United States         Office of
Environmental Protection   Emergency and
Agency            Remedial Response
EPA/ROD/R03-91/121
September 1991
Superfund
Record of Decision
Sealand Limited, DE

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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R03-91/121
4. TrUe and SuMMe
SUPERFUND RECORD OF DECISION
Sea land Limited, DE
First Remedial Action - Final
7. AlflhorW
9, MBrfoiniinQ OFQsinlzktion ratine And Adoicss
12. Sponsoring Organization (tone «nd Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Redpienfs Accession No.
5. Report Date
09/30/91
&
8. Performing Organization Rept No.
ia Proiect/Tssk/Work Unit No.
11. Contmct(O or Gr«nt(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
 15. Suppleinentiry Notes
 16. Abstract (Umrt: 200 words)
   The 2-acre Sealand Limited site,  a  former coal tar treatment and recycling  facility,
   is located in Mt. Pleasant, New Castle County, Delaware.   Land use in the area  is
   primarily industrial and commercial.   Current site features include a concrete  slab,
   a one-story building, an abandoned  rail spur, a gravel  road, and miscellaneous
   debris.   Ground water underlying  the  site is used as  a  source of drinking water.
   From  1971 until 1976, Adams Laboratory used the site  for  animal fat rendering
   activities.  The property was  subsequently sold to Conrail,  which cleaned up the
   property  to meet State standards  in 1979.  From 1982  to 1983-, Conrail leased the
   property  to Sealand.  Sealand  allegedly conducted treatment, processing, and
   recycling of coal to tar and off- specification creosote  wastes onsite until
   abandoning the site in 1983.   A 1983  State investigation  discovered 21 steel tanks
   or hoppers; a 10,000-gallon wooden  storage tank and 300 55-gallon steel drums,  which
   were  leaking liquids onsite; a boiler house; and various  mixing chambers and
   pressure  vessels on the abandoned site.  Additional studies by EPA and the  State
   identified organics including  PAHs, creosols, and solvents in the onsite soil,
   drums,  and tanks.  Subsequently in  1983,  EPA conducted  an emergency removal action

   (See  Attached Page)
 17. Document Analysis a. Descriptors
   Record of Decision - Sealand Limited,
   First  Remedial Action - Final
   Contaminated Medium: None
   Key  Contaminants:  None

   b. Icfentrffcrs/Open-ErKM Terms
DE
   c. COSATI Reid/Group
18. Avsilabifty Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
32
22. Price
(SeeANSI-Z39.18)
                                     See Instructions on Reverse
                                  OPTIONAL FORM 272 (4-77)
                                  (Formerly NTIS-35)
                                  Department of Commerce

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EPA/ROD/R03-91/121
Sealand Limited, DE
First Remedial Action -. Final

Abstract (Continued)

at the site and removed offsite 240,000 gallons of organic wastes from within the
wooden and steel tanks, and 320 drums.  Additionally, EPA disposed of 122 cubic yards
of solid waste, including 30 cubic yards of wooden tank debris and approximately 50 to
92 cubic yards of sludge and contaminated material offsite.  The owner voluntarily
removed 239 drums of off-specification product.  In addition, the storage tanks were
cleaned and moved, and the tank and drum storage area was capped with clay.  This
Record of Decision  (ROD) addresses onsite soil as the first and final operable unit
(OU1).  All hazardous materials contained in abandoned onsite tanks and drums were
disposed of offsite during the EPA removal action, and any remaining soil contaminants
pose low risks for humans at the site.  Based on this rationale, there are no primary
contaminants of concern affecting this site.

The selected remedial action for this site is no action.  There are no costs associated
with this no action remedy.

PERFORMANCE STANDARDS OR GOALS:  Not applicable.

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United States Environmental Protection Agency - Region III
Superfund Program  .  __
                       Record of Decision

                       Sealand Limited Site
                     Mt.  Pleasant, Delaware
                          September  1991

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Table of Contents


DECLARATION	  l

DECISION SUMMARY
1.   Site Name, Location, and Description 	  2
2.   Site History and Enforcement Activities  ....  2
3.   Highlights of Community Participation  	  4
4.   Scope and Role of the Response Action
       Within Site Strategy	  .  4
5.   Summary of Site Characteristics  	  5
6.   Summary of Site Risks	8
7.   Description of the No Action Alternative .... 12
8.   Documentation of No Significant Change 	 13

RESPONSIVENESS SUMMARY  .	14

Figures and Tables follow text

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                        RECORD OF DECISION
                       SEALAND LIMITED SITE

              	      '      DECLARATION

SITE NAME AND LOCATION

Sealand Limited Site
Mt. Pleasant, Delaware

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the
Sealand Limited Site,  in Mt. Pleasant, Delaware, which was chosen in
accordance with the requirements of the Comprehensive  Environmental
Response,  Compensation,  and  Liability Act  of 1980  (CERCLA),  as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA)  and,  to  the  extent  practicable,  the  National  Oil  and
Hazardous  Substances  Pollution  Contingency  Plan  (NCP).    This
decision document explains the factual and legal basis for selecting
the remedy for this Site.

The  Delaware Department  of  Natural  Resources  and  Environmental
Control  has not  yet concurred with  the selected remedy.   The
information supporting this remedial action decision is contained in
the Administrative Record for this Site.

DESCRIPTION OF THE SELECTED REMEDY

The  selected remedy  for  the  Sealand  Limited Site  is  No Action.
Under this alternative, no further action will be taken at the site.
Although not required by EPA policy or guidance,  a review of the
condition of the Site  will be conducted in five years to verify that
no unacceptable hazards  are posed by conditions which  then exist at
the Site.

DECLARATION STATEMENT

Emergency  removal activities  that  were  taken  at the  Site  were
sufficient to mitigate threats posed by the Site to human  health and
the environment.   Therefore,  no further  action  is  necessary  to
ensure protection of human health and the environment.
   Edwin B. Erickson                            Date
   Regional Administrator
   Region III

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                         DECISION SUMMARY

1.   Site Name. Location, and Description

     The  Sealand  Limited,  Inc.  Site  (Site)  is  located  in Mt.
Pleasant, New Castle County, Delaware,  several hundred feet east of
the  intersection  of  Routes  896  and  71/301  (Figure   1).    The
Chesapeake and Delaware Canal is approximately 2 miles north of the
Site.   The  Site property is approximately 2 acres  in size and is
currently owned by the Consolidated Railroad Corporation  (Conrail).
The Site is rectangular in  shape and is bordered on the west by an
active Conrail track and on the north and east by a 15-acre parcel
of land owned by  Tilcon Minerals, Inc.   On the south, the Site is
bordered by Routes 71/301.   Private residences and light  industrial
and commercial establishments are also located to the south and west
of the Site.

     The Site is presently inactive and unoccupied following an U.S.
Environmental  Protection Agency (EPA)  Emergency  Removal  Action
conducted  in late  1983  and  early  1984.   Current  Site features
include a concrete slab,  a one-story  building,  an abandoned rail
spur, a gravel road, and miscellaneous debris.  A one  to  three foot
thick clay cap which was placed  over the process area  following the
removal action is intact and well vegetated.  Shallow ground  water
flows in a north- northeasterly  direction,  toward Joy  Run, a stream
located 1000  feet north of the  Site.   Ground water  is  used as a
source for domestic water supplies.  The nearest residences are less
than 500 feet from the site.

