United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-89/076
September 1989
EPA Superfund
Record of Decision
Havertown PCP, PA
-------
50272.101
REPORT DOCUMENTATION 1" REPORT NO. I ~ 3. R8cipient'a ACC888ion No.
PAGE EPA/ROD/R03-89/076
4. YUle end SubIl1l8 5. Atport 0-
SUPERFUND RECORD OF DECISION 09/29/89
Havertown PCP, PA
First Remedial Action L
7. Aulhor(a) 8. Pwfonnlng Orgenlzallon Rept. No.
8. Pwfonnlng Org8lnlza1l0n N8m8 end Addre88 10. ProiKllT88IIWort< Unit No.
11. Con1raC1(C)... Gren1(G) No.
(C)
(G)
1~ Sponaoring Orgenlutlon N8m8 end Addre.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
15. Supplementary No..
1 L Ab8tract (Umi1: 200 wolda)
The Havertown PCP site is in Havertown, Delaware County, Pennsylvania, approximately 10
~les west of Philadelphia. This 12- to 15-acre site consists of a wood treatment
facility, an adjacent manufacturing facility, and Naylors Run Creek which drains the
area. Land use in the vicinity of the site consists of commercial and residential
properties. Contamination at the site is due to improper disposal of wastes generated
from wood preserving operations. From 1947 to 1963 PCP-contaminated oil was dumped into
a well which drained into ground water beneath the facility. In 1972 the State
identified contaminated ground water discharging from a storm sewer into Naylors Run.
From 1976 to 1982 EPA performed containment activities including installing filter fences
in Naylors Run and sealing a sanitary sewer pipe. In 1988 EPA installed a catch basin in
Naylors Run to trap discharge from the storm sewer pipe. Other onsite wastes include
five holding tanks filled with PCP- and VOC-contaminated wastewater and numerous
55-gallon drums of unanalyzed waste materials. This Record of Decision (ROD), the first
of two operable units, will address the remediation of surface water and the disposal of
drummed and tanked wastes. A subsequent ROD will address the impact of contaminated soil
on ground water contamination at the site. The primary contaminants of concern affecting
the surface water are VOCs including benzene, toluene and TCE; other organics including
phenols, dioxins, PCP, and PAHs; metals including arsenic and chromium; and oils.
/("f'\nt- i nn...r! on npxt' D.::ICYP \
17. Docwn8nI AnaJyaIa .. DMcrIpCoN
Record of Decision - Havertown PCP, PA
First Remedial Action
Contaminated Media: sw, debris
Key Contaminants: VOCs (benzene, toluene, TCE), other organics (dioxins, phenols,
PCP, p~etals (arsenic, chromium), oil
b. Idanllflenl T-
c. COSAl1 ~
18. AYIiIabIIty -- 18. S8curtty CIaaa (ThIa Rapor1) 21. No. 01 Pall"
None 54
20. S8curtty CIaaa (ThIa P8ge) n Price
J>Jf'\n...
. KJHM 2/2 (40fT'
(S. AHSI-Z3I.11)
SNIn8IrucI/- on 1It-
(FOftII8fIy NT1~35)
08p8t1man1 of CORWIWce
-------
EPA/ROD/R03-89/076
Haverton PCP, PA
16.
Abstract (Continued)
The selected remedial action for this site includes offsite land disposal of 200 drums
of soil and oily debris, and offsite treatment and disposal of 6,000 gallons of
wastewater stored in onsite tanks; soil monitoring; installing and operating an
oil/water separator at the storm sewer effluent point to Naylors Run; multimedia
monitoring; and implementation of site access restrictions. The estimated present
worth cost for this remedial action is $1,158,200, which includes an estimated annual
O&M cost of $110,000 for years 1-5 and $45,000 for years 6-30.
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DECLARATION FOR THE
RECORD OF DECISION
Site Name and Location
Havertown PCP Site (the site), Haverford Township, Delaware
County, Pennsylvania
Statement of Basis and Purcose
This decision document presents the selected interim
remedial actions addressing onsite soils, staged waste materials,
and the storm sewer effluent at the catch basin in Naylors Run, a
creek that drains the site area. These remedial actions were
developed in accordance with the Comprehensive Environmental
Response, compensation Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and Reauthorization Act (SARA) of
1986 and to the extent practicable, the National Contingency
Plan. The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial
actions are based. The Commonwealth of Pennsylvania has
concurred on the selected remedies.
DescriDtion of Selected Remedy
The selected Remedial Action Alternatives (RAA) address the
threats posed by the onsite soils, storm sewer effluent and
drummed waste. These actions are described below. EPA will
assume the site-lead for the Remedial Design and Remedial Action
(RD/RA) for this Record of Decision.
Onsite Soils
The selected remedy for the onsite soils is the "No Action"
alternative. This alternative achieves remedial action
objectives because the potential threat to the public's health
associated with the continued entrainment of contaminated dust
and infiltration of contaminants into the environment poses no
significant risk.
The next operable unit
the soils on groundwater at
Record of Decision will not
action.
will address any potential impact of
the site. The chosen remedy in this
interfere with any future remedial
Oil/Water seDarator for storm sewer effluent
The selected alternative for remediation of the storm drain
e.ffluent to Naylors Run is the installation and operation of an
optimum, oil/water separator. Such separators, which are
commercially available, are used in petroleum distribution and
transportation facilities and in a variety of other industrial
-------
and military operations. The oil/water separator complies with
ARARs and provides overall, long-term protection to humans.
Staqed Waste Materials
The recommended alternative for cleaning up the contaminated
waste staged onsite is landfilling and offsite treatment of the
aqueous waste. Offsite treatment and disposal of the waste was
selected because it can be easily implemented, will not be
affected by the lack of available working space, and will not
impact the surrounding population or environment.
SummarY of Risk and Rationale for Selection of Alternatives
The human health risk in terms of the maximum potential
increased risk of contracting cancer from a 70-year lifetime
exposure through inhalation or ingestion was calculated for each
potentially carcinogenic chemical. The results, expressed in
terms of risk per million people exposed, are as follows:
1.
Inhalation of entrained particulates containing
chromium VI, arsenic, and other metals from onsite
soils and of VOCs emanating from the site by persons
off site:
DISTANCB PROII TO SITB
500 ft 1000 ft 1320 ft 2000 ft 2640 ft
. Cancer risk 5.8 2.9 2.2 1.45 1.1
(per million)
These values are considered to be higher than the actual
risk because the analytical results for total chromium were used
as if they were 100% hexavalent chromium. While the hexavalent
chromium salt is a known human carcinogen through the inhalation
route, sampling performed in July, 1989 did not identify the
presence of hexavalent chromium in onsite soils.
2.
Inhalation of benzene and other VOCs at the nearest
residences (two within 75 m or 250 ft) to the catch
basin 5.5 (per million)
Ingestion of onsite soils: 8 (per million) This value
is considered to be higher than the actual risk because
the analytical results for total arsenic were used as
if they were 100% trivalent arsenic, the most
carcinogenic species.
3.
-------
3
4.
Ingestion of liquids from the underflow dam: 2 (per
million)
5.
The total risk from all sources for a person living
within 500 ft of the site and within 250 ft of the
underflow dam and ingesting the onsite soils and
sediments, the sediments under Naylors Run, and the
liquids in the underflow dam is not cumulative, however
for multiple exposures to different media a slightly
higher risk may be possible.
The "No Action" alternative for onsite soils, the oil/water
separator for storm effluent at the catch basin, and offsite
treatment and disposal of the staged waste were selected because
they meet established remedial action objectives with regard to
human health and the environment. The components of these
alternatives are well demonstrated and represent both a reliable
and a cost effective method for remediating site conditions.
Declaration
The remedy selected to address the onsite soils is
protective of human health and the environment, attains
acceptable levels of exposure for this remedial action and is
cost effective.
The remedy selected for the effluent in the catch basin is
also protective of the public's health and the environment,
attains Federal and state requirements that are applicable,
relevant and appropriate, satisfies the reduction of toxicity,
mobility, or volume requirement, and is both easily implemented
and cost effective.
The remedy selected for the staged waste materials is
protective of human health and the environment, attains Federal
and state requirements that are applicable, relevant and
appropriate, reduces potential mobility and toxicity to other
media, is easily implemented and has a higher degree of public
acceptance than the onsite treatment option.
'/
fl ~~ 8~-
Edwin B. Erickson
Regional Administrator
Region III .
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-. ~-~"
. . -. '.' ~
BAVERTOWH PCP SITE
Record of Decision
u.s. EPA Region III
Haverford Township, Delaware County, Pennsylvania
SITE DESCRIPTION
The Havertown PCP site consists of approximately 12 to 15
acres roughly delineated by Lawrence Road and Rittenhouse Circle
to the south, the former-Penn Central Railroad tracks to the
north, and the fence between NWP and Continental Motors to the
west. There is no distinct boundary to the east.
The investigation of the Havertown PCP site was performed by
the Commonwealth of Pennsylvania. In June 1987, the state
started a Remedial Investigation and Feasibility study (RI/FS) to
identify and define the hydrogeologic characteristics and extent
of contamination at the site. The RI/FS identified appropriate
corrective action to address actual or potential environmental
and public health threats. Based upon a review of the
Feasibility study, a Record of Decision (ROD) recommends
appropriate remedial actions. The site is located in Havertown,
Haverford Township, Delaware County, in southeastern
Pennsylvania. The site is located approximately 10 miles west of
Philadelphia (Figure 1) and is surrounded by a mixture of
commercial establishments, industrial companies, parks, schools,
and private homes.
