UnM SatM
Environmental ProtKtion
Agency
Oftoot
Emergency and
Rwrwdial RMponse
EPAyROO/R03-80A»7
June 1990
Superfund
Record of Decision
M.W. Manufacturing, PA

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502n.;01
REPORT DOCUMENTATION 1'. REPORT NO.     J ~    a. Redplenfa Acca8aIon No.     -
 PAGE. EPA/ROD/R03-90/087            
4. TiUe.nd SubtiUe                5. Report DaI8      
SUPERFUND RECORD OF DECISION                .
        06/29/90      
~'1. W. Manufacturing, PA                  
           ..       
Second Remedial Action                  
7. Author(.)                  L Pllrformlng Organlza1lon RepL No.   
t. Petfonnlng Orllelnlzation N8me end Add....          10. PtoledfTulllWon UnIt No.     
                  11. ConIract(C) Dr Gr8nI(G) No.     
                  (C)       
                  (0)       
1~ ~ Orll8lllzation N8m8 end AddrM8 -        11. Type of Report . P8r1ocI Cownd   
U.S. Environmental Protection Agency      800/000     
401 M Street, S.W.                 
Washington, D.C. 20460          14.       
15. Supplementary NoIII.                        
16. Ab81r.ct (Umlt: 200 word.)                      
The 1S-acre M.W. Manufacturing site is a former copper recovery facility in Montour 
County, Pennsylvania, two miles north of Danville. The Pennsylvania Department of 
Transportation (PennDOT) maintains a storage area immediately north of the site, and 
farmlands and wooded lots are adjacent to the site on the west and south. Mauses  
Creek flows' in a southerly direction past the site. Several private residences,  
motels, gas stat~ons, restaurants, and a Head Start school are located just north o~ 
the PennDOT storage area and rely on private ground water wells for drinking watez 
From 1966 to 1972, M.W. Manufacturing was engaged in secondary copper recovery from 
scrap wire, using both mechanical and chemical processes. Granular carbon wastes  
generated by the chemical process were dumped onsite, and spent solvents and acids 
were allegedly disposed of onsite. In 1972, M.W. Manufacturing filed fqr bankruptcy 
and the Philadelphia National Bank acquired the property. Warehouse 81 Inc. acquired 
the site in 1976 and unsuccessfully attempted to recover copper from the large waste 
piles of fluff material (fibrous insulation materials contaminated with metals and 
solvents). The initial remedial investigation revealed several areas posing potential
threats to public health: the carbon waste pile, four wire-fluff waste piles, a  
surface impoundment, a buried lagoon, and contaminated soil, drums and storage tanks. 
(See Attached Sheet)                  
17. Doa8I8n1 An8/y8Ia & Dnc:rIpIo,.                    
Record of Decision - M.W. Manufacturing, PA            
Second Remedial Action                  
Contaminated Media: soil, debris, sw             
Key Contaminants: VOCs (PCE , TCE), other organics (PCBs), metals (lead)     
b. ~T8m18                      
Co COSA 11 FI8ItIIGrcqt                        
18. Anilabilty SIaIenwnI            11. 8acuftr CI8a8 (11IIa AIporQ 21. No. of .......   
                 None   72     
              2G. 8acuftr CI8a8 (11IIa 1'188) a .....     
               NonA         
                    . 
(Sae ANSl-Z3I.18)
SNIn8InM:f- on At-
(FDI'III8Ity 1fT1S.35)
~tofc-.

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EPA/ROD/R03-90/087
M.W. MANUFACTURING, PA
Second Remedial Action
Ab~tract (Continuedj
A 1989 remedial action addressed the concerns for direct contact with, and ~gration of
contaminants from, "the .carbon-waste pile by excavating the carbon waste pile and
incinerating the waste offsite. This second remedial action addresses the remaining
principal threats at the site by treating the onsite waste and contaminated soil. A
.subsequent remedial action will address possible remediation of contaminated ground
water and offiete soil, sediment and surface water contamination. The primary
contaminants of concern affecting the soil, debris and lagoon water are VOCs includdng
PCE and TCE; other organics including PCBs; and metals. including lead. .
The selected remedial action for this site includes excavation and onsite incineration
of approximately 32,000 cubic yards of flu! waste, fo~loved by stabilization of
lead-contaminated ash and offsite disposal of residual ash; ezcavation and onsite
incineration of approximately 13,000 cubic yaDds of contaminated soil, followed by
onsite stabilization, as necessary, before offsite disposal; backfilling and capping the
soil (landfill closure) under the fluff waste piles; covering the soil not under the
fluff piles using hybrid closure (topsoil cover and revegetation); onsite treatment of
approximately 86,000 gallons of lagoon water using carbon adsorption and metal removal,
followed by onsite discharge to surface water; and onsite incineration of approximately
40 cubic yards of waste contained in tanks and drums, followed by stabilization of the
ash and offsite disposal; and ground water monitoring. The estimated present worth cost
for this remedial action is $35,950,000, which includes an estimated annual O&M cost of
$39,000 and an additional estimated $20,000 every 5 years.
PERFORMANCE STANDARDS OR GOALS: Action levels have been established for soil/waste
,based on a 10-6 cancer risk level or an HI of 1.0, where technically feasible. If soil
cannot be feasibly cleaned to the 10-6 risk level (e.g., excessive volume of
contaminated soil in one particular area onsite), cleanup will reduce the additional
incremental risk to the ground water to 10-4 levels or to MCLs, whichever are more
stringent. Chemical- specific cleanup levels for soil, fluff waste, and drummed and
tanked wastes were provided for eight indicator contaminants including PCE, TCE, PCB,
and lead.

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RECOnD OF DECISION
.
DECLARATION
Site Name and Location
M.W. Manufacturing Superfund site
Danville, Pennsylvania
Statement of Basis and Pu~ose

This decision document presents the selected remedial action
for the H.W. Manufacturing Superfund site in Danville,
Pennsylvania, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended, 42 USC 9601, et sea and is consistent, to
the extent practicable, with the National Oil and Hazardous
Substances contingency Plan (NCP), 40 C.F.R. Part 300. This
decision is based upon the contents of the Administrative Record
for the M.W. Manufacturing site. .
The Commonwealth of Pennsylvania concurs with selected
remedy. A copy of their letter of concurrence is attached.

Assessment of site
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present a current or potential threat
to public health, welfare or the environment.
Descriotion of the Selected Remedv

This operable unit is the second operable unit for the site.
The first operable unit involved removal of the carbon waste
pile. This action addresses the principal threats at the site by
treating the onsite waste and contaminated soils. Treatment
residuals will be disposed of offsite.
The major components of the selected remedy are:
o
Onsite incineration of fluff waste: stabilization of
ash and disposal in an offsite RCRA landfill.
o
Onsite incineration of the contaminated soils for
organics removal, stabilization of the metals where
necessary and disposal in anoffsiteRCRA landfill.

Onsite treatment of the lagoon water for organics
treatment and metals removal and discharge in
accordance with Federal NPDES and Pennsylvania
requirements.
o
o
Onsite incineration of the contents of tanks and drums;

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'"
stabilization of the ash and disposal in an offsite
RCRA landfill.
.
Covering of the soils under the fluff waste piles, once
the fluff waste has been removed, in accordance with
RCRA Subtitle . closu~e requirements.
C
A third operabie unit will involve continued study and
possible remediation of ground water contamination and offsite
contamination in the soil, surface water and sediment.

Statutorv Determinations
o
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable or relevant and appropriate to the remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility or volume as a principal element and utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable.
\
Because this remedy will result in hazardous substances
remaining onsite at levels that would not allow for unlimited use
and unrestricted exposure, the five-year review will apply to
this action.
~?~.
C-~7' Lid
Date

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DEC!SION SUMMARY
.
I.
site Location Description
The 15-acre M.W. ManufactuLing Superfund Site is located in
Montour County, Pennsylvania 2 miles north of Danville, 700 feet
west of State Route 54, and about 1/2 mile south of Interstate 80
(see Figure 1 for the site location map). The Site is located on
the Riverside USGS quadrangle map. The Pennsylvania Department
of Transportation (PennDOT) maintains a storage area immediately
north of the site. Farmlands and wooded lots are adjacent to the
Site on the west and south. Mauses Creek flows in a southerly
direction past the site on the east side of Route 54.
Mausdale, a residential area with approximately 24 homes, is
located approximately 1/4 mile southeast of the Site, and
Danville (estimated population 5,200) is located 2 miles south.
At the intersection of Routes 54 and 1-80, there are a number of
private residences, three motels, three gas stations, and several
restaurants. These properties, as well as a Head Start School
located just north of the PennDOT storage area, rely upon private'l
ground water wells for drinking water supplies.
A september 6, 1984, an EPA evaluation of this site
determined a Hazardous Ranking System (HRS) score of 46.44
(overall) based on 79.59 ground water score and a 10.91 surface
water score. The site was placed on the National Priorities List
(NPL) on October 1, 1984.
II.
site Historv
. The site is at present relatively inactive, in part due to
legal actions of the Pennsylvania Department of Environmental
Resources (PADER). PADER records indicate that Mr. Allan Levin
of Doylestown, Pennsylvania, proprietor of M.W. Manufacturing
corporation, owned the property from about 1966 to 1972. M.W.
Manufacturing was engaged in secondary copper recovery from scrap
wire, using both mechanical and chemical processes until it
ceased operations. In 1972, M.W. Manufacturing filed for
protection under Chapter 11 of Bankruptcy Laws, and the
Philadelphia National Bank acquired the property.

Warehouse 81 Inc. acquired the site in 1976. Subsequently,
Warehouse 81, Inc. and Domino Salvage, Inc. formed a limited
partnership to recover wire at the Site. Records indicate that
the only activities conducted by the Warehouse 81/Domino Salvage
partnership were mechanical recovery operations. While the
mechanical process generated the largest waste piles (the fluff
material),.the chemical process used by M.W. Manufacturing.
generated the largest potential for environmental impact (the
carbon waste material, the lagoons, and the contaminated soil)
(see Figure 2). .

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 OUADDANGU LOCATION £

 0          2000
        SCALE IN FEET
BASE MAP IS A PORTION OF THE U.S.G.S. RIVERSIDE. PA QUADRANGLE (75 MMUTE SERIES. 1969. PHOTOREVISED 1975) AND
THE DANVILLE, PA QUADRANGLE (7.5 MINUTE SERIES, 1969, PHOTOREVISED 1977). CONTOUR INTERVAL 20 FEET.


                                                                     FIGURE I
                      LOCATION MAP
     MW MANUFACTURING SITE.  MONTOUR CO..PA

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2
The chemical process involved the use of a hot oil bath to
melt the plastic insulation away from the metal in the scrap
wire. The high temperatures decomposed the PVC plastic into
carbon, which separated as a granular black material, and also
enhanced the dissolution of lead, zinc, and copper (lead-zinc
solder coating on copper wire) from the metal wire. Chlorinated
solvents trichloroethene (TCE) or tetrachloroethene (PCE) were
then used to rem~/e the residual oil from the separated copper.
These inorganic and organic contaminants have been identified
throughout the Site. .

The fluff waste produced by the mechanical stripping process
consists of fibrous insulation material mixed with bits of
plastic. Phthalate esters, copper, lead and chlorinated solvents
are all present in this material. It appears that the solvents
were introduced into the ~luff waste when Warehouse 8~ Inc. used
contaminated ground water in their fluff recovery operations as
no solvents were used during the original mechanical stripping
operations.
,
A Potentially Responsible Party search was conducted for
this Site, but little information was obtained. The previous
owners and operators of the Site have gone out of business and
records of generators, transporters and Site operations are not
available. .
The current owners of the Site, Michael G. Sabia and Michael
G. Sabia, Jr., doing business as Warehouse 81 Limited
Partnership, were Noticed for the RI/FS but elected not to
participate. A Special Notice Letter for the RD/RA for operable
unit 1 was sent to Warehouse 81 on March 6, 1989. Warehouse 81
again refused to participate.
III. Communitv Relations Historv
Most of the residents who were interviewed in the Danville
and Valley Township areas said that they first became aware of
the problem at the M.W. Manufacturing site in March 1986. At
that time, EPA discovered lead contamination in a well serving a
Head Start school near the Site. EPA noted the discovery in a
news release which was carried in the local papers. In addition,
EPA hosted a public meeting on March 11, 1986, to discuss the
water situation with officials and parents. Approximately 50
people attended the meeting. EPA supplied the school with
bottled water until later samples revealed safe levels of lead in
the well water. The original levels have never been observed
since then and EPA believes that any lead in the original sample
may have been from lead solder in the plumbing. All later
samples, taken after the water had been run for a few minutes to
flush the lines, have not shown any lead. Present interest in
the site is limited to local officials and a few residents living
on, or in proximity to it. Local restaurants and motels near the

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                               man CAIWOM wu

                         FLUFF PILES
                                                LEGEND
                                              SURFACE (MUMS
                                              FOtCNTIAL BORIEO DRUMS
                                              auftieo omws
                                                                                                             o

                                                                                                           D
D
      GENERAL  SITE ARRANGEMENT
MW MANUFACTURING SITE. MONTOUR CO..  '
                                                                                                       FIGURE  2

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3
site have installed elaborate water purification systems and
regularly test their water supply for a wide variety of
undesirable substances. The existence of these safeguards prior
.to. the discovery that M.W. Manufacturing had contaminated the
local ground water contributed to reducing fear and concern about
the site. on the part of local hotel and restaurant owners and
employees who comprise a large segment of the local business
community.
The Proposed Plan for the carbon pile remedial action was
placed in the designated information repository (the Thomas
Beaver Library, Danville, pa.) on February 24, 1989.
Concurrently, a public comment period was announced in a
newspaper advertisement which ran until March 27,1989. A public
meeting was held on February 28, 1989, to present the proposed
plan and preferred alternative for remediating the carbon waste
pile. Approximately twenty citizens attended as well as local
township and county officials and the media. A ROD for the
carbon waste pile was signed on March 30, 1989.
The Remedial Investigation, Feasibility study and Proposed
Plan for this operable unit were placed in the repository on
February 19, 1990. A public comment period was announced in a
newspaper advertisement on February 24 and 25, 1990. A public
meeting was held on February 27, 1990, to present the proposed
plan and preferred alternative for remediating onsite wastes and
soils. One private citizen attended, as well as local township
and county officials and the media. Response to public comment
can be found in the responsiveness summary at the end of this
document.
\
IV. SCODe and Role of this ODerable Unit

The remedial field investigation revealed widespread organic
and inorganic contamination throughout the Site. The principal
threats at the site were dealt with in two operable units.
On March 31, 1989, EPA selected a remedy for the first
operable unit, the carbon waste pile, a well-defined contaminant
source, unique from other areas in size, composition, and
contaminant concentrations. The selected remedy was offsite
incineration.
The second operable unit, the remedy of which is the subject
of this ROD, is being implemented to protect public health and
the environment by preventing direct contact with contaminated
waste and reducing further migration of contaminants into the
ground water. This operable unit addresses the following areas:
four wire-fluff waste piles, a surface impoundment, a buried
lagoon, contaminated soils, drums and storage tanks.

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4
EPA and-DER believe that direct contact with the
contaminated waste and migration of contaminants into the ground
water are the major concerns posed by this site. This operable
unit was initiated to deal with these concerns. It is fully
consistent with all future site-work and is consistent with
section 300.(30(a) (1) of the National Contingency Plan (NCP).
v.
SummarY of site Characteristics
Fluff Waste (32.000 C.Y.)

