. No designated wetlarrls occur in the vicinity of ~e site.
'!he cquifer beneath the site and fran which Ul-1R draws water meets the
requirements of a Class IIA Aquifer, defined urrler the EPA Grourrl Water
protection Progrcn as a current soorce of drinkirg water. Accordirg to the
Groorrl Water Protection. Pt'aJrcrn, Class II groorrl water shoold "achieve the
selected clean-up level throughoot the area of attainnent within the shortest
time technically feasible."
. Groorrl water pumpi~ at UMR draws down water fran an approximate area
of 2.4 square miles, whiCh includes the site arrl groorrl water that is irrluced
to flow fran the bed of the Schuylkill River. Grourd water arrl associated
contcrninants are expected to ultimately flow fran the site to the UMR via
fractures and related solution features in a direction which predominantly
follows strike but also has. a oortherly component.
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3
prior to..1974, the site was operated by Ellis Concrete Canpany as a .
concrete preparation plant. Ciooers may have been placed on the western am
central portions of the site durirq the' time that Ellis Concrete c:perated
.there ard/or later, by William J. O'Hara, Inc. Also, a railroad spur once
ran through the eastern portion of the site. '!his spur am the adjacent
Conrail tracks may have been built on cinders which contain hazardous
substances.
In 1974 the site was purchased by principals of WilliCln J. O'Hara, Inc.
William J. O'Hara, Inc. lan::1filled trash an::1 construction debris on the
central am eastern portions of the site am on the adjacent Conrail and 1\lrn-
pike properties through 1984. O'Hara also may have disposed liquid waste,
sludge am drums in the lan::1fill am placed cirrlers on-site. Between 1974
arrl 1977, O'Hara injected imustrial waste into a 160-foot well (the "in-
jection well") inside the gar~e located on western portion of the property
(See Exhibit 4).
At preSent, the principal site owner is Betty O'Hara, Trustee. O'Hara
sanitation Canpanyc:perates the site as a truckyard and waste transfer
facility. An auto repair am drillirq canpany also occupy the western errl
of the site. O'Hara is plannirq to move the waste transfer c:perations to a
." facility oorth of the Turnpike property. .
Surface am subsurface features associated with the Herrlerson Road
site Lamfill Operable unit ("DOU") include:
. shallow sediments, soils; cimers and trash;
. all local surface drainage; .
.. the adjacent intermittent stream; and
. groom water aOO rnR water affected am potentially affected by
disposal of hazardoUs substances onto the site fran the surface,
includin;J umergroooo tanks and pipes.
,
'!he Injection well Operable Unit (":rw:1J") pertains to grourrl water and UMR
contamination caused by or potentially caused by disposal of hazardous sub-
stances into the injection well. '!he ImJ is discussed in detail in a
previous Remedial Investigation and Feasibility Study ("RI/FS") and Record
of Decision ("roD").
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
EPA detected contCl'ninated groom water beneath the site in 1981 and
proposed the site for the National priorities List in 1983. '!he site was
fina~ized on the National Priorities List in 1984.' In December, 1985, an
Pdministrative Order on Consent was signed by EPA and nine resporrlents
for the canpletion of an RI and FS. In 1987, EPA divided the site into two
c:perab1e units - the ImJ and I.aJ.
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4
In June, 1988, the respoooents canpleted the nm RI/FS arrl EPA selected
a remedy in a roD for that cperab1e unit. In May, 1989, a Consent Decree was
entered for implementation of the remedy for the :rw:u by nine settlors. Under
that Consent Decree, the settlors are investigatio:;J further the area aroum
the injection well to identify whether direct remediation is appropriate
there. On-site wells will be pumPed to keep groum water fran leavio:;J the
site. Off-site recovery of grouoo water also may be implemented umer the .
Consent Decree. Recovered groom water will be treated with air strippers
prior to discharge either to the local sewage treatment plan or the adjacent
stream. Sane treated water may be reinjected to the ~ifer or be provided
to PSVK: for distribution. On am off-site wells will be monitored throughout
the Operation arrl Maintenance ("O&M") Phase. A treatment system has already
been installed at the one private well, q;>erated by McIlvain Wnber CanPanY, .
considered to be affected by the :rw:u at present. Finally, the settlors will
submit' a series of rePOrts on the status of the perfonnance of Remedial Design
am Remedial Action ("RD/PA"), includio:;J an "unsaturated am Saturated Zone(s)
Investigation Report(s)," a "Design arrl Construction Phases Plan," arrl "ai-
anrual O&M Reports." '!he work to be perfonned is ootlined in detail in the
Statement of Work ("OCM") attadled to the Consent Decree.
'!he resporxients to the Administrative Order submitted a draft FS for the
IDJ to EPA in April, 1989. In May, 1989, the respoments sul:mitted a draft
RI for the IDJ. EPA made the draft RI/FS arrl prcposed plan for the IDJ avail-
able for public review on June 12, 1989. Public ccmnents on the Proposed
Plan are included in the Administrative Record (see Exhibit 1).
'!he final RI/FS was due to be submitted to EPA on septanber 18, 1989,
but none has been received to date. '!he respoooents are in noncanpliance with
the Pdministrative Order because of this missed deadline.
SPecial notice letters for RD/PA of the Landfill Operable unit have been
sent to potentially responsible parties. In July, 1989, certain potentially
responsible parties offered to comuct an exPedited dla~cterization of the
western portion of the LQJ. No "gcxx1 faith" offer has been received arrl EPA'S
moratorium on RD/PA activity has concluded.
'!he Pennsylvania Department of Envirormental Resources ("PA DER") has
participated in all of EPA'S activities related to both q;>erable units.
III. cn1MONITY REIATIONS HIS'IDRY
Public ccmnent perioo for the IDJ RI/FS am Prq:>ased Plan closed on July
12, 1989. Althoogh q>portunity for a public meetio:;J was made available, no
~est for such a meetio:;J was received. Representatives fran PA DER, Depart-
ment of Interior, Fish am Wildlife Service, am National Oceanic am Atroospheric
Mministration have participated in development of the IDJ RI/FS since the first
draft was prcduced.
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5
EPA ootified the Pennsylvania Turnpike Ccmnission that work being con-
sidered for the IDU lID/FA is expected to affect the Turnpike property. The
Turnpike Ccmnission expressed an interest in excavating trash, constructing
a retaininJ wall, aoo backfilli~ on the Turnpike property in order to expaoo
the Turnpike to six lanes. All work wwld be done within the existinJ right
of way. The ccmnission ootified EPA that the Ccmnission plans to cooouct a
five-month study within the right of way to characterize the types aOO extent
of waste anj to design the retaini~ wall. EPA has offered to work closely
with the Turnpike Ccmnission in development of that study.
'rtle Responsiveness Surrrnary attached to this roD provides a response to
each of the significant ccmnents received from the public.
IV.
SOOPE AND roLE OF OPERABLE UNIT AND RESPONSE AcrICN
I
'rtlis roD for the LCXJ addresses the secooo of two planned activities at
the site. '!his roD addresses eooanJetment aOO potential eooanJetment from.
contcrninated or potentially contcrninated soils, surface water, groom water,
sediment anj air related to lamfillinJ, possible trenchinJ, spillinJ, place-.
ment, am stora;;je of hazardous waste at the site. The ItOJ roD addressed
groom water contcrnination aOO UMR contamination caused by or potentially
caused by disposal of hazardoos substances into the injection well. Together,
the roDs for the Laoofill aoo Injection Well cperable units address ex};X)Sure
arrl potential exposure to all contcrnination resulti~ from site activities.
v.
SITE. CHARACTERISTICS
A. Fill material ,tanks am leachate in LCXJ
Approx~tely 125,000 cubic yards of construction arrl demolition debris
am domestic waste fill the central aOO eastern portions of the site arrl
Conrail aOO Turnpike properties, coveri~ about 7.2 acres. Fill thickness
extems approximately three to 18 feet below the surface am generally in-
creases from west to sootheast. 33,000 cubic yards of tJiack cimers and
broken cimer blocks are estimated to cover about two acres in the ~tern
am central portions of the site anj Conrail am Turnpike properties .
About 16,000 cubic yards of trash fill am eimers, covering approximately
one acre, are located on the adj acent Conrail property to the sooth. 5,230
* Cimers have been cbserved in the western anj central portions of the site
am the Turnpike prq>erty. However, few samples have been analyzed fran the .
western portion of the site am the origin of cimers has oot been detetmined.
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6
cubic yards of trash arrl ciooer fill, coverirYJ about one-third acre, are
estimated to be located on TUrnpike property. Finally, three on-site uooer-
groom diesel fuel stor~e tanks, one on-site uooerground gasoline storage
tank, aID three septic tanks are included as part of the UXJ.
An estimated 2.5 million gallons of leachate, rarYJirYJ in thickness fran
three to ten feet, are present in the laoofill (see Exhibit 6). In addition,
a small area (220 square yards) in the soothwestern area of the larrlfill
contain six feet of leachate arrl fill. No water or leachate seeps have been
ooserved alo~ the eastern edge of the laoofill. Ol'Fsite soil is canprised
of silty clays aoo clayey silts aID rarYJes in thickness fran 12 to 90 feet
beneath the fill material. Liquid within the laoofill has been ct>served in
in portions of the laoofill to be perched above the regional water table.
B. Data Collected in the u:xJ RI
. As part of the RI for the I..CXJ, respondents collected ten surface soil
and ciooer ("as") samples fran the oorthwestern, central arrl eastern portions
of the site aoo analyzed these for volatile organic ccmpourrls ("volatiles").
A o:rnpa;it fran surface ciooer aoo soil samples was taken for sanivolatile,
inorganic, aoo total pheools analyses. .
. Fifteen test pits (TPl through TP15 on Exhibit 4) were excavated to depths
rarYJirYJ fran ten to 20 feet in the oorthern, central arrl eastern portions of
the site aID adjacent Turnpike am Conrail prq;>erties. In total, five solid
sanples aoo two cqueous samples were analyzed. 'three of the 15 test pits
were excavated fran the Turrpike property: of these three test pits, one
solid sample (TP2) was analyzed. Four of the 15 test pits were excavated
fran the Conrail property: solids fran two test pits (TPlO aID TPll) and
leachate fran one test pit (TPl2) of these fcur pits were sampled. Six
test pits were excavated on-site: solids arrl leachate fran one on-site test
pit (TP14) were sampled. Six test borirYJs [B-1, B-2, B-2A, B-3, B-3A, 8-4
(a backgroond location)] were installed at foor locations on-site, arrl samples
were analyzed fran depths rarYJirYJ fran three to 40 feet. 'these cinder and
soil sanples were analyzed for volatiles, sanivolatile canpourrls, pesticides,
PCBs, aID metals (see Exhibit 4). visual cbservations fran each test pit
arrl borehole, includin;;) ooservations of saturated coooitions, were legged.
,
Two sediment sanples ( "SED-4" arrl "SED-S") arrl two water samples ("WA-4
arrl WA-S") were ootained fran an area of former oo-site poooed water. '!hree
sediment sanples ("SED 1, SED-2, arrl SED-3") were ootained fran Freg Run.
'these five sediment sanples were analyzed for volatiles, sani-volatiles,
pesticides, Pa3s, aID metals.
Two. surface water sanples (WA-4 aoo WA-5) were ct>tainecj" fran an on-site
area of porxled water (this "porxl" 00 IOrYJer exists on the site, due to regradirYJ).
'the two water samples were analyzed for volatiles. '!he samples were can~ited .
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7.
for metals analysis. These scrnples were oot tested for sanivolatile organic
canpouOOs .
Results am conclusions fran these field activities in the "vadose
zone" (the zone above groom water) are presented in Exhibits 7, 8, am 9
am are discussed below. .
L Surface soil, shallow cimers, and sediments.
Toluene (a canponent of gasoline arrl diesel fuel) acrl 1, 2-dichloroethane
(a metal degreaser am paint remover) were detected in parts per million
( "t:PIt\") concentrations in the sediment samples fran the former pond in the
central portion of the site. Parts per billion ("t:Pb") levels of volatiles
were detected in all other sanples, except for tetrachloroethene ("PCE", a
ccmnon solvent) which was detected in ppm levels at BS2. .
Parts per million concentrations of 12 polycyclic aromatic hydrocarbons
("PAHs", which are sanivolatile organic canpourrls ccmnonly associated with
foss il fuels) acrl bis ( 2-ethylhexyl) phthalate (a plasticizer) were detected
in the shallow soil canpcsit for the site. Six PAHs and th~ other sani-
volatiles [benzidine, (used in organic syntheses, manufacture of dyes and ~
stiffEmin:J agent in rubber canpJUooin:J), bis(2-chloroethyl}ether (a
solvent), and bis( 2-ethylhexyl} phthalate] were found in ppm levels in
sediment samples fran the former poooed area. Because of the limited l1UItt>er
and distribution of sanples analyzed for sanivolatiles, the distribution of the
sani volatile contemination at the surface, for ooth soils and cirrlers, has
not been determined.
Inorganic conteminants detected in thecanpcsit semple were canparable
to levels detected in subsurface sanples collected fran the backgroorrl test
borll'X]. However, concentrations of lead, chranium acrl copper were slightly
elevated in one parrl sediment sample in the central portion of the site. .
Sample 005, collected. fran the sootheast corner of the site, was the
only semple to show 00 detectable levels of either organic or inorganic
contanination.
"
2. Cinder sarrples in lamfill
Two subsurface semples of ciooer fill were collected, fran TP-2, in the
central portion of the TUrnpike prq>erty, aoo B-3A, near the fonner pond.
Both semples detected priority pollutant canpourrls. HO\1IeVer, constituents
were different in the two samples.
The sample fran TP-2 was collected fran a deposit of ciooer fill that
was encountered below trash fill. This semple shO'1llled 330 ppb of ethylbenzene
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8
(an intermediate in proouction of styrene), 20 ppb of methylene chloride (a
solvent and cleaning fluid), 130 ppb of toluene, 32 ppm of 2,6-dinitrotoluene,
69 ppm of hexachlorobenzene, 56 ppm of hexachlorobutadiene, and 26 ppm of
bis(2-ethylhexyl)phthalate. The volatile canpounds are similar in nature
arrl concentration to contaminants fooOO in other test pit samples canfX)Sed of
natural soils, aOO to contaminants detected in surface samples. ais(2-ethy1- .
hexyl) phthalate, hexachlorobenzene, aOO hexachlorobutadiene were also detected
at TP-14. Dinitroto1uene was oot. detected anywhere else on-site. PCB ARXHIDRS
1248 (8.3 ppn) and 1254 (5.5 ppm) were also detected in TP-2. Again, this
was the only location where PCBs were fooOO.
Four PABs, ranging in concentration fran 100 Wb to 300 ppb, aOO 40 ppm of
butylbenzyl phthalate (a plasticizer) were the only organic canpounds identi-
fied in the ciOOer sample fran B-3A. Parts per billion concentratio~ of
ten methylated hydrocarbo~ were tentatively identified, possibly resulting
fran the degradation of a petroleum prcduct.
Detected concentratio~ of the inorganic contaminants cadmium (39,600 t:Pffi)
aOO rTla:Jnesium <13,600 Wm) were elevated above other test pit and test boring
samples in the ciOOer sample fran B-3A. Vhile the cadmium level is ootable,
it appears to be an isolated occurrence within the existing database. .
These samples are oot considered to characterize the nature or distribution
of contamination within the ciOOer fill. They can only be considered repre-
sentative of the imnediate area in which the sample was collected, as there
is 00 consistency between the two samples. . .
3. Soil beneath laOOf ill
In natural soils at the base of fill (test pits 5,10,11 and 14), ppm con-
centratio~ of four volatiles [ethylbenzene (a canponent of gasoline), toluene,
trichloroethene ("'OCE", a carmon solvent) and PCE] and 11 sanivolatiles in-
cluding bis(2-chloroethyl)ether were detected. Innatu~ soils ten to 30
feet below the base of fill, only diethylphthalate was detected, at concentra-
tio~ of ten to 20 Wb. It is rot likely that the diethylphthalate sample is
representative of soils at these depths, since phthalate esters are oot very
rndJile in the environnent and this was the only sample in the entire database
to detect this particular oampouOO.
Inorganic constituents were generally detected at backgrouOO levels in
natural soils above 10 feet. However, arsenic was foorD in ppm levels.
Chlordane, detected in a concentration of 134 Wb in TPll, constitutes the
only pesticide fouOO in natural soils at the base of the fill.
The nature of contaminants detected at the base of the fill in test
borings is different fran these foond in test pit .samples.
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9
4. Leachate samples fran beneath fill
Saturated fill was encountered in seven test pits ard two borirqs in
the central ard southcentral portions of the lardfil1. Only two test pits
contained free stardirq water. Aqueous samples were taken fran these two
pits. Seven volatiles, 16 sEmivolatiles, ard three pesticides were fourd in
the two leachate sanples. All concentrations in leachate were in ppb concen-
trations. TCE is quite mobile in the envirorment arrl therefore may be .
expected to be fourd in higher concentrations. .
5. Pomed water samples
Six volatile canpourds were detected, at similar concentrations, in each
porrled water sample. Maximum concentrations of the volatile canp:>urds de-
tected include: .
toluene- 844 ppb
trichlorfluoranethane - 368 ppb
1,1,1-trichloroethane - 6.8 ppb
ethyelbenZene - 2.6 ppb
benzene - 2.3 ppb .
1, l-dichloroethane - 1.9 ppb
'!he following metals were detected in the canpcsit sample, each in concen- .
trations 00 greater than 0.4 ppb: antim:my, arsenic, barium, chranium, copper,
lead, selenium, arrl zinc.
6. Stream sediments
Arsenic (800 ug/kg), beryllium (400 ug!kg), arrl cadmium (1,610 ug/kg)
were detected in stream sediments in concentrations higher than those found
on-site. PARs also were detected in stream sediments in high concentrations
(up to 400". Although the site is expected to cont~bute to this contam-
ination, upstream sources also may account for at least sane of this
conta1\ination.
7. umergroum tanks am pipes
Four urxiergrourxi storage tanks are located on-site. A 10,000-gallon
diesel fuel tank anj a 4,000-gallon diesel fuel tank were installed in 1986.
An 8,000-gallon diesel fuel tank was installed approximately ten years aJ0.
'!he aJe of a 1,00a-gallon gasoline tank is unknown. Results fran Horner
Tank tests on the tanks installed prior to 1976 indicate leak rates less
than (-.05) per hour, which meets National Fire protection Association
Code 30 criteria.
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10
Three septic tanks are reported to connect to lavatory facllities. Floor
drains, reportedly, do not drain into then. The presence or cordition of
leachin;;J beds is unknown.
C. potential Rootes of Migration Fran taJ Soorces ard Groord Water
F ate-ard-Transport Assessment
One major rcute of migration of hazardaJS substances ~sociated with
the rDU includes transport through the subsoil anj bedrock via infiltrati~
water. Once hazardoos. substances reach the groom water, they mayor may
oot rroveat the same speed am in the same direction ~ groord water. Other
potential routes of migration include transport to the st~eam via erosion
ard runoff, airborne transport fran fugitive dusts, ard volatilization.
. As described in the "Analysis of Cont.:minated Distribution anj Fate-am
Transport at the Heooerson Road Laoofill ~erable Unit", prepared by Camp
Dresser ard McKee ard dated f-tay 30, 1989, the overall mobility of organic
contaminants in the natural silty clay soils o~site is considered rooderate1y
. low. organic compounds with relatively high soil:water partition coefficients,
or "Koc", are considered relatively inmobile in soil (see Exhibit 10). '!he
chenicals foom o~site that are considered to be more md:>ile (i .e., more
likely to migrate fran soil to grounj water) are bis(2-ch1oroethy1}ether,
benzene, PCE am ~E. Many of the PARs, pesticides, anj PCBs detected .
o~site are carciI'1O;1ens arrl may migrate via airoorne dusts. HQWeI{er, when
bounj to soils, they terd not to leach am not to be transported to ground
water. Additional surface sampli~ is needed as part of the taJ RD to
characterize surface soorces of contamination anj supplement RD planned as
part of the rw:u. .
D. Results and Conclusions fran Iw:xJ RI
The RI for the rw:u concluded that the waste disposed into the injection
well has migrated to an area beyom the injection well's inmediate environs.
Gross and/or dissolved contamination is expected to ex~t in the void spaces
and fractures in the bedrock in both the unsaturated and saturated zones.
As part of the RI for the Iw:xJ, samples were collected fran on arrl off-
site wells and untreated anj treated UMR water. A risk assessment was
perfocned, usi~ this data. Data fran rw:u rronitori~ wells is oot co~
sidered representative of groom water impacted fran the rDU. Exhibits 11
and 12 surrmarize the human health risks for the 13 roodels ~sessed for the
IW:U .
'!be carciI'1O;1enic risk for the ItO], based on rnaxim~ concentrations of
ground water sanpled beneath the site, totals 3.6 x 10-. '!he Hazard Index,
also based on maximum o~site concentrations of grouoo water, totals 386.
Vinyl d1loride (a degradation proouct of TCE arrl used a'5 cdlesive for plastic) ,
1,1-dich1oroethane (a solvent and fumigant), arrl PCE were identified ~
posi~ the greatest prcportion of the potential cancer risk a'5sociated with
consumption of grouoo water beneath the site even thoogh toluene arrl xylenes
were foom in greatest concentrations in groum water. 1, 2-dichloropropane
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11
(a solvent, degreaser am soil fumigant) contributes the greatest prcportion
of ooncarcinogenic risk at the site am UMR.
In untreated UMR water, TeE, I, I, I-trichloroethane ( a solvent), am carbon
tetrachloride (formed y used as a metal degreaser, sol vent am a ref rigerant)
w~re foum in the highest concentrations. However, vinyl chloride,. chloroform
(used in flourocarbon refrigerants, plastics, am as a solvent), 1,2,3-tri-
chloropropane (a sol vent am degreas in;;1 aJent) am dichlorobranaoet.'1ane were
identified as pasin;;1 the greatest carcinogenic risk in untreated UMR water.
Treated UMR water meets Federal Safe Drinkin;;1 Water Act ~irements.
'!he total risk fran treated water was calculated at 4.4 x 10- (using
maximum concentrations) aro 1.9 x 10-5 (using averages).
'ttlirty-five chemicals. of concern were identified in the Iw:xJ RI (see
. Exhibit 15). Fifteen of the chemicals of conce~ associated with the Iw:xJ
were fooro at UMR in 1986. Certain site-related chemicals also have been
detected between the site aro UMR am at the McIlvain well.
'ttle site is located in an area of regional grooro water contamination.
TwO canpouros, 1,1,2, 2-tetrachloroethane am 1,2, 3-trichloropropane, which
contributed one-fifth to one-eighth of the risk associated with untreated UMR
water in 1986, were oot detected at the site.. in 1986. Trichloropropane
accounts for the secoro highest prq>ortion of carcinogenic risk in onerncrlel
that was used in the ~QJ Risk Assessment. Furthennore, five organic cc:rnpouros
have been detected in excess of health-based levels in foor off-site wells
oot considered to presently be affected by the Iw:xJ. Exhibit 14 shC1NS other
potential regional soorces of contanination.
VI.
rm RISKS
. A. Human Exposure pathways
1. Grcuro water expcsure - One major human exposure pathway is inhalation
am ingestion of groorrl water. To estimate the risk fran the I.DU via grourd
water exposure, maximun am mean values fran the two leachate sanp1es collected
in the 1arrlfill were multiplied by 0.15 - a value used to represent dilution
of leachate to the prq>erty line. For chemicals oot d8tected in leachate but
fooro in soil, a calculation, based on the organic carbon coefficient of the
respective chemicals am the fraction of organic carbon in the soils on-site,
was applied to predict the anticipated concentrations in grooro water beneath
the site. 'ttle 19 in::Ucator chemicals aro the concentrations used in this
calculation are presented in Exhibit 13.
Based .on the high rate of pumpin;;1 at UMR am potentianetric surfaces,
the IVDJ RI concluded that on-site grcum water eventually reaches UI-1R. Ni~e
chemicals of concern for the IaJ are also chemicals of concern for the ~m .
'ttle IaJ Risk Assessment concludes that UMR also presents a potential exposure
pathway.
*See Table 7-1 to Iw::xJ ROD aro Exhibit 13 to this roD. Data collected
fran UMR is considered very limited, as many constituents fooro at the site
are oot typically tested by Pm-~. UMR draws water fran a large area where
other potential soorces also exist.
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12
2. Exposure via dust arrl vapor inhalation - A secorrl exposure pathway
associated with the LOU is inhalation of dusts am vapors generated fran
heavy equipment by on-site workers arrl area residents. '!he concentrations of
soil particulates arrl vapors both on arrl off-site were modelled in the DOU
Risk Assessment with a two-step process. This process first estimated rates
of anissions arrl then incorporated these rates into an air dispersion model.
3. Exposure with in;;Jestion of soils arrl dermal contact - A third exposure
pathway is in;;Jestion or absorption via dermal contact of soils by on-site
workers durin;;J daily activities arrl by trespassers.- For on-site workers, an
iocidental soil in;;Jestion arrl dermal contact rate of 100 rtQ/day was adjusted
for five workin;;J days per week, 50 weeks per year, arrl 30 years per lifetime.
Trespassers on the site were assumed to be children <30 kg) ~o woo1d visit
the site 30 times per year arrl in;;Jest or contact 100 rtQ of soil per visit for
five years of a 70-year lifetime. Absorption through dermal contact was rot
included directly in the risk calculations but was assumed to be included in
the risk fran incidental in;;Jestion of soil. .
B. LOU Human Health Risk Assessment
'!he population at risk fran the I.aJ is limited to potential groom water
users, on-site workers arrl potential trespassers. No residential wells were
identified in the IvnJ RI as affected by the site. However, several-wells in
the vicinity of the site are used by local businesses arrl irrlustries. '!he
DnJ RI identifies the McIvain well as presently affected by the site. Finally,
custaners served fran UMR also are potentially affected by the LOU. '!he DnJ
RI arrl roD address the risk assessment performed on both the McIlvain well
am ~.' .
. Exhibit 16 sUITlTlarizes the baseline risk for the LOU. '!he total upper-
boum excess lifetime carcinogenic risk to a maximally exposed irrlividual
for the LOU is estimated at 1 x 10-2. '!he primary risk associated with the
LOU, 8.4 x 10-3, usin:J maximum values, is fran potential exposure to groom
water predicted to be contClT\inated fran transport of hazardous substances
through the fill material, natural soils, arrl bedrock fractures arrl voids.
'!he Hazard Index totals 3.9 (usin:J maximums) foS groom ~ater. '!he next
highest risk pathway for carcinogens, 1.5 X 10- (maximum values), is for
incidental in:Jestion of soil by on-site workers. In addition, a maximally
exposed or-site worker woold have an upper-boum excess lifetime risk of
2.4 X 10- via inhalation of fugitive dusts arrl vapors, based on maximum
concentrations. In general, non-carcinCXJenic risk totals reflect a similar
ranked order as for carcinogens. 'I1le Hazard Irrlex totals less than one for
in:Jestion of soil an::l irtlalation of fugitive dusts arrl vapors.
PARs canprise 60 percent of the groum water risk calculated in the RI
arrl are the mcst prevalent hazardous substances foom in the I.aJ. Accordin:J
to the groom water risk assessment, aldrin arrl PCBs canprise an crlditional
17 arrl ten percent of the carcinogenic risk, respectively. However, PABs,
aldrin an:}. PCBs terrl to renain bourrl to soils arrl not be transported to
groum water. Bis(2-chloroethyl)ether arrl six volatiles - benzene, mloro-
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13
form, pCE, TeE, 1,3-dichlorcprcpene, arrl hexachlorobenzene - are considered
relatively mobile (See "Analysis of Contaminated Distribution arrl Fate-arrl-
Transport at the Herrlerson Road Larrlfill cperable Unit," prepared by Camp
Dresser & McKee aoo dated May 30, 1989) 0 EPA considers. existence of these
chemicals in lamf ill leachate to pose the greatest threat to groord water.
EPA attributes about three quarters of the risk of cancer fran grour1:i water
exposure to bis ( 2-chloroethy I) ether am the remaini ~ one quarter of grOOrd
water carcinogenic risk to the six volatile organics listed above.
Aldrin ccmstitutes 72 percent of the maxiumun Hazard Iooex of 3.9 for
norr-carcinogenic risk associated with groum water. Since aldrin is rot
considered mobile, 1,3-dichlorcprcpene, which accounts for 8 percent of the
maximum noncarcinogenic risk, is the major noncarcinogenic chemical of concern.
associated with use of orr-site groom water. .
