United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/131
September 1991
&EPA Superfund
Record of Decision
Havertown PCP, PA
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50272-101
REPORT DOCUMENTATION 1. REPORT no. 2-
PAGE EPA/ROD/R03-91/131
4. TWe and SUMMe
SUPERFUND RECORD OF DECISION
Have rt own PCP, PA
Second Remedial Action
7. Auftoff.*)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipients Accession No.
5. Report Date
09/30/91
6.
8. fof fojiidjiy Organization RepC No.
10. Pro|ecVTaak/Worti Urtf No.
11. ContrsdtO or &ant(G) No.
(C)
(G)
11 Type of Report A Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Unite 200 words)
The 12- to 15-acre Havertown PCP site consists of a former wood treatment facility
and an adjacent industrial facility in Haverford Township, Delaware County,
Pennsylvania. Land use in the area is mixed residential and industrial. Naylors
Run, a creek that drains the entire site, flows into Cobbs Creek, which joins Darby
Creek before entering the Delaware River. Only three families who reside more than
one mile from the site use the ground water as their drinking water supply. From
1947 to 1991, National Wood Preservers (NWP) used the site for treating wood.
Treated wood was air dried on drip racks in dirt areas around the site and stored in
a dirt-covered storage yard. Chemicals were stored in several tanks adjacent to the
facility. It has been estimated that up to 1 million gallons of spent wood
preservatives were dumped into a nearby drip well. This disposal practice is
believed to be a primary source of contamination to ground water and, ultimately,
Naylors Run. From 1962 through 1989 the State conducted a number of investigations,
which revealed PCP, oils, PAHs, dioxin, heavy metals, VOCs, and phenols in ground and
surface water. In 1976, EPA initiated a response action, which included ground water
pumping and treatment, installing filter fences, sealing a sanitary sewer, and an
(See Attached Page)
17. Document Analysis a. Descriptor*
Record of Decision - Havertown PCP, PA
Second Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (dioxin,
PAHs, PCP, phenols), metals (arsenic) oils
e. COSATI Held/Group
18. AvsflabiBiy Statement
19. Security Class (TW» Report)
None
20. Security Class (This Page)
None
21. No. of Pages
120
22. Price
(See ANSU39.18)
See Instruction* on Jtevene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R03-91/131
Havertown PCP, PA
Second Remedial Action
Abstract (Continued)
attempt to grout two sewer pipes which discharged into Naylors Run. Currently,
contaminated ground water still discharges into Naylors Run from a storm sewer pipe. A
1989 Record of Decision (ROD) addressed Operable Unit 1 (OU1), the cleanup of wastes
staged onsite from previous investigative actions, and the interim remedial measure of
designing and installing an oil/water separator at the storm drain outlet along Naylors
Run. This ROD addresses an interim remedy for shallow ground water contamination, as
OU2. A subsequent ROD will address sediment contamination in Naylors Run, soil
contamination onsite, potential deep ground water contamination from onsite soil, and
surface water and sediment contamination due to runoff from onsite soil, as OU3. The
primary contaminants of concern affecting the ground water are VOCs including benzene,
TCE, toluene, and xylenes; other organics including dioxin, oils, PAHs, PCP, and phenols;
and metals including arsenic.
The selected remedial action for this interim remedy includes installing two free product
recovery wells with floating free product skimmers onsite; installing a shallow ground
water collection drain and pumping station, as well as additional ground water wells to
monitor shallow ground water; rehabilitating the existing storm sewer to reduce
infiltration by lining the sewer, followed by directing all shallow ground water
collected to the existing oil/water separator; constructing an onsite ground water
treatment plant, which will include chemical precipitation to remove inorganic compounds,
with either a powdered activated carbon treatment (PACT) system or an advanced oxidation
process (AOP), and granular activated carbon treatment as a reinforcement for the PACT or
AOP to remove organics and destroy dioxins; treating effluent from the oil/water
separator using the new treatment plant; discharging the effluent from the treatment
plant onsite to surface water; treating and disposing of any residuals offsite; and
ground water monitoring. The estimated present worth cost for this remedial action
ranges from $10,036,000 to $12,177,000,. which includes an annual O&M cost ranging from
$485,500 to $595,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on background levels, the more stringent of SDWA MCLs or MCLGs, or new limits set forth
in the final remedial action. Ground water clean-up goals include benzene 5 ug/1 (MCL),
PCP 1 ug/1 (MCL), TCE 5 ug/1 (MCL), toluene 1,000 ug/1 (MCL), xylenes 10,000 ug/1 (MCL),
and arsenic 50 ug/1 (MCL).
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RECORD OF DECISION
HAVERTOWN PCP
DECLARATION
SITE NAME AND LOCATION
Havertown PCP (Pentachlorophenol)
Haverford Township
Delaware County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial
action for Operable Unit Two (2) at the site, which addresses the
existing shallow ground water aquifer at the Havertown PCP site
in Haverford Township, Pennsylvania. The remedy 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
P.eauthorization 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 Pennsylvania Department of Environmental Resources concurs
with the selected remedy. This remedial action decision is based
upon and documented in the contents of the Administrative Record
for the site. The attached index identifies the items which
comprise the Administrative Record.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of the Comprehensive Environmental
Response, Compensation, and Liability Act, that actual or
threatened releases of hazardous substances from this site, as
discussed in the summary of site risks in the Record of Decision
(ROD), if not addressed by implementing the response action
selected in the ROD, may present an imminent and substantial
endangerment to the public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The principal threat at the site is the ground, water
contamination which has slowly migrated into the shallow ground
water aquifer. Very significant concentrations of PCP and other
chemicals of concern remain in the ground water. Natural
flushing and attenuation of the contamination has been
ineffective in removing the contaminants to low residual levels.
This phase of work or operable unit is the second of three
planned operable units for the site. The First Operable Unit
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removed existing hazardous waste from the site and installed an
oil/water separator as a first step in removing some contaminants
from Naylors Run, a creek that drains the site area. The Second
Operable Unit will collect and treat the shallow ground water
aquifer, which flows into Naylors Run. This action will initiate
the remediation of the shallow ground water aquifer, in
conjunction with the next planned operable unit, and will act as
the initial step in remediating the sediment contamination in
Naylors Run. It will protect human health and the environment,
principally children playing in Naylors Run. This action is
considered an interim action for ground water because it
addresses only the remediation of the shallow ground water
aquifer and is not the permanent remedy for ground water. The
Third Operable Unit, which is planned, will address sediment
contamination in Naylors Run, potential deep ground water
contamination from soils onsite, and surface water and sediment
contamination due to runoff from onsite soils.
The Second Operable Unit will require long-term management
including a projected 30 year operation of a treatment plant and
the disposal of wastes generated by that plant. The major
components of the selected remedy include the following:
Installation of free product recovery wells on the National
Wood Preservers (NWP) property.
Rehabilitation of the existing storm sewer line to reduce
infiltration of contaminants from the ground water to the
storm sewer.
Installation of a ground water collection drain adjacent to
the existing storm sewer line under the backyards of
residential properties to collect ground water for treatment
at a treatment plant.
Installation of a ground water treatment plant at NWP to
perform chemical precipitation, either powdered activated
carbon treatment or an advanced oxidation treatment and
finally granulated activated carbon treatment. These
processes should fully treat the ground water prior to
discharge back to Naylors Run.
DECLARATION OF STATUTORY DETERMINATIONS
This interim action is protective of human health and the
environment, complies with Federal and State Applicable or
Relevant and Appropriate Requirements directly associated with
this limited scope action, and is cost effective. Although this
interim action is not intended to fully address the statutory
mandate for permanence and treatment to the maximum extent
practicable, given its limited scope, this interim action does
utilize treatment and thus is in furtherance of that statutory
mandate. Because this action does not constitute the final
remedy for the Havertown PCP site, the statutory preference for
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remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element, although partially addressed in
this remedy, will be addressed by the final response action.
Subsequent actions are planned to address fully the principal
threats posed by conditions at this site. Because this remedy
will result in hazardous substances remaining on site above
health based levels, a review will be conducted to ensure that
the remedy continues to provide adequate protection of human
health and the environment within 5 years after commencement of
the remedial action. Because this is an interim action ROD,
review of this site and of this remedy will be ongoing as EPA
continues to develop final remedial alternatives for the
Havertown PCP site.
Edwin B. Erickson Date
'Regional Administrator
Region III
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HAVERTOWN PCP SITE
REMOVAL ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
I. FACTUAL INFORMATION
1. Report: Remedial Action Master Plan, Havertown PCP
Site, prepared by NUS Corporation, 12/83.
P. 100001-100075.
2. Memorandum to Dr. J. Winston Porter, U.S. EPA, from
Mr. James M. Seif, U.S. EPA, re: Justification for
approval of a removal action, 12/11/87. P. 100076-
100086.
3. Letter to Mr. Bob Caron, U.S. EPA, from Ms. M. Joyce
McCurdy, Agency for Toxic Substances and Disease
Registry (ATSDR) , re: Review of data to determine
the existence of a public health threat, 12/16/87.
P. 100087-100087.
4. U.S. EPA Incident Notification Report, Havertown PCP
Site, 12/18/87. P. 100088-100089. A handwritten
notation to question #76 regarding the cause of the
incident is attached.
5. U.S. EPA Incident Notification Report, Havertown PCP
Site, 1/9/89. P. 100090-100090.
Administrative Record File available 7/16/91.
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HAVERTOWN PCP OU1
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
III. REMEDIAL RESPONSE PLANNING
1. Report: Final Remedial Investigation Report,
Havertown PCP Site, Volume ly Chapters 1-4, prepared
by R.E. Wright Associates, Inc., 9/88. P. 300001-
3000139.
2. Report: Final Remedial Investigation Report,
Havertown PCP Site, Volume 2, Chapters 5-10,
prepared by R.E. Wright Associates, Inc., 9/88.
P. 300140-300415.
3. Report: Appendices, Final Remedial Investigation
Report, Havertown PCP Site, prepared by R.E. Wright
Associates, Inc., 9/88. P. 300416-300707.
4 . Report: Havertown PCP Site, Risk. Assessment,
prepared by R.E. Wright Associates, Inc., 6/30/89.
P. 300708-300808.
5. Proposed Plan, Havertown PCP Site, 7/89. P. 300809-
300833.
6. Report: Results of Borehole Geophysical Testing at
the Havertown PCP Site, prepared by R.E. Wright
Associates, Inc., 8/89. P. 300834-300867.
7. Report: Final Focused Feasibility Study, Havertown
PCP Site, prepared by R.E. Wright Associates, Inc.
and Lawler, Matusky & Skelly Engineers, 8/89.
P. 300868-300963.
8. Letter to Mr. Thomas J. Banner, Township of
Haverford, from Mr. J. Thomas Leaver, Commonwealth
of Pennsylvania Department of Environmental
Resources (PADER), re: Transmittal of the risk
assessment, 8/25/89. P. 300964-300964.
9. Letter to Mr. Thomas J. Banner, Township of
Haverford, from Mr. J. Thomas Leaver, PADER, re:
Transmittal of reports relating to Havertown PCP,
8/28/89. P. 300965-300965.
10. Record of Decision, Havertown PCP Site, 9/11/89.
P. 300966-301021.
* Administrative Record File available 7/11/91.
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11. Letter to Mr. Thomas J. Banner, Township of
Haverford, from Mr. J. Thomas Leaver, PADER, re:
Transmittal 'of reports relating to Havertown PCP
Site, 5/10/90. P. 301022-301041. A report entitled
Results of an Oil Recovery Testing Program at the
Havertown PCP Site is attached.
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HAVERTOWN PCP OU2
ADMINISTRATIVE RECORD FILE * **
INDEX OF DOCUMENTS
III. REMEDIAL RESPONSE PLANNING
1. Report: Field Sampling Plan, Remedial
Investigation/Feasibility Study, Havertown PCP Site,
prepared by Tetra Tech, Inc., 8/90. P. 300001-
300112.
2. Report: Work Plan, Volume I (Technical), Remedial
Investigation/Feasibility Study, Havertown PCP Site,
prepared by Tetra Tech, Inc., 10/90. P. 300113-
300217. A letter of transmittal is attached.
3. Dioxin Data Validation for the Havejrtown PCP Site,
SAS 5663C, 2/15/91. P. 300218-300289. A
transmittal memorandum is attached.
4. Data Validation for SAS 5742C, Dioxin/Furan, Site:
Havertown PCP, 4/3/91. P. 300290-300546.
5. Report: Final Baseline Risk Assessment, Havertown
PCP (RI/FS) Site, Haverford Township, Pennsylvania,
prepared by Tetra Tech, Inc., 6/91. P. 300547-
300781.
6. Notification of Federal Natural Resources Trustees,
Havertown PCP Site, Operable Unit #2, 6/21/91.
P. 300782-300782.
7. Letter to Mr. Jerome M. Curtin, U.S. EPA, from Mr.
Don Henne, U.S. Department of the Interior, re:
Lack of necessary documents for preparing the
Preliminary Natural Resources Survey, 6/20/91.
P. 300783-300783.
8. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. David
C. Kennedy, Pennsylvania Department of Environmental
Resources (PADER), re: Comments on the proposed
plan, 6/26/91. P. 300784-300784.
* Administrative Record File available 7/11/91, updated
9/23/91.
** Further information pertaining to Havertown PCP OU2 can
be found in the Havertown PCP OU1 Administrative Record
File.
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9. Report: Remedial Investigation Report, Havertown
PCP Site, Havertown, PA, prepared by Tetra Tech,
Inc., 6/24/91. P. 300785-301058.
10. Report: Feasibility Study, Havertown PCP Site,
Havertown, PA, prepared by Tetra Tech, Inc.,
6/28/91.P7~301059-301239.
11. U.S. EPA Proposed Plan, Havertown PCP, 7/91.
P. 301240-301259.
12. Letter to Mr. Jerry Curtin, U.S.EPA, from Mr. David
Kennedy, PADER, re: Comments on the draft Remedial
Investigation Report, 5/13/91. P. 301260-301260.
13. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. David
Kennedy, PADER, re: Comments on the draft Risk
Assessment Report, 5/17/91. P. 301261-301262.
14. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. David
C. Kennedy, PADER, re: Comments on the draft
Feasibility Study, 5/24/91. P. 301263-301266.
15. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. David
C. Kennedy, PADER, re: Comments on the Proposed
Plan, 6/26/91. P. 301267-301282. The Proposed Plan
with comments is attached.
16. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. Ralph
W. Siskind, Wolf, Block, Schorr and Solis-Cohen, re:
Comments filed on behalf of Philadelphia Chewing Gum
Corporation concerning the Remedial
Investigation/Feasibility Study and proposed option
for Operable Unit #2, 8/8/91. P. 301283-301286.
17. Partial letter to Mr. Thomas Banner, Township
Manager, from U.S. EPA, re: Posting of signs in
Bailey Park concerning exposure of contaminates from
Naylor's Run and the installation of a foot brdge to
minimize contact to Naylor's Run, 8/12/91.
P. 301287-301287.
18. Letter to Mr. Jerry Curtin, U.S. EPA, from Mr. David
C. Kennedy, PADER, re: Comments on-the draft Record
of Decision, 9/6/91. P. 301288-301288.
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V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/
IMAGERY
1. Community Relations Plan for Remedial
Investigation/Feasibility Study, Remedial
Design/Remedial Action, Havertown PCP Site, 1/91.
P.'500001-500033.
2. U.S. EPA Public Meeting, re: Havertown PCB Site
Proposed Plan, 7/30/91. P. 500034-500145.
3. Letter to Mr. Jerry Curtain [sic], U.S. EPA, from
Mr. Wayne L. Zimmermann, re: Comments on the July
30, 1991 meeting, 7/31/91. P. 500146-500146.
4. Letter to Ms. Carrie Clain Dietzel, U.S. EPA, from
Mr. Joseph Solderitsch and Ms. Margaret Solderitsch,
re: Comments on the July 30, 1991 meeting, 8/2/91.
P. 500147-500147.
5. Letter to Mr. Jerry Curtin, U.S. EPA , from Mr. and
Mrs. J. Sabatini, re: Endorsement of the proposed
plan alternative GW-4 option in cleaning the site,
8/2/91. P. 500148-500148.
6. Letter from Mr. Andrew M. Hachadorian, re: Comments
on the proposed clean up alternative, 8/5/91.
P. 500149-500149.
7. Handwritten letter to Mr. Jerry Curtin, U.S. EPA,
from Ms. Betty J. Haitz, re: Request for sampling
in resident's area, 8/6/91. P. 500150-500150.
8. Handwritten letter to Mr. Jerry Curtin, U.S. EPA,
from Ms. Jane Thorn and Ms. Deborah Albrecht, re:
Support of clean up alternative, 8/7/91. P. 500151-
500151.
9. Handwritten letter to Mr. Jerry Curtain [sic], U.S.
EPA, from Ms. H.M. Marnie, re: Support of clean up
alternative, 8/7/91. P. 500152-500152.
10. Handwritten letter to Mr. Jerry Curtin, U.S. EPA,
from Mr. Bob Clark, re: Support for EPA's GW-4
clean up alternative, 8/7/91. P. 500153-500153.
11. Handwritten letter to Jerry Curtain [sic], U.S. EPA,
from Ms. Judith Peters, re: Request for soil
testing, 8/8/91. P. 500154-500155.
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12. Letter to Mr. Jerry Curtin, U.S. EPA, from Ms.
Patricia Jillard, The Manoa Civic Association, re:
Response to EPA's proposed clean up alternative,
8/8/91. P. 500156-500156.
13. Letter to Mr. and Mrs. Joseph Solderitsch, from Mr.
Jerome M. Curtin, U.S. EPA, re: Response to letter
dated August 2, 1991 concerning the proposed plan,
8/14/91. P. 500157-500157.
14. Letter to Mr. David Manion from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to letter concerning
the proposed plan, 8/14/91. P. 500158-500158.
15. Letter to Mr. Bob Clark from Mr. Jerome M. Curtin,
U.S. EPA, re: Response to letter dated August 7,
« 1991 concerning the proposed plan, 8/14/91.
P. 500159-500159.
16. Letter to Mr. and Mrs. J. Sabatini from Mr. Jerome
M. Curtin, U.S. EPA re: Response to letter dated
August 2, 1991 concerning the proposed plan and
planned additional testing of Naylors Run, 8/14/91.
P. 500160-500160.
17. Letter to Mrs. Judith Peters from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to letter dated
August 8, 1991 concerning the proposed plan and
additional soil testing, 8/14/91. P. 500161-500161.
18. Letter to Mr. Wayne L. Zimmermann from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to letter dated July
31, 1991 concerning the proposed plan and a third
phase of investigation into possible contamination
east of Naylors Run, 8/14/91. P. 500162-500163.
19. Letter to Ms. H.M. Marnie from Mr. Jerome M. Curtin,
U.S. EPA, re: Response to letter dated August 7,
1991 concerning the proposed plan, 8/14/91.
P. 500164-500164.
20. Letter to Mr. Robert Synder from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to resident's
support of the proposed plan, 8/14/-91. P. 500165-
500165.
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21. Letter to Ms. Patricia Jillard, The Manoa Civic
Association, from Mr. Jerome M. Curtin, U.S. EPA,
re: Response to letter dated August 8, 1991
concerning the proposed plan, 8/14/91. P. 500166-
500166.
22. Letter to Ms. Jane Thorn and Ms. Deborah Albrecht
from Mr. Jerome M. Curtin, U.S. EPA, re: Response
to letter dated August 7, 1991 concerning the
proposed plan, 8/14/91. P. 500167-500167.
23. Letter to Mr. John L. Rendemonti from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to inquiry
concerning the proposed plan, 8/15/91. P. 500168-
500168.
24. Letter to Mr. Jerry Curtain [sic], U.S. EPA, from
Mr. Henry G. Meyer and Ms. Margaret C. Meyer, re:
Concerns over the condition of Naylors Run, 8/15/91.
P. 500169-500169.
25. Letter to Mr. and Mr. Henry Meyer from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to letter dated
August 15, 1991 concerning the Havertown PCB Site,
8/19/91. P. 500170-500170.
26. Letter to Ms. Betty J. Haitz from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to letter dated
August 6, 1991 concerning the proposed plan,
9/10/91. P. 500171-500171.
27. Letter to Mr. Joseph J. Di Biasi from Mr. Jerome M.
Curtin, U.S. EPA, re: Response to inquiry
concerning the proposed plan and the risk at Naylors
Run, 9/10/91. P. 500172-500173.
28. Letter to Mr. Jerome M. Curtin, U.S. EPA, from Mr.
David Manion, re: Comments regarding the public
meeting, (undated). P. 500174-500174.
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BIBLIOGRAPHY OF SITE SPECIFIC GUIDANCE DOCUMENTS
1. Information on Drinking Water Action Levels,
prepared by T. Fields Jr., OSWER/ERD, April 19,
1988.
Attachments: 1. Memo: Releases from Lawfully
Applied Pesticides
2. Memo: DBOP Contamination
3. Guidance for Ethylene Dibromide
in Drinking Water
2. Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA, prepared by
OSWER/OERR, October 1, 1988.
OSWER #9355.3-01
3; Superfund Federal-Lead Remedial Project Management
Handbook, prepared by OERR, December 1, 1986.
OSWER #9355.1-1
4 . Superfund Remedial Design and Remedial Action
Guidance, prepared by OERR, June 1, 1986.
OSWER #9355.0-4A
5. CERCLA Compliance with Other Laws Manual Draft
Guidance, prepared, by OERR, August 8, 1988.
OSWER #9234.1-01
6. Superfund Exposure Assessment Manual, prepared by
OERR, April 1, 1988.
OSWER #9285.5-1
7. Superfund Public Health Evaluation Manual, prepared
by OERR and OSWER, October 1, 1986.
OSWER # 9285.4-1
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DECISION SUMMARY FOR RECORD OF DECISION (ROD)
1. Site Name'. Location & Description
The Havertown PCP Site is located in Havertown, Haverford
Township, Delaware County, in southeastern Pennsylvania. The
site is located approximately 10 miles west of Philadelphia and
is surrounded by a mixture of commercial establishments,
industrial companies, parks, schools, and private homes, (see
Figures 1 and 1A)
The Site is comprised of a wood-treatment facility operated by
National Wood Preservers (NWP); the Philadelphia Chewing Gum
Company (PCG) manufacturing plant adjacent to the wood-treatment
facility; Naylors Run, a creek that drains the area; and
neighboring residential and commercial properties (see Ficrure 2).
The entire Havertown PCP Site consists of approximately 12 to 15
acres, roughly delineated by Lawrence Road and Rittenhouse Circle
to the south, the former Penn Central Railroad tracks to the west
and north, and Continental Motors to the West. There is no
distinct boundary to the East. NWP, the primary source of the
contamination, is the focus of this investigation. Structures on
the property include a sheet metal building with above ground
chemical storage tanks situated on a 2-acre property just north
of the intersection of Eagle and Lawrence Roads.
The Havertown PCP site lies approximately 300 feet above mean sea
level. It ranges in elevation from 280 feet above sea level in
the residential areas along Rittenhouse Circle, to 320 feet above
sea level northwest of Young's Produce Store. The present site
topography is a result of major cut and fill alterations to the
land. The NWP property is relatively flat, and drains northward
toward a drainage ditch that borders the abandoned railroad bed
north of the property. The PCG property is also flat, except for
a 12 to 15 foot embankment along its southeastern border which
separates the PCG property from residential backyards along
Rittenhouse Circle. The PCG property drains to the southwest and
southeast toward residential areas.
The entire Havertown PCP site is drained by Naylors Run, a creek
that flows in a southeasterly direction from the site. For the
most part, surface runoff across the NWP site enters artificial
drainage channels before discharging into Naylors Run. On the
NWP property, a significant amount of water accumulates in the
area of the gate for pedestrians near Continental Motors and in
the vicinity of NWP's main gate near Eagle Road. Under storm
event conditions, the large amount of flow that occurs on NWP
property in the area of the main gate empties into the drainage
ditch bordering the north edge of the property. Naylors Run
flows through natural channels, concrete-lined channels, and a
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Source: USGS Map
Lansdale PA Quadrant
POOR QUALITY
ORIGINAL
Figure l-General Location Map
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S /SWISS
/FARM
MAR
NATIONAL
000 PRESERVERS
PLANT
Figure lA-Havertown PCP Site
POOR QUALITY
ORIGINAL
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i::::::::
NW-3-8T"
NW-2-81
W-2S
CW-11
CW-1D
\/ P
PHILADELPHIA
CHEWING
HAV-01
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variety of pipes before entering Cobbs Creek near East Lansdowne,
approximately 4 miles southeast of the site. Cobbs Creek joins
Darby Creek, which flows through the Tinicum National
Environmental Center before entering the Delaware River.
2. Site History & Enforcement Activities
The NWP site was first developed as a railroad storage yard and
later became a lumber yard. In 1947 the wood-preserving facility
was constructed and operated by Mr. Samuel T. Jacoby. Also in
1947, NWP was incorporated by Jacoby. The property on which the
plant operated was leased from Clifford and Virginia Rogers
(Remedial Investigation Report, R.E. Wright Assoc., Inc., 1988
"Wright Report"). In 1963 the existing facility (NWP) was
purchased by the Harris Goldstein family.
In 1962,, the Pennsylvania State Department of Health became aware
of contaminants in Naylors Run, and linked the source of
contamination to National Wood Preservers waste disposal
practices. Mr. Jacoby was brought to trial by the Commonwealth
of Pennsylvania in 1964, for the disposal activities that
occurred at the Site. He was found not guilty because the State
had not complied with the provisions of Section 309 (Act 3, 1946)
(Wright Report, Page 1-35). In 1967, Shell Oil Company obtained
a leasehold interest for the portion of the Rogers' property
located at the northwest corner of Eagle Road and Lawrence Road.