The investigated area consists of a wood-treatment facility
operated by the National Wood Preservers site (NWP); the
Philadelphia Chewing Gum Company (PCG) manufacturing plant
adjacent to the wood-treatment facility: Naylors Run, a creek
that drains the area; and neighboring residential and commercial
properties (Figure 2).
NWP, the source of the contamination, is the focus of the
investigation. structures on the property include a sheet metal
building with aboveground chemical storage tanks situated on a
2-acre property just north of the intersection of Eagle and
Lawrence roads and the large PCG bubble gum production building.
The entire Havertown PCP site is drained by Naylors Run, a
creek that flows in a southeasterly direction from the site. For
the most part, surface runoff across the NWP site enters
artificial drainage channels before discharging into Naylors Run.
On the NWP property a significant amount of water accumulates in
-------
/
SCAlE IN FEET
. /
- /
i t I Y II /~( 1~1..ld.Jdl'!"
/' l.tIUIII,)' I I.
.. ['. (/
HAVERTOWN pcp SITE
HAVERTOWN. PA
2000
---~-------- - ---._--
PfHHSWlVA:>
~
FIGURE 1
LOCATION MAP
QUAOIIAHGlf lOCAl ION
LAWLER,IIA1USKY & SKELLY ENGINEERS
P8Mt RJ." .... YOlk
-------
c -
,
!:
. .~
c'
- ~
CO
o
FIGURE sra-e IN FEET
HAVIRTOW
NAYlrtT':.PCP S'TE
N, ,..
STUDY &
~"IA MAP
I
-
J
I
!
~ ~ 5 0
- ,OE~rIAL
RESIDENT
IA L
RE SIOENTIAL
RES
10 E N T
I A L
200'
.--
--
200'
1
-.-
-------
2
the area of the pedestrian gate near Continental Motors and in
the vicinity of NWP's main gate near Eagle Road. Under storm
event conditions, the large amount of sheet flow that occurs on
NWP property in the area of the main gate empties into the
drainage ditch bordering the north edge of the property. The
eventual fate of this runoff is Naylors Run. Naylors Run flows
through natural channels, concrete-lined channels, and a variety
of pipes before entering Cobbs Creek near East Lansdowne,
approximately 4 miles southeast of the site. Cobbs Creek joins
Darby Creek, which flows through the Tinicum National Environment
Center before entering the Delaware River.
Site History
The NWP site was first developed as a railroad storage yard
and later became a lumberyard. In 1947 the wood-preserving
facility was constructed-and operated by Mr. Samuel T. Jacoby.
In 1963 the existing facility was purchased by the Harris
GOldstein family.
In 1962, the Pennsylvania State Department of Health became
aware of contaminants in Naylors Run, and linked the source of
contamination to National Wood Preservers waste disposal
practices. Mr. Jacoby was brought to trial by the Commonwealth
of Pennsylvania in 1964, for the disposal activities that
occurred at the Site. He was found not guilty.
The majority of the activities resulting in pollution to the
water bearing strata (aquifer) beneath the site occurred during
the years of 1947 to 1963. Approximately 1 million gallops of
spent wood preservatives is believed to have been dumped into a
26-foot deep well on property adjacent to the site which was
leased from Clifford Rogers to Shell Oil Company. This disposal
event appears to be the major source of contamination to Naylors
Run.
In 1972 the Pennsylvania Department of Environmental
Resources (PADER) identified contaminated groundwater discharging
from a storm sewer into Naylors Run. PADER ordered
NWP,Philadelphia Chewing Gum Company (who owns the property
downgradient from NWP), Shell Oil Company (who leased adjacent
property from Clifford Rogers), and Mr. Clifford Rogers (owner of
property leased to NWP) to clean up Naylors Run, since they
occupy land where contaminated groundwater exists. The above
parties appealed to the State Environmental Hearing Board, and
later to the Commonwealth Court of Pennsylvania. The court
sustained Philadelphia Chewing Gum and Shell Oil Company's
appeals and ordered the cleanup to be executed by NWP and Mr.
Rogers. Implementation and maintenance of the cleanup actions by
NWP and Mr. Rogers were inadequate however, and failed to address
all of the environmental concerns both onsite and off.
-------
3
In response to a request from DER in 1976, the United States
Environmental Protection Agency (USEPA) initiated cleanup
activities under Section 311 of the Clean Water Act. Cleanup
activities occurred in two phases. The first phase established
containment operations at Naylors Run. Filter fences were
~nstalled to remove PCP contaminated oil from the surface water.
These fences were located just downstream from the outfall of the
24-inch storm sewer pipe and a 12-inch sanitary sewer pipe. The
second phase was carried out by the Emergency Response Team from
the USEPA. Groundwater collection and treatment, and cement
grouting of the two sewer pipes was attempted. The sanitary
sewer was sealed; however, contaminated groundwater still
discharges into Naylors Run from the 24-inch storm sewer pipe.
In 1982, the USEPA ended containment operations in Naylors
Run, when National Wood Preservers agreed to maintain in-stream
treatment measures pursuant to a consent agreement with EPA.
Subsequent inspections, however, revealed NWP was not properly
maintaining the filter fences.
Because of continuing releases of PCP-contaminated oil into
Naylors Run, in 1988, EPA's Emergency Response Team installed a
catch basin in Naylors Run to trap the discharge from the storm
pipe. EPA still maintains the catch basin.
The Havertown PCP Site was listed on the National Priorities
List by the USEPA in December, 1982. Subsequently, DER signed an
agreement with EPA to conduct a RI/FS at the site.
The NWP facility has not changed significantly since its
construction and today consists of a single metal-sheeted
building, which contains the wood-treatment equipment, and
several chemical storage tanks located immediately northwest of
the building. The production facility is surrounded by a dirt-
covered storage yard in which untreated and treated wood are
stored. The entire NWP facility is enclosed by a chain-link
fence. In 1963-1964 the Goldsteins had made some basic chemical
containment and chemical recycling modifications to the facility
at the request of the Pennsylvania Department of Environmental
Resources (PADER).
NWP custom-treats wood as requested by clients, who supply
the materials to be treated. Wood preservation is carried out to
prevent decay or insect infestation of woods used for
construction purposes where the wood will be constantly exposed
to the environment. The type of wood treated at this facility is
determined by the client, who supplies the material precut and
dried, so that, other than loading, treating, unloading, and
storing wood, essentially no other tasks are performed at this
facility. The entire operation at this facility is presently
manned by two employees.
-------
4
,.
Two wood-treating processes have been used at this facility:
the "empty cell pressure treatment process" and the "non-pressure
treatment dip treatment." The facility has three pressure
treatment cylinders; two inside the building and one outside.
Pressure-treated wood was air dried on drip tracks located on
dirt areas around the perimeter of the site. Wood that was
dipped into treatment solutions was similarly dried and handled.
This activity would account for the presence of PCP and heavy
metals in both onsite and drainage area soils. According to the
Remedial Investigation performed by PADER in 1988, at least six
wood-treatment chemical solutions have been used at the NWP
facility since its construction. From 1947 to 1977-1978 three
chemicals were used: pentachlorophenol (PCP) in P-9 Type A oil
(diesel fuel), PCP in P-9 Type C oil (mineral oils), and fluoro-
chrome arsenate phenol (FCAP) in water solution. PCP in oil
(both types) was used in both the pressure treatment and the dip
treatment processes. FCAP was used only in the pressure
treatment process.
:',~
Chlorinated copper arsenate (CCA) in a 0.4 or 0.6% water
solution, first used at the facility in the mid-1970s, eventually
replaced PCP and FCAP during 1977-1978. Other chemicals used on-
site since the 1970s include chromated zinc chloride (CZC, a fire
retardant) and tributyl tin oxide (TBTO, an antifouling
compound). All three water-soluble chemicals were used in the
pressure treatment process. .
The primary contaminants of concern at the site are the
result of wood-treatment operations at NWP. These are PCP,
chlorinated dioxins and dibenzofurans (typical low-level
contaminants in the manufacture of PCP), fuel oil and mineral
spirits components, heavy metals, certain volatile organic
compounds, and phenols. A complete list of the detected
contaminants is presented in Tables 1 thru 6. All these
materials are primary constituents or impurities of the various
wood-treatment solutions used at NWP since operation began in
1947.
...
Enforcement Historv
Between 1947 and 1963, National Wood Preservers, Inc.
disposed of waste liquids (primarily oil contaminated by
pentachlorophenol) by injection into a well which drained into
groundwater beneath the NWP plant. Citizen complaints resulted
in DER involvement. In 1973, DER ordered NWP (and other owners
and occupiers of land located between the NWP plant and Naylors
Run) to abate the pollution. All parties appealed, and seven
years of litigation ensued, in which DER ultimately prevailed
against NWP, but not against the other owners and occupiers.