'!he next highest risk pathway for carcinogens is i~estion of soil by
orr-site workers. Benzidine, foord in only one sample, represents 47 percent
of the risk am PARs represent another 47 percent. '!he Hazard Irrlex for
. i~estion or direct contact of orr-site workers with soils - is due primarily
to lead. .
'!he carcinogenic risk via inhalation is dcminated by chranium (75 percent
of maximun). Benzidine represents 15 percent of the maximum carcinogenic
risk via inhalation but was foom in only one sample. '!he Hazard Irdex for
orr-site workers is due primarily to inhalation of barium.
C. I.a.J am IW:XJ: Canparison of Human Health Risk Assessments
'!he chemicals of concern prcpcsed in the draft FS arrl adopted. in this
roD were based on chemicals use in the Risk Assessment. '!he Fate-ard-Trans-
port Assessment was not directly factored into selection of chemicals of
concern.
,
About half of the chemicals of concern associated with the roo arrl
adjacent prcperties also are identified as chemicals of concern for the
IvnJ. Benzene, which is a canpoum identified in the IVUJ roD as a
potential "regional contcrninant", is associated with the predcminant risk
for both cperable units. However, the other chemicals canprisiOJ the
predcminant carcinogenic risk identified at present for the two cperable
units are different. Data fran additional monitori~ wells, to be installed
for both the :rw::u am prcpcsed for the UXJ, is expected to support a roore
thoroogh characterization of the groord water for both. cperable units arrl
enable risk predictions to be refined.
'!he risk assessment for the IW:X.J only addressed groord water risks.
'It1e upper-balm excess lifetime carcinogenic risk to a maximally exposed
irrlividual calculated f~r the ItQJ, based on actual groom water data, was
calculated at 3.6 x 10-. '!he predcminant carcinogenic risk for the I.CXJ,
-------
/-
14
8.4 x 10-3, was based on prediction of movanent of 1~achate to grourrl water.
An additional carcinogenic risk, totalling 1.5 x 10- , is attributed to exposure
fran ingestion of soil arrl. inhalation of fugitive anissions in the IDU Risk
Assessment.
. The universe arrl volumes of materials disposed neither via the injection
well nor fran the taJ have been reported to the EPA. The local direction
of contaminant movanent in the fractured bedrock arrl grourrl water also is
not known. Contamination fran the IW:)J may affect grourrl water also impacted
or potentially impacted fran the IaJ. Thus, EPA does oot expect to disti~uish
the sources or relat.ive risks of grourrl water contamination at or near the
site between the two operable units.
Substantial uncertainties are associated with the characterizat.ion
of both cperable units. In light of these uncertainties ~ EPA' s general
starrlard for clean-up of Superfurrl sites to the 10-4 to 10- risk level,
the potential for adverse health effects, based on carcinogenic risks, is
considered substantial. "No action", with a risk estimated at 1 x 10-2
for the LOU, is unacceptable arrl site remediation to within the 10- to
10-7 risk range or backgroorrl levels is recarmerrled as an initial remedial
objective. .
D. Erivironnental Risks
'!he principal chanicals of concern associated with Frog Run are these'
bourd to soils. '!he levels of dissolved chElTlicals are within a factor of ten
of the a:xuatic chronic criteria; the RI concluded it is oot likely that these
. concentrations represent a threat t.o any continuously flowing stream of the
SChuylkill River. SEITIivolatile chanicals such as PAHs associated with site
soils can reach viable habitats via the gradual movanent of sedimentary
material along the strecrn bed. '!hese sanivolat.ile chanicals represent a
potential for impact via bioconcentration. However, concentrations of PAHs
in upgradient arrl downgradient sanples are similar, sUgJesting that off-site
contributions of PARs mask arrj contribution fran the site.
VI I. DESCRIPrICN OF THE ALTERNATIVES
.,
A. Ranedial Objectives
'!he resporxients developed seven remedial alternatives in the FS, ..;jSed
on the remedial objectives sumnarized below:
reduce the risk for groom water, soil, f ill materials, leachate,
am air to an acceptable level for carcinogens arrl ooncarcinogens;
. restore the a:xuifer beneath the site to "Class IIA" classification;
. prevent significant transport/migration of contaminants in soil,
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15
fill, and leachate to ground water:
. prevent the generation of leachate and thereby prevent the relea$t::
of contcrninants to grourrl water:
. significantly reduce the potential for release of site contcrninants
to the envirorment throogh fugitive particulate or vapor emissions.
Inherent in many. of these remedial objectives are "applicable or relevant
arrl appropriate requirements ("ARAR,sft). ARAR,s may include:
. a.rry starrlard, requirement, criterion, or limitation pranulgated urder
Federal environnental law:
\ .
o a.rry pranulgated stardard, requirement, criteria, or limitation under
a state environnental or facility-siti~ law that is more sti~ent
than associated Federal starrlards, requirements, criteria, or limi-
tations. .
AAARs inay be contaninant-specific, location-specific, or action-specific.
Exhibit 17 sUITll\arizes the ARMs considered in the PS for the UXJ. Addition-
ally, Federal Undergrourrl unjection Well requirements may be applicable or
relevant arrl appropriate, as may groom water withdrawal arrl discharge re-
quirements which are urder the jurisdiction of the Delaware River Basin
Carmission.
EPA developed an eighth alternative, based on Alternatives 3 aro 7 .
described in the draft FS arrl the remedial objectives listed above, but also
consideri~ the followi~:
. the need to fully coordinate ground water recovery, characterization
and remediation in the western portion of the site, and monitori~
wi th the IvnJ:
. Pennsylvania Turnpike Ccmnission plans to expaoo the Turnpike in the
vicinity of . the site to six lanes:. ,
o the need to remove d:>vious high levels of contanination that may be
encountered, such as highly stained soils or containerized waste,
prior to cappinJ.
. a potential conflict in maintaini~ the ~ water line on-site
with remedial d:>jectives and state ARMs.
Alternative 8 is presented in this roD but oot included in the draft FS.
B. Sumnary of Alternatives
'Ihe seven alternatives evaluated in the FS and EPA'S selected alter-
native, Alternative 8, are surrmarized below.
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16
1.
Alternative 1
This alternative wculd ~ire 00 on-site ranedial activities. The
site wculd be fenced, perio1ic monitorin;J of surface water, vadose zone, arrl
grcurrl water contaminants wculd be conducted, arrl deed restrictions wculd be
instituted to limit future uses of the site ard affected prq>erties. "
Surface water monitorin;J wculd identify the extent, if any, to which
FrD;1 Run is affected by remedial action. Surface water Walld be sampled two
times per year followin;J rain events at three stream locations. r>ata fran
vadose zone rronitori~ wculd provide warnin;J prior to an additional release
to grourd water.
If significant soil moisture is consistently detected, en;Jineerin;J
improvEments wculd be considered. Groord water monitorin;J wculd identify
chan;Jes in groord water quality even thoogh it may oot be possible to
identify whether a particular groord water cha~e is due to the rDU, nO],
or off-site soorces. The groord water rronitorin;J p~ram is described in
Alternative 7.
Under this alternative, approximately 125,000 cubic yards of trash,
approximately 33,000 cubic yards of cinder fill, an urdetecnined amount of
deeper contaminated soils ard bedrock, ard 2.5 million gallons of leachate
wculd remain on-site ard on adjacent properties. Additional leachate wculd
be generated in the future, pasirg a further threat to groord water. With-
oot cappin;J, Alternative 1 woold be unlikely to meet state closure requi!:"e-
ments. " "
This alternative wculd not reduce the existin;J risk fran exPOSur~ to
vapors ard dusts. The risk associated with this alternative, 1 x 10- ,
primarily based on the prediction of the movEment of leachate to groom
water, woold exceed EPA'S rarge of acceptability.
Estimated Construction Cost:
Estimated Annual O&M Ccsts:
$
$
325,500
72,500
,
Total Present Worth:
$1,077,100
Estimated Implementation Timeframe:
Three rronths to implEment.
2.
Alternative 2
In this alternative, the existirg on-site corrugated metal storm sewer
line wOlld be replaced with HDPE pipe ard the site wooid be graded to proper
contoors. Either a RCRA"multi-layer cap or a PA SOlid Waste multi-layer cap
woold be installed CNer the lardfill. Areas not already paved in the western
portion of the site woold be covered with bituminoos (asphalt) cap. Surface
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17
water, groum water, anj 1ardfill gas would be ronitored, am institutional
. controls would be implemented to limit future uses of the site am crljacent
prcperties.
Regradin;;j, improved surface drainage, am cappin;;j wOJ1d fac.ilitate run-
off into the storm sewer, reduce infiltration of water into the lamfil1, ard
thus reduce the product ion of leachate ard associated risks. . Furthermore,
capping woo1d address the risk fran direct contact arrl inhalation of fugitive
dusts for the duration of the O&M. Replacement of the existin:) storm sewer
line woo1d eliminate the possibility of leakage through the corrugated metal
pipe joints urder the cap. .
Four inlets woo1d be constructed to provide drainage for the canp1eted cap.
Two-foot by two-foot passive gas collection trenches woo1d be dug into the
top of the fill just inside the perimeter of the cap am filled with two-inch
stone. Vent pipes w0l1d penetrate the cap to release gases fran the trenches.
In addition, piezaneters would be installed in ard ara.m:1 the 1arrlfill to
monitor the vadose zone.
Alternative 2 includes installation of a RCRA or PA Solid Waste cap to
cover the central anj eastern portions of the site am affected 'l\.1rnpike
Canmission arrl Conrail prcperties. A RCRA cap woold use both a synthetic
membrane ard a canpacted clay layer as barriers. '!he PA cap w0l1d include a
siI'¥J1e canpacted clay layer. Synthetic membranes provide the loTNeSt permea-
bility barrier when prcperly installed am maintained. Canpacted clay also
provides a very low penneabi1ity barrier am is "se1f-merdin;;j" when small
cracks form with age. On the east side of the 1amfill, steeper slcpes may
require only a clay cap to assure cover slope stability. '!his woo1d be
further addressed duriI'¥J RD.
As with Alternative 1, existin;;j trash, cirders, contaminated soils arrl
bedrock, and leachate would remain on-site. However, based on a minimum of
one gallon of leachate generated per acre per day with a cap, future leachate
to be generated would be reduced fran an estimatec;i 3.4 million gallons per
year to less than 3,000 gallons per year. Consequently the groum water risk
w0l1d be reduced by three orders of magnitude. '!he risk fran air exposure
W0l1d be eliminated for the duration of O&M. Usin:) ~i~approach, the risk
associated with Alternative 2 is estimated at 8 x 10-. Because this alter-
native does oot include collection of leachate - the medium considered to
pose the greatest prcportion of risk - this alternative may oot meet State
ARARs for closure.
Estimated Construction Cost:
$2,469,000 (RCRA cap)
1,745,000(PA cap)
Estimated Annual O&M Costs:
$
91,700
Total Present WOrth:
$3,420,000 (RCRA cap)
2,696,000 (PA cap)
Estimated Canp1etion Timeframe: Six months to implement.
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18
3.
Alternative 3
As in Alternative 2, Alternative 3 would include regradirq the laoofill
aoo cappirq it 'Nith either a RCRA or PA Solid Waste multi-layer cap. A
bituminous cap would cover areas not already paved in the western portion of
the site. Institutional controls wooid be implemented as in previous alter-
natives. Alternative 3, however, includes installation of a french drain aoo '
sump leachate collection system in the laoofill alorq with monitorirq aOO
off-site treatment of leachate.
As with Alternatives 1 am 2, existirq trash, eimers, am contaminated
s0ils would remain o~site. 'Ibe effect of an asphalt cap over the western
portion of the site is unknown because EPA has determined that this portion
of the site is inadequately characterized. 'Ibe draft FS does rot identify
drainage controls to be instituted in this area, ror are maintenance measures
described or casted out. However, ranoval anj treatment of leachate - the
medium pcsirq the greatest risk - would reduce the carcinogenic risk ide~
tified umer Algernative 2 by one-half, resulti~ in a total carcil1CXJenic
risk of 4 x 10-. 2.5 mill ion gallons of existirq leachate anj 3,000
gallons of leachate estimated to otherwise be generated each year would be
directly treated. ...
Leachate treatment am dispcsal options include:
. o~site leachate treatment in conjunction with the groum water treat-
ment system to be constructed as part of the IVnJ ranedial action.
'Ibe treatment system to be designed for the nOl is planned to involve
metals precipitation am air strippirq. 'Ibis system may be suitable
to treat larrlfill leachate, although additional physical, chemical,
or biological treatment may be needed to remove semivolatiles or .
increase treatment eff iciency. Treated water woold be disposed either
into the local sewer system or adjacent strean: sane of the treated
. water may. be reinjected to the ~ifer or distribl4ed to PS\'C:
. off-site dispcsal of collected leachate for treatment at the local
sewage treatment plant. Pretreatment may be needed:
. disposal of collected leachate at an off-site oarnrnercial facility.
ARARs listed in Exhibit 17 include these for leachate treatment. Although
off-site treatment arrl disposal are included in this alternative for castiOJ
purpa;es, the final treatment aOO disposal option would be selected duriOJ RD.
Performance starrlatds for leachate treatment woold be based on the disposal
option selected. Leachate will be monitored aOO treated for chemicals of
concern listed in Exhibit 15. Shoold additional constituents be identified
in the leachate duriOJ RD/RA, treatment anj monitori~ may be enhanced
accordirqly.
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19
In general, Aternative 3, with cappi~, leachate collection, and rooni-
tori~, is expected to meet State landfill closure requirements.
Estimated Construction Cost:
$3,196,000 (RCRA cap)
$2,472,000 (PA cap)
Estimated Annual O&H Costs:
$
96,700
Total P1:'esent Worth:
$4,199,000 (RCRA cap)
$3,475,000 (PA cap)
Estimated Canpletion Timeframe:
Alternative 4
Ten roonths to implement.
4.
As in Alternative 3, Alternative 4 woold include run-on, run-off and
erosion controls, either a RCRA or FA Solid Waste Cap, leachate ronitorif)J,
collection,. and treatment, surface water, landfill gas, and vadose zone
monitori~, prq;>erty ~reements, and deed restrictions. Areas rot already
paved in the western portion of the site woold be covered with asphalt, as in
Alternative 2. .
Alternative 4 also woold use an active gas recOvery system to ~ve
volatile organic compounds in the landfill through "in-situ volatilization".
In-situ volatilization woold consist of a series of gas recovery wells.
placed within the fill material and connected to suction blowers ~ipped
with caroon adsorption treatment units. The n..unber of collection wells, .
size of the blowers, and capacity of the carbon treatment units woold be
determined duri~ RD and be based on pilot testif)J.
In-situ volatilization may remove volatile organics in the trash. Less
volatile organics and inorganics woold oot be removed in the trash. Also,
volatiles absort>ed to clays or cinders beneath the fill woold rot be likely
to be removed with this technology.
Records identifyi~ the volume, d1emical character¥tics, and location
of wastes dispcsed onto the I!XJ have oot been provided to EPA. '!he varied
canposition of in trash, cinders, and soils beneath the fill precludes
estimation of total volatiles in the LCXJ. Cons~ently, the volume of
volatiles to be recovered with in-situ volatilization has oot been identif-
ied. Similarly, the volLlT\e of nonvolatiles that wwld be left in place
in the trash and the volume of volatiles and nonvolatiles that wwld be
left in place in the soil and cinders beneath the fill have oot been
identif ied.
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20
'!he draft FS states that i~situ volatilization WOJld be teminated once
volatile organic canpounds are removed to clean-up levels that WOJld be deter-
mined in RD. 'Ibe draft FS further states that ARARs may be exceeded wi th
this ted1nology. HO\!ieVer, EPA anticipates that a very low efficiency of
volatile organic removal is likely to be achieved with i~situ volatilization
because the concentrations of volatiles in the lamfill are low canpared to
the concentrations of these canpoums at other sites where i~situ volatili-
zation has been successful. 'Ibus, it is unlikely that ARARs WOJld be exceeded.
Additionally, i~situ volatilization would not address bis(2-chloroethyl)-
ether, which is not very volatile. 8is(2-chloroethyl)ether canpriseS about
three quarters of the risk to groom water.
Assuming in-situ volatilization removes 100 percent of the volatiles
in the IDU, as represented by maximum values used in the Risk Assessment,
the risk to groom water quantified umer Alternative 3 would be reduced by
an additional on-quarter, am result in gn upper-bound lifetime risk to a
maximallly exposed irrlividual of 3 x 10-. 'Ibus, many wastes ccmprising
most of the risk, including volatile organic ccmpourrls and bis(2-chlo-
roethyl)ether, woold still be left in place.
Estimated construction Cast: $4,526,000 (RCRA cap)
$3,802,000 (PA cap)
Estimated Ann..1al 00\ CCEts: Yrs 1-3 $759,000
Yrs 4-30 $95,700
Total Present WOrth:
$7,332,000 (RCRA cap)
$6,609,000 (PA cap)
Estimated Implementation Timeframe:
11 months to implement.
5.
Alternative 5
'!his alternative includes dewatering and excavating "hot spots" in the
landfill, estimated for costing purposes at 3,800 cubic yards, am either
off-site incineration and off-site landfill disposal or offsite land disposal
only. Overlying fill would be redeposited into the excavation am the land-
fill woold be regraded arrl capped with a PA Solid Waste ep. 'Ibe cimer fill
on the western portion of the site which is not already paved would be
covered with asphalt as in Alternative 2. GraJrrl water, surface water,
and larrlfill gases woold be monitored to evaluate the effectiveness of
Alternative 5. Institutional controls woold be implemented to restrict
future use of the site arrl affected prc.perties.
'!he area assumed to be excavated is a contaminated area near the
soothcentral portion of the site near test pit 14. 'Ibis area is ide~
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21
tif ied in the draft FS as containin;;J the highest concentrations of
volatile am semivolatile CCIn};:CurrlS. The horizontal extent of this area
is not locally defined by the data available fran the RI arrl the limits
of this partial excavation would be deter.mined in the field durin;;J the
remedial phase. .
Approx~tely 4,000 cubic ya~s of fill material overlyin;;J the contam-
inated soils woold be resooved first arrl st~ed adjacent to the excavation.
If necessary, the area woold be dewatered to allow excavation to proceed
more easily. If incineration is chcsen, the urrlerlyin;;J contaminated fill
arrl soils woold then be excavated arrl sorted to remove oon-processable
wastes such as large timbers, concrete, arrl wire. The sorted waste would
be pack~ed in fiber drums arrl transported to an off-site haza~ous waste
incinerator.. The fX>n-processable waste would be loaded into trucks or roll-
off boxes for transportation to a haza~ous waste larrlfill. If 00 treatment
is chcsen, the contaminated soils arrl fill woold be transported to an
off-site hazardous waste larrlfill disposal facility.
. Approx~tely 149,200 cubic yards of trash, fill, arrl cirrlers woold
still be left in place urrler Alternative 5. Deeper contaminated soils
arrl bedrock also woold be left ,in place. Finally, leachate outside the
area to be excavated ao%r to be generated in the future would oot be
collected. .
partial excavation, incineration, arrl larrl disposal are estimated to
result in generation of leachate in volumes arrl concentrations slightly.
less than Alternative 2. Usi~ these assumptions, Alternative 5 would result
in a risk of less than 8 x 10-. Exposure arrl the consequent risk fran air-
borne soils woold be eliminated over the 10l'kJ-ter.m.
The soil "clean-up" staooards proposed for this alternative in the draft
FS are oot considered by EPA to be adequately justified. Since Alternative
5 was oot selected for the remedy, "soil ARARs" are oot presented in this
discussion. '
Excavated materials woold need to be treated prior to off-site disposal
in o~er to meet RCRA "I..a.rd Ban" requirements. Thus, treabnent arrl inciner-
ation is the only subalternative that would meet Larrl Ban requirements.
However, withoot leachate collection, Alternative 5 may oot meet PA ARARs
for clcsure..
Est~ted Construction Ccst: $11,670,000 (off-site incineration
and larrlfillin;;J)
$ 4,745,000 (off-site disposal only)
Estimated AnrnJal O&M Ccst:
$
91,700
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22
Total Present Worth:
$12,621,000 (off-site incineration
and landfilling)
$ 5,696,000 (off-site disposal only)
Estimated Implementation Timefrcrne:
12 rronths to implement.
6. Alternative 6
Under this alternative, fill materials and contaminated soils in the
leachate-saturated, central portion of the landfill, estimated to total
50,000 O.1.bic yards, woold be removed. Fill material overlying the contam-
inated soils (about 64,000 OJbic yards) woold be rerroved first and st~ed
adjacent to the excavation. If necessary, the excavation area woold be de-
watered to allow overlying surface wastes to be removed more easily. '!be
excavated, leachate-saturated fill and soil would be disposed by either off.
site incineration and off-site land disposal or by off-site land disposal
only. '!be overlying fill material woold be consolidated into a smaller. area
of the site, estimated to cc:Ner 3.5 acres, capped with a PA Solid Waste cap,
and vented with a passive gas venting systan. '!be remaining excavated area
woold be filled with CQ1IOOn soil. Monitoring woold be conducted and institu-
tional controls wwld be implemented as in Alternative 2.
If incineration was to be selected, the underlying contaminated fill and
soils woold be excavated and sorted to remov~ oonprocessable wastes such as
large timbers, concrete, and wire. '!be sorted wastes woold be pack~ed in
fiber drums and transported to an off-site hazardous waste landfill. If
incineration was rot to be selected, all contaminated materials woold be sent
to an off-site hazardous waste land disposal facility. Under both q>tions
t e existing stODn sewer pipe woold be replaced.
Excavation of leachate-contetninated fill and soils is included under
this alternative because leachate is considered to present the greatest threat
to ground water. 103,000 OJbic yards of trash, fill, cinders and shallow
soils, an unidentified volume of contaminated deeper so~s and bedrock, plus
3,000 gallons of leachate estimated to be generated per year woold oot be
ranoved under this alternative.
'!be risk associated with Alternative 6 is similar to that for Alterna-
tives 2 and 5 because the same volumes of leachate woold be generated urrler
all three alternatives. EP~ estimates that the risk woold be sanewhat lower
than Alternative 5 (8 x 10- ), however, since less contamination woold be
left in place. Also, State requirements for closure may require leachate
collection. .
Excavated materials wwld need to be treated prior to off-site dis-
pcsa1 in order to canply with Land Ban "regulations. '!bus, the excavation and
incineration subalternative is the only subalternative that meets Land Ban
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23
requirements. Even this subalternative may rot meet air quality am water
quality ARARs in the short term, because dusts arrl cx:iors walld be generated
duriC)Jexcavation, possibly in exceedence of National Ambient Air l)Jality
Standa~s arrl Pennsylvania Air Pollution Control regulations.
Estimated Construction Cast:
Estimated Annual O&M Cost:
$131,137,000 (off-site incineration and
off-site disposal).
$ 37,365,000 (off-site disposal only)
$ 91,700
Total Present Worth:
$132,087,000 (off-site incineration arrl
off -site disposal)
$ 38,316,000 (off-site disposal only)
Estimated Implementation Timeframe:
18 LnOnths to implement.
Alternative 6 is fran three to 50 times more expensive than Alternatives
1 through 5..
7.
Alternative 7
'!be resporrlents present Alternative 7 in the FS as a contiC)Jent alter-
native to. be implemented if the UXJ contributes to grourrl water contcm-
ination*. 'Ibe resporrlents propose institutiC)J grourrl water pumpiC)J am
treatment if grouoo water remediation is irxiicated for the UXJ after the
grouoo water recovery system for the ImJ is operated. 'Ibis remediation
Walld supplement the grouoo water pumpiC)J am treatment planned for the
IVnJ. .
Grouoo water pumpin;J, if successful, waJld remove contaminated water fran
the cquifer aoo keep contaminated grouoo water fran leavi~ the site. As part
of Iw:xJ Remedial Action, sufficient wells will be inst~ed in the most prcx:iuc-
tive fractures or solution features to recover contaminated grouoo water beneath
the site. Initially, three to five 8-inch grouoo water recovery wells, each
il'l'Stalled to a depth of up to approximately 400 feet, will be utilized to contain
aoo collect the grouoo water beneath the site. 'lhese wells are proposed to
be Pumped at a canbined rate of about 300 gallons per minute. If contaminated
grouoo water is fouoo to be bypassin;J the collection system (as determined
through perimeter grouro water IOOnitori~), additional recovery wells will be
installed arxVor the pumpi~ rates will be adjusted to create a suitable area
of pumpi~ influence. .
*Criteria for grouro water pumping are different in EPA' s selected remedy
than in Alternative 7, as presented in the draftFS.
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24
'!he IVlXJ treatment systan will be based primarily on use of an air
stripper. Air strippiaJ technology is based on the principle of vapor-liquid
equilibrium. Contaminated water is contacted with large volumes of anbient,
air. '!he concentration of contaminants in the influent air is far below 9:IUil-
ibrium, providio;; the drlvio;; force for transfer of contaminants fran water
to air. Contaminated water is Pumped fran the water source to the tower, where
it is Countercurrently contacted with air. 'Ihe water enterin] the tower trickles
down CNer a packed media which generates a thin film of water for air contact.
'Ihe thin film provides a large surface area for air to water contact. Air
strippio;; has been demonstrated to prO'Jide a cost-effective systan for
ranoving volatile organics from ground water.
Exhibit 21 oUtlines poSsible treatment processes to be used on
grourd water to be pumped at the IWX1. Additional treatment could include
pH adjustment, granular activated carbon, PAC!' activated sluciJe process, ard.
filtration. If required to meet air pollution control requiranents, the
effluent fram the air stripper will flow through a dehUmidifier and a vapor
phase carbon adsorption unit to reduce emissions of volatile organic compounds
(ard/or leachate) to mardated levels. '!his system also may be used to treat
groord water conteminated by the LOU. If additional treatment is needed to
address conteminants that. may be attributed to the I.OU, these or other a~di- .
tional treatment canponents waJld be added to the IW:U treatment system.
The Delaware River Basin Commission ~iews all penuit applications for
groom water withdrawals exceedin] 10,000 gallons per day (gpd). Performance
standards for the ground water treatment systan will be based on the option,
to be selected durio;; nn.J RD, for disposal of treated grourd. water. Exhibit
17 includes water ard air quality ARARs with which the treatment systat\ must.
canply.
Estimated Construction Cost:
Estimated O&M Cost:
$ 444,600
$ 104,000
Total Present WOrth:
$1,523,000
Estimated Implementation Timeframe: Two years to begin pumpin]
(not clearly indicated in FS).
*
Since all materials injected into the injection well am/or disposed into
the lamfill cperable unit have not been identified, it is unlikely that groom
water conteminants soley attributed to either cperable unit may be identified.
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25
8. Alternative 8
(a) Summary of Components of Alternative 8 - Alternative 8, developed
by EPA, includes:
. Alternative 3 - regrading, collection of runoff, runon and
erosion controls, leachate collection and treatment, capping*
monitoring, and institutional controls on-site and on adjacent
properties to restrict activities that would interfere with
remediation at the site (see Exhibit 19);
. Alternative 7 - contingent ground water recovery and treatmen .
A determination to institute pumping would be based on detection of
site-related ground water contamination at or near the property line
and a determination that ground water is still leaving the site
two years of ground water pumping for the IWOU (see Exhibit 20).
. Movement of trash, shallow soils and shallow cinder fill from the
Turnpike property to the Henderson Road site, additional charac-
terization of the Turnpike property after excavation, and appropriate
remediation to address wastes left in place and existing and potential
leachate there;
* See discussion below. A PA Solid waste cap is included in Alternative 8
for the central and eastern portions of the site. This alternative includes
consolidating characterization and evaluation of remedial alternatives for
the western portion of the KXJ with RD/RA for the IWDU and deferring selection
of the remedy for the western portion of the DOU which may include an asphalt
or PA Solid Waste cap, until that characterization work is complete. Further-
more, the means of preventing generation of leachate, including technologies
to prevent infiltration and leachate collection and treatment under the Turn-
pike property, is proposed under this alternative to be determined during RD.
**The Consent Decree for the IWDU requires ground water pumping to address
ground water contamination attributed to "the site". See Section V.B. of
the Consent Decree and Section 2.6.1 to SOW. The "two years of ground water
pumping for the IWOU" is specified for additional DDU ground water recovery
as part of this ROD simply to coordinate D3U pumping with the Final O&M
Phase Plan for the IWDU. As described in Section 2.6.1 of the IWDU SOW, "if
contaminated ground water is found to be bypassing the collection system
(as determined through perimeter ground water monitoring), additional recovery
wells will be installed and/or pumping reates will be adjusted to create a
suitable cone of depression." Thus, ground water pumping beneath or downgradient
from the icu may commence during RD for the IWDU if the above criteria are met.