Shell developed this portion of the Rogers' property and
constructed a gasoline station at this location (Wright Report,
page 1-35).
Many of the activities resulting in pollution to the water
bearing aguifer beneath the site occurred during the years of
1947 to 1963. It was originally estimated that up to 1 million
gallons of spent wood preservatives was dumped into a 15 to 25
foot deep well on property adjacent to the present Swiss Farms
Market site. A ground water monitoring well, Well R-2, is
located near this location. This disposal event appears to be a
major source of contamination to Naylors Run.
In 1972, the Pennsylvania Department of Environmental Resources
(PADER) identified contaminated ground water discharging from a
storm sewer into Naylors Run. In 1973, PADER ordered NWP,
Philadelphia Chewing Gum Company (which owns the property
downgradient from NWP), Shell Oil Company, and Mr. Clifford
Rogers (owner of property leased to NWP) to clean up Naylors Run,
since they occupied land where contaminated ground water existed.
The above parties appealed to the State Environmental Hearing
Board, and later to the Commonwealth Court of Pennsylvania. In
1978, the Commonwealth Court sustained Philadelphia Chewing Gum
and Shell Oil Company's appeals and ordered the cleanup to be
executed by NWP and Mr. Rogers (Wright Report, page 1-41). In
1980, the Supreme Court of Pennsylvania affirmed the Commonwealth
-------
Court's orders; the U.S. supreme Court refused to hear the appeal
by NWP and the Rogers. Implementation and maintenance of the
cleanup actions by NWP and Mr. Rogers were inadequate, however,
and failed to address all of the environmental concerns, both
onsite and off.
In response to a request from FADER in 1976, the United States
Environmental Protection Agency (USEPA) initiated activities
under Section 311 of the Clean Water Act. Cleanup activities
occurred in two phases. The first phase established containment
operations at Naylors Run. Filter fences were installed to
remove PCP contaminated oil from the surface water. These fences
were located just downstream from the outfall of the 36-inch
storm sewer pipe and a 12-inch sanitary sewer pipe. The second
phase was carried out by the Emergency Response Team from the
USEPA. Ground water collection and treatment, and cement
grouting of the two sewer pipes was attempted. The sanitary
sewer was sealed; however, contaminated ground water still
discharges into Naylors Run from the 30 inch storm sewer pipe.
In 1976, EPA commenced containment operations funded under
Section 311 of the Clean Water Act. These operations were
administered by the Coast Guard. As a result of negotiations
following receipt of a Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) notice letter dated
December 18, 1981, NWP assumed responsibility for operation and
maintenance of the containment operations in Naylors Run as of
February 1, 1982.
In December of 1982, the Havertown PCP Site was placed on the
NPL. Subsequent inspections throughout 1984, made by PADER and
EPA, found many deficiencies with the containment operations. On
October 10, 1984, a Unilateral Administrative Order was issued
against NWP by EPA which required NWP to perform various
abatement activities. These activities involved the adequate
operation and periodic maintenance of the filter fences on
Naylors Run.
In 1988, because of continuing releases of PCP-contaminated oil
into Naylors Run, EPA's Emergency Response Team installed a catch
basin in Naylors Run to trap the discharge from the storm pipe.
EPA still maintains the catch basin.
In 1987, PADER initiated the RI/FS for Operable Unit One (OU1)
which was completed in August 1989. A record of decision (ROD)
for OU1 was issued for the Havertown PCP site by the EPA on Sept.
29, 1989, which addressed the cleanup of wastes currently staged
on the site from previous investigative actions and the interim
remedial measure of designing and installing an oil/water
separator at the storm drain outlet along Naylors Run. On August
23, 1989, EPA sent a special notice letter to NWP to determine
its interest in participating in the Remedial Design/Remedial
-------
Action (RD/RA) for OU1. On September 6, 1989, EPA received a
written response from NWP. NWP declined to participate.
In order to address further problems at the site, EPA initiated
an RI/FS for the site for Operable Unit 2 (OU2). Those documents
were completed in June 1991.
The NWP facility has not changed significantly since its
construction and today consists of a single metal-sheeted
building, which contains the wood-treatment equipment, and
several chemical storage tanks located immediately northwest of
the building. The production facility is surrounded by a dirt-
covered storage yard in which untreated and treated wood are
stored. The entire NWP facility is enclosed by a chain-link
fence, although this fence does not accurately delineate the
boundary of either NWP or the adjacent Continental Motors. In
1963-1964 the Goldsteins made some basic chemical containment and
chemical recycling modifications to the facility at the request
of the State of Pennsylvania.
NWP custom-treated wood as requested by clients, who supplied the
materials to be treated. Wood preservation was carried out to
prevent decay or insect infestation of woods used for
construction purposes where the wood will be constantly exposed
to the environment. The type of wood treated at this facility
was determined by the client, who supplied the material precut
and dried, so that, other than loading, treating, unloading and
storing wood, essentially no other tasks were performed at this
facility. The present lack of activity at NWP seems to indicate
that NWP is no longer operating as a wood treatment facility.
Additionally, Alan Goldstein, one of the owners of NWP, did
inform EPA's contractor on the site, Tetra Tech, in the spring
of 1991, that he was operating the site as a lumber yard.
Two wood-treating processes have been used at this facility: the
"empty cell pressure treatment process" and the "non-pressure
treatment dip treatment". The facility has three pressure
treatment cylinders: two inside the building and one outside.
Pressure-treated wood was air dried on drip tracks located on
dirt areas around the perimeter of the site. Wood that was
dipped into treatment solutions was similarly dried and handled.
This activity would account for the presence of PCP and heavy
metals in both onsite and drainage area soils. According to the
Remedial Investigation performed by PADER in 1988, at least six
wood-treatment chemical solutions have been used at the NWP
facility since its construction. From 1947 to 1977-1978 three
chemicals were used: pentachlorophenol (PCP) in P-0 Type A oil
(diesel fuel); PCP in P-9 Type C oil (mineral oils); and fluoro-
chrome arsenate phenol (FCAP) in water solution. PCP in oil
(both types) was used in both the pressure treatment and the dip
treatment processes. FCAP was used only in the pressure
treatment process.
-------
Chromium copper arsenate (CCA) in a 0.4 or 0.6% water solution,
first used at the facility in the mid-1970s, eventually replaced
PCP and FCAP during 1977-1978. Other chemicals used on-site
since the 1970s include chromated zinc chloride (CZC, a fire
retardant) and tributyl tin oxide (TBTO), an antifouling
compound). All three water-soluble chemicals were used in the
pressure treatment process.
The primary contaminants of concern at the site are primarily the
result of wood-treatment operations at NWP. These are PCP,
polycyclic aromated hydrocarbons, dioxins and dibenzofurans
(typical low-level contaminants in the manufacture of PCP), fuel
oil and mineral spirits components, heavy metals, certain
volatile organic compounds, and phenols.
3. Highlights of Community Participation
The Remedial Investigation, Risk Assessment, and Feasibility
Study for the Havertown PCP site as well as the Proposed Plan and
background documentation for the second operable unit for the
Havertown PCP site were released to the public for comment on
July 11, 1991. These documents were made available to the public
in both the administrative record and information repository
maintained at the EPA Docket Room in Region III and at the
Haverford Township Building, Havertown, PA. The notice of
availability for these documents was published in the News of
Delaware County on July 10, 1991 and in the Philadelphia Inquirer
on July 18 and 25, 1991.
A public comment period was held from July 11, 1991 to August 11,
1991. in addition, a public meeting was held on July 30, 1991.
At this meeting, representatives from EPA and PADER answered
questions about problems at the site and the remedial
alternatives under consideration and solicited comments from the
attendees. A transcript of the public meeting was maintained in
accordance with Section 117(a)(2) of CERCIA, 42 U.S.C. §
9617(a)(2). A response to the comments received during this
period is included in the Responsiveness Summary, which is an
attachment to this ROD. The above actions satisfy the
requirements of Sections 113(k)(2)(b) (i-v) and 117 of CERCLA, 42
U.S.C. Section §(k)(2)(i-v) and 9617. All documents that form
the basis for the selection of the remedial action contained in
this ROD are included in the administrative record for this site
and can be reviewed or referred to for additional information.
4. Scope and Role of Operable Unit or Response Action Within
Site Stratecry
As with many Superfund sites, the problems at the Havertown PCP
site are complex. As a result, EPA has organized the remedial
work at the site into 3 operable units. This ROD addresses the
second planned remedial action at the site.
-------
The remedy for the First Operable Unit was documented in a 1989
ROD. It included the removal of existing waste from the site and
treatment of effluent discharging from the existing storm sewer.
This included installation of an oil/water separator and off-site
disposal of generated wastes. This remedy was constructed in May
1991 & the results are being monitored under EPA's operation and
maintenance -of the site. To date, the results indicate that
almost all of the oil and grease and most of the semi-volatile
organics are being removed from the effluent. However,
significant amounts of solubilized PCP still remain in it.
The principal threat addressed by this ROD is the ground water
contamination, which originated at the NWP facility, and has
slowly migrated to the southeast in the shallow aquifer and also
lays directly under the NWP facility. Very significant
concentrations of PCP and other chemicals of concern remain in
the ground water. Natural flushing and attenuation of the
contamination has been ineffective in removing the contaminants
to low residual levels.
To address the principal threat, the Second Operable Unit
encompasses the collection and treatment of contaminants in the
shallow ground water aquifer and upon treatment, discharge
effluent back into Naylors Run. As part of the investigation for
this operable unit, an evaluation of the contamination of the
sediments in Naylors Run was also made. While the actions of
this operable unit will not remediate the sediment contamination,
it will act as a first step in remediating the sediments by
removing contaminants from the ground water, which is one of the
media which transport contamination into the sediments. This
action is considered an interim action for ground water, because
it addresses only the remediation of the shallow ground water
aquifer and is not the permanent remedy for ground water. The
deep aquifer is not being remediated at this time due to the
presence of PCP contamination in the soils underlying NWP. It
was decided that any installed deep ground water extraction wells
might draw ground water through the existing contaminated soil
and thus further contaminate the existing aquifers. In the Third
Operable Unit, the existing soil contamination will be further
investigated to coordinate with deep ground water investigation.
The Third Operable Unit, which will be initiated in the next
year, will evaluate the extent of soil contamination at NWP and
the surrounding area, the potential impact on shallow and deep
ground water aquifer contamination, and further evaluate the
contamination of sediments in Naylors Run.
5. summary of Site Characteristics
A. Nature and Extent of Contamination
Ground water at the Havertown site flows in an easterly direction
6
-------
and occurs in two major zones. The upper zone consists of
surficial soils and weathered schist saprolite. The movement of
water in the saprolite zone is influenced by the degree of
saprolite weathering, relict bedrock structures, compositional
variations, and the thickness of the weathered zone. The lower
zone consists of highly fractured and jointed schist bedrock,
with water movement occurring along interconnected fractures.
The bedrock aquifer receives some of its recharge from the
downward flow through the overburden aquifer. Upward directed
flow also occurs within the overburden aquifer and presumably
provides base flow to Naylors Run. The depth to ground water
below the site ranges from approximately 23 feet below ground
surface in the vicinity of Young's Produce Store to approximately
0.5 feet below ground surface in the vicinity of Rittenhouse
Circle. Until very recently, September 13, 1991, neither aquifer
was thought to be used as a source of water supply in the
vicinity, as public water is supplied by the Philadelphia
Suburban Water Company. However, EPA was notified on September
13, 1991 that there are 3 families in Havertown who utilize
ground water as a drinking source. These families are located
more than 1 mile north and west of the site. An investigation is
now underway to determine if the ground water being used was
affected by the Havertown PCP site.
The present nature and extent of contamination at the Havertown
PCP site is summarized below for ground water, surface water and
sediments in Naylors Run, and water and sediment collected from
several portions of the storm sewer feeding into Naylors Run.
Ground water was sampled at 16 different locations. The results
are summarized in Table l and locations are shown on Figure 2.
Surface water was sampled at 11 locations. The results are
summarized in Table 2 and locations are shown on Figure 3. The
storm sewer water was sampled at 3 locations. The results are
summarized in Table 3 and locations are shown on Figure 3. The
sediments were sampled at 11 locations and 2 locations in the
storm sewer. The results are summarized in Tables 4 & 5 and
locations are shown in Figure 4 & Figure 3. respectively.
(Tables 1 through 5 include summaries of the major contaminants
and their associated values but they do not include every
individual contaminant. That information is available in the
RIFS report.)
Ground Water
Volatile organic compounds (VOCs), semi-volatile organic
compounds (predominantly pentachlorophenol), and dioxin isomers
are the majority of the contaminants present in the ground water
at the Havertown site. The shallow ground water is classified as
-------
TABLE 1 - SUMMARY OF
GROUNDWATER SAMPLING RESULTS
Sampling Date: August and November 1990
WELL VOLATILE SEMI ORGANICS/ DIOXIN INORGANICS
NUMBER ORGANICS PESTICIDES ISOMER PPB
PPB PPB PPT
NW-3
CW-1
(3 WELLS)
NW-6
R-4
hAV-02
CW-2
NW-]
CW-4
(3 wells)
K-2
CW-3
(3 wells)
iiW-6
(3 wells)
CW-5
(3 wells)
HAV-04
HAV-OS
HAV-08
HAV-07
"
1,2 Dichloroethene-
270
Trichloroethene-630
'
Total Xylenes-240
Total XyIenes-110
Benzene-270
Total Xylencs-540
Total Xylenes-390
Ethyl Benzene-160
Total Xytenes-1,300
Benzene-230
Total Xylenes 1,700
SV-212
PAH-212
SV-1,213
PCP-2SO
Dieldrin-.12
SV-2,800
PCP-2,800
Dieldrin-.61
SV-2,934
PCP-1,900
PAH-1,034
SV-1 1,558
PCP-6,800
PAH-4,719
SV-4,491
PAH-4,405
SV-4,160
PCP-3,700
PAH-760
SV-147,340
PCP-80,000
PAH-66,040
Endosulfan-3.5
SV-560
PCP-560
Only deep
SV-3,965
PCP-3,500
PAH-46S
Only deep
SV-201
PCP-140
SV-90,820
PCP-63,000
PAH-27,190
SV-3,774
PCP-3,300
PAH-444
SV-2,739
PCP-1900
PAH-839
0.032
0
0.008
0.007
23.136
4.464
shallow
9.976
0.776
29.39
0.001
0.012
0.084
173.739
(2,2,7,8 TCDD)
3.599
0.052
0.212
Cobalt-97.7
Manganese -4,620
Cobalt-206
Manganese 9,960
Arsenic- 13. 6
Cobalt-S9.6
Manganese-8,800
Aluminum-45.8
Manganese-28.5
Arsenic-8
Cobalt-146
Manganese- 1 9,200
Aluminum-2,390
Arsenic-2.3
Cobalt-413
Manganese-9,350
Cobalt-9.5
Manganese-561
Aluminum-31.4
Arsenic-26.1
Cobalt-69.3
Manganese -9, 120
Arsenic-22.7
Cobalt-91.7
Manganese-17,300
Aluminum-40.2
Cobalt-34
Manganese-6,860
Aluminum-48.5
Arsenic-2.8
Cobalt-41.8
Manganese-8,790
Alummum-42.8
Arsenic-28
Cobalt-16.2
Manganese-8,700
AJuminum-35.1
Cobalt-179
Mnganese-22,600
AJuminum-55.6
Cobalt-65^
Manganese-9,630
Alummum-38.4
Cobalt-41.7
Manga nese-3,350
Aluminum-61.1
Arsenic-2.7
Cobalt-SJ
Manganese-951
-------
Table 2-Naylor's Run/Cobbs Creek Surface
Water Sampling
Sampling Dates: September 1990 and January 1991
Location VOC's Semi-Volatiles/ Dioxin Inorganics
(ppb) Pesticides Isomers (ppt>)
(ppb) (ppt)
Nay 06
Nay-05
Nay-03
Nay 04
Nay 02
Nay 01
Nay 08
Nay 09
Nay 10
Cob 01
Cob 02
no sample taken
Xylenes-160
Benzene-31
Xylenes-27
Trichloroethene-7
Benzene-28
Ethylbenzene-6
Xylenes-46
Trichloroethene-4
Benzene- 11
Ethylbenzene-6
not taken
not taken
not taken
not taken
not taken
Lindane-.054
no sample taken
SV- 1,204
(PCP-1,200)
Heptachlor - .77
4-4 ODD - .38
SV-382
(PCP-380)
4-4 DDD-.38
SV-580
(PCP-580)
Dieldrin-.12
Dieldrin-.34
SV-140
(PCP-140)
none taken
0.299
0.004
-
not taken
not taken
not taken
not taken
not taken
Aluminum- 147
Lead-12.9
Manganese-228
Thallium-3.3
no sample taken
Aluminum 113
LeadS
Manganese-
10,000
Thallium-3
Aluminum-53.5
Lead-3.6
Manganese-7,430
Thallium-2.2
Lead 7.4
Manganese-8,220
Thallium-2
Lead-2.4
Manganese-686
Thallium-2
not taken
not taken
not taken
not taken
not taken
-------
Table 3 - Storm Sewer water Sampling
Sampling Date: September 1990
Location
SS01
SS02
SS02A
SS 03
SS04
SS05
Voc
Cppb)
no samples taken
Xylenes-3
Ethylbenzene-110
Xylenes-500
Benzene-120
2-Butanone-80
Trichloroe-
thene-16
no samples taken
no samples taken
Semi-Volatiles
Pesticides
(ppb)
no samples taken
SV-2,229
(PCP-2,100 PAH-
127)
no samples taken
SV-8,501
(PAH-8,172)
no samples taken
Dioxin
(PPt)
no samples taken
0.703
no samples taken
no samples taken
Inorganics
(ppb)
no samples taken
Aluminum-236
Barium-30
Cobalt-2
Manganese-77
Aluminum- 148
Barium-38
Cobalt-60
Lead 6
Manganese-
14,300
no samples taken
Alumihum-236
Arsenic-3
Barium-113
Cobalt-2.6
Manganese-1,500
Lead-3.2
no samples taken
-------
PHILADELPHIA
CHEWING
GUM
Approximate Scale:
1"=100'
Figure 3 -surface Water, Storm Sever, and Sediment Sampling
Locations near NWP
-------
Table 4 - Nay lor 's Run/Cobbs Creek Sediment
Sampling Date: September 1990 and January 1991
Location BOC's Semi-Volatiles/ Dioxin Inorganics
(ppb) Pesticides Isomers (ppb)
(ppb) (ppt)
Nay 06
Nay-OS
Nay 03
Nay 04
Nay 02/07
Nay 01
Nay OS
Nay O9
Nay 10
Cob 01
Cob O2
-
Tricnloroethane-7
.Benzene 28
Ethylbenzene 27
not taken
not taken
not taken
not taken
not taken
SV-120.680
(PCP-3.0OO
PAH-1 11.200)
Endrin-43
EndosuNan-48
SV-45,990
(PAH-32.990)
SV-117.160
(PAH-59.130)
4-4ODO-43
beta-BHC-35
Alpha-chkxoane-1 10
Gamma-Chlordane- 1 30
SV-9140
(PCP-830
PAH-7O40)
Endosulfan-51
SV-47,000
(PCP-1.800
PAH-41,320)
betaBHC-28
Oieldnn-73
AWnn-36
SV-76«
(PCP-810
PAH-4.220)
DieWrin-75
SV-43,206
(PCP-360
PAH-40.830)
SV-13,706
(PAH-40.830)
SV-64,634
(PAH-61.116)
SW-5,*«
(PAH-5^96)
SV-1,817
(PAH-1 .786)
O.OO3
O.O41
0.118
0.117
0.056
0.011
not taken
not taken
not taken
not taken
not taken
Aluminum-6,320
Lead-694
Managenese-3.800
Antimony. 137
Ar33nic-21.S
earium-115
Chroinium-S32
Cobalt-29.S
Vandlum.75.2
Aluminum 7130
Aisenfc-37.6
Safium-41S
Chcomium-34.6
Cobalt-12.8
Lead-232
Maflganese-1 .350
Vanadium-27
Aluminum 3,950
Lead 2,6
Antimony-7.9
ArsenJc-1.5
Barium-45.5
Chnxnium-31.4
Cobalt-12.8
Vanadium-27
Aluminum-6,110
Lead-12
Manganese-4.750
Antimony-14.1
Aisenic-1.a
Sarium-62.3
Chromium-426
Cobatt-7.1
Vanadium-118
Lead 288
Manganese-ass
Aluminum-4.3SO
Antimony-7.7
Areenic-14.5
Barium-41.4
Chremium-»2.7
Cobalt-7.7
Vanadium-20.7
Lead-32.4
Manganese-3.420
Aluminum-5.230
Antimony-7.2
Areenic-1.1
Barium.113
Ovomium-331
Cobalt-11.8
Vanadium-66.2
not taken
not taken
not taken
not taken
not taken
-------
Table 5 - Storm Sewer Sediment Sampling
Sampling Date: September 1990
Location VOC Semi-Volatiles\ Dioxin Inorganics
(ppb) Pesticides (PPt) (PPb)
(ppb)
SS01
SS 02
SS 02A
SS03
SS 04
SS 05
no samples taken
no samples taken
no samples taken
no samples taken
Trichloroethene-8
Trichloroethene-3
no samples taken
no samples taken
no samples taken
no samples taken
SV-8,501
(PAH-8,172)
SV-37,400
(PCP-20,000
PAH-13,450)
no samples taken
no samples taken
no samples taken
no samples taken
0.041
no samples taken
no samples taken
no samples taken
no samples taken
Aluminum-7,320
Arsenic-1.3
Chromium-100
Cobalt 5
Manganese-1,230
Lead-30
Vanadium-36
Zinc-102
Aluminum-
12,900
Arsenic-425
Chromium-656
Cobalt-11
Lead 226
Manganese-373
Mercury- .23
Vanadium-48
-------
Not to Scale
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-------
a class IIB aquifer, capable of being used as a drinking source.
The ground water is not being used by the adjacent populations
(except for the three families previously mentioned) but it does
empty into Naylors Run which eventually feeds Cobbs Creek. Its
movement is discussed under the Fate and Transport Section of
this ROD.
The volatile organic compounds trichloroethene and 1,2-
dichloroethene are found in highest concentrations (630 and 270
Mg/1/ respectively) on the National Wood Preservers property and
decrease from west to east across the site. Other prevalent
VOCs, benzene and total xylenes, are found in highest
concentrations on Philadelphia Chewing Gum property (270 and 1700
ug/1, respectively). In general, the concentration of all
volatile organic compounds have decreased in most monitoring well
locations since 1988.
Semi-rvolatile organic compounds have generally increased in
concentration since 1988. Pentachlorophenol and polycyclic
aromatic hydrocarbons (PAHs) make up the majority of the semi-
volatile organic compounds present in the ground water. The
highest levels of PCP were present in wells R-2, HAV-04, and HAV-
02 (80000, 63000, and 1900 ug/1, respectively). Wells R-2 and
HAV-02 presently contain floating free petroleum product. It is
estimated that there now exists approximately 6000 gallons of
free product in this area. PCP was found for the first time in
the furthest downgradient shallow well, HAV-07. PCP is also
present in the deep hydrologic zone, although in generally lower
amounts than those observed for the shallow hydrologic zone.
There are numerous dioxin isomers, all of which vary in their
potential toxicity. The isomer 2,3,7,8-TCDD is considered to be
the most toxic of the isomers. To evaluate dioxin,
concentrations of all isomers are converted to a toxicity
equivalent for 2,3,7,8-TCDD. Although 2,3,7,8-TCDD was only
present in 1 monitoring well, almost all monitoring points
exceeded a 2,3,7,8 toxicity equivalent of zero. The 2,3,7,8-TCDD
toxicity equivalent of the ground water has apparently increased
dramatically since 1988, especially in wells that still contain
free floating product. The characteristics of each contaminant,
as it relates to human health are discussed in the Summary of
Site Risks Section of this ROD.
Surface Water and Sediments in Naylors Run and Cobbs Creek
The surface water contained predominantly VOCs and PCP. Minor
concentrations of pesticides and metals were also present. The
surface water was generally absent of other semi-volatile organic
compounds (besides PCP) and contained no dioxins. VOCs and PCP
were not the dominant contaminants in the sediments. Instead,
the PAH subgroup of semi-volatile organic compounds dominated.
-------
As with ground water, the primary VOCs in the surface water were
benzene, total xylenes, trichloroethene, as well as toluene and
ethylbenzene. All VOCs decreased in concentration downstream.
No VOCs were present in the furthest downstream location in
Naylors Run (NAY-01). The total VOC concentration was 205 ug/1,
immediately outside the catch basin.
The concentration of PCP in the surface water ranged from a
maximum of 1200 Atg/1, in water entering the catch basin (NAY-03) ,
to 3 Mg/1 at the furthest downstream location sampled, Cobbs
Creek station 01. The maximum concentration of PCP and PAHs in
the sediment were found at station 06 in concentrations of 3000
and 111,200 ^ig/kg, respectively. No PCP was found in the
sediment downstream of station 08 (above quantification limits of
1000 jig/kg)
The pesticides gamma-BHC, 4.4'-DDD, heptachlor epoxide, and
dieldrin were present in the surface water. At least one of
these pesticides was present at every surface water station but
no more than 2 pesticides were detected at any 1 station. The
maximum concentration of any pesticide was 0.77 Mg/1- Dieldrin,
beta-BHC, heptachlor, aldrin, 4/4/-DDD, endosulfan sulfate, and
endrin were all present in the sediment. Heptachlor represented
the pesticide found in the highest concentration in the sediment
at 160 fig /kg.