Four main fluff piles extend across the northern' portion of
the Site. (see Figure 3) In addition, a small quantity
(approximately 300 C.Y.) of fluff material is present inside
of the formerMW Manufacturing facility. The major fluff
waste contaminants include tetrachloroethene, PCBs, lead,
and percent levels of copper and bis(2-ethyhexyl)phthalate.
Based on the results obtained from the RI, there appears to
be no burial of the fluff waste at the Site.
Surface Soil (2000 C.Y.)
The surface soil samples collected near the waste piles were
generally more contaminated than those elsewhere on the
Site. Surface soils were contaminated with
tetrachloroethene, bis(2-ethylhexyl) phthalate, copper, and
lead. The presence of this contamination may be indicative
of some onsite erosion of the waste piles or intentional
movement of the wastes by Site owners. -

Subsurface Soil (Includina Buried Laaoon)
(Aooroximatelv 11.000 C.Y.).
Subsurface soil contaminants were typically the same as the
surface soils. Although subsurface soil samples near the
waste piles generally contained the highest levels of
contamination, other "hot spots" were located throughout the
Site. These may be related to previous solvent spillage,
leakage from tanks or drums, or disposal of small amounts of
waste materials. One soil boring (apparently through a
buried lagoon) had high concentrations of tetrachloroethene
throughout the soil column. .
Surface Laaoon (86.000 aallons)

The water in the onsite lagoon was sampled and found to
contain low levels of organic compounds, whereas the major
contaminants in the sediment were bis(2-ethylhexyl)phthalate
and lead. -

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                                                         	)
                                                         FLUFF PILE
                                                            *M
                                                         VOLUME =
                                                         4.6OO C Y
                                                  FLUFF PILE* 7
                                                  VOLUME'9OCY.
                                                               LEGEND
                                                    |    1   FLUFF PILES

                                                            FLUFF AREA 1 - 4.JFT. AVERAGE THICKNESS

                                                            FLUFF AREA 2- I OFT AVERAGE THICKNESS

                                                            FORMER CARBON PILE
                                    o

                                  a
                                                                                                                     FIGURE   3
           FLUFF WASTE AREAS
MW MANUFACTURING SITE. MONTOUR CO., PA
SCALE IN FCET
                            GORPORAnON

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5
Drums and Tanks (40 C.Y.)
Solid wastes in drums and liquid wastes in two storage tanks
were found to contain volatile organics, phthalates, lead
and copper. The results of the geophysical investigation
indicate that there are a small number of buried drums on
the site. .
VI. Summary of site Risks

utilizing data generated during the RI, a Risk Assessment
was conducted to evaluate the potential impact to human health
which may result from the Site. Potential impact to the
environment will be considered in the next operable unit.
Risks to Human Health
In order to assess public health risks, three major aspects
of chemical contamination and environmental fate and transport
must be considered: (1) contaminants with toxic characteristics i
must be present, and must be released by either natural processes
or human action: (2) an actual or potential exposure pathway must
be present: and, (3) human receptors must be present. Risk is a
function of both toxicity and exposure: without anyone of the
above factors, t~are will be no risk. This risk assessment
estimates the potential for human health risks at the Site by
combining information on the toxicity of the chemicals found
onsite with site-specific estimates of exposures.
Toxicitv Assessment
Table 1 summarizes the chemical analytical results for the
samples collected at the Site. Table 2 lists the compounds that
were chosen as indicator chemicals. Those compounds not chosen
were omitted primarily because of their less frequent occurrence
or lower concentration.
The available toxicological information indicates that many
of the indicator chemicals have both noncarcinogenic and
carcinogenic health effects in humans and/or in experimental
animals. Although the indicator chemicals may cause adverse
health and environmental impacts, dose-response relationships and
the potential for exposure must be evaluated before the risks to
receptors can be determined. Dose-response relationships
correlate the magnitude of the dose with the probability of toxic
effects. .
. Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially' carcinogenic
chemicals. CPFs, expressed in units of (mg/kg-day)-', are
multiplied by the estimated intake of a potential carcinogen, in

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6
mg/kg-day, tS provide an upper-bound esti~ate of-the excess
lifetime cancer risk associated with exposure at that intake
. level. The term "upper bound" reflects the conservative estimate
of the risks. calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.

Reference doses (RfDs) have been developed by EPA to
indicate the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs,
expressed units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of chemical ingested from contaminated drinking water)
can be compared to the RfD. RfDs are derived fro~ human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animali
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
. An important component of the risk assessment process is the
relationship between the dose of a compound (amount to which an
individual or population is exposed) and the potential for
adverse health effects resulting from exposure to that dose.
Dose-response relationship provide a means by which potential
public health impacts may be evaluated. The published
information on doses and responses is used in conjunction with
information on the nature and magnitude of human exposure in
order to develop an estimate of health risks.
Values of available regulatory standards, reference doses,
and carcinogenic potency factors are presented in Table 3. Table
3 presents values both for chemicals that are known or suspected
human carcinogens and for chemicals having noncarcinogenic
effects. All available toxicity information is included in this
table. Expected doses of the indicator chemicals are presented
later in this section.
Risk Characterization

Three actual exposure routes have been identified for
contact with the contaminants onsite. The first is the routine
contact with the soils and waste materials (fluff) by the onsite
r~sidents, that consists of dermal contact with the soils and
wastes, accidental ingestion of contaminated dusts, and
inhalation of indoor and outdoor dust. The second is inhalation
of volatilized contaminants from the soils and wastes for the
Site residents. The third is household use of ground water.

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7
carcinogenic risks can be estimated by combining information
in the dose-response assessment (carcinogenic potency factors)
with an estimate of the individual intakes (doses) of a
contaminant by a receptor. These risks are expressed as numbers
of excess cancer deaths expected to occur in an exposed
population. Excess lifetime cancer risks are determined by
multiplying the intake level by the cancer potency factor. These
risks are probabilities that are generally expressed in
scientific notation (e.g., lxlO.6 or 1E-G). An excess lifetime
cancer risk of lxlO.6 indicates that, as a plausible upper bound,
an individual has a one in one million chance of developing
cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at a
site.
EPA policy requires that Superfund sites be cleaned so that
this excess risk falls between 1 per 10,000 and 1 per 1,000,000
(normally stated as 1XIO-t. and 1XIO.6) depending on site
conditions, feasibility of cleanup, costs, expected future use
and other factors. Barring any mitigation from any of these
factors, EPA's normal cleanup goal is 1 per 1,000,000 (1X10.6)
excess cancer risk. .
Table 4 presents a summary of the potential carcinogenic
risks resulting from the exposure routes. This total potential
risk is the mathematical summation of the individual risks posed
by the chemicals identified in Table 4. The risk is primarily
due to the accidental ingestion of and dermal contact with
1, 1, 2, 2-tetrachloroethane, 1,1,2-trichlorothane,
tetrachloroethene, bis(2-ethylhexyl)-phthalate, PCBs and dioxins.
The PCBs and dioxins are present at action levels and .
concentrations below their respective action levels, but their
high CPF results in high risks. The other major contributors to
risk via these exposure routes are trichloroethene and methylene
chloride.
I
I
I
The risks associated with regular, daily inhalation of
contaminants volatilizing from the site are several orders of
magnitude lower than those estimated for physical contact with
the wastes or soils. However, the risks for both site employees
and residents exceed 1X10.6, using the average waste
concentrations and exposure durations of 8 and 24 hours/day,
respectively. The primary contributors to this risk are 1,1,2-
trichloroethane, tetrachloroethene, and methylene chloride.
other carcinogens contributing to the total risk are
trichloroethene and 1,1,2-trichloroethane. The total potential
carcinogenic risks resulting from accidental dermal contact or
ingestion by site employees or trespassers are lower than those
resulting from the other exposure routes. For example, the
potential risk from dermal contact with the fluff waste by
employees is 2.2X10-6 at the average contaminant concentrations~
and accidental ingestion results in a potential risk of 9.7xlO .

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8
.
The risks due to household use of ground water posed by
conta1\\ination leaching from the wastes and soils is 9. ~ X 10-5
for site residents.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. If the Hazard Index exceeds unity (~.O) there is a
potential for noncarcinogenic health risks. The Hazard Index is
not a mathematical prediction of the severity of toxic effects,
but is simply a numerical indicator of the transition from
acceptable to unacceptable levels. Table 4 also lists the total.
Hazard Indices resulting from exposures to the site
contamination.
Accidental ingestion, inhalation and dermal contact with the;
fluff waste on a routine basis by an adult will result in a
potential total Hazard Index of 104 using average contaminant
concentrations. Lead is the most significant hazard under
this exposure scenario, along with copper, antimony, and bis(2-
ethylhexyl) phthalate. Household use of contaminated ground water
will result in a Hazard Index of 0.86 for the average
concentrations of contamination, but 2.4 based on the maximums.
The other exposure routes examined for the Site do not present a
significant noncarcinogenic health risk. The carcinogenic risks
resulting from physical contact with the contaminants at the site
exceed the range generally considered to be acceptable, that is,
between lXlO-4 and 1X10-7. The carcinogenic risks associated with
the regular inhalation of contaminants volatilizing from the
carbon waste pile fall just outside the upper end of the
"acceptable" range. These results indicate the need for remedial
action at the site.
..
Based on the results of this risk assessment, it is
necessary to propose remedial actions for the fluff waste and
soils in order to reduce the incremental cancer risk level and to
avoid the occurrence of noncarcinogenic health effects. The Site
presents a high carcinogenic and noncarcinogenic risk to site
residents and employees under several of the proposed exposure
scenarios.
The potential risks resulting from the routine dermal
contact, inhalation, and ingestion exposures were the highest of
all exposure routes examined. Therefore, this exposure ro~te was
selected for the determination of action levels.

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9
. .
Two sets of act~on levels were developed. One total
carcinogenic risk goal was set at lxlO-4 and the other was set at
1XIO-6. Action levels for noncarcinogens were set to meet a .
total Hazard Index of unity (1.0), and, therefore, only one
action level is needed for each noncarcinogenic indicator
compound. .

Remedial action levels based on risk assessment are shown in
Table 5 for risk to residents and nonresidents (associated with
the soils/wastes), respectively. Of the contaminants present in
the various media, certain organic and inorganic contaminants are
identified that are present in each media and in much greater
concentrations than the other contaminants and/or present the
greatest risk to human health and the environment. Remediation
of these primary contaminants to their respective remedial action
cleanup levels should also sufficiently treat the other organic
and inorganic contaminants that are present in the media at much
lower concentrations, since the secondary contaminants have
properties similar to the primary contaminants.
The surface soil and fluff waste action levels protect
against routine contact with the contamination, while the
subsurface action levels are set to reduce the future impact to
ground water. When it was determined that several of the 10"
subsurface risk levels would not be protective of the MCLs,
action levels were determined for those compounds to reduce the
impact to the ground water to the MCL levels. These levels also
appear in Table 5. .

Based on the above analysis, EPA believes that actual or
threatened releases of hazardous substances from this Site, if
not addressed by implementing the response action selected in
this ROD, may represent an imminent and substantial endangerment
to public health, welfare or the environment.
VII.
Alternative Analvsis
Each of the following alternatives, with the exception of
alternative 1, involves the placement of RCRA hazardous wastes.
During the Remedial Investigation/Feasibility Study (RI/FS) the
Toxicity Characteristic Leaching Procedure (TCLP) was used to
determine if characteristic wastes were present, in anticipation
of an imminent change in the RCRA regulations. The regulations
promulgating the TCLP testing procedure have now been finalized. .
Table 6 lists the various contaminated media and the pretreatment
assumed to be necessary, based on the TCLP results, in order to
comply with the Land Disposal Restrictions (40 C.F.R. Part 268).

Each of the alternatives, except the No Action Alternative,
requires the excavation of the same areas and quantities of
soils. Area C soils (see Figure 4) will be excavated and
backfilled so as to reduce the risk to onsite residents from

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               FORMER WkSTE CARBON PILE



              FLUFF  PILES
                                                    11
                                                UNDERGROUND
                                                   TANK
                                                ..-    (REMOVED)
                                               ABOVE mourn TANK
                                                                                                           FIGURE  .*_
AREA C SOILS
       urr
ML  3

-------
V
\
 \
                                         man CMMMH
                                   FLUFF HLCS
                        AREA AB SOILS
           MW MANUFACTURING SITE. MONTOUR CO.. PA
                                                                                                  200
                                                                                                              FIGURE
                                                                                                            JOFFCJRAnON

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10
routine contact to the 10-6 levels preferred by EPA. However,
EPA believes that there is no feasible technology that can clean
Area A/B subsurface soils (see Figure 5) so that the additional
incremental risk posed by drink~ng ground water contaminated by
leachate from those soils is less than or equal to the 10-6 risk
level (equivalent, for example, to 3.8 ppb of TCE in the water).
To achieve this risk level, over 200,000 cubic yards of soil
would have to be excavated and subsequently treated and/or
disposed of, making none of the alternatives feasible. EPA has
reviewed only those alternatives that reduce the additional
incremental risk to the ground water to 10-~ levels or to MCLs
whichever are more protective.
Alternatives 1 trough 6 would leave contamination onsite at
levels that would not allow for unlimited use or unrestricted
exposure and, therefore, 5-year reviews pursuant to section
121(c) of CERCLA would be required for each.

ALTERNATIVE 1 - No Action
,
. Fluff Waste: No Action
. Tanks and Drums: No Action
. Soils: No Action.
. Lagoon Water: No Action
This alternative is considered to provide a baseline against
which the other remedial alternatives can be compared. This
alternative involves taking no action at the MW Manufacturing
Site to remove, remediate, or contain the contaminated
soils/wastes or lagoon water.
. Periodic ground water monitoring of residential wells and
onsite monitoring wells would be conducted to prevent contact
with contaminated ground water. Four existing onsite wells and
three residential wells (the closest downgradient residences),
would be periodically sampled. The required sampling frequency
of these wells, that could range from quarterly to annually, is
dependent on the extent of ground water contamination.

For costing purposes, a quarterly sampling period will be
used for all wells.
Cost
The present-worth cost estimate for this alternative is
$532,000.
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements (ARARs)

with respect to action-specific ARARs, this alternative does
not comply with any of the RCRA closure options (clean closure or
landfill closure) that are applicable or relevant and appropriate

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11
for CERCLA remedial actions (40 C.F.R. ~~ 264.111 or 264.258)

ALTERNATIVE 2 - Onsite DisDosal of Fluff Waste in RCRA Hazardous
Waste Landfill. Onsite PhvsicaL'Chemical Treatment of Soils with
Onsite Landfill DisDosal. CaD Closure Over RCRA units
This alternative involves containment of the fluff waste
material and soils above the 10.' risk subsurface soil action
levels in an onsite hazardous waste landfill; incinerating the
contents of the tanks/drums in an offsite incinerator facility;
and treating the lagoon water onsite using a carbon adsorption
unit and then discharging the treated water in accordance with
NPDES requirements.