Remedial objectives to contain site-related ground water overlap for both
operable units.
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26
. Ranoval of surface oil-contcrninated soils, containerized hazardous
wastes, or highly contcrninated soils, if encountered:
. An exparded monitorinJ proJram over that recatmerded in the FS am
biannual evaluation of data ard remediation performance:
. Coordination with no] RD/FA in grouoo water pumpi~ am monitorinJ,
characterizinJ ard evaluatinJ the western portion .of the site,
evaluatirr.J am reporti~ on I.CXJ RD/FA performance, anj determini~
over the 10l'k;rtetm when ard whe~er remedial oojectives are met.
(b) Description of Canponents of Alternative 8 - As part of Alternative 8,
a short-term leachate collection program wOJld be designed ard implemented to
initially remove existi~ leachate fran the central ard eastern portions of
the rDU, includi~ the Turnpike aoo Conrail properties. '!his initial leachate
collection is expected to reduce the transport of contcrninants in existi~
leachate to grouoo water aoo thereby significantly reduce the risk. !he
initial leachate collection program wOJld be Unnediately followed with a long-
term leachate collection program, usi~ french drains. '!he locations of these
drains would be identified duri~ RD. Potential lateral infiltration of water
on-site fran the Turnpike prq;>erty or fran other off-site locations WOJld be
addressed in RD.
As described urder Alternative 3, leachate may be treated either on-site
wi th collected grOJoowater, at the local sewage treatment plant, or at an
off-site cam\ercial treatment facility. '!he leachate treatment ard disposal
option, to be selected duri~ RD, will detetmine respective performance
staooards. . Exhibit 17 includes potential ARARs for leachate treatment.
Alternative 8 includes a PA Solid Waste cap. This type of cap WOJld
provide the sarne degree of contairment as a RCRA cap but for less cost. The
PA cap would exterd over the eastern ard central portions of the site up to
the Turrpike prcperty, am include contaminated portions of the cdjacent
Conrail prcperty to the south. '!he cap would be designed to address
potential lateral migration of leachate into the capped area fran off-site
areas, includi~ the Turnpike prcperty. Since the Turnpike property will
be excavated in order to accanodate Turnpike expansion,~e PA cap was assumed,
for costi~ purposes, to oot be needed over that cdjacent area to the site.
Leak~e of the water main which runs through the eastern portion of the
site would interfere with remedial oojectives. Alternative 8 includes ad-
dressi~ potential leak~e durin;} RD. Sane options uooer consideration
include:
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27
(l)
excavation of contamination in vicinity of the pipe, runon/runoff
controls, encapsulation of the pipe with cement and leak detection
monitoring; .
(2 )
(3)
moviI'XJ the pipe further east of the site;
moviI'XJ the pipe frcm,the northeast corner of the site to
Henderson Road and alo~ the western perimeter of the site.
Option 2, estimated to cost about $1.5 million, is used for costi~
purposes. Option 1 is expected to be significantly less costly than cption
2 and Option 3 is expected to cost $2.5 million. Only if remedial cbjec-
tives and concerns raised by PA DER (see Responsiveness SUlTlt\ary) are met
waJld an alternative to fT\OIIi~ the water main be accepted.
In the draft FS, the respondents prcpose bituminous pavil')J OJer the
western portion of the site. Alternative 8 includes characterization of
contamination sources in the western portion of the site attributed to the
I.aJ - i.e., surface sources of contamination and hazardous substances expected
to be associated with cinders - as a supplement to the ~itional character-
ization planned for the vadose zone for the :rw:u RD/RA. I)Jril')J this charac-
terization, the three septic tanks arrl the floor drains in this area waJld be
remediated. "General Sccpe of Work to Characterize the Cinder Fill in the
Western Portion of the Henderson Road Landfill Operable unit," prepared by
Camp Dresser aoo McKee and dated July 7, 1989, describes work to be performed
as part of this additional characterization of the western portion of the
site. A Fate-ard-Transport Assessment, Risk Assessment, arrl Focused Feasi-
bility Study, or equivalents of these studies, woold be developed under Alter-
native 8 as part of RD/RA for the LOU in coordination with RD/RA for the
DQJto address. the cimers , soils, arrl unsaturated zone in the western portion
of the site. After the Focused Feasibility Study (or equivalent) is canpleted,
EPA woold select a remedy to address remediation in the western portion of
the site. This remedy woold be part of both cperable u~ts. Alternatives to
evaluate in the Focused Feasibility Study may include, ano~ others, in-situ
volatilization, soil flushi~ (see :rw:u roD), and various kirrls of cappirq.
Institutional controls, such as deed restrictions and easements, are
included in Alternative 8 to restrict any activities on-site, on the Conrail
property, or on other property( ies} that waJld interfere with the remedy.
Any activities that waJld jeopardize the int~rity of the Cap, such as truck
movement on the cap, or interfere with the leachate collection system waJld be
prohibited. Access aJreenents waJld be established where recovery and/or
monitori~ wells are to be installed or cperated and on the Conrail property,
where the cap and the leachate collection system are expected to be exterrled.
AR;>rq>riate institutional controls also ' would be implemented at other affected
prq>erties. These properties will be identified in RD.
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28 .
'n1e Consent Decree for the IVnJ requires groom water pumpi~ to address
groom water contamination attributed to "the site". '!be IvnJ SCA'l prq>oses
an approach to siti~ on-site recovery wells in locations anticipated to
address contamination most likely to be attributed to the injection well.
As described in this R:>D umer Alternative 7 arrl stated in the IVnJ &J.N, if
contaminated is fouoo to be bypassirg the collection systan, additional
recovery wells will be installed am/or pumpi~ rates will be adjusted to
create a suitable cone of depression. At least sane of the contaminated
groom water beneath the LCXJ may be contained on-site through the initial
groom water plUY\pi~ anj treatment planned for the rw:u. However, since
grouoo water may be affected by both operable units am records are oot avail-
able to distirguish contaminants originati~ fran either the IvnJ or LCX.J, the
criteria for initiatirg groom water recovery proposed umer Alternative 7,
Le., "if the LCXJ contributes to groom water contamination", is infeasible.
. Alternative 8 includes installation of I.DU rronitorin:J wells early in
RD am initiation of additional groom water recovery for theIDU if:
.
requiranents for clean-up of groom water are exceeded at or near
the facility boumary, am
groom water is still leavirg the site after rw:u recCNery wells are
operatirg.
'n1ese criteria are essentially the same as that for additional on-site groom
water pumpi~ associated with the IVnJ.
To the maximum extent practical, technically justified am cost-effective,
groom water recovery am monitorirg wells will be situated on-site . However,
recovery wells may be located off-site, such as on the Turnpike or PS\~ protr
erties, if such locations are detetmined to be ~timum for preventi~ an
additional dCJWn1radient release. '!bis criteria is consistent With the criteria
for off-site pumpirg described in Section 3.1 of the IVnJ SOW.
,
* .
Sectlon 3.1 of the :rw:u states:
'n1e followirg criteria will serve as a basis to determine whether off-
site pumpirg is warranted:
1. If it is detetmined that the area rorth of the Turnpike is ~tional
for controllirg further off-site release of contaminated groorrl water.
2. If data fran off-site monitorirg wells imicate that off-site, down-
gradient groom water contamination is similar in concentration curl
chanical canposition to that detected on-site (near source) ."
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29
The draft Feasibility Study does not clearly indicate when a deter-
mination walld be made to initiate and/or enhance ground water recovery for
the r.aJ. under Alternative 8, a preliminary recarmendation woold be made
after rDU grourd water monitoril"kJ. wells are installed and sampled as part of
or as a supplement to the unsaturated ard Sat~rated Zone{ s) Investigation
Report { s), to be submitted un::ier the Iw:xJ Consent Decree, an::i as a final
recarmendation in the :rw:u Design an::i Construction Phases Plan or as a sup-
plement to the Design an::i Construction Phases plan, shoold canbined recan-
meooations for initiation of groond water recovery for both cperable units
cause a delay in the :rw:u RD/RA. Further:rnore, the performance of ground
water recovery activities woold be evaluated an::i recarmendations. to improve
or enhance perfomance of the LCXJ remedy woold be proposed on a biannual
basis in synchrony with or as a supplement to the O&M Biannual Evaluation
Reports. The function an::i contents of the ab::>ve plans an::i reports are.
described in the SCM attached to the It'nJ RD/RA Consent Decree. Improvements
an::i enhancements to r.aJ remediation woold be deter:rnined alo~ with the EPA
Five-Year Evaluation for the Iw:xJ. Such coordination of RD/RA for both
c.perable units will ensure that the remedy for the site will be implemented
an::i evaluated in the roost technically soon::i an::i cost-effeCtive manner.
The Turnpike property is of particular concern because:
State records indicate liquids may have been poured onto fomer
trenches located there (See Administrative Record for rDU);
only one test pit was scm1pled on the Turnpike property (several
were excavated an::i lCXJged there);
the Turnpike Carmission has expressed an interest in expandi~ the
Turnpike to six lanes - an q:>tion that is' expected to require
particular attention duri~ RD so that Turnpike expansion does not
interfere with EPA's remedial cbjectives.
Alternative 8 includes excavation of trash an::i sha140w soils an::i cin::iers
on the Turnpike prc.perty, disposal of excavated material on to the Henderson
Road site, post excavation soil sampli~, an::i backfilliR;1 the Turnpike property
to accamodate future Turnpike Carmission.expansion plans. .This alternative
also includes, for costi~ purposes, implementi~ runon/runoff controls,
leachate collection, an::i construction of an asphalt cap over 33,000 square
feet of the Turnpike property. Additional remedial measures on the Turnpike
property may be selected duri~ RD if the additional characterization there
iooicates additional remediation is need to prevent a release of contaminants
to grourrl water. To the maximllt\ extent feasible an::i casteffective, grourrl
water arrl leachate woold be recovered an::i monitoriR;1 activities woold be
coooucted off the Turnpike property in order to prevent a conflict between
Turnpike expansion activities arrl remedial efforts.
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30
.Al thcugh samplio:] on the Turnpike property has been limited, EPA expects
that contamination of the less mobile canpourrls, such as bis(2-chloroethyl)
ether, aldrin, ard PARs, will be most prevalent in the upper three-to-five
feet of soils ard cirrlers. Volatiles may already have moved deep into the
fractured bedrock ard aquifer. Leachate, if encountered in the shallow zone,
constitutes the major media of concern, since contaminants are expected to
be transported to groom water primarily in leachate. Imnediate collection
of leachate, if encaJntered, ard removal of shallow soils ard cirrlers beneath
the fill are expected to significantly reduce the volume of contCMttinants fran
the Turnpike property. 'n1e silty-clay soils beneath the three-to-five foot
zone wOJld be left on the Turnpike property because these soils are expected
to retard downward migration of future leachate to the fractured bedrock
below. Q.Jantitative soil clea~up starrlards are rot included in Alternative
8 because soil removal criteria are proposed to be based on depth fran the
surface - oot on concentrations of contaminants.
Design am construction activities related to widenio:] the Turnpike will
need to be consistent with remedial d:>jectives for the IaJ. .Additional 100:]-
tem leachate collection may be needed on the Turnpike prq;>erty if contami~
ation left in place, after excavation on the Turnpike property, is determined
to pose a significant risk. Lorg-tenn leachate collection on the Turnpike
property wOJld be addressed in RD, once the Turnpike Ccmnission has sutmitted
plans to EPA regardio:] potential widenio:] of the Turnpike ard after the poten-
tial direction of leachate flow beneath the laoofill is identified.
'n1e Laoo Ban wculd require that hazardous wastes, . if excavated after
cappio:], must be treated prior to off-site disposal. Excavation fran the
Turnpike property ard o~site placement prior to cappio:] wculd cddress the
Turnpike Ccmnission's concerns am meet Laoo Ban requirements. Excavation,
incineration, am off-site disposal after the cap is installed are estimated
to cost about $6 million. Excavation ard o~site disposal, as included in
the selected remedy, is estimated to cost about $350,000. .Additional costs
pertaini~ to excavation, cappirg, post-excavation soil samplirg ard Q&Mat
the Turnpike property will total $238,139. '
As with aIrj older solid waste unit, there is potential for encounterirg
one or roore containers of hazardous waste durirt,;J RD/RA. In addition, o~site
soil samplirg durirg the RI in:iicated that oil-contaminated soils, especially
near car-truck garage maintenance areaS, may be contaninated with particularly
high concentrations of PARs. Removal of such containers ard oil-contaminated
soils wwld be -implementable arx1 cost-effective. Removal of shallow oil-
contaninated soil is expected to remove surface PARs ard thereby reduce the
risk fran inhalation ard io:]estion of dusts ard fran migration through infil-
tration am surface runoff. 'n1ese materials wOJld be disposed in canpliance
with Lan:i Ban requirements. .
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31
MonitoriOJ data collected from leachate, the vadC\Se zone, and groorrl
water woold be used to evaluate the. effectiveness of the remedy in preventiOJ
leachate generation arrl thereby minimize the release of contaminants to
grourrl water. Surface water IOOnitoriOJ woold support evaluation of possible
impacts on the stream adjacent to the site. Larrlfill gas monitorio:J woold
characterize gas migration duriOJ O&M in order to retrofit the cap shoold
gas buildup threaten cap integrity. 'tt1e monitoriOJo pr~ram woold OS developed
duri~ RD.
The same statistical approach to groorrl water IOOnitoring and to deter-
mini~ when and how to terminate pumpirg, to be developed as part of RD for
the UnJ, will be applied urrler Alternative 8 for the tOO. At a minimum, the
vadose zone arrl groorrl water IOOnitoril'\J prcgram to be designed for the rDU
woold include the same frequency and constituents as the Iw:xJ rrDnitori~
program. The chanicals of concern listed in Exhibit 15 and others as appro-
priate will be included in the IOOnitoriOJ prcgram for both cperable units.
(c) Vollm1eS of Contaminants Left On-site - Uooer Alternative 8, approx-
imately 125,000 cubic yards of trash, approx~ately 33,000 cubic yards of .
cirrler fill and an urrletermined volume of deeper contaminated soils and . .
bedrock woold be left on-siteo 7,965 cubic yarrls* of trash, cirrlers, and
underlyiOJ fill/soils fram the Pennsylvania Turnpike property will be
consolidated onto the site. An estimated 2.5 million gallons of existirg
leachate arrl 3,000 gallons of leachate estimated to otherwise be generated
each year will be directly removed and treated.
(d) Risk Reduction - Alternative 8 - The Risk Assessment for the I..OO was
based on the predict ion of the fOC)vanent of contaminants foorrl in leachate,
cirrlerfill, soils and shallow sed~ents sanpled pr~arily in the central
and eastern portions of the site arrl on adjacent properties. The Fate-ard-
Transport Assessment predicts that groorrl water affected by surface disposal
is and/or may in the future be contaminated with bis(2-chloroethyl)ether arrl
volatiles at levels that present significant risk. Irgestion of soil and
inhalation of fugitive dusts constitute the next highes~risk pathways for
carcinogens. 'tt1e selected remedy focuses on these risk pathways.
*5,230 cubic yards of cinders and trash plus 2,735 cubic yards of soils.
See "Letter Report, volumes and Gross Estimates for Excavation of Fill
Material and Soils in the PA Turnpike Prq:>er:ty," prepared by Camp Dresser
and McKee, Inc. and dated August 14, 1984.
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32
Runoff am erosion controls am a PA cap are expected to reduce groom
water carcir1CXJenic risk f~r the duration of 9gM by more than three orders of
m~nitude, fran 8.4 x 10- to about 8.4 x 10-. Leachate collection is
expect~ to further reduce risks ~y...one-half, resultin;j in groom water car-
cir1CXJenic risk 9f about 4.2 x 10-. 'Ibese technologies specifically
wc:uldreduce leachate, which is considered the medium of greatest concern.
Additionally, cappin;j woold eliminate the next highest risk pathways for
carcir1CXJens, i~estion of soil am inhalation of fugitive dusts by on-site
workers. '!bus, the total upper-boum excess 1ife~ime risk to a maximally
exposed imividual for Alternative 8 is 4.2 x 10- .
(e) -';raJm Water Clean-up Goals - Exhibit 15 lists groom water Clean-up
ARARs proposed for both operable units. Nine of the chemical-specific groom
water clean-up ARARs proposed in Exhibit 15 for the u:xJ are included in the
list of groon::l water clean-up ARARs for the noJ. In order to achieve consis-
tency with the IWXJ, the runerical value of the chemical-specific ARARs are
the same for both operable nits. For the ten remaininJ chemicals, EPA used
the same process of se1ectinJ numerical groon::l water clean-up ARARs, described
below, as for the noJ. As stated in the Declaration to this roD am in the ItfiJ
~D, aquifer clean-up ARARs will be reevaluated as part of EPA'S Five-Year
Rev iews.
Groum water clean-up ARARs woo1d be updated as the aquifer is charac-
terized further duri~ RD/RA for both operable units. specific criteria for
detez:mininJ whether groom water is 1eavi~ the site, which will apply to
both operable units, will be determined duri~ RD for both operable units,
based on water level am other relevant information to be collected as part
of groom water monitorinJ durinJ ItCJ groom water- recovery. .
EPA selected aquifer restoration in the IWXJ ~D as the clean-up goal
for the site because data uncertainties am canp1exities related to the
ffiOIJement of wastes through the aquifer make predictions difficult regardi~
potential off-site release which woo1d pose a risk to human health anj the
envirorment. Uooer Section 121(d)(2)(B)(ii) of SARA, alternate concentration
limits may not be applied at the property line if human exposure may occur
beyooo the bouooary of the facility unless:
(I)
there are kn:JWn am projected points of entry of groon::l water into
surface water;
(II)
on the basis of measurements or projections, there is or will be no
statistically significant increase of constituents fran groon::l
water in surface water at the point of entry or at arrj point where
there is reason to believe accumulation of constituents may occur
downstrean; am
... 'Ibis risk value should be Canpared to ~at derived for the LOO if groon::l
water clean-up criteria are met (4 x 10- ) as listed in Exhibit 18. .
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33
(III )
the r:-emedial action includes enfor:-ceable measur:-es that will pre-
clude human exposur:-e at any point between the facility bourrlary
arrl all known or pr:-ojected points of entry of ground water:- into
surface water.
EPA was oot pr:-epared to conclude that the existin;; measurements for:- projec-
tions establish that ther:-e is or will be no statistically significant in-
crease of constituents as described in (II) above.
i.
I
Grcund water clean-up criteria (ARARs) proposed in the IW:U RJD wer:-e
based on the most conser:-vative value dedved fran the followin;;: r1aximum Con-
rminnr Lwcwla (MXLs), Maximum Contaminent Level Goals (MCLGs), Aquatic Water:-
OJality Criteria, Drinkin;; Hater Equivalent Levels, Suggested No Adverse Effect
Levels, models developed durirg the Risk Assessment, processes descdbed in
the Superfurrl Public Health Evaluation Manual, arrl specific values accepted
by EPA (where no other ARARs exist).. Consistent with EPA Interim ARAR
Guidance dated July 14, 1987, MCLs, where available, were used. These wer:-e
based on identifyin;; the aquifer of concern as a:tUivalent to a Class IIA
Aquifer, a curr:-ent source of drinkirg water. Ai thcugh more r:-ecent guidance.
now allows EPA to select grcund water clean-up goals that are more protective.
than MCLs, the same approach to developin;; AAARs. for grourrl water is needed
for both q>erable units. 'tt1e stron;; emphasis on periodic r:-eevaluation of gr:-ou
water clean-up goals in both R:)rs will allow flexibility in r:-esporrlin;; to new
guidance arrl new data on the site.
Five canpourrls consider:-ed to be r:-egional contaminants (l, I-dichlor:-oethane,
l, 2-dichloroethane, benzene, trichloroethene arrl l, 2-dichlor:-opropane) were
propcsed in the rw:::u ROD to be remediated to the most conser:-vative value of
the following three criteria:
. Average concentrations of the canpourrls in the Estock, Hubin;;,
arrl HR-l wells, to be m:x:iified as additional backgrourrl wells are
~~oped~ ,
. Average .concentrations of the canpourrls in wells on-site (excludin;;
HR-2-l95, HR-4-l95, HR-4-295, HR-S-l92, arrl HR cluster lb
. Prqxsed chemical-SPecific AAARs for a Class IIA CGUifer multiplied by
a dilution factor of 33 as discussed in the IVU.J PS.
AAARs propcsed in the rw:::u ROD were based on the assumption that r:-egional
grcurrl water contamination wculd not change in the future. The IWJJ ROD .
states that the target criteria for r:-egional contaminants could be d1anged,
usiOJ the same criteria listed above with averages r:-ecalculated with new
values, if backgrcurrl contamination increases.
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34
( f) AAARs for Discontiruance of Ground Water ~ - One approach to
detemine when ard whether to discontinue pumpirq will be used for both q>er-
able units. As with the IWXJ, grourrl water clean-up criteria woold be applied
to grourrl water quality monitored at both recovery arrl monitorirq wells. The
q>eration of the grourrl water recovery and treatment system may be discon-
tinued when the upper limit of the mean concentration of each indicator
parameter (fran the five mast cOntaminated monitorirq arrl/or recovery wells
associated with the grourrl water treatment arrl recovery system as defined by
each pericd of samplirq or other basis to be determined in PD) is. less t."'lan
the appropriate clean-up criteria. A statistical tool, such as the Student IS
T Test, woold be used to define the upper rarqe within which the mean concen-
tration of a representative sample woold occur. The upper limit of the sample
mean must be below the specified clean-up criteria for foor consecutive quar-
terly monitorirq events before t."'le treatment system woold be discontinued.
This will ensure that seasonal fluctuations in site Coo:Htions are considered
in the evaluation. If sufficient information determines that regional influ-
ences are responsible for the cbserved levels of contaminants above the
specified criteria, the criteria may be waived for these ccrnpourrls. . The
pump-arrl-treat system wooldbe reactivated if the concentrations of the in-
dicator parameters show a statistically significant increase above the clean-up
criteria in two consecutive quarters.
Individual groooo water extraction wells may. be removed fran the grourd
water recovery arrl treatment system irrleperrlent of full system shutdown. If
groorrl water contaminant levels. fran an iooividual extraction well are below.
the clean-up criteria for four consecutive quarters, then the well may be
taken off-line. r10nitorirq of off-line wells woold continue on a quarterly
basis. The reaction of grourrl water quality at other wells fran the shut-
down of irrlividual extraction wells also wwld be cbserved to ensure that
the effectiveness of the grourd water recovery arrl treatment system is main-
tained. A discontinued well wwId be reactivated as a recovery well if the
concentration of the io:Hcator Parameters durirq the quarterly ronitorio;]
exceeds the clean-up criteria for two consecutive quart.-s. Pqain, require-
ments for recovery well or system shutdown for these parameters that are
regional contaninants may be waived if sufficient information detetmines
that regional influences are responsible for the cbserved contaminant
concentrations.
(g) perfonnance Criteria (ARARs) for Grourd Water Treatment - ARARs for
grourrl water treatment will be based on the discharge q;>tion to be selected.
For discharge of the treated effluent to Frog Run, canpliance with NPDES
disharge petmit requirements, which include the PA Toxic Strategy, woold be
applied.. PA DER may require that discharge at the property boundary must oot
adversely impact water quality ard 'GUatic life at the point wh~re it discharges
into the point of continuous flow ard that treatment to the 10- or 10-6
cancer risk level. be achieved.
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35
If part of the treated water is discharged back to the groord water
through an infiltration gallery to "flush" the unsaturated zone, drinkin:J
water stardards or human health criteria, whichever is more strin:Jent, woold
apply to the treated effluent. 'tt1e equivalent of an Uooergrourd Injection
Well petrnit aoo relaware River Basin Carmission approval woold be needed for
this disposal option.
(h) perfoItnance Criteria (ARARs) for Air Emissions - Exhibit 17 to the nOl
ROD lists air quality guidelines that woold apply to air amiss ions fram air
strippers or any other treatment options implemented at the site. Furthermore f
if VOC emissions are determined to jeopardize the attainment of the ozone
staooard, emission controls woold be required to reduce VOC emissions to an
acceptable level. 'tt1is determination woold be made by the PA DER on a case-by-
case basis. . .
(i) perfoItnance Criteria (ARARs) for Off-site Disposal - EPA'S Off-site
Policy prooibits the use for off-site disposal of hazardous waste of a facility
that has significant outstaooing Class I violations under RCRA. 'tt1ematerials
that are expected to be disposed off-site woold be soil excavated fran shallow
oil-stained areas, cuttin:Js fran the drilliBJ of wells, and contaminated
equipnent or garb used by workers. '!he applicaation of the Land Ban for dis-
posal of these materials will need to be considered.
(j) Costs - Costs associated with Alternative 8 are described in the
followiBJ documents, which are included. in the Administrative Record for the
LCXJ :
. "General. Scope of Work to Characterize the Cinder Fill in the Western
Portion of the Henderson Road Landfill q>erable Unit," prepared by
Camp Dresser & McKee, Inc., dated July 7, 19891
. "Henderson Road Landfill eperatin:J unit Estimated Costs of EPA preferred
Remedy, It prepared by Camp Dresser & MCKee, dated July 11, 19891
. "Henderson Road Lardfill q>erable unit Estimated~osts of EPA Preferred
Remedy," prepared by Camp Dresser & McKee, Inc., dated July 21, 19891
. "Vol\Jnes and Gress Cost .Estimates for Excavation of Fill Material and
Soils on the Pennsylvania Turnpike Property," prepared by Camp Dresser
& McKee, Inc., d4ted August 14, 1989.
'!hese costs are sl.UTlt\arized in Table 1
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36
TABLE 1
HENDERSON RJAD LOU
ESTIMATED COSTS Of EPA' s PREfERRED REliEDY
Annual
Estimated Operation am Total
Construction Maintenance Present
Item Cast Cast ($/yr) Worth (1)
Alternative 3 2,472,000 96,700 3,475,000
Alternative 7 444,600 104,000 1,523,.000
Turnpike Excavation
& Remedial Action 509,012 6,060 566,139
Soil & Container
Removal 89,900 N/A 89,900
Western Portion
Characterization
Evaluation 42,000 N/A 42,000
Biannual Evaluation N/A 6,500 29,170
Characterization of
Low petmability Layer
Beneath LOU 17,500 N/A 17 , 500
Potable tiater
Line Relocation 1,500,000 N/A 1,500,000
Post Excavation
Soil Samplirg at
Turnpike Prcperty 22,000 N/A 22,000
Total 5,097,012 213 , 260 7,264,709
(1) Canplted for a 30-year study pericd at cost of capital equal to 10%
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37
VIII. SUMMARY OF Ca-1PARATIVE ANALYSIS OF ALTERNATIVES
In the draft FS, the infoz:mation fran the draft RI for the LOU was used to
identify, screen am evaluate six alternatives plus one conti!'}Jent alternative
for addressi!'}J the risks posed by the LOU. .
Alternatives 1 through 7 do not address how remediation of the LCU Wa.1ld
be coordinated with the canplex remediation planned for the It'nJ, do rot ad-
dress the Turnpike Carmissions' s request to excavate on the Turnpike property,
nor PA DER's concern that the water line on the eastern portion of the site
. shoold be moved. '!he followi!'}J factors were considered durirg the FS in
screeni!'}J arrl evaluati!'}J the alternatives:
(1)
(2)
protectiveness of human health am the envirorment;
conformance with statutory requirements. Major requirements include
restori!'}J the cquifer beneath the site to Class IIA Aquifer standards,
State closure requirements for cappi!'}J, leachate collection,
am groom water monitori!'}J, perfotmance stamards for discharge of
groorrl water am leachate into Matsunk SewCkJe Treatment Plant or
Frog Run, or reinjection into the aquifer am State air emission
requirements;
(3)long-tetm effectiveness.
petmanent solutions are preferred;
(4 )
(5)
short-tez:m effectiveness;
~plementability i.e., technical am administrative feasibility;
(6)
(7)
cost;
reduction in volume, toxicity am lOObility of waste. Eln1;i1asis is
placed on treatirg wastes on-site, wherever possible, am applyi!'}J
inoovative techoologies;
(8)
(9)
,-
state acceptance;
anticipated ccmnuni tyaccept;:l "'e.
'!hese nine factors are canpared in Table 2 am discussed below.
'--,----.-
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38
TABLE 2
SlJMoV\RY' OF DETAILED AL~IVES EVMJJATED IN FS
H~ tn\D LANDFIt.L OPERABLE UNIT
AI terT'lative
DeScription
No action/minimal action
- fencirq
- deed restrictions an:1 access
agreements
- rronitorirq
1.
2.