2.   Site History and Enforcement Activities

     According to EPA records, industrial activity at the  Site  began
in 1971 when Adams Laboratory operated an animal fat  rendering  plant
on the property.   Sometime  prior to  1976,  Adams Laboratory ceased
operations at the facility.  In 1976,  Conrail acquired the property.
A contractor hired  by Conrail cleaned up the  Site to the Delaware
Department  of  Natural  Resources   and  Environmental  Control's
(DNREC's) satisfaction in 1979.

     In August 1982, Conrail leased the Site to Sealand Ltd.  for the
stated purpose  of waste oil recycling.  The  Site  was operated by
Sealand  Ltd.  from  August   1982  until August  1983.   During that
period, the operations consisted of the treatment and/or  processing
of coal tars and  other similar  materials referred to as No.  4 and
No. 6 oiL»,,oil/gas  tar,  off-spec creosote, ink oil waste, and oil
cuff (an oil and water mixture).  The operators allegedly accepted
the various materials, separated the water,  and  transferred the
liquid materials by tank truck to Burke-Parsons-Bowlby Corporation.

     Sealand Ltd. abandoned the Site in August 1983.  At  that  time,
the Site  contained 21  steel  tanks  or  hoppers,  one  10,000-gallon
wooden  storage  tank, approximately  300 55-gallon  steel drums, a
boiler house, and various mixing chambers and pressure vessels.  An
investigation of the Site conducted  by the DNREC concluded that the

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wooden storage tank and numerous 55-gallon drums were  leaking their
contents onto the ground surface.  The observed leaking liquids were
described  by DNREC  representatives  as  black, viscous,  tar-like
substances.  .Laboratory analysis of  samples  collected in October
1983 by the DNREC and EPA from tanks,  drums, and soils reported the
presence  of  polynuclear  aromatic organic   compounds,  creosols,
solvents, and other organic compounds.

     In  December 1983,  EPA initiated  an  Emergency Removal Action
under  the  Comprehensive Environmental Response,  Compensation and
Liability Act  (CERCLA).   The action  consisted of  the removal of
240,000 gallons  of coal tar which had been contained  in the wooden
and steel tanks, 320 drums,  and approximately 122 cubic yards of
solid waste.  The solid waste consisted  of 30 cubic yards of the
wooden tank debris and anywhere from 50 to 92  cubic yards of sludge
and contaminated material.  Parboil Company voluntarily removed 239
drums of off-spec product  (EPA OSC report mentions  two quantities,
238 and 239) from the site in December 1983.   In addition, storage
tanks were cleaned and moved,  and the tank and drum storage area was
capped with clay.  The extent of the capped area is shown in Figure
2.

     None of the potentially  contaminated soil located within the
storage  tank area  was  removed from the  Site.    Soil  from the
excavation  of  an L-shaped  trench  along  the  southern and western
boundaries of the storage tank area was also left  onsite within the
subsequently capped former tank area.  According to EPA records, the
trench was constructed along the railroad  side of the Site to aid in
minimizing any horizontal movement of  contaminants. The trench was
filled with clay, and it and soil within the storage tank area were
then covered  with l  foot  of  clay and 6  inches of topsoil.   Six
groundwater  monitoring  wells  were  also  installed during  the
Emergency Removal Action.   Available information indicates that
there were two wells existing onsite prior to  the emergency action.
The removal action was concluded in June  1984.

     The following  is  a chronology  of  EPA  and  DNREC regulatory
actions with regard to the Sealand Ltd. operations:

     -  August 1983:  DNREC  site visit  following  abandonment of
     Sealand Ltd. operations

     -  September 1983:  DNREC  request to EPA to  perform CERCLA
     preliminary assessment

     - September 1983: EPA performs visual site inspection

     - October 1983: EPA site assessment

     - November  1983 to June  1984: EPA Emergency Removal Action

     - August 20, 1985:  Civil Compliant filed  by the United States,
     U.S. v. Consolidated Rail Corporation, et al.. Civil No. 85-502
     MMS, pursuant to Sections  104 and 107 of CERCLA.

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     -  September 2,  1986:  Amended Civil  Complaint filed  by the
     United States in U.S. v. Consolidated Rail Corporation, et al..
     Civil  No 85-502  MMS,  pursuant  to Sections  104  and  107  of
     CERCLA. •—    -  --

     -  June  28,  1988: Sealand Limited  Site proposed  for National
     Priorities List  (NPL)

     -  December  30,  1988: EPA and Sealand Respondents  - National
     Industrial Services, Inc; Coopers Creek Chemical Corp.; Casie
     Ecology  Oil Salvage Co.,  Inc.; The Times Journal Company;
     Parboil  Company; Philadelphia Gas Works;   Consolidated Rail
     Corporation;  Public Service Electric and  Gas Company; Chem
     Clear, Inc.; Koppers Co.,  Inc.;  Globe Newspaper Company; The
     Washington  Post  Company;  Penn   Fuel  Gas,   Inc.;  USX  - sign
     Administrative   Order  on   Consent  for  RI/FS  (Docket  No.
     111-89-08-DC).

     -  January 30,  1990:  EPA  and Sealand Respondents enter  into a
     Partial  Consent  Decree for Response Costs  (Civil  No.  85-502
     MMS) .

     - August 30, 1990 Sealand Limited formally added to NPL


3.   Highlights of community Participation

     The RI/FS Report and the Proposed Plan for the  Sealand, Limited
Site were released to  the public for comment on July 26, 1991.  In
accordance with  Section  117(a)  of the Comprehensive Environmental
Response,  Compensation  and Liability  Act (CERCLA)  of  1980,  as
amended by the Superfund Amendments and Reauthorization Act of 1986,
these  two documents  were  made  available to the public  in the
Administrative Record maintained  at the EPA Docket Room in  Region
III, at the Middletown Public Library,  and at Townsend's, Inc. in
Mt. Pleasant,  Delaware.   The notice  of  availability  of these two
documents was published in the Wilmington News Journal on July 26,
1991.  A public comment period on the documents was held from July
26, 1991 to August 24, 1991. In  addition,  a public  meeting was held
on August 6,  1991.   At this meeting,  representatives from EPA and
the DNREC answered  questions  about conditions at the site and the
remedial  alternative  under  consideration.   A  response  to the
comments  received  during  this  period  is   included  in  the
Responsiveness Summary, which is part of this ROD.

4.   Scope and Role of the Response Action Within  Site Strategy

     EPA  first identified  the  need  to take action at  the Site
following the abandonment of the recycling  operation.   EPA then
conducted  the emergency removal  described   in  the  Site History
section of the Decisio"  snirnnayy.   Following  the completion  of the
removal action, the site  was listed on the National Priorities List,
and an  Remedial Investigation  (RI)  was undertaken by  a group of
PRPs.   Upon reviewing the RI  report  and the Site  risk assessment,

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EPA has determined that the Site does not pose  a threat to human
health and the environment, and that no further action is required.