Aluminum, cobalt, lead, manganese, and thallium represented the
metals of concern in the surface water. These metals, plus
antimony, arsenic, barium, chromium, and vanadium were prevalent
in the sediments. Only antimony, lead, and thallium were not
found at every sample station.
All surface water samples located away from the immediate
vicinity of the catch basin had a 2,3,7,8-TCDD toxicity
equivalent of zero. All sediment samples collected in Naylors
Run did contain dioxin isomers, although in low concentrations
outside the immediate vicinity of the catch basin.
Storm Sewer
Volatile organic compounds, PCP and dioxin were found in water
samples collected from station 02A. A TV inspection of the storm
sewer indicated numerous points of ground water inflow and what
appeared to be oil stains at pipe joints. The presence and
concentration of these compounds, mentioned above, reflect the
ground water contribution to the water in the storm sewer.
A sediment sample collected from the drainage swale located
adjacent to NWP indicated the presence of PCP in a concentration
of 20,000 /ng/kg. The location of this sample supports the
assertion that some of the sediment contamination in Naylors Run
is a direct result of surface soil erosion from NWP.
9
-------
B. Fate and Transport
Several contaminant migration pathways have been documented in
this investigation. Contaminants were previously directly
introduced into the ground water through an injection well.
Evidence suggests that contaminated surface soil has been eroded
from NWP and transported to Naylors Run via the storm sewer.
Once contaminants have entered Naylors Run, they may be
transported in the surface water, sediments, or through
bioaccumulation processes.
Ground Water Pathway
Ground water from the shallow hydrologic zone is discharging into
the reach of Naylors Run below the catch basin. The calculated
flow velocity in the shallow hydrologic zone is approximately 85
feet per year. Based on the length of time NWP has been in
operation, contaminants in the shallow hydrologic zone could have
migrated approximately 3400 feet in the last 40 years. However,
this investigation indicates that PCP has just reached well HAV-
07, located only 800 feet from NWP. It is believed that the
storm sewer behind the PCG building is intercepting some shallow
ground water and acting as a conduit for transport of ground
water into Naylors Run. Factors such as dilution, adsorption
onto soil, biodegradation, and transformation could also be
inhibiting further migration of contaminants in the ground water.
Ground water flows downward from the shallow hydrologic zone to
the deep hydrologic zone on NWP but has an upward direction of
flow in wells on PCG property. The deep hydrologic zone is
therefore probably providing some recharge to the shallow
hydrologic zone in the vicinity of Naylors Run. Some portion of
the ground water in the deep hydrologic zone likely travels under
Naylors Run via fractures and discharges further downgradient (to
the southeast). Ground water flow velocity in the deep
hydrologic zone, within fractured bedrock, is estimated to be 25
feet per year.
Free petroleum product was observed in wells R-2 and HAV-02. The
product is considered a Light Non-Aqueous Phase Liquid (LNAPL).
The lateral extent of the free product plume has apparently
decreased with time. Because the LNAPL is by definition less
dense than water, it will not directly affect the deep hydrologic
zone. The decrease in lateral extent and thickness of free
product may, however, be associated with a recent increase in the
concentration of PCP in the shallow hydrologic zone.
Surface Water Runoff Pathway
To date, our investigation has determined that ground water is
not providing any base flow to the reach of Naylors Run above the
10
-------
catch basin. Contaminants that are found in this section of
Naylors Run have likely travelled in surface water runoff from
NWP property. A comparison of contaminants in the surface soil
on NWP and contaminants found in the sediments of Naylors Run
indicates many of the contaminants found in the soil are present
in the sediment. Additionally, the presence of PCP at a
concentration of 20,000 ug/kg and dioxin isomers, with a
2,3,7,8-TCDD toxicity equivalent of 20.8 ppt, in the drainage
swale adjacent to NWP which drains directly to Naylors Run
provides additional evidence for the viability of this pathway.
Transport in Naylors Run
The flow characteristics of Naylors Run, combined with grain size
data indicate that the sediment is probably transported only
during high flow storm events. Dilution, diffusion, photolysis,
and biodegradation may act on contaminants dissolved in the
surface water. However, a close match between the predicted and
observed downstream decrease in PCP concentrations can be
accounted for by dilution alone. Bioaccumulation of contaminants
may also play a role in transport of contaminants in Naylors Run;
however, its role is difficult to quantify.
6. Summary of Site Risks
A. Human Health Risks
Contaminant Identification
Table 6 lists the chemicals of potential concern for all.media
at the Havertown PCP site. Over forty chemicals were selected as
chemicals of potential concern for the Havertown PCP site,
including volatile organic compounds, PCP, PAHs, pesticides,
dioxins and furans, and inorganics. Of these chemicals, PCP,
PAHs, and dioxins appear to be the primary chemicals of potential
concern in all media at the Havertown PCP site. Other chemicals
selected as chemicals of potential concern in all media include:
aluminum, arsenic, cobalt, and manganese. Several volatile
organic compounds selected as chemicals of potential concern were
detected only in ground water, including 1,2- dichloroethene,
trichloroethene, and vinyl chloride. The exclusive presence of
these chemicals in ground water may be due to their high water
solubility, low affinity for binding to sediment particles, and
potential volatilization from surface water to .the air. The
pesticides dieldrin and heptachlor epoxide were only detected in
Naylors Run surface water. The majority of the PAHs were found
only in sediment samples, probably due to their low water
solubility and high affinity for binding to sediment particles.
11
-------
Table 6
Summary of Che-meal s of Potential Concern for the Havertown PC? Site
1
Organlcs:
II acenaohthene
acenaohthylene
anthracene
benzene
benzo(a)anthracene
benzo(a)oyrene
benzo(a)pyrene (Equivalent)
benzo ( b ) f 1 uoranthene
benzo ( g , h . 1 ) pery 1 ene
benzo ( k ) f! uoranthene
bl s ( 2 -ethyl hexy 1 ) phthal ate
chlordane(Total)
chrysene
d1benzo(a.h)anthracen«
dlbenzofuran
1.2-dlchloroethent
dleldrln
endosulfan sulfate
fl uoranthene
heptachlor epoxida
1ndeno(1.2,3-c.d)Pyrene
naphthalene
2 -«ethyl naphtha 1 ene
pentachl orophenol
phetianthrene
pyrene
2.3.7.8-TCOO (Eoulvaltnt)
ItHchloroethene
vinyl chloride
Inorganics:
aluminum
antimony
arsenic
barium
chromium
cobalt
lead
manganese
mercury
nickel
thalliua
vanadium
zinc
Ground
-Water
Naylors Run'
Surface
water
Sedi-
ment
X X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Storm Sewer
Surface
Water
X
Sedi-
ment
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
POOR QUALITY.
ORIGINAL
-------
Several inorganic chemicals of potential concern, including
antimony/ nickel, thallium, vanadium, and zinc, were detected
only in Naylors Run. It is uncertain whether some of these
chemicals are actually associated with site-related disposal.
Exposure Assessment
The various pathways of exposure were evaluated as listed in
Table 7. It was determined that the pathway of major concern was
exposure to the surface water and sediments in Naylors Run
(through dermal absorption and incidental ingestion) by children
playing there. Also of current concern is bioaccumulation by
fish caught in Cobbs Creek and subsequent ingestion by the
general population and, more specifically, by mothers who are
nursing infants. In future use scenarios, the use of ground
water by residents for either ingestion or showering purposes was
considered a pathway of concern.
The exposure point concentrations used for each contaminant of
concern in each media are listed in Table 8. All exposure
parameters used to evaluate risks for each scenario are listed in
Table 9 and 10. The estimated chronic daily intakes of
contaminants of concern for each of the scenarios listed above
are provided in Tables 11 and 12.
Conservative assumptions were used to quantitatively estimate
exposure for the various pathways evaluated in this report. The
area in question is a stream (Naylors Run) running through
residential and industrial areas. The stream is used to carry
off storm water although industrial and residential contaminants
also enter it. Under current land-use conditions, it was assumed
that children would play in the more contaminated areas of the
Naylors Run 125 days per year for 10 years and during these play
activities, children would incidentally ingest 140 mg of sediment
each day. In addition, children were assumed to contact surface
water and sediments over one-third of the surface area of their
hands, arms, and legs. These are conservative assumptions used to
evaluate a reasonable maximum exposure case. The likelihood of
children in the area actually engaging in such behavior is
unknown.
For the fish ingestion pathway, recreational fishermen were
assumed to ingest an average of 42 grams (1.5 oz.) per day of
bottom feeding fish from Cobbs Creek. No data were available for
game fish which are more likely to be ingested by recreational
fishermen. Game fish may have much lower concentrations of
organic contaminants in their tissue than bottom feeding fish
given the differences in their foraging behavior. Therefore,
potential exposure levels may be overestimated.
For a hypothetical future land-use exposure pathway, it was
assumed that an individual would ingest 2 liters per day of
12
-------
o»
I
u»
ro
Table 7
Potential Human exposure Pathways for the Hatertown PCP Site
Under Current land-Use Conditions
exposure Media
(a)
Groundwater
Surface Water/
Sediments
Air
Biota
exposure Point Potential
Receptor
No exposure
point
Storm Sewer Children
playing:
Workers
Cleaning sumps
Naylors Run Children
Playing
On-sile and in Residents and
residential workers
areas
Fish caught Recreat lona 1
fromCobbs fisherman
Creek
Primary exposure Routes
Dermal absorption and
Incident* 1 Ingest Ion of
sediments and dermal
absorption of chemicals
in surface water
Derma 1 absorpt ion and
incident* 1 ingest ion of
sediments and dermal
absorpt Ion of cheated Is
In surface water
Inhalation of VOCs from
groundwater seeps and
storm sewer discharges
(releases from soils
evaluated In Phase 1
RIM*)
Ingest Ion of contaminated
fish I Issue by fishermen
and subsequent exposure
fxposure Pathway Complete?
No. (here are no residential or
industrial wells currently In use within
the Havertown PCP study are*.
Tes. It Is highly unlikely, however.
that children would be exposed to storm
sewer sediments to any significant
extent. Worker exposure to storm sewer
sediments would be very infrequent and
contact minimized by protective clolliiiiij
Yes. children may play In Naylors Nun in
the vicinity of the site
Tes. It is unlikely. Imwuvvr. Hut
significant releases of volatile would
occur form surface water, given the
minimal concentrations of VOCs in surf die
water. Oust would not be generated I rum
contaminated sediments.
Tes. Chemicals of concern that may
bloactumulato to significant levels in
fish tissue have been found. Fish tissue
8°
0.
Pathway Selected
for Quantitative
Ivalual ion?
No, pathway not
complete.
No. due to low
probability of
sign if leant
exposure.
Yes
No, ilue to low
piolidln lily nf
siynil leant
exposure.
Yes
to nursing Infants via
ingest Ion of breast milk
from mothers that consume
fish.
data from the NBS UP A I990b| were used
in this assessment. Nursing infants dho
may be at risk If the mother consumes
significant quant it ies> of fish (rum Cuuhs
Creek.
Soil related exposure routes were evaluated in the Phase I Rl baseline risk assessment (Greeley-Polnemus Croup. I909)
-------
Table 7 (cont)
Potential HuBuin rxposure Pathways for the Hdvertimn PIC Site
Under future land-Use Conditions
Exposure NedI*
Exposure Point Potential
Receptor
Primary Exposure Routes
Exposure Pathway Complete?
Pathway Selected
for quantitative
{valuation?
Groundwater
Hypothetical
Residential
Well
Resident
Ingest Ion of groundwater
and Inhalation of VOCs
while showering. Also.
nursing Infants may be
exposed to significant
levels of dloxtn fro»
mothers that Ingest
groundwaler.
Ves. If a Hell «*re Installed In the
primary areas of concern at the sit*,
then significant exposure to chemicals of
concern nay occur via direct use of
groundwater and Indirect exposure to
nursing infant* that ingest breast mlk
fro* exposed mothers. Although I IMS
probability of this pathway ociiirrinu is
low. it Is evaluated prinarily to justify
(Hitentlal icnedlation of groundvaler fur
the site
Tes
Surface Water/
Sediments
Air
Biota
same as current land-use of the Havertown PCP site
same as current land-use of the Havertown PCP site
sane as current land-use of the llaverlown PCP site
(a) Soil related exposure routes were evaluated in the Phase I Rl baseline risk, assessment (Gieelty I'olhemus Or
oup. 1969).
-------
Table 8
Exposure Point Concentration for Chemicals
of Concern
GROUNDWATER
POINT
CONCENTRATION
ORCANICS:
Benzene
1,2-oichloroetnene (total) (d)
b's(2-ethylhexyl)phthalate (d)
Benzo(a) pyrene (Equivalent)
Fluoranthene
Naphthalene
Pentacnlorophenol
2,3,7,8-TCDD (Equivalent)
Trichloroethene (d)
vinyl cnloride (d)
Inorganics:
Arsenic
Manganese
Thallium (d)
230.0
245.0
180.0
741.9
810.0
24,000.0
80,000.0
0.17
465.0
9.1
22.7
22,600.0
1.7
SURFACE WATER
POINT
CONCENTRATION
Naylors Run
organics:
Dieldrin
Heptachlor Epoxide
B«nzo(a)pyrene (Equivalent)
Pentachlorophenol
2/3/7/8-TCOO (Equivalent)
Inorganics:
Manganese
Tnalliua
1,200.0
3.0E'*
10.1OO.O
3.3
Fi«h TiMUe Suple*
From Cobbs Cr»ek
(b)
Chlord»ne (total)
Dialdrin
Keptacnlor Epoxide
2/3/.7,8-TCDO (Equivalent)
gongentr»tion in up/lea
BlacX Bull&wui (c)
59.0
63
8.6
0.0013
White Sucker (d)
238
4SO
37
0.007
SEDIMENTS
(ug/icg)
Exposure
CONCENTRATION
Organics :
ChlordaiM (total
Benzo(a)pyrene (Equivalent)
Fluorantnene
Pentacnloropnenol
2/3/T/8-TCOO (Equivaleivt
Inorganics :
Anatony
Arsenic
Bariua
chroaiun
Manganese
Nickel
Thallium
vanadiua
Point
230.0
28,061.7
21,000.0
3,000.0
0.118
14.1
37.6
41S.O
S32.0
4,750.0
33.0
1.0
118.0
POOR QUALITY
ORIGINAL
-------
Table 9
EXPOSURE PARAMETERS
PARAMETER CHILDREN CONTACTING CHILDREN FISHERMAN GROUND
SURFACE WATER INGESTING INGESTING WATER
SEDIMENTS IN FISH INGESTION
NAYLORS RUN
Surface Area in
contact
(50th Percentive)
Permeability
Exposure Time
Exposure
Duration
Exposure
Frequency
Averaging Time
Mean Body
Weight
Ingestion Rate
Percent ingested
Relative
Bioavailability
Factor
100 cm2
8.4. 10-" cm/hr
2.6 hrs./day
10 years
125 days/year
25,550 days
3,650 days
(non-carcingenic)
25kg
10 years
125 days/year
25,550 days
3,650 days
25kg
140 ing/day
100%
.5 per SV
IforVOC
30 years
365 days/year
25,550 days
10,950 days
70kg
41.7 g/day
100%
30 years
365 days/year
25,550 days
10,950 days
70kg
2 I/day
-------
Table 10
Exposure Parameter To Nursing Infants
Description Value
Kilograms of breast milk ingested by the infant
per day.
Proportion of maternal dioxin and furan in fat.
Proportion of maternal weight that is fat
Proportion of breast milk that is fat
Troportion of dioxin and furan absorbed
Maternal Exposure to Dioxin Equivalents
Half-life of dioxin equivalents
Elimination rate constanct (c)
Adjusted Elimination rate constant (e)
Maternal weight
Infant body weight at one year
Duration of lactation
Averaging time for evaluating noncarcinogenic
effect.
Averaging time to evaluating carcinogenic effects
0.8 kg/day
51%
0.3
0.036
0.68
Pathway specific
1.825 days
(i.e., 5 years)
3.8E-4
1.1E-3
70kg
8.3
730 days
(i.e., 2 years)
1,825 days
(i.e., 5 years)
27,375 days
(i.e., 75 years)
-------
Table 11
Chronic Daily intakes (COIt) £st'«utttf for Qircct
Contact «itn Surfact Water from Kaylors Run
by Children <
Ch«ica1 (a)
RM
Exocjurt Point
Conctntration
(ug/l)
«M£ COIf
(mg/kg/day)
Carcinogens
Noncarcmogfns
Organ ics:
Oieldrin
Neotachlor Eooxide
Benzo(a)pyrene (Equtlavent)
Pentacn loroon*no 1
Inorganics:
MangancM
Thai HUB
0.3
0.6
0.3
1.200
3.QE-4
10.100
3.3
1.3E-9
3.4E-9
1.3E-9
5.2E-6
1.2E-12
9.0E-9
2.4E-0
9.0E-9
3.6E-5
8.7E-12
3.0E-*
9.9E-8
Chronic Daily Intakes (COts) £jt»«ted for 0
-------
Table 11 (cont)
Chrome 0*l1y Intttw (COIt) Cstiwtad for
Ingestion of Fish Cttiont OoMtstrt*»
fro* cm N*v«rtOMt Kf S(t« in Cotts Crc*
Chemica1
RM£
Exposure Point
Concentration
(Units: ug/kg)
RME GDI
Carcinogens
Noncarcmogens
Chlordane (total)
Dieldrin
Heptachlor Epoxide
2,3-,7_,8-TCOO (Equivalent)
236
450
37
0.007
6.1E-5
1.2E-4
9.SE-6
8C-9
2.7E-4
2.2E-5
4.2E-9
POOR QUALIT,
ORIGINAL
-------
Table 12
Chronic Daily intakes (GDIs) Estimated for Ingestion of
Groundwater from the Havertown PCP Site by Hypothetical
Residents
Chemical
RME
Exposure Point
Concentration
(ug/L)
RME GDIs
(mg/kg/day)
Carcinogens
Noncarcinogens
Organics:
Benzene 230
1.2-Dichloroethene (total) 245
bis(2-Ethylhexyl)phthalate 180
Benzo(a)pyrene (Equivalent) 741.9
Fluoranthene 810
Naphthalene 24,000
Pentachlorophenol 80,000
Trichloroethene 465
Vinyl Chloride 9.1
2,3,7,8-TCDD (Equivalent) 0.174
Inorganics:
Arsenic 22.7
Manganese 22,600
Thallium 1.7
2.8E-3
2.2E-3
8.9E-3
9.6E-1
5.6E-3
1.1E-4
2.1E-6
2.7E-4
6.6E-3
7.1E-3
5.2E-3
2.2E-2
2.3E-2
6.8E-1
2.3E+0
1.3E-2
2.6E-4
5.0E-6
6.5E-4
6.4E-1
4.9E-5
Chronic Daily Intakes (GDIs) Estimated for
Nursing Infants Exposed to 2.3.7.8-TCDD (Equivalent)
via Ingestion of Contaminated Breast Milk
Maternal
Exposure
Pathway(a)
Maternal
GDI
(mg/kg/day)
Nursing Infant GDI
Carcinogens Noncarcinogens
(b) (c)
Current Land-Use;
Ingestion of fish
Future Land Use;
Ingestion of groundwater
4.2E-9
5.0E-6
8.4E-10
l.OE-6
3.3E-8
3.9E-5
-------
ground water from more contaminated areas at the site over a 30
year period.
Toxicitv Assessments
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) ~1, are
multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper bound estimate 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 CPFs. 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. CPFs for chemicals of concern are listed in Table 13.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of daily exposure
levels for humans, including sensitive individuals that are
likely to be without an appreciable risk of adverse health
effects. Estimated intakes of chemicals from environmental media
(e.g.. the amount of chemical ingested from contaminated drinking
water) can be compared to the RfD. RfOs 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 insure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur. The reference doses
used for each chemical of concern are listed in Table 14. This
information has been derived from IRIS or Heast data.
Risk Characterization
Excess lifetime cancer risks are determined by multiplying the
intake levels by the cancer potency factor. These risks are
estimates that are generally expressed in scientific notation
e.g., IxlO"6 or 1E-6. An excess lifetime cancer risk of IxlO"6
indicates that, as a plausible upper bound, an individual has an
additional one in one million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year
lifetime under specific exposure conditions at the site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
13
-------
Table 13
Chronic Carcinogenic Toxicity Criteria (SFs)
for Chemicals of Concern at the Havertown PCP Site
Route/Chemical
Slope Factor (SF)
(mg/kg/day)
(Potency Factor)
Oral Route
Organics:
Benzene
Benzo(a)pyrene (Equivalent)
Chlordane (total)
Dieldrin
bis(2-Ethyhexyl)phthalate
Heptachlor Expoxide
Pentachlorophenol
2,3,7,8-TCDD (Equivalent)
Trichloroethene
Binyl Chloride
Inorganics:
Arsenic
Inhalation Route
Benzene
Trichloroethene
Vinyl Chloride
2.9E-2
1.2E+1
1.3E+0
1.6E+1
1.4E-2
9.1E+0
1.2E-1
1.5E+5
1.1E-2
1.9E+0
1.7E+0
2.9E-2
1.7E-2
3.0E-1
-------
Table 14
Chronic Noncarcinogenic Toxicity Criteria (RfDs)
for Chemicals of Concern at the Havertown PGP Site
Chemical
Chronic RfD
(mg/kg/day)
(oral route)
Organics:
Chlordane (total)
1,2-Dichloroethene (total)
Dieldrin
bis(2-Ethylhexyl)phthalate
Fluoranthene
Heptachlor Epqxide
Naphthalene
Pentachlorophenol
2,3,7,8-TCDD (Equivalent)
Inorganics:
Antimony
Arsenic
Barium
Chromium (hexavalent)
Manganese
Nickel
Thallium
Vanadium
6.0E-5
2.OE-2
5.0E-5
2.OE-2
4.OE-2
1.3E-5
4.0E-3
3.OE-2
l.OE-9
4.0E-4
l.OE-3
7.OE-2
5.0E-3
l.OE-1
2.OE-2
7.0E-5
7.OE-3
-------
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference). 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. The (HI) provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
The results of the Baseline Risk Assessment are included in Table
10 and are summarized as follows:
Carcinogenic contamination in sediments may present a potential
human health impact from direct contact, particularly to children
playing in Naylors Run. Chemicals of concern are arsenic and
benzo(a)pyrene. The potential excess carcinogenic risk is
calculated to be 1 x 10~4' which translates to 1 additional
cancer per 10,000 exposed individuals. This level of risk is
considered to be marginally unacceptable to EPA as the range of
acceptable risk is considered to be between 1 in 10,000 to 1 in
1,000,000. The actions of this operable unit will not remediate
the sediments, but will act as a first step in remediating the
sediments by removing contaminants from the ground water.
Pesticides and dioxin in surface water and sediments may also
contribute to carcinogenic and noncarcinogenic health risks
associated with the ingestion of fish further downstream and
subsequent indirect exposure to nursing infants. It was
calculated that an additional carcinogenic risk due to fish
ingestion exists for 2 persons in 1000 and the additional
noncarcinogenic risk is about 13 times higher than desirable. It
was calculated that an additional carcinogenic risk to nursing
infants whose mothers have ingested fish from Cobbs Creek exists
for 1 in 10,000 persons and the additional noncarcinogenic risk
is 33 times greater than desirable.
With the exception of the 3 recently discovered families who use
ground water for drinking, no one currently uses the ground water
in Havertown Township for drinking. Under a theoretical future
use scenario of widescale use of ground water for drinking,
elevated carcinogenic risks and noncarcinogenic risks associated
with the ingestion of ground water may exist due to PAHs, PCP,
and dioxin contamination. It was calculated that an additional
future carcinogenic risk exists for 1 out of 2 persons who might
regularly ingest ground water over a lifetime. It was also
calculated that the future noncarcinogenic risk is 5000 times
above desirable if ground water was regularly ingested.
Concentrations of these chemicals in monitoring wells installed
along the periphery of the study area may present risks of
concern with respect to future residential use of ground water.
14
-------
A summary of the potential carcinogenic and noncarcinogenic risks
estimated for the exposure pathways quantitatively evaluated in
the Havertown PCP baseline risk assessment are presented in Table
15 and discussed below.
Ecological Assessment
There is a significant body of documentation that identifies the
Havertown PCP Site as a historical source of contamination of
Naylors Run. PCP does not appear to be the single major factor,
rather total semi-volatiles appear to be most important.
Historically, ground water discharge was thought to be the major
source of contamination in Naylors Run. This source has been
partially addressed by the construction of the oil/water
separator. Chemical data suggest that a present source of much
of the contamination may be surface runoff from the Havertown PCP
Site 'and the surrounding properties. Another source of potential
contamination is urban run-off. During storm events, Naylors Run
acts as a conduit for run-off. Significant concentrations of
chemicals could potentially be introduced into Naylors Run in
this fashion. In addition, high flow during storm events acts as
a flushing mechanism, resulting in surges of particulate
transport.
There were no Federal or State endangered or threatened species
of special concern observed within the Naylors Run portion of
Havertown PCP. There was no observed site related stress to
terrestrial vegetation. Modeling has indicated the potential for
toxicity to occur in terrestrial birds through surface water
ingestion. Potential exposure of waterfowl exists for toxicity
through ingesting contaminated water and food.
Conclusion
Although Naylors Run shows signs of impairment, there is evidence
of improvement when compared to historical conditions. If point
sources are eliminated in the vicinity of Havertown PCP, Naylors
Run may further improve. However, due to channelization, severe
flushing during storm events, and urban run-off, Naylors Run is
not expected to be able to support a high quality aquatic
community. The sediment contamination in Naylors Run will be
addressed as part of OU3.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
15
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7. Description of Alternatives
The Superfund statute and regulations require that the
alternative chosen to clean up a hazardous waste site meet
several criteria. The alternative must protect human health and
the environment, meet the requirements of environmental
regulations, and be cost effective. Permanent solutions to
contamination problems should be developed wherever possible.