(a) OCRA cap
(b) PA solid waste cap
- bi tuminaJS cap for cinders
- deed restrictions an:1 access
agreements
- rronitorirq
3.
- Leachate collection an:1
treatment
(a) OCRA cap .
(b) PA solid waste cap
- bituminous cap for ciroers
- deed restrictiors an:1 access
agreenents
- rronitorin;1
- In-situ volatilization
- leachatecoll. & treatment
(a) ICRA cap
(b) PA solid waste cap
- bituminaJS cap for ciroers
- deed restrictions an:1 access
agreenents
- rronitorirq
5.
- Partial excavation
(a) off-site incineration/off-site
disposal
(b) off-site disposal only
- FA solid waste cap
- bituminaJS cap for cinders
- deed restrictions an:1 access
agreenents
- rroni tori n;1
*
Key Evaluation Criteria
Unacceptable risk ClxlO-2).
Cest
$
1,077,000
ooes rot address present
leachate, major media of
concern. ooes rot reduce
volune or toxicity. Eliminates
air exposure an:1 reduces gtQJro
water risk three orders of
magnitude (Risk. 8X10-6).
(a)$ 3,420,000
(b)$ 2,696,000
Leachate collection reduces
gtQJ~ water risk by one-half
(4xlO ). Reduces mc:bility
toxicity, an:1 volume.
(a)$ 4,199,000
(b)$ 3,475,000
More reduction in lOObility, (a)$
toxicity, aR1 volume, an:1 risk (b)$
reduced by another one quarter.
However, rot expected to oe
su~essful an:1_g:?t cost-effective
(Risk:: 3 x 10. ).
7,332,000
6,609,000
(a) SOrtirg of processable
an:1 norprocessable wastes
(a)$ 12,621,000
would be difficult.
(b) Lard ban would preclude.
Risk s1 ightl y less than
Alternative 2, based on sane
volume of 1e~ate produced
(Risk <8x10- ).
(~$ 5,696,000
*
Key Evaluation Criteria in this rm are different than these presented in draft Table
5-1 of draft FS, oecause EPA disagrees with the resporoents' approach to assessirq
risk for each alternative an:1 certain major reasons for eliminatirq/selectin;1
alternatives that are described in draft FS.
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39
StH1AAY OF DETAILED AL~IVES EVALUATED IN FS
~ R)A[) lANDFrtl. OPERABLE UNIT
Alternative
Description
6.
- Major excavation
(a) off-site incineration/off-site
dispa;al
7.
- Conti~ency groum water
recovery an:\ treatment
8.
PREFERRED RENDY
- .Alternative 3b
- Alternative 7 in coordination
wi th rw:1J
- characterization of low
permeability layer beneath raJ
- potable water line relocation*
- oil stained, shallow soil an:\
container removal
(b) off-site dispa;al only
- limited PA solid waste cap
- limited vegetative coyer
- bituminous cap for cimers
- deed restrictions an:\ access
~reenents
- monitorirg
- 1\irrpike excavation, remediation
an:\ lORJ-term c:.M
- additional investigation an:\
remediation in western portion
of site in coordination with
IW:1J
'- biannJal evaluation
- post excavation soil sanpli~
at 1\irrpike property
.;. TOtal
Key EValuation Criteria
(a) SOrti~ of ;;>rocessable
an:\ oo",rocessable wastes
would be difficUlt.
( b) Lam ban would ;;>reclude.
Eliminates major source, but
sane contanination still left
an:\ leachate still to ~
generated (Risk <8xlO- ).
Meets ARARs for groum water
an:\ is protective. No source
control an:\ does rot address
air/soil exposure.
Feasible, will meet ARARs, &
focuses on major media of
concern (leachate). Attention
to water line am characteri-
zation in western portion of
site is more protective than
Al~rnative 3 (Risk < 4 x
10 ).
Cost
(a)$13l,137,000
$
1,523,000
$
$
$
3,475,000
1,523,000
17,500
$
$
1,500,000
89,000
(b)$ 38,316,000
$ 509,012
, $ 42,000
$ 29,170
$ 22,000
$ 7,264,709
Relocation of water line, at $1.5 million is included for costi~ p.lrposes. Alternate
e~ineeri~ solutions also may be considered in RD. Remedial cOjectives an:\ PADER
concerns must be met.
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40
Alternative 1 - No Action/Minimal Action - Alternative 1 was rejected
because it woold result in an unacceptable risk.
Alternative 2 - Runon, Ruooffam Erasion Controls anj Cappil'!1 - A RCRA or
PA cap woold enhance runoff, control erosion, contain hazardous substances in
the fill, and pravent exposure to contaminated materials through direct contact,
dust or vapors anj minimize filtration of water into the fill material. Mo~
itoring woold serve to identify the effects of site cperations as described. in
AI ternati ve 1.
However, this alternative woold not directly remediate leachate, trash,
fill, or ground water presently o~site, woold leave landfi11ed wastes in place,
and woold not add~ess how remediation of the UJU woold be coordinated ',Jiith the
canplex remediation planned for the IVnJ. '!he effect of an asphalt cap (per
the western portion of. the 'site is unknown, since this portion of the site has
not been adequately characterized. Finally, Alternative 2 woold oot address
ground water that is already contaminated.
Alternative 3 - Runen, Runoff am Erasion Controls, Cap~i~, and Leachate
Collection - '!he leachate collection system woold drain liqulds presently
accumulated at the base of the landfill and collect residual leachate once
the cap is installed. As in Alternative 2, protectiveness of human health
anj the envirorment woold be addressed to the extent that surface ruooff and
future leachate generation woold be reduced. By providing a means to directly
monitor leachate within the landfill, this alternative would provide additional
effectiveness monitoring of the cap during O&M.
However, existing leachate woold oot be recovered as quickly as possible
and landfilled wastes woold be left in place, possibly above health-based
levels over the long teDn. '!he FS does oot indicate how remediation of this
operable unit woold be coordinated with the IVnJ. '!he effect of an asphalt
cap CNer the western portion of the site is unknown. Finally, this alterna-
tive would not address groum water that is already contaminated.
Alternative 4 - Ruoon, Ruooff am Erosion Controls, ~inJ, Leachate
Collection am I~Situ Volatilization - This alternative would reduce infil-
tration of water through the landf ill, cOntain hazardoos substances in the fill,
soil, anj leachate, prevent exposure through airborne dusts anj vapors, anj
would provide for the rerooval am treatment of any liquids or gases emanatin:]
fran the unit for the duration of O&M. Toxicity arx1 mobility of contaminants,
includi1"k1 volatiles which canprise about one quarter of the risk associated
with grourrl water, would be reduced sanewhat through treatment of leachate
and gases. If Alternative 4 reduces volatiles statutory requirements for
clea~up would exceed RCRA closure requirements. FurtheDnore, i~situ vola-
tilization is considered an inoovative technology. .
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41
AI thoogh the volume 6f wastes may be sanewhat reduced with in-situ
volatilization, this technology is not expected ~o achieve a substantial
reduction in volatile organic canpound volume nor to address bis(2-chloro-
ethyl) ether. Bis(2-chloroethyl)ether is not very volatile but canprises
about three quarters of the carcinogenic risk associated with groond water.
Thus, many wastes canprisi~ ItOSt of the risk, includi~ volatile organic
canpounds and bis(2-chloroethyl)ether, would still be left in place.
As in Alternative 2, existi~ leachate woold not be recovered as quickly
as possible under Alternative 4. The FS does not indicate how remediation of
this ~rable unit woold be coordinated with the Iw:xJ. The effect of an
asphalt cap is unknown as discussed above. Finally, contaminated ground
water woold not be directly addressed through this alternative.
Alternative 5 - Dewateri~ and partial Excavation, off-Site Dis~al,
Rumn, Rumff and Erasion Controls' and PA Solid Waste Cap - Incineratlon and
.landfilli~ of excavated waste woold result in a reduction in volume, toxicity,
and rrobility. Based on incineration and .land disposal resulti~ in generation
of leachate in volumes. and' concentrations about ~al to Alternative 2,
Alternative 5 woold reduce toxicity and mobility only slightly when canpared
to cappi~. Furthermore, acute hazardous wastes warranti~ ircmediateexca-
vation to reduce risk were not foond duri~ thelU. 'Ibis alternative may
actually increase short-term risks via air-borne dusts and vapors.
Alternative 5 woold be difficult to Unplement due to sorti~ problems. .
'Ibe FS does not indicate how renediation of this operable unit woold be
coordinated with the ImJ. The effect of an asphalt cap over the western
portion of the site is unknown. Finally, this alternative does not address
ground water that is already contaminated.
Alternative 6 - Dewateri~ and Major Excavation, Off-site Dis~al,
Limited PA Solid Waste C~, Llmited Vegetative Cover - ~ll excavatlon,
treatment, and off-site dlSposal woold achieve a peI1'l\anent solution, and
result ina reduction in volume, toxicity and lOObility of chemicals of concern.
Mcst of the risk associated with the landfill woold be addressed under this
alternative. Alternative 6 is expected to meet lon;rterm ARMs.
However, contaminated soils and cinders ootside the area identified
as "saturated" woold be left in place, so that infiltration could still
release contaminants to the ground water. Full excavation and incineration
may increase short-term risks via air-borne dusts and vapors, be difficult to
implement due to sorti~ problans, and is oot considered ccst effective.
The FS does rot indicate how renediation of this operable unit wo.Jld be coor-
dinated with the Iw:IJ. 'Ibe effect of an asphalt cap on the western portion
of the site is unknown. Finally, this alternative does rot address ground
water that is already contaminated.
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42
Alternative 7 - ContiI'Xle~ Grcurd Water Recovery ardTreatment - This
alternative would prevent addltlonal off-site releases of contamination to
the regional aquifer. OVer a loI'Xl perioo of time, on-site grourd water con-
taminaton may be reduced to sane degree ard the grourd water risk would be
reduced. However, grOl1rrl water pumpiOJ alone wwld not address surface sources
of contamination.
. Alternative 8 -. Cappil'l1, Short an:i Lol'l1-Term Leachate Collection, Turnpike
Excavation, GraJrd Water Pumpil'l1, Coordination with IW:XJ-Al~ernative 8 focuses
on the primary risk pathways - leachate arrl airt>orne dusts - an;:} therefore is
the alternative most protective of human health an:i the envirorment. The PA
cap an:i leachate collection system are expected to meet state requirements.
Consolidation of materials fran the Turnpike property to the Heooerson Road
Site is expected to canply with Lard Ban requirements. Short-tem leachate
collection ard removal of oil-contaninated soilsan:i containerized waste, if
encountered, would pranote short-tem effectiveness.
Alternative 8 is the only alternative that mresses the need to ensure
that the ~ water line does oot interfere with remedial objectives. PA DER
has expressed additional concerns (see Responsiveness S1..II'!I'I\aIY). As p~rt of
Alternative 8, criteria for designiI'Xl a means of addressiI'Xl these . concerns ,
to be applied duriI'Xl RD, will include requirements that remedial d:>jectives
ard State AAARs are met.
Excavation of the Turnpike prc:perty is consistent with the PA Turnpike
C~ission's request. However, the Turnpike Ccmnission has requested that
the costs of additional characterization work, to be perfomed by the Turnpike
Ccmnission, be reirobursed fran the respordents an:i that institutional measures
not hirder future expansion in any manner. Such costs are oot included in .
Alternative 8.
Public carments on the Proposed plan are addressed in the Responsiveness
S1..II'!I'I\aIY .
IX.
'mE SELECTED REMEDY
A. SUIIItIary of Major Factors arrl Criteria Associated with Selected Remedy
EPA developed Alternative 8 as the selected remedy based on consideration
of the followiI'Xl:
. protection of human health an:i the envirorment an:i canpliance with
ARARs, in light of the uncertainty related to a potential off-site
release (discussed in the Iw:IJ roD) an:i uncertainty regardiI'Xl the
groorrl water risk posed fran the western portion of the site:
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43
. the overall implementability of each alternative; Le., direct source
control options, such as in-situ volatilization or excavation and
control options, such as in-situ volatilization or excavation and
treatment, are expected to be difficult to implement successfully;
. the need to coordinate, with RD/RA planned for the rtUJ, predesign
activities proposed am remedial action to be selected for the
western portion of the site, groum water recovery, site monitoril"kJ
am reporti~, am all canpliance criteria:
. plans umer development by the Turnpike Carmission to widen the
pennsylvania Turnpike;
. the need to implement short-tetrn remedial options, where appropriate
am cost effective.
While Alternative 1 through 7 ajdress sane of these considerations to .
sane. extent, no Alternative listed in the draft FS, alo~ with conti~ent
Alternative 7, adequately addresses all of these. . .
Alternative 8, developed by EPA arrl selected as the remedy for rDU, is
believed to provide the best balance of trade-offs amol"kJ alternatives. EPA
expects this alternative to be protective for as 101"kJ as the remedy is operated
am maintained. The selected alternative will reduce the risk fran ground
water, soil, fill materials, leachate arrl air to an acceptable level by:
(l) reducil"kJ the mobility of contaminants in soil, fill arrl leachate;
(2) preventi~ the generation of new leachate:
(3) reducil"kJ the potential for release of site contaminants through
fugitive particulate or vapor emissions: arrl
(4) containil"kJ groom water affected by the IaJ.
,
The selected roo remedy is consistant with the ImJ remedial oojective
to prevent a potential release to UMR. The selected remedy more effectively
meets the evaluation criteria for selecti~ a remedy, listed in Section VIII,
than Alternatives 1 throJgh 7. The selected remedy has the greatest potential
to meet ~ifer restoration ARARs both 00- arrl off-site. Also, the selected
remedy is expected to have the highest level of state am cam\unity acceptance.
The selected remedy potentially offers the highest level of protection
fran contamination both 00- arrl off-site by strategically locatil"kJ recovery
wells in coordination with the rw:u RD/RA. However, remediation of groom
water in fractured limestone is expected to be very difficult arrl other
soorces in the region may significantly contribute to ~ifer contamination.
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44
Furthermore, only a small volume of 'Hastes wOJld be reduced through leachate
collection arrl treatment arrl gas ventirq.
. The preferred alternative would leave larrlfilled wastes in place arrl may
result in hazardous substances remainirq on-site above health-based levels
over the lo~term. Therefore, as with the IVlXJ, a review will be corrlucted
within five years after cam\encanent of the RA for the LCXJ and every five
years thereafter throughoot O&M. This review. will involve evaluation of
whether technolCXJies implemented provide adequate protection of human health
arrl the envirorment, whether additional ranediation is appropriate, whether
prcx.;Jress is beirq made in meetirq clean-up goals, arx1 whether clean-up goals
shOJld be revised. EPA will corrluct this review for the LOJ, to the maximum
extent practical withooteffectirq a significant delay, simultaneously am in
coordination with the Five Year Reviews for the IVOJ.
B.Anticipated Charqes and Decisions to be Made ourirq RD/RA
Sane charqes may be made to the remedy as a result of the remedial
design arrl .construction process. Such charqes in general will reflect usual
mcrlifications resultirq fran the erqineerirq process. At a miniumum the .
followirq determinations associated with the LCXJ are anticipated to be made
durirq RD/RA: . .
. selection of remedy for the western portion of the. site (in coordin-
ation with IvnJ);
. selection of final design specifications for regradirq, cappirq (clay
arx1 vegetative cOVer are likely), and leachate collection at the
Tu~ike property after excavation;
. selection of final design specifications for the PA Solid Waste Cap;
. location of french drains;
,
. decision regardiOJ relocation of the on-site water main or design of
an alternate means of preventirq arrl detectirq leaks fran the water
main into the laOOfill am addressirq PA DER concerns;
. location am rumber of groorrl water monitorirq am recovery wells.
Determinations pertainirq to initiation of additional ground water
recovery, spec if ic treatment for the groom water, discharge of treated
ground water, am groom water pumpirq tetmination criteria, cmorq others, .
are anticipated to be made as part of RD/RA for the IVnJ (See Consent Decree
an:l RJD for :m:u). Such. detetminations will be applied to the LCXJ, as appro-
priate, so that only one set of criteria is applied for Lmplementation of
ground water recovery arrl roonitoriOJ fqr the site.
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45
c. Risk Level to be Attained
111e Risk Assessment for the LOU was based on the prediction of the move-
ment of contaminants foum in leachate, cimer fill, soils, arrl shallow sed-
iments sampled primarily in the central am eastern portions of the site arrl
on Conrail property. Based on the Fate-ard-Transport Assessment arrl the Risk
Assessment, grourxl water beneath. the site arrl on Conrail arxl 'furnpike Can-
mission properties may be contaminated with bis( 2-chloroethyl) ether am vol-
atiles at levels that present significant risk. I['XJestion of soil and
inhalation of fugitive dusts constitute the next highest risk pathways for
carcinogens.
As surrmarized in Exhibit 11, the upper-bourxl excess lifetime r~sk to
a maximally exposed irrlividual pr~icted for the LOU totals 1 x 10-. 85
percent of this risk, or 8.4 x 10- , is attributed to exposure to groom
water. As discussed in Section VI .B., 77 percent of this grouro water risk
is due to PAHs (60 percent), aldrin am PCBs (17 percent) which are oot
actually expected to be transported to grourxl water. .
Data fron wells drilled for the rw:::u are rot considerErl representative
of grouro water attributed to the LOU because the well locations are oot
representative of groom water affected or potentially affected by the larn-
fill aro. other surface soorces of contamination. '!he risk calculated for
the TICJ, based on maximum conc~ntrations of contaminantS fourrl in actual
on-site wells, totals 3.6 x 10-. The IvnJ roo proposes clean-up to a
7 x 10-4 risk level based on the chanical-specific ARARs propcsed in Ex-
hibit 16 to the Ivn.J roO. 111ese risk values are presented here for canpar-
ison with that predicted for the LOU as described above. Grouro water data,
to be collected fron additional wells for both the IVnJ am LOU, will enable
the risk assessment to be refined.
Runoff am erosion controls am a PA SOlid Waste cap are expected to
reduce groorxl water carcinogenic risk for the duration 9f O&M by about
three oroers of rtta.;1nitude, fran 8.4 x 10-3 to 8.4 x 1O-~ Leachate
collection is expected to further reduce rigks by one-half, resultirg in
groom water carcinogenic risk of 4.2 x 10- .. Cappirg will eliminate the
risk fran inhalation of fugitive gusts arrl i['XJestion of soil am result in
a total risk of less than 4 x 10- associated with the selected remedy.
'!he groom water carcinogenic risk assessed for the aquifer restoration
ct:>jective, based on achievirg Class IIA aquifer stamaros for the d1anicals
of concern proposed for the I~ am IDU am m<:x1if ied to addres~ reg ional
contamination am exc1udirg benzidine, is quantified at 4 x 10- (see
Exhibi t 18). Shoold backgroooo contamination increase or decrease i the
prq;x:sed alternate concentrations woold charge too.
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46
. ~risk level of less than 4 x 10-6 is within the ran:]e of risk of 10-4
to 10- , which is generally considered" acceptable" by EPA. However, canplete
aquifer restoration is not considered feasible becaus~ of background contam~n-
ation. 111e risk based on IW1J arrl u:x.J grourrl water clean-up goals, 4 x 10- ,
(excludin:] benzidine) exceeds EPA' s "acceptable" risk ran:]e. If higher standards
for groorrl water clean-up are determined to be feasible at a later time,
groorrl water clean-up ARARs may be chan:]ed accordin:]ly.
Because the nature, extent arrl location of hazardous substances disposed
into the LOU and injection well are uncertain, because backgroum contamination
may d1an:Je in the future, am because the remediation implementation timef rame
may exceed 30 years, EPA prcp03es conductin:] a formal evaluation of the clean-
up goals arrl progress in achievin:] these goals every five years fran the
carmencement of groorrl water pumpin:]. 111is evaluation WOJld be corrlucted for
both <:perable units to;}ether. Dependin:] on the OJtcane of these five-year
evaluations risk levels to be attained may change.
D.
Points of Compliance
Section l2l(d) of SARA directs the point of canpliance to be at the
property line. Monitorin:] wells will be sited to cbserve the effects of
groorrl water pumpin:J arrl mest effectively characterizegrourrl water flow arrl
quality. lhese locations may not directly coincide with the property line.
Clean-up criteria for groum water pumpin:] for the IDU are based achievin:]
ARARs in ground water beneath the site. 111is is consistent with clean-up
.criteria for groom water proposed for the IVlXl.
'!he point of canpliance for the grourrl water arrl leachate treatment
system will be at the point of discharge for the air stripper arrl prior to
artj mixin:J zone. '!he point of canpliance for anissions fran the air stripper
tower am larrlfill gas vents will be at the em of the stack or vent. .
x.
STA1Ul'ORY DETERMINATIOOS
A.
DeteIInination of En::ian:]ennent
'!he total carcincgenic risk predicted for the LOU is calculated at 1 x
10-2. Twelve d1anicals of' concern were WSed in derivin:] the carcincgenic
risk fran on-site groom water expcsure. The "Letter Report, Analysis of Con-
taminant Distribution am Fate-am Transport at the Herrlerson Road rArrlfill
q>erable unit" aOO Draft FS (paJes 4-39) conclude that the followin:] d1anicals
of concern are roobile aOO pose as the most significant threat to groorrl water:
* .
PAHs were canbined into . one group for the Risk Assessment (see Exhibit 16).
However, PARs aOO their associated grouro water ARARs are listed irrlividually
as d1anicals of concern in Exhibit 15. .
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47
. bis(2-chloroethyl)ether
. benzene .
. PCE
. TeE
Pdditional risk is posed fron i~estion of soils and inhalation of fugitive ..
dusts. These threats via exposure to grourrl water, soils, and air .constitute
an erda~errnent pursuant to section 106 (a) of CERCtA.
8.
protection of Human Health arrl the Environnent
The se~ected remedy is considered protective of human health and the en-
viroment. The treatment prescribed in the selected remfY for the LC(J is
designed to achieve an on-site risk of less than 4 x 10- , based on elim-
inati~ exposure fran inhalation of fugitive dusts and reduci~ leachate.
The existi~ on-site risk,. based. on predicti~ the movanent of leachate fran
the LC(J to grourrl water, is 1. x 10-2. .
The upper-bourrl lifetime risk to an irrlividual maximally exposed to
g~rd water in concentrations propOsed as ARMs in Exhibit 15 totals 4 x
10- (excludi~ benzidine, which drove the risk assessment calculation up
an additional two orders of ma:Jnitude because of its high detection limit and
high carcinoJenic potency). Since the approach for calculati~ risk for
chanicals listed in Exhibit 15 is furdClnentally different fran that based 00
reducin:J the volume of leach~te, it is rot surprisi~ that these risk values
differ. Even though 4 x 10- exceeds EPA'S "acceptable" risk ra~e, the
selected remedy is considered protective because it meat effectively cddresses
the considerations listed in Section VIII.
As described in the IVnJ roD, if 00 significant future off-site release
occurs, treatments at UMR is expected to continue to achievg a carcinogenic
risk of 4.4 x 10- (based on maximun values) and 1.8 x 10- . (based on
average values). Treatment at the McIlvain well as part ~f ImJ f" is
expected to reduce the carciInJenic risk there to below 1.0 x 10- .
For all excavation activities, measures will be needed to cddress
. dusts arrl odors durin:J construction. ~vorkers will need to wear protective
c10thi~ arrl equipment to reduce such short-term risks. Air pollution
controls will be implanented, if needed, to meet State air anissions re-
quiranents. .
c.
Attainnent of ARARs
Groorrl water clean-up goals (ARl\Rs) ard the basis for their selection
are listed. in Exhibit 15. These are based on apprc:priate arrl relevant
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48
requirements for a Class IIA Aquifer. Alternate concentration limits
(ACLs) are prc:pcsed for 1 ,l-dichloroethane, 1, 2-dichloroethane, benzene,
1,2-dichlorcpropane, aOO trichloroethene, as described in Section VII .8.8. .
'lhe process that has been am will continue to be used to select ACLs is
generally consistent with Section 264.94 of RCRA regulations an:1 1987 ACt
Interim Final G..Lidance. Mditional data on backgrourrl contamination gathered
durifrJ RD/AA (such as data fran new backgroorrl monitorlfrJ wells) will be
incorporated into the evaluation of ARARs that is planned fot every five
years thrcughoot O&M. Other factors that will be considered .in the Five-
Year Review will include implementability (Le., are new technologies avail-
able to address soorce control with an expected substantial degree of success
am is groorrl water quality improvifrJ at an acceptable rate dUrlfrJ remediation)
am effectiveness (Le., is treatment in the lamfill an:1,Ior unsaturated .
soils a cast-effective option to supplement groond water pumpifrJ).
Section VII.B.8. refers to tarrl Ban aOO off-site disposal requirements,
NPDES peITnittifrJ requirements, Injection Well pt'CXJram requiranents, an:1
state air pollution emissions requirements. Off-site grcum water withdrawals
exceedifrJ 10,000 gpd aOO surface arrl. grcund water discharges exceedifrJ 50,000
gI;X! generally require a pemit fran the Delaware River Basin Carmission. For
on-site pumpifrJ, the equivaleht of a peITnit fran the Delaware River Basin
Carmission is required. .
EPA's Undergroond Storage Tank regulations for tanks installed before
~cember, 1988 require: .
. corrcsion protection:
. spill an:1 overf ill prevention: am
. leak detection.
'lhese regulations apply to the on-site undergroond tanks.
D. Ccst Effectiveness
'!he selected remedy, with estimated casts of about $7.3 million,
affords overall effectiveness prcportional to its costs such that the remedy
represents a reasonable value for the money. Table 2 a:mpares estimated
ccsts affiliated with ead'l ccmponent of all alternatives.
A PA sOlid Waste cap is expected to provide the sane degree of protec-
tiveness as a RCRA cap, provided PA DER requirements for design are met. A
PA Solid Waste cap is estimated to CX)St $723,765 less than a RCRA cap.
Leachate collection, estimated at $727,000 constitutes one of the major
risk reduction canponents of the remedy. Because of the significant risk
reduction anticipated to result fran leachate collection, these CX)Sts are
considered well justified. .
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49
As described in the Iw::xJ roD, casts of the cquifer restoration d:>jective
are viewed as reasonable at this time considerirg the mardate urder the
Gro.lOj Water Protection prcgram to provide a high level of protection to
Class IIA ~ifers. ShOlld data gathered durirg RA indicate that ~ifer..
restoration will be significantly rore costly than originally estimated or
tha.t the selected ranedy is less feasible than originally estimated, this rew
infor:mation will be factored into the periodic evaluation of .~. This is
a cost-effective and practical approach.
'!he "Draft Letter Report on Volumes ard Grass Cast Estimates for Excav- .
ation of Fill Material ard Soils on the Pennsylvania Turnpike pr~erty at .
the Herderson Road Site", prepared by Camp Dresser & McKee, Inc. ard dated
May 11, 1989, estimates that costs of incineratirg soils below the trash ard
cirders on the Turnpike pr~erty woold total $6,171,000. If these soils
were lOOVed off-site after a cap is installed on the WJ, treatment WOlld be
necessary urder Lard Ban requiranents. Excavatirg ard backfillirg withOlt
treatment woold ccst $445,950. Because the same level of protectiveness is
expected fran excavatirg ard ranediatirg row instead of later, when treatment
wOlld be necessary, the costs to excavate arrl consolidate soils arrl fill
fran the Tunpike pI"q)ertyare justified.
'l11e "General Sc~e of Work to Characterize the Cirrler Fill in the
t'lestern Portion of the HRLQU", prepared by Camp Dresser & Mckee ard dated
July 7, 1989, estimates the cast of additional characterization in the
western portion of the site at $42,000. By canpletirg this characterization
simultaneoosly with the characterization of the unsaturated zone to be
perfor:med as part of the RD for the Iw:xJ, one canprehensive ranedy may be
selected for the western portion of the site for both ~erable units. EPA
expects that coordination of RD for ooth cperable units in the western.
portion of the site will produce the mcst technically SOlOO ranedy in the
mcst cost-effective fashion.
'l11e approach to deteminirg whether arrl hCM to cap" institute unsaturated
zone treatment, or implement other ranedies in the western portion of the
site, corrluct lOD}-tem monitorirg, arrl cooouct scheduled reevaluation of the
remedy arrl pIq?OSed ARMs for both cperable units tcgether constitutes a ccst-
effective approach to balancirg cost ard overall effectiveness in light of
.the canplexity of the site ard potential overlap of influence on grourrl water
between the two cperable uni ts .
E. utilization of Permanent Solutions Employirg Alternative-Technolcgies
To The Maximum Extent Practicable
Alternative 4, i~situ volatilization, may be considered a rore per-
manent solution, anployirg alternative technology, than the selected remedy.