5.   Simrmarv #f- Site Characteristics

     The  Site  is  located  within the Coastal  Plain Physiographic
Province  which  is characterized as a series  of  unconsolidated or
partially  consolidated sands, gravels,  silts,  and clays.   These
sediments  form  a  wedge which dips  and thickens  to the southeast.
According  to  Sundstrom and  Pickett (1971),  the  thickness  of the
coastal plain sediments is  approximately 700 feet in the vicinity of
the Site.   The geologic formations in the vicinity of the Site are,
from  youngest  to  oldest:  Columbia,  Mt.  Laurel,  Marshalltown,
English town, and Merchantville Formations. The Pliestocene Columbia
Formation  occurs  as a  thin cover over  the majority of the area in
the vicinity of the Site.

     The vadose zone at the Site is comprised of sediments of the
Columbia  Formation.  The Columbia Formation consists primarily of
unconsolidated  brown,  fine to  coarse  (0.1  to 1.0 mm),  subround,
moderately to poorly sorted sand.  Minor components include silt and
fine gravel.  In  some  areas,  the vadose  zone sediments consist of
fill containing trace  amounts of coal  and/or cinders which may be
attributable to the adjacent rail lines.   These minor constituents
caused the sediments to appear grey to dark grey.  The vadose zone
was generally 4 to 5 feet thick onsite.

     The  aquifer  beneath the  Site  consists of  the Columbia, Mt.
Laurel, Marshalltown,  and additional underlying formations.  These
formations  are  generally   hydraulically interconnected and  are
usually referred  to as the  water table aquifer.   No  laterally
continuous  confining  layers  are  in  evidence  within   the  depth
encountered by  onsite  wells.   This indicates  that there  are no
confining  layers  separating  the  water  table aquifer  from deeper
water  bearing  zones.     However,   the   Marshalltown  Formation,
encountered  at   approximately  93   feet below  grade,   contains
significant amounts of fine grained materials  (silt and clay) which
would impede groundwater flow and is thus considered an aquitard in
this setting.   Sundstrom  and Pickett  (1971)  do  not  consider the
Marshalltown Formation to  be an  aquifer and it  is not  generally
mapped as  such.  For the purpose of the Remedial Investigation  (RI),
the water  table  aquifer was considered to extend from the  surface of
the water table to a depth of 93  feet below grade.

     Grou»dwater  movement  at  the Site  has a downward component of
flow indicating that the Site is in a  groundwater recharge area.
Flow is considered to move  toward Joy Run northeast of the Site and
regionally to the C &  D Canal approximately  2 miles  north of the
Site.   The nearest downgradient residential well  is located on the
opposite  side of  Joy  Run;  the nearest commercial well is located
approximately 200 feet east of the  site.

     As part of the RI, onsite soil samples were  collected in March
and June  1990 to  delineate the  horizontal  and  vertical  extent of

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soil  contamination.    Soil  samples  were  collected  from  eight
locations within the former drum and storage tank area, four other
onsite areas and one additional soil sample location adjacent to the
east  side of^the  concrete pad.    In  one  boring,  no sample  was
collected because no sample interval of unsaturated soil was present
between the clay cap and the top of the water table.

     A  total of 24 soil  samples were  submitted  for laboratory
analyses,  including  three field  duplicate  samples.    Table  1
represents a statistical summary and frequency of detection for the
RI soils  analytical data.   The  distribution of  compounds detected
onsite  is  presented  in  Figure  3.    All  analytical  data  and
accompanying documentation is contained in the RI report.

     Twenty-three soil samples  were analyzed  for volatile organic
compounds  (VOCs).    VOCs were  found  in  onsite  soil samples  in
concentrations  ranging from  non-detect  to 220  ug/kg  (parts  per
billion).   Methylene chloride  was found  in  all  23  soil samples
(5-220 ug/kg); however, this compound was found to be a laboratory
contaminant in all but  one of the samples analyzed for VOC.  Acetone
was found in 20 of 23 soil samples (5-220 ug/kg); however, all but
one of these contain data validation qualifiers.  Benzene was found
in 1  of 23 samples  (4  ug/kg).    2-Hexanone was  found in  1  of 23
samples  (110 ug/kg).   Many of  the  values  reported for individual
VOCs were estimated  values below the detection limit established for
the compound in question.   These estimated values were considered
detected in this discussion of results.

     Semivolatile  organic   compounds  were  found  in  onsite  soil
samples at concentrations ranging from non-detect to 23,000 ug/kg.
Of the  24 Target  Compound List  (TCL)  list  semivolatile organic
compounds, all  24  were found in  at least one sample  and 22 were
found  in  at  least three  samples.    The compounds  found  most
frequently and at the highest  concentrations include naphthalene (8
of 24  samples,  with the highest concentration of 20,000 ug/kg),
2-Methylnapthalene  (8  of  24   samples,   up  to  14,000  ug/kg),
phenanthrene (11 of  24 samples, up to 22,000 ug/kg),  fluoranthene (9
of 24 samples,  up to 23,000 ug/kg),  pyrene  (10 of 24 samples, up to
22,000 ug/kg),  and other isomers of fluoranthene and pyrenes ranging
up to  20,000 ug/kg.   The  highest  concentrations  of semivolatile
organic compounds were seen in the borings that had been completed
below   the  clay   cap.   Total  semivolatile   organic   compound
concentrations of up to 169,840 ug/kg were detected between the clay
cap and the water table.

     Of tEi~19  metals analyzed,  only antimony was absent from any of
the samples.  Cyanide  was  detected in  two samples at 0.59 and 1.6
mg/kg.  Figure 3 shows  the  distribution of  several  metals  in onsite
soil samples.   Arsenic is present  at  concentrations ranging from
non-detect to  9.0 mg/kg.   Chromium was present  in all samples at
concentrations  ranging from  9.6 to 58.4  mg/kg.   The horizontal
distribution of chromium appears to be random.  The concentrations
of chromium appear slightly lower in the deeper samples than in the
shallow  samples.    Lead was  present  in   onsite  soil  samples in

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concentrations ranging from 6.1 to 100 mg/kg.  Lead was present in
all samples.  In a majority of samples the concentration of  lead was
lower  in the  deeper samples  than  in  the  shallow  samples.   No
horizontal distribution pattern is evident.   Mercury was present in
15 of  18  samples in concentrations ranging from non-detect to 3.9
mg/kg.

     Table  2  presents   a  statistical  summary  and  frequency  of
detection  for  groundwater analytical data.   The  distribution  of
selected  compounds  detected  is  presented  in Figure  4.    All
analytical data  and accompanying documentation is contained in the
RI report.

     Two  samples showed the presence of VOCs above the  level  at
which they could be quantified by laboratory equipment.  Methylene
chloride was detected in a sample from an offsite well  at 11.0 ug/1
and acetone in a sample from an onsite well at 10.0 ug/1.  Acetone
was present in the Trip Blank for April 26 at a concentration of 210
ug/1.  Methylene chloride was present in the Trip Blank  for  April 27
at l.O ug/1.   No other well water samples  showed  the presence of
VOCs.  Therefore,  it seems likely that  the presence of methylene
chloride  and acetone in ground water is indicative  of laboratory
contamination rather  than  of their presence  in onsite or offsite
wells.