Tanks and Drums: Approximately 40 cubic yards of material
would be removed from the tanks and drum shipments and hauled in
bulk shipments to a RCRA-approved incinerator. The remaining
empty drums and tanks would be transported to a RCRA-approved
hazardous waste landfill. The incinerator ash would be disposed
in a RCRA-apprbved hazardous waste landfill.
.,
Lagoon Water: Approximately 86,000 gallons of lagoon water
would be pumped through a 55-gallon carbon adsorption unit (after
any necessary pretreatment) and then discharged in accordance
with NPDES requirements. The spent carbon unit would be either
incinerated or disposed in a RCRA-approved hazardous waste
landfill. .
Fluff Waste (32,000 C.Y.): This alternative assumes that
the fluff material would require pretreatment for metals only
(primarily lead) to meet the LDR requirements before disposal.
The LDR treatment levels for RCRA characteristic wastes were not
promulgated during the FS and, therefore, the EP toxicity levels
were used as a basis for the pretreatment assumption. This.
alternative includes the cost of using a cement/pozzolan-based
stabilization technology to meet the LDR requirements.
. Soil Area A/B (7,000 C.Y.) and Area C (6,000 C.Y.): Under
this alternative, the soils would be excavated, treated on site
and disposed of in an on site landfill. Testing is required to
determine which treatability treatment option is most suitable to
the MW Manufacturing site solvent contamination.
. .
Placement of soil into the onsite hazardous waste landfill
will invoke the LDR restrictions. It is assumed that Area A/B
soils would require pretreatment for metals (primarily lead) and
solvents (primarily PCE) to meet the LDR requirements before
disposal, but that Area C soils would require treatment for
solvents only. The same stabilization technology used to .
stabilize the metals in the fluff material would most likely be
used for the soils. The soils would require treatment of the
solvents to the BDAT-based treatment levels prior to placement in

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12
the landfill~ If the BDAT-based levels could not be achieved, a
Treatment Variance would be issued based on the existing
treatment guidelines.
Though the possibility exists that treatment of the soils
may render some or all of them non-hazardous and, therefore, able
to be disposed of in a non-hazarous waste landfill, for costing
purposes, it will be assumed that all excavated soils will be
placed in the onsite landfill after treatment.

The lagoon and any excavated areas would be backfilled with
clean soil. For the soils surrounding the landfill and not
contained under the fluff piles, a hybrid closure would be used
that would consist of placement of a layer of topsoil
(approximately 6 inches) followed by revegetation.
since the fluff piles are considered to be a RCRA unit, the
soil under the piles must be managed according to the RCRA
closure requirements (40 C.F.R. Part 264.258). A clean closure
cannot be achieved for the RCRA unit for the following two
reasons: (1) the physical/chemical treatment processes cannot
decontaminate the soils to the remedial action levels for surface
soils for residents, that are necessary for the "edible soils"
criterion to be met; and (2) residual contamination, outside of
the "hot spot" areas, will remain in the subsoils under the fluff
material at the end of remediation. For these reasons, in order
to comply with RCRA closure requirements, the soils under the
fluff material must be covered with a cap of equal or lower
permeability than that of the subsoils (landfill closure). For
costing purposes, a synthetic cap, similar to the landfill cap,
will be assumed.
\
COST
The treatment costs of the various physical/chemical process
options used for removal of the solvents and other organics range
from approximately $65/C.Y. to $230/C.Y. of soil~ As the
treatment costs are very matrix-dependent, treatability testing.
is needed to further refine the cost estimates among the various
physical/chemical process options. The approximate median
treatment cost of $150/C.Y. was used in the cost estimate. The
present-worth cost estimate for this alternative, including the
cost of installing a RCRA-approved synthetic cap over the soil
that lies beneath the remediated fluff piles, is $16,843,000.

ComDliance with ARARs
The landfill must be constructed to the minimum technology
requirements of RCRA (40 C.F.R. II 264.301 and 264.303) and
Pennsylvania closure requirements (25 PA Code 175.264(v».

The subsoils under the fluff waste piles must be closed

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13
according to.RCRA closure requirements (40 C.F.R~264.258)and 25
PA Code SS75.264(o) and 75.264(t).
The surface impoundment muat be closed according to RCRA
closure requirements (40 C.F.R S264.258) and 25 PA Code
SS75.264(o) and 75.264(s).

OSHA standards (29 C.F.R. li1910.120(b)-(0» will be
followed during all site work.
This action will cause no violation of HAAQS due to fugitive
dust generated during construction activities (Clean Air Act, 40
C.F.R. 150.6 and 40 C.F.R. 152.21(j).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally 'approved State Implementation Plan for the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, SS
52.2020 - 52.2023).
\
Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. SS122.41-122.50), the
Pennsylvania NPDES regulations (25 PA Code S92.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code SS95.1
-95.3).
"Placement" of the wastes will invoke the RCRA Land Disposal
Restrictions. This alternative will comply with 40 C.F.R. Part
268.
Transportation of material to a RCRA permitted hazardous
waste landfill or incinerator will be done in compliance with
Federal regulations applicable to generators and transporters of
hazardous wastes (40 C.F.R. Part 262 and 40 C.F.R. Part 263) as
well as with Pennsylvania regulations (25 PA Code S75.263).

Onsite treatment will comply with RCRA regulations and
standards for owners and operators of hazardous waste treatment,
storage, and disposal facilities 40 C.F.R. SS 264.170 -
264.178(containers), IS 264.190 - 264.200 (tanks), SS 264.220 -
264.249 (surface impoundments) and II 264.250 -264.259 (waste
piles).
ALTERNATIVE 3 - Offsite DisDosal of Fluff Waste in RCRA Hazardous
Waste Landfill. Onsite Physical/Chemical Treatment of Soils with
Offsite Landfill DisDosal. Cap Closure OVer RCRA Units

. This alternative involves disposing the fluff waste material
and soils, contaminated above the 10.4 risk subsurface soil
action levels in an offsite, RCRA-approved, hazardous waste
landfill; incinerating the contents of the tanks/drum in an
offsite incinerator facility; and treating the lagoon water using

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14
an onsite carbon adsorption unit and then discharging the treated
water in accordance with NPDES requirements. This alternative is
similar to Alternative 2 except the fluff waste and any excavated
soil would be disposed in an offsite landfill rather than an
onsite landfill.
COST
The present-worth cost estimate for this alternative,
including the cost of installing a RCRA-approved synthetic cap
over the soil that lies beneath the fluff piles, is $32,186,000.
compliance with ARARs

The subsoils under the fluff waste piles must be closed
according to RCRA closure requirements (40 C.F.R ~264.258)and 25
PA Code ~~75.264(o) and 75.264(t).
The surface impoundment must be closed according to RCRA
closure requirements (40 C.F.R j264.258) and 25 PA Code
~~75.264(o) and 75.264(s).

. OSHA standards (29 C.F.R. ~~1910.120(b)-(o» will be
followed during all site work.
\
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities'(Clean Air Act, 40
C.F.R. ~50.6 and 40 C.F.R. ~52.21(j), National Ambient Air
Quality Standards).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the.
Federally approved State Implementation Plan for the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, II
52.2020 - 52.2023, State Implementation Plans for National
Ambient Air Quality Standards).

Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R., 122 1~122.41-122.50),
the Pennsylvania NPDES regulations (25 PA Code 192.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code 1195.1
-95.3).
"Placement" of the wastes will invoke the RCRA Land Disposal
Restrictions. This alternative will comply with 40 C.F.R. Part .
268.
. Transportation of material to a RCRA permitted hazardous
waste landfill or incinerator will be done in compliance with
Federal regulations applicable to generators and transporters of
hazardous wastes (40 C.F.R. Part 262 and 40 C.F.R. Part 263 as
well as with Pennsylvania regulations (25 PA Code 175.263).

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15
.
Onsite treatment will comply with RCRA regulations and
standards for owners and operators ot hazardous waste treatment,
storage, and disposal facilities 40 C.F.R. SS 264.170 -
264.178(containers), SS 264.190 - 264.200 (tanks), SS 264.220 -
264.249 (surface impoundments) and SS 264.250 -264.259 (waste
piles). .
ALTERNATIVE 4 - Onsite Incineration. CaD Closure
Over RCRA Units

This alternative involves incinerating the fluff waste
material and soils, contaminated above the 10'4 risk subsurface
soil action levels, in an onsite rotary kiln incinerator:
incinerating the contents of the tanks/drums in an onsite rotary
kiln incinerator: and treating the lagoon water in an onsite
carbon adsorption unit and then discharging to Mauses Creek.
Tanks and Drums: Approximately 40 cubic yards of material
would be removed from the tanks and drums and hauled in bulk
shipments to a RCRA approved incinerator. The remaining empty
drums and tanks would be crushed and/or dismantled and then
transported to a RCRA-approved hazardous waste landfill.

. The incinerator ash generated from the tank/drum wastes
w~uld most likely still be classified as a hazardous waste (due
to EP toxicity characteristic for lead) and would therefore be
disposed of in an offsite RCRA-approved hazardous waste landfill.
Lagoon Water: Approximately 86,000 gallons of lagoon water
would be pumped through a 55-gallon carbon adsorption unit (after
any necessary pretreatment) and then discharged in accordance
with NPDES requirements.

Fluff Waste: The ash content of the fluff waste is
approximately 12 percent and therefore an estimated 6,700 tons of
ash would be generated from incineration of the fluff material.
Due to the high lead concentration in the fluff waste, the ash
would most likely exhibit the EP toxicity characteristic for
lead. To comply with the LOR requirements the ash would require
stabilization of the lead. For costing purposes, it is assumed
that the ash would be stabilized onsite using a cement/pozzolan- -
based process and then transported to a RCRA-permitted hazardous
waste landfill. .
S011s: Assuming that the ash content of the soils is 80
percent by weight, an estimated 15,800 tons of soils would
remain after incineration. The incineration process would reduce
the organic contaminant levels to the surface soil action levels.
The incineration may also volatilize the lead in area A/B soils
to its surface soil remedial action level (500 mg/kg), or to the
point that the soil does not need treatment to comply with-RCRA

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16
LDR standards, although this cannot be determined at this time.
It is assumed that 8500 tons of area A/B soil will need to be
stabilized and disposed of in an offsite RCRA Subtitle C
landfill. An estimated 7300 tOBS of area C soils will not need
further treatment before disposal in the Subtitle C facility.

Following incineration of the soils and fluff waste,
excavated areas would be backfilled with clean soil. For the
-soils not contained under the fluff piles, a hybrid closure,
consisting of placement of a layer of topsoil (approximately 6
inches) followed by revegetation, would be used.
Since the fluff piles are considered to be a RCRA unit, the
soil under the piles must be managed according to the RCRA
closure requirements (40 C.P.R. S264.258). A clean closure
cannot be achieved for the RCRA unit, because residual
contamination outside of the "hot spot" areas will remain in the
subsoils under the fluff material after remediation. For this
reason, to comply with RCRA closure requirements, the soils under
the fluff material must be covered with a cap of equal or lower
permeability than that of the subsoils (landfill closure). For
costing purposes, a synthetic cap will be assumed.
Cost
The present-worth cost estimate for this alternative,
including the cost of installing a RCRA-approved synthetic cap
over the soil that lies beneath the remediated fluff piles, is
$35,950,000.
ComDliance with ARARs
The subsoils under the fluff waste piles must be closed
according to RCRA closure requirements (40 C.F.R 1264.258)and 25
PA Code IS75.264(o) and 75.264(t).
The surface impoundment must be closed. according to RCRA
closure requirements (40 C.F.R 1264.258) and 25 .PA Code
1175.264(0) and 75.264(s).

OSHA standards (29 C.F.R. IS1910.120(b) - (0» will be
followed during all site work.
This alternative will comply with the RCRA incinerator
regulations (40 C.F.R. 11264.340 - 264.999) and the pennsylvania
regulations for hazardous waste incineration (25 PA Code
175.264 (w».
Any residual ash considered a hazardous waste under 40
C.F.R. 1261.3 will comply with 40 C.F.R. SS 264.1 - 264.50 and 25
PA Code 175.264(v) which requirements regulate the land disposal

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.
17
of hazardous.wastes.
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air Act, 40
C.F.R. jSO.6 and 40 C.P.R. JS2.21(j).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved State Implementation Plan for the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, II
52.2020 - 52.2023). . .
Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. 11122.41-122.50), the
Pennsylvania NPDES requlations (25 PA Code 192.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code 1195.1
-95.3).
ALTERNATIYE 5 - Offsite Incineration
Ca
Closure Over RCRA Uni s
This alternative involves incinerating the fluff waste
material and those soils contaminated above the 10-4 risk
subsurface soil action levels, in an offsite rotary kiln
incinerator; incinerating the contents of the tanks/drums in an
offsite rotary kiln incinerator; and treating the lagoon water in
an onsite carbon adsorption unit and then discharging the treated
water to Mauses Creek.
Tanks and Drums: As described in the previous alternatives,
approximately 40 cubic yards of material would be removed from
the tanks and. drums, loaded onto trucks, and hauled in bulk
shipments to a RCRA-approved incinerator. The incinerator ash
generated from the tank/drum wastes would be disposed in a RCRA-
approved hazardous waste landfill.

Lagoon Water: As described in the previous alternatives,
approximately 86,000 gallons of lagoon water would be pumped
through a 55-qallon carbon adsorption unit (after any necessary
pretreatment) and then discharged in accordance with NPDES
requirements.
Fluff Waste (32,000 C.Y.): The ash content of the fluff
waste is approximately 12 percent and therefore an estimated
6,700 tons of ash would be generated from incineration of the
fluff material. Due to the high lead concentration in the fluff
waste, the ash would most likely exhibit the EP toxicity
characteristic for lead. To comply with the LDR requirements the
ash would require stabili~ation of the lead. The additional cost
of stabilizing the ash, which would be included in the
incinerations contract, is included in the cost estimate for this
alternative. The stabilized ash would then be disPosed in an
offsite RCRA-permitted hazardous waste landfill.
-'

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18
.
. Area A/B Soil (7,000 C.Y.): For costing purposes, the ash
content of the soils is assumed to be approximately 80 percent,
by weight. An estimated 8,500 tons of treated soil would be
produced by incineration. The incineration process would reduce
the organic contaminant levels to the surface soil action levels.
Although the level of lead in the ash may be low enough that it
does not require stabilization to comply with the upcoming LOR
standards, the cost of onsite stabilization will be included in
the cost estimate. Following stabilization, the ash would be
disposed of in an offsite RCRA permitted hazardous waste
landfill.
Area C Soil (6,000 C.Y.): An estimated 7,300 tons of
treated soil would be produced by incineration. Following
incineration, the ash would be disposed in an offsite RCRA-
permitted hazardous waste landfill. Stabilization of the ash
prior to disposal would not be required. .

Following offsite incineration of the soils and fluff waste'i
any excavated areas would be backfilled with clean soil. For the
soils not contained under the fluff piles, a hybrid closure could
be used, that would consist of placement of a layer of topsoil
(approximately 6 inches) followed by revegetation.
Since the fluff piles are considered to be a RCRA unit, the
soil under the piles must be managed according to the RCRA
closure requirements (40 C.F.R. Part 264.258). A clean closure
cannot be achieved for the RCRA unit, because residual
contamination outside of the "hot spot" areas will remain in the
subsoils under the fluff material after remediation. For this
reason, to comply with RCRA closure requirements, the soils under
the fluff material must be covered with a cap of equal or lower
permeability than that of the subsoils (landfill closure). For
costing purposes, a synthetic cap will be assumed.
COST
. The present-worth cost estimate for this alternative,
including the cost of installing a RCRA-approved synthetic cap
over the soil that lies beneath the fluff piles, is $58,904,000.
ComDliance with ARARs

The subsoils under the fluff waste piles must be closed
according to RCRA closure requirements (40 C.F.R 1264.258)and 25
PA Code 1175.264(0) and 75.264(t).
The surface impoundment must be closed according to RCRA
closure requirements (40 C.F.R 1264.258) and 25 PA Code
1175.264(0) and 75.264(s).

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19
OSHA standards (29 C.F.R. ~~1910.120(b)-(0» will be
_followed during all site work.