In 1976, EPA commenced containment operations funded under
Section 311 of the Clean Water Act. These operations were
, :
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TABLE 1
COMPARISON OF MEASURED CONCENTRATIONS TO APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
GROUND WATER (ROUND 1)
pollutants
EPA
RATING/
CATEGORY
MAX
REP. VALUES
CARCINOGENIC
-------
- - -
ARSENIC
BENZO(A)PYRENE
BENZO (A) ANTHRACENE
2,3,7,S-TCDD EQUIVALENTS
BETA BHC
TRICHLOROETHYLENE
BENZENE
CHLOROETHYLENE (VINYL-
CHLORIDE)
BIS(2-ETHYLHEXYL)PHTHALATE
NON-CARCINOGENIC
- - -
-----
~INC
COPPER
ETHYLBENZENE
LEAD
TRANS-1,2-DICHLOROETHYLENE
DICHLOROMETHANE (METHYLENE
CHLORIDE)
PENTACHLOROPHENOL
MIN
ug/l
ug/l
.
MCL
priority
..
MCLG
A
B2
1:32
B2
C
B2
A
A
BDL 7.9
BDL 3.4
BDL 19
6.68x10.4
BDL 18
BDL 86
BDL 20
BDL 9.4
ug/l
ug/l
ug/l
B2
BDL
7.8
BDL ( 2 . 3 )
BDL (20)
BDL (2~J
6.68x10
BDL (0.05)
15
5
(5)
(20)
50
o
5
BDL
2
8
5
4
10
5
10
BDL
28 581 161
2.9 14 7
BDL 340 44
BDL 3.1 1 50 20
BDL 52 13
1.2 62 10
BDL 13000 2400
E
*
Maximum contaminant levels as per the National Primary Drinking
Water Standards.
Maximum contaminant level
Drinking Water standards.
Water Act as amended June
1985.
goals as per the National Primary
Proposed MCL's under the Safe Drin~ing
19, 1986 Federal Register 46902, Nov. 13,
**
ug/1
identifies a unit of measure equivalent to 1 part of a contaminant
for every 1 billion parts of medium.
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TABLE 2
COMPARISON OF MEASURED CONCENTRATIONS TO APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
GROUND WATER - ROUND 2
i..:
CHEMICAL MIN MAX REP. VALUE MCL MCLG
-------------------- ----- ---------- ----- ------
ug/l ug/l
CARCINOGENIC
------- - - -
ARSENIC BOL(1.5) 23 2 50
2,3,7,8-TCDD EQUIVALENTS 7. 84X10-4 7. 84x10-4
TRICHLOROETHYLENE BDL (5) 1700 98 0
l,l-DICHLOROETHYLENE BOL (5) 21 3
BENZENE BDL (5) 320 30 5
1,2-DICHLOROETHANE BDL (5) 37 2 0
DIELDRIN BOL (0.1) 0.22 0
CHLOROETHYLENE BOL (10) 46 3 2
NON-CARCINOGENIC
-----------------------
NICKEL BOL (39) 55 BDL (39)
1,2-DICHLOROETHYLENE BOL (5) 720 48
(TOTAL)
ZINC 8 253 52
CADMIUM BDL (5) 5.6 BOL (5) 10
MERCURY BOL (0.2) 0.39 BDL (0.2) 2
LEAD BOL (1.5) 8.5 1 50 20
ETHYLBENZENE BOL (5) 160 11
,. TOLUENE BOL (5) 47 7
PENTACHLOROPHENOL BOL (100) 4100 1047
..
1./
".
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'l'ABLB 3
COMPARISON OF MEASURED CONCENTRATIONS WITH ARARS
SURFACE WATER BELOW OUTFALL
SURFACE WATER
(BELOW SS OUTLET)
MIN MAX REP. VALUE MCL MCLG
----------
ug/l ug/l ug/l ug/l
BDL (10) 70 18 5
BDL (S) 16 5
1. 54xlO.7 1.54xlO.7
CHEMICAL
-----
------
CARCINOGENIC
- - - -
- - - -
- - -
BENZENE
TRICHLOROETHYLENE
2,3,7,8-TCDD EQUIVALENTS
NON-CARCINOGENIC
- - - ------ - - -
ZINC 98 503 180
COPPER 8.8 11 9
LEAD 2.2 5.2 3 50 20
TRANS-l,2-DICHLOROETHYLENE BDL (5) 9.1 2
TOLUENE BDL (5) 7.8 2
DICHLOROMETHANE (METHYLENE 1.7 3.6 3
CHLORIDE)
PENTACHLOROPHENOL BDL (20) 660 296
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TABLB 4
ONSITE SOIL CONCENTRATIONS
SOIL
--------------------
CHEMICAL
- - - ... - - - -
CARCINOGENIC
- - -- '... ... - - -
BENZO(AJPYRENE
ARSENIC
BENZO (A) ANTHRACENE
CHLORDANE
BETA BHC
2,3,7,8-TCDD EQUIVALENTS
BIS (2-ETHYLHEXYL) PHTHALATE
BENZENE
CHLOROFORM
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
DIELDRIN
BENZO(K}FLUORANTHENE
NON-CARCINOGENIC
- - - -
-----
COPPER
ZINC
NICKEL
CADMIUM
LEAD
MERCURY
ETHYLBEN Z ENE
TOLUENE
DICHLOROMETHANE
1,2-DICHLOROETHYLENE
PENTACHLOROPHENOL
- - -
MAX
- - -
-=:1_----
uq/kq
7200
6850
10000
1300
1300
0.0176
34000
38
2.7
10
3.7
BDL (18)
19000
9790
13000
55
44
108
1.8
490
390
91
(TOTAL) 0
4500000
REP VALUE
...---
uq/kq .
1658
731
3927
371
140
0.00266
5251
3
o
2
o
BDL (18)
4995
835
2111
21
4
50
1
39
32
24
o
446613
. Arsenic values are for total arsenic and were assumed
under a worst-case scenario to be 100% trivalent.
-------
I.
TABLa 5
SEDIMENT CONCENTRATIONS
SEDIMENTS DRAINAGE
(BELOW OUTFALL) DITCH
- - - - - - - - - ------
CHEMICAL MIN MAX SED-10
------ ------- - - - - - - - - - - - - - - -
.,
.. CARCINOGENIC
"
"
I ------- - - - - - -
.
BENZO(A)PYRENE 340 14000 950
BENZO(A) ANTHRACENE 380 15000 340
DIELDRIN BDL (11) 57 BDL (46)
ARSENIC 2.5 6.5 1050
BIS (2-ETHYLHEXYL) PHTHALATE 210 2100 1900
CHLOROFORM BDL (6.3) 2.1 1.7
2,3,7,8-TCDD EQUIVALENTS 0.000047 0.006577
BENZENE BDL (6.3) 1.5 BDL (7.2)
NON-CARCINOGENIC
- - - - - - - - -----
BENZO(A)PYRENE 340 14000 950
LEAD 16 401 231
ARSENIC 2.5 6.5 1050
NICKEL 7.8 18 16
"OPPER 34 88 437
zINC 86 231 3510
CADMIUM BDL (1.1) 2.3 11
MERCURY BDL (.11) 0.13 1.5
BENZENE BDL (6.3) 1.5 BDL (7.2)
DICHLOROMETHANE 12 110 20
.'
..
"
-------
STANDARDS
CHEMICAL
- - - - - - - - - - -
- - - -
-------
CARCINOGENS
-------
**
CHROMIUM VI
BENZENE
ARSENIC
BERYLLIUM
CHLOROFORM
TETRACHLOROETHYLENE
NICKEL
CADMIUM
TRICHLOROETHYLENE
BIS(2-ETHYLEXYL) PHTHALATE
NON-CARCINOGENS
-----
-----
- - -
BENZENE
BERYLLIUM
ZINC
NICKEL
ANTIMONY
TOLUENE
ARSENIC
COPPER
SILVER
DICHLOROMETHANE
CADMIUM
ETHYLBENZENE
CHROMIUM VI
LEAD
TETRACHLOROETHYLENE
DIETHYLPHTHALATE
CHLOROBENZENE
1,1,1-TRICHLOROETHANE
MERCURY
TABLB ,
AIR CONCENTRATIONS
AIR (ROUND 2 of 3)
*
ACGIH PA ~
VALUES
- - - - - - - - - - - - - - - - - - - - - - - -
KIN MAX REP. VALUE
- - - - - - ------
nq/cu.m nq/cu.m nq/cu.m nq/cu.m ng/cu.m
5.19 13.5 8 120 8.33
2500 4800 3400 31200 12500
6.47 8.63 7 24 24
- 0.52 10.4 6 10 10
BDL (87) 300 118 31200 4350
850 1500 1288 1560000
7.54 17.3 12 240 240
0.19 2.2 1 120 55.6
BDL (87) 400 100 1560000 76900
BDL (27) 100 27
2500 4800 3400 31200
0052 10.4 6 10
20114 42047 25966
7.54 17.3 12 240
7.48 11.5 10 1200
12000 32000 19750
6.47 8.63 7 24
16.5 164 91
1.87 5.18 4
72000 90689 80774 3120000
0.91 2.2 1 120
2200 5200 4200
5019 13.5 8 120
1002 13.7. 12 1500
850 1500 1288 1560000
26 110 53
BOL (87) BDL (87)
BOL (87) BOL (87)
BDL(.41) BOL(.41) 240
12500
10
1
24
55.6
8.33
1500
120000
240
* American Conference of Government Industrial Health
** Hexavalent chromium values are for total chromium and were assumed
under a worst-case scenario to be 100% hexavalent.