     Few semivolatile organic compounds were detected  in groundwater
samples.   Bis(2-ethylhexyl) phthalate was detected at  an estimated
concentration of 2.0 ug/1 in one offsite well sample.  Naphthalene
was detected at estimated concentrations of 4.0 ug/1 in two onsite
well  samples.   No  other  well  samples   showed the   presence  of
semivolatile organic compounds.

     Twenty  metals  plus  cyanide  were   analyzed  in filtered  and
unfiltered groundwater samples from offsite and onsite wells.  The
presence of beryllium, cobalt, copper, silver, and zinc in some of
the  filtered and unfiltered  samples was questioned  during data
validation because the level at which they were detected was below
the detection limit used during analysis. Of the 20 metals tested,
only antimony,  barium,  beryllium, chromium and mercury  were not
present  above  their  respective detection  limits  in  any sample.
Cyanide was detected in filtered samples at 25.7 ug/1  and 19.5 ug/1.
 Cyanide was also detected a number of unfiltered samples.  Figure
4 shows  the distribution  of  several metals and cyanide  in both
onsite  and  offsite  monitoring   wells.     Iron  is  present  at
concentrations ranging from non-detect to 45,000 ug/1.  Manganese
was present  in  all  samples at concentration ranging from 17.8 to
6,360 ug/1.  The distribution of nickel  appears to  be limited to
onsite wells only.   The concentrations of  nickel  ranged from
non-detect to 789 ug/1.

     A review  of  the  compounds  detected  during  the  soil  and
groundwater investigations indicates that the chemicals of potential
concern   are  the   semivolatile  organic   compounds,  including
polynuclear aromatic hydrocarbons (PAHs), and two metals, nickel and

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mercury  in soil.   The remaining  compounds in  soil and  all  the
compounds  in groundwater  were  detected at  low frequencies  and
concentrations, at isolated locations, or at concentrations within
the range  of .background.   PAHs tend to  bind to  soil material  and
generally do not contaminate the groundwater.

     The  most  likely  potential  receptors  under  current  site
conditions are children exposed to shallow soils while trespassing
on  the Site;  under a  potential future use  scenario,  potential
receptors  are  workers  that  may   be   exposed   to  soil  during
construction activities.  The exposure pathways include ingestion of
soil and dermal  absorption of contaminants.  The presence of  the
clay  cap  currently  restricts  access   to  Site  contaminants  by
trespassers.  However,  construction workers  would be  exposed to the
relatively higher levels of contamination present in  the subsurface
soil.

     The nearest surface water, Joy Run, is located  1,000 to 1,500
feet north of the Site.   Soil within the  former tank  area is capped
so there is no source of surface contamination to  the stream.  There
is no visible evidence of intrusive activities or disturbance to the
cap.    There  are  currently  other  sources  of  surface  runoff
contamination  from  a   former  asphalt  manufacturing  facility,
including several tar spills and an abandoned  tank trailer, which
are between  the Site and  Joy Run..   A dump area  (which consists
mainly of discarded highway materials) located on the banks of Joy
Run is another potential source  of contaminated subsurface water.
These areas were not evaluated during the RI as they  are not a part
of the Site.

6.   Summary of Site Risks

     The risk  assessment  for  the  Sealand  Site  was conducted in
accordance with EPA protocols.  The  risk  assessment first evaluated
the chemicals  found in the soil and groundwater at the  Site  and
determined which Site-related chemicals are a potential concern to
human  health and the  environment.    Next,  it considered whether
humans or the environment are currently exposed to these chemicals
or will  be at some time  in the future.   In the final  step,  the
concentrations of the chemicals at the point of exposure were used
to estimate the potential for an adverse effect on human health or
the environment.

     The chemicals  of potential  concern for the  risk assessment
included Jill  semivolatile  organic  compounds  and  two inorganics,
nickel and* mercury,  in the soil.    The  selection of semivolatile
organics  is supported  by  the  analytical  data  collected during
previous investigations  and the history of Site  operations.   The
metals  are  included  based  on  their frequency  of  detection at
concentrations  above background.    In  soil,  the  eight  volatile
organic  compounds detected have low  frequency  of  detection  and
distribution.   The  inorganic parameters,  with  the exception of
nickel and mercury,  are within the range of background, or  appear to
be isolated occurrences unrelated to activities which took place at

                                 8

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the  Site.   No  chemicals  of potential concern  were identified in
groundwater samples.  The volatile and semivolatile  detections were
low in frequency and concentration and the inorganic parameters are
within Site-related background concentrations.

     The  potential  receptors,  both  current  and  future,  were
evaluated.    For  current  exposure,  the  most likely  potential
receptors  are  children  exposed  to  shallow  surface  soils while
trespassing on the Site on an infrequent  basis.  For the future use
of the Site,  the potential receptors are workers that may be exposed
to   soil  from  all  depths   during   construction   activities.
Observations during the remedial investigation and evidence of Site
use  support  an  exposure  pathway of   trespassers,  particularly
children.

     There are low density private residential areas located to the
east  of  the  Site.   Private residences  and  light  industrial and
commercial establishments are located to the  south  and west of the
Site.  Bordering the Site to the  north, a  15-acre  parcel of land
owned by Tilcon Mineral  Inc.  contains miscellaneous equipment and
debris.  There is no evidence of consistent use of the  Site  such as
dirt bike trails to suggest that children from the nearby residences
play at the  site on  a  regular  basis.   There  is evidence, however,
that  pre-teenage children  are  potentially exposed while walking
along the active railroad bed.  Although there  is no evidence that
these children  actively play on the Site,  the risk assessment was
based on a worst case  assumption that there is regular use of the
Site by area children.

     A future use scenario was  developed considering  exposure by
workers during construction of a manufacturing  facility.  The Site
is zoned for manufacturing uses only.  The zoning cannot be changed
to  residential   because   a  60-foot   frontage  is  required  for
residential  use  and  the  Sealand property  has only  57  feet  of
frontage.   Property to  the east  of  the Site is  also  zoned for
manufacturing use.  The  active  railroad bordering one side of the
Site  significantly reduces the  likelihood  that the Site will be
developed for residential use.

     Exposure pathways include all the various ways  in  which humans
may come in contact with the chemicals of potential  concern, either
currently or at some time in the future.   Identification of exposure
pathways is developed from a fate and  transport evaluation followed
by  an analysis of  the  likelihood  that  human  or environmental
receptors—will contact  the chemicals  and  the way in  which any
potential contact  may  occur.     The fate and transport evaluation
considers the properties of the chemicals of potential  concern, the
media in which the chemicals are found, and the likelihood that the
chemicals will persist and/or migrate to other  media.