Any residual considered a hazardous waste under 40 C.F.R.
~261.3 will comply with 40 C.F.R. ~~ 264.1 - 264.50 and 25 PA
Code S75.264{V) which requirements regulate the land disposal of
hazardous wastes. .
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air Act, 40
C.F.R. ~50.6 and 40 C.F.R. S52.21(j).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved state Implementation Plan for ,the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, SS
52.2020 - 52.2023).
Offsite transportation of the ash and other treatment
residuals will be done in compliance with Federal regulations
applicable to generators and transporters of hazardous wastes
(40 C.F.R. Part 262 and 40 C.F.R. Part 263) as well as with
Pennsylvania regulations (25 PA Code ~75.263).
Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. SS122.41-122.50), the
Pennsylvania NPDES regulations (25 PA Code ~92.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code SS95.1
- 95.3).
ALTERNATIVE 6 - Offsite Incineration of Fluff Waste. Onsite
Phvsical-Chemical Treatment of Soils with Offsite Landfill
Disposal. Cap Closure Over RCRA Units
This alternative involves incinerating the fluff waste
material in an offsite rotary kiln incinerator; treating the
soils contaminated above the 10-4 risk subsurface soil action
levels using a physical/chemical technology; incinerating the
contents of the tanks/drums in an offsite rotary kiln
incinerator; and treating the lagoon water in an onsite carbon
adsorption unit and then discharging the treated water into
Nauses Creek. This alternative is identical to Alternative 3,
Offsite Disposal, except that the fluff waste would be
incinerated offsite under this alternative rather than disposed
. in an offsite hazardous landfill.
~
Because the treatment costs are very matrix-dependent,
treatability testing is needed to further refine the cost
estimates among the various physical/chemical process options.
The approximate median treatment cost of $150/C.Y. of soil was

-------
20
used in the cost estimate.
this alternative, including
approved synthetic cap over
piles, is $41,060,000.
The present-worth cost estimate for
the cost of installing a RCRA-
the soil that lies beneath the fluff
ComDliance with ARARs

The subsoils under the fluff waste piles must be closed
according to RCRA closure requirements (40 C.F.R S264.258)and 25
PA Code 5575.264(0) and 75.264(t).
The surface impoundment must be closed according to RCRA
closure requirements (40 C.F.R 5264.258) and 25 PA Code
5575.264(0) and 75.264(s). .
Onsite treatment will comply with RCRA regulations and
standards for owners and operators of hazardous waste treatment,
storage, and disposal facilities 40 C.F.R. SS 264.170 - 264.178
(containers), 5~ 264.190 - 264.200 (tanks), ~S 264.220 -264.249
(surface impoundments) and is 264.250 -264.259 (waste piles).

OSHA standards (29 C.F.R. i51910.120(b) -(0» will be
followed during all site work.
\
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air Act, 40
C.F.R. 550.6 and 40 C.F.R. S52.21(j).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved state Implementation Plan for the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, II
52.2020 - 52.2023).
Any onsite surface water discharge will comply with the
Clean Water Act NPDES discharge regulations (40 C.F.R.11122.41-
122.50), the Pennsylvania NPDES regulations (25 PA Code 192.31),
and the Pennsylvania Wastewater Treatment Regulations (25 PA Code
1195.1 - 95.3).
"Placement" of the wastes will invoke the RCRA Land Disposal
Restrictions. This alternative will comply with 40 C.F.R. Part
268.
Transportation of material to a RCRA permitted hazardous
waste landfill or incinerator will be done in compliance with .
Federal regulations applicable to generators and transporters of
hazardous wastes (40 C.F.R. Part 262 and 40 C.F.R. Part 263 as
well as with Pennsylvania regulations (25 PA Code 175.263).

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21
.
VIII
COMPARISON AMONG ALTERNATIVES
The remedial alternatives analyzed in detail in Section VII
are compared against each other in this section.
Short-term Effectiveness
With the exception of Alternative 1, "No Action", all
remedial alternatives would provide protection of public health
from exposure to the wastes and contaminated soils in the short-
term. Alternative 1 includes only a minimal degree of protection
provided by the existing fence surrounding the site. Alternative
5, Offsite Incineration, could be implemented in the shortest
time period, approximately 8 to 10 months, followed by
Alternative 4, Onsite Incineration, in approximately 16 to 20
months. The remaining alternatives, which all include a
physical/chemical process for the soils, would take about 15-28
months to implement, once onsite activities begin including an
average 6-8 months for treatability studies. Because there would
be dust and/or volatile organics released during excavation,
treatment, and material handling activities, Alternatives 2
through 6 all would require control measures to minimize the
short-term risks to workers and the community during onsite
remedial actions.
Lona-term Effectiveness
Alternative 1, No Action, does not provide any additional
long-term protection of public health from exposure to the
soils/wastes and also does not protect the ground water from
further contamination. with respect to long-term reliability,
all alternatives involving treatment (Alternatives 2-6), are
considered reliable. Alternatives 2, 3, and 7 are intended to
treat the soils to the 10-4 risk subsurface soil action levels,
as a minimum, in order to protect the ground water. Alternatives
4 and 5, which include incineration, provide the maximum long- .
term effectiveness, as incineration would, at a minimum,
'remediate the organic contaminants to the 10-4 risk surface soil
action levels for residents. Regardless of which technology is
used to treat the soils, some residual contamination will remain
at the Site, requiring placement of some type of final cover
material (i.e., RCRA cap and/or soil cover) to eliminate the
direct contact exposure route.
With respect to the impact of the fluff waste on the MW
Manufacturing Site, Alternatives 3 through 6, which includ~
offsite incineration or offsite disposal of the fluff material,
are equally effective in the long-term, as the contaminated
material would be permanently removed from the Site. On an
overall basis, however, Alternatives 4 through 6, are more

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22
effective th~n Alternative 3, as incineration of the material
would permanently destroy the organic contaminants. Under
Alternative 3, Offsite Disposal, long-term risks associated with
the fluff material would remain at the offsite disposal facility.

.Alternative 2, Onsite Disposal, offers a slightly lower
degree of long-term effectiveness and reliability than that
provided by the other alternatives (except for Alternative 1), as
contaminated material would remain onsite and act as a potential
source of ground water contamination. The liner system and
leachate detection and collection zones, however, should serve to
adequately protect the ground water if they are constructed and
maintained properly.
Reduction of Toxicitv. Mobilitv. or Volume

Alternative 1, No Action, would not reduce the toxicity,
mobility, or volume of contamination at the MW Manufacturing
site. All of the other alternatives include treatment of the
wastes and soils, and therefore would reduce the toxicity of
these materials.
With regard to the fluff waste, Alternatives 4, 5, and 6,
which include incineration of the fluff material, would
significantly reduce the volume of the fluff by approximately 88
percent. These three alternatives would also provide the maximum
reduction of toxicity for the fluff waste by destroying the
organic contaminants in the matrix. Alternative 3, Offsite
Disposal, would not reduce the volume of fluff material, as the
incineration alternatives would, but it would reduce the volume
of contamination at the MW Manufacturing site by removing the
material from the site. Stabilization of the fluff material,
which may slightly increase the fluff volume, would reduce the
toxicity of the fluff waste by reducing the mobility of the metal
contaminants, particularly lead, in the material.
For the soils, Alternatives 4 and 5 offer the greatest
reduction in toxicity through incineration. Incineration would,
at a minimum, reduce the organic contaminants in the soils to the
10.' risk surface soil action levels for residents. Alternatives
2, 3, and 6 would, at a minimum, reduce the toxicity of the soils
to the 10.4 risk action subsurface soil action levels or to the
LDR treatment levels.
For the alternatives that include treatment, Alternative 2,
Onsite Disposal, would leave the greatest amount of contaminated
material (fluff waste and soils) permanently at the site. For
the other alternatives (except No Action), the amount of residual
contamination remaining at the site depends on how the soil is
treated and disposed. With all of the alternatives, residual
contamination, would remain in the subsurface soils located
outside of the "hot spot" areas but would be below the 10.4 risk

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23
subsurface sSil action levels.
ImDlementabilitv
The technologies proposed for all alternatives are, in
general, demonstrated and commercially available. With
Alternatives 2, 3, and 6, however, treatability studies would be
needed to determine the overall implementability and operating
conditions of the physical/chemical process options and to
determine which process is best suited to the Site. With respect
to ease of implementability, Alternative 5 would be the most
readily implementable because this alternative would not involve
mobilization, operation, and demobilization of an onsite
treatment system as included in the other alternatives that
requireonsite treatment.

With respect to administrative feasibility, the nearness of
residences and a school could cause public acceptance problems
for the onsite incinerator included in Alternative 4, as well as
for an onsite physical/chemical process in which toxic emissions
could potentially be released into the air (Alternatives 2, 3,
and 6).
Regarding interferences of alternatives with other remedial
actions at the Site, construction of the onsite landfill,
included in Alternative 2, could potentially interfere with the
installation of a pump and treatment system. Under this
alternative, ground water extraction/injection wells could not be
installed in the landfill area, which could potentially decrease
the effectiveness of any future ground water extraction system.
Under all of the alternatives (except No Action) installation of
a RCRA-approved impermeable cap over the RCRA units (fluff pile
area) may also interfere with the installation of ground water
extraction/injection wells.
Cost
The present-worth costs of the remedial alternatives are
summarized in Table' 7.
ComDliance With ARARs

For all alternatives, except Alternative 1, No Action, the
subsoils under the fluff waste piles must be closed according to
RCRA closure requirements for waste piles (40 C.F.R. 1264.258),
which requires a low-permeable cap to be installed over the
residual contamination when a clean closure is'not performed
under 40 C.F.R.1264.310, as well as 25 PA Code 1175.264(0) and
75.264(t). A clean closure cannot be performed for the MW
Manufacturing site because of the residual contamination that
will remain in the subsurface soils following remediation. For
Alternative 2 through 6, a hybrid closure using a soil cap would
be implemented for the soils not contained within the RCRA unit.

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24
For all-alternatives execpt Alternative 1, the surface
impoundment must be closed according to RCRA closure requirements
(40 C.F.R ~264.258) and 25 PA Code ~~75.264(0) and 75.264{s).
Onsite activities, involved with Alternatives 2 through 6,
must comply with OSHA standards (29 C.F.R. ~~1910.120{b)-{0» for
worker protection during remediation as well as with Clean Air
Act and Pennsylvania air emission requirements.
Alternatives 2 through 6 viII involve offsite transportation
of wastes/soils and/or treatment residuals and must comply with
.Federal (40 C.F.R. Parts 262 and 263) and state (25 PA Code
~75.263) regulations applicable to generators and transporters of
hazardous wastes as well as with Federal (49 C.F.R. 11107.171-
179) and state DOT regulations pertaining to transportation of
hazardous materials.
Alternatives 2 through 6, will involve onsite or offsite
disposal of the wastes/soils and/or treatment residuals and must
comply with the RCRA land disposal restrictions (40 C.F.R. Part
268) for hazardous wastes.
\
Alternatives 2 through 6 involve treatment, either onsite or
offsite, and must comply with RCRA regulations and standards for
owners and operators of hazardous waste treatment, storage, and
disposal facilities (40 C.F.R. Part 264). Any offsite treatment
and/~r disposal facilities used in Alternatives 2 through 6 must
all be RCRA permitted (40 C.F.R. Part 265).
Alternatives 2 through 6 may require onsite surface water
discharge of process wastewater and therefore must comply with
Federal NPDES discharge regulations (40 C.F.R. Part 122), the
Pennsylvania NPDES regulations (25 PA Code 192.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code ~95.1 -
95.3).
RCRA incinerator regulations (40 C.F.R. Part 264, Subpart 0)
as well as 25 PA Code i75.264(w) are applicable to Alternatives 4
through 6, which involve either onsite or offsite incineration.
Alternative 1, No Action, does not comply with the goal of
CERCLA/SARA to use treatment that permanently reduces the volume,
toxicity, or mobility of the contaminants at the site. All of
the other alternatives achieve this goal.

OVerall Protection
.. Alternative 1, No Action, does not provide any additional
protection of public health from exposure to the soils/wastes
other than the minimal protection offered by the existing fence.
This alternative also does not protect the ground water from
further contamination. All of the other alternatives would

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25
protect the public health from exposure risks (ingestion,
inhalation, and dermal contact) associated with the soils/wastes.
Alternatives 2 through 6 would also prevent migration of .
contaminants to ground water. ~ith alternative 2, however, there
may be a slightly greater risk of ground water contamination than
with the other alternatives (except Alternative 1) due to
. potential leakage from the onsite landfill.
Summarv Matrix of Detailed Analvsis of Alternatives

A summary matrix of the detailed analysis of alternatives is
pr~sented in Table 8.
IX
Selected Alternative
After careful consideration of the proposed remedial
alternatives with regard to the criteria specified above, EPA's
selected alternative for addressing the onsite contamination at
the M.W. Manufacturing Site is Alternative 4 - Onsite
Incineration of Wastes and Soils, Stabilization of the Ash and
Disposal in RCRA Subtitle C Hazardous Waste Landfill. This
alternative would permanently reduce the onsite mobility,
toxicity and volume of contaminated material so as to eliminate
the threat to public health from direct contact. By removing the
waste from the Site, the potential for further ground water
contamination will be reduced.
This alternative presents the most conservative approach to
deal with the contamination present at this site. Some of the
ARARs for this site involve decision points with regard to
varying treatment requirements based on future sampling of
residuals from the chosen treatment processes. For example, the
LDR regulations will require that the incinerator ash be treated
before disposal if leachate testing results are above allowable
limits. In addition, the Pennsylvania regulations regarding
disposal of residuals from waste treatment processes mandate
different disposal options based on various factors, including
chemical analysis of the residuals and potential disposal
facility. The selected alternative represents the maximum amount
of treatment and the most rigorous form of disposal that may be
required under these ARARs. It also represents, therefore, the
maximum costs.
At this time, EPA believes that this alternative will attain
the Best Demonstrated Available Technology treatment levels that
appear in 40 C.F.R. 1268.43, as incineration is the specified
treatment method. However, existing and available data do not
demonstrate that incineration can attain the LDR treatment
standards consistantly for the soil and debris waste to be
.addressed by this action. In the unlikely event that BDAT
standards cannot be met for the contaminated soils, and in order
for this alternative to proceed in a timely fashion, EPA is, at

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"'I
26
this time, applying for a treatability variance in accordance
with 40 C.F.R. 268.44. The alternative treatment levels to be
attained will be a reduction in contaminant levels by 90-99%.
Alternatively, if sampling show~ that these ARARs can be complied
with by eliminating treatment of the incineration residuals or by
disposing of those residuals in a less costly manner while still
providing equivalent protection of public health and the
environment, EPA intends to explore these options.
In addition, because this remedy will not clean the soils to
levels such that the additional incremental risk posed by
drinking ground water contaminated by leachate from those soils
is less than 10-6, EPA considers this to be an interim remedy for
protection of the ground water. EPA intends to conduct a further
investigation of the ground water in the near future and will
continue to search for technologies that will allow the 10-6
levels to be achieved. If fcund these remedies will be
incorporated into a ROD for the remediation of ground water at
this site.
x.
statutorv Determinations
The selected remedy is protective of human health and the
environment, attains all applicable, or relevant and appropriate
requirements for this operable unit, is cost-effective, will
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable, and satisfies the preference for treatment as
a principal element.

Because this remedy will result in hazardous substances
remaining onsite at levels that would not allow for unlimited use
and unrestricted exposure, the five-year review will apply to
this action.
Attainment of the ADDlicable or Relevant and ApDroDriate
Reauirements
The selected alternative will be consistent with those ARARs
identified for this site:
The subsoils under the fluff waste piles must be closed
according to RCRA closure requirements (40 C.F.R S264.258)and 25
PA Code SS75.264(o) and 75.264(t). .
The surface impoundment must be closed according to RCRA
closure requirements (40 C.F.R S264.258) and 25 PA Code
S!75.264(0) and 75.264(s).

OSHA standards (29 C.F.R. SS1910.120(b) - (0» will to be
followed during all site work.