Note:
nq/cu.m
is a unit of measure equivalent to 1 nanoqram of contaminant for
every cubic meter of air.
-------
5
administered by the Coast Guard. As a result of negotiations
following receipt of a CERCLA notice letter dated December 18,
1981, NWP assumed responsibility for operation and maintenance of
the containment operations in Naylors Run as of February 1, 1982.
In December of 1982, the Havertown PCP site was placed on the
NPL. Subsequent inspections throughout 1984, made by DER and
EPA, found many deficiencies with the containment operations.
After negotiations, an Administrative Order was executed on
October 10 ,1984 between NWP and EPA which required NWP'to
perform various abatement activities. These activities involved
the adequate operation and periodic maintenance of the filter
fences on Naylors Run. During this period DER and subsequently
EPA initiated the RIfFS. The RIfFS was concluded August 1989 by
DER. On August 23, 1989, EPA sent a special notice letter to NWP
to determine its interest in participating in the RD/RA for this
remedial action. On September 6, 1989, EPA received a written
response from NWP. It d~clined to participate.
Analvtical Data
The July, 1989 Focused Feasibility Study prepared for the
Pennsylvania Department of Environmental Resources (PADER) by
Lawler, Matusky and Skelly Engineers, Pearl River, New York
addressed three areas of concern: onsite soils, contaminated
waste in tanks and drums stored on National Wood Preserver's
property, . and water and air releases at Naylors Run. Groundwater
was not addressed in this study, but will be addressed in a later
investigation.
Soil sampling at the NWP plant site revealed concentrations
of fuel oil and PCP widely distributed across the site. Other
base neutral acids (BNAs), metals, dioxins, and dibenzofurans
were also identified. Soils in the tank area (Figure 3) had the
highest detected levels of metals, BNAs (including PCPs), oil and
grease, dioxins, and dibenzofurans. Because benzene was detected
in onsite soils in the low part per billion range, onsite
conditions are not considered to be responsible for air samples
collected around the perimeter of the site which show benzene
exceeding pennsylvania's air standards. Benzene, a constituent
of gasoline, is a common contaminant around gas stations, several
of which are located near the site.
The chemicals detected in surface water samples included
PCP, naphthalene, benzene, toluene, xylene, and phenanthrene.
Concentrations of these chemicals were not detected in surface
water samples, where the floating oil believed to be associated
with the NWP facility was not present. The concentrations of
pesticides and PCBs were below detection levels in all surface
water samples. The toxicity equivalent factors (TEF) for total
tetra- through octa-chlorinated dibenzodioxins and dibenzofurans
in all surface water samples were less than 1 parts per trillion
(0.033 to 0.164 ppt). Toxicity equivalent factors are
-------
NATIONAL WOOD
PRESERVERS INC.
SWISS
FARM
MARKET
FIGURE 3
HAVERTOWN PCP SITE
HAVER TOWN, PA
0 SOIL SAMPLE LOCATION
YOUNGS
PRODUCE
-------
6
coefficiently assigned to isomers of dioxin and dibenzofurans and
are based upon the toxicity of the most hazardous isomers.
contamination in the samples collected above the storm sewer
outlet consists mainly of various heavy metals. The presence of
arsenic, zinc, and copper may be associated with NWP because
these metals are used in the wood-treatment process at the site.
Analytical results show that the sediments generally have
higher levels of contaminants than the surface water. Several
BNAs were found at elevated levels in all sediment samples.
Total BNAs ranged from 221,000 to 6500 parts per billion (ug/kg)
in Naylors Run. PCP levels in samples collected below the
outfall decre~sed from 2300 ug/kg at SED-4 (Figure 4) to 120
ug/kg at SED-1 downstream. The highest level of pCP in sediment
was 8700 ug/kg at SED-10. Total concentrations of metals were
higher in the sediments than in surface water samples. Chromium,
a wood preservative, was -found at 40 ug/kg. No PCBs, dioxins, or
dibenzofurans were found above detection limits.
There are five holding tanks of contaminated water generated
during monitoring well construction and over 100 drums of waste
materials in a storage area northeast of the NWP building. The
two 2500-gal tanks and three 500-gal tanks onsite contain
contaminated water. The oil and grease concentrations in the
water are less than 5 parts per million (mg/l). PCP
concentration is high, about 11,000 ug/l. Toluene (up to 12
ug/l) and trichloroethene (2 ug/l) were also found in the tank
water. Additional material was subsequently added to the tanks by
PADER; however, no new sampling was performed.
Some of the 55-gallon drums were generated by PADER as a
result of the remedial investigation (i.e., used protective
clothing, soils, and various site debris). No analysis was
performed on the contents of these drums. The majority of the
55-gallon drums were placed onsite by EPA, and typically contain
PCP contaminated oil, absorbents, and soiled protected clothing
from EPA's maintenance of the offsite catch basin.
Analysis for dioxin and an acid extractable/phenolic
fraction was performed on the oil discharged at the catch basin
in September, 1988. Some dioxin isomers were detected in the
parts per trillion ranqe, but no 2,3,',8-tetrachlorodibenzo-p-
dioxin (most toxic dioxin isomer) was identified. Naphthalene,
l,l,4-dichlorobenzene, acenaphthene, and phenanthrene were also
found in trace amounts, but pentachlorophenol was detected at
2,951 ppm.
Risk Assessment
. An evaluation of the contaminants present in each medium of
the Havertown PCP site was prepared by Greeley-Polhemus Group,
Inc. (June, 1989) for PADER. It addresses onsite soils and air,
-------
NATIONAL WOOD
PRfcStRVEHS INC.
SED-9.
i
COVERED
PIPE
\ SECTION
PHILADELPHIA
0X CHEWING GUM CO.
<4100
LEGEND
EXISTING WELL LOCATIONS
STORM SEWER
SEDIMENT SAMPLING POINT
ANALYSIS DETECTION LIMIT
200' 0
SCALE IN FEET
FIGURE 4
200'
HAVERTOWN PCP SITE
HAVEHTOWN. PA
SEDIMENT
PENTACHLOROPHENOL (ug/kg )
,r ^86021-060-AA
iH^a
concilium*
-------
7
groundwater, Naylors Run surface water, sediments in Naylors Run,
and sediments in an onsite drainage ditch. The chemicals were
ranked in accordance with their toxicity-concentration (TC)
values. These values were summed for all media to obtain an
indicator score (IS), and the chemicals were ordered in
accordance with their IS values. Carcinogens were ranked
separately from noncarcinogens. Six indicator chemicals were
selected: arsenic, benzene, benzo(a) anthracene, benzo(a)pyrene,
chromium VI, and 2,3,7,S-TCDD equivalents.
The arsenic and chromium probably come from the chromated
copper arsenate used in the wood-preserving operations. The
benzene, benzo(a) anthracene, and benzo(a)pyrene probably are
contaminants in the PCP.
In addition to these indicator chemicals, all other
chemicals detected onsite and in the area that could potentially
cause human health effects were evaluated. These included PCP,
several metals (antimony, beryllium, copper, lead, mercury,
nickel, silver, and zinc), several volatile organic compounds
(VOCs) (chloroform, chloroethylene, dichloromethane,
dichloroethylene, tetrachloroethylene, and trichloroethylene), a
phthalate, and three pesticides (chlordane, lindane, and
dieldrin) that may have been used on site.
Based upon a review of all probable exposure pathways and
the proximity of target organisms to the contaminants, the human
health risk in terms of the maximum potential increased risk of
contracting cancer from inhalation or ingestion was calculated
for each potentially carcinogenic chemical. The results,
expressed in terms of risk per million people exposed, are
incremental, meaning that any increase in cancer cases would be
in addition to the normal 250,000 cancers cases expected for
every 1,000,000 people in the area, even if no contaminants were
present at the site. The risk values are as follows:
1.
Inhalation of entrained particulates containing
chromium VI, arsenic, and other metals from onsite
soils and of VOCs emanating from the site by persons
off site:
DISTANCE FROM THE SITE
500 ft 1000 ft 1320 ft 2000 ft 2640 ft
Cancer risk 5.S 2.9 2.2 1.45 1.1
(per million)
These values are considered to be higher than the actual
risk because the analytical results for total chromium were used
as if they were 100% hexavalent chromium. While the hexavalent
chromium salt is a known human carcinogen through the inhalation
-------
8
route, sampling performed in July, 1989 did not identify the
presence of hexavalent chromium in onsite soils.
2.
Inhalation of benzene and other VOCs at the nearest
residences (two within 75 m or 250 ft) to the catch
basin: 5.5 (per million)
Ingestion of onsite soils: 8 (per million)
This value is considered to be higher than the actual
risk because the analytical results for total arsenic
were used as if they were 100% trivalent arsenic.
3 .
4.
Ingestion of sediments from Naylors Run: 7 (per
m~llion). This value is probably higher, since
were collected prior to the construction of the
basin on Naylors Run.
samples
catch
5.
Ingestion of sediments from the onsite drainage ditch:
1 (per million)
Ingestion of liquids from the underflow dam: 2 (per
million)
6.
The total risk from all sources for a person living
within 500 ft of the site and within 250 ft of the
underflow dam and ingesting the onsite soils and
sediments, the sediments under Naylors Run, and the
liquids in the underflow dam is not cumulative;
however, for multiple exposures to different media a
slightly higher risk than would be calculated by adding
together the risks stated above may be possible.