     The focus of the fate and transport study  was polynuclear
aromatic  hydrocarbons  (PAHs)   in  soil  because  these   chemicals
comprise 17 of the 26 chemicals  of potential  concern.  PAHs, which
are mixtures of organic chemicals made up of  benzene rings, are

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by-products  of  the  incomplete  combustion  of organic  material.
Although combustion of petroleum products represents a major source
of  PAHs in  the environment, combustion of any  organic material
including wood,- coal,- charcoal  and even garbage can result in ash
and smoke containing  PAHs.

     The  chemical  properties  of  individual   PAH  compounds,  in
particular  their solubility  in water,  depend on  the  number  of
benzene  rings.    Chemicals  with  few  benzene  rings  (such  as
naphthalene  with two  rings)  tend to  be the most  water soluble,
mobile  in  the groundwater and also susceptible to  degradation by
bacteria.   They are also less toxic than  the  higher weight PAHs.
PAHs with higher numbers  of  benzene rings (such as benzo(a)pyrene
with five rings)  tend to  remain strongly bound to soil particles,
especially  particles  high  in  organic  content,  and are  highly
water-insoluble.  These higher weight PAHs are also more persistent
and are degraded slowly by bacteria.

     Because  chemicals of potential concern were not detected in
Site ground water, the soil represents the only  exposure pathway for
these chemicals.  The media of concern  is soil and the chemicals of
potential  concern  are  all   the  semivolatile  organic  chemicals
detected and nickel and mercury.  The exposure pathways identified
are (1)  ingestion of soil and (2) dermal absorption of contaminants.
In  risk assessment,  it is  seldom possible to  measure  a specific
dosage  for  each identified  exposure pathway.  As a  result,  it is
necessary to  estimate the dose  based upon a series of assumptions
such as how much soil the  average person ingests.  These assumptions
were developed  from  the  most  current  Superfund Risk  Assessment
Guidance documents.  The assumptions used in calculating the exposure
for each pathway are  presented in Table  3.

     In order to estimate the excess lifetime cancer risk associated
with exposure to potentially carcinogenic chemicals, cancer potency
factors (CPFs) have been developed by EPA's Carcinogenic Review and
Verification  Endeavor  (CRAVE) Workgroup.   CPFs  are  expressed in
units of (mg/kg-day) ~l and are multiplied by the estimated intake of
a potential carcinogen (expressed  in mg/kg-day).  This calculation
provides an upper-bound estimate of the excess  lifetime cancer risk
associated  with exposure  at that  intake  level.    Cancer  potency
factors  are  derived   from  the   results of  human epidemiological
studies  or chronic  animal  experiments to  which animal-to-human
extrapolation and uncertainty factors  have been applied.

     The .jsarcinogenicity  of some PAHs  has  been  known   to  the
scientific community  since the late 1800's and  a large database has
been developed regarding the  mechanism  of action of those PAHs which
are  or  appear  to be  carcinogens.   In  this regard, the  EPA has
performed a study which is based  on a biological model of cancer and
calculates  a best  estimate  of  the CPF  for the most  well known
                                10

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carcinogenic   PAH,   benzo(a)pyrene1.   In   addition,   this  study
developed CPFs for other carcinogenic PAHs, and based these values
on   a   comparison  of   their  toxicities  to  the  toxicity  of
benzo(a)pyrene~.  This.approach is in accordance with EPA's policy of
utilizing best science  to  develop  risk estimates.   Region III has
adopted this practice to support the risk assessment for  this Site.

     Excess lifetime cancer risks are determined by multiplying the
intake  level with  the  cancer  potency  factor.   These  risks are
probabilities that  are  generally expressed in scientific notation
(e.g., 1 x 10~6 or 1E-6).  An excess lifetime cancer  risk of l x 10~6
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.

     The cancer risk associated with each contaminant of  concern in
each exposure pathway for both current  and future use scenarios are
shown  in  Tables 4  and  5.   For the  sum of  the  current exposure
scenarios, the cancer risk associated with  trespassing on the Site
is 3 x 10~7.   Under the future use scenario, the cancer  risk  is  1
x 10~7.   These risk levels are below the 1  x  10~4  to 1 x 10"6 risk
range that EPA believes to represent  acceptable risk.    Therefore,
the  Site  does  not pose  an  unacceptable  cancer   risk  to exposed
individuals.

     Reference  doses   (RfDs)  have  been   developed  by EPA  for
indicating the potential for adverse health effects from exposure to
chemicals  exhibiting noncarcinogenic  effects.   RfOs,  which are
expressed in  units of mg/kg-day,  are  estimates of lifetime daily
exposure levels  for humans,  including sensitive individuals, that
are not likely to  result in an appreciable risk of adverse health
effects.  Estimated intakes  of chemicals from environmental media
(e.g., the amount of a chemical ingested  from  contaminated drinking
water) can be compared to the RfD.   RfDs  are derived  from human
epidemiological  studies or  animal studies to which  uncertainty
factors have been  applied  (e.g., to account for the use of animal
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.

     The numerical  value used to evaluate noncarcinogenic risk is
the Hazard Index (HI).  The HI is the ratio of the  exposure dose to
the RfD and is calculated by dividing dose (chronic daily intake or
GDI)  by tbs RfD.   The HI is not strictly an estimate of the risk,
but  a  number which compares  GDI  to  a  level considered  to have
limited potential  for lifetime health effects.   Hence,  HI values
greater than 1 indicate  that exposure exceeded the  acceptable daily
     1 Comparative potency approach for estimating the cancer
risk associated with exposure to mixtures of polycyclic aromatic
hydrocarbons (1988), Interim Final Report, Contract No. 68-02-
4403, ICF-Clement Assoc., Fairfax, VA.

                                11

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level while HI values less than 1 show that exposure is lower.

     Similar to cancer risks, the HI  values for each chemical are
added together_£o assess the overall potential for noncarcinogenic
effects.  This approach was developed by EPA based on the assumption
that  simultaneous exposures  to numerous  chemical compounds  can
result in an adverse health effect.   Tables 6 and 7 present the HI
associated with each chemical and pathway for the current and future
use  scenarios.   The  maximum  HI  values  for  all chemicals  for
ingestion and dermal contact added together, 0.007 for current use
and 0.006 for future use,  are more than 2 orders of magnitude below
the trigger  HI value of 1.  Therefore,  potential  noncarcinogenic
health  effects for  all  pathways  under  current  and future  use
conditions are expected to be negligible.

     Areas that represent some  uncertainty in the risk assessment
include carcinogenic and  non-carcinogenic  effects  of chemicals in
mixtures and the presence of any unknown chemicals.  There is very
little information  on  the toxicological effects of  mixtures.   In
some cases,  the presence of several chemicals together may result in
an enhancement of  the overall toxicity (synergistic) effects.  Other
chemicals  mixed  together  may  result  in  fewer  toxic  effects
(antagonism).   Lastly, the  chemical  analyses were  for  specific
parameters.   The  chemicals  evaluated  are  those  that have been
identified as the most important chemicals  in air,  soil, and water.
The possibility exists that other chemicals are present that were
not detected.   However, the chemicals which were found onsite are
reflective   of  the  activities which  took  place  during  Site
operations;  it does not  appear  likely  that  other sources  of
contamination exist at this time.