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27
This al~ernative will comply with the RCRA incinerator
regulations (40 C.F.R. ~~ 264.340 - 264.999) and the Pennsy1vania
regulations for hazardous waste incineration (25 PA Code
~75.264(W».
Any residual ash considered a hazardous waste under 40
C.F.R. ~261.3 will comply with 40 C.F.R. Part 264 and 25 PA
~75.264(V) which requirements regulate the land disposal of
hazardous wastes.
Code
This action will cause no violation of NAAQS due to fugitive
dust generated during construction activities (Clean Air Act, 40
C.F.R. ~50.6 and 40 C.F.R. ~52.21(j).
Fugitive dust emissions generated during construction
activities will comply with fugitive dust regulations in the
Federally approved state Implementation Plan for the Commonwealth
of Pennsylvania (Clean Air Act, 40 C.F.R. Part 52, Subpart NN, ~~
52.2020 - 52.2023).
\
Any surface water discharge will comply with the Clean Water
Act NPDES discharge regulations (40 C.F.R. ~~122.41-122.50), the
Pennsylvania NPDES regulations (25 PA Code ~92.31), and the
Pennsylvania Wastewater Treatment Regulations (25 PA Code ~95.1 -
95.3). .
Cost-Effectiveness
This alternative affords a high degree of overall cost
effectiveness in not only protecting the onsite residents, as
well as any future Site visitor, from direct contact with the
wastes and contaminated soils, but also in reducing future
contamination migrating to the ground water. The U.S. EPA
believes that the costs of the selected remedy are proportionate
to its overall effectiveness, therefore representing a reasonable
value for the money.

Utilization of Permanent Solutions and Alternative Treatment
Technoloqies to the Maximum Extent Practicable
The U.S. EPA believes that the selected alternative is the
most appropriate solution for remediating the contamination at
the M.W. Manufacturing Site. The organics in the soils and
wastes will be destroyed by incineration and the inorganics in
the ash immobilized by stabilization. This represents the
maximum extent to which permanent solutions can be utilized.

Preference for Treatment as a Principal Element
The statutory preference for permanent treatment is
satisfied as the selected remedy calls for onsite treatment of
waste materials and soils.

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29
.
RESPONSIVENESS SUMMARY
This Responsiveness Summary documents concerns and comments
expressed by residents of the community surrounding the MW
Manufacturing Superfund site during the public comment period
held by the EPA regarding a Proposed Remedial Action Plan for
remediating a contaminated fluff waste pile (the second of three
anticipated Operable Units). This summary also documents EPA's
responses to the comments and concerns expressed by members of
the community.
i
i
SUKMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA'S RESPONSES
During the comment period no written comments were received at
the Region III EPA office by either the Remedial Project Manager
or the Community Relations Coordinator. Both received frequent
calls from news reporters in the area and the RPM was interviewedi
for articles that appeared in the area daily newspapers as well
as for the ABC-TV station in Scranton, Pennsylvania, which also
serves the Danville area.
Because of the level of public response during the comment
period, representative questions are grouped below by topical
areas of concern: .
Phase I - Carbon Waste:
Q.
A.
Q.
A.
The carbon waste removal was scheduled to begin last
winter: why has it been delayed and when will it take
place?
Funding difficulties forced a delay in the carbon waste
removal. It is now set to be moved off site by the end
of this spring.
If the carbon waste can be moved offsite for disposal,
why can't the fluff waste be handled the same way?
After looking at several alternatives, including
offsite disposal, it was decided that the most
protective and cost effective method of disposal would
be onsite incineration.
Public Involvement in SUDerfund:
Q.
A.
,-
How widespread is public involvement in Superfund? Do
these type of meetings take place elsewhere?
The Comprehensive Environmental Compensation and
Liability Act (CERCLA) is the law which originally
authorized funds to EPA under Superfund. Congress
mandates that at every significant technical milestone,

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30
th~ public is encouraged to participate based on
published notices in newspapers, fact sheets and public
meetings. The decision to choose a particular type of
remediation can only occur after there has been an
opportunity for public comment after the formal
presentation of the various alternatives.
Can the public have any input into the type of
incinerator that's selected? Do we get a chance to
comment on the Remedial Design?
There will be a presentation of the final design for
the incinerator and other elements of the Phase II
cleanup. EPA has also asked that a local official be
designated as a contact point so that all information
can be channeled through a single individual.

Risk Factors/Safetv:
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Who will monitor the operation of the incinerator?
will there be air monitoring?
It is most likely that the Army Corps of Engineers,
which has decades of experience in mounting large
operations such as this, would hire contractors, and
oversee every single aspect of operations. The
Remedial Project Manager would, in turn, be responsible
for overseeing the whole project, taking any public
concerns back to the Army Corps to have problems
corrected, if needed.
If the Head start School is next to the site, is it
safe for the children and staff to be there while the
incinerator is burning?
Yes, because the permitting requirements for the
incinerator are so stringent, we will have to give very
high assurance that it will burn the wastes safely.
The destruction of the toxic materials has to be down
to 99.99 percent. In some cases, the percentage is
99.9999 percent for highly toxic substances.

How do you determine the relative safety of
incineration?
The risks are calculated on a very conservative basis,
using as a framework an exposure scenario of 70 years.
Even someone living on the site would not have the
exposure frequency that we use in our calculations.

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Q.
A.
Q.
A.
31
Fu~dinq the Proposed Plan:
Are you sure there's enough money to pay for such a
proposal? Where do we stand relative to other sites
and other regions?
We have successfully stated our case with Washington
that the MW site needs to be addresses as quickly as
possible. Our management supports this proposal and at
the current rate of funding, the money is available.
Our performance in this region has had one of the best
enforcement records in the country. In Pennsylvania,
we have been able to start and complete the most
constructions in the United states.
What happens to the people who originally created this
mess? Isn't it true that nowadays, there are enough
laws on the books to prevent such a problem?
Yes, most of the activity as it occurred during the
1960's and 1970's would be illegal at this time. The
parties responsible in this case are bankrupt, but EPA i
will continue on with the cleanup. .

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TABLE 1
.
CHEMICAL ANALYTICAL RESULTS
FLUFF WASTE SAMPLES
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
  Number of 
 Range of Positive Average
Contaminant Positive Detections/
 Detections Number of Concentration
  Samples 
2-butanone  2,800-6,400 6/17 1,647
toluene  250-2,000 10/17 507
tetrachloroethene 720-18,000 15/17 4,436
methylene chloride 7,700 1/17 453
bis(2-ethylhexyl) 72,000,000- 17/17 148,820,000
phthalate  230,000,000
di-n-octyl phthalate 1,800,000- 13/17 4,388,235
13,000,000
PCB-1254  898-18,100 17/17 9,384
(~g/kg)
(~g/kg)
antimony 80-143 10/17 65
barium 20-232 17/17 93
cadmium 0.65-4.4 17/17 2.4
chromium 24-59 17/17 40
copper 5;910-130,000 17/17 49,636
lead 1,600-3,600 17/17 2, 415
nickel 4.1-15 10/17 5.6
silver 1.6-5.7 11/17 1.8
zinc 135-2,580 17/17 623
(mg/kg)
(mg/kg)
Note: Averages reported are
nondetection. as zero.
the arithmetic averages calculated
using
R331918

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TABLE 1
.
CHEMICAL ANALYTICAL RESULTS
WASTES IN DRUMS AND BARRELS
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
  Number of 
 Range of Positive Positive Average
Contaminant Detections/
 Detections Number of Concentration
  Samples 
(}1CJ/kCJ)
(}1CJ/kg)
2-hexanone 970 1/19 51
benzene 2,100-210,000 3/19 11,294
total xylenes 1,200 1/19 63
1,1,2-trich1oroethane 890-680,000 11/19 127,920
tetrachloroethene 3,600-640,000,000 19/19 9,804,190
trichloroethene 1,500-18,000 3/19 1,200
chloromethane 560-6,200 3/19 529
bis(2-ethylhexyl)phthalate 230,000-690,000 3/19 65,263
di-n-o~ty1 phthalate 2,000-220,000 8/19 14,737
di-n-butyl phthalate 4,000-15,000 3/19 1,632
butyl benzyl phthalate 3,000-16,000 2/19 1,000
dimethyl phthalate 3,000-4,000 2/19 368
anthracene 7,000 1/19 368
benzo(a)anthracene 2,000 1/19 105
chrysene 3,000-8,000 5/19 1,316
fluoranthene 2,000-5,000 2/19 368
fluorene 4,000 1/19 210
naphthalene 2,000-14,000 9/19 2,368
2-methylnaphthalene 3,000-24,000 7/19 2,789
phenanthrene 5,000-32,000 7/19 5,474
pyrene 3,000-11,000 3/19 947
1,2-dichlorobenzene 4,000 1/19 210
1,2,4-trichlorobenzene 9,000 1/19 474
benzoic acid 13,000-810,000 3/19 45,526
isophorone 13,000 1/19 684
phenol 12,000 1/19 632
4-methylphenol 4,000-11,000 3/19 1,263
R331918

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TABLE 1
CHEMICAL ANALYTICAL RESULTS
WASTES IN DRUMS AND BARRELS
MW MANUFACfURING SITE
MONTOUR COUNTY, PENNSYLVANIA
PAGE TWO
  Humber of 
 Range of Positive Positive Average
Contaminant Detections/
 Detections Humber of Concentration
  Samples 
(mg/kg)
(mg/kg)
antimony 22-2,200 11/19 403
chromium 62-200 15/19 96
copper 155-496,000 18/19 61,413
lead 624-66,500 18/19 31,221
mercury 0.31-4.3 9/19 0.46
nickel 44-102 5/19 16
zinc 85-1,400 16/19 471
Hote: Averages reported
nondetections as zero.
are
ad thmetic
averages
calculated
using
R331918

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TABLE
1
LIQU!D
CHEMICAL ANALYTICAL RESULTS
WASTES (NON-WATER-MISCIBLE) IN STORAGE
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
TANKS
Contaminant
Tank 1
Tank 2
Tank 3
. (average)
4-methyl-  4,000 ND ND
2-pentanone 
toluene  2,000 2,000 2,500
total xylenes  ND 2,000 10,500
tetrachloroethene  82,000 76,000 44,500
trichloroethene  1,000 ND 25,000
PCB-1248 ' ND ND 43,000
(1l9/kg)
(llg/kg)
(llg/kg)
chromium 39 31 ND
nickel ND ND 20
silver 55 ND ND
(mg/kg)
(mg/kg)
(mg/kg)
ND
Not Detected
Note: Averages reported for Tank 3 are the arithmetic
averages for the duplicate samples collected, using
nondetections as zero.
R331918

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w
w
...
\0
...
CD
TABLE
1
CHEMICAL ANALYTICAL RESULTS
SEDIMENT SAMPL~S FROM STORAGE TANKS
MW MANUFACTURING SITE, MONTOUR COUNTY, P~NNSYLVANIA
"ank 1
"..nll ~
"ank ) (Averilge)
Conta.lnant
Solids
.
lIon-W..l...-
Ihsclble
IIoO-lI8t.r-
.I"dbl.
lIon-""",,,-
MIScible
....Ie,
NI,;clble
Sol ide
Solids
 hag/kg) (uQ/kg) (ug/kQ) (~g/kQ) (uQ/kQ) 1119/k9) ( 119/k g) Illg/kg) I"g/k<])
.-aeth,l-~-pentanona 20,000 IIA IIA 110 110 IIA 110 ~,OOO 110
toluene 1,000 IIA IIA .,000 1,000 IIA 1,000 I,SOO 110
total .,Iene. 1,000 II. II. liD liD IIA liD liD 110
tetrachloroethene 150,000 II. II. 61 , 000 liD II. .,9DO,000 48,500 1,040,000
tr Ichloroethen. ',000 IIA II. liD 110 II. ~18,~00 1,~OO 140,000
aethrlene chorlde liD II. II. 110 110 IIA 110 ~DO 110
bla(2-eth,lh..rllphthalat. liD IIA IIA liD liD IIA 110 liD ~,350,OOO
dl-n-but,l phthalata liD IIA IIA 110 110 IIA 110 110 12S,OOO
beoaolc acid liD II. IIA 110 61 , 000 1111 liD 110 110
phenol liD 1111 IIA liD 10,000 IIA liD 110 110
.-aethylphenol liD II. II. 110 7,000 IIA 110 110 110
PCB-U.' liD IIA II. liD liD IIA 40,500 110 3),)00
         -.-.--
 (mg/kg) (mg/kg) (mQ/kg) (mg/kQ) (rnQ/kg) IDlg/kg) Img/kg) Img/kg) (rng/kg)
antiaon, liD 1111 II. liD 110 IIA 56 110 11
chro81ua liD II. II. liD liD IIA 59 ~1 108
copper 90 II. IIA liD 110 IIA 1~, ~.,s 114 SO, 200
I.ad u. II. IIA 110 110 IIA ~,HO 110 12,1S0
ainc liD IIA IIA 110 52 IIA ~41 110 1411
NA
NO
Not Analvzed: not enough matrix present in sample bottl~ drawn from the bottom of the tank.
Not Detected
Note:
zero.
Averages reporled for 'fank 3 are the arithmetic averages for the duplicate samples coLlected, using nOlldt:tection:i d:i

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TABLE
1
CHEMICAL ANALYTICAl. RESULTS
LAGOON WATER AND SEDIMENT SAMPLES
MW MANUFACTURING SITE, MONTOUR COUNTY, PENNSYLVANIA
  Lagoon Wate~   Lagoon Sediment 
  lIumbe~ of     .
    Numbe~ of 
Cont..inant Range of Positive  Range of Positive 
 poaitive Detections/ Average Positive Detections/ Average
  Concentration Concentralion
 Detection. lIumber of  Detections NU8ber of
  Sa.ples   Samples 
(119/1 )
(P9/1)
(pg/kg)
( pg/kg )
2-butanone 4 1/6 0.1 liD  
toluene  1-5 5/6 2 300-900 3/6 28]
l,l,2-trichloroethane 6-12 6/6 8 16,000 1/6 2,b61
tetrachloroethene 18-31 6/6 26 210,000 1/6 ]5,000
trichloroethene 5-12 6/6 8 51,000 1/6 8,!)OO
I,Z-dichloroethene 2]-'6 6/6 47 300-20,000 2/6 3,383
l,l-dichloroethene liD   100 1/6 111
vinyl chloride ]-11 6/6 6 1,500 1/6 HO
aethylene chloride liD   ]0,000 1/6 !),OOO
bia(l-ethylhe.yl)phthalate 29-1!i0 6/6 66 ]5,000-4,600,000 5/6 1,199,83]
di-n-octyl phthalate ]-4 2/6 1 3,000-100,000 2/6 11,167
dimethyl phthalate 2-28 4/6 10 ND  
phenol  130-160 2/6 48 ND  
2-.ethylphenol l3-1!) 2/6 !) NO  
4-.ethylphenol 350-380 2/6 122 ND  
2,4-di8ethylphenol 26-260 6/6 108 NO  
dioxin  NA   0.020 1/6 0.003

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TABLE' 1
CHEMICAL ANALYTICAL RESULTS
LAGOON WATER AND SEDIMENT SAMPLES
MW MANUFACTURING SITE, MONTOUR COUNTY,
PAGE TWO
PENNSYLVANIA
  Lagoon Water   Lagoon Sediment 
        I
  Humber of   Humber of 
Conta.inant Range of Positive  Range of Positive 
 positive Detections/ Average Positive Detections/ Av~riacJe
 Concentration Concentration
 Detections Nu.ber of  Detections Humber of
  Samples   Samples 
(lig/1)
(1I9/l)
(mg/kg)
(mg/kg)
anti.ony 41.3-54.4 3/6 26 215 1/6 36
bariu. 124-163 6/6 138 1!H-316 S/6 196
chro.iu. 110   32-538 5/6 111
copper 3,910-1,110 6/6 S,060 279-9,690 6/6 2,884
lead 619-1,010 6/6 804 SOO-39,800 4/6 6,90S
nickel 10.2-50.5 6/6 21 42-54 3/6 24
ainc 402-663 6/6 484 64-146 6/6 111
HD
IIA
Hot Detected
Hot Analyzed
Mote:
Averages reported are arith.etic averages calculated using nondetections as zero.