It should also be noted that none of the noncarcinogens or
the noncarcinogenic effects were calculated to be such that
the Acceptable Daily Intake (ADI) for any chemical was
exceeded for any identified exposure. ADI's are the amounts
of contaminants that a body can consume on a daily basis
without experiencing any ill-effects. These values are
contained in EPA's Integrated Risk Information System (IRIS)
computer database.
7.
Remedial Action Obiectives
Remedial action objectives were broken down into three areas
of concern; onsite soils, catch basin in Naylors Run, and staged
waste materials.
Onsite Soils:
o
The remediation objective for the contaminated soils
onsite is to prevent wind entrainment of and access to
the contaminants in excess of safe levels; and
-------
. --. r. .
9
o
Although the risk was later found to be acceptable,
alternatives were evaluated and are presented in Table
#7.
Catch Basin in Naylors Run:
o
Reduce PCP oil discharge to Naylors Run to less than 5
mg/1. Since the highest PCP level found in the
floating oil was 2,951 mg/l, the highest PCP level
expected in the water if the objective is reached would
be approximately 17 ug/l PCP: and
o
Reduce the concentration of benzene and other VOCs by
17%.
o
These actions will bring the potential exposure risk
to the public and the environment from the storm sewer
effluent to within EPA's acceptable risk range.
Drummed Waste Materials:
o
The remediation objective for the contaminated waste is
to dispose of all materials in a safe and approved
method.
Sediments:
In 1987, before installation of the catch basin,
sediment samples were collected from nine locations in
Naylors Run. The samples were found to be contaminated
with arsenic, chromium VI, benzo{a) anthracene,
benzo{a)pyrene, PCP, and dioxins. Based on these data
and the limited analyses of samples collected in 1988,
the sediments are judged to present a potential health
risk. Remediation alternatives for the sediments
are not addressed here because no data exist after the
installation of the catch basin by EPA in 1988.
Potential health risk due to the public's exposure to
sediments from Naylors Run will be assessed in a second
operable unit.
GENERAL RBSPONSB ACTIONS
The following is a comprehensive list of general response
actions which were screened to identify the remedial action
alternatives which best address the contamination concerns for
each of the fOllowing: onsite soils, Naylors Run storm sewer
effluent, and staged waste material.
I.
CONTAMINATED SOILS
A. Excavation With Off-Site Disposal
-------
10
1.
Excavation
a. Grading
b. Backfill
c. Revegetation or
d. Retaining walls
paving
2.
Landfill Disposal
3.
Incineration
Bo Excavation With Onsite Containment
10
Sorbents
20
Stabiiization
30
Encapsulation
C. Excavation With Onsite Treatment
10 Biodegradation
20 Soil aeration
30 Solvent extraction
4. Chemical dechlorination
50 UV-ozonation
60 Oxidation
70 UV-PHOTOLYSIS
80 Incineration
90 Acid extraction
Do In Situ Containment of Soil
10
Capping
ao MUlti-media (gravel, clay, sand, soil)
bo Asphalt
co Concrete
Eo In Situ Treatment
10 Vitrification
-------
11
2. Chemical dechlorination
3. Bioreclamation
4. Solvent flushing
5. Vacuum well
II. CATCH BASIN
A. Surface Water and Oil Control
1. Cover
2. Gas collection
3. Upstream sedimentation basin
4. Physical treatment (separation)
B. Surface Water and Air Treatment
1. Biological treatment
2. Neutralization
3. precipitation
4. Oxidation
5. Hydrolysis
6. Reduction
7. Chemical dechlorination
8. UV and ozonation
9. Activated carbon water treatment
10. Air/stream stripping
11. Activated carbon air treatment
III. STAGED WASTE MATERIALS
A. Soils, Debris, and oils
1. Landfill
2. Incineration
3. Chemical dechlorination
-------
12
B. Aqueous Wastes (Handled Individually or Composited)
1. Liquid incineration
2. Landfill
3. Chemical dechlorination
4. Carbon adsorption
Based upon the limitations of existing technologies, the
existence of a viable onsite business concern and the requirement
of a permanent treatment remedy, all appropriate technologies are
discussed below.
DescriDtion of Alternatives
The alternatives selected were determined to be both
appropriate responses to conditions at the site and protective of
the public health and welfare, and the environment. They were
developed by cOmbining feasible and applicable technologies based
on their potential application within specified remediation
scenarios. The alternatives are developed separately for each
area of concern (contaminated soil on the NWP site, liquids at
the catch basin in Naylors Run, and contaminated waste from tanks
and drums).
The alternatives are further evaluated using the nine
criteria specified in Section 121 of CERCLA. These are
protectiveness of human health and the environment, compliance
with all applicable, "relevant and appropriate requirements
(ARARs); reduction of toxicity, mobility, or volume; State
acceptance; community acceptance; short-term effectiveness, long-
term effectiveness, implementability, and cost.
Tables 7, 8, and 9 refer to a review of the suitable
alternatives for onsite soils, Naylors Run storm sewer effluent,
and staged waste materials based upon the nine criteria listed
above.
EPA's Selected Remedies/statutorv Determinations
EPA's preferred alternatives for remediation of the
Havertown PCP site are alternative #1 for soil, #3 for surface
water, and #2 for the disposal of the onsite drums and tanks.
No-Action alternative for onsite soils
The No-Action alternative (#1) for soil achieves the
remedial action objectives because the potential threat to the
public's health associated with contaminated dust and
infiltration of contaminants into the environment poses no
-------
TABLE 7.1
INDIVIDUAL BVALUATIOH OP PINAL ALTERNATIVES - CONTAMINATED SOIL ON NWP SITE
ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4
ALTERNATIVE 1 CAP SOIL CAP SOIL EXCAVATION WITH
CRITERIA NO ACTION WITH CONCRETE WITH ASPHALT LANDFILL DISPOSAL
Short-Term
Effectiveness
Community Risk to community Temporary increase Temporary increase Temporary increase
protection not increased by in dust production in dust production . in dust production
remedy implemen- through cap instal- through cap instal- through excavation
tation. lation. contamina- lation. Contamina- and soil transpor-
ted soils remain ted soils remain tat ion.
undisturbed. undisturbed.
Worker No risk to Protection requir- Protection requir- Protection requir-
protection workers. ed against dermal ed against dermal ed against dermal
contact and inhal- contact and inhal- contact and inhal-
ation of contamin- at ion of contamin- ation of contamin-
ated dust during ated dust during ated dust during
cap construction. cap construction. excavation and
transportation.
Environmental No change from Cap installation Cap installation Excavation may
existing condi- may temporarily may temporarily temporarily impact
tions. impact air impact air air quality.
quality. quality.
-------
TABLB 7.2
INDIVIDUAL BVALUATION OF FINAL ALTBRNATIVES - CONTAMINATBD SOIL ON HWP SITB
CRITERIA
Time until
action is
complete
Compliance With
ARARs
Chemical-
specific
ARARs
Location-
specific
ARARs
ALTERNATIVE 1
NO ACTION
Not applicable.
Not applicable.
Not applicable.
There are no
location-specific
ARARs.
ALTERNATIVE 2
CAP SOIL
WITH CONCRETE
Cap installed in
three months.
Would meet Penn-
sylvania air
standards at the
site boundary.
Not relevant.
There are no
location-specific
ARARs.
ALTERNATIVE J
CAP SOIL
WITH ASPHALT
Cap installed in
two months.
,
Would meet Penn-
sylvania air
standards at the
site boundary.
Not relevant.
There are no
location-specific
ARARs.
ALTERNATIVE 4
EXCAVATION WITH
LANDFILL DISPOSAL
Excavation complete
in one year (75
trucks/week, 12
yd]/truck); back-
fill with clean
fill, grading com-
plete after an
additional two
months.
Would meet Penn-
sylvania air stand-
ards at the site
boundary.
Not relevant. There
are no location-
specific ARARs.
-------
TABLE 7.3
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES - CONTAMINATED SOIL ON NWP SITE
CRITERIA
Action-
specific ARARs
Other
criteria and
guidance
ALTERNATIVE 1
NO ACTION
Not applicable.
Within EPA's
acceptable cancer
risk range of
10'7 to 10-4.
Overall Protection
Human health
protection
Environmental
protection
I
I
Some reduction in
access to risk
through fence
repair.
contaminants
remain on site.
ALTERNATIVE 2
CAP SOIL
WITH CONCRETE
Would not meet
RCRA landfill
closure require-
ment (40 CFR
264.228, 40 CFR
264.310).
Within EPA's
acceptable cancer
risk range of
10-7 to 10-4.
Cap reduces direct
contact risk and
soil ingestion
risk to less than
1 X 10-6.
Contaminant move-
ment is reduced
by use of cap.
ALTERNATIVE 3
CAP SOIL
WITH ASPHALT
Would not meet
RCRA landfill
closur~ require-
ment (40 CFR
264.228, 40 CFR
264.310).
within EPA's
acceptable cancer
risk range of
10-7 to 10-4.
Cap reduces direct
contact risk and
soil ingestion
risk to less than
1 X 10-6.
Contaminant move-
ment is reduced
by use of cap.