     The  environmental risk  assessment  conducted  for  the  Site
concluded  that there  are no  complete  exposure  pathways.    The
contaminated  soils  are   capped and  there  are no   chemicals  of
potential concern in the  groundwater.   The nearest environmental
receptor of  concern, Joy  Run,  is potentially impacted by multiple
sources of contamination (not related  to Site activities) including
tar spills,  numerous piles of asphalt and highway debris between the
Site and the creek,  and road  bed materials dumped along the creek
banks.

7.   Description of the No-Action Alternative

     Under the Super fund Program, studies are conducted at NPL sites
to  characterize the  nature  and  extent of contamination and to
determine the most feasible cleanup approaches.  During the course
of the removal action that took place  at  this site, EPA disposed of
hazardous materials contained in tanks and drums abandoned onsite.
Leakage or  spillage  which took place prior to the removal action
during  Sealand's  short   tenancy at  the  Site  accounts   for any
contaminants currently onsite.  The levels  of  contaminants present
beneath the  site cap do  not pose  an unacceptable  risk  to human
health or the environment.
                                12

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     Long-term management  controls  relative to maintenance of the
clay cap are not considered necessary since even under  a worst case
scenario of cap  erosion  or loss of  integrity and subsequent human
exposure, a significant health threat would not  result.  Remaining
soil  contaminant levels are  within EPA's  acceptable  health risk
range,  even  considering  a  lifetime  of  residential  exposure.
However, EPA  will conduct a  five-year review to verify  that the
selected  remedy  remains . protective  of  human health  and  the
environment.

     EPA's selection of  the No  Action alternative under CERCLA is
not to be construed as a recommendation or indication that the State
of Delaware should not seek to undertake additional cleanup of the
Site pursuant to its authorities under State  law.   EPA considers
action to be  warranted  at a  site when the calculated cancer risk
exceeds one in  ten  thousand.   At the  Sealand  Site, an individual
would have less  than  one in one million chances  of developing cancer
as  a  result  of exposure  to  site  contamination.    Therefore,  in
accordance with the  National Oil and Hazardous  Substances Pollution
Contingency Plan (NCP),  no action is warranted.   However, the State
may have requirements that differ  from EPA's,  under which it may
chose to take further action.

8.   Documentation of No Significant Change

     The Proposed Plan for the Sealand Site was released for public
comment on  July 26, 1991.    The public comment period  closed on
August 24, 1991.  EPA reviewed all written comments submitted during
the public  comment  period.   A  summary of the  comments  received
during the public comment period is  included in  the Responsiveness
Summary  section of  this  Record of  Decision.    Based on  these
comments, it  was determined  that no significant change  to EPA's
proposed remedy, as  originally identified in the Proposed Plan, was
necessary.
                                13

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                      RESPONSIVENESS SUMMARY


1.   Overview

     On August  6,  1991,  EPA held a public  meeting  to present the
findings of  the remedial  investigation and  to solicit comments on
the Proposed Plan  issued  on July 26,  1991.   Residents did express
some   concern   over  the   potential   for  future   ground  water
contamination,  in particular, contamination that would potentially
reach their private wells  in the time prior to the five year review.
EPA  explained  that the  contaminants  of  concern  are  relatively
insoluble in water, and that no ground  water contamination has been
confirmed  in onsite  wells.   This suggests  that  domestic  water
supplies are not threatened by the site.

     The state  has  maintained that  the Site does pose a potential
threat to local ground water supplies, and has reserved its right to
take some action at the Site under its  Hazardous  Substances Control
Act.   The  potentially responsible  parties  questioned the State's
position relative  to ground water  issues.   The full text of the
State's response is  given  in  Section  3  of  this  Responsiveness
Summary.

2.   Background on  Community Involvement

     During community interviews and public  meeting  held throughout
EPA's remedial  response activities, the local populace indicated a
relatively low level of interest  in the Site.  Those  most interested
were residents who lived close to the Site,  or in a  new development
located approximately 1/2 mile from the Site.  Most residents were
primarily  concerned  about  the  quality  of  local   ground  water,
although some   were  also  concerned about their  property  values.
Workers at  Townsend's,  Inc., a  granary  located approximately 200
feet from the Site,  were interested in following EPA's activities at
the Site,  as they have been  since the time Sea land Limited began its
operation.    Townsend's employees frequently  complained  to local
health officials about odors released  during  Site operations.

     The Sealand Site property  is  bounded by  an active railroad
spur, a highway,  and a parcel of property  owned by  Tilcon, Inc.,
which is littered with road paving materials and a tar spill.  Local
businesses^-which include the granary, a small shopping plaza, and
Summit Airfield, are  apparently  unaffected  by the Site.  Once the
Site has been delisted, its affect  on  local property  values should
be  negligible.    No short- or  long-term  health risks  have been
identified respective to exposure to the Site.
                                14

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3.   Summary of Public Comments and Lead Agency Response

     Oral Comments Received During the Public Meeting

     Comment:   The  primary concern  expressed during  the public
meeting involved the potential for future ground water contamination
at the site.   At  least one resident stated that because EPA would
not  be  re-sampling  ground  water  wells for  five  years, residents
could  potentially be  consuming contaminated  ground  water  for  a
number of years before this was recognized.

     EPA Response:  The primary contaminants of concern at the Site,
polynuclear aromatic hydrocarbons (PAHs), are relatively insoluble
in water and tend to adhere to soil particles.  During  the RI, the
only  PAH detected   in  ground  water  was  naphthalene, which  was
detected in  two  onsite wells at the  estimated concentration of 4
parts  per  billion,  two  orders  of   magnitude   below levels  of
regulatory concern.   Even using the most sensitive  analytical method
available at the current time,  none  of the potentially carci/nogenic
PAHs were detected in ground water onsite.

     The clay  cap present  at  the  Site reduces the infiltration of
precipitation  through the  contaminated  soil.    In  addition,  if
contaminants were to enter  the ground water, the concentration of
these contaminants would be reduced as contaminants moved offsite
and became diluted.   As the nearest downgradient resident is located
over 1/4 mile  from  the site, it does not appear  that  residential
wells are threatened at  this time,  or will  be in the future.   If
data  collected  at   the  time  of  the  five  year review  suggest
differently, EPA will take appropriate action at  that time.

     Written Comments Received Purina the Public  Comment Period

     Comment:  EPA received a letter  from BCM Engineers, the PRP's
consultant,  concerning a statement in the Proposed Plan reflective
of the State's position relative to  the potential  for future ground
water contamination  at the  Site.   Specifically,  BCM questions the
State's  position  that  the  potential  for  future  ground  water
contamination  exists when  the  known behavior   of  PNAs  and  the
historical Site sampling data indicate the contrary.

     EPA Response:   EPA requested that DNREC provide a  response to
this comment.  A  September 9, 1991 letter  from  the State Project
Manager to the RPM states as follows:

     "The^State concurs  that laboratory  evidence reveals no
     contamination  of groundwater  has occurred  up  to now.
     However, due to the shallow  water table aquifer and its
     contact  with   contaminated  soils,  it  is  likely  the
     contaminants  presently   retained  in  the  soils  will
     eventually leach into the groundwater.  ([T]he soil boring
     logs from S-04, S-05, S-06,  S-07,  S-08, S-10  and S-ll
     indicate the presence  of  the water table aquifer  in the
     contaminated soils.) The presence of the clay cap will aid

                                15

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     in preventing infiltration of water into the contaminated
     batch thus minimizing the risks of the contaminants being
     introduced in this manner.