The solutions should reduce the volume, toxicity, or mobility of
the contaminants. Emphasis is also placed on treating the waters
at the site, whenever this is possible, and on applying
innovative technologies to clean up the contaminants.
In accordance with 40 C.F.R. §300.430, a list of remedial
response actions and representative technologies were identified
and screened to meet the remedial action objectives at this site.
The Feasibility Study (FS) investigated a variety of technologies
to see if they were applicable for addressing the contamination
at the site. The technologies determined to be most applicable
to these materials were developed into remedial alternatives.
These alternatives are presented & discussed below. All costs &
time frames provided fcr the alternatives below are estimates.
Four alternatives for remediation of the ground water in the
shallow aquifer were examined. The first required alternative is
No Action (GW-1), which includes limited monitoring.
The second alternative (GW-2) is a Limited Action that includes
institutional controls, deed restrictions, and monitoring.
The third alternative (GW-3) includes features from GW-2 plus
Source Removal in the form of free product recovery from the
shallow aquifer near NWP, treatment of the discharge from the
existing oil/water separator, and disposal via discharge of
treated water to Naylors Run.
The fourth alternative (GW-4) included features from GW-3, with
the addition of collection via installation of a new collector
drain, and containment using rehabilitation and lining of the
existing storm sewer pipe.
A. Alternative GW-l-No Action
Description; The no action alternatives is the baseline ground
water remediation alternative. The No Action alternative for
ground water would not include any new remedial action, but would
include limited monitoring activities.
Limited monitoring of the levels of contaminants in the ground
water would continue up to a thirty year period, with an
anticipated sampling frequency of two times per year for the
first five years, and yearly sampling for the next twenty-five
16
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Table -
Conclusions of the Havertown PCP
Baseline Risk Assessment
POOR QUALITY
ORIGINAL
[xpo*ure Pathway
Potential
Carcinogenic
Risk
Potential
Moncarclnogentc
Risk
(Hazard Index)(HI)
Comnents
land-Use Conditions
Children Playing in
Naylors Run
IE-4
Ingest ion of Fish from
Cobbs Creek
2E-3
13 6
Relatively low risk from direct contact with surface
water. Majority of the potential carcinogenic risk
associated with Benio(a)pyrene (equivalent) and
arsenic In sediment*. Highest levels of
bento(a)pyrene (Equivalent) and arsenic were found
upstrtM of the catch basin. HI slightly below
unity; therefore, noncarclnogenlc risk may not occur.
Carcinogenic risk exceeds the upper-bound of NCP
acceptable risk range (I.e.. 10). Majority of
carcinogenic risk fron dieldrln which was detected In
surface water at Naylors Run. HI exceeds unity;
therefore, recreational flshenmn that Ingest
significant quantities of fish from Cobbs Creek My
experience noncarclnogenlc effects. Chlordane,
dieldrln, heptaehlor epoxlde, and dioxin in fish all
contributed significantly to risk. Unclear whether
these chemicals are associated with the site.
Indirect Exposure to Nursing
Infants (Maternal exposure
from Ingest ton of fish)
IE-4
33
Increased carcinogenic risk from dioxin equals the
upper-bound of the NCP acceptable risk range
(I.e., 10 ). Haiard quotient for dioxin exceeds
unity for chronic exposure and 10-day health
advisory. Therefore, nursing infants May experience
adverse liver and developmental effects.
-------
Table 15 (Coot |
Cone lus ioni or ine Havertown PCP
Baseline Risk Assessment
POOR
ORIGIN*1-
Cipoiure Pathway
Potent laI
Carcinogenic
Risk
PotentlaI
Noncarclnogenlc
ftlsk
(Haiard Index)(HI)
COMMtS
future Land-Use Conditions
Ingest Ion of Groundwater
by Hypothetical Resident
SI-I
510
Inhalation of VOCS In
Groundwater by Hypothetical
Residents Hhlle Showering
«MO«)
Indirect fxposure to Nursing
Infants (Maternal exposure from
Ingest Ion of groundwater)
If-l
4[«4
Carcinogenic risk Is 1.000.000 tlws higher than the
the NCP point or departure (I e.. 10r) and 10.000
tleas higher tlwn the upper-bound of the UCP
acceptable risk range. Ihe sujorlty of the
carcinogenic risk associated with beiuo(a)pyrene
(e<)uUalent). PCP. and d(o«ln (See figure 6-t for
spatial distribution of cancer risk). HI exceeds
unity by a factor of MOO (reproductive effects), the
MJorlty of the noncarclnogenlc risk associated with
dloxln. exposure to dloxln also exceeds I-day and
10-day health advisories (adverse liver effects).
Carcinogenic risk f rae beniene. ICC, and vinyl chloride
exceeds wiper-bound of the NCP acceptable risk range
(I.e..10*). The rink fro* showering, however, does
not contribute significantly to risk fro* Ingest Ion.
Highest levels of VOCs In groundwater upgradlent fro*
PAH. PCP. and dloxln "hot spots." HI slightly
exceeds unity, due to exposure to ICC.
Increased carcinogenic risk fro* dloxln exceeds the
upper-bound of the NCP acceptable risk range (I.e..
(I.e.. I0*| by a factor of 1.000. Haiard quotient
for dloxln exceeds unity by a factor of 39.000; as
well as I-day and 10-day health advisories by factors
of 390 and 3.900 respectively. Therefore, nursing
Infants stay experience developnental problems fro*
chronic exposure and liver problem from subchronlc
and acute exposure.
-------
years. The sampling would include sampling approximately three
well clusters (nine wells) and two stream locations. The samples
would be analyzed for the Target Analyte List (TAL), Target
Compound List (TCL), and Dioxins.
Cost: There is no capital cost associated with the No Action
alternative. There would be O&M costs for the limited monitoring
program. The cost of monitoring the discharge from the existing
oil/water separator (OWS) is included in the O&M costs for the
Remedial Action initiated by the 1989 ROD.
A description of the estimated costs for this alternative are
summarized as follows:
Capital Cost: $ 0
Estimated
O&M per Year: $ 80,000 (first five years)
$ 40,000 (next twenty-five years)
Present Worth: $ 715,000 (thirty year period) '
Time to Implement: Immediate Implementation
Compliance with Applicable or Relevant and Appropriate
Requirements fARARs}
This ROD and its associated remedial action is considered to be
an interim action. This action is not meant to achieve
groundwater cleanup ARARs, which will be evaluated in connection
with the final remedy for the site. The remedy selected will
however, comply with ARARs directly associated with this limited
scope action. This interim action is in furtherance of, and not
inconsistent with, the planned final remedy which will finally
evaluate, among other things, the clean up of ground water. When
the final ROD for ground water is issued, ground water ARARs will
have to be met or waived. However, this ROD will identify the
ARARs, and all remedial actions taken will seek to comply with
ARARs to the maximum extent possible or to make progress toward
meeting all ARARs so that the final remedy can more easily and
fully comply with ARARs.
The known ARARs for chemicals of concern are as follows:
Air Emissions
The National Emissions Standards for Hazardous Air Pollutants set
forth in 40 C.F.R. $61.64(b) and promulgated under the Clean Air
Act, 42 U.S.C. Section 7401.
PA Air Pollution Control Act and Air Discharge Regulations, 25 PA
17
-------
Code, Sections 123.1, 123.2, and 127.12(a)(5)
Waste Management
Standards Applicable to Generators of Hazardous Waste (40 C.F.R.
Part 262)
Standards Applicable to Transporters of Hazardous Waste (49
C.F.R. §171.1-171.16)
Regulations and Standards for owners and operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities (40 C.F.R. Part
264)
Land Disposal Restrictions (LDR) Requirements (40 C.F.R. §268.1-
268.50)
Dioxin Containing Waste (50 Fed. Reg. 1978)
PA Hazardous Management Regulations (25 PA Code Subchapter D,
Sections 260.2 through 260.22, 261.1 through 261.34, 262.10
through 262.60, and 263.10 through 263.32 relating to the
identification and determination of hazardous waste, generator
and transporter rules and regulations.
Occupation Safety and Health Act (OSHA)
OSHA, 29 C.F.R. §1910.170
Surface Water
Clean Water Act, NPDES discharge regulations (40 C.F.R. §§122-
124)
PA Clean Streams Law (PA Code Title 25, Chapter 5)
PA NPDES Regulations (PA Code Title 25, Chapter 93.1 through 93.9
and 16, 92, 95, and 101)
Ground Water
PA Hazardous Waste Management Regulations (25 PA Code Section
264.90 through 264.100)
The No Action alternative would involve only the monitoring of
the existing ground water and would not remediate the ground
water contamination. Therefore, it is believed that this
alternative would be in compliance with air emissions, waste
management, and OSHA ARARs. The air emission ARARs would be
applicable to the possible volatilization of contaminants during
monitoring. The waste management ARARs would be applicable to
any wastes-generated (such as contaminated ground water,
18
-------
protective clothing, etc.) during monitoring and OSHA ARARs would
apply to all work done during monitoring. While this is an
interim ROD for ground water, the air emissions, waste management
and OSHA standards identified above are ARARs for this interim
action and would be met by this alternative.
This alternative would not meet any of the surface water ARARs as
it does not provide any remediation of surface water. As noted
above, ground water cleanup levels are not intended to be finally
addressed in this remedial action and, therefore, ground water
cleanup levels are not ARARs.
B. Alternative GW-2: Limited Remedial Action
Description; This alternative includes the elements listed in
the No Action alternative as well as additional monitoring
activities and institutional controls and deed restrictions. An
estimated total of five clusters and two stream locations would
be sampled. The samples would be analyzed for TAL, TCL, and
Dioxins. Approximately two new monitoring well clusters would be
installed to the east of Naylors Run.
Institutional controls would be geared toward limiting exposure
to contaminants at this site, by restricting use of the ground
water (e.g. deed restrictions), or limiting access to the
contaminated surface water (e.g. fencing). There is no assurance
that the institutional controls would be effective.
The additional well clusters would be used to better define the
levels of contamination in the deep bedrock aquifer.
This alternative could be implemented in a relatively short time
frame. Various affected residents would be contacted by to
initiate deed changes. The local governmental agency and
community would be involved in implementing the necessary zoning
changes. Deed and zoning changes are implementable, and this
activity could provide the opportunity to increase community
awareness and interest in the site. Additional resources would
need to be committed to install the new wells and for the
increased monitoring activities.
Cost: There is a capital cost associated with installing the
two new well clusters, and processing the paperwork necessary for
the deed and zoning changes for the Limited Action alternative.
The 0 & M cost for limited monitoring of the levels of
contaminants in the ground water would continue for up to a
thirty year period, with an anticipated sampling frequency of two
times per year. A description of the estimated costs for this
alternative summarized as follows:
Capital Cost: $ 198,000
O&M per year: $ 162,000
Present Worth: $1,900,000
Time to Implement: Several months
19
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Compliance with Applicable or Relevant: and Appropriate
Requirements (ARARs)
This ROD and its associated remedial action is considered to be
an interim action. This action is not meant to achieve
groundwater cleanup ARARs, which will be evaluated in connection
with the final remedy for the site. The remedy selected will
however, comply with ARARs directly associated with this limited
scope action. This interim action is in furtherance of, and not
inconsistent with, the planned final remedy which will finally
evaluate, among other things, the clean up ofground water. When
the final ROD for ground water is issued, ground water ARARs will
have to be met or waived. However, this ROD will identify the
ARARs, and all remedial actions taken will seek to comply with
ARARs to the maximum extent possible or to make progress toward
meeting all ARARs so that the final remedy can more easily and
fully, comply with ARARs.
The known ARARs for chemicals of concern are as follows:
Air Emissions
The National Emissions Standards for Hazardous Air Pollutants set
forth in 40 C.F.R. $61.64(b) and promulgated under the Clean Air
Act, 42 U.S.C. Section 7401.
PA Air Pollution Control Act and Air Discharge Regulations, 25 PA
code, Sections 123.1, 123.2, and 127.12(a)(5)
Waste Management
Standards Applicable to Generators of Hazardous Waste (40 C.F.R.
Part 262)
Standards Applicable to Transporters of Hazardous Waste (49
C.F.R. §171.1-171.16)
Regulations and Standards for owners and operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities (40 C.F.R. Part
264)
Land Disposal Restrictions (LDR) Requirements (40 C.F.R. $268.1-
268.50)
Dioxin Containing Waste (50 Fed. Reg. 1978)
PA Hazardous Management Regulations (25 PA Code Subchapter D,
Sections 260.2 through 260.22, 261.1 through 261.34, 262.10
through 262.60, and 263.10 through 263.32 relating to the
identification and determination of hazardous waste, generator
20
-------
and transporter rules and regulations.
Occupation Safety and Health Act (OSHA)
OSHA, 29 C.F.R. §1910.170
Surface Water
Clean Water Act, NPDES discharge regulations (40 C.F.R. §§122-
124)
PA Clean Streams Law (PA Code Title 25, Chapter 5)
PA NPDES Regulations (PA Code Title 25, Chapter 93.1 through 93.9
and 16, 92, 95, and 101)
Ground Water
PA Hazardous Waste Management Regulations (25 PA Code Section
264.90 through 264.100)
The Limited Action alternative would involve only the monitoring
of the existing ground water and would not remediate the ground
water contamination. Therefore, it is believed that this
alternative would be in compliance with air emissions, waste
management, and OSHA ARARs. The air emission standards would be
ARARs for the possible volatilization of contaminants during
monitoring. The waste management standards would be ARARs for
any wastes generated (such as contaminated ground water,
protective clothing, etc) during monitoring and OSHA ARARs would
arise in connection with all work done during monitoring. While
this is an interim ROD for ground water, the air emissions, waste
management and OSHA standards identified above would be ARARs for
this interim action and would be met by this alternative.
This alternative would not meet any of the surface water ARARs as
it does not provide any remediation of surface water. As noted
above, ground water cleanup levels are not intended to be finally
addressed in this remedial action and, therefore, ground water
cleanup levels are not ARARs for this action.
C. Alternative GW-3: Source Removal. Treatment. & Disposal
Description; This alternative includes features which will
actively treat the contaminated ground water presently
infiltrating into the storm sewer at the site. This includes
free-product recovery from the shallow aquifer in the
vicinity of NWP; treatment by the existing oil/water separator
(OWS); chemical precipitation; either of two treatment systems
(Powdered Activated Carbon Treatment, PACT, or an Advanced
Oxidation Process, AOP); granular activated carbon (GAG, as a
polishing step); stream discharge; improved access to the OWS
using an access route adjacent to the Philadelphia Chewing Gum
property; disposal and treatment of residuals at appropriate
21
-------
waste receiving facilities; and installation of additional
monitoring wells at least one of which will be east of Naylors
Run.
A Site Plan for GW-3, giving the locations of system components
is shown in Figure 5. A Flow Diagram for GW-3, is shown in
Figure 6. and is described below. The treatment plant with PACT
is shown on Figure 7 and with AOP on Figure 8.
Free Product Recovery from the Shallow Aquifer
Two free product recovery wells will be installed on or adjacent
to NWP property in the vicinity of the 'hot spot' at well R-2.
Each of the free product recovery wells will include a free
product skimmer.
A floating skimmer will be provided to remove any free product
whichaccumulates in the well. The skimmer will operate whenever
there is a significant accumulation of free product. The
contaminated oil from the skimmer pump will discharge to a Free
Product Storage tank at the NWP site. The Free Product Storage
tank vent will be fitted with a disposable vapor phase carbon
unit to control odors and air emissions from the tank.
Treatment by the Existing Oil/Water Separator fOWS)
The existing oil/water separator was sized to treat flows in the
range of 0 to 100 gallons per minute. The flow from the storm
sewer (in the shallow aquifer) will continue to be directed to
the existing oil/water separator (OWS), prior to further
treatment. The normal dry weather flow from the storm sewer has
been determined to be less than approximately twenty-five gallons
per minute (25 gpm).
The aqueous flow discharging from the OWS will then be pumped
(using the 25 gpm aqueous phase pumping station) to a new
treatment system, located on NWP property. Access to the OWS will
be improved by obtaining access agreements to permit vehicular
traffic or hand trucks. A gate would be provided at the entrance
to the right-of-way to restrict use of the access road to
authorized persons.
Free Product Recovery from the Existing Oil/Water Separator
Two free product skimmers will be installed in the OWS to remove
free product from the OWS. The skimmer will operate whenever
there is a significant accumulation of free product in the OWS.
The skimmers will discharge to a small day tank located near the
OWS.
22
-------
700 LF
GRAVITY DISCHARGE
TO NAYLORS RUN
1.200 LF.
2 FORCE MAINS
TO TREATMENT PLANT
EXISTING OIL/WATER SEPARATOR
WITH NEW FREE PRODUCT SKIMMERS
PHILADELPHIA
CHE»I>;C
CUM
l-f-^ / i ^* * * ' *. y^"-/\ /"*
V-1 I AQUEOUS PHASE
PUMPING STATION
xTt.**-** .' ,-'' \ ">»*'"7 '':'& .'' ~^^
IT N. / ,''' \ f,-^^'-VJV-''' "
' '* v ^V s'' ' ' tut * ^ Itoftt *' ''
v^S ^ ^» ^v / '" 6^^ ^ I^'I 1 '
^\\y*- ''-ct-u ,'/' ^-ji--~^^^ x '., \ \% \ >t
> V ^^ fm »»_«i ^ i i * f * *. * /^. «
2' SHALLOW AQUIFER
PREE PRODUCT RECOVERY WEU
WITH SKIMMER
LEGEND
-» ACCESS PATH TO SEPARATOR AREA
« EXISTING UONITORING WELLS (NOT SAMPLED)
f, EXISTING UONITORING WELLS (SAMPLED)
EXISTING STORM SEWER
EXISTING SAWITARY SEWER
** EXISTING GRADE
SCALE
Figure 5- Alternative GW-3
-------
EXISTING 30" DIAMETER
'STORM SEWER
-ELIMINATION OF INFLOW FROM FCC
-INFILTRATION < 2i CPU
N.W.P. SITE
1 I
FREE PRODUCT
SKIMMER
FREC PRODUCT
TRANSFER PUMP
FREE PRODUCT (5 CPU)
SKIMMER
VAPOR PHASE
CARBON
CANNISTER
I
EXISTING 100 GPM
OIL/WATER SEPARATOR
I STORM FLOW > 100 CPM
TO FREE PRODUCT
STORAGE TANK AT N V.P.
FU)W
PUUP
(25 CPU)
1
n
3.000 CAL
FREE PRODUCT
STORAGE TANK
TREATMENT
SYSTEM
OIL/WATER
SEPARATOR OVERFLOW
«(25-100 CPU)
4
NAYLORS
RUN
2' O SHALLOW AQUIFER
FREE PRODUCT RECOVERY WELL
ADJACENT TO N.W.P.
(TYPICAL FOR 2)
LEGEND:
NORMAL FLOW
INTERIM STORM FLOW
ULTIMATE STORM FLOW
Figure 6- Flow Diagram for Alternative GW-3
-------
VENT
INFLUENT FROM
EPAIUTOR AREA
VAPOR PHASE
CARBON
CANNISTER
TRANSFER
PUMPS
(25 CPM)
NUTRIENTS
MAKEUP PAC
REGENERATED
PAC
WET AIR OXIDATION
CARBON
REGENERATION
DISPOSABLE
GRANUUR ACTIVATED
CARBON
PACT SYSTEM WITH
CARBON REGENERATION
CHEMICAL PRECIPITATION
NAYLOK
RUN
PROCESS PIPING
ELECTRICAL RESISTANCE
AlAHU
UP Off
IP ON
OW ALARU
PUUP
Figure 7- Powdered Activated Carbon Treatment (PACT) System
-------
TO ATMOSPHEHt
CARBON
CANNISTCHS
ruvnl
CHEMICAL PRECIPITATION
ADVANCED OXIDATION PROCESS SYSTEM
DISPOSABLE
GRANULAR ACTIVATED
CARBON
NiTUlKS
RUN
LEGENIL
PROCESS PIPING
ELECTRICAL RESISTANCE
ABBREVATIONS
UV ULTRAVIOLET
JICH ALARM
IMP OFF
UP ON
~- ALARU
PUMP
Figure 8- Advanced Oxidation System (AOP)
-------
A free product transfer pump will pump the recovered oil to the
Free Product Storage tank located at the NWP site. This approach
will eliminate the need to move drums of recovered free product
from the existing OWS through the residential neighborhood. The
residual oils will be disposed of as K001 Wastes.
If necessary, appropriate chemicals (e.g. NaCl) can be metered
into the day tank to break any emulsion in the free product. This
may be necessary to allow pumping the recovered free product the
1,200 feet to the Free Product Storage tank.
The piping from the free product transfer pump to the Free
Product Storage Tank will be double walled with provision for
leak detection and periodic leak testing/monitoring.
Aqueous Phase Pumping Station
A submersible pumping station will be provided at the existing
OWS to convey the collected ground water to a suitable treatment
system. Installation of the pumping station will require
extending an electrical service to power the pumps, system
controls, and any desired alarm systems. Design pumping capacity
depends on the actual dry weather flow of water in the storm
sewer, and the instantaneous flow capacity of the selected
treatment system. Each pump will have a capacity of approximately
25 gpm. Only one pump will be able to run at a time, i.e. the
second pump will serve as a back-up. The system shall be provided
with necessary features for explosion-proof operation.
Treatment Plant
The water treated by the OWS will be pumped to the treatment
plant at the NWP site for removal of contaminants. The estimated
chemical concentration for the treatment plant influent is shown
on Table 16.
Chemical Precipitation (1st Stage of Treatment Plant)
The chemical precipitation system will treat the inorganics and
will remove the settleable solids which will be present in the
ground water. The system will effectively remove iron, calcium,
manganese, arsenic as well as chromium, cadmium and zinc from the
waste stream. Removal of the iron, calcium and manganese is
necessary for optimum performance of subsequent treatment
processes. The system will have provision to add polymer to
enhance removal of solids, and a gravity settling tank where the
metals and solids will accumulate. This solids fraction will be
collected in drums for disposal at a suitable facility.
Depending on the rate of formation of the solids, it is possible
that a dewatering device will be installed to reduce the volume
of waste solids, and to possibly allow the waste to be considered
23
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Table 16
HAVERTOWN PCP SITE
ESTIMATED CHEMICAL CONCENTRATION
EXISTING OIL/WATER SEPARATOR EFFLUENT
H9/L
ALLOCATED FLOW (gpm)
1,2 Dichloroethene
Vmyl Chloride
Trichloroethene
Benzene
Toluene
Ethyl Benzene
Xytenes
Naphthalene
2-Methylnapthalene
Pentachlorophenol
Total BNA
20
7
BDL
13
35
4
24
110
BDL
1
3,600
3,663
BDL = Below Detection Limits
-------
as a solid (rather than a liquid) waste. This solids fraction
will primarily be iron and manganese precipitants, but may
require special handling for disposal, since the solids could
include adsorbed dioxin or other significant contaminant
concentrations.
Treatability studies will be performed during the remedial design
phase of the project to adequately characterize the necessary
size, features, and disposal options of the chemical
precipitation system.
Removal of Oraanics
Following removal of metals using chemical precipitation, a
system will be provided for removal of organic compounds. Two
treatment alternatives for organic compounds have been selected
for evaluation. The two options are Powdered Activated Carbon
Treatment (PACT) as shown in Figure 3, or an Advanced Oxidation
Process (AOP), as shown in Figure 4. Either process would be
followed by a Granular Activated Carbon (GAC) polishing step.
The actual treatment system selection will be determined during
treatability tests for a few representative treatment
technologies. The treatment systems to be evaluated are described
as follows:
Powdered Activated Carbon Treatment with On-Site Carbon
Regenerat ion
A proprietary powdered activated carbon treatment system (PACT)
is capable of effectively removing the organic compounds in the
ground water at this site. The combination of the powdered carbon
and activated sludge in a continuously stirred tank reactor
(CSTR) effectively captures the volatile and semi-volatile
organic compounds onto the carbon/biomass solids matrix.
The combined effect of the powdered carbon and activated sludge
provides tolerance of shock-loads of any toxic organics. This
will provide enhanced system performance with potential
biodegradation of numerous organic compounds, after a period of
accumulation to the influent organic compounds.
The PACT system will be tolerant of significant organics
loadings, such as from any free product which is not captured by
the oil/water separator. It is possible that a supplemental
carbon source will be needed to provide an influent chemical
oxygen demand of approximately 150 mg COD/1. Inexpensive molasses
is a commonly used carbon source ,for the activated sludge, which
permits co-metabolism of recalcitrant organics.
A single batch-mode PACT unit will be provided to treat the flow.
A flow equalization tank will be provided for the batch unit, to
24
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permit continuous operation of the collection system. Transfer
pumps will be provided to fill the process tank in approximately
45 minutes.
If needed, on-site carbon regeneration can be provided by a wet
air oxidation (WAO) system. On-site regeneration would be
justified only if off-site disposal was not possible. The
smallest WAO unit would be capable of treating a 5 gpm residual
waste solids stream, and requires a thirty foot by forty foot
utility building to house the unit.
The smallest WAO unit would have enough capacity to oxidize
residuals from the PACT system, the GAC units, and the free
product from the skimmers. The WAO process uses high pressure
(2000 psi) and elevated temperature (540 °F) in a titanium
reactor to regenerate the carbon, and can be operated to
effectively destroy organic compounds such as PCP and dioxins.
Treatability tests would determine whether the WAO system was
needed at the NWP site.
Advanced Oxidation Process (AOP)
Advanced oxidation systems are a relatively new technology which
have been shown to be capable of treating the volatile and
semi-volatile compounds which are present in the ground water at
the site. For instance, a system using UV light, combined with
hydrogen peroxide and ozone will be able to destroy the compounds
found in the ground water.