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TABLE
1
.
CHEMICAL ANALYTICAL RESULTS
ONSITE SURFACE SOILS
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
  Number of 
 Range of Positive Average
Contaminant Positive Detections/
 Detections Number of Concentration
  Samples 
(ll9/kg)
(ll9/kg)
acetone  450 1/21 21
total xy1enes 42 1/21 2
1,1,2,2-tetrach1oroethane 33 1/21 2
, 
1,1,2-trichloroethane 3-2,800 10/21 275
tetrach1oroethene 23-67,000 18/21 10,151
trich1oroethene 2-21,000 .8/21 1,027
1,2~dich1oroethene 2-10,000 5/21 486
chloroform  64 1/21 3
methylene chloride 830 1/21 39
bis(2-ethylhexyl)phtha1ate 3,900-3,800,000 21/21 835,948
di-n-octyl phthalate 200-140,000 18/21 36,576
di-n-buty1 phthalate 480 1/21 23
dimethyl phthalate 130-270 2/21 19
anthracene  110 1/21 5
chrysene  380 1/21" 18
naphthalene  140-190 2/21 16
2-methylnaphthalene 82-130 2/21 10
phenanthrene 100-470 3/21 39
benzoic acid 430-1,300 2/21 82
phenol  170-330 2/21 24
4-methy1phenol 620-870 3/21 101
2,4-dimethylphenol 200-340 3/21 38
2,4-dichlorophenol 43 1/21 2
..
R331918

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TABLE 1
CHEMICAL 'ANALYTICAL RESULTS
ONSITE SURFACE SOILS
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
PAGE TWO
  Number of 
 Ranqe of Positive Averaqe
Contaminant Positive Detections/
 Detections Number of Concentration
  Samples 
2,4,6-trichlorophenol 36-41 2/21 4
4-chloro-3-methylphenol 170-220 2/21 19
heptachlor epoxide 41 1/21 2
4,4'-DDT  100-170 2/21 13
PCB-1242  210-920 5/21 112
PCB-1248  290-6,300 2/21 314
PCB-1254  61-3,700 6/21 210
dioxin  0.102-0.222 4/21 0.03
(~q/kq)
(~9/kq)
antimony 62.1-118 4/21 16
barium 22.4-107 21/21 74
cadmium 1. 2-11. 9 15/21 2
chromium 7.1-59 21/21 27
copper 742-171,000 21/21 21,635
lead 31. 9-9,770 21/21 1,453
nickel .8.5-40.2 21/21 22
s il ve r 8.6 1/21 0.4
zinc 54.8-787 21/21 242
(mq/kq)
(mq/kq)
Note:
Averages reported are ar i thmetic averages
using nondetections as zero.
calculated
R331918

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TABLE
1
CHEMICAL ANALYTICAL RESULTS
SUBSUR~ACB SOIL SAMPLES
MW MANUFACTURING SITE, MONTOUR COUNTY, PENNSYLVANIA
  O-l re.t   4-6 relit   6-8 r.et 
  Mu.ber of  Renge of lIueber of   lIuab.,r 01 
Conte.inent ..nge 01 po.itiv. Averege Po.tive Po. i tive Average llange ot po.ilivt! Avelal)e
 "eU..e Detection.1 Concentret ion IItItection. Detectlon.1 Concenlraliun Pou I "e Detect ion.1 Concentrltion
 Detection. lIu.ber of   Muebel of DeleC:L ion. lIueber of 
  Seeple.   Saeple.   Semple. 
hlJ/kg)
(,.g/kl))
( \lI)/kl))
( ~I)/kl))
( ~I)/k'l)
1~'I/k'jl
acetone 1,~00 1/:15 60 15..4] 2/)] 2  
:I-butenone ],000 1/25 120 56-1,)00 2/U .. 14 III
:I-he.enone    l 1/)) 0.06  
4-..th,1-2-pentenone        
ben.ene        
toluene    4-5 2/]] 0.)  
eth,lben.ene    ]-1 2/)] 0.4  
total .,Iene. 18 1/25 I )0 II)) 0.1  
chloroben.ene 5 1/:15 0.2     
1,1,l,2-tetrachloroethane        
1,I,I-trlchloroethane 41-l,100 )/25 10     
1,1,2-trichloroethane .. 1/25 0.4 )-1100 '11)] 2:l  
letlachloloethene ]-5:1,000 11/25 ),816 1-1,600,000 21/)] !i!i,IIU  
trichlo,oethene ]- 210 8/25 11 2-1,800 11)] 58  
1,2-dichlo,0.thene 1-26 4/25 2 1...64 II)] 5  
vlnrl chloride        

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TABLE 1
CHBMICAL ANALYTICAL RESULTS
SUBSURFACE SOIL SAMPLES
MW MANUFACTURING SITE, MONTOUR
PAGE 'NO
COUNTY, PENNSYLVANIA
  0-1 '..et   4-6 reet    6-8 '.et 
  .lIIIber of   lIu8ber of    lIumber of 
Conta.inant ..age 01 Poailiv8 Average lIange of po.itlvlt  lI"ng. of POfli,ilive 
 heti.e Detection.1 Po.the Detect ion.1 Ave."ge Po.tive DIIt..ct i..n.1 love <89'
    Concentration  Concentlation Concltnl... ion
 DetKt ion. .u.er of  Detection. lIu8bll. of  DIIlecllon. .h).bu. of
  S...,l..   Sa"ple.    S...pl... 
Cl'g/kg)
I~g/kg)
hg/kgl
C ~9/k9'
1I'9/11g I
I " )  
4-chloro-1-..th,lphenol    S1 l/l~ 2  
~.

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TABLE 1. .
CHEMICAL ANALYTICAL RESULTS
SUBSURFACE SOIL SAMPLES
MW MANUFACTURING SITE, MONTOUR
PAGE THREE
COUNTY, PENNSYI.VANIA
  0-2 reet   4-6 reet   b-8 t'eet 
 "DfJe of lIullber of  AanlJe of lIullber of   IIUllber of 
Conla.inanl P06itive Aver'"lJe POliilive  Ran'.!.. of ~uliiliYe Avel cUJt2
 ~8t 1 V8   poalive   AveralJe POlit"ive
 Deteclion..1 Coneenlretion  Deleet iOnli1 D..tect ion..1 Conce"'W'at ion
 DetectiDG.  Delact ion.. Concentration DlIllict ion.
  lluaber of   lIullb..r of  lIu..ber of 
  Sa.ple.   Saaple..   5""1'1.... 
hIJ/II,)
("lJ/klJl
( 1,,,/kql
("g/kgl
( "q/kql
( ""/kql
heplachlur epodde 1.7 l/2S 0.4   
chlordane  S.S 1/2S 0.2 21 1/2S 0.8
PCB-10l6  1,400 1/2S S6   
PCB-UU     600-1,400 ]/2S 164
PCB-Uti  200- 840 2/2':i U lSO- no 2/2S ]"I
pea-US4  17-1,000 2/2S 43 110 1/2S 7
PCB-1UO       
(8q/1l91
(ag/k9)
(81q/llql
(ag/ll,)
(8Ig/1l91
(119/1191
bariU8 n. 4-211 2S/2S 107 42.6-161 31/H 8] 6 J -1 09 ]/J 81>
cad.i'u. 1.2-12.7 !i/2S 1 1.]-2.2 b/J2 0.4   
chr08iu. 14-30 24/25 20 14-46 ]1/]2 21 20.1-]5.1 3/J 21>
copper :U. 3-3,100 24/2S b':ib 22-8,110 31/]2 IIOJ 32.4-16II )jJ HZ
lead 12.7-1,118 23/25 141 6-1,2S0 ]0/32 12J 14.2-48.] ]/J JI>
nicllel '.4-':i3.3 2S/25 2J l)-4S.7 32/12 11 U.8-U.6 3/] 4b
aine 22.S-)2I 2!i/25 82 U.7-122 31/J2 Ii] SS.II-JI'J J/J 144

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TABLE 1
cHEMtCAL ANALYTICAL RESULTS
SUBSURFACE SOIL SAMPLES
MW MANUPACTURING SITE, MONTOUR
PAGE POUR
COUNTY, PENNSYLVANIA
  8-10 reet   12-14 'eet   1b-18 r~e:t 
  .u.ber of  lIan",e of .umber of   Nu..bt:1 of 
Conte.lnent Ra"g. of Poaltl"e Av... a",e PUliitive  lIange ot Potiitive Av..cagll
 Poet he Petecl iona/ Concent...tlon PU6tive Delec ti on./ Avera",e  D..t..etiona/ conelntt.tiun
 Dttlection& Concentration Puslive
 Detect iOR' .wober of   .umbec or 08tecLionti Nu..ber at 
  S_ple.   Sample.   Samplea 
Meelone U-ZlO 2)4 9 I~-I'I,OOO 3/22 114 410 I/~ '.14
2-blltanone ),100-1.000 2/)4 291 29-14,000 3/22 662 3,900 1/~ 180
2-he.anon.    2-18 3/22 I   
4-.eth,I" 2-punl.none    1 1/22 0.004   
benaene 2 I/U 0.06      
10\lIene lJO-220 3/H 15      
eth,lb.naene    ~2U 1/21 :it   
total .,.ena.         
chlorob.naena         
1,I,2,2-tetrachloroeth.ne 4 I/H 0.1      
I,I,I-trichloroethane         
l,l,2-1rlchloroethane 2-4,)00 8/)4 2)9 2-15,000 ~/22 694 !I,400 1/5 1,080
letrachloroethene 2-ISO,OOO 22/)4 10,358 )-620,000 18/22 40,681 ".>'1'1,000 4/".> 15.408
tllchloroethene 2-1,900 9/U 100 2-2600 "/22 212 II II".> ,
1,2-dichloroethene 4 -!IIO II/H U    D/U 11':> IJ
vlnrl chloride 82 104 2      
( 1'9/119 .
( 119/119'
(119/"9'
( 119/"91
( 119/"9)
( 1''.1/'''))
....'

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50
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10
»-•
OD
TABLE,  1
CHEMICAL ANALYTICAL RESULTS
SUBSURFACE SOIL SAMPLES
MW MANUFACTURING SITE, MONTOUR  COUNTY, PENNSYLVANIA
PAGE FIVE


Contaminant



kange of
Postive
Detection!

8-10 feet
Number of
Positive
Detections/
Number of
Samples


Average
Concent i at ion



Range of
Postive
Detect ions

12-14 feet
Number of
Positive
Detections/
Number of
Samples


Average
ConcenLrat ion

16-18 Keul

Range of
Postive
Detect ions

Nunbei of
positive
Uutect loiik/
Number of
SonplttS

»
Avei age
Concent rat ion

                                      (M9/>9)
                                                     /3«

7,982
7.82}
3,078

13

3
0.7

10
IBS
23
SO

1
8,800
300-
30,000,000
100-40,000
260-3,600

S2
23-110
32

80

840
65-93
120


1/22
10,22
9/22
4/22

1/22
2/22
1/22

1/22

1/22
2/22
1/22


400
1,480,409
2,334
322

2
6
I

4

38
/
5



1,700-6,400
100-3/0
120


32
36
14

77
1,900





3/S
3/b
•A


1/5
i/5
1/5

1/5
«/*





2.180
1)2
24


b
/
3

15
380





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TABLE 1.
CHEMICAL ANALYTICAL RESULTS
SUBSURFACE SOIL SAMPLES
MW MANUFACTURING SITB, MONTOUR
PACE SIX
COUNTY, P~NNSYLVANIA
  1-10 reet    12-14 rll"t   u. - III ...."I 
 "lIge of ....ber of   of "umber uf   NUJnbt!~ uf 
Conte.inent Poaiti"e Avor8qe Renge Positive  !lang" uf   
toeU"e POittiv8   POtiJtJYU AvaH dilJe
  I18lectiona/ Concenllatlun   O"t""t iona/ AverCl4)tt POlit ivtt D..lucliun5/ Conc.nlllL iun
 Detection.  Detectiuna Concenlration Detections
  . ...be r of    .....bel ot  tlu..btU ot 
  Se.plea    Sallplea   :;......1". 
hg/1I9.
( ~'.I/lIg)
( ~'.I/k       
PCI-UU  19" 550 )/14 )I 140 1/22 I>
1'C1-12U     lJO 1/22 10
1'C1-12~4       
PeIl-I2bO  110 14 ".I   
C.g/k..)
ClIg/kg)
.1O-142 21/21 b1 )11-96.6 ".1/5 1>0
cad.iu8 1.)-9.) )/)1 0.. 1.1-1.6 )121 0.2   
chro8iu8 14-10.) 28/)1 21 2.)-16.6 20/21 18 1]-18. '/ 4/~ Il
copper 24-1,100 ]1/]1 600 23.1-)8,9011 21/21 l,1I~2 6.1-~n 5/5 IJ2
leed '.9-2,640 30/]1 121 6-9)2 21/21 88 1.2-141 5/~ II>I
nickel 14-66.) JI/JI 14 5.~"56.2 21/21 )0 18-62 5/~ ]]
zinc )J-ln H/H 64 19-115 20/21 118 Jt-80 ':II/~ ':Ill
IIlenll Spece - Conte.inent not detectud.
.ote:
AV..Ag81i lepurled 818 8cith8elic 8""r"98:» cMlculCilud ulunq nuudttlvcliuns at» aelG.

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                            TABLE   2

                       INDICATOR CHEMICALS
                      MW MANUFACTURING SITE
                   MONTOUR COUNTY,  PENNSYLVANIA
Known or Probable Carcinogens
benzene
tetrachloroethene*
trichloroethene
1 , 1-dichloroethene*
vinyl chloride
1,1,2, 2-tet rachloroethane
1,1,2-trichloroethane*
methylene chloride*
chloromethane
bis ( 2-ethylhexyl )phthalate*
polychlorinated biphenyls
dioxin ( 2,3,7, 8-TCDD)
nickel*
Noncarcinogens
2-butanone
toluene
1,1, 1-trichloroethane
di-n-butyl phthalate
naphthalene
antimony
copper
lead
zinc




   Chemical also causes noncarcinogenic health effects.
R331918

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'.
TABU;
3
 lefe DelnUni   "blent Matee Quality    Caecinogenlc Potency 
 Ref.eence Oo.e Celtecla 1 IIg/ I )I 31    
 ...tee Act 189/kg-daYI121(4)     Factocl21(41  . KPA
 (lUIUS)      
Cheaical     Adju.ted  aealth Adviaoeyl21(41 Img/kg/dayl-l  Weight of
     foe   1II1I.I/11      IIvidence
 IICL IICLG   Dc inking 10-6 Risk        121(41
  189/11 Oed Inhalation     Oeal Inhalation 
 189/1)   Watee Only     
       I-da, /ch ild: 75     
       10-day/ch 11d: 7.5     
2-butanone   0.05 0.086   Long - tee a/child : 2.5     
       Long-teem/adult: 8.6     
       Li fet ime/adul t: 0.86     
benaene 0.005 0    0.67 I-day/child: 0.235 2.hI0-2 2.9810-2 A
   10-day/chlld: 0.235
       I-day/child: 18     
toluene  2 0.30 1.5 15,000  10-day/c;11ld. 6     
       Li fet Ille/adul t. 10.8     
1,1,2,2-      0.17    2.0810-1 2.0810-1 C
teteachloeoethene        
       I-day/child. 140     
       10-day/child: 35     
l,l,l-trichloroethane 0.2 0.2 0.09 3.1 19,000  Long- teea/child: 35     
       Long- tee8/..dul t. 125     
       Li fetillle/adul t: 0.200     
1,1,2-   0.20   0.6    5.7810-2 5.7810-2 C
teteachloroethane        
       I-day/child, 2.0     
      0.88 10-day/child: 2.0 5.1810-2 3.3  lO-J 82
tetcechloeoethene  0 0.01   Lun9- teem/child: 1.4 .
       Long- teem/adult: 5.0     
teichlocoethene 0.005 0    2.8    I. h10-2 1. JalO-2  82
REGULATORY REQUIREMENTS AND DOSE-RESPONSE PARAM~TERS FOR INDICATOR CHEMICALS
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
~.