     "We maintain  that long term contact of  the groundwater
     with  the  contaminated  soils  will  likely  result  in
     contamination  of the groundwater.   Consequently  it is
     imperative the remediation of the  contaminated soils be
     conducted  in  a timely manner.   Furthermore,  it  is our
     opinion that  removal of the pollution source  occur now
     before it migrates into the groundwater of the surrounding
     area is a better alternative  than to study the site later
     and recommend  a clean up  after  the problem has  become
     larger in magnitude and scope.11 ,

     EPA does not agree with DNREC's assessment of the Site.  Based
upon the information available at this time,  EPA believes the Site
does not pose a threat to  human health or the environment, nor does
it pose a threat to ground water  resources  in the vicinity of the
site.  EPA does not, however, question the State's authority to take
action at this Site in accordance  with State law  to address what it
believes is a threat.
                                16

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     Attachment

     The Community  Relations activities conducted  at  the Sealand
Limited Site to. date have included the following:

     • January 23, 1990: Public meeting held following approval of
     the RI/FS  work plan  to inform  the public  of investigatory
     activities planned for the Site.  Fact sheet issued.

     • January 1991: EPA conducted community interviews to update
     community relations plan.

     • March, 1991: Fact sheet  issued providing an update on site
     activities.

     • July  26,  1991:   EPA  issued Proposed  Plan describing EPA's
     preferred remedy.

     • August 6,  1991:  EPA  and DNREC hold public meeting to present
     the findings of the RI and to solicit  public comment on the
     preferred alternative identified in the Proposed Plan.
                                17

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                                                      SEALAND LTD. SITE
                                                          «t. Pteaaant. OE
BCM PfOfKt NO. 00-401A-03
        2000 ft
                     Figure i
POOR QUALrft* l£2S2
   ORIGINAL
                                                       Seatand Site

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  BCM
                                               SEALAND LTD. SITE
                                                     Mt. Pleasant DE
      Adjacent
   Property Lines
        Sealand
       Property_Une
                                                        Sealand
                                                      Property Line
                                                             ^x
                                                                 ^ Adjacent
                                                                Property Lines
BCM Protect No. 00-6018-03
           80 Ft
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NORTH
                  Figure 2
Approximate Location of
       Clay-Capped Area
              Sealand Site

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                                                                         Figure 3
                                        Soil Quality Characteristics Map
                                                                    Seaiand  Site

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                                                                                    SEALANO LTD. SITE
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BCM Project No. OO-M18-03


0            300 Ft
                    NOfrm
                                           Ol !AI  IT^roundwater Quality  Characteristics

                                     ORIGINAL

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                                                                                    Tabl«l   Pigvt

                                  TABLE  1
               FREQUENT OF DETECTION FOR SOIL SAMPLES AND
                COMPARISON TO BACKGROUND CONCENTRATIONS

                            SEALANO LIMITED SITE
                          MT. PLEASANT. DELAWARE
             x                            SITE SPECIFIC
Data, Summary
                     Fra^uancy of                  Arithinote     Background
                      Oattction*        Rang*      AMrag* ••  0-2n    2-4ft
Volatile Organic*, ug/kg
                         7/18         4-71         184      4       9
Benzan*                  1/18        <1 - 4          14      <1       <8
2-Haxanono               1/18        <2 • 110        4.9      <2       <12
Toluene                   1/18        9600       526     300     <360
                         V19       OSO-2BOO       384     130     <380
                        12/19      <380>5800       622     310     <390
DkrwOiyl pMtaM»          1/19       <380 - 86 •>       269.    <430    <360


                  I MhM* o*»ar ft* total number of tampta Mean.
          I oonoavttratfon wajsaaontatad balow ttw Ojuaiilllailon Omit
Data qu*ctton*d by data vaMaflon waa oonddand to ba batow datacflen.
EPA aplit aampkM ««• not bwhidad aa pan of «tfa aummaiy.

Compiidby; BCM Engir^ra k& (BCU Pre)aet No. 00401843).

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                                                                                                 Tabl*  1 Pag*2
                                                  TABLE 1
                                FREQUENCY OF DETECTION FOR SOO. SAMPLES AM)
                                    COMPARISON TO BACKGBOUNO SAMPLES

                                            SEALAND UMTTED SfTE
                                          MT. PLEASANT. DELAWARE
                            s    SJTESPEOFC                                        REGIONAL
 DttaSumma/y
                                                                           •           b              •
            Frequency of                   ArtlnmaBo                   Northern       Ottawa    Southern NJ
             Duarton*        Ranga       Avaraaa *•  Background       Daiawan)                MO-Delaware  Geometric
                                                    0-211  2-* n                Mean   so                 MMn
 Metal*, mg/kg

 Aluminum       19/19       4.990 • 18,600     10.441   10400  10.700      30000      -      -     70000.000
 Antimony       4/10        <44 • 74         34     <44    <44         <1                         <1
 Araento         18/19        «a war»i not Indudadaa part ofMammmary.
a  Shae««»lBo««i^i9B* EtemartCanwnWtorMlnSoteandotf
b  Logan, T.O. and Ryan. JX 1«7. Land Appfcaflon o« Shidge. Lwrfa PuMahan. Chalaaa. ML
e  Pannaytvanla Sam UnloarXty. 1900. Cmarta and RMommandaaona tor Land Opcflrtllon ot Sfadpaa m fta Noittaagt
   BuOMin 881. Match 1986.
d  USEPA.19B6. Wtor QuaBty A«M«imint A SomaninQProcadura tor Torie and Conventional
   Po8ulBnt> In Surfaea and Qiound WMar - Part 1. EPA/800/648/003L Saptambar IfiOSFMaad.
a  USEPA. 1904. Haaflh Aiaatamant Dacumant for >norB«nloAfianlc.EPA«0/8-e»oaiF. March 1904.