Ultraviolet oxidation is an advanced oxidation process that uses
ultraviolet light with the addition of ozone and/or hydrogen
peroxide. The resulting oxidative environment is significantly
more destructive than the environment created with ozone or
hydrogen peroxide by themselves or in combination.
An ultraviolet oxidation system consists of a stainless steel
reactor with several stages, several UV lamps, an ozone
generator, and a hydrogen peroxide feed system. The UV lamps are
mounted vertically in the reactor and are enclosed in quartz
tubes. Ozone enters each stage through a stainless steel
diffuser. Hydrogen peroxide is metered into the reactor influent.
When the system is operated in the continuous mode, the
contaminants in the water are oxidized to form carbon dioxide,
and water. Any halogens are converted to inorganic halides. A
fixed-bed catalytic ozone destroying unit is part of the UV
oxidation process, producing oxygen and limiting ozone emissions
to an instantaneous concentration of 0.1 ppm in air. Ozone
emission rates would be negligible. Any volatilized organic
compounds are also destroyed in the off-gas. The off-gas is then
25
-------
vented to the atmosphere.
A Treatability Study is needed to verify performance and size the
plant. The AOP process would need to be installed in a utility
building, which would be located on the NWP property.
A consideration of any ultraviolet oxidation system is the amount
of heat generated by the UV lamps used in the treatment process.
This can cause scale formation on the quartz tubes. This scaling
can reduce the effectiveness of UV radiation and the overall
process. Some fouling would be stripped off by the ozone bubbles,
but a problem may develop every 1 to 1/2 years unless a citric
acid wash is used approximately every six months.
The discharge from the AOP system would be directed to granular
activated carbon units.
Granular Activated Carbon (GAG)
Disposable granular activated carbon (GAG) units will be
installed in series to polish the waste water prior to discharge
to Naylors Run. These units are relatively inexpensive and can
also provide effective back-up treatment (redundancy) at low
cost, for when there is an upset in the PACT unit or AOP unit.
Each disposable carbon unit contains approximately 1,000 pounds
of carbon, and can treat up to 30 gpm. For the anticipated flow
of 25 gpm, there would be a minimum of two units installed in
series. Periodic samples would be collected from the influent and
effluent of the GAG units, to predict breakthrough times and to
indicate how often the units would need to be replaced. Samples
of the spent carbon would be taken to determine disposal options
for the carbon.
The piping for the two units would permit any combination or
sequence of flow. Operation of the units would be staggered so
that the carbon units would not both reach breakthrough at the
same time. Treatability studies will be performed during the
remedial design phase of the project to adequately characterize
the necessary size and features of the granular activated carbon
treatment system.
Stream Discharge
The effluent from the treatment plant would be conveyed to
Naylors Run in the vicinity of Eagle Road for discharge. Periodic
samples would be collected in accordance with any discharge
permit for the facility. Discharge monitoring reports would be
submitted per any National Pollutant Discharge Elimination System
(NPDES) requirements.
26
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Waste Disposal or Discharge to Hazardous Waste Facilities
It is anticipated that the recovered free product from the
oil/water separator and free product recovery wells, as well as
the solids collected from the chemical precipitation, PACT
process, and GAC units may contain hazardous compounds which will
require special handling for disposal at an off-site facility. A
secure storage area will be provided, located on the NWP site, to
store the residuals until they can be removed or treated.
For instance, the residuals may be listed as K001 wastes. There
are several off-site facilities which can accept the K001 wastes,
subject to analysis and verification of the waste
characteristics. K001 wastes are wastes from wood preservation
processes as listed in 40 C.F.R. 261.32. A waste disposal firm
was contacted to explore actual disposal alternatives. It was
determined that KOOl wastes could be incinerated at two of its
facilities - one in New Jersey (drummed waste), or a facility in
Texas (bulk roll-off trailers). On-site incineration of the
solids is undesirable given the suburban location.
On-site treatment and destruction of organic residuals could be
provided by the wet air oxidation (WAO) system, particularly with
respect to residuals produced by the PACT process. Treatability
studies would evaluate operational conditions and equipment sizes
necessary to oxidize the spent carbon, recovered free product,
and other similar materials to the required destruction and
removal efficiency.
Cost; The capital cost for this alternative would include
installation of the Shallow Aquifer Free Product Recovery Wells,
the Skimmer systems, the Pumping Stations, the Chemical
Precipitation system, and purchase and installation of the
selected treatment system for organics. The cost of the PACT
system would be significantly reduced if the WAO system was not
needed for on-site residuals management. The capital and O&M
costs for monitoring would be similar to Alternative 2.
A description of the estimated costs for this alternative
summarized as follows:
Using Using
PACT System AOP System
Capital Cost: $ 5,018,000 2,577,000
O&M per Year: $ 445,000 479,500
(first year)
Present Worth: $ 9,684,000 7,553,000
Time to Implement: Approximately 36 Months
27
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Compliance with Applicable or Relevant and Appropriate
Requirements fARARs^
This ROD and its associated remedial action is considered to be
an interim action. This action is not meant to achieve
groundwater cleanup ARARs, which will be evaluated in connection
with the final remedy for the site. The remedy selected will
however, comply with ARARs directly associated with this limited
scope action. This interim action is in furtherance of, and not
inconsistent with, the planned final remedy which will finally
evaluate, among other things, the clean up of ground water. When
the final ROD for ground water is issued, ground water ARARs will
have to be met or waived. However, this ROD will identify the
ARARs, and all remedial actions taken will seek to comply with
ARARs to the maximum extent possible or to make progress toward
meeting all ARARs so that the final remedy can more easily and
fully comply with ARARs.
The known ARARs for chemicals of concern are as follows:
Air Emissions
The National Emissions Standards for Hazardous Air Pollutants set
forth in 40 C.F.R. §61.64(b) and promulgated under the Clean Air
Act, 42 U.S.C. Section 7401.
PA Air Pollution Control Act and Air Discharge Regulations, 25 PA
Code, Sections 123.1, 123.2, and 127.l2(a)(5)
Waste Management
Standards Applicable to Generators of Hazardous Waste (40 C.F.R.
Part 262)
Standards Applicable to Transporters of Hazardous Waste (49
C.F.R. §171.1-171.16)
Regulations and Standards for owners and operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities (40 C.F.R. Part
264)
Land Disposal Restrictions (LDR) Requirements (40 C.F.R. §268.1-
268.50)
Dioxin Containing Waste (50 Fed. Reg. 1978)
PA Hazardous Management Regulations (25 PA Code Subchapter D,
Sections 260.2 through 260.22, 261.1 through 261.34, 262.10
through 262.60, and 263.10 through 263.32 relating to the
identification and determination of hazardous waste, generator
and transporter rules and regulations.
28
-------
Occupation Safety and Health Act fOSHA)
OSHA, 29 C.F.R. §1910.170
Surface Water
Clean Water Act, NPDES discharge regulations (40 C.F.R. §§122-
124)
PA Clean Streams Law (PA Code Title 25, Chapter 5)
PA NPDES Regulations (PA Code Title 25, Chapter 93.1 through 93.9
and 16, 92, 95, and 101)
Ground Water
PA. Hazardous Waste Management Regulations (25 PA Code Section
264.90 through 264.100)
The Source Removal, Treatment, and Disposal Alternative (GW-3)
would involve only the limited collection of ground water and
would provide treatment of ground water collected in the catch
basin area through a 3 step treatment process. It is believed
that this alternative would be in compliance with the air
emission and OSHA ARARs. The air emissions standards would be
ARARs for any possible volatilization of contaminants during
monitoring or construction or any off-gas venting from the
treatment plant. The OSHA ARARs would arise in connection with
work done during construction.
Although the disposal of generated wastes may present problems in
meeting waste management ARARs, it is expected that all waste
management ARARS can be met for wastes that were generated by
construction of the treatment plant, any soil excavation, or
residuals from the treatment process, such as oils and carbon.
These wastes could alter disposal plans, depending on the level
of dioxin in the wastes. If there are levels of dioxin less than
1 PPB, then the wastes could be disposed of at a RCRA Subtitle C
facility. If the dioxin levels in the soils exceed 1 PPB, then
the wastes would not be considered K001 wastes (wastes from a
wood treatment site). As a result, the waste would have to be
incinerated off site, if possible, or stored on site until
another disposal method was arranged. However, it is anticipated
that the proposed treatment plant process (AOP or PACT) will
destroy dioxins to below the 1 PPB level. Additionally, if a WAO
system is installed as part of the PACT system, on site
destruction of organic wastes, including dioxin, could be
provided. Installation of the WAO may be necessary in order to
meet this ARAR.
While this is an interim ROD for ground water, the air emissions,
waste management and OSHA standards are ARARs for this interim
29
-------
action and will be met by this alternative. Surface water
standards are ARARs for the treated ground water, discharged into
Naylors Run, and such surface water ARARs would be met to the
maximum extent possible, as the treatment being utilized is the
best available technology. As noted above, ground water cleanup
levels are not intended to be finally addressed in this remedial
action and, therefore, ground water cleanup levels are not ARARs
for this action.
D. Alternative GW-4 Source Removal. Containment. Collection.
Treatment, and Disposal
Description; This multi-faceted alternative includes all of the
features provided in Alternative 3 as well as a collection system
(shallow ground water collector drain and pumping station), and
Containment (rehabilitation and in-place lining of the existing
storm sewer).
A Site Plan for Alternative 4, giving the locations of system
components is shown in Figure 9. A Flow Diagram for Alternative
4 is shown in Figure 10. as described below. The PACT and AOP
treatment systems are shown on Fionires 7 & 8.
Ground Water Collector Drain
Installation of a collector drain near the existing storm sewer
will provide controlled collection of the contaminated shallow
ground water. The estimated chemical concentration of shallow
ground water collected by the drain is given in Table 17. The
drain is shown on Figure 11. The purpose of a collector drain is
to effectively capture the plume of contaminated water in the
shallow aquifer at the southern edge of the site. The
contaminated water can then be sent to a treatment system for
removal of the contaminants. System components are selected to be
compatible with any free product which may be collected.
Although not designed to act as an collector drain, the existing
30" storm sewer pipe has intercepted a portion of the flow of
contaminated ground water. The storm sewer pipe is subject to
periodic high storm water flows, which significantly restrict the
utility of using the storm sewer to collect water for further
treatment. Also, the storm sewer does not appear to be effective
in capturing the plume along its entire length. This
significantly limits the effectiveness of the storm sewer for
capturing the plume of contaminants in the shallow ground water.
Installation of the collector drain will significantly improve
capture of the plume, in comparison to the performance of the
existing storm sewer. The collector trench will be installed to
the depth of the fractured bedrock (significantly deeper than the
storm sewer), to improve collection throughout the shallow
aquifer. Also, the collector pipe will not be subject to periodic
flow excursions and flooding during storm events. The periodic
30
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HPDE3 MONITORING)
700 LF.
GRAVITY DISCHARGE
TO NAYUDRS RUN
"'
1.200 LF.
Z FORCE MAINS
TO TREATMENT PLANT
FORCE MAIN TO EXISTING
OIL/WATER SEPARATOR
STORM SEWER
REHABILITATION
EXISTING OIL/WATER SEPARATOR]
WITH NEW FREE PRODUCT
SKIMMERS
'HILADELPHIA
CHEWING
GUM
2' SHALLOW AQUIFER
RECOVERY WELL WITH SKIMMER
COLLECTOR (WITH MANHOLE)
-+ ACCESS PATH TO SEPARATOR AREA
EXISTING MONITORING WELLS (NOT SAMPLED)
£ EXISTING MONITORING WELLS (SAMPLED)
EXISTING STORM SEWER
EXISTING SANITARY SEWER
'«- EXISTING GRADE
Figure 9- Alternative GW-4
-------
AIR
COMPRESSOR
-.
AAKS
N.WP. SITE
COUXCTOR TRENCH
PUMPING STATION
COLLECTOR TRENCH
VAPOR PHASE
CARBON
CANNISTER
FREE PRODUCT
TRANSFER PUUP
FREE PRODUCT (S CPM>
SKIMMER
EXISTING 30" DIAMETER
STORM SEWER
EXISTING 100 GPM
OIL/WATER SEPARATOR
-ELIMINATION OF INFLOW FROM PC.G.
-ELIMINATION OF INFILTRATION
-STORM SEWER REHABILITATION
FREE PRODUCT
SKIMMER
TO FREE PRODUCT
STORAGE TANK AT N W.P.
2' 0 SHALLOW AQUIFER
FREE PRODUCT RECOVERY WELL
ADJACENT TO N.W.P.
(TYPICAL FOR 2)
FLOW
PUMP
(25 CPM)
LEGEND:
NORMAL FLOW
STORM FLOW
1
3.000 GAL
FREE PRODUCT
STORAGE TANK
TREATMENT
SYSTEM
NAYLORS
RUN
Figure 10- Flow Diagram for Alternative GW-4
-------
Table 17
Estimated Chemical Concentration
Collector Drain
(PPB)
FLOW (gpm)
1.2 Dichloroethene
Vinyl Chloride
Trichloroethene
Benzene
Toluene
Ethyl Benzene
Xyiene
Naphthalene
2-Methylnapbthalene
Pentacblorophenol
Total BNA
Calcium
Iron
Magnesium
Manganese
Zinc
Dk»n (2,3,7,8-TCDD) TE
COLLECTOR
20
22
2
23
160
40
27.2
910
400
5300
42,000
61.000
23,600
3390
14,900
16,600
130
115ppTr
-------
ACCESS
MANHOLE
M.H. B
MH A
AIR
COMPRESSOR-
SAPROLITE
GROUND WATER COLLECTOR
LOW SHEAR
BLADDER PUMP
TO
TREATMENT
COaECTOR
PUMPING STATION
TS*TATTE'RC LEVEL"!
MEMBRANE LINER
INTERCEPTOR PIPE
(8" DIA PVC>
Figure 11- Collector Drain
-------
high flows into the storm sewer make continuous treatment
unrealistic for the storm sewer effluent.
Unless this action is taken, there is a significant concern that
the plume of contaminated ground water will migrate beyond the
storm sewer, and possibly into seeps in the back yards of
residences along Rittenhouse Circle.
A collector drain will be installed, roughly in parallel with the
existing storm sewer pipe. Unlike the storm sewer, however, the
collector drain will be designed and installed to efficiently
intercept the flow of contaminated ground water. The following
factors have been identified concerning construction and
placement of the drain:
Drain Excavation
The drain excavation should be extended to the approximate
elevation of the fractured bedrock for maximum effect. This will
require excavation to a depth of approximately fifteen to twenty
feet'. The base of the drain should be a minimum of two feet wide
in section. Shoring of the drain trench will be needed during
construction to minimize the quantity and cost of disposal of
excavation material. Shoring is also necessary to prevent
possible cave-ins and personal injury or property damage.
Interceptor Pipe
A perforated pipe will be placed at the bottom of the drain,
which will serve to convey the ground water to a pumping station.
The perforations will be oriented so that they are above the
normal depth of water flowing in the pipe to minimize
accumulation of debris.
The slope of the interceptor pipe will be designed so that a
constantly descending gradient is maintained to the pumping
station. Test pits will be excavated along the route of the
interceptor pipe during the Remedial Design and Remedial Action
(RD/RA) phase of the project, so that the interceptor pipe design
invert elevations can be determined.
Samples would be collected at various depths in the test pits to
determine the levels of contaminants and disposal options for the
excavated materials. Depending on the contaminant levels, the
soils could be used as clean fill, or if contamination is
present, could be landfilled, incinerated, or other possible
alternatives.
During installation, irregularities in the elevation of the
fractured bedrock between test pits may require excavation of
fractured bedrock where it extends above the interpolated bedrock
elevations.
31
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Access Manholes
Manholes will be provided every few hundred feet for access, and
at any changes in pipe alignment. The access manholes should be
vented to ensure free drainage of the interceptor pipe. The
Remedial Design will evaluate the possible provision for
retrofitting disposable vapor phase carbon units, if odors become
a problem.
Selection of Materials of Construction
In many cases, there will be a choice of different possible
materials of construction for a given system component. For
instance, the interceptor pipe could be made of PVC or some other
appropriate material. Costs have been estimated assuming that
the major pieces of equipment will not require significant use of
exotic materials of construction.
Drain Backfill Material
The drain will be appropriately graded and backfilled with a
highly porous select gravel. The gravel will drain freely to the
perforated interceptor pipe at the bottom of the drain.
The drain will be lined with a permeable geotextile fabric on the
face of the trench which is upgradient to the collector pipe, to
permit unimpeded flow while minimizing gradual plugging of the
gravel with fine particles (fines).
To minimize entry of surface drainage and run-off into the
collector drain, an impermeable membrane liner will be placed
above the gravel layer. This membrane liner will be extended
along the face of the trench which is downgradient to the
collector pipe. Without this feature, where the collector drain
crosses any buried utility lines, there would be the undesirable
possibility of contaminated ground water flow entering the select
backfill present in other utility trenches.
The impermeable membrane will minimize such flows wherever the
collector drain encounters such potential conduits for the ground
water to escape the collector trench. This key feature will
minimize any communication between the ground water in the
collector trench with permeable soil formations which are
present.
The seams where two rolls of membrane adjoin will be sealed to be
water tight. The liner thickness (and any necessary reinforcing)
will be selected to withstand any hydraulic forces acting on the
membrane due to the differential head across the membrane.
32
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Collector Drain Pumping Station
A pumping station will be provided to convey the collected ground
water to a suitable treatment system. Installation of the pumping
station will require extending an electrical service to power the
pumps, system controls, and any desired alarm systems. Pumping
capacity will depend on the actual flow of water in the collector
trench, and the instantaneous flow capacity of-the treatment
system. Each pump will have a capacity of approximately 25 gpm.
The pump system shall be provided with necessary features for
explosion-proof operation. Low shear diaphragm pumps will be
provided to minimize emulsification of the oily water.
Monitoring Wells
Installation of the interceptor trench could potentially affect
the performance of existing monitoring wells which are located in
the vicinity of the drain. This will require careful attention
to the design and installation of the drain, or possibly
installation of new wells outside the drain area, so that
representative samples can be collected.
Rehabilitation of the Existing 30-inch Storm Sewer
A recent closed circuit television surveillance of the storm
sewer pipe indicates the presence of a small pipe discharging
into a manhole located on the south side of the Philadelphia
Chewing Gum property. This source of inflow is apparently an
unpermitted connection to the storm sewer, which unnecessarily
increases the dry weather flow of the storm sewer. It is
anticipated that this source of inflow will be plugged, after
USEPA notifies the affected property owners of the action to be
taken.
The last section of storm sewer pipe (extending approximately 200
feet from the manhole south of PCG to the discharge point into
Naylors Run) was observed to contribute noticeable infiltration
into the storm sever pipe during dry weather.
The storm sever pipe vill be lined in-place. The lining vill
virtually eliminate any infiltration into the storm sever pipe.
The contaminated vater vhich is presently being collected by the
storm sever pipe vill instead be collected in the interceptor
drain, with the advantage that the flovs in the interceptor drain
won't be subject to radical flow increases during storm events.
Cost; The capital cost for this alternative vould include
installation of the items included in alternative 3 as veil as
the collector drain and pumping station, and rehabilitation
(lining) of the existing storm sever pipe. The capital and O&M
costs for monitoring vould be comparable to Alternative 2.
33
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A description of the estimated costs for this alternative are
summarized as follows:
Using PACT System
Capital Cost: $ 7,437,000
Using AOP System
$ 4,997,000
O&M per year: $
(first year)
595,000
Present Worth: $ 12,177,000 $
Time to Implement: Approximately 36 Months
485,500
10,036,00
Compliance with Applicable or Relevant and Appropriate
Requirements fARARs)
This ROD and its associated remedial action is considered to be
an interim action. This action is not meant to achieve
groundwater cleanup ARARs, which will be evaluated in connection
with the final remedy for the site. The remedy selected will
however, comply with ARARs directly associated with this limited
scope action. This interim action is in furtherance of, and not
inconsistent with, the planned final remedy which will finally
evaluate, among other things, cleaning of the ground water. When
the final ROD for ground water is issued, ground water ARARs will
have to be met or waived. However, this ROD will identify the
ARARs, and all remedial actions taken will seek to comply with
ARARs to the maximum extent possible or to make progress toward
meeting all ARARs so that the final remedy can more easily and
fully comply with ARARs.
The known ARARs for chemicals of concern are as follows:
Air Emissions
The National Emissions Standards for Hazardous Air Pollutants set
forth in 40 C.F.R. §61.64(b) and promulgated under the Clean Air
Act, 42 U.S.C. Section 7401.
PA Air Pollution Control Act and Air Discharge Regulations, 25 PA
Code, Sections 123.1, 123.2, and 127.12(a)(5)
Waste Management
Standards Applicable to Generators of Hazardous Waste (40 C.F.R.
Part 262)
Standards Applicable to Transporters of Hazardous Waste (49
34
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C.F.R. §171.1-171.16)
Regulations and Standards for owners and operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities (40 C.F.R. Part
264)
Land Disposal Restrictions (LDR) Requirements (40 C.F.R. §268.1-
268.50)
Dioxin Containing Waste (50 Fed. Reg. 1978)
PA Hazardous Management Regulations (25 PA Code Subchapter D,
Sections 260.2 through 260.22, 261.1 through 261.34, 262.10
through 262.60, and 263.10 through 263.32 relating to the
identification and determination of hazardous waste, generator
and transporter rules and regulations.
Occupation Safety»and Health Act (OSHA)
OSHA, 29 C.F.R. §1910.170
Surface Water
Clean Water Act, NPDES discharge regulations (40 C.F.R. §§122-
124)
PA Clean Streams Law (PA Code Title 25, Chapter 5)
PA NPDES Regulations (PA Code Title 25, Chapter 93.1 through 93.9
and 16, 92, 95, and 101)
Ground Water
PA Hazardous Waste Management Regulations (25 PA Code Section
264.90 through 264.100)
The Source Removal, Containment, Collection, Treatment, and
Disposal Alternative (GW-4) would provide extensive collection
and treatment of ground water through an underground collection
drain and through a 3 step treatment process. It is believed
that this alternative would be in compliance with the air
emission and OSHA ARARs. The air emissions standards would be
ARARs for any possible volatilization of contaminants during
monitoring or construction or any off-gas venting from the
treatment plant. The OSHA standards would be ARARs for work done
during construction.
Although the disposal of generated wastes may present problems in
meeting waste management ARARs, it is expected that all waste
management ARARS can be met for any wastes that were generated by
construction of the treatment plant, any soil excavation, or
35
-------
residuals from the treatment process such as oils and carbon.
This waste could alter disposal plans, depending on the level of
dioxin in the wastes. If there are levels of dioxin less than 1
PPB, then the wastes could be disposed of at a RCRA Subtitle C
facility. If the dioxin levels in the soils exceed 1 PPB, then
the wastes would not be considered K001 wastes (wastes from a
wood treatment site) . As a result, the waste would have to be
incinerated off site, if possible, or stored on site until
another disposal method was arranged. However, it is anticipated
that the proposed treatment plant process (AOP or PACT) will
destroy dioxins to below the 1 PPB level. Additionally, if a WAO
system is installed as part of the PACT system, on site
destruction of organic wastes, including dioxin, could be
provided. Installation of the WAO may be necessary in order to
meet this ARAR.
While this is an interim ROD for ground water, the air emissions,
waste management and OSHA standards are ARARs for this interim
action and will be met by this alternative. Surface water
standards are ARARs for the treated ground water, discharged into
Naylors Run, and such surface water ARARs would be met to the
maximum extent possible, as the treatment being utilized is the
best available technology. As noted above, ground water cleanup
levels are not intended to be finally addressed in this remedial
action, and, therefore, ground water cleanup levels are not ARARs
for this action. (To the extent that ground water cleanup levels
were to apply to this action, which EPA does not believe, such
ARARs would be waived on the basis that this interim action is
only a part of a total remedial action for the site that will
attain such ARARs when completed or such ARARs would be waived
under the other waiver criteria, pursuant to CERCLA Section 121
8. Summary of Comparative Analysis of Alternatives
A detailed analysis was performed on the four alternatives using
the nine evaluation criteria specified in the NCP 40 C.F.R.
Paragraph 300. 430 (e) (a) in order to select a final remedy for
this Operable Unit (OU2) . The following is a summary of the
comparison of each alternative's strengths and weaknesses with
respect to the nine evaluation criteria. These nine evaluation
criteria can be categorized into 3 groups: Threshold criteria,
primary balancing criteria, and modifying criteria.
Threshold Criterion
-Overall Protection of Human Health and the Environment
-Compliance with ARARs
36
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Primary Balancing Criterion
-Long Term Effectiveness and Permanence
-Reduction of Toxicity, Mobility, or Volume through
Treatment
-Short Term Effectiveness
-Implementabi1ity
-Cost
Modifying Criterion
-State Acceptance
-Community Acceptance
Tables 18 through 21 summarize the comparative analysis of each
criterion and they are further defined in Table 22. These
evaluation criteria relate directly to requirements in Section
121 of CERCLA, 42 U.S.C. Section 9621, which determines the
overall feasibility and acceptability of the remedy. Threshold
criteria must be satisfied in order for a remedy to be eligible
for selection. Primary balancing criteria are used to weigh
major trade-offs between remedies. State and community
acceptance are modifying criteria that are formally taken into
account after public comment is received on the Proposed Plan.