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TABLE 3 .
R~ULATORY REQUIREMENTS AND DOSE-RESPONSE
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
PAGB TWO
PARAMETERS FOR INDICATOR CHEMICALS
 Safe DdDUng   Aabient Nater Ouality   Carcinogenic Potency 
 Reference Dose Criteris (pg/l)())   
 ...ter act (8g/kg-dsy)(2)(4)   ractod2)14) Ii:PA
 C1.UUS.     Heslth Advisory(2)(4) (lICJ/kg/ddD-l 
    Long-term/child: 0.013 A
       Long-term/adult: O. 0411   
..thylene chloride   0.06   0.19 l-day/child. 13.3 1. :>dO-) l.hlO-2 82
    10-day/chlld: 1.5
chIaro_thane      0.19   1.26dD..2 6.)2.10-) 
!, i s(2-ethylhe.yl)   0.02  21,000    6.84.10-4  82
phthalate         
di-n-butyl phthalate   0.01  44,000      
naphthalene   4.0810-1        
polychlorinated  0    0.01211   1.00  82
biphenyls          
       I-day/child: 1810-6   
      1. hlO-1 10-day/child: hlO-} I .56d05  82
diodn      Long-term/child: 1810-8 
       Long-term/adult: ).5810-8   

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TABLE 3
REGULATORY REQUIREMENTS AND DOSE-RESPONSE PARAMETERS FOR INDICATOR CHEMICALS
MW MANUFACTURING SITH
MONTOUR COUNTY, PENNSYLVANIA
PAGE THREE
 Saf. Driall1D1 Reference Doae Ambieot Water Quality   Carcinogenic Potency 
 "wr Aot (89/kg-day)(2)(41 Criteria (~g/l)())   rectorl2 II 4) 
 UJC2HSJ     KPA
Che.lcal     Adjuated  Heelth Adviaoryl21(4) IIIICJ/kg/day)-1 Wei~t of
     for  (llg/1)    Bvldence
 ICL IICLG   Drinking 10-6 RI&..     (2)(4)
 (8111/1) (8111/1) Orel Inhaletlon    Orel Inheletion 
   Weter Ooly    
eothlooy   4.0810-4  146      
copper  1.1 o.on 0.01 1,000      
       Long-tera/child: 0.02   
lead 0.005 0 1.4810-)  50  Long-term/edu1 t: 0.01   
       LifeU.../edult I 0.01   
nickel   0.01  15.4  10-day/child: 1   
    LIf"t i..e/adult: 0.)5  8."10-1 II
alnc   2.1810-1  5      
Reference.:
(1)
ca)
(1)
(4)
(5)
BPA, .oveaber I), 1985(a)(b)(cl.
BPA, .ove.ber 16, 1981.
KPA, October 1986.
BPA Integrated Ria" Infor..tion
KPA, Auguat 18, 1988.
Syatea (IRIS).
A
81/82
C
Ino..n hu..n cerclnogen.
Probable hu..n carcinogen.
Poa.lble hu..n carclnogeo.

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.
TABLE 4
Significant Risk Levels at M.W. Manufacturing
TOTAL CARCINOGENIC RISK.
ROUTINE CONTACT WITH SURFICIAL MATERIALS
BY ONSITE RESIDENTS
Source of Contaminant Total Risk
Contamination Concentration 
Surface Soils Average 1. 4 X 1 O:~
  Maximum 1. 2 X 10
Fluff Waste Average 3.1 X 10-4
  Maximum 5.2 X 10-4
TOTAL HAZARD INDEX
ROUTINE CONTRACT WITH SURFICIAL MATERIALS
BY ONSITE RESIDENTS
I
I
,
I.
Source of Contaminant Total
Contamination Concentration HI
Surface Soils Average 17
 Maximum 121
Fluff Waste Average 104
 Maximum 177

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                    TABLE 4

            TOTAL CARCINOGENIC RISK
        EXPOSURES THROUGH HOUSEHOLD USE
                OF GROUNDWATER
Source of
Contamination
Existing Plume
Soils & Wastes
Contaminant
Concent rat ion
Average
Maximum
Average
Maximum
Total
Potential
Risk for
Onsite
Receptors
4.0 X 10~2
6.0 X 10"1
9.1 X 10"5
7.0 X 10~4
Total
Potential
Risk for
Offsite
Receptors
3.7 X 10~2
5.7 X 10"1
7.4 X 10"5 x
6.6 X 10~4
              TOTAL HAZARD INDEX
EXPOSURES THROUGH HOUSEHOLD USE OF GROUNDWATER
Source of
Contamination
Existing Plume
Soils & Waste
Contaminant
Concentration
Average
Maximum
Average
Maximum
Total
Potential
Risk for
Onsite
Receptors
24
124
8.6 X 10"1
2.4
Total
Potential
Risk for
Offsite
Receptors
22
115
6.4 X 10"1
2.1

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TABLE 4
TOTAL CARCINOGENIC RISK
EXPOSURES TO VOLATILE EMISSIONS
.     
Source of Site Workers  Site
Contamination Residents
Surface Soils 2.4 x 10-5 4.2 X 10-4
Fluff Waste 9.4 x 10-6 1.7 X 10-4
/

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TABLE
5
RISK-BASED REMEDIAL ACTION LEVELS FOR PRIMARY CONTAMINANTS
RESIDENTS (~9/k9)(I)
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
IN SOILS/WASTES
 Sue face SoU Fluff Waste Subaueface Soil  .
ContaaiDant 1 . 10-6       
 1. 10-4 1 . 10-6 1. 10-4 1. 10-6 1. 10-4 MCL 
 818k 818k 8iak Riak Risk Risk  
tWtrachloroeth8ne 1.1 . 10-] 0.11 2.0 . 10-] 0.2 9.2 8,200 4600 
 (5) (5) (5) (5)    
!'eichloeoetbene 5.4 . 10-] 0.54 liD 110 11 15.100 1800 
 (5) (5)      
Vinll cblodde 110 .0 110 110 0.001 1 290 
     (5)   
1, 1, 2-!'eichloe08tbane  1.0 . 10-3 0.1 110 810 0.85 150  
 (5) (5)   (51   
Bi.(2-etbJlbe.Jl)pbtbalate 0.13 13 ]0 2,916 89,000 1,965,000  
 (330) (330) (338)     
I'C8 1.1 . 10-5 0.001 0.002 0.2 0.85 100  
 (80-160) (80-160) (80-160) (80-1601 (80-1601   
Coppee 800,000. IpO,OOO. 800,000. 100,000. .. ..  
Lead 500,000". 500.000". 500.000". 500.000." .. ..  
(1)
Contract LaboratorJ progeaa eCLP) eequire.ent Cappro.iaate laboratory detection li.it) shown in
bracket..
lIot detected in aediua. .
Action levela are for noncaecinogenic effects onlJ since copper is a noncarcinogenic sub8tance.
!'be 10-6 and 10-4 ri.k level. do not apply in this ca8e. Action level for copper based on the
rocused 'ea.ibilitr Study errs) for carbon waate pile.
Action 18vel cannot be eltabliahed - contaainant leaching cannot be predicted.
Ba.ed on BPA Region III PolicJ.
"his tabl. pr...nt. the ao.t con.ervative action level values for the fluff, fro. 8everal
e.poaur. acenario. (routine contact, or leaching to groundwater). -'
810
.
..
...
.ote:

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                                            TABLE  5
       RISK-BASED  REMEDIAL ACTION LEVELS FOR  PRIMARY  CONTAMINANTS  IN SOILS/WASTES
                                      RESIDENTS (M9/kg)(1)
                                     MW MANUFACTURING SITE
                                 MONTOUR  COUNTY,  PENNSYLVANIA
Contaminant
Tetrachloroethene
Tr ichloroethene
Vinyl chloride
1,1, 2-Tr ichloroethane
Bis( 2-ethylhexyl )phthalate
PCB
Copper
Lead
Surface Soil
1 x 10-6
Risk
1,200
[5|
5,400
(S)
NO
1,000
15)
88,000
1330)
8.6
(80-160)
800,000*
500,000***
1 x 10-4
Risk
1,200,000
15)
5,400,000
(5)
NO
1,000,000
(51
88,000,000
(330)
8,600
(80-160)
800,000*
500,000***
Fluff Waste
1 x 10-6
Risk
2,100
[5]
NO
NO
NO
159,000
(330)
15
(80-160]
800,000*
500,000***
1 x 10-4
Risk
2,100,000
(5)
NO
NO
NO
159,000,000
15,000
,(80-160)
800,000*
500,000***
Subsurface Soil
1 x 10-6
Risk
9.2
17
0.007
(5)
0.85
(5)
89,000
0.85
(80-160)
**
* *
1 x 10-*
Risk
8,200
15,100
7
750
7,965,000
700
* *
* *
(1)   Contract Laboratory Program (CLP) requirement (approximate laboratory detection limit) shown in
      brackets.
NO    Not  detected in medium.
*     Action  levels are for noncarcinogenic effects only  since copper is a noncarcinogenic substance.
      The  10~6 and 10~* risk levels do not apply in this  case.  Action level for copper based on the
      Focused Feasibility Study (FFS) for carbon waste pile.
**    Action  level cannot be established - contaminant leaching cannot be predicted.
*•*   Based on EPA Region III  Policy.
Note:  This table presents the  most conservative action level values for the fluff, from several
      exposure scenarios (routine contact, or leac    i to groundwater).

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                                TABLE
        LDR BRETREATMENT ASSUMPTIONS FOR CONTAMINATED MEDIA
                          MW MANUFACTURING SITE
                      MONTOUR COUNTY,  PENNSYLVANIA
   Medium
  Pretreatment
   Assumptions
                  Rationale
 Fluff
 Waste
Pretreatment for
metals
             No  pretreatment
             for solvents
TCLP extract lead  concentration > EP toxicity
level (5.0 mg/L)  (EP toxicity  levels used as
interim BOAT levels  in  the FS)

TCLP extract solvent concentrations < BOAT
levels
 Area A
 Soil
 (includes
 Lagoon
 Sediments)
Pretreatment for
metals

Pretreatment for
solvents
Total lead concentrations  >  threshold
concentration

Solvent (halogenated  aliphatics)
concentrations  > threshold concentrations
 Area  B
 Soil
Pretreatment for
metals

Pretreatment for
solvents
Total lead concentrations  >  threshold
concentration

Solvent (halogenated  aliphatics)
concentrations > threshold concentrations
 Area  C
 Soil
No pretreatment
for metals

Pretreatment for
solvents
Total lead concentrations  <  threshold
concentration

Solvent (halogenated  aliphatics)
concentrations > threshold concentrations
 Tanks
 (sediment)
Pretreatment for
metals
            Pretreatment for
            solvents
High lead concentrations  in Tank 3; should be
EP toxic for lead  (EP toxicity levels used as
interim BOAT levels  in the FS)

Sediments are saturated with high solvent
concentrations > BOAT levels
 Drums
Pretreatment for
metals
            Pretreatment for
            solvents
TCLP extract lead  concentration  (in Carbon
Waste) > EP toxicity  level  (5.0  mg/L)  (EP
toxicity levels  used  as  interim  BOAT levels in
the FS)

TCLP extract solvent  concentration (in Carbon
Waste) > BOAT levels
R332924
                        2-35

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TABLE 7
.
SUMMARY OF PRESENT-WORTH COSTS
ALTERNATIVES 1 THROUGH 6
MW MANUFACTURING SITE
MONTOUR COUNTY, PENNSYLVANIA
Alternative Abbreviated  Present-Worth Cost
Number Title  ($l,OOOs)
1 No Action  532
2 Onsite Hazardous Waste 16,843
 Landfill Disposal 
3 Offsite Hazardous Waste 
 Landfill Disposal  32,186
4 Onsite Incineration 35,950
5 Offsite Incineration 58,904
6 Offsite Incineration of 41,060
 Fluff Waste 
 Offsite Hazardous Waste 
 Disposal of Soils  

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TABLE 8
                                                        SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES
                                                                         MM MANUFACTURING SITE
Alternative 1
Mo Action! I)
Alternative 2
OMite Hazardous Waste
LaatffUl Disposal! 1>
Alternative 3
Offsite Haiardou*
Haste Landfill
Disposal(l)
Alternative 4
Onsite Incineration!1)
Alternative i
Offsite
Incineration! ' )
Alternative 6
Offsite Incineration
of Fluff Haste. pMsite
Physical/Chemical
Treatment of Soils'1)
            SHORT-TERM EFFECTIVENESS
Mot applicable
Mot applicable
Protection of public
health fro« exposure
to soils/wastes would
be achieved in
9-20 Months (not
including tisw for
treatability studies).
Oust aiay be generated
and volatile organics
released during
excavation activities.
Oust end/or vapor
control My be
required. Periaeter
air Monitoring My be
needed to determine
any adverse air
emissions to the
coMMunity.
Protection of public
health from exposure
to soils/uastes would
be achieved in
6-17 Months (not
including tine for
treatability studies).
Dust «ay be generated
and volatile organics
released during
eiicavation activities.
Oust and/or vapor
control nay be
required. Periaeter
air Monitoring My be
needed to determine
any adverse air
emissions to the
coMMunity .
Protection of public
health troai exposure
to soils/wastes would
be achieved in
2 yearb.
Dust My be generated
and volatile organics
released during
eicavation activities.
Dust and/or vapor
control nay be
required. Incinerator
and perimeter air
•onitoring My be
needed to determine
any adverse air
eaissions to the
coMMunity.
Protection of public
health frost exposure
to soils/wastes would
be achieved in
20 Months.
Oust My be generated
and volatile organics
released during
excavation activities.
Oust and/or vapor
control May be
required. Perimeter
air Monitoring way be
needed to deternine
any adverse air
emissions to the
couunity.
Protection of public
health from exposure
to soils/wastes would
be achieved in
12-23 xionths (not
including tiae for
treatability studies).
Dust nay be generated
and volatile organics
released during
excavation activities.
Oust and/or vapor
control way be
required. Perimeter
air Monitoring nay be
needed to determine
any adverse air
emissions to the
coMMuni ty .

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SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES

NN MANUFACTURING SITE

MONTOUR COUNTY. PENNSYLVANIA

PAGE TWO
Alternative 1
No Action(l)
Alternative 2
Omtite Kasardous Waste
Laadfill Disposal! I)
Alternative 3
Off site Hazardous
Waste Landfill
Disposal(l)
Alternative 4
Onsite Incineration!1)
Alternative S
Offsite
Incineration! ' )
Alternative 6
Offsite Incineration
of Fluff Waste, Onsite
Physical/Chemical
Treatment of Soils!1)
            SHORT-TERM EFFECTIVENESS  (Continued)
Not applicable
Spill control
procedures stay be
needed to protect
community and
environment fro*
spills of hasardous
materials during
physical/chemical
process.
Spill control
procedures may be
needed to protect
community and
environsient from
spills of hazardous
staterial* during
physical/chemical
process.