However, i~situ volatilization is not expected to be implanentable am would
-------
50
not result in a substantial risk reduction (see Section VILB.8). Alter-
natives 5 a.OO 6, which waJld involve excavation of the lardfill, are con-
sidered more permanent solutions than the selected remedy. Ho\rt'I8Ver, these
were determined to be less protective than ~ternatives 3, 4, ard 8. Addi-
tionally, Alternatives 5 ard 6 are not considered to be ccst-effective arrl
would be difficult to Lmplement.
F. preference For Treatment As A principal Element
'lhe selected remedy involves treatment of . leachate ard grourd water to
address the principal threat posed by th.e UXJ - grourd water contcrnination.
AlthaJgh Alternatives 4, 5 arrl 6 involve treatment of a:lditional media, these
alternatives are rot significantly more protective than the selected remedy
arrl are rot ccst-effective. Further:more, Alternatives 5 arrl 6 are expected
to be particularly difficult to Lmplement.
XI.
IXX:t.JMENrATION OF SIGNIFICANT CHANGES
'lhe Proposed Plan for the site arrl Administrative Record were released
for public catiment in JUne, 1989. A report on fate-an:i-transport of .contam-
inants in the I.DU, prepared by Camp Dresser & McKee, was included as itan
111.22 to the Administrative Record. EPA reviewed all the oamments that. .
were submitted both verbally arrl in writirg durirg the public cerement pedod.
In JUly ard August, Camp Dresser & McKee sub'nitted the last reports listed
in the Administration Record. 'lhese reports address ccsts associated with
Alternative 8. Upon review of these carments, EPA determined that 00 signif-
icant marges to the remedy, ~ identified originally in the Proposed Plan,
were necessary. .
-------
TABLE OF CONTENTS
HENDERSON ROAD LANDFILL OPERABLE UNIT
DECISION SUMMARY
Page
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
III. COMMUNITY RELATIONS HISTORY ^
IV. SCOPE AND ROLE OF OPERABLE UNIT AND RESPONSE ACTION
V. SITE CHARACTERISTICS
j
A. Fill Material, Tanks, and Leachate in LOU ;,
B. Data Collected in LOU Remedial Investigation j
C. Potential Routes of Migration from LOU Sources and
Ground Water Fate-and-Transport Assessment
D. Results and Conclusions from IWOU Remedial investigation
VI. LOU RISKS
A. Human Exposure Pathways
B. LOU Human Health Risk Assessment
C. LOU and IWOU: Comparison of Human Health Risk Assessments
D. Environmental Risks
VII. DESCRIPTION OF THE ALTERNATIVES
A. Remedial Objectives
B. Summary of Alternatives
VTII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
IX. THE SELECTED REMEDY
A. Summary of Major Factors and Criteria Associated with
Selected Remedy
B. Anticipated Changes and Decisions to be Made During RD/RA
C. Risk Level to be Attained
D. Point of Compliance
X. STATUTORY DETERMINATIONS
A. Determination of Endangerment
B. Protection of Human Health and the Environment
C. Attainment of ARARs
D. Cost Effectiveness
E. Utilization of Permanent Solutions Employing Alternative
Technologies to the Maximum Extent Practicable
F. Preference for Treatment as a principal Element
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
-------
EXHIBITS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Administrative Record of LOU
site Location Map
site Area Zonin:j Map
Larrlfill Investigation Map
~vatershed Map .
On-site Leachate O:currence Map
Summary of Analytical Results, Surface Soil and SedLment samples
Summary of Analytical Results, Test pit Samples
Summary of Analytical Results, Test Borirq Samples
organic 'Carbon Content, Study Chanicals
Summary of Cancer Risk Factors an:i Hazard Irrlices, Iw:.u
Supportirq Tables. for Iw:.u Risk Assessment . .
Indicator Chanicals and Concentrations Used In LOU Risk Assessment
potential Sources of Off-Site Regional Aquifer Contamination.
proposed Chanical-Specific Grourrl Water ARARS";'~
Summary of LOU Risks .
potential ARARs for LOU .
Risk Calculations for Ground Water ARARs
Figure of Alternative 3 as a Component of Alternative 8
Figure of Alternative 7 as a Component of Alternative 8
Treatment Processes for Recovered Ground Water
,
-------
:::<::: 3:':' "
HENDERSON ROAD LANDFILL SITE II *
ADMINISTRATIVE RECORD FILE **
INDEX OF DOCUMENTS
III. REMEDIAL RESPONSE PLANNING
1)
2)
3)
4)
5)
*
**
Note:
Letter to Mr. Alan Robinson~ BCM Eastern, Inc., from Ms.
Gerallyn Downes-Valls, U. S. EPA, re: . Comments.
on the revised Work Plan for the soil sampling and analysis
proposed for the Henderson Road Site Landfill Operable Unit,
11/2/87.P. 300001-300063. The following are attached:
a)
a Modified Sampling Procedure;
b)
a Quality Assurance Project Plan Review;
a letter regarding analytical data collected from
the Henderson Road NPL Site;
c)
a letter regarding modifications to the
Work Plan/Project Operations Plan.
Transmittal letter to Ms. Gerallyn Downes-Valls, U.S. EPA, from
Ms. Margaret E. Bonaker, BCM Eastern, Inc., re: Marked up copy
of the November 17, 1987 letter from Ms. Gerallyn Downes-Valls
to Mr. Alan Robinson, 11/18/87. P. 300064-300067. The marked
up letter is attached.
d)
Handwritten memorandum to Ms. Peg Bonaker, BCM Eastern, Inc.,
from Ms. Gerallyn Downes-Valls, U.S. EPA, re: Transmittal of
the Henderson Road Detection Limits and Compounds, 1/20/88. P.
300068-300072. The tables .of Detection Limits and Compounds
are attached. .
~~P~~~:co~~;:~~o~~ii/~:)~~: f~~ ~~~~~~:~~O~~~~ Site, prepared
Report: Draft Landfill Investigation Report {or The.
~:~~:~~~nI~~~~ ~;~:.La~~f~661~b:~~~~1~nit, prepared by BCM
Administrative Record File available 5/31/89, updated 9/21/89.
. .
For further documentation on this site, please refer to the.
Henderson Road Site Administrative Record. ..
Company name or organizational affiliation is identified in .
the index only when it appears in the record.
1
-------
6)
7)
8)
9)
10)
11)
12)
13)
14)
Letter to Mr. Alan Robinson, BCM Eastern, Inc., from Ms.
Gerallyn Downes-Valls, U.S. EPA, re: Transmittal of the
inorganic data review, 3/4/88. P. 300312-300318. . The
amendment to the inorganic data validation is attached.
Report: . Volume 1, Remedial Investigation Report Landfill
Operable Unit, prepared by BCM Eastern, Inc., 5/89. P. 300319-
300520. References are listed on P. 300515-300519.
Report: Volume 2, Remedial Investigation Report Landfill
Operable Unit, prepared by BCM Eastern, In~., 5/89. P. 300521-
301240. References are listed on P. 301156 and 301198-301199.
Report: Feasibility Study Report Landfill Operable Unit,
prepared by BCM Eastern, Inc .., 4/89. P. 301241-301520.
Letter to Ms. Gerallyn Valls [sic], U.S. EPA, from Mr. Robert
D. Buller, BCM Engineers [sic], re: Transmittal of recent
published papers addressing the relationship between Polycyclic
Aromatic Hydrocarbons (PAHs) and oil stains, 5/19/89. P.
301521-301532. Two papers entitled "Soil Cleanup Criteria for
Selected Petroleum Products" and "Accumulation of Polycyclic
Aromatic Hydrocarbons. in Crankcase Oil" are attached.
Letter to Ms. Gerallyn Valls [sic], U.S. EPA, from Mr. Louis R.
Martin, Pennsylvania Turnpike Commission, (PTC) re: .
Preliminary analysis of the estimated costs associated with the
symmetrical and non-symmetrical [sic] widening of the Turnpike
to six lanes, ~/23/89. P. 301533-301535.
Report: Comparison Study Analytical Data, Henderson Road
Site, prepared by Versar, Inc., (undated). P. 301536-301572.
Deed between Bethlehem Steel Corporation to Mr. William J.
O'Hara and Mrs. Betty E. O'Hara, 3/14/77. P. 301573-301577.
Letter to Ms. Carole Kurtz, Pennsylvania Department of
Environmental Resources, from Mr. James J. Kayer, Pennsylvania
Turnpike Commission, re: O'Hara Sanitation'~continuing
trespass upon Pennsylvania Turnpike Commission property,
12/14/88. P. 301578-301603. The following are attached:
a)
a letter regarding O'Hara Sanitation trespassing on
Commission property;
a letter regarding O'Hara's request for PTe
cooperation of handling drainage;
b)
c)
a letter regarding PTC's awaiting status of
Engineering Data review sent to O'Hara;
d)
a letter regarding transmittal of comments and
drawings;
2
-------
15)
16)
17)
18)
e)
f)
g)
h)
i)
j)
k)
a memorandum regarding the removal of clean
fill from Turnpike property;
two site maps;
a memorandum regarding estimate of
consequential damages;
five Pennsylvania Turnpike Commission
forms;
a fence stakeout map;
excerpt from a Federal report;
three aerial photographs.
Letter to Mr. James Snyder, Pennsylvania Bureau of Waste
Management, from Mr. Peter Schaul, U.S. EPA, re: Completion of
the Remedial Investigation, 1/27/89. P. 301604-301607. A
memorandum regarding closure requirements for a hazardous waste
landfill is attached.
Letter. to Ms. Gerallyn Downes-Valls, U.S. EPA, and Mr. Wayne
Walters~ U.S EPA, from Mr. Preston Luitweiler, and Mr. Mark
Kropilak, Philadelphia Suburban Water Company (PSWC), re:
PSWC's concerns about groundwater withdrawals in the UMR
basin, 2/22/89. P. 301608-301610. .
Letter to Mr. Bruce Smith, U.S. EPA, from Mr. Steven Speece,
re: Comments on O'Hara Sanitation's position, 3/6/89. P.
301611-301612.
Letter to Ms. Gerallyn Valls [sic], U.S. EPA, from Mr. Steven
Speece, re: Transmittal of all relevant documents concerning
the Conrail and Pennsylvania Turnpike Commission matters,
4/14/89. P. 301613-301696. The following are attached:
a)
b)
c)
d)
e)
a letter regarding the removal of .lean fill
from Turnpike property;
a letter regarding PTC stating they are
awaiting for a review of Engineering Data;
a letter regarding information to be
reviewed by O'Hara's counsel;
a letter regarding a meeting between PTC and
O'Hara scheduled on July 11, 1989 at 11:00
A.M.;
a letter regarding the scheduled meeting with
PTC. ;
3
-------
f)
g)
h)
i)
j)
k)
1)
m)
n)
0)
p)
q)
r)
s)
t)
u)
v)
a letter regarding a meeting to discuss
O'Hara's lack of activity;
a letter. regarding setting up a meeting at
the site;
a letter regarding a request for a meeting
with O'Hara Sanitation Company
representatives;
a letter regarding an inspection made on
August 29, 1986 of the Turnpike's right-of-
way'; .
an Active Status Certification form;
a letter regarding the Tur'npike Survey Corps'
restaking the legal right of way;
a letter regarding inspection of the O'Hara
Sanitation Company;
a letter regarding delaying an on-site
inspection;
a letter regarding rescheduling a meeting
until October 1984;
a letter regarding an on-site meeting;
a letter regarding an on-site meeting to
resolve the situation at the site;
a letter regarding an immediate response to Mr.
O'Hara's position;
a letter regarding PTC's offer of extension to
answer the Complaint;
,
a letter regarding the transmittal of the
Defendant's Brief in Support of Preliminary
Objections; .
a Notice and Complaint for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company;
an Answer to Complaint for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company; .
a Praecipe for Argument List for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company;
,4
-------
w)
x)
y)
. z)
aa)
bb)
cc)
dd)
ee)
ff)
gg)
hh)
ii)
j j)
an Order Sur Defendant's Preliminary
Objections for Pennsylvania Turnpike
Commission vs. O'Hara Sanitation Company;
a Preliminary Objection for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company; .
an Order for Pennsylvania. Turnpike Commission vs.
O'Hara Sanitation Company;
a Defendant's Brief in Support of Preliminary
Objections for Pennsylvania Turnpike
Commission vS.O'Hara Sanitation Company;
a Plaintiff's Brief in Opposition to Defendant's
Preliminary Objections for Pennsylvania Turnpike
Commission vs. O'Hara Sanitation Company; .
a Praecipe of Appearance for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company; .
a Certificate of Service for Pennsylvania
Turnpike Commission vs. O'Hara Sanitation
Company;
a letter regarding work completed by O'Hara
Sanitation Company;
handwritten notes regarding telephone
messages;
a letter regarding Conrail's position for the
proposed sale of Conrail property in King of
Prussia, Pennsylvania; .
a letter regarding the purchase o~Conrail
property in King of Prussia, Pennsylvania;
a letter regarding the encroachment on
Conrail property by O'Hara Sanitation
Company;
a letter regarding O'Hara Sanitation Company
dumping of substantial amount of waste
material on Conrail property;
a letter regarding O'Hara Sanitation Company
encroachment of Consolidated Rail Corporation
property; . .
5
-------
19 )
20)
21)
22)
23 )
24)
25)
26)
27)
kk)
a Temporary License Agreement Permitting
Entry of Property.
Letter to Honorable John Fullam, U.S. District ~ourt, from Mr.
Robert Smolski, U.S. Department of Justice, re: Transmittal of
the United States' Petition For Approval and Entry of the
Consent Decree of 4/17/89. P. 301697-301701. The Petition is
attached. . .
Letter to Mr. James Snyder, Bureau of Waste Management, from
Mr. Bruce Smith, U.S. EPA re: Proposed Plan foi the Henderson
Road NPL site, 5/19/89. P. 301702-301702. .
Letter to Ms. Rose Harvell, U.S. EPA, from Mr. Harry Butler,
CDM Federal Programs Corpora~ion, re: Transmittal of the Draft
Letter Report on Volumes and Gross Estimates for Excavation of
Fill Material on the Pennsylvania Turnpike Property, Henderson
Road Site, 5/30/89. P. 301703-301708. The report is attached.
Letter to Ms. Rose Harvell, U.S. EPA, from Mr. Harry Butler,
CDM Federal Programs Corporation, re: Transmittal of the'
Letter Report on Analysis of Contaminant Distribution and Fate-
and-Transport at the Henderson Road Landfill Operable Unit,"
5/30/89. P. 301709-301725. The report is attached. "
Letter to Mr. Robert Buller, BCM Engineers [sic], from Ms.
Gerallyn Valls [sic], U.S. EPA, re: Draft comments on the
Remedial Investigation and Feasibility Study, 6/9/89. P.
301726-301752. A letter regarding the transmittal of the
Revised Remedial Investigation Report and the Final Feasibility
Study Report is attached.
Report: The Henderson Road NPL Site Operable Unit Proposed
Plan, prepared by U.S. EPA, (undated). P. 301753-301783.
Report: Supplement to Proposed Plan, Henderson Road NFL Site
Landfill Operable Unit, prepared by U.S." EPA, (undated). P.
301784-301787.
, "
Letter to Ms. Gerallyn Valls [sic], U.S. EPA, from Mr. Preston
Luitweiler, Philadelphia Suburban Water Company, re: "
Relocating the 36-inch steel transmission main, 6/12/89. . P.
301788-301798. An article entitled "Accumulation of Polycyclic
Aromatic Hydrocarbons in Crankcase Oil" is attached. ". .
Letter to Ms. Gerallyn Downes-Valls, U.S. EPA, from Ms. Debra"
S. Glover, Camp Dresser' McKee, Inc., re: Draft Letter Report
on Volumes and Gross Cost Estimates for Excavation of Fill
Material and Soils on the Pennsylvania Turnpike Property at the
Henderson Road Site, 5/11/89. P. 301799-301802. ."
6
-------
28)
29)
30)
31)
32)
33)
Letter to Ms. Gerallyn Downes-Valls, U.S. EPA, from
S. Glover, Camp Dresser & McKee, Inc., re: General
Work to Characterize the Cinder Fill in the Western
the Henderson Road Landfill Operable Unit, 7/7/89.
301805. A Landfill Investigation Map is attached.
Ms. Debra
Scope of
Portion of
P. 301803-
Letter to Ms. Gerallyn Downes-Valls, U.S. EPA, from Mr. Robert
J. Delorenzo, Camp Dresser & McKee, Inc., re: Estimated Costs
of EPA Preferred Remedy, 7/11/89. P. 301806-301811..
Letter to Ms. Gerallyn Downes-Valls, U.S. EPA, from Mr. Robert
J. Delorenzo, Camp Dresser & McKee, Inc.; re: Revised.
Estimated Costs of EPA Preferred Remedy, 7/21/89. P. 301812-
301817. . .
Letter to Ms. Jean Wright, U.S. EPA, from Mr. Donald Senovich,
Camp Dresser & McKee, Inc., re: Transmittal of the Letter
Report entitled "Volumes and Gross Cost Estimates for
Excavation of Fill Material and Soils on the Pennsylvania
Turnpike Property", 8/14/89. P. 301818-301823. The Letter
Report is attached.
Letter to Mr. Robert Buller, BCM Engineers; Planners and
Scientists, from Ms. Gerallyn Valls [sic], U.S. EPA, re:
Transmittal of EPA's comments to the Revised Remedial.
Investigation Report (May, 1989) and Feasibility Study Report
for the Henderson Road Landfill Operable Unit (April, 1989),
8/18/89. P. 301824-301847. The comments are attached.
Letter to Ms. Jean Wright, U.S. EPA, from Mr. DonaldSenovich,
Camp Dresser & McKee, Inc., re: Transmittal of the Final
Letter Report entitled."Comments to the Revised Remedial
Investigation Report. (May 1989) and Final Feasibility Study
Report for the Henderson Road Landfill Operable Unit", 8/23/89.
P. 301848-301872. ..
7
-------
v. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1)
Press Release from EPA Environmental News entitled "EPA
Announces Availability of Proposed Plan For The Landfill
Operable Unit At The Henderson Road", 6/16/89. P. 500001-
500003.
2)
Cover Page re: Correction. to EPA Ad, (undated).
500006. EPA's Proposed Plan is attached.
P. 500004-
8
-------
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-------
EXHIBIT 2
NOM. Aari 1SH, anvmt torn M Notmtann,
Upper Menon
Township
Henderson Road
Site
Figure 1. The Henderson Road study area in Upper Merion Township, Pennsylvania.
-------
PRWCRIYLEGEM3
01 Ph Suturtun
03 GIMgoo Quarry me
IK Pli Suburtun
00 PSCO
07
10 Mrtol OteMnm RMvnan Ma
MM t OMhr O>l*»
300 S Hand OagH Daa*>
Wm » Bat» OVlara
towfitltp Btoch Mo 1 \
(CMOEMON ROAD SJIE
t AW)f«l CFERAHE UMI
SIM Area Parcw Map
t-J
UJ
U)
-------
M I* f f
AUI J
—TWn v, >
— Ifr' "'" ^
"-^w»i""^^*35S^^**"*;^^v-j,
_ y .
i X yp^^T
1—^ / §5''T)
MTJjourjki
Oj^f*^>l (
irmj -r x
HENDERSON ROAD SITE
LAHDFR.L OPERABLE UMT
, .
IESI HI IOCAIIOM AH> NUKHFR
sat IOCA?KM • NUMW
TNASHfll
,717, OFPTHOF
DEPTH W
SIREAM SCO** MI
IOCAIIOM S NUMBER W
BOHMQ I OCA I KIN t
m* ftfft (Pwcfc.l
Landfffl mvtstlgatlon Map
e
M
H
^
-------
BCM
HENDERSON ROAD
Location of Ephemeral Stream (Approximate)
Location of Ephemeral Stream
BCM Prefect No. 00-5801-02
-------
HENDERSON ROAD SITE
LAMDfU. OKHAW.E UWT
Lcachate Occurrence
cr\
-------
SUMMARY 0' ANALYTICAL RESULTS
DECPlEI 1985 AND JULY 1986 SURFACE SOIL AND SEDIMEIIT SAMPLES
HENDERSON ROAD SITI
LANDFILL OPERAILE UNIT
':7"'4.-:': - ~ -- .....
-- -. - - - -
LA8QRATORY ID: N521909 N521910 N521911 N521912 N521913 N521914 N5Z1915 N521916
w.PLE DATE: 1211Z/85 12/12/85 12112/85 1Z/12/85 12112/85 12112/85 12/12185 12112/85
w.PLE IWE: BS1 BS2 153 854 8S5 BS6 BST Bsa
SAMPLE TYPE: SS/CINDEI SS/CINDEI SS/TIASH SS/TRASH SS/TRASH SS/TRASH SS/TRASH SS/TRASH
P.r...ter Cunlta)
volatfle C08POU"da CUI/kg)
Acetone
8enz-
Ca~ Tetrachlorfde
Ch loroOenz-
'cZ-ofchloroethene
C1a-1l3:~lchloropropene
Ethyloenz-
Methyl- Chloride
Tetrachlor08th- CPeE)
Toluene
1,1,1-Trfchloroethene
Trfchloroeth- CTCE)
Trichlorofluor088thene
TOTAL VOLATILES DETECTED
S_iwletl le C08POU"da (Ul/kg)
Acenapftth-
.Anthr8C-
8enzidine
.Senzo(a)Anthrecene
.SenzoCa)PYf'ene
.Senzo(b) Fluorenthene
.SenzoCk)Fluorenthene
.BenzoCI.h,i)Perlyene
8Iacz-Chloroethrl)Ether
SI.(2-£thylhe~ )Phthalate
Butyl Benzyl Phthalate
.Chrysene
-0 ibenzo(a,h)Anthr8Cene
oibenzofuran
.Fluorenthene
.Fluorene
.1nd8n0C1,Z,3-cd)Pyrene
. Z-Methylnaphthalene
.Naphthalene
Phenenthrene
.Pyrene
Pesticides and PCI. (Ul/kg)
Aldrin
alpha-BHC
de\ta-IHC
4 4' -DOT
Dteldrin
Heptachlor
lnorlen;c C~ CIIII/kg)
Antimony
Arsenic
Beryll "..
Cadi"..
ChrClli~
Copper
Cyenide
Lud
Mercury
IIfckel
Thall I~
Zinc
TotaL Phenolic. (melk.)
NT
e10
e10
110
e10
e10
e10
100
300
200
e10
e10
60
770
NT
NT
NT
NT
NT
NT
NT
NT
.NT
NT
NT
NT
IT
NT
NT
IT
NT
NT
NT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT .
liT
liT
liT
liT
liT
liT
liT
liT
liT
NT
e10
e10
60
e10
e10
e10
80
3,760
110
40
50
120
1.,220
liT
IT
liT
liT
liT .
NT
liT
liT
liT
liT
liT
NT
liT
NT
NT
liT
liT
liT
liT
liT
liT
liT
liT
liT
IT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
. PAil inch'" In total PAH vel un for FfguJ"88 4-1,
liT lIot tested aa pert of this' study
5S Surf8Ce Sol l .
Source: BeM Engineers CleM Project 110- 00-5808-Q2)
NT
e10
e10
670
e10
e10
e10
70
70
10Q
e10
e10
360
1,270
liT
liT
liT .
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
4-2, and 4-3
liT
e10
e10
250
e10
e10
e10
50
e10 .
ZO
e10
e10
1.0
360
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
NT
NT
NT
NT
liT
NT
liT
NT
NT
liT
liT
liT
liT
liT
liT
liT
NT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
liT
e10
e10
<10
<10
<10
<10
<10
<10
<10
<10
<10
e10
ND
NT
IT
liT
liT
IT
liT
NT
liT
NT
NT
NT
NT
NT
liT
liT
IT
NT
NT
liT
liT
liT
liT
NT
liT
liT
liT
liT
liT
NT
liT
liT
liT
liT
liT
liT
liT
IT
liT
liT
liT
NT
e10
e10
170
<10
e10
e10
30
<10
40
<10
e10
500
740
liT
liT
liT
liT
liT
liT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT
,
NT
liT
. liT
NT
NT
NT
NT
e10
<10
e10
e10
<10
<10
50
<10
170
10
<10
540
770
liT
liT
liT
NT
liT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT
NT
NT
1fT
NT
NT
NT
NT
NT
liT
NT
NT
NT
liT
NT
NT
NT
NT
NT
liT
e10
<10
370
<10
<10
<10
<10
<10
120
<10
<10
<10
1.90
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT
NT
NT
NT
liT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT .
NT
NT
NT
NT
NT
NT
NT
liT
NT
IT
liT
liT
liT
-------
::::4:~::~:-:' -:
, . \
. CO.:1;:: j
LAIOIATOIY 10: 11521917 11521918 11521921
SAMPt.E DATE: 12/12/85.12/12/85 12/12/85
SNlPL! NAME: BS9 BS10 BS CCIIt
SAMPLE OESClIPTION: SS/TRASN SS/CINDER
Plr...ter (unitl)
volatile Ca.p0und8 (ug/kl)
ACICone
Benzene .
Carbon Tetrecnloride
Chloroblnzerw
',2-0ichloroethane
CII-1l3:~ichl.orapropene
EthytDINerw
Methytene Chloride
Tetrachloroethene (PCE)
Toluene
""1-Trichloroethane
Trichloroethene (TCE)
Trichlorofluo~thane
TOTAL VOLATILES DETECTED
S.ivotati le COIIiPCU"da (ug/kg)
ACINJlftthene
*Anthracene
Benzidi,.
-BenzoCa)Anthr8Cene
-Senzoc a )PYrene
-SenzoCb)Fluorenthene
-SenzoCk)Ftuoranthene
-Senzocg,h,i)Pertyene
BiIC2-Chloroethyl)Ethar
SiIC2-Ethylhexyl)Phthalate
Sutyl Benzyl Phthalate
*Ctlryserw
*Dibenzoca,h)Anthraeene
Oibenzofuren
- Fl uoranthene
-Fluorene
*lndenoC1,2,3-cd)Pyrene
2-Methyl~thalene
-Naphthalene
Phenanthrene
*Pyrene
liT
<10
<10
<10
<10
<10
<10
50
140
120
<10
<10
150
460
liT
liT
NT
liT
liT
NT
NT
liT
liT
NT
NT
NT
NT
liT
NT
NT
NT
NT
NT
NT
liT
TOTAL SEMIVOLATILES DETECTED
Pesticides and pcal (UI/kg)
Aldrin
elpha-BHC
delta-SHC
10 4' -DOT
O;eldrin
Heptachlor
Inorganic C~ (1liii/kg)
AntilllOn'f
Arsenic
Beryll h.-
C..h.-
ChrCllliua
Co,:Ip8r
Cyenide
Lied
Mercury
Nickel
Thall iUl
Zinc
Total Phenolics (8g/kg)
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT
NT
liT
NT
NT
NT
<10
<10
<10
<10
<10
<10
20
<10
30
<10
<10
40
90
liT
NT
NT
liT
NT
liT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
liT
liT
liT
1 800
2'300
<1 ' 600
6:500
5,500
10,000
10,000
<4,000
<1,600
3,300
<1,600
6,000
<4,000
liT
13 000
1'600
-------
SUMMARY 0' ANALYTICAL RESULTS
TEST P IT SAMPLES
HENDE.SOM lOAD SITE
LAND'ILL CPERAILE UNIT
=':-::3::: '3
l.'
LAIOItA TOllY 10:
SNtPLE DATE:
SNtPLE NAME:
SMPLE TYPE:
Per_ter (Unit.)
.
Volatile Compounda (ug/kg)
Benzene
Chlorobenzene
Chlorofonl
Ethylbenzana
Methylene Chlorfde
Tetracftloroethana (PCE)
Toluene .
Trana-1,3-0fchloroprapene
Trfchloroethene (TCE)
TOTAL VOLATILE c:a.PClJMDS
S..fwlatf Ie C~ (ug/kg)
-SenzoCk)Fluoranthene
Bis
-------
.