The evaluations are as follows:
Protection of Human Health and Environment
The preferred alternative, GW-4, will provide the best available
treatment of the contaminated ground water, prior to discharge to
Naylors Run. Given the apparent presence of significant PCP and
dioxin contamination in the ground water, it is prudent to
install an effective collection and treatment system for the
contaminated ground water, which this alternative does. GW-3
would provide only limited collection of contaminated water and
hence would not be as protective. GW-2 would provide only
minimal protection by use of deed restriction and fencing. GW-1
would provide no protection, therefore GW-1 is eliminated from
consideration & won"t be evaluated any further in this analysis.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARsl
CERCLA requires that remedial actions meet applicable or relevant
and appropriate requirements (ARARs) of other Federal and State
environmental laws, or that there are grounds for invoking a
waiver. These laws may include, but are not limited to: The
37
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Table 18
SUMMARY OF DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
HAVEftTOWNSITC
MAOUM.
ALTUINA11VC
ntoracndMor
BUMhNBCALtM
';;:- 'AND: : .;:.
tNWtONMZKt
ObMMJANCB
TOXICfTV,
omunr,A
vounat
wncnvgNBUANp
TOMANINCE
cort
»int
ICOTMNCt
GW-1
NO ACTION
(taclud*.
Will «« Kldreu
of Ike fell -a
Nocheokal-
tprcttcARAIU
uc pptfcable lo
1 No further
rWMCOOM DCyMM
time realized
od everted
(octetcdwitfa
NofiMkct
NotartbertepMloa
* ***
pvcuciod >y
Stale.
OOOODI
COJMPMJ;
(begroud
Mrtwe water.)
WilMMMI
> WUIM fravUe
tot rioiecikoolo
hvwobealibfcr
funvc yxxiad
witet- -JK io< for
tfitSttj.
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rcUted
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atifccsfte.
(denned tln>««h
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tlOMMtkML
rfn* « Ruk of
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LUicd icducthw of
No tapteneflMfcm
JMunollKr thtn
ABAR*.
Mlpmthmaf
-------
Table 19
8°
o.
SUUUARY OF DFTAHED EVALUATION OF REMEDIAL ALTERNATIVES
HAVER10WNSTTE
rrwfv* '.. I
ALTBRKAIIVB
twncnbx or
HUMAN ttKtnV
NVBIQIOMNI
: toactrtt -: :;
MOtlRm.ANDi
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I AND
<*»«** Worth)
fcntt
GW-J
LIMITED
REMEDIAL
ACTION
(kdwtadlNo
Artioa
WUpraride*
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e4incnl
« WHIM Met
> Nofunhet
reoiffWMi UC^UIM
thratieafani
4 capedcd
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f/MOW
NK
^
SMK.
cttmb
fraviov MttaB.
tcltted
pound witer
W1I not provide
protection kit
the rate of the
rallied
Ml «MBUB|tioD
Restriction)
Identified tkm«)i
I notier
ARARibfclui
tUpoHdnacrr
Itberitx
Wliae^not
largtakind
do* M imft of
NolapttveaUtoa
otket thin
redwtkmhilkc
will be Amu*
rcwh of MMnl
Ltadtcd Kductloa of
of
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Graph*
pratectkm at
w wfaoe water wM
ARAR*.
hMimlanlcoctTol
M%nUonot
i^||^y^« t
Imieib
eoMiol
W rettrict tawe
pouad wilex we «n4
IkertforcRBltitbe
-------
Table 20
SUMMARY OF DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
HAVEETOWN SITE
.<
og
c* oi
8°
Q.
HEMBDUL
ALTERNATIVE
OW-3
SOURCE
REMOVAL.
IHEATMENT.
AND
DISPOSAL
-------
Table 21
SUMMARY OF DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
HAVERTOWNSnB
KEtODlAL
pt
-------
Table 22
GLOSSARY Of EVALUATION CRflERIAf
''..'"'
Threshtrid Criteria ' ,- ' "<'<
gritnaiv BaTancfnq Criteri* ; /
^ ^SSKS^S=S^^^SS^ 'i
once cleanup goate we «*fevci^
t^"1
>,Af -- - - * ' >
i Treatment-te the
^^^ JP* « * %»%i
refcwnii?^
;*%< 'S-o-'X^.M^r^
V«" ," "t *£
'^:^y".
POOR QUALITY.
ORIGINAL
-------
Toxic Substances Control Act, the Clean Water Act, the Safe
Drinking Water Act, & the Resource Conservation and Recovery Act.
A "legally applicable" requirement is one which would legally
apply to the response action if that action were not taken
pursuant to Sections 104, 106, or 122 of CERCLA. A "relevant and
appropriate" requirement is one that, while not "applicable", is
designed to apply to problems sufficiently similar that their
application is appropriate. Pursuant to CERCLA Section 121
(d)(4)(A), a remedial action that does not attain a level or
standard of control at least equivalent to a legally applicable
or relevant and appropriate standard may be selected if the
remedial action is only part of a total remedial action for the
site that will attain such level or standard of control when
completed.
The Source Removal, Containment, Collection, Treatment, and
Disposal Alternative (GW-4) would provide extensive collection
and treatment of ground water through an underground collection
drain and through a 3 step treatment process. It is believed
that this alternative would be in compliance with the air
emission and OSHA ARARs. The air emissions standards would be
ARARs for any possible volatilization of contaminants during
monitoring or construction or any off-gas venting from the
treatment plant. The OSHA standards would be ARARs for work done
during construction.
Although the disposal of generated wastes may present problems in
meeting waste management ARARs, it is expected that all waste
management ARARS can be met for any wastes that were generated by
construction of the treatment plant, any soil excavation, or
residuals from the treatment process such as oils and carbon.
This waste could alter disposal plans, depending on the level of
dioxin in the wastes. If there are levels of dioxin less than 1
PPB, then the wastes could be disposed of at a RCRA Subtitle C
facility. If the dioxin levels in the soils exceed 1 PPB, then
the wastes would not be considered K001 wastes (wastes from a
wood treatment site). As a result, the waste would have to be
incinerated off site, if possible, or stored on site until
another disposal method was arranged. However, it is anticipated
that the proposed treatment plant process (AOP or PACT) will
destroy dioxins to below the 1 PPB level. Additionally, if a WAO
system is installed as part of the PACT system, on site
destruction of organic wastes, including dioxin, could be
provided. Installation of the WAO may be necessary in order to
meet this ARAR.
While this is an interim ROD for ground water, the air emissions,
waste management and OSHA standards are ARARs for this interim
action and will be met by this alternative. Surface water
standards are ARARs for the treated ground water, discharged into
Nay lor s Run, and such surface water ARARs would be met to the
38
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maximum extent possible, as the treatment being utilized is the
best available technology. As noted above, ground water cleanup
levels are not intended to be finally addressed in this remedial
action, and, therefore, ground water cleanup levels are not ARARs
for this action. (To the extent that ground water cleanup levels
were to apply-to this action, which EPA does not believe, such
ARARs would be waived on the basis that this interim action is
only a part of a total remedial action for the site that will
attain such ARAR when completed or such ARAR would be waived
under the other waiver criteria, pursuant to CERCLA Section 121
(d)(4)(A). None of the other alternatives would provide
remediation that could meet ARARs.
Reduction of Toxicitv. Mobility, and Volume through Treatment
Alternative GW-4 will provide collection and treatment of the
ground water and will provide the best possible reduction in
effluent toxicity. Since there will be significant capture of
contaminated residual materials, the effective volume of wastes
being discharged to Naylors Run will be reduced. Alternative GW-
3 would provide treatment of contaminants but only limited
collection, hence the reduction in contaminants would not be as
significant. GW-2 would not reduce contamination.
Short-term Effectiveness
Alternative GW-4 should produce a high quality effluent for
discharge to Naylors Run immediately after operation of the
treatment plant begins. This alternative should collect all
available free product and contaminated ground water and should
significantly reduce the contamination on site immediately.
Including time needed for the treatability studies, it is
possible that this alternative can be expedited and implemented
in about a 36 month period. Construction itself should take an
estimated 18 months. GW-3 would also provide short term
effectiveness but it would not be actively collecting
contaminated ground water and would be able to treat only a small
portion of the existing contaminated ground water. GW-2 would
provide negligible short-term effectiveness.
Long-term Effectiveness and Permanence
Since this is an interim action for ground water, long term
effectiveness and permanence is not applicable here. However,
installation of a collector drain and treatment system, as
provided for in GW-4, will virtually eliminate .the direct
discharge of untreated ground water.
Implementability
Alternative GW-4 is straightforward with respect to the technical
aspects of its implementation. Treatability tests will be
39
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performed to evaluate the effectiveness of the selected treatment
technology. Any construction activities will have a short-term
impact on the daily lives of the local residents, which will
include inconvenience and the general disruption associated with
earth work in a well established and populated area. GW-3 would
also be readily implementable and would be disruptive to
residents but not as significantly since it would not involve the
installation of the collection drain. GW-2 is easily
implementable.
Cost
To an extent, the cost associated with cleaning-up the site is
driven by the presence of dioxin isomers in the ground water,
which is currently being discharged to Naylors Run. Disposal
options for the process residuals can be better characterized as
part, of the treatability study. The cost of implementing the
preferred ground water collection and treatment option, GW-4, is
between about 10 and 12 million dollars (present worth). The
cost of alternative GW-3 is $7.5 to $9.7 million dollars. The
cost of alternative GW-2 is $1.9 million dollars.
State Acceptance
The Commonwealth of Pennsylanaia has been involved in the review
of the Remedial Investigation and Feasibility Study and is
supportive and concurs on the selection of the interim remedy,
alternative GW-4. The position of the Commonwealth on
alternative GW-3 is that they prefer GW-4 to GW-3 and the
Commonwealth would not support GW-2.
Community Acceptance
Community acceptance is more fully addressed in the attached
Responsiveness Summary. The Responsiveness Summary provides a
thorough review of the public comments received on the RI/FS, the
Proposed Plan, and EPA's response to the comments received.
9. Selected Remedy
After careful consideration, the selected remedy for remediating
the ground water contamination in the shallow aquifer shall be
the construction of a treatment plant, in conjunction with
planned treatability studies to optimize the effectiveness of the
advanced oxidation process or the powdered activated carbon
treatment. Under this remedy, GW-4, 2 free product recovery
wells shall be installed at NWP, and a treatment plant shall be
constructed to treat ground water through chemical precipitation,
granulated activated carbon treatment, and either PACT or AOP
treatment. Also to be installed shall be an underground
40
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interceptor drain behind PCG to collect ground water and direct
it to the existing oil/water separator. The plant is expected to
operated for 30 years. All effluent from the oil/water separator
shall be pumped to the proposed treatment plant after which it
shall be discharged to Naylors Run. Improved access to the OWS
also will be implemented and additional ground water wells shall
be installed north and south of the underground interceptor pipe.
Also, the existing ground water wells will be sampled for
contaminants of concern twice a year. This action is alternative
GW-4 and details are provided under "Performance Standards".
Performance Standards
A. Free Product Recovery from the Shallow Aquifer
Two free product recovery wells will be installed on or adjacent
to NWP property in the vicinity of the 'hot spot' at well R-2.
Each of the free product recovery wells will include a free
product skimmer.
A floating skimmer will be provided to remove any free product
which accumulates in the well. The skimmer will operate whenever
there is accumulation of free product. The contaminated oil from
the skimmer pump will discharge to a Free Product Storage tank at
the NWP site. The Free Product Storage tank vent will be fitted
with a disposable vapor phase carbon unit to control odors and
air emissions from the tank.
B. Treatment by the Existing Oil/Water Separator (OWS)
The existing oil/water separator was sized to treat flows in the
range of 0 to 100 gallons per minute. The flow from the storm
sewer (in the shallow aquifer) will continue to be directed to
the existing oil/water separator (OWS), prior to further
treatment. The normal dry weather flow from the storm sewer has
been determined to be less than approximately twenty-five gallons
per minute (25 gpm).
The aqueous flow discharging from the OWS will then be pumped
(using the 25 gpm aqueous phase pumping station) to a new
treatment system, located on NWP property. Access to the OWS will
be improved by obtaining access agreements to permit vehicular
traffic or hand trucks. A gate will be provided at the entrance
to the right-of-way to restrict use of the access road to
authorized persons.
C. Free Product Recovery from the Existing Oil/Water Separator
Two free product skimmers will be installed in the OWS to remove
free product from the OWS. The skimmer will operate whenever
there is accumulation of free product in the OWS. The skimmers
will discharge to a small day tank located near the OWS.
41
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A free product transfer pump will pump the recovered oil to the
Free Product Storage tank located at the NWP site. This approach
will eliminate the need to move drums of recovered free product
from the existing OWS through the residential neighborhood. The
residual oils will be disposed of as K001 Wastes.
If necessary, appropriate chemicals (e.g. NaCl) can be metered
into the day tank to break any emulsion in the free product. This
may be necessary to allow pumping the recovered free product the
1,200 feet to the Free Product Storage tank.
The piping from the free product transfer pump to the Free
Product Storage Tank will be double walled with provision for
leak detection and periodic leak testing/monitoring.
D. Aqueous Phase Pumping Station
A submersible pumping station will be provided at the existing
OWS to convey the collected ground water to a suitable treatment
system. Installation of the pumping station will require
extending an electrical service to power the pumps, system
controls, and any desired alarm systems. Design pumping capacity
depends on the actual dry weather flow of water in the storm
sewer, and the instantaneous flow capacity of the selected
treatment system. Each pump will have a capacity of approximately
25 gpm. Only one pump will be able to run at a time, i.e. the
second pump will serve as a back-up. The system shall be provided
with necessary features for explosion-proof operation.
E. Treatment Plant
The water treated by the OWS will be pumped to the treatment
plant at the NWP site for removal of contaminants. The estimated
chemical concentration for the treatment plant influent is shown
on Table 16.
F. Chemical Precipitation (1st Stage of Treatment Plant)
The chemical precipitation system will treat the inorganics and
will remove the settleable solids which will be present in the
ground water. The system will remove iron, calcium, manganese,
arsenic as well as chromium, cadmium and zinc from the waste
stream. Removal of the iron, calcium and manganese is necessary
for optimum performance of subsequent treatment processes. The
system will have provision to add polymer to enhance removal of
solids, and a gravity settling tank where the metals and solids
will accumulate. This solids fraction will be collected in drums
for disposal at a suitable facility.
42
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Depending on the rate of formation of the solids, it is possible
that a dewatering device will be installed to reduce the volume
of waste solids, and to possibly allow the waste to be considered
as a solid (rather than a liquid) waste. This solids fraction
will primarily be iron and manganese precipitants, but may
require special handling for disposal, since the solids could
include adsorbed dioxin or other significant contaminant
concentrations.
Treatability studies will be performed during the remedial design
phase of the project to adequately characterize the necessary
size, features, and disposal options of the chemical
precipitation system.
G. Removal of Organics
Following removal of metals using chemical precipitation, a
system will be provided for removal of organic compounds. Two
treatment alternatives for organic compounds have been selected
for evaluation. The two options are Powdered Activated Carbon
Treatment (PACT) as shown in Figure 3, or an Advanced Oxidation
Process (AOP), as shown in Figure 4. Either process would be
followed by a Granular Activated Carbon (GAC) polishing step.
The actual treatment system selection will be determined during
treatability tests for a few representative treatment
technologies. The treatment systems to be evaluated are described
as follows:
H. Powdered Activated Carbon Treatment with On-Site Carbon
Regeneration
A proprietary powdered activated carbon treatment system (PACT)
is capable of effectively removing the organic compounds in the
ground water at this site. The combination of the powdered carbon
and activated sludge in a continuously stirred tank reactor
(CSTR) effectively captures the volatile and semi-volatile
organic compounds onto the carbon/biomass solids matrix.
The combined effect of the powdered carbon and activated sludge
provides tolerance of shock-loads of any toxic organics. This
will provide enhanced system performance with potential
biodegradation of numerous organic compounds, after a period of
accumulation to the influent organic compounds.
The PACT system will be tolerant of significant organics
loadings, such as from any free product which is not captured by
the oil/water separator. It is possible that a supplemental
carbon source will be needed to provide an influent chemical
43
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oxygen demand of approximately 150 mg COD/1. Inexpensive molasses
is a commonly used carbon source for the activated sludge, which
permits co-metabolism of recalcitrant organics.
A single batch-mode PACT unit will be provided to treat the flow.
A flow equalization tank will be provided for the batch unit, to
permit continuous operation of the collection system. Transfer
pumps will be provided to fill the process tank in approximately
45 minutes.
If needed, on-site carbon regeneration can be provided by a wet
air oxidation (WAO) system. On-site regeneration would be
justified only if off-site disposal was not possible. The
smallest WAO unit would be capable of treating a 5 gpm residual
waste solids stream, and requires a thirty foot by forty foot
utility building to house the unit.
The smallest WAO unit would have enough capacity to oxidize
residuals from the PACT system, the GAC units, and the free
product from the skimmers. The WAO process uses high pressure
(2000 psi) and elevated temperature (540 °F) in a titanium
reactor to regenerate the carbon, and can be operated to
effectively destroy organic compounds such as PCP and dioxins.
Treatability tests will determine whether the WAO system was
needed at the NWP site.
I. Advanced Oxidation Process (AOP)
Advanced oxidation systems are a relatively new technology which
have been shown to be capable of treating the volatile and
semi-volatile compounds which are present in the ground water at
the site. For instance, a system using UV light, combined with
hydrogen peroxide and ozone will be able to destroy the compounds
found in the ground water.
Ultraviolet oxidation is an advanced oxidation process that uses
ultraviolet light with the addition of ozone and/or hydrogen
peroxide. The resulting oxidative environment is significantly
more destructive than the environment created with ozone or
hydrogen peroxide by themselves or in combination.
An ultraviolet oxidation system consists of a stainless steel
reactor with several stages, several UV lamps, an ozone
generator, and a hydrogen peroxide feed system. The UV lamps are
mounted vertically in the reactor and are enclosed in quartz
tubes. Ozone enters each stage through a stainless steel
diffuser. Hydrogen peroxide is metered into the reactor influent.
When the system is operated in the continuous mode, the
44
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contaminants in the water are oxidized to form carbon dioxide,
and water. Any halogens are converted to inorganic halides. A
fixed-bed catalytic ozone destroying unit is part of the UV
oxidation process, producing oxygen and limiting ozone emissions
to an instantaneous concentration of 0.1 ppm in air. Ozone
emission rates would be negligible. Any volatilized organic
compounds are also destroyed in the off-gas. The offgas is then
vented to the atmosphere.
A Treatability Study will be needed to verify performance and
size the plant. The AOP process will need to be installed in a
utility building, which would be located on the NWP property.
A consideration of any ultraviolet oxidation system is the amount
of heat generated by the UV lamps used in the treatment process.
This can cause scale formation on the quartz tubes. This scaling
can reduce the effectiveness of UV radiation and the overall
process. Some fouling would be stripped off by the ozone bubbles,
but a problem may develop every 1 to 1/2 years unless a citric
acid wash is used approximately every six months.
The discharge from the AOP system will be directed to granular
activated carbon units.
J. Granular Activated Carbon (GAC)
Disposable granular activated carbon (GAC) units will be
installed in series to polish the waste water prior to discharge
to Naylors Run. These units are relatively inexpensive and can
also provide effective back-up treatment (redundancy) at low
cost, for when there is an upset in the PACT unit or AOP unit.
Each disposable carbon unit contains approximately 1,000 pounds
of carbon, and can treat up to 30 gpm. For the anticipated flow
of 25 gpm, there will be a minimum of two units installed in
series. Periodic samples would be collected from the influent and
effluent of the GAC units, to predict breakthrough times and to
indicate how often the units would need to be replaced. Samples
of the spent carbon would be taken to determine disposal options
for the carbon.
The piping for the two units would permit any combination or
sequence of flow. Operation of the units will be staggered so
that the carbon units would not both reach breakthrough at the
same time. Treatability studies will be performed during the
remedial design phase of the project to adequately characterize
the necessary size and features of the granular activated carbon
treatment system.
K. Stream Discharge
The effluent from the treatment plant will be conveyed to Naylors
45
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Run in the vicinity of Eagle Road for discharge. Periodic samples
will be collected in accordance with any discharge
permit for the facility. Discharge monitoring reports will be
submitted per any National Pollutant Discharge Elimination System
(NPDES) requirements.
L. Waste- Disposal or Discharge to Hazardous Waste Facilities
It is anticipated that the recovered free product from the
oil/water separator and free product recovery wells, as well as
the solids collected from the chemical precipitation, PACT
process, and GAG units may contain hazardous compounds which will
require special handling for disposal at an off-site facility. A
secure storage area will be provided, located on the NWP site, to
store the residuals until they can be removed or treated.
For instance, the residuals may be listed as K001 wastes. There
are several off-site facilities which can accept the K001 wastes,
subject to analysis and verification of the waste
characteristics. K001 wastes are wastes from wood preservation
processes as listed in 40 C.F.R. 261.32. A waste disposal firm
was contacted to explore actual disposal alternatives. It was
determined that K001 wastes could be incinerated at two of its
facilities - one in New Jersey (drummed waste), or a facility in
Texas (bulk roll-off trailers). On-site incineration of the
solids is undesirable given the suburban location.
On-site treatment and destruction of organic residuals could be
provided by the wet air oxidation (WAO) system, particularly with
respect to residuals produced by the PACT process. Treatability
studies would evaluate operational conditions and equipment sizes
necessary to oxidize the spent carbon, recovered free product,
and other similar materials to the required destruction and
removal efficiency.
M. Ground Water Collector Drain
Installation of a collector drain near the existing storm sewer
will provide controlled collection of the contaminated shallow
ground water. The estimated chemical concentration of shallow
ground water collected by the drain is given in Table 17. The
drain is shown on Ficrure 11.
The purpose of a collector drain is to effectively capture the
plume of contaminated water in the shallow aquifer at the
southern edge of the site. The contaminated water can then be
sent to a treatment system for removal of the contaminants.
System components are selected to be compatible with any free
product which may be collected.
Although not designed to act as an collector drain, the existing
30" storm sewer pipe has intercepted a portion of the flow of
46
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contaminated ground water. The storm sewer pipe is subject to
periodic high storm water flows, which significantly restrict the
utility of using the storm sewer to collect water for further
treatment. Also, the storm sewer does not appear to be effective
in capturing the plume along its entire length. This
significantly limits the effectiveness of the storm sewer for
capturing the plume of contaminants in the shallow ground water.
Installation of the collector drain will significantly improve
capture of the plume, in comparison to the performance of the
existing storm sewer. The collector trench will be installed to
the depth of the fractured bedrock (significantly deeper than the
storm sewer), to improve collection throughout the shallow
aquifer. Also, the collector pipe will not be subject to periodic
flow excursions and flooding during storm events. The periodic
high flows into the storm sewer make continuous treatment
unrealistic for the storm sewer effluent.
Unless this action is taken, there is a significant concern that
the plume of contaminated ground water will migrate beyond the
storm sewer, and possibly into seeps in the back yards of
residences along Rittenhouse Circle.
A collector "drain will be installed, roughly in parallel with the
existing storm sewer pipe. Unlike the storm sewer, however, the
collector drain will be designed and installed to efficiently
intercept the flow of contaminated ground water. The following
factors have been identified concerning construction and
placement of the drain:
N. Drain Excavation
The drain excavation will be extended to the approximate
elevation of the fractured bedrock for maximum effect. This will
require excavation to a depth of approximately fifteen to twenty
feet. The base of the drain will be a minimum of two feet wide
in section. Shoring of the drain trench will be needed during
construction to minimize the quantity and cost of disposal of
excavation material. Shoring is also necessary to prevent
possible cave-ins and personal injury or property damage.
O. Interceptor Pipe
A perforated pipe will be placed at the bottom of the drain,
which will serve to convey the ground water to a pumping station.
The perforations will be oriented so that they are above the
normal depth of water flowing in the pipe to minimize
accumulation of debris.
The slope of the interceptor pipe will be designed so that a
constantly descending gradient is maintained to the pumping
station. Test pits will be excavated along the route of the
47
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interceptor pipe during the Remedial Design and Remedial Action
(RD/RA) phase of the project, so that the interceptor pipe design
invert elevations can be determined.
Samples will be collected at various depths in the test pits to
determine the levels of contaminants and disposal options for the
excavated materials. Depending on the contaminant levels, the
soils could be used as clean fill, or if contamination is
present, could be landfilled, incinerated, or other possible
alternatives.
During installation, irregularities in the elevation of the
fractured bedrock between test pits may require excavation of
fractured bedrock where it extends above the interpolated bedrock
elevations.
P. Access Manholes
Manholes will be provided every few hundred feet for access, and
at'any changes in pipe alignment. The access manholes will be
vented to ensure free drainage of the interceptor pipe. The
Remedial Design will evaluate the possible provision for
retrofitting disposable vapor phase carbon units, if odors become
a problem.
Q. Selection of Materials of Construction
In many cases, there will be a choice of different possible
materials of construction for a given system component. For
instance, the interceptor pipe could be made of PVC or some other
appropriate material. Costs have been estimated assuming that
the major pieces of equipment will not require significant use of
exotic materials of construction.
R. Drain Backfill Material
The drain will be appropriately graded and backfilled with a
highly porous select gravel. The gravel will drain freely to the
perforated Interceptor pipe at the bottom of the drain.
The drain will be lined with a permeable geotextile fabric on the
face of the trench which is upgradient to the collector pipe, to
permit unimpeded flow while minimizing gradual plugging of the
gravel with fine particles (fines).
To minimize entry of surface drainage and run-off into the
collector drain, an impermeable membrane liner will be placed
above the gravel layer. This membrane liner will be extended
along the face of the trench which is downgradient to the
collector pipe. Without this feature, where the collector drain
crosses any buried utility lines, there would be the undesirable
possibility of contaminated ground water flow entering the select
48
-------
backfill present in other utility trenches.