Spill control
procedures May be
needed to protect
community and
environment from
spills of hazardous
materials during
phy s i ca 1/chem i ca 1
process.
            LONG-TERM EFFECTIVENESS
Does not reduce
existing risks.
Provides minimal long-
term protection of
public health from
•uposure to
soils/wastes.




'

Eliminates enisling
risk of public
exposure to
soils/wastes.
Landfill significantly
reduces leaching of
contaminants from
fluff waste to
g round water. Periodic
maintenance required
to ensure long-term
reliability of
landfill and cap.
No remaining long-term
risks to groundwater .
RCRA cap and/or soil
cover eliminates
direct contact to
residual contamina-
tion. Periodic
maintenance of cap
required.




No remaining long-term
risks to groundwater.
RCRA cap and/or soil
cover eliminates
direct contact to
residual contamina-
tion. Periodic
maintenance of cap
required.




Ho remaining long-term
risks to groundwater.
RCRA cap and/or soil
cover eliminates
direct contact to
residual contamina-
tion. Periodic
maintenance of cap
requi red .




No remaining lontj-teim
risks to groundwater.
RCRA cap and/oi soil
cover eliminates
direct contact to
residual contamina-
tion. Periodic
maintenance of cap
required.





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SO
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ui
SUMMARV MATRIX FOR DETAILED  EVALUATION  OP ALTERNATIVES

MM MANUFACTURING SITE

NONTOUR COUNTY, PENNSYLVANIA

PAGE THRM
Alternative 1
No Action! 1)
Alternative 2
Onsita Hazardous Haste
IWkiflU DiaposalM)
Alternative 3
Offsite Hazardous
Haste Landfill
Disposal) 1)
Alternative 4
Onsite Incinerationd)
Alternative 5
Olfsite
Incineration! 1 )
Alteinative 6
Offsite Incineration
of Fluff Hacte, Onsite
Phy s i cal/Chemlcal
Treatment of Soils(')
            REDUCTION OP TOXICITY, NOBILITY. OR VOLUME
Doe* not reduce the
toxicity, Mobility, or
volume of contaminants
at the site.






,












1




Toiicity of toils
reduced to either
subsurface action
level t or LDR
treatment levels.
VoliuM) of contaminated
media not reduced.
Nobility of
contaminants in fluff
waste (and possibly
Area A/B soils)
reduced by
stabilization in
onsite landfill.
Nobility of
contaminants also
reduced by
containment. Fluff
waste and all treated
soil remain onsite.
Residual contamination
remains in soil
outside of treated
•hot spots.*




Toxicity of soils
reduced to either
subsurface action
levels or LOR
treatment levels.
Volume of contaminated
media at site (fluff
waste and possibly
treated soil)
significantly reduced.
Nobility of
contaminants in fluff
waste (and possibly
Area A/B soils)
reduced by
stabilization.
Nobility of
contaminants also
reduced by containment
in offsite landfill.
Pluff waste volume not
reduced but material
i* removed from site.
Residual contamination
remains in soil
outside of treated
•hot spots.*

Toiiicity of soils
reduced to surface
soil action levels
(>99.99I destruction
of organics). Volume
of contaminated media
at site (fluff waste
and possibly treated
soil) significantly
reduced. Nobility of
residual contaminants
in fluff ash (and
possibly Area A/B soil
ash) reduced by
stabilization.
Nobility of
contaminants in ash
also reduced by
containment in offsite
landfill. Pluff waste
volume reduced by 881
and ash is removed
from site. Residual
contamination remains
in soil outside of
treated "hot spots.*


Toxicity of soils
reduced to surface
soil action levels
(>99.99» destruction
of organics). Volume
of contaminated media
at site (fluff waste
and possibly tieated
soil) significantly
reduced. Nobility of
residual contaminants
in fluff ash (and
possibly Area A/a soil
ash) reduced by
stabilizat ion.
Nobility of
contaminants in ash
also reduced by
containment in offsite
landfill. Pluff waste
volume reduced by 881
and ash is removed
from site. Residual
contamination remains
in soil outside of
treated "hot spots.*


Toxicity of soils
reduced to either
subsurface action
levels or LDR
treatment levels.
Volume of contaminated
media at site (fluff
waste and possibly
treated soil)
significantly reduced.
Nobil ity of residual
contaminants in flutt
ash (and possibly Aiea
A/B soil) reduced by
stabi 1 izat ion.
Nobility of
contaminants in ash
also reduced by
containment in otfsite
landfill. fluff waste
volume reduced by 881
(>99.99t destruction
of organics) and ash
is removed from site.
Residual contami nat iun
remains in soil
outside of treated
"hot spots."

-------
to
IO
SUMMARY MATRIX POM DETAILED EVALUATION OP ALTERNATIVES
NW MANUFACTURING SITE
NONTOUR COUNT*, PENNSYLVANIA
PACE POUR
Alternative 1
No Action! 1)
Alternative 2
On* it* Haiardous Haste
Lamdfill Di*po*al(l>
Alternative 3
Offsite Hazardous
Waste Landfill
Disposal! 1)
Alternative 4
Onsite Incineration!1)
Alternative 5
Offsite
Incineration! ' )
Alternative 6
Otfsite Incineration
of Fluff Waste, Onsite
Piiys ical/ChemicjPl
Treatment of Soils!')
            INPLENENTABILITY
Deed restriction*
would require certain
legal procedure* and
cooperation of state
and local agencies.

Groundwater monitoring
and 5-year cite
review* required.










Technologies are
generally demonstrated
and commercially
available.

Treatability studies
would be needed to
determine the overall
implement abl 1 ity and
operating condition*
of the physical/
chemical process.

Groundwater Monitoring
and 5-year site
review* required.



Technologies aie
generally
demonstrated.
Availability of RCRA-
persiitted hazardous
waste landfills any be
lisiited.

Treatability studies
would be needed to
determine the overall
implementabili ty and
operating conditions
of the physical/
chemical process.

Groundwater monitoring
and S-year site
reviews required.
Technologies aie
demonstrated and
commercially
available.

Groundwater monitoring
and S-year site
reviews required.











Technologies are
demonstrated and
commercially
available.

Groundwater monitoring
and S-year site
reviews required.











Technologies are
generally demonstrated
and coumei cial ly
available.

Treatability studies
would be needed to
determine the overall
implement**!*! 1 i t y and
operating conditions
of the physical/
chemical process.

Groundwaler monitui i ny
and S-year site
reviews required.



           COST
Capital
$0
OtM
$31,000 (annually)
$20,000 (every
S year*)
Present-Worth
$532,000
Capital
$16,091,400
OtM
$45,300 (annually)
$20,000 (every
5 years)
Present-Worth
$16. (43, 000
Capital
$31.531,000
OtM
$39,000 (annually)
$20.000 (every
5 years)
Present-Worth
$32.186,000(2)
Capital
$35,295,000
OtM
$39,000 (annually)
$20,000 (every
i years)
Present-Worth
$35,950,000
Capital
$58,249,000
OtM
$39,000 (annually)
$20,000 (every
S years)
Present-Worth
558,904,000
Capital
$40,405
OtM
$39,000 (annually)
$20,000 (every
5 years)
Present -Worth
$41,060(2)

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SUMMARY MATRIX FOR DETAILED EVALUATION Of ALTERNATIVES
MM MANUFACTURING SITE
MONTOUR COUNTY. PENNSYLVANIA
PAGE FIVE
Alternative 1
No Actiondt
Alternative 2
OMitm *Ui«rdous Haste
LMdflll Disposal! 1)
Alternative 3
Offsite Hazardous
Haste Landfill
Disposal! 1)
Alternative 4
Onsite Inc inerat ion( 1 )
Alternative 5
Otfsite
Incineration! 1 )
Alternative 6
Offsite Incineration
of Fluff Waste,* Onsite
Physical/Chemical
Treatment of Soils(l)
           COMPLIANCE WITH AKARs









^










,







Soils under fluff
piles emit comply with
RCRA closure)
requirement* for waste
pile* (40 CFR
264. 256), requiring
installation of a RCRA
cap. A waiver of RCRA
cap requirement needed
to use hybrid closure
(soil cap) for soil
under fluff pile*.
Landfill must comply
with RCRA landfill
requirement a (40CFR
Parts 264.301-264.304)
and Pennsylvania
closure requirements
(PA Code, Title 2t>,
Ch. 75, Subchapters
C4D).
Post-Closure oust
comply with RCRA post-
closure care and
groundwater monitoring
requirements (40CFR
Part 264.117 and
264.310).
Soils under fluff
piles must comply with
RCRA closure
requirements for waste
piles (40 CFR
264.250), requiring
installation of a RCRA
cap. A waiver of RCRA
cap requirement needed
to use hybrid closure
(soil cap) tor soil
under fluff pile*.
Post-Closure mast
comply with RCRA post-
closure care and
groundwater monitoring
requirements (40CFR
Part 264.117 and
264.310).









Soils under fluff
piles must comply with
RCRA closure
requirements tor waste
piles (40 CFR
264.258), requiring
installation of a RCRA
cap. A waiver of RCRA
cap requirement needed
to use hybrid closure
(soil cap) for soil
under fluff piles.
Post-Closure must
comply with KCRA post-
closure care and
groundwater monitoring
requirements (40CFR
Part 264. 117 and
264.310).









Soils under fluff
piles oust comply with
RCRA closure
requirements tor waste
piles (40 CFR
264.258), requiring
installation of a HCKA
cap. A waiver of RCRA
cap requirement needed
to use hybrid closure
(soil cap) for soil
under fluft piles.
Post-Closure must
comply with RCRA post-
closure care and
groundwater monitoring
requirements (40CFR
Part 264.117 and
264.310).









Soils under fluff
piles must comply with
RCRA closure
requirements for waste
piles (40 CFR
264.258), requir ing
installation ol a RCRA
cap. A waiver of RCRA
cap requirement needed
to use hybrid closure
(soi 1 cap) foi .soil
under tlutt piles.
Post -Closure BIUSI
comply with RCRA post
closure care and
groundwaler monitoring
requirements (40CFM
Part 264.117 and
264.310) .










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10
10
M
SUMMARY MATRIX FOR DETAILED EVALUATION OP ALTERNATIVES
MM MANUFACTURING SITE
MOMTOUR COUNTY, PENNSYLVANIA
PAGE SI*
Alternative 1
No Action(l)
Alternative 2
Om*lt« B»»»r
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SUMMARY MA7RII fOR D87AILRO RVALUA7JON or AL7BRNATIVES
MW -..UFAC7URIMG SI78
IIOIIt'OIIR C0U1I7J, PIII.SYLVUIA
PAG8 SnD
  Alternative )     Allernative Ii
Alternative 1 Alternative 2 Offsite Hazardous Alternat iv" . Alternative !) Ofhite Incineration
.0 Action(l) 0881'. "..rdous Waste Waste Landfi 11 OnB ite Incinerationlll Of bite  of Fluff waste, OnBite
 ~'111 Di8posal(1) oisposal(ll    Incinerationlll  PhYSical/Che.icat
      Treat.ent of Soils 11
OOKPLIUC8 ..IYH &RAR. (continued)

Off.ite 8urf.ce water
di.charge au.t c08pl,
wltb.
. Clean ~ter Act
.PD88 dhcharge
regulatio.8
e "ft.8,1~aai. .polS
di.charge aust co.pl,
vith: regulations
. rederal Protection
of W8t18.d. ...cutive
Order (8.0. 11"0)
. An, soils/wast.s
that are .placed. .ust
co.pl, with ReU Land
Oisposal Rastrictions
(40 cr. Part 268)
prior to disposal
,
Off.ite surface weter
discherge .ust co.ply
with:
e Clean Water Act
.POES di.cherge
r.gulations
. Penns,lvania NPDES
discherge Dust cODply
vith: regulations
. red.ral Protection
of W8tlands C.ecutive
Order (8.0. 11990)
e Aa, soils/wast.s
that are .pl.ced" must
co.ply with IleRA Laad
Oispolal Restrictions
(40 C'R Part 268)
prior to dispolel
Off Bite surface vatar
dilcharge must coaply
vith:
a Clean Water Act
IIPOES discharge
regulations
. Pennsylvania NPDES
dilcherge .ust coaply
vith: regulations
e rederal Protection
of Wetlands S.ecutlve
Order (8.0. 119901
. Any lolls/wastel
that are "placed" must
co.pl, vith RCRA Land
Oilposal Restrictions
(40 CrR Part 268)
prior to disposal
Offsite'surface vater
discharge .ust co.ply
vith:
a Clean Water Act
.POES discharge
re'Julat ionB
a Pennsylvania NPOES
discharge .ust co.ply
with: re
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SUMMARr MA7RII fOR D£7AILED EVALUA710N
MN NANurAC7URI.o SI78
~fOUR COO.7r, P8..SYLVA8IA
PAG8 81G117
or AL7EIUIA71VI:S
  Alternat ive )     Alternative 6
Alternative I <anlaUve 2 Offaite aaaardoua Alternative 4 Alternative 5 Ofhite Incine.ation
liD Act ionl1) oa.it8 ....rdoua Waate Wane Land fill Onsite Incinerationlll Offaite of Fluff Waate, Onaite
LIat,aal D'.poaalll) Incineutionll)  Physical/Che.ieal
 Diapo..l(l)    Treat.ent of SoilaCI~
CONPLIA8C8 WI7H ""a Ccontinued)

7raat...t/ di.po.al
facilitia. 8U.t c08plr
witha Ie" ra,ulation.
and atandard. for
owner. and operatorl
of ha.ardoul wa.ta
treat..nt, Itorage,
and dbpo.al
tacilitiel 140Cra Part
264)
,
Doea not c08plr with
8PA'I Groundwater
Protection Strate'l
poUcr Ca ftIC)
Doe. not co.plr with
clolure require..ntl
Cclean cloaure,
landfill clo.ure, or
alternate clolurel.
C08pliel with EPA'.
Groundwater Protection
StrateYI Policr Ca
ftIC)CJ
7reat..nt/ diapoaal
facilitiel 8Uat c08ply
with I RCRA re,ulationa
and Itandarda tor
ownera and operatorl
ot haaardoua waIte
treataent, Itorage,
and disposal
facilitiea C40CFR Part
264)
Co.pliea with .PA'a
Groundwater Protection
StrateYI Policr Ca
ftIC)()
7reat8ent/ dispoa.l
facilitiea .uat co.ply
with: RCRA regulations
and atanda.da fo.
ownera and operators
ot haaardous waate
treat.ent, storage,
and dispoad
tacilitiea C40CFR Pa.t
264)
RCRA incinerator
re,ulations C40CfH
Part 264, Subpart 0)
Co.pliea with EPA'a
Groundwater P.otection
Strategy Policy la
'HC)I))
7reat.ent/ diapoaal
facilitiea .ust co.ply
vith: RCRA regulations
and standa.da for
ovnera and operato.s
of hazardous vaste
treat.ent, storage,
and disposal
facilities 140CFR Part
264)
RCRA incinerato.
regulations 140CFR
Pa.t 264, Subpart 0)
Co.plies with EPA's
Groundwater Protection
Strategy Policy Ca
7BCII])
Treat.ent/ diapoaal
facilities .uat comply
withl RCRA regulations
and standards for
owne.s and operators
of haaardous waste
tceat8ent. .torage,
and dispoul
facilitiea C40CFR Part
264)
RCRA incinerator
regulations C40CFR
Part 264, Subpar~ 01
Complies with ~PA's
Groundwater Protection
St rate,y Policy I a
TBCII])

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actio. objoctl".  ,roundwator.   ,round"ator.   ,roundwater.   gloundvater.   groundwatel.  
Mo. 2J.                     
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