. E:IJfI:9IT. 9
UIIM'I' OP AULYTICAI. ""'TI
E" AULT.' ~ ..... '987 SOIl. IAll'\II
lit"" IIQIO IITI
\Al8f11.1. QPtUlU ~IT
E'" ~TCIt' 10: 8" "20-01 8"'20.02 8"'2]-01 81"2]'02 8"'25'05 87"24'0'
1ICQ71 . 1C1t17'Z IOU' 1ICI,91 . OUI 1fC1222
~. DATI: 11/19/81 ''''9111 "/20/81 , "20111 , 1/24111 11/23/81
EPi ..,~ I ...,.: I.'" I"" I"U I.a 1116& IIIU
~I ~0t&f(0II: 1'1(14.1'.', 1-1(]O.11.5' I'Z(14.5"6) I,Z(3Q.I'.5) I,UC40'4I." 1'1<19'2Q.51
"'~I n,,: 'UW'., 10" ..cur., Ioi' ..cur., Ioi' '.CIII'.' Ioi' '.CIII'.' Ioi L '.CIW.I 501 ~
'.r_ter (unit,)
vOlulle ~~-.- 110 110 110" 110 110 110
5_iw.'.tl 'e e---.- (U8Ita) c820 c8SO c830
"_Cllr:' c830 ",000 20 J
Oietlly tll8'.to c&1O c820 c&SO c&1O ., ,000 50
",_11- 50.& c820 ..aU eGO c" 000 50
''''ttlr- caJO eGO eGO ". 000 5 A
Oi-fto~tftel.to eGO IIC c&SO c&SO IIC Ie
.",*,- 60 eGO ZO .& A eGO c'. 000 40
.,.... 513 c820 .J:U c&SO c'.OOO 20
IYfY'~'lftttl.'ata eGO c8ZO c&SO c'.OOO ~
-e-OCa)Mtllr_- c&1O c8ZO c&SO c&1O c'. 000 .99Q
. 1',CZ'etlly'IIUyU""ttlalaCo Ie IIC IIC IIC Ie .e
-CIIrw- c&SO eGO 40 .& A c&SO c, ,000 ~
Oi.ftoGCtV'lfttftelato c&SO IIC c8SO Ie c'.OOO c99Q
TOT~ _I-'.,,".'~' '40 . 110 . 110 '"
'-Clcl.. .... 'C88 (81111.) . 110 . . 110 110
1-..10 ,-- (811..) '.SID .& '7.- J 14.".& ".18.& ".000 .&
"'..,- '0.18 J
"'t...., .... 1 , .... "'.7 ..... , "'.1 . ..... I
"....ic c,.. '.4 '.4 ,. ,. IZ
""1\8 ,. .& 10 ." 40 " 9.1 J
. ..,.,,, 1 \8 c'.1 7.4 ~. c1.2 Z.1.& '.0 1.8 J
c..1\8 ].2 .& . I.' 5,' 1.5 1.1 9.7
C.'ci\8 '.190 '.1" "';1 414 .& 7SO '"
CIIr8I\8. t.' . ~J 11 '7
I:GM& C j.H 12 ~ ,.. fL 15
c....- 1 ~ 40~ 1 ~ 14~ 44.&
Cywtl. c1.2 c1.2 c1.2 c'.2 c'.2 c'.Z
Ir8l1 14. 9aO 39.. Zt.. 11." 3S. ZOO 49,_'&
..... 'O 'J ~ z.m' Z1 18 34
..... i\8 " '."0' 560 611 W
...,.... 60 "8 ., 1.Z10 109
:rc:r cO.n cO. 12 cO.12 cO.12 cO.12 cO. IZ
7.5 .& 54 Z2 47 '4 3Z
Itot..h. '.400 .& '9.J. UL '.4'" # 736 .& 72' J 372 J
"'8111\8 cO."UL cO. 4 UL cO.nUL cO.72UL cO.7t UL
511- c'.' c1.7 c'.7 c1.7 c'.7 c1.7
5018h. 314.& ~JUL 4ft J Z70 J 2M .& 25Z J
TII." i 181 c,.. UL c'.7 UL 41.7 UL c'.1 UL ".7 UL
'1",,\8 " 34 U 1ft " 34
ZInc " 101 1ZS "
T8I1COCIW&I I...lfl. .. - (811"" 0.04 A .
--. ,"018r.r.' . . . .
OCt8nl. 3'1~'Z. '0188tWr1- o.r" . . . . .
-- - 1 .'0 h. 0. . . . . .
C-,e'~ ~ 0.1 . . . . .
--. .7~18 - ,.01" . . . . 110
',":ie &clcl. J. "",1..1.- .2 4.1 J.I 8.4 . .
0 dIId88'r\ .,ar . 0.01" . liD
""....tldlll8 . .
Ulrlcllll8. 1""-" . 0.1 . . ~ 110
Z''"-''8'. &cld. zcyt 1.- . O.J IlO IlO 110
--laic &cid, OIGCtVt IOtar . "1 5.1 4.4 110 110
OCt8nl. Zc4.'-Tr =. . O. . 0.' . 110 110 110
...... 1.1'01-- 8CIPt\)- . . 0.01 A 110 . 110
D_. Z.4'OI8tll't'. IlO IlO O.OS" 110 . 110
0_. Zt,.,.TrI88tlPlt- . . 0.1 . . 110
H88C8nI Z.~ . . 0.1 . . 110
~_II8" - IlO IlO 0.011" . 110 ..
1.0-'. z.ittPIt- IlO IlO 0.' .. 110 110
]'II888n8. Z.I'OI~ .. IlO IlO g:j 110 110
Z.P8I1t8nl&a. Z.4-o1:; . IlO IlO . 110
M8nI." &_J. . . . O.OS A " .
II Crie &clcl. ......... . . . 0.011 A . 110
........ . . . . . 110
OCtane. Z.J.7"rl""'-- . . . . . 110
0-. J'I~ IlO IlO . . . 110
1_. Z,,-o188tlPlt- IlO IlO. " . . 110
'1:::~OC~Z.2.4.4.7.7- . . . . . 110
". U'-- . . 110 . . . .
........ ,"018tt1yt.
--. },1'018tt1yt. IlO IlO . . . 110
Dod888n8. Z","'Trl--t. . . . . . .
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-------
1
RESPONSIVE.JESS SUtt1t\RY
HENDERSON ROAD SITE LANDFILL OPERABLE UNIT
I::PA made the draft RI/FS, which was prepared by .the respondents uooer the
1985 Administrative Order on Consent, and Proposed Plan available to ~~e
public for review on June 12, 1989. Comments were received fram the public
through July 12, 1989.
EPA provided preliloinary COiYments to the respondents on the draft RI/FS
on June 9, 1989. EPA provided final comments on the draft RIfFS, which
included consideration of public comments received, to the respondents on
August 18, 1989. A revised, final RI/FS was due to be submitted to EPA
on Septanber 18, 1989 but none has been received to date. Consequently, this
ROD is being prepared without a final RI/FS.
7his Responsiveness Summary will provide EPA'sresponse to Public
CQTIments received.
I.
Comments Submitted by Philadelphia Suburban Water Company, July
10, 1989
Ccmnent:
Landfilling has continued past 1984.
Response: Determination whether landfi 11 ing has continued past 1984 will
not affect the remedy. Certainly I landfilling during RD/RA would be in-
consistent with remedial objectives. PA DER has reported that the land-
filling aspect of a Sept~r, 1988, PA DER order is under appeal~
Ccm'I1ent:
Traffic to be permitted on-site should be spelled out.
Response: Activities determined to be inconsistent with the selected rem-'
edy will be controlled as part of the "institutional controls" canponent
of the. remedy. As stated in Section VII.B.S of this ROD, "Any activities
that would jeopardize the integrity of the cap, such as truck movenent on
the cap, or interfere with the leachate collectiion system would be pro-
ilibi ted." Specific weight, volume and location of traffic that would be
allowed will be addressed during Remedial Design.
Comment: EPA influence on permit approvals for relocation of trash trans-
fer facility and potential delays in LOU RD/RA pending issuance of such
permi ts .
Response: The EPA Superfund Remedial Branch has not participated in any.
discussions with DER or Upper Merion Township regardin;J the permit and
zoning applications for trash recycling facility north of Turnpike property.
As continued trash transfer operations at ~'e Henderson Road site. are
considered inconsistent with the selected remedy, these activities will not
. be allowed on-si te once Remedial Action is underway. No delays related to
the facility north of tne Turnpike ure anticipated at this time.
Comment:
Need for EPA oversight during RD/RA.
Should RD/RA be conducted by potentially responsible parties, EPA
.Res2
-------
2
will maintain appropriate oversight of all RD/RA.
Carment: Qualifications of RsnTech.
Response: A contractor has not been selected for RD/RA of the LOU. Should a
RD/RA proceed as "enforcement lead", the qualifications of the Potentiallly
RespollSible Parties performing t:l1e work would need to be approved by EPA.
Ccmnent:
Sinkholes do exist in the vicinity of the site.
Response: The additional lnfo~tion concerning sinkhole activity in the
inmediate area of the site is noted. EPA has requested, as part of EPA's
comments on the draft RI, that the statement in the RI should be reworded to
. reflect t.~ses findings. .
Ccmnent:
No stream flow measurements were made in Frog Run.
Response: The respondents and EPA made several visits on several times of
the year to deteDnine if this stret~h of Frog Run had sufficient water to
collect a sample. The portion of the stream adjacent to the site remained
dry throughout the duration of the RIo. Since no channelized flow was observed,
stream flow measurements could not be made.
Ccmnent: Runoff and the drainpipe which discharges into Frog Run should have
been sal1pled. .
Response: Sufficient runoff from the site to justify the collection of a
semple was not observed throughout the duration of the RI. However, EPA has
included sufficient funds, in the est~ted costs of the selected remedy,
to collect and analyze samples of storm water runoff biannually throughout
the duration of site remediation, should condidtions change in the future.
Cannent:
Leachate is likely to be migrating to UMR.
Response: EPA agrees that the landfill leachate is a maj~ concern for the
LOU, as it presents the majority of the risk to public health. Based 00 t.,e
RI results, there does not appear to be the linpetus for leachate to flow to
UMR in the unsaturated zone, and leachate was not observed discharg ing to
Frog Run. Therefore, the major pathway for the leachate to migrate to UMR
is through the natural soils (silty clay) and unsaturated bedrock to the
saturated zone, where it \llQuld flow to UMR. The migration of leachate
through the natural soils was modeled during the RI using conservative
assumptions, and the results were carried through the Risk Assessrent to
evaluate the effect on public health. EPA has also included, in the selected
remedy, provisions to remove . leachate in the "perched" zone and subsequently
install a leachate collection system, monitor leachate develotment and quali ty
in the "perched" zone, and ground water quality in the bedrock, and the .
contingency to collect and treat contaminated ground water from the bedrock
aquifer. The selected remedy provides a sufficient level of investigation and
remedial action to address the contaminated leachate associated with the LOU. .
Ccmnent: The two soil borings which have bE?en done in this area to date are.
not adequate for the purpose of determinio:;J the risk associated wi th stopping
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3
the cap at the western edge of ~~e wateI company's easement. Before consid-
ering relocation of the water ~ain, 3 concerted effort should be ~aje
to characterize the contamindtion under and to tne east of the water Lnain.
PSWC prefers not to move the water main.
Response: EPA agrees that additional characterization is needed in the
vicinity of the water main, as part of Remedial Design, to fully address
the potential for leakage from the water ;nain aoo ~intenance of the water
main to interfere with remedial opjectives. In consideration of protection
of i1Uman health am state acceptance aoo for costing purposes, movement of
toe water ,Thain to tne east, crossing under the Upper Merlon Townshlp sewer
line, Frog Run, aoo the SEPTA railroad tracks, ~~en alon:J the eastern side of
those tracks to Church Road, then back under the tracks, stream and sewer to
reconnect to the main at Church Road, as described in your June 12, 1989 .
letter to EPA, is iocluded in the selected remedy. However, other engineerin:J
options regardin:J the water main and extent of the cap may be considered .
during Remedial Design. Providing remedial objectives are met an alternative
to movi~ tile water main may be selected during Remedial Design. PA DER will
be provided an opportunity to participate in this final decision.
Ccinrent:
Glasgow, Inc. may not be using UMR water.
. Response: Glasgow Quarry, Inc. is listed in the draft Workplan for RD/RA
for the Injection Well Operable Unit as an owner of property potentially
affected by the injection well. Institutional controls are planned to be
implemented as part of RD/RA for the Injection Well Operable Unit. Asappro-
priate, institutional controls for RD/RA for the LOU will be added.
Comment: The tax parcel map incorrectly identifies william H'Hara Jr. as
the owner of parcels 10, 20 and 25.
Response:
This comnent was included in EPA IS conments on the RI/FS.
II.
Ccmnents fran F. Costanzi, PA DER, dated July l2.c. 1989
The distance to UMR is 2,000 feet.
Ccmrent:
Response:
This correction has been made in the ROD.
Ccmrent:
DER agrees that a PA cap will il1eet our standards.
Response:
No response needed.
Ccmnent: More emphasis is needed on 0' Hara I s role in waste disposal
operations compared to Ellis Concrete's role.
, .
i
Response: Section 1 to the ROD sumnarizes the information known regarding
surface waste disposal operations at the site. The potentially Responsible
Parties have not provided records of materials disposed at ~'e site.
Comment: PA DER I S Residual Waste regulations, now in draft form, should
be available in final form in time to be useful to address remediation in
the western portion of the si te.
Response:
When these regulation are finalized, their applicability,
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4
relevance, and appropriateness will be determined. Exhibit 17, which is
trie same as Table 2-1 to the draft FS, lists these proposed regulations
as relevant and appropriate.
Comment: Further characterization on the Turnpike property is necessary
in L.ght of the minimal sanpling previously conducted. Use of in-situ
soils to prevent downward migration is not wholly accepted.
Response: EPA agrees that additional cnaracterization is needed prior
to design of a remedy on the Turnpike property. However, excavatioa and
consolidation of shallow. soils and fill is eXPected to be consistent with
remedial objectives, will meet Land Ban requirements, and is more cost-erfect-
lve than incineration. The selected remedy includes, for costing purposes,
implamentation of runon/ runoff controls, leachate collection, and construction
of an asphalt cap over 33,0"" square feet of the Turnpike property. Section.
II-B.8 of this ROD states, "Other appropriate remedial measures on the Turnpike
property may be selected during RD to support the remedial objectives for the
LOU ." .
III.
Ccmnents Provided fran Ragesh Patel, PA DER, dated July 12, 1989
The cap should meet PA DER requirements.
Canrent:
Response: PA DER will be provided the opportunity to review design plans.
EPA expects that state ARARs !tlay be met in final cap design.
Ccmnent:
etc.
There is no 3ynopsis given for the French drain location, material,
Response:. Design or the leachate collection system will occur during Remedial
Design, after additional characterization of trielow permeability layer of
the landfill is completed.
Canrent: The retaining wall should be structurally sound and aesthetically
acceptable towards the turnpike side. The waste between the retaining wall
and the turnpike should be disposed of in a responsible manner.
,
Response: A retaining wall that is not structurally sound would be inconsis-
tent with remedial objectives. Excavated waste from the Turnpike property
will be placed on the Henderson Road site. This is eXPected to meet
RCRA Land Ban requirements.
Ccmnents Provided from John Fabian, PA DER, dated June 5, 1989
IV.
Carrnent: Although water mains are pressurized, a break of even maintenance
elsewhere in the system can result in a loss of pressure in this section of
the main. Infiltration of leachate through a pipe joint or crack could
result.
Response: This consideration will be fully addressed in Remedial Design.
Unless an alternative to rnovi1'J3 the water main is designed that meets remedial
objec~ives and ARARs, the water main will be moved.
Ccmrent: How dOes PS~ plan to provide maintenance to this main if it is
denied permission to break the solid waste cap in order to gain access to
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5
the pipe?
Response:
This consideration will be fully addressed in Design.
Coorrent:
Pipe could interfere with leachate collection.
Response:
This consideration will be fully addressed in Design.
Ccmnent:
A leaking pipe could jeapardize ~~e integrlty:of the cap.
Resf)Onse:
This consideratlon will be fully addressed in Design.
Coorrent: Would PSW:: assume liability for spread of contaminants
if pipeline ruptures after the RA contractor has left the site?
Response: An acceptable alternative to moving the pipe would need to be
based on demonstration that such a release of contaminants from a ruptured
water main would not occur. It is possible that PS~ would be provided the
opportunivj, during Remedial Design, to accept the liability for a ruptured
.nain. This ROD .
proposes moving the water main, unless an alternative that meets remedial
objectives is designed. Therefore, PSWC has not been approached on this
issue. . .
Ccmnent:
The following three options may be acceptable:
1. The water main is abandoned and water service is picked up by
remaining connections (if they exist) . .
2.
A new water main is constructed arourrl the site.
3. The P~~ ROW is excavated, lined and backfilled thus restoring
it to its original condition.
Response:
These options will be considered in Remedial Design.
v.
Ccmnents Provided fran Pennsylvania 'I\1rnpike Carm~sion, dated
July 11, 1989
Ccmnent:
Institutional controls should not hinder future Turnpike expansion.
. .
Response: As stated in Section VILB.8 of this ROO, "To the maxirm.Jn extent
feasible arx3 cost-effective, ground water and leachate v.ould be recovered and
monitoring activities would be conducted off the Turnpike property in order
to prevent a conflict between Turnpike expansion and ranedial efforts."
. .
After trash and shallow soils are excavated from tlle 'I\1rnpike property, contam-
ination may be left in the vadose zone. Contaminated leachate is likely to be
generated on ~'e Turnpike property unless appropriate remedial action is taken.
Thus, EPA and the Turnpike Carmission will need to work closely together during
RD/RA of the LOU and during design and construction of expansion of the Turnpike
near the site in order that the Turnpike may be expanded in a manner that is
consistent with ranedial objectives. .
Ccmnent: The 'I\1rnpike Ccmnission should be consulted and plans for expansion
should be considered prior to determining the actual location of any well to
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6
be located on the Turnpike property.
Response: Access agreements would be instituted prior to installation of
any well on the Turnpike property. See response above regarding consider-
ation of ~urnpike Commission expansion plans.
Comment: The Canmission reserves its right to modify final design of a
retaining wall.
Respons~: No legal response is called for. EPA agrees that flexibility
is needed at this point regarding design issues.
Ccmnent: '1':1e Carmi ssion I s supplemental study wi 11 not be canpleted until
five months after a contract has been executed between the COOT:'Iission am the
contractor.
Response:
This scheduling infor.Dation has been incorporated into the ROD.
Ccmrent: Duri~ the discussion between EPA arXi the Ccmnission prior to the
release of the Proposed Plan, it was agreed that there ~uld be no capping upon
the Turnpike property. '
Response: "Capping" on the Turnpike property as described in the Proposed
, Plan was intended to mean a tecnnology that would miniInize infiltration of
water into the subsurface, so that generation of leachate on the rurnpike
property would be minimized. The, type of cap, whether asphalt, vegetative,
or d PA Solid Waste cap along portions of the Turnpike property south of the
retaining wall, will be determined in Remedial Design, after the Turnpike
property is sufficiently characterized and in full consideration of planned
excavation.
VI.
Comments Provided on Behalf of AlumaxInc., Childers
C , Con oleum Cor ration, Sandvik, Inc., Scott
and the Smi thKline Beckman Corporation
Ccmnent: "Respondents" for the RI/FSs for the two operable uni ts are
different.
Response: EPA considers all signators to the 1985 Administrative Order on
Consent to be bourxl to canpletio; the RI/FSs for both operable uni ts . The
fact that EPA divided the site into,two operable units, in order to expedite
ground water remediation, does not absolve any signators from their obliga-
tions under the Administrative Order. '
Comment:, Contamination attributable to the LOU differs in type and con- .
centration franthe contamination associated with the I~. The Proposed
Plan ignores that PAHs and aldrin comprise most of the risk and incorxectly
concludes that benzene, chloroform, PeE, 'ICE, 1,3-dichloropropene, hexochloro-
benzene and bis (2-chloroethyl) ether represent the major cancer risk from
ground water. For non-carcinogenic risk associated with ground wat~r expo-
sure, the analysis is similar.
Response: As stated in the Proposed Plan, EPA canbined the PAHs into one
category, leaving 19 chemicals of concern. Otherwise, the percentage of
ground water chemicals of concern that overlap between the two operabl~ unirs
an~, gpnerl.lly ::""C'rr.:':t "i_' \'cc,:~:,~, ,];"L,O
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7
In the analysis of risk to.ground water that is presented in the
proposed Plan, EPA assurces that ci1emicals of concern with K greater
than 10,000 are relatively imnobile and are not likely to po~e a major
threat to ground water. This point is presented in the draft LOU RI on
page 4-39.
The more mobile canpounds detected in the LOU are similar to the IVlJU
chemicals of concern. The LTImObile compounds detected at the LOU are not
likely to be observed at. significant concentrations in the growx: water.
This is one reason why distinguishing betY.1een different "plur.1es" (an
inaccurate tean in this hydrologic regime) may not be possible.
Furtheanore, ground water quality below the landfill and other on-site
surface sources of contamination has not been monitored as part of the RI.
The potential for the LOU to contribute to ground water contamination exists,
and the potential for contamination fran the LOU and IVlJU to overlap and be
difficult to distinguish exists. Info~tion gained during recent geophysi~~l
logging as part of IWoo Reuedial Design further supports EPA I S contention.
tilat ground water affected by the site may be affected by both operable units.
The Proposed Plan only addresSes ground water risks when canparing
IWOU and LOU chanicals of concern. EPA anticipates that surface ranediation
at the LOU (i.e., capping, runon/runoff and erosion controls) may be distin-
guished fran ranediation at the It~U. .
Carment: The statanent in the Proposed Plan that EPA does not expect
to be able to distinguish between the two operable units as to the sources
of ground water cont~nination beneath the site appears to contradict the
draft LOU RI and FS.
Response: The draft RI and FS have been disapproved by EPA. See the
August 18, 1989 letter fram Gerallyn Valls to Robert Buller, in Admin-
istrative Record. . A revised, final RI/FS was due to EPA on September
18 in response to the cornnents attached to Ms. Valls I August 18 letter.
Carment: The lWOU RD/RA approved by the Court neither provides for nor
anticipates the performance of additional investigations, such as inves-
tigation in the western portion of the site. The focus of the unsaturated
zone investigation is on contamination associated with the'lnjection well
that may be present in the unsaturated zone due to EPA' s theory of a well
back-up. There does not appear to be any need to consolidate this work
with investigation of surface sources of contamination in this area.
Response: EPA is not proposin; that the additional characterization for
the western portion of the site, presented in this ROD, should be considered
(or financially supported) as part of lWOU RD/RA. However, because ground
water beneath the western portion of the site may be threatened from either
well back-up or surface sources of contamination, it is reasonable to
collect infoanation on this portion of the site and evaluate the fate-and-
transport to grourx:1 water from. both potential sources together. This way,
one ranedy for the unsaturated zone in the western portion of the site may
be selected without unnecessary administrative delays. .
Carment: The Settling Generators object to any implication in the Proposed
Plan that contaminated ground water believed to be associated with the LOU
is also attributable to the lWOU, or vice versa.
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8
Response: For the reasons discussed above, ground water in the vicinity
~f ~'e site is not expected to be distinguished between operable units.
EPA rec()gnizes that Predesign ror the lWOU was initiated with the intent
of locating on-site monitoring and recovery wells where the greatest contamin-
ation is likely to De found from the inJection well, i.e., in the western and
central portions of the site. Section 2.6.1 of the lWOU SOW states that additional
recovery wells wlll be iostalled and/or pumping rates will be adjusted to create.
a suitable cone of depression if contaminated ground water is found to be by-.
passirg the collection system. Thus, it is possible that recovery wells in
the central and eastern portion of the site will be needed as part of the lWOU,
even though contaminated groundwater which may be found in this area may also
be affected by the LOU.
However, it is clear that monitoring and recovery wells in the central
and eastern portions of the site will be needed to characterize and recover
ground water affected by the landfill. Alternative 7, as described in the
draft FS, does not adequately address ~,is fact in light of LOU threats to
ground water. .
Exhibit 20 was developed by EPA to depict sane preliminary locations for
ground water recovery and monltorlng wells to supplement the preliminary
locations listed. in the If'l)U SOW. The number and locations of these
wells may be modified during LOU Remedial Design and rost be coordinated
with the ground water mooitoring and recovery planned for the lWOU.
Comment: It is inappropriate Eo ~le FS to address the coordination needed'
between ooth operable units without demonstration of a clear connection
between tne contamination found in both units.
Response: As discussed above, it is reasonable to anticipate that ground
water may be affected by both operable units. EPAacknowledges that
coordinating ground water RD/RA between both operable units will be complex;
this is a lnajor reason why the need for such coordination is emphasized
in the ROD.
VII.
Carments Sukmi tted on Behalf of 0' Hara Sani tattbn Cattpany, dated
July 12, 1989
Carment:
ownership of the site is inaccurately portrayed.
Response:
Principal owner is Betty O'Hara, Trustee.
Ccmnent:
Loose refererx:e to injection of waste by "O'Hara.1I
Response: Reference to individuals and/or canpanies directly involved
in waste injection is not included in the ROD.
VIII. Carments Submitted on Behalf of William J. O'Hara, Inc., Estate
of William O'Hara, Sr., and Betty E. O'Hara, July 12, 1989
Carment:
Unit."
Respondents do not accept the validity of the IlLarxifill Operable
Response: EPA fully considers the Landfill Operable Unit to be part of the
slte. EPA considers all respondents to the 1985 Administrative Order on
Consent to be obligated to cauplete the RI/FS for the Larxifill Operable
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9
Unit. A Compliance Schedule fo~ the LOU RI/FS was initiated under the
Administrative Order in a letter, dated November 2, 1987, from Gerallyn
Valls to Alan Robinson, arx1 modified in accordance with the terms of the
.;dministrative Order, during the developnent of the RI/FS.
Comment: Many of the key assumptions and methodologies used in the RI/FS
do not represent the independent opinion or findings of 8CM.
Response: The utility of preparing an RI/FS is to provide the basis
for EPA's selection of a remedy. EPA disapproved the draft RI/FS in August,
1989, for the reasons included in tne disapproval letter. The documents
listed in the Administrative Record, including those prepared by Camp Dresser
& McKee, form the basis for the remedy developed and selected by EPA.
Additional oversight costs have been incurred because the information included
in ~'e draft RI/FS was insufficient to complete this ROD.
Carment: There is no basis for the need for any ground water monitoring.
There is no documentation that the ground water has been contaminated by
the LOU or any substances migrating from the LOU.
Response: No ground water Inonitoring wells considered representative of the
LOU have been instdlled. The Risk Assessaent, Fate-and-Transport
Asses $lent , and this ROD all conclude that the LOU is expected to threaten
ground water beneath the site and contribute a substantial human health
risk.
Carment: Ground water recovery being undertaken as part of IWJU RD/RA
will collect leachate migrating from the LOU.
Response:
Sumnary.
See the first response listed on page 8 to this Responsiveness
CQ~nt: Institutional controls being implemented under the IWJU will
address the ground water camponent of the LOU.
Response: Since the LOU is considered to contribute to ground water con-
tamination, institutional controls pertaining to ground water remediation
are considered to apply to the LOU.
Carment: As discussed in Section VII.8.8 of this ROO, excavation on the
Turnpike property prior to capping the Henderson Road site is most cost-
effecti ve.
Response: Unless the cap is in place before removing leachate, it would
reenter the unit through infiltration of rainfall. It is premature to
decide exactly when to ~lement leachate collection.
Carment: EPA agrees that many concern3 related to design of the cap
and leachate collection should be left to Ranedial Design. However,
based EPA's experience in closing other landfills, EPA expects that leachate
removal prior to capping would remove leachate from the unit more effectively
than after capping. Capping and long-ter~ leachate collection would immediately
follow leachate ranoval so that infiltration would not occur. "Short-term"
does not mean lIimnediate; II leachate collection would occur after the RD/AA
Workplan is approved. .
Carment: . Rapid leachate ranoval will no more reduce risk than Alternative
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13
most concentrated contaminants, because infiltration has occurred over a
long period. Because short-term leachate removal is expected to be more
effective in reducing leac11ate than collection. of existing leachate after
capping, the. risk reduction is considered to be relatively significant.
Comment: The Risk .\s3essment used in ble Proposed Plan is not technically
supportable.
Response: The Risk AsseSSinent used in this ROD is consistent with the EPA
Superfund Public Health Evaluation r1anual. However, EPA agrees that the
fate and transport of contamiaants needs to be carefully considered in
assessing risk for this site. Discussions in various sections of this
ROD address the canplexity of the "true risk. II
EPA has concluded, for the reasons set forth in this ROD which include
consideration of assumptions used in the risk assessment, conclusions fran
the Fate-and-Transport Assessnent, the contribution from the lWOU, remedy
being implemented for the lWOU, and potential release to UMR, that the
LOU presents a substantial risk fram exposure to ground water and inhal-"
ation and ingestion of fugitive dusts. The major chemicals of concern
are bis(2-chloroetilyl) ether and volatile organics.
Catr.1ent: Tlle evidence in the RI/FS clearly proves that E'rogRun contam-
ination originates upstream.