Cempiladby: BCM En0lnaani he. (BCM Prajaet No. 00401843)

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                                                              Tabto 2 Pegat
                    TABLE 2

FREQUENCY OP DETECTION FOR GROUNOWATER SAMPLES AND
     COMPAHSON TO BACKGROUND CONCENTRATIONS

               SEALANO UMtTED SITE
             MT. PLEASANT, DELAWARE
SITE SPECIFIC
Data Summary
Matais, Flltarad. ug/l
Aluminum
Antimony
Barium
BaryUhim
Calcium
Chromium
Cobatt
CflKMMaf
•*• "••*•
tan
Magnaaium
Manganaaa
MeM
miiiali»i
Sodium
Vanadium
Zno
CyanWa
MaMa.Unffitorad.ug/1
Aluminum
Barium
BaryMum
Calcium
Cnrofnium
Cobatt
Coppar
tan
laadt
Magmafun*
Manganaaa*
MOM .
Potaaakjnv "
Soda**""
Vanadium
Zno
Cyartda
Dttaolon*(]
3/10 [21
1/10 [1J
10/10 [3]
1/10 [11
10/10 [0]
1/10 [11
2/10 [2J
2/10 [2]
8/10 [31
10/10 [2]
10/10 [4]
3/10 [11
10/10 (3)
10/10 (1)
2/10 [2]
3/10 11J
2/4 H

6/6
6/8
2/8
6/8
2/8
1/8
2/8
6/8
4/8
6/8
6/8
1/8
5/8
6/8
3/8
5/8
6/8
Rang*
<16 - 217
<21 - 24
SO- 149
<14 • 2
13400-87.000

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                                      TABLE  2

                TOOUENOr OF DETECTION FOR GflOUNOWATER SAMPLES AND
                     COMWWSON TO BACXQROUNO CONCENTRATIONS

                                SEALANO UMTTED SITE
                               MT. PLEASANT. DELAWARE
                                                 STTESPSOPIC
Otta Summary
                                                                      MW1    MW2*
VoUta* Organta Compot
                             1/7          <3 • 2 *          2,4         <3      <3
MMXytom CNortd*              2/7          <3 • 11           i3         
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                               TABLE  3

               ASSUMPTIONS USED IN CALCULATING EXPOSURE

                         SEALAND LIMITED SITE
                        MT. PLEASANT, DELAWARE
INGESTION OF SOIL

   Current DM
            Ingestien Ratt (mg/day)
            Body Wight (kg)-Child
            Exposure Frequency (days/year)
            Exposure Duration (years)
                                                          Reference
100   EPA, 1989c
 32   EPA, 19896
100   Site Specific
  4   Site Specific
   Future Use
            ingestton Rate (mg/day)
            Body Weight (kg) • Adult
            Exposure Frequency (days/year)
            Exposure Duration (years)
100
 70
120
  1
EPA.1989C
EPA.1989C
Site Specific
Site Specific
DERMAL ABSORPTION FROM SOIL

   Current Use
            Skin surface area  (sq. cm). Child          4.970    EPA. 1989b
            Skin adherence factor (mg/sq. cm)          2.77    EPA, I986g
            Absorption factor (percent)                 1.8    EPA, 1988
            Exposure frequency (events/year)          100    Site Specific
            Exposure duration (years)                   4    Site Specific
            Body weight (kg)-Child                    32    EPA, 1989c
   Future Use
            SUn surface area (sq. cm). Mutt          3.120    EPA, I989b
            SUn adherence factor (mg/sq. cm)         2.77    EPA. I986g
            Absorption factor (percent)                 04    EPA. 1988
            Exposure frequency (events/year)           120    Site Specific
            Exposure duration (years)                   1    Site Specific
            Body weight (kg)-Adutt                    70    EPA. 1989e
CompUed by. BCM Engineers Inc. (BCM Protect No. 00401843)

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                                         TABLE  4

                             CANCER RBK ESTIMATES-CURRENT USE

                                    SEALANOUMITEOSrTE
                                   MT. PLEASANT. DELAWARE
         Chwnfeal
   CO      Stop*   WWgfttof  Chemical
(mg/kg^ay)   Factor   CvManca   Specific
                              RMc
                                                                     Total Expotur*
         bis(2-e>iyttM«yl)ptn
  4.96-11
  2.4E-10
  8.1E-00
  2.6E-08
  7.8&00
  84E-10
  94C-&
  t.lE-00
122
X2Z
0.014
X22
3J2
82
B2
B2
82
82
82
82
                                                             2E-10
                                          O0048
1E-10
OE-00
3E-OI
3E-00
3E-OB
4E>M
         8wno(Dpyraiw
  8.1E-10    3J2
           O014
           122
           i22
  2JC48    i22
           122
                                                    82
                                                    82
                                                    82
                                                    82
                              46-10
                  36-10
                  2E4S
                  7E40
                  7C48
                  16-10
                                                                        2E-OT
                      TOTAL EXK3SURE
                                                                        3frOT
Compfcdtty; BCM EngbtMA toe. (BCM PrajMt Me, 00401»43)

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                                 TABLE  5

                     CANCSRPSK ESTIMATES-FUTURE USE

                           SEALANO LIMITED SITE
                          MT. PLEASANT. DELAWARE
Chwnfctf
               GDI      Stop*   Wtfghtof  Chemical   Total Expoaura
              BAo-day)   Factor   Evidane*   Spacifie     Pathway
               RME                        Rtak
WaC-Em
*yl)pmiau
BwtzoMpyrwM
Nttraw«plwny«ainlM
4.06-11
ZSE-tO
1^E-00
2.06-08
1.3&OS
1.1E-OB
166-00
                                 122
                                 122
122
122
122
122
04048
82
82
82
82
82
82
82
82
                                          1E-10
                                          BE-10
                                          6&00
                                          4E-M
                                          4E-00
                                          1E-11
                                                               7E-OB
bte(2-ehy»wiyI)pMtalati
              Z4E-10
              1J
MtroMdlplwnylamlM
              1.1640

              Z4600
          122
          122
          O014
          122
          122
          122
          122
          82
          82
          82
          82
          82
          82
          82
          82
                                                    16-10
                                                    86-10
                                                    1E48
                                            TOTAL EXPOSUflft
                                                      1EXJ7
      Mnknum bpowt* t> dtRntd n flM upptr bound 96 pworrt
      Hvri of ft»mo« prataMc eenewmttan
   BCUCnglMm to. (BCMPrejKt to. 00401*03)

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                      TABLE 6
     CHRONC HAZARD INDEX ESTIMATES-CURRENT USE

                 SEALANO UMfTB) SITE
                MT. PLEASANT. DELAWARE
                        CO
Chwnteri
              RIO
           (mg/kfrday)
                        Hazard MM
BwnotoAdd
Mwewy
1J&08
1.1E-OT
2J606
4.7&W
1.4tOT
AfltfWI
      M*
Ruaranttwrn
Pyiww
4  •

OQ2
O004
008
03
004
                                                  0.0000004
                                                  O0004
                                                  0.001
                                                  O.00001
                                                  0*000002
                                                  0*0000000
                       1.4647
Ruoram
t**tt&t****rtt*t
                •HM
Okvbulyt pMhaiaM
1.46-07
1.4C-07
1.4M7
1.4&07
08
O08
004
008
O1
                           0*000008
                           OiOOOOOOS
                                                  0*000007
                                                  0000001
                                                                0002
MMwy
2J&07
7.1E4B
1JS47
3J&OT
3JMT
4J.M7
4

ooa
OOM
O08
OS
O04
                       7-Ofror
                       3JM7
             04
             OOB
             004
                                                  0.000001
                                                  ooooa
                                                  O004

                                                  0*000006
                                                  0000001
                                                  O00001
                                                  O00001
                                                  0.000001
                                                  0*000007
                                                  OjQQOQx
                                     O1
                                                                OC08
                                             TOTM.DVOSUK
                                         ooor
BCMEnolnaarakie.(BCMPreiaclNo.O»«01»«3)

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