ALTERNATIVE 4
EXCAVATION WITH
LANDFILL DISPOSAL
Would meet RCRA
clean closure and
land disposal
requirement (40 CFR
264.111, 40 CFR
268.31).
within EPA's
acceptable cancer
risk range of 10-1
to 10-4.
Excavation and off-
site landfill
reduce direct con-
tact/soil ingestion
to less than
1 X 10-6.
contaminant source
is removed by use
of excavation and
landfill.
-------
TABLE 7.4
INDIVIDUAL EVALUATION 01' I'INAL ALTERHATIVES - CONTAMINATBD SOIL ON HWP SITE
ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4
ALTERNATIVE 1 CAP SOIL CAP SOIL EXCAVATION WITH
CRITERIA NO ACTION WITH CONCRETE WITH ASPHALT LANDFILL DISPOSAL
Reduction of
Toxicitv. Mobilitv.
or Volume Throuqh
Treatment
Treatment None. None. None. None.
process used
Amount destroyed None. None.. None. All contaminated
or treated soil removed.
Reduction of None. Air and ground- Air and ground- Toxicity, mObility,
toxicity, water mobility water mobility and volume of con-
mobility, or reduced by reduced by taminated soil
volume capping. capping.. reduced on site.
Irreversible None. None. None.. None.
treatment
Type and quant- None.. None. None. None.
ity of residuals
remaining after
treatment
statutory Does not satisfy. Does not satisfy. Does not satisfy. Does not satisfy.
preference
for treatment
, .
-------
TABLB 7.5
INDIVIDUAL EVALUATION 01' I'INAL ALTBIUIATIVBS - CONTAHINATBD SOIL ON NWP SITB
ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4
ALTERNATIVE 1 CAP SOIL CAP SOIL EXCAVATION WITH
CRITERIA NO ACTION WITH CONCRETE WITH ASPHALT LANDFILL DISPOSAL
Lonq-Term Effective-
ness and Permanence
0
Magnitude of Source has not Risk eliminated Risk eliminated Source has been
residual risk been removed. as long as cap is as long as cap is removed; risk will
Existing risk maintained. maintained. no longer exist.
could potentially Because source is Because source is
mitigate over only contained, only contained,
time. inherent hazard inherent hazard of
of waste remains. waste remains.
Adequacy and No controls over The cap controls The cap controls Excavation and off-
reliability of remaining contami- contaminated soil. contaminated soil. site landfill are
controls nation. The cap is effec- . The cap is effec- adequate and reli-
tive and reliable tive and reliable able to control
with minimal only if regularly contaminated soil.
maintenance. Cap maintained. Cap
will withstand cannot withstand
truck traffic. constant truck
traffic.
Need for 5- Review would be Review would be Review would be Not applicable.
\ year review performed to required since required since Contaminated soil
ensure that contaminated soil contaminated soil would not be on
protection of remains on site. remains on site. site.
human health and
the environment
is maintained.
-------
TABLE 7.6
INDIVIDUAL BVALUATION or rINAL ALTERNATIVES - CONTAMINATBD SOIL ON NWP SITB
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
CAP SOIL
WITH CONCRETE
ALTERNATIVE 3
CAP SOIL
WITH ASPHALT
ALTERNATivE 4
EXCAVATION WITH
LANDFILL DISPOSAL
Imnlementabilitv
Ability to
construct and
operate
I.
I
I
I
Ease of doing
more action
Ability to
monitor
effectiveness
No construction
or operation.
If monitoring
indicates more
action is nec-
essary, may need
to'go through.
the FS/ROD process
again.
Monitoring would
further document
existing condi-
tion.
Simple to con-
struct. Would
require about
2150 yd3 of
reinforced con-
crete and 1620
ydJ of gravel.
Simple to extend
capping.
Inspection and
monitoring would
detect failure
before significant
exposure occurs.
,
Simple to con-
struct. Would
require about
1350 yd3 of
asrhalt and 1620
yd of gravel.
Simple to extend
capping.
Inspection and
monitoring would
detect failure
before significant
exposure occurs.
Simple to con-
struct. Would
require backfillin~
of about 45,200 yd
of soil.
Can handle varying
volumes.
Not applicable.
-------
TABLE 7.7
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES - CONTAMINATBD SOIL ON NWP SITE
CRITERIA
Ability to
obtain approv-
als and coor-
dinate with
other agencies
Availability of
service and
capacities
Availability
of equipment
specialists,
and materials
Availability
of technology
Cost
Capital cost
Annual O&M cost
(with monitoring)
ALTERNATIVE 1
NO ACTION
No approval
necessary.
No services or
capacities
required.
None required.
None required.
$18,800
$65,000
Present worth oost $335,000
ALTERNATIVE 2
CAP SOIL
WITH CONCRETE
No approval
necessary.
Only basic con-
struction services
needed.
No special equip-
ment, materials,
or specialists
required. Cap
materials avail-
able within 20
miles.
Cap technology
readily available.
$668,900
$55,000
$1,288,100
ALTERNATIVE 3
CAP SOIL
WITH ASPHALT
No approval
necessary.
Only basic con-
struction services
needed.
No special equip-
ment, materials,
or specialists
required. Cap
materials avail-
able with 20
miles.
Cap technology
readily available.
$344,100
$65,000
$1,075,900
ALTERNATIVE 4
EXCAVATION WITH
LANDFILL DISPOSAL
Need a permit for
hauling contamina-
ted soil; need
approval for land-
fill disposal.
Limited landfill
availability.
Need licensed
drivers.
Not applicable.
$19,144,000
$281,400
$19,425,400
-------
.' . . .~;, . ',;. : . :. - - '
'. ::.~.. ~'-:;""",: ,",,:.:. . . .:-.. ':' '. !
, ,.;.
--------------------
. . .
',," .. .,..'
TABLE 7.8
INDIVIDUAL EVALUATION or rINAL ALTBRNATIVES - CONTAMINATBD SOIL ON HWP SITB
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
CAP SOIL
WITH CONCRETE
ALTERNATIVE 3
CAP SOIL
WITH ASPHALT
ALTERNATIVE 4
EXCAVATION WITH
LANDFILL DISPOSAL
Acceptabilitv
bv State
Moderate
Moderate
Moderate
Moderate
Public Acceptance
Moderate
Moderate
Moderate
Moderate
-------
I
I.
I
I
TABLE 8.1
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES - LIQUID EPPLUENT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Short-Term
Effectiveness
Community
protection
Worker
protection
I .
I.
Environmental
impact
Time until
action is
complete
Compliance
with ARARs
Chemical-
specific
ARARs
I '
Risk to community not
increased by remedy
implementation.
No significant risk to
workers.
continued impact from
existing conditions.
Not applicable.
Not applicable.
Risk to community not in-
creased by remedy imple-
mentation.
Protection required
against VOCs inhalation
and dermal contact during
maintenance of filter
fence.
continued impact to air
quality.
Currently in place.
Does not meet Pennsylvania
air standards past the
site boundary. Would meet
NPDES requirements at the
site boundary.
Temporary disturbance of
storm sewer discharge
during installation of
separator.
Protection required
against VOCs inhalation
and dermal contact dur-
ing servicing of oil/-
water separator.
Temporary increase in
stream turbidity during
construction.
Two months.
Would meet Pennsylvania
air standards past the.
site boundary. Would
meet NPDES requirements
at the site boundary.
-------
.:,:. ..'
,..-",' ,
, "".""
TABLB 8.2
, :,::'.....,.,":.
INDIVIDUAL BVALUATION OF FINAL ALTBRNATIVES - LIQUID BFFLUBNT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Location-specific
ARARs
Action-specific
ARARs
Other criteria
and guidance
I
Overall Protection
Human health
protection
- Air inhalation
- Surface water
ingestion
Not applicable.
Not applicable.
Not applicable.
No reduction in risk.
No reduction in risk.
Not applicable.
Would not meet NPDES
requirements.
Would allow inhalation of
contaminated air exceeding
1 x 10~ risk. Would reduce
ingestion of surface water
exceeding 1 x 10-6 risk.
No significant reduction
in risk.
Does not reduce surface
water ingestion risk to
less than 1 x 10-6.
oil/water separator in
100-year flood zone.
May meet NPD~S require-
ments for oil and
grease.
Protects against inges-
tion of surface water
and inhalation of con-
taminated air exceeding
1 x 10-6 risk.
Can reduce air inhala-
tion risk to less than
1 x 10-6.
Can reduce surface water
ingestion to less than
1 x 10.6.
-------
TABLE 8.3
INDIVIDUAL EVALUATION OF FINAL ALTERNATIVES - LIQUID EFFLUENT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Environmental
protection
Reduction
Toxicitv.
or Volume
Treatment
Continued VOCs emission
to air and contaminated
. oil discharge to Naylors
Run.
of
Mobilitv.
Throuqh
Treatment
process used
Amount
destroyed or
treated
Reduction of
toxicity,
mobility, or
volume
Irreversible
treatment
None.
None.
None.
None.
Continued VOCs emmission to
air and reduced contamina-
ted oil discharge to
Naylors Run.
Existing catch basin and
filter fence.
Treat less than 1.3 gpd
oil.
Toxicity of surface water
reduced in the vicinity of
catch basin.
Present oil recovery
system is reversible.
VOCs emmission and con-
taminated oil discharge
are mitigated by use of
optimum oil/water
separator.
Optimum Oil/water
separation.