Response: while existing data indicates that contamination may originate
from upstre~~, definitive conclusions based on three sediment samples
cannot be made. Additional sampling and runon/runoff and erosion controls are
needed to Jleet ranedial objectives.
Cam1ent:
EPA's comments in the Proposed plan that the FS does not take
-
both operable units. The Statement of Work for RD/RA for the lWOU was
completed in October, 1988, which was several months befoe completion of
the draft FS.
Ccmnent: EPA' s ccmnent that Al ternati ves 1 through 6 do not address
ground water that is already contaminated is misleading because it is not
reasonable to expect the LOU to be responsible for existing ground water
contamination unless it is first established that it is the source of that
cont~l1ination.
Response: . For the reasons set forth in this ROD, EPA considers the LOU to
potentially contribute to on-site and downgradient ground water contamina-
. tion.
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~r3!':' :LO
TABLE 4-11
STUDY CHEMICALS. Koc VALUES
HENDERSON ROAQ SITE
LANDFILL OPERABLE UNIT
Chemical"
Koc
Benzidine
Bis(2-chloroethyl)ether
1.2-Dichloroethane
Ch 1 oroform '
Benzene
Carbon Tetrachloride
Trichloroethene
Tol uene .
Tetrachloroethene
alpha-BHC
Nexachlbrobenzene
Fluorene
Heptachlor,
Phenanthrene
Hexachloroethane
Hexachlorobutadiene
Fluoranthene
Dieldrin
Aldrin .
Bis(2-ethylhexyl)phthalate
Chlordane
DDT
PCB-1254
PCB-1248
Benzo(k)fluoranthene
Benzo(a)pyrene
Benzo(a)anthracene
11
14
14
58
83
110
126
300
364
3 . 800 ,
3.900
7.300
12.000
14.000
20.000
29.000
38.000
43.000
96.000
123.027
'1 40 . 000
243.000
530.000
530.000
550.000
1.023.293
1.380.000 '
Source: BCM Engineers (BCM Project No. 00-5808-02)
-------
(Continued)
Page 3
Specific Type Proposed Leral hphnation of Applicability to
ARAR legal Ci tation Clanificat on Chnitication FS Options
Federal (Continued)
S. Clean Ai r Act Contalllinant
a. National Ambient Air 40 CFR Part 50 Applicable or Enforceable standards for direct For gas venting. at80spheric
Quality Standards (40 CFR Part 61 Relevant and or indirect emissions to the emissions during treat8ent
(NAAQS) for Huardous Appropriate at80sphere or non-isolation of unit is
Air Pollutants) selected. these regulations
8.y be applicable.
16. To.ic-Substances Control Ac ti on 40 CFR 161 Relevant and Enforceable regulations for "al be relevant and appro-
Act (TSCA) Appropri ate disposal and storage of PCBs pr ate to regulate disposal
of PCBs
a. PCB Spill Cleanup Ac ti on 52 FR 10688 To be Considered Policy statenent establishing To be considered for r...-
spill reporting requirements and diation of PCB cont..ination
cleanup perfonaance standards
1'. Resource Conservation and Action 40 CFR 264 Relevant and Enforceable regulations for non- If offsite hazardous waste
Recovery Act (RCRA), Appropriate CERCLA hazardous waste storage. remoyal option is selected.
including "land Ban" treatment and disposal sites. RCRA subtitle C Is appli-
Requiretnents SARA e..-ption fro. land Ban cable to destination.' For
requir....nts for "Superfund" onsite disposal option;
sites until Nov88ber 8. 1990. releyant and appropriate.
Also proyides guidance on
closure options.
~
8. DOT Rules for Hazardous Ac ti on 49 CFR Parts 101 Applicable Enforceable regulations for Applicable if partial or
"-terials Transport - and 111-119 transport of hazardous materials .ajor elcayation results
in offsite disposal of haz-
I ardous was tes.
I
[
9. Occupational Health and Act i on 29 CFR Parts 1904 Applicable Enforceable regulations proyides Applicable to onsite work
Safety Act (OSHA) 1910. and 1926 health and safety requirements perfonned during i~l...n-
for onsite workers tation of a renedia action.
. .
I .
, .
-------
(Continued)
Page 4
ARAR
Specific Type
Lega1 Citation
Proposed Lega1
C1&ssification
E.p1&nAtion of
C1&ssification
Applicability to Pha.e
3 FS Options
Pennsv1vania
1. PA Safe Drinking Water Act Cont..inant PL 206 (1984) AppHcab1e Statute corresponding to Federa1 Hay app1y to contingent
SOWA to protect pub1ic drinking ground~ater recovery
water suppHes . and treat8lent.
(a) PA Safe Drinking Water Conbli nant PA Code. Tit1e 25. App1icab1e When deve10ped. wl11 provide Hay app1y to contingent
Chapter 109 (Future) standards for drinking water ground~ater recovery and
cont..lnant 1eve1s. treat8lent.
2. PA C1ean Stre..s Law Act i on PA Code Tlt1e 25. AppHcab1e Enforceab1e 1aw intended to App1icab1e if discharges
Chapter 5 rec1ai. and restore p011uted of cont..lnated wat.r to.
stre..s through wat.r qua1ity ephemera1 str... is inc1uded
contr01. in remedia1 action (ground-
(~ater or 1eachate tr.at8tnt
a1so ston8Water discharg.s).
(a) Genera1 (Provisions) Ac ti on PA Code Tit1e 25. Re1evant and Estab1ishes procedures and Re1evant and appropriate for
Chapter 91 Appropri ate regu1atory frame~rk for C1ean reeedla1 actions Inv01ving
Stre..s La~. wastewater discharges.
(b) PA NPDES Ru1es. Ac ti on PA Code Tlt1e 25. Re1evant and State progr.. governing point- App1icab1e for actions
Chapt.r 92 Appropriate source discharges. inv01ving dlschar,e of
p011utants to sur ace water
(groundwater or 1eachate
treat8lent a1so. ston.water
discharges).
(c) PA Water Qua1ity Contallinant PA Code Tit1e 25. App1icab1e Enforceab1e standards for waters App1icab1e for actions
Standards ~Chapter 93 that are to be protec~ed. invo1ving discharge of
p011utants to surface wat.r
(ground~ater or 1eachat.
treatment a1so. ston8Water
discharges) .
-------
Page 5
(Continued)
ARAR
Specific Type
Legal Ci tat ion
Proposed legal
Classification
hplanation of
Classification
Applicability to Pha,e
3 FS Opti ons
Pennsylvania (Continued)
(d) Municipal Pretreabnent Action PA Code Title 25. Relevant and Enforceable regulations for dis- Relevant and appropriate for
Regulations Chapter 94 Appropriate charge into publicly owned renedial actions involving
treabnent vorks (POTW). vastevater discharge to
POTW.
(e) PA Wastevater Treatment Action PA Code Title 25. Applicable Enforceable reyulations to .ain- Applicable for remedial
Regulations (includes Chapter 95 tain vater qua ity through treat- actio~s involving discharge,
PA Toxlcs Strategy) ..nt requireMents and standards. to eph...ral stre. (frOil
groundvat.r or leachate
treatllent) .
(f) PA Industrial Waste Action PA Cod. Title 25. Relevant and Enforceable industrial vaste Relevant and appropriate
Treat..nt Regulations Chapter 91 Appropri at. tr.atllent requireMents and for reaedlal actions
standards. involviny discharges to
.phemera stre... (fr-
groundvater or leachate
treat8lent) .
[ (g) PA Special Water Action PA Code Title 25. Relevant and Requirenents for spill notifica- Relevant and appropriate for
Pollution Regulations Chapter 101 Appropriat. tion and landfill bonding. remedial actions involving
landfill closur..
3. PA Air Pollution Control Cont.inant PL 2119 (1960) Applicable Enforceable standards vhich Applicabl. to r...dial .
Act of 1960 and Air PA Code Title 25. include NAAQS plus 5 additional actions involving direct or
Pollution Control Chapters 121-143 consti tuents Indirect ..issfons to the
at80sphere. (Gas venting.
leachate tr.abDtnt .xcava-
tions. dust ..Issfons.)
~
4. Pennsylvania Solid Waste Action PL 91. Ii t1 e 35 Applicable Comprehensive statute governing Applicable for offsite
the transportatlon. processing. disposal and onslte closure.
treat8ent. storage. and disposal Closure plan required for
of all solid vastes. SWKJs.
-------
(Continued)
Page 6
ARAR Specific Type legal CHation Proposed lerAl bphnation of Applicability to Phase
ClassHicat on Classification 3 FS Opti ons
Pennsylvania (Continued)
(a) PA Hazardous Waste Action PA Code Title 25. Relevant and Enforceable regulations corres- Relevant and appropriate for
Appropri ate ponding to rederal RCRA reyula- offsite disposal and waste
tions. Govern the gene rat on. classification.
transportation. and disposal of
hazardous wastes.
(b) COnDonwealth Municipal Action PA Code Title 25. Relevant and Enforceable regulations for non- Relevant and appropriate for
Waste Regulations Chapters 211-285 Appropriate hazardous waste disposal. r8D8dial actions which
involve the unit as a solid
waste landfill and for gas
and water quality ~itor-
ing. Also provides clloure
standards.
(c) PA Residual Waste Action PA Code Title 25. Relevant and Enforceable regulations f~r Relevant and appr:triate for
Regulations (Proposed) Chapters 281-289 Appropriate non-h&zardous residual waste reDedial actions ich
(Proposed) disposal. which are presently involve residual wastes
covered by the C0880nwealth (such as cinders).
Municipal Vaste Regulations.
5. PA.Sto,..,ater Manag...nt Act Action
Act No. 161
Stonnwater runoff control during
alterations to site
Applicable
6. PA Erosion Control
Regulations
PA Code Title 25.
/I Chapter 102
Governs erosion and sedimentation
control to prevent pollution of
surface water
Action
Applicable
7~ PA Hazardous Substances
Transportation Regulations
Ac ti on
PA Code Title 13
and 15
Requir...nts for transport of
hazardous ..terials
App It cab 18
8. PA Floodplain HanagementAct location.
Pl 851. No. 166
Relevant and
Appropriate
Provides for floodplain land-use
lIanag...nt.
I. 4512q
Applicable for r888dial
actions that include land
disturbance. .
Applicable for r8D8dial
actions that include earth-
.oving capping on waste
e.cavatlon.
Applicable for r...dial
actions that involve trans-
portation of hazardous
wastes for offsite disposal.
Relevant and appropriate for
remedial actions within
floodplain ar.as.
-------
RISK CALCTJT....A'!'IONS FOR I}ROU!TJ :';A'!'E~ AFJ\..qs
H~rnERSON ROAD LOU ROD
I
I
I
I
I
I
I
I
I
I
Arsenic and Compounds :
Barium and Compounds :
Cadmium and Compounds :
Chromium :
Copper and Compounds:
Lead and Compounds :
Silver and Compounds :
Zinc and Compounds :
Cyanides :
Benzoi6 acid:
2.4-Dimethylphenol :
Phenol :
2-Hethylphenol (o-cresol) :
p-Cresol (4-Hethylphenol) :
Bis(2-eth~lhexyl)phthalate:
Butyl benzyl phthalate:
1.2-Dichlorobenzene :
1.3-Dichlorobenzene :
Dibutyl Phthalate :
Naphthalene :
n-Nltrosodiphenylamine :
Benzyl alcohol :
4-Chloroaniline :
2-Hethylnaphthalene :
Benzene :
Carbon Tetrachloride :
Chlorobenzene :
Chloroethane :
Chloroform :
Chlorodibromomethane :
Bromodichloromethane :
1.1-Dichloroethane :
1.2-Dlchloroethane (EDC) :
l.l-Dichloroethylene :
1.2-Dichloroethylene-c :
1.2-Dichloroethylene-t :
1.2-Dichloropropane :
Ethylbenzene :
Dichloromethane :
Tetrachloroethylene :
Toluene :
Trichloroethylene :
Trichlorofluoromethane :
Vinyl Chloride :
Xylene (mixed) :
1.3-Dichloropropene :
Pollutant
Cleanup
Level
(ug/l)
50.00
5000.00
10.00
50.00
1300.00
20.00
50.00
5000.00
200.00
700.00
400.00
3500.00
42.00
72.00
512.00
820.00
620.00
470.00
770.00
350.00
71. 00
364.00
35.00
1750.00
5.52
5.00
60.00
19,000.00
100.00
100.00
100.00
5.06
6.02
7.00
70.00
70.00
6.28
680.00
47.00
6.90
2000.00
25.80
12000.00
2.00
175.00
5.00
Mean Risk
to Exposed
Individual
2.50E-03
2.05E-04
9.94E-06
4.57E-06
1. 86E-05
1. 74E-05
1.32E-05
1.57E-05
1.&OE-04
1.13E-06
1. 01E-05
1.01E-05
8.l1E-06
1. 31E-04
2.57E-05
Source: Roy Smith, EPA Toxic~logist, September, 1989
::X:-.::!:3 E' 1..5
Hazard Indey
(Intake/Rfr
2.86
0.99
0.29
1. 00
4.08
0.48
0.68
0.29
0.01
1. 90
2.50
0.01
0.04
0.73
0.20
0.15
0.22
0.03
0.2~
0.2
0.11.
0.20
0.06
N/A
0.29
0.14
0.14
0.00
0.02
0.20
0.10
0.19
0.02
0.02
0.19
0.38
0.00
0.48
-------
' Cleanup Mean Risk
I
I Level to Exposed Hazard Index
I
Pollutant I (ug/l) Individual (Intake/RfD)
I
I
I
Bis(2-chloroethyl)ether I 5.70 1.79E-04
I
Benzidine ' 16.50 1. 08E-01 0.20
,
Hexachlorobenzene I 1. 90 9.17E-05 0.07
I
Hexachlorobutadiene I 0.90 2.01E-06 0.01
I
Aldrin I 0.00 1.94E-06 0.00
I
Benzo(a)pyrene equivalents: 2.50 8.21E-04
DDT I 0.01 1.17E-07 0.00
I
I
I
Total: 1. 13E-01 19.76
4.19E-03
Without benzidine
-------
OCMJ
II
I'
.......-.:-"'..--' .-
..,._.,"",..._...~:.-::--..... -,'"
----
. ;
.. ,'...
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-1..-.;..0.""
HENDERSON ROAD SITE
LANDfILL OPtRAIIU UNlf
, ~,
. ' ',1
\ I <, : '
'I I /
11'/''''''' t.'
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~ / OJ.'
I '
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_lit
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)
{. .
. .
I
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Source:
c:::J l"" 08 MCMA GI t1' ...-s ......... I:.'"
Draft F~) Apr 1989 ' -'".''''''''''.1\1''...-'''
,.,. --~-
~ a cn' .-." "-'-"'.
It {)n~nt. f\ ..
o TurnpI?k of ..1lcrIlIlLt've ~1 cap' may
1 e property .
Delailed Alternalive 3:
~~ and Leachale Colleclion
a cnml~nent of Alt. 8
---
. 'J
I.
:~
I I'
LJJ
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PI
1Wtl
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1-'
'0
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ttEND£RSO
Ula'LL N ROAD SITE
0NaA8L8 ...,
11IeM "'1Dc8dM!I
.... .-or-In..'::' =,1
~.,. AcIY8I WIll
.......
! 'J
!~
t-I
Propo88d ~
R.cov. lIonltoJing and I')
. ry W.II Location. ~
-------
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.. ..... ...... ........ ...,. ar. ........,...... '.c""'.'"
..... .... ...... ..... ......... ... ... .... ,,".rr...
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Pilot Study Proces~ ~chematics
FOB 'l'HEA'1'T NC r. HOLIND \-I J\'T'J.:n: T':JOU -. LOU
lH¥deno61l ~o.d In'ecUon i] 5aao
MontgomelTY County. Penn, Jlvt~"A8
" .
-------
SITE SPECIFIC GUIDANCE DOCUMENTS
1)
Report: Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, Interim Final, prepared by
U.S. EPA, 10/88.
,
9
-------
C:::\C:R,~L Gurr',to,SCE vJct.:~~::~rs *
1) "?rC'~\Jlgat!on of Sices frolD t'pdate.s 1-4." re~eral ?cgister,
J... ~ A .I
"-::_-=-
6/]0/136.
2) "?roposal of update 4." Federal Register, dated 9/13/85.
3) ~~~~randulD to U. S. EPA fro~ Mr. Gene Lucero resarding cO~i.y~i:y re13t~ons-
at S~~erfund Eaforcement sites. daced 8/28/85.
",
4) Ground~ater Contamination and Protection. updated by Mr. Donald V.
Feliciano on 8/28/85.
5) Guida~ce on Remedial Investigatio~sunder CERCLA. dated 6/85.
6) GI1'tda:\ce on Feasibility Studies under CERCLA. dated 6/85.
7) "Proposal of Update 3," Federal Register, dated 4/10/85.
8) ~.;:ot".:indum to U. S. EPA from Mr. Jack ~fcGraw entitled "Co~~\';:1it:l Relations
Act i vit ies at Superfund Sites - Interim Guidance ,I' dated 3/22/85.
9) "Pr.,~osal of Update 2," Federal Register, dated 10/15/84. -
10) ~!A Ground~ater Protection Strategy, dated 9/84.
\ ,
11) ~'-;.:)orandum to' U. S. EPA from Mr. William N. Heckman, Jr. entitl:d
"Transl'Ditta 1 at Superfund Removal Procedures - Revision 2," da ted 8/20/84.
12) "Proposal of Update I," Federal ~eg1ster, dated 9/8/83.
13) ~~'?~nity Relations in Superfund: A Handbook (interim ver$ion), dated
9 i 83.
1 ~) "? ro.:, ~ : sa 1
12;'30/82.
of first r~Hior.al Priority Ust." F'e~eral ~~.s~.!.t c:~:ed
....
15) tl'::x;.~:1ded Eligibt1~ty Ust," Federal Register, dated 7/23/82.
:6) "bterim Priorities Ust ," Federal Register, dated 10/23/81.
17) rr: cont rolled Hazar~ous !'~aste Site Ranking System: A User.' s ~~:;~! 1
(l.l:1dated). .. .
18) Field Standard Operating Procedures- Air Surveillance (un~at~d).
19) Field Standard Operati~g Procedures- Site S1fety Plan (\:::,~.3C:'~).
*Locatp.d in U. S. EPA Region III office.
,
-------
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-------
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) FOR THE HENDERSON ROAD LOU
ARAR
Speciftc Type
Legal Citation
Proposed Legal
CIlSsifiution
hphnatton of
CIlSstflution
Applicability to
FS Options
federal
1. Safe Drinking Water Act
a. MI.I.... Cont.inant
leve 1s (t.cl s )
b. MI.I.... Contaelnant
level Goals (t.clGs)
c. Secondary "a.i~
. Cont.lnant Levels
d. EPA's Groundwater
Protection Strategy
2. . Clean Water Act
a. Ambient Water Quality
Criteria (AWQC)
Contaeinant
40 CfR Put 141
SARA Section 121
(d)(2)(A)( I I)
40 CFR Part 143
Action
None
Cont_inant
Pl92-S00
~
Section 304(a)(I)
AppHuble
Relevant and'
Appropriate
To be considered
To be considered
To be considered
Enforceable STDs for public
drinking water supply systeas
Non-enforceable guidelines that
do not consider the technical
feasibility of cont_lnant
r880val
.Non-enforceable guidelines for
public drinking water syst..s
unenforceable polley regarding
protection of groundwater,
resourus
Non-enforceable. used to develop
s tlnduds
If contingency groundwater
trea~nt Is triggered
through .onltorlng. SOWA
requireaents ..y be appli-
cable (Hels) or -to be con-
sidered" (secondary tEll)
and (HelGs) to groundwater
at the property line.
See Above
See Above
To be considered If ground-
water treat8ent Is triggered
through 8Onltorlng.
If contingency Yroundwater
treat..nt Is tr ggered
through 8Ontoring. CWA
requirements ..y be a lito
be consideredll (AWQC). Mly
also be applicable for lur-
face water discharges If
-receiving water is con-
sidered navigable (NPOES).
I 'J
N
H
l11
H
,;)
t-'
-..j
-------
(Continued)
Page 2
ARAR
Specific Type
legal Citation
Proposed Legal
Classification
hplanAtion of
Classification
Applicability to
FS Opti ons
Federal (Continued)
b. General Pre-treat.ent
. Regulations
3. EPA Health Advisories
4. . Health Effects Assessments
( HEAs)
Contaminant
Contaminant
Contaminant
40CfR Part 403
EPA Office of
Drinking Water
None
~
Relevant anC:
Appropriate
To be considered
To be considered
Enforceable standards for
discharge to a POTW
.Non-enforceable guidelines for
public water supply syst..s
Non-enforceable toxicity data for
specific ch..icals for use in
public health assessments. Also
. to be considered are carcinogenic
potency factors and reference
doses provided in the Superfund
Public Health Evaluation Manual
(EPA. 1986)
If continency groundwater
treatment is required. these
regulations may be relevant
and appropriate to a
recovered groundwater dis-
charged. Also relevant and
appropriate if leachate is
pretreated and/or discharged
to a POTW.
To be consid.red if con-
tingency grrundwat.r treat-
ment is trigg.red through
.onitoring. Health advI-
sories may be applicabl.
for cont..inants not regu-
lated under SOWA.
To be considered where reDI-
dial alternativ.s addr.ss
risk-based criteria or
standard setting for
c1eanup.
Also appli.s to dust ..is-
sions. ..issions during
excavation and ..isslon
fr08 leachate or ground-
water treat88nt units.
. . .
..'
.
. .
. .
-------
EXHIBIT 11
SUMMARY OF CANCER RISK fACTORS AND HAZARD INDICES
INJECTIONH~~h[JR~QjW ffil
UPPER MERION. PENNSYLVANIA
Model
Descrtptton
CRf'
HI
~enarto I:
Model I:
Model 2:
Model 3:
Model 4:
Scenarto II:
. Model 5:
Based on a hypothetical sa8Ple using aggregate 8iXllU8
(oncentratlons (Including HR-2-195) fr08 Site wells (I.e..
data do not represent an actual sa8Ple)
Direct Ingestion of hypothetical sa8Ple
SI8Ulated Incorporation Into the UMA of hypothetical sa8Ple
SI8u1ated Incorporation Into the UMA of the hypothetical sa8ple
for all che.lcals of concern added to aggregate 8iXI808
concentrations found In the UMA .
SilUlated tncorporatlon Into the UMA of Site chealcals DOt
found tn the UMR and 8ixlau. concentrations found In the UMR
Based on a hypothettcal sa8Ple using average concentrations
fro. Stte wells (without HR-2-195 or HR-5-192)
" . .
St.ulated tncorporatton Into the UMR for all chealcals
of concern. .
Scenario Ill: Based on concentrations of che.tcals found In untreated
UMR water. Aggregate lllixtmu. values cOllptJed fro. al1 data
Model 6:
Hodel 7:
Maxtmum concentrations In untreated UMR water for chemicals
of concern
Average concentrattons In untreated UMR water for chemtcals
of concern
36.284
1.091
1.211
188.6
251.5
181.4
15.8
385.6
11.6
13.1
2.9
3.1
."
..
2.2
0.6
C\l
0:.
t-4
o
o
<=>
l~
I
,
1-1
W
H
11
1--'
I.""
r-
-------
.,
~.
,
(f-::XHIBIT 11 COOT'D)
Hodel
Descrlptton
CRF
HI
Hodel 8:
Maxl.u. concentrations In untreated UHR.water for a'i
che.lcalsfound In the UHR
2.3
228.0
Model 9:
Average concentrations In untreated UMR water for all
che.lcals found In the UMR
0.6
86.6
Scenario IV:
Based on concentrations of che.lcals found In treated OHR.
vater. Aggregate .aXl8U. values used.
Maxl8U. concentrations In treated UMR water for che.tcals of
concern
..
19.2 1.5
6.2 0.1
44.0 1.5
18.1 0.1
6.8. 0.009
'-,1.
Model 10:
Mode 1 11:
Average concentrations In treated UHR water for che.lcals of
concern
Mode I 12 :
Maxl8U. concentrattohs In treated UMR water for a'i
che.lcals found In the UMR
Model 13:
Average concentrations In treated UMR water for ai'
che.lcals found In the UMR
~
Mcilvain Hell Hater
I.
eFR. Probability of cancer Incidence In a population of 1,000,000 people
HI . Hazard Index
Source: BeM Eastern Inc. (BCM Project No. 00-5528-02)
1'\... .
\. ..J .
0:
,..-1
,.....
-
<:)
C
. .
.
, .
-------
EXHIBIT 12
~
~.
.....
o
<:)
o
J'.
I . CAIICIIIOIiENIC 11151 ASSESSMENI
INJECTION WELL OPERABLE UNIT
_"1501 lOAD 1111
UPPfl .11(11. HIIIsnVAIUA
Ch_iul
bposw. ....,. ".ed~ ConcentraUana at lit.
, .
. Model 1
...., 1
...., 4
...., ,
....1 2
C.rcinogens found Onl~ .1 Slle
Clf 'ercent
. caf .'ercent
Clf 'ercent
Clf '.rcent
liIC2-flh~Iha.~I) Phlh.I.la
4-thloroanll lna
N'.ilrolodiph~l..ine
C.rcinogens found..1 Slla end UMI
I
len,ene
ChI oro' 01'8
I.I-O',h'oroethena
1.2-DI,hloroelh.ne
1.'-DI,h'oroelhene
.Methrlene ch'orlde
letrachloroethene
Ir Ichloroethene
vln~1 chloride
C.rbon 'atrachlor Ide'
Olch'orObr0808ethene'
Dlbr08DChlor08elhene'
101.1 Cancer lilk faclor
CPer 1,000,000 People)
Clf '.rcent
.
6.64 0.0 O.ZO 0.0 O.ZO 0.0 O.ZO 1.1 0.01 I.'
]1.49 0.1 .0.92 0.1 1.92 0.1 0.92 8.S 1.J8 8.1
5.60 0.0 0.11 0.0 0." 0.0 0.11 0.1 0.01 0.0
2,525.11 1.1 15.11 6.9 16.51 6.0 1.14 0.4 Zl.J4 10.1
1.002." 2.1 11.98 2.9 82.15 6~' 52.11 21.' 1.64 J.I
1.141.00 21.4 Zn.44 21.1 215.04 11.4 2.60 1.4 62.66 24.4
1.066.00 2.9 JI.90 2.9 n.50 2.S 0.51 I.J 1.. J.I
1,690.29 4.1 51.51 4.1 59.66 4.1 1.29 4.4 24.86 '.1
IIl.14 0.5 5.46 0.5 6.11 O.S 0.11 1.4 I.OS 1.4
14.210.00 ,.4 421.40 )9.) 4)).19 14.1 S.S9 .2.9 J." 1.4 .'
191.11 0.5 5.15 O.S 9.11 0.8 4.1ft 2.1 1.K 8.'
6,511.41 11.1 191. 14 11.1 262.86 ZO.6 65.11 14.1 111.11 4J.' ,.
,.
)11.41 1.0 11.14 1.0 14.86 1.2 J.l1 2.0 J.. t.1
)11.41 1.0 11.14 1,0 41.54 J.1 16.40 19.J J." t.1
240.00 0.1 1.2 0.1 U.68 1.1 6.41 J.4 1.99 0.8
16,28).96 1.090.98 1,216.55 188.66 . 256.59 ~
H
tJj
H
13
t-'
I\)
-------
lapos""e Mode'. bued .. .O.t. for Upper llerl.. ...erw'r
If)
0-:
~
o
o
<:)
(EXHIBIT 12 CONT'D)
untre.ted UMI W.ter Ire.ted UMI Weter
Ch-In' Mode' 6 Mode' 7 Mode' . Model 9 ...., 10 1Iodt, II 1Iodt, 12 IIodtI IS
I Clf Percent Clf 'ercent elf 'ere..t elf 'ercent Clf 'ercent elf 'erc..t elf 'ercent af 'ere...
I.rcioogens fCKnt .t Site 8f1d UMI .
I
!
anoe 0.74 0.4 0.74 1.0 0.74 0.) 0.74 0.9 0.74 ).9 0.74 12.0 0.7' 1.1 0.14 4.0
Jlnrofor. S2.n 2'.1 1.)9 I.' S2.n 2).1 1.)9 1.6 2.55 I).) 0.69 11.2 2.55 5.' 1.69 1.1
I-Oichloroethene 2.60 1.4 1.)0 1.7 2.60 1.1 1.)0 1.5 1.56 '.1 0.52 '.4 1;56 ).5 1.5l 2.'
2-0ichloroethene 0.52 0.) 0.26 0.1,. 0.52 0.2 0.l6 0.) I.. 10.' 0.26 4.2 2.. 4.1 0.26 1.'4
,I'Oichioroethene 1.29 4.4 1.66 2.2 '.29 1.6 1.66 1.9 4.91 25.9 1.66 16.1 4.91 11.) 1.66 ...