The impermeable membrane will minimize such flows wherever the
collector drain encounters such potential conduits for the ground
water to escape the collector trench. This key feature will
minimize any communication between the ground water in the
collector trench with permeable soil formations which are
present.
The seams where two rolls of membrane adjoin will be sealed to be
water tight. The liner thickness (and any necessary reinforcing)
will be selected to withstand any hydraulic forces acting on the
membrane due to the differential head across the membrane.
S. Collector Drain Pumping Station
A pumping station will be provided to convey the collected ground
water to a suitable treatment system. Installation of the pumping
station will require extending an electrical service to power the
pumps, system controls, and any desired alarm systems. Pumping
capacity will depend on the actual flow of water in the collector
trench, and the instantaneous flow capacity of-the treatment
system. Each pump will have a capacity of approximately 25 gpm.
The pump system shall be provided with necessary features for
explosion-proof operation. Low shear diaphragm pumps will be
provided to minimize emulsification of the oily water.
T. Monitoring Wells
Installation of the interceptor trench could potentially affect
the performance of existing monitoring wells which are located in
the vicinity of the drain. This will require careful attention
to the design and installation of the drain, or possibly
installation of new wells outside the drain area, so that
representative samples can be collected.
U. Rehabilitation of the Existing 30-inch Storm Sewer
A recent closed circuit television surveillance of the storm
sewer pipe indicates the presence of a small pipe discharging
into a manhole located on the south side of the Philadelphia
Chewing Gum property. This source of inflow is apparently an
unpermitted connection to the storm sewer, which unnecessarily
increases the dry weather flow of the storm sewer. It is
anticipated that this source of inflow will be plugged, after
USEPA notifies the affected property owners of the action to be
taken.
The last section of storm sewer pipe (extending approximately 200
feet from the manhole south of PCG to the discharge point into
Naylors Run) was observed to contribute noticeable infiltration
49
-------
into the storm sewer pipe during dry weather.
The storm sewer pipe will be lined in-place. The lining will
virtually eliminate any infiltration into the storm sewer pipe.
The contaminated water which is presently being collected by the
storm sewer pipe will instead be collected in the interceptor
drain, with the advantage that the flows in the interceptor drain
will not be subject to radical increases in flow during storm
events.
Summary
This alternative calls for the design and implementation of an
interim remedial action to protect human health and the
environment. The goals of this remedial action is to remove all
free product and contaminated ground water from the shallow
ground water aquifer and to collect data on the aquifer and
contaminant response to remedial measures. The ultimate goal of
remediation will be determined in a final remedial action for
this site. This remedial action will be monitored in accordance
with the below performance standards to determine the feasibility
of achieving this goal with this method and to ensure that
hydraulic control of the contaminated plume is maintained. After
the period of time necessary, in EPA's judgment, to arrive at a
final decision for the site, a final ROD for ground water, which
specifies the ultimate goal, remedy, and anticipated timeframe,
will be prepared. Upon completion of a final RIFS, this interim
remedy may be incorporated into the design of the site remedy
specified in the final action ROD.
In order to restore contaminated ground water to beneficial use,
and to further reduce human health risk levels in surface waters,
the remediation implemented under the selected remedy shall
operate until site-specific remediation levels are achieved.
Thus, ground water shall be collected and treated up to 30 years
or until the levels of the contaminants of concern reach
background levels, maximum contaminant levels (MCLs) or maximum
contaminant level goals (MCLGs), whichever are lower, or until
information from the final operable unit impacts upon these
levels. MCLGs are health goals which are set at a level at which
no known or anticipated adverse effects of the health of persons
occur and which allows an adequate margin of safety. MCLs are
levels, set as close to MCLGs as possible, which are considered
feasible. The MCLs and MCLGs for organics are set forth
respectively in 40 CFR 141.61 (a) and 40 CFR 141.50 and for
inorganics in 40 CFR 141.11 (b) and 141.62 (b) . MCLs and MCLGs
for selected chemicals of concern are listed in Table 23.
Background concentration of the contaminants of concern will be
approved by EPA after a determination of compliance with the
procedures for ground water monitoring as outlined in 25 PA Code
264.97. In the event that a contaminant is not detected in
50
-------
Table 23
Havertown PCP Site
Chemical-Specific ARARs
Chemicals
of
Potential Concern
Organlcs:
acenaphthene
acenaphthylene
anthracene
benzene
benzo (a) anthracene
benzo(a)pyrene
D1 s (2-ethy | hexy 1 ) phthal ate
chrysene
1 , 2- trf ch 1 oroethy 1 ene
ethyl benzene
riuoranlhene
naphthalene
2 -methyl naphthal ene
pentachlorophenol
phenanthrene
pyrene
2,3,/.8-rCDO (Equivalent)
to! uene
trlchloroethylene
vinyl chloride
xylene
USEPA National
OHnklng Hater
Regulations
Current ft
Final
MCU*
+
5
700
»
1
*
1,000
5
5
10.000
Final
MCLGs*
0
100
700
*
»
0
*
1.000
0
0
10.000
PA Hater Quality
Criteria
Naylors Run
Surface Hater
Discharge
ir
0.003"
0.003s
lb
0.003"
0.003b
909s
0.003"
*
580«
40e
10h
'
13 9 pH 7.8'
3.5 * pH 6.5e
0.003"
0.003"
1 X 10-*
330*
3"
0.02"
«
POOR QUALITY
ORIGINAL
-------
Table 23 (continued)
Havertown PCP Site
Chemical-Specific ARARs
Chemicals
of
Potential Concern
Inorganics i
aluminum
arsenic
cobalt
manganese
USER* National
Drinking Water
Regulation*
Current &
Final
MCLs§
50
SO
Final
MCLfis*
»
*
PA Water Quality
Criteria
Nay Tors Run
Surface Water
Discharge
50"
Notes;
Final MCLs and MCLGs become effective July 1992
b Human Health Criteria
r Chronic Toxlcity for the Protection of F1sh and Aquatic Life
No USEPA National Drinking Water Regulation or Commonwealth of Pennsylvania.
ARARs for these chemicals
-------
COMPOUND
Act ton*
AcroUIn (Propcral)
Acrylonltrtl*
*nt*n*
lroMob*ru*n*
troBoch loroMthent
IroModlchloroMthan*
IroMofom
IroMonthen*
2-gutenon* (Methyl ethyl
kttont)
lutylbenim*
Stc-lutylbtnien*
Ttrt-tutylbtnttnt
Ctrbon dl tut fid*
Carbon Utrechlorlde
Chlorobentene
Chlorotthtn*
1-Chlorocyclohtxtf*
2-Chloro*thyl vinyl
thtr
CMorofora
1-Chloroh*ii«n*
ChloroMthtrw
Chlorotolutrw
2-Chlorotolu*n*
4-Chlorotoluerw
DlbroMtchloroMthMM
1,2-Dlbron-S
-chloropropent
1,2-DlbroMMttunw
DtbronKMWthtne
1,2-0lchlorobeni*ne
1 ,3-Olchlorobentcne
1.4-Olchlorobenien*
DteMorodtf luoromethine
1,1 DlcMoro«th»o«
1,2-Dlchloroetharw
CAS »
67-64-1
107-02-8
107-13-1
71-43-2
108-86-1
74-97-5
75-27-4
75-25-2
74-83-9
78-93-3
104-51-8
135-98-8
98-06-6
75-15-0
56-23-5
108-90-7
75-00-3
-
100-75-8
67-66-3
,
74-87-3
95-49-8
.
124-48-1
106-93-4
74-95-3
95-50-1
541-73-1
106-46-7
75-71-8
75-34-3
107-06-2
STORE!
*
81552
34210
34215
34030
34413
32101
32104
34413
.
-
.
32102
34301
34311
34576
32106
,
34418
-
.
34105
-
-
-
34536
34566
34571
34668
34496
34531
CLP
CIP f
CHOI b CROL°'C
ug/l
10
10
-
.
10
10
10
10
.
-
-
10
10
10
10
-
-
10
.
10
.
.
10
-
.
-
.
.
10
10
ug/Kg
10
-
10
.
10
10
10
10
.
-
-
10
10
10
10
.
10
.
10
-
.
10
-
-
-
.
-
-
10
10
601
ug/L
.
-
-
.
0.10
0.20
1.18
.
*
'
0.12
0.25
0.52
0.13
0.05
.
0.08
.
-
0.09
-
-
0.15
0.32
0.24
1.81
0.07
0.01
602 I
60S 624
ug/L ug/L
.
0.7(3) -
0.5(3)
0.2(2) 4.4
. .
2.2
4.7
nd
.
-
2.8
0.2(2) 6.0
nd
-
nd
1.6
nd
-
.
-
3.1
-
-
-
0.4(2) nd
0.4(2) nd
0.3(2) nd
.
4.7
2.6
6010
ug/L
.
-
-
-
nd
.
0.10
0.20
nd
.
-
-
-
0.12
0.25
0.52
*
0.13
0.05
.
0.08
nd
.
0.09
-
-
nd
0.15
0.32
0.24
nd
0.07
0.03
8020 I
80SO 8240
ug/L ug/L
.
0.6(3)
0.5(3) -
0.2(2) 4.4
-
. .
2.2
4.7
nd
. .
-
.
2.8
0.2(2) 6.0
nd
nd
1.6
.
nd
.
.
3.1
-
-
0.4(2) nd
0.4(2) nd
0.3(2) nd
nd
4.7
2.8
ORIGINAL
RevUlon Datet October 1990
SOI. 3 502.1
ug/L ug/L
.
-
-
.
nd
nd
0.07 0.002
0.04 0.02
.
.
-
0.003
0.001
0.008
nd
0.02
0.06 0.002
. ,
0.01
nd
.
0.05 nd
0.03
0.03
nd
nd
nd
nd
nd
0.002
0.002
502.2 502.2
PIO NECO
ug/L ug/L
.
-
.009
-
0.01
0.02
1.6
1.1
» *
.
*
*
*
0.01
0.003 0.01
0.1
-
0.02
.
0.03
.
.
0.03
0.6
2.2
. .
O.OS
0.07
0.03
503.1
A 504
ug/L
.
-
0.02
0.002
.
'
1.1
-
0.02
0.02
0.006
0.004
-
0.008
.
.
-
0.008
.
.
0.01(4)
0.01(4)
.
0.02
0.006
0.006
.
.
-
524.1
ug/L
.
-
0.10
0.12
nd
0.28
0.66
nd
nd
nd
«
0.28
0.14
-
.
0.24
.
*
nd
.
0.30
1.8
0.36
6.30
1.0
m
2.0
0.33
0.17
0.22
324.2
WIDE
ug/L
,
0.04
0.03
0.04
0.08
0.12
0.11
0.11
0.13
0.14
0.21
0.04
0.10
-
*
0.03
0.05
0.13
-
0.04
0.06
0.05
0.26
0.06
0.24
0.03
0.12
0.03
0.10
0.04
0.06
524.2
NARROW
ug/L
.
0.03
0.11
0.09
O.OS
0.20
0.06
0.10
0.12
0.33
-
0.02
0.03
0.02
0.04
.
O.OS
0.08
0.06
0.07
0.50
0.10
0.10
0.05
O.OS
0.04
0.11
0.03
0.02
-------
Table 24
POOR QUALITY,
ORIGINAL
< C O N T)
Revision 0«t«t October 1990
COMPOUND CAS *
1,1-Dlchlorotthtnt 75-35-4
Cli-1,2-Dlchlorotth«nt 156-59-2
Trtnt-1,2-DlcMoro«thent 156-60-5
1,2-Dlchioroproptnt 78-67-5
1,3-Dlchloropropww 142-26-9
2.2-OlcMoropcoptnt 594-20-7
1,1-DlcMoropropent 563-58-6
CU-1,3-Olchloropropent 10061-01-5
IrMtt-I.S-OUhloroproptnt 10061-02-6
Ethyl btnitnt 100-41-4
NtxacMorobuttdltnt 87-66-3
2-HtRtnont 591-70-6
liopropylbtnitnt 98-62-6
4-Uopropyltoluww 99-67-6
Mtthyltnt chlofldt 75-09-2
4-N*thyl-2-pent«norw 108-10-1
NtpMhtttnt 91-20-3
N-Propylbtnitnt 103-65-1
Styrtnt 100-42-5
1.1,1.2-Ittr»chlorotth«nt 630-20-6
1,1,2,2-Tttrtchlorotthtnt 79-34-5
Tttr»cMoro«thtnt 127-18-4
lolutnt 108-68-3
1.2.3-lrlchlorobtnitfw 87-61-6
1.2,4-lrlchlorobtnitnt 120-62-1
1,1,1-TrlcMorotthtnt 71-55-6
1,1.2-IrlcMorotthtnt 79-00-5
Trlchlorocthrnt , 79-01-6
UlchlorofluoroMthMW 75-69-4
1,2,3-TrlchloroprofWM 96-18-4
1,2,4-TrlntthyibtntttM 95-63-6
1,3,5-Trlntthylbcniene 108-67-6
Vinyl kcettle 108-05-4
Vinyl chloride 75-01-4
0-Xyltnt 95-47-6
M-Xylent 108-38-3
P-Xyl*ne 106-42-3
lotel Xylenes 1330-20-7
STORET
*
34501
.
34546
34541
.
34704
34699
34371
.
.
-
.
34423
.
-
.
-
34516
34475
34010
.
34506
34511
39180
34488
-
.
39175
-
.
-
CLP
CRDl "
ug/L
10
10*
10*
10
-
.
-
10
10
10
.
10
-
10
10
-
.
10
-
10
10
10
.
-
10
10
10
-
.
10
.
-
10
CLP»
' CROlb'C
ug/Kg
10
10*
10*
10
.
*
10
10
10
.
10
.
.
10
10
.
-
10
-
10
10
10
.
10
10
10
-
.
10
.
.
10
602 t
601 603
ug/L ug/L
0.13 -
0.10 -
0.04 -
.
0.34 -
0.20 -
0.2(2)
.
.
-
-
0.25 -
,
.
-
0.03
0.03
0.2(2)
.
0.03
0.02
0.12 -
nd - .
. .
'
0.18
. .
.
-
624
ug/L
2.8
.
1.6
6.0
-
.
-
5.0
nd
7.2
.
.
.
-
2.8
.
-
.
-
6.9
4.1
6.0
.
3.6
5.0
1.9
nd
.
-
-
nd
-
.
.
8010
ug/L
0.13
.
0.10
0.04
.
0.34
0.34
-
.
.
-
.
-
.
.
0.03
0.03
.
0.03
0.02
0.12
nd
.
.
0.16
.
.
-
8020 I
8010 8240
ug/L ug/l
2.8
.
1.6
6.0
-
.
nd
5.0
0.2(2) 7.2
.
.
-
2.8
» .
.
-
6.9
4.1
0.2(2) 6.0
.
-
3.8
5.0
1.9
nd
.
-
-
nd
nd
nd
nd
nd
501.3 502.1
ug/L ug/L
0.003
0.002
0.002
nd
nd
.
-
.
.
-
-
nd
.
.
0.01
0.001
.
,
*
0.003
0.007
0.001
nd
. .
.
0.006
. ,
.
-
502.2
PID
ug/L
nd
0.02
0.05
.
0.02
0.005
.
0.05
-
.
0.01
.
0.05
0.01
*
0.02
.
0.02
0.02
0.01
0.01
502.2
MECO
ug/L
0.07
0.01
0.06
0.006
0.03
0.05
0.02
.
.
.
0.02
.
-
0.005
0.01
0.04
-
*
0.03
nd
0.01
0.03
0.4
.
.
.
0.04
.
503.1
t 504
ug/l
.
.
0.002
.
0.005
0.009
.
0.04
0.009
0.006
.
0.01
0.02
0.03
0.03
.
-
0.01
.
-
0.006
0.003
.
.
0.004
0.004
0.002
524.1
ug/l
0.19
0.19
0.17
0.10
*
.
*
nd
nd
0.13
.
nd
nd
0.20
0.41
0.29
0.12
nd
nd
0.26
-
0.36
0.21
nd
nd
*
0.31
0.20
nd
0.13
-
324.2
WIDE
ug/L
0.12
0.12
0.06
0.04
0.04
0.35
0.10
0.06
0.11
-
0.13
0.12
0.03
.
0.04
0.04
0.04
0.05
0.04
0.14
0.11
0.03
0.04
0.06
0.10
0.19
0.08
0.32
0.13
0.05
0.17
0.11
0.05
0.13
524.2
HARROW
ug/L
0.05
0.06
0.03
0.02
0.08
0.08
0,12
0.03
0.10
-
0.10
0.26
0.09
.
0.10
0.10
0.27
0.07
0.20
0.05
0.08
0.14
0.20
0.04
0.06
0.02
0.07
0.09
0.09
O.M
0.04
O.M
0.0!
O.W
Ciii-I.Z-Dlchloroulhcnc OIK! Irons-1,2-OltMoi oetlicix: not KcpnrnU-il. Di-li-cUon llmils mcusui t-il tu<|ctliur.
-------
POOR
ORIGINAL
Table 24
METHOD DETECTION LIMIT-PESTICIDE. PCS
n d
NEIIICI»E>
Mvlilon Datti October 1990
COMPOUND
Aclfluorftn
AlKhlor
Aldlcsrb
Aldlc»rb sulfor*
Atdlcsrb sultoxld*
Aldrln
Atrston
Anttryn
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Atrsilr*
Ailnphot Methyl
ygon
lentsion
IroMCIl
lutMhlor
utylst*
Atphs-IHC
ts-IHC
0*lts-tHC
CMM-IHC (llndMM)
Bolstsr (Sulprdfot)
Csrbtryl
Csrbolursn
Csrboxln
ChlorMixn
Alpht-Chlordww
GsniM-ChlordsfW
Chlordant
Chlorneb
CAS ff
50594-66-6
15972-60-8
116-06-3
1646-88-4
1646-87-3
309-00-2
1610-17-9
834-12-8
12674-11-f
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
1912-24-9
114-26-1
25057-89-0
314-40-9
23184-66-9
2008-41-5
319-84-6
319-85-7
319-86-8
58-W-9.
-
63-25-2
1563-66-2
5234-68-5
133-90-4
5103-71-9
5103-74-2
57-74-9
2675-77-6
STORET
*
,
.
-
39330
.
-
34671
39488
39492
39496
39500
39504
39508
.
-
-
.
-
39337
39338
34259
39340
-
.
.
-
.
-
39350
CLP .
CRDL "
ug/L
*
.
-
0.05
.
1.0
2.0
1.0
1.0
1.0
1.0
1.0
.
-
.
-
.
-
0.05
0.05
0.05
0.05
-
-
-
,
0.05
0.05
.
-
CLP "
1 CROL b
ug/Kg
.
.
-
.
1.7
.
-
33
67
33
33
33
33
33
.
-
.
.
.
-
1.7
1.7
1.7
1.7
-
-
-
.
'7
1.7
.
8080
ug/L
.
-
-
-
-
0.004
nd
nd
nd
0.065
nd
nd
nd
.
.
-
.
-
0.004
0.006
0.009
0.004
-
-
-
-
0.014
-
8250 8140
ug/L ug/L
.
-
-
-
1.9
nd
30
nd
nd
nd
36
nd
.
1.5
-
-
»
.
-
nd
4.2
3.1
nd
, 0.15
.
-
-
. .
-
nd
-
8150 608
ug/L ug/L
.
- .
0.004
nd
nd
nd
0.065
nd
nd
nd
. .
-
*
.
, ,
-
0.003
0.00
0.009
0.00
-
-
-
.
.
0.014
625
ug/L
.
-
.
-
1.9
.
nd
30
nd
nd
nd
36
nd
.
-
-
-
.
-
-
4.2
3.1
,
-
.
.
.
-
.
nd
-
505
ug/L
.
0.225
.
-
0.075
0.08
15.0
0.48
0.31
0.102
0.102
0.189
2.4
-
-
*
*
.
.
0.003
-
.
.
.
0.006
0.012
0.14
-
508 * 525 525
507 * I 508* 515.1 * MAGNETIC ION 531.1 '
ug/L ug/L ug/l ug/L ug/L ug/l
0.096
0.38 1.0*
1.0
2.0
2.0
0.075 0.1 0.1
0.6
2.0
. . .
0.14
-------
Table 24
< C O N 1 )
POORQUAUIY
ORIGINAL
MvUton 0«t«: October 1990
STORET
COMPOUND CAS f
CIP . CIP '
CHOI " CHOI "
ug/l ug/Kg
8080 8250 8140
ug/l ug/l ug/L
506 * 325 323
8150 608 625 505 507 * i 508A 515.1 * MAGNETIC ION 531.1 *
ug/l ug/L ug/L ug/L ug/L ug/L ug/l ug/l ug/l ug/l
CMorobenilUtt
2-CMoroblphtnyl
CMorprophM
CMorpyrlfM
Chloroth*lonll
CouMphot
CyclMU
DCPA
2,4-D
2.4-01
4,4<-DOO
4, 4* -DDE
4, 4 '-DDT
Dtltpon
Doncton
Dltilnon
DICMfc*
3,5-Dlchlorobtntolc
Acid
2,3-OUMorobtphtnyl
Otchtorprop
DIcMorvo*
Dlildrln
Olnonb
DIphtnMld
Dltutfoton
DliuUoton futfon*
OliuKoton lultoxldt
Endow) (MI 1
Endotulfin II
Endotulf«n tulfate
Endrln
Endrln Idohyd*
Endrln k«tone
EPIC
501-15-6
2051-60-7
101-21-3
*
2921-88-2
56-72-4
1134-23-2
1897*45-6
94-75-7
94-82-6
72-54-8
72-55-9
50-29-3
75-99-0
8065-48-3
333-41-5
1918-00-9
51-36-3
16605-91-7
120-36-5
62-73-7
60-57-1
88-85-7
957-51-7
298-04-4
2497-06-5
2497-07-6
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-3
759-94-4
I !!»»
39310
39320
39300
-
.
-
-
-
.
-
39380
.
.
.
.
34361
34356
34351
39390
34366
-
.
0.10
0.10
0.10
.
.
-
.
-
0.10
.
.
.
.
0.05
0.10
0.10
0.10
0.10
0.10
.
-
3.3
3.3
3.3
-
.
.
.
.
-
3.3
-
,
.
.
1.7
3.3
3.3
3.3
3.3
3.3
-
0.012
0.004
0.012
-
.
.
.
.
0.002
.
.
.
0.014
0.004
0.066
0.006
0.023
.
.
-
2.8
5.6
4.7
.
.
-
.
.
2.5
-
m
.
*
nd
nd
5.6
nd
nd
.
.
0.3
1.5
1.0
1.0
0.011
0.004
0.012
1.0
0.25
0.6
1.0
.
.
1.0
0.1
0.002
0.1
.
0.20
.
0.014
0.004
0.066
0.006
0.023
.
.
-
-
2.8
5.6
4.7
.
.
.
.
.
2.5
-
.
-
nd
nd
5.6
nd
nd
.
-
5 ....
0.08(A) - 0.1 0.1
0.5 - -
0.025
0.25
0.025. 0.02 -
0.2
0.8
0.0025 ....
0.01 ....
0.06 ....
1.S
.....
0.25 .....
0.081
0.061
O.I 0.1
0.26
2.5
0.012 0.02 ....
0.19
0.6
0.3 -
3.8
0.38 .....
0.019 - - -
0.024 '
0.015 - -
0.063 - 0.015 1.0 0.5
0.025 ....
.
0.25 .....
-------
Table 24
( C O T )
POOR QUA .ITY
ORIGINAL
MvUlon 0»t«i October 1990
OMTOUND
STORET
CAS * *
CLP
CROL b
ug/L
CLP '
1 CRDl b
ug/Kg
8080
ug/L
8250
ug/L
8140
ug/L
8150
ug/L
608
ug/L
625
ug/L
505
ug/l
508*
507 * t 508A
ug/L ug/L
3 W.I *
ug/L
525 525
MAGNETIC ION
ug/L ug/L
531.1 *
ug/L
thoprop
trldUioU
tDMlptlOl
trwrlml
tfMulfothlon
'nthlon
'turldorw
Ktpttchlor
H*pt»chlor poNldt
2,2*. 3.3' ,4,4*.6-
HtptKhtoroblphtnyi
2,2«,4.4',5,6'-
MtKKhloroblphtnyl
Htxtchlorocyclo-
ptntMlltfW
Htxctlnon*
3-Hydroxycirbofurwi
5-NydroxydlcMte
HCPA
NCPP
mrphot
mthlocirb
Mtthonyl
MtthmycMor
mthyl pirMxon
MttoUchlor
Nttrtbuitn
Hcvlrphoi
HGK 264
Moltnatt
Niltd
NapropMld*
4-Nltrophcfx>t
Clt-Xonaehlor
Irans-Monachlor
2593-13-9
22224-92-6
60168-88-9
115-90-2
55-38-9
59756-60-4
76-44-8 39410
1024-57-3 39420
52663-71-5
118-74-1
60145-22-4
77-74-4
51235-04-2
16655-82-6
7600-50-2
150-50-5
2032-65-7
16752-77-5
72-43-5
950-35-6
51218-45-2
21087-64-9
7786-34-7
113-48-4
2212-67-1
300-76-5
15299-99-7
100-02-7
39765-80-5
0.25
1.5
0.10
* *
0.05 1.7 0.004 1.9
0.05 1.7 0.083 2.2
.
»»*
200
200
0.25
0.5 17.0 0.176
*
0.3
0.1 -
* » *
» *
.
*
0.003 1.9 0.003
0.083 2.2 0.004
0.002
0.13
V
*
* *
0.96
.