Treat 1.3-8 gpd oil.
90' VOCs in the vapor
removed.
Toxicity of air and
surface water reduced
in the vicinity of catch
basin.
Oil/water separation is
reversible.
-------
TABLE 8.4
INDIVIDUAL BVALUATION OP PINAL ALTBRNATIVES - LIQUID BPPLUBNT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Type and quant-
ity of residual
remaining after
treatment
Statutory pref-
erence for
treatment
Lona-Term
Effectiveness
and Permanence
Magnitude of
residual risk
- Air inhala-
tion
- Surface
water
ingestion
No residual remaining. Residual oily absorbent
materials: approximately
four barrels per month.
Does not satisfy.
Source has not been re-
moved; existing risk
will remain.
Source has not been re-
moved: existing risk
will remain.
Satisfies.
Source has not been re-
moved: existing risk
would remain.
Risk reduced through
inspection and mainten-
ance of existing catch
basin.
Liquid oil residue: less
than four barrels per
month.
Satisfies.
Risk eliminated through
air containment within
separator.
Risk eliminated through
optimum oil/water
separator.
-------
TABLE 8.5
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES -LIQUID EPPLUENT CONTROL AT CATCR BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Adequacy and
reliability
of control
Need for 5-yr
, review
I'
Implementability
Ability to
construct and
operate
Ease of doing
more action
if needed
Ability to
monitor
No controls over remain-
ing contamination. No
reliability.
Review would be required
to assess impact of
discharge.
No construction or
operation.
Not applicable.
Monitoring would better
define extent of
contamination.
Present system can reduce
contaminated oil discharge,
but is not reliable. No
control of air contamina-
tion.
Review would be required
to ensure that minimal
protection of human health
and the environment is
maintained.
Simple to maintain filter
fence.
If monitoring indicates
more action is necessary,
may need to go through
the FS/ROD process again.
Monitoring would determine
effectiveness of treatment.
The alternative is ade-
quate and reliable to
control contaminated oil
and air.
Review would be required
to ensure that adequate
protection of human
health and the environ-
ment is maintained.
Installation will re-
quire excavation of soil
and rock near catch
basin; operation is
routine.
Can treat 200 gpm. If
volumes exceed maximum
separator capacity due
to severe storms, they
must bypass separator.
Monitoring would deter-
mine effectiveness of
treatment.
-------
TABLE 8.6
INDIVIDUAL EVALUATION 01' I'INAL ALTERNATIVES - LIQUID EI'I'LUENT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
Ability of obtain
approvals and
coordinate with
other agencies
Availability
of services
and capacities
Availability of
equipment, spec-
ialists, and
materials
Availability
of technologies
No approval necessary.
No services or capac-
ities required.
None required.
None required.
No approval necessary.
Need continued sorbent
boom maintenance.
Present system is current-
ly maintained: no special
equipment, etc., required.
None required.
No permit required, how-
ever, EPA must attempt
to meet standards for
construction and opera-
tion of separator.
Oil/water separator
maintenance services
available from commer-
cial sources. oil to be
hauled by licensed
carrier to permitted
disposal facility.
Oil/water separator
vice requires pump,
barrels - readily
available.
ser-
Oil/water separation
technology well develop-
ed and available.
-------
TABLE 8.7
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES - LIQUID EFFLUENT CONTROL AT CATCH BASIN
CRITERIA
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
PRESENT SYSTEM FOR
LIQUID CONTROL
ALTERNATIVE 3
OPTIMUM OIL/WATER
SEPARATOR
~
capital cost
$50,000
$20,000
$50,000
$45,000
$158,500
$45,000
Annual O&M
cost (with
monitoring)
Present worth
cost
$275,000 $556,600 $665,100
Low Moderate High
Low Low High
AcceDtabilitv
by state
Public
AcceDtance
-------
TABLE 901
INDIVIDUAL EVALUATION OP PINAL ALTERNATIVES - CONTAMINATED WASTE PRON TANKS AND DRUNS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOIL
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
OFFSITE TREATMENT
OF AQUEOUS WASTE
Short - Term Effectiveness
Community protection
Worker protection
Environmental impact
Time until action is
complete
Compliance With ARARs
Chemical-specific ARARs
Temporary increase
production through
and transportation
and debris.
in dust
loading
of soil
Protection required against
dermal contact and inhalation
of contaminated waste during
loading, transportation, and
treatment.
Loading, transportation, and
treatment may temporarily
impact air quality.
Offsite landfill of soil and
debris and carbon adsorption
of aqueous waste may be
completed in two months.
Temporary increase
production through
and transportation
and debris.
in dust
loading
of soil
Protection required against
dermal contact and inhalation
of contaminated waste during
loading, transportation, and
treatment.
Loading, transportation, and
treatment may temporarily
impact air quality.
Offsite landfill of soil
debris and bulk transfer
liquids may be completed
months.
and
of
in two
Would meet Pennsylvania air Would meet Pennsylvania air
standards at the site boundary. standards at the site boundary.
, I
-------
TABLB 9.2
INDIVIDUAL BVALUATION or rINAL ALTBRNATIVES - CONTAMINATBD WASTB rRON TANKS AND DRUMS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOIL
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
OFFSITE TREATMENT
OF AQUEOUS WASTE
Location-specific ARARs
Action-specific ARARs
Other criteria and guidance
Overall Protection
Human health protection
Environmental protection
Not relevant. There are no
location-specific ARARs.
Would meet RCRA clean closure
and land disposal requirements
(40 CFR 264.111, 40 CFR
268.31) .
Protects against inhalation
of contaminated air to less
than 1 x 10~ risk.
Eliminates potential for
ingestion, inhalation.
Potential contaminant release
to environment eliminated.
Not relevant. There are no
, location-specific ARARs.
Would meet RCRA clean closure
and land disposal requirements
(40 CFR 264.111, 40 CFR
268.31).
Protects against inhalation of
contaminated air to less than
1 x 10.6 risk.
Eliminates potential for
ingestion, inhalation.
Potential contaminant release
to environment eliminated.
-------
TABLE 9.3
INDIVIDUAL EVALUATION OF FINAL ALTERNATIVES - CONTAMINATED WASTE PROM TANKS AND DRUMS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOIL
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
OFFSITE TREATMENT
OF AQUEOUS WASTE
Reduction of Toxicitv.
Mobilitv. or Volume
Throuah Treatment
Treatment process used
Amount destroyed or treated
Reduction of toxicity,
mobility, or volume
Irreversible treatment
Type and quantity of
residuals remaining
after treatment
Statutory preference for
treatment
Carbon adsorption of water
99.9% PCP in the aqueous waste
removed by carbon adsorption.
Toxicity of contaminated
water reduced.
Carbon adsorption with regen-
eration of carbon is irre-
versible.
Metals and chlorinated com-
pounds are residual in the
waste. Carbon requires
regeneration or disposal.
satisfies.
Offsite treatment (possibly
carbon adsorption)
99.9% PCP in the aqueous waste
removed by carbon adsorption.
Toxici~y' of contaminated water
reduced.
Carbon adsorption with regen-
eration of carbon is irre-
versible.
Metals and chlorinated com-
pounds are residual in the
waste. Carbon requires
regeneration or disposal.
satisfies.
-------
TABLE 9.4
INDIVIDUAL EVALUATION 01' I'INAL ALTERNATIVES - CONTAMINATED WASTE I'ROM TANKS AND DRUMS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOIL
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
Offsite TREATMENT
OF AQUEOUS WASTE
Lonq-Term Effectiveness and
Permanence
Magnitude of residual risk
Adequacy and reliability of
control
Need for 5-yr review
Implementabilitv
Ability to construct and
operate
Ease of doing more action
if needed
Ability to monitor
effectiveness
Risk eliminated through off-
site land-fill and carbon
adsorption.
Actions are adequate and
reliable to control contamin-
ated waste.
Not applicable.
Carbon adsorption requires
some operation.
Carbon adsorption can handle
varying aqueous/waste volumes
or concentrations of contam-
inants.
Visual inspection adequate to
ensure removal. Carbon adsorp-
tion effluent will be
monitored.
Risk eliminated through off-
site land-fill and treatment.
Actions are adequate and
reliable to control contamina-
ted waste.
Not applicable.
No operation required.
Offsite treatment facility
will have flexibility to treat
waste as required.
Visual inspection adequate to
ensure removal.
-------
TABLB 9.5
INDIVIDUAL BVALUATIOH 01' PINAL ALTBRNATIVES - CONTAMINATBD WASTE PROM TANKS AND DRUMS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOI.L
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
OFFSITE TREATMENT
OF AQUEOUS WASTE
Ability to obtain approvals
and coordinate with other
agencies
Availability of service
and capacities
Availability of equipment,
specialists, and materials
Availability of technology
Need a permit for hauling the
waste and an approval for
landfill disposal. May need
NPpES discharge permit for
carbon adsorption process.
Need carbon adsorption ser-
vices. Limited approved
landfill site availability.
Needs operator to install
and operate carbon adsorp-
tion. Need licensed drivers.
Carbon adsorption is conven-
tional technology.
Need a permit for ~auling the
. waste and an approval for
landfill disposal.
Limited approved landfill site
availability. Treatment facil-
ity available nearby.
Need licensed drivers. Need
bulk liquid handling trucks.