.'hy'ene Chloride 0." 0.4 0.02 0.0 0." 0.) 0.02 0.0 0." 1.5 O.R 0.). 0." O.l 0.02 I.'
,trechloroethene 5.)9 l.9 1.11 1.5 5.J9 1.4 1.11 I.) 0.44 2.) 1.15 2.4 0.44 1.0 0.15 0.1
Ichl oroethene 4.05 l.1 1.11 l.' 4.05 I.' I. II 1.4 1.95 10.1 0.50 1.1 '.95 4.4 0.50 2.i
nyl Chloride. 65.71 15.1 65. 7t 86.7 6S. 71 28.8 65.71 75.9 . 0.65 ).4 0.65 10.5 0.65 1.5 0.65 1.5
lrbon 'etrechlorlde' 5.71 2.0 0.)1 0.5 ).71 1.6 0.)1 0.2 I." 15.S 1.)1 1.2 2.91 6.' 0.)1 2.0
chlorObr0808ethane' 56.40 19.4 0.74 1.0 56.40 16.0 0.74 0.4 0.74 ).9 1.)1 1.1 0.)7 0.8 0.)1 2.0
brl80Chi orC8ethene' 6.48 5.5 0.24 0.) 6.48 2.8 0.24 0.1 0.48 2.5 1.24 0.1 0.48 1.1 0.24 I.)
rc inogens fCKnt On, Y .. UMI
"
i,2;2.'.trech'oreth... 0.00 0.0 0.00 0.0 6.29 l.'
~,J-'rlch'oraprGfNW1l 0.00 0.0 0.00 0.0 54.29 15.0
181 Cencer IIlk fector 181.41 75." 227.95
I :r 1,000,000 People)
0.51 0.7
10.29 11.9
0.00 0.0 I.. . 0.51 1.1
0.00 0.0 ! I.. . "24.S7 55.9
19.22 '.1' 45.99
0.57 ).0
Il.OO 64.0
86.57
18.14
'~ce: leM fest ern Inc. CProject 10. 00'5528-02)
~
H.
W
H
~:J
~h-iu" not fatrd In Iite-releted .8llplel. Iisk ulcu'.U... based an detec:tlan 1I.1t1.
1-' .
- I\)
.' I
-------
HAZARD IIIDEX (HI) fQR CHEMICALS WITH a-WCIIIOGIIIC EffECTS
INJEC'I'IO~T ~'TELL O?:::?A3~E mrr'I'
HEIIDERSOI ROAD SI~r
UPPD MEIUCIII, PEIISTLYAIUA
Model 1 Model 2 Model 3
Ch_fC8l HI '.rcMC HI '.rCMe HI P.rcMe
Ch_fC8l1 ~ith Non-clrcinogenic Effecta found only Ie Site
Benzoic Acid 0.5857 0.2 0.0176 0.2 0.0176 0.1
Benzyl Alcohol 1 .4857 0.4 0.0429 0.4 0.0429 0.3
Bfl(2-Ethyl~8XYI)Phthllatl 0.4857 0.1 0.0146 0.1 0.0146 0.1
Butyl Benzyl Phthilite 3.3416 0.9 0.1002 0.9 0.1002 0.7
4-Cltlor08nflf". 1.6571 0.4 0.0416. 0.4 0.0416 0.4
2,4-01..thylphenol 0.1117 0.0 0.0034 0.0 0.0034 0.0
Of-n-butyl Phthalltl 0.0519 0.0 0.0016 0.0 0.0016 0.0
2-M8thylnaphthllene 0.0229 0.0 0.0007 0.0 0.0003 0.0
2-M8thylphenol 11.6600 3.0 0.3500 3.0 0.3500 2.6
4-M8thylphenol 4.7143 1.2 0.1414 1.2 0.1414 1.0
Naphthllene 0.001' 0.0 0.0000 0.0 0.0000 0.0
Phenol 0.0200 0.0 0.0006 0.0 0.0006 0.0
lit- Xy l ene 1 .0286 0.3 0.0309 0.3 0.0309 0.2
p-Xylene 0.271' 0.1 0.0081 0.1 0.0081 0.1
Ch_icill ~ith Non-clrcinogenic Effectl found It Sitl 8nd UNa
Ch lorobenzene 0.3280 0.1 0.0098 0.1 0.0132 0.1
Cltlorofor'8 1 .2371 0.3 0.0371 0.3 0.1023 0.7
1,4-0Ichlorobenzene 1.07'00 0.3 0.0314 0.3 0.0320 0.2
1,1-0Ichlor08thane 0.7095 0.2 0.0213 - 0.2 0.0215 0.2
1,1'Olchlor08thene 0.3231 0.1 0.0098 0.1 ,0.0114 0.1
Trana-1,2-0ichlor08thene 11.2143 2.9 0.3371 2.9 0.3443 2.5
1,2-0ichloropropene 300.7519 78.0 9.0225 78.0 11.0276 80.5
Ethyl benzene 2.2286 0.6 0 .0669 0.6 0 .0707 0.5
Methyl- Clttorida- 0.404a 0.1 0.0121 0.1 0.0137 0.1
TetrlChlor08th- 14.0000 3.6 0.4200 3.6 0.4253 3.1
To t '-"8 23.4286 6.1 0.7029 6.1 0.7033 5.1
1,1,1-Trichtoroethene 0.3987 0.1 0.0120 0.1 0.0137 0.1
Carbon Tetrachlorida. 4.0816 1.1 O. 1224 1.1 0.1633 1.2
TOTAL HAZARD INDEX- 385.6150 11.5659 13.7023
. Conc:Mtrltlona baled on datectlon tt.itl. - Mot datected in Sallpt.. fra the Slt8.
.. HUlrd Index vilun Irelter thM 1 I8Y indiC8te adver.. heel th effecta. -
::G::~3::':' 2.2
-------
(Conti,.,..)
Model 4
Mod8l 5
Mod8l 6
HI
Percent
Percent
"I
Percent
HI
Ch_ical"
Ch_icaLs Mith Non-carcinogenic Effect. Found only at Sfte
Benzofc Acfd 0.0116 0.6 0.0016 0.2 0.0000 0.0
lanzyl Alcoltol 0.0429 1.5 0.0126 0.4 0.0000 0.0
Bf8<2-Ethylhexyl)Phthalate 0.0146 0.5 0.0001 0.0 0.0000 0.0
Butyl Benzyl Pttthalat8 0.1002 3.5 0.0006 0.0 0.0000 0.0
4-Chloroanflf,. 0.0486 1.7 O.OZOO 0.6 0.0000 0.0
2,4-Df..thylphenol 0.0034 0.1 0.0013 0.0 0.0000 0.0
Df-n-butyl Phthalate 0.0016 0.1 0.0006 0.0 0.0000 0.0
2'Methylnaphthalene 0.0001 0.0 0.0004 0.0 0.0000 0.0
2-Methylphenol 0.3500 12.1 0.1251 4.0 0.0000 0.0
4-Methylphenol 0.1414 4.9 0.0411 1.5 0.0000 0.0
Naphthal- 0.0000 0.0 0.0000 0.0 0.0000 0.0
Phenol 0.0006 0.0 0.0004 0.0 0.0000 0.0
...Xyl- 0.0309 1.1 0.0088 0.3 0.0000 0.0
p-Xyl- 0.0011 0.3 0.0010 0.0 0.0000 0.0
Ch_ical. Mith Non-carcinogenfc Effect. Fcard at Sfte Ind IJ8
Ch lorabenz- 0.0034 0.1 0.0034 0.1 0.00J4 0.2
Ch l ol"Ofol"8 0.0651 2.2 0.0146 0.5 0.0651" 3.0
1,4-Dfchlorobenz- 0.0006 0.0 0.0071 0.2 0.0006 0.0
1,1-Dfchloroethane 0.0002 0.0 0.0058 0.2 0.0002 0.0
1,1-Dfchloroeth- 0.0016 0.1 0.0048 0.2 0.0016 0.1
Trana-1,2-Dfchloroeth- 0.0011 0.2 0.0171 2.5 0.0114 3.2
1,2-Dichloropropane 2.0050 69.2 2.6734 85.9 2.0050 91.1
Ethylbenz- 0.0038 0.1 0.0131 0.4 0.0038" 0.2
Methyl- Chloride 0.0016 0.1 0.0023 0.1 0.0016 0.1
Tetrachloroeth- 0.0053 0.2 0.0036 0.1 0.0053 0.2
Toluene 0.0004 0.0 0.0442 1.4 0.0004 0.0
1,1,1-Trfchloroethane 0.0011 0.1 0.0025 0.1 0.0011 0.1
'
carbon Tetrachlorfd88 0.0408 1.4 0.0321 1.0 0.0408 1.9
TOTAL HAZARD 1 NOn- 2.89n 3.1114 2.2009
. Concentrations baaed on detection l i.its. Not detected in s8q)les fr08 the Site.
- Hazard Index values greaur than 1 II8Y indicate adverse health effects.
.:...C-::3I:' :2
-------
::::.:::3::: :2
(Contfnu8d)
Model 7 Model 10 Model 11 McIlvain
OI_i cal HI Perc."t HI Percent HI Percent HI Percent
Ch..icall vith Mon-carcinogenic Effectl Found Only at Sfte
Benzoic Acid 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
Benzyl Alcohol. 0.0000 0.0 0.0000 0.0 0.0000 0.0 0 . 0000 0.0
8iIC2-Ethylhexyl)Phthalate 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
Butyl Benzyl Phthalate 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
4-OIloroeni line 0.0000 0.0 0.0000 0.0 0.0000 '0.0 0.0000 0.0
2,4-0f..thylphenol 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
Di-n-butyl Phthalate 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000. 0.0
2.Methylnephthalene 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
2-Methylphenol . 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
4.Methylphenol 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
Naphthalene 0.0000 0.0 0.0000 0.0 0.0000 0.0 0 . 0000 0.0
Phenol 0.0000 0.0 0.0000 0.0' 0.0000 0.0 0.0000 0.0
nt-Xylene 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
p-Xylene 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
Ch..icall vfth Mon-carcinogenic Effect. Found at Sfte end UMR
Chloroblnzene 0.0005 0.1 0.0005 0.0 0.0005 0.1 0.0050 55.3
CM orofol'll 0.0011 0.3 0.0031 0.2 0.0009 0.1 0.0000 0.0
1,4-0ichlorobenzene 0.0006 0.1 0.0004 0.0 0.0004 0.1 0.0000 0.0
1,1-0ichloroethane 0.0001 0.0 0.0001 0.0 0.0000 0.0 0.0031 34.7
1,1-0ichloroethene 0.0003 0.1 0.0010 0.1 0.0003 0.0 0..0000 0.0
Trans-1,2-0ichloroethene 0.0029 0.5 0.0029 0.2 0.0014 0.2 0.0000 0.0
1,2-0ichloropropene 0.6015 98.0 1 .4369 91.2 0.7018 98.8 0.0000 0.0
Ethyl benzene 0.0001 0.0 0.0001 0.0 0.0001 0.0 0.0000 0.0
Methylene Chloride 0.0000 0.0 0.0002 0.0 0.0000 0.0 0.0009 10.1
Tetrachloroethene 0.0011 0.2 0.0004 0.0 0_0001 0.0 0.0000 0.0
Toluene 0.0000 0.0 0.0000 0.0 0.0000 0.0 0.0000 0.0
1,1,1-TriChloroethane 0.0008 0.1 0.0003 0.0 0.0002 0.0 0.0000 0.0
,
Carbon Tetrachloride- 0.0041 0.7 0.0321 2.2 0.0041 0.6 0.0000 0.0
TOTAL HAZAaO IIIDEX- 0.6139 1.4788 0.1100 0.0090
. Concentrations baed on detection lilliu. Not detected fn S8IIpl.. frOll the Site.
.. Hazard Indu values greater then 1 I118Y irdicate adverse heal th effects.
Source: BCM Ea.tern Inc. CleM Project Mo. 00-5528-02)
. . .
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E:C-.::3 IT 13
INDICATOR CHEMICALS
CONCENTRATIONS'USED IN RISK ASSESSMENT
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
Soil a
(uo/ko)
Max;MU8 M.anb
Wat.r
( u all )
Max;mum Meanb
VOLATILE ORGANICS
Btnztnt 410 11 152 4.4
Chlorofonn 70 5.8 30.2 1.4
Et.hylb.nzene 3,920 23.7 52.6 10.7
T.trach10roethtne 4,100 19.8 34.9 1.4
Toluent 4,650 106.7 844.0 214.5
T r; ch 10 roe thtnt 2,B5O 8.3 14.1 1.2
Trichlorof1uorOntthant 540 24.1 368.0 13.2
l,3-Dichloroprop.ne.. 50 5.7 10.3 1.1
SEMIVOLATILE ORGANICS
B.nzidint 7,300 630 NA NA
Bis(2-chlorotthyl)tther 62,000 947 92 10.0
Hexachlorobenzene 69.000 1,002 16 6.3
He.ach10robutaditne 56,000 1,024 35 32.4
PAHs 955,000 9,129 100.8d 84.2d
PAHs. 411,220 3,652 82.3d 61.5d
PCBs". 13,800 3.5 13 d 0.003d
INORGANICS
Bar; UII 253,000 45,000 c 267 264
ChrQII;UII 198,000 16,000 c 10 5
Lead 156,000 24,000 27 3
PESTICIDES
Aldr; n 2.5 0.29 16.0 0.9
4,4'-00T 37 0.84 . 3.2 3.1
,
. Adjust.d Conc.ntration (Stction 5.4)
.. Both i sOlntrs
... Total
a Ons;te soil, fill and sed;~.nt
b Geometr; c N&It
c Below background
d Est;~t.d conc.ntration using c.rta;n soil
NA Not applicable
Source: 8CH Engin.trs (Project No. 00-5808-D2)
data (s.. S.ct;on 5.2.4)
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E:.~:3I':' lu
LEGEND
1. CONRAIL SPUR 7. GLASGOW LANDFILL
2. RIveR ROAD COKE WORKS LGLASGOW QUARRY
3. MONTGOMERY COUNTY LANDFILL I. Pt1II.ADELPHIA ELECTRIC QUARRY
~ .. SCHUYLKILL EXPRESSWAY 10. STANLEY KESSLER COMPANY
=.~ - S. PENNSYLVANIA TURNPIKE ".LUKENS STEEL
. . . ,..,...~.. CRATER RESOURCES. 1He.. U.COOPERS CK. CHEW. SITE
~ II 0 0 .~~ (PICKLE LIQUOR SITEJ 13. O'HARA LANDFILL
SOURCE:. USGS 7.5 min. 0uadrang68 I Norristown. PA I Photoreviaed 1983
~.
north 0
.
2000ft.
HENDERSON ROAD'
o Potential
REMEDIAL INVESTIGI~,~ION Groundw~~~~"~lo,~taminatlon
Irl,~i !'t:".l:~~-~ ':'I=-t'...:.~rll .1 ,- ~~ :1 I" ~.L/-,',L'/:~' ~~i-f)
-------
EXHIBIT 15
PROPOSED CHEHICAL SPECIFIC ARARS FOR
. HENDERSON ROAD SITE
INJECTION VELL AND LANDFILL OPERABLE UNITS*
ARAR Hethod/
Parameter (Jlg/l) IVOU LOU (""ll) Source
METALS
Arsenic:. x 50.0 (30) HCL (PHCL)
Bari ua x . 5,000.0 PHCL
Cadaiua x 10.0 (5) HCL (PHCL)
Chro.iua (total) x x 50.0 (100) HCL (PHCL)
Copper x . 1,300.0 (1000) HCLG (PHCL)
Lead x (x) 20.0 (5.0) HCLG (PHCL)
Silver x 50.0 HCLG
Zinc:. x 5,000.0 He:.
OTHER PARAMETERS
Cyanide x 200.0 AVQC
ACID EXTRACTABLE
ORGANICS
Benzoic ac:.id x 700.0 Ha
2,4-Dimethylphenol x 400.0 .AVOC
Phenol x 3,500.0 DWL
2-Hethylphenol x 42.0 Ha
4-Hethylphenol x 72.0 . Ha
BASE/NEUTRAL EXTRAC1'ABLE
ORGANICS
Benzidine x 16.5 CLP
Bis (2-ethylhexyl)
phthalate x 512.0
Bis(2-c:.hloroethyl)ether x 5.7 ' CLP
Butyl Benzyl Phthalate x 820.0 Ha
.1,2-Dic:.hlorobenzene x. 620.0 (600) HCLG (PHCL)
1,3-Dic:.hlorobenzene x 470.0 AVQC
1,4-Dichlorobenzene x 75.0 HCL
Di-n-butyl phthalate x 770.0 SNARL
Bexachlorobenzene x 1.9 CLP
Bexachlorobutadiene x 0.9 CLP
Naphthalene x 350.0 Ha
PAB (benzo(a)pyrene) x 2.5 CLP
H-nitrosodiphenya.ine x 71.0 *.*
Benzyl alc:.ohol x 364.0 Ha
4-Chloroaniline x 35.0 Ha
2-Hethylnaphthalene . x 1,750.0 Ha
-------
EXHIBIT 15
(Continued)
PROPOSED CHEHICAL SPECIPIC ARARS POR
HENDERSON ROAD SITE
INJECTION VELL AND LANDFILL OPERABLE UNITS*
ARAR Methodl
Parameter (~g/l) lieU LOU (~g/l) Source
VOLATILE ORGANICS.
Benzene x (x) 5.52 (5.0) b (HCL)
Carbon Tetrachloride x 5.0 HCL
Chlorobenzene x 60.0 HCLG
Chloroethane x 19,000.0 EPA
Chlorofor8 x x 100.0 HCLa
Dibromochloromethane x 100.0 HCLa
Dichlorobromomethane x 100.0 HCL
Dichlorobromethane x 100.0 HCL
1,1-Dichloroethane x 5.06 b
1,2-Dichloroethane x 6.02 b
1,1-Dichloroethene x 7.0 HCL
1,2-Dichloroethene . x 70.0 HCLG/PHCL
1,2-Dichloropropane x 6.28 b
1,3-Dichloropropene x 5.0 CLP
Ethylbenzene x x 680.0 HCLG/PHCL
Hethylene Chloride x 47.0 ***
Tetrachlorethene (PeE) x (x) 6.9 (5.0) *** (PHCL)
Toluene x x 2,000.0 HCLG/PHCL
Trichloroethene (TeE) x (x) 25.8 (5.0) b (HCL)
Trichlorofluoromethane x x 12,000.0 EPA
Vinyl Chloride x 2.0 HCL
.-Xylene x 175.0 DVEL
p-Xylene x 175.0 DVEL
PESTICIDES AND PCBs '
Aldrin x 0.004 CLP
DOT x 0.012 CLP
PCBs x 0.5 PHCL
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EXHIBIT 15
(Continued)
PROPOSED CHEMICAL SPECIFIC ARARS POR
HENDERSON ROAD SITE
INECTION VELL AND LANDFILL OPERABLE UNITS*
Proposed Maxiai. Contaminant Level (SDVA)
Maxiaim Contaminant Level (SDVA)
Maxiai. Contaminant Level Goals (SDVA)
National Interi. PrisaryDrinking Vater Regulation (Safe Drinking
Vater Act)
USEPA CLP detection li.it .
Ambient Vater Ouality Criteria
Suggested No Adverse Effect Level
Drinking Vater Equivalent Level
Recommended by EPA
Model in Appendix A of RI
Organoleptic .
EPASuperfund Public Health Evaluation Manual, DEa, Vashington,
DC . .
EPA 54011 - 861060 (OSVER Directive 9,285.4-1), Ocyober, 1986
. - This value is for total trihalomethanes
b - Alternate concentration limit based on background contamination
( ) - numbers and letter in parentheses are related to each other for
chemical in that rove Value represent changes in the Safe
Drinking Vater Act MCLs since the IVOU-ROD
IVOU - Chemicals are based on Exhibit 16 of the IVOU-ROD.
LOU - Chemicals are based on Table 2-4 of the LOU Draft PS.
PMCL -
MCL -
MCLG -
NIPDVR -
CLP -
AVQC -
SNARL -
DVEL -
EPA -
Ma -
Mc -
*** -
(77)
* The basis for proposed ARAR'sis that the site is located above a
Class IIA aquifer.
,
-------
EXHIBIT 16
Sill
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E:lliI3I:'. 16, ..
"
INDIVIDUAL CARCINOGENIC RISK
INHALATION"OF FUGITIVE EHISSIONS
HENDERSON ROAD SITE
'LANDFILL OPERABLE UNIT
Individual Canc.r Rhk
Referencea (1 ug/m3) Haximum4 (263 ug/m3)
Chem; ca 1 Ha)ltimumb Averageb Haximumb Av.rageb
A 1 dri n < 1 )It 10-8
-------
::::
-------
INDIVIDUAL CARCINOGENIC RISK
RESIDENTIAL USE OF GROUNDWATER AT THE PROPERTY ~INE
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
Individual Cancel" Risk-
Maximum Averaae
C/ilfllt; ca 1 Ingestion Inhalat.ion Ingestion Inhalation
PAHs 4.06 )C 10-3 9.78 )C 10-4 3.03 x 10-3 5.0 )( 10-4
A 1 dri n 1.18 x 10-3 2.21 x 10-4 6.6 x 10-5 1.2 )( 10-5
Bis(2-ch1oroethy1)ether 4.34)C 10-4 4.12 )( 10-4 4.7 )( 10-5 4.4 )( 10-5
PCBs 4.29 )C 10-4 4.08 x 10-4 1.0 x 10-7 1.0 )( 10-7
Hexachlorobenzene 1.16 )( 10-4 1 . 10 )( 10-4 4.6 x 10-5 . 4.3 )( 10-5
Benzene 1.9 )C 10-5 1.8 x 10-5 5.6 x 10-7 5.0 x 10-7
Hexachlorobutadiene 1.2 )( 10-5 1.1 )( 10-5 1.1 x 10-5 1.0 )( 10-5
1,3-Oich1oropropene 8.0 )( 10-6 7.0 )( 10-6 1.0 x 10-6 1.0 )( 10-6
Ch1orofonn 8.0 )( 10-7 7.6 x 10:-7 3.7 x 10-8 3.5 x 10-8
Tetrachloroethene 8.0 )( 10-6 7.3 x 10-6 3.0 x 10-7 3.0 )( 10-7
4,4'-ODT 5.0 )( 10-6 4.0 x 10-6 5.0 x 10-6 4.0 )( 10-6
Trichloroethene 7.0 )( 10-7 6.0 )( 10-7 6.0 x 10-8 5.0 )( 10-8
Sub-Total 6.26 x. 10-3 2.18 x 10-3 3.21 x 10-3 6.15 x 10-4
TOTAL 8.44 x 10-3 3.82 x 10-3
- Individual Cancer Risk = Potency Factor x Chronic Oai1y Inta~e (CDI), where:
CDI-ingestion = ma ~hemicala x
11 tel"
2 liters x k 1b t x iO.15
day 70 g .w.
0.15 = Groundwater dilution factor
COX-inhalation = (CDI-ingestion x 0.95+)
(+ 0.95 = Correction factor to include exposure via inhalation for all
ch..icals except fluorene. anthracene. aldrin, and DOT which have factors of
0.19 [see Section 5.5.1.3J)
i
~.
The assUMptions used in calculating the CDI are discussed in Section 5.5.1.3.
a Table 5-10
. Source: BCH Engine.~s (Project No. 00-5808-02)
(REVISED 7/12/89)
EXHIB~7 16
~ \>
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EXHIBIT 16
NONCARCINOGENIC RISK
RESIDENTIAL USE OF WATER AT THE PROPERTY LINE
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
Chemical
TOTAL
Hazard Index*
Maximum
Ingestion Inhalation
Average
Ingestion Inhalation
Aldrin
DDT
1 ,3-Oichloroprop«ne
Hexachl orobenzen*
Hexachl orobutadiene
Lead
Tetrachloroethene
Chloroform
Toluene
Chromium
T ri chl orof 1 uorome thane
Ethyl benzene
Barium
Sub-Total
2.32
0.03
0.15
0.09
0.07
0.08
0.015
0.013
0.012
0.009
0.005
0.002
0.0023
2.8
0.44
O.OOS
0.14
0.08
0.07
—
0.014
0.012
0.003
—
0.008
0.002
—
0.77
0.13
0.03
0.016
0.034
0.07
0.009
0.0006
0.0006
0.003
0.004
0.0002
0.0005
0.0023
CL32
0.02
0.005
0.015
0.032
0.07
„_
0.0005
0.0006
0.0009
—
0.0003
0.0004
—
0.13
3.6
0.45
• Hazard Index - Chronic Daily Intake (COD
Reference Dose
where:
-„ . .. mq chemical 2 liters 1
COI-Ingestion - 1.7 x " x irT [1^
liter day 70 kg b. wt.
x 0.15
COI-Inhalation • (CDI-Ingistion) x 0.95*
(+ 0.95 • Drinking water equivalent for all chemicals except Aldrin and DOT,
for which 0.19 was used.) ^
Groundwater dilution factor -0.15
Sourcs: SC* Er.ginssrs (Project No= 00-5808-02)
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::a:I3I:'
,
..'
:'6" ~ '
NONCARCINOGENIC RISK
INGESTION OF SOIL BY TRESPASSERS
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
. Hazard Index.
Chemical Maximum Average
Lead 0.37 0.06
Chromium 0.13 0.011
Hexachlorobenzene 0.29 0.004
Hexachlorobutadiene 0.09 0.002
Barium 0.017 0.003
Benzidine 0.012 0.0011
Tetrach10roethene 0.0014 <0.0001
1.3-Dichloropropene 0.0006 0 . 0001
Aldrin 0.0003 <0.0001
DDT 0.0002 <0.0001
Ethyl benzene 0 . 0001 <0.0001
Toluene 0.0001 <0.0001
Tr1chlorofluoromethane <0.0001 <0.0001
Chloroform <0.0001 <0.0001
TOTAL 0.9 0 . 08 ..
. Hazard Index. Chronic Daily Intake
Reference Dose
where:
Chronic Daily Intake. mg chemicala x 1
Kg soil 30 Kg b.wt.
I
X 1xl0-41 Kg 5011
day
I
a Table 5-10
Source: BOH Engineers
-------
-:-'r.1T~ -..,., : 6 L
-~.._~-. .
. NONCARCINOGENIC RISK
INGESTION OF SOIL BY ONSITE WORKERS
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
Hazard Index
Chemical Maximum Average
Lead 0.16 0.03
Hexachlorobenzene 0.12 0 . 0018
Chromium 0.06 0.005
Hexachlorobutadiene 0.04 0.0007
Barium 0.007 0.0011
Benzidine 0.005 0.0005
Tetrachloroethene 0.0005 <0.0001
1.3-Dichloropropene 0.0002 <0.0001
Aldrin 0.0001 <0.0001
DOT 0.0001 <0.0001
Ethylbenzene 0 . 0001 <0.0001
Toluene <0.0001 <0.0001
Trichlorofluoromethane <0.0001 <0.0001
Chloroform <0.0001 . <0.0001
TOTAL 0.39 0.04
,
. * Hazard Index. Chron1 c Dal1 y Intau
D""~"".",,....... n...~...
011;' 1Iii1 ..,."'.. """"
where:
Chronic Daily Intake. mg chemicala x 1
Kg soil 70 Kg b.wt.
x lxlO-4 Kg 50il
day
a Table 5-10
Source: BOM Engineers (Project No. 00-5808-02)
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-----------,-~~- - -.-
NONCARCINOGENIC RISK
INHALATION OF FUGITIVE EMISSIONS
HENDERSON ROAD SITE
LANDFILL OPERABLE UNIT
=c::::n:-: .
Chemical
Hazard
Referencea (1 ug/m3)
Maximumb Averageb
Index
Maximuma (263 ug/m3)
Maximumb Averageb
Barium
l,3-Dichloropropene
Ethylbenzene
Tetrachloroethene
Toluene
Trichlorof1uoromethane
. Chloroform
Hexach1orobenzene
Hexach1orobutadiene
Lead
Chromium
Benzidine
Aldrin
DDT
TOTA~
0,0005
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
0.0005
0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0,0001
<0.0001
<0.0001
<0,0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
0.0001
a Concentration of 50il in air
b Concentration of chemical 1n 5011
c Table 5-10
O. 14
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
<0.0001
0.0065
0.0021
0.0084
0.0030
0.0003
<0.0001
<0.0001
0.16
where:
Chronic D~i1y Intake. mg chemicalc x kg 5011 x
Kg soil m3 air
Source:
BCM Engineers
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