0.027
0.011
0.19
1.0
0.38
3.8
-
'
0.76
0.25
*
2.5
0.75
0.15
5.0
0.5
0.15
0.25
*
0.025 -
* *
' tf »
*
0.01 -
0.015 -
0.0077 -
0.04
0.05
» *
0.13
0.2
0.3
0.04
0.2
0.1
0.1
-
0.3
* ,
*
0.1
*
0.04
0.2
0.1
0.1
0.1
0.03
*
2.0
4.0
0.3
0.04
*
*
0.3
-------
Table 24
( C 0 M I )
ORIGINAL
RtvUlon 0«t«: October 1990
COMPOUND
Norflurcton
Oct*chloroblphenyl
Parcthlon *tthyl
PtbultU
Pent «ch 1 orobl ptitny 1
PtnttcMoropMnol
Cli-PtrMthrln
Tr*n«-P*nMthrln
Phorctt
PIclorM
ProMton
ProMtryn
PronMtd*
Proptchlor
Proptitnt
Ronr*t
SiMilr*
SlMtryn
SlUophoi
Stirofet
2,4,5-1
2,4,5-IP («Hvtx)
Tttouthluron
TcrbKll
Ttrbuto*
Itrbutryn
2,2',4,4«-
TttrtcMoroblphcnyl
STORE T
CAS * *
27314-13-2
40186-71-8
21115-22-0
298-00-0
1114-71-2
60233-25-2
87-86-5
52645-53-1
52645-53-1
298-02-2
1918-02-1
1610-18-0
7287-19-6
23950-58-5
1918-16-7
119-40-2
122-34-9
1014-70-6
22248-79-9
91-76-5
91-72-1
34014-18-1
5902-51-2
13071-79-9
886-50-0
2437-79-8
Tokuthlon (Prothlofot)
Toxaphene 8001-35-2 39400
TrtwfciMfon 43121-41-3
2,4,5-Trlchloro-
blphenyl 15862-07-4
TrtchloroTMtc
Irlcycleiole
Irtlluratln
Vernolate
327-98-0
41814-78-2
15B2-OT-6
1929-77-7
CLP . CLP * 508 *
CROL CRDL ° 8080 8250 8140 8150 608 625 505 507 * t 50M
ug/L ug/Kg ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L
v* » »» 0»5 *
> * v _ V
* . . 0.3 * *
......... 0.13 *
» * » * . »»
0.5
* . * 0*5
0.15 ....
0.19
* **0a 7 o *
0.5
0.13
0.3 ....
6.8 0.07$
********* 0*29 *
« * 5,0 * * *
0,76
0.1 ....
. * » 0*1* * * *
i.j
... . . . 4,5
0.5
0.25
0.50 - - ....
5.0 170 nd nd 0.24 nd 1.0
0.65
0.15 - - ....
1.0
0.025
0.13
. *"
515.1 " MAGNETIC
ug/L ug/L
'
0.1
0.1
0.076 3.0
0.14
* *
0.2
* *
*
0.08
0.075
*
0.1
nd
0.12
-
525
ION 511.1 *
ug/L ug/L
0.2
2.0
0.1
0.3
*
0.2
» *
0.1
nd
0.06
-------
POOR QUA K
ORIGINA.
Acen«t>hthen«
Acenaphthyltn*
Anthr*c«f*
tnso(a)mthrK«rw
tnio(b)fluorMithtn*
ltnio(k)tluoranthww
l*nio(a)pyr«n*
l*nio(g,h. 1 )ptryl«nc
Itnildln*
U(2-chloro«thyl)«th«r
1i(2-cMoro«thoxy)Mthww
tt(2-cMoroUopropyl)«th«r 01
2.,2'-oxyt)UO-CMoropro(MMw)
U(2-«thylh«xyl)»dlp«U
((2-«thylhcNyl)phth«Utt
4-lro*Nph«fiylphtfiyt«thtr
utylbemylpnth*l»t*
Cartotol*
4-CMoroMtlllfW
4-CMoro-3-Mthylpntnol
2-ChtororaphthaltTM
Z-Chlorophtnot
4-Chlorof*tnylphfnyt«thtr
Chryttrw
Olbtnio(a,h)MithrM:tnt
DltNnsofurwt , .
Ot-n-butylphth«Ut«
1 ,3-OlcMorotmueot
1 , 4-0 1 eht orotwnien*
1,2-Dlchlorobtnxen*
3,3'-DlcMorobtntliiln*
2,4-DlcMorophenol
DttthylphthiUte
2,*-Dlnethylphenol
DlmethylphthtUtc
83-32-9
208-96-8
120-12-7
56-55-3
205-99-2
207-08-9
50-J2-8
191-24-2
92-87-5
111-**-*
111-91-1
r
108-6-1
103-21-1
117-81-7
101-55-3
85-68-7
86-74-8
106-47-8
59-50-7
91-58-7
95-57-8
7005-72-3
218-01-9
53-70-3
132-64-9
84-74-2
541-73-1
106-46-7
95-50-1
91-94-1
120-83-2
84-66-2
105-67-9
1J1-11-3
34205
34200
34220
34526
34230
34242
34247
34521
39120
3*273
34278
5*281
39100
34636
3*292
34452
34581
34586
34641
34320
34556
81302
39110
34566
34571
34536
34631
34601
34)36
34606
3*3*1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
330
330
330
330
330
330
330
3)0
330
330
3)0
330
330
330
330
330
330
330
330
3)0
330
3)0
330
330
330
330
3)0
330
3)0
3)0
3)0
3)0
*
*
20
15
0.36
0.31
14
0.39
31
0.32
19
2.0 (6)
0.3* (6)
1.8 (4)
0.94(12)
0.58 (4)
0.36 (6)
1.19(12)
1.34(12)
1.14(12)
*
0.68 (4)
0.49 (6)
0.63 (4)
0.29 (6)
1.9
3.5
1.9
7.8
4.8
2.5
2.5
(.1
44
5.7
5.3
S.f
2.5
1.9
2.5
3.0
1.9
3.3
4.2
2.5
2.5
2.5
1.9
4.4
1.9
16.5
2.7
22
2.7
1.6
1.8 UV
2.3 UV
0.66 FL
0.013 FL
0.018 ft
0.017 FL
0.023 FL
0.076 FL
-
-
*
0.15 FL
0.030 FL
1.8 (10)
2.3 (10)
0.66 (10)
0.013(10)
0.018(10)
0.017(10)
0.023(10)
0.076(10)
0.08 (5)
0.3 (11)
0.5 (11)
0.8 (11)
2.0 (6)
2.3 (11)
0.34 (6)
0.36 (4)
0.94 (12)
0.31 (4)
J.9 (11)
0.15 (10)
0.030(10)
0.36 (6)
1.19 (12)
1.34 (12)
1.14 (12)
0.13 (5)
0.39 (4)
0.49 (6)
0.32 (4)
0.29 (6)
1.9
3.5
1.9
7.8
4.8
2.5
2.3
4.1
44
5.7
5.3
5.7
2.5
1,9
2.3
J.O
1.9
3.3
4.2
2.5
2.5
* »
2.5
1.9
4.4
1.9
16.5
2.7
1.9
2.7
1.6
*
0.1
0.1
0.2
0.3*
0.3*
0.1
0.1
0.5
0.8
»
0.3
0.3
0.1
4.0
*
*
0.6
0.3
0.1
0.04
0.04
0.2*
0.2*
0.04
0.1
*
0.6
0.6
»
0.3
»
»
»
0.04
0.1
0.3
0.8
0.04
Bcnto(b)fluor«nthene end bcnto(k)fluoronthcne not voperated. Detection limits mcosured together.
-------
,vj!< QUALITY,
ORIGINAL!
Table 24
< C O
RevUlon D«tei October 1990
COMPOUND
2,4-Dlnltrophenol
2,4-Olnltrotoluene
2,6-Olnltrotolucnt
Ol-n-octylphthalat«
Fluor anther*
Fluorene
Henechlorobentene
He*achl orobut edl ene
MexacMoroethene
Nexechtorocyctopentadlene
1 ndeno( 1 , 2 , 3 - ed)py rene
laophorona
2-Ncthyl-4,6-dlnltr«phenol
2-Methylnaphthalene
2-Nethylphenol
4-Methyl phenol
Naphthalene
2-NUroanlllnt
3-Nttroantllne
4-Nltroanlllna
Nltrobeniene
2-Nltrophenol
4-Nltrophenol
N-NltrotodlnethylMlne
N-Nl trotodl -n-pr opyloerine
N-Nltroeodlphenylaalne
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2,3,7.8-lttrachlorodlbenio-
p-dioxln (2,3,7,8-ICOD)
1 , 2 , 4 1 r 1 chl orobeniena
2,4,5-lrlchlorophenol
2,4,6-lrlchlorophenol
CAS *
51-28-5
121-14-2
606-20-2
117-84-0
206-44-0
86-73-7
118-74-1
87-60-3
67-72-1
77-47-4
193-39-5
78-59-1
534-52-1
91-57-6
95-48-7
106-44-5
91-20-3
88-74-7
99-09-2
100-01-6
98-95-3
68-75-5
100-02-7
62-75-9
621-64-7
86-30-6
87-86-5
85-01-8
108-95-2
129-00-0
1746-01-6
120-82-1
95-95-4
88-06-2
STORET
34616
34611
34626
34596
34376
34381
39700
34191
14196
34386
34403
34408
34657
34696
34447
34591
34646
34438
34428
34433
39032
34461
34694
34469
34675'
34551
14621
CIP
CROL '
ug/L
50
10
10
10
10
10
10
10
10
10
10
10
50
10
10
10
10
SO
50
50
10
10
50
10
10
50
10
10
10
10
50
10
CIP * .
> CROlb'd
ug/Kg
1700
330
330
310
330
330
330
310
310
330
330
330
1700
330
330
330
330
1700
1700
1700
330
310
1700
310
330
1700
330
310
310
330
1700
110
8040 to
no
ug/L
13
nd
nd
31
5
16
5.0
0.45
2.8
7.4
0.14
nd
0.64
8120
ECO
ug/L
nd (4)
0.06 (9)
0.06 (9)
3.0 (6)
0.05(12)
0.01(12)
nd (12)
nd (9)
nd (4)
nd (9)
0.77 (4)
0.70 (4)
0.59 (4)
2.2 (4)
0.05(12)
nd
0.58 (4)
8250
CC/MS
ug/L
42
5.7
1.0
2.5
2.2
1.9
1.9
0.9
1.6
nd
3.7
2.2
24
1.6
1.9
3.6
2.4
nd
nd
1.9
3.6
5.4
1.5
1.9
1.9
2.7
6)10
HPLC
ug/L
*
0.21 a
0.21 UV
0.043 H
1.8UW
0.64 fl
0.27 FL
604 to
612
ug/L
13 (4)
0.02 (9)
0.01 (9)
3.0 (6)
0.21 (10)
0.21 (10)
0.05 (12)
0.34 (12)
0.05 (12)
0.40 (12)
0.043(10)
15.7/5.7(9*)
16.0
1.8 (10)
3.7/3.6(9*)
0.45 (4)
2.8 (4)
O.H (7)
0.46 (7)
0.81 (7)
7.4 (4)
0.64 (10)
0.14 (4)
0.27 (10)
0.002(13)
0.05 (12)
0.64 (4)
625
CC/MS
ug/L
42
5.7
1.
2.
2.
1.
1.
0.
1.
nd
3.7
2.2
24
1.6
1.9
3.6
2.4
nd
nd
1.9
3.6
5.4
1.5
1.9
1.9
2.7
325
513 MAGNETIC
ug/L ug/L
-
0.1
0.2
* *
0.1
0.02
»
*
j.o
0.2
* *
0.1
0.002
* »
525
ION
ug/L
*
0.2
0.1
0.03
0.1
*
-
0.3
0.01
0.02
« luo different detector* ere used, FID trvd ECO.
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FOOTNOTES (COfT.l
600 SERIES; 40 CFI Part 136 Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the
ClMn Water Act. Consists of 2 HPLC sathods (60S « 610), 10 GC Methods and 3 CC/MS wthods (613,
624 t 625).
601 Purgeable Nsloc«rbom
602 Purgeable Aromstic*
603 Arcrolein I AcrylonitriU
604 Ptisnols
60S Bsruldlnss
606 Phthslst* Estsrs
607 HitrosMinM
608 Orgsnochlorins Ptsticidss i PC8s
609 NitrosroMtics «nd Isophoron*
610 Polynucltsr Aroastic Hydrocarbons
611 Hslosthcrs
612 Chlorinstsd Hydrocarbons
613 2,3,7.8-T«trae*>lorodibtrao-p-dioxin
624 Purgsablcs GC/MS
62S Bas«/Nsutr»ls «nd Acids GC/NS
8000 SEMES or SW-84A; Tsst Ncttiods for Evaluating Solid Wasts, Physicsl/Chsvicsl Methods. To dttamin*
uhstlMr solid Masts is Hazardous Uastss as dafinsd by Issourcs Consarvstion ( Recovery
Act (RCXA).
8010 Halooanated Volatile Orgsnics
8020 AroMtic Volstile Organic*
8030 Aerolein, Aerylonitrile and Acetonitrile
8040 Phenols
8060 Phthslsts Eaters
8080 Orgsnochlorins Pssticidss I PCSs
8090 NitrosroBBtics and Itophorone
8120 Chlorinstsd Hydrocarbons
8140 Organocnospnorus Pesticides
8150 Chlorinstsd Herbicides
8240 GC/MS Method for Volatile Organic*
8250 Bsse/Nsutrsl extrsctablss by CC/MS
8310 Polynuclesr ArosBtic Hydrocarbons (PAH) by HP1C; (UV « 254 tm. Fl « ex: 280 rm, eai:380 n»)
POOR QUALlHi
ORIGIhslAL
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FOOTNOTES
nd - not determined
(*) - meter in parenthesis indicates the method used in the series
CLP/CRDL - Contract Laboratory Progran/ Contract Required Detection Limits (SOW 3/90)
a - Detection limits listed for toil/sediment are based on wet weight. The detection limits calculated by th«
laboratory for soil/sediment, calculated on dry weight basis, as required by the contract, will be higher.
b - The values in these tables are quant i tat ion limits, not absolute detection liaits. The amount of material
necessary to produce a detector response that can be identified and reliably quantified is greater than
that needed to simply be detected above the background noise. The quantitation liaits in these tables
are set at the concentrations in the sample equivalent to the concentration of the lowest calibration
standard analyzed for each analyte. Specific detection Haiti are highly matrix dependent. The detection
limits listed herein are provided for guidance and may not always be achievable. There is no
differentiation between the preparation of low and mediua soil samples in this method for the analysis for
Pesticides/Aroclors.
c - Lou Detection Liaits for Volatile HSL Compounds in soil/sediment. For compounds with a low detection limit
of 10 ug/Kg. the aediua detection limit is 1200 us/Kg.
d - Low Detection Liaits for Semi-Volatile HSL Compounds in soil/sediment. For compounds with a low detection
limit of 330 ug/Kg, the medium detection limit is 10000 ug/Kg. For compounds with a low detection limit
of 1700 ug/Kg, the mediua detection limit is 50000 ug/Kg.
e - Estimated Detection Limit; defined as either MDl (Appendix B to 40 CFR Part 136 - Definition and Procedure
for the Determination of the Method Detection Limit - Revision 1.11) or a level of compound in a sample
yielding peak in the final extract with signal-to-noise ratio of approximately 5, whichever value is
higher. The concentration level used in determining the EDL is not the same as the concentration level
presented in this table.
500 SERIES: Methods for the determination of Organic Compounds in finished Drinking Water and Raw Source
water
501.3 Measurement of Trihalone thanes in Drinking Water with Gas Chromatograph/Mass Spectrometry and
Selected Ion Monitoring
S02.1 Volatile Halogenated Organic Compounds in Water by Purge and Trap Gas Chromatograph, packed colum
502.2 Volatile Organic Compounds in Water by Purge and Trap Capillary Gas Chromatograph with
Photoionization (PIO) and Electrolytic Conductivity (HECD) Detectors in Series, capillary column
503.1 Volatile Aromatics and Unsaturated Organic Compounds in Water by Purge and Trap Gas Chromatograph
504 Measurement of 1,2-Oibroooethane (EDS) and 1.2-Oibromo-3-chlorapropane (OBCP) in Drinking Water
by Microextraction and GC
SOS Analysis of Organohalide Pesticides and Commercial Polychlorinated Biphenyl (PCS) Products in
Water by Microextraction and Gas Chromatography
S07 Determination of nitrogen- and Phosphorus-Containing Pesticides in Water by Gas Chromatography
with nitrogen-Phosphorus Detector
SOS Determination of Chlorinated Pesticides in Water by Gas Chromatography with an Electron Capture
Detector
508A Screening for Polychlorinated BIphenyls by Perchlorination and Gas- Chromatography
513 2.3.7,8-Tetrachlorodibenzo-p-Oioxin
S1S.1 Determination of Chlorinated Acids in Water by Gas Chromatography with an Electron Capture Detector
524.1 Volatile .Organic Compourds in Water by Purge and Trap Gas Chromatography/Mass Spectrometry, packed
column
524.2 Volatile Organic Compounds in Water by Purge and Trap Capillary Column Gas Chromatography/Mass
Spectrometry, capillary column - wide bore and narrow bore
S2S Determination of Organic Compounds in Drinking Water by Liquid-Solid Extraction and Capillary
Column Ga* Chromatography/Mass Spectrometry - magnetic, ion trap, and quadrupole
S31.1 nmijrimanr of H-Methylcarbamoyloximes and M-Methylcarbamates in Water by Direct Aqueous Injection
HPLC with Post Column Derivatization
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samples taken for determination of background concentration, the
detection limit for the method of analysis utilized with the
respect to that contaminant shall constitute the "background"
concentration of the contaminant. The appropriate detection
methods for chemicals of concern (as specified in Table 6) would
be the 600 Series and the detection limits that should be used
are specified in the "Region III, Method Detection Limit
Comparison of October 1990" and included as Table 24. Although
the operable unit is not necessarily intended to meet background
cleanup levels, EPA will seek to comply with these levels to the
maximum extent possible to make progress toward the final remedy.
If EPA determines that implementation of the selected remedy
demonstrates, in corroboration with hydrogeological and chemical
evidence, that it will be technically impractical to achieve and
maintain the remediation levels throughout the area of
attainment, the EPA, in consultation with the PADER, will amend
the ROD or issue an Explanation of Significant Differences to
inform.the public of alternative remediation levels.
The discharge levels for contaminants in the treated ground water
effluent will be determined by EPA in consultation with PADER as
part of remedial design in accordance with the substantive
requirements of Pennsylvania's NPDES program.
10. Statutory Determinations
The Superfund process requires that the alternatives chosen to
clean up a hazardous waste site meet several criteria. The
alternative must protect human health and the environment, be
cost-effective, and meet the requirements of all state and
federal laws and regulations. Permanent solutions to
contamination problems should be developed, whenever possible.
These solutions should reduce the volume, toxicity, or mobility
of the contaminants. Emphasis is also placed on treating the
wastes at the site, whenever this is possible, and on applying
innovative technologies to clean up the contaminants.
Protection of Human Health and the Environment
The selected interim remedy, alternative GW-4, will provide
adequate protection of human health and the environment through
the collection of contaminated ground water, its treatment and
release into the surface waters, and the collection of existing
free product through extraction wells. In addition, well
monitoring will be continuous to monitor progress. At the
present time, with contaminated ground water feeding Naylors Run,
an additional cancer risk of 1.0 x 10~4 exists to children
playing in Naylors Run, which is marginally unacceptable. It is
believed that this action alone will reduce this risk and when
combined with future planned remedial actions during operable
unit 3, will reduce the risk to a level between 10~4 and 10~6,
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which is in the acceptable range. The Hazard Index for this
scenario is already less than one and this action will further
reduce this risk. This action alone will also reduce any
carcinogenic and non-carcinogenic risks to individuals who are
consuming fish caught in Cobbs Creek. It also may remediate the
ground water contamination to a point where, in the future, it
may be used 'as a drinking source.
Implementation of the selected remedy will not pose unacceptable
short term risks or cross media impacts.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
This ROD and its associated remedial action is considered to be
an interim action. This action is not meant to achieve
groundwater cleanup ARARs, which will be evaluated in connection
with-the final remedy for the site. The remedy selected will
however, comply with ARARs directly associated with this limited
scope action. This interim action is in furtherance of, and not
inconsistent with, the planned final remedy which will finally
evaluate, among other things, the clean up of ground water. When
the final RQD for ground water is issued, ground water ARARs will
have to be met or waived. However, this ROD will identify the
ARARs, and all remedial actions taken will seek to comply with
ARARs to the maximum extent possible or to make progress toward
meeting all ARARs so that the final remedy can more easily and
fully comply with ARARs.
The known ARARs for chemicals of concern are as follows:
Air Emissions
The National Emissions Standards for Hazardous Air Pollutants set
forth in 40 C.F.R. §61.64(b) and promulgated under the Clean Air
Act, 42 U.S.C. Section 7401.
PA Air Pollution Control Act and Air Discharge Regulations, 25 PA
Code, Sections 123.1, 123.2, and 127.12(a)(5)
Waste Management
Standards Applicable to Generators of Hazardous Waste (40 C.F.R.
Part 262)
Standards Applicable to Transporters of Hazardous Waste (49
C.F.R. §171.1-171.16)
Regulations and Standards for owners and operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities (40 C.F.R. Part
264)
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Land Disposal Restrictions (LDR) Requirements (40 C.F.R. §268.1-
268.50)
Dioxin Containing Waste (50 Fed. Reg. 1978)
PA Hazardous Management Regulations (25 PA Code Subchapter D,
Sections 260.2 through 260.22, 261.1 through 261.34, 262.10
through 262.60, and 263.10 through 263.32 relating to the
identification and determination of hazardous waste, generator
and transporter rules and regulations.
Occupation Safety and Health Act (OSHA)
OSHA, 29 C.F.R. §1910.170
Surface Water
Clean Water Act, NPDES discharge regulations (40 C.F.R. §§122-
124)
PA Clean Streams Law (PA Code Title 25, Chapter 5)
PA NPDES Regulations (PA Code Title 25, Chapter 93.1 through 93.9
and 16, 92, 95, and 101)
Ground Water
PA Hazardous Waste Management Regulations (25 PA Code Section
264.90 through 264.100)
The Source Removal, Containment, Collection, Treatment, and
Disposal Alternative (GW-4) would provide extensive collection
and treatment of ground water through an underground collection
drain and through a 3 step treatment process. It is believed
that this alternative would be in compliance with the air
emission and OSHA ARARs. The air emissions standards would be
ARARs for any possible volatilization of contaminants during
monitoring or construction or any off-gas venting from the
treatment plant. The OSHA standards would be ARARs for work done
during construction.
Although the disposal of generated wastes may present problems in
meeting waste management ARARs, it is expected that all waste
management ARARS can be met for any wastes that were generated by
construction of the treatment plant, any soil excavation, or
residuals from the treatment process such as oils and carbon.
This waste could alter disposal plans, depending on the level of
dioxin in the wastes. If there are levels of dioxin less than 1
PPB, then the wastes could be disposed of at a RCRA Subtitle C
facility. If the dioxin levels in the soils exceed 1 PPB, then
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the wastes would not be considered K001 wastes (wastes from a
wood treatment site) . As a result, the waste would have to be
incinerated off site, if possible, or stored on site until
another disposal method was arranged. However, it is anticipated
that the proposed treatment plant process (AOP or PACT) will
destroy dioxins to below the 1 PPB level. Additionally, if a WAO
system is installed as part of the PACT system, on site
destruction of organic wastes, including dioxin, could be
provided. Installation of the WAO may be necessary in order to
meet this ARAR.
While this is an interim ROD for ground water, the air emissions,
waste management and OSHA standards are ARARs for this interim
action and will be met by this alternative. Surface water
standards are ARARs for the treated ground water, discharged into
Naylors Run, and such surface water ARARs would be met to the
maximum extent possible, as the treatment being utilized is the
best available technology. As noted above, ground water cleanup
level's are not intended to be finally addressed in this remedial
action, and, therefore, ground water cleanup levels are not ARARs
for this action. (To the extent that ground water cleanup levels
were to apply to this action, which EPA does not believe, such
ARARs would be waived on the basis that this interim action is
only a part of a total remedial action for the site that will
attain such ARARs when completed or such ARARs would be waived
under the other waiver criteria, pursuant to CERCLA Section 121
Cost-Effectiveness
The selected remedy affords overall effectiveness proportionate
to its costs. Additionally, there were no other alternatives
which provided the same degree of remediation which were more
cost effective.
Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
fMEPl
The selected remedy utilizes permanent solutions to the maximum
extent practicable. This interim action is not designed nor
expected to be final but the selected remedy represents the best
balance of tradeoffs among alternatives with respect to pertinent
criteria, given the limited scope of work. EPA expects to use
permanent treatment that will provide, when implemented,
immediate capture and treatment of the contaminants and will be
effective in the both the short and long term. This treatment
will reduce toxicity, mobility and volume of the contaminants and
is implementable. Although the solution may be temporarily
disruptive to the community during construction, it will achieve
the permanent capture and treatment of contaminants in the
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shallow ground water aquifer, which have been a concern to the
community for over 30 years. Both the Commonwealth of
Pennsylvania and the Havertown Community at large have been
supportive of the selected remedy.
Preference fo'f"'Treatment as a Principal Element
The principal threat addressed by this ROD is the ground water
contamination, which originated at the NWP facility, and has
slowly migrated to the southeast in the shallow aquifer and also
lays directly under the NWP facility. Very significant
concentrations of PCP and other chemicals of concern remain in
the ground water. Natural flushing and attenuation of the
contamination has been ineffective in removing the contaminants
to low residual levels. As such, the installation of a treatment
plant with an associated collection drain is the principal
element of this remedy needed to remediate the principal threat.
Additional discussion of the preference for treatment will be
addressed in the final decision document for the site.
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