Treatment facilities are
available.
-------
TABLB 9.6
INDIVIDUAL BVALUATIOH O~ ~IHAL ALTERNATIVES - COH'l'AHIHATBD WASTB rROM TANKS AND DRUMS
CRITERIA
ALTERNATIVE 1
LANDFILL OF SOIL
AND OILY DEBRIS,
CARBON ADSORPTION
OF AQUEOUS WASTE
ALTERNATIVE 2
LANDFILL OF SOIL
AND OILY DEBRIS,
OFFSITE TREATMENT
OF AQUEOUS WASTE
Cost
capital cost
continue first year annual
O&M cost
Public Acceptance
$153,000 $161,200
o 0
$153,000 $161,200
Moderate Moderate
Moderate, Moderate
Present worth cost
Acceptabilitv bv State
-------
13
significant risk to human health. Any potential impact from the
soil on groundwater will be addressed in the next operable unit.
Because of the location and size of the site (2 acres) in
the middle of a commercial/industrial area, surrounded by a
residential community, no wildlife is expected to be impacted by
the continuance of present site conditions. No wetlands, parks,
critical habitats or habitats of endangered species are within
close proximity to the site, and based on sediment and surface
water data, runoff from the site exerts a negligible effect on
Naylors Run.
Even though compliance with the provisions of Section 121 of
SARA regarding the degree of cleanup is not triggered by the No
Action alternative, it is appropriate to demonstrate that this
alternative is protective of human health and the environment.
The chosen alternative meets current ACGIH, NIOSH and
Pennsylvania Air Standards for all contaminants which originated
from the site. While no legislated quantitative cleanup levels
for hazardous wastes in soils exists, the risk assessment
determines the degree of cleanup necessary. Since risks at the
site for the different media are within EPA's acceptable range of
10"7 to 10"4 for an incremental cancer risk, the requirements of
the No Action alternative is protective of the public's health.
Since there is minimal remedial construction, capital and
O&M costs are low (Table 10) and monitoring costs are moderate.
The no action alternative complies with all appropriate
criteria for selection as the remedial response for onsite soil
contamination.
Because the selected remedy provides for a security fence
around the site perimeter and an ongoing business currently
occupies the site, it is unlikely that children will be found
frequently playing on the property. Therefore, the possibility
of onsite soil ingestion by the public is not considered a
probable event.
The No Action alternative for onsite soils is protective of
both human health and the environment. All potential pathways
from direct contact were examined in order to make this
determination.
A 5-year program for soil monitoring will be implemented and
results will be reviewed yearly. A determination will then be
made by EPA concerning the appropriateness of taking further
actions. Upon completion of this program, EPA will determine if
additional sampling or remedial action are necessary.
Oil/Water separator for storm sewer effluent
-------
TABLE 10
NO ACTION - CONTAMINATED SOIL ON NWP SITE
A.
CAPITAL COSTS
$
15,000
1yr
$ 18,800
$316,200
$335,000
1. Fencing
2. contingency (25%) of
construction costs
3.800
Total Capital Costs.........~...........
B.
CONTINUING O&M COST
1. Monitoring
Present worth (8% for 5
C.
PRESENT
WORTH. . . . . . . . . . . . . . . . . . . . . . . . . . .
$
65,000
years)..........
-------
14
The recommended alternative for remediation of the storm
drain effluent to Naylors Run is the installation and operation
of an oil/water separator (Alternative 3). Such separators,
which are commercially available, are used in petroleum
distribution and transportation facilities and in a variety of
other industrial and mi-litary operations. Of the three
alternatives, only the oil/water separator complies with ARARs
and provides overall, long-term protection to humans (Table #11).
The unit is expected to remain in place for 30-years, however a
periodic review of site conditions may alter this time-frame.
Discharge criteria was previously discussed in the Remedial
Action Objectives section of this ROD.,
Installation of a carbon adsorption air treatment unit is
not considered necessary since the oil/water separator is a
closed vessel with only a small vent from which VOCs could be
released. Also, since the existing risk due to inhalation of
organics from the catch basin at the two residences nearest to
the basin is based on limited empirical data, the following
additional actions are to be conducted in the area of the catch
basin:
o Measurement of flow volumes from the stormwater
pipe draining the NWP site area and in Naylors Run
o Air sampling for VOCs near the catch basin
o Perform a one time water and oil sampling program
within the catch basin for PCP, VOCs and other
contaminants of concern to update the historical
sampling data
o Perform yearly monitoring of sediments, water, and
biota to determine current site conditions and the
need for further remedial actions
Landfill and offsite treatment for staged waste materials
The recommended alternative for cleaning up the contaminated
waste staged on site is alternative #2 - landfill of soil and
oily debris and offsite treatment of aqueous waste (Table #12).
While the two alternatives evaluated are similar, offsite
treatment of the liquid waste is recommended for two reasons:
o It can be implemented more readily; a carbon
adsorption unit does not have to be brought on
site, effluent testing is not required, and
compliance with NPOES standards is not needed.
o Offsite treatment will not require discharging of
effluent (albeit treated) to Naylors Run and
therefore will be more acceptable to the
community.
-------
TABLE 11
OPTIMUM OIL/WATER SEPARATOR -
LIQUID EFFLUENT CONTROL AT NAYLORS RUN CATCH BASIN
A. CAPITAL COSTS
B.
C.
1.
Initial monitoring of sediments, water,
and biota
2.
Oil/water separator, including
installation
3.
Health ~nd safety
Predesign data acquisition
4.
5.
Engineering and design (25% of Nos. 2-4)
Legal and administrative (20% of Nos. 2-4)
6.
7.
Contingency (25% of Nos. 2-4)
Total capital Costs.........................
CONTINUING O&M COST
1.
O&M of oil/water separator
Monitoring of water and sediments
2.
Total O&M
Present worth (8% for 30 years).............
]?~~~!l~ ~()~~...............................
$ 50,000
35,000
2,000
25,000
15,500
12,400
15.500
$155,400
$ 30,000/yr
15,000/yr
$ 45,000/yr
$506,600
$662,000
-------
TABLE 12
LANDFILL OF SOIL AND OILY DEBRIS AND OFFSITE TREATMENT OF
WATER FROM CONTAMINATED WASTE IN TANKS AND DRUMS
A. CAPITAL COSTS
1. Sampling, analysis, and labeling $ 30,000
of soil and oily debris (200 drums)
2. Offsite disposal (landfill) of 35,000
soil and oily debris
3. Sampling and analysis of aqueous waste 5,000
4. Offsite hauling and treating of 24,000
aqueous waste (6000 gal § $4/gal)
5. Health and safety 10,000
6. Engineering and design (10%) 10,400
7. Legal and administrative (20%) 20,800
8. Contingency (25%) 26.000
Total capital costs 161,200
B. CONTINUING O&M COST 0
C. PRESENT WORTH $161,200
-------
--.--
- ._-~. --------:- .' .' . "'.
- '."
15
The state has concurred with these selected remedies.
APPlicable. Relevant and Appropriate Reauirements (ARARs)
The remedial action alterna~ives selected for two of the
three problem areas of concern (the catch basin and the onsite
staged -materials) must meet or exceed all applicable, relevant
and appropriate requirements (ARARs) unless a waiver provided by
CERCLA Section 121(d) (4) is invoked.
Remedial action alternatives for the catch basin are not
intended as final remedial actions for the site. ARARs are
waived (CERCLA Section 121(d) (4) (Ať for this portion because it
is only part of a total remedial action alternative to be
developed in an upcoming_operable unit. Offsite disposal
requirements for generated wastes from the catch basin and
existing onsite staged material will comply with all RCRA
transport and disposal regulations.
As described in Section 121 of SARA, no review of ARARs is
to be made when the No-Action Alternative is selected as in the
case of onsite soils.
Communitv Relations
EPA considers public participation in the decision-making
process associated with site remediations to be vital.
Consequently, the Agency makes site-related documents available
to the public at a particular location in the community. For
this Site, the information repository is the:
Haverford Township Building
2325 Darby Road
Havertown, PA 19083-2251
Since this was a State-lead site, the State was required to
announce the availability of the FS Report and to provide a
public comment period. The comment period for the Havertown PCP
Site began on August 25, 1989, and extended until September 25,
1989.
A responsiveness summary is provided in Appendix A.
Comments, inquiries, and requests for additional information
may also be made by contacting the following EPA/PADER
representatives:
-------
16
Ms. Nanci Sinclair (3PAOO)
community Relations Coordinator
(215) 597-4164
Mr. Nick DiNardo (3HW22)
Regional Project Manager
(215) 597-8541
US EPA
841 Chestnut Street
Philadelphia, PA 19107
";
Thomas Leaver
PA Dept. of Environmental
P. O. Box 2063
Harrisburg, PA 17120
(717) 783-7816
Resources
..-.;
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I"
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-------
- - --
- --.'"
, ,
. , ,
-
~ . - .
Appendix "A"
Responsiveness summary
On August 25, 1989, the Delaware County Times ran an EPA
advertisement announcing the preferred cleanup altern~:ives for
the Havertown PCP Superfund Site. The comment period extended
from August 25, 1989 to September 25, 1989 and, was announced in
this ad.
Throughout the Superfund process, EPA and PADER have never
received written comments from Havertown residents regarding the
site. No comments were received during the past comment period.
I'
i',
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